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Home My WebLink AboutFEIR_SJHTC_VOLUME_3FHWA-CA-EIS-90-D SCH. NO. 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/ENVIRONMENTAL IMPACT STATEMENT AND SECTION 4(F) EVALUATION VOLUME III -RESPONSES TO COMMENTS SUBMITTED PURSUANT TO: Is (State) Division 13, Public Resources Code (FederaL) 42 U.S.C. 4332 (2) (C), and 49 U.S.C. 303 BY THE U.S. Department of Transportation Federal Highway Administration AND San Joaquin Hills Transportation Corridor Agency Orange County, California COOPERATING AGENCIES: California Department of Transportation California Transportation Commission U.S. Any Cones of Engineers California Department of Fish and Game U.S. Department of the Interior,.Fish and Wildlife Service The fotlowing persons may be contacted for additionaL information concerning this document: Judith L. Heyer James J. Bednar Steve Letterty Department of Transportation Federal Highway Administration San Joaquin Hills 2501 Pullman Street California Division Transportation Corridor Agency Santa Ana, CA 92705 P. 0. Box 1915 345 Clinton Street (714) 724-2252 Sacramento, CA 95812-1915 Costa Mesa, CA 92626 (916) 551-1310 (714) 557-3298 x297 to • FHA-CA-EIS-90-D SCH. NO. 9001 0230 12-ORA-73 P.N. 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/ENVIRONMENTAL IMPACT STATEMENT AND SECTION 4(F) EVALUATION VOLUME III -RESPONSES TO COMMENTS SUBMITTED, PURSUANT TO: (State) Division 13, Public Resources Code (Federal) 42 U.S.C. 4332 (2) BY THE U.S. Department of Transportation Federal Highway Administration AND San Joaquin Hitls Transportation Corridor Agency Orange County, California COOPERATING AGENCIES: (C), and 49 U.S.C. 303 California Department of Transportation California Transportation Commission U.S. Army Corps of Engineers California Department of Fish and Game U.S. Department of the Interior, Fish and Wildlife Service The following persons may be contacted for additional information concerning this document: Judith L. Heyer James J. Sednar Steve Letterly Department of Transportation Federal Highway Administration San Joaquin Hills 2501 Pultman Street Catifornia Division Transportation Corridor Agency Santa Ana, CA 92705 P. 0. Box 1915 345 Clinton Street (714) 724-2252 Sacramento, CA 95812-1915 Costa Mesa, CA 92626 (916) 551-1310 (714) 557-3298 x297 LJ INTRODUCTION Attached for review are the responses to comments received on the DEIR/DEIS for the San Joaquin Hills Transportation Corridor. As a result of the public review process, approximately 2,400 comments were received from approximately 251 commentators on the DEIR/EIS. These comments are contained in Volume II. Due to the volume of comments received on the document, a system was developed to assist the reader in finding the response to a particular comment. This document consists of two parts: Part I.is a listing of comments and Part II is the actual responses. The discussion below provides the reader guidance on how to utilize each of these parts during review of this document. Part I consists of a matrix of all comments received on the •DEIR/EIS submitted for public review. The first column identifies the comment number. Please refer to Volume II for a listing of all commentators and their corre- sponding comment number. The second column identifies the name of the commen- tator. Finally, the third column identifies the subject of the comment through the use of a coding system. Each comment received was given a code which identified the subject of the comment. A listing of all subject codes is provided for reference on the following page. This coding is then, used to identify in which chapter.of Part II the response to this comment is located. Part II consists of the responses to comments, and is organized by sub- ject. The subjects listed generally follow the same subjects identified in the Table of Contents of the EIR/EIS. The reader can utilize this chapter in one of two ways: 1) to review the responses to comments by chapter or 2) to choose a comment number on the matrix and refer to the chapter identified under the subject code. It should be noted that, where appropriate, comments which identified similar issues were consolidated and one response generated. Thus, if the reader reviews a chapter and does not find the comment number they are looking for in numerical order, then the comment was responded to under a consolidation of responses and the reader will need to review those responses in that chapter. • U LIST OF SUBJECT CODES SUBJECT CODE SUBJECT AL Alternatives AQ Air Quality B Biological Resources C/N CEQA/NEPA Issues CO Construction Impacts C Cost CP Cultural/Paleontological CU Cumulative Impacts F Fiscal Impacts F/T Funding/Tolls G Geotechnical GI Growth Inducement HW Hazardous Waste/Materials HB Housing/Business Relocation • L MM Land Use Mitigation Monitoring N Noise NEI Not EIR/EIS Issue NR No Response Necessary 0 Objectives OP Opinion PR Park and Ride PEB Pedestrian/Equestrian/Bicycle Facilities PD Project Description PH Phasing PS Public Services & Utilities PN Purpose and Need RD Request for Data T Traffic and Circulation TR Transit V Visual Resources WR Water Resources 4F Section 4(f) • • PART I MATRIX OF COMMENTS RECEIVED ON TCA DEIR/EIS FOR THE SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR • 01/31/91(TCA901B%INDEX-A) • • • N P-- W P" W C C� H S 7 N LL LL LL- LL- LL. 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M M a) OJ (1) .O -C .0 m -G .0 -a m eC tLf S -C .0 Q) cmE E E E U U U U C C C U U U O O O O O O O O •r •r •r •r O O O •r •r •r LO tD 1� e•-1 N M Mr LL') rr N M s!' r1 N M N M r� 1.� r� 00 00 00 00 00 C) CI) c 1 CA O O O rr .—r r♦ N N cV cV N N N N N N N N co tM CV) cn cn M t 1 1 00 00 06 00 00 00 00 00 00 00 00 o0 00 00 00 00 00 00 LO X F co a y w ac m 0 a U H P M W G O C.� H C.� W 7 Cn N LLJ CD, Z Q a v 0 0 � N N V! N N V1 Vf •p 'p •� C OJ OJ W fn N V1 N N O O O O U U U 0) d 0) '� -� �--� �+ r-w U U U U S. S_ S. t0 c0 cO C C O O C •t Y -,ad Y -he S. S_ S. � S- (2) 0) tSf Rf 4- 0) '-+ .� N M trT --� N M d• �-+ M —4 N M N M M M M M et et e1• to LO t, to tp M M M M M M M M M M M � en cn M fM 00 00 O 00 00 00 00 00 00 00 00 N 00 06 00 00 LO M i 00 X f co a U) w ix m 0 P P M O 0 01/31/91(TCA9018%INDEX-A) PART II RESPONSE TO COMMENTS TABLE OF CONTENTS PAGE Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . AL-1 Air Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . AQ-1 Biological Resources . . . . . . . . . . . . . . . . . . . . . . . . .B-1 CEQA/NEPA Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . C/N-1 Construction Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . CO-1 Cost. . . . . . . . . . . . . . . . . . . . . . . C-1 Cultural/Pal eontol ogi cal . . . . . . . . . . . . . . . . . . . . . . . . CP-1 Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . CU-1 Fiscal Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . F-1 Funding/Tolls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . F/T-1 Geotechnical . . . . . . . . . . . . . . . . . . . . . . . . . . . . . G-1 Growth Inducement GI-1 Hazardous Waste/Materials HW-1 Hou.si ng/Business Relocation . . . . . . . . . . . . . . . . . . . . . . . HB-1 LandUse .. . . . . . . . . . . . . . . . . . . . . . . . . . . .L-1 Mitigation Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . MM-1 Noise . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . N-1 Not EIR/EIS Issue . . . . . . . . . . . . . . . . . . . .. . . . . . . . NEI-1 No Response Necessary . . . . . . . . . . . . . . . . . . . . . . . . . . NR-1 Objectives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .0-1 Opinion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . OP-1 Park and Ride . . PR-1 Pedestrian/Equestrian/Bicycle Facilities PEB-1 Phasing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PH-1 Project Description . . . . . . . . . . . . . . . . . . . . . . . . PD-1 Public Services & Utilities . . . . . . . . . . . . . . . . . . . . . . . PS-1 Purpose and Need . . . . . . . . . . . . . . . . . . . . . . . . . . . . PN-1 Request for Data . . . . . . . . . . . . . . . . . . . . . . . . . RD-1 Traffic and Circulation . . . . . . . . . . . . . . . . . . . . . . . . . T-1 Transit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . TR-1 Visual Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-1 WaterResources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . WR-1 Section 4(f) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4F-1 0 01/31/91(TCA9018%INDEX-A) i • ALTERNATIVES 1-2-4. 1-2-17 Both of these comments are overview statements of other, more detailed EPA comments. For this reason, they are not further addressed here, but are ad- dressed in Responses of Comments 1-2-18, 1-2-19, 1-2-21, 1-2-22, 1-2-23, 1-2-24 and 1-2-25 in this Chapter. 1-2-18 The findings in the document regarding the infeasibity of alternative land use concepts is based on earlier environmental analysis which was reevaluated in the course of preparing the EIR/EIS. The conclusions of the SEOCCS study are still considered valid. Further, because a large percentage of the Area. of Benefit is committed to the designated land uses, there are very significant legal and practical constraints to a fundamental restructuring of land uses as suggested by the comment. As discussed in the growth inducing analysis, the area of the project is projected, by the County, to be in jobs/housing balance in 2010. Nevertheless, there is still a demonstrated need for the facility. Additionally, a recent report prepared by the County CAO's office in conjunc- tion with the AMR/DMP report shows how the high ratio of workers per household in Orange County will, consistent with the jobs/housing balance methodology provisions of the SCAG GMP, attain the jobs/housing ratio target defined by SCAG in the 1989 South Coast AQMP. With regard to considering the alternative of "increased densification for improved transit service," this suggestion is another variation on using the federal transportation process to dictate local government land use decision making. Under California law, local governments are vested with the authority to make land use decisions. The "increased densification" alternative would not accomplish the objectives of the project, even with very fundamental and infeasible changes in the local General Plans. As stated in their comment letter, in its consideration of the FIP, EPA acknowledged the relative roles of local governments and the air quality agencies and there is no basis for as- serting that transportation planning may be used as the vehicle for changing the roles of local governments and transportation agencies. The EIR/EIS in- cludes an analysis of a reasonable range of alternatives as required by CEQA and NEPA. f01/31/91(TCA9018%INDEX-A) AL - 1 1-2-19. 1-2-20, 3-7-13 EPA asserts that "down zoning" of lands to be served by the Corridor should be considered as a feasible alternative as a means of reducing transportation demand and, concomitantly, the need for the Corridor. EPA's opinion is noted. The EPA comment ignores the fact that the General Plans in south Orange County have guided and directed land use and circulation decisions for the last de- cade. It would be inconsistent with the essential purpose of the planning and zoning laws to fundamentally alter the Circulation Element of the General Plans given that long-term land uses have been established on the basis of the Circu- lation Element. For example, "downzoning" of much of the area of benefit of the Corridor is not feasible because commitments to the present zoning scheme have been made in reliance on that scheme and the policies of the general plans. Similarly, increased densification along the Corridor is not feasible because much of the land has been dedicated or committed to open space purposes. Both institutional constraints and potential economic impacts of regional downzoning are mentioned on page 2-30. The findings of the SEOCCS study have been only briefly referenced in the EIR/EIS because there is no need to repeat in detail information from SEOCCS and previous Corridor environmental documents (EIR Nos. 267 and 494), although the key information from those earlier studies is discussed. The County's adoption of SEOCCS and the Corridor reflected a decision on a mid -range population figure for the south County and a balance of land use and transportation facilities. Regional downzoning is not a probable scenario; it would be speculative to assess the impacts of such a scenario. However, it should be noted that in the unlikely event of wide scale downzoning, traffic would not necessarily decrease on all facilities. Over half of the Area of Benefit is existing land uses. Lower density development that might be inherent in a downzoning alternative would make trip reduction methods and transit less feasible; likewise, air quality impacts might be greater than other scenarios because of an imbalance of jobs/housing. EPA's comment ignores the respective roles and functions of local governments in land use planning and transportation agencies in facility planning. California law requires a correlation of land use and circulation required to serve allowable land use. Thus, by law the General Plans would not be funda- mentally altered as suggested by the comment because the result would be sig- nificant imbalance in the Land Use and Circulation Elements. As is reviewed at length in the Corridor DEIS, a major comprehensive re -assessment of land use 01/31/91(TCA9018%INDEX-A) AL-2 and circulation needs was undertaken by Orange County through the SEOCCS pro- cess in the mid -seventies. Consistent with the general plan process, the County identified circulation needs required to provide transportation capacity for the levels of development provided for the General Plan. One major facili- ty required to serve these defined land uses was the SJHTC. It is entirely appropriate for environmental documents to consider such regional planning documents in evaluating the feasibility of project alternatives. The courts have reviewed the transportation/land use relationship and have consistently differentiated the two functions, and indicated that it is appro- priate for transportation agencies to consider local land use decisions in the identification of whether.project alternatives are feasible. The courts have also indicated that the NEPA process may not be used to assert federal agency control over local government land use decision making. In addition, the comment would potentially require the evaluation of hundreds of different options and sub -alternatives. The EPA position in this regard is contrary to the leading decision of the United States Supreme Court concerning the evaluation of alternatives in NEPA documents. The Supreme Court stated: "Common sense... teaches us that the `detailed statement of alter- natives' cannot be found wanting simply because the agency failed to include every alternative device and thought conceivable by the mind of man. Time and resources are simply too limited to hold that an impact statement fails because the agency failed to ferret out every possible- alternative..." (Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc., 435 U.S. 519, 551 (1978).) 1-2-21 The costs of the Corridor are acknowledged in the Draft EIR/EIS. Page 2-29 is Table 2.6.A, which shows project costs. It is acknowledged that a land use alternative should not be dismissed simply because it may involve financial costs. Instead, alternatives in the Draft EIR/EIS have been determined to be infeasible based on a variety of tests primarily relating to feasibility, implementability, and ability to meet project objectives. 1-2-22 The comment states that other alternatives such as rail, might address the through traffic. As discussed in Response to Comment 1-2-24 in this Chapter, • 01/31/91(TCA9018%INDEX-A) AL-3 0 the Corridor is an integral component of a broad based regional transporta- tion/air quality planning effort that integrates several transportation modes. Transportation studies conducted over the last decade have concluded that rail in and of itself will not meet the transportation demand. The 20 percent through traffic is not a substantial portion of the traffic growth. The comment appears to imply that if through traffic were accommodated in some other way, the Corridor as planned would not be needed. Through traffic is not the basis for the Corridor. 1-2-23 A substantial TSM plan, incorporating some of the features in the comment, is incorporated as a project mitigation measure (see page 5-19, Measure T/C-5 in the Draft EIR/EIS). Other TSM measures are proposed and incorporated into all long-range planning efforts by the County and SCAG. However, none of the TSM measures provide sufficient capacity by themselves, and the Corridor is still needed. The traffic modeling utilized for the project (OCTAM) assumes optimum signal timing and no incidents. TSM measures are implemented to manage and optimize the circulation system; they do not provide the basic system capacity. Because the traffic model does not include a penalty for problems such as uncoordinated signals, an optimum TSM scenario is already included in the traffic -modeling. In conclusion, the TSM measures referenced in the comment are assumed in place from a modeling standpoint and will also be an integral part of Corridor opera- tions. TSM measures do not eliminate the need for the Corridor. 1-2-24, 1-2-26 In addition to the "land use alternatives," the EPA comment letter discusses "transportation system management" alternatives, "mass transit alternatives," and "alternatives to widen other routes" both individually and collectively. EPA asserts that a revised document should include: ..optimal combinations of land use, TSM, transit, limited widenings of other facilities and other demand management (TDM) strategies. While each option individually may not meet project objectives, a combination of the strategies might". 01/31/91(TCA9018%INDEX-A) AL-4 The EPA comment acknowledges that the DEIR/EIS analyzed mass transit as an alternative to the project, but then suggests that a different mass transit alternative be analyzed, even though no relevant local or regional transporta- tion study indicates that the EPA alternative would be feasible or accomplish the objects of the project. The relevant regional planning documents establish that the alternatives proposed by EPA are not feasible. The EPA comment ignores the comprehensive regional transportation planning context within which the role of the Corridor has been defined. Each of the programmatic elements suggested by EPA in fact has been articulated as part of the comprehensive regional transportation plan embodied in the Regional Mobili- ty Plan (RMP) of 1989. The following discussion will identify the key features of the RMP as they apply to the specific functions of the Corridor. The purpose of the RMP has been stated as follows: The Regional Mobility Plan serves as the Federal and State required Regional Transportation Plan. It has a 20-year planning horizon and is intended to establish the policies and actions to address the region's mobility issues. It is presented as one element of a broader Regional Strategic Plan and has been developed in coordina- tion with the Regional Growth Management and Regional Air Quality Plan(s). This plan serves as the basis for programming in the Transportation Improvement Program for this region. The RMP was prepared in response to growth projections for significant regional population increases that will occur largely from forces and trends independent of the provision of facilities for population increases. The Growth Management Plan adopted by SCAG in February, 1989, drew the following conclusions regard- ing long-term population growth: The SCAG Draft Baseline Projection. . . projects the 2010 popula- tion of the region at 18.3 million [compared with an estimated January, 1988, population of 13.7 million]. . . (p. I-2). Most of the increase in population will be generated internally rather than through migration to the region (p. I-2). The vigorous projected growth in population is due to an excess of births over deaths (natural increase) and to more people entering than leaving the region (net in -migration). Overall, natural increase represents 63q of the region's population growth over the 30-year period be- tween 1980 and 2010. . . Between 1980 and 2010, approximately 9.0 million people are projected to leave the region while 8.1 million are projected to enter from other parts of the United States and 01 /31 /91 MA90W I NDEX-A) AL-5 • 3.3 million are projected to come to this region from other coun- tries (p. II-3, emphasis added). Thus, contrary to EPA's implicit assertion that population increases are fos- tered by transportation system improvements, the growth in the South Coast region's population is generated almost entirely by natural birth rates of the existing population and foreign migration, neither of which is particularly amenable to land use regulation or other growth control measures. The RMP does not assume that the transportation system can be manipulated to reduce regional transportation needs but instead assumes that the population growth pressures are real and must be addressed in a manner that incorporates both regional air quality and mobility goals: The goal of the Regional Mobility Plan is to recapture and retain the transportation mobility levels of 1984, and the Plan provides specific means to address the goal. By 2010, daily person trips and work commutes on the region's streets and freeways will in- • crease by 42 percent. If nothing is done to improve the transpor- tation system, by 2010 these additional trips may bring traffic to a near halt on much of the system for much of the day (RMP at p. I- 1). The RMP was prepared as a comprehensive regional transportation plan, incorpo- rating aggressive Transportation Demand Management, Transportation System, and Transit Development Programs as well as a comprehensive system of HOV and mixed -flow improvements in exactly the manner outlined in the EPA letter under EPA's "Combination of Alternatives" approach (see p. 8 of the EPA letter, Comment 1-2-26). For example, the RMP programs are projected to reduce daily work trips by over 4.5 million trips through the use of TDM measures regional- ly, by 1.4 million trips through increased transit and to reduce daily conges- tion by 800,000 hours through Transportation System Management Programs (see p. I-7, attached). The transit program alone was estimated to require $18 billion in capital funds. Due to the comprehensive RMP program for reducing trips, "the growth manage- ment, demand management and transit development components [of the RMP] contribute greatly to reducing the total level of mobility needs that must be addressed through mixed -flow and HOV lane improvements. As a result, the Plan includes only 1,840 lane miles of mixed -flow improvements for freeways and conventional highways and 1,285 lane miles of HOV improvements, as opposed to the 5,300 lane miles of mixed -flow and 2,290 lane miles of HOV improvements which would have otherwise been required (RMP at pp. A-1 to A-2). • 01/31/91(TCA9018+INDEX-A) AL-6 • The RMP goes on to define the transportation program for mixed -flow and HOV lane improvements as follows: Due to the very heavy focus of the Plan on strategies of growth management, demand management and transit development in providing for mobility needs, the freeway element presents an improvement program which is quite modest relative to overall needs. The major portion of mobility needs is to be addressed by other means. As a consequence of this strategic focus, not only is the overall free- way element quite modest, but the element itself contains a large number of new corridors and freeway "gap closures" relative to widenings of existing facilities. The emphasis is more on connec- tivity and completion particularly in the less developed areas, than on straight capacity expansion. In the more developed areas, freeway improvement is supplanted by the very heavy transit empha- sis. Two of the new or improved corridors, the I-15 Norco Reach and the I-105 Century have been under construction for a number of years. All the others are at various stages of the environmental process with some like the Route 710 gap and the San Joaquin Hills Corridor already at or near final completion. Consistent with the overall strategic focus of the Plan, all the new freeway corridors except the I-15 Norco Reach are also designated for HOV development. (RMP at p. V-17, emphasis added). Within this overall strategic context, the Corridor is identified in Figures V- 4 and V-5 as a combined mixed -flow and HOV facility and as a "Long Range Corri- dor" on Figure V-16 of the RMP. Additionally, the RMP states as "actions necessary to implement the financial program:. . . Support the implementation of select toll facilities in Orange County" (RMP at p. VI-12). Thus, the RMP more than anticipates EPA's call for a "Combination of Alternatives" approach. Mixed-flow/HOV facilities designated in the RMP represent the bare minimum level of facility improvements addressing air quality/mobility needs in the context of trip reductions and VMT reductions (numbering several million trips eliminated per day) resulting from extremely aggressive transit, TDM and TSM programs to be implemented at the regional level. Given the scope of their authority and planning framework, the Trans- portation Corridor Agency or FHWA cannot be assumed through a NEPA EIS process to achieve TDM, TSM and transit trip reductions in excess of those already planned for in the RMP through a far more comprehensive regional transportation 01/31/91(TCA901B%INDEX-A) AL-7 i and air quality planning process. (Moreover, State and federal law vest TCM planning and implementation authority with air quality districts and MPOs). Likewise, because the RMP already represents the product of a regional planning process defining the level of facility expansion appropriate to regional air quality/mobility objectives, the Corridor EIS is an inappropriate vehicle for re-examining the RMP's assumptions as to which highways should be widened as an alternative to constructing the Corridor (other comprehensive transportation alternatives studies, such as the Santa Ana Transportation Corridor Transit Element Alternatives Analysis provided significant input into the RMP's ulti- mate conclusions regarding which existing facilities should be expanded and in what ways). Similarly, the RMP represents an assessment of which types of transit systems should be constructed from a regional effectiveness perspective and has con- cluded that HOV systems are the most appropriate transit use designation for the Corridor. As the RMP notes, the use of HOV lanes directly supports (and in many circumstances is necessary to -the success of) TDM programs: High Occupancy Vehicle (HOV) lanes have been implemented to provide additional incentives to increased ridesharing and transit usage. The provision of a separate lane for the exclusive use of carpools, vanpools, or transit vehicles provides valuable time savings in contrast to the travel times of single occupant vehicles in con- gested general use lanes. The time savings thus afforded has been widely recognized as a powerful incentive in the promotion of ridesharing and the reduction of vehicle trips and vehicle miles of travel. In the context of the Plan, HOV lanes can be seen not simply as the inducement to increased ridesharing but as accommo- dating the increased carpool and bus transit demand that will fol- low from the measures contained in the Transportation Demand Man- agement Element. (RMP, at p. V-21, emphasis added; see also pp. 2- 32 to 2-33 of the SJHTC DEIS). The SJHTC DEIS , at pp. 3-14 and 3-16 to 3-17, contains a detailed analysis of how the use of toll road funding provides the financing the construction of HOV facilities well in advance of when such facilities could be constructed under conventional highway financing and the manner in which the HOV functions of the Corridor complement and carry out RMP and AQMP programs for mobility and air quality objectives. It should also be noted that Transportation Demand Management Programs are not implemented in a vacuum. The FEIR for the Irvine Center Development Agreement 01/31/91(TCA9018%INDEX-A) AL-8 (1981) contains an extensive analysis of the factors affecting ridesharing and transit use and concluded that "concentrated employment centers" are the prima- ry determinant and often the necessary pre -condition for the success of such programs. The Corridor will provide a functional HOV linkage between residential areas and at least four major concentrated employment centers: The University of California at Irvine, IBC, Irvine Spectrum, and the Aliso Viejo employment center (see SJHTC DEIS, at pp. 3-18 to 3-22). At a broader regional level, the Corridor, when combined with the regional HOV system depicted in Figure I-5 of the RMP will further encourage the use of ridesharing systems as the system becomes more amenable to fulfilling individual needs. And it must be kept in mind that, due to relative funding (compare Figure I-5 of the RMP with Figure I-7) and lead time requirements, the HOV system will shoulder the greatest responsibility for reducing single occupant vehicle trips during the timeframe of the RMP and the air quality attainment timeframe established by the federal Clean Air Act Amendments of 1990. In conclusion, the Corridor is an integral component of a broadly based and responsible regional transportation/air quality planning effort that integrates TDM, TSM, fixed rail transit, bus systems, and all forms of ridesharing with mobility oriented and ridesharing supportive mixed-flow/HOV systems of a very modest scale (in terms of regional demand) and which together represent the South Coast region's best planning program for reducing mobile source emissions by eliminating trips, reducing VMT and reducing congestion. 1-2-25 The comment is correct in stating that additional lanes are needed on I-5 and I-405 with or without the Corridor. The widening of these facilities will not achieve the objectives of the project. As discussed in the EIR/EIS, there are very significant engineering and traffic management limitations for these facilities beyond what is currently planned. The level of service assumption is indicated in Table 2.8.A by footnote 1, which shows 20,000 ADT per lane, representing LOS E. 2-4-1. 2-4-2. 2-4-3. 2-4-4a-g. 2-4-5. 2-4-6. 2-4-7. 2-4-8 The traffic demand for the San Joaquin Hills Transportation Corridor has great- ly exceeded the capacity of a four lane facility for a number of years. In 1964, San Joaquin Hills Road was shown on the Master Plan of Arterial Highways (MPAH) as a Secondary Arterial (total four lanes carrying capacity 8-20,000 trips/day). This arterial served .the same demand line as the SJHTC, and the evolution of the arterial is an indicator of the fact that traffic demand along the Corridor route exceeds four lane facility capacity. By 1967, San Joaquin 01/31/91(TCA9018%INDEX-A) -AL-9 0 Hills Road had been upgraded to a six lane facility (Primary Arterial Highway) in order to accommodate projected demand on the order of 20-30,000 trips/day. The Southeast Orange County Circulation Study (SEOCCS), which sought to balance of traffic circulation capacity and land use. The SEOCCS projections along the Corridor route showed demand ranging from 85,000 trips/day to 130,000 trips/day. This greatly exceeds the carrying capacity of a four lane facility, which might reach 40,000 trips/day under the most ideal conditions. One of the primary goals of the Corridor is to relieve congestion on parallel facilities. The four lane facility suggested in the comments would not offer congestion relief and would operate at Level of Service F in both a toll phase and ultimately in a toll free phase. While it is true that a narrower Corridor would have less significant direct impacts, the ability to reduce the width of the Corridor, while meeting project goals of reducing congestion on the regio- nal transportation system, is met by the Demand Management alternative. TCA engineers analyzed an initial six lane facility with future HOV lanes and found that it represented the smallest Corridor which could handle traffic; given this capacity analysis result, it would be unreasonable to study an even small- er facility. The Demand Management alternative provides an opportunity to support the most efficient size Corridor while preserving the, median for other travel modes, such as reversible lanes, HOV, and light rail. The toll system can be used to manage traffic by raising prices to ease congestion on the facility, but not to the level of a four -lane facility. Comment 2-4-4g states that the summary of archaeological findings does not emphasize the historical value of the sites that will be lost. The historical value of the sites is analyzed as required under Section 106. Such information is summarized in the EIR/EIS on pages 3-57, 4-110 and Appendix D, based on the most recent Phase II archaeological testing and Determination of Eligibility (Chambers Group, Inc., 1990). 2-9-4 The EIR/EIS acknowledges that significant impacts to wildlife and wildlife habitats will occur as the result of the construction of the Corridor and provides feasible design and mitigation measures to limit the impacts. The No Project Alternative primarily attempts to describe conditions in the absence of the proposed Corridor and the other improvements that would be needed to pro- vide roadway capacity. Alternative methods of addressing transportation de- mand, including the possibility of changes in land use planning, and increased 01/31/91(TCA9018%INDEX-A) AL-10 implementation of Transportation Systems Management Measures, are discussed in the EIR/EIS in Section 2.8. 3-4-40, 4-18-5. 4-18-11, 4-33-5 TCA DEIR/EIS No. 1 is a tiered environmental document which represents the conclusion of an extensive Corridor planning effort. Section 2.8, beginning on page 2-28, discusses in detail alternatives which were evaluated in earlier environmental documents. These alternatives were considered by the County of Orange prior to selecting the concept alignment and project alternatives brought forth in this DEIR/EIS. These alternatives included: a. Reduced Route Location Study b. Expanded Route Location Study C. Alternative Land Use Concepts d. Transportation System Management e. Mass Transit f. Widening of SR-1 g. Widening of I-405/I-5 h. Downgrading the Corridor to a surface arterial i. Connecting the Corridor to I-405 via Oso Parkway In general, due to the spatial distribution -of land uses and land use densi- ties, coupled with the lack of a traditional central business district destina- tion point, non -automobile alternatives were unable to meet the project objec- tives. The widening of parallel facilities (I-405/I-5 and SR-1) has alterna- tive environmental implications which are greater or less than the proposed project depending on the topic. The downsizing of the Corridor to an arterial would not meet the project need and would require the widening of parallel facilities which carry their own set of environmental impacts. Also, please see Responses to Comments 3-5-37 and 4-32-1 in this Chapter. 3-5-7. 4-21-6. 4-21-23, 4-21-27, 4-31-19, 4-31-20, 4-33-11, 7-13-5. 7-123-5. 8-17-1 The Corridor is part of, and consistent with, the Regional Mobility Plan (RMP) prepared by SCAG. The RMP is the most current regional transportation planning effort in the Southern California area and incorporates, to the greatest extent feasible, travel modes which reduce "auto dependence." Notwithstanding the RMP's focus on alternative travel modes, the RMP calls for the development of a limited number of new highway facilities, including the Corridor. Moreover, it should be noted that, in the event that travel demand patterns change in the future, the Corridor offers an ideal means to evolve into more efficient modes 01/31/91(TCA9018%INDEX-A) A L - 1 1 C of travel. For example, if the Demand Management Alternative is selected as the configuration for the width of the Corridor, HOV lanes and reversible lanes will be developed as demand requires. Additionally, the 88 foot center median can accommodate a future light rail project. However, in order for there to be more permanent mode changes for regional travel, significant changes will have to occur in the land use densities, land use patterns, and attitudes toward transit. The regional transportation system called for in the RMP is designed to recap- ture 1984 mobility levels. Therefore, the alternative of using increased congestion to reduce trips is inconsistent with the RMP. Furthermore, in- creased congestion results in both substantial economic costs of added travel time and increased air pollution. 3-5-37, 3-5-38, 3-5-50, 4-19-15, 4-22-14, 4-22-15, 4-28-1. 4-33-10, 4-33-12, 7-82-6. 7-82-7. 7-84-43, 8-1-2. 8-7-4, 8-13-4. 8-19-5. 8-19-10 In addition to the No Build Alternative and the two primary Build Alternatives (the Conventional Operations Alternative and the Demand Management Alterna- tive), the Draft EIR/EIS addresses a full range of alignment and nonalignment alternatives. Since TCA Draft EIR/EIS 1 is part of a tiered process of envi- ronmental review, authorized by both CEQA and NEPA, it is appropriate to refer to analysis of alternatives contained in previous environmental documents. However, the Draft EIR/EIS does not rely exclusively on incorporation by reference, and discusses alternatives to the project in Section 2.8. The Draft EIR/EIS discusses mass transit alternatives in Section 2.8e, at page 2-32, concluding that while a transit -only alternative is infeasible, future imple- mentation of light rail is not precluded by the design of the Corridor, which includes a sufficiently large median envelope to accommodate future light rail transit. Further, the mass transit alternative determined to be more feasible for implementation as part of the Corridor, high -occupancy vehicle lanes, has been included in the proposed project, and is consistent with the comprehensive Regional Mobility Plan included in the South Coast Air Basin Air Quality Management Plan. The alternatives discussion also addresses methods for reduc- ing the need for the Corridor through alternative land uses, transportation system management techniques, and the expansion of other regional roadways including State Route 1, Interstate 405 and Interstate 5. Additionally, as part of the tiered environmental review process, a wide range of alignment alternatives for the Corridor was addressed in EIR No. 267, which is incorpo- rated by reference in the Draft EIR/EIS. Based upon the analysis of 28 align- ment alternatives for the Corridor in EIR No. 267, the County of Orange adopted the present general alignment for the Corridor as the environmentally superior 01/31/91(TCA9018%INDEX-A) A L- 1 2 alignment alternative. A Summary of the EIR No. 267 alignment analysis is in- cluded in the Draft EIR/EIS, beginning at page 2-42. The Draft EIR/EIS includes site specific alignment alternatives developed to minimize or avoid potentially significant environmental effects at Crystal Cove State Park and Bonita Canyon Reservoir. Alternatives for the location of interchanges and the mainline toll plaza are addressed between pages 2-49 and 2-51 of the Draft EIR/EIS. Finally, Section 4.7 and Appendix A of the Draft EIR/EIS discussed potential alterna- tives to avoid impacts to specific wetland and park, open space; and historic sites. 3-5-42, 3-5-43, 4-21-24 As discussed in Section 2.8 of the EIR/EIS, regional downzoning is not consid- ered a feasible alternative to the Corridor project. The extensive changes in existing and planned land uses necessary to remove the demand for the Corridor are too speculative to form a feasible alternative. (See also Response to Comment 1-2-19 in this Chapter.) • The TCA has no power to adopt or enforce a growth moratorium. That is an action that would need to be taken by the appropriate cities and the County. The effects of cumulative development on traffic and air quality are evaluated through the following methods: 1) County and city General Plans, 2) SCAG Regional Mobility Plan incorporating such items as jobs/housing balance poli- cies, 3) Air Quality Management Plan, 4) Congestion Management legislation which also requires Growth Management Plans, and 5) cumulative impact analysis requirements of CEQA and NEPA. Comment 3-5-43 refers to balance within as the regional planning authority has jobs/housing balance goals are to be met lish a subregion different from SCAG's. 3-5-44 a smaller subregion. SCAG, empowered established the regions within which . The TCA has no authority to estab- See Response to Comments 3-5-46 and 4-21-20 in this Chapter. 3-5-45 Light rail is not precluded due to steep terrain. Design features, as de- scribed on pages 2-16 and 2-33 of the EIR/EIS, are incorporated into the pro- ject to allow for future rail transit. • 01/31/91(TCA9018%INDEX-A) AL - 1 3 • Alternatives relative to the use of mass transit have been considered as part of the comprehensive planning effort associated with this project; please see Section 2.8, Alternatives Withdrawn from Consideration, which begins on page 2- 28 of the DEIR/EIS. The propositions providing for transit funding allocated those funds to specific projects. A majority of the Measure M monies are allocated for MPAH improvements, which are included in the traffic modeling for the Corridor. Some Measure M monies will be available for City improvements. 3-5-46 See Response to Comment 3-5-48 under Traffic. 3-5-49 The EIR/EIS analyzes a reasonable range of alternatives (see Response to Com- ment 3-5-37 in this Chapter). Also, please refer to Responses to Comments 3-5-47 and 3-5-48 under Traffic. • 3-7-14 The following information is provided about the general theory and practice of Transportation System Management (TSM). "Transportation System Management (TSM) is an approach to solving transportation problems by improving the efficiency of the existing transportation system. TSM views existing streets and highways, rail trackage, parking facilities, bike and pedestrian facilities, and public and private vehicles as elements of a single transporta- tion system. TSM attempts to organize these elements through oper- ating, regulatory, and pricing policies into one efficient, produc- tive, and integrated transportation system. Transportation System Management utilizes primarily low-cost tech- niques to make short -run improvements to the system. Several basic types of strategies guide the use of these techniques. Vehicle flow on streets can be improved through such techniques as synchro- nizing traffic signals. More efficient utilization of vehicles can be encouraged through the promotion of public transit and rideshar- ing. Walking and biking can be encouraged through the bike and pedestrian facilities. The inclination to drive alone to one's destination can be discouraged through parking management and other methods. And congestion during commute hours can be reduced 01/31/91(TCA901B%INDEX-A) AL-14 0 through such techniques as the promotion of alternative work sche- dules. The advisability of adopting specific TSM measures depends upon local factors such as size, density, levels of congestion, travel patterns, and local objectives." (Excerpt from California Local Elected Officials Guide to Transpor- tation System Management, League of California Cities, 1981.) The potential trip reduction associated with TSM depends on the specific situa- tion and TSM measures. Page 2-31 of the EIR/EIS describes a number of TSM measures which are being implemented in the County. The text further explains that the use of TSM measures alone is not a feasible alternative to development of the Corridor. SCAG's Regional Mobility Plan determined that even with growth management, • transportation demand management and transportation system management, the Corridor would be a needed facility to meet regional transportation goals. 4-5-2. 4-36-1Oa. 4-36-10b. 4-36-10c. 8-15-5. 8-26-3 The San Joaquin Hills Transportation Corridor is planned to accommodate rail transportation in the future. Generally speaking, for rail systems to be viable, the following factors must be present: 1. Population densities in the service area should be in a range of approxi- mately 14-20,000 persons/square mile. 2. There should be highly centralized employment, residential, and shopping districts. 3. The centroids mentioned above should be separated by enough distance to allow the rail system to reach efficient operating speeds. 4. Linear urban development. 5. Attitude of acceptance toward mass transportation. The items above would be constraints to feasibility of rail on existing facili- ties. A substantial local mass transit system would be needed to disperse the trips to non-centroid work places. 01/31/91(TCA9018%INDEX-A) AL - 1 5 At the present time and into the near future, many of the key elements required for viability are not present in Orange County. Specifically: 1. Population densities in south Orange County are (and will remain) in the range of 4-7,000 persons/square mile (below the threshold cited above). Population density can be verified from various Orange County publica- tions, including the Orange County Progress Report. 2. The development in south county is of a contemporary suburban pattern and density allocations without dense centroids of employment, business, shopping and residential districts. This development pattern has limited linear distribution which might make mass transit viable in the immediate future. From an economic standpoint it should be noted that major costs associated with rail systems are related to the purchase of the rolling stock (cars) and to the large work force needed to operate, maintain, and ticket the system. Also see Response to Comment 4-10-7 in this Chapter. 4-10-7 Redevelopment of out -of -use rail corridors is not a feasible method for reduc- ing transportation demand for the Corridor. The majority of available rail lines are in the northern area of -the County and would, even if redeveloped, serve a different traffic demand than the Corridor. Further, the future redevelopment of such rail corridors is too speculative to include in current regional traffic modeling. The San Joaquin Hills Transportation Corridor is part of (and consistent with) the Regional Mobility Plan (RMP), prepared by the Southern California Associa- tion of Governments (SCAG) and the South Coast Air Quality Management District (SCAQMD). The RMP guides the long range development of the regional transpor- tation system for the SCAG region, including feasible rail transit projects. Additionally, the 1989 RMP is used to determine the conformity of transporta- tion projects, in the South Coast Air Basin, with the Air Quality Management Plan (AQMP). Under the SCAG-approved conformity procedures and the 1989 AQMP conformity Guidelines, the Corridor is in conformance with the 1989 AQMP for the purposes of SCAG and other local agencies. 4-18-1. 4-18-7 See Responses to Comments 2-9-4, 4-5-2, and 4-10-7 in this Chapter. 01/31/91(TCA9018%INDEX-A) A L - 1 6 0 0 11 Please see Response to Comment 4-34-5 under Purpose and Need. Furthermore, additional trains are being added through the passage of Measure M by OCTC/OCTD along the I-5 corridor. 4-21-19 Amending the General Plans in areas surrounding the proposed Corridor alignment is not a feasible alternative to the Corridor project. (Please refer to Sec- tion 2.8 of the EIR/EIS.) These General Plans as they exist today represent a balance between open space and the development limits permitted. Additionally, the success of attempting to downzone properties which have already gone through the Specific Plan and Planned Community processes is highly improbable because of the legal requirements associated with such an undertaking. The City of Irvine has over 3,000 high density housing units identified in the • IBC, which is more than adequate to accommodate the demand for this type of housing within the planning horizon. Also, high density housing within the Irvine Spectrum would not be appropriate because of overflight impacts (noise, safety) from E1 Toro Marine Base (please see City of Irvine General Plan). Furthermore, the Spectrum was part of detailed negotiations with the City of Irvine, which resulted in the current configuration of Citywide land use desig- nations and densities, and an increase in the amount of acreage preserved in open space. Altering the current General Plan could adversely jeopardize the open space areas slated for preservation in exchange for entitlement in the Spectrum. 4-21-20, 8-23-3 The imposition of tolls on existing roadways is not a feasible alternative to the Corridor project. The costs of imposing tolls, both installing toll col- lection infrastructure and the substantial economic dislocation of reducing mobility, are prohibitive. Tolling only some existing roadways would increase congestion on alternative routes. Further, the transportation projects being developed by the TCA, and those authorized under AB680 are the only toll road- ways authorized by State law. However, the Corridor represents an opportunity to reduce demand for single occupant vehicle use, and to more closely approxi- mate imposition of the full cost of transportation. Users of tollways such as the San Joaquin Hills Transportation Corridor (SJHTC) would actually be paying much closer to the true cost of driving than users of free facilities. Addi- tionally, the TCA's HOV policy is identified in Response to Comment 3-8-14 under Project Description. Further, the Transportation Systems Management/ 01/31/91(TCA9018%INDEX-A) AL- 1 7 • Transportation Demand Management (TSM/TDM) strategies discussed in the SJHTC EIR/EIS include a provision for TCA, Caltrans and the Orange County Transit District to work together to implement park and ride lots along the Corridor at five major intersections. Intersections recommended for park and ride lots are Crown Valley Parkway, Alicia Parkway, Laguna Hills Road, El Toro Road and Ford Road. 4-21-21 The toll road as an inherent HOV strategy (people will be encouraged to carpool to reduce cost of tolls) will further the goal of reducing the number of vehi- cle trips and thereby reduce the demand for parking at trip destination points. Parking reduction is one component of a trip reduction strategy which requires a substantial investment in mass transit. Please see Response to Comment 4-5-2 in this Chapter for a discussion regarding the feasibility of transit. Furthermore, eliminating parking is not an action within TCA authority. 4-21-23 0 Incentives to carpooling and other non -single occupant vehicle travel are provided through urban design as provided by cities and the counties through their General Plans, and regional policy -such as AQMD Regulation XV. In order to provide an adequate level of service, the Demand Management Alternative envisions an increase of HOVs to account for 30% of Corridor users. 4-21-26 Refer to the first paragraph of the Response to Comment 3-1-1 under Project Description. Additionally, the SJHTC Demand Management Alternative provides for the future implementation of HOV lanes in the median which could be re- versed to coincide with peak demand directional traffic flows. The phasing of these HOV facilities would be based on traffic demand and the availability of funds for their construction. Further, the TCA's interim HOV pricing strategy is provided in Response to Comment 3-8-14 under Project Description. 4-21-39 The TCA has configured the project commensurate with the goals of congestion relief and consistent with the Air Quality Management Plan and Regional Mobili- ty Plan. The proposed reconfiguration would not provide adequate capacity to meet travel demand, and additionally would not generate adequate revenue and is therefore economically infeasible. The proposed reconfiguration would not meet • 01/31/91(TCA9018%INDEX-A) AL-18 0 the project need described in Section 1.0, Purpose and Need for Action, con- tained in the DEIR/EIS. 4-32-1 The Draft EIR/EIS discusses the development of light rail or other mass transit facilities as an alternative to the Corridor, or as a means to reduce demand for automobile oriented transportation facilities. The development of light rail transit facilities in the median of existing freeways was not specifically addressed in the Draft EIR/EIS. However, the Regional Mobility Plan ("RMP"), developed by the Southern California Association of Governments as part of the Air Quality Management Plan addresses the need for, and effectiveness of, regional transit facilities. As discussed at pages V-23 through V-30 of the RMP, expected development of regional mass transportation facilities along existing Orange County freeways is expected to be limited primarily to the development of high occupancy vehicle lanes, at least in the near term. Fur- ther, the RMP concludes that both the proposed regional transit improvements and new highway construction, including the Corridor, will be necessary to meet regional mobility goals. Please also refer to Response to Comment 3-5-37 in this Chapter, with respect to the range of alternatives considered in the Draft EIR/EIS. 4-33-13, 4-33-14, 4-33-15, 4-33-16, 4-33-17, 4-33-18, 4-33-19, 4-33-22 SEOCCS does not provide the sole basis for forecasts and need for the Corridor. SEOCCS is important because it provided the original basis for County adoption of ultimate population numbers and necessary infrastructure improvements, including the Corridor. The balance of development and infrastructure in the south County was established through SEOCCS. Some of the comments stated that circulation frequently followed land use decisions. A key outcome of the SEOCCS process was to ensure that circulation and land use were balanced and planned concurrently. The need for the proposed Corridor as an appropriate alternative has been reconfirmed through a number of regional forecasts and plans. These documents and analyses, as recently as 1990, confirm the appropriateness of the Build Alternatives. Traffic projections/modeling for the Corridor, used in develop- ing the Build Alternatives and in the EIR/EIS, were based on a focused (SOCTAM) model of the County's OCTAM model. Refer to pages 3 and 4 of the Traffic Technical Study, Technical Study Number 7 of the DEIR/EIS. SOCTAM incorporates Orange County socioeconomic forecast OCP-88 and more detailed roadway network and land use data for the area serviced by the Corridor. The focusing process of SOCTAM strengthens the predictability of the model along the Corridor. 0 01/31/91(TCA9018%INDEX-A) A L- 1 9 0 In addition to the use of OCP-88 and updated traffic modeling, the Corridor as an appropriate build alternative has been reconfirmed through the regional planning studies of SCAG. The Corridor is an integral component of the Region- al Mobility Plan (RMP). The RMP is linked to SCAG's Growth Management Plan, housing allocation process and the Air Quality Management Plan. The RMP as a mobility strategy incorporates the following: growth management, transportation demand management, transportation system management, and facility development. Several of the comments ask about the affects of growth management and jobs/housing policies. As described above, the effects of such actions have been included in the regional studies completed in 1988, 1989 and 1990 (see Chapter 14.0 References). In addition, Appendix B of the County GMP Element discusses the relationship of the County GMP Element to the freeway system. The discussion identifies the Corridor as one of the necessary transportation system improvements which will help alleviate existing and future traffic congestion on the arterial highway system in Orange County. Development of the Corridor, along with improvements to the arterial highway system, is necessary to provide adequate transportation services for future growth in the region (EIR/EIS, page 6-9). Thus, comment 4-33-22 has already been addressed by the County through the Growth Management Element. It is not necessary to examine -the General Plans to verify SEOCCS.'�More recent forecasts/modeling efforts confirm the need for a Corridor Build alternative. Comment 4-33-16 states that zoning represents a maximum number of units which may be reduced by decision makers in taking action on a project. It is ac- knowledged that agencies with land use authority may change projects through the consideration of vesting proposals. The Corridor is shown to be needed through OCP-88 and SCAG forecasts; a minor reduction in total units of a par- ticular project will not substantially alter the basis for the Corridor. If major reductions in land uses occurred, they would most likely have a major effect only on the 1.5 percent of the Area of Benefit that is not presently committed. While this again would not have a substantial effect on the need for the Corridor, such a change can be accommodated through the phasing pro- cess, that is the TCA could delay implementation of additional lanes or median improvements. However, delay of median improvements would be inconsistent with many of the comments on the EIR/EIS urging early implementation of HOV facili- ties. For further discussion of the downzoning issue see Response to Comment 4-21-19 in this Chapter. 01/31/91(TCA9018%INDEX-A) A L- 2 0 0 0 4-33-20. 4-33-21 The relationship of Aliso Viejo to implementation of the Corridor is acknowl- edged. Aliso Viejo is limited to construction of up to 10,00 units prior to the Corridor being in place. However, if the Corridor is not implemented, the developer of Aliso Viejo could provide the same capacity through approximately 17 million dollars of other highway improvements. A determination as to whether supplemental environmental documents are needed is the responsibility of the appropriate land use authorities, such as cities and the County. The TCA is not empowered to make land use decisions. Fur- thermore, since the TCA relies on County and SCAG regional plans, no informa- tion has become available to demonstrate that such supplemental environmental documents might be required to assess a no build alternative. 6-15-29 Please see Response to Comment 3-4-110 under Traffic/Circulation. 6-15-30 Upon initial review of the suggestion to lower the railroad, two problems are inherent: 1) the lowering of the railroad would place the rail line in the 100- year floodplain and 2) rail lines are designed to operate on very flat grades (the flat grades imply a two mile length of improvements). These issues com- bined make this solution fiscally imprudent. 6-17-6. 6-17-7. 6-17-8. 6-17-9 These comments provide additional information which is hereby incorporated into the Final EIR/EIS. 7-5-2. 7-5-3. 7-8-6 Freeway geometry curve radii do not permit the use of the Brock property west of the proposed Corridor alignment. Additionally, any westward realignment of the Corridor would undermine the Moulton Niguel water tank, which is considered a life line facility. These factors in addition to the vested rights of the Brock Company prevent the TCA from realigning the Corridor to the west in the Nellie Gail area. • 01/31/91(TCA9018,.INDEX-A) AL-21 7-51-2 The commentator is referred to Response to Comment 3-5-37 in this Chapter for information on the general route establishment and to Response to Comment 4-5-2 in this Chapter for Mass Transit information. The commentator is also referred to EIR No. 267 completed in 1979 which studied the route location possibilities for the project (see Response to Comments 3-4-40 and 3-5-37 in this Chapter). 7-88-81 See Response to Comment 3-5-37 in this Chapter and 1-1-50 under Biological Re- sources. 7-136-1 As discussed in Responses to comments 2-4-1 and 3-5-37 in this Chapter, a substantial number and variety of types of alternatives have been studied for the Corridor. The suggested alternative, to terminate the segment of the proposed Corridor from SR-133 to the existing SR 73 freeway, would not serve the arterial and freeway relief functions of the Corridor. This alternative would increase already over capacity, traffic levels on the 405, 133 and Pacific Coast Highway. Furthermore, the land uses in the portion of the Corridor which the commentator wants to eliminate have been cooperatively planned with the Corridor. Responses to the specific subcomments are as follows: 1. The statement is not true, as drivers from the north would need to use already congested I-405, SR 133 and Pacific Coast Highway to reach the Corridor. Drivers from the south would have to exit the Corridor when it ended and would again encounter overcapacity conditions to complete their journeys. 2,6. Costs of the facility or alternatives are not environmental issues to be addressed in the EIR/EIS. Rather, costs are one of the factors consid- ered by the TCA Board in taking actions, but considered independently of environmental factors. The option of being able to build without making it a toll road is not a factor in selecting an alternative; since the toll road was provided in legislation, there is no need to circumvent this funding mechanism. 3. Improvements to the El Toro "Y" will be funded through Measure M monies. 01/31/91(TCA9018%INDEX-A) AL-22 9 4. Implementing light rail only between Laguna Canyon Road and SR-73 would not result in substantially fewer impacts than the proposed Corridor. The grading and other improvements required to implement light rail would be similar with the comment and the proposed Corridor. For further discussion of light rail, see Response to Comment 4-5-2. 8-7-6 Rerouting the SJHTC alignment close enough to the I-405 so that people on the freeway could review conditions on the Corridor and, .based on traffic conges- tion levels, decide whether to take the freeway or the Corridor, is not feasi- ble because of existing and committed land use in this area. However, with that basic concept in mind, there are several ways of accomplishing the same goal. Mitigation Measure T/C-5 in the EIR/EIS requires the TCA adopt a Traffic Management System (TMS) plan to increase the efficiency of the Corridor. Additionally, other potential methods for relaying traffic information include lighted sign boards (presently under consideration by TCA) and special traffic information radio stations. A Caltrans traffic information lighted sign board is already in operation near the I-5 E1 Toro road exit and AM 530 is currently operating as a traffic information only radio station. The existence of these two traffic information sources demonstrates the feasibility of future Traffic Management Systems. 8-19-7 Regarding previous environmental analysis of alignment alternatives, please refer to Responses to Comments 3-4-40 and 3-5-37 in this Chapter. In addition, EIR No. 267 analyzed several potential alignments closer to the I-405 freeway (Nos. 1, 4, 7, 10, 11 and 12 in Figure 2.14). These alignments were not deter- mined to be environmentally superior to the current alignment adopted by the County of Orange. Any alignment closer to the I-405, than previously analyzed, would result in major community disruption and housing/business relocation. 8-21-5 See Response to Comments 4-5-2, 3-5-7 and 3-5-37 in this Chapter. 01/31/91(TCA9018%INDEX-A) A L - 23 0 AIR QUALITY 1-2-6. 1-2-33, 1-2-38, 1-2-39, 1-2-41, 1-2-42, 1-2-43, 3-3-1. 3-3-3. 3-3-4. 3-3-5. 3-3-7. 3-5-118, 3-5-131, 3-5-132, 3-5-133, 3-5-134, 4-7-12, 4-21-44, 4-22-7. 6-17-10, 6-17-19, 6-17-36, 7-84-30, 7-91-2 A number of the commentators have asked questions regarding the conformity of the Corridor with the State Implementation Plan ("SIP") and the proposed Feder- al Implementation Plan (the "FIP"). In summary, the commentators have ques- tioned whether a new highway in the South Coast Air. Basin can be consistent with the various air quality plans and with the policies of the California Clean Air Act and the Federal Clean Air Act. Other commentators have raised questions regarding the validity of the SIP in light of the decisions in Abram- owitz v. U.S. EPA (1987) 832 F.2d 1071 and Coalition for Clean Air v. Reilly (1988) which invalidated certain aspects of the 1982 SIP within the South Coast Air Basin and which ordered the Environmental Protection Agency ("EPA") to prepare a draft FIP pursuant to the provisions of the Federal Clean Air Act. • The consistency of the proposed Corridor (the "Project") with the provisions of the SIP and the proposed FIP are discussed in detail in Section 3.4 of the DEIR/DEIS. Since the public circulation of the DEIR/DEIS, however, Congress has enacted significant amendments to the Federal Clean Air Act, including amendments to the transportation conformity provisions of the Federal Clean Air Act (Section 176). Although the precise effect of the recently enacted Clean Air Act of 1990 will not be entirely known until implementing regulations promulgated by the EPA and concurred in by the Federal Highway Administration are developed, it appears the 1990 amendments have made the following changes with regard to transportation projects under the provisions of the Federal Clean Air Act: 1. Clean Air Act conformity review of individual projects is limited to pro- jects which are not included in an approved regional transportation plan or program, and projects whose design concept has changed from the de- scription in the regional transportation plan. 2. Except for carbon -monoxide impacts, compliance with the Clean Air Act is determined for each regional transportation plan and program and not for each highway project, unless the highway project has changed from the de- sign concept and scope of the project assumed in the regional transporta- tion plan. 3. The Clean Air Act establishes a test for conforming regional transporta- tion plans and transportation programs that they be "consistent with 01/31/91(TCA9018%INDEX-A) AQ-1 • necessary emission reductions contained in applicable implementation plan." In order to determine that a transportation plan and program conforms to the State Implementation Plan, the plan and program is re- quired to contribute to the annual percentage reduction in emissions in non -attainment areas. 4. The amendments establish transition provisions governing the conformity determinations for individual transportation projects until such time as an implementation plan is adopted which conforms with the provisions of the Clean Air Act. The interim rules concerning transportation plans and programs require the plans and programs to (i) be consistent with the most recent estimates of mobile source emissions; (ii) provide for the expeditious implementation of transportation control measures in the applicable implementation plan; and (iii) with respect to ozone and carbon -monoxide non -attainment areas contribute to annual emission reduc- tions. With regard to transportation projects, the interim transporta- tion conformity provisions of the Clean Air Act require that (i) the transportation project come from a conforming transportation plan and • program or for 12 months after the enactment of the Clean Air Act Amend- ments of 1990, from a transportation program found to conform within three years prior to the date of enactment of the Clean Air Act Amend- ments; and (ii) in carbon -monoxide non -attainment areas, eliminate or reduce the severity and number of violations of the carbon -monoxide standards in the area substantially affected by the project. In addition to the above references to changes to the transportation conformity provisions of the Clean Air Act, the Clean Air Act Amendments (the "Amend- ments") establish several other changes relative to the proposed Project. In particular, the new date for attainment of the National Ambient Quality Stan- dards for the South Coast Air Basin is set for the year 2010. The extension of the date for attainment of the National Ambient Air Quality Standards in the South Coast Air Basin and certain other provisions of the Amendments have significant implications for the proposed FIP. As discussed below, the statu- tory scheme and the legislative history of the Amendments suggest that the EPA is not required to finalize the proposed FIP for the South Coast Air Basin. The Amendments contemplate that the States may be given the opportunity to submit new SIPs to address carbon -monoxide non -attainment areas. Under Section 107(a)(4) of the Amendments, EPA is required to promulgate new designations of areas as being in attainment, non -attainment or unclassifiable with respect to the standards for ozone and carbon -monoxide. Several of the House and Senate conferees to the conference committee on the Amendments explained that Congress did not intend the EPA to finalize the FIP in California and thereby preempt 01/31/91(TCA9018%INDEX-A) AQ - 2 0 0 the State and regional air quality planning that is going on in the Los Angeles area. In January, 1991, the Federal District Court vacated the order in Coali- tion for Clean Air. Under the District Court's determination that the Amendments eliminate the need for the promulgation of the FIP, transportation conformity determinations pending the approval of a new SIP for the South Coast Air Basin will be governed solely by the transition provisions of the new transportation conformity provisions of the Amendments. The District Court ruling remains subject to appeal. If the Court of Appeal requires EPA to pro- mulgate the FIP, notwithstanding the provisions of the Amendments, then trans- portation conformity determinations .will be governed by the provisions of the Amendments and any additional specific requirements of the FIP. The draft FIP published by EPA in September 1990 indicated that they were deferring action on identifying new highways in the South Coast Air Basin as a Transportation Control Measure pending the further documentation by the South Coast Air Quality Management District (AQMD) and Southern California Associa- tion of Governments ("SCAG") regarding the air quality benefits associated with • construction of new transportation facilities. In addition, the draft FIP indicated that the EPA would require the transportation conformity procedures adopted as part of the 1989 Air Quality Management Plan by the AQMD and the SCAG to include project -specific conformity criteria in addition to the plan and program level conformity requirements specified in the AQMD and SCAG con- formity procedures. The exact provision of the 1990 Amendments that will apply depends on when the SJHTC is advanced to construction. If it is advanced prior to November 1991, it must demonstrate that it was included in a RTP "found to conform within three years prior to" enactment of the Amendments (Section 176(c)(3) of the Amended Act.) The SJHTC was included in the 1988, 1989, and 1990 RTIP's, for which conformity findings were made by SCAG and the FHWA. In addition, it must be demonstrated that the SJHTC "eliminates or reduces the severity and number of violations of the carbon monoxide standards in the area substantially affected by the project." While the procedures for making such a determination have yet to be issued, the fact the SJHTC reduces carbon monoxide emissions by 14.7% indicates a positive impact. If the SJHTC is advanced to construction after November 1991, but before EPA approval of a SIP for the area, the Corridor will have to meet the same carbon monoxide test required for the pre -November 1991 conformity procedures. In addition, it must be part of a transportation plan and program which meet the interim criteria identified in Section 176(c)(3) of the Amended Act. If the project is advanced after approval of a SIP, similar plan and program level • 01/31/91(TCA9018%INDEX-A) AQ - 3 0 conformity tests must be met, but the conformity will be based on the provi- sions of the SIP, rather than the interim criteria. Congress placed an emphasis on plan and program level conformity reviews simi- lar to those included in the DEIR. Speaking on behalf of all of the House Public Works Committee members serving on the Conference Committee for the Amendments, Congressman Anderson provided the following guidance on conformity: This [conformity] process recognizes that transportation -related air quality issues must be analyzed on a system -wide basis and be controlled through regional strategies in order to be effective. Consequently, individual projects contained in transportation plans and programs should be analyzed in the aggregate, rather than indi- vidually where assessments of regional impacts cannot be measured with any degree of accuracy. This process would not require that each individual project in the transportation plans and programs be analyzed individually to meet the conformity provisions contained in the bill; rather, it requires the transportation plans and pro- • grams when taken as a whole to conform to the SIP. Furthermore, in the final version of the Amendments, the Congress deleted a requirement in previous drafts of the Amendments that conformity consider the "growth likely to result from" activities subject to conformity. As the DEIR documents (p. 6-2), the available research indicates that it is difficult to identify the "growth- inducing impacts" of individual transportation improve- ments. Therefore, the EPA suggestion that "potential induced growth" from the SJHTC be addressed contradicts Congressional direction, and requests analyses which the available academic research indicates cannot be effectively per- formed. In summary, the Amendments have to a great extent confirmed the approach to transportation conformity reflected in the Transportation Conformity Procedures Handbook adopted by SCAG in March 1990 and discussed in Chapter 3.4 of the DEIR/DEIS. In particular, the Amendments emphasize the importance of making transportation conformity determinations based on an analysis of the conformity of a network of regional transportation improvements, rather than focusing transportation conformity determinations on individual projects. In particu- lar, the Amendments emphasize that transportation conformity determinations for individual projects should focus on whether the design and scope of the indi- vidual project has been changed from the descriptions of the Project in the Regional Transportation Plan. 01/31/91(TCA9018%INDEX-A) AQ - 4 • u The Clean Air Act Amendments of 1990 have not altered the analysis of the Project's consistency with the 1989 Air Quality Management Plan ("AQMP"). Indeed, as discussed, the Project would appear to have satisfied the consis- tency provisions of the Clean Air Act and the AQMP because: (1) The Project is identified in the Regional Transportation Plan and in the regional transportation improvements program; (2) The design and scope of the Project (under the Demand Management Alterna- tive) conforms with the design and scope of the Project as described in the Regional Transportation Plan (the "Regional Mobility Plan") as de- scribed by SCAG in the Transportation Conformity Procedures Handbook; (3) The Project comes from a transportation improvement program which has been found to conform within the previous three years. Therefore, under the terms of the Clean Air Act, the Project by definition satisfies the conformity requirements of the Clean Air Act; (4) The Project includes the construction of High Occupancy Vehicle lanes within the 2010 planning horizon of the Air Quality Management Plan, and the Transportation Corridor Agency intends to commit to the construction of the HOV lanes by 2010 as required by,the SCAG Transportation Conformi- ty Procedures (see also Response to Comment'l-2-46 in this Chapter); (5) Since the Project will operate as a toll facility in the foreseeable fu- ture, it will include financial incentives to discourage single occupant vehicle use by providing an effective 50% discount per passenger for each additional passenger added to a automobile; and (6) Under the Demand Management Alternative, new highway capacity on the corridor is deliberately constrained to ensure that the Project will not encourage growth beyond that contemplated by the SCAG Growth Management Plan and the County and City General Plans. Several commentators questioned whether the Project could conform to the 1979 SIP in light of the fact that this Project was not specifically defined at the time of the approval of the 1979 SIP. As discussed in Section 3.4 of the DEIR/DEIS, although the alignment for the Project was adopted by the time of EPA approval of the SIP in 1979, the Project was not specifically described in the SIP. Nevertheless, as discussed in the DEIR/DEIS (page 3-14), the Project implements several of the Transportation Control Measures identified in the 1979 SIP. • 0V31/91(TCA901B%1NDEX-A) AQ-5 The Environmental Protection Agency (EPA) suggests that conformity with the 1979 SIP cannot be demonstrated in part because the DEIR/EIS does not use the 1979 SIP population projections. As described on page 3-14 of the DEIR/EIS, the conformity analysis using the 1979 SIP population projections would be of very little analytic value, as the 1979 population projections have long been superseded by more recent and more accurate projections. As discussed in the DEIR/EIS, the most effective method of evaluating consistency with the 1979 SIP is through consideration of the Transportation Control Measures (TCMs). Com- ment 1-2-42 suggests that construction of the Corridor could have a negative impact on implementation of TCMs such as HOV facilities on other roadways in the regional network. Construction of the Corridor is not expected to have negative impact on implementation of TCMs for two reasons. First, as discussed at greater length in the Alternatives Chapter, the Corridor is only one com- ponent of the system of region -wide transportation improvements including a wide range of TCMs which are proposed under the Regional Mobility Plan. Plan- ning for the Regional Mobility Plan balanced the range of transportation im- provements in order to provide for effective implementation of TCMs. Although the additional roadway capacity called for in the RMP, including the Corridor, will improve traffic flow and reduce vehicle miles travelled, regional travel demand is projected to be sufficiently great to encourage the use of TCMs including HOV lanes on other facilities. Second, in designing the Corridor, two HOV ridership scenarios were considered in sizing the facility; assessing both conservative and aggressive HOV ridership scenarios, Corridor size was restricted based on the aggressive HOV-use assumption. Attainment of the 30% HOV use assumption is considered feasible, in part, because the California Clean Air Act mandates the achievement of 1.5 average vehicle ridership by 1999, a goal implemented by AQMD policies, including Regulation XV (see also Response to Comment 1-2-45 in this Chapter). Because the number of general purpose lanes planned for the Corridor is restricted, ridership in HOV lanes will be encouraged. Similarly, the constrained sizing of general purpose lanes limits the increase in a regional mixed -flow capacity, therefore avoiding any negative effect on TCMs including HOV lanes on other facilities. As indicated in Comment 1-2-43 from EPA, location of the Corridor entirely within the southeast Orange County subregion will not preclude long-distance commuting. However, as further indicated in the comment, 20% of the traffic on the Corridor is expected to be regional -through traffic. The principle service area of the Corridor will be entirely within the southeast Orange County sub- region, facilitating trips from south Orange County housing to job concentra- tions within the subregion. Reducing travel constraints within the southeast Orange County subregion is expected to affect choices of housing location, encouraging home -to -work trips within the subregion and conversely discouraging intersubregional commuting. The potential growth -inducing effect of the Cor- • 01/31/91(TCA9018%INDEX-A) AQ-6 0 ridor by allowing regional -through travel is discussed in the DEIR/EIS, includ- ing growth impacts in San Diego County. Several commentators questioned the adequacy of the AQMP and the RMP given the specific identification of the Project in the RMP and the AQMP. The RMP, which is a component of the AQMP, establishes a 20 year plan of transportation im- provements in the South Coast Air Basin to improve regional mobility and to address a portion of the measures identified as necessary to satisfy State and Federal air quality requirements. The determination has been made by the air quality agencies (SCAG and the AQMD) that certain modest increases in highway capacity in the region are necessary to reduce congestion on a limited number of critical transportation facilities in order to achieve the air quality requirements. The proposed Project is identified as one of the few additional highway capacity improvements within the 20 year planning horizon of the RMP and the AQMP. The goal of the RMP is to maintain the mobility levels of 1984. Although this is a modest goal, it will be difficult to achieve because of the growth projected by SCAG by the year 2010. In this regard, the RMP made the following comments regarding the transportation needs of the region: • Our region, now home to 13.7 million people, faces significant growth. In the coming 22 years, nearly five million additional people will live here (the population is expected to be 18.3 mil- lion in 2010). The region's highways and streets - many'of which have already reached saturation levels during peak commuting hours - will have to cope with vehicles of the new residences as well as the increased freight traffic that serves consumer needs in the region's economy. By 2010, daily person trips and work commutes on the region's streets and freeways will increase by 42%: DAILY TRIPS (MILLIONS) 1984 2010 40.2 57.0 WORK COMMUTES (MILLIONS) 1984 2010 7.3 10.3 If nothing is done to improve the transportation system, by 2010 these additional trips may bring traffic to a near halt in much of the system • 01/31/91(TCA9018%INDEX-A) AQ - 7 for much of the day. To address the critical mobility and air quality needs of the region, the RMP proposed a program that lags behind increas- es in population and travel to prevent further expansion of gridlock throughout the region without stimulating growth beyond that contemplated by the Air Quality Management Plan. The need for, and effect of the RMP is further demonstrated by Table I-2 of the RMP, as follows: 2010 2010 1984 Without Plan With Plan Vehicle Miles Traveled (000's) 221,292 376,187 284,382 Vehicle Hours Traveled (0001s) 6,343 19,575 7,850 Hours of Delay (000's) 629 10,132 899 Percent Delay 10% 52% 11% Average Speed (MPH) All Facilities 35 19 36 Freeways 47 24 45 Miles of Congestion AM Peak 280 2,564 452 PM Peak 612 4,567 856 Transit Ridership Home -to -Work Trips 6.6% 5.1% 19.3% Several commentators questioned how the Project would facilitate achievement of the California Clean Air Act goal of achieving an average 1.5 vehicle occupancy by the year 1999. The Project would assist in achievement of the goals of the California Clean Air Act because of the following: (1) Tolls will, by definition, provide a market incentive for increased ridership per vehicle; (2) In the year 2010, HOV users would achieve both a time saving and a cost saving by carpooling; (3) Under the Demand Management Alternative, the size of the Project has been deliberately constrained to encourage increased ridership per vehicle and to ensure that the Project does not stimulate additional growth beyond that contemplated by the regional and local growth management plans and general plans. 01/31/91(TCA9016•••INDEX-A) AQ-$ 0 0 Ll 1-2-30. 3-1-8. 3-1-9. 3-5-135 One commentator has asserted that the cumulative air quality analysis in the DEIR/DEIS did not consider increased emissions due to growth in areas served by the Corridor (the "Project"). The growth inducement and cumulative effects of the Project are discussed in Sections 6.0 and 7.0 of the DEIR/DEIS. These analyses included an evaluation of future growth in Orange County and the region. The traffic data which is used to analyze the air quality effects of the Project specifically included traffic to be generated by growth anticipated under the city and county general plans. In addition, the traffic model also assumed that there would be increased growth in certain portions of Orange County (primarily those areas served by the Foothill Corridor southern section and the Eastern Transportation Corridor) beyond the growth currently allowable under the general plans. The Southern California Association of Governments ("SCAG") Transportation Conformity Procedures indicate that transportation projects are sized in accor- dance with the Regional Growth Management Plan if the facility size is consis- t tent with the description in the Regional Mobility Plan (the "RMP"). According to SCAG, the RMP assumed the Corridor would be 8 lanes including 2 High Occu- pancy Vehicle lanes. Therefore, the Demand Management Alternative is sized in accordance with the SCAG Growth Management Plan. Also, please refer to Responses to Comments 1-2-6 and 4-22-6 in this Chapter. 1-2-32 The EPA's letter includes a series of on travel time, latent travel demand, and effects on transportation control comments concerning the Corridor's effect use of HOV lanes on parallel facilities, measures: By providing an alternative route and reducing congestion on some existing facilities, travel times could be reduced. This reduction in time could encourage shifts in travel demand. . . Similarly, a time savings on mixed flow lanes could encourage more trips by reducing travel time, thereby satisfying latent demand and longer trips by making further destinations more appealing (p. 12). Given that the DEIS acknowledges that time savings provided by HOV lanes affects travel demand, how would any time savings resulting from congestion relief on mixed flow lanes affect travel demand from existing and planned/committed land uses (not induced growth, specifically trip generation and destinations?) (p. 13). • 01/31/91(TCA901B*,1NDEX-A) AQ-9 0 However, based upon the information in the DEIS, it appears that the SJHTC could negate the benefits of the I-405 HOV lanes by im- proving LOS to C and D (p. 13). The DEIS does not adequately assess the impact of the proposed project on transportation control measures (TCM's) in the AQMP and other demand management programs. As discussed above, this would include the impact of this project on HOV use. . . and local gov- ernment commitment to the AQMP TCMs. The overall effect of improv- ing travel speeds for the single -occupant vehicles on the demand management strategies in the AQMP and regional ridesharing efforts should be analyzed (p. 19). The general answer to all of these questions and assertions is that the EPA has isolated the Corridor from its appropriate context: local and regional land use/transportation/air quality planning and planning assumptions. The EPA then raises issues which can be dealt with only at the regional and systems level, not in a DEIS dealing with a single project. Some reasonable assumptions about future land uses, transportation networks, travel demand, population, and employment must be made to permit any analysis, and the DEIS uses the assumptions identified as appropriate by local, County, and regional and State agencies. (See especially pages 6-1 to 6-14 of the DEIS). 1-2-34, 3-1-7 At the time the Draft EIR/EIS was being prepared, EMFAC7E was not available to be used in the air quality modeling. The EMFAC7E emissions model was used in 1989 when the air quality modeling was started and later updated to EMFAC7D by applying a 16% increase in emissions as a correction factor to the modeling results, as advised by the California Air Resources Board (CARB). The use of the year 2000 emission corrections together with 2010 traffic forecasts is a conservative approach that would result in higher air quality levels. 1-2-35 The comment asserts that CO levels may be understated because the DEIR/EIS does not account for induced trips or growth, and uses a population projection five percent lower that SCAG's. As discussed in the Response to Comments Traffic Circulation and Growth Inducing Chapters, the TCA does not agree that induced trips or growth will occur. Regarding population forecasts, between OCP-88 and 01/31/91(TCA901B%INDEX-A) AQ-10 0 • SCAG, the difference is not high enough to create a measurable difference in CO levels. Regarding the use of OCTAM II, as discussed on page 5-1 of the DEIR/EIS, the OCTAM II forecasts have not been officially adopted, and they are subject to revision. Therefore, the TCA believes it is appropriate to continue using the SOCTAM model. 1-2-36 The air quality analysis is based on toll free traffic at each of the modeling receptor locations with the exception of the mainline toll plaza where toll traffic was used. The use of toll free traffic was selected to provide a worst case scenario of higher traffic volumes and lower vehicle speeds. The toll traffic at the mainline toll plaza was used to. optimize the distribution of manual toll collection lanes and AVI lanes to minimize vehicle queuing. 1-2-37, 1-2-44 The AQMP, GMP and RMP are regional plans with a 20 year time horizon; these plans have been in effect for less than two years. Therefore, the extent and success of implementation are difficult to determine. This is particularly the case as most of the measures called for in the regional plans are not scheduled for current implementation. However, it is appropriate for the EIR/EIS to rely on the AQMP, GMP and RMP as adopted regional planning strategies. Further, these plans, including implementation actions by local governments, are subject to enforcement by AQMD. Nonetheless, Corridor traffic modeling included transportation measures called for in the AQMP to the greatest extent feasible. As described in Response to Comment 1-2-23 under Alternatives, TSM measures are accounted for in the traf- fic model through free -flow assumptions. Further, transportation measures now in place, such as AQMD's Regulation XV, were included in Corridor modeling. 1-2-40, 4-24-11, 7-119-7. 7-119-8 As described in Section 4.4 of the EIR/EIS, the proposed Corridor will not result in any new CO violations in the years 1995 or 2010, for which modeling was performed. Since traffic volumes are expected to increase over time, CO modeling for 2010 provides a "worst case" evaluation for analysis of year 2000 CO levels. It is agreed that the Corridor air quality analysis shows substan- tial increases in CO levels along the Corridor compared to current conditions, because a portion of the Corridor extends through undeveloped land where cur- 01/31/91(TCA9018%INDEX-A) AQ - 1 1 • rent CO levels are at the eight -hour background concentration of 3.4 ppm, as measured by Caltrans. However, these increases will not result in violations of State or federal standards. Regionally, the Corridor, modeled for 2010 on a "worst case" scenario assuming eight mixed flow lanes for the Corridor, would result in a CO reduction of 14.7 percent compared to the "No Build Alternative." In addition, the Corridor will reduce severe congestion on a number of major arterials (e.g., PCH, Moulton Parkway). Therefore, this indicates that the Corridor will result in a reduc- tion in the severity and number of CO violations in the area affected by the project. 1-2-45 Air quality studies demonstrate that when vehicles move at higher speeds and less time is spent stopped in traffic idling, vehicle emissions are reduced with a resulting positive impact to air quality. The commentator implies that the most effective way to attain regional transportation goals is to force gridlock and hope that this unpleasant situation will convince drivers to resort to demand management strategies. The strategy of relying on congestion to reduce vehicle miles traveled has not proved successful in the past. While congestion on Orange County freeways has steadily increased each year, the number of vehicle miles traveled has also continued to increase. Regarding the provision of HOV lanes on the Corridor, it is not financially feasible to fund HOV construction with the first phases of the project. HOV traffic generally is triggered by service volumes that approach capacity, and this is another reason for delaying HOV construction. Project phasing is structured to allow for Corridor improvements, such as the addition of HOV lanes, to occur as traffic demand warrants and funding becomes available through the collection of toll revenues. This method of project phasing will allow the Corridor to be initially constructed with three general purpose lanes in each direction. TCA believes that the California Clean Air goal of attaining a vehicle occupan- cy rate of 1.5 persons per vehicle can be achieved on the SJHTC with or without HOV lanes. Support for this conclusion is given by the following: Tolls will, by definition, provide a market incentive for increased vehicle occupancies. • In the year 2010, HOV users would achieve both a time saving and a cost saving by carpooling. 01 /31 /91(TCA901 B%I NDEX-A) AQ -12 • • Under the Demand Management Alternative, the size of the project has been deliberately constrained to encourage increased ridership per vehicle. • HOV usage will be encouraged by design features of the Corridor, including the provision of direct HOV access ramps. In addition, the TCA expects to participate in regional transportation systems management projects, including the use of express buses and ride sharing. It is also important to note that incentives to achieve an average vehicle occupancy rate of 1.5 persons by 1999 have been developed by SCAQMD as part of Regulation XV. Further, incentives are being implemented by employers to meet Regulation XV. It is also important to note that provisions of the California Clean Air Act require achieving an average vehicle occupancy rate of 1.5 by 1999. AQMP goals and measures to increase average vehicle ridership include the following: alternate work weeks, flextime, telecommuting, employer ridership 1 and transit incentives, vanpool purchase incentives, provision of facilities (bicycle racks, lockers and showers) to -support bicycling and pedestrian activ- ity, parking management, transit improvements, merchant transportation incen- tives, auto use restrictions and requirements for the development of Local Air Quality Elements (SCAG, March, 1990). If current Regulation XV requirements are not sufficient to reach Average Vehi- cle Ridership (AVR) goals, the AQMP calls for SCAQMD to expand Regulation XV requirements to lower employer threshold sizes (to apply the regulations to smaller companies). The incentives and methods to achieve average vehicle occupancy of 1.5 persons have been implemented by a substantial number of local jurisdictions and agen- cies within the South Coast Air Basin. In the event that the average vehicle occupancy rate of 1.5 persons per vehicle is not achieved on the Corridor through the existing incentives and programs discussed above, TCA will consider implementation of pricing strategies to achieve the 1.5 vehicle occupancy rate (see Response to Comment 3-8-14 under Project Description). • 01/31/91(TCA901B%INDEX-A) AQ-13 1-2-46. 3-3-2. 3-3-6. 3-3-8 Southern California Association of Governments ("SCAG") commented that the EPA and the DEIR/DEIS does not commit to construction of High Occupancy Vehicle ("HOV") lanes by 2010. HOV lanes are part of the project (the "Project") in both the Conventional Operations Alternative and the Demand Management Alterna- tive. If the Project is approved, the Transportation Corridor Agency ("TCA") will condition approval on future construction of HOV lanes as required by the Transportation Conformity Procedures. The action of the TCA in this regard will be a binding legal commitment. The TCA plans to spend considerable sums on construction of various median improvements as part of the first phase of construction in anticipation of the subsequent construction of the HOV lanes themselves. For example, bridges will be designed and constructed to complete- ly span the median without columns, median grading will be completed for the HOV lanes as part of the first phase. These improvements constitute an invest- ment in HOVs and a form of commitment. In addition, at SCAG's suggestion, the TCA is exploring the use of policies to achieve HOV usage equivalent to that provided by an HOV lane, prior to construction of the exclusive HOV facilities. (Please refer to comment 3-8-14 under Project Description regarding the TCA's HOV pricing strategy, and Response to Comment 4-5-1 under Funding/Tolls regard- ing pricing and ability to pay). Several commentators have questioned why the DEIR/DEIS refers to both the con- struction of HOV lanes by the year 2010 and in other cases by the year 2000. The SCAG Transportation Conformity Procedures refers to the construction phas- ing in of transportation improvements, including HOV lanes, referenced in the Regional Mobility Plan (the "RMP") by the year 2010. Thus, the current re- quirement of the AQMP and the RMP is that HOV lanes be constructed by the year 2010. However, it is the TCA's intent to.construct HOV lanes as soon as traf- fic conditions dictate. It should be noted that TCA's commitment to stage HOV lanes in response to traffic demands rather than based on forecasts is actually a more definitive commitment because traffic service can be measured while forecasts are subject to time fluctuations, due to the pace of land use improvements. Based on current traffic forecasts, it is anticipated that the HOV lanes would be constructed by the year 2000. The TCA has prepared a finan- cial analysis which indicates that toll revenues beyond debt coverage will be sufficient to finance construction of the HOV lanes before 2010, but not ear- lier than 2000. The volume criteria to be used by TCA in determining when HOV lanes are to be constructed is when the mixed flow lanes exceed Level of Service (LOS) D. This determination will be made based on ongoing traffic monitoring as discussed in Response to Comment 2-10-2 under Traffic and Circulation. 01/31/91(TCA901B%INDEX-A) AQ - 1 4 • An alternative initial configuration of three mixed flow lanes in each direc- tion, with one lane shifting to dedicated HOV use during peak periods, as suggested by the EPA, is infeasible. The HOV lane will not meet the full demand of the mixed flow lane it replaces, congesting the remaining mixed flow lanes beyond acceptable levels of service. 1-2-47 Short-term estimates of air quality levels during construction are not general- ly required as part of an Environmental Impact Statement unless there are unique and extenuating circumstances of long and extended periods of construc- tion activity, at the same location, which would severely degrade existing air quality. The activities and time schedule associated with the construction of the Corridor would not be considered unique and extenuating circumstances. 2-11-12 The park and ride lot near Bonita Canyon Drive should be shown on the east side of Bonita Canyon Road in Figures 4 and 5 of the Air Quality Technical Report No. 3. The analysis prepared has been checked and was correct; however, our drafting was in error. 3-1-2 The comment indicates that the DEIR accurately characterizes the air quality setting; therefore, no response is required. The comments regarding 1989 air quality measurements of ozone are noted. We also note and agree with the comment that the Caltrans CO measurements in the vicinity of the Corridor were below State and federal standards. 3-1-3. 3-1-4. 3-1-6 These comments restate i.nformation contained in the DEIR. No response re- quired. 3-1-5 To reduce PM10 emissions during construction the TCA will implement the fol- lowing fugitive dust control measures: Watering and paving of construction roads or other dust preventive measures as required in District Rule 403. 01/31/91(TCA9018%INDEX-A) AQ - 1 5 • After clearing, grading, earth moving or excavation perform the following: Spread soil binders; Wet area sufficiently to form and maintain a crust on the surface, preventing dust pickup by the wind; Sweep streets if silt is carried over to adjacent public tho- roughfares. To reduce construction related emissions, as part of preparation of the Traffic Management Plan outlined in Mitigation Measures 17-22 and 17-23, TCA will consider the following measures to prevent freeway and arterial closure im- pacts: • The cities in the Corridor will be notified of lane or arterial closure at least one month in advance. Notices will be posted at • locations close to such closures. • Freeway closures will occur during off-peak hours if possible. • Adequate parking will be provided for construction equipment when not in use and construction personnel. 3-1-10 With respect to the TCA implementing an HOV pricing strategy with initial opening of the Corridor, see Responses to Comments 3-1-1 and 3-8-14 under Project Description. Because the Corridor will operate at levels of service C and D during the first years of operation, dedicated HOV lanes will not pro- vide an attractive option to the solo commuter. Refer to Response to Comment 1-2-46 in this Chapter regarding HOV lanes. Also, refer to page 4-34 of the DEIR/EIS for a discussion of HOV modeling. 3-1-11 The EIR/EIS uses a conservative analysis method and acknowledges that HOV lanes will further reduce emissions as discussed on page 4-34 of the DEIR/EIS. As stated in Chapter 6, the Corridor is not a growth inducing facility; how- ever, one of the project build alternatives (Demand Management) proposes the 01/31/91(TCA9018%INDEX-A) AQ - 1 6 0 use of reversible HOV lanes in the median as a traffic management tool, and a means to limit the overall size of the facility. See the Alternatives Section of the DEIR/EIS for discussion of future rail transit. While transit is not currently a feasible alternative, the build alternatives allow for future implementation of transit. 3-1-15 The suggested mitigation measures are currently incorporated into the DEIR. 3-1-16 Mitigation Measure 17-1.1 has been added to the DEIR/EIS providing for the implementation of the proposed mitigation: 17-1-1 Prior to the commencement of any construction activity, the TCA shall prepare a "Construction Equipment Emission Plan" which shall include measures to incorporate the following practices into con- struction operations: • The washing of all trucks leaving the site • A program which ensures,the proper timing and maintenance of construction equipment • Use of low sulfur fuel for construction equipment. 3-1-17 The suggested mitigation measures are included in the DEIR through the prepara- tion of the Traffic Construction Management Plan, with the exception of the following: • Provide rideshare incentives for construction personnel • Provide transit incentives for construction workers Given the size of the project area, varying work hours and lack of transit opportunities, these two provisions will not be added to the DEIR/EIS. 3-1-18 The majority of the suggested mitigation measures are applicable to a develop- ment project, not a transportation facility. The TCA will coordinate with �' 01/31/91(TCA9018%INDEX-A) AQ - 1 7 OCTC/OCTD and local government agencies in support of implementing TSM/TDM strategies. Please see Response to Comment 3-8-14 under Project Description. 3-1-19 The San Joaquin Hills Transportation Corridor design includes the recommended conservation features. The facility will be minimally lit, only at Corridor/Arterial intersections and toll plazas. Regarding the landscaping palette, see Response to Comment 2-•6-1 under Biology. 3-3-9. 3-3-10 The San Joaquin Hills Transportation Corridor uses auxiliary lanes only for weaving areas and climbing locations. In this specific context the lanes are designed in accordance with Caltrans design standards, and the lanes do not serve as "through lanes" bypassing interchanges or ramps. At the north end of the project the number of lanes proposed has been designed to transition to the existing improvements on SR-73. Please refer to Response to Comment 3-2-5 under Traffic and Circulation for additional information on improvements by others to SR-73 northerly of the terminus of the San Joaquin Hills Transportation Corridor. 3-3-11 One commentator has requested an analysis of the proposed AB 680 private toll road projects on Route 91 and Route 57. These projects were selected by Caltrans as private toll road demonstration projects after circulation of the DEIR/DEIS. The projects are in a pre -conceptual stage and no project -level detailed traffic or air quality information is available. Nevertheless, both projects are included in the Regional Mobility Plan ("RMP") and in the traffic model. Therefore, the cumulative effects of these projects have been consid- ered in the regional traffic and air quality analysis prepared for the RMP and for the DEIR/DEIS. 3-5-13 Existing CO background levels were measured by Caltrans during the period of November, 1989, to January, 1990, as part of the SJHTC project. A description of the measurement procedures is in the Air Quality Technical Report (Technical Study No. 3), pages 5 and 6. Other background pollutant levels were taken from SCAQMD monitoring results at El Toro, and Costa Mesa air quality monitoring stations. 01/31/91(TCA9018%INDEX-A) AQ - 1 8 • 3-5-33 3-5-34. 3-5-35 The air quality analysis focused on NOx, TOG, PM1O and CO. All pollutants were analyzed on a regional level. The geographic region was defined by the County of Orange based on the area where travel and traffic would be affected by the Corridor, as shown in Figure 4.4.1 of the DEIS. 3-5-34 The Corridor's effect on regional emissions within the South Coast Air Basin has been analyzed as part of the modeling effort completed for the 1989 AQMP. The conformity guidelines for implementing the 1989 AQMP require analysis of a facility's effect on the air quality subregion in which it is located. Please refer to Response to Comment 3-1-3 in this Chapter regarding the SCAQMD finding on the adequacy of the modeling effort. 3-5-65 • The Corridor level mesoscale analysis in the DEIS (Section 4.4, Table 4.4.A) includes the Foothill and Eastern Corridors. 3-5-82. 7-56-38 Traffic in south Orange County will flow more freely with the SJHTC than with the No -Build scenario. Based on the results of the DTIM regional air emissions computer model (also used by Caltrans), the Demand Management Alternative would result in a substantial reduction in emissions over the No Build Alternative. Please see Section 4.4 (Air Quality) of the EIR/EIS for further information regarding the projected air quality impacts of the SJHTC. Regarding the allegation that the County traffic model is imprecise, please refer to the Response to Comment 4-5-6 under Traffic and Circulation. The 20-year planning horizon is the appropriate time frame for analysis of projected project impacts. Additionally, the general plans for most jurisdic- tions within the Corridor area of benefit assume build out in the next 20 years. Further, the 20-year time frame for traffic analysis is used and re- quired by Caltrans for State highway projects. Regarding the study area and cumulative projects outside of the study area, please refer to Response to Comment 3-5-30 under Traffic and Circulation. 0 01/31/91(TCA901B%INDEX-A) AQ-19 Ll 3-5-83 The majority of the "likely project effects", listed on pages 9 and 11 of your comment letter, are already taken into consideration in the traffic modeling for the DEIR/EIS. Additionally, the calibration process followed for the traffic model further addresses concerns related to a number of these "likely project effects". 3-5-84. 7-88-76, 7-105-4 A very conservative 0.5 meter/sec windspeed was used for the microscale analy- sis. Higher wind speeds would result in increased dispersion of pollutants, resulting in lower CO concentrations. With respect to the study area, refer to Response to Comment 3-5-34 in this Chapter. 3-5-85 CO concentrations are highest near the source and quickly disperse as the • distance from the source is increased. As the distance from the source is increased, the likelihood of a violation of standards would decrease. This is the reason that CO levels are modeled at or very near to the roadway right-of- way (microscale analysis). The cumulative air quality impacts are analyzed as part of the regional (mesoscale) analysis, Section 4.4, Table 4.4.A of the DEIS. 3-5-86 The no toll traffic volumes were used for the air quality modeling at all receptor sites except at the mainline toll plaza, which was modeled using toll traffic. The use of the higher no toll traffic is a worst case scenario which would result in higher CO levels from high traffic volumes and lower operating speeds. 3-7-19 Carbon Monoxide (CO) is the major component of vehicle emissions and is re- quired by State and federal standards to be modeled on a microscale level. There are no similar State or federal requirements for NOx, TOG and PM10. The predicted CO levels for the San Juan School (Receptor 1) and the Montessori School (Receptor 6) were modeled and are listed in Table 4.4.B of the DEIS. The predicted 2010 CO levels for the Stonybrooke School and Capistrano Valley High School are as follows: 01/31/91(TCA9018%INDEX-A) AQ - 2 0 1-Hour 8-Hour Stonybrooke School 10 ppm 5.4 ppm Capistrano Valley H.S. 11 ppm 5.1 ppm The predicted air quality levels at each of the four schools discussed above do not exceed that of the State and federal air quality standards of 20 ppm and 35 ppm for the one hour period and 9.0 ppm for the eight hour period, respective- ly. 3-7-20 The air quality standards referred to are described on page 3-11 of the DEIR/EIS. Health related effects of CO are discussed in the Air Quality Tech- nical Report (Technical Study No. 3), page 8, and are listed in Table 8. 3-8-17 The TCA plans to build six lanes of the Corridor as the first stage. Two HOV lanes will be added as soon as traffic conditions dictate. Current traffic estimates indicate that it will be necessary to add HOV lanes to the facility between 2000 and 2010. This staging plan is designed to ensure that the capac- ity of the Corridor is limited to the demand, and that unneeded capacity not be added, to the facility prematurely. Thus, the project should compliment the efforts of local jurisdictions to develop and implement TDM and transit pro- grams. 3-8-25. 7-12-3 Turtle Rock was not analyzed for CO because of its distance from the Corridor. The closest residential unit in Turtle Rock is over 3/4 of a mile from the Corridor right-of-way. CO is a localized pollutant which quickly disperses over distance. The highest CO concentrations are found near the roadway and at intersections. Receptor sites were selected at the roadway right-of-way of each of the intersections to the Corridor and roadway segments between inter- sections. If there are no violations predicted at the Corridor right-of-way, then at further distances no violations would occur. Please see Response to Comment 3-5-85 in this Chapter. 3-8-26 The air quality modeling analyses was prepared using a windspeed of 0.5 me- ters/second, a worst case condition which represents poor air circulation. 01/31/91(TCA9018%INDEX-A) AQ - 2 1 Mitigation would not be required because the predicted air quality levels from the Corridor do not exceed any State or federal standards. 3-8-98 The correction is noted; it does not affect the conclusions of the EIR/EIS. The editing change is hereby incorporated into the Final EIR/EIS. 4-7-6 The air quality analysis is based on the travel forecasts which predict an increase in the average regional vehicle speed and a reduction in both vehicle travel time and fuel usage. The traffic modeling for the Corridor was based on growth projections including the build out of committed and approved develop- ment in the south County area. As discussed in Chapter 6 of the DEIR/EIS, most land uses in the Corridor area are already committed/approved; there is very little open space available for additional development, and any such new devel- opment would require changes to the applicable general plans. Therefore, since • the Corridor has been planned to accommodate traffic demand based on reasonably projected future development, increased congestion above predicted levels of service is unlikely. Comments on latent demand are addressed in Response to Comment 1-2-32 in this Chapter and -in the Traffic and Circulation Chapter,. 4-7-7. 4-21-5 The Corridor air quality analysis does not rely on improvements in automobile technology to attain improved air quality in the future. Rather, the Corridor, as part of the Regional Mobility Plan included in the AQMP, is expected to improve regional air quality through congestion reduction. With regard to fostering additional trips, please refer to Chapter 6.0 of the EIR/EIS and Response to Comment 3-5-47 under Traffic and Circulation. 4-7-11 Sierra Club v. Metropolitan Transportation Commission ("MTC"} involved the lawsuit by the Sierra Club against the MTC, the Metropolitan Planning Orga- nization for the San Francisco Bay area. The case involves the MTC in its requirement under the Federal Clean Air Act to find the project, program or plan is in conformity with the State Implementation Plan approved and promul- gated under the Clean Air Act, in this case the 1982 Bay Area Air Quality Plan which is part of California's approved SIP. Appendix H to the 1982 Plan con- tains "transportation conformity assessment provisions which require the MTC to annually review the Bay Area's Regional Transportation Plan and Transportation 01/31/91(TCA9018%INDEX-A) AQ-22 0 Improvement Programs to assess their compliance with the 1982 Plan. The MTC annually prepares the RTP, which includes proposals for funding highway and bridge projects in the Bay Area. With respect to the RTP, MTC's Conformity Assessment is "a determination of the air quality impacts of the RTP Amend- ments." With respect to the TIP, MTC's Conformity Assessment is to include "an assessment of major highway projects to determine if they will adversely affect emissions." The District Court in its decision noted that these provisions are designed to assist the MTC in complying with Section 176(c) of the Clean Air Act. The plaintiffs, The Sierra Club, sought a summary judgment ruling that the MTC had failed to carry out the conformity assessments required by the 1982 Plan provisions. The MTC's position as a defendant in the action was that the Conformity Assessment requirements were not enforceable, or, in the alterna- tive, that even if they were enforceable, MTC had fulfilled them in a satisfac- tory manner. The District Court found that the Conformity Assessment provisions are enforce- able under a citizens' suit. The District Court also found that MTC's evalua- tion of highway -related projects in both the TIP and the RTP was not sufficient to satisfy -the conformity conditions under the 1982 Plan. With respect to the TIP, the District Court held that the Conformity Assessment provisions concern- ing the TIP required the MTC to assess whether major highway projects "will adversely affect" emissions. The District Court found that the MTC did not make this assessment in a meaningful fashion and thus could not realistically determine whether a project conformed to the 1982 Plan. The District Court concluded that there was no dispute that MTC was liable for failing to comply with that portion of the Conformity Assessment provisions requiring an assess- ment of whether major highway projects in the TIP will adversely affect emis- sions. The District Court, however, did not find the record in the MTC case complete enough with respect to the appropriate form of a remedy, therefore it deferred ordering any remedy pending receipt of supplemental submissions. The District Court in the MTC case has not fashioned a specific remedy in connec- tion with the MTC's failure to carry out its mandate. The MTC decision has no direct implications with regard to the Corridor. The case does generally stand for the proposition, however, that the provisions of regional transportation plans and Transportation Improvement Programs may be enforced. 4-9-1. 4-13-1 The Direct Travel Impact Model used to predict the regional yearly air emis- sions with and without the Corridor includes the construction of the Foothill and Eastern Transportation Corridors. 01/31/91(TCA9018%INDEX-A) AQ - 2 3 4-14-3. 8-18-3. 8-18-7. 8-33-2 The health related effects of air emissions are the basis for the federal and State Ambient Air Quality Standards (AAQS). Predicted carbon monoxide levels that are below these standards are not considered to be a health risk. CO levels at Leisure World are predicted to be significantly lower than the state and federal 1-hour and 8-hour CO standards. See Air Quality Technical Report, Tehnical Study No. 3, page 8, Table 8, for discussion of health effects of CO emissions. 4-16-2. 4-18-3 The Corridor is consistent with the 1979 State Implementation Plan and 1989 Air Quality Management Plan. The Corridor level analysis prepared for the area where the Corridor would have a direct effect on traffic, demonstrates an improvement in yearly air quality emissions for the year 2010. The carbon monoxide microscale analysis conducted at the Corridor right-of-way (selected to represent the location of closest human activity to the roadway) does not exceed the State or federal CO standards. 4-20-4 Generally, the CO levels of a roadway are considered at distances of 1000 feet or closer to the roadway. Carbon monoxide levels disperse quickly which results in a significant reduction of CO concentrations over distance. The CO levels at the Corridor right-of-way, based on worst case wind speed and direc- tion, are predicted to be below federal and state standards. The CO levels at Turtle Rock would be significantly lower than the levels at the Corridor right- of-way due to the distance of the community from the Corridor. The closest residential unit in Turtle Rock is over 3/4 of a mile from the Corridor right- of-way. 4-20-5 See Response to Comment 4-20-3 under Noise. 4-21-4 Please refer to Responses to Comments 4-9-1 and 7-113-2 in this Chapter. 01/31/91(TCA9018%INDER-A) AQ - 2 4 11 4-21-7. 4-21-8. 8-14-4 The construction of the Corridor is expected to lead to an improvement in regional air quality, through implementation of the Transportation Control Measures of the regional Air Quality Management Plan, as discussed in Section 3.4 of the Draft EIR/EIS and in Responses to Comments 2-9-4 under Alternatives and 1-2-30 in this Chapter. As suggested by the action of the Bay Area Metro- politan Transportation Commission referred to by the commentator, the effects on air quality of changes in transportation infrastructure vary with conditions between regions, and can be a matter of disagreement, among experts. However, as set forth in the Regional Mobility Plan and Air Quality Management Plan for the South Coast Air Basin, the modest additions to highway capacity, along with a commitment to transit facilities (including HOV), are expected to benefit regional air quality by, among other effects, reducing total vehicle miles traveled and increasing travel speeds. 4-21-9 While transportation facilities .as a whole make significant contributions to local air quality levels, the impacts of a single transportation facility would not have a significant effect on global air quality. As' discussed in the DEIR/EIS, the Corridor is consistent with the AQMP, the regional planning tool for improving and maintaining air quality. 4-21-18 See Responses to Comments 3-5-85 and 3-7-26 in this Chapter. 4-22-5. 7-56-35 Please refer to Chapter 6.0 of the EIR/EIS and Response to Comment 3-5-47 under Traffic and Circulation. 4-22-6 Regarding the use of the 2010 design year for traffic analysis, please refer to Response to Comment 3-5-82 in this Chapter; regarding the study area, please refer to Response to Comment 3-5-34 in this Chapter. The methodology utilized to analyze the air quality effects of the Corridor (the "Project") complies with the specific modeling requirements adopted by the Air Quality Management District ("AQMD"), Southern California Association of Governments ("SCAG"), Caltrans and FHWA. These include: 0 01/31/91(TCA9018%INDEX-A) AQ - 2 5 1. An analysis of emissions on a corridor level in accordance with SCAG Transportation Conformity Procedures Handbook (See Responses to Comments 3-3-3 and 3-3-4 in this Chapter). 2. Use of the DTIM and Caline models approved and accepted by Caltrans, FHWA and the air quality agencies. 3. Use of the 2010 planning horizon as required by Caltrans, SCAG and the AQMD. The 2010 planning horizon is suggested by these agencies because it conforms to the planning period of the Air Quality Management Plan and the RMP. Realistic estimates beyond the 20 year time period are not feasible. In addition, the Federal Clean Air Act now has set a 20 year deadline for the region's compliance with the National Ambient Air Quali- ty Standards. The air quality analysis evaluates the effect of the Project on 2010 conditions because this approach conforms with the methodology approved by the above -referenced air quality and regional planning agencies. 4-24-5. 7-56-33, 7-88-57, 7-88-58 The long-term effects of air quality on the Laguna Canyon ecosystem would be based on exceedance of the State and federal secondary air quality standards. These secondary standards are based on damage to crops, vegetation, wildlife, visibility, climate and on adverse effects to the economy. Since there are no violations of State and local standards by the Corridor, local ecosystems would not be significantly impacted. For further discussion of microclimate issues, please refer to Response to Comment 4-32-13 in this Chapter. 4-32-13, 4-33-96, 4-33-97, 7-88-58, 7-114-6. 7-114-7 The predicted air quality levels from the Corridor do not exceed any State or federal standards. In accordance with the Southern California Air Quality Management District, the construction of the Corridor will be subject to speci- fic mitigation measures to control fugitive dust such as watering and paving of construction roads, spreading of soil binders, wetting of construction areas sufficient to form and maintain a crust on the surface, preventing dust pickup by the wind, and sweeping of streets if silt is carried over to adjacent public thoroughfares. Please refer to Mitigation Measures 17-1 through 17-24 in Section 4-17 of the DEIR/EIS for additional information. Regarding the impact • 01 /31/91(TCA9018%INDEX-A) AQ - 26 of future construction of HOV lanes, see Response to Comment 4-32-12 under Construction Impacts. To state that air flow patterns in the immediate vicinity of the SJHTC will be "radically changed" is, we believe, speculative. Furthermore, air flow is only one factor influencing microclimate. Slope, aspect, exposure, substrate, and vegetation cover are all important considerations as well. Microhabitat is defined by additional factors, among them: soil characteristics, food avail- ability of shelter, and more. The notion that air flow "alterations are cer- tain to displace many residents of the area (animals.and plants)," and sensi- tive species in particular, places undue emphasis on air flow as defining microhabitat. To summarize, the impacts of air flow alternations on plants and animals along the SJHTC are strictly speculative at this time. (Source: per- sonal communications - Golightly, Richard. Professor of Wildlife Biology, Hum- boldt State University, Arcata, California; Reiger, John. Biologist, Califor- nia Department of Transportation, San Diego.) 4-33-7 Please refer to Response to Comment 4-33-6 under Project Description. 4-33-98 The information requested is provided in Technical Study No. 3, but not all within the same table. Table 2 outlines the ambient air quality monitoring summary from the E1 Toro and Costa Mesa monitoring stations. Information in this Table identifies what the ambient air quality is within the subregion. Table 3 illustrates the results of subregional modelling of air quality effects with and without the Corridor. By comparing the Tables, one can determine the magnitude of change in air quality levels under the 2010 Build/No Build sce- narios. The Conventional Alternative was used in this modeling effort to determine the "worst case" air quality scenario. 4-34-16. 7-1-3. 7-33-1. 7-125-1 The predicted air quality levels from the Corridor do not exceed any State or federal standards. • 01/31/91(TCA9018%INDEX-A) AQ - 2 7 4-36-2 As described in the DEIR/EIS, High Occupancy Vehicle lanes are included as part of the Corridor project. The HOV lanes were predicted to operate at a level of service (LOS) of C or better (55 mph) as compared to the regular lanes operat- ing at an LOS of F (25 mph) to C (55 mph). The vehicle emissions at lower speeds contain higher CO levels. The constant speed of 55 mph for the HOV lanes will produce fewer pollutants. 4-36-9. 7-123-2 Commentators have questioned whether the Corridor (the "Project") will encour- age single occupancy vehicle use and therefore interfere with implementation of various Transportation Control Measures such as carpooling and trip reduction programs. As a mixed -flow facility, the Project will allow for single occupancy vehicle use. At the same time, a number of components have been included in the Pro- ject to discourage single occupancy vehicle use and encourage High Occupancy Vehicle ("HOV") use including: 1. Tolls; 2. HOV lanes and possible HOV goals (achieve similar occupancy rates of parallel free facilities) to encourage increased HOV use prior to con- struction of HOV lanes; 3. Restriction of capacity of Project to accommodate only traffic to be generated by land uses approved under existing local general plans and Southern California Association of Governments ("SCAG") growth management plan. In addition, the Project is part of a region -wide network of transportation improvements included in the SCAG Regional Mobility Plan (the "RMP"). Overall, the RMP is intended to prevent further deterioration of traffic conditions in the region by modest increases in new highway capacity and a strong commitment to transit systems (including HOV). The RMP represents the professional judg- ment of the Regional Planning Agency of the mix of transportation systems which are necessary to reduce congestion and thereby assist the region in meeting State and Federal air quality goals. C7 01/31/91(TCA901B%INDEX-A) AQ-28 • 6-17-27 The following wording is added to Paragraph "8" on page 2-39. "The RMP, a portion of the AQMP, has been modeled as an integrated regional transportation plan with the objective of balancing trans- portation infrastructure needs with land use projections. The transportation facilities in the RMP are sized to achieve regional mobility goals and air quality emission standards." 6-17-35 Please refer to Responses to Comments 1-2-6 and 4-22-6 in this Chapter. 6-17-42 The sentence is hereby revised to state, "This table indicates that the Conven- tional Alternative, as compared to the "No Build Alternative....." • 7-14-9 Please refer to Response to Comment 4-.21-7 in this Chapter regarding the effect of new roadways on regional air quality. Also, please refer to Response to Comment 4-24-11 in this Chapter regarding local air quality impacts. 7-39-1. 7-46-1 The California and federal Ambient Air Quality Standards (Clean Air Act) are used as the air quality standards in the DEIR/EIS. 7-45-8 The Foothill and Eastern Transportation Corridors are included in the regional air quality analysis discussed in Section 4.4 of the DEIS. Please refer to Response to Comment 4-21-10 under Land Use. The air quality effects of air- craft operations at John Wayne Airport are not considered by the DEIS. 7-56-36 There are currently no State or federal standards for benzene. The regional mesoscale analysis indicates that the Corridor would result in a reduction of yearly contaminants in the year 2010 as compared to the No Build alternative. 0 01/31/91(TCA9018%INDEX-A) AQ - 2 9 0 This would also be true of individual pollutants such as benzene, which would be expected to decrease with the Corridor. 7-56-37 The Corridor was analyzed and compared to all current and applicable air quali- ty standards. 7-56-39 Air emissions from motor vehicles are not considered hazardous pollutants. 7-60-4 The predicted air quality levels at the commentator's home, 25761 Arlington Drive, Laguna Niguel, would be 5.0 ppm for the eight hour CO concentration and 10.3 ppm for the one hour CO concentration. These levels are substantially lower than the State air quality standard of 9.0 ppm for the eight hour period and 20 ppm for the one hour period. 0 7-64-3. 7-141-10 The air quality modeling takes into consideration changes in traffic volume and speed. The effects of the grades along the Corridor are reflected in the lower vehicle speeds which would result in higher vehicle emissions. 7-89-3. 7-89-4. 7-108-13 The Corridor air quality analysis was prepared using worst case assumptions of toll -free traffic conditions, except at toll plaza locations, which were in- cluded to account for air quality effects of plaza queuing. The mainline toll plaza was analyzed with 60% of the traffic using the automatic vehicle identi- fication (AVI) toll lanes and 40% using the manual toll collection lanes. The emission data for vehicle acceleration, deceleration and queuing, for both types of toll collections, was incorporated into the CO microscale analysis. 7-90-2 Air quality levels, predicted at receptor sites along I-5, do not exceed State or federal standards. 01/31/91(TCA901B%INDEX-A) AQ - 3 0 0 �7_ 7-107-1 Mitigation Measure 6-15 calls for replacement of oak tree resources affected by the construction of the Corridor. Additionally, TCA is investigating the possibility of obtaining AB 470 grant funds to use for planting large qualities of oak trees along the proposed SJHTC alignment. The TCA would welcome any local support regarding this effort. However, planting enough new trees to have a substantial impact on vehicle emissions along the Corridor is infeasi- ble, as such extensive planting would displace existing vegetation. Further, construction of the Corridor will not introduce 130,000 new cars per day to the transportation system. Initially, traffic volumes on the Corridor will consist of existing traffic diverted from other facilities. In future years the Corridor will serve the traffic demands of existing and planned development. The majority of the planned development within the area of bene- fit for the Corridor will occur with or without construction of the Corridor, as discussed in Chapter 6 of the DEIR/EIS. 7-108-14 ' The toll plazas are designed to handle 60% of the traffic volume with automatic vehicle identification (AVI) toll lanes. Vehicles using these lanes will not have to stop to manually pay a toll but i.nstead will travel through these toll gates at up to 55 mph. These lanes will help control queuing -and limit conges- tion. 7-108-16 The air quality violations referred to on page 5-2 of the DEIS were predicted using traffic forecasts from the OCTAMII traffic model. As stated on page 5-1, this program has just been completed and represents the eventual replacement to the SOCTAM traffic model used for the DEIS. Further refinements and modifica- tions are required before this model will be used. The air quality analysis discussed in the DEIS is based on the traffic forecasts from the SOCTAM traffic model. There are no predicted air quality violations using the SOCTAM traffic model. 7-109-10 Please refer to Responses to Comments 4-7-6 and 4-23-13 in this Chapter regard- ing local and regional air quality effects of the Corridor. 01/31/91(TCA9018%INDEX-A) AQ - 3 1 7-113-2 Regional air quality is improved by the project because the Corridor improves mobility to a region which is suffering from numerous freeways and arterials currently operating at very congested levels. Construction of the Corridor will allow these same trips to move at a greater speed; vehicles emit greater emission when traveling at slower stop and go speeds than accomplishing the same trip on an uncongested facility. The model used to produce these results is an air quality model produced by the Southern California Air Quality Manage- ment District and California Air Resources Board. These models are not pro- duced by the TCA, but are created by the aforementioned agencies to measure project impacts on air quality. For additional information regarding how the Corridor relates to regional planning goals, please see Response to Comment 4-10-7 under Alternatives. 7-129-1. 8-15-4 Smog is caused by the interaction of sunlight with nitrogen oxide (NOx) and hydrocarbons (TOG). The regional mesoscale analysis discussed on pages 4-33 and 4-34 and shown on Table 4.4.A of the DEIR/EIS indicates that the Corridor would result in lower NOx and TOG emissions than the No Build Alternative without the Corridor. 7-141-11 The air quality analyses are based on travel and traffic projections along the Corridor and local arterials. The traffic volumes for each of the next 20 years are not available and would require extensive efforts to model. There- fore we cannot determine, on a yearly basis, what the expected additional contaminant emissions would be over the next 20 years. Section 4.4 of the DEIS, provides a comparison of the 2010 contaminant emissions with and without the Corridor. The projections provided are consistent with NEPA/CEQA guide- lines and provide adequate air quality modeling for decision makers and the public to ascertain project impacts on air quality. 8-10-1 The information provided in the comment is acknowledged. The TCA is aggres- sively pursuing a Traffic System Management Plan which will develop operational procedures for incidences and emergencies (Mitigation Measure TC-5 in Chapter 5.0 of the DEIR/EIS). 01/31/91(TCA901B%INDEX-A) AQ - 3 2 C7 0 • 0 n 8-18-19 Please refer to Response to Comment 4-21-7 in this Chapter regarding the Cor- ridor's beneficial effect on regional air quality. Please refer to Response to Comment 3-4-73 under Cumulative Impacts regarding the modeling assumptions for arterials and freeways. . Please refer to Responses to Comments under Noise regarding the Corridor's noise impacts. As discussed in the DEIR/EIS noise impacts have been mitigated in all locations, where feasible. 8-28-2. 8-29-1 Please refer to Responses to Comments 4-21-7 and 4-34-16 in this Chapter. 01/31/91(TCA9018%INDEX-A) AQ - 33 0 • BIOLOGICAL RESOURCES Refer to Responses to Comments 1-1-11 through 1-1-67 in this chapter. 1-1-11 It should be noted that the loss of riparian habitat in Bonita Canyon was discussed in the Draft EIR/EIS and Technical Appendices, and that complete mitigation (in the form of replacement habitat) for the loss of this habitat will be provided as part of the Draft Wetlands Mitigation Plan contained in the Final EIS. Refer to Response to Comment 1-1-16 in this Chapter regarding potential impacts to the vireo. 1-1-12 Refer to Responses to Comments 1-1-16, 1-1-25, 2-7-9, and 3-5-97 in this Chap- ter. 1-1-13, 1-1-36, 1-1-40, 1-1-41, 1-1-42, 1-1-43, 3-5-96, 4-21-33, 4-29-1. 7-56- 21 As part of the wetlands mitigation plan process, which includes review by and coordination with the U.S. Fish and Wildlife Service (USFWS) and the California Department of Fish and Game (CDFG), the precise replacement ratio of impacted wetlands habitat will be finalized. TCA is proposing 1:1 replacement of im- pacted wetlands. Refer to Response to Comment 43-32-6 in this Chapter regard- ing the method utilized for delineation of wetlands. Refer to Section 4.6 of the Draft EIR/EIS for descriptions of potential habitat impacts of the proposed project. Table 4.6.A delineates the amount of acreages impacted within grassland, coastal sage scrub, chaparral, oak savannah, oak woodland and wetlands habitats. The Draft Wetlands Mitigation Plan addresses the components listed in Comment 1-1-41. Refer to Response to Comment 3-5-109 in this Chapter. The same type and quality of wetland habitat replaced as part of the mitigation plan require- ments will mimic or be of higher quality than the habitat impacted by the Corridor. The mitigation plan also includes requirements for monitoring and maintenance, and requires replacement of the habitat in the event of failure. Specific provisions for land ownership and protection of riparian and sensitive 01/31/91(TCA9018%INDEX-8) B - 1 upland mitigation sites will be determined as part lands Mitigation Plan and during -the Section 404 processes. The USFWS has reviewed the mitigation Site Selection Plan (a pre -draft plan) as well as prior to submittal of the 404 application sent to referenced in Comment 1-1-42 was reviewed as part Wetland Mitigation Plan. 1-1-14 of preparation of the Wet - and Section 7 Consultation strategy presented in the the Draft Mitigation Plan :he Corps. The publication )f preparation of the Draft Refer to Response to Comment 2-7-14 in this Chapter. 1-1-15, 1-1-31, 1-1-38, 1-1-65 Refer to Responses to Comments under Growth Inducement. The Draft EIR/EIS concludes that the proposed Corridor will not have growth inducing effects upon biological resources. 1-1-16. 1-1-17, 1-1-18, 1-1-19, 1-1-20, 1-1-39, 1-1-45, 4-22-29, 4-22-30 The FHWA will respond to the recommendation of the EPA and USFWS regarding the initiation of a Section 7 consultation. The Informal Consultation will deter- mine if the Corridor does affect any endangered or threatened species (such as the vireo). The TCA will engage in all required actions under the Endangered Species Act. The effect of the project on endangered species is evaluated in the EIR/EIS. There is no confirmed evidence that the least Bell's vireo is breeding at Bonita Canyon Reservoir. Refer to Response to Comment 3-5-97 in this Chapter. The FHWA will coordinate with the U.S. Fish and Wildlife Service on a regular basis to check on the status of the California gnatcatcher. The Analysis of Avoidance Alternatives for Wetland Impacts (404 (b)(1) Evalua- tion) is contained in Technical Study No. 5, Volume II of the Technical Stud- ies. This analysis demonstrates that all prudent avoidance and alternative measures through past alignment alternatives have been identified and evaluated and that the current alignment is the result of design refinements to minimize impacts to wetlands habitats and sensitive resources. Refer to Response to Comment 1-2-49 in this Chapter. 01/31/91(TCA9018%INDEX-8) B - 2 Refer to Responses to Comments 1-1-22 through 1-1-67 in this Chapter. The Service's comment regarding potential endorsement of the No Build Alternative is noted. 1-1-22, 1-1-44 The singing male vireo was sighted in the Bonita Reservoir, but outside of the Corridor line of disturbance. No nesting has as yet occurred within the habi- tat in the Bonita Reservoir. Therefore, there are no direct impacts to nesting habitat of the vireo as a result of the Corridor. There are direct impacts to the riparian habitat in Bonita Canyon, which poten- tially provides habitat for the vireo and other sensitive riparian birds. These impacts are identified in the Draft EIR/EIS. Technical Report No. 5 is considered to be part of the Draft EIR/EIS, and therefore the information is incorporated. • As part of the wetlands mitigation plan, specifications for the quantity of replacement habitat has taken into consideration the indirect noise effects of the Corridor to avian species in wetlands habitats (including the federal and State endangered least Bell's vireo). 1-1-23 In the process of preparing this document, a request was made to the Laguna Niguel office of the USFWS regarding sensitive species potentially present along the Corridor. The original request was made in May 1987. An updated list was requested in March 1990. At Caltrans' inquiry, the USFWS replied that the 1987 list remained appropriate, and no update was necessary. Comprehensive surveys have been carried out for all species on the USFWS 1987 list. In addition to the species listed by the USFWS, the surveys looked for other species recognized as sensitive, such as the tricolored blackbird, northern harrier, ashy (mesa) clubmoss, etc. 1-1-24 The list provided by the USFWS did not include the peregrine falcon, light- footed clapper rail or the California least tern. Nevertheless, the field surveys did not locate the peregrine falcon nor any suitable nesting habitat 01/31/91(TCA9018%INDEX-8) B - 3 i for this species. See Response to Comment 2-7-10 in this Chapter for discus- sion of the light-footed clapper rail and the California least tern. 1-1-25. 1-1-26, 1-1-27, 2-9-5. 2-9-18, 3-5-95, 4-19-7. 4-28-15 4-28-16. 4-32-5. 4-33-34. 4-33-42. 4-33-60. 4-33-61- a-33-69_ a_3a_1n_ a_U_11_ a_aa_19 4-J4-1J1 '+-J'4-1'i. /-JV-10. /-00-40, /-00-40, /-90-Ly. /-232f-5. /-tStS-13. /-tStS-bU. 7-88-74, 7-88-86, 8-4-6 The studies completed for the Corridor incorporated previous work by P&D Tech- nologies for Draft EIR 494, field studies done by P&D in response to comments on the Draft EIR 494, field studies by LSA for this Draft EIR/EIS, and an analysis of wetland habitat based on the Unified Federal Methodology. The Draft EIR/EIS incorporated all of -the work performed by P&D Technologies, as well as additional follow up studies performed by LSA and others. The Bio- logical Assessment report is based principally on the biological resource analysis prepared by P&D, and includes revisions and additions provided by the follow up work. A literature search and records check was made for information on the biologi- • cal resources of the Corridor. Documents researched included field studies conducted for various sections of the Corridor, species descriptions and re- search literature. Aerial photography was used in designing the botanical surveys. In addition, previously prepared vegetation and sensitive species maps were used in the design of the field surveys and the preparation of this report. The Corridor was surveyed in 1983, 1985, 1987 and 1988 by P&D Technologies. Vegetation surveys were conducted in late June and early July of 1983 of selected portions of the area of disturbance from the vicinity of Bonita Canyon Reservoir south to Aliso Creek. Wildlife surveys included the entire length of the Corridor. Other special census surveys were conducted for sensitive am- phibian, reptile, bird and mammal species. In reference to Comments 4-34-11 and 4-34-12, over 650 hours were spent on biological surveys for the Corridor during 1983, 1985, 1987, 1988 and 1990. Over 48 hours were spent on botanical surveys and over 95 hours were spent on wildlife surveys in 1983. Botanical surveys were conducted in late June and early July of 1983 in an attempt to locate spring flowering annual species. The remaining hours, totalling over 400, were spent in field surveys in 1985, 1987 and 1988. 01/31/91(TCA901B%INDEX-B) B - 4 0 P&D Technologies surveys in 1985, 1987 and 1988 included field reconnaissance, as detailed in the following reports: in 1985, Avian Resources of the Bonita Canyon Riparian Area With a Special Emphasis on a Least Bell's Vireo Census, Spring, 1988 Biological Survey Results, and Mule Deer Activity Analysis. LSA conducted a spring field survey in 1990, searching for sensitive species along the Corridor. Approximately 89 hours over 21 days from May to July were spent conducting field surveys. LSA also conducted a wetlands delineation survey in 1990. Approximately 24 hours were spent in this delineation. Based on all the previous work, it is not anticipated that any new sightings will be made of the sensitive species listed in these and other comments. The. previous work was thorough and extensive, and covered all the undeveloped portions of the Corridor alignment. However, as stated below, additional surveys will be conducted for the sensitive species is listed in various com- ments. Pertaining to Comment 4-34-12, there is no contradiction between surveying along the Corridor and including an intensive survey of Bonita Reservoir area. The comment includes information about sensitive and non -sensitive species that are discussed in the Draft EIR/EIS. The wildlife observed in Sycamore Hills was recorded and discussed in the Draft EIR/EIS, as well as the previous stud- ies used in the preparation of the Draft EIR/EIS. The vegetation communities within the Corridor were mapped by P&D Technologies in 1983, with updated reports in 1986, 1988 and 1990. These reports identify several plant communities as wetland types. The survey performed by LSA Asso- ciates during the week of March 5, 1990, used the vegetation information col- lected by P&D to identify candidate wetland locations. LSA used the routine on -site determination methodology described within the "Federal Manual for Identifying and Delineating Jurisdictional Wetlands," the Unified Federal Methodology, January 10, 1989. The plant communities are shown on Figures 1 through 5 (Conventional) and 6 through 10 (Demand Management) in Technical Study No. 5. In reference to Comment 1-1-27, it should be noted that the listing of Pacific pocket mouse in the Draft EIR/EIS (on page 29 of the Spring 1990 survey re- sults) is not based on the 1990 field observations. •Rather, the listing refers to animals trapped by M'Closkey (1972) in the vicinity of the Corridor at what is now the Spyglass Hill housing development. In regard to Comment 4-28-15, the relevant information provided in the PhD dissertations prepared by M'Closkey and Meserve will be reviewed and incorporated, if appropriate, into the Final EIR/EIS. 0 01/31/91(TCA9018%INDEX-6) B - 5 0 In Response to Comment 7-56-29, previous biological surveys of the study area (P&D 1987, 1988; Hays, L.R. and M.A. Benner 1985, Avian Resources of the Bonita Canyon Riparian Area with Special Emphasis on a Least Bell's Vireo Census; P&D Technologies 1988, Mule Deer Activity Analysis; and P&D Technologies 1988, A Biological Resource Analysis San Joaquin Hills Transportation Corridor) have provided base data of approximate numbers for specific species. However, population estimates for all wildlife were not provided because it was not determined to be necessary for the impact analysis. The Pacific pocket mouse is discussed in the Biological Assessment report as being potentially present in the project area. It is recognized that the mouse has existed in the past in the Newport Coast area. However, based on the review of existing information with regard to habitat and substrate preference, and on trapping efforts carried out by LSA in other areas of the Newport Coast, it is unlikely the species occurs along the Corridor due to the lack of suit- able sandy substrate and associated habitat; therefore, the conclusions regard- ing potential impact to sensitive species in the Draft EIR/EIS are appropriate. However, as part of TCA's ongoing commitment to continue surveying for sensi- tive species, a trapping survey will be conducted at the appropriate time of year and under suitable conditions in an attempt to further determine the presence or absence of this species. Pertaining to Comment 2-9-16, all the information provided by the field surveys and document information were included in both the Draft EIR/EIS and the Bio- logical Assessment report (Technical Study No. 5). In addition, the document identifies all coastal sage scrub and saltbush scrub as habitat for the gnatcatcher to indicate that gnatcatcher habitat is not limited to reported sightings. Regarding comments pertaining to the need for an additional deer movement study, it was determined unnecessary due to the previous study prepared by M. Benner, P&D Technologies, Mule Deer Activity Analysis, September, 1988. The wildlife movement patterns disclosed in the Draft EIR/EIS were not based solely on that study, but also on previous field observations from 1983 through 1989 by the authors of the mule deer study and LSA Biologists. Regarding the need for additional wildlife movement studies for other species and ongoing monitor- ing, terrestrial wildlife (with the exception of certain bird and insect spe- cies) does not migrate in Southern California. Therefore, there is no estab- lishment of definable routes such as occurs with migrating species. This makes it difficult to identify movement routes and corridors, except in the general sense that all major drainages and ridgelines function as areas of movement. The Draft EIR/EIS identifies that movement occurs along major ridges and drainages. 01/31/91(TCA901B%1NDEX-B) B-6 • 0' Paul Beier, a qualified mountain lion researcher, has stated his conclusion that the San Joaquin Hills no longer and probably will not again support moun- tain lions. With respect to deer and coyote, as stated above, areas of move- ment were defined in the document. It should be noted that neither deer nor coyote are considered sensitive species due to their satisfactory overall population status statewide. However, TCA recognizes the importance of the local mule deer population to the general public and, therefore, is incorporat- ing design features to provide access across the Corridor. Refer to Response to Comment 1-1-50 in this Chapter. Also refer to Response to Comment 2-7-3 in this Chapter for discussion of Corridor design in the Bonita Canyon area, which will allow wildlife movement between the San Joaquin Hills and Upper Newport Bay. Regarding Comment 4-34-10, updated field studies have been done since the work in 1983 that have included the Laguna Canyon area. In addition, the information provided in the Laguna Laurel Planned Community and other projects have been used in the preparation of this Draft EIR/EIS. There have been no profound changes in the Laguna Canyon area since that would warrant a change in the findings. The surveys were done at the appropriate time of year to locate annual flowering species. The Dud7eya stolonifera mentioned in Comment 4-34-11 was located in the 1983 study and is discussed in the EIR on page 3-41 and in the Biological Assessment report on page.48. The document notes the presence of California gnatcatcher and San Diego horned lizard in coastal sage scrub habitat along the Corridor. The bird species listed by the Audubon Society are mainly common species found elsewhere along the Corridor. Regarding Comment 7-56-29, TCA does not propose to conduct census counts of wildlife populations for the Corridor study area. While this type of data may be informative, it is not required for analysis of impacts to wildlife popula- tions. In response to the identified project impact of reduction of wildlife popula- tions, especially sensitive species populations, additional surveys will be conducted for the following sensitive species. The following mitigation mea- sure is provided: 6-20 Surveys will be conducted by the Project Biologist for the following sensitive species during the appropriate time of year, if possible: 01/31/91(TCA901B%INDEX-B) B- 7 • California gnatcatcher (Polioptila californica californica) • Cactus wren (Campylorhynchus brunneicapillus) • Spotted bat (Eudurma maculatum) • Greater mastiff bat (Eumops perotis californicus) • Pacific pocket mouse (Perognathus longimembris pacificus) • San Diego horned lizard (Phrynosoma coronatum blainvellei) • Orange -throated whiptail lizard (Cnemidophorus tigris) • Palmer's grappling hook (Harpagonella palmeri) • Greene's ground cherry (Physalis greenei) • Coastal scrub oak (Quercus dumosa) • Big -leaved crown beard (Verbesina dissita) • Blochman's dudleya (Dudleya blochmaniae) • Summer holly (Comarostaphylis diversifolia diversi- folia) • Southern spikeweed (Hemizonia australis) The surveys will be conducted during the appropriate time of year for maximum effectiveness of survey results. Should the surveys indicate presence of any of these sensitive species within the Corridor area of effect, a determination will be made as to the significance of project impacts on the species. If necessary, additional mitigation measures will be implemented as part of the Mitigation Monitoring Program. Results of ongoing monitoring and surveys will be included as part of monitoring reports which will be submitted to the TCA Board as required by AB318O. 1-1-28 The vegetation present along the Corridor was mapped from aerial photographs followed by ground truthing surveys to determine the extent of various habitats within the Corridor alignment. The alignments of the Corridor included a defined "area of disturbance" which includes areas outside cut and fill slopes but potentially subject to grading, vehicular activity and other disturbances associated with the construction of the Corridor. The proposed project's limit of disturbance established for the environmental analysis is indicated on the Draft EIR/EIS graphics as a dashed line on either side of the Corridor. The area of disturbance maps were then overlain onto the vegetation maps and the amount of acreage of each vegetation type impacted was measured using an elec- tronic planimeter. This is a standard technique that has been developed and adopted for use in wetland analysis for estimating acreages of existing and impacted wetland habitats. This technique has been extended to upland habitats for similar uses. 01/31/91(TCA901B%INDEX-B) B - 8 There was no attempt to quantify the numbers of birds along the Corridor. The impacts to the California gnatcatcher were assessed on the basis of habitat lost. The acreage of coastal sage scrub lost as a result of the Corridor construction was calculated and the total included in the Draft EIR/EIS. Surveys for gnatcatchers and other species were performed in 1983 by P&D Tech- nologies, with follow-up surveys in 1985, 1988 and 1990. One pair of gnatcat- chers was seen in 1983, and 20 territorial males in 1988. Six of the males seen in 1988 belonged to a breeding pair, and were either nesting or raising young within the limits of disturbance. No gnatcatchers were recorded in the 1985 study, which concentrated on riparian species in the Bonita Reservoir. The 1990 study discovered 14 birds along the route from MacArthur Boulevard to El Toro Road. Quantification of the numbers of birds observed is useful, but does not neces- sarily represent the total numbers of birds present within the Corridor align- ment. Because it is difficult to extrapolate from numbers of individuals observed to an accurate estimate of population, and because construction of the Corridor is expected to impact habitat but not directly affect individuals, impacts were assessed in terms of the amounts of habitat lost, rather than the potential loss of individuals. See Responses to Comments 1-1-25 and 2-9-12 in this Chapter for concerns re- garding survey techniques and the area covered. 1-1-29 Refer to Response to Comment 4-17-18 under Construction Impacts. 1-1-30 The impacts discussed in the comment have been addressed in the Draft EIR/EIS. See Response to Comment 1-1-28 in this Chapter for concerns regarding construc- tion related impacts of erosion, vehicle/heavy equipment parking and construction. The impacts of noise are discussed on pages 4-66 through 4-68 of the Draft EIR/EIS. Refer to Mitigation Measures 6-3 through 6-12 and 17-1 through 17-21 in the Draft EIR/EIS. 1-1-32 Refer to Response to Comment 3-5-97 in this Chapter. 01/31/91(TCA9018,INDEX-8) B - 9 0 1-1-33 Regarding revegetation to Response to Comment Mitigation Measure 6-5 They are not intended sage scrub, and there i 1-1-34 of graded slopes with coastal sage scrub species, refer 3-5-97 in this Chapter. The procedures discussed in are intended to minimize impacts during construction. as mitigation for complete replacement of lost coastal s no statement to that effect in the Draft EIR/EIS. Refer to Responses to Comments 1-1-16 and 3-5-97 in this Chapter. 1-1-35 The Draft EIR/EIS text has been revised in Section 4.6 to reflect the correct wetland impact acreages. 1-1-37. 1-1-39 The Final EIS will contain the Section 404 (b)(1) evaluation per Corps require- ments. 1-1-46 Numerous discussions have been held with representatives from the U.S. Fish and Wildlife Service regarding the least environmentally damaging alignment possi- ble for the Corridor within the Bonita Canyon area. The alignment shown for the Corridor in the Draft EIR/EIS represents the coordinated efforts of the Transportation Corridor Agencies, the USFWS, the County of Orange, the Califor- nia Department of Fish and Game, and others to achieve a balanced design that takes all environmental factors into consideration, including minimization of impacts to wetlands habitat. Elevating the Corridor to span the entire Bonita Creek/Canyon area is consid- ered infeasible. Approximately 30 feet below ground level, the area is under- laid with a layer of compressible bay mud that would make a raised structure unstable. An additional factor against elevating the Corridor in the Bonita Creek/Canyon area is the proximity of the site to the Newport Inglewood Fault. Refer to the Draft Wetlands Mitigation Plan for replacement of wetlands habitat in Bonita Canyon and to Response to Comment 2-7-3 in this Chapter. Refer to the Analysis of Avoidance Alternatives - Wetlands Impacts in Technical Study No. 5 of the Draft EIR/EIS. 01/31/91(TCA9018%INDEX-B) B- 1 0 0 1-1-47 Refer to Responses to Comments 1-1-23, 1-1-25 and 3-5-97 in this Chapter. 1-1-48 Refer to Responses to Comments 1-1-50 and 2-7-3 in this Chapter. 1-1-49 Refer to Response to Comment 1-1-50 in this Chapter. 1-1-50, 2-5-7. 2-9-22, 2-9-23, 2-9-34..3-8-49, 3-8-142, 3-8-143, 3-9-4. 3-9-5. 3-9-14, 4-4-4. 4-19-14, 4-20-1. 4-21-31, 4-24-12, 4-32-18, 4-32-30, 4-32-46, 4- 33-59, 4-35-1. 4-35-3. 7-12-6. 7-30-1a. 7-30-1c, 7-30-3. 7-30-4. 7-30-5. 7-30- 6. 7-30-7. 7-30-8. 7-52-2. 7-84-32, 7-88-28 through 40, 7-105-3. 7-109-8. 7- 114-23, 7-114-24, 7-120-2. 7-124-2. 7-128-2. 7-141-3 As discussed in the Draft EIR/EIS, Section 4.6, and the Technical Studies docu- ment, Volume II, a wildlife crossing study (Technical Memorandum 3-20) was con- ducted to determine the feasibility of implementing a crossing opportun.i-ty for free ranging wildlife in the Corridor vicinity. The study examined several factors pertaining to placement of crossing facilities, including existing and future permanent open space areas, known wildlife movement patterns, topograph- ical features, grade of crossings, animal safety and structural design require- ments of the Corridor where it intersects with wildlife movement routes. In response to the comments made regarding wildlife movement corridors and the need for more crossings, two crossings will be incorporated into the project design in addition to the one discussed in the Draft EIR/EIS at the interface of the Shady and Emerald Canyons. The two additional crossings would be locat- ed in Laguna Canyon and at the head of the western fork of Bommer Canyon. All three crossings will be under bridges that will be designed to provide an open view to the other side. The design will minimize the intrusion of bridge structures into the crossing. Each bridge location will require varying design parameters, however the following criteria for the crossings will be applied at a minimum: • The bottom of the crossing will be no less than 20 feet wide, and the distance from the ground to the bottom of the bridge should be no less than 17 feet in height. 01/31/91(TCA9018%INDEX-B) B - 1 1 • The roadway will have an opening in the middle to allow light to come through. • For those crossings that are at a minimum of 20 feet in width, the crossing will be shaped like an hour glass, with the greatest con- striction in the middle and the sides flaring out at either end. This design is intended to minimize the length of the narrowest sec- tion of the crossing under the Corridor. The flaring will begin as close to the center of the roadway bridge as possible. • The corridor will be fenced at the wildlife crossings and in adjacent open space areas. The fence will be seven feet high with a mesh no greater than six inches in size. These criteria are recommendations of Caltrans biologists with experience in incorporation of wildlife crossing features into highway design. These three crossing locations, in addition to design modifications in the Bonita Creek area downstream of the Bonita Creek Reservoir (refer to Response to Comment 2- 7-3 in this Chapter), will reduce the Corridor's impact on wildlife movement through the project study area, however not to below a level of significance. In addition to these three wildlife crossings, the Corridor design includes bridges at San Diego Creek, Al i so Creek and Oso Creek. These areas are not proposed as wildlife crossings, however they would provide that opportunity. Accordingly, Mitigation Measure 6-16 has been modified as follows: 6-16 Project design will include bridges at the following canyons to allow wildlife to cross under the Corridor: • Laguna Canyon adjacent to Laguna Canyon Road (approximately Station No. 790); • Canyon between Shady and Laurel Canyons (approximately Station No. 877); and • Westerly fork of Bommer Canyon (approximately Station No. 935). The following features will be designed as feasible for each bridge loca- tion: 01/31/91(TCA9018%INDEX-B) B - 1 2 0 0 • The design will minimize intrusion of the bridge structures into the crossing. • The bottom of the crossing will be no less than 20 feet wide, and the distance to the bottom of the bridge should be no less than 17 feet in height. • The roadway will have an opening in the middle to allow light to come through. • The crossing will be shaped like an hour glass, with the greatest constriction in the middle and the sides flaring out at either end. This design is intended to minimize the length of the narrowest sec- tion of the crossing under the Corridor. The flaring will begin as close to the center of the roadway bridge as possible. • The corridor will be fenced at the wildlife crossings and in adjacent open space areas. The fence will be seven feet high with a mesh no greater than six inches in size. Final project design plans will include final locations and specifications of these wildlife crossings. The following discussion provides background information on the undercrossing features as proposed in the Draft EIR/EIS. The previous environmental document for the Corridor (DEIR No. 494) proposed a wildlife overcrossing in the Shady/Bommer Canyon area in conjunction with recreational hiking/bicycling trails uses. During the preparation of the current Draft EIR/EIS, biologists from the California Department of Fish and Game and the U.S. Fish and Wildlife Service were contacted regarding the pref- erence of undercrossings vs. overcrossings for feasibility of use by large free ranging mammals in the San Joaquin Hills region. There was no consensus among those contacted as to a preferred type of facility, as there has not yet been an extensive implementation of such crossings, thus few cases from which to gauge their success. However, undercrossings have been incorporated by Cal - trans into the design of several other State highways (SR 52 and SR 395) as well as private development projects with successful use by migratory and non - migratory species. Refer to the Caltrans memorandum attached to the Wildlife Crossing Technical Memo (T.M. 3-20) in Technical Report No. 5, Volume II of the Technical Studies. 01/31/91(TCA901B%INDEX-B) B - 1 3 Refer also to Response to Comment 2-7-3 in this Chapter regarding the Corridor design over Bonita Creek to facilitate wildlife movement through that area. In regard to Comment 3-9-4 in this Chapter, the entire length of the Corridor was evaluated for suitable topographical locations for wildlife crossings. In order to provide the most likely locations where wildlife would utilize a crossing feature, it is preferable that the topography of the area on either side of the Corridor superstructure be lower than the roadway grade. The undercrossing would then be constructed at approximately the same grade as existing topography. The least amount of grade change for animal approaches is preferred so that access is facilitated. This criterion was used in selecting the sites of the two additional wildlife crossings. In regard to Comment 3-9-5 in this Chapter, the conclusions cited from the Wildlife Crossing Memorandum regarding likelihood of wildlife movement into certain areas or across Corridor structures took into consideration the wild- life movement patterns for the region as illustrated in Figure 3.6.6 of the • Draft EIR/EIS. In addition, the conclusions are basically logical assumptions of constraints posed by traffic and structural barriers which do not require a biologist's expertise. However, additional wildlife crossings are being imple- mented as part of project design, as discussed previously. In reference to Comment 4-20-1, the mountain lion accident referenced by some commentators did not occur under similar conditions as would be in the Corridor alignment vicinity. That accident occurred on State Route 74 which does not provide specific animal access crossing facilities such as undercrossings or overcrossings. The design of the three Corridor undercrossings would incorpo- rate bridges over drainage areas, where identified above, with chain link fencing on either side of the opening to help guide animals under the Corridor. In reference to Comments 4-32-18 and 4-32-46, cost is a factor taken into consideration for provision of crossings; however, three crossings are now being provided. The final design of the wildlife crossings has not yet been determined. The recommendations made in Comments 2-9-34, 7-30-7 and 7-30-8 in this Chapter will be taken into account in the final design. It should be noted that the wild- life crossings are bridges and will be based on similar designs developed for deer and used with success along the State highways mentioned previously. Recommendations by the resource agencies included the provision of a skylight to provide light in an otherwise shaded opening. is 01/31/91(TCA9018%INDEX-S) B - 14 0 0 In response to Comments 7-88-30, 7-88-31, and 7-88-32 in this Chapter, no grate is proposed for the undercrossings because the undercrossings are bridges. It is unknown whether undercrossings would act as prey traps for predators. Comment 7-88-31 makes this assumption without providing examples. Most preda- tors in the San Joaquin Hills (coyote, fox, etc.) rarely sit and wait for prey to come within range. These species generally run live prey down or feed on carrion, and their physical build and other adaptations have developed in response to this hunting behavior. Comment 7-88-32 notes that much of the movement of wildlife occurs in the pre- dawn or night hours, when light is a minimum. The latter statement indicates that wildlife move during the dark, which should not inhibit their movement under the Corridor. However, the undercrossings are not anticipated to be very dark, as the intention of the design is to ensure that light can be seen from either end. In addition, a skylight has been proposed to further admit light into the undercrossings, although a prior commentator had recommended against such a design. 1-1-51 See Response to Comment 2-7-3 in this Chapter. 1-1-52, 1-1-53, 1-1-54, 7-88-54, 7-88=55, 7-88-56, 7-141-4 Section 4.6 of the Draft EIR/EIS discusses potential noise impacts upon wild- life (p. 4-66) The conclusion in the Draft EIR/EIS that noise impacts from the Corridor would not be significant was based upon the premise that a reduction of wildlife numbers in the vicinity of the Corridor would occur due to the physical construction and presence of the Corridor. Noise levels from the Corridor would contribute to the overall effects of partial reduction of wild- life use of the area. The degree to which wildlife will reinhabit the area is dependent upon the sensitivity of individual species. The studies referenced by the commentator were neither attached nor identified; therefore, the valid- ity of the statements regarding the impacts of 60 dB noise levels on avian species cannot be verified. However, due to the concerns expressed in this and other comments, noise impacts to wildlife species will be taken into consider- ation as part of the design for revegetation of habitat mitigation areas (e.g. proximity of mitigation areas to the Corridor). Refer to Responses to Comments 1-1-57 and 3-5-109 in this Chapter. Regarding potential impacts to the vireo, see Responses to Comments 1-1-16 and 1-1-22 in this Chapter. Regarding Comment 7-141-4, detailed analysis of potential impacts from noise on wildlife breeding, sterility, mortality rates, litter sizes, etc. by species, 01/31/91(TCA9018%INDEX-B) B - 1 5 0 were not conducted as part of the Biological Assessment for the project. This information would not alter the stated conclusions and possible mitigation per- taining to noise effects. 1-1-55. 1-1-56 The potential impacts mentioned in the comment related to human presence in the Corridor area would pertain to a project's growth inducement effects. The Draft EIR/EIS concludes that the proposed Corridor would not induce growth; therefore, these impacts are not anticipated to occur as a result of this project. 1-1-57. 4-28-35 Refer to Response to Comment 1-1-16 in this Chapter. The Resource Management Plan and Draft Wetlands Mitigation Plan will be prepared in consultation with (and reviewed by) the USFWS, the California Department of Fish and Game and the EPA. Mitigation Measure 6-19 has been added as follows: 6-19 A Resource Management Plan will be prepared by the Project Biologist(s) prior to construction to specify design and implementation of biotic mitigation measures, including habitat replacement and revegetation, protection during construction, performance (growth) standards, mainten- ance criteria and monitoring requirements. The Wetlands Mitigation Plan (Mitigation Measure 7-2) and the native vegetation portion of the Land- scape Plan (Mitigation Measure 15-14) will be considered components of the Resource Management Plan. The Draft Resource Management Plan will be reviewed by the U.S. Fish and Wildlife Service and the California Depart- ment of Fish and Game, and the final plan will be approved by the TCA Board prior to project construction. The primary goal of the Resource Management Plan will be to ensure the long-term perpetuation of the existing diversity of natural wetland and upland habitats in the project area and adjacent urban interface zone. This will be accomplished through the restoration of impacted habitats to replicate former habitat values. The Resource Management Plan will contain the following: Per Mitigation Measures 6-12, 6-13, 6-15 and 7-3: planting specifi- cations, including plant palettes, numbers, container sizes and spac- ing of plantings; irrigation specifications (type, frequency); site 01/31/91(TCA901B%INDEX-B) B - 1 6 • preparation requirements (e.g., grading, water flow, soil treat- ments); planting techniques and recommended planting times; • Replacement ratios for oak woodland plantings will be determined by the Project Biologist in conjunction with biologists from the Cali- fornia Department of Fish and Game and the U.S. Fish and Wildlife Service. Areas to be vegetated with oak woodland plant communities will be designed for north facing fill slopes and/or graded drainage; • Sources of plant materials and methods of propagation; • Specification of parameters for the determination of the amount of replacement habitat, including the indirect effects of noise from the Corridor; • Specification of parameters for maintenance and monitoring of re- established habitats, including weed control measures, frequency of field checks and monitoring reports. Specification of performance standards for growth of re-established plant communities and cut slopes per the following guidelines: Riparian Woodland (Based upon CDFG requirements per recent streambed alteration agreements) • Two years after planting, the tree canopy will be 50% or great- er. The standard for tree height will be seven to nine feet for sycamore, cottonwood, black willow, red willow, and golden wil- low and six feet for arroyo willow. Mean height will reach or exceed this standard in two years; • Five years after planting, the tree canopy cover will be 90% or greater. The standard for tree height will be 13 to 15 feet for sycamore, cottonwood, red willow, arroyo willow and golden wil- low and 18 feet for black willow. At least 90% of the canopy trees will reach or exceed this height in five years. Canopy trees are defined as those that contribute to the measured can- opy cover. Oak Woodland • After one year, 80% of all plantings will survive. • 01/31/91(TCA901B•+INDEX-B) B-17 After three years to five years, 60% of all plantings will sur- vive. The following growth standards shall apply: Height After Three years Five years 1 gallon 3 feet 6 feet 5 gallon 5 feet 7-9 feet 15 gallon 6-7 feet 10-12 feet Canopy coverage to be 15% after three years and 25% after five years. For relocated oak trees: 60% will survive after five years, with all die -back trees being replaced as necessary to achieve the performance standards. Tree replacement will be approved per the same procedure established above for initial plantings. Coastal Sage Scrub The goal of the coastal sage scrub mitigation will be to repli- cate the existing distribution patterns and relative proportions of key coastal sage scrub species within the impacted habitat; therefore, the mitigation design will require detailed transects of each revegetation site prior to Corridor construction to determine the existing frequencies of those species as measured by percent cover. If the site is severely degraded, frequency and distribution of species should be determined from adjacent areas. Rather than assessing overall site coverage or a per- centage survival of plantings, performance standards will assess the progress of the revegetation toward achieving the respective frequencies and distribution. Because different species have different growth patterns, performance will vary from site to site, depending on which species have been targeted. In gener- al, after five years the percentage of cover of each key species should be within 20% of the existing condition. Protection of seeds and soil will be accomplished through the use of a short- term pioneer species such as Plantago insularis, which will provide rapid site coverage but will not compete with native plantings in the long term. 01/31/91(TCA9018%INDEX-8) B - 1 8 • • Coordination between UCI and TCA regarding planting of addition- al coastal sage scrub within the campus Ecological Reserve. • Remedial measures to be taken if performance standards are not met; • Measures for topsoil preservation and erosion control; • Design of protective fencing around Environmentally Sensitive Areas (ESAs) and construction staging areas as designated by the Project Biologist(s) (per Mitigation Measure 6-2); • Specification of locations and quantities .of gallinaceous guz- zlers (catch basin/watering devices); specification of monitor- ing of water levels in guzzlers (per Mitigation Measure 6-14); • Specification of design, quantity and location of raptor roost- ing sites (per Mitigation Measure 6-17); .>• Conduct tree survey to identify trees to be removed by construc- tion, and trees to be protected as wildlife habitat (e.g., roosting sites) (per Mitigation Measure 15-15); determine loca- tions for planting of specimen trees, such as interchanges, overcrossing embankments and park and ride lots; • Develop criteria for selection of specimen trees to include minimum trunk diameter, crown diameter, height, overall health and other factors per the Project Biologist; • Specification of the purpose, type, frequency and extent of chemical use for insect and disease control operations as part of vegetative maintenance within sensitive habitat areas; • Specification of the purpose, type, frequency and extent of control burning for non-native landscape maintenance; • Mitigation plan implementation financing. 1-1-58 The referenced document will be reviewed prior to initiation of the Section 7 Consultation process. 01/31/91(TCA9018':INDEX-B) B-19 0 1-1-59, 1-1-61 The Water Quality Analysis contained in Volume I of the Technical Studies attached to the Draft EIR/EIS concluded that cumulative water quality impacts from development within the project watersheds could be significant depending upon duration and intensity of storm events. However, the analysis also con- cluded that successful implementation of the Runoff Management Plan would reduce the estimated pollutant levels in downstream drainages to below a level of significance per Regional Water Quality Control Board (RWQCB) standards. The Regional Water Quality Control Boards will review and provide comments on preliminary versions of the RMP prior to the final version. The Draft EIR/EIS also concluded, however, that project alterations to stream - beds and natural and beneficial floodplain values (including wildlife movement corridors) would cause significant unavoidable impacts. Regarding Comment 1-1-61, refer to Response to Comment 1-1-16 in this Chapter. 1-1-63 0 The Runoff Management Plan will contain specific measures to reduce aquatic pollutants generated by the Corridor to a level below significance as deter- mined by RWQCB standards. 1-1-64 The Erosion and Siltation Control Plan will provide specific measures to reduce the impacts of erosion and siltation upon downstream waterways and wetland habitats. Mitigation Measure 17-12 has been amended as follows: 17-12 Prior to approval of final design, an Erosion and Siltation Control Plan will be prepared by the project engineers and submitted for review to the Santa Ana and San Diego Regional Water Quality Control Boards. Construction. To prevent construction caused erosion on the Corridor adjacent to streets, highways, developed land, streams and swales, the following measures will be implemented: I*01/31/91(TCA9018%INDEX-B) B - 2 0 s All project related grading will be performed in accordance with standards and criteria specified in the Caltrans Highway Design Manual and the Orange County Grading Ordinance. Unless otherwise approved by the engineer in writing, the con- tractor shall not expose a total area of erodible earth materi- al, which may cause water pollution, exceeding 750,000 square feet for each separate location, operation, or spread of equip- ment before either temporary or permanent erosion control mea- sures are accomplished. Possible measures include mulching, seeding, landscaping, interceptors, diversions, benches and terrace drains. • Where erosion which will cause water pollution is probable due to the nature of the material or the season of the year, the contractor's operations shall be so scheduled that permanent erosion and sediment control features will be installed concur- rently with or immediately following grading operations. • The contractor shall also conform to the following provisions: 1. Where working areas encroach on live streams, barriers adequate to prevent the flow of muddy water into streams shall be constructed and maintained between working. areas and streams, and during construction of such barriers, mud- dying of streams shall be held to a minimum. 2. Removal of material from beneath a flowing stream shall not be commenced until adequate means, such as a bypass chan- nel, are provided to carry the stream free from mud or silt around the removal operations. 3. Before starting any work on the project, the Contractor shall submit, for acceptance by the Engineer, a program to control water pollution effectively during construction of the project. Such program shall show -the schedule for the erosion control work included in the contract and for all water pollution control measures which the Contractor pro- poses to take in connection with construction of the pro- ject to minimize the effects of his operations upon adja- cent streams and other bodies of water. The Contractor shall not perform any clearing and grubbing or earthwork on the project, other than that specifically authorized in 01/31/91(TCA901B%INDEX-B) B - 2 1 0 writing by the Engineer, until such program has been ac- cepted. 4. Water containing mud of silt from aggregate washing or other operations shall be treated by filtration, or reten- tion in a settling pond, or ponds, adequate to 'prevent muddy water from entering live streams. 5. Cut and fill slopes will not be steeper than 2:1, unless a thorough geological and engineering analysis indicates that steeper slopes are safe and erosion control measures are specified. 6. Earthen or paved interceptors and diversions will be in- stalled at the top of the cut or fill slopes where there is a potential for surface runoff onto constructed slopes. 7. Permanent benches and/or terrace drains will be installed • in accordance with TCA/CDMG standards and noted on final plans. 8. Fills placed against watercourses will have suitable pro- tection against erosion during storm flows, such as riprap, protective walls and culverts. 9. Excavated and/or stockpiled materials will not be deposited or stored in or alongside watercourses where the materials can be washed away by high water or storm runoff, or become a source for off -site sediment damage. • Facilities for control of erosion will be indicated on a plan pre- pared by the contractor and presented to the TCA prior to the begin- ning of each storm season. The facilities shall include: 1. Sandbag scheme 2. Areas for temporary planting 3. Areas to be controlled by application of straw or jute mesh 4. Specific location and size of desilting basins 01/31/91(TCA9018%INDEX-B) B - 2 2 0 Project. Erosion will be controlled during project operation through the following measures: • In the areas where geotechnical data indicate that there is a high potential for erosion, landscaping will be chosen which retains the erodible soils. Additionally, the landscaping will be established with the aid of fiber blankets such as "hold-n- grow" or jute mesh. • Where there is a potential that erosion may continue in spite of the holding capability of the landscaping and fiber blankets, additional sizing of storm basin will be provided if unusual data indicate that conditions warrant. Based on extensive geo- technical testing, TCA is not aware of any areas of this nature. • Performance standards to ensure adequate control of erosion and siltation downstream of the Corridor include maintenance of pre - construction conditions. • If after assessment of topsoil resistance to flow in downstream areas, the outlet velocity of culverts and drainage ditches is found to be excessive, then energy dissipators will be designed to intercept the flow pri'br to its release downstream of the culvert. Dissipators may be in the form of 1) velocity reducer rings inside the culvert where they will have no visual impact on the surroundings, 2) rock slope protection designed to blend in with the natural scenery, or 3) impact type concrete stilling basins. Increased runoff during storm conditions will be conveyed to a proposed retarding basin where the peak flow will be reduced to pre -project levels or less. TCA will sequence construction of the basins which assures that they can be operational during grading of the Corridor. The TCA is planning to construct a small retention basin (with approximate capacity for 2,300 acre feet) in the Laurel Canyon vicinity to retain the runoff from the Corridor project. The basin will be designed and construc- ted to meet the following standards: 1. Retention of all Corridor runoff from all frequency storms up to and including the 100-year storm (2-yr, 5-yr..100- yr). 01/31/91(TCA9018%INDEX-8) B - 23 • 2. The retention will be accomplished by flow -through basins to avoid the possibility of setting weirs at elevations which might not capture smaller, more frequent storms. 3. Enlargement of the E1 Toro Road basin if required to meet the criteria described above. 4. Use of standard design criteria for energy dissipation at basin outlets which return flows to velocities normally occurring in the downstream conditions. This criteria will 1-1-66. 4-19-8 include but not be limited to OCFCD design criteria. Refer to Section 7.0 of the Draft EIR/EIS, which states: "The significant effects of the Eastern and Foothill Transportation Corridors, in conjunction with the effects of the San Joaquin Hills Transportation Corridor, may be considered cumulatively significant . on the regional environment. The Traffic and Air Quality Analyses prepared for this Draft EIR/EIS assume construction of the ETC and FTC, thereby taking into account the cumulative effects of the three Corridors." Regarding Comment 1-1-66, with respect to the cumulative effects on regional open space and wildlife from the three Corridors, as well as from development throughout Southern Orange County, please refer to Response to Comment 2-7-14 in this Chapter. Also refer to Response to Comment 1-2-2 under Cumulative Impacts which addresses requests to evaluate the environmental impacts of the three toll roads in one document. 1-2-7 Refer to Response to Comment 3-5-109 in this Chapter. Disposal sites for dredged material will be determined as part of the 404 Permit application process. The Permit application will be submitted to the Corps of Engineers with the Draft Wetlands Mitigation Plan. The EIR/EIS addresses the requirements of Section 404 of the Clean Water Act in Chapters 4.3, 4.6, 4.7 and in Technical Report No. 5. 01/31/91(TCA901B%INDEX-B) B - 2 4 I* s 1-2-13 Refer to Response to Comment 1-2-7 in this Chapter. The EIR/EIS addresses the requirements of Section 404 of the Clean Water Act in Chapters 4.7, 4.3, 4.6 and in Technical Report No. 5. The TCA has verified through returned receipt for certified mail that the District Engineer at the U.S. Army Corps of Engin- eers (at 300 N. Los Angeles Street, Los Angeles, California) received a copy of the Draft EIR/EIS and Technical Studies Volumes I and II. 1-2-48, 1-2-54, 1-2-56, 1-2-58. 1-2-66, 4-22-26, 4-28-13 Compliance with the regulations implementing Section 4O4(b)(1) of the Clean Water Act will be achieved through coordination with the Corps as part of the Section 404 permitting process. However, the Corps has been aware of the. design and development of design alternatives over the last several years. The information about wetlands which will be impacted by the Corridor project was previously provided to the Los Angeles District of the U.S. Army Corps of Engineers as follows: 1. Meeting at the Caltrans District 7 Office with Ms. Cheryl Connel of the Los Angeles District U.S. Army Corps of Engineers on June 12, 1987, to review the maps and analysis relative to wetlands expected to be impacted by the Corridor project. 2. Meeting in the field with Ms. Connel on June 19, 1987, to review wetlands with the biological consultant working on the Corridor pro- ject. 3. Letter of March 17, 1988, from W. B. Ballentine, Chief, Environmental Planning Branch, District 7, Caltrans to Charles Holt, Chief, Regula- tory Branch, U.S. Army Corps of Engineers Los Angeles District, which presented the maps and information regarding wetlands expected to be impacted by the Corridor project. 4. Meeting in the office of LSA Associates, Inc. on August 18, 1988, with Mr. Larry Smith of the Regulatory Branch of the Los Angeles District U.S. Army Corps of Engineers, together with representatives of the U.S. Environmental Protection Agency, U.S. Fish and Wildlife Service, California Department of Fish and Game, Caltrans District 7, Federal Highway Administration, various local agencies involved and consultants working on the Corridor project. At this meeting an update, review and discussion of the analysis and mapping of the 01/31/91(TCA901B%1NDEX-B) B- 25 0 wetlands expected to be impacted by the Corridor project were con- ducted. FHWA and TCA are currently coordinating with the Corps of Engineers, Fish and Wildlife Service and Department of Fish and Game regarding the wetlands mitiga- tion/Section 404 permit process. In addition, a Pre -Discharge Notification has been sent to the Corps. Refer to Response to Comment 1-2-13 in this Chapter regarding the Corps' receipt of the Draft EIR/EIS for review. Refer to Re- sponse to Comment 1-2-48. The Corps had the opportunity to verify the wetlands delineation and jurisdiction of the waters of the U.S. through review of the Draft EIR/EIS and, additionally, in response to the Pre -Discharge Notification. Regarding the comment that the proposed project does not comply with the Clean Water Act because practicable, less environmentally damaging alternatives are available, refer to the Analysis of Avoidance Alternatives - Wetlands Impacts in Technical Study No. 5. This report provides an area by area analysis of the Phase I route alternatives presented in EIR No. 267 specific to potential impacts to wetland areas. In addition, the Draft EIR/EIS summarizes this • analysis beginning on page 4-83. The analysis contained in EIR No. 267 was used to refine the alignment alternatives for selection of the Phase II project alignment, with several route variations as evaluated in DEIR No. 494. As required by CEQA and the Clean Water Act, the analysis evaluated whether any of the previously considered route alignments would be practicable alternatives which would have fewer adverse impacts to wetlands habitat within the Corridor area of affect. The analysis demonstrates that the project alignment repre- sents the least damaging alternative to wetlands in consideration of all envir- onmental, structural and cost factors. The EPA does not specify other less damaging alternatives than those already considered in the Phase I and II evaluations. Per the comment regarding Section 7 Consultation (and avoidance alternatives), refer to Response to Comment 1-1-16 of this Chapter. The Draft EIR/EIS analyzes the potential impacts to the aquatic environment in Sections 4.3 and 4.7. The Runoff Management Plan proposed as mitigation for potential project impacts of water quality and runoff management will be de- signed to reduce project impacts to below a level of significance in accordance with Regional Water Quality Control Board standards. Refer to Response to Comment 6-17-40 under Water Resources. The Draft EIR/EIS does propose measures to reduce project impacts to wetlands. Refer to Mitigation Measures 7-1 through 7-10, and Response to Comment 3-5-109 of this Chapter. 01/31/91(TCA9018%INDEX-8) B- 2 6 • 9 Regarding the Draft EIR/EIS analysis of cumulative impacts, Section 7.0 of the Draft EIR/EIS made the following conclusions regarding cumulative impacts to biological resources: "Although the proposed project, in conjunction with future anticipated projects, would result in a cumulative reduction in biological resources in the region, the future projects also serve as vehicles for implementing the County's regional open space program which includes a 16,000 acre permanent open space in the area of the Corridor. Due to the existing public policies, impacts to biological resources.in this region have been partially mitigated. The United States Fish and Wildlife Service and the California Department of Fish and Game policies for no net loss of wetland habitat provide further mitigation requirements. Impacts to wetlands will be fully mitigated as the result of protection, enhancement or replace- ment. Although the preservation of open space and mitigation for loss of wetland habitat, and additional proposed mitigation measures, would par- tially mitigate cumulative impacts to biological resources, the project would contribute to the following: 1) cumulative loss of Category 3 and 4 habitat; 2) elimination of individuals of animal species; 3) disruption of predator/prey relationships; 4) decrease in species diversity due to variability of habitat; and 5) decrease in the total number of habitable acreage." Also refer to Response to Comment 1-2-2 under Cumulative Impacts. The Draft EIR/EIS does include potential impacts to "Waters of the United States" which include wetlands habitats. TCA has not formally requested deter- mination of jurisdiction by the Corps. The Corps' determination may add to or amend our findings as part of the Pre -Discharge Notification which has been sent to the Corps for review. The majority of stream courses evaluated for the wetlands impact analysis contained in the Draft EIR/EIS happened to contain riparian habitat. Figures 4.7.1 through 4.7.7 in Section 4.7 of the Draft EIR/EIS differentiate several types of wetlands habitat. The category of Riverine Intermittent Streambed in- cludes some drainages which contain little wetlands vegetation, yet are con- sidered waters of the U.S. within the Corridor's potential area of disturbance. Prior to issuance of the 404 Permit, the Corps requires receipt of certifica- tion of Section 401 of the Clean Water Act by the Regional Water Quality Con- trol Board (RWQCB). As indicated in Response 6-17-40 under Water Resources, the Runoff Management Plan will be reviewed by the RWQCB prior to finalization of 01/31/91(TCA9018%INDEX-8) B - 2 7 the plan and project construction. TCA will send a request for certification to the RWQCB with the Runoff Management Plan for their review. The Draft EIR/EIS acknowledges the significance of impacts to any amount of wetlands habitat. Refer to Responses to Comments 1-1-13 and 3-5-109 in this Chapter. The referenced wetland area identified in Appendix 1 of Technical Study No. 5 (Site No. 17) is not located within the Corridor area of disturbance, and therefore is not included in Table 4.7.A in the Draft EIR/EIS. 1-2-49, 1-2-50 In the 1979 EIR No. 267, alternative alignments avoiding the Bonita Reservoir by passing to the west of it were given consideration. The westerly alignments pose the following disadvantages: 1. In order to pass west of the Reservoir, it would be necessary to cross Bonita Creek downstream of the Reservoir. This crossing would create destruction of wetlands habitat acreage. 2. Passing westerly of the Reservoir necessarily forces the Corridor to impact the Coyote Canyon landfill because highway geometrics meeting appropriate design standards for horizontal curves cannot be provided which would avoid the boundaries. Impacting the landfill has several problems including: A. A potential for uncovering hazardous waste. B. A potential for having waste polluted waters run down the corri- dor near Bonita Canyon wetlands (which are lower in elevation). C. Severe geotechnical problems caused by unsuitable materials in the landfill. D. A Solid Waste Facility Permit would be required by The Califor- nia Integrated Waste Management Board to excavate solid waste prior to construction of the Corridor; permit procedure would disrupt the closure/post-closure plan currently in process for the landfill. 3. Westerly alignments would create more significant noise and visual impacts to residences in Harbor View Knoll community. 0 0 01/31/91(TCA9018%INDEX-B) B - 2 8 0 0 Easterly alternative alignments (passing the Corridor east of the Reservoir) were also evaluated. Alignment alternatives east of the Reservoir present constraints on both sides of the Corridor. Westerly, these constraints are the reservoir and Bonita Creek downstream. East of the alignment, the land is owned by the University of California, Irvine, and operated as their Ecological Reserve. The Universi- ty is on record advising the TCA that a more easterly alignment is infeasible due to the taking of the Ecological Reserve which provides habitat for the following valuable resources: 1. California gnatcatcher (bird) 2. Cactus wren (bird) 3. Dudleya multicaulis (plant) 4. Chorizanthe staticoides chrysacantha (plant). The alignment proposed by TCA attempts to minimize impact upon UCI's Ecological Reserve and Bonita Reservoir by making the maximum use of existing road right- of-way (the existing Bonita Canyon Road). In addition to the Ecological Reserve on University land, there are archaeolog- ical sites east of the Corridor's selected alignment. Impacts to these sites would require Section 106 review and clearances; if the Corridor were to be realigned in this area. The second line under the discussion of Practicability of Alternatives to Avoid Encroachments or Support Probable Incompatible Floodplain Development (page 4- 25 of the Draft EIR/EIS) has been amended as follows: "These various constraints are discussed in Sections 3.5, 3.7, 3.10 and in Appendix A." The constraints posed to selection of the least environmentally damaging align- ment by existing development, potential noise impacts, cultural resources, biological resources, existing recreational areas and planned open space/ conservation need to be considered equally in the determining of the practica- bility of alternative alignments. Refer to Response to Comment 1-1-46 in this Chapter pertaining to the infeasi- bility of elevating the structure through this area. 10 01/31/91(TCA9018%INDEX-B) B - 2 9 1-2-51 Previous environmental studies completed for this project examined a number of resources before setting the alignment. Most significant, wetlands resources in the Laguna Canyon area were found to be present on both sides of the Corri- dor. Hence, moving the Corridor away from the present impacts in a northerly direction would impact other riparian habitat of approximately the same size. This habitat is located approximately 400 feet northerly of the alignment and easterly of Laguna Canyon Road. Attempts to move the Corridor southerly would only increase the amount of impacted wetlands. In.fact, the alignment cannot be moved far enough in a southerly direction to escape the impacted wetlands because alignment geometry would be severely jeopardized. In addition, extreme southerly realignment would involve massive ridgeline grading in areas of slope instability westerly of Laguna Canyon Road. 1-2-52 Refer to Response to Comments 1-2-17 through 1-2-27 of this Chapter regarding practicability of the suggested alternatives. 1-2-53. 1-2-57 Refer to Response to Comment 1-1-46, 2-7-3 and 3-5-109 of this Chapter. -The Draft Wetlands Mitigation Plan provides for design of wetlands revegetation along Bonita Creek pursuant to replacement of the total amount of habitat impacted by the Corridor in that area. 1-2-55 The statements in the comment are documented in the Draft EIR/EIS as conclu- sions. Refer to Responses to Comments 2-7-3 and 3-5-109 of this Chapter. 1-2-61 Refer to Response to Comment 1-1-16 in this Chapter. 1-2-64 Refer to Response to Comment 1-1-16 in this Chapter regarding initiation of a Section 7 Consultation. A Biological Opinion will be issued by USFWS as a result of Section 7 Consultation. It must be emphasized that the only endan- gered species sited in the project area was a single least Bell's vireo. 01/31/91(TCA9016%INDEX-B) B- 3 0 1-2-65 Refer to Response to Comment 1-1-50 in this Chapter. 1-2-67 Refer to Response to Comment 2-7-14 of this Chapter. 2-6-1. 2-6-2. 2-6-3. 2-6-4. 2-6-5. The presence of the many -stemmed dudleya (Dudleya multicaulis), Orange County Turkish rugging (Chorizanthe staticoides chrysacantha) and California gnat - catcher within the portion of UCI crossed by the Corridor was noted in the Draft EIR/EIS. Surveys were conducted in 1983, 1985, 1987, 1988 and 1990 for these and other sensitive biological resources. The survey effort included work on the UCI campus. The two plant species and the gnatcatcher were located within this section of the Corridor alignment during these surveys. Prior to • project construction, as specified in Mitigation Measure 6-12, the presence or absence of individuals of these species will be verified. If found, appropri- ate mitigation will be implemented under the supervision of the Project Biol- ogist. The presence of the gnatcatcher in coastal sage scrub and saltbush scrub was discussed in the Biological Assessment, and impacts to this species were iden- tified. Mitigation for the gnatcatcher will include the replacement of coastal sage scrub habitat. The precise amount of replaced habitat (i.e., no net loss of habitat) cannot be determined until final design is complete. Potential replacement may compensate fully for impacts to coastal sage scrub and salt - brush scrub habitat. The Draft EIR/EIS and the Biological Assessment discuss impacts to the cactus wren per CEQA. Mitigation is not proposed for this species because the mitiga- tion for the gnatcatcher as part of Mitigation Measure 6-13 (refer to Response to Comment 3-5-97 in this Chapter) will partially function as mitigation for the cactus wren, since these two species share similar habitat types. It should be noted that the petition to the U.S. Fish and Wildlife Service to list the cactus wren as a sensitive species only includes populations in the extreme southern end of Orange County and not populations from the San Joaquin Hills. 0 01/31/91(TCA9018%INDEX-B) B - 3 1 2-7-1 The comment represents the opinion of its author and will be taken into consid- eration as part of the decision making process. 2-7-3. 2-7-4. 2-7-11, 2-9-22, 2-9-23, 4-32-15, 4-33-37, 6-17-44, 7-12-1. 7-12-2. 7-88-1. 7-88-2. 7-88-22, 7-88-28, 7-128-1. The Draft EIR/EIS and accompanying Biological Assessment report identify that the proposed project will contribute to the removal and fragmentation of wild- life habitat in general, including foraging habitat for raptors and thus will have a direct and cumulative impact upon regional reduction of open space habi- tat and wildlife individuals. Recent preliminary radio tracking work with coyotes conducted by the U.S. Fish and Wildlife Service has indicated that, in addition to crossing MacArthur at the Bonita Canyon Road/MacArthur intersection, there is at least some coyote movement from Upper Newport Bay through the Big Canyon Golf Course, across • MacArthur Boulevard and through other open space areas (including Pacific View Memorial Park) and likely to Buck Gully. Thus, the MacArthur/Bonita Canyon intersection is not the only connection between Upper Newport Bay/San Joaquin Marsh complex and the San Joaquin Hills. However, the following mitigation measure has been added: 6-21 The section of the Corridor containing the MacArthur interchange will be redesigned to more completely accommodate wildlife movement. The new alignment of MacArthur will cross over the Bonita Canyon drainage on a bridge, as will the two ramps associated with this new alignment. In addition, Bonita Creek will remain as an open channel, similar to the existing channel. By retaining Bonita Creek, and by providing a bridge structure for the Corridor, wildlife movement between Upper Newport Bay, San Joaquin Marsh, San Diego Creek and the San Joaquin Hills will be maintained. The Corridor will not block access to the Upper Newport Bay from the San Joa- quin Marsh area. With respect to coyotes being necessary to the ecology of the least tern and the light-footed clapper rail by controlling the red fox popula- tion, final Corridor design will allow continued coyote movement through this area. The value of Bonita Creek lies in its connections for wildlife movement between upstream and downstream habitat areas (i.e., San Joaquin Hills and Upper New- port Bay). Additionally, the creek/habitat corridor allows for exchange of 01/31/91(TCA9018%INDEX-8) B - 3 2 0 genetic material between populations, maintenance of the balance of preda- tor/prey relationship, and maintenance of a continuous connection between larger open space habitat areas upstream and downstream. The term keystone species used by the commentator is unfamiliar. If the refer- ence is to indicator species, coyotes have not previously been identified as such, since their adaptability to adverse changes in their environment renders them unlikely indicators of changing or degrading conditions. The subject of wildlife movement corridors is addressed in Section 4.6 of the Draft EIR/EIS and acknowledges that the proposed project would disrupt wildlife movement patterns in the project vicinity. As part of the project design, three wildlife crossing features will be provided to allow movement across the Corridor. The results of the feasibility study which analyzed this and other alternative crossing locations is discussed in the Draft EIR/EIS text and Response to Comment No. 1-1-50 in this Chapter. 2-7-5. 4-28-23 The comments reflect the opinion of the commentators that the Draft EIR/EIS does not adequately address the impacts to significant habitats and species which would result from construction of the Corridor. Refer to Response to Comment 1-1-25 in this Chapter and 2-6-7 under Project Descri.ption. 2-7-6. 4-31-12 The biological mitigation measures included in the proposed project have been designed by wildlife biologists for successful and complete mitigation of impacts to wetlands, sensitive plant species (many -stemmed dudleya [Dudleya multicaulis] and Orange County Turkish rugging [Chorizanthe staticoides chrysa- cantha]). Mitigation for the effect of nighttime lighting on nocturnal wild- life activity is discussed in Response to Comment 3-8-55 in this Chapter. The Draft EIR/EIS also identifies that there will be impacts that will be par- tially mitigated but will remain a significant impact of the project (refer to Table 4.1.A of the document). The purpose of the Draft EIR/EIS is to document the potential impacts and prescribe reasonable and most effective measures possible for consideration by the project decision makers. The last sentence of Comment 2-7-6 represents the opinion of the commentator, and will be taken into consideration by the decision makers. 01/31/91(TCA9018%INDEX-B) B - 3 3 2-7-7 The comment represents the opinion of the commentator and will be taken into consideration by the decision makers. Refer to Response to Comment No. 2-7-6 in this Chapter. 2-7-9. 7-86-34 See Response to Comment 2-7-3 in this Chapter. Much of the mitigation provided in the Draft EIR/EIS is based on previous practices.. The remaining measures were developed as the result of research and questioning of knowledgeable per- sons, and reflects the current state of knowledge regarding appropriate and successful mitigation. 2-7-10. 7-88-87 The light-footed clapper rail and the least tern were not identified as present during the field surveys, and previous comments and the U.S. Fish and Wildlife Service (refer to Response to Comment 1-1-24 in this Chapter) did not mention their potential presence. Subsequent research has indicated that the tern may forage in San Diego Creek, and the clapper rail may forage along the terraces and banks of the Creek in emergent marsh habitat. The Corridor will bridge San Diego Creek. The loss of foraging habitat for these species is not expected to occur, because no suitable habitat exists that would be permanently removed. In addition, foraging habitat is available else- where along the Creek, in San Joaquin Marsh and Upper Newport Bay. The southwestern pond turtle was identified in the Biological Assessment as present in the Bonita Creek area. Impacts to this species, as with all wild- life species in the Corridor area, were identified to include the direct, local and cumulative regional loss of habitat and the possible loss of individuals. Additional impacts to the pond turtle were not identified. 2-7-13 The extension of California Avenue over San Diego Creek is not a part of the proposed project and therefore is not analyzed in the Draft EIR/EIS. 01/31/91(TCA9018%INDEX-8) B- 3 4 A number of commentators have raised concerns -about the need for preservation of open space at a regional scale, and the potential effect of the Corridor on existing and planned open space areas. The importance of preserving consoli- dated blocks of open space in the rapidly developing south Orange County area is not a concern exclusive to the Corridor, or to any other individual project that may have effects on open space and wildlife habi.tat. As is suggested by the comments, and representing the general consensus of the biological com- munity, open space and, more critically, wildlife habitat values are best preserved in relatively large contiguous areas rather than in smaller preserve areas fragmented by intervening urban development. In contrast to the proce- dure common in most areas of the State, requiring the dedication and preserva- tion of fragments of open space in connection with each development project independently, the County of Orange has been able to take advantage of an • unusual land ownership structure in the south County area to preserve substan- tial areas of contiguous open space. The direct impacts of constructing the Corridor, including the grading of existing land forms, and removal of open space 'and wildlife habitat (as described in Section 4.6 of the Draft E.IR/EIS), are changes in the environment that can be mitigated through restoration or enhancement activities associated with the Corridor project itself. For example, as discussed in Response to Comment 3-5-97 in this Chapter, impacts associated with the removal of coastal sage scrub habitat will be mitigated through replanting of similar habitat. Similarly, loss of oak trees associated with construction of the Corridor will be mitigated through a replacement planting program. However, the effects of the Corridor, considered cumulatively with other development activities within the south County on regional open space and wildlife habitat, cannot be miti- gated effectively by actions associated solely with the Corridor project. In recognition of this problem, that regional and cumulative impacts cannot be effectively mitigated solely on a project by project basis, the County of Orange has engaged in a systematic process of cooperative planning to assure the preservation of large contiguous blocks of open space in conjunction with land use approvals and development of infrastructure throughout the south County. As discussed at•greater length in Attachment B to Appendix A of the Draft EIR/EIS, the County's cooperative planning effort has taken advantage of the concentration of land ownership in the south County to condition the ap- proval of master planned communities on the dedication of large contiguous open space areas. Simultaneously planning for the development of the south County and supporting infrastructure, including the Corridor (initially included on • 01/31/91(TCA901&:INDEX-B) B-35 the County's Master Plan of Arterial Highways in 1976), the County was able to protect a 16,000 acre greenbelt area in the San Joaquin Hills. Although the cumulative environmental effect of development in the south County results in a significant effect on the availability of open space and wildlife habitat, with a resulting impact on the presence of wildlife, these cumulative effects cannot be addressed by any single project, and have been mitigated, to the extent feasible, by the County's regional planning efforts. A number of commentators have specifically suggested the dedication of open space acreage to offset the effects of the Corridor. As discussed in some length in Chapter 6 of the Draft EIR/EIS, almost all of the land in the Corri- dor area has already been committed to particular land uses by the County and the cities having jurisdiction. As shown on Figure 3.7.1 in the Draft EIR/EIS, the area surrounding the Corridor has already been preserved or is subject to dedication requirements. Therefore, additional open space dedications would require taking existing development rights, at substantial additional cost. From practical implementation and operation standpoints, these additional costs • for purchase of developable lands would render the project infeasible. In addition, it is likely that acquisition of additional large contiguous blocks of land to be dedicated as open space preserves could not be accomplished in Orange County, as the majority of land is either existing or planned for pres- ervation, or development, rendering that mitigation less effective. As dis- cussed above, the preservation of open space, and the biological resources associated with the open space, on a regional scale has been appropriately undertaken by the County, rather than being attempted on a project by project basis. Several commentators have suggested that mitigation of impacts related to the Corridor should, at least to some extent, include mitigation for the effects related to growth which will be induced by the Corridor. As discussed in Chapter 6 of the Draft EIR/EIS, the Corridor is not expected to induce growth, principally because the areas which might be subject to development pressure either have already received development approvals or have been planned as permanent open space. In effect, with the County having jointly planned developed land uses and infrastructure, the Corridor is simply the last piece of the integrated plan being proposed for implementation. Therefore, although the Draft EIR/EIS identifies the effect of the Corridor in dividing the existing open space in the San Joaquin Hills, this is a change from existing conditions which was anticipated during the development of the greenbelt open space. As discussed in Responses to Comments 1-1-50 and 2-7-3 in this Chapter, design measures have 01/31/91(TCA901B•:INDEX-B) B-36 0 been incorporated into the project to mitigate the Corridor's fragmentation effects on existing open space to the extent feasible. It is not anticipated that the fragmentation of the existing open space will lead to ecosystem col- lapse, or "dead zones." In fact, although the Corridor does bisect the coastal hills, large scale habitat areas remain on each side of the Corridor: approxi- mately 4,000 acres in the Bommer Canyon/Shady Canyon/Laguna Canyon area, over 4,000 acres in the Irvine Coast/Crystal Cove State Park complex, and approxi- mately 3,000 acres in the Wood Canyon/Aliso Creed dedication area. Based on current biological studies, these contiguous open spaces will support viable populations for the foreseeable future. However, as discussed in the Draft EIR/EIS in Section 4.6, mammals requiring large habitat areas for support will be limited in their numbers by fragmentation of the existing open space area. Precise numbers of current populations of potentially affected animals have not been developed as part of the analysis for the Draft EIR/EIS. Precise popula- tion counts are not expected to affect conclusions with respect to significance to impacts of*the Corridor. For additional discussion of survey methods, refer to Response to Comment 1-1-25 in this Chapter. 0 2-7-15 The comment represents the opinion of the commentator and will be taken into consideration by the decision makers. Refer to Response to Comments 1-1-50 and 2-7-14 in this Chapter. 2-8-31, 2-8-32, 2-8-35, 2-8-36, 2-9-32 The one -quarter mile study area on each side of the Corridor centerline extends considerably outside the limits of Corridor construction. This width was selected by P&D Technologies as part of their original biological assessment of Corridor impacts in 1983 in an attempt to include off -site project impacts to wildlife and plant communities. Refer to Response to Comment 1-1-28 in this Chapter regarding the limit of disturbance used for project evaluation in the current Draft EIR/EIS. The Draft EIR/EIS evaluates the overall impacts to wildlife movement, habitat fragmentation, noise impacts and reduction in wild- life numbers (as the result of road kills as well as loss of habitat) through- out the open areas along the Corridor. Although not specifically mentioned, the areas of the Corridor within or adjacent to the coastal zone were included in this analysis. 0 01/31/91(TCA9016•••INDEX-B) B-37 2-8-33, 2-8-38, 2-8-39, 4-32-35 See Responses to Comments 2-8-31 and 3-5-68 in this Chapter. Downstream im- pacts to wetlands have been identified as not significant with successful implementation of the Runoff Management Plan. 2-8-34 All the species in Table 3.6 A are considered to be coastal species in a gener- al sense. There are no species which are limited to the specific Coastal Zone, with the possible exception of the Laguna Beach dudleya. 2-8-40, 2-8-41 As discussed in Response to Comment 3-5-109 in this Chapter, the impacts to off -site wetlands will be mitigated to below the level of significance. Re- garding Coastal Commission participation in wetlands planning, refer to Re- sponse to Comment 2-8-27 under Water Resources. 0 2-9-6. 2-9-7. 2-9-16, 2-9-17, 4-28-4. 4-28-6. 4-28-7. 4-28-8. 4-28-14 A request was made to the U.S. Fish and Wildlife Service for information on rare, threatened and endangered plant and animal species in the vicinity of the Corridor. In addition, the current available information on sensitive species was reviewed by P&D Technologies in 1988. Additional review was conducted by LSA. Surveys were conducted by P&D of all plant communities along the Corri- dor, with follow up surveys by LSA. The Table cited in the comment, Table 3.6.A, included all the plants provided by the U.S. Fish and Wildlife Service (see Appendix F) and species subsequently identified in the literature that may occur within the Corridor alignment. All the information provided by the field surveys and document information were included in both the Draft EIR/EIS and the Biological Assessment report. In addition, the document identifies coastal sage scrub as habitat for the gnatcatcher to indicate that gnatcatcher habitat is not limited to reported sightings. Refer to Response to Comment 4-17-18 under Construction Impacts. The species mentioned in Responses to Comments 4-28-6 and 4-28-7 were not included in the Biological Assessment for various reasons stated below; how- ever, additional surveys will be conducted for seven of the 12 species (refer to Response to Comment 1-1-25 in this Chapter). Depending upon the timing of 01/31/91(TCA901B%INDEX-B) B -3 8 0 0 the survey, some of the species may not be readily observed or present. The presence of absence of these species will be determined based on an assessment of habitat, as follows: Calochortus catalinae, Catalina mariposa was evaluated in 1984 by the Cali- fornia Native Plant Society as being too common to be listed as a sensitive species. In 1988, the CNPS included the mariposa on their List 4 for plants of limited distribution. This list is for plants whose "vulnerability or suscep- tibility to threat appears low at this time" (California Native Plant Society, 1988). Based on this analysis and the definitions of rare or endangered spe- cies provided by CEQA Section 15380 and the California Endangered Species Act, the Catalina mariposa would not meet the requirements for listing as rare, threatened or endangered, and therefore was not included in the analysis of sensitive species. Dichondra occidentalis, western dichondra was included as a List 4 species in 1984 and 1988 by CNPS. In addition, the dichondra is considered as a Category 3c species by the U.S. Fish and Wildlife Service. Category 3c species are species that are considered to be too widespread or not threatened to warrant listing as a threatened or endangered species. Therefore, this species did not meet the requirements for CEQA and CNPS and was not considered for inclusion in the analysis of sensitive species. Harpagonella palmeri, Palmer's grappling hook is a CNPS list 2 species. The R- E-D (Rarity -Endangerment -Distribution) of this species is 1-2-1, which means that it is rare, but found in sufficient numbers and distributed widely enough that the potential for extinction is low at this time, endangered in a portion of its range and more or less widespread outside California. The species was not included in the list of sensitive species; however, additional studies will be conducted to determine the presence or absence of this species in the Corri- dor. Hemizonia australis, southern spikeweed is a CNPS list 3 species. List 3 species are species about which so little is known that their placement on other lists cannot be determined. Additional surveys will be conducted to determine the presence or absence of this species within the Corridor align- ment. Polygala cornuta ssp. fishiae, Fish's milkwort, is a list 4 species. Please refer to the discussion under Mariposa lily regarding list 4 species for rea- sons why this species was not included in the sensitive resources analysis. 0 01/31/91(TCA9018%INDEX-8) B - 3 9 0 Chorizanthe procumbens albiflora, Fallbrook spineflower, is a CLAPS List 4 spe- cies. Please refer to the discussion under Mariposa lily regarding list 4 species for reasons why this species was not included in the sensitive resour- ces analysis. Comarostaphylis diversifolia diversifolia, summer holly, is a CNPS List 1B species. The R-E-D for this species is 2-2-2, which means that the occurrence is confined to several populations, it is endangered in a portion of its range and it is rare outside California. Summer holly is a perennial shrub that is readily observable year round. The botanical literature identifies this species as occurring in chaparral near the coast. No summer holly was seen during the botanical surveys, and none is expected to occur. However, the additional field studies will include surveys for this species. Dudleya blochmaniae, Blochman's dudleya is a CNPS 1B species. The R-E-D for this species is 1-2-2, which means this species is rare, but found in sufficient numbers and distributed widely enough that the potential for extinc- tion is low at this time. However, this species is endangered in a portion of its range and is rare outside California. Based on the CNPS listing, the current status of this species is uncertain. Blochman's dudleya is described as occurring in dry stony places below 1500 feet. This species was not observed during the surveys, and it is not ex- pected to occur along the Corridor due to a lack of suitable habitat. However, the additional field studies will include surveys for this species and/or its habitat. Juncus actus sphaerocarpus, spiny rush is a CNPS List 4 species. Please refer to the discussion under Mariposa lily regarding list 4 species for reasons why this species was not included in the sensitive resources analysis. Physalis greenei, Greene's ground cherry, is a CNPS list 3 species. List 3 species are species about which so little is known that their placement on other lists cannot be determined. Additional surveys will be conducted to determine the presence or absence of this species within the Corridor align- ment. Quercus dumosa, coastal scrub oak, is not listed by any agency. Its taxonomic status as a species is uncertain; however, the evidence would indicate that it is a species and should be considered sensitive. However, the only recorded populations occur at Pelican Hill, Dana Point, Niguel Hill and Aliso Canyon. 01/31/91(TCA9018%INDEX-B) B - 4 0 0 0 None of these populations lie within the Corridor alignment. Additional sur- veys will be conducted to determine whether the species occurs within the Corridor alignment. Verbesina dissita, big -leaved crown beard, is listed on CNPS List 1B and is listed as threatened by the California Fish and Game Commission. This species is currently known only from two locations south of Laguna Beach. Additional surveys will be completed to determine whether this species occurs within the Corridor alignment. 2-9-8 See Responses to Comments 2-7-3 and 2-7-10 in this Chapter. 2-9-9 See Response to Comment 4-17-18 under Construction Impacts regarding grading for the Corridor by adjacent development projects. 2-9-10, 4-28-9 The original survey work conducted by P&D Technologies and subsequent work by LSA did not uncover any substantial stands of native bunchgrass along the Corridor. 2-9-11 The title is taken from the report prepared by P&D Technologies. The names are taken from the County of Orange Environmental Management Agency's Master Environmental Assessment Program. The names were retained for the sake of consistency for the Draft EIR/EIS. The habitat found along the Corridor that is defined as "coastal sage scrub - mixed" is the same as coastal sage scrub. 2-9-12, 2-9-13, 2-9-14, 2-9-15 As stated in Comment 2-9-12, the information requested is available in the 1988 report prepared by P&D Technologies, A Biological Resource Analysis. This report is available to the public and is cited in the Draft EIR/EIS Biological Assessment Report (LSA, August, 1990). There is no information presented in the P&D report that was not in the Draft EIR/EIS. In addition, the tables contained population estimates that were accurate in 1988, but might no longer be correct for 1990 studies. 01/31/91(TCA901B'•.INDEX-8) B-41 In regards to Comment 2-9-13, the comment regarding the potential eastern extension of the Orange County Turkish rugging is noted. This possible east- ward extension, while providing additional information on the species, does not change the findings of impacts to the rugging from the Corridor project. Regarding Comments 2-9-13, 2-9-14, and 2-9-15, refer to Response to Comment 4- 17-18 under Construction Impacts. 2-9-19, 4-28-16 The information supplied on mule deer is taken directly from the 1988 study and supplemental work prepared by P&D Technologies. The size of the deer population is small relative to populations elsewhere. This was acknowledged in Santa Ana Mountains Deer Herd Management Plan, pre- pared by the California Department of Fish and Game, 1985. The Department's report includes an observation that the deer population in the San Joaquin Hills was small and would probably disappear due to encroachment by cumulative development. The wildlife movement corridors as discussed on page 3-46 of the Draft EIR/EIS, and shown on Figure 3.6.6, are representative of known or expected movement patterns of all free ranging upland mammals include mule deer. 2-9-20, 2-9-21, 2-9-43 The populations of Orange County Turkish rugging and dudleya-have been deleted from Figure 4.7.3. Refer to Responses to Comments 4-17-18 under Construction Impacts and 2-9-10 in this Chapter. As part of the 1990 Spring Survey conduc- ted by LSA, the vegetative mapping conducted by P&D Technologies was verified. The survey resulted in modifications to mapped plant communities adjacent to E1 Toro Road (Upper Woods Canyon). The graded area was correctly reflected on Figure 3.6.3 as disturbed habitat. 2-9-24 The more detailed discussion of the California gnatcatcher is provided in the Biological Assessment report (Technical Study No. 5). Surveys were conducted for the orange -throated whiptail along with other species. The Draft EIR/EIS defines potential as well as occupied habitat for these species. 01/31/91(TCA9018',INDEX-B) B-42 • • 2=9-25, 3-8-51, 3-8-52, 3-8-53, 3-8-144, 3-8-145, 3-8-146, 3-8-147 Refer to Response to Comment 4-17-18 under Construction Impacts. Sightings of wildlife outside the limits of disturbance were not mapped because it was believed that specific sightings are not necessarily indicative of the entire extent of the habitat for a given wildlife species. To show a specific sighting, particularly one that may not be related to a nesting site, might give a false impression that the wildlife species observed is limited only to the area where it was sighted. The comments do not provide the source of information for the alleged addition- al endangered species habitats. The field surveys conducted for the Draft EIR/EIS (and previous EIR No. 494) adequately present the most up to date information available regarding sensitive biological habitat areas potentially impacted by the Corridor (refer to Response to Comment 1-1-25) in this Chapter. 2-9-27, 2-9-28, 2-9-29, 2-9-30, 2-9-41, 7-88-84, 7-88-85 See Responses to Comments 4-17-18 under Construction Impacts and 2-9-25 in this Chapter. Figures 4.7.5 and 4.7.6 were correct in sequence in the Draft EIR/EIS. The referenced section of the Corridor alignment missing from the graphics in Section 4.7 was omitted because, in accordance with the field surveys conducted for the analysis, no sensitive species were mapped within that section. 2-9-32 Refer to Responses to Comments 1-1-28 and 4-28-39 in this Chapter. The con- struction monitoring team to be specified in the Mitigation Monitoring Program will ensure that activities remain within this line. 2-9-33, 3-5-12, 3-5-32 The impacts of streambed modification on downstream areas are discussed in the Water Resources and Construction Impacts Sections. Please refer to Mitigation Measures 3-2, 3-4, 3-6, 17-12, 17-13, 17-17 and 17-18 in the EIR/EIS. 2-9-34. Wildlife have been observed using channels for movement, one example being San Diego Creek Channel which connects Upper Newport Bay and San Joaquin Marsh. Culverts have also been known to provide passage for wildlife. Neither of 01/31/91(TCA9018%INDEX-8) B-43 these provide a complete substitute for the loss of natural drainages, and the overall impact to wildlife movement is acknowledged in the Draft EIR/EIS. Refer to Responses to Comments 1-1-50 and 2-7-3 in this Chapter. 2-9-35 See Response to Comment 2-9-33 in this Chapter. The Draft EIR/EIS concludes that successful implementation of the Runoff Management Plan (see Response to Comment 6-17-40 under Water Resources) will mitigate water quality impacts to below a level of significance, eliminating potential effects on downstream wetlands. 2-9-36. 3-5-73, 4-28-12, 7-88-72 Subsequent to the 1988 work performed by P&D Technologies, LSA Associates, Inc. redelineated wetlands and Waters of the U.S. using the Unified Federal Method- ology. This method was used at the request of Caltrans and FHWA and in accor- dance with FHWA and Caltrans Guidelines. Based on the work performed under this method, corrections were made to the wetland graphics and impacted wetland totals. One of the modifications to the original delineation was the re -confi- guration of habitats along the eastern side of Laguna Canyon and eastern El Toro Road. The site re-evaluation concluded that the E1 Toro wetland should be expanded to include a slightly larger area to the east. This change has been made to the Draft EIR/EIS as follows: the bottom paragraph that begins on page 4-80 of the text reads: "Although they are . no 'longer exhibit characteristics of wetland hydrology. However, because the site is dominated by obligate wetland plants (plants restricted to wetlands), this area is still considered to be a wetland. Therefore, the remaining wetlands within the wetlands include the narrow band . Creek, a small . . . channel and the small area that contains the obligate wetland species." The review of the data in the Wetlands Identification and Delineation Report (Technical Study No. 5) did not alter the finding as presented in Section 4.7 of the Draft EIR/EIS with respect to the extent of potentially impacted wetland habitat in Laguna Canyon. Refer also to Response to Comment 1-2-48 in this Chapter. 01/31/91(TCA9018%INDEX-B) B - 4 4 0 C 2-9-37, 2-9-38 The Corridor mainline toll plaza is not located in Crystal Cove State Park. The daylight line for toll plaza grading is at its closest point 500 feet away from the park boundaries. The Corridor toll plazas are included in the area of disturbance, mapped as a dashed line on both sides of the Corridor, as shown on the Figures in Sections 3.6 and 4.6 of the Draft EIR/EIS. Therefore, the potential impacts of the toll plazas were evaluated in the Biological Assess- ment Report. Details regarding toll facility operations are provided in Section 2, Project Description (see page 2-2) of the Draft EIR/EIS. The rationale for locating the toll plaza at its proposed location is that numerous sites were investigat- ed but did not meet the basic requirements of being located mid -range along the Corridor, in an area with a relatively flat profile (less than 2%). 2-9-40, 4-28-2 See Responses to Comments 1-1-25 in this Chapter and 4-17-18 under Construction Impacts. 2-9-42 See Responses to Comments 1-1-25, 2-9-6, 2-9-12, and 2-9-36 in this Chapter. 2-9-44, 2-9-45, 2-9-M 2-9-47, 2-9-48, 2-9-49, 2-9-50, 2-9-51, 2-9-52, 2-9-53. 4-33-53 These comments address the delineation of wetlands methodology used in prepar- ing the wetlands impact analysis for the Corridor. The methodology utilized for the wetland habitat mapping work was per the Federal Manual for Identifying and Delineating Jurisdictional Wetlands, (adopt- ed January, 1989 by the U.S. Army Corps of Engineers, U.S. Fish and Wildlife Service, EPA and the Soils Conservation Service). This methodology is required by Caltrans for all wetlands determinations. The hydrophytic vegetation criteria was misapplied at Sites 1 and 3. Rather than report the percentage of the dominant species that were hydrophytic, the wetlands analysis reported the actual percent cover of the dominant species present on site. Using the method discussed in the comment would change the vegetation designation; however, conclusions regarding the wetland status of these sites remain unchanged. For Site 1 there was direct observation of 01/31/91(TCA9018%INDEX-8) B - 4 5 0 hydrologic characteristics that led to the conclusion that this was a wetland. For this reason, the correction has no effect upon the conclusions. Site 3 is a remnant terrace along Trabuco Arroyo that is now 30 feet above the creek. The dominant trees, elderberry, Sanibucus mexicana, are old with signs of dete- rioration. Roots from these trees were observed along the outer edges of the terrace to be quite deep. Because of the deep rooting characteristics of these trees, it was speculated that the trees established themselves at the site when the creek bed was much higher and have been able to persist following subse- quent stream downcutting because of their ability to reach the saturated zone created by the creek. This site is clearly in a topographic position where it cannot pond and its coarse sandy soils are excessively drained. For this reason, it was concluded that this site did not satisfy the criteria for desig- nation as a wetland. Because of recent drought conditions, extra care was taken to characterize both soil and hydrology characteristics. Hydric soil characteristics are typically very persistent and would not be expected to vanish altogether, even after several years of drought. Hydric soil characteristics were easily observed at . many sites. Additionally, wetland delineation fieldwork was performed between March 6 and 8, 1990, approximately one week following a significant precipita- tion event. Sufficient moisture fell during that event to provide some indica- tion of the potential for saturation of the surface for "long duration." At many locations standing and running water was observed. Where neither soil characteristics nor wetland hydrologic characteristics were observed, it was concluded that the area did not satisfy the criteria for designation as a wetland. Comment 2-9-47 points out that river bars and flats may be composed of sandy soils that may not have observable hydric characteristics. This is quite true and commonly observed within the drainages of Orange County. In these areas, because neither soils nor vegetation can be necessarily relied upon to deter- mine the presence and extent of wetlands, hydrology characteristics must be carefully evaluated. Characteristics such as topographic position, soil perme- ability, water -borne sediment deposits, drift lines, scour areas, and drainage patterns were carefully evaluated to ensure that wetlands adjacent to waters of the U.S. were not omitted from the delineation. Comment 2-9-49 raises the issue of whether the flood retention basin adjacent to Oso Creek was constructed within a wetland and whether it should continue to be considered to be within the jurisdiction of the Corps of Engineers. The analysis was restricted to an analysis of existing conditions, including the presence or absence of vegetation and hydrologic indicators. A determination whether the flood control structure was constructed with proper permits and 01/31/91(TCA901B%INDEX-8) B - 4 6 resulted in the elimination of wetlands was not within the scope of this analy- sis. The soils in the retention basin are not physically connected to the soils in the creek, as is the case for the soils discussed in the quote from the Federal Manual. Comment 2-9-50 raises the issue of what wetlands have been eliminated by recent road construction associated with the flood retention structure to the east of E1 Toro Canyon Creek and whether these areas should continue to be considered wetlands. The analysis of the area shows that the construction of the road and flood retention structure have significantly altered the hydrology of this area resulting in an overall reduction of the extent of the wetlands within this area. Again, a determination whether the flood control structure and associat- ed roads were constructed with proper permits and resulted in the elimination of wetlands was not within the scope of this analysis. Comment 2-9-50 also points out that an area that is dominated by obligate plants should be considered to be a wetland. The information on the data sheets was reevaluated and this area (located east of E1 Toro Creek) has been subsequently included within the area delineated as wetland. The text on pages 4-73 and 4-74 of the DEIR/EIS and Figure 4.7.4 have been altered accordingly in the Final EIR/EIS. Comment 2-9-51 suggests that, if wetland species predominate in and around Laguna Canyon Creek, these areas should be considered to be wetlands. The original analysis made this same conclusion and such areas were included within the original delineation. Comment 2-9-52 suggests that a determination of whether under normal circum- stances the alluvial fan created by Coyote Canyon Arroyo below the road is saturated during the growing season for one or more weeks. As previously discussed, the delineation was performed within a week of a significant storm event and flowing and ponded water were observed in many locations. In this area, the vegetation community was dominated by two species, mule fat, Bac- charis g7utinosa, a facultative wetland species, and purple sage, Salvia 7euco- phy77a, an upland species. Because this area had not more than 50 percent hydrophytic dominant plants, the Federal Manual considers these areas to be problem sites and requires the careful investigation of soils and hydrology. The investigation showed that the site is an alluvial fan where outwash sands are deposited following intense flow events. It was observed that, although water continued to be flowing within the adjacent stream from recent rains, the soils were not saturated to the surface several days following a major storm and a water table, if one exists, is very deep. For this reason it was con- cluded that this area should not be considered a wetland. 01/31/91(TCA9018%INOEX-8) B - 4 7 • Comment 2-9-53 suggests that the area along the eastern side of Coyote Canyon Road near the intersection with Bonita Canyon Road that is dominated by willows but was not determined to be a wetland should be reconsidered. The information on the data sheets was re-evaluated and this area has been included within the area delineated as wetland. The graphics in the DEIR/EIS depicting plant communities and impacts to sensitive species have been revised to reflect this delineation. The commentator also suggests that areas dominated by mulefat, a FACW species, should be considered to be wetlands. These areas were carefully reviewed and, many areas having mulefat were included within the wetland delineation. It was observed within this survey area that when this species is the single dominant species or occurs in association with nonhydrophytic species, the site did not have hydric soils or wetland hydrology and for this reason these plant communi- ties were not considered to be wetlands. The assertion in Comment 2-9-53 that head -cutting is evidence of wetland hydrology is incorrect. Head -cutting is evidence of the concentration of runoff and of the stream channel coming into equilibrium with a new base eleva- tion. In this case, a head -cut channel was observed in an alluvial fan con- taining coarse sandy sediments. There was little possibility for the soils to remain saturated to the surface for "long duration. 2-11-1. 2-11-2 Previous project alignment Alternative U (DEIR No. 494) would have had more significant impacts to the Bonita Reservoir and the sensitive wetlands habitat contained within that area than Alternative R alignment. Although Alternative R results in more substantial effects on upland resources, including coastal sage scrub habitat, Alternative R was carried forward due to the wetlands, which would be affected by Alternative U. The Draft EIR/EIS discusses mitiga- tion for impacts to Dudleya multicaulis. The mitigation will include the dudleya populations on the UCI campus that are impacted by the Corridor. Refer to Response to Comment 3-5-97 in this Chapter. Impacts to coastal sage scrub will be mitigated along the Corridor as part of the landscaping plan. Regarding mitigation, refer to Response to Comment 3-5- 97 in this Chapter. Additionally, the TCA, in developing the Resource Manage- ment Plan required by Mitigation Measure 6-19, will pursue mitigation oppor- tunities in the UCI coastal sage scrub open space reserve (see Response to Comment 1-1-57 in this Chapter). 01/31/91(TCA9016%INDEX-B) B - 48 2-11-3. 2-11-5 Refer to Responses to Comments 1-1-57, 3-5-97, and 3-5-109 in this Chapter. 2-11-4. 3-8-39 Mitigation Measures 6-1 and 6-2 primarily address the concerns raised in the comment. Mitigation Measure 6-1 has been revised as follows: 6-1 Project Biologist. A Project Biologist(s) will be retained prior to final design and will attend a pre -grade meeting to establish and coordinate all necessary restrictions for grading operations and construction. The Biologist(s) will prepare the Resource Management Plan, Wetlands Mitiga- tion Plan and will contribute to the preparation of the Landscape Plan with the Project Landscape Architect. The Project Biologist(s) will be present on site as necessary during construction to monitor implementation of the established restrictions. . Measure 6-2 has been modified as follows: 6-2 Environmentally Sensitive Areas (ESAs) within the project right- of-way which will not be impacted by project construction will be mapped. Protective fencing will be installed around the ESAs as well as construction staging areas as deemed appropriate by the Project Biologists to prevent trespassing into these areas. The Mitigation Monitoring Program specifies the parties responsible (the Project Biologists) for overseeing and monitoring the construction activities. 3-5-10 The precise number of individuals of each potentially affected animal species is not known. This information is not necessary to analyze impacts to wildlife populations. Part of the difficulty in determining population size lies in the length of time required to provide a reliable estimate. Populations of wild- life species, particularly prey species such as deer, fluctuate both within and between years. The determination of population size is therefore dependent upon the time of year when surveys are conducted and the types and numbers of surveys performed. However, more surveys are not necessarily a guarantee of accuracy for a population estimate. Refer to Response to Comment 1-2-25 in this chapter regarding the need for additional biological surveys. The DEIR/EIS • 01/31/91(TCA9018%INDEX-B) B - 49 0 adequately addresses the Corridor's environmental setting in Section 3.6 and the potential impacts to animal species populations in Section 4.6. 3-5-72 The importance of wetlands as a critical habitat is evidenced by the require- ment to replace the impacted habitat on at least an acre for acre basis per the policies of the U.S. Fish and Wildlife Service, a commenting agency. Pursuant to CEQA and NEPA, the Draft EIR/EIS addresses cumulative biological impacts in Sections 4.6 and 7.0. However, a description of historic wetlands loss in California was not determined essential to the analysis of potential impacts. 3-5-74, 3-5-78, 7-141-1 Regarding cumulative impacts to open space, refer to Response to Comment 2-7-14 in this Chapter. There are no known biotic methodologies for projection of precise numbers of losses of individuals due to a project such as the proposed Corridor (see Response to Comment 3-5-10). Impacts of restricting wildlife • movement are discussed in Section 4.6 of the Draft EIR/EIS (see Responses to Comments 1-1-50 and 2-7-3 of this chapter). As a point of clarification, there are no ground dwelling species in the Corri- dor study area that are true "migratory" species. Refer to Response to Com- ments 1-2-2 under Cumulative Impacts regarding evaluation of cumulative effects of all three Corridors. 3-5-75, 4-34-9 The biological analysis in the Draft EIR/EIS determined that the proposed Corridor will further fragment the existing open space areas in the study area however, the majority of wildlife populations in the area will not be decimated in the long-term. One of the stated purposes of the dedication of regional open space acreage was to provide long-term habitat for local wildlife. Refer to Responses to Comments 1-1-50 and 2-7-14 in this chapter. 3-5-76, 3-5-79, 4-19-9. 7-88-59 The size of contiguous open space necessary to sustain viable ecosystems is frequently a matter of professional opinion and cannot be absolutely deter- mined. Generally, the only known values are specific to individual species. In addition, the size of the contiguous open space is not the only factor that should be considered in determining whether ecosystems will remain viable. Other factors include the extent of food supply for the various species, the 01/31/91(TCA9018%INDEX-B) B - 5 0 is 0' extent of cover provided by both shrubs and trees, the extent and nature of open flat terrain versus mountainous country, the availability of water and other resources, the location of water and other resources relative to each other and to the entire open space area, the availability of "island habitats" within open space areas, wildlife tolerance to human activity, the relationship of the open space and its habitats to edge developments including commercial, industrial and residential areas, the types, amounts and intensity of human use of the open space areas, and the ongoing maintenance activities such as con- trolled burning and weed control, balancing of prey -predator relationships, disease control, pest control and other factors. As is apparent from the above discussion, no one number is readily available to determine the size of contiguous open- space necessary to "sustain a healthy ecosystem". Therefore, the sizes of preserved areas are dictated by available land and an attempt to balance biological concerns (in the absence of hard data) with development potential. • In addition, any attempt to estimate the parameters required to sustain an ecosystem over a particular time frame (e.g., 25 years) is complicated by the dynamic nature of ecosystems, including an inability to predict natural disas- ters. Attempts to manipulate parameters may result in protecting some habitats and species at the expense of others. Refer also to Response to Comment 2-7-14 in this Chapter. The biological analysis adequately presents the potential impacts to wildlife on both a regional and local basis as discussed in the Draft EIR/EIS, page 4-64 and the Technical Study No. 5. The referenced document provides relevant discussion of the significance of wildlife in Orange County; however, the conclusions as stated in the Draft EIR/EIS regarding potential impacts of the project upon wildlife do not change. 3-5-93 Refer to Response to Comment 1-1-50 in this Chapter regarding wildlife access across the Corridor. Refer also to Response to Comment 2-7-3 in this Chapter regarding Corridor design modification to facilitate wildlife movement through Bonita Creek to Upper Newport Bay. 01/31/91(TCA9018%INDEX-B) B - 5 1 3-5-94. 4-21-32, 7-88-27, 7-114-21 The Corridor will be fenced with seven foot high chain link fencing along sections of the Corridor between Sand Canyon Avenue and Laguna Canyon Road (in the known wildlife movement corridor areas) and five foot high fencing along the remaining sections. An additional mitigation measure has been added to the EIR/EIS, as follows: 6-18 Chain link fencing will be installed on both sides of the Corridor for its entire length at the Caltrans right-of-way line. The fencing will be seven feet in height in those areas of known wildlife movement across the Corridor (the Project Biologist to determine the precise areas during final design) and five feet in height in remaining sections. . 0-V-1V. 4-CS-J1, 4-go-.33, 4-LtS-34. 4-sL-tS, 4-.jL-11, 4- 32-21, 6-17-16, 7-30-10, 7-30-11, 7-56-32, 7-56-34, 7-88-48, 7-88-49, 7-88-50, 7-88-52, 7-114-8 Mitigation Measure 6-13 has been amended as follows to partially mitigate the loss of native habitats along the Corridor: 6-13 The landscaping along the Corridor in open space (non -urban) areas will be limited to a mix of native, non-invasive, drought tolerant plant species. In upland areas, the species that will be selected will be the same as those that are found in coastal sage scrub habitat appropriate for support of the California gnatcatcher, the San Diego horned lizard, orange - throated whiptail and the cactus wren. The coastal sage scrub species will be planted on cut and fill slopes in the upland areas from El Toro Road interchange to approximately one mile north of the future Sand Canyon interchange, in Aliso Woods Canyon Regional park, and in Bonita Canyon in areas not adjacent to planned community development. The landscape pal- ette will replace in kind the coastal sage scrub habitat that was removed and will establish such habitat wherever possible along the Corridor. The plant palette will include important native scrub species such as Califor- nia buckwheat (Eriogonum fasciculatum), California sagebrush (Artemisia californica) and black sage (Salvia mellifera). The source of information for the landscape palette will be the list provided in Technical Study No. 5, the plant list attached to the 1990 spring survey conducted by LSA Associates, Inc., of the Draft EIR/EIS, augmented by information provided by subsequent studies and by the Project Biologist. The Project Biologist will review the landscape palette and will make recommendations as to the inclusion or removal of species, and will also review and make recommenda- tions on the proposed distribution of habitats along the Corridor. The 01/31/91(TCA901B••INDEX-8) B-52 0 purpose of the landscaping effort shall be to replace and establish coa- stal sage scrub habitat, thereby replacing wildlife habitat for the gnat - catcher and other species. The Project Biologist will coordinate with the U.S. Fish and Wildlife Service and the California Department of Fish and Game to determine the amount of replacement habitat, taking into consideration the indirect effects of noise from the Corridor. Seeds, cuttings and potted plants will be collected from local plant material where feasible, supplemented by material from native plant nurs- eries. No species native to California but not found in the San Joaquin Hills area will be used, unless the species selected is considered to be appropriate for use by the Project Biologist. Invasive weedy or non-native species will not be used in landscaping along open space areas. Examples of invasive plants include, but are not limited to, pampas grass, periwinkle, English ivy and giant reed. In Response to Comments 3-9-10 and 3-9-11 the appropriate portions of the sug- gested mitigation from the Foothill Transportation Corridor DEIR has been incorporated into Mitigation Measure 6-13. Refer also to Response to Comment 1-1-57 which contains the text of the Re- source Management Plan, Mitigation Measure 6-19. Landscaping of slopes adjacent to urban, existing and planned development areas will include an appropriate mix of non-native and native drought tolerant, non- invasive non -weedy plant species. Mitigation Measure 15-14 is expanded as follows: 15-14 A detailed landscape plan will be prepared and implemented for cut and fill slope areas by the Project Landscape Architect in consulta- tion with the Project Biologist. The plan will be prepared during project final design and approved by the TCA Board prior to construc- tion. The Landscape Plan will contain the following components: • Design of landscaping of Corridor cut slopes; specification of plant species types, quantities/densities, seed, container sizes and/or hydromulch mix, soil compatibility and preparation requirements, irrigation systems for establishment; .10 01/31/91(TCA9018%INDEX-B) B - 53 • Mitigation Measure 6-13 as discussed above; • Specification of cut slopes preparation for planting of plant materi- als (per Mitigation Measure 15-11); • Selection of plant materials for enhancement of slope landform varia- tion consistent with the surrounding natural setting (per Mitigation Measure 15-12); • In urban areas, where utilization of native species is not feasible, specification of nonnative, non-invasive drought tolerant species (per Mitigation Measure 15-12); • Design of landscaping to shield existing residences from light and glare from Corridor lighting fixtures and signage (per Mitigation Measure 15-18); • Design of landscaping to soften retaining walls and maintain visibil- ity of business signage per Caltrans Outdoor Advertising Act (per Mitigation Measures 15-22 and 15-23). Performance standards for project landscaped areas include the following: As different species have different growth patterns, performance will vary from site to site, depending on which species have been targeted. In general, after five years, the percent cover of each key species should be within 20% of the existing condition. Protection of seeds and soil will be accomplished through the use of a short term pioneer species such as Plantago insularis, which will provide rapid site coverage, but will compete with native plantings in the long term. 6-12 Species of Concern. Mitigation options for the many -stemmed dudleya (Dudleya multicaulis) and Orange County Turkish rugging (Chorizanthe staticoides chrysacantha) include a program of on -site and off -site trans- plantation of species. The final details of the mitigation plan will be developed prior to construction as part of the Resource Management Plan for the Draft EIR/EIS. The details of the planting effort are described below. Mitigation options for the many -stemmed dudleya and Orange County Turkish rugging include off -site acquisition of lands with same species, pay fee per habitat acre or plants lost and transplantation of species (seed collection and propagation). Final mitigation plans shall be determined 01/31/91(TCA901B%1NDEX-B) B- 54 0 in conjunction with a Memorandum of Understanding between the TCA, the California Department of Fish & Game (CDFG) and the U.S. Fish and Wildlife Service. • The salvage program for Orange County Turkish rugging will include: - Salvage of the first six inches of topsoil from impacted habitat areas. The topsoil will be stockpiled for the shortest possible time before respreading at six inches depth. - The topsoil shall be respread on a site selected by a qualified botanist. Preferred sites include embankment areas of the Cor- ridor. The mitigation sites will be in areas exposed to full sun. Shaded or partially shaded areas will be avoided. Seed will be salvaged in June and July and stored at a nursery until the mitigation sites have been prepared. Germination tests will be performed on the seed. If viability is low and/or number of seed insufficient, off -site seed collection will be required. - The seed will be raked in or hydromulched into the topsoil. There will be no nurse ..crop in the hydromul ch, and the spray equipment will be cleaned out thoroughly to avoid contamination of the seed material. - A small percentage of the seed collected on -site will be sown in a nursery to preserve the gene pool. The work will include propagating the seed into container size plants and harvesting the seed from those specimens to augment planting on the site, and serve as an additional plant source throughout the monitor- ing period. It would be appropriate to conduct a test program before the full-scale mitigation project, since no past effort for relocation can be considered an unqualified success. • The salvage program for many -stemmed dudleya will be a several part effort, consisting of: - Corms will be salvaged during the fall drought season and stored at a nursery until the mitigation site is prepared. 0 01/31/91(TCA9018%INDEX-B) B - 5 5 n Topsoil will be salvaged to a depth of six inches from the sur- face and will be stockpiled for the shortest possible time prior to respreading to six inches depth. Large blocks of substrate with the corms and associated flora kept in place will be salvaged and stockpiled for the shortest possible time prior to replacement on mitigation areas. • Reestablishment will include: - Salvaged corms will be placed in a nursery to provide a backup seed source, in the event of initial failure to reestablish species in the wild. - Dormant corms will be transplanted to appropriate locales where the species is not now present or occurs in low numbers. - Transplantation and seeding sites will be created on the right- of-way. These will be in areas of rock outcroppings, where the embankment is stairstepped. This will provide flat areas for establishment of populations. - Salvaged topsoil and soi 1 bl ocks with plants will be placed on the crests of the stairsteps. Topsoil area will be seeded dur- ing the rainy season with seed salvaged from preexisting popula- tions. - East facing slopes will be selected for relocation sites. For Comment 4-32-8, in response to the relative amount of coastal sage scrub, both the Draft EIR/EIS and the biological assessment describe coastal sage scrub as being found extensively in the San Joaquin Hills. This was not in- tended to imply that coastal sage scrub is "abundant" in California. Regarding Comment 4-32-11, any habitat established through landscaping the Corridor median would be temporary, as future transit options would remove vegetation. Therefore, TCA does not propose to landscape the median. In reference to Comments 7-88-48, 7-88-49, and 7-88-50, it is noted that the recommended ratios are the opinion of the commentator and are not based on either previous efforts or on data provided from other studies. Replacing coastal sage scrub at higher ratios than one to one is difficult, because sufficient mitigation areas may not be available. The quote from Beier is for 01/31/91(TCA901&+INDEX-B) B-56 one option presented in the Foothill Transportation Corridor document. Because the gnatcatcher is currently not listed by State -or federal agencies as endan- gered or threatened, Mitigation Measure 6-13 as proposed is appropriate mitiga- tion, and replacement at a per acre ratio is not required. In regards to Comment 7-88-52, revised Mitigation Measure 6-13 states that seeds, cuttings and potted plants will be collected from local plant material where feasible, supplemented with native plant materials from local nurseries. In reference to the second part of the Comment, the commentator does not make clear why replacing habitat along the slopes of the Corridor should not func- tion as mitigation for coastal sage scrub loss. Replacement on site is prefer- able to replacement off -site for all habitat types. 3-5-99, 4-21-36, 7-45-3 Mitigation Measure No. 6-15 stipulates that the designated Project Biologist in conjunction with biologists from the California Department of Fish and Game and the U.S. Fish and Wildlife Service will determine the appropriate replacement ratios for the specific habitat areas where oak trees would be removed as a result of Corridor construction. Mitigation Measure No. 6-15 has been revised as.follows: 6-15 The Resource Management Plan to be -implemented by the TCA will compensate for lost oak trees at an appropriate replacement ratio and spacing crite- ria, to be determined by the Project Biologist in conjunction with the U.S. Fish and Wildlife Service and the California Department of Fish and Game. Oak trees to be removed will be tallied as part of plan prepara- tion; and replacement resources will likely include a combination of plant sizes such as acorns, one and five gallon trees and/or transplantation, where feasible. Details of this plan will be developed in conjunction with the TCA, the Project Biologist and the Project Landscape Architect. Seedlings or small containers may be more appropriate than large containers since large stock often does not adapt well to its planting holes and grows less vigorously than small stock that quickly gets its roots into native soils. Refer to the performance standards for revegetated oak woodland, provided in Response to Comment 1-1-57 in this chapter. 0 01/31/91(TCA9018%INDEX-B) B - 5 7 3-5-109, 3-5-110, 4-28-20, 4-28-36, 4-28-38, 4-32-40, 4-32-41, 4-33-64, 7-86- 25, 7-108-17 The Draft Wetlands Mitigation Plan is included as part of the Final EIS. Review of the Draft Wetlands Plan will occur as part of the 404 Permit applica- tion submitted to the Army Corps of Engineers. The following is revised Miti- gation Measure 7-3: 7-3 During the process of obtaining the required permits for encroachment into habitat areas (1601/404), the TCA will prepare a.wetlands mitigation plan and will coordinate with the affected resource agencies (California De- partment of Fish and Game, U.S. Fish and Wildlife Service and U.S. Army Corps of Engineers) and local jurisdictions. Mitigation replacement or enhancement will result in no net loss of wetlands. Guidelines for site selection will include the following: 1. The sites selected will be evaluated for their suitability for use as riparian habitat mitigation areas. As described above, the param- eters evaluated will include, but not be limited to, soil condition, hydrology (current water availability), geology and drainage consid- erations, level of difficulty of site preparation, designation for particular Tand uses, and the archaeological and historical sensitiv- ity of the site. 2. Maintenance and monitoring goals will be established that are compat- ible with mitigation plans that have been or are being developed for other projects in the vicinity of the Corridor. Examples of such projects are the mitigation plans for Pelican Hill Road, Aliso Viejo development and Salt Creek. 3. The components and implementation of the Wetlands Mitigation Plan will include the following: A set of objectives for site selection and habitat replacement, and a set of parameters for the determination of the amount of replacement habitat, including the indirect effects of noise from the Corridor. Maintenance and monitoring specifications including requirements for site maintenance, terms of maintenance, frequency of moni- toring, financing mechanisms, performance standards and documen- tation of the implementation program. • • 01/31/91(TCA9018%INDEX-B) B - 58 0 • Design and seasonal guidelines to minimize impacts during con- struction; fencing plans for protection of wetland habitats not impacted by construction. • Replacement site selection guidelines. Per Mitigation Measure 7-4, actual replacement ratios and acreage, site locations and habitat values will be determined through extensive coordination with CDFG, USFWS, COE, UCI, County of Orange and Caltrans during preparation of the Wetlands Mitigation Plan. • Implementation specifications, including numbers, size and spac- ing of vegetation; site preparation, plant propagation and plan- ting techniques, irrigation techniques, and soil treatments. • Site maintenance requirements and terms, weed control measures, frequency of monitoring and monitoring reports, performance standards and remedial measures. • Maintenance of water flow to existing and established wetlands; description of water control devices; and • Documentation of the implementation program, including financing mechanisms, routine evaluation of the mitigation by wildlife agencies, and ultimate land ownership. The performance standards for wetlands plantings are as follows: Two years after planting, the tree canopy will be 50% or great- er. The standard for tree height will be seven to nine feet for sycamore, cottonwood, black willow, red willow, and golden wil- low, and six feet for arroyo willow. Mean height will reach or exceed this standard in two years. Five years after planting, the tree canopy cover will be 90% or greater. The standard for tree height will be 13 to 15 feet for sycamore, cottonwood, red willow, arroyo willow and golden wil- low, and 18 feet for black willow. At least 90% of the canopy trees will reach or exceed this height in five years. Canopy trees are defined as those that contribute to the measured can- opy cover. 0 01/31/91(TCA9018%INDEX-B) B - 5 9 Refer to also to Response to Comment 1-1-13 in this Chapter. 3-8-35 The assessment of project impacts by LSA was based upon the assessment prepared by P&D Technologies, and was updated to reflect the current project design. Changes made by LSA included the discussion of additional field sightings of sensitive species and sightings of sensitive species not previously found by P&D, the removal from the discussion of non -sensitive species such as the African clawed frog, and the identification of light and glare as a significant impact. Apart from these changes, there are no known inconsistencies between the two reports. The only difference in the areas covered in the field surveys were that P&D surveyed a larger area around the Corridor than did LSA, primari- ly because at the time P&D prepared their report, the alignment and areas of disturbance of the Corridor were less defined than for the current project. 3-8-36 The Final Resource Management Plan (including the Final Wetlands Mitigation Plan) will be submitted to the TCA Board for approval prior to project con- struction. 3-8-37 The impacts to streambed resources and associated wildlife were discussed in detail for Bonita Canyon Reservoir and Creek on pages 66-67 of the Biological Assessment Report. Impacts to wildlife are discussed in detail on pages 58-61 and impacts to wildlife movement in Bonita Creek on page 70 of the Biological Assessment Report. 3-8-38 Specific wildlife breeding grounds were not located during the surveys for the Corridor. In general, the various habitats occupied by wildlife species in- clude breeding habitats, although certain species (in particular birds) may forage in areas separate from nesting or burrowing areas. However, for the wildlife species within the Corridor alignment the overall loss of habitat includes the loss of breeding areas. The effects of the Corridor on species relocation, crowding and compatibility were discussed on page 4-64 of the DEIR/EIS under Loss and Fragmentation of Wildlife Habitat, and on page 7-4 under Wetlands. Biological Resources. In terms of the effects of species relocation, crowding and compatibility at 01/31/91(TCA9016%INDEX-8) B - 6 0 • habitat mitigation sites, there would be a temporary impact of wildlife dis- placement and crowding into other habitat areas until the mitigation sites are completed. In addition, the potential loss of individuals from project con- struction has been identified in Section 4.6 of the Draft EIR/EIS. 3-8-40, 3-8-41 Refer to Response to Comment 2-11-4 in this chapter which describes the respon- sibilities of the Project Biologist(s) (Mitigation Measure 6-1) and Mitigation Measure 6-2, which requires fencing of Environmentally Sensitive Areas. The City of Irvine will have the opportunity to review the Mitigation Monitoring Program as part of the review and approval of the Final EIR/EIS by the TCA Board. 3-8-42, 3-8-43, 3-8-44 Refer to Response to Comment 1-1-57 which specifies the components of the Resource Management Plan. 3-8-45, 3-8-46 The impacts to wildlife have been identified in the DEIR/EIS, and mitigation is planned as amended in the Final EIR/EIS. 3-8-47 As with any new road facility, following project construction, local and re- gional agencies will update their emergency response plans to include the Corridor as a potential emergency route. 3-8-48. 3-8-141, 6-17-44 It is not feasible to plant riparian species in the realigned Bonita Channel due to flood control requirements. Riparian vegetation will be planted in mitigation sites as specified in the Draft Wetlands Mitigation Plan (refer to Response to Comment 3-5-109). However, natural vegetation will be allowed to grow within the Channel. 3-8-49, 3-8-142, 3-8-143 Refer to Responses to Comments 1-1-50 and 2-7-3 in this Chapter. 01/31/91(TCA9018%INDEX-8) B - 6 1 • 3-8-50 The proposed wildlife crossing locations along the Corridor route were designed based upon the movement routes determined from previous biological studies conducted on the project area. Figure 3.6.6 depicts these movement routes. Refer to Responses to Comments 1-1-50 and 2-7-3 in this Chapter. 3-8-54 Refer to Response to Comments 2-7-10 and 2-7-13 in this Chapter. 3-8-55, 7-88-53 The discussion of light and glare impacts on page 4-68 of the Draft EIR/EIS is modified to include the following: Examples of affected wildlife include rodents and other small mammals that forage at night to avoid detection by predators; owls and other predators that hunt in darkness; and diurnal (day -time) birds that roost at night in tall trees and other exposed areas. Mitigation Measure 15-17 is revised to include the following: "At interchanges, landscaping shall be used to shield existing adjacent residences from light and glare due to lighting fixtures and freeway signage. All lighting shall be designed and installed so that it is directed away from any natural open space areas along the Corridor. Muted lighting will be installed in areas adjacent to and within 500 feet of open space areas." 3-8-56. 4-31-14, 4-31-15 One commentator asserted that the environmental assessment to be undertaken by The Nature Conservancy as part of their management study of Irvine Company open space properties would be a valuable tool for use by the TCA in developing mitigation measures for the Corridor. We understand that The Nature Conservancy and the Irvine Company have agreed to have the Nature Conservancy conduct an environmental assessment of all existing and proposed Irvine Company open space lands and to assist the Company in developing a management plan for the resources on the open space Properties. The Nature Conservancy evaluation was initiated in late 1990. No information is presently available concerning The Nature Conservancy work and is unlikely to be available for some time. Therefore, it is impossible to evaluate how The Nature Conservancy environmen- 01/31/91(TCA901B%INDEX-B) B- 6 2 C tal assessment and resulting management plan may affect the TCA actions con- cerning the Corridor. As is the case with any significant new information, at the time the Nature Conservancy/Irvine Company environmental assessment and management plan is developed, the TCA will evaluate this information to deter- mine how the TCA may better respond to environmental and other issues concern- ing the Corridor. 3-8-57 Refer to Responses to Comments 1-1-50, 2-7-14 and 3-.5-97 in this Chapter and Mitigation Measures 6-13 and 6-16. Review of final design plans and supporting documentation will be approved by the TCA Board, of which the City of Irvine and County of Orange are members. 3-8-58 The significance of the Bonita Reservoir riparian area is acknowledged in the Draft EIR/EIS. The Draft Wetlands Mitigation Plan provides design and imple- mentation of replacement habitat for the acreage impacted by the Corridor in this area. Refer to Responses to Comments 2-7-3 and 3-5-109 in this Chapter and 3-8-60 under Water Resources. 3-8-101 Page 3-28 has been amended to reflect the date of LSA's Biological Assessment Report as follows: Draft EIR/EIS page 3-28, first paragraph, second sentence: "The 1984 study has been updated by LSA Associates, Inc., (San Joaauin Hills Transportation Corridor Biological Assessment, August, 1990)" 3-8-102 Figures 3.6.1 through 3.6.5 have been amended in the Final EIR/EIS to include compass map symbols. 3-9-6 Refer to Responses to Comments 1-1-50, 2-7-3 and 3-8-55 in this Chapter. • 01/31/91(TCA9018%INDEX-8) B - 63 • 3-9-7. 3-9-8 Mitigation measures for impacts to gnatcatcher, cactus wren, San Diego horned lizard and the orange throated whiptail habitat are discussed in Response to Comment 3-5-97 in this Chapter. An additional mitigation measure has been added pertaining to replacement of raptor roosting sites (refer to Response to Comment 1-1-57 in this chapter: 6-17 Raptor roosting sites will be provided during construction of the Corridor with input from the Project Biologist regarding location, design and quantity of sites. The Resource Management Plan will contain the final specifications and performance standards of the roosting sites. 3-9-13 Refer to Section 4.15.2, "Mitigation Measures", on page 4-130 of the Draft EIR/EIS. Specifically, Mitigation Measures 15-1 through 15-23 cover basic characteristics of the proposed Corridor landscaping, bridge design and overall aesthetics. Additionally, see Mitigation Measure 5-2 for aesthetics of pro- posed sound walls. Refer to Response to Comment 3-5-97 in this chapter regard- ing the components to be included in the Landscape Plan. 3-9-15 TCA cost sharing in open space acquisition efforts in Laguna Canyon is not part of the current mitigation program for the Corridor. However, TCA is open to participating in discussions with the County, the City of Laguna Beach and interested environmental groups regarding the possibility of TCA involvement in such a program. 4-4-5. 4-4-6 There is no evidence to support the conclusion that all the larger animals in the San Joaquin Hills and other areas will die off as the result of the con- struction of the Corridor. The Draft EIR/EIS acknowledges that there will be a net reduction in wildlife populations resulting from Corridor construction. However, this reduction does not necessarily lead to loss of all large animals. 01/31/91(TCA901B%INDEX-B) B - 6 4 • • There is no logical basis for concluding that the land dying as a result of larger animals dying off will leave only gophers, which will dig holes and cause soil erosion. 4-19-8 Refer to Response to Comment 1-2-2 under Cumulative Impacts. 4-20-2 The literature and field survey work conducted for the Draft EIR/EIS (refer to Response to Comment 1-1-25) attempted to determine all sensitive biological resources present or potentially present along the Corridor. There was no sensitive cactus species identified prior to comments on the Draft EIR/EIS. The report on the biological resources of the UCI Campus prepared by the Cham- bers Group also did not identify this species as sensitive. Although the Draft EIR/EIS discusses cumulative effects of the proposed Corri- dor (see Sections 4.7 and 7.0), the Corridor is not expected to create a "Mag- net" effect for new growth. As discussed in Chapter 6.0, approved or committed land uses occupy the majority of available development areas served by the Corridor. Refer to Response to Comme-nt 1-1-15 regarding potential Growth Inducing Impacts of the Corridor. 4-21-16 See Responses to Comments 1-2-25 and 1-1-50 in this Chapter. 4-21-17 The attachment referred to discusses four major effects of the fragmentation of habitat as: 1) restriction and isolation of large free -ranging animals; 2) the loss of genetic integrity and viability within the species; 3) loss of species dependent upon a particular habitat; and 4) invasion by weedy, exotic plant species and opportunistic wildlife species. The Draft EIR/EIS identifies the fragmentation of habitat and the effects on wildlife movement as significant impacts after mitigation. A generic determi- nation of significance or non -significance of the "island effect" or local extinction of wildlife species due to isolation of small, discrete habitat units is not possible. The extinction rate varies among species and it is generally dependent on the size of the habitat and distance from other habi- tats. In the case of the Corridor, the primary "islands" that will be created 01/31/91(TCA9018%INDEX-B) B-65 are relatively large and the "distance" (degree of division) is relatively short, when considering the width of the Corridor for avian species and the land connections for ground dwelling species. The significance of the effects resulting from the loss of genetic diversity (integrity and viability loss) cannot be determined at this time, because 1) the amount of diversity varies among populations of different species; and 2) the amount of genetic diversity required to minimize the effects of inbreeding depression is unknown and is probably dependent upon a) the species being analyzed, b) the numbers of individuals required to avoid inbreeding, and c) the existing genetic diversity in a given population. The numbers of indi- viduals (in a given population) required to avoid inbreeding depression is known only for certain species, however, the number of individuals is not necessarily reflective of the amount of genetic diversity. Invasion by weedy plant species and opportunistic wildlife species is consid- ered not to be significant because, per the amended Mitigation Measure 6-13 (Response to Comment 3-5-97), invasive, weedy or non-native species will not be used within open space areas traversed by the Corridor. 4-21-30, 7-30-1b Refer to Responses to Comments 1-2-25, 1-1-50, 2-7-3 and 2-7-14 in this Chap- ter. 4-22-10, 7-88-53, 7-105-2 Refer to Response to Comment 1-1-50 in this Chapter regarding mitigation for impacts to wildlife movement. The biological analysis evaluated the impacts of the proposed Corridor on wildlife movement patterns and concluded that, even with the three planned crossing locations, the project would result in a sig- nificant unavoidable adverse impact to movement patterns. Refer to Response to Comment 1-1-52 in this Chapter regarding mitigation for potential noise impacts to wildlife. Light and glare was established as a potentially significant impact in the Draft EIR/EIS. Mitigation Measure No. 15-7 (see Response to Comment 3-8-55 in this chapter) specifies that hooded lights will be provided along the Corridor to reduce glare. The Mitigation Measures discussion of Section 4.6 has been amended to reference that measure as it applies to wildlife. The Biological Assessment Report (Technical Studies Volume II, Report No. 5) addresses each of the endangered species per the U.S. Fish & Wildlife Service _ 01/31/91(TCA9018%INDEX-8) B- 6 6 0 list (refer to page 36 of the Biological Assessment Report). Those species which were determined present within the Corridor area of disturbance were ana- lyzed for potential impacts from construction of the facility. The Mitigation Monitoring Program, as required by A.B. 3180, will ensure that all certified mitigation measures in the Final Draft EIR/EIS will be imple- mented. 4-22-28 Endangered, threatened, and rare species are defined by the California Depart- ment of Fish and Game and the U.S. Fish and Wildlife Service as follows: A native species "is rare when, although not presently threatened with extinction, it is in such small numbers throughout its range that it may become endangered if its present environment worsens." A native species "is threatened when, although not presently threat- ened with extinction, it is likely to become an -endangered species in the foreseeable future in the absence of the special protection and management efforts..." A native species "is endangered when its prospects of survival and reproduction are in immediate jeopardy from one or more causes." 4-24-7 Regarding the effect of Laguna Beach Proposition H, refer to Response to Com- ment 3-5-140 under Section 4(f). Refer to Responses to Comments 2-7-6 and 2-7- 9 in this Chapter regarding project mitigation measures. 4-28-5 See Response to Comment 2-9-6 in this Chapter. The species were included at the request of Caltrans and the TCA. 4-28-10 The information in the Biological Assessment was based on the work by P&D Technologies, with additional information provided by follow-up field surveys. The plant community of chamisal chaparral is rare along the Corridor, being found only in a small area on the north facing slope of the ridge between Laurel and Camarillo Canyons west of Laguna Canyon Road. • 01/31/91(TCA9018%INDEX-8) B - 6 7 0 4-28-11 Rock outcrop flora is not recognized as a unique habitat by any biological authority. Rock outcrop flora is composed of species found within major recog- nized habitat types, but usually includes fewer species that are best adapted to rocky conditions. Therefore, this flora was not identified as a separate plant community in the Draft EIR/EIS, although sensitive species, such as dud- leya, that tend to occur in rocky areas were discussed. 4-28-17 Refer to Response to Comment 1-1-50 in this Chapter. TCA is unaware of the referenced memos regarding bridging wildlife movement corridors. 4-28-19. 4-28-29 Refer to Responses to Comments 2-7-5 and 2-7-9 in this Chapter. Refer to the revised project mitigation measures for biological impacts as discussed in Responses to Comments 1-1-25, 1-1-57, 1-1-64, 2-11-4, 3-5-97, 3-5-109, 3-8-55 and 4-28-39 in this Chapter. 4-28-21 The reference to "initial study tables" is unclear as to what tables are being referenced. Two tables are included in the impact section. Table 4.6.A shows quantities of habitat loss as the result of the two alternative designs. This table provides information in a clear format that is easily understood. Table 4.6.B shows levels of wildlife tolerance to certain types of environmental disturbance. This table provides general information on the expected response of wildlife to different types of disturbance. Please refer to Response to Comments 2-7-3 and 2-7-5 in this Chapter. 4-28-22 While some introduced annual grassland habitats in Southern California do play an important role in ecological systems, they are generally considered less important than native habitat types for several reasons, including: 1) they are more common than many habitats, including wetlands, coastal sage scrub and native grasslands; 2) they do not provide habitat for as many sensitive species as wetlands and coastal sage scrub; and 3) the diversity of both native plant and animal species is generally lower for introduced annual grasslands than for most native habitats. The impacted grasslands along the Corridor are also of lower value because of the grazing that has occurred. 01/31/91(TCA9018••.INDEX-B) B-66 to 4-28-24, 4-28-25 The potential loss of dudleya from the project is considered to be significant, as stated in Section 4.6 of the Draft EIR/EIS. However, mitigation provided for this impact (replacement plantings), discussed in Response to Comment 3-5- 97 in this Chapter, reduces the impact to the species below the level of sig- nificance. As mitigated, impacts to this species related to the Corridor will not significantly affect the population as a whole. The cumulative losses are discussed on page 4-69 of the Draft EIR/EIS. 4-28-26 None of these impacts listed in the comment would be significant with applica- tion of the stipulated mitigation measures. In regards to the introduction of exotic, invasive species, please see Response to Comment 3-5-97 in this Chap- ter. Fire hazards and fire control measures are discussed on page 3-56 of the Draft EIR/EIS. Hazardous wastes (such as greases and oils) and fuel spillage are discussed on pages 59-60 of the Biological Assessment report. The Erosion and Siltation Control Plan to be implemented as part of project construction will reduce the potential effect of erosion and sedimentation on native vegetation to below the level of significance. Refer to Response to Comment 1-1-64 in this Chapter. 4-28-27 Refer to Response to Comment 1-1-25 in this Chapter. 4-28-30 Refer to Response to Comment 3-5-97 in this Chapter for mitigation of impacts to coastal sage scrub and oak woodland. Replanting is not proposed for losses of grassland and chaparral, as these impacts are not determined to be signifi- cant. 4-28-32. 4-28-37 The requirement for mitigation monitoring is discussed on page 4-2 of the Draft EIR/EIS. As required by CEQA, the TCA will adopt a Mitigation Monitoring Program at the time of project approval. Refer to Responses to Comments under Mitigation Monitoring. • 01/31/91(TCA9018%INDEX-8) B - 6 9 • A maintenance and monitoring log will be required as part of the Mitigation Monitoring Program for all project mitigation measures. 4-28-39 Mitigation Measure 7-2 has been revised as follows: 7-2 "Wetland habitats within the Corridor area, not impacted by project con- struction, will be designated as Environmentally Sensitive Areas (ESAs) on construction plans and fenced off as appropriate for protection before any Corridor construction begins. In areas where construction is occurring within a portion of and directly adjacent to wetland habitats, fencing will be placed 100 feet outside of the wetland habitat/delineation areas. In areas crossing through wetland habitat, fencing will be placed along the limits of disturbance, as shown in the Draft EIR/EIS. The Project Biologist will review the project grading plans and erosion and sedimenta- tion control plans to insure protection of wetland areas." The Mitigation Monitoring Program specifies that the Project Biologist will be i on -site during construction activities. 4-29-3 There is no over wintering habitat for Monarch butterflies along the Corridor alignment area. 4-31-11 Refer to Response to Comment 2-6-7 under Project Description. 4-32-2 Figures 3-6-1 through 3-6-5 and 4-7-1 through 4-7-7 have been amended to clar- ify the match lines between Corridor segments. The dashed line outlined on these figures indicates the maximum area of disturbance to habitat. Cross streets are shown for reference. 4-32-4 Refer to Responses to Comments 1-1-50, 2-7-3 and 3-5-94 in this Chapter. 01/31/91(TCA901B%INDEX-B) B - 7 0 • 4-32-6 The "Federal Manual for Identifying and Delineating Jurisdictional Wetlands" method was utilized per Caltrans and FHWA requirements as specified in the FHWA Technical Advisory 6640.8A for preparation of EIS documents. This method was adopted in January, 1989 by a joint agreement between the U.S. Army Corps of Engineers, EPA, U.S. Fish -and Wildlife Service and Soil Conservation Service. The "Unified Method" is used by projects involving FHWA, the Clean Water Act (404 Permits), Executive Order 11990, and federal funds. 4-32-7 The commentator's reference to the Draft EIR/EIS text regarding black -shoul- dered kites is taken out of context. The complete text on page 4-67 is provid- ed here in full: "Raptors are one of the most significant and sensitive types of wildlife within the Corridor area. Although some birds of prey such as the black - shouldered kite, American kestrel and turkey vulture can adapt to the presence of humans and human activities, raptors generally require large areas secluded from disturbance that contain suitable foraging and nesting habitats." (Emphasis added) The full quote from the Draft EIR/EIS clarifies that all raptors, including the black -shouldered kite, are considered sensitive, and the significant impacts to these species is clearly stated on page 4-69. 4-32-9 The comment is correct. The Draft EIR/EIS discussion on page 3-38 does not imply that all the plant species found in the riparian woodland plant community are all natives. 4-32-10 The statement referred to in the comment was intended to indicate that the harrier "passing through" was not nesting on site; it was not intended to indicate that the harrier was not resident elsewhere in Orange County. The same paragraph mentions that a pair was seen between El Toro Road and Laguna Canyon Road that may have been in the vicinity of a nest. 0 01/31/91(TCA9018%INDEX-B) B - 7 1 4-32-17 The document states on page 4-72 under Significant Unavoidable Adverse Impacts that there will be a reduction in wildlife populations as a result of the Corridor even after all feasible mitigation measures are implemented. 4-32-19. 7-88-79 Refer to Responses to Comments 1-1-57, 3-5-97 and 3-5-109 in this Chapter. The objectives of the Wetlands Mitigation and Landscape plans include selection of the most feasible locations for habitat establishment as close to the impacted areas as possible. 4-32-20, 4-32-29 Refer to Responses to Comments 1-1-3, 1-1-57, 3-5-97 and 3-5-109 in this Chap- ter. Actual implementation of habitat planting and revegetation plans will take place concurrent with or subsequent to project construction in order to avoid further impacts to mitigation areas from construction activities 4-32-22, 4-32-23, 4-32-24 The County procedure on road construction is to grant a construction easement (which was included within the limits of construction as shown on the figures), beyond which no construction activity can take place. Mitigation Measures 6-3 through 6-10 are intended to minimize constructive activity within the con- struction easement and to minimize impacts to all habitats and wildlife. Refer to Response to Comment 2-11-4 which provides the text of amended Mitigation Measure 6-2. The Mitigation Monitoring Program specifies the responsibilities of the moni- toring by the Project Biologist during construction. The Project Biologist will stake the limits of construction activities as discussed in Mitigation Measure 6-2. 4-32-27 Mitigation Measure 6-9 is intended for construction activities only. Refer to Response to Comment 1-1-64 in this Chapter, which outlines the components of the Erosion and Siltation Control Plan, and Response to Comment 6-17-40 for discussion of the Runoff Management Plan. Also, please see Response to Comment 3-5-97 (Landscape Plan Components) and Exhibit 2 of the Response to Comments document, Aesthetic Design Guidelines; this landscape goals and standards 01/31/91(TCA901B%INDEX-B) B - 7 2 • 0 manual emphasizes the use of drought tolerant and native plants to reduce watering requirements. 4-32-28 The reference is to the Mitigation Measure 6-10. Nesting areas are areas in which nesting does or potentially could take place. The intention of the measure is to define an area to include potential raptor nesting sites that might be disturbed by construction. The area defined will depend upon the raptor species and proximity of nests. 4-32-31. 4-32-32 There will be a Project Biologist, or team of biologists, who will work with the Project Landscape Architect to design the Landscape Plan. The Project Landscape Architect will be a person who is knowledgeable and skilled in this work, because such a person would be required to successfully implement the mitigation measures. It should be noted that many biologists lack the skills necessary to properly design a revegetation plan, because more than the knowl- edge of biological habitats and wildlife requirements is needed in developing successful landscape designs. This was why both a Project Biologist and a Project Landscape Architect are required for the complete implementation of the Landscape Plan. 4-32-33 Refer to Responses to Comments 1-1-57 and 3-5-97 in this Chapter. 4-32-34 The specifications for installation and maintenance of the gallinaceous guz- zlers will be included in the Resource Management Plan. Refer to Response to Comment 1-1-57). The guzzlers will be installed three months prior to con- struction. 4-32-39 The determination that the impacts to wetlands areas will be mitigated to a level below significance is predicated on the successful implementation of the Draft Wetlands Mitigation Plan to be included in the Final EIR/EIS. The plan will specify replacement of impacted wetland acreage at a minimum ratio of one to one. The plan must be approved by the U.S. Army Corps -of Engineers prior to 0 01/31/91(TCA9018%INDEX-B) B - 7 3 6 allocation of a 404 Permit. Refer to Responses to Comments 1-1-13 and 2-7-3 in this Chapter. 4-32-45, 4-32-47, 4-32-48 With exception of the Draft Wetlands Mitigation Plan (included with the FEIS), the Resource Management Plan, Landscape Plan, Erosion and Sedimentation Control Plan and the Runoff Management Plan will be prepared and approved prior to project construction. Findings will be adopted in conjunction with project approval upon certification of the Final EIR by the TCA Board and Final EIS by FHWA. 4-32-49 Refer to Response to Comment 4-17-18 under Construction Impacts. 4-32-50 Trash cleanup will be part of the highway maintenance activities conducted by Caltrans. 4-32-51 The EIR/EIS and Biological Assessment Report graphics were checked for incon- sistencies in habitat areas and minor revisions were made accordingly. The Final EIR/EIS contains the revised graphics. 4-33-29 Refer to Response to Comment 4-17-18 under Construction Impacts. 4-33-31 Refer to Responses to Comments 1-1-50 and 3-5-94 in this Chapter. 4-33-32 Refer to Responses to Comment 1-1-25 and 1-1-50 in this Chapter. 4-33-33 Refer to Response to Comment 3-5-14 under Section 4(f). As discussed in Chap- ter 2.0, a Corridor Route Location Study, EIR No. 267, analyzed 28 alternative 01/31/91(TCA9018%INDEX-8) B - 7 4 0 routes for the San Joaquin Hills Transportation Corridor. From the results of that study, the County of Orange adopted the current route for additional evaluation in consideration of all potential environmental effects of the various alternatives. The impact upon open space areas was one of the poten- tial effects evaluated in that decision. 4-33-34 Refer to Responses to Comments 1-1-25 and 1-1-50 in this Chapter. 4-33-36 It is true that bats cannot be observed in the daytime, however their habitat can be observed. Based on the field surveys, habitat for sensitive bat species such as the greater mastiff bat and the spotted bat, probably does not occur along the Corridor. Nevertheless, additional surveys focusing on these species will be conducted as discussed in Response to Comment 1-1-25 in this Chapter. 4-33-38 See responses 3-5-97 and 4-28-10 in this Chapter. The EIR/EIS does not consid- er that coastal sage scrub is found "'on every low mountain"'. Areas designated as Chaparral on the plant community maps (Figures 1-10 in the Biological Assessment Report) contain primarily chaparral species, it is not uncommon for coastal sage scrub communities to contain some chaparral species such as chamise and likewise chaparral can contain some coastal. sage scrub species. However, in the latter case, these communities were designated as coastal sage scrub based on' the predominance of typical coastal sage scrub species. 4-33-39. 4-33-53 Refer to Response to Comment 4-32-2 in this Chapter regarding amended EIR/EIS graphics. The wetlands habitat illustrated in Figures 4.7.1 through 4.7.7 is correct per the Wetland Identification and Delineation report (Appendix A of the Biological Assessment Report) conducted in March, 1990. The methodology utilized for that habitat mapping work was per the Federal Manual for Identifying and Delineating Jurisdictional Wetlands, (adopted January, 1989 by the U.S. Army Corps of Engineers, U.S. Fish and Wildlife Service, EPA and the Soils Conservation Service). This methodology is required by Caltrans for all wetlands deter- 01/31/91(TCA9018%INDEX-B) B - 7 5 0 minations. Figures 3.6.1 through 3.6.5 were derived from the original mapping work done by P&D Technologies for DEIR No. 494. Several areas on those figures were inadvertently left unmodified and required adjustment to reflect the recent wetlands delineation work referenced above. The figures have been amended to reflect the current condition. Based on a number of comments on the Draft EIR/EIS, two areas, one in El Toro and one in Bonita Canyon, were reeval- uated and determined to be wetlands. Other areas that were reevaluated in response to the comments were still determined to be upland. See Response to Comment 2-9-44 in this Chapter. Figures 3.6.3 and 4.74 have been amended to reflect the populations of sensitive plant species omitted in the Draft EIR/ EIS. 4-33-40 See Response to Comment 2-9-25 in this Chapter. Without the opportunity to review the data/report findings from the UCI Museum of Vertebrate Zoology regarding sightings of California gnatcatchers and cactus wrens since 1988, it is not possible to ascertain the accuracy of the information provided in Exhib- it 3 of the comment letter. 40 4-33-41 Refer to Response to Comment 4-17-18 under. Construction Impacts. 4-33-43, 4-33-44, 4-33-45, 4-33-46, 4-33-47, 4-33-48, 4-33-49, 4-33-50, 4-33-51 Refer to Response to Comment 4-17-18 under Construction Impacts. The retention basin on E1 Toro Road is related to development application in Aliso Viejo approved by the County of Orange. Existing concerns regarding the operation of the El Toro Road detention basin should be directed to that agen- cy. With construction of the Corridor, the TCA will be mitigating all hydro- logical impacts which will involve improvements to the El Toro Road detention basin. The TCA concurs that grading should not commence prior to environmental docu- mentation, and the Agency is consistent with this requirement since no grading by the TCA will be initiated until certification of the Final EIR/EIS. 4-33-54, 4-33-55 The analysis contained in Section 4.7 of the DEIR/EIS evaluated potential im- pacts to wetlands from the proposed project as described in Section 2.0 of the 01/31/91(TCA901B%1NDEX-B) B-76 Draft EIR/EIS. The realignments of Laguna Canyon Road, El Toro Road, Bonita Canyon Road and Ford Road as they relate to the Corridor have been included in the analysis and are shown in the wetlands graphics (Figures 4.7.1, 4.7.2, 4.7.3, 4.7.4, 4.7.5, 4.7.6 and 4.7.7). The extension of Culver Drive to the Corridor is not a part of the Corridor project. 4-33-56 In response to the commentator's statement of Corridor impacts, the environ- mental analysis determined that there would be no unavoidable adverse air quality impacts to biotic resources; road kills would not be a significant adverse effect; the Corridor would not be growth inducing; and the Corridor has been cooperatively planned with other development which led to dedication of regional open space areas in the project vicinity (see Response to Comment 2-7- 14 in this Chapter). Also refer to Response to Comment 3-5-109 in this Chapter regarding components of the Wetlands Mitigation Plan. 4-34-10 See Responses to Comments to 1-1-25 in this. Chapter and 4-17-12 and 4-17-13 under CEQA/NEPA Issues. 4-34-15 The Draft EIR/EIS does not deny the potential presence of occasional mountain lions in the San Joaquin Hills area, however, 'please see Response to Comment 1- 1-25 in this Chapter. 4-34-19 See Response to Comment 2-9-36. The studies were performed by a qualified wetlands analyst. 4-35-2 Refer to Responses to Comments 2-7-6 and 3-5-97 in this Chapter. 6-17-5 The discussion of the avoidance alternatives suggested is provided in Section 4.7 and Technical Study No. 5 regarding wetland resources and Appendix A re- garding Section 4(f) resources. • 01/31/91(TCA901B%INDEX-B) B - 7 7 • 6-17-11, 6-17-12, 6-17-13, 6-17-14, 6-17-15, 6-17-43 Refer to Response 2-7-14 in this Chapter for discussion of regional open space issues related to the Corridor. Regarding Comment 6-17-15, refer to page 3-39 of the Draft EIR/EIS which dis- cusses the status of the Orange County Turkish rugging. This species is dis- cussed in the analysis because, as a Category 2 Candidate species, its status is uncertain and, therefore, it is a potentially sensitive species. Refer to Response to Comment 3-5-97 in this Chapter for discussion of replace- ment of coastal sage scrub habitat, and Response to Comment 1-1-57 for discus- sion of oak woodland revegetation as part of the Resource Management Plan. 6-17-17 As stated in Section 4.6, no significant impacts to vegetation and wildlife will occur with the No Build Alternative. 6-17-45 TCA will take into consideration the location of planned trail facilities as part of the final design location for three crossings. Refer to Response to Comment 1-5-50 in this Chapter. 6-17-51 The conclusions in Section 10.0 remain as stated in the Draft EIR/EIS. 7-4-2. 7-8-5. 8-24-3 Refer to Response to Comment 4-15-1 under Construction Impacts. 7-30-12 This comment was evidently made in reference to the work done on the Foothill Transportation Corridor. The surveys conducted for the San Joaquin Hills Transportation Corridor were done at the appropriate time of year for the California gnatcatcher and other sensitive species. Refer to Response to Comment 1-1-25 in this Chapter. 01/31/91(TCA901B%INDEX-B) B - 7 8 0 7-52-1 Refer to Responses 2-7-3 and 2-7-14 in this Chapter. 7-54-1 The comment represents the opinion of the commentator and will be taken into consideration by the decision makers. 7-56-22 Refer to Responses to Comments 2-3-2 and 7-114-14 under Water Resources. 7-56-23 The Draft EIR/EIS (Section 2.9) determined that the No Project Alternative is the environmentally -superior alternative in terms of impacts to biological re- sources. However, in order to implement the proposed Corridor, the Draft EIR/EIS has determined that, with consideration of environmental impacts as well as structural design requirements and feasibility, it would not be feasi- ble to completely avoid impacting certain wetland and oak woodland habitats along the alignment. Refer also to the "Analysis of Avoidance Alternatives" in Volume II of the Technical Studies document. The selected alignment alterna- tives, Conventional and Demand Management, evaluated in the EIR/EIS are the result of the Phase I Alternative Alignment Study EIR, and DEIR No. 494. These analyses evaluated the environmental superiority of various alignment alterna- tives in consideration of minimizing of potential impacts to wetlands and other types of habitat areas. 7-56-24 Refer to Response to Comment 1-1-13 in this Chapter. It is noted that the potential impacts to Bonita Reservoir would total 2.9 acres (with the Demand Management Alternative). The total reservoir area is comprised of approximate- ly 26 acres of wetland habitat. 7-56-27. 7-128-3 Refer to Response to Comment 3-5-94 in this Chapter. The DEIR/EIS concluded that road kills would not be a potentially significant impact from the proposed Corridor (refer to discussion in Section 4.6). 01/31/91(TCA9018%INDEX-8) B - 7 9 7-56-28 Refer to Responses to Comments 1-1-50 and 1-1-52 in this Chapter. 7-56-31 Several statements in this comment are not precisely accurate. The native vegetation in southern California has proven to be fairly resilient to change, including changes brought about by intensive grazing and other uses that heavi- ly impact the habitats. While not extensive, coastal sage scrub, chaparral and especially Mediterranean grasslands are far from being among the least dominant vegetation [habitats]. Far more rare habitats (or vegetation) just within California include vernal pools, wetlands, alpine tundra and coastal maritime scrub. There is no basis for assuming that coastal sage scrub, chaparral and especially Mediterranean grasslands are more sensitive to pollution and "cli- mactic" [sic] conditions than other habitats. Contrary to the statement that many of our native plants require optimum conditions to survive, many plants in southern California show a remarkable adaption and resiliency to fluctuating, changing and differing climatic factors, soil types, slope orientation and sun exposures. It is true that while drought -tolerant plants can tolerate low water conditions, other factors such as high salt content, toxic chemicals or soil compaction may not be so readily tolerated. 7-56-51 Response to Comments 1-1-57, 3-5-97 and 3-5-109 in this Chapter specify the components and performance standards of the mitigation plans which will be implemented to replace coastal sage scrub, sensitive plant species and riparian plant communities impacted by the Corridor. The success of the revegetated communities will be monitored by the Project Biologist in accordance with the performance standards required by project approval. 7-57-4 Refer to Responses to Comments 1-1-50, 2-7-3, and 2-7-9 in this Chapter. 7-82-1. 7-82-12, 7-82-13, 7-82-19, 8-20-2 The study by Steve Loe was concentrated primarily in the Irvine Coast area around Newport Coast Drive (previously Pelican Hill Road), and only generally relates to the Corridor. Several of the suggestions of culvert or undercross- ing design proposed by Mr. Loe will be taken into consideration as part of final design of the wildlife crossings. 01/31/91(TCA9018%INDEX-B) M • • There is no basis for the assumption that the failure to include the recom- mendations by Mr. Loe will result in the loss of large mammals in the San Joaquin Hills area. However, there will be reduction in large mammal popula- tion sizes as a result of the construction of the Corridor. This reduction is considered to be a significant impact and is identified in the DEIR/EIS on pages 4-64 through 4-70. The statement that the failure to include some or all of the suggestions pro- vided by Mr. Loe will result in no mitigation being provided by the Corridor is incorrect. Refer also to Responses to Comments 1-1-50, 2-7-3 and 2-9-19 in this Chapter. 7-82-2 In general, cost is not a factor in determining the appropriate mitigation measures for identified impacts. Exceptions to this would include cases where the measures would be extremely costly, e.g., excessive earthwork to construct overpasses, bridges, tunnels for any significant length or quantity. The feasibility of each measure is weighed against the potential impact and alter- native measures which could be implemented. 7-82-9 Dudleva stolonifera was not found in the project area of disturbance during field surveys conducted for the biological analyses (current and previous). Refer to the referenced field studies in the Biological Assessment Report (Volume II of the Technical Studies document). 7-86-13 No springs were discovered during the field surveys that would be impacted by the Corridor. However, there may be an impact if the springs are adjacent to the Corridor and will no longer be used by wildlife. Mitigation in the form of guzzlers has been included in the EIR/EIS for impacts to drainages and subse- quent loss of water sources. The following has been added to Mitigation Mea- sure 6-14: "Guzzlers will serve to mitigate project impacts of loss of available water sources for wildlife." Section 4.3 of the DEIR/EIS discusses impacts to groundwater. 01/31/91(TCA9018%INDEX-B) B - 8 1 7-86-18 Refer to Responses to Comments 1-1-13 and 2-7-9 in this Chapter. 7-86-19 The Final EIR/EIS contains the comments of the resource agencies on the poten- tial impacts as discussed in the Draft EIR/EIS. 7-86-20 The Irvine Company currently owns the Bonita Canyon Reservoir and dam. Future ownership of the reservoir is not determined at this time; however, it is anticipated that it will be preserved as riparian habitat. Inquiries regarding seismic stability of the dam should be addressed to The Irvine Company. 7-86-21 See Response to Comments 1-1-13 and 2-7-9 in this Chapter. • The project proponent is responsible for the correct and complete implemen- tation of all mitigation required by any environmental document. The agencies act as reviewers of mitigation and to ensure compliance with the mitigation measures developed. 7-86-35 The Biological Assessment for the Corridor evaluated potential impacts to specific plants and wildlife species by area, including Bonita Reservoir and San Diego Creek (Technical Study No. 5, pgs. 17-18). Also identified in the Assessment report are impacts from the Corridor to wildlife movement (pg 70). These cited discussions are also provided in Section 4.6 of the Draft EIR/EIS. 7-88-3 See Response to Comment 2-9-25 in this Chapter. See also Response to Comment 2-6-1 in this Chapter regarding the status of the cactus wren. 7-88-4. 7-88-6. 7-88-7 Refer to Responses to Comment 4-17-18 under Construction Impacts. 01/31/91(TCA9018%INDEX-B) B - 82 0 s 7-88-5 See Response to Comments 1-1-13, 1-1-25 and 2-7-3 in this Chapter. 7-88-8 The TCA will comply with all mitigation measures adopted for the project. Mitigation Monitoring will be aggressively pursued through the implementation of a Mitigation Monitoring Program consistent with the intent of AB 3180. Exhibit 3 is the Mitigation Monitoring Program for the Corridor. 7-88-9 See Response to Comment 2-6-1 in this Chapter. The Long Range Development Plan for the campus has since been reviewed and the relevant information incorpor- ated in the document. • 7-88-10 The ROW map included in the Draft EIR/EIS shows the ROW as defined in previous documents. The area set aside as mitigation for campus development is not included in this area. 7-88-11 The CEQA documents referred to in the comment are not identified by title. Therefore, it is impossible to know to which document the commentator is refer- ring: However, all documents known and available at the time of the prepara- tion of the Draft EIR/EIS were reviewed for relevant information. The Campus Long Range Development Plan Final EIR was not available at the time of dis- tribution of the Corridor Draft EIR/EIS. 7-88-13 See Responses to Comments 1-1-25 and 2-6-1 in this Chapter. 7-88-17, 7-8-18 The current alignment of the Corridor was based in part on the concerns of the resource agencies to minimize impacts to wetlands. Of the biological resources cited in the comment, the wetlands are considered by most biological profes- sionals to be of the greatest concern, both because the habitat is scarce and 01/31/91(TCA9018%INDEX-B) B - 83 • becoming more scarce, and because wetlands provide one of the most biologically diverse habitats in southern California. Comment 7-88-18 indicates the opinion of the commentator with regard to the relative value of habitats. No response is necessary. 7-88-21 Refer to Responses to Comments 2-7-3, 2-7-10 and 2-7-13 in this Chapter. 7-88-25 and 7-88-26 See Responses to Comments 2-7-3, and 2-7-10 in this Chapter. 7-88-41, 7-88-42 See Responses to Comments 1-1-25, 1-1-50, 2-7-3 and 3-5-10 in this Chapter. It should be noted that other factors besides cattle control the population of • deer in the San Joaquin Hills area, among them disease, parasites and preda- tors. In the event of removal of cattle in Laguna Canyon, the conclusions regarding deer movement as presented in the Draft EIR/EIS and in Response to Comment 1-1-25 in this Chapter would not substantially change. 7-88-43 Studies of the home ranges, etc. of bobcat, coyote and others could provide additional information on these species. The information would not change the conclusions of the impacts provided in the DEIR/EIS, which states that signifi- cant impacts to these and other species remain even after mitigation. 7-88-44 The preservation through purchase of entire canyons is not feasible. The majority of the canyons crossed by the Corridor are either already planned for preservation or for development. Refer to Response to Comment 2-7-14 in this Chapter. The proposed locations of the wildlife crossings (Response to Comment 1-1-50 in this Chapter) reflects these future land use designations. 7-88-45 See Responses to Comments 2-7-6, 2-7-9, 3-5-97 and 3-9-7 in this Chapter. 01/31/91(TCA9018%INDEX-B) B- 84 0 Fundamental population characteristics such as population sources and sinks (Pulliam, 1988) function to define wildlife and plant populations and the influences upon their growth and decline. As such, characteristics are based on whole populations and not on small subsets of these populations. Therefore the determination of fundamental population characteristics, while informative, does not provide additional information for the determination of impacts. 7-88-46, 7-88-47 The comment contains factual information, along with an opinion regarding maintenance requirements of coastal sage scrub habitat. No response is neces- sary. 7-88-61 The commentator does not specifically identify the referenced analysis conduct- ed by the National Park Service. The Section 4(f) analysis contained in Appen- dix A of the Draft EIR/EIS identifies all significant impacts of the proposed project on public lands along the Corridor alignment. 7-88-71 Refer to Response 3-5-97 regarding revegetation with coastal sage scrub. Re- garding mitigation of impacts to oak woodland habitat, losses are proposed to be mitigated to a level below significance as determined by the project biolo- gist. Refer to revised Mitigation Measure 6-15, as provided in Response to Comment 3-5-99 in this Chapter. 7-88-73 This species of land snail (Helminthoglypta tudiculata) has not previously been identified as a significant species by any wildlife agency. Therefore, impacts to this species were not specifically addressed. The Draft EIR/EIS acknowledg- es the loss of wildlife populations due to the Corridor. The land snail is in- cluded in this overall impact. 7-88-75 See Response to Comment 2-9-6 in this Chapter. The species regarded by CNPS as "sensitive, rare, threatened or endangered" were evaluated for inclusion in the EIR/EIS. Mitigation was provided for those species that were significantly impacted by the Corridor (Dudleya inulticaulis and Chorizanthe staticoides chrysacantha). It should be noted that species identified by the CNPS as rare 0 01/31/91(TCA9018%INDEX-B) B - 85 0 or endangered (CNPS does not designate threatened species) are not always officially listed as rare, threatened or endangered by federal and State wild- life agencies. 7-88-77 The comment references a "unique fen -like wetland" in the lower canyon. There are no fens in Laguna Canyon. Fens are characterized by alkaline soils found in high latitude areas. Generally, these areas experience severe winter condi- tions of rain and snow which result: in the development of the saturated alka- line soils upon which fens develop. The wetlands in Laguna Canyon were thoroughly described and impacts to those wetlands were also described. Project impacts will not result in the loss or degradation of any downstream wetlands. 7-88-79 Refer to Responses to Comments 1-1-57, 3-5-97, and 3-5-109 in this Chapter. Wetland mitigation sites are proposed as part of the Draft Wetlands Mitigation Plan, included in the Final EIS. 7-88-80 See Responses to Comments 1-1-57, 2-7-3 and 3-5-109 in this Chapter. The commentator's opinion regarding use of Aliso Creek as a mitigation area for replacement of wetland habitat is noted. The County of Orange has adopted specific planting guidelines for Aliso Creek mitigation areas within the Wild- life Enhancement Program. 7-108-1. 7-108-3 Realignment of the proposed Corridor alignment to the north in the Bonita Creek area would impact the UCI Ecological Preserve area. Refer to Response to Comment 1-2-49 in this Chapter. 7-108-4 Refer to Response to Comment 1-1-50 in this Chapter. 01/31/91(TCA9018%INDEX-8) B- 86 • 7-114-18 Refer to Responses to Comments 2-7-9, 3-5-97 and 4-32-20 in this Chapter. The Wetlands Mitigation Plan entails creation of new wetland areas in addition to enhancement of existing areas. The careful siting of grading spoils and simi- lar measures are mitigation intended to minimize construction impacts; they are not intended as mitigation for loss of wetland habitat. 7-118-5 Refer to Responses to Comments 2-7-6 and 2-7-14 in this Chapter. The commentator's concerns regarding potential losses of wildlife and open space are noted, and will be considered by the decision makers. 7-119-10, 7-119-11 Refer to Response to Comment 3-5-68 under Water Resources. Potential impacts to the groundwater table were determined to be insignificant (Draft EIR/EIS, page 4-29). 7-119-12 Refer to Responses to Comments 1-1-13, 1-1-50 and 2-7-6 in this Chapter. 7-120-2 Refer to Responses to Comments 1-1-50, 2-7-3, and 2-7-6 in this Chapter. 7-128-3 The fence to be installed along the length of the Corridor will be repaired when necessary as part .of the routine highway maintenance performed by Cal - trans. The Draft EIR/EIS determined that roadkills would not be a significant unavoidable adverse impact of the proposed project (Section 4.6 of the Draft EIR/EIS). As such, TCA does not propose to replace wildlife lost as a result of roadkills on a 1:1 basis. 7-128-4 The Mitigation Monitoring Program will specify the required amount of time necessary for the Project Biologist to be on -site during construction and implementation, operation and maintenance of the mitigation measures. The 01/31/91(TCA9018':INDEX-e) B-87 monitoring will be conducted by more than one biologist wherever necessary, as specified in the Program. 7-140-2 Refer to Responses to Comments 2-7-3, 2-7-10 and 3-5-97 in this Chapter. Im- pacts to sensitive species were addressed in Section 4.6 of the Draft EIR/EIS. 7-147-2 See Responses to Comments 2-7-3, 2-7-14, 3-5-97 and 4-21-17 in this Chapter. There is no basis for the statement that the coyote will be lost as a result of the development of the Corridor. The Draft EIR/EIS does not state that the predator -prey balance will change. In response to the questions asked regarding the coyote, the studies requested have not been done. This information was not considered essential to determine the impacts of the Corridor. See Responses to Comments 1-1-50 and 2-7-3 in this Chapter regarding wildlife movement corridors. In response to the question asked regarding the interconnection of sensitive bird populations and the coyote, see Response to Comments 1-1-50 and. 2-7-3 in this Chapter. There is no scientific data on the size of the population neces- sary to ensure the survival of each sensitive bird species. Population sizes are usually dependent upon habitat size, quality and availability. 7-147-3 The regional dedicated open space in the Newport Coast and Aliso Woods areas totals approximately 16,000 acres, not 60,000 acres. Refer to Response to Comment 3-5-97. 8-1-1 It is not clear from the comment which specific canyon the commentator is referencing, however the Biological Assessment evaluated impacts to wildlife species within Upper Laurel Canyon (Technical Study No. 5, pages 24 and 25). 8-6-2 Refer to Responses to Comments 1-1-50, 2-7-3, and 2-7-6. The Biological As- sessment provided in the Draft EIR/EIS has addressed the potential impacts to 01/31/91(TCA901B%INDEX-B) B- 88 • wildlife populations whose territory interacts with the proposed Corridor alignment. 8-11-1. 8-14-2. 8-15-2 Refer to Responses to Comments 1-1-13, 1-1-50, 2-7-3, 2-7-6 and 2-7-9 in this Chapter. The biological analysis in the Draft EIR/EIS concluded that the loss of habi- tat, and wildlife and plant individuals due to construction of the proposed Corridor would be a significant unavoidable adverse impact. Approval of the project would necessitate a decision of overriding consideration of these iden- tified impacts. The Mitigation Monitoring Program will be implemented to ensure proper instal- lation, operation and maintenance of the adopted measures. As part of this program, Environmentally Sensitive Areas (ESAs) will be delineated by the • designated Project Biologist (and biological monitoring team) as areas to be protected during construction. Refer to Response to Comment 2-11-4 in this Chapter. 8-19-9. 8-20-1 Refer to Responses to Comments 1-1-25, 3-5-97 and 7-82-9 in this Chapter. 8-19-12 Refer to Responses to Comments 1-1-25, 2-7-6 and 7-82-1 in this Chapter. 8-36-3 Refer to Responses to Comments 2-7-3, 2-7-6 and 2-7-9 in this Chapter. 0 01/31/91(TCA9018%INDEX-B) B - 89 CEQA/NEPA ISSUES 1-2-1. 2-7-2. 3-4-2. 3-4-29, 3-5-8. 4-17-17, 4-22-31, 6-15-1. 6-15-2. 8-4-5. 8- 14-6 These comments refer to overall inadequacies of the EIR/EIS. They do not refer to specific deficiencies, but rather are generally introductory statements by the commentator, which lead into their specific comments. For responses to the specific deficiencies, the reader is referred to those comments. The general opinion of the authors with respect to the adequacy. of the DEIR/EIS will be taken into consideration by the decision makers. 1-2-8. 1-2-9 Please refer to Response to Comment 1-2-2 under Cumulative Impacts. 1-2-10 As discussed at greater length in the Alternatives Chapter, the EIR/EIS does address a full range of alternatives, including alternatives to the project, such as mass transit or other regional roadway improvements, and alternative alignments for the project. Although alternative alignments were addressed through a tiered CEQA process in EIR 267, the analysis of alternative align- ments is summarized at length in the EIR/EIS, and EIR 267 is incorporated by, reference. 1-2-11 Although an attempt was made by the drafters of the EIR/EIS to conform to the 300 page limit given in 40 C.F.R. Section 15027, the TCA is cognizant of the advisory nature of the CEQ provision. The drafters have attempted to limit the size of the main text of the document, in order to keep the EIR/EIS manageable as an information source for the general public. In fact, the DEIR/EIS runs closer to 400 pages than to the 300 recommended by CEQ. In order to provide complete information on this unusually complex project, the EIR/EIS includes extensive appendices and technical reports volumes, containing material of more technical nature. In this manner, the EIR/EIS achieves both the public infor- mation and full disclosure goals of NEPA. 1-2-12 In response to this request, EPA will be removed from the list of cooperating agencies for the Corridor EIR/EIS. 01 /31 /91(TCA9018%I NDEXC) C/N-1 1-2-13 The U.S. Army Corps of Engineers, along with other involved or interested agencies and individuals, received the DEIR/EIS for review. Regarding compli- ance with the requirements of the Clean Water Act, please refer to Responses to Comments 1-2-48, 1-2-49, 1-2-51, 1-2-52, 1-2-53, 1-2-55 through 1-2-60 under Biological Resources and Responses to Comments 1-2-59 and 1-2-60 under Cumula- tive Impacts. 1-2-14 An initial Record of Decision issued by FHWA would certify the EIR/EIS for NEPA adequacy. It would not commit FHWA to funding approvals for the Corridor project. 1-2-15 -It is anticipated that all federal approvals for the Corridor, including any FHWA actions, will be based on the EIR/EIS. 2-7-16 In the event of additional environmental documentation, all appropriate agen- cies will be included in preparing the scope of such additional environmental review as required by CEQA and NEPA. 3-4-5. 3-4-30, 3-4-35 All facilities which are an integral part of the project, as shown on the con- ceptual plans of April, 1990, were analyzed in the EIR/EIS. This includes the HOV lanes, access ramps, flyover and underpass referenced in the comment. There was no intent to split the project into parts. Impacts are analyzed and miti- gation measures identified as necessary for all project components. Also see responses to 3-4-31 through 34 under Project Description. 3-4-39, 3-4-90, 6-13-14 The Draft EIR/EIS acknowledges that construction of I-5 Interchange Alternative Option 2 will require the relocation of a number of businesses, including Sepulveda Building Materials, and could potentially result in the loss of tax revenues to the City of Laguna Niguel. (Draft EIR/EIS Section 4.9). As dis- cussed in Response to Comment 3-4-9 under Fiscal Impacts, CEQA does not require specific evaluation of economic or social effects, such as those potentially 01/31/91(TCA9018%INDEXC) C/N-2 .7 9 46 C7 resulting from the loss of tax revenue. Further, the physical results of a potential decline in tax revenue are too speculative to be currently assessed. The Draft EIR/EIS does discuss the impact of the construction of I-5 Inter- change Alternative Option 2 on the effected businesses including Sepulveda Building Materials. The CEQ regulations implementing NEPA, and NEPA case law, indicate that social and economic impacts may be assessed at a lesser level of detail in an EIR than purely environmental or ecological concerns, and general- ly, effects to a local tax base are not required to be assessed in an EIS. As indicated in the Draft EIR/EIS, the TCA is participating in a study of land use opportunities within the City of Laguna Niguel to encourage business relocation within the city and thereby reduce potential effects on the City's tax reve- nues. As described above, the studies of land use alternatives in the City of Laguna Niguel are outside the scope of the EIR/EIS. 3-4-82 Mitigation Measures to alleviate the impacts to the City are provided in the • various environmental topic sections of the EIR/EIS. 3-4-83 As stated on page S-6, the list of Areas' of Controversy/Issues to be Resolved is a summary list. The list includes "I-5 Confluence land use/traffic studies", which covers some of the impacts with which the City of Laguna Niguel is concerned. Contrary to the comment, this does not represent a procedural deficiency of the EIR/EIS. 3-4-84 For the majority of environmental topics, impacts are not called out by city. However, significant unavoidable adverse impacts occurring within Laguna Niguel are covered in the DEIR/EIS. All unavoidable adverse impacts are summarized in Chapter 10 of the DEIR/EIS. For a more detailed analysis of the impacts, the reader is referred to the environmental topics in the EIR/EIS. 3-5-111 All mitigation measures which state that a certain action shall or will be done, unless otherwise stated, are necessary to reduce impacts to a less than significant level. The extent to which specific measures reduce project relat- ed and cumulative impacts is identified in the subsection of each Chapter 4 environmental topic, and in Chapter 5, entitled SIGNIFICANT UNAVOIDABLE ADVERSE 0 01/31/91(TCA9018%INDEXC) C/N-3 IMPACTS. In some cases, it is also identified in the impacts analysis and in the mitigation measures. 3-5-113, 7-84-22 California Government Code Section 66484.3 authorizes the County of Orange and cities within the County to join together to plan for and develop major tho- roughfares and bridges, including the Corridor. TCA is a public agency formed by a Joint Powers Agreement among the County of Orange and the cities of Costa Mesa, Dana Point, Irvine, Laguna Niguel, Mission Viejo, Newport Beach, San Clemente, San Juan Capistrano and Santa Ana. Pursuant to CEQA, the TCA is acting as Lead Agency for the preparation of environmental documentation for the Corridor. CEQA requires that where a project subject to approval by a public agency may have a significant effect on the environment, the public agency must prepare an Environmental Impact Report prior to taking action on the project. CEQA is intended to insure that public agencies fully assess the potential environmental effects of proposed actions. Where a public agency is considering action on a public project, CEQA does not require that environmen- tal documentation be prepared by a public agency other than the agency propos- ing the project. 3-6-16 With respect to the schedule relative to the P&D I-5 Land Use Study, see Response to Comment 3-4-38 under Fiscal Impacts. Design/Build award is sched- uled to occur at the earliest in March of 1991. 3-6-17, 3-6-110 The P&D I-5 Land Use Study will be available for public review in mid -January, 1991. This is approximately one full month prior to Board action on the DEIR/ EIS. This should be ample time for City staff to review and interpret the data and obtain review by City Commissions and the Council. 3-6-56 The correction is noted; it does not affect the conclusions of the EIR/EIS. The editing change is hereby incorporated into the Final EIR/EIS. 3-6-108 The TCA expects to distribute the Response to Comments document at least two weeks prior to the Board Hearing certifying the EIR/EIS. 01 /31 /91(TCA901 B% I NDEXQ C/N-4 • i 4-7-13 The comment asks that the EIR/EIS be rewritten to describe the project's impac- ts and purposes more realistically. The comment does not state specific text which needs to be rewritten; therefore, it is not possible to respond. Howev- er, it should be noted that information in the Response to Comments will be incorporated into the Final EIR/EIS, and it is likely that some of the text will be rewritten or expanded to add information/clarification from the Com- ments made on the Draft EIR/EIS. 4-17-12, 4-18-2. 4-31-2 State legislation authorizes both the collection of developer fees and the construction of the Corridor as a toll facility. The public review period for the DEIR/EIS was consistent with the requirements of CEQA and NEPA. CEQA requires a review period of a minimum of 45 day; while NEPA requires at least a 60 day review period. The review period for the DEIR/EIS was 73 days. The commentator does not identify where the EIR/EIS is considered inadequate; the comment is therefore considered the opinion of the commentator and will be taken into consideration by the decision makers during the review process. However, this general issue (adequacy of the (EIR/EIS) is addressed throughout the comments and responses. 4-17-13, 4-17-14, 7-114-1. 7-119-15 The formal period for comments on the Draft EIR/EIS extended for 73 days bet- ween September 15, 1990 and November 26, 1990. Comments received subsequent to the end of the formal comment period have been included in this Response to Comments document. Public review for the Draft EIR/EIS exceeds the minimum public review requirements of CEQA (minimum 45-day public review period when state agencies are involved, CEQA Guidelines Section 15087(c) and NEPA (minimum 60-day public review period, 40 C.F.R. Section 1506.10(c)). 4-22-2. 4-22-18, 4-22-31 The opinion of the Natural Resources Defense Council with respect to the ade- quacy of the Draft EIR/EIS will be taken into account by the decision makers. 01/31/91(TCA9018%INDEXC) C/N-5 4-22-17 The mitigation measures in the EIR/EIS are meaningful in that they are specif- ically identified, capable of implementation, and tied to a time line that is realistic and definite. Where specific information is not available to formu- late specific mitigation actions, the preparation of mitigation plans is iden- tified as a mitigation measure, and appropriate guidelines or criteria for such mitigation plans are set forth. Due to the performance criteria set forth in the measures, it is not anticipated that additional significant environmental effects will occur as a result of the implementation of these measures. Pursu- ant to AB 3180 (codified at Public Resources Code Section 2108.6), a mitigation monitoring plan will be adopted by the TCA Board at the time of project approv- al. The reference in the last sentence of the comment to other mitigation measures is addressed in the response to the Department of the Interior letter, which contains USFWS comments beginning at 1-1-10 under Biology. 4-24-15, 4-24-16 0 Refer to response -to comments topics under land use, biology, water resources, traffic, and air quality. Regarding proposed combined analysis of the Corridor with other regional transportation facilities, please refer to Response to Comment 1-2-2 under Cumulative Impacts. 4-28-3. 4-28-18 The summary format was developed to meet the requirements of CEQA and NEPA, Caltrans and FHWA. It is acknowledged that the summary table in Chapter 4 is unusual, however this is a format issue only and does not affect the substan- tive issues in the EIR/EIS. 4-33-52 TCA was not a sponsor of the "ground -breaking" two years ago which is referred to in the comment. The Foothill Corridor has been analyzed in EIR No. 423, and the northern segment was the subject of a Supplemental EIR, which was certified by the TCA Board in May, 1990. There are no federal clearances required for the northern segment of the Foothill Transportation Corridor, nor are federal funds utilized or a connection to a federally funded facility required. Regarding confidence in the adequacy of the document, that will be determined by the TCA Board of Directors, who are elected officials, based on the Draft . 01/31/91(TCA9018%INOEXC) C/N-6 C EIR/EIS, the Response to Comments, and opinions of the commentators. The DEIR/ EIS was reviewed by Caltrans and FHWA before being distributed for public review, and was prepared in accordance with those agencies' policies and CEQA and NEPA. �, nil'V: The information requested is provided in the Draft EIR/EIS. The comment refers to a "decade old study that has failed to evaluate up-to-date planning solu- tions". It is true that the Corridor has been proposed and evaluated over a long period of time. However, continuing study has reconfirmed the need for the project and the inability of other alternatives to meet the project objec- tives. The Draft EIR/EIS does not simply rely on an old study, but has incor- porated new studies and evaluation to ensure that the information for the deci- sion makers is current. 4-34-3 The Draft EIR/EIS analyzed six categories of alternatives in addition to two I- 5 connection alternatives and two project design alternatives. A mass transit alternative was discussed on pages 2-32 and 2-33 of the Draft EIR/EIS. The DEIR/EIS does describe and analyze a full range of alternatives, including alternative routes. Please see Response to Comment 3-4-40 under Alternatives. 4-34-22 A complete analysis of the impacts on neighborhoods and property owners, including those referenced in the comment, is provided in the appropriate sections of the EIR/EIS. These include land use, noise, air quality, and housing and business relocation. 6-7-4. 6-9-5 Please see Response to Comment 6-16-1 under Housing/Business Relocation. 6-13-2 Your concerns regarding Option #2 are noted. With respect to your concerns regarding public noticing of the project, please see Response to Comment 6-16-1 under Housing/Business Relocation. Furthermore, the TCA has initiated sessions with the landowners affected by confluence improvements. 0 01/31/91(TCA9018%INDEXC) C/N-7 • 6-13-13. 6-15-4. 6-15-52, 7-29-14 The I-5 Land Use Study by P & D Technologies will be made available to the TCA Board in mid -January, 1991, for use in making their decision to approve or deny the Corridor project. The study, although related to the Corridor project, is not a part of the DEIR/EIS. Therefore, we do not feel it is appropriate in this situation to request an extension of the public review period for the DEIR/EIS. Additionally, the study is not an environmental document and conse- quently is not governed by the requirements for public review under CEQA and/or NEPA. The document will be distributed to interested members of the public after mid -January. Please see Responses to Comments 3-4-38 under Fiscal Impacts and 7-29-13 under Housing/Business Relocation. 6-13-14. 8-19-8 -CEQA and NEPA require the TCA to evaluate and respond to all comments received on the Draft EIR/EIS. The responses must manifest a good faith, reasoned analysis. See Response to Comment 3-6-108 in this Chapter regarding availability of the Response to Comments document. Further, previous comments were considered' in developing the project alterna- tives, design and mitigation addressed in the DEIR/EIS; and citizen comments are considered by the TCA Board and FHWA in making decisions on the project. 6-13-15 The TCA will continue all coordination activity with Sepulveda Building Mate- rials and the business owners in the I-5 Confluence area. 6-14-2 Please see Response to Comment 6-16-1 under Housing/Business Relocation. 6-15-51 Alignment Option #1 and #2 have been discussed and analyzed at length in each relevant area of the DEIR/EIS, including the project description, affected environment, and environmental consequences and mitigation measures. 01/31/91(TCA9018%iNDEXC) C/N-8 • • 6-15-53 Option #2 would only be implemented with the Demand Management Alternative. Therefore, this option is referred to as the Demand Management Alternative. Option #1 can be implemented with either the Demand Management or Conventional Alternative. The pairings were provided for ease of reference. 6-15-54 Cost and efficiency will be considered by the decision makers in reaching a conclusion on Option #1 or #2 as part of their review of engineering features related to Corridor construction. 6-15-56 The information presented in the DEIR/EIS is accurate and complete for evaluat- ing the environmental impacts associated with Corridor construction. Addition- al detailed information relative to cost and scheduling are engineering details and are not necessary for the environmental analysis of the EIR/EIS. The Board of Directors has been presented engineering details at numerous public meetings regarding Corridor phasing and cost estimates. This information will be con- sidered by the Board during their deliberations regarding selection of Option- #1 or #2. 6-15-68 Your opinion regarding the information that should be contained in the EIR/EIS is so noted. Asm Economic studies have been performed by the City of Laguna Niguel (see Response to Comment 3-4-8 under Fiscal Impacts). The TCA's Land Use Study is intended for a different purpose (see Response to Comment 3-4-38 under Fiscal Impacts). The appraisal requirement for right-of-way acquisition may only commence upon certification of the EIR/DEIS. 6-17-2 The statement in the EIR/EIS is an explanation of FHWA policy regarding imple- mentation of NEPA requirements. • 01/31/91(TCA9018%INDEXC) C/N-9 • 6-17-50 The second page of Chapter 8.0 was mailed to all parties who received the DEIR/EIS for insertion into their copy of the document. This page will be included in the FEIR/EIS. 6-20-11 See Response to Comment 6-16-1 under Housing/Business Relocation. Please note that the next scheduled public hearing regarding this -project is February 14, 1990, at 9:30 a.m. at Santa Ana Civic Center - Council Chambers, 20 Civic Center Drive, Santa Ana. 7-53-2 Please refer to Response to Comment 7-45-5 under Section 4F. 7-82-8 Comments received during the public preparing their staff report to the key issues, including an overview of results of this program. The Board on the proposal under consideration. Comment 6-13-14 in this Chapter. 7-86-1 review period are reviewed' by TCA staff in TCA Board. This staff report identifies the public participation program and the reviews this staff report prior to acting Additionally, please refer to Response to Regarding the Response to Comments for EIR No. 494, please see Response to Comment 8-7-5 in this chapter. Regarding the comment period, see Responses to Comments 4-17-12 and 13 in this Chapter and 6-16-1 under Housing/Business Relocation. 7-86-2. 7-86-26 As stated on page S-6, this list was meant to be a summary only. Throughout the Draft EIR/EIS the topics listed in the comment are addressed. With regard to the technical and economic ability to fulfill proposed mitigation measures, the TCA is committed to fulfilling the mitigation measures, and indeed will provide mitigation monitoring in accordance with AB 3180. 01/31/91(TCA9018%INDEXQ • C/N-10 • 0 In addition, Chapter 11, Comments and Coordination, provides a summary of issues brought up in response to the Notice of Preparation/Notice of Intent, and the many meetings on the project. 7-86-3 TCA will be responsible for certifying the EIR portion of the environmental document and selecting a locally preferred alternative. The EIS portion of the document will proceed to the FHWA. The FHWA, in cooperation with other federal agencies, will then render a decision as to whether or. not to issue a record of decision on the EIS. TCA's experience in designing and completing a road project is best described through the cumulative skills of the TCA and CDMG engineering staff, which results in a resume of roadway construction and design ability matched or exceeded by only a few public agencies. • 7-86-27 The concerns of the resource agencies are not elaborated beyond the listing in Chapter 11 because the concerns provided input into project and mitigation design and thus to a certain extent are incorporated into the project and the EIR/EIS. It is true that some of the persons consulted with are no longer with the agencies; however, as noted above, information from these agencies was used in the design of the project. 7-145-2 The Draft EIR/EIS was organized primarily by environmental topic, rather than geographic area. TCA staff are available to help commentators find the speci- fic information they are looking for if the commentator requests it. 8-4-7.8-4-8 Regarding the review period, please see Responses to Comments 4-17-12 and 4-17-13 under CEQA/NEPA and 6-16-1 under Housing/Business Relocation. Regard- ing permission to go into the areas in Laguna Canyon that are not open to the public, the TCA is not the landowner and thus cannot provide permission for access. Although the TCA is not in a position to provide access to the Corri- dor alignment to the public, it is important to note that the biology of the area has been extensively studied for more than ten years, reports have been available to the public, and the public has commented on the reports. • 01/31/91(TCA9016%INDEXC) C/N-11 8-7-3. 8-16-4. 8-19-13 8-19.14. 8-21-1 Please refer to Response to Comment 4-17-18 under Construction Impacts, with respect to developer grading issues. 8-7-5. 8-13-5. 8-19-1 The comments on EIR No. 494 have not been put away in archives. Quite the opposite has occurred, with the TCA revising the project in response to many of the comments and adding information requested in EIR No. 494 (such as toll information) into the Draft EIR/EIS. Responses to Comments to EIR No. 494 were prepared and distributed to the commentators in October, 1990. That document includes a matrix indicating where the Responses to Comments on DEIR No. 494, have been incorporated into the Draft EIR/EIS. 8-7-7 Refer to Response to Comment 4-17-18 under Construction Impacts. 8-7-8 The public hearing process for the SJHTC has been, and will continue to be, conducted in full compliance with CEQA and NEPA. Chapter 11 of the DEIR/EIS, Comments and Coordination, outlines the public meetings and hearings conducted on the project since 1979. The following is a summary of the most recent meetings, which were opportunities for the public to transmit verbal comments and questions on the Corridor project. Environmental Scoping Meeting - Comment on EIR No. 494 July 20, 1988 - University High School Environmental Scoping Meeting - Comment on EIR No. 494 July 27, 1988 - 25552 La Paz Road, Laguna Hills. City of Irvine Council Meeting - City Council Chambers August 23, 1988 City of Newport Beach Council Meeting - City Council August 8, 1988 Chambers City of Newport Beach Council Meeting - City Council August 22, 1988 Chambers Map Showing - University High School, Irvine October 10, 1990 01/31/91(TCA9018%INDEXC) C/N-12 • 0 Map Showing - Laguna Beach High School October 17, 1990 Map Showing - Capistrano Valley High School October 24, 1990 Public Meeting - Laguna Hills High School November 14, 1990 Future public hearings on the project in front of the TCA Board are scheduled for February 14 and 28 and March 14, 1991. Regarding a special hearing in Laguna Beach, *the TCA will participate as requested. However, it is important to note that concerns of the residents of Laguna Beach, as expressed at the hearings and in writing, will be addressed through the Response to Comments, regardless of whether or not there is an additional hearing in Laguna Beach. 8-9-7. 8-10-2. 8-13-3 The TCA has not waived the option of adopting the No Build or No Project Alter- native. The need for the Corridor has been identified by transportation and planning studies for more than ten years, and the recent Regional Mobility Plan, a portion of the.Air Quality Management Plan, includes the Corridor as part of the proposed regional transportation network. Based on this identified transportation need, the County of Orange and, after its formation in 1986, the TCA, have advanced the design of the Corridor, and have conducted environmental review for the Corridor, including the current Draft EIR/EIS. However, a final decision to proceed with the construction of the Corridor has not yet been made. The Board of Directors of the TCA, comprised of elected representatives from the member agencies, will review the proposed Corridor and consider the potential environmental effects described in the EIR/EIS prior to making a final decision on the project. The Board of Directors has the authority to select the No Build or No Project Alternative, to select one of the alter- natives analyzed in the EIR/EIS, or to develop new alternatives for further study. 8-13-6 The impacts referenced in the comment are addressed in the Draft EIR/EIS. The whole alignment of the Corridor has been analyzed in one document because CEQA and NEPA require analysis of the whole project. Providing a separate document would not be consistent with legal requirements, and it also would not result in any more information or different conclusions than are in the DEIR/EIS now. • 01/31/91(TCA901B%INDEXC) C/N-13 8-18-1 The DEIR/EIS has been prepared in accordance with all applicable laws and policies. The DEIR/EIS clearly acknowledges impacts, including significant unavoidable impacts of the project, and includes mitigation measures to reduce or eliminate impacts. 8-18-8 The comment states that there are inconsistencies between the text and the technical studies. Without reference to specific inconsistencies, no specific response can be provided. The TCA believes that the text of the DEIR/EIS and technical studies are consistent. 8-19-2 Please refer to Response to Comment 1-2-2 under Cumulative Impacts. 8-19-15 0 Monitoring for archaeological and paleontological resources for any existing grading is the responsibility of the project sponsor in accordance with appli- cable laws and policies. As described in Mitigation Measures 11-1 through 11- 5, the TCA will ensure archaeological and paleontological monitoring as re- quired. 8-25-5 The comment refers to the need for additional study with current information. Although the project has been under study for several years, the TCA has con- tinued to update studies as appropriate to ensure that the most current infor- mation is used by the decision makers. 8-27-2 Regarding the allegation that grading for the Corridor has been done illegally; refer to the Response to Comment 4-17-18 under Construction Impacts. Regarding public input, see Response to Comment 6-16-1 under Housing/Business Relocation. Regarding the Corridor's effect on air quality; a state of the art air quality study conducted for the Corridor using the Direct Travel Impact Model (DTIM) _ 01/31/91(TCA9018%INDEXC) C/N-14 • 0 projects that air quality will improve with implementation of the Corridor. For further information regarding projected post Corridor construction air quality see section 4.4 of the EIR/EIS. 8-27-4 The financing plan for the Corridor will use developer fees to fund a portion of the construction cost of the project. In fact, approximately 48.5% will be funded by development fees which will be assessed on new development only. The remaining 51.5% of the construction cost will be funded from toll collections. This financing plan represents an innovative approach to funding the difference between available State and Federal funds for transportation projects and the cost of constructing such projects. The financing plan is structured so that construction of the Corridor will be paid for by people who use the tollway and purchasers of new homes within the Corridor area of benefit. 8-31-2 • The environmental document for the SJHTC is an Environmental Impact Report (EIR)/Environmental Impact Statement (EIS). The document was done as an EIS to satisfy federal environmental requirements. because the Corridor will connect with the I-5 Freeway, which is a part of the federal highway system. Addition- ally, the EIS was done to leave the door.open for Federal funding in the event that it becomes available. 8-32-1 As discussed in Chapter 1 of the Draft EIR/EIS, the need for the Corridor has been identified based on existing and projected traffic demand in the region. The TCA Board of Directors, made up of elected representatives from each of the member agencies, will review the proposed project in light of the potential environmental effects described in the EIR/EIS. The Board of Directors may take action on the project, including approving the No Build or No Project Alternative or one of the proposed Build Alternatives. The Draft EIR/EIS uses the best information available during. the period of its preparation. CEQA provides that no additional environmental documentation is required unless significant new information, with respect to changes in the project or changing circumstances, is developed. 9 01 /31/91(TCA9018%INDEXC) C/N-15 CONSTRUCTION IMPACTS 3-2-7 See Mitigation Measures 17-22 and 17-23 on page 4-143 of the Draft EIR/EIS. These plans require coordination with local agencies. 3-4-58 Initial Corridor construction will involve the rough grading of the entire Corridor right-of-way which includes the median reserved for future HOV/transit operations. HOV lane construction will therefore not, create any impacts to Corridor operations because all future construction activity will occur within the rough graded median and not require the closure of existing lanes. 3-4-66 The impacts associated with construction activities are discussed in Section 4.17 of the DEIR/EIS. Mitigation Measures 17-22 and 17-23 require the prepara- tion of traffic management plans in association with the local agency to ensure that Corridor construction activity minimizes traffic conflicts and provides for business access. In addition, a mitigation measure has been added; please see Response to Comment 3-4-14 under Fiscal Impacts. 3-5-19, 3-5-24 The area for potential blasting is given in Response to Comment 6-17-39 in this Chapter along with a description on the nature of the blasting which consists of very small powder factors well away from development. The geotechnical report in the DEIR/EIS Technical Studies (Volume II) identifies the general locations where dewatering may be necessary. Specific dewatering will be con- trolled by permits from appropriate regulatory agencies. Additional details on construction impacts are provided below. CONSTRUCTION TECHNIQUES Construction techniques are controlled by the construction contract specifi- cations, special provisions and the plans whenever the techniques may impact safety or the quality of the constructed product. Where these restrictions do not control, it is standard practice to allow the contractor to utilize con- struction techniques which will expedite the project schedule. • 01/31/91(TCA901B%INDEXC) CO -I 0 Construction techniques vary markedly from contractor to contractor and are, in general, dependent on the following factors: 1. Availability of contractor's equipment; 2. The size, training, and experience of the contractor's labor force; 3. The availability of construction materials; 4. The physical size, location, and character of the project; 5. The length of time allowed for construction; and 6. The nature of storm seasons encountered during construction. As a result of the variables described above, construction techniques can be described in general terms only. With this background, the project may be divided into the following general types of work: mobilization and access to the project, grading, subbase construction, surfaces and pavements, structure construction, drainage construction, toll and traffic control facility con- struction. Mobilization and Access Techniques Generally, the contractor will establish a project field office, within the project right-of-way, consisting of one or more trailers. The contractor is solely responsible for selecting the field office site, developing power, telephone communications, sanitary facilities, security for that office, equip- ment, and materials. The contractor may develop access from the major property owners along the project, and will bear all responsibility, liability, and cost for these access points. Any time the contractor accesses public streets, roads or land, he will be strictly controlled by a series of laws, codes, acts, orders, and specifications which provide for public safety and welfare. Grading Techniques The first work task for grading operations will consist of clearing and grub- bing the land so that trees, plants, weeds, grass, roots and similar materials do not mix into the finished surfaces of the project. This operation will typically be performed by track type tractors, of the sizes known as D81s through D11's. Burning of the land to be cleared will not be allowed. 01/31/91(TCA9018%INDEXC) CO-2 1� Typical Equipment Used for Grading Common Name Estimated Equipment Type Designation Number Size Descriptions Track Type Tractors D8, D9, D10 100 (Total for 300 to 520 horse - for 24 months) power; operating weights: 70,000 lbs to 123,000 lbs Wheel Tractor 631, 637, 657 145-200 (Total 550 to 950 horse - Scrapers for 18 months) power, loaded weights: 137,000 lbs to 460,000 lbs Off -Highway Trucks .773B, 777B, 785 50 (Total for 650 to 1,290 horse- 18 months) power, loaded weights: 185,000 lbs to 460,000 lbs. Carry 44 to 102 cubic yards Wheel Tractors 824, 834 50 (Total 315 to 450 horse - .for 18 months) power; operating weight: 67,000 lbs to 102,000 lbs Front Shovels E 650 10 (Total for 380 horsepower; 12 months) weight: 142,000 lbs.; bucket 5 cubic yards Compactors 815B, 825C 50 (Total for 210 to 315 horse- 24 months) power; weight: 44,000 lbs to 71,000 lbs 0 01/31/91(TCA901B%INDEXC) CO-3 Earthwork, the cutting or filling of material along the Corridor, will general- ly be done by track type tractors and scrapers, although the shovel and truck method of excavation and filling may also be used. Standard contractor prac- tice, availability of equipment and trained operating engineers make scraper construction the more likely alternative. New equipment available in the last five years has increased the rippability of construction equipment, and it is likely that most earth/rock material encountered on the Corridor can be exca- vated with D1O track type tractors and impact rippers or single shank rippers. If very difficult materials (these materials would be the Topanga and Bommer formations and/or the San Onofre Breccia) are encountered (generally bedrock materials with seismic wave velocities greater than 8,000 feet/second), limited blasting may be employed. Blasting would be used to fracture (in the construc- tion trade this is called pre -splitting) and loosen material and not to move large volumes of material by explosive force. Blasting would be strictly limited to the smallest charges needed for fracturing, and the location of all blasts would be well away from existing residences and similar development as provided in National Safety Council criteria. If blasting is used in the Corridor construction, the explosives used would • probably be nitroglycerin-nitroglycol types (NG) in lieu of black blasting powder. Typical ratios of explosives to rock excavation for road cuts are in the range of 0.6 lb to 0.8 lbs of explosive use per cubic yard of rock materi- al. Areas where explosives might be employed range from a point one-half mile easterly of the proposed Pelican Hill interchange, thence southeasterly to a point one mile westerly of Laguna Canyon. The closest distance to any existing residence would be more than 4,000 feet. Given the relatively small size of explosives and the relatively large distance from existing homes, it can be estimated that temporary ground displacements resulting from the blasting would probably be in the range of 0.0007 to 0.00019 inches, and that momentary ground accelerations in the range of magnitude of 0.0O4g to O.007g might be experi- enced. These ground motions are very small, and it is probable that the blast- ing, if used, would not be felt. As evidence of the fact the ground motions are very small, it may be noted that ground accelerations smaller than 0.01 g are not felt even under ideal condi- tions; the accelerations anticipated from explosive pre -splitting are less than one-third of this threshold and only detectable with sensitive instruments. As to the safety associated with blasting, it may be noted that the insurance industry working with the engineering profession has established an energy ratio as a measure of the potential for damage. When this ratio exceeds six, the blasting is considered hazardous. An energy ratio less than three is considered safe, and the smaller the ratio the better. Based on the charges identified above and a worst case frequency for vibration of a house (15 cycles is 01 /31 /91 MA901 B••• I NDEXC) CO-4 0 0 per second), the energy ratio for the project's proposed blasting would be 0.0002, which is very safe. If rock does require blasting, it is likely that the excavated products would be hauled with 700 series or ADT series off highway dump trucks. If the exca- vation rock consists of competent material, it may be analyzed for recycling, as crushed aggregate to be used in the base material for Corridor pavement. In general, the geology of the area makes this prospect unlikely. Excavation and embankment construction will proceed in accordance with geotechnical reports describing stabilization or drainage features to be constructed. Hauling of earth and rock materials will generally be confined to the limits westerly of Laguna Canyon Road and easterly of Ford Road to avoid impacts to public trans- portation and to provide earth moving efficiency, which will lower construction costs. When earthwork must be moved outside these limits, the contractor will give preference to hauling along the pioneered alignment of the Corridor, using Corridor bridges and routes not yet open to public traffic. This will decrease contractor impacts on public roads and streets. Subbase Construction Techniques Subbase construction as intended in this DEIR/EIS, consists of the construction of subbase and base materials that underlie the Corridor pavement. Materials for subbase will conform to construction Contract Specifications and Special Provisions which are based on State standards. Where excavated rock shows promise of being a competent material for engineering aggregate, it will gener- ally be recycled due to the relatively limited supply of aggregate in the County. The contractor may wish to obtain aggregate by recycling demolished concrete and asphalt products. These sources generally make excellent aggre- gate products, lower construction costs and tend to preserve valuable resourc- es. Subbase construction will involve the use of transporting, spreading, compacting and watering equipment. Typical Equipment Used for Subbase Construction Common Name Estimated Equipment Type Designation Number Size Descriptions Gravel Transporting Trucks Spreading • 01/31/91(TCA9018%INDEXC) Belly Dumps 18 Wheelers Motor graders CO-5 200 (Total for 12 months) 30 (Total) Carry 50 tons 120 to 275 horse- Ll Equipment (Patrols) power; weights: 12OB to 16G 27,000 lbs to 54,000 lbs Compactors Vibratory and 20 (Total) 100 to 155 horse - wobble weights: 14,000 lbs to power; weights: 14,000 lbs to 24,000 lbs Surfaces and Pavement Techniques Pavement for the Corridor will consist of flexible and rigid pavements. Flex- ible pavements are generally asphaltic concrete materials, while rigid pave- ments are portland cement concrete materials. Rigid pavements will be applied to all heavily traveled areas of the Corridor, unless there is reason to believe that settlement may occur in a given reach of the Corridor. If settlement is predicted, flexible pavements may be used • because of their ability to "heal" or adjust to settlement cracks. To the extent possible, recycled aggregate will be used in the pavement materials to decrease cost, improve pavement strength and durability, and to protect exist- ing, unmined resources. Equipment use for pavement construction typically consists of transporting trucks, pavers, and compactors. Typical Equipment Used for Paving Operations Common Name Estimated Equipment Type Designation Number Size Descriptions Transporting Belly Dump 300 (Total) Carrying 50 tons Paving Slip Form Pavers 15 (Total) 400 horsepower; SF-550, Barber- Weight 115,000 lbs Greene AP 1200 Paving 28' width at 30' per minute; Compactors Vibratory 20 (Total) 155 horsepower compactors Weight 25,000 lbs CB 614 • 01/31/91(TCA9018%INDEXC) CO-6 0 Portable PUM 3300 2 (Total) Produces 200 to Plants Portable Venturi 600 tons/hour Mixer Asphalt Plant Structure Construction Techniques The types of structures to be constructed as part of the Corridor consists of bridges, retaining walls, soundwalls, culverts. In general, tunnels presently appear to be infeasible due to geotechnical problems and prohibitive costs, although additional geotechnical testing will be done as part of the design process to confirm or deny this conclusion. Bridge construction for the Corridor will consist of concrete structures in lieu of steel structures in almost all cases to reduce maintenance costs asso- ciated with painting steel structures. Concrete bridges will generally be cast -in -place, conventionally reinforced or post -tensioned box girder bridges • for longer spans. Short spans (40 feet or less) may consist of cast -in -place deck slab bridges. In general, bridges will be founded on driven concrete or steel piles and/or cast -in -drilled -piles. During construction, bridges will rest on timber falsework founded or driven timber files and/or siles where soils can support bearing pressures in excess of 2,000 pounds per square inch. Typically, falsework piles will be driven to bearing values of 20 tons or 45 tons, using single or double action steam, or diesel pile drivers. Structure piles will be driven to bearing values of 45, 70, or 90 tons using the same type of driving equipment. Structure concrete will typically be placed using pumping equipment or buckets and tremies. Bridge decks will be constructed using motor driven, rail guided, screeds ("Bidwells"). Culverts will be con- structed in a manner similar to construction bridges except that they will not be founded on piling but will rely on the development of soil bearing pres- sures. Retaining walls will be constructed of masonry materials up to a height of approximately 10 feet. Above that height, reinforced concrete will be used. In suitable soil conditions, crib walls and/or reinforced earth products may be used to retain the earth. Drainage Structure Techniques In general, drainage conduits will be of concrete, steel, or aluminum materi- als. Where concrete conduits are used in conjunction with high velocity or abrasive flows, additional concrete cover of the reinforcement will be pro- 0 01/31/91(TCA9018%INDEXC) CO-7 • vided. Riprap aprons will be provided where flows are unstable or supercrit- ical. 3-5-71 If balanced cut and fill is not achieved during Corridor construction, the following methods will be used for disposal of excess material: fill will be stockpiled within the Corridor right-of-way until it can be moved to an adjacent development site where environmental clearances for fill operations have already bee obtained as part of the project appro- vals; or until it can be transported to an approved disposal site such as a certified landfill. fill will be transported directly to an adjacent development site or an approved disposal site such as a landfill. However, it should be noted that with the split profile Corridor design pro- • posed from Laguna Canyon Road to Ford Road, it appears that little or no fill material will be left over after completion of excavation. Further, disposal of excess material is thoroughly discussed in Section 4.17 on page 4-137 of the DEIR/EIS. 3-5-90 Technical Report No. 3, in Volume I of the Technical Studies which supports the conclusions in the EIR/EIS, includes the following information regarding par- ticulate matter released during construction activities for the Corridor. The California Air Resources Board (ARB) estimates that roadway construction disturbance covers 6.46 acres per mile, and that the average monthly emissions factor is 600 pounds per acre disturbed when normal dust control procedures (watering, compaction, and slow speed travel on unpaved surfaces) are utilized. When this factor is applied to the approximately 17.5-mile to 19.4 mile Corri- dor (depending on the alternative selected), an average daily dust generation rate of about 1.75 to 1.97 tons per day during a typical weekday is predicted if the entire length of roadway is under simultaneous construction. It should be noted that actual construction of the Corridor will be in phases and 17.5 to 19.4 miles of roadway will not be under construction simultan- eously. Therefore, 1.97 tons of particulates released per day is a worst case estimate. 0 01/31/91(TCA9018%INDEXC) CO-8 9 Additionally, TCA will implement fugitive dust control measures during con- struction including the following: watering of construction roads spreading of soil binders street cleaning, if necessary, on public thoroughfares adjacent to Corri- dor construction activities These standards are included as mitigation measures in the DEIR/EIS. Please refer to Response to Comment 4-32-13 under Air Quality regarding mitiga- tion measures during construction. 3-6-25 It is anticipated that, through proper coordination with local agencies during the construction period, disruption to local businesses can be kept to a mini- mum. Please see Mitigation Measures 17-22 and 17-23 which require the prepara- tion of Specific Traffic Management Plans prior to final design. Furthermore, Mitigation Measure 17-23a has been added to provide a business access plan for the confluence area (see Response to Comment 3-4-14 under Fiscal Impacts). 3-7-41, 3-7-45, 3-7-46, 4-32-25, 4-32-42 The last sentence of Mitigation Measures 17-1 (requiring grading spoil truck traffic to be addressed in a "Traffic Construction Management Plan") is hereby deleted, and Mitigation Measure 17-1a has been added to the list of mitigation measures and reads as follows: Prior to any construction activity involving the disposition of excess fill, an "Excess Fill Disposition Plan" (resulting from excess excavation) shall be prepared which includes the following components: a) identification of disposal sites for excess grading spoil away from sensitive receptors. b) identification of haul routes which avoid residential areas. c) establishment of fill quantities for each disposal site. d) grading plans for each disposal'site. e) revegetation plans for disposal sites where appropriate. f) grading contract provisions will require that disposal sites be located outside ESAs identified pursuant to Mitigation Measures 6-2 and 7-2, and if disposal will occur outside the Corridor area of impact, contract provisions will require coordination with the California Department of • 01/31/91(TCA9018%INDEXC) CO-9 Fish and Game and USFWS to assure avoidance of critical wildlife habitat areas. 3-7-41 The construction cost estimate for the earthwork which are appropriate to the these unit prices specifically include material. 3-7-47 Corridor was based on unit prices for amount of the imbalanced quantities and allowances for disposal or borrow of The TCA will require its Design/Build team to prepare construction detour and phasing plans subject to the review of the City. Please see Response to Com- ment 3-8-89 in this Chapter for further information. 3-8-3 Exhibit 1 of the Response to Comments document is the June, 1990 San Joaquin Hills Transportation Corridor Agency Financing Plan, which addresses cost estimates. Planning studies for future fixed guideway transit are not included in the financing plan. Such studies would be conducted in the future, possibly by a group of agencies, in addition to the TCA. 3-8-85 The additional restrictions on construction operations proposed by the request- ed additions to Mitigation Measure 17-4 appear unreasonable given that the City's Noise Ordinance relative to construction was devised to protect adjacent residential units from excessive noise from nearby construction activities. The Corridor at its closest point will be three-quarters of a mile from exist- ing residential units in the City of Irvine. Therefore, the existing language for Mitigation Measure 17-4 is more than adequate. The movement of haul trucks and other heavy construction equipment will be regulated by Mitigation Measure 17-8. In addition, please see Response to Comment 3-8-86 in this Chapter. 3-8-86 Mitigation Measure 17-8 is revised as follows: 17-8 Haul routes for construction equipment and heavy construction -related vehicles will be located away from existing residential and other sensi- 01/31/91(TCA9018%INDEXC) CO-10 • s tive land uses. Haul route locations and schedules shall be reviewed by the appropriate local jurisdiction. 3-8-87 Mitigation Measure 17-9 is revised as follows: 17-9 The powder ratio of blast charges will be, controlled to limit the blast- ing ground borne vibration where structures and other cultural resources are within 500 feet from the blast site. Blasting in such areas will be monitored by the TCA; if it is determined that blasting cannot be con- ducted in a manner to prevent damage to structures and/or cultural resources, alternative methods of construction will be utilized. Advance notice of blasting activities shall be provided to local law and fire enforcement agencies and nearby homeowners associations. Blasting activ- ities shall be consistent with Mitigation Measure 17-4. -3-8-88 No modification to Mitigation Measure 17-22 is necessary because the existing wording requires advance notice of traffic disruptions and coordination with local jurisdictions. 3-8-89, 3-8-90, 7-132-4 Existing Mitigation Measure 17-22 is modified as follows: 17-22 Advance notice of temporary traffic disruptions will be provided to affected areas, businesses and the public. Traffic Management Plans for handling traffic during construction shall be prepared during final design of the project with review and comment by input and approval of the local jurisdictions in which the traffic detours and delays may occur. Traffic Management Plans will assure maintenance of emergency access and access to existing businesses. At a minimum the Traffic Management Plan shall include: a) Detour route location b) Signing to affect detour c) Layout of cones and barricades. 0 01/31/91(TCA9018%INDEXC) CO-11 • 4-15-1 Mitigation Measure 17-25 has been added to the DEIR/EIS. This Mitigation Measure reads as follows: 17-26 Prior to any grading activities, the TCA shall prepare a "Vector Control Plan" which will consist of specifications (to be applied during Corridor construction) which prevent the migration of ro- dents, insects, and pests to residential units. This plan will be reviewed by the Orange County Vector Control District to insure that it contains the most effective means of pest migration con- trol. 4-15-5 The TCA will commit to an "Order of Work" construction specification in the areas of Corridor construction immediately adjacent to existing residences which has as its goal the maximum construction possible of berms, noise walls and similar features prior to routine construction activities. 4-17-18 All grading along the Corridor alignment that has taken place to date has been approved as part of specific development projects. The TCA has not engaged in or authorized any grading activity prior to environmental clearance. Addition- ally, the environmental impacts associated with the grading within the Corridor alignment is addressed in the 'Environmental Impact Reports (EIRs) for each development project. EIRs for each individual project were certified prior to approval of each of these developments and prior to any grading that took place. Table 3.7.A on page 3-51 of the EIR/EIS lists the development projects along the proposed Corridor alignment. The following is a list of development projects which border the proposed Corridor alignment, and the corresponding EIRs certified for each of these projects: EIR # Pelican Hill Road 296, 460 Aliso Viejo Planned Community 088 Aliso Creek Corridor Specific Plan 78-002, 002 Country Village Planned Community 090, 465, 406, 278, 473 Nellie Gail Ranch 75-62 01/31/91(TCA9018%INDEXC) CO-12 Laguna Niguel Planned Community Colinas de Capistrano Project approvals and the County of Orange authority to authorize 4-32-12 316 and the EIRs listed below for each specific planning area within the Laguna Niguel Planned Community: 286, 74-83, 202, 099, 78-005, 219, 78-008, 199, 145, 017 204, 270, 321, 138, 131, 226, 418 environmental impact as the lead agency. development related report certification was granted by The TCA does not have land use grading activity. The phasing of HOV lane construction will not effect traffic on the Corridor. Initial construction will provide for full -width grading, which will minimize air quality and noise impacts of construction, as the HOV lanes are added to the median in future years. Since the construction of HOV facilities will occur in an envelope between existing Corridor traffic the net affect of the addition noise will be minimal due to the manner in which noise levels are additive (i.e. logarithmatically). More specifically construction noise levels are approximately the same magni- tude as high speed freeway traffic noise and consequently the -net change at the source would be approximately 3 dBA. When this change is distance attenuated to a nearby source the resultant will be both temporary and insignificant. It should also be noted that construction noise occurs during daylight hours and consequently this impact when expressed in terms of leg or CNEL is minimal. The commentator is referred to Table 4.17.A in the DEIR/EIS for specific con- struction equipment noise levels. With respect to dust control during HOV construction the construction specifi- cations used by the TCA are the same as those used by Caltrans and they speci- fically give requirements for controlling dust. Please refer to Sections 4.4 and 4.17 of the DEIR/EIS for additional discussions of dust control measures. 4-32-26 Mitigation Measure 17-26, which has been added to the DEIR/EIS, reads as fol- lows: 17-26 The parking and storage of all construction vehicles and equipment shall be limited to those portions of the Corridor right-of-way already graded. • 01/31/91(TCA9018%INDEXC) CO-13 0 4-32-38 Mitigation would not be required for the No -Build Alternative because under this scenario the project would not be built. All previous grading was com- pleted as part of associated development projects which obtained the necessary environmental clearances with the County of Orange acting as lead agency. Please see Responses to Comments 4-17-18, 7-86-23 in this Chapter. The DEIR/ EIS does contain sufficient discussion relative to the No -Build Alternative. The discussion of the No -Build Alternative is contained within every section of the DEIR/EIS and is compared throughout the document- with the impacts of the Build Alternatives. 6-3-4 Please refer to Response to Comment 3-4-14 under Fiscal Impacts. 6-14-6 Section 4.17 of the DEIR/EIS (Construction Activities) discusses the impacts associated with Corridor construction and provides mitigation measures. Fur- thermore, Responses to Comments 3-4-14 under Fiscal Impacts and 3-8-89 in this Chapter provide additional mitigation during construction. 6-15-23. 6-15-25 The EIR/EIS addresses construction to the extent possible based on current available information. The TCA does not agree that there will be profound difficulties as referenced in comment 6-15-23. The realignment of I-5 allows for freeway lanes to be constructed in coordination with traffic phasing. As suggested by the comment, due to its design, Option #1 can be constructed more quickly. That Option #1 is more expedient to construct has been described by TCA staff to its Board of Directors in the form of reports on possible construction scheduling. This reinforcing comment will be further considered by the TCA Board in making its Option selection. 6-15-31. 6-15-32, 6-15-33, 6-15-34, 6-15-35 Section 4.17 of the DEIR/EIS addresses impacts associated with construction activities. The calculations regarding the $100,000,000 dollar loss of produc- tivity are not valid given the mitigation measures provided in the DEIR/EIS and added as a result of responses to comments. Mitigation Measures 17-22 and 17-23 require the preparation of traffic management plans. The addition of 01/31/91(TCA9018%INDEXC) CO-14 Mitigation Measure 17-23a (see Response to Comment 3-4-14 under Fiscal Impacts), which requires a business access plan, and the modification to Miti- gation Measure 17-22 (see Response to Comment 3-8-89 in this Chapter). Which addresses emergency access requirements, provides sufficient mitigation to counter the estimates of delay and inconvenience. The impacts associated with construction can be reduced to below a level of significance. The temporary construction impacts to I-5 associated with Option #1 as compared to Option #2 will be less but not to the magnitude identified in your comment. This information has been presented to the Board of Directors, see Response to Comment 6-15-23 in this Chapter. The TCA has performed preliminary construction phasing schedules for each of the two options and considered in these schedules the following types of key activities: 1. Detouring of traffic. • 2. Construction of structure falsework. 3. The Order of Work establishing proper sequencing of operations. Based on these schedules there is not as dramatic a difference in construction schedules between the two options as the commentator believes. The commentator's assumptions for the cost of delay do not accurately reflect the way motorists will adjust to known delays. Several freeway improvement projects with similar delays have been constructed in Orange County over the past five years and motorists are accommodating these projects by ranging travel times and/or reliance on traffic advisory broadcast available on AM radio. With these real life adjustments the motorists time can not be valued at $5.0O/hour. 6-15-63 The commentator has failed to take into account the fact the Option #2 improve- ments involve a westerly realignment of the existing I-5 freeway which allows for a convenient construction of new freeway pavement which can be sequentially used as a phased (detour) for freeway traffic. Without this realignment the inaccurate conclusion will be reached concerning construction delays. 0 01/31/91(TCA901B%1NDEXQ CO-15 6-16-9 Please see Response to Comment 3-4-14 under Fiscal Impacts, 3-8-89 in this Chapter and Mitigation Measure 9-1 on page 4-105 of the DEIR/EIS which requires the implementation of Federal and State relocation programs. 6-17-39 If blasting is used in the Corridor construction, the explosives used would probably be nitroglycerin-nitroglycol types (NG) in lieu of black blasting powder. Typical ratios of explosives to rock excavation for road cuts are in the range of 0.6 lb to 0.8 lb of explosives used per cubic yard of rock materi- al. Areas where explosives might be employed range from a point one-half mile easterly of the proposed Pelican Hill interchange, thence southeasterly to a point one mile westerly of Laguna Canyon. The closest distance to any existing residence would be more than 4,000 feet. Given the relatively small size of explosives and the relatively large distance from existing homes, it can be estimated that temporary ground displacements resulting from the blasting would • probably be in the range of 0.0007 to 0.00019 inches, and that momentary ground accelerations in the range of magnitude of O.004g to 0.0O7g might be experi- enced. These ground motions are very small, and it is probable that the blast- ing, if used, would not be felt. As evidence of the fact that the ground motions are very small, it may be noted that ground accelerations smaller than 0.01g are not felt even under ideal conditions; the accelerations anticipated from explosive pre -splitting are less than one-third of this threshold and only detectable with sensitive instru- ments . As to the safety associated with blasting, it may be noted that the insurance industry working with the engineering profession has established an energy ratio as a measure of the potential for damage. When this ratio exceeds six, the blasting is considered hazardous. An energy ratio less than three is considered safe, and the smaller the ratio the better. Based on the charges identified above and a worst case frequency for vibration of a house (15 cycles per second), the energy ratio for the project's proposed blasting would be 0.0002, which is very safe. At the time of this response, the Pelican Hill Road project is under construc- tion using blasting in areas closer to development than that proposed by the corridor. We believe that this construction is a good model for blasting vibration and noise impacts. To our knowledge, no complaints have been raised concerning this prototype project. 01 /31 /91(TCA9016% I NDEXC) CO -16 C7 6-18-3 Other than temporary physical disturbances such as fugitive dust, the only major physical impacts during construction that would affect property and businesses would be actual physical takes of buildings. These are addressed in Section 4.9 of the EIR/EIS. For additional information regarding mitigations for temporary physical distur- bance during construction, please see Response to Comment 6-15-31 in this Chapter. 7-25-8 Only emergency parking will be permitted along the Corridor. Furthermore, the majority of the Corridor which traverses urbanized areas will contain berms and/or noise walls which would preclude direct access to any adjacent land use. . 7-50-1 The construction phasing of the Corridor may take into consideration the com- pletion of the noise barriers prior to other phases of construction. TCA will install noise abatement walls adjacent toy residences prior to cons- truction wherever the requirements of reasonable construction practices allow. 7-86-23 Construction will not be limited to the dry season. Such a restriction is not necessary in order to provide satisfactory mitigation for construction related siltation and erosion. Section 4.17 of the DEIR/EIS (Construction Activities) discusses the impacts associated with project construction. Implementation of Mitigation Measures 17-10 through 17-19 will reduce construction impacts to where there are no significant unavoidable impacts associated with construction activities. 7-86-24 Fill from construction activity will not be placed in any landfill. Fill material will be used on -site or in conjunction with adjacent development projects. The contractor will be required to pay for the disposal of all un- suitable materials, accompanied by the appropriate fee to the landfill opera- tor. • 01/31/91(TCA9018%INDEXC) CO - 1 7 7-114-12 The TCA tables i Highway includes is unable to reconcile the Table referenced in the comment with any i TCA EIR/EIS 1. Page 4-134 in the EIR/EIS shown the results of the Energy Analysis Program. The Indirect Energy Shown on page 4-134 energy used during construction. • U 01/31/91(TCA901B%INDEXC) C0-18 • • COST 3-4-70. 3-4-71 Please see Table 2-6-A on page 2-29 of the DEIR/EIS. This Table provides cost information for the Demand Management and Conventional Alternatives for both initial construction and the ultimate project. Ultimate project cost includes the cost of building HOV lanes. 3-5-123 The anticipated cost of maintaining the Corridor is not an environmental issue subject to analysis in this EIR/EIS. However, for information purposes, Corri- dor operation costs are included within the Financing Plan in Exhibit 1. Regarding sufficient sources for funds to maintain the project, that is an issue for Caltrans to consider when agreeing to take over Corridor maintenance. It is unclear which deficit is being referred to; however, all operation and maintenance costs of the facility will be provided through toll collection for the first 30 years. Subsequent to retirement of the bonds, the facility will become Caltrans' responsibility. 4-17-3 The TCA has developed accurate cost information and summarized this data in Table 2-6-A on page 2-29 of the EIR/EIS. If the commentator is seeking addi- tional details on quantities used on these estimates, that information is available from the TCA by requesting the Preliminary Cost Estimates for the San Joaquin Hills Transportation Corridor. Additionally, the TCA has prepared a detailed description of the funding for this project titled: "San Joaquin Hills Transportation Corridor Financing Plan, June, 1990." The commentator is referred to this document for a complete explanation of financing. This docu- ment is provided as Exhibit 1 to this Response to Comments document. Additional information can be obtained by contacting TCA at 345 Clinton Street, Costa Mesa, CA 92626, or by telephone (714/557-3298). 4-17-6 The cost of the Corridor is rising at a rate of approximately 4.1% per year, are typical construction costs reported in the California Construction Co Index. Specifically, this rise could be equated to approximately $20 millio The cost comparison made by the commentator is erroneous because it fails • 01/31/91(TCA9018%INOEXC) C - 1 compare the costs of equivalent facilities in the previous and current year estimates. 4-18-4 Costs for the project are not rapidly approaching the one billion dollar mark (see Table 2.6.A). The TCA has reported cost changes through press releases, as the nature of the project changes, and through a number of documents, including the Financing Plan (see Exhibit 1). Regarding justification of the project, see Chapter 1.0 of the DEIR/EIS, Purpose and Need, and Responses to Comments under Purpose and Need. 4-22-21 Pleaser refer to Response to Comment 3-4-9 under Fiscal Impacts. Costs associated with mitigation measures are addressed in Response to Comment 7-86-43 under Funding/Tolls. 6-13-5 The decision makers are aware of the business relocation costs associated with Option #2. These costs will be considered as part of a decision matrix re- quested by the member agencies. 6-13-6 The costs presented for Option #2 reflect construction and right-of-way costs with allowances for relocation assistance. Furthermore, the tollway is not being funded through general tax reserves but is being financed through a com- bination of developer fees and bonds which will be repaid through anticipated toll revenues. 6-13-7 The $10,000,000.00 difference reflected in the memo from Mr. Hartje to Mr. Wool l ett is a difference in the cost of construction not in the purchase of right-of-way. The difference in right-of-way costs between Option #1 and Option #2 is approximately $24,000,000.00, according to estimates by the pro- fessional staff at TCA. 01 /31 /91 MA9018'•• I NDEXC) C - 2 • 6-15-17. 6-15-18, 6-15-62, 7-28-7 The conversation with TCA's Corridor Manager has been misunderstood. The information he intended to convey was that Option #2 is approximately $40,000,000 more expensive than Option #1. Of this $40,000,000 approximately $22,000,000 to $24,000,000 is for increased costs associated with right-of-way while the remaining $16,000,000 to $18,000,000 is associated with increased construction costs. These figures were recited from the engineer's memory with the caveat that this was approximate. In fact, the total of $43,000,000 with approximately $19,000,000 in right-of-way and $24.,000,000 for construction is an accurate estimate. Cost estimates are updated annually to reflect the rise in construction costs. According to the California Construction Cost Index (CCCI) this annual increase has been about 4.1% per year. Our estimates have accounted for this. The package of cost data sent to the commentator was complex and it is clear that conclusions were drawn comparing adjacent segment (5-1, 5-2) of the Corri- dor under one alternative rather than corresponding segments (both 5-2) under different alternatives. If the commentator reviews this he should discover construction cost differences between the Demand Management and Conventional Alternatives (ultimate project development) for the connection (5-2)-of�approx- imately 17,000,000. Right-of-way cost differences remain constant at $24,000,000 and the total difference is approximately $41,000,000 (uninflated for the CCCI of 4.1%). With adjustment the construction cost increases by a multiplier of 1.041. The total difference is $43,000,000 as reported above. If this remains confusing the commentator is invited to call the TCA for further explanation. Cost information is adequately described for an EIR/EIS. 6-15-19 The unit prices used in the cost estimates are taken from the Caltrans' publi- cation Construction Cost Data which reflects actual freeway costs incurred on contracts similar to the project. This data is updated annually. The quanti- ties calculated have been independently checked and it is unlikely that gross errors exist in this estimate. 01/31/91(TCA9018%INDEXC) C - 3 0 6-15-20 A 2O% contingency factor has been used on these estimates and that would nor- mally be considered conservative in the profession. 6-15-21. 6-15-22, 6-15-23 The problems cited (groundwater, hazardous waste, and staging) have been con- sidered by the agency and it is our judgement that the unit prices and 20% contingency account for these potential problems. 6-15-24 Cost comparisons are not appropriately analyzed as environmental issues under CEQA/NEPA (see Response to Comment 3-4-9 under Fiscal Impacts). However, for informational purposes, the difference in costs between Option #1 and Option #2 is 40 million dollars. 6-15-61V No change is necessary. Option #1 impacts are identical regardless of imple- mentation of the Conventional or Demand Management Alternative. Option #2 would only be utilized as a Demand Management Option. See Response to Comment 6-15-53 under CEQA/NEPA Issues. 6-20-6 Your objection to Alignment #2 due to the cost of purchasing land from existing businesses is noted. 6-20-7 Your objection to Alignment #2 due to the cost of business relocation is noted. 7-24-4. 7-24-13 Please see Response to Comment 3-4-8 under Fiscal Impacts. The additional cost of 40 million dollars for alignment Option #2 covers the cost of right-of-way and construction. 01/31/91(TCA901B%INDEXC) C-4 9 7-28-6 Your comment regarding the accuracy of the data presented on Table 2.6.A is noted. 7-28-8. 7-28-9 The TCA is bearing the cost associated with all project improvements. The cost of the project will be funded through the collection of developer fees and bonds repaid through the collection of tolls. 7-28-10, 7-28-11 The Cost of Business Relocation includes moving personnel property, re-estab- lishment of businesses, and in -lieu fees for relocation benefits. The figures are an accurate representation. Also, the acquiring of right-of-way is not included in the relocation line item. 7-45-7 The figure of $667 million, quoted in our public relations handout titled "Frequently Asked Questions About the San Joaquin Hills Transportation Corri- dor", is the cost of constructing the initial project of three general purpose lanes in each direction. The $791 million quoted in the DEIR/EIS is the cost for ultimate build out of the project. Table 2.6.A on page 2-29 of the DEIR/EIS provides a breakdown of the initial and ultimate costs of the Corridor project. 7-57-1. 7-57-3 Please see Exhibit 1 (San Joaquin Hills Transportation Corridor Financing Plan) of the Response to Comments Document. 7-86-17 Mitigation measures have been detailed in the DEIR/EIS and are included in the project cost estimates. The commentator is referred to Response to Comment 2- 8-2 under Geotechnical Impacts which describes the large volume of geotechnical data which has been developed for this project. Geotechnical risks and associ- ated economic impacts have been accounted for by the TCA using this extensive data. More specifically, unusual geotechnical conditions are reflected in: 1) the unit prices for those items of earthwork where problems are likely to • 01/31/91(TCA9018%INDEXC) C - 5 occur, or 2) they have been accounted for by quantifying the problem in terms of unsuitable material estimates. Additional detail regarding the geotechnical constraints in the project area are provided in Technical Study No. 1 (the Geotechnical Study contained in Technical Studies - Volume I of the EIR/EIS). 8-22-5 Please refer to Responses to Comments 4-17-6 in this Chapter and 7-84-3 under Fiscal Impacts. 8-33-4 The basis of the $300 million cost is not clear to TCA. Nevertheless, the cost of the Corridor is rising at a rate of approximately 4.1% per year, as are typical construction costs reported in the California Construction Cost Index. Table 2.6.A ("Project And Right -of -Way Costs") of the DEIR/EIS provides a breakdown of initial and ultimate costs for both the Demand Management and Conventional Alternatives for the Corridor. Pleaser refer to Response to Comment 6-15-17 in this Chapter regarding construction cost increases. 10 01/31/91(TCA901B%INDEXC) C - 6 0 �J L` • CULTURALJPALEONTOLOGICAL 2-11-7 The portions of the archaeological report referring to sites CA-Ora-123, 181, 218 and 1119 will be forwarded to the UCI Office of the Vice Chancellor Admin- istrative and Business Services. 2-11-8 CA-Ora-1041 lies entirely outside the Area of Potential Effect of the Corridor and has never been the subject of studies associated with the Corridor. It will not be impacted by the proposed Corridor work. Based on conversations with UCI personnel last year, CA-Ora-1041 was investigated for UCI by LSA in 1989. 3-7-39, 7-138-1C The archaeologist and paleontologist listed in the mitigation measures will be responsible for monitoring grading operations. The mitigati-on measures state that it is the archaeologist and paleontologist who are responsible for deter- minations of resource value. 3-8-71..3-8-72 It is acknowledged that the City of Irvine and County of Orange master environ- mental assessments are a source in documenting impacts to sites of paleontolog- ical significance. The TCA is aware of known and probable paleontological sites through the report Updated Assessment of the Paleontological Resources Situated Within the SJHTC and Recommended Mitigation Plan prepared by Chambers Group Inc./John Cooper in 1990. The DEIR/EIS acknowledges the high sensitivity of much of the alignment to these resources. A further listing of the sites is not necessary for an assessment of impacts. 3-8-73 The mitigation measures suggested by the City are similar to the ones in the DEIR/EIS. Due to the need to meet FHWA requirements for a 106 clearance, it is not appropriate for the TCA to change the measure. However, it is important to note that the intent and much of the language of Mitigation Measure 11-1 is the same as the wording suggested by the City. 01/31/91(TCA901B%INDEXC) C P - 1 3-8-74 Please refer to Appendix D, Archaeological Site Assessment, which is a Table with all the sites, their eligibility, percent within the ADI, and recommenda- tions. 3-8-75 It is recognized that these resources may need to work in tandem. This will be addressed through the data recovery plan referenced in* Mitigation Measure 11-1. 3-10-_1_. 3-10-2. 3-10-3. 3-10-4. 3-10-7. 7-138-1a. 7-138-1b, 7-138-ld-f. 7-138-1k. 7-138-2 The TCA is aware of the volume of material which may be uncovered, and the need for many person hours, and probably several different firms to- be involved in the recovery of material. As discussed in the DEIR/EIS, the TCA has an agree- ment with the Museum of Natural History and Science of the Natural History Foundation of Orange County, which is intended to provide space for the speci- mens and assistance in establishing more detailed plans for removal and curation of material. Mitigation.Measures 11-3,11-4 and 11-5, provide appropriate mitigation at this. stage of the project to ensure proper treatment of the resources. The mitiga- tion measures outline the TCA's commitment to proper treatment of paleontological resources. Further details of the number of paleontologists, and specific paleontological procedures can properly be established as part of the next phase of the project, the Design/Build phase. The mitigation mea- sures, and the report Updated Assessment of the Paleontological Resources Situated Within the SJHTC and Recommended Mitigation Plan prepared by Chambers Group Inc./John Cooper in 1990, are listed as specifications that the design - build firm must comply with. Mitigation Measure 11-3 will ensure that all pre-existing localities will be recorded in advance and not left to chance. Uniform measures and funding for the paleontologic work will be provided by TCA through their contracts requiring compliance with the mitigation measures. Procedures for the work will be set up in conjunction with the next phase of design and will not be postponed until after the start of the work. The comment is correct that the paleontological crew will be present and moni- toring grading, thus having a greater role than simply to be notified if re- 01/31/91(TCA9018%INDEXC) C P - 2 L' #9 sources are found. The mechanism and authority for halting construction, carrying out salvage work and collecting from finished fresh cuts will be defined in the Design/Build contracts that the TCA will grant and manage. Significance of fossils will be determined by the paleontological monitor. 3-10-5. 7-138-1Q. 7-138-1i The DEIR/EIS does include the same provisions as required by the responsible governmental agencies. The findings and recommendations of the Orange County Master EIR are incorporated into the mitigation measures and the Chambers Group Inc./John Cooper report. The ownership of the specimens will be by the Natural History Foundation of Orange County. The transport, storage and preservation of fossils and other paleontological material has been arranged through the agreement between the TCA and the Natural History Foundation of Orange County. 3-10-6. 7-138-1i The Natural History Foundation of Orange County has signed an agreement with the TCA and has not indicated that their needs cannot be met. Museum volun- teers will assist the TCA's professional consultants, but are not intended to replace -them. The TCA is responsible for funding all monitoring and transport of material. 4-25-6 CSUF 1028, 1037, 1035, 1036, 1039, 1040 and ORa 855, 963, and 964 are outside the project limits and will not be impacted by construction of the Corridor under any proposed alignment. It should be noted that the sites listed with CSUF numbers are actually sites with CA -Ora trinomial designations, i.e. CSUF 1038 is actually CA-Ora-1038 and so forth. All of the sites listed are entire- ly outside the Area of Potential Effect and therefore will not be impacted by the proposed project. The closest site to the Area of Potential Effect is CA - Ora 1038. It is a small lithic and shell scatter that is about 1Ox20 meters in diameter. CA-Ora-1038 lies well outside the Area of Potential Effect on the opposite side of Camino Capistrano from the Corridor. No impacts to this site are anticipated. 4-29-2. 4-34-20, 7-56-30 The SJHTC project involved extensive planning to identify and avoid known archaeological sites. The sites within the proposed alignment have been stud- ied by the Chambers Group (archaeological consultants). The findings of this • analysis have been forwarded to the State Historic Preservation Office. The 01/31/91(TCA901B%INDEXC} C P - 3 • archaeological program for the SJHTC seeks avoidance, if possible; if avoidance is not possible resource recovery plans for site excavation will be developed and implemented. See Mitigation Measures 11-1 and 11-2 on page 4-111 of the DEIR/EIS. Archaeological monitoring will be provided during all grading in sensitive areas. These procedures are consistent with CEQA guidelines. No Native -Ameri- can burial sites will be impacted or disturbed with project construction. The Chambers Group has coordinated closely with representatives from the local Tribal Council. The reference to -the Pelican Hill site is not associated with this project. 4-33-77 A Section 106 clearance is being processed for this project; completion of the 106 process is required as a part of the Final EIR/EIS. All cultural resource work on this project, including surveys, test level investigation, Determina- tion of Eligibility, Determination of Effect and Data Recovery Plans have been and will continue to be completed in compliance with applicable laws and poli- cies, and subject to review and approval by the FHWA and the State Historic Preservation Officer. The comments about recovery and destruction being potentially significant are addressed through the project's compliance with the 106 process. Determina- tions about site significance and recovery requirements are made through this process. The comment refers to "emergency archaeology." This term does not apply to the Corridor project because all data recovery will be conducted in accordance with SHPO approved plans. (See Mitigation Measure 11-2 in the EIR/EIS.) The comment states that further analysis is required to justify the finding of "no impact." The analysis of cultural resources has been completed in accor- dance with all Section 106 requirements. Therefore, no further analysis is required to justify the finding. 7-82-18 It is unclear whether the commentator is referring to grading which will be conducted by the TCA after EIR/EIS certification or referring to past or pres- ent grading associated with development projects approved by the County of Orange. With respect to future grading by TCA, archaeology and paleontology monitors will be in place during grading operations within sensitive landforms 01/31/91(TCA901B%INDEXC) C P - 4 • (see mitigation measures in Section 4.11 of EIR/EIS). With respect to grading administered by the County of Orange, OCEMA has established procedures regard- ing cultural resources. Please refer to Response to Comment 4-17-18 under Construction Impacts regarding previous County approved grading. 7-138-1a-h The TCA will acquire the right-of-way for the Corridor prior to initiating grading. Subsequent to property acquisition, the mitigation measures in the EIR/EIS will be implemented in conjunction with grading operations. Thus, there will not be a conflict in policy because the property will be within TCA's jurisdiction. Furthermore, no such conflicts are anticipated because the TCA has incorporated adequate mitigation for paleontological impacts. • 01/31/91(TCA9018%INDEXC) C P - 5 9 CUMULATIVE IMPACTS 1-2-2. 1-2-31, 4-21-3. 4-24-1 The comment states that the DEIR/EIS is inadequate because it does not evaluate the San Joaquin, Foothill, and Eastern Corridors in a single environmental document. The comment suggests that such a programmatic EIS for the SJHTC, FTC and ETC projects is necessary because "all three Corridors are in Orange County and, taken together, could pose serious cumulative impacts to the resources of a single geographic area." Additionally, the commentator, suggests that there must be a tiered EIS process to evaluate alternative highways or other trans- portation modes which could relieve peak load congestion in the area. In focusing on cumulative impact assessment to define the scope of an EIS, the comment suggests an almost unlimited area of analysis for environmental review of transportation projects. However, both the Department of Transportation ("DOT") and the federal courts have recognized the need to define .specific criteria for defining the scope of NEPA review precisely because of the com- plexities inherent in assessing proposed additions to regional transportation systems. Federal court decisions clearly indicate that highway projects which connect to logical termini and which have independent utility are appropriately defined for NEPA evaluation. (See Daily v. Volpe, 514 F2d 1106 (9th Cir. 1975); Piedmont Heights Civic Club, Inc. v. Moreland, 637 F2d 430 (5th Cir. 1981).) The criteria for determining the scope of NEPA review for federal transpor- tation projects are further set forth in FHWA's NEPA Regulations. The FHWA Regulations require that the "project" must be defined in a manner which: (1) Connects logical termini and is of sufficient length to address environ- mental matters on a broad scope; (2) Has independent utility or independent significance, i.e., is usable and a reasonable expenditure even if no additional transportation improvements in the area are accomplished; and . (3) Will not restrict consideration of alternatives for other reasonably fore- seeable transportation improvements. (23 C.F.R. Section 771.111(f).) ' Again, the federal courts have clearly articulated both the rationale for the logical termini and independent utility criteria, and the manner in which these criteria should be applied. For example, in Coalition on Sensible Transporta- 0 01/31/91(TCA9018%INDEXC) CU - 1 tion v. Dole, (826 F2d 60, D.C. Cir. 1987) the Circuit Court of Appeal dis- cussed the issue of appropriate NEPA scope of analysis as follows: ". . .it is inherent in the very concept of a highway network that each segment will facilitate movement in many others; if such mutual benefits compelled aggregation, no project could be said to enjoy independent utility. The proper question is whether one project will serve a signi- ficant purpose even if a second related project is not built. Only when a given project effectively commits decision makers to a future course of action will this form of linkage argue strongly for joint environmental evaluation." Contrary to the assertion of the commentator, the San Joaquin, Foothill, and Eastern Transportation Corridors are not inextricably linked in a fashion requiring joint environmental evaluation. The San Joaquin Hills Transportation Corridor indisputably connects logical termini - connecting Interstate 5 to existing State Route 73 - nor does the commentator assert any facts suggesting otherwise. Likewise, given the broad geographic area addressed by the DEIR/EIS and prior State level environmental documentation, it cannot be argued that the Corridor fails to "address matters on a broad scope." The Corridor does not connect to either the Foothill or Eastern Corridors, The Corridor clearly has independent utility,, as it is intended to provide congestion relief for State Route 1, and relief for Interstates 5 and 405 in a manner quite different from that of the Eastern and Foothill Corridors. Simi- larly, the Corridor provides congestion relief for arterials located between the coast and Interstates 5 and 405, provides access to the 16,000 acre coastal greenbelt, and provides new access to the University of California at Irvine - transportation functions completely independent of those of the Foothill and Eastern Corridors. Project funding for the Corridor is also completely in- dependent of the Eastern and Foothill Corridors, as evidenced by the definition of the area of benefit for assessing transportation fees on new development projects. Finally, the separate evaluation of the Corridor and the Eastern and Foothill Corridors in no way restricts consideration of alternatives for other foresee- able transportation improvements. Although all three Corridors are a part of the full set of regional transportation improvements considered necessary in the Regional Mobility Plan, prepared by the Southern California Association of Governments (the metropolitan planning organization for the region), they are geographically and functionally separate, and completion of the Corridor would in no way compel adoption of the Foothill or Eastern Corridors. 01/31/91(TCA901B%INDEXC) C U - 2 .9 With respect to the impacts of the San Joaquin, Foothill, and Eastern Corri- dors, the DEIR/EIS provides a complete cumulative analysis. The traffic and air quality modeling for the Corridor included the Foothill and Eastern Corri- dors (in addition to other projects), thereby providing a cumulative analysis of the transportation and air quality effects of regional transportation im- provements (see Response to Comment,3-5-31 in this Chapter). Further, Chapter 7.0 and Appendix E of the DEIR/EIS .describes cumulative impacts of transpor- tation improvements and other development projects related to the Corridor. This type of analysis clearly complies with the direction provided by the Court of Appeal in Coalition on Sensible Transportation, which stated "insofar as it may bear on an agency's duty to consider impacts in a context that includes other pending projects, the appellees fully complied by planning on the basis of what might be regarded as the 'worst case scenario,' i.e., it assumed ulti- mate completion of the related projects." (Coalition on Sensible Transportation at 71.) Finally, the assertion that air quality conformity analysis needs to be per- formed simultaneously for the San Joaquin Hills, Eastern, and Foothill Corri- dors contradicts earlier stated positions of EPA. In comments to the Metro- politan Transportation Commission in the San Francisco Bay Area with respect to the 1990-1994 Transportation Improvement Program, EPA states its,position that "the air quality analysis must consider the impacts of all projects along an entire corridor," and in discussing widening projects to regional transporta- tion facilities indicates that "these widening projects are significant when viewed on a corridor level and air quality impacts must be evaluated on this level." (Letter from David P. Howekamp, EPA, to Lawrence Dahms, MTC, September 1, 1989.) The assertion that it is an analysis at a corridor level which is appropriate for air quality impacts is inconsistent with EPA's current asser- tion that a region wide analysis must be performed including the San Joaquin, Foothill, and Eastern Transportation Corridors, in order to adequately assess the effects of the San Joaquin Corridor. Further, in this same letter to MTC, EPA clearly articulates the importance of conducting regional air quality analysis in association with regional planning, explaining "EPA understands MTC's desire to balance air quality and transportation needs but believes that doing so within the contingency plan is inappropriate. The appropriate place for this balancing is within the air quality plan where all factors influencing air quality and the various means and their costs for attaining the ambient standards can be addressed." It is precisely this regional planning balance, struck by the drafters of the regional air quality and transportation plans, upon which the DEIR/EIS relies to establish the context for future development of the Corridor and other regional transportation improvements. As suggested by EPA's comment to MTC, it is inappropriate for a single project environmental 01/31/91(TCA9018%INDEXC) CU -3 document to engage in duplicative regional analysis already carried out in association with regional transportation and air quality planning. 1-2-59. 1-2-60 More specific information in the form of acreage loss of wetlands (due to the Eastern and Foothill Transportation Corridor) has been added in Response to Comment 3-5-31 in this Chapter. The EIR/EIS does not consider preservation of open'space as mitigation for wetlands losses. The EIR/EIS language is as follows: Although the proposed project, in conjunction with future antici- pated projects, would result in a cumulative reduction in biologi- cal resources in the region, the future projects also serve as vehicles for implementing the County's regional open space program which includes a 16,000 acre greenbelt in the area of the Corridor. Due to the existing public policies and -the incorporation of open space areas in future projects, cumulative impacts to biological resources in this region have been partially mitigated. The United States Fish and Wildlife Service and the California Department of Fish and Game policies for no net loss of wetland habitat provide further mitigation requirements.. Although the preservation of open space and mitigation for loss of wetland habitat and additional proposed mitigation measures would partially mitigate cumulative impacts to biological resources, the project would contribute to the following: 1) loss of Category 3 and 4 habitat; 2) elimination of individuals of animal species; 3) disruption of predator/prey relationships; 4) decrease in species diversity due to variability of habitats; and 5) decrease in the total number of habitable acre- age. The TCA does not agree that wetlands impacts "cannot be mitigated to an insig- nificant level." In accordance with resource agency policies, there will be no net loss of wetland habitat. 2-11-13 The conversion from faculty, staff and students to employees was made by the City of Irvine for purposes of their traffic modeling. The list provided in Table E-E was provided to the EIR/EIS preparers by the City of Irvine. 01/31/91(TCA9018%INDEXC) C U - 4 LA • 3-4-73. 3-4-74 The commentator is correct in that several anticipated projects listed in Table E-G/Appendix E) as being within the City of Laguna Niguel do not actually lie within the City boundaries. The following projects listed as within Laguna Niguel actually lie within unincorporated Orange County: • Mathis Ranch • Laguna Hills • Aliso Hills • Alicia Creek • Aliso Viejo Planned Community • The Missions • Banning Ranch. The remaining Laguna Niguel projects (i.e., Kite Hill, Narland Business Center, Laguna Niguel Planned Community and the Country Village Planned Community) total approximately 28,000 dwelling units, consistent with the commentator's estimate. The unincorporated Orange County projects were inadvertently included on the Laguna Niguel list, but were not duplicated on the unincorporated Orange County list (Table E-J in Appendix Q . Further, the locations of the projects are correctly depicted on _Figure E-1 (Appendix E) despite the Table errors. The exception is project number 137 (Banning Ranch). Banning Ranch is not repre- sented on Figure E-1, but is located within unincorporated Orange County, east of Pacific Coast Highway and north -of Superior Avenue. The Final EIR/EIS hereby incorporates the above revisions. The cumulative impact analysis presented in the Draft EIR/EIS is not altered as a result of the revisions discussed above. The conclusions remain valid because no projects were duplicated on the various "anticipated projects" lists. Therefore, no overestimation of housing units occurred. 3-5-31, 3-5-87, 3-5-88, 3-5-89, 3-5-112, 4-2-1. 4-5-8. 4-16-3. 4-22-8. 4-22-9. 4-24-1. 4-32-52, 4-33-1. 4,33-2. 4-33-85, 4-33-95, 4-34-23, 7-1-5. 7-82-3. 7-105-1 As background to the methodology for the cumulative impacts assessment, the following is a summary of CEQA Guidelines provisions for cumulative impacts. "The cumulative impacts from several projects is the change in the environment which results from the incremental impact of the project when added to other • 01/31/91(TCA9019%INDEXC) CU - 5 0 closely related past, present, and reasonably foreseeable probable future projects." (Guidelines, section 15355, subd. (b).) The discussion of cumula- tive impacts must reflect the severity of the impacts and their likelihood of occurrence; but the discussion need not provide as great detail as must be provided for the effects resulting from the project alone. The cumulative impacts discussion must included the following elements: 1) either a) a list of past, present, and reasonably anticipated future projects, including those outside the agency's control, that have produced, or are likely to produce, related or cumulative impacts, or b) a summary of projections contained in an adopted general plan or related planning document that is designed to evaluate regional or areawide conditions, provided that such documents are referenced and made available for public inspection at a specified location; 2) a summary of such individual projects' expected environmental effects, with specific reference to additional information stating where such information is avail- able; and 3) a reasonable analysis of all of the relevant projects' cumulative impacts, with an examination of reasonable options for mitigating or avoiding such effects. (Guidelines, section 15130, subd. (b).) The terms "past, pres- ent, and reasonably anticipated future projects" include not only projects currently under construction, but also related "unapproved projects currently under environmental review." The lead agency must use "reasonable efforts to discover, disclose, and discuss" related past, present, and future projects, even if under review by other agencies. ("Discussion" following Guidelines section 15130). The cumulative impacts analysis in the EIR/EIS uses both the list of projects and summary of projections methodologies. In addition, other information is used in some sections where the specific topic of analysis warrants a cumu- lative analysis based on information beyond the list or projection methodolo- gies. The list of projects is contained in Appendix E and summarized in Chap- ter 7 of the EIR/EIS. The following discussion explains how cumulative impacts are analyzed in the EIR/EIS. 1. The analysis is based on projections of County growth in population, dwelling units and employment from OCP-88. OCP-88 is the County of Orange's adopted forecast and incorporates build out of adopted land use plans. The OCP -88 population projections coincide with the Southern California Association of Governments (SCAG) 89 Modified Growth Forecast for the year 2010. SCAG's Countywide population projection of 2,982,200 forecast is about five percent higher than the OCP -88 total of 2,833,800. The traffic modeling, and thus related topics such as air quality and noise, are based on OCP-88. Thus, regional projections, adopted by the County of Orange, provide the basis of analysis in the EIR/EIS. • 01/31/91(TCA901B%INDEXC) C U - 6 :i 2. Within each environmental topic section, cumulative projects and/or spe- cific appropriate study areas (larger than the Corridor project site) are addressed. Examples of this are as follows: • Page 3-40, discussion of Dudleya multicaulis addresses the historic range of the plant throughout Southern California. • Page 3-50, analysis of agricultural lands discusses agricul- tural acreage in Orange County. • Page 4-31, Mitigation Measure 3-8 recognizes the need to accommodate future flood levels, including foreseeable pro- jects which would contribute runoff to the area. • Biological Resources, pages 4-64, 4-66, 4-68, 4-69, discuss and acknowledge the project's contribution to cumulative impacts on habitat and wildlife. ' 3. Cumulative impacts of the Eastern and Foothill Transportation Corridors and other planned roadway improvements are included through their inclu- sion in the regional forecasts, traffic modeling and through the specific cumulative impact analysis in Appendix E. These planned improvements are described on pages 2-54 through 2-57 of the EIR/EIS and listed on Table E-A. Foothill Transportation Corridor. This information is based on the Final Supplemental EIR No. 423 (FTC, northern Segment) and the EIR currently in preparation for the southern segment (MBA). The following list of significant effects does not necessarily apply to each link alternative. Where a range is identified in a segment, it is due to the difference in impacts reflected in each alignment. Extensive landform alterations in hillside and canyon areas (25 to 81 million cubic yards of cut and fill); Loss of high value vegetation: oak and riparian woodland, riparian scrub and marsh (75 acres in the northern segment and 30 to 90 acres in the southern segment); • Cumulative loss of moderate to high value vegetation: coastal sage scrub, native and non-native grasslands, open water and disturbed (370 acres in the northern segment and 460 to 540 in the southern segment); • 01/31/91MA90M.-INDEX0 CU-7 Displacement and bisection of existing land uses; Removal of land from and/or displacement of agricultural production (400 to 440 acres of agricultural land in the northern segment with 27 acres of prime agricultural land and 325-540 acres in the south- ern segment with 21 acres of prime agricultural land); and Aesthetic impacts -to existing and approved residential land uses. Eastern Transportation Corridor. The following significant adverse im- pacts have been identified in EIR No. 451 (Phillips Brandt Reddick, February, 1988) and confirmed in the EIR/EIS currently under preparation by P&D Technologies, Inc. to result from implementation of the Eastern Transportation Corridor: Extensive landform alterations in hillside and canyon areas (grad- ing impacts ranging from 46.9 to 53.8 millions of cubic yards of excavation and 42.7 to 50.3 millions of cubic yards of embankment); Overall reduction and degradation of open space; Adverse effects upon existing scenic routes,(Viewshed impacts in- clude Featherly Park and residential communities in Yorba Linda in the Gypsum Viewshed, communities north and west of Peters Canyon Reservoir in the East Orange viewshed, Cowan Heights residents and Lemon Heights residents in the Peters Canyon viewshed, and Tustin Ranch Planned Community and transition area in the Tustin Plain viewshed); Loss of existing agricultural land, including 167 to 426 acres of prime, 10 to 15 acres of unique agricultural soils and 1,617 acres of continuing agricultural preserves (under the Williamson Act); Crossing of streambeds (29 intermittent blue line streams and 2.5 acres of wetland loss), increased sedimentation potential (to upper portions of Gypsum, Blind, Hick and Rattlesnake Canyon Watersheds), and increased pollution of water resources (measured in grams per year): 1,425 to 3,711 grams of lead; 528 to 1,432 grams of zinc; 139,230 to 388,612 grams of filterable residue; 181,424 to 482,540 grams of chemical oxygen demand; and 3,552 to 10,006 grams of total kjeldahl nitrogen; 1* 01/31/91(TCA9019%INDEXC) C U - 8 0 0 Loss of high value vegetation: oak and riparian woodland, riparian scrub and marsh (28 to 45 acres); • Loss of moderate to high value vegetation: coastal sage scrub, native and non-native grassland (672 to 826 acres); • Fragmentation of wildlife habitat, and destruction and/or displace- ment of wildlife; a change in movement will occur between east (Gypsum, Blind, Coal, Santiago and Fremont) and west (Weir canyon). Contiguous area will be broken in two. Movement across the Blind and Gypsum watershed will be restricted; • Short-term dust and .air pollutant* emissions during construction; the Corridor, with the west leg, will contribute: 1,545 tons of particulate emission, 109,200 pounds of carbon monoxide, 464,880 pounds of nitrogen oxides, and 46,800 pounds of hydrocarbons; • Minor long-term regional emissions.(units measured in tons per day for the year 2010): 30.58 to 30.61 units of total organic gases (TOG) from the Corridor with 361.59 units in Orange County, 501.24 to 502.53 units of carbon monoxide (CO) from the Corridor with 1,009.55 units in Orange County, and 21.41 to 21.43 units of nitro- gen oxides (NOJ from the Corridor with 173.13 units in Orange County. • Subregional air pollutant emissions measured at 17 receptors, rang- ing from 12.0 to 14.1 parts per million of CO for one hour CO mod- eling and 8.5 to 9.7 parts per million for eight hour CO modeling; • Effects upon existing and committed land uses, including parks and open space spines; Featherly Regional Park Irvine Regional Park • 01/31/91(TCA901B%1NDEXC) Noise levels of 68-69 Leq; in- crease in noise levels over existing ; visual impacts from elevated ramp structures and noise walls. Noise levels of 65-67 Leq; minor visual impacts. CU-9 Harvard Community Athletic Park Peters Canyon Regional Park Limestone Canyon Regional Park Noise levels of 72 Leq/73 to 74 CNEL; increases of 17 Leq/8 to 9 CNEL over existing; eight hour CO standards exceeded at two receptors. Possible visual impacts if ramps constructed. Noise levels of 67 to 73 Leq; minor visual impacts. Noise levels of 66.0 CNEL; minor visual impacts. Weir Canyon Regional Park Noise levels at 67-68 Leq/67-68 CNEL; minimal visual impacts. Irvine Ranch Agricultural Eight hour CO standards Headquarters Historic. Complex exceeded at four receptors; minimal to potentially signif- icant visual impacts. Archaeological Resources Full removal of resource. On -Road Bicycle Trails/ Crossed at 14 locations. Equestrian Trails Crossed at 7 locations. Planned City Parks No impacts. Other Open Space No impacts. • Introduction of potential risks of hazardous materials incidents to a currently undeveloped area. 4. Reasonably anticipated future projects are listed and their cumulative impacts analyzed in the cumulative impact analysis in Appendix E and summarized in Chapter 7 of the EIR/EIS. The study area for the list of projects is the same as the Corridor Area of Benefit (AOB). Due to the proximity to the Corridor, a small portion of the City of Mission Viejo was also included, although it is not within the AOB. The AOB contains approximately 122 square miles and contains all or portions of the fol- lowing jurisdictions: Cities of San Clemente, Dana Point, San Juan Capistrano, Laguna Niguel, Laguna Beach, Irvine, Newport Beach, Costa Mesa and Santa Ana, and unincorporated County of Orange lands. The AOB contains developable areas most likely to contribute to cumulative im- pacts in conjunction with the Corridor. The AOB was adopted by the TCA 0 9.1 01 /31 /91(TCA9018%I NDEXC) CU -10 • 0 for the purpose of determining which areas in the County would generate traffic that would use the Corridor and benefit from it, and is the basis of development fees paid for Corridor construction. The AOB is based on regional traffic modeling prepared by the County of Orange and based on adopted socioeconomic forecasts. Although regional through traffic will utilize the Corridor, the majority of the trips will be generated from within the AOB. Also, please refer to Response to Comment 3-5-30 under Traffic/Circulation. To go beyond the regional projections utilized -for the traffic modeling and socioeconomic analysis and identify a list of projects outside the area and outside the County is not required. The regional traffic model prepared by the County of Orange includes projections of regional through trips based on the adopted General Plans and socioeconomic forecasts of Orange, Riverside, San Diego and Los Angeles counties. Comments 4-33-85 and 4-33-95 state that the AOB was too imprecise for usage in this analysis. The TCA does not agree that the AOB is impre- cise. As described above, the AOB was established as the area which would generate traffic to and benefit from the Corridor. The AOB is appropriate as the area to address a list of reasonably anticipated projects. However, it is not the sole basis of the -cumulative impact analysis in the EIR/EIS. As described above, a cumulative impact area was established for each topic to ensure a complete cumulative impacts analysis. 5. Mitigation measures are provided for cumulative effects within each envi- ronmental mitigation topic listing. The TCA has incorporated all reason- able and feasible mitigation for cumulative impacts. Refer to Response to Comment 2-7-14 under Biology for discussion of open space preservation as mitigation. Comments 3-5-88, 4-33-1, and 4-22-9 state the need to assess impacts in other counties, particularly Riverside, San Diego and San Bernardino. The regional traffic forecasts which account for regional through trips coming from these areas, and the jobs/housing balance analysis based.on OCP-88 and the SCAG Growth Management Plan provide the appropriate assessment of effects on these counties. As noted on page 6-12 of the EIR/EIS, the Corridor may be a factor in inducing growth in north San Diego County. However, as noted in the EIR/EIS, there are a number of other factors which could influence growth in north San Diego 0 01/31/91(TCA9018%INDEXC) CU-11 0 County. Thus, there is no need to develop a separate list of projects in these other counties in order to adequately assess cumulative impacts. Comments 4-22-8, 4-22-9 and 4-33-1 refer to the Corridor as being part of a larger project. It is true that the project is part of the County's Master Plan of Arterial Highways and is part of the SCAG Regional Mobility Plan. As a facility which was initially adopted by the County over 14 years ago, the Corridor is one facet of the.regional transportation system. However, given the Corridor's geographic location and the area which will generate most trips to the Corridor, it is entirely appropriate that the Corridor be considered and analyzed as an individual project. Regional and cumulative effects are ana- lyzed throughout the document as described in this response. No other analysis of a larger project is required or appropriate. The three transportation corridors being planned by the TCA will serve different parts of the County. The traffic modeling completed for the San Joaquin Hills Transportation Corri- dor clearly demonstrates that there is no overlapping or combined traffic effect of the San Joaquin Hills Transportation Corridor with the other two planned corridors. As discussed in the Growth Inducing Chapter of the EIR/EIS, the Corridor is not opening up new areas for development, nor is it removing a constraint for development. Thus the Corridor cannot be viewed as combining cumulatively with the other corridors or other projects as part of a 1 arger project. The com- bined effects of building the whole network on growth and development in Orange County, San Bernardino, Riverside and San Diego have been addressed in the EIR/EIS through the methodologies described above and in the Growth Inducing Chapter of the EIR/EIS. In conclusion, the EIR/EIS provides a comprehensive analysis of cumulative impacts which meets all requirements of CEQA and NEPA. The combination of individual cumulative study areas for environmental topics, the regional pro- jections and the list of reasonably anticipated future projects provide a thorough and complete cumulative analysis. Furthermore, through inclusion in the Regional Mobility Plan the effects of the Corridor and other regional transportation projects have been subject to cumulative analysis. 3-6-26 Land use data for the City of Mission Viejo is summarized in Table E-K and was utilized in the cumulative impacts analysis. 01/31/91(TCA901B%INDEXC) CU - 1 2 6-17-49. 6-17-55 The information and correction noted in these comments are hereby incorporated into the Final EIR/EIS. ci�- 0 01/31/91(TCA9018%INDEXC) CU - 1 3 FISCAL IMPACTS 3-4-3 The City of Laguna Niguel commissioned Alfred Gobar Associates, Inc. to prepare a study to "estimate the potential loss of City revenues inherent in each of two alternative design concepts for construction of a freeway interchange between the San Joaquin Hills Transportation Corridor and the I-5 Freeway.i' The Gobar analysis and report was the primary source for a number of specific comments in the City Letter relating to economic impact. The City's Letter asserted that the City's estimated potential loss of sales and property tax income (as concluded by Gobar) would have significant impacts on the City's discretionary budget and would require major mitigation to offset those im- pacts. Review of the Gobar report has determined that there are serious shortcomings in the report itself, particularly in terms of documentation, basis for assump- tions used, choice of analytical methodology, and application of the methodolo- gy. As a result, the findings in the Gobar report greatly overstate the amount of losses to the City, to the extent that the hypothesized losses may not be as onerous as implied. Key to the Gobar's report calculation of loss for each alternative is the choice of financial analysis methodologies, and the validity of the calcula- tions performed using those methodologies. Based on extensive analysis of these calculations and using widely accepted standard financial analysis tech- niques, it is virtually impossible to replicate the loss figures found in the Gobar report. The Gobar report apparently has chosen to utilize a valuation technique called Capitalization in Perpetuity to establish the Present Value of the City's loss 1 Gobar Report, p.1 2 According to the standard appraisal text, Capitalization Theory and Techniques (published by the American Institute of Real Estate Ap- praisers and used in a course required for MAI certification), Capi- talization in Perpetuity is defined as "capitalization of perpetual income that is expected to endure indefinitely with no expectancy of change." An example of .an appropriate application of this methodo- logy would be for a fixed rate insured passbook savings account, which returns $5 per year, pays 5% interest, and for which there is 0' 01/31/91(TCA9018%INDEXF-G) F - 1 of a sales and property tax income stream attributable to the removal of cer- tain businesses from the confluence area. However, the analysis within the Gobar report ignores certain key factors that are present in this situation. Small, local serving businesses of the type in the assumed study area are subject to relatively frequent failures and change overs, so that the assumption that the income stream (even in current dollars) would be steady (let alone perpetual) is invalid. In fact, field inspec- tion reveals that at least one of the businesses designated by Gobar for the Primary Impact Area (Norena Tile) -was replaced by another business in the two months since completion of the Gobar Report. The assumption that sales and property tax revenue generated from the impacted businesses would be "permanently lost" to the City ignores the basis dynamics of the retail market and the nature of the busi- nesses in the assumed impact area. As an example, a local resident currently buying building materials at Sepulveda Building Materials would be more likely to shift some,.if not all, of his/her business to another Laguna Niguel outlet, such as Home Club, than to go out- side the immediate area for such purchases if Sepulveda Building Materials were to close. In this way, the sales tax and (through increased income which in turn determines appraised values of a busi- ness property) property tax would be shifted to another location within the City, rather than being "permanently lost" from City cof- fers. The Gobar report makes a specific assumption that both sales tax and property tax will grow at assumed annual rates of inflation, and apparently subtracts a blend of those inflation rates from the as- sumed "reinvestment" rate to establish a capitalization rate for the calculation of Net Present Value under the Capitalization in Perpetu- ity technique. Unfortunately, in so doing the Gobar report appears to mix simple growth rates (for the interest rate) and compound rates (for inflation), which is counter to accepted mathematical method- ology. Further, the basic assumption of Capitalization in Perpetuity no special provision for recovery of capital (which is safe and secure, and can be recaptured at any time upon demand). Capitaliza- tion of this investment would be as follows: $5 return = $100 value 5% interest rate 01/31/91(TCA901B%1 NDEXF-G) F - 2 0 • ology. Further, the basic assumption of Capitalization in Perpetuity is that the income stream is level in perpetuity, so that an infla- tion assumption is inappropriate. Given the technique definition and the facts that are present in this situation, the choice of Capitalization in Perpetuity as an analytical technique is not appropriate. With varying periodic cash flows and a finite analysis period (since we can assume that the properties have a finite economic life), a standard Discounted Cash Flow Analysis ' is the appropriate technique to establish the Net Present Value of the cash flows associated with the impacted properties. To calculate short-term losses attributable to disruptions during the period of interchange construction, Gobar apparently used a Discounted Cash Flow method, which appears to be appropriate to the situation. However, the format presentation of assumed loss of income during specific periods is virtually without documentation, and thus it is impossible to verify independently whether the individual year totals are calculated correctly. More important, to establish the level of annual loss under each alterna- tive and for each Impact Area, Gobar makes broad assumptions (e.g., busi- nesses within a certain area will have to close for a period of years while construction is underway). Unfortunately, Gobar provides no empiri- cal evidence or data to establish how these key assumptions were devel- oped, so again it is impossible to prepare an independent evaluation of the validity or appropriateness of those assumptions of the calculations of Present Value that result. By utilizing accepted mathematical techniques and the assumptions that are outlined in the Gobar report, it should be possible to reproduce the calculation results, or at least to come within a reasonable range of those results taking into account rounding and other factors. However, the results reported in the Gobar report cannot be replicated in this fashion. ' "The analysis of cash flow projections, period by period over a pre- sumed term of ownership, to compute the present value for a given rate of return..." (Akerson, Charles B., Capitalization Theory and Techniques, American Institute of Real Estate Appraisers (Chicago, 1984), p. 138) 01/31/91(TCA9018%INDEXF-G) F - 3 • If the Gobar report utilized non-standard mathematical techniques or special formulas to calculate estimates of Present Value, presumably those non-standard techniques or formulas would have been explained (or at least referenced) somewhere in the report. However, the only references to technique in the text of the report indicate that standard methodologies were used. The Gobar Report utilizes a large number of assumptions, virtually none of which is documented or supported by data or empirical evidence. Each of the assumptions used in the analysis can have a major effect on the calcu- lations of loss presented in the Gobar report. Among the key assumptions for which evidence is not provided are the following. 1. Definition of Stud- and Impact Areas The Gobar report claims to have "delineated" the "study area" into "Prim- ary, Secondary, and Tertiary Impact Areas" for each alternative. However, no rationale is offered for the choice of the overall study area, and there is no detailed map within the report to establish its precise bound- aries or those of the three Impact Areas. As an example of the impreci- sion of report documentation, the Tertiary Impact Area is defined as "all other properties in the general vicinity of the interchange".1 The lack of a precise definition of impact areas makes it impossible to perform an independent verification of the appropriateness of Gobar's assignment of a business to a given area. This, in turn, makes it virtu- ally impossible to establish the reasonableness and accuracy of the calcu- lations of loss within the report. The Gobar report apparently accepted the DEIR's designation of "full take" properties to establish the Primary Impact Area. Throughout the report, a variety of maps of the "study area" are pre- sented. The precise boundaries and shape of the study area vary from map to map, bringing into question even further how the Gobar report defined the various areas for which he asserted and calculated a fiscal conse- quence. Gobar Report, p.6 01/31/91(TCA9018%INDEXF-G) F - 4 2. Financial Analvsis Factors Even if it were assumed that the basic annual loss figures for each alter- native and each impact area were correct (which does not appear to be the case), the choice of financial variables can have a major impact on the calculation of present value of the various income streams. In establishing the "reinvestment" or "interest" rate used in the calculations, the Gobar Report chose a rate about equivalent to that for Tax Free Municipal Bonds (which currently have a coupon rate of about 7.5 percent). However, because tax free municipal bonds have an element of risk, they are an inappropriate choice to approximate the return of a "risk free" long-term investment (i.e., one with an assured long-term return with no risk of capital loss). • If, instead, the authors of the Gobar report had chosen to compare to 30-Year U.S. Treasury Bonds (which, although taxable, are considered to be risk -free), the rate of interest would have been approximately 9.5 percent, or two points higher than Gobar's assumed rate. That single change in assumptions (assuming all of Gobar's other assump- tions were correct) would reduce the calculated present value of long-term loss under Alternative I by approximately $278,000 (28 percent of total long-term loss) and the present value under Alterna- tive II by $13 million (41 percent of total long-term -loss). The Gobar report assumes that property taxes (and therefore the pro- perty value base) will increase at a rate of three percent per year, or a premium of one percent over the Proposition 13 limit. To accom- plish this premium implies that the commercial properties would turn over once every five to ten years, depending on the rate of property value inflation. Such a high turnover rate would imply that the properties in question are relatively unstable, which argues against the required assumption of a steady income stream in perpetuity. 3. Other Consultant's Assumptions Other Gobar report assumptions, while not specifically called out in the text of the report, appear to overstate the magnitude of potential loss. Certain figures in the Gobar report are footnoted as being based on "Con- sultant's Assumption", but there is no explanation of the basis on which those assumptions were made. *1 01/31/91(TCA9018%INDEXF-G) F - 5 • A prime example appears in the line item relating to Costco in Gobar's Exhibit III-3 (page 20 of the Gobar Report). Applying stan- dard ratios to the "assumed" $400,000 in annual sales tax, this would imply annual sales of approximately $338 per square foot for Costco (which Gobar variously reports to contain 118,250 or 118,500 square feet). However, Urban Land Institute reports that power centers average approximately $300 per square foot, and that factor combined with the fact that Laguna Niguel stores overall achieve sales per unit that are about 75 percent of countywide averages would indicate that Gobar's estimate is probably overstated. • If the Costco sales figure were adjusted to $225 per square foot ($300 times 75 percent), City sales tax revenue from this single source - which by Gobar's calculations would account for 42 percent of the total annual sales tax lost under Alternative II - would drop by approximately $134,000, which would in turn drop the estimated present value of long-term lost income under Alternative II by about $4.3 million (13 percent of the Gobar-report's concluded total loss). • The entire retail potential analysis (in which he concludes there is no If potential" for offsetting revenue) is premised on a large number of assumptions, none of which is spelled out in the report. Thus, it is impossible to verify whether the conclusions are reasonable and accurate. • Even though the Gobar report admits in the text that there may be possible offsetting revenues to replace some of the monies that are assumed lost', the report makes no allowance for those revenues in calculations of loss. If there is significant revenue potential, this factor should have been included in the Gobar report, if only in a hypothetical "Best Case" Scenario. On page 44 of the Gobar Report, it states that a large-scale home improvement outlet which generates "substantial sales tax revenues and moderate ad valorem property tax revenues ... may be feasible in the study area..." the report also refers to "concurrent studies [which] may identify potential locations for [commercial] develop- ment." This conflicts with other statements in the report that "there does not appear to be significant potential... through the replacement of revenue -generating [commercial] land uses in the study area." 01/31/91(TCA9016•••INDEXF-G) F-6 0 Because of the noted flaws in technique and the lack of assumptions, documenta- tion, it appears that the conclusions of loss presented in the Gobar report do n.ot reflect the facts of the situation. Specifically, the following elements must be considered in evaluating the report conclusions: • The data on which the Gobar report based its conclusions are not always consistent, and apparent errors in certain assumptions raise questions about the validity of the numbers. • It is difficult _to trace -what data was used -in specific calculations in the report, making it impossible to confirm the validity of the calculations. • Certain methodologies chosen to calculate present values of income streams appear to be inappropriate, and the financial factors chosen for those methodologies are subject to serious question. • Potential offsetting revenue, -which may mitigate a significant por- tion of the loss (and the existence of which is acknowledged in the report text) is ignored in the report's calculation of loss, thus throwing into question the basic conclusions of the report. The DEIR/EIS does analyze the impacts.' associated with the construction of_ Alignment #2. The Alignment #2 option is specifically referenced on page 2-25 of the project description. Housing and Business relocation are discussed in Section 4-9 of the DEIR/EIS. There are specific references in this section identifying that.28 commercial/light industrial properties along this alignment would incur some encroachment. Furthermore, Table. I in Appendix I provides a complete list of all properties encroached upon by the Corridor right-of-way. Please see Response to -Comments 3-4-8, 3-4-14 in this Chapter. 3-4-8. 3-4-12, 3-4-99, 3-4-104, 6-3-5. 6-5-5. 6-5-6. 6-8-4. 6-13-9. 6-15-2._ 6-15-49, 6-18-5. 7-29-10, 7-29-12 The City of Laguna Niguel, which was incorporated in December, 1989, is one of a series of recently incorporated cities in the fast growing southern portion of Orange County. Although nearly 75 percent of Orange County's 185 plus neighborhood and community shopping centers are located in the northern and western sectors of the County, nearly 50 percent of the County's estimated 3.5 million square feet of planned new retail development will be located in South Orange County. .' 01/31/91(TCA9018',INDEXF-G) F- 7 10 As of First Quarter 1990 (the latest period for which data are available), the City of Laguna Niguel accounted for nearly two percent of the County's total population, while stores in the City captured less than one percent of the County's taxable retail sales. While the recent opening of the City's first power center (on La Paz Road) will change the relative imbalance of these two measures, this still indicates that there will be market potential for addi- tional retail activity within the City's boundaries and particularly within the three study areas contained within the I-5/73 Confluence Land Use Study. The area within a three mile radius of the confluence study area contains a current population of nearly 60,000 (3.0 percent of County total population), and is expected to grow to a population of over 78,500 by 1995. Population in the five mile radius area will increase from a current 199,000 (9.2 percent of the County) to about 243,000 by 1995. In contrast to the shares of current population, growth in the two defined areas is expected to account for 7.9 percent and 18.5 percent of the County's total 1990 to 1995 growth, respec- tively. Based on the projected population growth in the five mile radius market area, an additional 100,000 to 200,000 square feet of con- • venience/neighborhood retail development could be supported over the next five year period. Private sector employment within the 1,537 businesses in the three mile radius area totals approximately 16,500 persons, including 5,100 commercial business employees and 4,400 office based workers. There are over 41,000 employees working in 3,734 firms in the five mile area. In addition, the federal government's Chet Holifield Office Building includes offices for Internal Revenue Service, Immigration and Naturalization Service, Social Security, and National Archives, with an estimated 1,500 public sector jobs added to the area's employment base. Particularly in the three mile radius area, household incomes are significantly higher than the County's averages ($42,194 median and $53,081 mean). In the three mile area, median income is $57,503, compared to $48,982 in the five mile radius. Mean household incomes for the two areas are $68,696 and $59,789, respectively. Even though Laguna Niguel's share of County retail sales is less than a "fair share" amount when compared to population, existing and proposed commercial development in South Orange County is significant. Within the five mile radius area, there are a total of 25 existing shopping centers, including 11 catego- rized as neighborhood, 9 community, 1 regional, and 2 super regional centers (Mission Viejo Mall and Laguna Hills Mall). Altogether, the centers contain nearly 4 million square feet of gross leasable area and over 600 stores. . 01/31/91(TCA9018%INDEXF-G) F - 8 • New centers coming into the five mile market area include five projects (about 900,000 square feet gross leasable area) under construction, and two community centers (total over 200,000 square feet) in planning. The Gobar study identified a number of businesses that may be removed from the commercial stock as a result of the Corridor's construction, particularly in the interchange area. While the net removal of retail is expected to be sig- nificantly less than that identified in the Gobar study (see Response to Com- ment 3-4-3 in this Chapter), it may nonetheless 'create the opportunity for appropriate additional commercial development to replace some or all of the businesses that are actually removed. Based on projected population levels and existing and anticipated retail sup- ply, there will be both a short and long-term need in the market area for convenience and neighborhood scale retail development. Both community and regional type retail facilities are in a condition of oversupply, particularly in the area immediately surrounding confluence area. • In the defined hotel market area (roughly from Irvine Industrial Complex -East, southward along Interstate 5 to San Clemente), a total of 20 properties were found, catering primarily to business oriented, short-term guests. The majori- ty of properties are targeted to the budget/economy.segment of the market, and year round occupancy levels are relatively poor, averaging about 57 percent, which is below the traditional industry break even level of 60 percent. In recent years, the area's room stock has grown significantly, although cur- rent construction levels are low. However, it appears the major chains have optioned significant amounts of property, to be poised to re-enter the market once the current glut of supply is cured. The 34 room Travelodge Motel along Interstate 5 on Camino Capistrano has been identified in the DEIR/EIS as being removed due to Corridor activity under Option 2. The area hotel/motel market is severely oversupplied at present, with overall occupancies generally below the levels considered necessary for break even operations. The nature of the demand generators in the market area is such that it is highly dependent on short-term, budget conscious business travelers. Until the base of such development in the immediate area of the subject sites improves significantly and catches up with supply, opportunities for develop- ment are very limited. However, once this occurs, development of an additional lodging facility in Laguna Niguel will become feasible. • 01/31/91(TCA901B%1NDEXF-G) F - 9 • As described, although the timing of development of individual elements may vary, there is potential for a variety of commercial development. Altogether, the development potential within the City of Laguna Niguel (with emphasis on the three sites contained with the I-5/73 Confluence Land Use Study) could total approximately 70,000 to 85,000 square feet of retail outlets, and a car dealership, and as many as 200 hotel or motel rooms (please see attached Table). Assuming that hotel development is feasible at build out this scale of develop- ment would generate annual gross taxable retail sales of approximately $18,245,800 (including an estimated $5,341,000 from relocation of the auto dealership) and annual gross room revenue of $3,577,000, both stated in current (1991) dollars. Assuming a City Sales and Use Tax share of one (1) percent of retail sales, and a City Transient Occupancy Tax of eight (8) percent, City revenues from these two sources would total approximately $522,028. In addi- tion to these revenues, the City will receive property tax revenue, based on the assessed values of the commercial properties involved. If hotel development is replaced with support retail, gross revenue will total $26,996,800 per year, with the City receiving annual sales and use tax revenues of $269,968. In addition to the new business potential and the relocation of the auto dealership, it is also noted that current Corridor related planning efforts are directed to "saving" the Costco and Sepulveda Building Materials businesses thereby significantly reducing any potential loss in commercial activity relat- ed revenue to the City of Laguna Niguel. The DEIR/EIS states that construction of the Corridor could potentially result in the loss of sales tax revenue due to displaced businesses in the City of Laguna Niguel. The DEIR/EIS acknowledges that Laguna Niguel has a very limited tax revenue base. The TCA disagrees that the loss of sales tax revenue will have a physical impact on the community of Laguna Niguel. If Alignment #2 is selected, there will be approximately 22 acres available (Alignment #1) for relocation opportunities. This acreage could then be used to relocate existing businesses or attract new businesses to the confluence area, which would pro- vide an attractive business environment due to additional regional access opportunities and increased visibility. In addition, the study area is cur- rently experiencing a relative high vacancy rate which provides ample opportu- nity for relocation. The TCA has viewed the introduction of Alignment #2 as an opportunity to improve Laguna Niguel's tax base. 01/31/91(TCA901B%1NDEXF-G) F-10 • • SUMMARY OF POTENTIAL CITY REVENUES FROM TRANSPORTATION CORRIDOR SITE COMMERCIAL DEVELOPMENTS Alternative I - Including Hotel Annual Gross Revenue Annual Revenue to City Pacific Park $3,577,000 $286,160 200 Room Hotel [13 Moulton Parkway $4,546,800 $45,468 20,000 sq.ft. GLA Convenience Center [23 Camino Capistrano a. 6 Acre Auto Dealer [33 $5,341,000 $53,410 b. 50,000 sq.ft. GLA Neighborhood Center [41 $13,699,000 $136,990 Total Alternative I $27,163,800 $522,028 Alternative II - Excluding Hotel Pacific Park 15,000 sq.ft. GLA Support Retail [23 $3,410,000 $34,100 • Moulton Parkway 20,000 sq.ft. GLA Convenience Center [23 $4,546,800 $45,468 Camino Capistrano a. 6 Acre Auto Dealer [33 $5,341,000 $53,410 b. 50,000 sq.ft. GLA Neighborhood Center [43 $13,699,000 $136,990 Total Alternative II $26,996,800 $269,968 Notes: 113 70 percent occupancy, $70 ADR, bed tax 8 8 percent. [23 $227.34 per sq.ft. sates (upper decile), City share of sales tax 2 1 percent. [31 Based on market area average taxable revenue for automobile dealers, city share of sales tax e 1 percent. [41 $273.98 per sq.ft. sales (upper decile), City share of sales tax a 1 percent. Sources: P$D Technologies, Urban Land Institute, Urban Decision Systems 0 01/31/91(TCA9018%INDEXF-G) F - 1 1 • To the extent that sales and property tax revenue from displaced businesses is not replaced by the shifting of customers, relocation, or opening of new busi- nesses within the City of Laguna Niguel, there could be minor, but short-term, reductions in City revenues. However, in the longer term - particularly after construction of the SJHTC is complete - there should be no net reduction of revenue to the City of Laguna Niguel generated from these commercial facilities or their replacements. With respect to alignment #1, the loss of $25,520.00 annually to the City's budget cannot be perceived as significant or resulting in a physical change to the environment. Again, the Gobar study assumed all affected businesses would relocate outside of the City and not avail themselves of opportunities to relocate within the community. This approach appears quite excessive, given the increased visibility brought to the confluence area. Furthermore, page 2- 52 of the DEIR/EIS identifies Alignment Option #1 as the environmentally sup- erior alternative relative to business and housing relocation. 3-4-9 • The EIR/EIS acknowledges on page 4-105 that construction of I-5 Interchange Alternative Option 2 could potentially result in the loss of tax revenues to the City of Laguna Niguel ("City"). However, the Draft EIR/EIS does not exten- sively analyze the economic and social impacts resulting from a potential loss of revenue to the City, or describe mitigation measures for such effects. The California Environmental Quality Act (CEQA) and the regulations promulgated pursuant to CEQA (CEQA Guidelines) do not require the inclusion of economic or social analysis in an environmental impact report. Economic or social effects by themselves are not treated as significant effects on the environment. "An EIR may trace a chain or cause and effect from a proposed decision on the project through anticipated economic or social changes resulting from the project to physical changes caused in turn by the economic or social changes. The intermediate economic or social changes need not be analyzed in any detail greater than necessary to trace the chain of cause and effect. The focus of the analysis shall be on the physical changes" (CEQA Guidelines Section 15131). Although the Draft EIR/EIS identifies potential economic effects on the City, specific physical effects of the tax revenue reduction for the City are too speculative to determine at the present time. The actual loss of tax revenue to the City will depend on the extent to which relocation of existing business- es is feasible, and the extent to which new businesses develop and provides additional tax revenues to the City. Further, specific physical impacts from a revenue reduction in the City will depend on a variety of factors, including the City's allocation of its remaining revenue resources. Please see Response to Comment 3-4-39 under CEQA/NEPA Issues for a discussion regarding the con- . 01/31/91(TCA9018%INDEXF-G) F - 1 2 U sideration of economic issues for NEPA, and Response to Comment 3-4-8 in this Chapter regarding loss of tax revenue. 3-4-10 The cited calculations of loss are overstated because: (1) assumptions used in the calculations are erroneous; (2) methods chosen to calculate are in appro- priate to the facts of the situation; and (3) there is no allowance made for the shifting of business to other Laguna Niguel merchants, relocation of dis- placed businesses, or new business opportunities created by completion of Corridor. Please see Responses to Comments 3-4-3 and 3-4-8 in this Chapter. 3-4-11 The magnitude of net loss is significantly less than projected in the Gobar report, and could be shown to approach zero once all mitigating income sources are considered. Please see Responses to Comments 3-4-3 and 3-4-8 in this • Chapter. 3-4-13 The impacts associated with construction activities are discussed in Section 4.17 of the DEIR/EIS. Mitigation Measures 17-22 and 17-23 require the prepara- tion of traffic management plans in association with the local agencies to ensure that Corridor construction activity minimizes traffic conflicts and provides for business access. In addition, please see additional Mitigation Measure 17-23a as proposed in Response to Comment 3-4-14 in this Chapter. 3-4-14, 6-3-1. 6-7-1. 7-24-10, 7-29-3. 7-29-4. 7-29-5 The cooperative I-5 land use study is a separate study effort which addresses the Camino Capistrano access issue. Due to the unique site constraints associ- ated with the Camino Capistrano area (proximity to I-5 and railroad right-of- way, topography and flood control), there is heightened interest regarding how access can be provided to the area with the implementation of Alternative 2. One improvement which will increase local access opportunities is the connec- tion of Cabot Road between Crown Valley Parkway and Oso Parkway. The County of Orange is planning on awarding a contract to provide this connection during the summer, 1991. The solution to improved Camino Capistrano access is to provide a connection to Cabot or Crown Valley Parkway at the north end of Camino Capistrano. A mitigation measure has been added to the DEIR/EIS which requires implementation of the additional Camino Capistrano access if Alternative 2 is • 01/31/91(TCA901B%INDEXF-G) F - 1 3 selected. With Alternative 1 the existing access to Camino Capistrano will not be altered. Mitigation Measure 17--23a reads as follows: 17-23a Prior to any construction activity occurring within the 73/I-5 con- fluence area, the TCA, with review by the cities of Laguna Niguel, Mission Viejo, and San Juan Capistrano, shall prepare a Confluence Construction Period Business Access Plan. This plan shall identify how access to businesses in the confluence area will be maintained during construction activities. One component of the construction period business access plan shall be the provision of appropriate emergency access and will include implementation of a permanent connection on the north end of Camino Capistrano to insure access to Oso Parkway or Crown Valley Parkway (with implementation of the Alternative #2 connection to I-5). Fund- ing will be developed based on local agency and business benefits or contributions to need. Business relocation within mendations contained in th 3-4-15 Th`e DEIR/EIS does cant. Contrary to and an appropriate will be small. The to be eliminated o 3-4-16 e r Mitigation Measures 9-1 through 9-7 identify the business relocation program which will be pursued by the TCA. This program provides appropriate mitigation to displaced businesses. The TCA will work cooperatively with the City of Laguna Niguel during administration of the relocation program and pursue a goal 01/31/91(TCA9018%INDEXF-G) F- 1 4 • to retain as many displaced businesses as possible within the City's corporate limits. 3-4-19, 3-4-20, 4-22-20 Business relocation within Laguna Niguel and the implementation of the recom- mendations contained in the cooperative Land Use Study will provide adequate economic assistance for the City of Laguna Niguel. No additional mitigation is necessary. 3-4-28 There is no need to "revisit" Alternative #1. Alternatives #1 and #2 are pre- sented in the DEIR/EIS as viable alternatives for the connection of SR-73 with I-5. Both alternatives receive an equal analysis in the DEIR/EIS and have proceeded to the 35 percent design stage. The Board of Directors may choose either alternative when considering the route alignment for the Demand Manage- ment alternative. If the Board selects the Conventional Alternative, then Option 1 would be implemented. 3-4-37 The DEIR/EIS adequately addresses the impacts associated with construction of either the Demand Management or Conventional Alternative. Alignment #1 and #2 options are adequately analyzed and compared in the DEIR/EIS. Adequate mitiga- tion is contained in the DEIR/EIS for addressing project impacts. Therefore, recirculation of the document is not necessary since significant new informa- tion will not be added to the document. 3-4-38 The P&D Technologies ( I -5 Land Use) Study is a planning study which does not need to be included in the DEIR/EIS. The study will focus on land use opportu- nities available with the implementation of Alternative #2. The study will be distributed to the public in mid -January approximately one month prior to the February, 1991, Board hearing on the Corridor route alignment and DEIR/EIS certification. The Board will take public comment on the I-5 Land Use Study at its February meeting. This procedure will allow adequate time for analysis and enable the City of Laguna Niguel to formulate a recommendation relative to its particular interest. • 01/31/91(TCA901B%INDEXP-G) F - 1 5 3-4-60 Given a proper analysis of the impacts of the interchange on area businesses and the potential for mitigating income sources, the net loss of revenues will be significantly lower than those projected in the Gobar report. As a result, there should be little if any effect on the City's revenues and ability to provide public services. Please see Response to Comments 3-4-3 and 3-4-8 in this Chapter. 3-4-64 The effect on employment is not significant. If businesses take advantage of the relocation opportunities available to them, relocation within the City of Laguna Niguel will be readily available. 3-4-65 Employment through Corridor construction is not an environmental implication of the project. However, Corridor construction employment opportunities will have a net benefit on socioeconomic conditions. Based on the number of construction vehicles operating (1,032) times an employee factor of 1.3, there would be approximately 1,341 persons employed through direct construction activities. If office support and consultant services are added, the employment provided through Corridor construction would approach 2,000 persons. 3-4-72 The funding sources for the project do not involve environmental impacts. Therefore, their discussion in a DEIR/EIS is not relevant. For your informa- tion, Exhibit 1 the San Joaquin Hills Corridor Financing Plan, to this Response to Comments document is provided. 3-4-81 Impacts related to business displacement and the local tax base are not signif- icant; therefore, no change is necessary to the environmental checklist regard- ing items #38 and #39. Please see Response to Comment 3-4-15 in this Chapter. 3-4-91 While it may be a statement of fact that the development of the interchange could result in a "potentially [emphasis added] significant loss of sales tax and property tax revenue to the City of Laguna Niguel", the amount of the 01/31/91(TCA901B%1NDEXF-G) F-16 • • probable loss has been grossly overstated in the Gobar report. The summary of the report ignored potential mitigating revenues, and utilized incorrect techn- iques and assumptions that do not reflect the facts of the situation. Please see Responses to Comments 3-4-3 and 3-4-8 in this Chapter. 3-4-92 The estimate of "Present Value of Loss of Income Streams to City" is based on an inappropriate application of a methodology (Capitalization in Perpetuity) that presumes: (1) a steady, risk free stream of income; (2) income in perpetu- ity; and (3) no consideration of return of capital. None of these assumptions apply to the situation being analyzed, because: (1) the income stream is derived from a series of small businesses, which tend to fail and/or change frequently; (2) the consultant added the element of infla- tion, which runs counter to the definition of the analytical method being used; and (3) the assumptions used to calculate the various numbers are either undoc- umented or disproved by readily available facts that are not included in the report. The Gobar report further distorts the magnitude of loss by ignoring the basic fact that revenue currently generated by the potentially displaced businesses would most likely be captured by other existing Laguna Niguel retail outlets, or by businesses that may open in the future in the city as a result of comple- tion of the Corridor. Please see Response to Comments 3-4-3 and 3-4-8 in this Chapter. 3-4-93, 3-4-94 The specific numbers reported are greatly affected by the consultant's choice of methodology and capitalization rate factors, particularly for interest rate and inflation rate, both of which are used in establishing a capitalization rate for the calculation. Each point difference in capitalization rate trans- lates into a significant change in the calculated Present Value (about $170,000 for Alternative I and $8 million for Alternative II). For interest rate, the Gobar Study used tax-free municipal bonds, which carry coupon rates of about 7.5 percent. If, for example, the report had used U.S. Treasury bonds (which are considered to be risk free, although taxable), the interest rate would have been closer to 9.5 percent, and the calculated amounts would have dropped significantly. As for the Gobar report property tax infla- tion assumption, it implies that there will be a significant turnover of the commercial properties in the impact area, which in turn implies instability and • 01/31/91(TCA9018%INDEXF-G) F - 1 7 • thus no assured income stream. The basic assumption that business (and thus related tax revenue) will actually be lost to the City of Laguna Niguel is discussed in Response to Comment 3••4-92 in this Chapter. 3-4-95, 3-4-96, 3-4-97 While there may be some impact to businesses in the area of the interchange during the construction period, descriptions of those areas in the Gobar study are vague and imprecise and it is impossible to comment on the reasonableness of its estimates of short-term loss. Further, it ignores the fact that there are alternative outlets within the City of Laguna Niguel for the local serving types of businesses involved in the impact areas, and thus it is likely that the revenue lost by one Laguna Niguel business will be recaptured by another firm within the City. There is no empirical evidence or other data offered in support of the Gobar report assumptions about the duration and magnitude of the impacts in each of the Impact Areas. Further, the report's definitions of the Secondary and • Tertiary Impact Areas are relatively imprecise, so that independent verifica- tion of the figures is impossible with the information available in the report. The calculation of Present Value of Loss of Income Streams cannot be replicated using industry standard Discounted Cash Flow techniques, based on the assump- tions shown in the table. If a non-standard technique was applied, that tech- nique should be documented in the report. 3-4-98 Without more precise definitions and maps of the assumed impact areas, it is impossible to verify the locations of any given business, particularly for the Secondary and Tertiary impact areas. A number of different overall study areas boundaries are shown in the various maps included as exhibits in the report. Please see Responses to Comments 3-4-3 and 3-4-8 in this Chapter. 3-4-100 This very generalized statement epitomizes the approach that is taken through- out the report, particularly when it comes to precise definition and documenta- tion for assumptions used in the analysis. There is no indication which land uses were reviewed, nor are the criteria on which they were judged to "appear to be feasible" included in the Gobar study. 01/31/91(TCA9018%INDEXF-G) F- 18 • 3-4-101 The Exhibits referenced in these paragraphs include a number of significant errors or inconsistencies as identified in Response to Comment 3-4-3 in this Chapter. The effects of these errors on the conclusions drawn by the consul- tant are unclear, but they could be significant when considered cumulatively. 3-4-102 Exhibit IV-6 purports to be the Gobar report "Demand Analysis for Community Level Retail Floor Space" within a three mile trade area. Unfortunately, there is no documentation of the assumptions that underlay this analysis, so that independent verification of its findings. is impossible. It is unclear why the Gobar report chose to ignore the potential for neighborhood or convenience commercial, corresponding approximately to the two mile ring as defined in Exhibit IV-1 of the Gobar report. Please see Responses to Comments 3-4-3 and 3-4-8 in this Chapter. is 3-4-103 Gobar's five mile area analysis apparently related to regional demand, although the widely respected Urban Land Institute defines such a trade area as support- ing community level types of businesses. Further, the report's reference to development of a regional mall in the Golden Triangle area is irrelevant, since that project is approximately ten miles from the study area and thus outside the five mile trade area. Please see Responses to Comments 3-4-3 and 3-4-8 in this Chapter. 3-6-32 The Areas of Controversy section denotes that the I-5 Land Use/Traffic Studies are areas of controversy. 4-17-9. 7-1-6 The planned location of the San Joaquin Hills Transportation Corridor has been disclosed to purchasers of property along the proposed Corridor alignment since the early 1980s, through real estate documents provided at the time of sale. Additionally, numerous environmental documents have disclosed the proposed Corridor alignment, and large signs marking the proposed alignment where it crosses arterial roadways have been in place since 1986. Further, public noti- fication procedures mandated by the California Environmental Quality Act (CEQA) were followed for each of the Environmental Impact Reports written since the 9 01/31/91(TCA901B%1NDEXF-G) F-19 Corridor project's conception. Therefore, anyone purchasing property along the proposed alignment of the Corridor, since the early 198Os, should have done so with knowledge of the proposed Corridor project. 6-6-1 Mitigation measures in Chapter 4, pages 4-105 and 106 of the DEIR/EIS, describe business relocation assistance in accordance with The Uniform Relocation Assis- tance and Real Property Acquisition Policies Act of 1970 as amended. 6-9-1 Please see Response to Comment 6-8--3 under Traffic and Circulation and 3-4-14 in this Chapter. 6-13-3 The unique set of issues faced by Sepulveda Building Materials if Option #2 is selected is noted and will be considered by the decision makers prior to making an alignment decision. 6-13-4. 6-14-3. 6-14-5 Section 4.9 of the DEIR/EIS discusses the impacts associated with housing and business relocation. Proposed mitigation includes the implementation of fede- ral and State relocation programs. Response to Comment 3-4-14 in this Chapter brings forth a mitigation measure which provides a business access plan during construction. The TCA has commissioned a separate I-5 Land Use Study. This study is investigating opportunities to relocate businesses (should Option #2 be selected) within the abandoned Option #1 right-of-way and to use air space associated with Option #2. This study will be available for public review in mid -January, 1991. For additional information regarding fiscal implications, please see Response to Comment 3-4-8 in this Chapter. 6-13-8 Your concerns regarding the impact to small businesses with the implementation of Option #2 is noted and will be considered by the decision makers. 01/31/91(TCA9018%INDEXF-G) F - 2 0 • 6-13-10 Your cooperation in dealing with the TCA is greatly appreciated and the Agency will continue to provide you every consideration possible in finding a solution to your business needs. 6-14-4 Please see Response to Comment 3-4-8 in this Chapter. The I-5 Land Use Study commissioned by the TCA is investigating the potential for retaining Costco in its current location with implementation of Option #2. This study will be available for public review in mid -January. 6-14-7 Please see Response to Comment 6-13-6 under Cost. 6-15-8 • Please see Responses to Comments 3-4-8 and 3-4-14 in this Chapter. 6-15-9 There is no evidence that any special district would be adversely impacted by the change in property tax assessments. Furthermore, construction of the Corridor will greatly increase the value of confluence area business properties due to increased access and visibility, this increase in value would more than offset any reduction in the number of property tax assessments. 6-15-46, 6-15-48 The I-5 Land Use Study is a separate planning study, focusing on Land Use opportunities and circulation improvements which can be implemented with Option #2 to protect the economic vitality of the confluence area. The I-5 Land Use Study will be available in mid -January, 1991 for public review. The Study will be presented to the Board of Directors as part of the staff report and public hearing package for their use in selecting an I-5 connecting option. In addi- tion, please see Responses to Comments 3-4-8 and 3-4-14 in this Chapter. 6-18-1 No evidence has been presented that proximity of the Corridor to your office building will result in financial impacts which would result in a physical 01/31/91(TCA9018%INDEXF-G) F - 2 1 change to the environment. In fact, it is highly probable that increased visibility and access will improve the value of the office structure. 6-18-6 Please see Section 4.9 of the DEIR/EIS (Housing and Business Relocation). 6-18-7 Please see Section 4.9 of the DEIR/EIS (Housing and Business Relocation). 6-19-1 Your comment regarding the severity of the impact to your business is noted. 6-19-3 Your comment regarding saving local businesses is noted. • 6-20-9 The commentator's concerns will be considered by the TCA Board of Directors at the time an I-5 connection option is selected. The traffic studies for the South End do not demonstrate volumes on Marguerite Parkway or Avery Parkway that cannot be handled by typical design measures. 7-3-4 Tollways represent an innovative approach to funding the difference between available State and federal funds for transportation projects and the cost of constructing such projects. Additionally, the Corridor is designed to relieve overloaded arterials by providing a facility more suited to handle intercommunity traffic. 7-9-6 TCA is required to, and will, implement all mitigation measures. A sound wall to mitigate noise impacts to residences along Westridge Lane is proposed as described in the Response to Comment 7-4-1 under Request for Data. 01/31/91(TCA9018%INDEXP-G) E - 2 2 • • 7-13-1 The size of the informal survey may lead to erroneous conclusions. The TCA has seen the results of three studies which show strong support for the Corridor: 1. Wilbur Smith Post Card survey 2. Baldassare Study 3. City of Irvine Opinion Survey These surveys were over a broader range of interest and performed in a manner which is generally recognized. 7-13-2 The peak period use of the Corridor has been demonstrated by studies to provide economic viability for the tollway. The toll phase of the project is, in fact, an interim measure and ultimately the tollway, as required by law, will become a freeway where its ability to draw traffic will not be limited by tolls. • 7-22-2 See Response to Comment 4-5-1 under Funding/Tolls. 7-24-1 This statement is the opinion of the commentator and will be taken into con- sideration by the decision makers during the review process. 7-24-3 Comment acknowledged. During construction of either alignment alternative, access to local businesses would be maintained, detours will be adequately signed and congestion minimized to the extent possible. Please see Response to Comment 3-4-14 in this Chapter. Should your business be displaced, you would be relocated to a comparable location and compensated fairly. Please refer to Section 4-9 of the DEIR/EIS (Housing and Business Relocation) for details regarding housing and business relocation assistance. • 01/31/91(TCA9019%INDEXF-G) F- 23 C 7-24-5. 7-24-9 The SJHTC EIR/EIS (Table I, page 5, Summary of Housing and Business Impacts) lists 28162 Camino Capistrano as a partial take of the structure and parking lot for alignment alternative II connection of the Corridor to I-5. 28142 Camino Capistrano is not listed as being displaced by either alignment alterna- tive. At such time as the route selection has formally been adopted and final design has been accomplished, exact right-of-way requirements will be established. An appraisal which will reflect the value of the property being acquired will be prepared and reviewed. Upon its acceptance by the agency, an acquisition agent will contact owners and lessees, if any, to provide the appraised value and to advise you of all the benefits to which you are entitled based upon the requirements of the State of California Department of Transportation, guide- lines of the State of California Department of Housing and Community Develop- ment, and the Federal Uniform Relocation Assistance Act requirements which • apply to appraisal, acquisition and relocation. Final determinations of these benefits are not possible until the actual re- quirements for the project are utilized. Should your business be displaced by the selected alternative, you may be assured that the agency will follow these guidelines and will work with you to the greatest extent possible. 7-24-6 Comment noted. 7-84-3 The DEIR/DEIS project has not intended to mislead either the public or the decision makers. The short-term construction activity slowdown has occurred since the document's circulation. Notwithstanding this disclosure, the history of this Corridor can be reviewed to show that the temporary slowdowns in devel- opment, such as those in 1980-81 and those today, do not change the need for the Corridor. The real estate industry and land development cycles have his- torically experienced fast paced growth peaks followed by market slowdowns as overly active markets return to normalcy. 01/31/91(TCA9018%INDEXF-G) F - 2 4 • 7-60-3. 7-85-3 There is no evidence that construction of the Corridor will result in a loss of property value resulting in a physical change in the environment. With respect to notification of property owners and purchasers regarding the pending con- struction of the Corridor, please see Response to Comment 4-17-9 in this Chap- ter. Given the aesthetic guidelines under which the Corridor will be cons- tructed (provided as Exhibit 2), construction of noise walls, and the provision of greatly improved access, the Corridor will not have an adverse impact on property values. 7-132-3 With Corridor construction, there will be no change in access to local eques- trian trails. 0 01/31/91(TCA9018%INOEXF-G) F- 2 5 • FUNDING/TOLLS 2-10-1 The TCA is aware of the actions taken by the California Transportation Commis- sion relative to project funding. 3-3-12 A coordination meeting between SCAG and TCA was held on December 10, 1990. TCA will continue to coordinate with SCAG on issues including HOV pricing and park and ride facilities. Also, see Response to Comment 3-3-9 under Air Quality. 3-4-69. 4-18-12. 7-25-2. 7-109-2 The study of toll feasibility took into account the demographic profile of Southern Orange County and the user group. The study by Wilbur Smith and Associates found that discretionary income, coupled with traffic delays on freeways and parallel arterials, provided substantial demand to support a toll facility. The enabling legislation required that the toll road parallel free facilities (I-5, I-405, SR-1) which could be used by those persons who were opposed to paying tolls or could not afford to pay. 3-5-18, 3-5-124, 3-5-129 The availability of funds to build the Corridor is not an issue that requires discussion in the DEIR/EIS. Documentation/Reports providing a thorough analy- sis of cost and revenue are available at the offices of the TCA. All mitiga- tion measures described in the DEIR/EIS will be fully funded through the Design Build concept. However, for informational purposes, please see Exhibit 1 of this Response to Comments document (San Joaquin Hills Corridor Financing Plan). 3-6-71 The TCA has prepared a separate Toll Facilities Plan (schematics) and Toll Facilities Program dated November 1990 which will be distributed to the City through the Technical Advisory Committee. Toll traffic forecasts are consid- ered to be compatible with forecasts used in the DEIR/DEIS as screenline checks were utilized by our consultant for this purpose. 01/31/91(TCA901B'••INDEXF-G) F/T-1 • 3-6-83 The commentator is referred to DEIR/EIS page 2-2 which provides substantial information on toll system operation. Further information will be available with final design; however, it should be noted that no new impacts are antici- pated to result from these design refinements. 3-6-84 See page 5-1 of the EIR/EIS for an explanation of why toll free volumes are utilized as a worst case assessment. The commentator is referred to the Technical Studies Volume II, Study 7, of the DEIR/EIS which contains a description of the toll/toll free data. 3-8-19 It is anticipated (conservatively) that the construction bonds can be retired by the year 2010 and the SJHTC can at that time become a freeway. Screenlines have been provided in the DEIR/DEIS as a way to demonstrate to the public the projected traffic conditions on the surrounding highway network with implementation of the SJHTC as a toll facility. The toll volumes for the year 2010 were forecasted on a basis which is equivalent to the proposed rate of approximately $0.15 per mile. If this toll rate were excessive, the following might occur: 1. Arterial traffic would be significantly higher when tolls are imposed than in a toll free condition. 2. Total traffic might be significantly constrained by the tolls and might rise noticeably when tolls are removed. Reviewing the column titled "Arterials," it can be seen that percentage change in arterial traffic with or without tolls is less than 10 percent (e.g., screenl i ne #2, 150/140 = a toll vs. toll free ratio of 1.071 which is a 7.1 percent change). This contradicts the notion that tolls will radically divert traffic to the arterials. Similarly reviewing the "Totals" column, the ratios indicate that toll impo- sition does not change the overall demand to travel across the screenlines by 01/31/91(TCA9018%INDEXF-G) F/T - 2 0 • more than 4 percent to 6 percent. Simply stated, tolls do not appear to unrea- sonably impede basic travel demand. If the "Freeway" column is reviewed it should first be compared with the Build/ No Build Alternatives. With this in mind, it can be observed that building the Corridor and operating it as a toll facility provides initial congestion relief followed by additional congestion relief when tolls are removed. The observation that arterial traffic at screenline 5 increases when tolls are removed is explained in part by the way the screenline unavoidably crosses certain arterials which feed the Corridor. The variation is also small and within the standard error of projections. 3-8-20 The toll sensitivity model is not dependent upon the accuracy of the Corridor's financial plan. It is dependent upon generalized financial models commonly used by the most reputable banking and/or governmental institutions to forecast future economic trends. 3-8-21 Mitigation Measure T/C-5 has been amended. This amendment will establish a traffic monitoring program whereby Corridor traffic will be monitored on a regular basis. See Response to Comment 2-10-2 under Traffic and Circulation. 3-8-22 Upon retirement of the construction bonds the interim toll facilities would be removed as follows: all ramp toll plazas would be removed by the TCA and wid- ened ramp aprons reconfigured to freeway standards. Where CHP enforcement areas have been provided they will remain unaltered. At the main toll plaza, two options exist: Plan 1. Total removal of all main toll plaza buildings, aprons, ramps, etc., except for law enforcement areas and revegetation with native materials. • 01/31/91(TCA9018%INDEXF-G) F/T - 3 Plan 2. Retention of the main toll plaza area with conversion to viewpoint and the reuse of the toll building for law enforcement, maintenance or similar uses. 4-4-3 • The sources of revenue for construction of the San Joaquin Hills Transportation Corridor are as follows: Approximately 48.5 percent of construction costs will be funded by fees collected from developers in the area of traffic benefit (AOB). These fees are collected on new development (commercial or residential) on a one time basis. The remaining 51.5 percent of the funding comes from bonds (that are paid back by toll revenues) or HR-2 monies that have been set aside by the California Transportation Commission in an amount of approximately $43 million dollars. There are no general tax, property tax, gasoline tax, or sales tax revenues used by this project and consequently the "user/funded" (tolls) approach does not take money away from other programs. 0 4-5-1. 7-123-3. 8-4-3 Toll traffic studies performed by Wilbur Smith and Associates utilized, in part, a postcard opinion survey to measure the viability of the demand for the Corridors under toll conditions. Based on this data and standard traffic modeling techniques (see Response to Comment 4-5-6 under Traffic), it is pos- sible to forecast a strong travel demand under toll rates as high as $.15/mile. Those travelers who do not wish to pay this rate may benefit from carpooling use of the Corridor, or they may simply choose to use the existing freeway/ arterial highway network which will be relieved by the Corridor. 4-7-8. 4-7-9 The DEIR/EIS only briefly discusses financing because financing is not an environmental issue subject to CEQA and NEPA. A combination of fees on new development and toll revenue will finance the Corridor. Development fees are collected at the time a building permit is granted by one of the TCA's member agencies. Fees are assessed at different rates for residential and commercial property. The fees are assessed on new development only, and will fund approximately 48.5 percent of the construction cost of the Corridor. The remainder of the cost will be funded through tax exempt, 30 year toll revenue bonds that will be sold by the TCA. These bonds will be repaid through the tolls collected. State law requires that the tolls 01/31/91(TCA901B%INDEXP-G) F/T - 4 • 0 be removed once the bonds are repaid. Additionally, a commitment of approxi- mately $43 million has been promised by the California Transportation Commis- sion to help fund project costs. Further, on October 12, 1987, the Orange County Transportation Commission designated the Corridor as a pilot demonstra- tion project authorized by the Federal Surface Transportation and Uniform Relocation Assistance Act. Also, State legislation (SB 1413, SB 1415, AB 1074 and AB 1075), enacted in August and September of 1987, allows the designation of a "demonstration toll road project" on any transportation corridor in Orange County. As a "demonstration toll road project," the Corridor is eligible for up to 35 percent federal funding for construction. The TCA has committed that toll enforcement will be paid for from toll reve- nues. After tolls are removed from the facility, upon repayment of construc- tion bonds, police services will be provided by the California Highway Patrol, as with other State Highways. During the period that the facility will be tolled, separate police arrangements will be required to be funded with TCA funds. Several alternative sources for Corridor policing services during the toll period are being considered, including private agencies and contracting with the California Highway Patrol. Caltrans will provide maintenance services for the Corridor in the same manner as for other State highways. The purpose of the Corridor project is not to accelerate growth in Orange County. The primary objective of the Corridor is to serve the general public by alleviating existing and planned projected (without the Corridor) peak period traffic congestion on the regional circulation system and to minimize regional through traffic use of arterial highways. For further discussion regarding the need for and purpose of the Corridor project see Section 1.0 of the Draft EIR/EIS. 4-7-10, 4-17-5. 7-37-9. 7-62-3. 7-75-1. 7-86-9. 7-86-38 Financing plans for the Corridor, as well as the Joint Powers Agreement forming the TCA, contemplate that toll revenue bonds will be repaid solely from devel- oper fees and toll revenues. Risk of default in bond indebtedness is expected to be assumed by letter of credit banks. The San Joaquin Hills Transportation Corridor is part of (and consistent with) the Regional Mobility Plan (RMP), prepared by the Southern California Associa- tion of Governments (SCAG) and the South Coast Air Quality Management District (SCAQMD). The RMP guides the long range development of the regional transpor- tation system for the SCAG region. Additionally, the 1989 RMP is used to 01/31/91(TCA9018%INDEXF-G) F/T - 5 • determine the conformity of transportation projects, in the South Coast Air Basin, with the Air Quality Management Plan (AQMP). Under the SCAG approved conformity procedures and the 1989 AQMP conformity Guidelines, the Corridor is in conformity with the 1989 AQMP for the purposes of SCAG and other local agencies. Please see Exhibit 1 to this Response to Comments document, San Joaquin Hills Transportation Corridor Financing Plan. 4-17-7. 7-84-36, 7-84-37, 7-84-38, 7-150-1 The method of funding the Corridor has evolved because the public has expressed a strong desire to have the user of the facility pay for the facility. This method of funding does not require special sales taxes or property taxes. The government code establishing the TCA (legislation passed in 1987) estab- lishes the authority to collect developer fees. Subsequent legislation and TCA actions establish the authority to collect tolls (see Response to Comment 4-17-19 in this Chapter). These actions are not in conflict. Over the course of the past three years critics of the Corridor have pointed to the new residents in south Orange County as being culpable for the traffic problem. The equity provided by funds coming from new development and user tolls fully mitigates this concern. There is no factual data which establishes that a new resident and toll user would pay four times more than other users. The enumeration of four concern areas is acknowledged; however, comment 4-17-7 has not demonstrated that these areas equate to an inflation multiplier of four. Regarding developers passing on fees, the TCA has no authority or control over developers' actions in this regard. 4-17-19 The TCA's authority to collect tolls on the San Joaquin Hills Transportation Corridor (SJHTC) is mandated by State legislation. California Senate Bill 1413 (passed December 1987) allows the SJHTC to operate as a toll road on an interim basis until the original revenue bonds used for construction financing are paid off. It is anticipated that the bonds will be repaid within 30 years. State law requires that the tolls be removed once the bonds are repaid. 01/31/91(TCA9018%INDEXF-G) F/T - 6 0 4-18-6 Contrary to the observation, congestion is increasing in its temporal duration each day. Table 1.33 indicates a few of the areas where level of service F is occurring. Level of service F is becoming so prevalent in our area that Cal - trans has developed new designations such as F1, F2, etc., where the subscript designates the number of hours the facility operates in a failed condition. Given this decay in level of service today, it can be accurately predicted that the non -rush hours will rapidly decrease in the future and make the Corridor even more inviting. To decrease individual costs for Corridor use travelers may wish to carpool. Those who simply must drive as a solo occupant and feel they can't afford the tolls will realize some relief in congestion of the existing parallel (free) routes as other traffic is drawn to the Corridor which will be operating at level of service C or D. 4-21-40 The commentator may wish to assist the TCA in initiating legislation or ballot initiatives which support rail. The project proposed is at the threshold of economic feasibility and use of the tolls for other projects (albeit that they have a great long-range 'merit) needs support from the local interest groups. Regarding implementation of rail transit, please see Response to Comment 4-5-2 under Alternatives. 4-24-18 See Responses to Comments 3-4-69 and 4-5-1 in this Chapter. Please see Exhibit 1 of this Response to Comments document, which is the finan- cial plan prepared for the SJHTC. With respect to the loss of open space land, it should be noted that the Corridor was planned in a cooperative manner with regional land use planning efforts for south Orange County, which set aside certain areas for development while setting aside important natural resource areas for open space preservation. The Corridor was considered part of the built environment equation and, although the corridor will traverse areas where land is currently undeveloped, it will not result in the conversion of any lands previously planned for open space to a development scenario. 4-33-28 See Response to Comment 3-6-84 in this chapter. 0 01/31/91(TCA9018%INDEXF-G) F/T - 7 0 The Financial Study necessarily assumes a worst case scenario in the length of time to retire the bonds and traffic used to pay tolls (low volumes). These assumptions have been erroneously combined by the commentator to conclude that the Corridor is not needed. The traffic congestion experienced today was actually forecast in the 1974 SEOCCS study and that kind of reality check confirms the cited table. 4-33-71, 7-36-1. 7-84-3. 7-84-23, 7-86-40 Exhibit 1 to this Response to Comments document is the financing plan for the San Joaquin Hills Transportation Corridor. Given the cyclical nature of the real estate market, the TCA had previously anticipated a slowdown in building permits and therefore development related revenue. The housing slowdown has been anticipated within the financing plan. The DEIR/DEIS is not intended to mislead either the ers. The short term slowdowns have occurred since and this slowdown will be considered by the decisi this disclosure, the history of this Corridor can t temporary slowdowns in development such as those in do not ultimately change the need for the Corridor. 4-33-79 public or the decision mak- the documents circulation, in makers. Notwithstanding reviewed to show that the the 1980-81 and those today The toll revenue projection analysis considered all costs of vehicle ownership. 4-34-6. 4-34-7 The author's experience on the Philadelphia to Atlantic City toll road is so noted. The greatest assurance that can be provided that toll roads will be used is that the banking industry will not loan money to a toll road which will not generate revenue. The studies conducted by TCA and the banking industry illustrate a strong demand for the toll road. Only one percent of all toll road projects have ever failed, and this failure simply resulted in an exten- sion on the period of bond repayment, not complete financial failure. Further- more, application of the Philadelphia -Atlantic City example is not an appro- priate comparison given the unique characteristics of south Orange County (urban pattern, poor level of service on parallel freeways and arterials). Please refer to Responses to Comments 4-4-3 and 4-7-10 in this Chapter regard- ing potential use of tax monies. 01/31/91(TCA9016%INDEXF-G) F/T - 8 1�1 Please refer to Response to Comment 7-141-2 under Purpose and Need regarding traffic demand in the off peak. Please refer to Response to Comment 3-4-69 and 4-5-1 regarding toll feasibi- lity. Please refer to Response to Comment 4-18-6 in this Chapter regarding the lega- lity of collecting tolls. 6-20-1 The comment compares a 24 hour count to a peak hour count. The two counts are not directly comparable and consequently the comment is unclear. Avery Parkway runs roughly east -west and consequently "...traffic levels east of Avery....." is also unclear. The comment will be interpreted to express concern on in- creased traffic. Your concern regarding increased traffic is noted. 7-13-2 The peak period use of the Corridor has been demonstrated by studies to provide economic viability for the tollway. The toll phase of the project is, in fact, an interim measure and ultimately the tollway, as required by law, will become a freeway and its ability to draw traffic will not be limited by tolls. 7-24-10 The commentator's business currently suffers from indirect access. If Option #2 is selected the TCA will construct a new arterial highway connection to Camino Capistrano (at Via Escolar). This connection makes access more indirect by approximately 3000 feet. The TCA will also help develop a new northerly connection of Camino Capistrano to Cabot Road see Response to Comment 3-4-14. This northerly connection combined with the southerly Via Escolar connection would provide better access than that which exists today. 7-25-4. 7-84-34, 7-84-39, 7-119-4 Please see Exhibit 1, San Joaquin Hills Transportation Corridor Financing Plan. The Legislation passed by the State of California allowing the construction of the toll road requires that, upon retirement of the bonds used to pay for pro- ject construction, the facility convert to free use. Just as you have provided examples of toll roads where this has not occurred, the following are examples where tolls have been removed: The Connecticut Turnpike, Merritt Parkway (Connecticut), Charter Oak Bridge (Connecticut), Bissell Bridge (Connecticut), • 01/31/91(TCA901B%1NDEXF-G) F/T-9 Putman Bridge (Connecticut), Denver/Boulder Turnpike, Western Kentucky Parkway, Butler Expressway (Jacksonville, Florida), Mathews Bridge (Jacksonville), Warren Bridge (Jacksonville), Hart Bridge (Jacksonville), and Trout River Bridge (Jacksonville). 7-25-6 The TCA is a government agency, a joint powers authority, which does not make a profit. 7-29-3 Please refer to Response to Comment 3-4-14 under Fiscal Impacts. 7-37-2 Tolls on the corridor will be pro -rated to the length of travel on the Cor- ridor. 7-37-3 As higher gasoline taxes and operating costs evolve; they will affect all other facilities as well as the Corridor, leaving the tolls (an interim fee) as the difference between travel routes. Also, see Responses to Comments 3-4-69 and 4-5-1 in this chapter. 7-37-5 In essence TCA's goal is to plan, design, construct, and operate three tollways (SJHTC, ETC, and FTC) that will become freeways when the construction bonds are retired. The government code establishing the TCA is specific, available for public inspection and does contain the postulated secret agenda. Measure M monies are designated to help improve the MPAH and will not be used for the Corridors. The toll facilities and MPAH are the combined solution to traffic problems. See Response to Comment 3-5-1 under Growth Inducement. 7-46-2 The San Joaquin Hills Transportation Corridor as a toll road is required to parallel "free" facilities thereby providing drivers an option of using a "free" facility if so desired. 01/31/91(TCA9018%INDEXF-G) F/T-10 • 7-57-2. 7-84-24, 7-84-25, 7-84-26, 7-84-28, 7-86-41, 7-86-42, 7-111-1 Please see Exhibit 1 (San Joaquin Hills Transportation Corridor Agency Financ- ing Plan) to this Response to Comments document. 7-84-27 Please refer to Response to Comment 7-13-2 under Fiscal Impacts. The financial plan for the SJHTC project considers toll collections during both peak and off peak hours. Regarding Measure M, please refer to Response to Comment 7-56-1 under Purpose and Need. 7-86-4 The TCA will implement all mitigation measures identified in the Final EIR/EIS. The TCA has adopted an aggressive mitigation monitoring program which imple- ments the intent of AB 3180. Mitigation costs have been built into the project • cost estimates. Please see Exhibit 1 (San Joaquin Hills Transportation Corri- dor Agency Financing Plan) for information relative to project financing. 7-86-5 Landowners cannot be reassessed for additional project cost. However, future developer fees can be increased and tolls raised if necessary. It should be noted that neither financing method, developer fees or tolls can be raised to a point which reduces revenue since that would be contrary to the purpose of fee collection. Current development fees are based on cost estimates for the Corridor. Devel- oper fees are annually adjusted based on the California Department of Transpor- tation (Caltrans) Construction Cost Index. The latest adjustment was effective on December 14, 1989. Once a project decision is made based on the alterna- tives and environmental documentation contained in the Draft EIR/EIS, the development fees will be updated and adjusted as necessary to reflect the cost of the selected Corridor project. The costs associated with mitigation are fully reflected in the specific miti- gation construction item or in the contingency items, and the entire project costs are used to assess developer fees. 01/31/91(TCA901B%1NDEXF-G) F/T-11 Depending on the toll collections technology selected the error rate for toll collections will range between two and five percent. The financial plan for the SJHTC has used very conservative contingency factors to account for these errors. 7-86-7 See Response to Comment 3-1-1 under Project Description. 7-86-36 See Response to Comment 7-86-5 in this Chapter. There is an adequate margin of error built into toll projections to account for cost overruns and unknown mitigation costs. 7-86-37 • The specific details of law enforcement have not been finalized; however, the current plan is that on opening day the California Highway Patrol will provide law enforcement for policing the Corridor traffic and TCA will provide employ- ees to operate toll facilities. 7-86-39 Toll amounts are not tied to development approvals but are a function of the amount of traffic on the Corridor. 7-86-43 The actual cost of mitigation measures will, in part, depend upon the results of consultation and coordination with the state Department of Fish and Game, U.S. Fish and Wildlife Service, U.S. Army corps of Engineers, Environmental Protection Agency, Federal Highway Administration, Caltrans and others. The cost of the most salient mitigation measures has preliminary estimates total- ling approximately $15.9 million. The cost of providing mitigation is included in specific items of construction work that involves a particular type of mitigation. For example, the cost of soil erosion control is accounted for in the cost for landscaping, the unit cost for grading, and the cost for slope protection (the latter cost being 01/31/91(TCA901B%INDEXF-G) F/T-12 0 approximately $21,000 per acre, as an example). Where specific mitigation items are not shown, the costs are understood to be included in the contingency cost for the project. It is customary in engineering estimates to report costs on the basis of construction contract bid items (for example, a specified cost per cubic yard for excavation or another cost per linear foot of freeway lane), and consequently costs are not broken out and subtotaled as mitigation costs. More directly, in response to the line of questions, it is important to under- stand that the project is funded as a whole. Developer fees, State and Federal funds, and toll revenues will be integrated into one source to fund all of the facilities and mitigation measures because these features are constructed under one contract, rather than several contracts differentiated by the funding source. The cost of mitigation measures will be part of the cost of the overall pro- ject. Funding for the project is anticipated to come from development fees, toll road revenues, Federal toll road demonstration project funds and State funds. Funds for mitigation come from the exact same mixture of funds as the rest of the project. In general, approximately 48 percent of the mitigation measures would be paid for by developer fees, while the rest would come from State, Federal or toll road sources. Developer fees will be collected from the following jurisdictions, which make up the Area of Benefit for the Corridor: Costa Mesa Newport Beach Dana Point San Clemente Irvine San Juan Capistrano Laguna Niguel Santa Ana Mission Viejo Unincorporated Orange County The Corridor's Area of Benefit is divided into two zones. Zone A is closest to the Corridor and consequently has developer fees greater than Zone B. Zone B, conversely, is further away from the Corridor and developer fees are less than Zone A. New development in both zones must pay developer fees in accordance with the following SJHTC Fee Program. 0 01/31/91(TCA9018%1NDEXF-G) F/T-13 0 SJHTC FEE PROGRAM Single Family Multifamily Zone Residential Residential Non -Residential A $2,023/Unit $1,178/Unit $2.71/Sq.ft. B $2,566/Unit $ 914/Unit $2.01/Sq.ft. The fee amounts are subject to revision each year to adjust for cost increases due to inflation and other factors. The commentator is referred to Exhibit #1 San Joaquin Hill Transportation Corridor Financing Plan. 7-118-6 For a discussion of people's willingness to pay tolls, see Response to Comment 4-5-1 in this chapter. For a discussion of other alternatives, see the Alter- natives chapter. 7-123-4. 8-29-3 The TCA has no plans to discourage carpooling. In fact, charging a toll will encourage people to carpool and split the cost of using the Corridor. Trans- portation projects must be designed to provide an adequate level of service during the peak hours of travel (the longer the period of peak demand, the more this rule becomes true). Since rush hour in Orange County now lasts from early morning till late at night during the week and frequently from 10 a.m. till early evening on weekends, a transportation system that is only adequate for off-peak hours is not adequate at all. 8-4-2 EIR 494 for the SJHTC published in 1988 was never certified because it failed to address the Corridor as a toll facility. Consequently, TCA EIR/EIS 1 was written to address potential impacts associated with imposing tolls on the Corridor. The EIR/EIS states that toll road traffic volumes are expected to be similar in magnitude to volumes anticipated for a toll free condition. This is a logical assumption because there are few parallel routes between north and south Orange County. Traffic volumes on a toll facility are projected to be 80 percent to 90 percent of volumes projected for a toll free condition. The toll condition is expected to result in minor shifts from the Corridor to PCH, the I-5 and the I-405 freeways with minor impacts to arterials. 01/31/91(TCA901B%INDEXF-G) F/T-14 0 0 The EIR/EIS fully addresses the impacts associated with toll and toll free conditions on the SJHTC. For further information regarding toll/toll free conditions and associated impacts, see section 5.0 ("Traffic and Circulation") of the EIR/EIS. Additionally, Volume II of the technical studies which provide support for assumptions in the EIR/EIS; contains toll and toll free Traffic Projections Study (Technical Report TM-2-67A). Further, Figure 5.3 on page 5- 11 of the EIR/EIS shows screenline comparisons of toll/toll free traffic vol- umes for the SJHTC, freeways and arterials. 8-19-6 Refer to the Response to Comment 8-7-6 under Alternatives. 01 /31 /91(TCA9018%1 NDEXF-G) F/T-15 0 GEOTECHNICAL 2-8-2. 2-8-3. 2-8-4. 2-8-5. 2-8-6. 2-8-8. 2-8-9. 2-8-10, 2-8-48, 2-8-13, 2-8-15 In the evolution of the San Joaquin Hills Transportation Corridor, a number of independent geotechnical studies have been employed to determine the feasibili- ty of the project and the resultant public welfare and safety. The TCA has used these studies in several ways, but most important, has assured that geo- technical firms are not biased by previous work; rather, each study has focused in greater depth on the conditions found by the previous work. More specific- ally, four levels of geotechnical investigations have been completed to date. In 1982, the firm of Leighton and Associates performed a Preliminary Geotech- nical Feasibility Study of the project from approximately Laguna Canyon Road to MacArthur Boulevard. The results of this study were 'that the project was geotechnically feasible, although some areas required greater than average geotechnical mitigation (and commensurate costs). During the early 198Os, grading related to approved developments occurred along the southerly reach of the Corridor alignment. CEQA clearance for that grading is discussed in Response to Comment 4-17-18 under Construction. Each unit of grading in this area was reported on separately by licensed professional engi- neers, and the reports were reviewed by the Orange County EMA and found to be adequate in addressing both the potential for a future corridor and public welfare and safety with respect to the adjacent development. In 1988, the TCA retained the services of Geofon to provide a reconnaissance geotechnical study on the entire length of the Corridor. This study included thorough research of all geotechnical studies performed in the area, including those done for developers and those done by others such as Caltrans and the California Division of Mines and Geology. Geofon's work, which included a sig- nificant field investigation program, thorough laboratory testing and analysis, was concluded in September, 1989, with the following fundamental conclusion: "that the development of the Corridor Alignment as planned is feasible from a geotechnical viewpoint." In parallel with the Geofon work, the TCA also retained the services of Geo Tech Imagery Inc. to provide low level, oblique photography of the area. The purpose of this work was to determine whether the geotechnical conditions on the Corridor warranted more "global" rather than site specific solutions. These geotechnical photographs were given to Geofon to be further reviewed and considered as part of their reconnaissance study. (The photographs are on file 01/31/91(TCA9018%INDEXF-G) G - 1 at the TCA, if further review is required). This photography and the Geofon study did not reveal that the Corridor's construction possessed any noteworthy problems to the surrounding landform. To date, the TCA has no evidence that the Corridor project will adversely affect adjacent property. The Geotechnical Constraints Map was developed from the results of geologic and geotechnical field investigations, laboratory testing and geologic and engi- neering studies; the purpose of the map was to provide.a general visual presen- tation of constraints to highway construction in the Corridor. Ongoing geotechnical investigations and studies have focused on issues such as cut and fill slopes stability (gross and superficial); identifying stabiliz- ing/removing existing landslides; identifying foundation conditions susceptible to liquefaction and measures required to stabilize such areas; soft foundation soils and measures required to improve the foundation conditions; and locating depths of natural groundwater and developing construction techniques having minimal impacts on groundwater. Geotechnical engineering considers the existing ground conditions in and adja- cent to the Corridor and the impacts of highway construction in these areas. The objective of the studies is to provide stable foundation conditions for embankments and structures which will result in no damage to areas adjacent to or downstream of the Corridor. To achieve this end, the studies recognize the importance and interdependence on disciplines such as geology and hydrology. The interactive nature of geotechnical constraints is acknowledged. The pre- ceding text described the process undertaken to evaluate geotechnical impacts of the Corridor project. Based on the studies conducted for the Corridor, the TCA does not agree that "some relevant constraints may not have been included in the area of study." The key issue brought up in these comments is the potential for damage or alteration to areas outside the project study area. The "extent to which project activities... will alter... characteristics outside the project area" is addressed as follows: in accordance with applicable codes, the Corridor will provide all remedial actions necessary to ensure that geotechnical problems such as slope instability, mudflows, etc. are not caused by or exacerbated by the Corridor. Nevertheless, it should be noted that, based on the geotechnical studies, the Corridor will not impact geotechnical aspects of surrounding properties. 01/31/91(TCA901B%INDEXF-G) G - 2 0 0 Regarding non -fluvial erosional process (comment 2-8-6), competent geotechnical studies have not revealed evidence of the postulated problem. 2-8-7 Additional, larger -scale maps are provided in the Technical Studies distributed with the EIR/EIS (Technical Study No. 1, Geotechnical Study, Geofon, Inc., 1989). Larger scale maps are also available for review at the TCA. 2-8-11 Major streams are listed on page 3-7 of the DEIR/DEIS and depicted on Figure 3.3.1. 2-8-12 Stabilizing and strengthening compressive foundation soils with surcharges and relief wells have minimal impact on the areas immediately adjacent to the site. As the compressible foundation soil is being loaded, "excess pre -pressures in the soil resulting from these additional loads is created. The excess pre - pressures need to be relieved to allow the soil to develop additional strength through consolidation. Excess pre -pressures are relieved through mecha.nisms such as relief wells, sand drains/wick drains. 2-8-14 Based on information presented in the three volume geotechnical report prepared by Geofon; there is no evidence of retriggering of landslides or abnormal past construction seismic sensitivity. 3-5-17. 3-6-50 The TCA has shown the grading on 1"-200' scaled plans at each of its map show- ings and at the public hearing and these plans are available at the TCA for review. The grading information is summarized in the DEIR/DEIS of Tables 2.2.0 and 2.2.D. Although the size of the Corridor project is too great to include a full set of Figures at the scale suggested, impacts from proposed cut and fill operations are discussed in Sections 4.4 (Landform), 4.15 (Visual Resources) and 4.17 (Construction) of the DEIR/EIS. 0 01/31/91(TCA9018%INDEXF-G) G - 3 3-6-59 Design level geotechnical studies have continued in this area and the results of these studies along with the bridges proposed in the area combine well to avoid significant problems. It is not anticipated that extraordinary engineer- ing, construction, or cost will impacts result from the existing geology. 3-7-42. 4-24-9 The DEIS/DEIS includes mitigation measures providing for grading and revegetat- ion to approximate natural forms. See Mitigation Measures 14-1, 15-10, through 15-23, and Exhibit 2 - Aesthetic Design Guidelines. The DEIR/EIS describes the potential effects of Corridor construction, including geotechnical stabiliza- tion changes. Measures to mitigate the visual impacts are described in Section 4.15 of the DEIR/EIS. 4-10-4. 7-56-13, 7-56-16, 7-56-52, 7-56-53 No structure can be guaranteed to be 100 percent earthquake proof; but the TCA is designing to the highest standards of the profession and has further imple- mented additional design features to provide greater structural- durability. In general, civil engineering projects are designed to withstand one of the following seismic standards: 1. Maximum Probable Earthquake Which is the largest earthquake to occur in a causative area in a speci- fied interval of time (for example, 200-year period). XV 2. Maximum Credible Earthquake Which is the largest earthquake which can occur in a causative area without regard to time. Of the two criteria the latter is more "stringent": The San Joaquin Hills Transportation Corridor is considered to be a lifeline facility and consequently is designed to the highest standards in the profes- sion (specifically: a Maximum Credible Earthquake). In the specific case of the SJHTC, the following faults could cause shaking on the project: 1. New- 01/31/91(TCA901B%1 NDEXF-G) G - 4 • 11 port/Inglewood fault; 2. Whittier/Elsinore fault; 3. San Jacinto fault; 4. Sierra Madre fault; 5. San Andreas fault; 6. Coronado Banks fault. Of these possible sources, the most critical due to proximity and magnitude is the Newport/Inglewood. (Other faults may yield larger earthquakes; however, their distance from the project attenuates the shaking.) The Newport/Inglewood fault is capable of a Richter Magnitude 7 earthquake. Corridor structures bridging wildlife movement corridors will be designed to the same seismic safety standards as the rest of the facility. No significant effects on wildlife are anticipated as a result of earthquake effects on the Corridor. In limited areas of the Corridor, there may be liquefaction; two of those areas are along E1 Toro Road and Laguna Canyon Road (see Figure 3.2.2). In these areas, mitigation against liquefaction damage to structures can be obtained through the use of piling. All bridge structures crossing Laguna Canyon Road and E1 Toro road (including ramps) will include suitable piling systems. Liquefaction damage to the Corridor embankments can be mitigated through con- struction methods consisting of in -site densification, grouting, vibratory compaction of unconsolidated alluvium and/or removal of unsuitable soils. The TCA is committed to employing design features for both the structure and em- bankments which protect the Corridor to lifeline standards. (See Mitigation Measure 2-1 in the DEIR/EIS.) The Corridor has been thoroughly investigated to ensure that it does not lie with Alquist-Priolo zones (zones that are known to be especially active). This research has shown that the Corridor does not cross or lie in an Alquist-Priolo zone. A potential for soil liquefaction is not tantamount to collapse due to the availability of design techniques to mitigate these potential problems. Over and above the TCA's lifeline standards for the Corridor which include design for the Maximum Credible Event, the TCA has developed an additional seismic design standard which achieves additional durability and performance from structures under smaller (than Maximum Credible Events) earthquake loads. This additional criteria is described in TCA/CDMG Design Memorandum No. 6, "Seismic Design Criteria for Corridor Bridges." 4-29-4 Based on the Corridor vated material would soils of uniform grain 01/31/91(TCA9016%1NDEXF-G) Geological Studies, be suitable for use size are excavated, G-5 it is considered unlikely that exca- as beach sand. In the event that their first use would be as roadbed material, with additional, unused material available for beach sand uses. Also, please refer to Response to Comment 3-5-69 under Water Resources (re: beach sand replenishment). See Response to Comment 4-10-4 in this Chapter. 7-86-15 The TCA has determined what measures are applicable to this project appropriate to the current level of design. The design procedures referenced in the miti- gation are construction/design specifics based on the final design. It is not anticipated that any additional impacts will occur from these final design measures, as they will simply implement the standards established in the EIR/EIS. 7-86-16 The agency responsible during a geologic failure would depend on the cir- cumstances and the point in time when the failure occurs. Generally, during construction of the Corridor, the TCA would be responsible for repair of failures. After the facility is opened to traffic, it is contemplated that Caltrans will assume responsibility for the facility. 7-86-22 Please see Responses to Comment 4-17-18 under Construction Impacts. For com- ments from federal agencies, please see the letter from the Department of Interior and EPA (response groups 1-1 and 1-2); for comments from State re- source agencies, see Coastal Commission letter (response group 2-8). 7-86-32 See Response to Comment 6-17-39 under Construction Impacts. There are no structures in the immediate area. 01/31/91(TCA9018%INDEXF-G) G - 6 0 0 GROWTH INDUCEMENT These comments express concern that the Corridor would induce growth, including the possibility of new growth, above and beyond or inconsistent with approved Local Coastal Plans. As discussed in the EIR/EIS in Chapter 6, Growth Inducing Impacts, approval and construction of the Corridor is not expected to signifi- cantly influence growth in the Area of Benefit over the 20 year period, 1990- 2010. All of the central and south Orange County coastal zone, from Newport Beach to San Clemente, is included within the Area of Benefit. Thus, the land use categories analyzed on page 6-9 of the EIR/EIS include the entire coastal zone area which would be affected by the Corridor. As shown on page 6-9, there are no unplanned land uses within the area analyzed, and only 1.5 percent of the area is not committed through some type of vesting. The 1.5 percent not committed is shown on General Plans for a specific use, but is not a vested use. The comments also state that there is insufficient information or analysis to support the conclusion that the Corridor will not be growth' inducing. The TCA has appropriately relied on the following information to support their conclu- sions: categorization of land uses provided by the cities and the County (in- cluding existing vested uses), existing dwelling units, adopted County and SCAG socioeconomic forecasts, regional plans including the County's General Plan and Growth Management Plan and SCAG's Regional Mobility Plan, jobs/housing balance policies, published information analyzing the relationship of transportation improvements and land use, and consideration of other factors (independent of transportation facilities) which affect growth rates in California. The County of Orange projects that development/growth in south Orange County will occur in much the same manner with or without the Corridor. Based on the analysis conducted for the EIR/EIS and review of the County's plans and forecasts, the TCA supports the County's conclusion and does not find evidence to contradict any of the County's findings in this regard. Comment 2-8-54 states that there is insufficient evidence that growth would be limited to planned growth. There is no available evidence to indicate to the TCA that growth outside of planned growth would occur. As discussed in Chapter 6 of the EIR/EIS, a variety of factors influence growth. The combination of those factors, the County and SCAG's Growth Management Plans, the County's 01/31/91(TCA901B%INDEXF-G) GI-1 0 Development Monitoring Plan and the environmental and public review process required for any land use decision making body to allow further growth, support the TCA's conclusions. Regarding the likelihood that developers will seek additional development or that existing developed areas will redevelop at more intense levels, the TCA believes, for the reasons described above, that it would be speculative to assume that an intensification of development would occur between now and the horizon planning year of 2010. Comment 4-22-4 states that the illustrations misrepresent the toll road's impacts because of the failure to reflect any development along the Corridor through the Greenbelt. Where a Development Agreement, Offer of Dedication or other mechanism is currently in place providing for permanent open space, the EIR/EIS and exhibits presented at the public hearing appropriately represent such open space. As shown in the EIR/EIS, a substantial portion of the "Green- belt" area has been set aside as open space, and no development is expected to occur in those areas. Comment 4-22-12 states that open space will be lost with the "inevitable pro- gression of growth" around the Corridor right-of-way. The planned open space referred to on page 6-9 is considered permanent open space by virtue of devel- opment agreement, offer of dedication or other mechanisms. Conversion of such permanent open space is constrained by State law. Comment 7-56-8 asks about the increase of crime. There is no correlation between the crime rate and the Corridor. Comment 7-84-17 asks about mitigation measures for growth inducing impacts. Based on the conclusions of the EIR/EIS as summarized above, no such mitigation measures are required. Furthermore, given the EIR/EIS conclusion that con- struction of the Corridor will not have a significant growth inducing effect, the Corridor will not have secondary or indirect environmental effects (e.g. on biology, wetlands or air quality) related to induced growth. Regarding percentages of driver use (existing and new), the EIR/EIS includes 1995 and 2010 traffic projections. 1-2-5. 1-1-27 The DEIR/EIS does discuss whether the currently planned demand for that level of growth is independent of this project. This issue is inherent in the con- 01/31/91(TCA901B%INDEXF-G) GI-2 0 • clusion in the EIR/EIS that development/growth in south Orange County will occur in much the same manner with or without the Corridor. The TCA and the County do not agree that "the planned development occurring in the area is a result of this project." The County and Regional plans are premised on a balance between land use and circulation. It is acknowledged that the future Corridor has influenced existing development. However, to imply that the future existence of the Corridor is the reason the area is developed as it is today is to ignore regional plans and policies and the numerous other factors, such as demand, which affect growth in Southern Cali- fornia. Furthermore, as discussed in the Air Quality Chapter of this Response to Comments, transportation system capacity is not the fundamental determinant of demand. Concomitantly, since growth would be a likely outcome of demand, transportation system capacity is not the fundamental determinant of growth. Regarding market demand effects of the Corridor, the only apparent market demand effect would be synonymous with any growth inducing effect. As outlined in the DEIR/EIS, the conclusion of the EIR/EIS is that development/growth is south Orange County will occur in much the same manner with or without the Corridor. The EIR/EIS does not state conclusively that "improved transit access increases the demand for development." The EIR/EIS simply acknowledges that provision of light rail transit in the future (beyond 2010) _could increase pressure for intensification/redevelopment of areas adjacent to the Corridor. This was based on the densities needed to support transit. The provision of future transit is expected to occur after the time period for which a reasonable prediction on growth inducing effects can be made. Further- more, the EIR/EIS does not provide environmental clearance for a future transit system. This is appropriate, given the fact that rail transit is not a cur- rently proposed project and thus no specific system or engineering is available to assess in an environmental document. 1-2-28 None of the "committed" developments is conditioned on the Corridor being in place. One development, Aliso Viejo, would need to implement other arterial improvements if the Corridor is not built. Of the 32,965 acres of committed land, approximately 25,000 acres are committed to open space. The proportions of the 42 percent that are planned for residential and commercial/industrial use can be seen by the tables in Appendix E. 0 01/31/91(TCA9018%INDEXF-G) GI-3 Contrary to the comment, it is not necessary for the EIR/EIS to assess all potential environmental impacts associated with the planned growth. The summa- ries in Appendix E are adequate. The potential environmental impacts of the planned growth are appropriately addressed in regional planning documents, General Plans and individual environmental documents. With regard to foresee- able growth that is as yet unplanned, no such quantifiable growth is expected as a result of the Corridor. However, the traffic model assumed that there would be increased growth in certain portions of Orange County (primarily those areas served by the Foothill Corridor southern section and the Eastern Trans- portation Corridor) beyond the growth currently allowable under the General Plans. This addresses any cumulative growth inducing effects of all three Corridors. 1-2-29 Contrary to the comment, the Area of Benefit (AOB) for the San Joaquin Corridor is independent of the AOB for the Foothill and Eastern Transportation Corri- dors. The traffic studies conducted to support the Corridor Fee Program docu- ment that a very small percentage of the trips on the Corridor originate out- side of the AOB, but within the County. The TCA has separate Boards of Dir- ectors for the San Joaquin and Eastern/Foothill Corridors, and the finances for the projects cannot be intermingled. There is no AOB for the freeways listed in the comment. Additional quantification of the cumulative impacts of the Foothill and Eastern Transportation Corridors has been added to Response to Comment 3-5-31 under Cumulative Impacts. 2-8-53, 2-8-55, 4-31-18, 7-144-3. 8-22-3 These comments question the conclusion that new highways do not induce growth. The TCA's conclusions are based on two factors: 1) the evidence supplied by the County and SCAG adopted plans and existing conditions/land uses/land use com- mitments and 2) published information regarding the relationship of transporta- tion improvements to land use. For further information on the first factor, refer to Response to Comment 1-1-15 in this Chapter. The DEIR/EIS cites two studies which support the conclusion that transportation improvements in and of themselves do not correlate to population increases. The TCA acknowledges that this is a topic which may be subject to professional disagreement. However, in the absence of consensus within the planning field or conclusive empirical studies, the TCA has relied on the best available information. 01/31/91(TCA9018%1NDEXF-G) GI-4 0 0 Comment 2-8-55 also brings up the issue of induced growth which has already occurred, even if it has not been constructed. Such growth is not an issue that can be further addressed in this EIR/EIS. As discussed extensively throughout the EIR/EIS, the County undertook a thorough analysis process prior to adopting the Corridor as part of the Master Plan of Arterial Highways. This analysis included consideration of various ultimate population levels for the South County. Any growth that has already been induced by the future expecta- tion of the Corridor has been considered, analyzed and approved by the appro- priate elected officials based on environmental documents and regional planning documents such as General Plans, the SCAG Regional Mobility Plan and Growth Management Plan and adopted socioeconomic forecasts. 2-8-56 This comment states that the growth inducing effects of future transit on the Corridor should be analyzed now, in the DEIR/EIS. On page 6-11, the EIR/EIS acknowledges that implementation of future light rail transit in the median, after the year 2010, could increase pressure for intensification/redevelopment of areas adjacent to the Corridor. However, the TCA does not agree that growth inducing effects of future transit can be addressed at this time for the rea- sons described below. The majority of regional planning documents, including those which form the basis of much of the. EIR/EIS analysis, such as the County's traffic modeling, are based on a certain horizon year which represents the length of time for which forecasts can appropriately be made. The planning horizon for the Corri- dor project is 2010, a period of time 20 years from the present. It would be speculative to forecast potential growth inducing effects of transit beyond the year 2010. Furthermore, as discussed on page 2-32 of the EIR/EIS (Mass Transit Alternatives), the Regional Mobility Plan determined that development of rail systems on corridors would be incremental, with upgrading to a higher capacity as demand develops. Thus, neither regional planning studies nor other factors affecting transit feasibility, such as densities and urban layout, provide an indication of future transit being feasible before the year 2010. In conclusion, the provision of future transit is expected to occur after the time period for which a reasonable prediction on growth inducing effects can be made. Furthermore, the EIR/EIS does not provide environmental clearance for a future transit system. This is appropriate, given the fact that rail transit is not a currently proposed project and thus no specific system or engineering is available to assess in an environmental, document. Note that the Regional Mobility Plan calls for High Occupancy Vehicle facilities along the Corridor, but does not include rail transit. The Corridor includes HOV facilities. 01/31/91(TCA9018%INDEXF-G) GI-5 9 2-8-57 The comment questions whether growth inducement in north San Diego County would be planned or unplanned growth. Based on regional planning documents which will direct future growth in San Diego County, the TCA assumes that any Corri- dor related induced growth in north San Diego County will be planned growth which may occur at a different rate or pattern than if the Corridor were not built. 3-5-1 The conclusion of the Growth Inducing Impacts chapter of the EIR/EIS is that development/growth in south Orange County will occur in much the same manner with or without the Corridor. Contrary to the comment, no Corridor related growth inducing impacts will occur in south Orange County, and thus air pollu- tion will not be exacerbated. Regarding SCAQMD comments, see Response to Comment 1-2-30 under Air Quality. 3-5-105 The suggested measure is outside the authority of the TCA to implement; how- ever, it is not considered necessary for the reasons described below. The Corridor will provide an incentive to reduce trips through the HOV and car pool features. Other traffic reduction measures are being required through the Growth Management Plan requirement that was a part of Measure M passed by Orange County voters and through Regulation XV, AQMD, which requires an in- crease in ridership to 1.5 persons per vehicle. These regulations have strict requirements for traffic reduction which go beyond any trip reduction that could be implemented by the TCA. 3-5-106, 3-5-107 The suggested measures are not within the authority of the TCA to implement. The Corridor is designed and sized to accommodate traffic generated by existing and planned growth in south Orange County. All regional plans, including the General Plans, the Master Plan of Arterial Highways and the County and SCAG Growth Management Plans, provide a balance between development and circulation improvements. In addition, the regulations described in Response to Comment 3- 5-105 in this Chapter demonstrate the significant planning and control mecha- nisms which have been adopted. Thus, the suggested mitigation measures are not required to offset significant effects of the Corridor. 01/31/91(TCA9018%1NOEXF-G) GI-6 • 3-6-55 The calculations of land uses on page 6-9 of the EIR/EIS do not include the City of Mission Viejo. However, based upon the City's General Plan and a review of existing development, the conclusions of Chapter 6, Growth Inducement Impacts, would not change substantially if Mission Viejo were included. The second part of the comment has been addressed in Response to Comment 3-6-26 under Cumulative Impacts. 3-8-93 The requested study is provided on page 6-9 of the EIR/EIS. Based on compila- tion of data from the County and cities within the Area *of Benefit, acreages were determined for the various land use categories. This information and the discussion on page 6-11 provide the basis for the conclusion that the area of benefit will not be affected by construction of the Corridor. 3-8-94 It is acknowledged in the EIR/EIS that the decision making process for land use approvals was influenced by the planned Corridor. This is'appropriate, given the balance of land use and transportation facilities that were planned by the County with their adoption of SEOCCS. Subsequent development approvals have been subject to environmental analysis requirements to prove that capacity existed or would be provided in conjunction with a project to serve individual projects. With regard to the comment that the EIR/EIS does not adequately discuss devel- opment impacts that would occur without construction of the Corridor, the TCA does not believe that the referenced impacts would occur. As stated on page 6- 11, the County of Orange projects that development/growth in south Orange County will occur in much the same manner with or without the Corridor. Thus, no separate development impacts would occur without the Corridor. It should be noted however, that the No Build or No Project alternative, in which the Corri- dor would not be built, would have a number of other impacts- which are described throughout the environmental topic sections of the EIR/EIS. 4-5-3 Refer to Responses to Comments 1-1-15 under Biological Resources and 2-8-53 in this Chapter. 01/31/91(TCA9018%INDEXF-G) GI-7 4-21-13, 4-33-3. 4-33-4 The Corridor in and of itself will not facilitate people living greater dis- tances from their work places. The Corridor will assist in providing jobs/housing balance within the County through facilitating movement within the County. The Corridor is assumed in SCAG's Regional Mobility Plan, which is an important link in their strategy to achieve jobs/housing balance. Outside of Orange County, the EIR/EIS acknowledges on page 6-12 that the Corri- dor may be a factor in inducing growth in north San Diego County by providing improved access to employment centers in Orange County. However, San Diego County has its own jobs/housing balance goals and policies to address this issue. The EIR/EIS also points out that the Corridor is only one of many factors which would affect growth in north San Diego County. The comment refers to the impact of facilitating low density sprawl type devel- opment. Based on adopted regional plans, including the General Plan, County and SCAG Growth Management Plans and the Regional Mobility Plan, the Corridor will not facilitate low density sprawl type development. The Corridor is an integral component of the Regional Mobility Plan which has been developed in coordination with the Regional Growth Management Plan and the Regional Air Quality Management Plan. Also see Response to Comment 4-31-7 under Purpose and Need. 4-33-81 The inclusion of the Corridor in the Growth Management Plan is not overstated. The Corridor is identified as one of the necessary transportation system im- provements. 4-33-82 Please refer to Response to Comment 3-5-51 under Cumulative Impacts. 4-33-83 The statement that development of committed land uses is not contingent on construction of the Corridor is reconfirmed by the County of Orange. Also see Response to Comment 4-33-20 under Alternatives. However, in the case of Aliso Viejo, they may exceed 10,000 dwelling units by providing alternative arterial improvements. 0 0 01/31/91(TCA901B%INDEXF-G) GI-8 • 0 6-17-21 All three corridors are key facilities in providing greater mobility in Orange County and are shown on the RMP. Also see Response to Comment 4-10-7 under Alternatives. 6-17-22 The information provided in the comment is hereby incorporated into the Final EIR/EIS. 7-40-1 Roads do not generate traffic. Traffic is generated by trip destination at- tractions such as employment centers. For information regarding the need for and purpose of the SJHTC project please refer to Section 1.0 of the EIR/EIS. For information on the issue of "induced demand," see Response to Comment 3-5- 47a-g under Traffic. • 01/31/91(TCA9018%INDEXP-G) GI-9 C: HAZARDOUS WASTE/MATERIALS 2-2-1 Page 3-61 identifies the Coyote Canyon Sanitary landfill as being within the project area. This was meant to be "within the project study area," and not meant to imply that the landfill was within the actual Corridor right-of-way. Page 4-113 states, "The proposed corridor alignment avoids The Coyote Canyon Landfill." If there are any changes to the project which would impact the landfill, CIWMB will be notified immediately. 2-2-2 This comment does not apply, since the Corridor project will not impact the landfill. 3-8-76 The information requested by the comment is provided in Mitigation Measures 12-2 through 12-4. 6-13-11 The comment provides the following information which is hereby incorporated into the final EIR/EIS; regarding the last sentence in second paragraph of Item 2 on page 3-58: in October, 1990, the OCHCA confirmed completion of remedial actions, regarding contamination, at this site. 6-15-22 The DEIR/EIS identified hazardous waste problems related to.the project. See mitigation measures described on pages 4-113 through 4-115 of the DEIR/EIS. 7-47-1 The TCA is committed to ensuring that pollutants do not enter the water table by virtue of mitigation monitoring programs. In addition, Mitigation Measure 3-9 has been revised to address pollutant runoff with additional detail. Please see Response to Comment 2-3-2 under Water Resources. The TCA is committed to a program of maintenance which will monitor both the problems of possible contaminants and obstruction in our drainage facilities 01/31/91(TCA901B%INDEXH-0) HW - 1 (see Mitigation Measures 3-2 through 3-8 on page 4-31 of the DEIR/DEIS). Once the Corridor construction is complete, maintenance will be the responsibility of Caltrans and you may contact them if you see problems occurring; during con- struction of the Corridor, please feel free to contact the TCA Corridor Manager at 714/557-3298 and report any problems. 0 • 01/31/91(TCA9018%INDEXH-0) HW - 2 0 0 HOUSINGIBUSINESS RELOCATION 3-4-18 With implementation of Alternative 2, the TCA will coordinate business reloca- tion activities with the City of Laguna Niguel. In.addition, please see Res- ponse to Comment 3-4-16 under Fiscal Impacts. 3-4-59 Please see Response to Comment 3-4-9 under Fiscal Impacts. 3-4-61 The TCA will coordinate a meeting with Caltrans, and the City to research other sites. Caltrans' primary interests are the size and reasonable access from the property to the Corridor and I-5 freeway. The City's recent incorporation and knowledge of future land use designations will greatly assist the TCA in re- 16 additional sites. 3-4-62 Please see Responses to Comments 3-4-8, 3-4-19 and 3-4-38 under Fiscal Impacts. 3-4-63 Please see Responses to Comments 3-4-8, 3-4-19 and 3-4-38 under Fiscal Impacts. In addition, it should be noted that the confluence area currently suffers from an existing, inadequate local circulation system. Implementation of Corridor improvements will improve an existing situation. 3-6-45 Section 3.8 is a summary of the the vicinity of the Corridor. understanding of where potential DEIR/EIS discusses the magnitude Alternative. 3-6-48 types of housing and business developments in This discussion provides the reader with an displacements could occur. Section 4.9 of the of displacements associated with each Build With respect to items 38 and- 39, see Response to Comments 3-4-15 and 3-4-81 under Fiscal Impacts. The checklist does not need to be changed for item 40 0 01/31/91(TCA901B%INDEXH-0) H B - 1 because all impacts to regional trail linkages can be mitigated to below a level of significance. Please see Mitigation Measure 13-1 in the DEIR/EIS. 3-7-34, 3-7-35, 3-7-36 See Response to Comment 4-25-1 under Project Description. On January 5, 1991, more detailed plans depicting the project were sent to the City if additional questions remain TCA will arrange a meeting with the City's staff to explain the project. 6-2-1. 6-2-2 The TCA will coordinate with the AT&SF Railway regarding the possible impacts of the additional trackage on our project. The process outlined in AT&SF Railways letter are familiar to the TCA and we are committed to complying with them. 6-3-2 Please refer to Response to Comment 3-4-14 under Fiscal Impacts. 6-7-5 Representatives from the TCA would be pleased to attend any coordination meet- ings with area property owners. On December 12, 1990 TCA representatives met with area property owners to begin discussions regarding project impacts and available alternatives. the TCA will continue these coordination activities. 6-8-1 Please see Response to Comment 3-4-27 under Project Description. Sections 3.8 and 4.9 of the DEIR/EIS discuss housing and business relocation. 6-8-5 Your concerns regarding the project are so noted. 6-10-1 Your concerns regarding the unique nature of your business are noted, and will be considered by the decision makers when they make an alignment choice. The TCA has commissioned a study of land use opportunities available with the 01/31/91(TCA9018%INDEXH-0) HB- 2 0 El implementation of Option #2. This study known as the I-5 Land Use Study will be available for public review in mid -January. This study may identify reloca- tion opportunities available to In-N-Out near your current location. 6-11-1 Alignment Option #1 would require the relocation of six businesses. Option #2 would require, in a worst case scenario, the relocation of sixteen businesses including the Shell station at 28662 Camino Capistrano. Appendix I of the DEIR/EIS provides a complete listing of the housing and business displacement with each option. Your support of the option which requires the relocation of the fewest busines- ses (Option #1) is noted. 6-14-8 Please see Response to Comment 3-4-8 under Fiscal Impacts. 6-14-9 The impact of relocating businesses in other portions of Laguna Niguel does not need to be addressed in this DEIR/EIS because prior to obtaining entitlements for commercial opportunities all environmental clearances and land use implica- tions would be or have been considered and analyzed by the City of Laguna Niguel (or County of Orange, prior to incorporation) as the appropriate lead agency with land use authority. 6-15-5 Section 4-9 of the DEIR/EIS discusses the impacts associated with housing and business relocation. Appendix I contains a chart which lists all properties which will be dislocated with either Option #1 or #2. Page 5 of this chart (See Item 14) lists Allen Cadillac/Oldsmobile as a full take under Option #2. There is no impact to the property in question with Option #1. The loss of employment is not significant in a regional perspective. Relocation assistance will help off -set the employment loss if the business relocates in the imme- diate area and does not close. 6-15-6. 6-15-66 Loss of employment can be balanced through relocation assistance. The TCA is committed to helping businesses relocate in the immediate area. Furthermore, 0 01/31/91(TCA9018%INDEXH-0) H B- 3 • the TCA has commissioned a separate I-5 Land Use Study which will outline relocation opportunities available with the implementation of Option #2. If Option #2 is pursued there will be development opportunities available with the abandonment of the Option #1 right-of-way. Pages 4-102 and 103 of the DEIR/EIS provide statistics which illustrate that the south Orange County currently contains substantial vacant office and indus- trial square footage available for business relocation. In addition, please see Response to Comment 3-4-8 under Fiscal Impacts. 6-15-7 Your comment regarding the total loss of employment within the City of Laguna Niguel is noted. However, if you assume that Allen Oldsmobile/Cadillac, Sepul- veda Building Supply and Costco relocate in south Orange County, then employ- ment opportunities would be maintained in the south Orange County sub -region, but perhaps outside the corporate limits of the City of Laguna Niguel. 6-15-10, 6-15-13, 6-15-14, 6-15-15. 6-15-16 is As discussed in Section 4.9, Housing and Business Relocation, of the Draft EIR/EIS, business relocation will be conducted by the TCA in accordance with the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, as amended (the "Uniform Act"). The Uniform Act defines the scope of public agency responsibility for business relocation associated with public acquisition of real property. Further, as described in Mitigation Measure 9-3 of the Draft EIR/EIS, a relocation program, consistent with Caltrans' reloca- tion policies, will be prepared prior to acquisition of real property. In the event that appropriate relocation cannot be conducted, the relocation program will provide for in lieu payments or other appropriate benefits. There are several options available to help businesses relocate and construct new facilities prior to closing of existing businesses. The most common ap- proach is for the property in question to be purchased earlier than necessary with the existing buildings leased back to the business for continued operation until the new facility is completed. The TCA is interested in pursuing all relocation options available to provide for a smooth transition if Option #2 is pursued. However, the project schedule and the lead time associated with the construction of a new facility for your business will make a smooth transition very difficult. Due to the location of Allen Oldsmobile/Cadillac (adjacent to I-5 and immedi- ately within the confluence area) and the schedule associated with Option #2, 01/31/91(TCA9018%INDEXH-0) H B - 4 0 • it appears that, given your unique relocation requirements, the opportunity to relocate your business and not be closed longer than seven days is not achiev- able. This fact regarding the operation of your business is brought out in detail in the I-5 Land Use Study. 6-15-11 The I-5 Land Use Study will identify two probable relocation sites for the Allen Oldsmobile/Cadillac dealership. One site is immediately west of your current location and the other immediately to the south at Avery and Camino Capistrano. Neither site is within 10 miles of the Irvine Auto Center and both are in close proximity to your existing location. The I-5 Land Use Study will be available for public review in mid -January. 6-15-12 The sites to the west and south are both similar in that they are flat parcels, have freeway visibility and arterial access necessary for successful business operations. Please see Response to Comment 6-15-10 in this Chapter. 6-15-26 Please see Response to Comment 3-4-14 under Fiscal Impacts. 6-15-36 Direct taking of private property is discussed in Section 4.9, Housing and Business Relocation, of the Draft EIR/EIS. Indirect effects on property adja- cent to the Corridor are discussed throughout the Draft EIR/EIS in the relevant impact sections. As discussed in the Draft EIR/EIS, potentially significant impacts to residences and businesses have been substantially mitigated, and no indirect take of private property is expected to occur. 6-15-42 Your comment that the wording should be changed on page 4-102 of the DEIR/EIS to reflect the fact that South End businesses will be relocated outside of the immediate area is noted. It should be identified that the existing wording begins by stating that "Because a majority" will relocate in the immediate area provides that wording since it infers that some businesses (the minority) may choose not to relocate in the immediate area. In addition, please see Response to Comment 6-15-6 in this Chapter. 0 01/31/91(TCA9016%IHDEXH-0) H B - 5 C 6-15-43 The $785,000.00 is an estimate of the cost associated with assisting and coor- dinating for business relocation; the purchase of property is part of the right-of-way purchase estimate. 6-15-44 The commercial relocation requirements are accurately stated for each alterna- tive. Note the number of properties (i.e., 6 for ,Conventional and 16 for Demand Management) properties and not the aerial business properties requiring relocation. See Table on page 4-102 of the DEIR/EIS. The term "accurate" is hereby revised to "quantitative." An assessment of relocation opportunities is provided; it was, however, not possible to provide quantitative square foot vacancy rates. 6-15-45 40 The statement "such commercial sites are virtually non-existent," refers to commercial sites directly adjacent to the freeway which provide freeway adver- tising opportunities. However, commercial space which could accommodate the businesses such as strip malls, mini malls, and business parks do exist in Laguna Niguel, Mission Viejo and San Juan Capistrano. The location of these types of properties (strip malls, mini malls, auto malls and business parks) are dispersed throughout Laguna Niguel, Mission Viejo, and San Juan Capistrano. The statement does not indicate that each city has all of these types of prop- erties available for relocation of the displaced businesses. 6-15-60 See Response to Comment 6-15-53 under CEQA/NEPA Issues. 6-15-65 There are not any contradictions in the document regarding this issue. Em- ployment loss should be evaluated considering relocation opportunities, the regional perspective of this project, and employment opportunities created by the project. With respect to tax revenue loss please see Response to Comment 3-4-8 under Fiscal Impacts. 01/31/91(TCA901B%INDEXN-0) HB-6 0 • 6-15-67 The maps contained in the DEIR/EIS are adequate to portray information relative to environmental consequences of the project. Maps reflecting engineering details are available at the TCA, 345 Clinton Street, Costa Mesa, CA 92626. 6-16-1 The TCA respectively disagrees that the review period for the DEIR/EIS needs to be extended based on the following outline of the public notice procedures pursued with this project. NOTIFICATION OF SJHTC DEIR/EIS I. A. Notices of Availability Notices of Availability (NOAs) were mailed between September 14th and 17th, 1990, to 4687 people and agencies. The mailing list included property- owners along the Corridor (within 300 feet of the APE and in many cases, beyond), and extensive list of Homeowners Associations, people with interest or involvement. Additionally, NOAs were mailed out by certified mail with the EIRs that were distributed for public review. B. Newspaper Ads Published - Newspaper ads were published advertising the NOA in the following newspapers: - The Orange County Section of the L.A. Times on September 14, 1990. - The Orange County Register on September 15, 1990. - The Orange Coast Daily Pilot on September 24, 1990. - The Irvine World News on September 27, 1990. - The Laguna News Post on September 27, 1990. - The Saddleback Valley News on September 26, 1990. - The Laguna Niguel News on September 27, 1990. 0 01/31/91(TCA9018%INDEXH-0) H B - 7 C7 II. A. Revised Notices of Availability Revised NOAs for the purpose of changing the date of the Public Hear- ing at Laguna Hills High School from October 29, 1990, to November 14, 1990, were mailed to the original mailing list of 4,687 people and agencies. The revised NOAs were mailed out on October 26, 1990. Those who received an EIR during the September 14th - 17th mail out received their revised NOAs by certified mail. Additionally, the revised NOA served to extend the public review period for the DEIR/ EIS from November 15, 1990 to November 26, 1990. Revised NOAs were published in the following newspapers: The Orange County section of the L.A. Times on October 26, 1990. The Orange County Register on October 26, 1990. The Orange Coast Daily Pilot on October 26, 1990. - The Irvine World News on October 25, 1990 The Laguna News Post on October 25, 1990. The Saddleback Valley News on October 26, 1990. The Laguna Niguel News on October 25, 1990. The Capistrano Valley News on October 25, 1990. III. Public Map Showings. - Public Map Showings were held as follows: - University High School on October 10, 1990. Notification was part of the September 14th - 17th NOA mailed and published in the newspapers. - Laguna Beach High School on October 17, 1990, Notification was part of the September 14th - 17th NOA mailed and published in the newspa- pers. - Capistrano Valley High School on October 24, 1990. Notification was not part of the September 14th - 17th or the revised October 26th NOAs. Flyers advertising the event were mailed, on October 20, 1990, 01/31/91(TCA901B%INDEXH-0) H B - 8 , 10 0 to addresses on our NOA mailing list with the following zip codes: 92692, 26290, 22675, 92693, 92677, 92656 and 92653. A revised NOA advertising the event was published in the Saddleback Valley News on October 19, 1990. Based on the extensive notification efforts outlined above and the fact that CEQA and other relevant legal noticing procedures do not require public notic- ing by mail, it is the opinion of the TCA that we have gone above and beyond all requirements for public noticing of the SJHTC project and the related DEIR/EIS. In addition, please see Responses to Comments 3-4-14 under Fiscal Impacts regarding economic effects of the project and 2-8-4 under Cumulative Impacts. 6-16-10 The TCA has commissioned a separate planning study known as the I-5 Land Use Study. The purpose of this study is to identify development opportunities with the implementation of Alignment #2. This study will be distributed to the public in mid -January and will be presented to the decision makers as part of their consideration of the project alternatives. 6-17-38 The requested correction is noted and incorporated into the Final EIR/EIS. 6-18-2 The DEIR/EIS contains Chapters on Noise (3.5 and 4.5) Visual Resources (3.13 and 4.15), Land Use (3.7 and 4.8) and Construction Activities (4.17). 7-24-11 TCA will follow Caltrans procedures for right-of-way acquisition. TCA will provide, as appropriate, relocation assistance and business good will compensa- tion for businesses that are displaced. Please refer to the Response to Com- ment 7-24-5 under Fiscal Impacts for additional information. 7-24-12 We assume the comment author is referring the loss of direct access to busines- ses along Camino Capistrano. Please refer to Response to Comment 3-4-14 under Fiscal Impacts. 0 01/31/91(TCA901B%INDEXH-0) HB-9 7-28-3 Please see Responses to Comments 3-4-8 under Fiscal Impacts and 3-6-48 in this Chapter. 7-28-4 Please see Response to Comment 3-4-8 under Fiscal Impacts. 7-28-5 Your opinion regarding the significance of the impacts related to the local tax base are noted. 7-29-11 Please see Responses to Comments 6-11-1 in this Chapter and 6-13-4 under Fiscal Impacts. 7-29-13 The P&D Technologies Study was commissioned by TCA for the purpose of evaluat- ing potential land uses for right-of-way that would be left vacant in the event that Alignment Alternative #2 was selected and implemented. The study was never intended to be used to determine the superiority of either of the align- ment alternatives. Please see Response to Comment 6-13-13 under CEQA/NEPA Issues regarding additional response. 7-60-7. 7-85-4 The TCA will only be purchasing those residences which are within the Corridor right-of-way. There is only one residence which would require acquisition with the Demand Management Alternative (AP #637-542-22). Minor modifications to the Demand Management Alternative may be able to avoid this acquisition. The land use planning in south Orange County occurred with the knowledge of the future alignment of the Corridor. The development of the Corridor will improve re- gional and local mobility, which is a quality of life issue. Visual and noise impacts will be mitigated by the construction of sound walls and extensive landscaping. These mitigation measures are designed to address quality of life issues associated with visual resources and ambient noise levels. 01/31/91(TCA9018%INDEXH-0) H B- 1 0 0 C 7-60-8 The Response to Comments document provides a response to each of the seven questions raised in your letter of comment. Please see the appropriate re- sponse category. 7-108-2 All businesses that would be relocated under the Demand Management Alternatives with the Alternative #2 connection at I-5 are located in the vicinity of the I- 5 confluence. The I-5 confluence area is characteristically very different from the area of the proposed Corridor alignment adjacent to UCI and therefore these areas cannot be effectively compared. EIR 267 contained an alignment study which is helpful in understanding the logic behind the presently proposed Corridor alignment. Basically, the align- ment cannot be shifted northerly in the vicinity of UCI for the following reasons: The corridor cannot be constructed on top of the old County landfill (Coyote Canyon) in the vicinity of MacArthur Boulevard, San Diego Creek and University Drive. If this option were pursued, there would be the potential for uncovering hazardous waste and -polluting downstream waters. The Corridor cannot displace or be constructed on top of MacArthur Boule- vard. - The location of the Ecological 'Preserve at UCI and rare plants and animals. - The presence of archaeological sites which may be eligible for placement on the National Register of Historic Places. 8-12-3 Please see Responses to Comments 3-4-8 under Fiscal Impacts and Response to Comment 6-11-1 in this Chapter regarding business relocations associated with Alignment; Alternative No. 2. Regarding access to business remaining on Camino Capistrano under Alternative No. 2, please see Response to Comment 3-4-14 under Fiscal Impacts. so01/31/91(TCA9016%INDEXN-0) HB-11 0 8-30-2 TCA will follow Caltrans' policies for acquiring other than dedicated right-of- way. A copy of the Caltrans right-of-way acquisition procedures is attached for your information (see Exhibit 3). 8-35-2a The comment is not related to the San Joaquin Hills Transportation Corridor. However, our response is as follows: There appears to be confusion on the part of the commentator regarding the agency responsible for the potential I-5 widening project in the vicinity of Ms. Charnesky's residence. Any widening of the I-5 which may occur adjacent to Ms. Charnesky's residence would be conduc- ted by Caltrans (San Diego office). Further, the I-5 widening Ms Charnesky is referring to is not related to the Foothill Transportation Corridor. Caltrans is not a part of the TCA. However, Caltrans will be overseeing the design of the Corridor for the purpose of ensuring that the final project will be acceptable to them for operation and eventual ownership. Caltrans will take ownership of the SJHTC upon retirement of the 30-year bonds used to finance construction of the Corridor. 8-35-2b. 8-35-2d Caltrans will oversee the design of the entire SJHTC project including the I-5 connection. Refer to the Response to Comment 8-35-2a in this Chapter for fur- ther information regarding Caltrans role in the SJHTC project. 8-35-2c The meeting with the City of San Clemente was regarding the Foothill Transportation Corridor, and no questions regarding the San Joaquin Hills Transportation Corridor were raised. 8-35-2e It appears that the roles of TCA and Caltrans as they were stated at the sub- ject meeting with the City of San Clemente have been misunderstood. Please see Response to Comment 8-35-2a in this Chapter. 01/31/91(TCA901B%INDEXH-0) H B - 12 0 8-35-2f Yes, Caltrans is involved in an oversight role. The; member of the TCA agency making a decision on the conni they will oversee the design, whatever choice the TCj previous questions on I-5 or 405, the freeway system Caltrans, and TCA's projects do not make improvements other than what is disclosed in the EIR/EIS. And, improvements to I-5 would be approximately from Avery Ortega Highway, as disclosed in the EIR/EIS. 0 0 01/31/91(TCA9018%INDEXH-0) H B- 1 3 are not involved as a ction to I-5. However, makes. Regarding any 3elongs specifically to m the I-5 or the I-405 more specifically, any Parkway south to about LAND USE 2-7-12 Section 4.8 of the Draft EIR/EIS discusses the proposed project's relationship to the Coastal Zone at this location. As discussed in this Section, this portion of the Coastal Zone is governed by policies contained in the cities of Newport Beach and Irvine Local Coastal Programs (LCPs). Impacts to the Bonita Canyon Creek channel are discussed in Sections 4.3 and 4.7. It should be noted that the impacted portions of the Bonita Canyon Creek lie outside of the Coastal Zone boundary. Also, please refer to Response to Comment 2-8-45 in this Chapter for further information regarding the proposed projects consistency with the City of New- port Beach LCP. 2-8-44 The proposed project does not intersect the Coastal Zone within the City of Laguna Beach. Therefore, a determination of project consistency with the City's LCP is not necessary. Additionally, according to the City of Laguna Beach (telephone conversation, Tamara Campbell, 12-11-90), the City's Local Coastal Program (LCP) is inte- grated into their comprehensive General Plan; LCP policies and objectives are not differentiated within the City's General Plan. Therefore, an LCP consis- tency determination would coincide with the determination made relative to the City's entire General Plan. Section 4.8 of the Draft EIR/EIS, as well as Response to Comment 3-5-138 in this Chapter, discusses proposed project consis- tency with the City of Laguna Beach General Plan. 2-8-45 The City of Newport Beach Local Coastal Program (LCP) contains 15 policies to protect environmentally sensitive habitat areas and unique coastal resources (i.e., wetlands). The City's LCP designates the following types of habitats as environmentally sensitive: Areas supporting species that are rare, endangered, of limited dis- tribution, or otherwise sensitive; Riparian areas; 0 01/31/91(TCA9018%INDEXH-0) L - 1 • • Freshwater marshes; • Saltwater marshes; • Intertidal areas; • Other wetlands; and • Unique or unusually diverse vegetative communities. Of the above habitat types, the proposed Corridor (i.n the Bonita Creek area) would impact the following: riparian areas, freshwater marshes, other wet- lands, and unique or unusually diverse vegetative communities (i.e., coastal sage scrub habitats. However, Sensitive Habitat Protection Policy number A-3 states that the habitat protection policies "are not intended to prevent public agencies and private property owners from maintaining drainage courses and facilities, sedimentation basins, public infrastructure, and other related facilities in a safe and effective condition with minimal impact on the environment nor are they intend- ed to prohibit public infrastructure when the environmental process demon- strates that adverse impacts can be mitigated, or that the benefits outweigh the adverse impacts." As stated in Sections 4.7 and 4.8 of the Draft EIR/EIS, wetland impacts in this area have been mitigated to a level below significance, consistent with the City's LCP habitat protection policy number B-6.a, which states that impacts to wetlands require minimum mitigation (i.e., submission of a detailed restoration plan). Please refer to Responses to Comments 3-5-97 under Biological Resources for a discussion of coastal sage scrub mitigation and 3-5-109 under Biological Resources for a description of the proposed wetland mitigation plan. Therefore due to the provision of mitigation for Coastal Zone Impacts, the proposed pro- ject is consistent with the City's LCP. 2-8-46 As depicted in Figure 3.7.1 of the Draft EIR/EIS, no portion of the prime farmland impacted by the proposed project lies within the Coastal Zone Bound- ary. 01/31/91(TCA9018%INDEXH-0) L - 2 0 C 2-11-14 As stated in Section 4.8 of the Draft EIR/EIS, UCI population projections were obtained from the adopted UCI Long Range Development Plan (LRDP) (STA, Inc., 1989). It should be noted that the estimates of students and faculty popula- tions were rounded for presentation purposes. The total UCI population, as stated in the EIR/EIS (i.e., 40,000), is very close to the actual projection contained in the LRDP (i.e., 40,643). 3-5-138 Portions of the City of Laguna Beach General Plan are addressed in Section 4.8 of the Draft EIR/EIS. The conflict between the proposed project and the City's policy viewing additional freeways and highways as unacceptable transportation solutions is acknowledged. Alternatives to the construction of the Transporta- tion Corridor are discussed in Chapter 2 of the Draft EIR/EIS. Each of the policies and goals identified in the Laguna Beach comment is addressed below. In most instances, the Corridor is either compatible with the goals and policies of the Laguna Beach General Plan, or potential inconsis- tencies are mitigated by measures proposed in the Draft EIR/EIS. However, the proposed project remains incompatible with some of the, policies. and goals of the Laguna Beach General Plan. These inconsistencies are unavoidable, partic- ularly in light of the City's position that highways are unacceptable transpor- tation solutions. Water Ouality Policies Implementation of the proposed project will result in short-term adverse im- pacts to wetlands in the Laguna Canyon/El Toro Road area. However, the Draft EIR/EIS contains measures, such as wetland habitat replacement, that will mitigate inconsistencies with these Laguna Beach General Plan policies (see Sections 4.3 and 4.7). In addition, the Corridor has been designed to utilize drought resistant landscaping and has been aligned so as to avoid the environ- mentally sensitive Laguna Lakes area. Therefore, the project includes measures that mitigate the project's inconsistencies with these General Plan policies. Section 4.3 of impacts on the consistent with the Draft EIR/EIS states that off -shore marine environment this General Plan policy. • 01/31/91(TCA9018%INDEXH-0) L - 3 the project will have no adverse and, therefore, the Corridor is Park Policies The proposed project includes measures to mitigate impacts to the Laguna Green- belt (e.g., berms), and permits implementation of the various Trail Master Plans of the County and Laguna Beach through design features such as bridge structures (see Section 4.3 and Appendix A). The Corridor project, therefore, includes sufficient measures to mitigate inconsistencies with this Laguna Beach General Plan Policy. Visual Resource Protection The Draft EIR/EIS contains an extensive aesthetic analysis of the proposed Corridor project (see Section 4.15). In addition, the proposed project has been designed to reduce the project's visual impact on the surrounding environ- ment. Specifically, through measures such as landscaping, slope rounding and contour grading, visual impacts of the Corridor will be reduced. Although an extensive effort has been undertaken to reduce the project visual impacts, implementation of the Corridor project will result in unavoidable adverse impacts in the Laguna Canyon/El Toro Roads area. Therefore, imple- mentation of the proposed project will result in an unmitigable conflict with these Laguna Beach General Plan policies. Vegetation and Wildlife Policies The Draft EIR/EIS includes mitigation to reduce the proposed project's impact on vegetation and wildlife resources; however, the construction and operation of the Corridor will have a significant adverse impact on the regional assem- blage of biotic resources. There are also opportunities for habitat enhance- ment in remaining open space areas. Specifically, the County and other agen- cies have preserved approximately 16,000 acres of open space and wildlife habitat as part of the regional/open space/habitat mitigation program discussed in Section 4.6 of the Draft EIR/EIS. To sum, the proposed project will result in unavoidable adverse impacts to biotic resources and, as such, is an unmitigable conflict with these General Plan policies. Watershed Policies The DEIR contains measures to limit the Corridor's impact on natural drainage channels and includes a runoff management plan to control the volume, velocity and sediment from project runoff (see Section 4.3). In addition, the project 01/31/91(TCA9018%INDEXH-0) L-4 0 0 has been designed in a manner to preclude any significant impacts from the 100- year flood. Erosion and sediment impacts also will be mitigated through sedi- ment controls (e.g. debris basins) and through planting and maintenance of native plant species adjacent to the Corridor. Therefore, the Corridor project will mitigate inconsistencies with the Laguna Beach General Plan Policies by measures proposed in the Draft EIR/EIS. Natural Hazards Policies The proposed project has been designed to avoid flood prone lands and geologi- cally unstable areas or has measures to reduce the project's hydrological/ geological risks to an acceptable level. Therefore, the Corridor is considered to be generally consistent with these General Plan Policies. However, it should be noted that the proposed project traverses an area with potential geological hazards, according to the Laguna Beach Geologic Hazards Map. As such, General Plan Policy 10-E requires that no development be permitted in this area unless a comprehensive geological and soils report is prepared pursu- ant to Title 22 of the City's Municipal Code. Although the proposed project has been designed in accordance with Caltrans standards and has been the sub- ject of a geological feasibility study, a special study in accordance with Title 22 of the City's Municipal Code has not been prepared. , The detailed geotechnical studies that have been completed and further design studies that are underway provide a greater level of analysis than the City's requirement. Air Quality The proposed project is consistent with adopted air quality plans, and is anticipated to result in a positive net effect on air quality by providing roadway capacity improvements that will accommodate local traffic increases without any adverse air quality impact. As such, the proposed project is consistent with these Laguna Beach policies. Archaeology Policies The Draft EIR/EIS contains appropriate measures for the eligible archaeological sites, such as excavation analysis, protective measures, reporting and curation of collections consistent with federal guidelines that will mitigate the pro- ject's impact to cultural resources. The Corridor is, therefore, compatible with this General Plan Policy. 0 01/31/91(TCA901B%INDEXN-0) L - 5 • Ridgeline and Hillside Slope Policies The Draft EIR/EIS identifies that implementation of the proposed project will result in significant adverse effects to topographic features. Mitigation mea- sures to reduce the project's impact on ridgelines and hillside slopes have been included in the Draft EIR/EIS; however, project impacts to topographic features is considered an unmitigable conflict with these Laguna Beach General Plan Policies. 3-6-44 As stated on Figure 3.7.1, illustrated land uses are generalized to reflect major General Plan land use designations. Please note that land use conclu- sions in the Draft EIR/EIS are based upon analyses of detailed land use desig- nations as found in the applicable planning document (i.e., General Plan and LCP). Illustrated land uses were generalized due to the need to balance the extraordinary scope of the proposed project against the need to meet Caltrans and FHWA guidelines. The level of detail presented in Figure 3.7.1 is suffi- cient enough to illustrate the concepts used to make project land use compati- bility/consistency determinations. 3-6-49 It is acknowledged that the City of Mission Viejo adopted its General Plan by resolution number 90-91 on October 8, 1990. However, adoption of the City's General Plan occurred subsequent to circulation of the DEIR/EIS. Therefore, the information provided in the DEIR/EIS represents the most current and accurate information at the time of document preparation. However, the City of Mission Viejo General Plan has been reviewed resulting in the following determinations regarding land use compatibility: The Circulation Element includes the Corridor as a necessary regional transportation facility as referenced in Circulation Policy 2.1. • The adopted land uses in the Corridor vicinity have not changed from the designation depicted in the DEIR/EIS so as to alter the compatibility or consistency determinations contained in the DEIR/EIS. In fact, the City's General Plan allows for an intensification of commercial uses (i.e., Commercial Intensive Overlay Area) adjacent to the Corridor alignment. These types of uses are considered compatible with the proposed project in that "the designation of permitted... uses are intended to achieve compati- bility" among land uses (General Plan Glossary, p. 2). Since the Corridor 01/31/91(TCA9018%INDEXH-0) L - 6 is included in the City's General Plan and because the Land Use Policy Map is intended to represent a mix of compatible land uses, the Corridor is consistent with the adopted City of Mission Viejo General Plan. The above information does not alter the conclusions contained in the DEIR/EIS relating to land use compatibility, and has not been incorporated into the EIR/EIS. 3-7-32 As discussed in Section 4.15 (p. 4-122) and Appendix A (pgs. 4 through 7) of the DEIR/EIS, I-5 improvements associated with the Corridor will not signifi- cantly alter the existing urbanized viewshed experienced from within the City of San Juan Capistrano, and would be compatible with existing and planned land uses. Also, please refer to Response to Comment 4-25-2 regarding visual im- pacts at Camino Capistrano. Table 4.4.B in the DEIR/EIS does not identify any receptors along the I-5 alignment, within the City, that exceed federal or State air quality standards under the 1995 or 2010 build scenarios. Thus, noise effects due to the Corri- dor and associated improvements will not result in land use incompatibility with existing and planned land uses. The information provided above does not alter the conclusions of the DEIR/EIS relating to land use compatibility and has not been incorporated into the EIR/EIS. 3-7-33 Please refer to Response to Comment 4-25-3 under Section 4(f). 4-11-2. 4-32-54 The development of an approximately 12,000 acre greenbelt in the San Joaquin Hills is the result of comprehensive County open space planning beginning in the mid-1970s. As described in Attachment B to Appendix A of the Draft EIR/ EIS, regional open space and transportation needs have been cooperatively planned with extensive open space dedications required in conjunction with development approvals in the south Orange County area. (See Response to Com- ment 2-7-14 under Biological Impacts). 0 01/31/91(TCA9018%INDEXH-0) L - 7 0 4-19-12 The effects of the Corridor on open space areas in the San Joaquin Hills, including Los Trancos Canyon, Crystal Cove State Park and the Laguna Laurel dedication areas, are discussed both in the 4(f) analysis included as Appendix A to the Draft,EIR/EIS and in Chapter 4. The alignment of the Corridor has not been shifted seaward beyond the limits of the alignment defined in the Draft EIR/EIS. 4-21-10 As a result of reducing congestion on the regional transportation network, construction of the Corridor will improve ease of access to John Wayne Airport. However, improved airport access is not expected to increase the use of the airport, which is regulated by the Federal Aviation Administration, based on flight safety factors and the passenger limits set with the recent expansion of the airport. Expanding the facility at John Wayne Airport to allow increased use would require separate environmental analysis. 4-24-4 As stated on pages 6-12 and 6-13 of the DEIR/EIS, population, employment and housing figures are expected to increase in -the Area of Benefit with or without construction of the Corridor. This statement is based on County of Orange and SCAG growth projections. It is true that the three cities mentioned have implemented policies to preserve open space areas, however only the cities of Laguna Beach and San Juan Capistrano have passed bond measures to fund acquisi- tion of proposed preservation areas. The City of Irvine has adopted a General Plan Amendment (GPA-16) that modified the Conservation/Open Space Element to designate certain parts of the City as Preservation Areas. As discussed in Response to Comment 7-84-42 in this Chapter, this latter change in land use designations was included in the set of land use assumptions in the Corridor traffic modeling effort. The reduction in population/housing/employment num- bers due to the Laguna Beach and San Juan Capistrano bond measure will not measurably reduce the growth projected in the Area of Benefit. Regarding adoption of the No Build Alternative, please refer to Response to Comment 8-9-7 under CEQA/NEPA. 4-31-13, 4-31-14 Please refer to Response to Comment 3-8-56 under Biological Resources. 01/31/91(TCA9018%INDEXH-0) L - 8 0 6-16-6 All project grading (both grading widths and volumes) are presented in Chapter 2 of the Draft EIR/EIS. The specific segment requested by the commentator (i.e., between Crown Valley Parkway and Greenfield) is contained within the segment listed in the DEIR as "from Avery Parkway to Moulton Parkway". 6-16-7 As shown on Figure 3.7.1, both existing and planned land uses are illustrated according to the applicable adopted General Plan land use designations. Please note also that jurisdictional boundaries are represented in Figure 3.7.1. Therefore, the Draft EIR/EIS documents planned land uses and recognizes "the existence of General Plans of the jurisdictions it [the Corridor] crosses". 6-17-34 The TCA acknowledges that the comment provides clarification to Table 3.7.1. However, the information provided does not alter the conclusions of the DEIR/ EIS, and Table 3.7.1 has not been modified. 6-17-37 The requested correction is hereby incorporated into the Final EIR/EIS. 7-56-2 The purchase of the Laguna Laurel site reservation of land for the Corridor Comment 3-5-140 under Section 4(f). 7-84-42. 7-108-5 for open space purposes included the right-of-way. (Also see Response to Land use assumptions used in the preparation of the Draft EIR/EIS represent the most current and accurate data available at the time of document preparation. Land use input to the traffic model was provided by OCP-88, the adopted Orange County data. 7-108-6 Please refer to Response to Comment 4-22-19 under Purpose and Need. 0 01/31/91(TCA9018%INDEXH-0) L - 9 8-14-5 Please see Response to Comment 2-7-14 under Biological Resources. 0 0 01/31/91(TCA9018%INDEXH-0) L - 1 0 • U MITIGATION MONITORING 2-2-4. 3-2-12. 4-28-32 TCA is aware of the requirement to adopt a Mitigation Monitoring Plan. The plan will be presented to the TCA Board for consideration in conjunction with certification of the EIR/EIS, and will be adopted, pursuant to AB318O and the mitigation monitoring requirements of the TCA Administrative Code, at the time of project approval. 3-5-125 Regarding public hearings and approval schedule, please refer to Response to Comment 8-7-8 under CEQA/NEPA. 3-5-126 Regarding SIP/FIP approval, please refer to Response to Comment 1-2-6 under Air Quality. • 01/31/91(TCA9018%INDEXH-0) MM - 1 • NOISE 1-2-68, 3-7-30, 3-7-49, 7-124-4. 7-132-2. 7-134-1. 7-134-4 The 2010 predicted traffic noise levels at receptor sites R14 and R15, resi- dences along Spotted Bull Lane, would increase two to four dBA above the exist- ing I-5 traffic noise levels. This is considered a noticeable increase in traffic noise levels. The discussion on page 4-59 of the DEIR/EIS states that noise barriers at sites R14 and R15, along Spotted Bull Lane would be ineffective and are not recom- mended. However, in an effort to provide some type of noise mitigation to these homes, TCA will conduct a study of the feasibility of improving the noise attenuation properties of each of the impacted homes. The feasibility of improving these homes is based on their existing condition. If these homes are fully air conditioned with double glazed window units, gasketed doors and extra thick building insulation, then there would be very little feasibility of improving their noise attenuation properties. If determined feasible, the TCA would offer to implement mitigation of improvements to the noise attenuation properties of the homes. Please refer to Mitigation Measure 5-1 in the DEIR/EIS for R-14 and 15 of Spotted Bull Lane regarding this issue. The EIR/EIS acknowledges, on page 4-61, that if building attenuation improvements are not feasible at sites R14 and R15, there will be a significant adverse noise impact. Regarding sites R14 and R15, the TCA is committed to mitigating for noise im- pacts to the extent possible. Regarding sites R45 and R46, the following information is provided: these sites are a retail center and a six story office building. Upon examination of the buildings (windows, air conditioning, etc.), it was determined that no further building attenuation measures would further mitigate noise. The existing buildings likely provide enough attenua- tion to achieve interior noise standards. (Note: the impact is based on exte- rior standards). Regarding site R47, which is three houses, the following information is provid- ed: these homes are subject to excessive noise levels from the flight path of John Wayne airport. Further, the homes are in a redevelopment area and are likely to be replaced in the future with commercial structures. Therefore, TCA implementation of noise attenuation measures to the homes is not appropriate. 0 01/31/91(TCA9018%INDEXH-0) N - 1 n U 2-5-4. 2-5-5. 2-5-6 Receptor site R42 is located within Crystal Cove State Park, approximately 300 feet from the edge of pavement of the SJHTC roadway. The predicted traffic noise level of 66 dBA at this site is based on traffic volume and speed and vehicle mix, which would result in the maximum noise level. The closest primi- tive camping site to the Corridor, identified as Sycamore Campground in the GDP for the State Park, is approximately 2000 feet south of R42. As distance from the roadway increases, noise levels will decrease at the rate of 5 dBA per doubling of distance, i.e. at 600 feet from the edge of pavement the maximum noise levels would be 61 dBA. Thus the noise levels experienced at this primi- tive camping site will not approach or exceed federal noise abatement threshold criteria. Mitigation at Crystal Cove State Park has not been considered because it would not be consistent with FHWA policy which requires mitigation at locations where human activity would be impacted. Due to the limited access at the location of R42, human activity is not expected to occur. Traffic noise levels at more distant locations from the Corridor where human activity would occur is expected to achieve a maximum noise level of Leq - 50 dBA (see Appendix A of EIR/EIS, 4(f) Resources). 2-11-6 Section 4.5 of the DEIR/EIS analyzed the Corridor's noise impacts at identified sensitive receptors, including Receptor 42D - 2 Locke Court at UCI. This location was the closest developed UCI residential area in the vicinity of the Corridor during preparation of the DEIR/EIS. As shown in Table 4.5.A, this receptor will not experience noise levels which exceed the federal noise abate- ment threshold criteria or City of Irvine standards. Although recommended noise mitigation was not identified in the DEIR/EIS for Receptor 42D, the TCA will coordinate with UCI during final design of the Corridor regarding noise effects on this Receptor. Mitigation for the planned facility and staff hous- ing in the vicinity of the Corridor/Bonita Canyon Road interchange, and the planned Support Commercial, Campus Support Services, and Research and Develop- ment, in the vicinity of the Corridor/Bison Road interchange, is not recom- mended in the EIR/EIS because these facilities will not be initiated in the construct ion timeframe of the Corridor. It is anticipated that a detailed noise analysis will be performed by UCI prior to construction, per Mitigation Measures 153 and 154 of the FEIR for the LRDP, respectively. 01/31/91(TCA9018%INOEXH-0) N - 2 • 3-7-17 Of the 16 sites referred to by the commentator in San Juan Capistrano (Sites R1 through R16), noise mitigation is recommended at all 16 sites. Please see Table 4.5.A and the discussion of mitigation measures on pages 4-50 and 4-51 of the DEIR/EIS. 3-7-21, 7-64-2 The use of noise barriers for exterior land uses and -acoustical treatment for interior land uses have been found, by both FHWA and Caltrans, to be the most reasonable measures to reduce a noise impact where the overall benefits exceed the overall adverse social, economic and environmental effects. There is no demonstrated need for consideration of other measures. 3-7-22 The information requested by the author is provided on page 3-23 of the DEIR/ EIS. The remaining information requested by the commentator, "the predicted noise level, the range of potential measures and the recommended mitigation measure" is listed in the Table. The predicted noise levels are listed for both Leq and CNEL values. The range of recommended noise barrier heights from 8 feet to 16 feet is shown along with the mitigated traffic noise level for each height of noise barrier. The recommended noise barrier is indicated in the Table as a parenthesis around the mitigated noise level which satisfies the Caltrans requirements for mitigation. 3-7-23 In accordance with FHWA Procedures for Abatement of Highway Traffic Noise and Construction Noise, residential land uses are considered exterior land uses. This is based on the presumed use of outdoor areas around the residential property and that mitigating outdoor noise levels is more difficult than indoor levels. The exception to this would be apartments in upper floor building locations where there is no access to outdoor areas. 3-7-24 The Corridor is designed for future year 2010 operation. In accordance with FHWA and Caltrans policy, the traffic noise levels are modeled for the design hour volume or the peak hour volume of the design year of operation, which ever results in the highest noise level. 01/31/91(TCA9018%INDEXH-0) N -3 w 3-7-25. 3-7-26 Table 4.5.A of the DEIR/EIS lists the location, beginning and end station numbers, and height of the recommended noise barriers at each receptor sites; Figure 4.5.1 shows the location of these noise barriers. Please refer to Response to Comment 3-7-44 under Visual Resources regarding agency review of design plans. 3-7-27 The footnote at the bottom of Table 4.5.A, page 4-48 states that the notation EP refers to edge of pavement. 3-7-28 The effects of traffic noise on equestrian trails is discussed in Appendix A, Section 4(f) Evaluation. 3-7-29 The noise receptors were selected to be the closest noise sensitive receptors to the Corridor, representative of all land uses that would be effected by traffic noise from the Corridor. The recommended noise barriers are designed to extend beyond the noise sensitive receptor site, to protect all the noise sensitive land uses near each of these sites. 3-7-31 The change in no build noise levels in Table 4.5.C. is in units of dBA. The change in noise level can be applied to both CNEL and Leq. Table 4.5.0 pro- vides a comparison of the No Build and Build scenarios. 3-8-27 The comparison of OCTAM II and SOCTAM traffic projections considered both the change in traffic volume and the change in traffic speed (level of service). 3-8-28 The reference on page 4-61 of the DEIR/EIS to 3.8 dB as "a barely noticeable change in level" should have been stated as a noticeable change in level. 01/31/91(TCA901B%INDEXH-0) N - 4 0 9 3-8-29, 3-8-30 The noise modeling assumptions are presented in Technical Study No. 4, Noise Technical Report, along with sample traffic noise prediction model input and output files. Traffic noise predictions were based on three vehicle classifi- cations: autos, medium trucks and heavy trucks. The traffic volume for each vehicle classification is listed in the Noise Technical Report, Appendix C, for every link of the Corridor. The analysis provided in Section 4.5 identifies the worst case scenario for noise impacts. As discussed on page 4-4-3 of the DEIR/EIS, noise associated with the construction of the Conventional Alterna- tive is identified as the worst case scenario. The Demand Management would result in noise impacts lower than or equal to the Conventional Alternative. 3-8-32 The noise analysis for the SJHTC did consider Irvine's General Plan land uses because the noise model is based on the traffic model which uses general plan land uses as input. Differences in arterial noise levels with and without the SJHTC are explained by looking at the projected ADTs with and without the project. See Figure 1.3.1 of the DEIR/EIS. Noise levels on Bonita Canyon road would* decrease with the Corridor because the ADTs would be 26,000 vs. 46,000 without the Corridor. More traffic translates to more noise. Noise levels on Sand Canyon Avenue east of the Corridor will remain the same regardless of whether the Corridor is built or not. Projected ADT on Sand Canyon are 11,000 without the Corridor and 12,000 with the Corridor. One thousand cars per day will not produce a perceptible increase in the noise level. 3-8-33 The methodologies used for the Foothill Corridor are the same as those used for the San Joaquin Hills Corridor. Specific modeling assumptions for the noise impact assessment can be found in the Noise Impact Study, Technical Report No. 4. 9 01/31/91(TCA901B,.INDEXH-0) N - 5 1�1 3-8-34 The predicted traffic noise level of 66 dBA, at Crystal Cover Park (Site R42), was modeled at the ROW, at a distance of 500 feet from the centerline of the roadway. As the distance of a listener from the roadway is doubled, the noise level will decrease by 5 dBA. The traffic noise levels at 1,000 feet and 2000 feet from the Corridor centerline would be 61 dBA and 56 dBA, respectively. The effect of noise on wildlife will be lessened at increased distances from the Corridor. To reduce the Corridor's potential visual impacts on Bommer Canyon, a berm will be constructed adjacent to the northbound travel lanes. The berm will also provide a reduction in traffic noise levels to Bommer Canyon, lessening the impact of noise on wildlife. For a discussion of the relationship of the project to the wildlife resources, please refer to Response to Comment 3-8-95 under Section 4(f). 4-12-1 The land use at Moulton Parkway and La Paz that would be affected by the Cor- ridor traffic noise levels is the Laguna Hills Hospital on the northbound side and a parking lot and commercial land uses on the southbound side. The hospi- tal is considered by FHWA criteria as a noise sensitive interior land use. The predicted interior traffic noise levels are determined based on the hospital's exterior building construction, masonry walls with single glazed windows. The predicted interior traffic noise levels would be an Leq = 44 dBA, which does not exceed the FHWA interior noise abatement criteria of Leq = 52 dBA (see DEIR/EIS Table 4.5.B - Interior Land Use Activities). 4-15-3. 4-15-4 The Nellie Gail Ranch Owners Association approval of the recommended 12 foot high noise barrier between Moulton Parkway and Fargo Road is noted. 4-20-3 The traffic predictions indicate a reduction in- travel speed along the grade between Turtle Rock and Spyglass Hill. The predicted carbon monoxide (CO) levels and traffic noise levels both consider the effects of a lower vehicle operating speed on a steep grade. 01/31/91(TCA9018%INDEXN-0) N - 6 is 4-24-6 The Temple Hills neighborhood is located approximately two miles from the Corridor. Predicted traffic noise levels at this location would be 42 dBA, substantially lower than the federal abatement threshold criteria of 67 dBA for residential land uses. There are no violations of the State or federal co - standards outside the Corridor right-of-way, thus the degradation in the air quality would be minor at this location. Due to the distance from the Corridor to this area and intervening topography, there will be no significant visual impacts at this location. 4-32-14. 7-88-55 The study prepared by the San Diego Association of Governments in January, 1990, "Comprehensive Species Management Plan for the Least Bell's Vireo", discusses the effects of noise on small migratory songbirds. The study finds that continuous noise levels above an Leq = 60 dBA within habitat areas may affect the suitability of such areas for use by Bell's vireos for nesting. These findings are based on one noise measurement survey conducted by Caltrans, which found a maximum of 61 dBA at a sample vireo nest. The study does con- clude that further data must be collected to more clearly define the potential noise impacts to the vireo. There are no studies that relate effects on wild- life to traffic noise. The research on noise affects from power lines has been compared to traffic noise, since both. sources of noise are continuous and steady state in nature. The conclusions of most of these studies are wildlife will tend to avoid areas where high noise levels are present. However, over a period of time many mammals become desensitized to the noise and will return to the area of the noise source. 4-32-53 At the crossing of Laguna Canyon Road, the traffic noise levels from the Corri- dor would not exceed the FHWA noise abatement threshold criteria (less than 67 dBA) at a distance of 350 feet or more from the edge of pavement of the road- way. As the distance from the Corridor doubles, the traffic noise levels will be reduced in the range of 4 dBA to 5 dBA. 7-1-4 Noise impacts and mitigation measures are described in Section 4.5 of the EIR/EIS. Noise barriers will be installed as appropriate in Nellie Gail (see pages 4-59 and 4-60 in the EIR/EIS). 0 01/31/91(TCA9018%INDEXH-0) N - 7 0 7-8-2 Please refer to Responses to Comments 7-9-2 in this Chapter and 7-4-1 under Request for Data. Sound barrier locations are typically at the outside right-of-way for the freeway. The exact location depends on specific site conditions, such as topography, soil foundation, etc. The exact location of the sound wall adja- cent to your house will be determined during the final design stage. 7-8-3. 7-8-4 The predicted traffic noise levels along the grade are based on higher vehicle noise emissions for traffic movements along the grade. The noise barriers were designed to mitigate the higher vehicle noise levels. Dense vegetation and trees are not effective noise mitigation measures. However, the plans for the Corridor incorporate a landscaping plan which includes a plant palette which identifies trees and shrubs for aesthetic purposes. 0 7-9-2 27391 Westridge Lane lies at the same elevation as the roadway, at approx- imately 320 feet. The predicted traffic noise levels at this location is an Leq = 69 dBA during the period of 3-4 p.m., the hour of maximum traffic noise level. The existing noise levels would be similar to the monitored noise level at receptor site R28 of 49 dBA. A barrier 12 feet high is recommended at the edge of the pavement of the SJHTC to mitigate traffic noise levels to 63 dBA. Regarding time frame for grading and completion, grading is planned to start in 1991, and completion of the project is expected in 1995 or 1996. 7-10-3 Please refer to Response to Comment 7-10-1 under Visual Impacts. 7-12-4 The predicted traffic noise levels from the Corridor would not be higher than existing background levels in the Turtle Rock area due to the distance of the Corridor from Turtle Rock (3/4 mile) and intervening topography. 01/31/91(TCA901B%INDEXH-0) N - 8 0 7-22-5 The proposed project will build soundwalls adjacent to the Corridor which reduce noise levels to below the federal threshold criteria of 67 dBA. Alicia Parkway is a County road, and is not a part of this project. The project is, therefore, not responsible for mitigation noise from that facility. Such con- cern should be addressed to the County of Orange. 7-28-2. 7-28-12 Receptor site R20 at 28603 Avenida Del Caballo was chosen as a receptor site to represent the house which lies in the closest proximity to the Corridor in Option 1. Option 2, at the time the noise study was completed, was requiring the taking of this residence; therefore, Receptor R20A, the house next door, at 28611 Avenida del Caballo (see errata sheet for address correction) was modeled for comparison purposes. These two receptors, R20 and R20A, are not in the same location. Twenty minute noise measurement samples were taken at each home on April 23, 1990, to assess the existing noise levels. The 1 DBA difference in existing levels is due to the different locations of these receptors relative to Paseo de Colinas, the predominant source of existing traffic noise. Site R20A is approximately 70 feet further away from Paseo de Colinas, then R20. 7-28-13 Sites R22 and R23 have lower readings because of the existing five foot bar- riers built along Bridgeport Plaza property lines which shield I-5 traffic noise. These existing barriers were modelled in the 2010 noise levels predic- tions. Another contributing factor to the lower monitored levels is that site R22 lies 600 feet from Paseo de Colinas, whereas site R20 lies 50 feet from this roadway. 7-28-14 Receptor R17 has a lower reading than R20 primarily because there is no local traffic which contributes to the I-5 traffic noise. R20 lies on the corner of Paseo de Colinas and Avenida del Caballo, and Paseo de Colinas is the primary noise source. A 20 minute measurement sample was taken at the Church building on April 24, 1990, at 2:05 p.m. With the exception of a few cars passing the microphone location at less than 15 mph, traffic movements on I-5 was the only source of noise. I* 01/31/91(TCA9018%INDEXH-0) -N - 9 7-28-15. 7-28-16 Site R17, the Rancho Capistrano Community Church, was chosen as a receptor site because it represents the closest sensitive land use to I-5 in this area. The Church is considered by FHWA as a category E interior land use activity. Based on its building attenuation, the predicted interior traffic noise levels would not exceed the FHWA noise abatement criteria of Leq = 52 dBA. The closest recreational facility at this location is a pond which is at a distance of approximately 670 feet from the edge of pavement of I-5. The traffic noise level at this site was modeled in response to the commentator's concerns, and the resulting 2010 predicted traffic noise level is an Leq = 65 dBA. No miti- gation would be required at this location. 7-28-17 A barrier is recommended at the right-of-way for site R22 because the existing five foot barrier at the property line is ineffective in reducing noise levels below the noise abatement criteria. This barrier would also reduce the future noise levels at site R23, and the levels are reported in the DEIR/EIS Table 4.5.A. The Option 2 alignment lies over 800 feet away from the residences at Bridgeport (R22 and R23), and the predicted noise level at site R22 using Demand Management traffic conditions is 61 dBA. Hence, the residences at Bridgeport would not require mitigation with the Option 2 alignment. Only the Conventional Alternative predicted noise levels are reported because these are the worst case scenario. 7-28-18 Sites R20 and R20A, the residences on the west side of Avenida del Caballo were chosen, as stated above, since they lie in the closest proximity to the Corri- dor. Levels at the east side of Avenida del Caballo were modelled (see attached map for receptor location) in response to this comment, and the pre- dicted Leq is 71 dBA for Option 1 with the Conventional Alternative traffic conditions and 65 dBA for Option 2 with Demand Management traffic conditions. The structural barrier along the SJHTC Option 1 will reduce noise levels by 8 dBA. The 15 houses on the east side of Avenida del Caballo are included as homes impacted (see errata sheet). The Leq of 65 dBA at the home on the east side of Avenida del Caballo demonstrates that Paseo de Colinas is the primary source of traffic noise. 01/31/91(TCA901B%INDEXN-0) N - 1 0 0 0 7-28-19, 7-28-20 The station references for the R2OA barrier was incorrectly listed in Table 6 of the Noise Technical Report No. 4. A four foot and six foot barrier were tested on SJHTC between station 9460 and 9484. No reduction is achieved with this barrier due to the fact that the primary noise source is Paseo de Colinas, and not the projected traffic on the Corridor. This barrier is therefore not recommended. Barriers were tested along I-5 to reduce levels at sites R20, R2OA, R22 and R23 for both Option 1 and Option 2; however, due to the existing terrain (the sites are at an elevation over 40 feet above I-5) and due to the local traffic contributions in the case of Receptor R2O and R2OA, a barrier along I-5 is ineffective. In summary, a six foot barrier is recommended for Option 1 to reduce noise levels below standards (65 dBA) for the residences on Avenida del Caballo; however, a barrier is not recommended on the Corridor in Option 2. 7-28-21 The noise increase at the home on the corner of Paseo de Colinas and Avenida del Caballo is due to the realignment of Paseo de Colinas closer to this home. This realignment is a part of the Corridor improvements under analysis. A bar- rier along Paseo de Colinas would not be a feasible mitigation measure since the barrier could not be continuous, and visibility along intersecting local streets would be affected. 7-28-22 Two separate analyses were conducted for the noise study, a site specific analysis and a contour analysis. The roadway in each analysis was modelled from the base maps provided for the Conventional and the Demand Management Alternatives for both Option 1 and Option 2 at the I-5 connection. The site specific analysis modelled traffic noise levels at the exact position and elevation of the selected receptor sites with respect to I-5, the Corridor and local roadways. Attached are the graphs and output files for Receptors R20 and R2OA. Exhibit 4 is the graphics from the, Stamina Noise Model input parameters which demonstrate that the new design of I-5 at the intersection of Avery Parkway, including the westerly relocation of I-5, was modelled. The predicted noise levels shown in Table 4.5.A of the DEIR/EIS are based on detailed model- ling of both Alignments. The contour analysis represents area where the respective noise are to be used as a preliminar • 01/31/91(TCA901B%INDEXH-0) y N-11 0 were developed based on the traffic volume during the noise peak hour, truck percentage and speeds. The receptor height was assumed to be the same as the roadway elevation, and no shielding was incorporated to model the existing terrain. The contour distances are reported from the centerline of the road- way. Local roads were not modelled in the contour analysis and the contours do not provide a detailed picture of predicted levels at intersections. The error the commentator is referring to in Technical Report No. 4, Noise Impact Study, Table 4 (page 9) is not apparent. Figure 1.3.1 in the DEIR demonstrates that the Average Daily Traffic (ADT) on the SJHTC between Paseo de Colinas and Greenfield Drive is 90,000 vehicles. The ADT on I-5 between Paseo de Colinas and Junipero Serra is 220,000 vehicles. The Contours along I-5 would be further away from the contours on SJHTC since the increased traffic volume creates a noisier condition. 7-28-23 The commentator's understanding of the basic differences in geometry between Option #1 and Option #2 is correct. Please note that Option #2 is proposed only in the event that the Demand Management Alternative is selected. On the other hand, Option #1 may carry either the Demand Management or Conventional Width of the Corridor. Under all options we have rechecked the basic control line for CNEL contours and we find that these are correctly oriented to the appropriate alignment for each option. 7-28-24. 7-28-25, 7-28-26, 7-28-27 Please refer to Responses to Comments 7-28-12, 7-28-13, 7-28-14, 7-28-15, 7-28- 17, 7-28-18, 7-28-19, 7-28-21 and 7-28-22 in this Chapter. 7-41-1 The use of noise barriers to reduce traffic noise impacts is recommended by Caltrans and FHWA to mitigate noise impacts. Noise will be mitigated through both sound barriers and improvements to the sound attenuation properties of home (if determined feasible). 7-44-1 A noise barrier is recommended between La Paz Road and Pacific Park Drive, on the north side of the Corridor, to protect the homes at the Quail Creek Apart- 01/31/91(TCA9018%INDEXH-0) N - 1 2 0 0 ments. On the south side of the Corridor, between La Paz Road and Pacific Park Drive, there are existing commercial uses that would not be impacted by the Corridor. 7-45-4 Section 4.5, Table 4.5.A in the DEIR/EIS, shows the predicted noise levels and land use categories, identifying those receptor sites that exceed the standards and require mitigation. 7-50-2 Please refer to Response to Comment 4-26-2 under Project Description. 7-50-3 Roadway surfacing materials are usually selected to improve highway safety and not to reduce tire noise. However, with regard to the traffic noise along the is grade, most of the increased noise will be from auto and truck engine emissions and not the tire noise. 7-50-3 Marketing claims by manufacturers of low noise asphalt have not been substan- tiated. Asphalt Institute studies show that low noise asphalt reduces noise by less than 1 dba. A difference of three dba is the threshold at which the average person would perceive a change in noise levels. 7-50-4 The Corridor, at the location where it extends over Greenfield Drive, would exceed the federal noise abatement threshold criteria of 67 dBA within 400 feet from the roadway centerline. Beyond 400, feet noise impacts would not occur. Mitigation is .not required at this location because there are no existing residential land uses within 400 feet of the Corridor centerline. 7-50-5. 8-6-3 The DEIR/EIS contains an adequate discussion of noise impacts associated with the Corridor. See Sections 3.5 and 4.5 of the DEIR/EIS and Technical Report No. 4. Air Quality impacts are adequately addressed in Section 3.4 and 4.4. The author does not identify where this analysis is inadequate, therefore this 01/31/91(TCA9018:INDEXH-0) N-13 statement is the opinion of the author and will be taken into consideration by the decision makers. 7-56-40 The DEIR/EIS identifies traffic noise impacts, and provides noise abatement measures to mitigate these impacts. 7-56-41 Noise barriers will be designed to local code and structural standards. The final design and location of the noise barriers will take into consideration reflected noise. 7-60-2. 7-85-1 The predicted 2010 traffic noise levels at the Commentators' home, 25761 and 25781 Arlington Drive, Laguna Niguel, would be 68 dBA during the noisiest hour of the day. Noise receptor site R24, described in Section 4.5 of the DEIR/EIS, was selected as a representative location to evaluate the noise impact to the homes along Arlington Drive. The recommended mitigation measure is to con- struct a noise barrier at the property line of the Laguna Niguel Townhomes subject to approval of the property owners (see page 4-59 of the DEIR/EIS). The noise barrier height would be designed to provide a minimum of five dBA noise reduction to the impacted homes. The construction noise levels would vary depending on construction activity in the range of 67 dBA to 98 dBA at 50 feet, the highest noise level having the shortest duration. The typical construction noise level, over an eight hour period, would be an average of 80 dBA at 50 feet. At the location of the com- mentator's home, the average eight hour construction noise level would be 65 dBA, approximately the same as the existing noise level from traffic movements in this area. 7-88-54 Noise impacts are discussed on pag considered to be significant. Th sounding board is questionable. comment are typically bowl shaped See Response to Comment 4-32-53 in Laguna Canyon Road. This impact was not Canyon is a natural referred to in the structures; Laguna Canyon is not so shaped. this Chapter on the traffic noise levels on 4-42 of the DEIR/EIS. statement that Laguna Amphitheaters such as 0 01/31/91(TCA9018%INDEXH-0) N - 1 4 0 7-89-1 The traffic noise levels from the Corridor would be noticeable in Rim Rock and other Canyons of Laguna Beach depending on the listener's distance from the Corridor and the level of background noise from local traffic movements. However, the Corridor traffic noise will still be substantially lower than the FHWA noise abatement threshold criteria of 67 dBA for residential land uses. 7-89-2 Leisure World is located over 3,000 feet from the Corridor, and would not be affected by traffic noise levels along the Corridor. Traffic movements along Moulton Parkway would remain as the primary source of traffic noise to resi- dents in Leisure World. 7-90-1 The added traffic noise levels from the Corridor will be mitigated by the use of noise barriers to protect residents and other noise sensitive land uses along the Corridor. At two locations on Spotted Bull Lane, noise barriers would not be effective. As outlined in Mitigation Measure 5-1, the TCA.will determine the feasibility of implementing improvements to the noise attenuation properties of the impacted houses. 7-134-4 The predicted traffic noise levels at receptor sites R14 and R15 along Spotted Bull Lane are 72 dBA and 75 dBA, respectively. There is no substantiation of the commentator's remarks that I-5 traffic noise levels along Spotted Bull Lane are 78 dBA during the summertime and 3 dBA to 5 dBA higher during the winter- time. 8-5-3 The intent of the noise barrier between LaPaz Road and Pacific Park Drive, on the north side of the Corridor, is to mitigate the traffic noise impacts to the Quail Creek Apartments. If it is found, during final engineering design, that the noise barrier does not provide the required mitigation, the barrier will be extended over Pacific Park Drive toward Moulton Parkway. • 01/31/91(TCA9018%INDEXH-0) N - 15 NON-EIRZEIS ISSUE Prior to taking an action to approve the Corridor project, the TCA Board of Directors must certify the Final EIR. This certification involves concluding that: 1) the document has been completed in compliance with CEQA, and 2) the Board has reviewed and considered the information within the EIR prior to approving the project. Some comments transmitted to the TCA express an opinion on the project itself or address issues not within the scope of environmental analysis. These com- ments do not address the adequacy of the EIR/EIS, but are considered by the Board as part of their action on the project. This Chapter of the Response to Comments includes comments on the project out- side the scope of environmental analysis. Where this occurs, the response so indicates. 3-5-41. 7-84-1 The Master Plan of Arterial Highways (MPAH) is a consensus document which reflects the best integral program the County and cities can form for overall circulation. Originally conceived in 1954, this plan is updated annually and the cities are the agency which may make the changes. Thus, the plan is not ten years old. The MPAH changes are a direct reaction to City changes in their general plans, and consequently, the MPAH continuously changes to conform with development and growth approved by -the local agencies. 3-5-120 Average vehicle occupancy increases as traffic flows approach roadway capacity. When capacity is reached travel time increases significantly enough to make carpooling attractive. The specific example of this in Orange County is the I-405 freeway. HOV lanes are effective because the peak -hour traffic exceeds capacity and has reached level of service F. Under toll operations additional incentives beyond the traditional time savings will promote HOV usage. These are: 1. The ability of HOV passengers to reduce travel costs by sharing toll fees. 2. The ability of HOV vehicles to subscribe to an AVI collections of tolls. The AVI system would process vehicles without delays at toll ramp or main- line plazas. 01/31/91(TCA9018,.INDEXH-0) N E I -1 9 3-5-121 Section 2.10 of the DEIR/DEIS (page 2-54 to 2-57) discusses related projects. Recently (after the circulation of the DEIR/DEIS) two AB 680 projects were selected by Caltrans for the Orange County area. One of these will construct an 11.2 mile long (privatization) toll road along the Santa Ana River. This project would be an extension of SR-55 from I-5 to I-405. The second project would add four lanes to existing SR-91 from the Riverside County line to SR-55 (a distance of approximately 10 miles). There are privatization projects in San Diego County (near the Mexican border) and in northern California near Vacaville; these are so distant that they are well out of an area that could impact the proposed project. Newspaper articles in the course of 1990 have speculated on a toll road through the mountains to Riverside. No Federal, State or local agency (known to the TCA) has prioritized or authorized the concept of this project. 3-5-128 The Foothill Transportation Corridor and Eastern Transportation Corridor are not the subject of this DEIR/EIS. Information regarding the status of these projects may be obtained at the offices of the TCA. See Responses to Comments 4-21-3 and 4-24-1 under Cumulative Impacts. 3-5-137 It is the understanding of the TCA that none of the General Plans of the County or the cities in the Corridor area have been determined to be inadequate or invalid, or are facing a current legal challenge to their adequacy or validity. The County's Master Plan of Arterial Highways has been updated periodically since its adoption based on changes in land use approvals and projected trans- portation needs. See Response to Comment 3-5-138 under Land Use. 3-6-87, 3-6-88, 3-6-103, 3-6-104 These comments do not apply to TCA EIR/EIS 1 distributed for public review. 3-9-16 TCA will be happy to meet, at the convenience of EMA Harbors, Beaches and Parks, to discuss planning coordination and other matters of concern. 01/31/91(TCA9016% INDEXN-0) N E I - 2 0 r: 4-4-7 The purpose of the EIR/EIS as stipulated by the National Environmental Policy Act and the California Environmental Quality Act is to address potential envi- ronmental impacts of the proposed project such that sufficient information is available for the decision makers. The issue of morality is not a required topic of analysis under CEQA; however, this issue will be considered as part of the decision making process. 4-20-7. 4-20-8 The TCA will cooperate with any plans the City has for arterial improvements to the extent that those improvements depend on the Corridor. The long standing arterial designations of Bonita Canyon Road and Culver Drive make it difficult to defend the position that noise impacts to surrounding development should not have anticipated or are the result of the Corridor. 4-21-41, 4-21-42 It is not appropriate to incorporate these measures into the Corridor EIR/EIS. The measures outlined relate to development projects and would be implemented by local agencies, as required by the AQMP, during their approval of these projects. 4-24-13, 7-64-5. 7-144-4 The County of Orange and other local jurisdictions in the vicinity of the Corridor have realized the need to maintain open space areas and have under- taken a program of preservation within the County. Please refer to Response to Comment 2-7-14 under Biological Resources regarding the County's effort to preserve open space. It is not within the scope of this EIR/EIS to examine the requested correlation. 4-24-14 The author does not identify additional environmental issues to be analyzed in the EIR/EIS or where the existing information is deficient. All required environmental topics are analyzed in the EIR/EIS. 4-31-10 Please refer to Response to Comment 3-5-45 under Alternatives, for discussion of the effects of Measure M on the need for development of the Corridor; Res- 01/31/91(TCA9018%INDEXN-0) N E I - 3 0 ponse to Comment 3-5-140 under Section 4(f), for discussion of the passage of Measure M; and Response to Comment 4-33-71 regarding effects of economic reces- sion. 7-1-7. 7-1-10, 7-124-1 The purpose of the EIR/EIS is to provide the public and the decision makers with environmental information for use in the decision making process. The project cannot be constructed without certification of the EIR/EIS by the TCA Board and FHWA. Substantive comments on the information provided in the EIR/ EIS are addressed in this document. Comments in support of or opposed to the project are provided in this document; however, a response is not required under CEQA or NEPA. 7-3-2 Please refer to Response to Comment 3-5-113 under CEQA/NEPA Issues. 7-53-4. 7-56-4. 7-56-20. 7-56-55 . The role of the public initiative process is not an issue to be discussed under CEQA or the CEQA guidelines. However, the Board of Directors for the San Joaquin Hills Transportation Corridor is comprised of elected officials from each of the member agencies. The Board is aware of the strong sentiments within the community of Laguna Beach regarding construction of the SJHTC. See also Response to Comment 4-17-7 under CEQA/NEPA. 7-56-9 It is outside the scope of this EIR/EIS to determine if this project will result in similar actions being taken in other areas of the United States. 7-56-54 The observation that traffic merely re-routed to other freeways after the San Francisco Earthquake fails to report 1) the congestion on other freeways and 2) the loss of business and other transportation associated revenues. As discussed under Growth Inducement, no developments are contingent upon construction of the Corridor. Please refer to the Growth Inducement Chapter of this document for a further discussion of this issue. 01/31/91(TCA9018%INDEXH-0) N E I - 4 • • 7-56-56 Please refer to Response to Comment 7-53-4 in this Chapter regarding the public initiative process and Response to Comment 3-4-45 under Alternatives for a discussion of Measure M. 7-76-1 The comment does not state what human factor is being referred to. All required environmental topics are analyzed in the EIR/EIS. 7-84-13, 7-84-14, 7-84.15 The number of units allowed within the Aliso Viejo Planned Community will be less if the SJHTC is not built. However, this will not affect the need for the SJHTC project which is needed to serve not only planned but existing land uses. 7-84-16 The overall traffic and air quality benefits projected to be realized with implementation of the SJHTC far exceed any contribution to traffic and air quality from additional units in Aliso Viejo. Refer to sections 5.0 and 4.4 in the EIR/EIS respectively, regarding the expected traffic and air quality bene- fits of the SJHTC project. 8-24-1. 8-33-1. 8-34-3. 8-35-1. 8-36-1 This comment does not identify environmental issues or deficiencies in the EIR/EIS. 0 01/31/91(TCA901&:INDEXN-0) NEI-5 L� NO RESPONSE NECESSARY Prior to taking an action to approve the Corridor project, the TCA Board of Directors must certify the Final EIR. This certification involves concluding that: 1) the document has been completed in compliance with CEQA, and 2) the Board has reviewed and considered the information within the EIR prior to approving the project. Some comments transmitted to the TCA express an opinion on the project itself or address issues not within the scope of environmental analysis. These com- ments do not address the adequacy of the EIR/EIS, but are considered by the Board as part of -their action on the project. This Chapter of the Response to Comments includes comments on the project out- side the scope of environmental analysis. Where this occurs, the response so indicates. 2-1-1 This comment is the cover letter from the State Clearinghouse acknowledging compliance with review requirements. 2-2-3 The Final EIR/EIS will include a separate Response to Comments section. A copy of the Final EIR/EIS will be sent to the commentator at the noted address. 2-8-58 The Coastal Commission's request to the office of Ocean and Coastal Resources Management is acknowledged. 2-10-3 The TCA will continue to coordinate financial and transportation planning activities with the CTC. 3-2-1. 3-2-2. 3-2-4. 3-4-1. 3-8-1. 3-9-1. 3-11-1. 4-38-1. 6-4-2. 6-12-1. 6-16-11, 7-15-1. 7-16-1. 7-19-1. 7-21-1. 7-32-1. 7-43-1. 7-59-1. 7-110-1 This is a statement representing support of the Corridor; no response is re- quired. 01/31/91(TCA9018%INDEXH-0) N R- 1 This statement reflects the opinion of the commentator; no response necessary. 3-4-7 This comment is an introductory statement. Please refer to Responses to Com- ments 3-4-40 under Alternatives; 3-4-58 and 3-4-66 under Construction Impacts; 3-4-70 under Cost; 3-4-73 under Cumulative Impacts; 3-4-8, 3-4-64, 3-4-65 and 3-4-72 under Fiscal Impacts; 3-4-69 under Funding/Tolls; 3-4-61, 3-4-62 and 3-4-63 under Housing/Business Relocation; 3-4-41, 3-4-42, 3-4-46, 3-4-47, 3-4-55, 3-4-56, 3-4-57, 3-4-59, 3-4-67, 3-4-77 and 3-7-78 under Project Description; 3-4-43 under Public Services/Utilities; 3-4-6, 3-4-48, 3-4-49, 3-4-68 and 3-4-75 under Traffic/Circulation; 3-4-79 and 3-4-80 under Visual Resources and 3-4-76 under Section 4(f) for a complete discussion of the City's perceived deficiencies in the DEIR/EIS. 1. 7-149-1. 8-21-2 This is a statement representing opposition to the Corridor; no response is required. 3-5-15 The documents referenced were evaluated where appropriate in the responses to the City's comments. 3-6-31 Please refer to Responses to Comments 3-6-65 and 3-6-69 under Project Descrip- tion and 3-6-66, 3-6-67, 3-6-68 and 3-6-70 under Traffic/Circulation and 3-6-71 under Funding/Tolls. 3-8-155 The City of Irvine's response to Mr. and Mrs. Anderson is hereby acknowledged. 0 0 01/31/91(TCA9018%INDEXH-0) N R - 2 0 4-7-14 This comment represents an amendment to the references in the original letter; no response is required. 4-20-12. 4-26-3. 6-8-6. 7-88-88 These are conclusionary statements; no response is necessary. 4-21-43 Please refer to Responses to Comments 1-1-50, 2-7-14, 3-5-94, 3-5-96, 3-5-99, 4-21-30 and 4-21-34 under Biological Resources; 3-5-101 and 4-21-38 under Water Resources; 4-21-39 under Alternatives; 4-21-40 under Funding/Tolls; and 4-21-41 and 4-21-42 under Not EIR/EIS Issue regarding the implementation of the pro- posed mitigation measures. All feasible mitigation measures have been incor- porated into the EIR/EIS to reduce or eliminate the project and cumulative impacts of the Corridor. 4-22-13 Please refer to the Department of Interior letter beginning with Response to Comment 1-1-10. 4-27-1. 6-5-1. 7-60-1. 8-13-1. 8-21-6 These are introductory statements; no response is necessary. 4-37-1 Request for implementation of barriers identified in the DEIR/DEIS; no response necessary. 5-1-1 Southern California Gas Company has no comments on the project. 5-2-1 County Sanitation Districts of Orange County have no comments at this time. 01/31/91(TCA9018%INDEXH-0) N R - 3 0 6-1-1. 7-26-1. 7-38-1. 7-43-1 This is a statement in support of Alignment #2 at the I-5 connection; no response required. 6-5-2. 6-9,-6. 6-13-1. 6-13-12, 6-15-3. 6-18-8. 7-29-1 This is a statement in opposition to Alignment #2 at the I-5 connection; no response required. 6-14-1 Your comment regarding on -going negotiations with Costco is noted. 6-15-55. 6-20-10, 7-24-7. 7-110-2. 7-112-1. 7-122-3 This is a statement in support of Alignment #1 at the I-5 connection; no response required. 6-17-1 This is a statement in support of the Demand Management Alternative; no res- ponse required. 7-9-5 Statement of availability to provide information; no response necessary. 7-59-3 This is the commentators opinion on HOV lanes; no response necessary. 7-62-5 The commentator is making a statement of fact; no response necessary. 8-15-1 Please refer to Responses to Comments 2-7-3 and 2-7-9 under Biological Resour- ces regarding mitigation and habitat fragmentation. The statement regarding quality of life is the opinion of the author and will be taken into consideration by the decision makers. 01/31/91(TCA901B%INDEXH-0) N R- 4 0 8-18-1. 8-22-1. 8-23-1. 8-28-3. 8-30-1. 8-35-3 The comment does not bring up environmental issues relative to the EIR/EIS; no response necessary. 0 01/31/91(TCA9018%INDEXH-0) N R- 5 0 OBJECTIVES 2-8-47, 3-5-81, 3-5-114, 3-5-115, 3-5-136, 4-19-3. 4-19-11, 6-17-46, 7-1-2 As discussed in Chapter 1 of the Draft EIR/EIS, the Corridor would improve access to recreational resources in coastal southern Orange County. Improving access to coastal resources is consistent with the goals of the California Coastal Act which place a high priority on public access and encouraging recre- ational use of coastal areas. The extent to which existing access is inade- quate is illustrated by the existing Level of Service column on Tables 1.3.A and 1.3.0 in Chapter 1 of the DEIR/EIS. As shown on the Tables, existing Levels of Service are at E and F (overcapacity) on the freeways and key recrea- tional access facilities such as Pacific Coast Highway. Analyses identifying existing and future traffic conditions on freeways and arterial highways pro- viding access to coastal recreational resources are provided in Chapters 1 and 5 of the Draft EIR/EIS. Further, the Draft EIR/EIS contains information con- cerning the manner in which the Corridor would facilitate public access to recreational areas by providing an alternative access method and by relieving traffic on currently congested roadways. For example, the Corridor would provide an alternative parallel route to SR-1, thereby providing alternative access to recreational resources while simultaneously relieving traffic con- ditions on SR-1. The rel"ationship of the Corridor to applicable Local Coastal Programs is discussed on pages 4-95 and 4-96 of the DEIR/EIS-. With respect to potential overuse of coastal resources, the following infor- mation is provided. According to the Harbors, Beaches and Parks Department, the County of Orange has no predetermined carrying capacity for County owned recreational open space or regional parks. Park capacity, to a great extent, is dictated by the number of parking spaces available at each recreational facility, restricting access when available parking is fully engaged. Since many of the proposed County regional parks in the Corridor area have opened recently or are not yet open to public use, there are no current user statis- tics or estimates of carrying capacity. Orange County's current Regional Recreational Facilities Plan, updating the 1980 Recreational Needs Analysis, is based on recreation need, and reasonable expectations dictated by the County's financial capabilities. As indicated in the recreation element of the County General Plan, wilderness regional parks are designed to be regional parks in which the land retains its undeveloped character with minimal improvements, and which is managed and protected to preserve natural processes. The resource management and development policy for wilderness regional park areas permit only "restricted hardscape and domestication appropriate to provide access and enjoyment/observation of natural resources and processes." Interpretative programs and concessions are permitted. The County's recreational element does • 01/31/91(TCA901B%1NDEXH-0) 0-1 1], not contain regulations which specifically control the number of individuals permitted access to such park areas. Many of the recreation areas discussed in the Draft EIR/EIS, such as Aliso/Wood Canyon Regional Park, currently exist as passive recreational sites. It is expected that various levels of active recreation uses will be developed at these locations in the future, increasing both the demand for the sites and their planned carrying capacity. The proposed Corridor and feeder arterials would provide the additional travel capacity to serve the increased traffic demand. In light of the policies enunciated in the California Coastal Act, encouraging access to coastal recreational resources for inland residents as well as those living near the coast, restriction of access to coastal resources in order to protect their environmental values is more properly accomplished through tech- niques limiting the use of each site, rather than restriction of regional transportation access to coastal recreation areas. Management techniques such as controlling the size and location of parking areas are both more effective and more equitable means of assuring proper use and availability of coastal recreation sites than attempting to constrain access artificially by limiting the capacity of roadways. Overuse of coastal recreational resources is further regulated by state law. For example, areas subject to the California Coastal Act, including the coastal recreational sites seaward of the Corridor, must comply with the policies of the Coastal Act including Public Resources Code Section 30212.5 requiring distribution of public facilities in such a way as to avoid "overuse by the public of any single area" and Public Resources Code Sections 3O24O(a) and (b) protecting sensitive natural resources. Park management techniques for regu- lating public use of recreation areas are expected to be finalized during the review of park plans adopted for each recreation area. In addition, specific park development plans will be subject to the requirements of CEQA and to specific local coastal programs ("LCPs") approved by the Coastal Commission pursuant to the California Coastal Act. As described in the Draft EIR/EIS, the Corridor is consistent with the approved LCPs for Aliso Creek, Irvine Coast, and the cities of Irvine and Newport Beach. Compliance with these regulations, in conjunction with the utilization of park management techniques, will provide an effective and equitable means of assuring proper use and availability of recreation areas. 01/31/91(TCA9018%INDEXH-0) 0-2 • 0 3-5-51 Please refer to Response to Comment 3-5-39 under cussion of the effectiveness of the Corridor in related to traffic and traffic congestion. 6-17-4 Traffic/Circulation for dis- meeting project objectives The Corridor will implement SCAG's Regional Mobility Plan (RMP) which includes the SJHTC as a critical transportation link providing needed infrastructure im- provements in south Orange County. Also see Responses to Comments under Alter- natives and Air Quality chapters. 7-37-1 The traffic benefits from the Corridor are shown in the DEIR/DEIS on Figure 1.3.1. In general, compared to projected conditions without the Corridor, parallel routes on the MPAH require and will receive relief from projected congestion if the Corridor is built, from the Corridor construction while feeding routes on the MPAH will receive more traffic. Also see Response to Comment 4-5-6 under Traffic/Circulation. 0 01/31/91(TCA9018%INDEXH-0) 0-3 0 OPINION Prior to taking an action to approve the Corridor project, the TCA Board of Directors must certify the Final EIR. This certification involves concluding that: 1) the document has been completed in compliance with CEQA, and 2) the Board has reviewed and considered the information within the EIR prior to approving the project. Some comments transmitted to the TCA express an opinion on the project itself or address issues not within the scope of environmental analysis. These com- ments do not address the adequacy of the EIR/EIS, but are considered by the Board as part of their action on the project. This Chapter of the Response to Comments includes comments on the project out- side the scope of environmental analysis. Where this occurs, the response so indicates. 2-5-1. 2-5-9. 3-4-89, 3-11-2. 4-10-1. 4-10-2. 4-14-5. 4-14-6. 4-14-7. 4-16-1. 4-17-2. 4-17-8. 4-17-10, 4-18-14, 4-19-1. 4-19-6. 4-20-13, 4-21-1. 4-21-28, 4-21-45, 4-22-33, 4-23-1. 4-24-19, 4-31-15, 4-34-4. 6-10-2. 6-20-8. 7-1-1. 7-1-8. 7-1-9. 7-6-1. 7-7-1. 7-10-2. 7-13-3. 7-17-1. 7-20-1. 7-23-1. 7-24-2. 7-24-8. 7-24-14, 7-25-1. 7-27-1. 7-28-1. 7-35-1. 7-40-2. 7-45-1. 7-45-9. 7-55- 1. 7-56-3. 7-56-11, 7-56-15, 7-56-17, 7-56-19, 7-62-1. 7-86-45. 7-87-1. 7-88-68, 7-88-69, 7-92-1. 7-94-1. 7-105-5. 7-109-6. 7-114-13, 7-118-1, 7-131-1. 7-133-1. 7-139-1. 7-140-4. 7-140-6. 7-146-1. 7-147-1. 8-2-1. 8-3-1. 8-4-1. 8-5-1. 8-7-1. 8-10-3. 8-12-1. 8-12-2. 8-13-2. 8-13-7. 8-14-1. 8-15-5. 8-16-3. 8-18-2. 8-18-6. 8-21-3. 8-22-4. 8-22-6. 8-24-2. 8-24-4. 8-25-1. 8-25-4. 8-26-4. 8-27-1. 8-28-1. 8-29-4. 8-33-5. 8-34-1. 8-34-4. 8-36-2 This comment is the opinion of the author and will be taken into consideration by the decision makers during the review process. 3-5-9. 3-5-21, 3-5-23, 3-5-40, 3-5-57, 4-17-11, 7-17-15, 4-17-16, 4-18-8. 4-18-10, 4-18-13, 4-22-3. 4-24-17, 4-34-1. 4-35-2. 6-5-10, 7-53-3. 7-56-10, 7- 56-18, 7-56-50, 7-60-6. 7-84-40, 7-113-1. 7-114-2. 7-127-1. 7-130-1. 7-144-1. 8-15-3 The comment does not identify where the information provided is not adequate and is, therefore, considered the opinion of the commentator and will be taken into consideration during the review process. 0 01/31/91(TCA9018%INDEXH-0) OP-1 PARK AND RIDE 3-6-43 The "Crown Valley Park and Ride" is located at Greenfield Drive. The proposed park and ride lot would not require the relocation of any structures. The lot would be provided by using existing commercial parking spaces which are not needed to meet peak hour parking demand which does not occur simultaneously with park and ride operations. The commercial parking spaces are located in the Rancho Niguel Shopping Center. 3-8-12 It is acknowledged that Caltrans is often a Lead Agency for implementing park and ride lots. The information in the comment does not represent a change in the conclusion of the EIR/EIS. 0 01/31/91(TCA9018%INDEXP) I PR-1 PEDESTRIANJEOUESTRIAN/BICYCLE FACILITIES 3-6-46 The information provided in the comment serves to clarify the EIR/EIS text and is noted herein. 3-6-47 Figure 3.12.1 has been altered to reflect the information provided in the comment. 3-8-69 DEIR No. 494 evaluated the joint use of an overcrossing/bridge for wildlife and recreational trails uses in the Shady/Bommer Canyon area. At the time of that analysis (1988), the project did not propose the overcrossing as a facility strictly for wildlife since there was no consensus from the resource agencies regarding the likely success of an undercrossing vs. overcrossing design. Numerous comments were received on the DEIR No. 494 questioning the feasibility of a joint use overcrossing, given the potential for conflict between bicycle riders and wildlife. As a result of subsequent communication with resource agency biologists, the current project design includes an undercrossing type of facility specifically designed for wildlife. Although not a decisive choice among the biological community (refer to Response to Comment No. 1-1-50 under Biological Resourc- es), this type of structural design will allow for a relatively smooth transi- tion in terms of wildlife movement across the Corridor (i.e., less severe grade levels for animals to traverse). Refer to Response to Comment No. 1-1-50 under Biological Resources for a more detailed discussion regarding the undercrossing facility. 3-8-70, 3-8-80 To TCA's knowledge, the City has not yet adopted a specific alignment of the Bommer Canyon Class I bicycle and riding and hiking trails. The solid blue line on Figure-3.12.1 indicates the future off -road Class I trail. The portion of this trail between Bonita Canyon Road and the Corridor alignment is termed the Irvine Coast Trail on the County Master Plan of Riding and Hiking Trails. The Class II facility for Sand Canyon Avenue has been revised on Figure 3.121 to follow the currently planned roadway alignment. All appropriate corrections 01/31/91(TCA9018%INDEXP) P E B - 1 to the riding/hiking and bicycle trails text and Figure 3.12.1 have been included in the Final EIR/EIS. 3-8-77, 7-118-3. 7-132-1. 7-134-3 TCA will provide local jurisdictions the opportunity to review and comment on the project final design plans prior to approval. The following is hereby added to Mitigation Measure 13-1 of the EIR/EIS: "In conjunction with final design, the TCA will coordinate with the appro- priate local agency regarding the construction of existing and master planned trail crossings." 3-8-78 Bicycle trail facilities constructed as part of the Corridor project will be designed and built in accordance with Caltrans and local jurisdictional stan- dards. These standards include the specific parameters mentioned in the com- ment. 3-8-79 Refer to Response to Comment Nos. 3-8-109, 3-8-148, 3-8-150 and 3-8-151 in this Chapter. 3-8-109, 3-8-149 Table 4.1.A (not 4.1.B) has been modified to reference Mitigation Measure No. 13-1. 3-8-148, 3-8-152, 3-8-154 Class II bicycle lanes for University Drive and Pelican Hill Road have been added to Figure 3.12.1. The text on page 4-117 is a cumulative list of Corri- dor crossings at bicycle, riding and hiking trails. 3-8-150 A Class I trail is provided along the west side of Jamboree Road between East - bluff and Bayview Drive. 01/31/91(TCA901B%INDEXP) PEB-2 0 3-8-151 The University Drive Trail is a Class II facility, and the text has been amended to reflect that classification. MacArthur Boulevard has both Class I and II bicycle facilities. Refer to Appendix A - Section 4(f) Evaluation for further explanation of these trails. 3-8-153 The Section 4(f) analysis evaluated potential impacts and proposed mitigation measures for existing Class I bicycle and riding and hiking trails. Mitigation measures for those facilities are covered in Appendix A. Mitigation Measure 13-1 has been amended to include existing and future Class II trails. 4-8-1. 4-8-2. 4-8-3. 4-8-4. 4-8-5. 4-8-6. 4-8-7. 4-8-8. 4-8-9. 4-8-10, 4-8-11, 4-8-12 TCA will incorporate the construction criteria as specified in these comments as part of the final design plans for the Corridor crossings of bicycle and riding and hiking trails. 4-8-13 This comment is interpreted to mean that, with construction of the Corridor, wildlife movement will tend to be directed along recreational trails which will either transition laterally or across the freeway due to the Corridor's effect of fragmenting existing open space areas in the San Joaquin Hills. There is no intentional mixing of the two uses by the proposed design of the Corridor (refer to Response to Comment No. 3-8-69 in this Chapter). The TCA is responsible for design and construction of the Corridor such that it provides for adequate crossing of existing and planned trails which intersect the alignment. The crossing locations are part of the proposed project; howev- er, it is clarified that implementation of any other portions of planned trails will be part of subsequent projects. The commentator's suggestion of creation of a document on the mixing of recre- ational trails and wildlife uses and details section (presumably to address issues such as separation of the two entities for safety purposes) will be taken into consideration as part of the final design of the Corridor. 01/31/91(TCA9018%INDEXP) P E B - 3 4-8-14 The Corridor's effects on the Aliso Creek and Niguel Trails are discussed in Appendix A -Section 4(f) Evaluation of the DEIR/EIS. As stated on page 3-62 of the DEIR/EIS, existing publicly owned bicycle and riding/hiking trails are discussed in Appendix A of the document. The requested modification is not consistent with the format of Section 3.12 and has not been incorporated into the EIR/EIS. 4-8-15 The suggested revised description of the Niguel Trail has been incorporated into the Final EIR/EIS. 4-8-16, 4-8-17, 4-8-18 Figure 3.12.1 has been amended to reflect the corrections contained in these comments. 6-4-1 The comment regarding pedestrian ramps on the north and south sides of the Corridor alignment being planned and partially constructed to provide pedestri- an access underneath Alicia Parkway to the Aliso Viejo Greenbelt area is here- with incorporated into the Final EIR/EIS text. 7-132-1 The TCA is in contact with the City and County and will commit to incorporation of trails which they identify. 7-141-9 Refer to Section 4.13 of the EIR/EIS and Appendix A, the Section 4(f) Evalua- tion, for discussion of potential impacts to public and privately owned trails from construction of the Corridor. The current usage of the trails by the public, while informative, would not be essential to an analysis of potential impact to trail facilities and would not alter the conclusions in Section 4.13. Thus, that data is not included in the final EIR/EIS. 01/31/91(TCA901B%INDEXP) PEB-4 0 0 PHASING 4-5-4 Please see Response to Comment 4-5-2 under Alternatives. 6-16-4. 6-16-8 The complexity of the project and the public need have dictated a schedule which requires that the length of the Corridor be open to traffic as soon as possible. At the I-5 connection, this will involve 36 to 40 months of contin- uous construction. The Corridor will be phased and/or constructed simultaneously throughout its entire length. Staging (the addition of future interior lanes) will occur after initial construction. Phasing is discussed in Section 2.5 of the DEIR/ EIS on page 2-27. �j With respect to Fiscal Impacts associated with Alternative #2 alignment, please refer to Responses to Comments 3-4-8 and 3-4-9 under Fiscal Impacts. 7-6-2 The phasing of the project will be planned to insure that the Corridor can be opened to traffic as soon as possible. Please refer to Response to Comment 4-3-1 under Water Resources which discusses early construction of retarding basins in Laguna Canyon. 01/31/91(TCA9018%INDEXP) PH-1 0 PROJECT DESCRIPTION 2-6-6. 2-6-8 The TCA has been working with UCI for three years, and prior to TCA being formed, the County of Orange coordinated with UCI on design and right-of-way issues for five years. The purpose of going onto UCI property is to reduce impacts to wetlands. The Corridor is shown on the UCI Long Range Development Plan. In previous discussions with UCI, the campus has never indicated that the sensitivity of the Preserve area would prevent the Corridor from using the proposed right-of-way. The TCA will continue to work with UCI to reach a mutually agreeable right-of-way limit. The EIR/EIS provides environmental clearance based on 200 scale design plans of April, 1990. 2-6-7 0 The biological analysis is thorough in its coverage of the affects upon sensi- tive plant communities and wildlife species. Detailed mapping of affected plant communities and field surveys of sensitive species are provided in the Biological Assessment Report in Technical Studies document Volume II. Text discussion and Table 1 in the report addresses all pertinent species and indi- cates their sensitivity status and sighting or non -sighting within the Corridor impact area. Refer to Response to Comment 2-6-1 under Biological Resources for further clarification. Studies in addition to those cited in the response were conducted for special groups, such as least Bells vireo and mule deer. 2-8-1 The TCA acknowledges the Coastal Commission role. Page S-5 of the DEIR/EIS lists the Coastal Commission as a Responsible Agency due to the possible need for a coastal consistency determination. 2-8-49 A potential reach of the Corridor from approximately E1 Toro Road southerly to approximately Moulton Parkway has been graded by developers who own the align- ment in order to balance earthwork for the adjacent tracts for which they have vested rights. This grading was done under CEQA approved EIRS and inspected by the Orange County EMA prior to the formation of the TCA. For further discus- sion of previous grading activities, please refer to Response to Comment 4-17-18 under Construction Impacts. • 01/31/91(TCA9018%INDEXP) PD - 1 2-9-1. 2-9-2. 2-9-26, 4-33-29 Refer to Response to Comment 4-17-18 under Construction Impacts. With respect to siltation impacts, please refer to Response to Comment 7-86-23 under Con- struction Impacts. 2-9-3. 2-9-31 The TCA has not conducted any grading adjacent to the UCI campus. In fact, the TCA has not issued any grading contracts associated with the San Joaquin Hills Transportation Corridor. The grading adjacent to the UCI campus is associated with Pelican Hill Road. The County of Orange is the Lead Agency for the Peli- can Hill Road project, in association with the City of Newport Beach and City of Irvine. Any concerns regarding inappropriate grading should be directed to OCEMA. 2-11-9 The Bison Avenue ramp connecting to California Avenue is part of the project and will be funded through project construction. Furthermore, it should be noted that TCA invites negotiations with UCI relative to the exchange of im- provements for right-of-way. 3-1-1. 3-1-12, 3-1-13, 3-8-13, 7-86-11 It is the intent of the TCA to initially construct the Corridor without HOV lanes, with HOV lanes constructed between 2000 and 2010 based on the results of demand monitoring. With respect to TCA's HOV implementation policy please see Responses to Comments 1-2-6 in Air Quality, 3-3-2 and 3-8-14 in this chapter. Please refer to Exhibit 1 with regard to toll financing projections. Please refer to Response to Comment 1-2-46 under Air Quality regarding HOV implementation. Growth inducing impacts have been thoroughly analyzed in the Draft EIR/EIS (see Section 6.0). Further, 98.5% of the land along the Corridor is either devel- oped, or committed (development approvals including development agreements) for future land uses which include large open space areas. The traffic model used to formulate traffic projections for the Draft EIR/EIS is based on the County Master Plan of Arterial Highways (MPAH), which includes the Foothill, Eastern and San Joaquin Hills Transportation Corridors. Addi- tionally, the models used to analyze projected post Corridor conditions such as 9 0 01/31/91(TCA901B%INDEXP) PD - 2 0 L] air quality and noise levels, were also based on the traffic model which as- sumes implementation of all three Corridors. Therefore, the Draft EIR/EIS provides an adequate analysis of the cumulative effects of all three Corridors. Transportation Demand Management (TDM) programs are adequately discussed in Technical Report No. 8, included in Volume II of the Technical Studies which provide additional information included in the Draft EIR/EIS. In addition, the member agencies of the TCA, in effect, form a TDMA. The scope of this TDMA applies strictly to the Corridors and not to the local arterials. 3-1-14, 4-16-4 The potential for transit alternatives is discussed in the EIR/EIS on pages 2- 16, 2-32 and 2-33. The project design allows room for the future implementa- tion of transit projects, as requested by the comment. 3-4-4. 3-4-23, 3-4-24, 3-4-26, 3-4-42, 3-4-88 Information on the two alignment options for connection of the Corridor to I-5 is provided in the DEIR/EIS. In addition, based on requests for a comparative matrix of the two alternative connections at the South End, the TCA will pre- pare a comparative matrix that will be provided for the TCA Board to use in making their alternative selection decision. The Demand Management and Conventional cross sections for the I-5 connection are similar and, therefore, the analysis of the Alternative #1 Conventional Alternative connection with I-5 adequately assesses the effects of the Alter- native #1 Demand Management alternative. The Alternative #1 Conventional connection provides a worst case scenario. 3-4-21 As discussed in Responses to Comments 3-4-45 in this chapter, the DEIR/EIS ad- dresses both the Alignment #1 and Alignment #2 I-5 connections. With regard to the comment that most of the right-of-way has already been acquired, the TCA owns 46 acres at this time, which does not represent a substantial portion of the right-of-way needed. The remainder of the comment represents the opinion of the City which will be considered by the decision makers. 3-4-22 Alignment #1 is not a mitigation measure, but rather is an alternative that the Board may or may not select as the preferred alignment. Feasible mitigation 01/31/91(TCA9018%INDEXP) PD - 3 measures are identified in the DEIR/EIS, and those mitigation measures applying specifically to Alignment #2 will be made a part of the project if the TCA Board selects Alignment #2. As discussed in the Project Description chapter on pages 2-51 through 2-54, there is no one environmentally superior alternative, rather, each alternative has some aspects which are environmentally superior and some which are not. A decision on the alternative to be selected will be made by the TCA Board based on a variety of environmental, engineering, public interest and feasibility factors. 3-4-25 Please see Response to Comment 3-4-110 under Traffic and Circulation. 3-4-27, 6-7-2. 6-9-2 When the TCA formed its member agencies it set up an issues inventory to deter- mine all of the outstanding concerns associated with Corridor construction. Specifically, from that issues inventory the City of San Juan Capistrano iden- tified the need to provide improved Corridor access and improve the traffic operations of the Avery/I-5 interchange and therefore a study was commissioned to investigate solutions which resulted in the development of Option #2. Alternative #2 was developed as a means of improving the interrelationship of the Corridor with local circulation patterns and to shift the alignment away from existing residences.The development of Option #2 occurred in November of 1989. Option #2 is presented in Chapter 2 of the environmental document (Project Description), and is thoroughly discussed in the DEIR/EIS. 3-4-31 Contrary to the comment, HOV lanes and access ramps have been adequately ad- dressed. The HOV lanes and access ramps have been analyzed based on their inclusion in the conceptual design plans, and in the traffic, noise and air quality studies. The commentator is referred to Figure 2.10, which shows lane configurations, including HOV lanes. Figure 2.3 also shows planned exclusive HOV interchanges/access. The EIR/EIS clearly acknowledges the existence of these lanes and ramps as part of the project. However, the DEIR/EIS also states that HOV facilities are not expected to be implemented with the initial phases of the project. 3-4-32 With Alternative #2, the Paseo de Colinas/Avery flyover is part of the project. 01/31/91(TCA9018%INDEXP) PD - 4 0 0 3-4-33 With Alternative #2, the Via Escolar underpass is part of the project. 3-4-34 With Alternative #2, the realignment of I-5 in the confluence area is part of the project. 3-4-41 The impacts of this I-5 connection are discussed throughout the DEIR/EIS. Traffic impacts of the I-5 connection are summarized in Chapter 5 of the DEIR/EIS, and are analyzed in a separate traffic study which is part of the Technical Studies volumes prepared with the EIR/EIS and submitted concurrently for public review. It is unclear what "traffic costs" are referred to in the comment. The costs of the improvements are summarized on page 2-29. 3-4-46 Figure 2.13 provides a perspective and plan view of the connection of Via Escolar_with Camino Capistrano. 3-4-47 The problem with developing Corridor access from Camino Capistrano to the Corridor is that the railroad adjacent to Camino Capistrano requires vertical clearance of 23 feet (with structural depth of bridges vertical separation from Corridor to arterial exceeds 30 feet) in a very limited horizontal distance; the result is an infeasible rate of grade for a ramp. 3-4-55 See Response to Comment 3-4-109 under Traffic and Circulation. 3-4-56 The I-5 HOV direct connectors are not currently part of the project; therefore, they are not assessed in the EIR/EIS. If such connectors are proposed, they will need to undergo environmental evaluation. 01/31/91(TCA9018%INDEXP) PD - 5 0 3-4-57 The DEIR/EIS analyzes the Corridor operations in a worst -case scenario to insure that the greatest impacts are disclosed to the public. The optimistic HOV projections are not representative of the worst case and hence the conser- vative HOV projections have been used. The slip ramp would be constructed in the median area and consequently have no significant impacts. The net effect of this facility would be to reduce traffic on the Corridor and its feeder arterial. 3-4-58 Since the proposed construction will occur in the median, which is 88 feet wide, there will be ample room to construct the HOV facilities without negative impacts to the (initial) six -lane construction. 3-4-67 See Responses to Comments 3-4-13 and 3-4-14 under Fiscal Impacts. Alternatives for access to Alex Michael's property, which is outside the City's corporate limits, are provided in the I-5 Land Use Study. 3-4-77 The project does not include commuter rail. However, the median is reserved for potential future transit implementation. The OCTC Commuter Rail Study is one of the preliminary planning tools which could lead to the development of a rail transit project making use of the Corridor median, or otherwise connecting to the Corridor. However, as discussed in the DEIR/EIS, the feasibility of future rail transit is speculative. 3-4-78 Under the Conventional Alternative, Oso Creek will be realigned as noted. The proposed maintenance facility will not involve the covering of flood facili- ties. Since the project does not propose to cover existing flood facilities, the additional analysis requested by the commentator is unwarranted. 3-4-85 The HOV lanes are a part of the Corridor project, and are analyzed in the DEIR/EIS, with respect to I-5 HOV connections, refer to Response to Comment 3-4-6 under Traffic and Circulation. 01/31/91(TCA9018%INDEXP) PD - 6 0 3-4-86 The project does not limit the access of local residents. In the area of Camino Capistrano the poor access that exists today is a direct result of constraints that have existed for many years and are beyond the control of the TCA. Chief among these constraints are: 1. The longitudinal barriers formed by the I-5 freeway and the AT&SF Railway or Oso Creek; 2. The well -documented geotechnical problems of landslides along the hills westerly of the business in the area has prevented or severely obstructed traffic circulation solutions. The TCA has suggested opportunities for solving Camino Capistrano access prob- lems and incorporated some of these in its plans where the project's impacts warrant the measures. Specifically incorporated into the design of Option #2 is a Via Escolar connection of Camino Capistrano to Marguerite Parkway. This connection (proposed to be funded entirely by the TCA) is proposed to return the Camino Capistrano access to its equivalent level of service. The TCA has also recommended the improved connection of Camino Capistrano southerly of Oso Parkway. Under Option #1 local access remains as it is today. Under Option #2, the additional route traveled by emergency vehicles is approximately 3,000 feet. Consequently, the change in response time is approximately one minute. Also see Response to Comment 3-4-14 under Fiscal Impacts, regarding access. 3-4-87 The DEIR/EIS is consistent with CEQA guidelines. The components of the Alter- native 2 alignment identified by the commentator (Paseo de Colinas/Avery Fly- over, Via Escolar "underpass", and relocation of 7,000 feet of I-5 both hori- zontally and vertically) are part of the project description and, are assessed in the DEIR/EIS analysis. The DEIR/EIS analysis is based on the Corridor Concept Plans (April, 1990). 3-5-16, 3-5-25 These comments are an introduction and a summary of comments on the inadequacy of the project description. The specific items raised in later comments are responded to below. 0. 01/31/91(TCA9018%INDEXP) PD- 7 3-5-20 Please see Response to Comment 3-1-1 in this chapter and Exhibit 1 San Joaquin Hills Corridor Financing Plan. 3-5-22 Water resource implications of the project are thoroughly discussed in Sections 3.3 and 4.3 of DEIR/EIS. Additionally, Technical Report No. 2, Hydrological Technical Studies, provides in-depth information relat.ive to floodplain hydrau- lics, conceptual drainage, and water quality. Mitigation Measure 3-8 on page 4-31 establishes that "retarding measures for additional run-off generated by the project include the objective of no net increase in run-off downstream in Laguna Canyon." Light rail is not a component of this stage of the project. As discussed in the DEIR/EIS, rail transit is infeasible for the foreseeable future. 3-5-26 Please see Response to Comment 1-2-2 under Cumulative Impacts. 3-5-27, 3-5-28, 3-5-29, 3-5-56 The study areas within which potential environmental effects were assessed in the Draft EIR/EIS vary in size, depending on the nature of the potential envi- ronmental effect. Potential environmental effects associated primarily with direct impacts of project construction, such as geotechnical and archaeologi- cal/paleontological impacts, were addressed within study areas closely mapped to the proposed Corridor alignment. Study areas of substantially larger scope were used for potential environmental impacts expected to occur within a larger area. The transportation and air quality analyses were based on traffic model- ing which included the Eastern and Foothill Corridors, as well as other re- gional transportation facilities included in the Master Plan of Arterial High- ways, and covered projected traffic from adjacent counties. 3-5-52 The comparative impacts of the Demand Management are discussed throughout the DEIR/EIS. Whereve ences, they are discussed. Where the impacts a tives are discussed together. Further detail on natives is available in EIR No. 494 and EIR No. 01/31/91(TCA9018%INDEXP) m : a r and Conventional Alternatives there are measurable differ - re the same, the two alterna- most of the Section 2.8 alter- 267. Summary information on 0 0 • 0 these previous alternatives is provided in the EIR/EIS. The analysis has been updated in some cases to reflect more current conditions with respect to exist- ing land uses and traffic volumes. 3-5-55 See Response to Comment 1-2-1 under CEQA/NEPA Issues. 3-5-103 This mitigation measure is not consistent with the RMP. Also, see Response to Comment 3-1-1 in this chapter. 3-5-104 The crossing .of the Corridor at both Laguna Canyon and E1 Toro Road will be accomplished by bridging. Ramps connecting the Corridor to Laguna Canyon Road and E1 Toro Road will be included in the Corridor design. 3-5-117 Comments regarding the world's fossil fuel reserve do not fall within the scope of a single project EIR/EIS. However, we have provided the following response: According to a publication entitled "Resources and Man" by the Committee on Resources and Man from the National Academy of Sciences, the total world petro- leum reserve is 2.1 trillion barrels. Resources and Man concludes that 80% of that reserve will be used by the year 2050 and that the world oil reserve will be exhausted by the year 2070. However, it should be noted that the consump- tion of oil world wide has been steadily declining since it reached its peak in 1979. Additionally, automobiles powered by means other than the internal combustion engine are now being researched and developed. A prime example of such an automobile is General Motor's electric car which is projected to be available and ready for general purpose commuting within 10 years. The DEIR/EIS does not state that "the grade of the route" (of the Corridor) "is not conducive to rail or other types of transit." One purpose of the Demand Management Alternative Concept is to reserve enough space in the Corridor median to allow future construction of light rail or other types of transit. Additionally, technology in use today demonstrates the feasibility of light rail systems with 6 percent grades. Examples of such systems are the TGV and is 01/31/91(TCA901B%1NDEXP) PD-9 the ML0002 currently operating in France and Japan respectively. The TGV is capable of 5%+ grades at 185 miles per hour and the ML0002 is capable of grades up to 10%. 3-6-1 Please see Responses to Comments 3-4-37 under Fiscal Impacts and 3-4-4 in this chapter. The Conventional Alternative is paired with the Option 1 I-5 connec- tion. However, the Demand Management Alternative can be implemented with either Option 1 or Option 2. Part of the rationale for developing the Option 2 connection was to provide a more efficient transition for the reversible HOV lanes, which are a key component of the Demand Management Alternative. 3-6-2. 3-6-3. 3-6-4. 3-6-5. 3-6-6. 3-6-7. 3-6-8. 3-6-9. 3-6-10, 3-6-11, 3-6-12, 3-6-13, 3-6-14, 3-6-15 The matrix as requested will be prepared and presented to the SJHTC Board of Directors in conjunction with public meetings related to alignment decisions. The TCA will prepare the requested data in cooperation with the affected cities and in concert with their consensus on the parameters. 3-6-18, 3-649, 6-16-3 The ramps described by the commentator were included in the focused study of the South End to test their viability. This analysis shows low volumes which do not support their construction. However, through the traffic monitoring program outlined in Response to Comment 3-4-14 under Fiscal Impacts, if need is identified, these improvements can be authorized by the TCA Board subject to CEQA, NEPA and Caltrans requirements. Please refer to Response to Comment 3-4-108 under Traffic and Circulation regarding further details on this inter- change. 3-6-33 Please refer to Response to Comment 3-6-2 in this chapter. 3-6-34 The comment provides a clarification which is hereby incorporated into the Final EIR/EIS. 01/31/91(TCA901B%INDEXP) PD-10 0 • 3-6-38 See Response to Comment 3-6-18 in this Chapter. The comment provides clarifi- cation that is hereby incorporated into the Final EIR/EIS. 3-6-39 The comment does not state what is not clear in the figure and table. Concep- tual Design Plans are available for City review which show the HOV access at 200' scale. 3-6-40 Figure 2.13 shows I-5 connection Alignment No. 2. The dashed line is meant to show Alignment No. 1 and is for comparison purposes. 3-6-41 Yes, the connection options are the essential difference relative to the I-5 connection. However, under the Conventional Alternative, Option 2 is not necessary; therefore, the pairings were provided as noted. 3-6-64 The peak hour volumes for this link have not been modeled but it is estimated that they will be: 2010 W PM 240 EB 200 EB 160 WB 300 WB 3-6-65, 3-6-73, 3-6-74, 3-6-75 If the City desires a strip map for its use, a series of 1: = 1000' scale draw- ing can be obtained from TCA by requesting the Corridor signing plans. These plans show all ramps. It is not practical to display the detail requested on exhibits the size of Figure 2.2 and the signing plans are the next larger display. • 01/31/91(TCA9018%INDEXP) PD-11 • 3-6-72. 6-16-2 The depth of discussion and detail associated with Section 2.0 (Project De- scription) effectively describes the project and relevant alternatives. The adequacy of the project description is based on the fact that this section of the DEIR/EIS contains the following subsections: 2.1 Introduction and General Description of Project Build Alternatives 2.2 Common Features of the Build Alternatives 2.3 Design Features of Demand Management Alternative 2.4 Design Features of Conventional Alternative 2.5 Phasing 2.6 Right -of -Way and Project Costs 2.7 No Build Alternative 2.8 Alternatives Withdrawn from Consideration 2.9 Environmentally Superior Alternative 2.10 Related Transportation Prospects 2.11 Park and Ride Facilities Vertical and horizontal alignment at the southerly end is described in Section 2.3 on pages 2-23 and 2-25. More detailed plans are also reproduced in Section 4.5, Noise (see Figure 4-5.1-1 for the I-5-area). 3-6-81 See Response to Comment 3-4-49 under Traffic and Circulation. 3-6-85 As stated on page S-6, the list of Areas of Controversy/Issues to be Resolved is a summary list. The list includes "I-5 Confluence land use/traffic studies. The text on page S-7 refers to determining the most suitable alternative to meet County transportation needs. Determining the most suitable alternative will also include determining the best I-5 connection option. 3-6-93 There is no premature pairing of Option 1 or Option 2 with the Conventional or Demand Management Alternatives. Please see Responses to Comments 3-4-37 under Fiscal Impacts and 3-4-4 and 3-6-1 in this chapter. 01/31/91(TCA901B%1NDEXP) PD - 12 • 3-6-94 In the engineering profession and with respect to this DEIR/EIS, the term "common alignment" refers solely to horizontal location of the Corridor. 3-6-95 Figure 2.1 is a schematic representation of the regional location of the Corri- dor and is not intended to demonstrate the location of interchanges along the Corridor route. Interchange locations are identified -on Figures 2.2 and 2.10. Therefore, the change suggested has not been incorporated into the EIR/EIS. 3-6-96 Yes, the 88 foot width is the minimum median width under the Demand Management Alternative and the 64 foot width is the minimum median width under the Conven- tional Alternative. Implementation of rail transit "in a worst case scenario" would require a 56-foot wide right-of-way. Other transit options are available which would require less than 56 feet of width. 3-6-97 On page 2-16 the paragraph under the heading "Potential Future Median Use Options" states that HOV and transit are only available with the Demand Manage- ment Option and that with the Conventional Alternative the median could be used for HOV lanes or transit but not both. 3-6-98 The Greenfield interchange is proposed as a half -diamond. However, there is sufficient right-of-way to accommodate a full diamond if future traffic demand warrants such a design. The volumes shown in the South End Traffic Study (Tech Report #7) do not warrant construction of a full diamond interchange at this time. The Southbound on -ramp from Greenfield Drive, in conjunction with the Northbound off -ramp from the Corridor to Greenfield Drive, would not provide the movements you propose to Crown Valley. These movements can be provided by remaining on I-5 and not accessing the Corridor. 3-6-99 Page 2-32 describes Mass Transit Alternatives. The comment refers to "no project" alternative which does not appear on this page, therefore, it is un- clear what text is being referred to in the comment. Nevertheless, with regard 01/31/91(TCA9018%INDEXP) PD - 1 3 0 to the 2010 forecasts, page 1-6 of the DEIR/EIS states "in Figure 1.3.1, the traffic volumes for the 2010 without the Corridor assume the complete build out of the Master Plan of Arterial Highways (MPAH), including both the Eastern and Foothill Transportation Corridor". 3-6-100 The Alternatives chapter in the DEIR/EIS was prepared in accordance with FHWA Technical Advisory 6640.8A. The text in each of the Alternatives Withdrawn From Consideration assesses each alternative, and if appropriate, explains why it was eliminated from detailed study. 3-6-102 Table 2.8.A on page 2-36 illustrates the number of existing freeway lanes, the number needed with the Corridor and the number needed without the Corridor. The last column, the number of lanes needed without the Corridor would be the number of lanes needed if the No -build alternative were selected. • 3-7-1 Your support for the Demand Management with Option 2, I-5 connection is noted. It should be noted that the DEIR/EIS does not provide a recommendation on what alternative to pursue, but provides an environmental evaluation of each of the alternatives under consideration for use by decision makers and interested public participants to help in their decision making regarding a preferred project. 3-7-2. 3-7-3. 3-7-4. 3-7-5. 3-7-6. 3-7-7. 3-7-8. 3-7-9 As stated on page S-6, the list is a summary list. The fifth item on the list is "Effect of the Project on arterial traffic", which addresses the traffic issue brought up by the commentator. All the other items mentioned in the com- ments are included, in summary form on the list on page S-6. ' 3-7-lla-f The commentator is referred to the expanded description provided in Response to Comment 4-25-1 in this Chapter for a description of the connection alterna- tives. However, specific information on this can be found in the Reference Documents that TCA has sent to each of its member agencies. 01/31/91(TCA9018%INDEXP) PD-14 • 0 The local Corridor access options have been described in the DEIR/EIS in the text and rendering for the I-5/Corridor connection, more specifically under Option #1. All local arterial access remains as it is today; however, access to the SJHTC is indirect, requiring motorists in the area around Avery Parkway to travel circuitous routes to Greenfield Drive to access the Corridor. Under Option #2, all movements to the Corridor and existing freeway are provided. Local access to the Corridor is shown in Figures 2.12 and 2.13 of the DEIR/EIS. Right-of-way takings are described in the DEIR/EIS in Table 1 of Appendix I. Adjoining land uses are described in Sections 3.7 and 4.8 of the Draft EIR/EIS. The only arterial road relocations required in the area of the confluence are described in Response to Comment 4-25-1 in this Chapter. 3-7-12 The information requested by the commentator would not provide new environmen- tal information at this stage of the project, thus it was not included in the DEIR/EIS. The study was prepared by the County of Orange; the assumptions and methodologies involved examining a range of alternative populations and growth patterns and corresponding circulation requirements for the area; the Board of Supervisor's action as a result of the study was to choose an ultimate popula- tion figure in the mid -range of population figures reviewed in SEOCCS, and to adopt a Master Plan of Arterial Highways which assured a balance of land use and transportation facilities. 3-7-15 With respect to the need for the interchange at Laguna Canyon Road please see Response to Comment 4-11-1 under Traffic and Circulation. The interchanges at Pelican Hill Road and Sand Canyon are needed with the opening of the Corridor based on the General Plan Land Use and Circulation Elements of the City of Irvine and Newport Beach. The City of Irvine's General Plan reflects the City's recent Conservation/Open Space Element which sets aside significant open space areas in Bommer and Shady Canyons. 3-7-16 The improvements to SR 74 (Ortega Highway) a cumulative manner as are all MPAH planned is necessary in the existing reference for 01/31/91(TCA9018%INDEXP) PD - 1 5 are considered with this project in improvements. No additional detail cumulative effect analysis. 0 3-7-38 Coordination with City or County staff in the development of Right -of -Way Stage Relocation Plans is inherent in the existing wording of Mitigation Measure 9-2. Relocation plans will be coordinated with the affected jurisdiction. 3-8-2 The DEIR/EIS for the San Joaquin Hills Transportation Corridor incorporates extensive mitigation measures for minimization of grading impacts. The mitiga- tion measures require that during final design the project engineer and Aes- thetics Guidelines and Standards Committee (of which the City of Irvine is a member) shall provide evidence to the Executive Director of TCA that Mitigation Measures 15-1 through 15-23 have been implemented. These 23 mitigation mea- sures advocate specific grading and visual resource requirements which are compatible with the City's Hillside Development Manual. Therefore, the exist- ing mitigation measures contained within the DEIR/EIS adequately address the City's hillside grading concerns. Furthermore, City participation in the Aesthetics Guidelines and Standards Committee will provide a forum for Director of Community Development review. The specific request to add a statement to the project description is not necessary due to the mitigation measures previ- ously referenced. For additional information, please see Exhibit 2, Aesthetic Design Guidelines. 3-8-7 All appropriate corrections will be incorporated into the EIR/EIS text. 3-8-9 Table 2.2.A does have shading; however, with mass production of the EIR/EIS, some copies did not copy properly. Additional copies of the Table will be provided upon request. 3-8-11 The statement of the benefits associated with the Barranca Parkway/I-5 overcrossing is accurate. 3-8-14 The TCA HOV pricing strategy is as follows: The SJHTC as a toll facility will inherently encourage HOV usage due to the cost savings available to persons 01 /31 /91(TCA9018%I NDEXP) PD -16 • commuting together. Additionally, the exclusive HOV facilities provide a time savings because tolls will be paid exclusively through the AVI system, which accommodates vehicle without stopping. The TCA will monitor average occupancy rates as a function of the TMS plan to provide demonstration that Corridor vehicle occupancies are comparable to that which would occur on the Corridor with HOV lanes in the initial usage of the six general purpose lanes as part of the initial Corridor construction program. The DEIR/EIS traffic analysis addressed a worst case scenario whereby the roadway operates as a "free" facility. Furthermore, a full sensitivity analy- sis has.been developed to illustrate the distribution of trips with toll opera- tion. Therefore, any increase in ridership through increased HOV usage results in fewer VMT and does not require additional traffic analysis. Traffic analyses have illustrated that peak period third lane HOV usage will not accommodate mixed flow lane peak hour demand, thereby resulting in an unacceptable level of service operation (below LOS D). 3-8-16 At the southerly confluence both connection alternatives allow adequate room for direct HOV connector ramps from the Corridor to I-5. At the time that these facilities are needed and have connection opportunity (receptive room on I-5) separate environmental documentation will be provided to address the construction -related impacts. At the northerly end of the Corridor the TCA can geometrically match the median improvements which Caltrans and OCTC have prioritized for the existing SR-73. 3-8-18 The median is a fixed size, and different facilities may use less area in the median. The following geometric constraints demonstrate that existing transit facilities can fit within the reserved median. More specifically, geometric constraints which have been used to size the median can be checked in the following source: ITE Transportation and Traffic Engineering Handbook, a summary of the key criteria from this document is displayed below with critical dimension shown in bold type: 0 01/31/91(TCA9018%INDEXP) PD - 17 • TYPICAL BASIC GEOMETRIC AND RIGHT -OF WAY CHARACTERISTICS FOR SELECTED TRANSIT FACILITY TYPES Light Rail Transit In Street In Exclusive Center Exclusive Rapid Characteristic Unit Busway Reservation Right -of -Way Transit -------------------------------------------------------------------------- Access control full partial full full Number of lanes or tracks 2 2 2 2 Widths a. Transit vehicle ft 8.5 9.5 9.5 10.3 b. Lane envelope clearance* ft 12.0 11.0 12.5 13.5 c. Track gauge ft - 4.71 4.71 4.71 d. Emergency • Walkway ft # None 2.5 2.5 e. Maximum shoul- ders (each)# ft 2.5 None None None f. Border barriers or fencing (each) ft 2.0 None 1.0 1.0 g. Overall Minimum right-of-way (1) Aerial ft 33 - 24 26 (2) At -grade ft 33 22 30 32 (3) Subway ft 39 - 38 40 Stations a. Side platform width ft 10 6 12 12 b. Center platform width ft - - 24 24 c. Platform length ft 120 400 400 500-600 Minimums a. Vertical clearance ft 14 14 14 14 b. Design Speed mph 60 40 60 60-80 c. Horizontal Curve radius (for new construction) ft 400 200 500 400-600 • 01/31/91(TCA9018%INDEXP) PD - 1 8 When these dimensions are added in reasonable conditions (e.g., a 24-foot center station would not be installed on steep rural terrain) more than ade- quate width is demonstrated. With respect to grade constraints, see Response to Comment 4-26-2 in this Chapter. 3-8-97 In Table A the following numbers should apply: Demand Management Costs: Project Cost (excludes R/W) 698.6 R/W 69.7 Total 768.3 The data shown in Table 2.6.A is correct and it should be noted that the list- ing of right-of-way cost occurs twice in table and this should not be accounted for more than once. The last row in Table 2.6.A is listed as "Total Project Cost", it will be separated for clarity. The right-of-way data from Table 2.6.A (which is correct) has been mistransferred to the summary table. The correct total acreages are demand Management: 972 Acres; Conventional Alternative 922 Acres. These corrections will be made to the summary table. 3-9-22 Current plans for the disposal of excess material generated during construction of the Corridor include the following measures: - The portion of excess material which qualifies as aggregate will be recycled as aggregate for construction of the Corridor. Excess material will be deposited, where feasible, at development sites within the project vicinity. 0 01/31/91(TCA9018%1NDEXP) PD-19 C� However, measures to minimize household and yard waste are inapplicable to a highway project. 3-8-99, 6-17-26 The last sentence on page 2-38 of the EIR/EIS is hereby modified to read as follows: "...to the coast and to the Laguna Green belt area by relieving weekend traffic on SR-1, MacArthur Boulevard and Laguna Canyon Road." 3-8-105, 3-8-108 The corrections are noted; they do not affect the conclusions of the EIR/EIS. The editing changes are hereby incorporated into the Final EIR/EIS. 4-1-1 The TCA has planned its interchange locations and configurations to be compati- ble with the Master Plan of Arterial Highways. In the specific instance of the Culver Drive connection to the Corridor, the City of Irvine has historically opposed the connection between the Corridor and Bonita Canyon Road. In an effort to be compatible with the greatest benefit to the public, the TCA has planned the Pelican Hills Road interchange location so that it could serve a future connection to Culver Drive. The improvements currently being proposed for the Corridor will not include a Culver Drive connection. 4-21-14 The Alternatives section does include an analysis of alternative land use concepts on pages 2-30 and 2-31. As discussed on these pages, implementation of alternative land use concepts would be inconsistent with approved plans, unlikely given the changes in existing approvals and policies that would need to be made by a variety of jurisdictions, and outside the authority of the TCA, which is not empowered to make land use decisions. 4-25-1 Specifically from Ortega Highway northerly a distance of 2.1 miles (station 518+00 to Station 625+00) all improvements are within existing I-5 Right -of -Way no matter which connection alternative is selected. In this area one lane and one shoulder are being constructed in each direction and slowly transitioned 01/31/91(TCA9018%INDEXP) PD - 2 0 • i northerly to two lanes and a shoulder in each direction. Greater detail is available from the TCA on plans labeled contract S90-01. Under Connection Option #1 The transition continues northerly in a manner that will bring the existing I-5 to a total of six lanes in each direction (218 foot total width). In this area the existing freeway is four lanes in each direction. The widening takes place within the existing right-of-way up to a point northerly of village road where the widening begins to take the narrow strip between the existing freeway and existing Rancho Viejo Road. The widening in this area is minimized with re- taining wall. At a point just southerly of Spotted Bull Lane the widening and retaining walls begin to impact the parallel road (Rancho Viejo Road) and it moves easterly. Continuing northerly the existing arterial moves easterly just adjacent to the widening road at the Montessori School. The road and freeway impacts are displaced to the east a maximum just southerly of Via Escolar where the I-5/SJHTC NB connector is 90 feet east of its current edge of pavement and the arterial is 100 feet east of its existing edge of pavement Under Option #2 The lane additions are similar to Option #1 but they do not have as much east- ward displacement. Specifically, existing .Rancho -Viejo Road and the freeway are displaced a maximum of 50 feet at- a point 600 feet southerly of Via Escolar. 4-26-2 CDMG has performed engineering studies to lower the SJHTC mainline profile grade from the 6% and 5.5% grades proposed in the DEIR to 3.0% between La Paz Road and Greenfield Drive. Two alternative 3.0% profile grades were investi- gated and are referred to as Alternate "A" and Alternate "B". The Alternate "A" profile grade begins at approximately Sta. 681+00 and ties into the profile at approximately Sta. 766+00. Alternate "B" profile grade begins to deviate from the proposed profile at approximately Sta. 694+00 and ties into the original profile at approximately Sta. 768+00. The two alternate profiles maintain a 3.0% upgrade from near Moulton Parkway to the crest verti- cal curve located just north of Greenfield Drive. Alternate "A" profile grade results in significant additional heights of em- bankment between La Paz Road and Moulton Parkway. Approximately 25 to 30 feet of additional height will result with this profile. The additional embankment • 01/31/91(TCA9018%INDEXP) PD - 2 1 0 heights may require retaining walls on each side of the Corridor from Pacific Park Drive to Moulton Parkway. Retaining walls were assumed in lieu of requir- ing additional right-of-way in this area as development has occurred or is underway adjacent to the Corridor. Retaining walls with heights of approxi- mately 30 feet and a total length of approximately 2,500 feet would be required to accommodate the additional embankment for Alternate "A". The additional heights of embankment also result in significant excess vertical clearance for the Pacific Park Drive and Moulton Parkway overcrossings. Alternate "B" pro- file grade does not involve additional embankment in this area. South of Moulton Parkway, both alternative profile grades result in additional depths of excavation from south of Moulton Parkway to Greenfield Drive. The Alternate "B" profile grade is lower than Alternate "A" and results in signifi- cant additional excavation. Both alternative profile grades will require retaining walls at various locations on each side of the Corridor from south of Moulton Parkway to Greenfield Drive. Retaining wall heights of approximately 36 feet for Alternate "A" and approximately 52 feet for Alternate "B" would be required to accommodate the additional depths of excavation. Total lengths of approximately 2,400 feet of retaining wall would be required for Alternate "A" and approximately 5,000 feet of retaining wall would be required for Alternate "B". Standard reinforced concrete retaining walls were used as the basis of the Alternate "A" estimates. Due to the extreme heights of the retaining walls for Alternate "B", reinforced concrete crib walls, in a stepped configuration, were used for estimating purposes. It should be noted that the selection of retaining wall types used in specific locations will be subject to additional geotechnical and engineering studies and that the types assumed for this pro- file grade study do not represent a final determination of retaining wall type. 4-31-8 Refer to Response to Comment 4-31-5 under Purpose and Need. 4-33-6. 4-33-8 As identified by the commentator, the Conventional Alternative (CA) ultimate lane configuration is larger than the lane configuration assumed for the Corri- dor in the Regional Mobility Plan (RMP), according to the Southern California Association of Governments (SCAG). SCAG has stated that the RMP assumes a maximum of six general purpose lanes and two HOV lanes, while the CA requires as many as ten general purpose lanes and two HOV lanes in some locations in order to attain LOS D peak hour service. Inconsistency with existing regional planning is expected to be an important consideration in selecting an alterna- tive for the Corridor. However, if the TCA Board determines that the CA is • 01/31/91(TCA901B%INDEXP) PD-22 preferable, inconsistency with the RMP will not, by itself, render the alterna- tive infeasible. As discussed in the DEIR/EIS at page 3-19, under the SCAG- approved Conformity Guidelines, transportation projects which differ from their size description in the RMP must meet the conformity criteria specified for project -specific amendments to the RMP. These criteria require that the pro- ject demonstrate positive air quality impacts, be consistent with the applica- ble goals, policies and programs of the 1989 AQMP and not impede the implemen- tation of the Transportation Control Measures (TCMs) in the 1989 AQMP. The Conventional Alternative is in conformity with the 1989 AQMP under these cri- teria because is provides a positive air quality benefit for the region. A discussion of the effect of the 1990 Clean Air Act Amendments on conformity determinations is provided in Response to Comment 1-2-46 under Air Quality. 4-33-25 TCA decision making about the timing of HOV lanes is based on a number of factors, primarily related to traffic demand and financial feasibility. The capacity of HOV lanes on I-405 could not be assessed in the DEIR/EIS, since they have just recently opened. However, traffic modeling conducted by the County of Orange demonstrated that the Corridor would still be needed even with planned improvements on other facilities in the County. The TCA agrees that it will be easier to induce.people to carpool when other facilities are congested; this is one of the reasons for the timing of HOV lanes, to implement them when traffic demand on the Corridor is at a level which will make the HOV lanes desirable in terms of time saving. The TCA does not agree that the new roadways will set back mass transit ef- forts; as discussed on page 2-33 of the DEIR/EIS, future implementation of a fixed light rail system is facilitated by construction of the Corridor with the median envelope which can accommodate future transit. 4-33-27 A toll -free HOV lane is not discussed because it is not economically feasible. Specifically, the bond covenants from financial underwriter of the project will not allow competing free lanes. 4-33-75 The option of not allowing truck traffic was examined in Technical Memorandum 2-15, which is included as the ninth study in the Technical Studies volume of the EIR/EIS. The conclusions of the Technical Memorandum were that truck restrictions on the Corridor were unlikely to be successful and were not neces- 01/31/91(TCA901BtINDEXP) PD-23 nary because other design measures would mitigate environmental, safety and operational concerns of heavy vehicle traffic. The auxiliary lanes cannot be eliminated due to the grades; they would be needed even if it were possible to restrict trucks. The last two questions relate to effects of restricting trucks on the corridor; since this is not feasible, it is difficult to address -these questions. Howev- er, the following information is provided. The effect on most parallel routes would be minimal as the Corridor is not expected to -be a desirable route for trucks, however, there may be some locations where trucks would increase on parallel routes if not allowed on the Corridor. Regarding the viability of Aliso-Viejo Town Center, it is assumed that trucks would find a route to serve the center. 4-33-76 Deletion of one of the paired interchanges will cause traffic to pass through a signalized intersection E1 Toro/Laguna Canyon which has inadequate capacity to handle the additional diverted flows. Alternatively, the division of traffic through this intersection some traffic would be diverted along E1 Toro Road/Moulton Parkway to destinations in Irvine, and this distance is signifi- cant. More significant than distance to the motorist is delay, and delay along an E1 Toro/Moulton Parkway diversion could amount to more than five additional minutes. Diverting traffic through the signalized intersection of E1 Toro and Laguna Canyon Road would create a significant traffic hazard due to frustration associated with lengthy delay in the left turn movements from Laguna Canyon Road to E1 Toro Road. Unreasonable delays in traffic cause motorists to dis- obey signalized rights -of -way and hence increase accidents. This same problem would result in a diversion along E1 Toro Road and Moulton Parkway where seven traffic signals are encountered. 4-34-18 Both the Laguna Canyon and E1 Toro Road interchanges are needed in order to provide adequate level of service on either facility. The deletion of the E1 Toro road interchange results in substantial congestion at the E1 Toro/Laguna Canyon interchange and necessitates the extension of Santa Maria between El Toro Road and Laguna Canyon Road. 01/31/91(TCA901B%INDEXP ) PD- 24 0 4-33-93 A complete discussion of the issues surrounding the banning of truck traffic are contained in the DEIR/EIS, please see Technical Report No. 9. The TCA is not proposing the banning of truck traffic as a component of the project nor as project mitigation. 4-34-24. 8-33-3 Decreasing grades will not have significant benefits. in mitigating noise im- pacts or improving air quality. These conclusions are based on facts which recognize that noise on the Corridor is more a function of the volume of traf- fic and the speed of traffic than it is dependent , on roadway grades. Grades. would be important if a majority of the Corridor volume were truck traffic. This is not the case for the Corridor, since approximately four percent of the traffic will be truck traffic (this percentage fits real freeway conditions in industrial/commercial areas). In other words, more than 96% of the noise generating traffic is not significantly affected by grades in the range of six percent. In general, reducing Corridor grades will tend to decrease noise. However, a grade reduction from six percent to three.percent will not lead to a signifi- cant reduction in Corridor noise.. Specifically, noise modeling procedures generally recognize that grades affect noise emission from truck traffic only. NCHRP Report 117 titled "Highway Noise, A Design Guide for Engineers" does not make any adjustment for grade to automobile noise and makes the following adjustment to truck noise: 3% grade 2 dba added to projected truck noise 6% grade 3 dba added to projected truck noise From this, it can be estimated that lowering grades will decrease noise by perhaps one or two dBA (but only,for the truck's contribution). It should also be remembered that truck traffic is probably less than four percent of the Corridor ADT. Also, reducing grades to three percent would tend to attract more truck traffic to the Corridor because the route would be easier to travel. A one or two dBA reduction in noise is the maximum that can be expected from grade reduction. For a more detailed discussion, please refer to Attachment II, Alternate Profile Grade Study. 0 01/31/91(TCA9016%INDEXP) PD - 2 5 While the comment refers specifically to noise impacts related to grade reduc- tions, we have also studied grade reduction impacts related to light and glare and energy. With respect to air quality, the same basic observations on the composition of traffic (96% auto, 4% trucks) are primary reasons that air quality calculations are not significantly affected by grades. There are no readily available emission factors that differentiate between going uphill or downhill. The emission factors used in the air quality analy- sis were developed by the California Air Resources Board using a typical driv- ing cycle to simulate actual driving conditions (i.e.. stop and go, accelera- tion, deceleration, driving on city street and freeway, etc.). The U.S. Envi- ronmental Protection Agency's Compilation of Air pollutant Emission Factors (AP-42, September 1985) has an emission. factor category that could be used as a surrogate to approximate the loading effect due to grades. Emission factors from AP-41, Appendix K were used with the following assumptions: 6% grade: 100% air conditioner usage, 15% extra load, 10% trailer towing. At grade: 0% air conditioner usage, 0% trailer towing. Results of the above comparison are that going up the 6% grade would: increase total hydrocarbons (THC) by 77., increase carbon monoxide (CO) by 43%, and reduce nitrogen oxides (NOx) by 16%. However, vehicles traveling downhill in the opposite direction would be pollut- ing less because of less strain on the engine and with some coasting. The net effect would probably washout, or at worst, only a marginal net increase in emissions due to going up the 6% grade. 4-36-1 The accident rate on typical freeways is approximately 1.03 accidents per mil- lion vehicles miles. The accident rate on the reversible lanes on I-15 is approximately 0.98 accidents per million vehicle miles. 4-36-4. 4-36-5 The "with Corridor" and "without Corridor" volumes on I-405 westerly of the confluence are nearly identical in the year 2010. The Orange County Transit District has done studies which address the need for transit on I-405 and SR-55. These studies do not yet project demand for service on SR-73. 4-36-6 See Response to Comment 3-7-15 under Project Description and 4-11-1 under Traffic and Circulation. 01/31/91(TCA9018%INDEXP) PD-26 I* 0 5-3-1 The TCA is aware of the location of both water facilities and has shown them on our evolving plans. Furthermore, in the months of November and December of 1990 our design consultants have met -with MWD to coordinate design issues. 5-3-2 Thank you for the information relative to your environmental work associated with the San Joaquin Reservoir Improvement Project. - The construction of the Corridor will not have any impact on the existing facility or the proposed improvements. 6-7-3 Please see Responses to Comments 3-4-38 under Fiscal Impacts and 6-16-1 under Housing/Business Relocation. 6-9-3 Your support of the conclusions stated in the letters from George J. Jeffries and Mr. Pinto are so noted. 6-9-4 Please see Response to Comment 3-4-27 in this chapter. Your dislike of Option #2 is so noted. 6-14-10 With regard to how Alignment's # 1 and 2 are analyzed, see Response to Comment 3-4-4 in this Chapter. With regard to the benefits of either Alignment, as disclosed in the DEIR/EIS, there are advantages and disadvantages of either I-5 connection. The TCA will make a decision based on a number of factors includ- ing environmental impacts, engineering and feasibility. Alignment Option #1 and #2 are discussed equally throughout the DEIR/EIS. 6-15-37 The EIR/EIS contains a clear description of the length associated with the Alternatives. Page 2-18 describes Demand Management with the Alignment #2 I-5 connection. Page 2-25 describes the Conventional Alternative with the Align- • 01/31/91(TCA9018%INDEXP) PD-27 ment # 1 I-5 connection. The Demand Management Alternative with the Alignment # 1 I-5 connection would be the same length as the Conventional Alternative, 17.5 miles. 6-15-38 The observation provided by the commentator are correct, but the lateral improvements associated with the Corridor project are pushed to the north with Option #2. 6-15-39. 6-15-40 The I-5 alignment alternatives are sub -alternatives to the Demand Management Build alternative. Build and alignment alternatives are not confused or inter- changed. 6-15-41. 6-15-57. 6-15-58. 6-15-59 Response to Comment 3-4-4 in this Chapter provides an explanation of how the I- 5 Alignment alternatives are analyzed in the EIR/EIS. Regarding costs, see Response to Comment 6-15-17 under Cost. 6-15-64 Please see Response to Comment 6-15-23 under Construction Impacts. The time necessary for right-of-way acquisition and relocation requirements has been factored into the project schedule. The TCA is developing a hazardous waste management plan designed to expeditiously respond to hazardous waste clean-up requirements. It should be noted that Section 4.12 Hazardous Waste Materials identifies only seven known hazardous waste sites within the right-of-way that may result in potential hazardous waste materials problems (see Table 4.12.A) known of these sites represent significant known hazardous materials problems. Furthermore, the project will be built through a Design/Build contract whereby the contractor will absorb the cost of delays not accounted for in the con- tract. 6-17-23 Figure S-1 will be modified with a footnote to reflect the changes that will result with the elimination of the Birch Street off -ramp and the construction of ramp TR-1 which provided for the same movement. 01/31/91(TCA9018%I NDEXP) PD- 28 • 6-17-24 The author does not identify what information should be provided in the re- quested legend nor does he identify how Figure 2.3 is unclear; the suggestion has not been incorporated into the EIR/EIS. 6-17-28 The results of Laguna Canyon Road Interchange alternative studies were: 1. That the Corridor crosses the canyon with longer bridges than previous proposed. This in response to both aesthetic and wildlife concerns. 2. The bridges decrease grading impacts and slightly increase cost. 3. That aesthetics may be further enhanced by the concept on a land bridge. The coverage in the DEIR/EIS covers the most conservative possibilities from these studies. 6-17-29 San Joaquin Hills Road is not shown on.either the County or City Master Plans to interchange with the Corridor and the City of Newport Beach has gone on record opposing such an interchange. Consequently, no interchange analysis is required. the geotechnical reference cited using San Joaquin Hills Road was inadvertent. 6-17-30 The analysis of the West End Study, prepared concurrently with prior DEIR 494, is summarized on pages 2-49 to 2-51 of the DEIR/EIS. 6-17-31 Technical Memorandum TM 3-17, CDMG will be added to the Technical Studies Volume to document the toll plaza selection. 6-17-32 The easterly shift of the alignment cited was through a limited longitudinal reach of the Corridor (approximately 2000 feet). As mentioned in the"DEIR/EIS, this shift occurred to avoid potential hazardous waste sites. The shift 91/31/91(TCA901 B%INDEXP) PD- 29 0 occurred entirely within the project APE. Given the extensive studies done in the wider area no new impacts will occur. Given the relatively large distance of the road to homes no detectable change in projected noise levels will occur. 6-17-33 The TCA committed to its member agency (the City of Newport Beach) Ford Road Realignment as a traffic/noise/visual impact mitigation measure. Since this mitigation was planned it seemed efficient to use it as the necessary detour route in that area. This plan is not the only alternative but the other alter- natives can be covered better in the separate EIR being prepared for the Ford Road realignment. 6-18-4 This statement is correct. Option 2 would have greater impacts on your proper- ty than Option 1, as discussed in Section 4.9, Housing/Business Relocation, of the EIR/EIS. 0 6-19-2 Alignment #2 provides for substantial local arterial improvements (Avery/Paseo de Colinas) which greatly improve intersections currently operating at a very poor level of service. The Alternative #1 cannot provide for similar local improvements due to engineering constraints. 6-20-5 Under connection Option #2, the grade is higher but no steeper than existing. The conclusions concerning traffic safety do not take into account the design standards which would be used on this alternative if it is selected. 7-2-2 In general the interchange of the Corridor and Laguna Canyon Road is needed to efficiently convey traffic to locations in Irvine. The elevation of the Corri- dor over Laguna Canyon is relatively high to minimize grading impacts along the length of the Corridor. This height forces a loop ramp system to gain suffi- cient elevation in a relatively small space so that SR-133 traffic can reach the SR-73 Corridor above. 01/31/91(TCA9018%INDEXP) PD-30 9 7-9-3. 7-9-4 With the Demand Management Alternative there would be three general purpose lanes in each direction, with one climbing lane on the far side of the Corridor from your residence, and two HOV lanes. 7-11-1 See Response to Comment 4-33-76 in this Chapter regarding need for both interchanges. The commentator's attention is directed to the fact that the proposed bridge height at Laguna Canyon Road is approximately 40 feet. 7-25-3 It is not true that the Corridor will be used only for buses, carpools and "special" vehicles. The Corridor does provide for carpool or HOV lanes, and the median also provides for future transit. However, a minimum of 6 general purpose lanes for all traffic will be provided. Regarding carpools and tolls, the TCA is studying options for varying the toll to encourage carpooling. To some extent the toll itself is an incentive to carpool since more people can travel the same distance and only pay one toll if they carpool. 7-34-1 The clover leafs may provide more visual mitigation than the commentator rea- lizes. The TCA has prepared landscaping concepts in this area which are very effective in making the interchange compatible with the terrain. The commenta- tor is invited to visit the TCA aesthetics team and review these concepts. 7-45-2 Please refer to Response to Comment 3-5-117 in this chapter. 7-45-6 Please -refer to Response to Comment 7-25-4 under Funding/Tolls. 0 01/31/91(TCA9018%INDEXP) PD - 3 1 7-59-2 The need for both interchanges (El Toro Road and Laguna Canyon Road) is dis- cussed in Responses to Comments 3-7-15 in this chapter and 4-11-1 under Traffic and Circulation. 7-64-4 The Corridor is part of the MPAH which is the master plan for the County's circulation system. This master plan provides for. a balance of highways, arterials and collector roads which form a complimentary network. The inter- change spacing south of E1 Toro Road was determined primarily on a circulation configuration that evolved prior to the Corridor (1968-70). To address the impacts associated with these fixed arterials, the Corridor includes a collec- tor/distributor system to distribute traffic north of E1 Toro Road. Where the land is undeveloped, future interchanges have been spaced at one mile or more apart. 7-64-4 The purpose of the SJHTC is to alleviate existing and planned projected (with- out the Corridor) peak period traffic congestion on the regional circulation system and to minimize regional through traffic use of arterial highways. In other words, the SJHTC is a major component of the plan to help areas currently suffering from traffic congestion. Traffic congestion in these areas is pro- jected to worsen without construction of the Corridor. Regarding the proposed number and location of interchanges on the Corridor; TCA has planned its interchange locations and configurations to be compatible with the Master Plan of Arterial Highways (MPAH). The MPAH is a proposed plan for the future regional transportation network which is formulated through the combined consensus of the County of Orange and its component cities. The plan represents the best projection based on existing and planned land use of the County and cities regarding the configuration and capacity of traffic facili- ties that will be needed to serve future traffic volumes. Interchanges are located strategically within this plan to best serve the origins and destina- tions of existing and planned regional trips. For information regarding the aesthetics of the SJHTC and the steps that TCA is taking to minimize any visual impacts the Corridor may have, please refer to Section 4.15 ("Visual Resources") of the EIR/EIS. A 01/31 /91(TCA9018%INDEXP) PD- 32 0 For information regarding affected natural habitats and related mitigating measures, please see sections 3.6 and 4.6 of the EIR/EIS. Population densities along the Corridor are controlled by the respective Gener- al Plans and subsequent approvals of development entitlements of each of the jurisdictions within the area of benefit for.the Corridor. 7-82-10 TCA owns only 46 acres of right-of-way, southerly of Moulton Parkway. The majority of the remaining right-of-way necessary for the Corridor is reserved with offers of dedication which have not yet been accepted. Grading along the Corridor alignment is discussed in Response to Comment 4-17-18 under Construc- tion Impacts. In the event that the'No Project Alternative, or an alternative alignment, is selected, the proposed alignment, based on EIR 267, would be available for a variety of alternate uses, including a linear park as suggested by the commentator. 7-82-14 Please see Responses to Comments 2-9-1 and 2-9-3 in this chapter. 7-82-15 The TCA has not issued any grading contracts associated with the San Joaquin Hills Transportation Corridor. The commentators reference to 35% must be that the TCA has completed 35% of the design work for the Corridor. Design work does not involve any construction activity. 7-82-16 TCA EIR/EIS 1 is a tiered environmental document and is the construction level document or final tier. EIR No. 267, certified by the County of Orange, pro- vided an environmental analysis of alternative alignments and alternative transportation modes brought forth in TCA EIR/EIS 1 through the alternative alignments analysis. TCA EIR/EIS #1 contains an extensive discussion regarding previous alternative analysis and associated environmental documentation. Please refer to page 2-28 of Section 2.8, Alternatives Withdrawn from Consider- ation. 0 01/31/91(TCA901B%INDEXP) PD-33 C; 7-82-17 Impacts to paleontological resources were considered during the alternatives analysis. The San Joaquin Hills are known to contain numerous paleontological resources. The DEIR/EIS contains adequate mitigation for paleontological resources. See Mitigation Measures 11-3, 11-4 and 11-5. Furthermore, the TCA has entered into an agreement with the National History Museum of Orange County regarding curation. 7-84-19. 7-84-20 See Response to Comment 3-5-37 under Alternatives. 7-84-21 The conclusions in Tables 2.8.A and 2.8.B are based on existing conditions and Orange County traffic modeling. 7-84-29 A list of permits and approvals required if the Build Alternative is chosen is provided on page S-5 of the DEIR/EIS. A chronology of future actions is: TCA Board hearing February 14, 1990 Record of Decision Spring/early summer of 1991 (completes Federal environmental process) Other Permits and Approvals 1991 7-84-33 The project has been on the County's Master Plan of Arterial Highways as the San Joaquin Hills Transportation Corridor since 1976. Keeping this name is appropriate and is not inaccurate. The project was authorized to be a toll facility in 1987. The County, TCA and Caltrans have all openly discussed the project as a toll facility. One of the reasons the current EIR/EIS was pre- pared and distributed was to allow the public to review the impacts of the Corridor as a toll road. 01 /31 /91 MA901 BA NDEXP) PD - 3 4 0 7-84-35. 7-84-41 The HOV lanes are part of the project description. Please see page 2-20 HOV/ Transit Median. The impacts of the HOV lanes are quantified in the DEIR/EIS since they are contained within the project area of potential effect. Regard- ing HOV relationship to toll pricing, please see Response to Comment 3-8-14 in this chapter. 7-86-44 Initial construction of the Corridor as a six -lane general purpose facility without HOV lanes is based on traffic demand and the lack of available funds for constructing HOV lanes; not on any willingness on the part of TCA to delay the construction of HOV lanes. Please refer to the Responses to Comments 3-1-1 in this Chapter and 3-4-48 under Traffic and Circulation. Regarding the pro- jected air quality impacts of the SJHTC project, please refer to Section 4.4 of the EIR/EIS. 7-88-12 Please refer to Response to Comment 2-6-1 under Biological Resources. 7-88-14. 7-88-15 The allegation regarding additional grading for the Corridor occurring as a result of the Pelican Hill Road project is unfounded. Any concerns regarding grading associated with the Pelican Hill Road project should be addressed to the County of Orange which in conjunction with the Cities of Newport Beach and Irvine are the lead agencies for the project. The TCA has no involvement with the Pelican Hill Road project. 7-88-16 The traffic volume and speed determines the extent of the CNEL noise contours not the location of the right-of-way line. 7-88-19. 7-88-20, 7-88-24 The California Street extension over San Diego Creek would have little or no impact on the traffic operations of the Corridor which is a regional facility. TCA is working closely with the City of Irvine regarding the sizing of arterial facilities which interact with the Corridor. Environmental impacts associated 01/31/91(TCA901B%INDEXP) PD-35 with extending California Street will need to be addressed at the time either UCI or the City of Irvine decide to pursue such a project. See Responses to Comments 2-7-3 and 2-7-10 under Biological Resources. 7-88-22 The bridge structure for the San Joaquin Hills Corridor as it crosses over San Diego Creek is described as follows: Both bridges over San Diego will be concrete box girder construction. The bridges for the mainline are on a straight profile grade while the bottom of the ramp bridge is arched. These type of bridges are attractive for nesting by cliff swallows. The height of the bridges will be similar to Jamboree. Adding height at the crossing would require extensive fill southerly on the Corridor thereby further impacting Bonita Reservoir/Creek area. 7-88-23 • Noise barriers on bridges are not encouraged because the damages to motorists from potential impacts with the sound barrier would be greater than the per- ceived benefits. Additionally, any perceived benefit from sound barriers installed on the SJHTC bridge over the San Diego Creek would be counteracted by ambient noise levels from the existing Jamboree and MacArthur bridges on either side. 7-88-82 Comment noted. However, the extension of Aliso Creek Road is not a TCA pro- ject. Responsibility for the Aliso Creek road extension project lies with the County of Orange and the City of Laguna Beach. 7-88-83 Please see Responses to Comments 2-9-1 and 2-9-3 in this chapter and 7-88-6 under Biological Resources. 7-114-20 The California Drive bridge is not part of the proposed project. This bridge, if built, would be constructed by the University of California, Irvine, as part 01/31/91(TCA9018%INDEXP) PD-36 0 0 of UCI's Long Range Development or by the City of Irvine as part of the City's capital improvement program. 7-137-1 Flattening the road to a grade sufficient to allow current electric cars would raise the cost of the Corridor to a point where it is economically infeasible. Please refer to Response to Comment 4-26-2 in this Chapter. 7-140-1 Please see Responses to Comments 2-9-1 and 2-9-3 in this chapter. 7-140-2 The DEIR/EIS acknowledges and provides maximum mitigation for the impacts noted. The No Project alternative has been fully explored. The TCA Board will consider this alternative along with the Build alternatives when they make a decision on the project. 7-145-3 Traffic conditions in the I-5 confluence with and without the Corridor and for alignment alternatives I and II are thoroughly analyzed i;n the South End Study, which is included in Volume II of the Technical Studies which provide support for conclusions in the EIR/EIS. The projected impacts to housing and businesses are listed in Table I in the EIR/EIS. These impacts are for a worst case scenario and represent TCA's best estimate for projected right-of-way impacts at this stage of Corridor design. 7-145-3 The commentator is referenced to 4-25-1 in this Chapter for a description of the lanes needed under the various connection options. 7-145-4 The No Build Alternative is presented in the DEIR/EIS. The inconsistency with local municipal and the County General Plan is based on the fact that all communities and the County locate the SJHTC at its conceptual alignment on their land use and Circulation Elements, and assumed construction of the Corri- dor when determining building intensity limits and traffic generation. • 01/31/91(TCA9018%INDEXP) PD-37 0 The No Build alternative has been extensively analyzed in a number of envi- ronmental documents, going back to 1976 when the SEOCCS study was prepared and the County adopted population forecasts and put the Corridor on the Master Plan of Arterial Highways to ensure a circulation system to meet the population needs. The No Build alternative would be inconsistent with General Plans because the Corridor is shown on the General Plans and assumed in the traffic modeling. The planning process which has occurred to develop the General Plans and the resulting decisions made by the County and the cities -have been based on popu- lation forecasts, County action on SEOCCS, and the need to balance infrastruc- ture, including circulation, with the development of the community. The Gener- al Plans, zoning and Development Agreements which have been adopted have been based on required environmental analysis and public review. For further discussion of the General Plans and potential for alternative land use concepts as a project alternative, the commentator is referred to Page 2-30 of the DEIR/EIS. 8-9-1 Table 2.2.0 (Grading Widths) on page 2-10 of EIR/EIS lists the grading widths for specific sections of the proposed Corridor Alignment. For additional information regarding right-of-way impacts south of the SJHTC/ I-5 connection, please refer to the Response to Comment 4-25-1 in this Chapter. 8-9-5 Under each of the two alternative Corridor alignments, two additional lanes in each direction would be constructed along the I-5 between Avery Parkway and Junipero Serra to accommodate traffic southbound merging from the corridor onto the I-5. One additional lane in each direction would be constructed along the I-5 between Junipero Serra and the Ortega Highway. Right-of-way impacts from the addition of these lanes are minor, for the most part, and consist of only partial land takes. Of the ten required land takes, one is a temporary con- struction easement for a retaining or sound wall, leasing only nine permanent partial land takes. For further information regarding widths of additional lanes on I-5 and the associated right-of-way impacts refer to Table 2.2.C. ("Grading Widths") and Table I ("Summary of Housing and Business Impacts") in the EIR/EIS. 01/31/91(TCA9018%INDEXP) PD-38 • 1�1 PUBLIC SERVICES AND UTILITIES 3-4-43, 3-4-44, 3-44-45, 6-3-3. 6-5-7. 6-5-8. 7-29-6. 7-29-7 A mitigation measure has been added to the Draft EIR/EIS requiring the TCA to develop an access plan subject to approval by the cities of Laguna Niguel and San Juan Capistrano. Please see Response to Comment 3-4-14 under Fiscal Impacts. 3-8-62, 3-8-63, 3-8-64, 3-8-65, 3-8-66, 3-8-67, 3-8-68 The issues raised in these comments represent design issues to be addressed during final design. 6-8-2 Please see Response to Comment 3-4-86 under Project Description and 3-4-14 (01 under Fiscal Impacts. 7-86-8 The TCA will be entering into an agreement with the California Highway Patrol regarding patrolling of the Corridor. If such an agreement is not reached the- TCA will provide for private patrol. 0 01/31/91(TCA901B%INDEXP) PS-1 0 PURPOSE AND NEED 1-2-3 The commentator states that the DEIS does not effectively justify the need for the project. The comment does not state what information is missing to justify the need for the project. The need for the project is described in Chapter 1 of the EIR/EIS in terms of socioeconomics, existing and projected roadway capacities and the Regional Mobility Plan. Also see Responses to Comments 1-2-16 and 3-5-5 in this Chapter. The remainder of the comment addressed "latent demand." The EPA letter asserts that the Corridor could encourage more trips than are estimated in the state- of-the-art traffic models used in the DEIS by reducing travel time and satisfy- ing "latent demand." The EPA's point appears to be that reducing congestion is somehow bad per se because individuals will not have to suffer the severe gridlock which dominates much of the regional transportation system in Southern California. This statement by the EPA does not reflect regional transportation planning in Southern California and the objectives of the Regional Mobility Plan. The Southern California Association of Governments' Regional Mobility Plan makes it clear that even with the transportation improvements proposed in the Regional Mobility Plan (including the Corridor), the demand within the region will not be significantly increased. All available evidence indicates that the growth in vehicle miles traveled (VMT) in the region is far outstripping system capa- city. In other words, system capacity is not the fundamental determinant of demand. The California Department of Transportation reports that although the size of the State Highway System in the South Coast Region hardly changed between 1986 and 1989, VMT increased dramatically: 1986 1989 Miles of State Highway 3725.1 3733.7 +.2% Millions VMT 51,128 62,415 +22% (Caltrans, Travel and Related Factors in California, 1986 and 1989 Annual Summaries.) This information strongly indicates that factors other than extensions of the highway system are driving the increase in VMT, and that the very modest increases in the highway system proposed in the Regional Mobility Plan will not significantly effect increases in "latent demand." The Regional Mobility Plan proposes a program that lags behind increases in population and travel: • 01/31/91(TCA9018%INDEXP) PN - 1 0 1984 2010 Increase Population: 12.4 million 18.3 million +47% Daily Trips: 40.2 million 57.0 million +36% Vehicle Miles Traveled: 221.3 million 284.3 million +28% State Highway Miles: 14,847 miles 16,686 miles +12% "Latent travel demand" is highly unlikely to be prodded by a project assumed in the Regional Mobility Plan (which is also the key source of the transportation and demographic assumptions for the AQMP) in a region that will increase re- gional highway capacity by less than half the established increase in VMT and one-third the number of daily trips. Furthermore, these issues can only be dealt with at the regional planning level, where basic assumptions and overall policies and plans are addressed. The EPA's comment overlooks the fact that the extent of the highway network is just one of many factors influencing travel, including income, availability and cost of parking, costs of vehicle ownership and operations, changes in the percentage of the population that is of driving age, changes in the number of workers per household, changes in the economy, etc. Any attempt to quantify the impacts that a single facility such as the SJHTC.(which is only 7% of the 12% addition to the regional network planned through 2010) would be purely hypothetical because of its highly marginal nature, and the lack of a reliable methodology for dealing with the many other factors influencing demand on a project specific level. 1-2-16 The general implication of this comment is that the reduction in ADT with implementation of the Corridor, projected for the year 2010 on sections of I-5 and I-405, does not justify the need for the Corridor. Table 1.3.A in the DEIR/EIS projects a reduction of 30,000 ADT or more, on most sections of these facilities, with implementation of the Corridor. This equates to just under a 10% reduction in ADT in the year 2010, if reductions on both facilities are averaged. It is logical that as regional population continues to grow, the transportation system must expand and change to meet the growing demand for moving people and goods within the region. Unfortunately, this has not happened in Orange County. In the past 30 years the County's population and economy have grown enormously. However, very few miles of new freeway have been constructed to serve the transportation needs of this rapidly growing area. Only one north 01/31/91(TCA9018%INDEXP) PN - 2 • south facility currently connects residential communities in South Orange County with employment centers located in the central and northern portions of the County. The I-5 and the I-405 are currently heavily congested for 10 to 12 hours during week days and sometimes for up to 5 hours or more on weekends. There is no significant off peak period on these freeways and therefore the use of ADTs is appropriate to justify the need for the Corridor project. Once roadway capacity (about 2,000 vehicles per lane.per hour for a highway) has been reached, the duration of the congestion increases, but not the rate of flow. Because the peak hour volumes on existing regional highways (including I-5 and I-405) are already at capacity, the peak hour traffic volume for with- out or with the Corridor in a congested condition would be the same. The roadway cannot handle anything beyond its maximum traffic capacity, which has already been reached. However, in many locations, implementation of the Cor- ridor will reduce the duration of the peak period. For example, as shown in Table 1.3.A on page 1-5 of the DEIR/EIS, the E1 Toro Road/Lake Forest Drive segment of the I-5 has a vehicle/capacity ratio of 1.39 without the Corridor and 1.22 with the Corridor in the year 2010, with 10 general purpose lanes and 2 HOV lanes. Using Caltrans criteria, this is 2 to 3 hours congestion without the Corridor and less than 1 hour with the Corridor. While the Corridor does not solve the problem of congestion on I-5 and I-405, it does reduce congestion substantially. Following retirement of the 30 year bonds used to finance construction of the SJHTC project, the Corridor would be turned over to Caltrans and become a free facility. The law requires that the tolls be removed once the construction financing bonds are repaid. 3-5-5. 3-5-6. 7-84-44, 7-109-7. 7-111-2. 8-4-10 The "Need for Project" (page S-1) establishes the relationship between the Corridor and the 14 year planning effort (1976-1990) incorporating regional land use, transportation and open space considerations. The SEOCCS study established the need for the project in 1974-76. Subsequently, SEOCCS traffic forecasts have been verified by actual traffic counts conducted by Caltrans. SEOCCS prediction for 1990 volumes, on I-5 and south County north -south move- ments, have proved very accurate; thus supporting the current need for the project. Further, all current traffic/land use models reaffirm the need for the Corridor and existing traffic conditions exceed acceptable level of ser- vice. Traffic models used in this study and maintained by the County of Orange 0 01/31/91(TCA901B%INDEXP) PN - 3 (OCTAM I and II), as well as individual models maintained by various planning agencies such as the ITAP model developed by the City of Irvine, confirm that present congestion problems in south Orange County create significant pressure on arterial roadway systems located near or parallel to congested interstate freeways. Comment 3-3-5 contains a quote from the Draft Summary 1991 AQMP Amendment and includes the AQMP as an exhibit. As described in the EIR/EIS (pages 1-2), the Corridor is an integral component of the Regional Mobility Plan which is a central element of the AQMP. As further described in pages 3-12 through 3-22, the Corridor is in conformance with air quality policies and carries out a number of adopted air quality/transportation strategies. Also see the Air Quality Section of the Response to Comments and Response to Comment 4-33-13 under Alternatives. 3-6-35 See Response to Comment 3-4-6 under Traffic and Circulation. 3-6-37 The correction is noted and is hereby incorporated into the Final EIR/EIS. 3-7-10 The commentator is directed to Technical Study No. 7 (Traffic) and more speci- fically the SJHTC South End Study (in Technical Study No. 7) with detailed intersection and interchange analysis performed for the following: Location # Description 10 Ortega Hwy/I-5 11 Ortega Hwy/I-5 12 Ortega Hwy/Camino Capistrano 13 Ortega Hwy/Rancho Viejo 4-4-1. 4-4-2. 7-111-3 The suggestions in the Comments are addressed in the EIR/EIS in pages 2-31 and 2-33 through 2-40 of the Alternatives Chapter. As stated in the EIR/EIS, improving existing transportation and carpools would not eliminate the need for the Corridor. Furthermore, improving the existing transportation system would 01/31/91(TCA9018%INDEXP) PN - 4 0 0 result in a number of significant impacts such as residential and business displacement and loss of parkland. 4-7-5 Please refer to Response to Comment 3-5-7 under Alternatives. 4-10-6 Although, some companies are leaving the area, socioeconomic forecasts (see Chapter 6 of the EIR/EIS) show that population, housing and employment will continue to grow between now and the year 2010. Employment in South Orange County is projected to grow 63% between 1990 and 2010. Based on existing conditions and adopted County and SCAG plans and forecasts,- the Corridor is needed. 4-14-4 0 Refer to Response to Comment 4-14-1 under Traffic and Circulation. 4-17-1. 4-17-4 The recognized method of establishing the need for a route i,s through the use of traffic models (see Response to Comment 4-5-6 under Traffic and Circulation) or by identifying a deficiency in the existing highway network. In the case of the San Joaquin Hills Corridor, both a forecast model and an analysis of the existing highway capacities demonstrate a need for the Corridor. More specifi- cally the existing I-5 and 405 are operating at Level of Service F during critical peak periods. Additionally, several arterial highways in the area of (traffic) benefit have unreasonable levels of traffic congestion because they were planned to rely on the Corridor for relief. Contrary to the comments, the issue of reasonable demand and usage has been proved and addressed in the EIR/EIS and in all the regional planning documents referenced and summarized in the EIR/EIS. The relief which the Corridor provides to parallel free routes (such as I-5, I-405 and PCH) serves as an opportunity for those motorists who are unable to pay tolls. In this way the Corridor is a win -win situation. The toll user obtains significant congestion relief by direct use of the Corridor, while the freeway motorist benefits from diminished traffic (traffic that uses the Corri- dor instead of existing freeways/arterials). • 01/31/91(TCA9018%INDEXP) PN - 5 0 4-22-19 The San Joaquin Hills Transportation Corridor is a regional transportation facility designed to address the present congestion problems in south Orange County. Furthermore, the facility is designed to accommodate projected traffic demand which will further degrade the existing poor levels of service exper- ienced on arterials and interstate freeways. Please refer to the "Need for Project" discussion in Chapter 1 of the EIR/EIS for additional information. The Corridor is referenced in the General Plans of the County of Orange, and the cities of Irvine, Newport Beach, Laguna Beach, Laguna Niguel, Mission Viejo, and San Juan Capistrano. Development activity in these jurisdictions (except Laguna Beach) has been approved and built based on regional plans which balanced development and transportation systems. Table 3.7.A provides an extensive listing of the development of projects built, under construction or approved along the Corridor. These projects include the 1,300 acre Nellie Gail Ranch, 6,000 acre plan for Laguna Niguel, 1,400 acre development of the Univer- sity of California, Irvine, 6,000 acre Aliso Viejo project and the 23,000 acre Aliso Creek Corridor Specific Plan. The preservation of the Laguna Laurel site as an open space area will not alter the demand for a regional facility designed to provide vital transportation infrastructure to the south Orange County area. The need for an interchange with Laguna Canyon, although diminished by the Laguna Laurel change, is not removed due to high employment growth in the Irvine Spectrum and the presence of Laguna Beach as a significant tourist destination. The traffic modeling provided for the project provides a "worst case" scenario. In fact, if the funds are not obtained for the individual installments needed to purchase Laguna Laurel, the site could be developed as originally envi- sioned. The request for further economic analysis to ascertain whether other develop- ment areas will be preserved as open space is unnecessary given the level of development which has already occurred in the project areas described in Table 3-7A, the connection between development areas and existing open space dedica- tion, and the existing commitment of funds for open space acquisition of cur- rently existing sites. Finally, with respect to additional analysis, the pur- chase of Laguna Laurel as an open space area was made with the reservation and acknowledgement of right-of-way for the Corridor. Additional discussion of the 01/31/91(TCA9018%INDEXP) PN - 6 0 proposed Laguna Laurel purchase is provided in Response to Comment 3-5-140 under Section 4(f). 4-22-32 This comment is a summary of the commentators previous comments, which are addressed above. 4-24-2. 4-31-9. 7-14-4. 7-66-3. 7-84-12 The solutions to traffic congestion in Orange County are planned to work to- gether. The propositions providing new transit funding allocated those funds to specific projects. A majority of the Measure M monies are allocated for MPAH improvements, which are included .in the traffic modeling for the Corridor. Some Measure M monies will be available for City improvements. The Corridor was initially conceived based on the Southeast Orange County circulation study (SEOCCS) adopted by the County in 1976. As part of SEOCCS, the County examined a variety of alternative population scenarios. With their decision on SEOCCS, the County selected a mid -range ultimate population figure and a balanced land use/transportation system which included the Corridor. As discussed in Chapter 1 of the EIR/EIS, the Corridor serves several objectives. While alleviating existing and projected peak period traffic is a key objec- tive, the Corridor will improve levels of service over a much wider area than the E1 Toro "Y." Improving the "Y" will have no impact on the need for the Corridor. Improve- ments to the "Y" were programmed into the traffic modeling for the Corridor. Furthermore, as discussed in Chapter 1, even if all currently planned roadway and freeway improvements are completed, the Corridor would still be a needed facility. 4-31-9 Regarding the adequacy of the information in Table A, Cost of the No Build Alternative, no network improvements that can achieve the Corridor project objectives have been identified or included on the MPAH. The MPAH and Measure M modeling included the Corridor. Thus, the conclusion in the Table regarding the cost of such improvements is accurate. • 01/31/91(TCA9018%INDEXP) PN - 7 4-31-3. 4-31-6 Please refer to Response to Comment 8-9-7 under CEQA/NEPA Issues, regarding the decision making process for the project and Response to Comment 4-33-13 under Alternatives regarding current demand for the Corridor. 4-31-4 Refer to the Responses to Comments 8-9-7 under CEQA/NEPA Issues, and 4-33-13 and 3-4-40 under Alternatives. 4-31-5. 8-7-2 The purpose and need for building the SJHTC and the project objectives remain the same as when the Corridor was initially conceived. In fact, the need for the Corridor today is greater than ever before. (See also Response to Comment 4-33-13 under Alternatives). As in 1976 when the Corridor was added to the County MPAH, there is only one major thoroughfare known as the I-5 Freeway which connects south Orange County to northern cities and to job centers in the central County area. Additionally, the I-5 Freeway is heavily congested and is currently operating at a level of service (LOS) F during hours of peak traffic flow. The commentator is referred to the Technical Studies Volume II - Techni- cal Report (7 page 10) for documentation of the fact that the "peak hour" on the I-5 has grown into an 8 hour period..- Consequently there is no significant off-peak on the free facility to attract traffic away from the Corridor. The opinion of the commentator with regard to the value of the project will be taken into consideration by the decision makers. 4-31-7 Assumptions in the EIR/EIS are based on: 1) the 1988 Orange County Preferred (OCP-88) population, housing and employment forecasts adopted by the Orange County Board of Supervisors as the preferred set of land use forecasts for Orange County, 2) the Orange County General Plan including the Growth Manage- ment Plan, 3) SCAG's Regional Mobility Plan, and 4) The Air Quality Management Plan. Additional assumptions/conclusions are drawn from the following: 1) the Orange County OCTAM traffic model uses an average Orange County commute of 11.91 miles, and 2) a recent survey of employee residence locations for the Irvine Business Complex and Irvine Spectrum demonstrated that employee residence patterns reflect the desire to live in close proximity to employment centers 01/31/91(7CA9018%INDEXP) PN - 8 • (Consumer Attitude and Demographic Study 1987, Letter Report to Rich Cermak, The Irvine Company, 1989, prepared by The Research Network, Ltd.) 4-34-5 The San Joaquin Hills Transportation Corridor project is part of an extensive regional planning effort based on the Southern California Association of Gov- ernments Growth Management Plan (GMP), Regional Mobility Plan (RMP), and Hous- ing Needs Assessment. This regional planning effort which involves OCEMA and OCTD/OCTC and other regional and local agencies includes provisions for widen- ing the I-5 freeway and transit, TSM/TDM measures, and Master Plan of Arterial Highways (MPAH) improvements. The regional planning focus ties job growth and housing demand with transportation planning. The demand for the SJHTC still exists, even with the improvements noted in your comments. The I-5 Corridor, I-405, SR-1 and parallel arterials are currently and projected to continue to operate at inadequate levels of service (E and F) without the complete menu of transportation improvements. Finally, it is not possible or legally enforce- able to restrict regional through traffic use of arterial highways. In fact, projects such as the SJHTC are needed so that regional through traffic and local inter -community trips can be removed from the local arterial system. 4-34-17 The E1 Toro Road Park and Ride lot is a conceptual location. This park and ride facility would serve Aliso Viejo and Laguna Beach residents. Given that El Toro Road is a major arterial that intersects with the Corridor it is appro- priate from a transportation/circulation perspective to build a facility at this location. It is expected that OCTD will be the lead agency for park and ride development. The future construction of any such facility will be designed to insure that the placement of the facility does not hinder wildlife movement nor increase downstream flood levels. 4-36-3 Link analysis data shows the Irvine area as a strong destination; but the origins (e.g., from the south) are not so nicely concentrated as to support transit to the extent which might be expected. At the confluence of SR-73 and I-405 the 2010 traffic volume just westerly of the freeway to freeway connection will be approximately 270,000 ADT. In this same area approximately 40,000 ADT is identifiable as through Corridor. • 01/31/91(TCA9018%INDEXP) PN - 9 0 6-17-3 Your comments relative to employment vs. growth are so noted. The first full paragraph on page 1-2 with the changes is provided and hereby incorporated into the Final EIR/EIS. Orange County employment is now growing faster than hous- ing, having increased from about 428,000 employees in 1970 to 1.2 million in 1986, an increase of about 18O% during that 16 year period. County employment is projected to increase by about another 5O% by the year 2010. This dramatic growth in population and employment has been accompanied by an even greater increase in traffic. However, based on the draft .AMR/DMP findings Orange County has a labor force participation rate of 1.71. Accordingly, the rate of employment rate increase relative to housing units is not the significant indicator of jobs/housing balance, but rather it is the rate of employment growth relative to the number of total workers (i.e., workers per household which equals labor force participation rate) that is the critical determinant. In its comments on the draft 1989 South Coast AQMP, the County of Orange point- ed out that the major commute flow in the South Coast Air Basin is from Orange County to Los Angeles, not Riverside to Orange, thereby indicating that Orange County requires added employment growth to reduce inter -regional VMT. Further, the anticipated growth in population, employment and development and the accom- panying increase in traffic in south Orange County as a result of already approved projects and other proposed development, which is consistent with the cities' and the County's General Plans, will greatly exacerbate the congestion on the regional transportation network. 7-22-7 Regarding other solutions such as monorails, mass transit alternatives are assessed on pages 2-32 and 2-33 of the EIR/EIS. As stated on those pages, a transit only alternative is currently infeasible, however, the project design allows for implementation of transit in the future. Regarding controlling building, the infeasibility of alternative land use concepts is assessed on page 2-30 of the EIR/EIS. Also, see the Growth Induc- ing Chapter of this Response to Comments. 7-25-7. 7-56-45 Traffic studies show that, following construction of the Corridor, parallel arterials will experience reduced traffic volumes and feeder facilities to the Corridor will experience some congestion in the localized areas where they intersect with the Corridor. 01/31/91(TCA9016%INDEXP) PN - 1 0 • • It is not projected that people traveling from either Costa Mesa or San Juan Capistrano would use the Corridor and Laguna Canyon or E1 Toro Road to reach the 5 or the 405. Commuters from these areas would use the I-405 and the I-5 because these routes are the most direct and would provide the path of least resistance to their destinations. 7-56-1. 7-56-5. 7-56-47, 7-56-48, 7-56-49, 7-62-4. 7-66-2. 7-7-2. 7-119-1. 7-119-3. 8-3-2. 8-25-3 Measure M money will be used to implement needed improvements to the Master Plan of Arterial Highways (MPAH) of which the San Joaquin Hills Transportation Corridor is a part, and implement improvements planned by OCTC/OCTD to the regional transit system. All of these transportation programs complement one another and are part of a regional circulation improvement plan known as the Regional Mobility Plan (RMP) prepared by the Southern California Association of Governments. Based on the mobility needs identified through regional planning efforts and modeling of traffic demand for existing and committed development in south Orange County, all the transportation improvements contained in Mea- sure M and implementation of the SJHTC are necessary in order to provide acceptable mobility levels to Orange County and the region. The two items mentioned in comment 7-56-1 in this Chapter, former commitment and money are not factors which would affect future decisions by the TCA Board. Feasibility of the project, and the need for the project, must be considered by the TCA Board. Prior commitments or money spent would not be able to override a lack of need for the project, if the project was shown to be unnecessary. 7-56-12 Please refer to Response to Comment 7-56-1 in this Chapter regarding the rela- tionship of the project to Measure M. The unpopularity of a project is not an environmental issue to be addressed in the EIR/EIS. Public opinion is a factor considered by the decision makers in taking action on a project, yet it is not an issue subject to CEQA or NEPA analysis. The Corridor will not add to already existing congestion. See the Growth Inducing Chapter of this document for further explanation. 40 01/31/91(TCA901B%INDEXP) PN - 1 1 0 7-82-4 Mitigation Measure 3-8 in the EIR/EIS states that TCA has the objective of achieving no net increase to downstream runoff in Laguna Canyon following construction of the SJHTC. This is proposed to be achieved by constructing a retarding basin near Laurel Canyon and Laguna Canyon Road and adjacent to the proposed location of the Corridor. This retarding basin will be necessary regardless of the status of the Laguna Laurel development. 7-86-10. 7-108-7 A complete discussion of alternatives is provided in Section 2.8 (Alternatives Withdrawn from Consideration) starting on page 2-28 of the DEIR/EIS. The precise mechanisms of the congestion management and growth management plans have not been finalized at this date. Anticipating the results of these new planning efforts requires considerable speculation. However, the efforts to date on such plans have assumed completion of the SJHTC. The absence of the SJHTC would likely trigger findings of transportation deficiencies under these programs. Unless alternative transportation improvements were identified, such deficiencies might result in a loss of Proposition III or Measure M funds to local jurisdictions with such deficiencies. The Draft EIR considers a number of such alternatives and concludes that they are infeasible. If the congestion and growth management plans slow build out of the general plans due to insuffi- cient transportation infrastructure (notwithstanding the construction of the Corridor), traffic demand could also increase more slowly. Demand would be expected to reach the same levels projected in the modeling for the Corridor, increasing to the build out level over a longer period. However, even if total demand in the interim period is less than currently projected, congestion on alternative routes would be expected to increase the Corridor's share of the total trip demand. Therefore implementation of the congestion and growth management plan is not expected to affect the need for the project. As described in the EIR/EIS, changes in land uses to achieve the transportation goals are unlikely because only 11 percent of the land in the area of benefit is not committed to an open space or development use. Therefore, these plans are not likely to result in changes in land use and consequent traffic genera- tion, and would not significantly change the need for the Corridor. 7-108-9 The Corridor is needed to provide acceptable mobility based on existing and proposed development. The current level of service on the 5, 405, SR-1 and 01/31/91(TCA9018%INDEXP) PN - 1 2 0 parallel arterials is unacceptable. The construction of the Corridor is needed to alleviate this existing situation which will only be further accelerated with future planned development in the no corridor scenario. Therefore, the slow down in current development due to the cyclical nature of the real estate industry does not remove the need for the project. 7-108-15 The alternatives of improving other facilities in lieu of constructing the SJHTC is thoroughly analyzed in Section 2.8 ("Alternatives Withdrawn From Consideration"). Please refer to the aforementioned section for further infor- mation regarding why improving existing facilities will not remove the need for the SJHTC. 7-109-9 Please see Responses to Comments 3-5-5 and 7-108-9 in this Chapter and Section 1.3 of the DEIR/EIS "Need for the Project". 7-119-2 Regarding the relationship of the project to Measure H and Measure M; please refer to Responses to Comments 4-22-19 and 7-56-1 in this Chapter. 7-123-1 HOV or carpool lanes are planned as part of the Corridor improvements. The project proposed is a toll road which will encourage people to carpool in order to reduce toll cost. Furthermore, coordination between the TCA and major employees such as Parker Hannifan through reduced tolls for vanpools can con- tribute to the success of Title XV. 7-140-3 Please see Responses to Comments 3-4-40 and 4-5-2 under Alternatives 7-82-16 under Project Description and 4-24-2 under Purpose and Need. 7-140-5 Please see Response to Comment 4-34-6 under Funding/Tolls and Exhibit 1 of this document. 0 01/31/91(TCA901B%INDEXP) PN - 1 3 7-141-2 In the design and environmental analysis, the TCA assessed the worst case traffic conditions for congestion, noise, and air quality. The worst case conditions are individually studied to indicate high volumes of traffic with resultant speed deterioration or low volumes with high speed control. Since facilities are built to accommodate more than the lowest hourly demand level, there is no need to analyze the off-peak periods. The commentator may wish to request specific data on traffic volumes from the State; however, the following data is taken from annual traffic census counts that have been conducted in Or- ange County. It is probable that temporal patterns of the census data will reflect the times in question: 9 p.m. to 6 a.m. Monday -Friday 10% ADT 9 a.m. to 3 p.m. Monday -Friday 20% to 4O% ADT Saturday 90% to 100% Weekday Sunday 75% Weekday Year 2010 SJHTC 0 9 p.m. to 6 a.m. Monday -Friday 9,000 to 16,000 trips per interval per day 9 a.m. to 3 p.m. Monday -Friday 20,000 to 65,000 trips per interval per day Saturday 80,000 to 160,000 trips/day Sunday 65,0000' to 120,000 trips/day The wide range of numbers illustrates that reason that these values are not in common use for engineering or environmental analysis. It should also be noted that the Demand Management Alternative was developed in response to the desire to minimize the overall size of the facility. The commentator also refers to periods of light traffic on the I-405 freeway. The comment does not define "light traffic" but it should be noted that cur- rently the freeway in south Orange County operates at or over acceptable levels for several hours a day. 01/31/91(TCA9018%iNDEXP) PN-14 19 0 REQUEST FOR DATA 7-4-1. 7-5-1 The property line of 27471 Maverick Circle is approximately 100 feet from the edge of the SJHTC right-of-way .and 11 feet below the Corridor. A sound wall is proposed between this property and the Corridor (approximately 15 feet from the rear property line). The proposed sound wail begins near Moulton Parkway at a height of ten feet and extends southerly between the Corridor and the residen- ces on Westridge Lane and Maverick Circle. The height of the wall may vary with the topography. The existing LEQ noise level at noise receptor location R28 (27151 Westridge Lane) listed on page 4-46 of the EIR/EIS, is 49 dBA without mitigation (noise wall). The predicted year 2010 LEQ noise level with the Corridor in place is 69 dBA at R28. Caltrans requires that noise abatement be considered if the additional noise from the Corridor will cause the noise level at the site to exceed 67 dBA or if it is 12 dBA louder then ambient conditions. Implementa- tion of mitigation measures will result in a 2010 LEQ noise -level of 63 dBA. The closest site to Maverick Circle where background (existing) air quality levels have been measured was 7 ppm (parts per million) for CO (carbon mono- xide) for a one hour reading and 4.5 ppm for an eight hour reading. With the Corridor in place the one hour CO concentration for the Maverick Circle area is predicted to be 10 ppm and the eight hour concentration is predicted to be 5.1 ppm. The Federal standard for the maximum one hour CO concentration is 35 ppm and the eight hour standard is 9 ppm. The State standard for the maximum one hour CO concentration is 20 ppm and the eight hour standard is 9 ppm. Neither the Federal or the State air quality standards, for maximum CO concentrations, are predicted to be exceeded in the Maverick Circle area with implementation of the Corridor. 7-4-3 The comment is unclear as to what is intended by "lights". Traffic signals will be installed at the interchanges. Traffic signals on the arterial roads in the community are under the jurisdiction of the County or City and these agencies should be contacted directly. Freeway lighting on the Corridor is described on page 4-129 with emphasis on the first paragraph which describes the goal of the lighting: to illuminate interchanges ramp plaza, etc. The Corridor will not have regularly spaced lights along its entire length. Your attention is also directed to third paragraph in the light and glare section 01 /31 /91(TCA901 B••. I NDEXR-T) RD - i 9 which addresses mitigation features which will be incorporated into the pro- ject. A plan of the Corridor was sent by separate letter. 7-4-4 The commentator will was sent a copy of the plan of the Corridor as requested. 7-8-1. 7-9-1 The distance from the commentator's rear property line to the nearest edge of the Corridor is approximately 70 feet horizontally. The Corridor is 40 feet below the elevation of the residence. 01/31/91(TCA9016%INDEXR-T) RD - 2 TRAFFIC AND CIRCULATION 2-10-2 The cost -benefit information relative to which alternative would be the best use of State funds need not be -added to the DEIR/EIS. The TCA will produce the cost/benefit analysis prior to CTC funding but outside the DEIR/EIS process. The DEIR/EIS contains the appropriate traffic forecast for build out of the Corridor relative to the environmental review process.; please see Section 5.0 and Technical Report No. 7 (Traffic Technical Studies, Traffic and Circulation Study, Toll and Toll -Free Traffic Projections, and South End Study). The TCA will commit to monitoring corridor traffic as a function of the Traffic Manage- ment System Plan and provide such monitoring reports to the CTC. The TCA prefers this approach because five year interval traffic projections contain a high error rate and do not reflect actual needs because demand for additional lanes will be more of a function of HOV pricing, implementation of other arte- 611 rial improvements, and the rate of development. Mitigation Measure T/C 5 has been expanded to read as follows: T/C-5 The TCA shall adopt a Traffic Management System (TMS) plan to in- crease the efficiency of the facility. The. goal of this plan is the development of administrative and operational procedures which can be applied during normal traffic conditions, as well as during incidents and emergencies. The TMS may include mainline detection, ramp meter- ing, television surveillance, variable message signing, a control center, and Corridor management procedures, as appropriate, which can be applied with hardware and software components. The system will be operated by Caltrans, with support and coordination with the Califor- nia Highway Patrol and the TCA. The TMS plan shall include a traffic monitoring report procedure which will result in the production of yearly reports to the SJHTC Board of Directors. The traffic monitoring reports shall report peak hour and ADT trips associated with Corridor operations. The purpose of the reports shall be to provide the SJHTC Board information on the actual traffic numbers associated with toll road operation and the need for improvements to insure proper operation of the facility. 01/31/91(TCA901B%INDEXR-T) T - 1 • 2-11-10 The TCA utilizes the Orange County EMA's transportation model and data bases. 2-11-11 These intersections were not included in the analysis because their projected traffic levels were not significantly affected with or without the Corridor. 3-2-5. 3-2-6. 3-2-11, 4-31-17 The TCA is committed to realigning Ford Road northerly of its existing align- ment. TCA commitment to this mitigation project includes: the preparation'of a separate Environmental Impact Report (a public scoping meeting was held on December 12, 1990), preparation of Construction Plans, Specifications and Esti- mates meeting the requirements of both the cities of Newport Beach and Irvine, the construction of the new Ford Road from the Corridor to MacArthur, including indirect connector roads (accommodating minimized through traffic) between the existing and realigned facility and funding of all of the above features. 40 The TCA has configured the Corridor in accordance with the Master Plan of Arterial Highways. The MPAH does not have a connection of San Joaquin Hills Road to the Corridor and the TCA does not intend to promote a connection. Connection of San Joaquin Hills Road to Pelican Hills Road is not within the jurisdiction of the TCA, and it is not our intention to influence the member agencies' plans for the connection. The TCA will commit to coordination with the City to identify appropriate viewshed requiring the transparent noise barriers. See Response to Comment 3- 2-8 under Visual Resources which adds Mitigation Measure 15-24 about potential use of transparent barriers. The TCA is committed in its design to minimize siltation impacts on Newport Bay. The precise details of this mitigation will be determined in meeting with the appropriate regulatory agencies (e.g., Army Corps of Engineers, California Department of Fish and Game, California Regional Water Quality Control Board, County Flood Control District, etc. and the City). The construction speci- fications will be worded to require construction of these facilities in a sequence which captures and mitigates the temporary construction impacts of the Corridor. The TCA has convened an Ad Hoc committee and special technical subcommittee to report on the funding responsibilities for a series of projects which extend 01/31/91(TCA9018%INDEXR-T) T - 2 0 r� u northerly beyond the logical termini of the San Joaquin Hills Transportation Corridor project. The technical subcommittee using traffic impacts/benefits as a guideline established the matrix of reasonable funding responsibilities for these projects (known generally as the Costa Mesa Confluence Projects). The missing ramp connector at SR-73/SR-55 is part of these improvements. In June of 1990, the TCA took the initiative of budgeting $13.2 million toward the aggregate of the Costa Mesa Confluence (this amount being the sum of fund- ing responsibilities determined in the attached matrix). The TCA is committed to and looks forward to continued cooperation on this project, which is now under the direction of the Orange County Transportation Commission. Environmental clearance for the confluence has been obtained or will be com- pleted by several other agencies. Environmental Clearance for the SR-73/SR-55 has been obtained by Caltrans. 3-4-6. 3-4-36, 3-4-50, 3-4-51, 3-4-52, 3-4-53, 3-4-54, 3-4-105, 3-4-107, 3-6- 24, 3-6-68 In general, when traffic models are prepared it is not possible to have a model which precisely forecasts both regional and local traffic. The limitations to this expectation have to do specifically with the.amount of detail that can be accommodated in representing finite connectors from the centers of zones to the highway network. While high speed computers are practically capable of han- dling the enormous amount of detail required, human ability to inventory and maintain this information on both a regional and local level is limited. Consequently, the TCA has utilized a model which is most appropriate for the Corridor and main arterials. In areas where greater detail is required it is common practice to augment a regional study with a focused study. In the specific case of the SJHTC and the I-5 connection, the SJHTC South End Study was provided to fulfill this goal. On traffic studies of facilities such as the Corridor there will be anomalies. It has been TCA's view that the most professional way to handle these matters is to display them just as they appear in the model, rather than adjust them. Not withstanding this disclosure, some of the City's observations of obvious errors may not be correct. Specifically, it is admittedly surprising (at first glance) that La Paz Road at the I-5 freeway will have less traffic in the future than existing counts. But when one considers that the area bounded by Alicia Parkway, SJHTC, Oso Parkway, and I-5 is fully developed, it becomes reasonable to observe that the traffic from the area will not be drawn in only one direction (in the future) to the I- 0 01/31-/91(TCA9018%INDEXR-T) . T - 3 i 5; on the contrary, this subarea is now served by two freeways, I-5 and SJHTC. Since the land use has matured, the existing traffic volumes on La Paz (approx- imately 15-20,000 ADT) will still occur, but will tend to split between I-5 and SJHTC. The resultant relief at La Paz and I-5 is probable. The explanation provided above should be reviewed by your traffic consultant using recent aerial photographs (available from the TCA) which show the mature character of development in the subregion. As to volumes on Crown Valley Parkway, Paseo De Colinas, etc., we recommend use of the intended (focused) South End Study, which is shown in the Technical Studies supplement to the DEIR/EIS. Disparities between local and regional traffic model numbers will not change the cumulative impact analysis because the overall average daily trips for the region are consistent and the discrepancies only result in lower or higher ADT numbers on various arterials, as proven by screenline analysis. In general, it has been TCA's policy to size its facilities to the most conser- vative data available. In the specific area of the Corridor/I-5 connection the volumes in the South End Study will be utilized for design. ;10 The discrepancies between the Corridor model and the focused model would have to be very large and occur over several arterials in order to cause a signifi- cant difference in environmental impacts. Additionally, all of the discrepan- cies would have to be in the same algebraic direction for the impact to change in a cumulative fashion. TCA's review of the modeling data indicates that this is not the case. As discussed in Response to Comment 2-10-2 in this Chapter, the TCA will commit to monitoring traffic as a function of the Traffic Manage- ment System Plan. This will insure proper operation of the facility. 3-4-17 Additional access to Camino Capistrano (other than Via Escolar) will be pro- vided as identified in Mitigation Measure 17-23a (with implementation of Alter- native #2). See Response to Comment 3-4-14 under Fiscal Impacts. 3-4-48 Volume II of the Technical Studies attached to the DEIR/EIS contains intersec- tion capacity analysis, ramp volumes, and arterial volumes for the Paseo De Colinas connection to the Corridor along with similar data for a number of interchanges in the Route 73 to I-5 connection area. The large volume of traffic data in Volume II may have made this data difficult to locate; for the commentator's quick reference, the information sought follows page D-2 of the SJHTC South End Study. The specific section is labeled "Turn Movement and 01/31/91(TCA9018%INDEXR-T) T - 4 18 Intersection Capacity Utilization Summary," and contains approximately 80 pages of tabulated analysis for 27 interchanges/intersections in the area of SJHTC to I-5 connection. The analysis includes existing data (where appropriate), and forecast data. Paseo De Colinas has existed on the MPAH since 1972 (as a secondary arterial highway). As the Corridor has evolved, the arterial has changed; commensurate with its role in circulation. Specifically, in 1978, Paseo De Colinas was up graded from a secondary arterial highway to a primary. A primary is capable of carrying traffic volumes in the range of 20,000 to 30.,000 trips per day. The forecasts for this arterial highway (under either Option #1 or (Option #2) are within this range, and no additional analysis is required. Intersection analy- sis of Paseo de Colinas is addressed in the focused South End Traffic Study, as appropriate to the option under consideration. 3-4-49, 3-4-108 The City's attention is directed to the very low design hour volumes shown in the SJHTC South End Study. These ramps are not warranted from a traffic or economic standpoint. Notwithstanding this data, there is sufficient right-of- way to accommodate a full diamond if future traffic warrants such a design. Through the traffic monitoring program outlined in Response to Comment 3; 4-14. under Fiscal Impacts, if need is identified these improvements can be autho- rized by the TCA Board, subject to CEQA, NEPA and Caltrans-requirements. The focused model, (South End Traffic Study), included modeling of the full diamond interchange. The fact that very low design hour volumes on the south - bound on -ramp and northbound off -ramp result from that model indicate that traffic relief for Crown Valley Parkway is a function of the Corridor/I-5 Freeway option selected, not the diamond ramp configuration at Greenfield. 3-4-54, 3-4-106 The TCA has met with representatives of the respective cities to reach consen- sus on design volumes used for ramps; it appears that the commentator is not aware of that process. The TCA, in cooperation with the member agencies is developing a policy to address resolution of conflict between different models. 3-4-68 The toll revenue generation required to support the Corridor has been analyzed on the assumption that attractive, free, parallel routes will impact the usage of the Corridor. The analysis shows the Corridor is economically viable. The 01/31/91(TCA9016%INDEXR-T) T - 5 fact that most of the revenue is collected during peak periods does not change the fundamental conclusions: 1. That the Corridor is relieving congestion; and 2. That the Corridor is economically viable. The overall balance of the transportation system is achieved by the user's choice of the most efficient route (i.e., the route with the least congestion and best travel time). The toll system and TMS will allow the TCA (and its member agencies) to insure the greatest contribution of the SJHTC to the over- all balance of the transportation system. Regarding design and non -peak use, see Response to Comment 4-31-5 under Purpose and Need. 3-4-75 The TCA is funding the connections between the Corridor and local arterials. These costs are included in the construction estimates for the build alterna- tives. Construction costs associated with turn lanes and signals and similar local arterial improvements associated with the Corridor connection will be borne by the TCA. 3-4-109 Toll plaza locations are shown on Figure 2.5 of the DEIR/EIS. Southbound Corridor traffic cannot escape without paying a toll at the southbound Green- field because this traffic would have paid a toll at a mainline, southbound on - ramp or collector distributor ramp. Consequently, the postulated diversion cannot occur. 3-4-110. 3-4-111 Volume II of the Technical Studies attached to the DEIR/EIS contains a detailed analysis (South End Study) of the traffic impacts of indirect access to the Corridor. The impacts are most apparent on the Crown Valley Parkway arterial link southerly of I-5 as shown in Figure 3 specifically as a comparison of Option 1 and Option 2 ADT volumes. The TCA has studied alternatives to Option 1 and Option 2 which included: 01/31/91(TCA9018%INDEXR-T) T - 6 1. Ramps from Corridor alignment #1 to Paseo De Colinas. Alternative dropped due to unsafe geometry. 2. Lowering the Corridor under Paseo De Colinas. Alternative dropped because it could not achieve adequate design speeds and because of potential geotechnical impacts to.adjacent residences. 3. Relocation of the AT&SF Railway (to relieve profile geometry problems). Alternative dropped because it involved lowering the railroad more than ten feet into a 100-year floodplain, or it involved horizontal shooflies which had geotechnical impacts to adjacent residences. Through the preliminary design, TCA's section engineer has studied the alterna- tives listed and a Technical Memorandum is'available from the TCA. It is the engineering judgement of the TCA/CDMG professional staff that no other feasible or reasonable alternative exists. 3-5-30. 3-5-36, 3-5-64, 3-5-66 The area of greatest impact/benefit related to the Corridor is the south Orange County Subregion. Therefore, it is appropriate for the study area to reflect this relationship. The area of benefit/study area was derived by including all traffic zones which received more than 2% of origin or destination from the traffic links of the Corridor. The Major Thoroughfare and Bridge Fee Program Manual provides a further description on the zonal contribution of traffic. To expect a regional transportation facility not to experience a certain degree of regional through traffic is unrealistic. The 20% regional through trips repre- sent a minuscule percentage of the trips already generated in Los Angeles or San Diego Counties. The development of the SJHTC will not increase/decrease the amount of existing through trips nor in and of itself alter land use pat- terns outside of the study area. For further explanation of the study areas evaluated, see Response to Comment 3-5-31 under Cumulative Impacts. The traffic forecasting model used accounts for traffic both north of and south of the County boundaries. The data from these areas is considered by using larger zones. The model used and previous traffic analysis have shown that the Major Thoroughfare and Bridge Fee descriptions of the Area of Benefit are such that they encompass trip making zones down to about two percent of Corridor link volumes. 9 01/31/91(TCA9018%INDEXR-T) T - 7 3-5-39, 3-5-52 a. b. c The Chapter II extract from "Traffic Calming" is an opinion paper on a subject that has been written about extensively for 25 years. The opinions expressed there are generally not new, and represent only one of the wide diversity of opinions that are expressed on this subject. The paper has little relevance for the EIR/EIS. Traffic planning in Southern California evolved from public and private professionals working together to refine goals, establish objec- tives, and such means of implementing these goals and objectives. It is a participatory process which typifies planning in the. USA, and is not always found in other countries (the referenced paper is discussing Brisbane, Austra- lia). The prestigious Urban Land Institute in the USA has recently released a more relevant (and factual) document entitled "Myths and Facts about Transpor- tation and Growth" which strongly refutes many of the opinions expressed in the CART paper. This document is contained in Attachment 5 of this Response to Comments. See Response to Comment 3-5-5 under Purpose and Need. Regarding the applica- bility of planning documents, see Response to Comment 4-33-13 under Alterna- tives. Regarding travel modes/technologies, see Response to Comment 3-5-7 under Alternatives. 3-5-47a-g. 3-5-53a through 3-5-53g. 3-5-58 The following is a general response to the issues raised in the article "Traffic Congestion and Capacity Increases." The article critiques the method- ology used to forecast future regional traffic volumes in the San Francisco Bay Area. The forecasting methodologies that are used in the Orange County area are somewhat different than those used in the Bay Area, and the alternative transportation systems differ between the two regions; therefore the specifics of the critique are not all applicable to the traffic volume forecasts used for the SJHTC DEIR. However, the general thrust of the critique can be restated in terms that apply to the Corridor and transportation planning in general. The basic thesis of the article is that the forecast traffic volumes, as applied to a new transportation facility such as the San Joaquin Hills Cor- ridor, are inaccurate because they do not correctly model human responses to traffic capacity increases (primarily due to latent and induced demand). The paper goes to great lengths to prove the obvious: traffic forecasts, like all predictions of future human behavior, are less than 100% percent accurate. Traffic modelling attempts to predict how drivers will respond to alternative circulation networks that may be available in the future. Such models are 01/31/91(TCA9018%INDEXR-T) T - 8 • inherently limited by the accuracy in which the modeler can forecast the fac- tors determining traffic volume, including future land uses, demographics, trip generation, alternative transit availability, the tolerance of commuters for traffic congestion, and the balance of jobs and housing. Notwithstanding the inherent complexities of any modeling effort, the traffic modeling used for the Corridor is the best available, and provides a planning tool of sufficient detail for accurate Corridor design and decision making. 1. The Lead Agencies have obtained the best possible model of environmental consequences that can be obtained. In the case of the Corridor, the best available traffic models are the Orange County Environmental Management Agency's (EMA) OCTAM I and OCTAM II models. These models are the most comprehensive regional models available to the TCA. These models forecast travel demand based on factors that have been calibrated to accurately reproduce existing traffic patterns. These same factors are then applied to future land use and other socioeconomic conditions to produce future traffic conditions. 2. The accuracy of the model is commensurate with the precision of the deci- sion to be made. For example, a change in traffic forecasts of 10% to 20% would not change the conclusion that the Corridor was needed or even that the scale of the facility should change. Roadway capacity increases come in large amounts; i.e. adding a lane in each direction to a six lane freeway results in a 33% increase in capacity. In this case, the smallest possible increment of capacity increase (33%) is greater than the preci- sion of the model (10% to 20%). Therefore, the build/no build decision and the scale of the corridor are relatively independent of the limita- tions of the model. 3. The design of the facility should provide future decision makers with wide latitude to modify the facility to deal with changing conditions. Given that the future is not 100% predictable, a transportation facility should be designed so that additional or alternative improvements can be accom- modated if the forecasts are not borne out. In the case of the Demand Management Alternative for the Corridor, the median area is reserved for a number of future options that can be selected once more information is available. These options include HOV lanes, reversible HOV lanes, and transit. The "Traffic Congestion and Capacity Increases" paper makes a number of criti- cisms of traffic forecasting in the Bay area that would also apply to traffic forecasting in Orange County. Any modelling effort can be improved. The paper 0 01/31/91(TCA9018%INDEXR-T) T - 9 0 points out the limitations on the accuracy of current modelling techniques, but provides little guidance as to how to improve the models; it provides no cita- tions showing that such changes in the model would actually result in more accurate traffic forecasts. The paper discusses at length two aspects of transportation demand that are often not taken into account in traffic modelling: "latent demand" and "in- duced demand." Latent demand is existing demand for use of a transportation facility that is not actualized (at least at peak hours) because potential users are discouraged from using a congested facility. Latent demand is addressed in Response to Comment 1-2-3 under Purpose and Need. Regarding driver responses to congested conditions, the comment seems to be implying that the only appropriate way to attain regional transportation goals is to force gridlock and hope that this unpleasant situation will convince drivers to resort to demand management strategies. Unfortunately, the strategy of relying on congestion to reduce vehicle miles traveled has not proved successful in the past. While congestion on Orange County freeways has steadily increased each year, the number of vehicle miles traveled has also continued to increase. Another issue cited in the paper is "induced demand"; that is, new demand for a transportation facility that is a result of implementation of the facility. Such induced demand is seen in land use changes that can occur as a result of a new facility being completed. For example, in the absence of other cons- traints, widening a roadway can spur additional development along the roadway corridor. The County's models of the Corridor traffic volumes do not include induced demand as a factor. As noted on page 6-2 of the Draft EIR (the Guil- iano paper), existing research on induced demand does not provide any reliable models which can quantify such an effect. Other factors, such as economics and politics, appear to have a greater influence on land use and development deci- sions than the provision of new transportation facilities. While it is possible that provision of some new transportation facilities may induce additional demand (in a way that cannot be forecast), the converse is clearly untrue. Transportation facility demand, at least in California, con- tinues to increase whether new facilities are constructed or not. This is best shown by the increase in travel demand in the South Coast Region over the period between 1986 and 1989. While only 8.6 miles of new State highways were constructed (a 0.2% increase), actual vehicle miles travelled on the State 01/31/91(TCA9018%INDEXR-T) T - 1 0 • highway system increased by 22%1. Growth occurred in the South Coast Region despite the lack of new transportation facilities or alternatives. As specifically applied to the Corridor Area of Benefit, there is a very limited supply of buildable land that is not already committed to a specific land use. As noted in the Draft EIR on page 6-9, 56.5% of the land in the Corridor Area of Benefit is already developed and 42% of the remaining land is planned through committed development agreements or other vesting techniques which cannot legally be changed. In exchange for the development agreements, the County exacted a number of transportation improvements, open space commit- ments and public facilities from proposed developments which could not other- wise be funded. Over 98% of the land in the Area of Benefit already has a committed land use, and there is very limited opportunity for induced growth or induced demand to occur. 3-5-48. 3-5-119 • The project would assist in achievement of the goals of the California Clean Air Act because of the following: (1) Tolls will, by definition, provide a market incentive for increased rider- ship per vehicle; (2) In the year 2010, HOV users would achieve both a time saving and a cost saving by carpooling; (3) Under the Demand Management Alternative, the size of the Project has been deliberately constrained to encourage increased ridership per vehicle and to ensure that the Project does not stimulate additional growth beyond that contemplated by the regional and local growth management plans and general plans. The project has been designed to accommodate volumes with 30% HOV use, which translates to a vehicle occupancy rate of 1.5. (4) HOV usage will be encouraged by design features of the facility, including the provision of direct HOV access ramps. In addition, the TCA expects to participate in regional transportation systems management projects includ- ing the use of express buses and ride sharing. 'Source: Caltrans, Travel and Related Factors in California, 1986 and 1989 Annual Summaries 01/31/91(TCA901&:INDEXR-T) T-11 It is also important to note that incentives to achieve an average vehicle occupancy rate of 1.5 persons by 1999 have been developed by the SCAQMD as part of Regulation XV. Further incentives are being implemented by employers to meet Regulation XV. It is also important to note that provisions of the Cali- fornia Clean Air Act require achieving an average vehicle occupancy rate of 1.5 by 1999. AQMP goals and measure to increase Average Vehicle Ridership include the fol- lowing: Alternate work weeks, flextime, telecommuting, employer rideshare and transit incentives, vanpool purchase incentives, provision of facilities (bicy- cle racks, lockers, showers) to support bicycling and pedestrian activity, parking management, transit improvements, merchant transportation incentives, auto use restrictions (SCAG Guidelines for the Development of Local Air Quality Elements, March, 1990). If current Regulation XV requirements are not sufficient to reach Average Vehicle Ridership (AVR) goals, the AQMP calls for SCAQMD to expand Regulation XV requirements to lower employer threshold sizes (to apply the regulations to • smaller companies). The incentives and methods to achieve average vehicle occupancy of 1.5 persons have been implemented by a substantial number of local jurisdictions and agen- cies within the South Coast Air Basin. 3-5-54 Again, the doctrine pursued by Exhibit 6 is not relevant to the planning that has occurred in south Orange County. In fact, due to the link between develop- ment intensity and transportation infrastructure, this facility is desperately needed, not to allow for future growth (98.5% of the study area is built, has approved development plans, or is reserved in open space) but to respond to an existing situation. 3-5-59, 3-5-60 The EIR/EIS does not assume 1.5 persons per vehicle, rather it analyzes both an optimistic and a conservative percentage HOV use scenario. The optimistic HOV use scenario of 30% is approximately 1.5 persons for each vehicle. The use of 1.5 persons per vehicle as one scenario is not faulty or unsupported. Rather, since a 1.5 average Vehicle Ridership is mandated by both AQMD and the Califor- nia Clean Air Act, this scenario is consistent with regional air quality plan- ning. 01/31/91(TCA901B%1NDEXR-T) T-12 0 The assumption that other regional road projects will be completed is not a faulty or unsupported assumption. The comment is not specific as to what changes to the MPAH should be assumed. The MPAH and the project are part of a region -wide network of transportation improvements included in the SCAG Regional Mobility Plan (the "RMP"). Overall, the RMP is intended to prevent further deterioration of traffic conditions in the region by modest increases in new highway capacity and a strong commitment to transit systems (including HOV). The RMP represents the professional judgment of the Regional Planning Agency of the mix of transportation systems which are necessary to reduce congestion and thereby assist the region in meeting State and Federal air quality goals. Therefore, assumptions of future roadways utilized in the DEIR/EIS are reasonable. 3-5-61 Traffic forecasting is subject to statistical variation, as is any procedure involving numerical data (including traffic counts). There is no such measure as a "rate of error," and statistical variation in traffic forecast data is a complex subject involving many factors such as reliability of input assumptions (land use, for example), simulation algorithms embodied in the modeling pro- cess, and subjective variables that affect driver behavior but which cannot be modeled. The data used in this report are from the South Orange County Traffic Analysis Model (SOCTAM). Produced by Orange County EMA, this model produces long-range traffic projects which have been used for a variety of applications in this part of the County, including corridor analysis, and the data are considered adequate for analyses such as these. An analysis of potential error rates would be speculative. The commentator is also referred to Response to Comment 4-5-6 in this Chapter. 3-5-62 Traffic data for the year 2010 is used in the EIR/EIS because the General Plans for jurisdictions in the Area of Benefit for the Corridor assume build out within 20 years and prudent environmental analysis procedures support the use of a 20 year planning horizon. The use of year 2010 traffic data is also consistent with Caltrans data requirements for environmental documents which address transportation projects. 3-5-63 The comment is unclear about which data need to be correlated. The traffic data used in the DEIR/EIS are derived from SOCTAM, which in turn is based on 01/31/91(TCA9018%INDEXR-T) T - 1 3 0 Orange County preferred 1988 (OCP-88) set of land use assumptions, which is the best available information. For further explanation of modeling differences, see Response to Comment 3-4-6 in this Chapter. 3-5-67 It is acknowledged that transportation model databases need to be updated periodically. However, this does not automatically support the conclusion of the comment that air quality improvements are overestimated and unsupported. Exhibit 7, page 6, calls for a new origin and destination survey after the 1990 census. It also states that the subsequent modeling effort "may" lead to modifications in the 1994 AQMP update. Exhibit 7 does not support the comment. SCAG has commented on the DEIR/EIS (Comment Letter 3-3). The comments from SCAG do not reflect the concern brought up in the comment. The traffic model utilized in the EIR/EIS is adequate for the traffic and air quality modeling associated with the project. 3-5-116 2010 is the horizon year for County and regional planning, including the MPAH. The County is responsible for implementing the MPAH, except for the* three transportation corridors, which will be implemented by the TCA. The funding sources that will provide for implementation of the MPAH are a combination of private development exactions and fees, state gas tax subven- tions and federal road program funds. 3-5-130 The methodology outlined in Exhibit 6 of the comment is a traditional approach in common use throughout the United States and is basically the same as used in the DEIS/EIS. The only difference is that the model used by TCA did not employ a mode choice model. The reason for this is the significantly different tran- sit mode split in the Bay area compared to Orange County. Since the process outlined in Exhibit 6 is basically the same as that used in the DEIS/EIS, the results would be comparable. 01/31/91(TCA901B%INDEXR-T) T - 14 • 3-6-19. 3-6-20 Comment 3-6-19 provides background information to comment 3-6-20; no further response is necessary. Please refer to Response to Comment 3-6-18 under Pro- ject Description. 3-6-21 The TCA in response to previous Issues Inventory items commissioned the SJHTC South End Study to address precisely this comment. The City of Mission Viejo was allowed to input, review, and approve the study and the TCA has committed to design using the results from this study. The SJHTC South End Study was commissioned to address the comments noted. The City of Mission Viejo participated directly in identifying the scope of the study. The study contains forecasts of future traffic volumes along key arterials and intersection capacity analysis at twelve intersections in the City of Mission Viejo or at its boundary. Of the I-5 connection alternatives, Option #1 proposes no change to the access in Mission Viejo; while option #2 (by proposing construction westerly of the existing I-5 freeway) would improve city access. Intersection analysis at the following locations were intended to address the local access conditions: Location Intersection Analyzed 1 Camino Capistrano/Avery Parkway 2 Avery Parkway/I-5 NB Ramps 3 Avery Parkway/I-5 SB Ramps 4 Marguerite Parkway/Avery Parkway 14 Crown Valley Parkway/I-5 NB Ramps 15 Crown Valley Parkway/I-5 SB Ramps 16 Oso Parkway/I-5 NB Ramps 17 Oso Parkway/I-5 SB Ramps 18 Camino Capistrano (Marguerite)/Via Escolar 24 Crown Valley Parkway/Medical Center Road 25 Marguerite Parkway/Crown Valley 26 Cabot Road/Oso Parkway 27 Marguerite Parkway/Oso Parkway 01/31/91(TCA9018%INDEXR-T) T - 15 0 3-6-23 The observation that the TCA is funding portions of local circulation improve- ments in Newport Beach, Irvine and Costa Mesa is incorrect. Specifically, the local agencies of Irvine, Costa Mesa, Newport Beach, and the County are inves- tigating funding of a regional State facility (not local improvement). 3-6-36, 3-6-91 The comment is correct. The comment is a clarification which does not change the conclusion of the EIR/EIS and is hereby incorporated into the Final EIR/EIS. 3-6-42 The SJHTC South End Traffic Study has been identified as a focused study which will be relied upon for design at the I-5 connection. 3-6-52 0 The northbound ramp was inadvertently left off Figure 5-2. The most -conserva- tive traffic volume on the ramp is 10,150 ADT. The source of this ramp volume is TCA engineers correlation between toll and toll free volumes, as described, in Technical Report No. 7, Toll and Toll Free Traffic Projections. 3-6-53 See Response to Comment 3-6-30 under Section 4F. The comment describes in- tended action with the City. 3-6-61 The exhibits are correct as labeled. The HOV label refers to the single con- current flow HOV lane included with the conventional alternative. 3-6-62 Comment noted; the report is now final. 01/31/91(TCA9019%INDEXR-T) T - 1 6 0 3-6-63 The AM peak hour volumes northbound south of the confluence have been misprint- ed. They should read 13461 in lieu of 3461. This mistake has occurred typi- cally on the exhibits noted and will be corrected. 3-6-66 The TCA is committed to developing an assessment matrix based on criteria which meets the consensus of the cities. This matrix will be presented to the Board for use as part of the decision making process. 3-6-67 See Response to Comment 3-6-42 in this Chapter. The focused SJHTC South End Study provides the traffic volume estimates and is intended for arterial high- way design/mitigation purposes. 3-6-70 By its incorporation into the Technical Studies, the traffic impacts (Intersec- tion Capacity Analysis) described in SJHTC South End Study are part of- the DEIR/EIS and will be considered by the TCA Board of Directors.- 3-6-76 The DEIR/EIS does not presuppose a DMC correlation with only alternate #2 (and conventional correlation with only Alternate #1). The commentator is referred to page 2-23 of the DEIR/EIS. The only option not under consideration is a conventional width corridor along alignment Option #2. This option was not carried forward because the width requirements could not be accommodated while maintaining an Avery interchange with full ramps. 3-6-77 The selection of an I-5 connection Option is not significantly limited by the choices given in the EIR. The geometric problems of conventional with Option #2 are reinforced with even greater economic impacts than the DMC and conse- quently it is extremely unlikely that this alternative would have support. The commentator's observations were made on a screencheck document and DEIR/EIS has been changed to describe the available options. See Response to Comment 3-6-2 under Project Description. 01/31/91(TCA9018%INDEXR-T) T - 1 7 3-6-78 The focused SJHTC South End Study was commissioned specifically to address these comments and it is recommended that these volumes be used in lieu of the data shown on Figure 1.3.1. (It is assumed that the commentator's reference to Figure 1.5.1 [now obsolete] is intended to apply to Figure 1.3.1). 3-6-79, 3-6-80, 3-6-82 The SJHTC South End Study was a focused study intended to provide greater accu- racy and its results should be used where conflicts such as those cited exist. See Responses to Comments 3-4-6 in this Chapter. 3-6-86 The MPAH has sized the arterial highway network to feed traffic to the Corridor and accept traffic from the Corridor. The impacts postulated have actually been addressed by the evolution of these streets since the Corridor was adopted is on the MPAH. 3-6-89 Comment noted. 3-6-90 Table 1.3.A has been incorporated into the DEIR/EIS since the screencheck and this shows the approximate LOS noted by the commentator. 3-6-92 The comment addresses a figure that was not included in the DEIR/EIS. The commentator is referred to 1.3.A which depicts updated data. 3-6-105 The page and figure number do not correspond to the DEIR/EIS. Figures 5.1 and 5.2 are readable and provide the information requested regarding traffic dis- tribution. 01/31/91(TCA901B%INDEXR-T) T-18 0 3-6-106 Figure 5.3 of the DEIR/EIS includes an inset which displays the location of the screenlines. 3-6-109 The focused South End Study provides the data requested to the extent of insur- ing the City that the interchange will operate within reasonable capacity ranges. The Technical Studies Volume II with its LOS analysis demonstrates the Corri- dor's ability to alleviate congestion. As to the congestion on I-5, improve- ment of I-5 with HOV lanes (in the future) and the development of the Foothill Transportation Corridor are projects which will relieve traffic congestion on I-5.- 3-7=48 The I-5/Ortega highway interchange is analyzed in the SJHTC South End Study and found to operate in a satisfactory manner. The FTC, a parallel route, will also provide traffic relief on I-5. 3-8-4 Section 5.0 Traffic and Circulation of the DEIR/EIS provides a discussion regarding the impact of toll operation on 2010 traffic volumes. This discus- sion begins on page 5-8. 3-8-5 The traffic and revenue study conducted by Wilbur Smith and Associates includes an elasticity curve which demonstrates that due to heavy congestion on parallel free facilities and above average incomes that the area of benefit for the SJHTC shows the least sensitivity to tolls. 3-8-6 Truck traffic on the SJHTC is included in the DEIR/EIS as a worst case analysis given the difficulty in banning truck traffic from using the Corridor. If the City of Irvine is desirous of pursuing such a ban they should use their ability as a Member Agency to service this issue through the TAC and the Board of Directors. 01/31/91(TCA9018'•INDEXR-T) T - 19 3-8-8. 4-31-16 Culver Drive extension currently exists on the MPAH and for that reason it is shown on our planning documents. We have designed the project to be compatible with the City's deleted link while planning the Pelican Hill Road Interchange to be capable of conversion if the Culver Drive link is restored to the MPAH. Comments by others have requested information on the potential link and it has been shown for that reason. The Michelson Drive extension is also shown on the County MPAH. The City is currently working through a cooperative process with the County to resolve these inconsistencies. 3-8-10 The TCA believes that the volume of truck traffic will be extremely low due to grades and/or tolls and that the normally designed features used by Caltrans and incorporated into the Corridor will be adequate. These design features include deeper pavement sections and climbing lanes where grade and traffic volumes warrant. 3-8-15 It is not financially feasible to fund HOV construction with the first phase of construction. HOV traffic generally is triggered by service volumes that approach capacity and this is another reason for delaying HOV construction. The observations offered will be inventoried and considered in TCA's future pricing strategy; but they are not directly applicable at this time. 3-8-103 Please see Exhibit 1 of the Response to Comments Document for information regarding reserve estimates. 3-8-104 The analysis referred to is a review of the screenline traffic numbers provided in Figure 5.3 of the DEIR/EIS. 3-8-106 The clarification in the comment is hereby included in the Final EIR/EIS. 01 /31 /91(TCA9018••• INDEXR-T ) T- 20 0 0 3-8-107 The SR-1 links have been removed from Table 1.3.A because they were duplicative of Pacific Coast Highway volumes on Table 1.3.C. 3-8-110 through 3-8-140 In the listing of comments provided, a number of highway links are cited as being in Table 1.3.0 but not on Figure 1.3.1. The exhibits are meant to be used in conjunction with the tables. It is not practical to display the traf- fic Area of Benefit (AOB) on the 11 x 17 size of Figure 1.3.1 and maintain legibility. Additionally, certain volumes are in conflict and will be corrected. More generally LOS calculated are compatible with the more generalized MPAH. If the City's Master Plan does not conform to the consensus MPAH, LOS will vary, consequently a footnote will be added to the Table to indicate the dif- ference. 3-9-17 Comment noted. 3-9-18 The only post Corridor construction phasing presently under consideration is an interchange with the future Sand Canyon Avenue, and the addition of HOV lanes when traffic demand warrants and funding becomes available for HOV construc- tion. The Corridor is expected, at opening day, to operate at level of service (LOS) C or D and have substantial traffic volumes in all six lanes (three lanes in each direction). Benefits associated with the Corridor will be present on opening day of the project. Chapter 5 also provides a discussion and analysis of opening day (1995) traffic conditions and impacts. 3-9-19 Figure 1.3.1 of the EIR/EIS shows the projected ADTs for arterials adjacent to the Corridor. The few arterial segments where traffic would increase when compared to the no Corridor scenario are those segments at interchanges with 01/31/91(TCA9018%INDEXR-T) T - 2 1 the Corridor. The interchanges are being designed to operate at LOS D or better assuming all facilities shown on the 1989 MPAH. During the evolution of the Corridor, the County has upgraded arterials serving the SJHTC as required by their traffic forecasts. The increases in traffic mentioned are increases from existing volumes, and do not necessarily indicate a need to change the MPAH. 3-9-20 Project phasing is structured to allow for Corridor improvements to occur, such as the addition of HOV lanes, as traffic demand warrants and funding becomes available. This method of project phasing will allow the Corridor to be ini- tially constructed with three general purpose lanes in each direction while also allowing for future expansion of the facility to accommodate projected increases in traffic volumes. 3-9-21 Access to Coyote Canyon Road will be provided through the Ford Road Realignment project which has been initiated by the TCA. 3-34-2 HOV (carpool) lanes on the Corridor will offer people who are willing to carpool not only a time savings but will also allow them to save money by sharing the cost of using the Corridor. Additionally, the use of HOV lanes allows the width of the Corridor to be narrower and have fewer environmental impacts, while still providing an adequate level of service for peak traffic hours. Further, HOV lanes constructed on other Orange County highways such as the SR-55 and I-405 have proved successful. 4-5-6. 4-5-7. 4-20-10, 4-20-11 Traffic forecasts for the Corridor are made by a procedure which is in common use by the planning and engineering professions in this country. This process is known as modeling. In a traffic forecasting model, specific trip making characteristics are represented by mathematical formulas and processes which convert raw data (land use population, employment, and road network geometry) into tabulations which describe travel volumes on specific routes. In the most fundamental forecast, the following elements must be available before a travel projection can be made: 01/31/91(TCA901B%INDEXR-T) T - 2 2 0 1. Trip Generation Model This model answers the fundamental question "how many trips are created in a specific zone" (such as a residential area or shopping area). It is important to understand that trip generation models do not identify where trips desire to go, nor do they describe specific routes for the generated traffic. The building blocks (raw data) for trip generation models are the Land Use Plans adopted by the County of Orange and each of the cities. These Land Use Plans describe what the local agencies will permit in the future (year 2010; in the case of the Corridor). 2. Trip Distribution Model This model determines which zones in the study area have destinations for the trips produced in the Generation Model described above. Trip distri- bution apportions generated traffic to specific zones by accounting for the distances between the generation point and the destination. Zones with small separation distances receive a lot of the distribution, while zones with large separation received smaller distribution; traffic is also apportioned by accounting for the "attraction" of an area. Generally, the attraction of a zone is related to its ability to draw employment or shop- ping. Large employers have high work trip attractions; similarly, large malls attract a lot of shopping trips. The trip distribution model is used to apportion work trips, shopping trips, business trip, etc., from the generation zone to all other appropriate zones. Mathematically, the possibilities encountered in trip distribution are huge, and high speed computers are required to determine all of the possibilities. At the end of the trip distribution process, the number of trips generated from a zone are known and the destination for the trips is determined but a travel route has not been selected. 3. Route Assignment Model This model analyzes the most efficient routes to carry generated traffic from its origin zones to the destination determined by the trip distribu- tion model. The route assignment model systematically tests a very com- plicated road network in the study area to find the shortest route. The shortest route can be defined by time or distance. The route assignment model considers the size (carrying capacity) of each route, and assigns more trips to highways which can have more lanes and higher speeds. 01/31/91(TCA9018%INDEXR-T) T - 2 3 • One of the strengths of the modeling process is that it can be verified and, if needed, calibrated to match actual conditions. As an example, the 1974 Southeast Orange County Circulation Study forecasts into the 199Os predicted traffic volumes on I-5 and 405 freeways of approximately 200,000 trips per day. Actual traffic counts performed by the State verify that the 1974 projections have come true. The calculations submitted as part of comments 4-5-6 through 4-5-8 are based on cursory trip generation methods and they completely fail to account for the distribution or route assignment descriptions which are critical to traffic forecasting. Consequently, the conclusion that 2.4 million trips per [day?] will be attempting to use a facility with a capacity for [only] 200,000 trips per day is faulty. When the traffic model is run in a fashion consistent with accepted, standard practice, the results displayed on Figure 1.3.1 will be obtained; these results will have accounted for the future land uses -adopted by the local governments and the highway networks they have adopted on their Master Plans. Also, by examination of the trip tables, i.e., traffic from zone to zone, the through traffic on the Corridor can be determined. 4-6-1. 4-6-2. 4-6-3. 4-6-4. 4-6-5 The TCA is fully committed to the desires of its member agency (the City of Newport Beach) with respect to the local arterial highways. The TCA is not proposing to construct a San Joaquin Hills Road interchange, nor does the TCA propose any extension of or improvements to San Joaquin Hills Road. The "so-called" by-pass route is enhanced, not damaged, by the Corridor, pri- marily because traffic along PCH southerly of Corona del Mar creates the need for the by-pass; and this same "reservoir" of traffic will be reduced from 46,000 trips/day in the year 2010 to approximately 31,000 trips per day (see Figure 1.3.1 of the EIR.) The toll booths installed on the Corridor at the Pelican Hill Road interchange will toll northbound traffic in proportion to the remaining (northerly) reach of the Corridor, at a rate of $.15/mile. This toll will be approximately $.50 per each directional trip. The southbound direction is tolled in a similar man- ner. It is unlikely that these nominal tolls would impede travel demand that would otherwise suffer a time delay along the conjectured diversion route. 01/31/91(TCA9018%INDEXR-T) T - 2 4 11 More specifically, traffic from south of Corona Del Mar to the Jamboree inter- change at existing SR-73 would travel along Pelican Hills Road and then along the Corridor in approximately ten minutes less time than along a San Joaquin Hills Road to MacArthur route. The timesaving occurs because the arterial is a longer route of travel by approximately one mile, because the speed along the arterials are approximately 15 mph less than the Corridor, and because stop signs and traffic signals along the arterials will cause delays. It should be noted that San Joaquin Hills Road has existed on the Master Plan of Arterial Highways since 1964 as at least a Secondary Arterial. That classi- fication can be expected to have a carrying capacity of 20,000 trips per day, and the 2010 traffic with the Corridor does not exceed this well established demand. The TCA has not proposed a connection of San Joaquin Hills Road to the Corridor nor has it proposed the arterial's extension or improvement. Any environmental analysis requirements associated with the arterial are the responsibility of the San Joaquin Hills Road proponents; please contact the City of Newport Beach �- for Master Plan information on this arterial. 4-7-2. 4-7-3 Table 1.3.A in the DEIR/EIS identifies that the I-5 and the I-405 adjacent to the SJHTC' project are operating at levels of service (LOS) E and F. In the future, without the Corridor, the problem identified will be further exacerbated. This is further identified in Section 5 of the DEIR/EIS. Addi- tionally, the traffic studies in Technical Volume -II (of the DEIR/EIS) provide backup for this conclusion. Furthermore, TCA is actively involved in coor- dinating with Caltrans regarding the SJHTC project. 4-10-5 The truck use of the San Joaquin Hills Transportation Corridor will be minimal (well below four percent of the ADT) due to the imposition of tolls and compet- ing parallel routes which have more attractive (flatter) grades. It is highly unlikely that the limited truck traffic will pose a significant danger to Corridor users. If truck traffic were to become a problem, a higher toll could be applied, however, it is very unlikely that this problem will evolve. 4-11-1 The City of Laguna Beach's purchase of the Laguna Laurel property has not been completed. The potential purchase, however, does not mandate that Laguna 01/31/91(TCA9018%INDEXR-T) T - 2 5 0 Canyon Road remain at its present width. The decision to widen Laguna Canyon will be a Caltrans decision, and Caltrans will size the road according to the travel demand. There is a strong traffic demand for northbound Corridor trips to turn onto SR-133 to employment locations in the Irvine Spectrum. In the evening peak period, this travel pattern reverses. This is the reason for the SJHTC to SR-133 ramps. The TCA is interested in preserving the Laguna Canyon environment to the great- est extent possible and welcomes meeting with those who can best represent the Canyon resident's concerns. 4-14-1 The development of the Aliso Viejo tract is accounted for in the land use information which serves as the basic data for the traffic forecasting model. There is a common misconception that development which is now occurring is the only data that has been used to size the Corridor; factually this is incorrect. Data tabulations used as input to the traffic forecasting model correctly account for existing development, development under construction and all devel10 - opment to the year 2010. Consequently, the size of the Corridor has been designed to account for the future needs of the area through the year 2010. 4-14-2 The Wilbur Smith Traffic and Revenue Study did not make a conclusion on the origin and destination adequacy of the Corridor. The WSA Traffic and Revenue Study was conducted along existing routes to synthesize toll rate data. The study used origin and destination data as an input into the rate study, but this study did not attempt to verify either the trip distribution or route assignment models (see Response to Comment 4-5-6 in this chapter). The Wilbur Smith and Associates postcard study was not designed to establish origin and destination needs, it was designed to evaluate vehicle occupancy rates, and attitudes toward tolls. The Corridor is planned to serve existing and future land use as identified on the County and City Land Use plans. TCA does not have a goal of Land Use build out. 4-20-6. 4-20-9 Both Bonita Canyon Road and Culver Drive in the area referenced (northerly of Bonita Canyon Road) have existed on the MPAH since the late 1960s. As an arterial highway, traffic volumes in the range of 20,000 to 30,000 are not unusual or unanticipated. Since Culver Drive was planned to handle arterial 01/31/91(TCA901B%1NDEXR-T) T-26 0 • • volumes and the volumes on Culver Drive with the Corridor are within this range, no mitigation funding is proposed by TCA for this facility. Also, please refer to Responses to Comments 4-20-7 under Non-EIR/EIS Issue regarding future implementation of improvements to Culver Drive and Bonita Canyon Road. 4-21-2 The air quality and traffic models are based on demographic statistics adopted by the County of Orange and applied in the SOCTAM model. 4-21-11 The streets cited (University Drive, San Joaquin Hills Road, Marguerite, and Pelican Hill Road) are arterial highways, with alignments established since 1969. As arterial highways, they are designed to carry relatively high volumes of traffic. Since the traffic projections on these arterials (with the Corri- dor) do not exceed the volumes which they were originally established to carry, there are no new impacts. 4-21-12 Differences between traffic projections on, EIR No. 267 (1979), DEIR No. 494 (1988) and the current DEIR/EIS are primarily due to changes in land use data. It is a fundamental principal of transportation planning that traffic genera- tion results from land use improvements and, as the member agencies have changed their land use plans from.1979 to the present, traffic projections have necessarily changed. 4-22-16 See Response to Comment 4-5-6 in this chapter. The modeling process used is one in common use in the profession. Most significantly, projections made in the past have been realized to date. 4-24-8 It is true that when the SJHTC becomes operational traffic volumes on parallel facilities will decrease and volumes on feeder facilities such as Laguna Canyon Road will increase. Bearing this in mind, Pacific Coast Highway Traffic vol- umes will decrease with implementation of the Corridor and therefore enhance coastal access. Additionally, it should be noted that most feeder facilities 01/31/91(TCA9018%INDEXR-T) T - 2 7 have been upsized to accommodate increases in traffic that have resulted from the growth of the regional population. Current congestion on Laguna Canyon Road is a direct result of the size and capacity of the facility which has not kept pace with traffic demand. Capacity improvements to Laguna Canyon Road are planned by Caltrans. 4-27-2. 4-27-3. 4-27-4. 4-27-5. 7-122-1 The SJHTC South End Study shows an ADT for year 2010 of 5 (5,000 trips per day) on Avery Parkway between Marguerite Parkway and its existing terminus. This volume represents the traffic loading which comes from the residential tracts along roads such as Olivia Place and Las Ondas. A review, by TCA staff, of an aerial photograph of the tracts confirms the dwelling units used in "the study and shown in the land use data. The fact that the volume is surprisingly small in your view is understandable and merits explanation. As you have observed, the existing traffic counts, and indeed your own experience have been with volumes that are about 8,000 ADT. This actual volume (8,000t) consists most probably of approximately 5,000 residential trips (since both tracts have access solely to Avery Parkway) and approximately 3,000 trips from the college. The college volume may well seem small to you (indeed the volume used in the study from the college is about 31,000 trips per day (see zone 34). The problem is simply that the model and the figure cannot report details in as fine a representation as you might wish. The difference between the college access and the residential street is about 700 feet. On the scale of the exhibit this distance is impossibly small. The 5,000 ADT value was used because we thought that it most accurately reflected traffic near the eastern terminus of Avery Parkway (near your homes). At this location only residential traffic would be using Avery. This decision was driven by the need to depict what happens if the easterly extension of Avery is deleted from the MPAH. As the model moves westerly along Avery traffic contributes to the projection 43,000 ADT (option #1 and 1A) or 46,000 reasonable. Parkway the remainder of the college and indeed the volumes of 38,000 to to 53,000 ADT (option #2 and 2A) are With respect to Marguerite Parkway southerly of Avery a different phenomenon is probably in effect and it would generally be encouraging to community. The present high freeway traffic volume of approximately 180,000 ADT is probably diverting traffic to parallel facilities to the extent that the SJHTC and ultimately FTC relieve the I-5. More traffic can be diverted from Marguerite to I-5. Since the differences observed are small, about seven percent of the 01/31/91(TCA9018%INDEXR-T) T - 2 8 • 0 • projection, this would be considered to be a forecast that traffic on Marguer- ite will remain about the same. Figure C-1 of the SJHTC South End Study shows the check which was used to verify that the model was forecasting reasonably. This exhibit shows care and reasonableness well within the forecasting standards of the profession. 4-27-6 The development noted must be occurring in compliance with approved land use plans and consequently will be accounted for in the Corridor model. The Austin -Foust Study is a focused area study and has appropriately smaller boun- daries. Notwithstanding name changes Avery Parkway has been designated as an arterial highway on the County MPAH since 1963. As such it would normally be expected to carry traffic in the order of 20,000 to 30,000 ADT and hence no new impact would result from implementation of the Corridor. 4-27-7 See Responses to Comments 3-4-6 4-27-2 and 4-27-6 in this Chapter. P � P 4-33-23 The 20% through volume cited is not intended to be the sole justification for the Corridor. Also see Response to Comment 4-5-6 in this chapter. 4-33-26 The comment does not allow that other facilities in the median may be more efficient in keeping the LOS above D. Specifically, the strong directional peak characteristics of the area may mean that reversible lanes are more effec- tive than HOV lanes. 4-33-72 The 25% cited is a percentage describing vehicle mix. Twenty-five percent of traffic is some type of truck. Of that 25% most of the trucks are pickups approximately 19% of the total mix. This leaves approximately 6% of a typical freeway mix that are commercial trucks subject to special design and operation problems. This percentage is not abnormal. It is common on freeways and generally commensurate with traffic census data collected by the County. 01/31/91(TCA901B%INDEXR-T) T - 29 0 4-33-73 The Joint Policy Statement sets up goals and not absolute mandates. Given the legislative hurdles it would be appropriate to address this concern by mitiga- tion monitoring (i.e., monitor truck traffic to see if problems occur prior to attempting to pass legislation which may not be required.) 4-33-74 The comment assumes a diversion of truck traffic diversion does not occur. Some small amount of the Corridor and is capable of paying tolls and ance of the truck traffic can be accommodated which have been designed to carry truck traffic 4-33-78 away.from the Corridor. This truck traffic is attracted to negotiating grades. The bal- on other parallel facilities as well as autos. See Response to Comment 3-4-69 and 4-5-1 under Funding/Tolls. Additionally, the financial plan for the Corridor took into consideration the ability of people to pay tolls based on their disposable income. Disposable income would be what is left after basic living expenses, including .parking fees, are deducted from gross income. 4-33-80 Yes, the 10-20% reduction includes all traffic using the Corridor. 4-34-21 The traffic modeling completed for the project demonstrates the impact the project would have on congestion levels in Laguna Beach. The comparison within the DEIR/EIS page 1-4 is as follows: Existing Without Project With Project year 1988/89 Year 2010 Year 2010 PCH 47,000 63,000 52,000 (N of Broadway) PCH 40,000 64,000 50,000 (S of Broadway) Laguna Cyn Rd. 38,000 35,000 43,000 01/31/91(TCA9018%INDEXR-T) T-30 0 Ll As a parallel facility the Corridor significantly reduces future congestion levels on PCH. With the Corridor Laguna Canyon Road future congestion levels increase over future levels without the Corridor since Laguna Canyon Road provides access to the Corridor. 4-36-8 The Corridor project does not propose removing HOV or Transit facilities; it merely plans to build them in a sequence driven by demand to insure that the most effective options are selected. See also Response to Comment 4-34-21 in this chapter. 6-5-3. 6-5-4. 6-5-9. 7-29-2. 7-29-8 Please refer to Response to Comment 3-4-14 under Fiscal Impacts. 6-8-3 Access will be provided to Camino Capistrano with the implementation of Option #2 as defined in the I-5 Land Use Study. Please see Response to Comment 3-4-14 under Fiscal Impacts. 6-12-2 The goal of the TCA is operate three Corridors most difficult part of local agencies have crei Corridor projects and congestion relief. As a the TCA i s not able to direction must come fror responsibility for prior agencies (who either cc area or benefit from the led the way in identify these improvements and budget assignment of $1 this ooint forward. the specific: to plan, finance, design, construct, and (ETC, FTC, and SJHTC) in Orange County. Perhaps the these projects is the financing and to this end the ted a fee program which must be scrupulously applied to the greater public benefit which results from their direct result of these difficult financial constraints lead the way financially on other improvements. This the Orange County Transportation Commission (with its itizing transportation improvements) and from the local ntribute to the problem identified in the confluence improvements) sharing in the funding. To date TCA has ing a means of assigning funding responsibilities for ie have demonstrated our commitment with a fiscal year 3.2 million toward the confluence improvements. From OCTC should suDoly their expertise to lead these im- provement plans to construction and the local agency coordination to finalize funding commitments. 0 01/31/91(TCA901B%INDEXR-T) T- 3 1 6-15-28 The I-5 Land Use Study which has been commissioned by the TCA includes a sub - task which involves locating an additional access point along north Camino Capistrano thereby eliminating the current 1-1/2 mile cul-de-sac. 6-15-47 This issue will be considered as part of the traffic analysis prepared with the I-5 Land Use Study. Furthermore, these traffic movements are analyzed in the South End Traffic Study contained in Technical Report'7 of the DEIR/EIS. 6-15-50 The South End Traffic Study (Technical Report 7 of the DEIR/EIS) analyzed intersection capacity utilization at 27 locations in the confluence area for existing and future years for both options. Therefore, the micro level analy- sis requested has been completed and is part of the DEIR/EIS. 6-17-25 The following ramps on I-5 and I-405.would be overloaded with the I-5/I-405 widening alternative: Ramps AM PEAK PM PEAK 1. Avery Parkway to I-5 - all ramps Avery Parkway to I-5 - all ramps 2. Crown Valley Parkway Northbound Crown Valley Parkway southbound off - ramp 3. E1 Toro Road - all ramps E1 Toro Road - all ramps 4. Lake Forest northbound on -ramp 5. Irvine Center Drive northbound loop on -ramp Lake Forest southbound on -ramp 6. Culver Drive northbound on -ramp Culver Drive southbound on -ramp 7. Jamboree northbound on -ramp Jamboree southbound off -ramp 01/31/91(TCA901B%INDEXR-T) T - 3 2 17� 0 Ramps . 8. MacArthur Boulevard northbound MacArthur Boulevard northbound loop loop on -ramp and southbound loop on -ramp and southbound loop off -ramp off -ramp The following connecting arterials would be overloaded under the I-5/I-405 widening alternative: 1. MacArthur 2. Culver 3. Irvine Center Drive 4. Lake Forest 5. E1 Toro 6. Crown Valley 7. La Paz 6-17-47 s� The traffic volume of 5,000 ADT on San Joaquin Hills Road westerly of Pelican Hills and 8,000 ADT on Pelican Hills Road southerly of San Joaquin Hills road will be added to the figure. 6-20-2 The comment will be taken into account by the Board of Directors when making a connection alternative selection. 6-20-3 The Avery Parkway interchange will be sized to accommodate the traffic proposed under Option #2 if that selection is made. Consequently, the comparison drawn may not be valid. 6-20-4 Corridor connection alternative Option #2 provides a new connection of Via Escolar to Camino Capistrano which would relieve the cited problem. The com- mentator should consider this option. 01/31/91(TCA9018%INDEXR-T) T - 3 3 7-3-1 In the year 2010 the traffic just westerly of the confluence of SR-73 with SR- 405 is about 270,000 ADT. This projection can be determined by adding the 2010 volumes on SR-73 and SR-405 (either with Corridor 150 + 120 = 270,000 ADT or without Corridor 200 + 75 - 275,000 ADT). The result is virtually no change in I-405 west of the confluence. 7-3-3 The sizing of the confluence of SR-73 and I-5 is such that acceptable levels of service will be maintained. As further relief for the I-5 freeway it is impor- tant to note that the FTC will relieve traffic on the existing parallel I-5. 7-12-5 The comment notes the fact that climatic conditions may affect the operations of the Corridor. The design standards used for the project mitigate against r� combinations of low visibility, wet pavements, etc., by using conservative criteria for sight distance, stopping calculations, etc. 7-14-1 Figure 1.3.1 of the DEIR/EIS shows the traffic relief provided by the Corridor. These volumes show approximately a 14,000 trip per day decrease in the year 2010 on PCH. 7-14-2 See Response to Comment 7-13-2 under Fiscal Impacts. The Corridor will serve its purpose by relieving peak period congestion. Studies by the agency have shown the project is economically viable based on peak period/off peak period toll revenues. More importantly the tolls are intended as an interim means to finance the project which becomes a freeway (as required by law) upon retire- ment of the construction bonds. As a freeway the project will relieve conges- tion on a an even basis with the other freeways. 7-14-3 Contrary to the opinion stated, toll facilities offer carpooling an incentive in as much as tolls may be shared by the carpool participants. Use of high tech tolling can provide an incentive in allowing traffic to be detected with- out stopping. 01/31/91(TCA901B%INDEXR-T) T - 3 4 0 7-22-3 Restriction of truck travel time, while theoretically promising, is impractical because the federal interstate exists to carry passengers and goods across the country. Consequently, interstate travel begun in an area distant from Orange County cannot reasonably be prohibited as it passes adjacent to our com- munities. 7-25-2 For those who choose not to pay the tolls, the freeway system remains a viable alternative especially in light of the fact that freeway will be relieved from congestion by those who can afford the Corridor. The user will also have the opportunity to carpool to reduce toll impacts. 7-29-9 The South End Study, included in Volume II of the technical studies which provide support for conclusions in the EIR/EIS, analyzes local traffic cir- culation associated with alignment Alternative II. 7-31-2 A cordon line cut just northerly of Alicia Parkway from I-405 to PCH contain.s the following volumes (without the Corridor): 270, 80, 55, 31, 64 Total: 500. With the Corridor, the same sequence along the screenline appears to be 235, 56, 32 120, 29, 50 Total 522. The fact that the total volumes of traffic (522/500 = 1.04) crossing the screenline in the year 2010 are within 4% of each other indicates that the forecast is reasonable. 7-56-14 The DEIR/EIS describes negative impacts from traffic on page 5-18 and 5-20. In the Technical Studies Volume information is displayed which shows vol- ume/capacity ratios and intersection capacity impacts. 7-57-5 The interchange will be signalized to allow bicycle trail users to obtain a positive right-of-way for crossing the Corridor ramps. 01/31/91(TCA901B%INDEXR-T) T - 3 5 • 7-75-4 State of the art traffic studies show that, without construction of the Corri- dor, traffic congestion in south Orange County will continue to worsen between now and the year 2010 (projected year of build out for south Orange County). The SJHTC is projected to alleviate traffic congestion and make driving in south Orange County more bearable. For more information regarding the need for the SJHTC project and its expected benefits, please refer to sections 1.3 and 1.4 of the DEIR/EIS. We assume the author, when referring to "additional pollution", is referring to air pollution. Regarding alleged additional air pollution generated by the SJHTC; state of the art air quality studies show that regional air quality is anticipated to improve with construction of the Corridor. The projected posi- tive impact of the SJHTC on air quality is based on the project's contribution to roadway capacity improvements and the resulting decrease in driving time needed to reach destination attractions. For further information regarding the expected air quality impacts of the project, please refer to Section 4.4 of the DEIR/EIS. Please refer to Responses to Comments 7-84-21 under Project Description, 3-5-41 under Non EIR/EIS Issues, 4-33-71 under Tolls and 7-84-2 and 7-84-4 through 7- 84-11 in this Chapter. 7-84-2 The commentator is correct in observing that the change in development will delete certain traffic; however, the purchase of property from The Irvine Company is not completed, and all funds necessary have not been raised. In this context, the traffic should not be subtracted. 7-84-4 The level of commitment for the cited arterial can be seen from the MPAH and the respective City and County General Plans. Caltrans has no jurisdiction over these arterials. 7-84-5 The Laguna Canyon Road widening is not currently scheduled in the STIP. 01/31/91(TCA901B%INDEXR-T) T - 3 6 0 7-84-6 Environmental documentation for the cited projects is the responsibility of the project proponents, and these do not include TCA. 7-84-7 In general, these projects would rely on gas tax revenues, Measure M monies, and/or City tax revenues and project conditions of approval. TCA tolls or developer fees are not used to fund these improvements, and the funding, inso- far as it depends on timing, is assumed to be available by the 2010 for circu- lation planning. 7-84-8 The only arterial cited as extending through to Laguna Canyon Road that would have a significant impact if not extended, would be Aliso Creek Road. Deletion of this arterial would increase the need for the project and add an additional 20,000 trips/day. 7-84-9 Of the arterials cited, only Aliso Creek Road is planned for extension to Laguna Canyon Road. This extension will be implemented by the County between 2000 and 2010. 7-84-10 Caltrans has not proposed a four lane facility. The traffic modeling conducted for the DEIR/EIS is appropriate. 7-84-11 To the extent that the arterial highway system paralleling the Corridor is not constructed (and the cited arterials are parallel facilities), there would be a need for the Corridor. While funding of the arterials is complicated, any inability to build the arterials cited only increases the need for additional highway capacity. Despite the allegations, there is a good track record for building arterial improvements required for infrastructure, and Measure M money will tend to improve this picture for the arterials. 01/31/91(TCA901B%1NDEXR-T) T- 37 7-106-1 Avery Parkway is capable of handling traffic volumes in the order of 20,000 to 30,000 trips per day. Congestions occurs when flow on the highway is delayed by undersized interchanges. In the specific area cited the Avery Parkway Interchange to I-5 is the factor causing congestion because its tight diamond configuration does not allow enough room to store turning moves. Connection Option #2 would improve this condition by opening the storage room between freeway ramps. 7-106-2 Safety is ensured in the project design by virtue of the standards used for design. Caltrans (state) and the American Association of State Highway and Transportation Officials (AASHTO) criteria are the highest standards used in the profession and they are applied to every step of the project. These stan- dards are very conservative in their assumption on the capability of drivers. The assumption relative to a driver's ability to see, perceive hazards, and react to the hazards are analyzed in the development of these standards and ample allowance is made for the inexperienced, inattentive, or slow -reacting driver. 7-106-3 The traffic volumes which are forecast of land. As land is developed for the developed new traffic is generated. increases in traffic with or without tf tion becomes: are a direct result of the development first time or as land is more intensely Consequently there will be significant e project. Given this impact the ques- Do we attempt to ease congestion so that we are not stalled in traffic going nowhere with pollution being produced during the congestion, or Do we lessen congestion by insuring that no one has to remain in conges- tion for lengthy periods. The latter case is better from an air quality standpoint. Ultimately, of course, either solution needs to have the Orange County traveler convert to more efficient travel such as HOV or light rail and the solutions can evolve out of the Demand Management cross-section alternative. 01/31/91(TCA9018%INDEXR-T) T - 3 8 • r� Air Quality and Noise effects,of the Corridor are assessed in Section 4.4 and 4.5 of the EIR/EIS. 7-108-10 The statement about 80% to 90% of toll free volumes is in terms of the peak hour volume. The daily volumes may be lower than the 80% to 90% due to lack of congestion on competing roads (I-5) in the evening to early morning (8 p.m. to 5 a.m.). The screenlines shown are for a particular toll scenario (optimum) and may not reflect the toll rate that will eventually be selected. 7-108-11 To have a narrower Corridor, volumes would need to be much less than Caltrans design criteria for the Year to 2010 (toll free at LOS D). Wide median allows for mass transit or reversible railway to get the smallest cross section possi- ble. The Corridor has to be sized for its ultimate operation which is a freeway. Sizing it only for toll traffic would require future widening which would be unacceptable to the local communities. 7-108-12 Volumes on the screenline are within.5% of each other which is within the accu- racy of the transportation models used. The volumes would be closer if the screenlines were extended, but the overall differences would not be signifi- cant. 7-115-1 The I-5 Corridor connections are described in the DEIR/EIS on page 2-23 and in Figures 2.12 and 2.13. If the commentator finds the geometry complicated, he may wish to visit the TCA for an explanation of the ramp usage. .To avoid the problem of a bottleneck, the TCA has carefully sized lanes which merge traffic onto I-5 southerly of the connection. One other strong mitigation to the concern raised is the construction of the Foothill Transportation Corridor which will relieve traffic on I-5. The commentator may wish to indicate his support for this project as a part of his future comments. 0 01/31/91(TCA901B%1NDEXR-T) T-39 0 7-117-1 The commentator is referred to Figure 1.3.I. of the DEIR/EIS for volume of traffic with and without the project. In general, routes parallel to the Corridor receive traffic relief. Noise impacts and air quality impacts are described in sections 4.5 and 4.4 respectively of the DEIR/EIS. On page 4-34 and 4-35 of the DEIR/EIS the air quality benefits of the Corridor construction are compared to the no build condition. Noise impacts can be mitigated with barriers and the impacts are described on page 4-42. 7-119-5. 7-119-6 In 1987 and 1988, post card surveys were done to determine motorists' interests in toll facilities along their routes of travel. The results of these studies were incorporated into the toll traffic analysis used in the DEIR/EIS. Regarding consideration of the traffic patterns and/or need for a road in this location, see Responses to Comments 3-5-5, 4-17-1 and 4-34-5 under Purpose and • Need. 7-122-2 This comment represents the opinion of the commentator, which will be con- sidered by the decision makers. 7-141-12 Speed decreases with an increase in the volume to capacity ratio, according to a graph developed by the (former] Bureau of Public Roads. This graph is called the capacity restraint curve. When the volume of traffic is less than the facilities carrying capacity, speeds may achieve their full safe, legal poten- tial. When the volume of traffic exceeds practical capacity (level of service E) by 50%, speed drops to approximately 60% of its maximum. As volumes further increase to a point where they are double LOS E, the speed drops to about 38% of maximum. Given the specific condition at the location on I-5, it is likely that year 2010 peak hour speeds will be in a range of 15 to 30 mph. It is likely that during the off-peak times speed will range between 50 mph and maximum legal limit. 7-141-13 Also See Response 7-141-12 in this Chapter. Year 2010 peak hours speeds for the location given will likely be in the range of 25 to 35 mph. In the 01/31/91(TCA901B%INDEXR-T) T-40 • off-peak hours, it is anticipated that full legal speed will develop. The speeds given in Responses to Comments 7-141-12 and 7-141-13 are subject to determination due to accidents, inclement weather, etc. 7-141-14 The connection of the SJHTC to the I-5 freeway has been analyzed for two con- nection alternatives described in the DEIR/EIS. Also see Figures 2.12 and 2.13), along with the text on page 2-23 of the DEIR/EIS. In addition, the specific sizing of the connection to I-5 is planned to. achieve State standards, which assure adequate sight distance, design speed, driver comfort and many additional criteria. The listing of all of these criteria would be too ex- tensive for inclusion in the DEIR/EIS. 7-141-15 The connection of the SJHTC to SR-73 will occur at Jamboree Boulevard. In essence, the connection has the Corridor joining the freeway as an extension of 01 the lanes under Jamboree Boulevard. See Figure J-4 in the DEIR/EIS. 7-145-1 The South End Traffic Study is included in Technical Studies Volume II to the DEIR/EIS. Additionally, please refer to Response to Comment 3-6-66 in this Chapter and 3-4-38 under Fiscal Impacts. 7-145-5 It would not be unreasonable for a freeway lane to handle 1,500 to 1,800 vehi- cles per hour. With these lane capacities, the projected volumes can be accom- modated in the proposed lanes. One of the most significant aids to traffic in the San Juan Capistrano reach of the I-5 is the construction of the Foothill Transportation Corridor which will provide relief for I-5. 8-5-2 Please refer to Response to Comment 3-4-6 in this chapter. 8-16-1 With regard to the effects of Measure M on the need for the SJHTC project; please see Response to Comment 7-56-5 under Purpose and Need. 0 01/31/91(TCA9018%INDEXR-T) T - 4 1 The Master Plan of Arterial Highways (MPAH) is a dynamic document which is periodically updated to reflect the projected capacity needs of the County circulation system based on general planned land uses and the correspondingly projected levels of population and vehicle miles of travel. Regarding the existing and future size and capacity of Laguna Canyon Road from E1 Toro Road to Pacific Coast Highway, the responsibility for upsizing this facility to keep pace with traffic demand lies with Caltrans and the City of Laguna Beach. Unfortunately, the City has resisted the widening of the road- way. Consequently, the level of service on this facility is poor and will become steadily worse as demand for traffic capacity increases between now and the year 2010 (projected build out for the County). Regarding the deletion of the Laguna Laurel project and the resulting effect on the need for the SJHTC project, please see Response to Comment 4-22-19 under Purpose and Need. 8-16-2 The amount of traffic on arterials in the vicinity of the Leisure World commu- nity, with the exception of the section of E1 Toro Road between the Corridor and Aliso Creek Road, is projected to be less with implementation of the SJHTC project than without. For example, Moulton Parkway between El Toro Road and Laguna Hills Drive has existing average daily trips (ADT) of 32,000. 'ADT on this section of Moulton Parkway in the year 2010 are projected to be 64,000 without the Corridor and 36,000 with the Corridor. This reduction in ADT with implementation of the Corridor is logical for the following reason: facilities running parallel to the Corridor will experience traffic congestion relief because some trips will use the Corridor to reach their destination. Traffic increases (with SJHTC implementation) will usually be limited to sections of feeder facilities in the immediate vicinity of the Corridor. Please see Figure 1.3.1 of the DEIR/EIS for further information regarding existing and projected traffic volumes in the vicinity of the SJHTC project. 8-18-4 Regarding the projected future size of Moulton Parkway, the Orange County Master Plan of Arterial Highways (MPAH) shows Moulton Parkway as a six lane facility in the year 2010. The Orange County Transportation Commission is currently working on the Moulton Parkway Superstreet Study. The study is not yet complete, and consequently, it is too early to make statements regarding the study's recommendations for the future size of Moulton Parkway. 01 /31 /91(TCA901 B', I NDEXR-T ) T - 4 2 0 Please see Figure 1.3.1 of the DEIR/EIS for further information regarding existing and projected traffic volumes near Leisure World and the SJHTC. 8-22-2 You are correct in used for improving under Purpose and SJHTC. 8-25-2 your indication that some of the Measure M funds will be the E1 Toro Y. Please refer to Response to Comment 7-56-5 Need for further information regarding Measure M and the Please refer to Responses to Comments 4-24-2 and 7-56-1 under Purpose and Need. 8-26-2 With regard to the ultimate congestion of new freeway facilities, the SJHTC is • being planned to be capable of expanding to accommodate projected future traf- fic volumes. Under the Demand Management Alternative, as traffic demand for the SJHTC increases, the following sequence of steps could be implemented: 1. Construction of the initial six lane facility 2. The addition of two HOV lanes; one HOV lane in each direction 3. The addition of a light rail transit system in the median. Regarding the suggestion that TCA should plan further into the future than ten years, the TCA is planning 20 years into the future. The traffic study for the SJHTC uses projections for the year 2010. The traffic model is based on Gen- eral Plan data from the County and the jurisdictions in the area of benefit for the Corridor. These General Plans assume a 20 year build out. Consequently, a 20 year planning horizon is appropriate for use in analyzing the potential environmental impacts associated with the SJHTC project. 8-28-5 Please refer to Response to Comment 1-1-15 under Growth Inducement. 8-31-3 Implementation of the SJHTC will alleviate traffic congestion on parallel facilities, such as PCH and the I-5. Feeder facilities to the Corridor, such as Laguna Canyon Road, will experience a traffic increase in the vicinity of the Corridor. • 01/31/91(TCA9019%INDEXR-T) T - 43 C Laguna Canyon Road between PCH and E1 Toro Road is currently congested, with a poor level of service. The authority and responsibility to upgrade this sec- tion of Laguna Canyon Road to accommodate existing and projected traffic de- mands and to complement and keep pace with the rest of the Orange County arter- ial highway system, lies with Caltrans and the City of Laguna Beach. 01/31/91(TCA901B%INDEXR-T) T - 4 4 0 TRANSIT 2-7-8. 4-21-22, 4-21-25, 4-36-5. 7-2-1. 7-12-7. 7-12-8. 7-12-9. 7-13-4. 7-22-1. 7-35-2. 7-42-1. 7-51-3. 7-84-18, 7-91-1. 7-109-4. 7-119-14 See Responses to Comments 3-5-7, 3-5-37 and 4-5-2 under Alternatives. As discussed in the referenced responses and in Chapter 2 of the EIR/EIS, alternatives of transit and rail are considered infeasible as replacements for the Corridor. Therefore, it is not appropriate to assess the comparative costs of such improvements. 3-5-122 See Responses to Comments 3-6-28 in this section and 4-5-2 under Alternatives. 3-6-28, 3-6-29, 3-6-54, 3-6-82 All of the studies and future transit stations are important items in long-term transit planning. These items are not addressed in the EIR/EIS because the implementation of rail on the Corridor is not a project addressed or environ- mentally cleared in the EIR/EIS. The comments provide information which is hereby incorporated into the Final EIR/EIS. 3-6-101 The last sentence of the comment is correct. 3-11-3 The Corridor median design allows for future implementation of transit consis- tent with the comment. 4-33-9 It is acknowledged that rail transit on either build alternative is not pres- ently included in the RMP. Nevertheless, the SJHTC is appropriately called a Corridor for the following reasons: 1) the median design provides for a vari- ety of future transit scenarios, 2) HOV lanes will be implemented as part of the project, and 3) the RMP identifies the SJHTC as a "Long -Range Corridor" on Figure V-16 of the RMP. 0 01/31/91(TCA901B%INDEXR-T) TR - 1 4-33-24 See Response to Comment 3-8-14 under Project Description. 7-35-2 See Response to Comment 4-5-2 under Alternatives for the basic conditions which need to evolve for light rail to be viable. The Demand Management alternative provides for the best evolution of travel into a light rail system. The DVI fees collected in Orange County are rededicated to law enforcement of that specific problem and they would not provide significant revenue to the physical improvement or operating expenses associated with a real system. 7-42-1 Based on the population densities in south Orange County, light rail is not a viable alternative to the Corridor at this time. However, the Demand Manage- ment alternatives for the Corridor reserves sufficient right-of-way in the median to accommodate HOV lanes and/or a light rail system in the future when these alternative modes of transportation can be funded and become viable respectively. Please refer to Response to Comment 2-7-8 in this chapter for additional information. 8-29-2 Refer to the first paragraph of Response to Comment 3-1-1 under Project Description. 8-34-2 The development and use of carpool lanes is a federal, State and regional policy meant to increase the number of person trips served by the transpor- tation system. Locally, these policies have been implemented by SCAG through the Air Quality Management Plan and Regional Mobility Plan. The Corridor is planned to be consistent with these plans. 01/31/91(TCA9018%iNDEXR-T) T R- 2 1* C] VISUAL RESOURCES 2-5-8 As stated in Appendix A, there are no improved trails in the vicinity of the Corridor designated in the 1982 General Plan for the State Park. Section 4.15 of the EIR/EIS (page 4-130) discusses the light and glare impacts at Crystal Cove State Park. The determination of no line -of -sight visual or light and glare impacts was determined through field reconnaissance, review of topogra- phic maps and preliminary Corridor design plans and the distance of the State Park boundary to the Corridor (approximately 1,000 feet). 2-8-50 Section 4.15 (Visual Resources) and Appendix A discuss the Corridor's visual effect on the following coastal resources in the Coastal Zone: Crystal Cove State Park, Irvine Coast Dedication Area, and Aliso/Wood Canyons Regional Park. The analysis in the EIR/EIS does not identify significant visual impacts to recreational uses of these facilities. 3-2-8. 7-126-1 Mitigation Measure 15-24 has been added to the'EIR/EIS as follows: 15-24 During final design, the TCA shall coordinate with the City of New- port Beach and the County of Orange regarding potential use of trans- parent noise barriers near the Ford Road interchange and the vicinity of Nellie Gail Ranch (where existing transparent barriers exist), respectively. 3-2-10 The measures identified to reduce visual impacts are consistent with the mea- sures outlined in Section 4.15 (pages 4-131 to 4-133) and Exhibit 2, Aesthetic Design Guidelines. 3-4-79 Visual impacts associated with the implementation of the Greenfield Drive half - diamond interchange were analyzed in the context of the Niguel Equestrian Trail on page 26 of Appendix A and Figure J-22 in Appendix J of the EIR/EIS. Resi- dences in the vicinity of this interchange will experience similar visual impacts to those identified in Appendix A. No additional analysis is required. 01/31/91(TCA9018%INDEXV-4) V - 1 A full diamond interchange was not analyzed in the visual analysis because it is not a component of the project design under consideration in the EIR/EIS. However, upon review of Figure J-22 and the visual analysis in Appendix A, there would be no additional significant impacts with this configuration. 3-4-80. 3-6-27, 3-6-51, 3-7-43 Section 4.15 of the EIR/EIS identifies and analyzes the effect of the Corridor and associated noise barriers on views from eighteen locations along the align- ment. The comments do not identify any specific areas where similar impacts would occur. Regarding noise barriers, the Wall Design Goals Section of the Aesthetic Design Guidelines (Exhibit 2) provide examples of potential landscape/design features to soften visual effects of noise barriers. Property owners concerns regarding visual impacts will be taken into consideration by TCA during final design of noise barriers, as outlined in Mitigation Measure 5.2 of the EIR/EIS. The DEIR/EIS includes a figure (Figure 4.5.1) identifying recommended noise barriers along the Corridor alignment. During construction, the FEIR/EIS iden- tifies where proposed noise mitigation measures are different from those iden- tified in the DEIR/EIS. The TCA has prepared renderings where viewsheds have been directly impacted by the Corridor. In its analysis of viewsheds, the TCA considered both businesses and residences in the City. As a matter of fact, virtually all business in Mission Viejo potentially affected by changes in the viewshed have the back sides of buildings oriented toward the Corridor. With respect to residences, no Mission Viejo residences suffer from line of sight obstruction by the Corri- dor and those residences which will view the Corridor from Mission Viejo already view the I-5 freeway at virtually the same distance and field of view. Consequently, no new impacts will occur to these residences. As stated in Section 4.15 (Page 4-122), Spotted Bull Lane experiences short range views of the existing I-5 freeway and long range views of the Corridor/I- 5 connection. These views are dominated by an existing urban viewshed. The conclusion of the visual analysis determined that the Corridor/I-5 connection and the I-5 improvements would not significantly alter existing topography or the urbanized viewshed visible from this location, thus no mitigation was recommended. Furthermore, it should be noted that the Aesthetic Design Guidelines (Exhibit 2) provide for extensive landscaping along the Corridor and related improve- 01/31/91(TCA901B%INDEXV-4) V - 2 0 ments (i.e., Rancho Viejo Road). Please also refer to Response to Comment 3-7- 44 regarding City review of design plans. 3-7-44 The TCA is actively including the cities in review of the design plans for the Corridor which include all Corridor design components. On December 31, 1990, the first set of design plans were transmitted to member agencies. 3-8-81 The split level design component is identified in the majority of Figures in the DEIR/EIS, including Figure 2-10 in Chapter 2.0 - Project Description. Further discussion of this design variation is not necessary. It is not appropriate to discuss this design variation under the discussion of Alternatives because this design is part of the proposed project. 3-8-82 Please refer to the discussion on page 4-128 of the DEIR/EIS, under the heading Mainline Toll Plaza, for a discussion of this facility's effect on Turtle Rock. In summary, the visual analysis determined that due to intervening topography and distance the mainline toll plaza will not be visible from Turtle Rock. 3-8-83, 4-32-16, 7-119-9. 8-26-1 As discussed on page 4-129 and 4-132 of the DEIR/EIS, lighting fixtures and signage for the Corridor would only be places at or near proposed interchanges/ ramp toll plazas and at the mainline toll plaza. These light sources shall be of a low glare quality, directed towards activities on the Corridor and hooded as required to protect adjacent residences and open spaces. 3-8-84 Extension of Sand Canyon to the Corridor is not a component of the project under study in the EIR/EIS; however, the design of the Corridor is compatible with the future extension of Sand Canyon Avenue as shown on the City of Irvine General Plan. The visual impacts of this extension would be a subject analyzed in the environmental documentation to be prepared in the future under the auspices of the City of Irvine. The design of the Corridor interchange at Sand Canyon allows for future connection of the southerly extension of the roadway to the Corridor. • 01/31/91(TCA9018%INDEXV-4) V - 3 0 4-25-2. 4-25-4. 7-143-2. 7-144-2. 8-9-2. 8-9-4 The viewshed from Camino Capistrano was field reviewed by the TCA and found to consist of two distinct components. Laterally (easterly and westerly orienta- tions) the viewshed is rural in composition. In these directions, there will be no significant impacts for the following reasons: 1. The Corridor project will not make any 'improvements westerly of Camino Capistrano. 2. The Corridor project will connect to the existing I-5 at an elevation that does not impact easterly views of ridges and distant mountains. The second component of view from Camino Capistrano looks northerly into an urban view of existing highway facilities and commercial buildings. In this area, the Corridor bridges (under either Option #1 or Option #2) will be of a similar scale and style as the existing skyline, and consequently no new impact will result. 4-26-1 The EIR/EIS identifies the noise and visual impacts associated with the Corri- dor and recommends mitigation to reduce these impacts to the extent feasible levels. These measures include incorporation of noise barriers and landscaping along the Corridor alignment. For additional information regarding Corridor aesthetic Guidelines/Criteria, please refer to Exhibit 2 of this document. 4-32-3 The renderings in the EIR/EIS are intended to provide the reader with a picture of what the sensitive visual resources will see after the Corridor is con- structed and landscaping and mitigation measures in place. The drawings are based on preliminary design plans and accurately depict the scale and perspec- tive. It is not the TCA's intention to "sell" the Corridor through the use of these graphics. But rather provide information to the public regarding poten- tial impacts. 7-10-1. 7-60-5. 7-85-2 As shown in Figures J-5 and J-9 in Appendix J of the DEIR/EIS, the Corridor will be visible from Arlington Drive; however, structures associated with the Corridor will not block views of the Santa Ana Mountains to the east. Visual impacts at this location would be similar to those identified for residences near the Cabot Road/Crown Valley intersection on page 4-124 of the DEIR/EIS. . 01/31/91(TCA901B%1NDEXV-4) V - 4 The Conventional Alternative will be closer to Arlington Drive than the Demand Management Alternative, as shown in Figure J-9. Noise modeling prepared for Receptor 24 would be the closest indicator of potential noise impacts on Arlington Drive. As shown in Table 4.5.A of the DEIR/EIS, this receptor currently experiences noise levels of CNEL = 67 dBA'and LEQ = 65 dBA and with implementation of the Corridor is projected to experience noise levels of CNEL = 67 dBA and LEQ = 69 dBA. Both of these noise levels exceed the noise abatement threshold criteria of CNEL = 65 dBA and LEQ = 67 dBA. As stated on page 4-59 of the DEIR/EIS, a sound barrier located at the end of pavement would need to be 18 feet high to break the line of sight of truck stacks. This height barrier would not be considered feasible and would not provide a 5 dBA or more noise reduction. As an alternative, a barrier is recommended at the property line of the townhomes. The height of the barrier would be determined during final design, subject to approval of the property owners. OF 7-88-51 The EIR/EIS discusses the visual, light and glare impacts associated with the construction of the Corridor and recommends mitigation measures to reduce these impacts, including landscaping with native vegetation (Mitigation Measures 15- 12 and 13). Exhibit 2 (Aesthetic Design Guidelines) identified the extent of the use of native vegetation in the landscape plan. The commentator does not identify where the discussion of impacts is considered inadequate to meet the requirements of CEQA and NEPA. The comment is considered the opinion of the commentator and will be taken into consideration by the decision makers during the review process. 7-114-19 It is unclear where in the DEIR/EIS the author is referencing. Please refer to Section 4.15 of the DEIR%EIS for a discussion of the Corridor's visual impacts and the measures being incorporated into the project design to enhance the aesthetic quality of the facility. Exhibit 2 (Aesthetic Design Guidelines) identified the extent of the use of native vegetation in the landscape plan. 01/31/91(TCA901B%INDEXV-4) V - 5 0 WATER RESOURCES 1-1-60 Refer to Response to Comment 1-1-59 under Biological Resources. 1-1-62 Refer to Response to Comment 1-1-63 under Biological Resources. 1-2-62 Refer to Response to Comment 1-2-48 under Biological Resources. 1-2-63, 3-9-25 The reference to Section 4.18 on page 4-27 of the Draft EIR/EIS was an error. The correct reference was to Section 4.17, Construction Impacts. Page 4-27 has been corrected and included in the Final EIR/EIS. Refer to Response to Comment 2-3-2 in this Chapter regarding preparation of the Runoff Management Plan. Refer to Response to Comment 1-1-63 under Biological Resources regarding preparation of the Erosion and Siltation Control Plan. It is recognized that all of the interactions between several of the chemical constituents may not have been formulated as part of the projected pollutant loadings calculations. The regression model included forecasting methodology for individual quantifications rather than, as an example, the reciprocal relationship between of chemical oxygen demand and oil and grease. Thus these projected levels may not occur simultaneously; however, the modeling is de- signed to present a worst case forecast for impact analysis purposes. In reference to Comment 3-9-25, the project specific water quality impacts have been identified to be mitigable to below a level of significance with success- ful implementation of the Runoff Management Plan measure as amended herein. The determination of the Corridor's potential for contribution towards signifi- cant cumulative water quality impacts is dependent upon several variable fac- tors such as storm intensity and duration. this conclusion is discussed on page 7-3 of the DEIR/EIS. 01/31/91(TCA9018%INDEXV-4) WR - 1 2-3-1 Comment restates text from DEIR/EIS. �Iff o No response necessary. v.n v Wa a:o Mitigation Measure 3-9 (Runoff Management Plan) has been amended as follows to provide additional information regarding components and performance standards of the plan. Mitigation Measure 3-9 will read as follows: 3-9 Prior to final design, the TCA shall prepare a detailed Runoff Management Plan (RMP). The plan shall address the provision and location of facili- ties to route and detain Corridor runoff for the purpose of maintaining runoff velocity at or below existing rates and preventing Corridor pollut- ants from reaching improved and unimproved downstream drainages. County of Orange Best Management Practices will be included in the runoff facili- ties for the Corridor and associated park and ride lots as determined appropriate by the Design Engineer. The plan shall be submitted to the RWQCB, for review and comment. The Runoff Management Plan shall, at a minimum, accomplish the following: a. Assess the existing water quality in a representative sample of down- stream improved and unimproved drainages for the purposes of estab- lishing a baseline standard. Water quality standards established by OCEMA and the Regional Water Quality Control Board (RWQCB) shall be used as a reference standard. b. Locate and construct detention/settlement basins within the vicinity of drainages identified in the DEIR/EIS as being potentially impacted by Corridor pollutants. The detention/settlement basins shall be sized to retain runoff from the peak flow in the 25-year storm. Provisions for metering runoff shall be included in the design of the detention/settlement basins so as not to overload treatment capacity. Detention basins shall be equipped with oil and grease traps or some other acceptable method to aid in the breakdown and permanent remov- als of pollutants. Runoff Management Plan will specify cleaning of grease traps. C. Locate and construct grass covered drainage channels from the Corri- dor to the detention/settlement basins identified per the above. C� 01/31/91(TCA9018%!NDEXV-4) WR- 2 0 0 d. Route Corridor runoff through the above drainage channels to the de- tention/settlement basins. Final design to specify locations of discharge points and entry into municipal treatment systems, if ap- propriate. e. Develop a landscape palette suitable for use in Corridor drainages and detention/settlement basins which promotes the use of plant mate- rial able to breakdown corridor pollutants. f. Establish a regular testing methodology and schedule to monitor the level of heavy metals and other pollutants within the drainage/settlement basins and representative downstream improved and unimproved drainages. g. Report findings of testing to TCA Board on a regular basis through the mitigation monitoring reporting process. h. Develop measures to reduce pollutant levels which exceed the estab- 40 acceptable threshold levels. as provided by the RWQCB. Submit measures to the RWQCB for review prior to RMP approval and construc- tion. These measures will assure that. impacts related to the Corri- dor do not cause downstream exceedance of RWQCB standards. The plan will specify a process for application of these mitigation measures. i. Establish maintenance procedures to ensure adequate function and prevention of accidental breakdown of detention basins, grease traps, drainage channels and other runoff facilities. With regards to mitigation of downstream impacts to the Laguna Canyon drainage area, Mitigation Measure 3-8 has been amended as follows: 3-8 Drainage facilities constructed in association with the San Joaquin Hills Transportation Corridor within Laguna Canyon shall be designed so that additional runoff generated by the project does not result in any net increase in runoff downstream in Laguna Canyon. This design criterion shall be met through incorporation of the following parameters: a. Retention of all Corridor runoff from all frequency storms up to and including the 100-year storm (for example 2 yr, 5 yr...100 yr.). b. Retention will be accomplished by flow -through basins to avoid the possibility of setting weirs at elevations which might not capture smaller, more frequent storms. 0 01/31/91(TCA9018%INDEXV-4) WR-3 C. The TCA currently uses the OCEMA hydrology manual. The Orange County Flood Control District shall review all hydrology and hydraulic cal- culations on behalf of the Laguna Canyon property owners. d. Enlargement of the E1 Toro Road basin if required to meet the crite- ria described above. e. Construction sequencing of the basins which assures that they can be operational during grading of the Corridor. f. The TCA will utilize standard design criteria for energy dissipation at basin outlets which returns flows to velocities normally occurring in the downstream conditions. This criteria will include but not be limited to Orange County Flood Control District design criteria. The DEIR/EIS acknowledges in Section 7.0 that the Corridor may contribute to a cumulative impact to water quality in downstream drainages, including the Upper Newport Bay. 2-8-16, 2-8-18, 2-8-19, 2-8-20, 2-8-22 The information requested in Comment 2-8-16 is provided in the Floodplain Hydraulic Study and Conceptual Drainage Study contained in Technical Study No. 2, Volume I of the DEIR/EIS Technical Studies. The Floodplain Hydraulic Study (Technical Memorandum TM 3-22) contains informa- tion on the project geographic location, hydrologic setting (topography, pre- cipitation, runoff, groundwater), floodplain studies, Corridor impacts on floodplains and increased runoff to major drainage crossings from Corridor or roadway surface. The Conceptual Drainage Study (Technical Memorandum TM 3-16) provides additional information relative to hydrologic setting (rainfall and runoff, soils and soil cover and land use) hydrolytic analysis, a detailed discussion of major watersheds (San Diego Creek Basin, Bommer Canyon, Laguna Canyon Channel, Aliso Creek Basin and San Juan Creek Basin), bridge crossings and culvert crossings. The final component of the technical studies is the Water Quality Analysis prepared by LSA. Regarding Comments 2-8-18 and 2-8-19, the requested background information on geographic history of floodprone areas and project alteration of past/current flood problems, while informative, was determined not to be essential for analysis of potential impacts to floodplains. 11 01/31/91(TCA9018%INDEXV-4) WR - 4 .10 0 Regarding Comment 2-8-20, refer to Response to Comment 2-9-44 under Biological Resources. Impacts pertaining to streambed alteration and filling are addres- sed in Section 4.7 of the DEIR/EIS and in Response to Comment 1-1-13 under Biological Resources. Response to Comment 1-1-64 under Biological Resources provides the revised mitigation measure for the Erosion and Siltation Control Plan. Protection of environmentally sensitive areas are discussed in Response to Comment 3-8-39 under Biological Resources. 2-8-17, 2-8-23 The watersheds of Buck Gully and Los Trancos Canyon are completely outside the Corridor footprint. The topographic base in Figure 4.5.1-9 on page 4-58a illustrates the ridgeline for these watersheds in relation to the Corridor's cut/fill lines. Emerald Canyon and Boat Canyon watersheds are completely outside the project boundary and will not be affected. The remaining water- sheds located within the Coastal Zone that may be affected by the project are Muddy Canyon, Morro Canyon, Lower Laguna Canyon,' Wood Canyon, Aliso Creek, Lower Aliso Canyon and San Diego Creek. Downstream impacts will be mitigated through implementation of the Runoff Management Plan described in Response to Comment 2-3-2 in this Chapter. 2-8-21 The following channels may receive additional flow as a result of the Corridor: Bonita Channel - The channel will be designed to withstand any erosion. A pilot channel will convey low flow to prevent any siltation within the channel. The design shall be such that the 100-year flow will be contained within the facility and does not increase flood hazards. Laguna Canyon - A proposed retarding basin will mitigate the increase in peak flow due to the Corridor. Niguel Creek - An existing retarding basin has been designed to mitigate addi- tional flows from the Corridor. Narco Channel - This facility is made up of underground storm drains. No erosion or siltation will take place within the system. Refer to Response to Comment 1-1-64 under Biological Resources, which provides the amended Mitigation Measure 17-12 for the Erosion and Siltation Control Plan. Is 01/31/91(TCA9018%INDEXV-4) WR - 5 2-8-24 The Water Quality Analysis presented in Technical Study No. 2 utilizes a one- half inch storm event as a basis for determining a worst case pollutant loading into downstream drainages. As shown in studies which were referenced during preparation of the analysis, this size storm event would remove approximately 90% of the pollutants from the roadway in surface runoff. The analysis incor- porated a reasonable runoff coefficient which did not assume ground saturation, therefore it would apply to a drought year and a worst case condition. In a year of higher rainfall yield, ground saturation would cause higher dilution of pollutants. 2-8-25. 4-22-22 The findings of the Water Quality Analysis state that the Corridor project would add significant amounts of pollutants into drainage areas immediately adjacent to the Corridor, but that with successful implementation of the pro- posed Runoff Management Plan (Mitigation Measure 3-9, see Response to Comment 2-3-2 in this Chapter), pollutant loadings would be reduced to a level within State and federal standards. 2 8-27 Impacts on streambed alterations and dredging or filling of Waters of the United States are governed by the 404-1601 permit processes. Any request for review of these applications should be directed to the U.S. Army Corps of Engineers and the California Department of Fish and Game, respectively. 2-8-28 The analysis contained in Section 4.3 of the Draft EIR/EIS has determined that the effects of these flood control facilities on downstream reaches will be minimal. Refer to Response to Comment 4-22-17 under CEQA/NEPA Issues. 2-8-29 Corridor mitigation measures assure that Corridor runoff will not exacerbate the existing flood control problems in Laguna Canyon. Runoff impacts in other drainages and floodplains along the Corridor, which do not have existing flood control deficiencies, will be mitigated as described in Mitigation Measures 3-2 through 3-7, to avoid the creation of Corridor induced flood control problems. 01/31/91(TCA901B%INDEXV-4) W R- 6 0 0 3-2-9 See Response to Comment 1-1-64 under Biological Resources. 3-5-2 The reference to the Laguna Canyon Road channel was intended to describe the flow in the [natural] thalweg along Laguna Canyon Road. It is acknowledged that a channel does not exist in this location. Refer to Response to Comment 2-3-2 in this Chapter. 3-5-11, 3-5-69, 3-5-70, 3-5-100 During the short term (construction) condition, sedimentation through drainages would increase amounts of beach sand replenishment. After the construction period has been completed and erosion, siltation and sedimentation control measures are in place (refer to Response- to Comment 1-1-64 under Biological Resources), the amount of streambed materials will generally decrease. These �. levels would not be reduced* to a significantly low level depletion upon suc- cessful implementation and maintenance of these measures. The proposed retarding basin at the Laguna Canyon Road interchange is a flow - through type. Sand and sediment settles to the bottom of the channel in the form of bed -load. The excess flow will be diverted into the basin through a side weir along the top of the channel wall. The bedload by-passes the basin and continues to flow downstream. Other proposed structures over the major stream crossings are bridges that will cause no ponding in the upstream channel. The sediment in these channels will continue to flow under the Corridor to downstream reaches. 3-5-68. 4-19-4.'4-19-10, 4-21-15 Section 4.3 of the Draft EIR/EIS addresses water quality impacts of the pro- posed project on downstream drainages and the marine environment. The results of the water quality analysis (provided in Technical Studies document Vol. I) indicate that the potentially significant loading of pollutants into coastal drainages and the ocean will be reduced to below a level of significance by implementation of the Runoff Management Plan as described in Mitigation Measure 3-9 and revised in Response to Comment 2-3-2 in this Chapter. 01/31/91(TCA9018%INDEXV-4) WR - 7 The authors of the Water Quality Analysi by Or. Ford provides adequate background runoff impacts through coastal drainages 3-5-101, 4-21-37 s determined that the report prepared hydrological data and conditions for and into the marine environment. The Regional Water Quality Control Board (RWQCB) has designated beneficial uses for drainage subareas within both the Santa Ana and San Diego Regions. As described in the Water Quality Analysis (Technical Study 2c), not all of the drainage areas impacted by the Corridor are designated. REC-1, however, the Run- off Management Plan will be designed to assure that runoff levels meet RWQCB standards (refer to Response to Comment 2-3-2 in this Chapter). 3-5-108, 7-114-5. 7-114-10 The mitigation measure relative to the preparation of a Runoff Management Plan has been revised, as provided in Response to Comment 2-3-2 in this Chapter. The preparation of mitigation plans is identified as a mitigation measure and appropriate guidelines or criteria for such mitigation plans are set forth. As stated in Mitigation Measure 3-9, a Runoff Management Plan will be submitted for review to the Regional Water Quality Control Board (RWQCB) prior to con- struction of the Corridor. Further, implementation of the runoff management mitigation actions will be assured by the Mitigation Monitoring and Reporting Plan to be adopted concurrently with any project approval by TCA. Regarding potential impacts of runoff mitigation facilities, refer to Response to Comment 2-8-28 in this Chapter. 3-6-60 The mention of Mission Viejo being an "unincorporated community" has been updated on page 36 of the Conceptual Drainage Study to reflect the City's incorporation in 1988. 3-7-18 Refer to Response to Comment 2-3-2 in this Chapter and Response to Comment 1-1- 64 under Biological Resources. The impacts studied as part of the Location Hydraulics Study are those required by the FHPM and Caltrans. The channelization proposed for Oso Creek would complete a connection between upstream and downstream channelized sections. The length (4,100 feet) of the existing downstream channelized section makes it unlikely that erosion will occur. Notwithstanding TCA's research in this area, 01/31/91(TCA9018%INDEXV-4) mm • 0 0 L_ 1�1 0 the City Engineer and OCEMA Engineering staff will be consulted during design and will review the plans. Also refer to Response to Comment 4-22-17 under CEQA/NEPA Issues. 3-8-23, 3-8-24 The referenced buffer/setback area for Bonita Reservoir will not be able to be maintained during construction. Refer to Response to Comment 4-28-39 under Biological Resources regarding Mitigation Measure 7-2 for protection of wetland habitats during construction. The recommended mitigation measure strategy is already inherent in the project Mitigation Measures 3-9 (see Response to Comment 2-3-2 in this Chapter) and 17- 12 (see Response to Comment 1-1-64 under Biological Resources). 3-8-59 Refer to Response to Comment 2-7-3 under Biological Resources. 3-8-60 Mitigation Measure 3-7 has been modified in the Final EIR/EIS as requested (addition of the words "and approved by"); the new wording is as follows: 3-7 Project plans (drainage improvements) shall be coordinated with and ap- proved by the cities of Irvine, Newport Beach, Laguna Beach, Mission Viejo, Laguna Niguel, San Juan Capistrano and the County of Orange to avoid any adverse impacts on those agencies' facilities. The design of drainage facilities shall be consistent with hydraulic studies prepared by the Corridor Design Management Group TCA. 3-8-91, 3-8-92 Please see Response to Comments 2-2-1, 2-2-2 and 7-47-1 under Hazardous Waste/Materials. 3-8-100 University Drive is depicted on Figure 3.3.1; no modification is required. 01/31/91(TCA9018%INDEXV-4) WR - 9 i 3-9-2 The quantities of impact as relayed in the comment are appropriately provided in terms of linear feet for creek realignment and acres for wetland impacts. These quantities are an accurate indication of the impacts for floodplain, streambed and wetlands components of the hydrologic system. 3-9-3. 7-114-15 Although the Biological Assessment Report (Technical Study No. 5) recommended revegetation of Bonita Channel with native wetland plants, flood control and channel maintenance would be constrained with extensive natural growth in place. However, the Bonita Channel will be soft bottom, as required by the City's General Plan and revegetation will be allowed to occur naturally. The detention basins will be placed within the project's area of disturbance as evaluated in the DEIR/EIS and illustrated in the Biological Resources Section (4.6) and, therefore, impacts from those facilities have been determined to the extent feasible in the Draft EIR/EIS prior to final design. The grasslined channels associated with runoff detention basins referenced in Response to Comment 2-3-2 will be planted with herbaceous species appropriate for breakdown of pollutants as determined by the Project Biologist in conjunction with the Project Engineer. 3-9-12 The changes cited have been made to tables and paragraphs of the Conceptual Drainage Study (T.M. 3-16), as follows: Page 12, Table 3: Aliso Creek Channel - 7,700 cfs instead of 7,300 cfs Page 12, Table 3: Horno Creek Channel - 3,200 cfs instead of 3,100 cfs Page 18, Last Paragraph: Bonita Creek Channel - 2,363 cfs instead of 2,200 cfs Page 32, Paragraph 2: Aliso Creek Channel - 7,700 cfs instead of 7,300 cfs Page 39, Paragraph 2: Oso Creek Channel - 6,300 cfs instead of 6,200 cfs Page 48, Table 5: Aliso Creek Channel - 7,700 cfs instead of 7,300 cfs 3-9-23 The statements referenced from the Draft EIR/EIS text remain true in the indi- vidual contexts of floodplain and water quality. However, the following is provided to further clarify the issues. Statistical curves show that the percent of pollutant loading steadily increases up to a one-half inch storm event, then levels off with the increasing amount of rainfall. With storm 01/31/91(TCA9018%INDEXV-4) WR- 1 0 f events in excess of one-half inch, the pollutant levels are decreased (diluted) but sedimentation quantities are increased. 3-9-24 Both Mitigation Measures 3-8 and 3-9 apply here. Reference to Mitigation Mea- sure 3-9 is hereby incorporated into the EIR/EIS. 3-9-28 The specific parameters of the Best Management Practices facilities will be developed as part of preparation of the Runoff Management Plan during the final design stage of the project. The EIR/EIS analysis has determined that poten- tial impacts from these measures would not be significant, given the standards identified in the Draft EIR/EIS mitigation measures relative to construction impacts (mitigation measures in Chapter 17 of the EIR/EIS) and revised Mitiga- tion Measure 3-9, as described in Response to Comment 2-3-2 in this Chapter. 3-9-29 It is recognized that all of the interactions between several of the chemical constituents may not have been formulated as part of the projected pollutant loadings calculations. The regression model included forecasting methodology for individual quantifications rather than, as an example, the reciprocal relationship between of chemical oxygen demand and oil and grease. Thus these projected levels may not occur simultaneously; however, the modeling is de- signed to present a worst case forecast for impact analysis purposes. 3-9-30 Page 9 of the Water Quality Analysis and page 3-9 of the Draft EIR/EIS have been amended in the Final EIR/EIS to reflect the information presented in the comment. 4-10-3 Refer to Response to Comment 2-3-2 in this Chapter and Mitigation Measure 3-8 in the EIR/EIS. TCA.intends to mitigate flows for all storms up to and includ- ing the 100-year flood. • 01/31/91(TCA9018%INDEXV-4) WR - 1 1 LI 4-21-38 Refer to Mitigation Measures 3-2 through 3-8 on page 4-31 of the Draft EIR/DEIS and Response to Comment 2-3-2 in this Chapter. 4-22-26 Please see Response to Comment 1-1-13 under Biological Resources. 4-22-27 The Federal Highway Administration (FHWA) has acted as Lead Agency for the preparation of the EIS under NEPA; notwithstanding the participation of Caltrans and the TCA, FHWA has been involved in the Draft EIR/EIS throughout its preparation. Preparation of an entirely separate EIS by the Army Corps of Engineers could require a wasteful duplication of effort as to issues already addressed in the current Draft EIR/EIS. Further, as discussed in the Sierra Club case cited in the comment, CEQA regulations generally direct agencies to reduce paperwork in implementing NEPA, and the Corps of Engineers and the Department of Transportation are directed to cooperate to reduce unnecessary duplication and paperwork in processing FHWA projects requiring Army Corps' approval. (33 U.S.C. § 1344 (q).) 4-30-1 Refer to Responses to Comments 2-3-2, 2-8-21 and 2-8-29 in this Chapter. 4-30-3 See Responses to Comments 2-3-2 and 2-8-29 in this Chapter. 4-30-4 TCA has committed to facilities to control energy and velocities of flows leaving the Corridor's storm drains and basins. See Response to Comment 2-3-2 in this Chapter. 4-30-7. 4-30-10, 8-19-3 The TCA is planning to construct a small retention basin (with approximate capacity for 2,300 acre feet) in the Laurel Canyon vicinity to retain all of the runoff from the Corridor project up to and including the 100 year storm. The need for this basin is not dependent on implementation of the Laguna Laurel 01/31/91(TCA9018%INDEXV-4) W R- 12 project. The basin will be designed and constructed to meet the standards described in Response to Comment 2-3-2 in this Chapter. 4-30-10 Refer to Response to Comment 2-3-2 in this Chapter. As implied in the comment, the capture of storm flows and the review of the hydrology calculations are singularly important. Mitigation Measures 3-8 and 3-9 commit TCA to capturing all stormflows up to and including the 100 year event, and it further invites inspection of the hydrology calculations by engineers .from the various agencies with jurisdictions in the area. These commitments address the expressed con- cerns. 4-32-36 The Conceptual Drainage Study clearly states the project shall not interfere with the operation of the existing deli 1 ti ng basin in San Diego Creek. Al so refer to the Erosion and Siltation Control Plan (Mitigation Measure 17-12) in Response to Comment 1-1-64. Furthermore, as part of construction of the Corri- dor bridge over San Diego Creek, the channel bed in the vicinity of the bridge shall be protected against scour. This would only reduce the amount of silt and sediment transported to the bay. Any trash that may be on the road will be intercepted at the proposed grate inlets and subsequently removed by the maintenance crew. 4-32-37 Mitigation Measures 3-2 and 3-4 through 3-9 in the Draft EIR/EIS address im- pacts to surface runoff. Also see Response to Comment 2-3-2 in this Chapter for revised Mitigation Measure 3-9. Grasslined channels will assist in the breakdown and trapping of pollutants in Corridor runoff. 4-33-65 Design of a retarding basin within the Laguna Canyon watershed requires very extensive and time consuming procedures for reduction of Peak discharge for a range of flood frequencies. The proposed facility will have to accommodate the 100-year discharge as well as the higher frequency events such as the 5- and 10-year storms. Currently the CDMG staff and the section engineers are in the process of determining the most economical way of routing the on -site drainage from the SJHTC as well as the flows from several small canyons along the Corri- dor to the Laguna Canyon Channel. After a final determination for routing 0 01/31/91(TCA9018%INDEXV-4) WR- 13 0 these flows has been made and approved, the staff will be in a position to accurately estimate the peak flow in Laguna Canyon Channel downstream of the Corridor. The design of the retarding basin, if needed, can only proceed after the final alignment and configuration of the Corridor and its interchanges within the Laguna Canyon watershed has been completed. Also refer to Responses to Comments 2-3-2 and 2-8-29 in this Chapter. 4-33-66 The 73 day public review period for the Draft EIR/EIS.provided adequate oppor- tunity for review of the Conceptual Drainage Study. 4-33-67, 4-33-68 In order to estimate potential pollutant loadings, the water quality analysis utilized several factors, including average daily trips per defined roadway segment, and average pavement width for the length of the project. On a drain- age by drainage basis, the ratio of impervious surface area to total watershed area may be between one and two percent; however, the EPA does not consider the impacts to be definitely significant if greater than one percent. The proposed mitigation measure for implementation of a Runoff Management Plan (see Response to Comment 2-3-2 in this Chapter) will reduce the levels of pollutants entering downstream drainages to a level below significance per standard criteria set by the Regional Water Quality Control Board. 4-33-69 It is acknowledged that there may be a build up o 6-15-21. 7-114-3 f In the event that the groundwater bearing media under the Corridor are com- pressed to the extent that groundwater flow is restricted, the water will flow towards the low point which is the stream crossing and will cross under the Corridor through the stream crossing. A subdrain system and weepholes will be provided at concrete lined stream channels to accommodate the groundwater. 01/31/91(TCA901B%INDEXV-4) W R- 14 0 6-17-18 The goal of the proposed runoff mitigation measures in the Laguna Canyon water- shed is to maintain peak runoff for post corridor conditions at or below those which would occur under existing conditions. This will apply to a series of storm frequencies including the 100-year storm and higher frequency events such as the 2- and the 10-year frequency flows. A detailed Runoff Management Plan will be prepared, as described in Response to Comment 2-3-2 in this Chapter. 6-17-20 The analysis provided in the Draft EIR/EIS provides a conservative worst case scenario and mitigation has been developed to mitigate to this level. Under the No Project Alternative, projected future traffic demand would be concentrated on existing arterials rather than the Corridor. It is likely that increased arterial congestion would lead to the widening of existing arterials and/or the development of new arterials. Under this scenario, VMT is expected to be greater than VMT in the Newport Bay drainage under the Build Alterna- tives. Pollutants from the projected traffic would be concentrated on the arterial system within the drainage to Newport Bay. Detailed water quality analysis has not been prepared for this scenario; however, it is expected that runoff pollutants could meet or exceed the levels under the Build Alternatives. 6-17-56 The requested corrections to Appendix A have been made, and are included in the FEIR/EIS. 7-7-2 The commentator does not specify which hydrologic information is insufficient. The floodplain hydraulic and drainage studies which accompanied the Draft EIR/EIS were prepared in July and August, 1990, respectively, and thus include the most up to date information possible for analysis of the potential hydro- logic impacts. 7-51-5 The commentator's attention is directed to Mitigation Measures 3-1 through 3-9 and Response to Comment 2-3-2 in this Chapter. 01/31/91(TCA901B%INDEXV-4) WR - 15 C 7-56-4 Benzene is not considered to be a significant component of roadway runoff and was thus not included in the water quality regression model utilized for the Corridor Water Quality Analysis. Benzene is a product of gasoline vapors and would potentially impact activities associated with handling of gasoline. 7-82-4 Mitigation Measure 3-8 in the Draft EIR/EIS states that TCA has the objective of achieving no net increase to downstream runoff in Laguna Canyon following construction of the Corridor. This is proposed to be achieved by constructing a retarding basin near Laurel Canyon and Laguna Canyon Road and adjacent to the proposed location of the Corridor. Refer to Response to Comment 4-33-65 in this Chapter. 7-86-12 Page 3-10 of the Draft EIR/EIS presents a discussion of groundwater basins within the project limits. There are no known springs along the Corridor alignment. Water table data have been compiled along all the stream crossings by recent geotechnical explorations. 7-86-14 Ground water is described in Volume I of the Technical Studies (page 19 and 20) attached to the Draft EIR/DEIS. Additionally, more site specific data is available for inspection at the TCA in the form of boring logs from the Geofon Reconnaissance Study of the Corridor or the thirteen section design geotechn- ical reports done on the Corridor. The commentator is welcome to contact the TCA to request an appointment to view this data due to the extensive amount of data available. 7-86-33 The 208 program implemented by the cities of Irvine and Newport Beach and the County of Orange has resulted in a dramatic improvement to the water quality of Upper Newport Bay. The Corridor Runoff Management Plan (see Response to Com- ment 2-3-2 in this Chapter) will incorporate measures which support and enhance this water quality improvement effort. 01/31/91(TCA901B%INDEXV-4) WR- 16 • 7-114-4 Refer to Responses to Comment 2-3-2 in this Chapter and 1-1-64 under Biological Resources, which provide the expanded mitigation measures for the Runoff Man- agement Plan and the Erosion and Siltation Control Plan, respectively. These Plans will stipulate that runoff and -erosion control devices will be designed to mitigate impacts to within applicable State and County standards. As part of project final design,, the preliminary size and slope of each culvert and drainage ditch will be determined, and the outlet velocity will be calcu- lated. Subsequent, the flow in the downstream area will be analyzed. Based on the average grain size of the topsoil, its resistance against the resulting velocity and volume of flow will be assessed. If it is found that the velocity is excessive, energy dissipators will be designed to intercept the flow prior to its release downstream of the culvert. Dissipators may be in the form of 1) velocity reducer rings inside the culvert where they will have no visual impact on the surroundings, 2) rock slope protection designed to blend in with the natural scenery, or 3) impact type concrete stilling basins. 7-114-5 Benches will be not used on design indicates that they on fill slopes higher than wide and shall be spaced benches. Refer to Response 7-114-9 cut slopes except where stability analysis in final are needed. Intermediate benches shall be provided- 90 feet. These benches shall be at least 20 feet no more than 75 feet measured vertically between to Comment 3-5-108 in this Chapter. Refer to Response to Comment 1-1-64 under Biological Resources. 7-114-11 It is not clear to which mitigation measure the comment pertains, as the mea- sures in Section 4.3 are not identified by letter, but rather are numbered 3-1 through 3-9. Refer to Response to Comment 3-9-3 in this Chapter for discussion of vegetation in drainage channels. 7-114-14 The assumption that dilution downstream will reduce pollutant concentration in Corridor runoff was not proposed as mitigation for water quality impacts. Rather the Runoff Management Plan as specified in Mitigation Measure 3-9 (see 01/31/91(TCA9018%INDEXV-4) WR- 17 Response to Comment 2-3-2 in this Chapter) will be designed to reduce pollutant quantifies to below a level of significance per Regional Water Quality Control Board standards. Refer to Response to Comment 4-33-69 in this Chapter. 7-114-16 The TCA will pursue the limitation of pesticides within landscaped areas to the extent possible. However, landscape maintenance activities will require a certain degree of pesticide use. Refer to components of the Landscape Plan included in Response to Comment 3-5-97 under Biological Resources. The imple- mentation of Mitigation Measure 3-9 as identified in Response to Comment 2-3-2 in this Chapter will reduce the impact of any pesticide use to an insignificant level. 7-124-3 Drainage for Corridor facilities will meet the design standards of both the OCEMA and Caltrans. Since the location of the problem and the quantity of runoff are not more fully described in the comment, the TCA will review Cal - trans maintenance records for additional information on the problem as part of its final design of the Runoff Management Plan. The drainage standards used by the TCA will handle flows much larger than the general description provided. 7-141-5 The total drainage area of the Laguna Canyon Channel upstream of the confluence with Niguel Creek is 2,480 acres. After construction of the Corridor, about 130 acres of this area will be within the Corridor right-of-way. About one half of these 130 acres will be paved and become impervious and the remainder will consist of landscaped side slopes. However, a conservative assumption would be that all of the 130 acres (or about five percent of the total drainage area) will be paved. Under natural conditions, the soil low infiltration rate, less than hydrology studies by the Corridor the 100-year storm, the peak flow about 3,080 cfs to about 3,275 cf to a proposed retarding basin whe ject levels or less. along the proposed route of the Corridor has 0.3 inches per hour. Preliminary detailed Design Management Group indicate that during downstream of the Corridor will increase from s. This increase in runoff will be conveyed re the peak flow will be reduced to pre-pro- • 01/31/91(TCA9018%INDEXV-4) WR - 18 0 0 7-141-6 Section 4.3 of the Draft EIR/EIS and the Water Quality Analysis in Technical Study No. 2 identify the potential pollutant loadings in drainages downstream from the proposed Corridor. 7-141-7 All Corridor facilities will be designed to incorporate all feasible public safety measures. 7-141-8 A determination of the exact percentage of the roadway runoff into the Pacific Ocean cannot be made prior to final design of the retarding basin in Laguna Canyon; however, given the design standard in Mitigation Measure 3-9 (see Response to Comment 2-3-2 in this Chapter), which requires that downstream flows be retained at pre -project levels, there will not be a significant in- crease of any roadway runoff entering the Pacific Ocean. 8-8-1 Please see Response to Comment 2-3-2 in this Chapter. 'Additionally, please see Mitigation Measures 3-2 and 3-8 on pages 4-30 and 4-31 of the Draft EIR/EIS. 0 01%31/91(TCA901B%INDEXV-4) WR- 19 SECTION 4 M 1-1-1 The acknowledgment of the Department of the Interior of the consideration of constructive use issues in the Section 4(f) analysis is -noted. 1-1-2 The comment is noted and acknowledged. 1-1-3 The Section 4(f) analysis reflects the policy of the Federal Highway Adminis- tration that the acquisition of air easements in these circumstances does not constitute an actual use of these 4(f) resources. Even if the acquisition of air rights is considered an "actual use", there is no feasible and prudent alternative to the use of the Arroyo Trabuco Equestrian Trail, San Diego Creek/Santa Ana Heights Equestrian Trail/Orange County Bicycle Trail 40, Niguel Equestrian Trail, the Oso Creek Corridor•or Orange County Bicycle Trail 72 because these trail facilities cross longitudinally across the proposed Corri- dor alignment. There is no feasible and prudent alternative alignment avail- able which would avoid or mitigate the effects on these resources described in the Section 4 (f) Analysis. 1-1-4 The noise effects on the Niguel Equestrian Trail should be evaluated in the context of the trail's urban surroundings (adjacent to an existing arterial) and in recognition of the fact that the portion of the trail adjacent to the Corridor is very limited. Therefore, the noise effects of the Corridor influ- ence only a very small portion of the trail and will not substantially impair the recreational values of this facility. The analysis concluded that there would be no constructive use of Aliso Wood Canyon Regional Park as a result of the projected noise increases at the fire access road because there are no current or planned recreational useE at this location. The Corridor will not have any significant effect on wildlife move- ment in the park because there are no more than 100 acres of wildlife habitat in the area north of the Corridor. As acknowledged in the section 4(f) Analy- sis, the Corridor will prevent access to a very small portion of the Park from one particular gateway. This is not considered a substantial impairment of the values, functions or attribute of this resource because other access points are is 01/31/91(TCA901B%1NDEXV-4) 4F-1 • available. In any event, recognizing that the issue of constructive use of this resource may be a matter of some dispute, the Analysis also includes an evaluation of whether there are any feasible and prudent alternatives to the use of the Park by the Corridor. The effects of the Corridor on the Laguna Laurel Dedication Areas is discussed at length in the Section 4(f) Analysis and at other relevant portions of the EIR/EIS. Because the Analysis recognizes that there is some dispute regarding the constructive use of this privately -owned area, the Analysis also includes an evaluation of whether there are any feasible and prudent alternatives to the use of the area by the Corridor. The Analysis documents that other alignments would have a more significant effect on this resource or on other publicly - owned 4(f) resource areas. We note that the County of Orange Environmental Management Agency has concurred with the Section 4(f) evaluation of this area. The visual effects on Bommer Canyon Park are very minimal, and will be further mitigated by the Construction of a berm along a portion of the Corridor align- ment in this area. Urban development is currently visible from the Park. The Corridor will be a considerable distance from the Park (See Figure J-29). In any event, because the analysis recognizes that the effects on Bommer Canyon make be a matter of some dispute, the Analysis also includes an evaluation of feasible and prudent alternatives which would avoid or further mitigate the effects on the Park. The proposed alignment has already been designed to mitigate effects on Bommer Canyon and the Turtle Rock residential community. It is not possible to move the alignment further to the west without actually using portions of the Crystal Cove State Park. The proposed alignment is the only alignment that is available which avoids any actual or constructive use of Crystal Cove State Park and which also minimizes the visual effects of the Corridor on Bommer Canyon Park. The effects of the Corridor on Bonita Creek Park must be evaluated in the context of its urban surroundings. The Park is already in close proximity to two major arterials. Although noise levels in the park are projected to increase, with mitigation the levels will be below the federal noise abatement criteria and at a level that will not substantially impair the use of facility for the planned recreational activities. The Section 4(f) analysis includes correspondence which has been received to date from the local agencies regarding the Section 4(f) evaluation. The com- ment that the commentator accepts the opinion of the local officials with jurisdiction over the 4(f) resources is noted. 01/31/91(TCA901B%INDEXV-4) 4 F - 2 0 0 1-1-5 The comment is noted. 1-1-6 The EIR/EIS includes a detailed discussion of the relationship of the Corridor to the transportation needs in Orange County. In addition the Regional Mobil- ity Plan adopted by the Southern California Association of Governments, and the relevant general plans within the County of Orange recognize the role of the Corridor in addressing the transportation needs of Orange County and the region. 1-1-7. 1-1-8. 1-1-67 The 4(f) Analysis includes an extensive discussion of the history of the effort by the County of Orange and other jurisdictions to cooperatively plan the parks and other 4(f) resources with the corridor. This history indicates that the location and design of the 4(f) resources was in many respects determined in contemplation of the locally -preferred alignment of the Corridor. The 4(f) Analysis and the Biological Resources Section of the EIR/EIS includes an exten- sive discussion of the proposed measures to mitigate the effect of the Corridor on wildlife resources. In addition,* the regional open space. program of the County of Orange and other local agencies has been, in part, designed to miti- gate the effect of the Corridor on biological resources by establishing large blocks of consolidated habitat. (See also, the Biological Resources Chapter in this document). 1-1-9 The TCA plans to continue to work closely with its member agencies and other local, state and federal governmental entities in design the Corridor in a manner which is sensitive to and compatible with surrounding public resources. The mitigation measures proposed in the EIR/EIS, and the Mitigation Monitoring Program will provide a legally -binding commitment in this regard. 2-8-43 Please refer to Appendix A - Section 4(f) Evaluation for a discussion of exist- ing publicly owned open space areas as well as the those areas that will be potentially under public ownership by the time Corridor construction commences. 01/31/91(TCA9018%INDEXV-4) 4 F - 3 • 3-4-76 Please refer to Appendix A - Section 4(f) Evaluation for a discussion of the Corridor's effect on the Oso Creek Trail. 3-5-14, 7-120-4 Please refer to Appendix A - Section 4(f) Evaluation for a discussion of all publicly owned recreational resources affected or potentially affected by the Corridor. Also, refer to Section 4.8, Land Use, for a. discussion of the Corri- dor's impact on areas currently designated for public open space but currently privately owned. 3-5-127. 7-84-31 Section 4(f) of the Department of Transportation Act applies exclusively to the United States Department of Transportation, Federal Highway Agency. The Sec- tion 4(f) analysis, included as part of the Draft EIR/EIS, is subject to public review and comment in the same manner as the complete Draft EIR/EIS. The requirements of Section 4(f) must be satisfied in order for the Federal Highway Administration to approve the use of land from a significant publicly owned park, recreation area, wildlife or waterfowl refuge, or any significant his- toric site. There is no separate "approval" for Section 4(f) compliance. 3-5-139. 4-22-23, 4-22-25, 8-4-9 8-27-6. 8-31-1 Appendix A of the Draft EIR/EIS provides an analysis of compliance with Section 4(f) of the Department of Transportation Act, with respect to the effect of the proposed Corridor on parklands, wildlife refuges, and historic resources. As required by Section 4(f), the analysis in Appendix A identifies 4(f) resources potentially affected by the Corridor, and describes the extent to which the Corridor will affect the resources and the uses and values associated with each resource. Further, the Section 4(f) analysis describes a range of alternatives which were assessed as a means of avoiding or minimizing potential impacts to 4(f) resources. In addition to recounting the range of alternatives to the project, and alternative alignments for the project as a whole, the analysis assesses possible site specific avoidance alternatives at each 4(f) resource identified in the 4(f) analysis. In general, changes to the proposed Corridor alignment to create site specific avoidance alternatives would result in equal or greater effects on the identified 4(f) resources, while alternative align- ments for the Corridor and nonalignment alternatives would have greater effects on 4(f) resources or be otherwise infeasible. The 4(f) analysis details mea- 01/31/91(TCA9018%INDEXV-4) 4 F- 4 0 0/ sures to minimize harm where the Corridor will potentially affect 4(f) resources. 3-5-140. 7-82-5. 7-88-64, 7-88-67, 7-88-78, 7-109-12, 7-114-22, 8-19-4 Several commentators have indicated that they believe that the proposed acqui- sition of the Laguna Laurel property by the City of Laguna Beach (and the associated passage of Measure H which authorizes the sale of municipal bonds to fund a portion of the proposed acquisition) will result in additional and more profound impacts by the project on the Laguna Laurel area than are evaluated in the DEIR/EIS. Some of these commentators also indicated that they believed that the announced City/Irvine Company agreement would alter the Section 4(f) Analy- sis included in the DEIR/EIS and that Section 4(f) prohibits locating the Corridor in the Laguna Laurel area. The Irvine Company and the City of Laguna Beach have announced that they have tentatively agreed to enter into an agreement for the purchase of the Laguna Laurel property by the City of Laguna Beach over a five year period. On Novem- ber 6, 1990, the voters of the City of Laguna Beach approved a bond measure to raise $20 million for the acquisition of the Laguna Laurel property. It has been reported that the sales price for the Laguna Laurel property is $78 mil- lion. In addition, the County of Orange has indicated that they may contribute $10 million toward the acquisition of Laguna Laurel subject to the City of Laguna Beach agreeing to certain conditions regarding the Corridor. As of January 1991, the City and The Irvine Company have not executed an option agreement for the Laguna Laurel property. Nevertheless, the City and The Irvine Company have announced that they intend to enter into an agreement providing the City an option to acquire the .Laguna Laurel property in five separate installments. The right-of-way for the Corridor is excluded from the agreement and would not be acquired by the City under the option agreement. The first option period would allow for the acquisition of the portion of the Laguna Laurel property adjacent to the Corridor right-of-way. The property to be included within the first option would include the areas identified in the Section 4 (f) Analysis as the "Laguna Laurel Dedication Areas" to the north and south of the Corridor alignment. These are the areas that were to be dedicated by The Irvine Company to the County of Orange as a condition of approval of the Laguna Laurel development project. In addition, the area included within the first option includes the area previously planned for a golf course in the Laguna Laurel development plan. The effects of the Project on the Laguna Laurel property are discussed in detail in the Section 4(f) Analysis. (DEIR/EIS Appendix A). In addition, the effects of the Corridor on the Laguna Laurel property are discussed in other 011 01/31/91(TCA9018%INDEXV-4) 4 F - 5 0 relevant sections of the DEIR/EIS. (e.q. Chapter 4.6 (Biological Resources), Chapter 4.8 (Land Use), Chapter 4.15 (Visual Resources). The Section 4(f) Analysis included an evaluation of Laguna Laurel as though this property were publicly owned even though the Laguna Laurel property is not currently subject to Section 4(f) of the Department of Transportation Act. In particular the Section 4(f) Analysis discussed the visual, noise, air quality, wildlife move- ment effects of the Corridor on the Laguna Laurel property. The proposed sale of the Laguna Laurel property to the City of Laguna Beach does not change the evaluation of the effect of the Corridor on the Laguna Laurel property or the Section 4(f) Analysis. As discussed above, the existing land use plan for Laguna Laurel includes open space uses on the Dedication Areas. Therefore, the sale of this property to the City of Laguna Beach (in lieu of the dedication by The Irvine Company) does not alter the evaluation of the effects of the Corridor. The only change as a result of the proposed sale of the Laguna Laurel property to the City of Laguna Beach relevant to the Corridor is that the area currently designated as open space and to be developed as a golf course would instead be utilized for passive recreational and open space purposes if this property is acquired by the City. This change does not result in any significant change in the analysis of the effect of the Corridor on this property. The DEIR/EIS assumes that the golf course property was to be protected pursuant to a scenic easement to be granted by The Irvine Company as a condition of approval of the Laguna Laurel development project. (DEIR/EIS p. 4-125). The Section 4(f) Analysis acknowledges that the view from the northern dedica- tion area (Laguna Ridges) in the vicinity of the Corridor right-of-way will be substantially impaired. The Analysis also indicates that the Corridor will create a barrier between inland canyons on the east (Shady, Bommer and Camarillo) and the coastal canyons on the west (Muddy, Moro and Laurel). There- fore, the DEIR/EIS evaluates the effects of the Corridor on the Laguna Laurel property. The proposed agreement between the Irvine Company and the City does not alter this evaluation. One commentator (No. 7-109-12) indicated that Section 4 (f) prohibits the approval of any federal highway project unless the "best possible" route is selected. As discussed in the Section 4(f) Analysis, Section 4(f) of the Department of Transportation Act requires the Secretary of Transportation to find that there is "no feasible and prudent alternative" to the "use" of a Section 4(f) resource by a federally -funded highway facility. The Section 4(f) Analysis specifically discusses whether there are any feasible and prudent 01 /31 /91(TCA901 B••. I NDEXV-4) 4 F - 6 19 01 alternatives to the proposed alignment through Laurel Canyon and evaluates the relative effects of project alternatives on Section 4(f) resources. The following discussion regarding the Corridor's effect on the Irvine Coast Dedication Area is hereby incorporated into the Section 4(f) Evaluation of the FEIR/EIS: Irvine Coast Dedication Area - This resource is located below the Laurel Canyon Dedication Area and is an area that has been dedicated as permanent open space as part of the conditions of approval for the Irvine Coast Planned Community. The Local Coastal Program for the Irvine Coast identifies the following poten- tial uses of the Dedication Area. Recently, the Irvine Company has proposed an offer of dedication to the County of Orange, however, this offer has not yet been accepted by the County. Therefore this resource is not currently within public ownership however, it is anticipated that the offer of dedication will be accepted by the County within the construction timeframe of the Corridor. Analysis of the location and the topography between the Corridor and this resource has determined that there will be no actual use or proximity impacts at this resource. Due to its location south of the Laurel Canyon Dedication Area, Resource No. 9 in Appendix A, it has been determined that this resource will experience fewer Corridor related proximity impacts (i.e. visual, noise, air quality) than those identified for the Laurel Canyon Dedication Area. 3-5-141 Please refer to Response to Comment 3-5-140 in this chapter regarding visual impacts on Laguna Laurel area. Appendix A of the EIR/EIS identifies the Corridor's effect on the visual envi- ronment at Crystal Cove State Park. The comment does not identify where the discussion of visual effect of the Corridor at Crystal Cove State Park is considered inadequate. 3-5-142 Appendix A of the EIR/EIS identifies feasible mitigation measures to minimize the Corridor's effect on Section 4(f) resources. 3-5-143 Please refer to Response to Comments 3-5-139 through 3-5-142 in this Chapter. of 01/31/91(TCA901B•INDEXV-4) 4 F - % 0 3-6-30 The I-5 Land Use Opportunity Study by P&D Technologies had as its goal the identification of a plan which would maximize the economic value of land lying solely along the alignment of Corridor Option #1 for the eventuality that this alignment might be vacated (alignment #2 selected). A similar study was not performed along the alignment of Option #2 simply because the TCA had not been given any irrevocable offers of dedication along this alignment. The study maximizing land use was to include a study of the constraints upon the land; constraints such as terrain, access, trail constraints, wetlands, etc. The commentator implies that study was to address the development of trails; this is factually wrong. Trails are best planned by the State, County, and local agencies. To the extent that a trail exists TCA will protect the facili- ty in -place or coordinate with the appropriate jurisdiction to realign the trail. In the specific case of the Oso Trail, under either SJHTC/I-5 connec- tion option an ample horizontal window of 200 feet and vertical clearance of more than 50 feet exists for the trail. 3-6-57 Figure A-3 has been modified to identify the items identified in the comment to clarify the position of the resource. The revised figure has been included in the Errata of the FEIR/EIS. 3-6-58 Figure A-4 is correct in its position of the trail. As shown in Figure J-22, the trail is located on the east side of Greenfield Drive. Also, as identified in Figure A-4 and in the text on page 17 of the DEIR/EIS, a portion of the trail currently terminates approximate 900 feet from the Corridor and that the remainder of the trail is proposed and contingent on the County's acceptance of an offer of dedication from the landowner. 3-6-107 This comment is referring to a preliminary version of the EIR/EIS and does not pertain to the information contained in the DEIR/EIS circulated for public review. 01/31/91(TCA901B%INDEXV-4) 4 F- 8 is 0 3-7-37 Please refer to Response to Comment 3-8-89 under Construction Impacts regarding coordination of construction within affected jurisdictions. Also refer to Mitigation Measure 17-22 and 17-23 of the DEIR/EIS as well regarding this issue. 3-7-40 Please refer to Appendix A for a discussion of the Corridor's effect on the Rancho Viejo Road Bike Trail. 3-8-31 There is a typographical error in Technical Report No. 4 regarding noise levels at Crystal Cove State Park. The following modification is hereby incorporated into the FEIR/EIS: ...and would not result in a substantial impairment of noise sensitive activities, features or attributes of this resource.". 3-8-95 Bommer Canyon Park is included in the Draft Section 4(f) Evaluation because it is owned by the City of Irvine, a public entity. It is believed that the author is referring to Bommer Canyon Regional Park. This park is a County master planned regional park to the east of Bommer Canyon Park and is within the City of Irvine Open Space/Conservation area. However, both the future regional park and open space/ conservation area are currently within private ownership (The Irvine Company). The City and The Irvine Company have entered into an MOU which addresses open space dedication which will occur with future development within the City. It is not anticipated that the City will require dedication of any of these areas as a condition of a development approval prior to completion of the Corridor. Thus, Section 4(f) would not apply to this area. However, if any of these areas did come under public ownership prior to Corri- dor construction, it is not anticipated that there would be an actual or con- structive use of the resource. The Corridor would be located on preserved right-of-way and would not actually use the resource, and through provisions in its General Plan, the City has anticipated the Corridor. The General Plan discusses the Corridor in the following areas: 1) the Corridor is designated in the Circulation Element, 2) the Corridor is an allowable use within desig- nated Preservation Areas in the Land Use Element, and 3) the Conservation and 0 01/31/91(TCA901B%1NDEXV-4) 4F-9 Open Space Element states that the Corridor is compatible with Preservation Areas if the "least environmentally damaging feasible alternative" is chosen. Thus through cooperative planning of the Corridor and planned land uses in the City of Irvine, the Corridor would not result in a constructive use of the resource if the least environmentally damaging feasible alternative is chosen. 3-8-96 The changes requested in the comment are hereby incorporated into Appendix A of the FEIR/EIS. 4-19-5 Please refer to Appendix A of the EIR/EIS for a discussion of publicly owned bike paths and trails in the vicinity of the Corridor and the Corridor's visual and noise effects on these resources. Measures to minimize harm have been provided where potential impacts have been identified. The comment does not identify any resources where this discussion is considered inadequate and the comment is therefore the opinion of the commentator and will be taken into con- sideration by the decision makers during the review process. 4-22-24, 7-56-44, 7-88-63 Appendix A provides a discussion of the Corridor's effect on 4(f) resources in its vicinity and outlined measures to minimize harm to these resources. The comment does not identify where the information provided is not substantive and therefore the comment is the opinion of the commentator and will be taken into consideration by the decision makers during the review process. 4-25-3. 7-118-4 Appendix A of the EIR/EIS addresses the area to be acquired through the bond measure (identified as Northwest Park in Appendix A) and the Capistrano Bluff Open Space to the north. As shown in Figure 3.7.1, illustrated land uses are generalized to reflect major General Plan land use designations. A General Plan amendment which changes the designation areas to be acquired by the bond measure to open space/preservation has not been completed at this time; thus this figure illustrates the most current City General Plan designations in this area. 01/31/91(TCA9018%iNDEXV-4) 4 F- 1 0 0 0 4-25-5. 8-9-6 As noted on page 4-88 of the DEIR/EIS text, all transition work for the Corri- dor/I-5 connection will occur within the existing I-5 right-of-way. This transition work will not significantly alter the existing visual or noise environment. The predicted year 2010 noise levels near the open space areas (with the project) are less than 65 CNEL, which is the noise standard for park/open space areas (see results for receptor R17). Therefore, no noise standard for mitigation is required. With respect to historical landmarks, since all construction will occur within the existing I-5 right-of-way there will be no impacts to Camino Capistrano near the three farmhouses located within the open space area near Trabuco Creek. Also, please refer to Responses to Comments 4-25-3 in this Chapter and 4-25-4 under Visual. 4-25-7 Scenic corridors are not protected resources under Section 4(f) of the Depart- ment of Transportation Act. As discussed in Response to Comment 4-25-6 under Cultural/Paleontology Resources, all of the sites identified are outside the Area of Potential Effect (APE). The APE, approved by FHWA, was developed to delineate the maximum area for cultural resources that would be directly or indirectly affected by con- struction of the Corridor. Section 4(f) would only apply to archaeological or paleontological resources within the APE which are on or eligible for the National Register. The second paragraph of the comment reflects the opinion of the author which will be taken into consideration by the decision makers. 4-32-44 Measures to minimize harm (i.e., mitigation measures) were incorporated into Appendix A - Section 4(f) Evaluation of the DEIR/EIS. 4-33-86 As discussed in Chapter 2.0, connection of the Corridor to the I-5 Freeway will require some widening of I-5 from approximately the Avery Parkway interchange to Ortega Highway depending on option selected. All improvements will be constructed within existing publicly owned right-of-way. • 01/31/91(TCA901B%INDEXV-4) 4 F - 1 1 0 4-33-87, 4-33-94 Notwithstanding the fact that some of the identified potentially affected 4(f) resources were cooperatively planned with the development of the Corridor, the 4(f) analysis discusses the potential effects of the Corridor on all of the identified 4(f) resources, and goes beyond the requirements of Section 4(f) to analyze privately owned areas offered for dedication to a public entity as well as areas that have been designated on a formal plan as a future park which are not yet in public ownership. However, areas of cooperative or concurrent planning are identified in the discussion of potential 4(f) resources in Appen- dix A, and in Attachment B to Appendix A (History of Cooperative Corridor and Open Space Planning in Orange County) because the development of park and open space properties in conjunction with regional transportation planing provides additional context in which to understand the impacts of the Corridor on 4(f) resources. Further, the Federal Highway Administration has recently published proposed rules defining the extent of constructive use under Section 4(f), which indicate that constructive use impacts do not occur where the Section 4(f) resource and the proposed transportation improvement have been concur- rently planned (see, 55 Fed.Reg. 23). . 4-33-88. 4-33-90 FHWA defines "constructive use" as circumstances where the transportation project does not incorporate land from a Section 4(f). resource; however, the projects proximity impacts are so severe that the activities, features or attributes that qualify a resource for protection under Section 4(f) are sub- stantially impaired and which require noise abatement measures. As discussed in Appendix A of the DEIR/EIS, the activities, features or attributes of Aliso/ Wood Canyons Regional Park, Sycamore Hills and Laguna Laurel Dedication Area, in the vicinity of the Corridor, will not be substantially impaired by con- struction of the Corridor. In the case of Aliso/Wood Canyons Regional Park, the activities in the vicinity of the Corridor are of a short duration and would not be significantly impaired by noise from the Corridor. In the case of Sycamore Hills and the Laguna Laurel Dedication Areas, there are no existing or planned recreational facilities in these areas which would be impaired by noise from the Corridor. Please refer to Response to Comment 4-32-14 under Noise for a discussion of noise impacts on biological resources. 01/31/91(TCA901B%INDEXV-4) 4 F- 1 2 0 0 4-33-89, 4-33-91, 8-4-4 The 4(f) analysis indicates that although construction of the proposed project would substantially increase noise levels, it would not substantially impair the activities, functions or attributes of this resource. Thus, a constructive use would not occur. The opinion of the City has been included in the EIR/EIS to fully disclose the stated position of the City on this matter. 4-33-92 As described at page 33 of Appendix A of the Draft EIR/EIS, the Corridor align- ment passes between the two Laguna Laurel dedication areas in a reserved right- of-way. By remaining in this alignment, the Corridor will not require acqui- sition of right-of-way from the dedication area resource, and thus will avoid actual use of the dedication areas. Due to the longitudinal nature of the resource, shifting the alignment of the Corridor either inland or seaward would require an actual take of right-of-way from either the northern -or southern dedication area, resulting in a greater impact to the resource. Note that any alignment seaward of the alignment proposed would result in an actual take of right-of-way from Crystal Cove State Park, while an inland shift of alignment sufficient to entirely avoid the northern Laguna Laurel dedication area would require an alignment of the Corridor. through existing residential areas, resulting in substantial community disruption, and failing -to meet the trans- portation goals of the project. 4-34-8 Appendix A identifies Section 4(f) resources and examines the Corridor's effect on the existing and planned facilities within these resources in the vicinity of the alignment. This analysis determined that Corridor -related proximity impacts (i.e. visual, noise, air) will not significantly impair the activities, features and attributes of these resources. In particular, the Corridor will not be visible from Crystal Cove State Park due to intervening topography and vegetation. It is true that the Corridor will be visible from the other re- sources identified in the comment, however, the visual exposure to the Corridor does not substantially impair the use of the resources. Please refer to Responses to Comments 2-8-22 and 2-8-23 under Water Resources regarding flooding and water quality. The last two sentences of the comment are the opinion of the author and will be taken into consideration by the decision makers during the review process. 01/31/91(TCA9018%INDEXV-4) 4 F - 1 3 • 4-36-7 Please refer to Response to Comment 4-33-89 in this Chapter. Also, the Corri- dor's effect on the Sycamore Hills Open Space Area is discussed in Appendix A - Section 4(f) Evaluation in the DEIR/EIS. 6-17-52 Appendix A of the DEIR/EIS is correct when it states that there will be no physical effect on the San Diego Creek trails by the Corridor. 6-17-53 The majority of the text modification requested is provided in the text on page 40 of Appendix A. Addition of this information into Table B would not alter the discussion or conclusions provided on this page. However, the text on page 40, third paragraph is hereby modified and incorporated into the FEIR/EIS as follows: "... In addition, freeway widening, where existing bridge, piers or • abutments cannot accommodate the additional lanes, would require rebuilding interchanges and bridge structures. The necessary freeway widenings are iden- tified on Table 2.8.6. ..." 6-17-54 Pages 40 and 41 analyzes how the Non -Alignment Alternative does not meet the project objectives outlined in Chapter 1.0. The content of the amplification requested by the comment is unclear, therefore the existing discussion of nonconformance with project objectives has not been modified. 7-14-5. 7-14-6. 7-14-7. 7-14-8. 7-53-1. 7-56-43, 7-75-2 Pursuant to Section 4(f) of the U.S. Department of Transportation Act (49 U.S.C. 303), the Secretary of Transportation shall not approve any project which requires the use of any publicly owned land from a public park; recrea- tion area, or wildlife and waterfowl refuge of national, State or local sig- nificance as determined by the federal, state or local officials having juris- diction thereof, any land from a historic site of national, State or local significance as so determined by such officials unless 1) there is no feasible and prudent alternative to the use of such land, and 2) such program includes all possible planning to minimize harm to such park, recreational area, wild- life and waterfowl refuge, or historic site resulting from such use. The commentator is therefore incorrect in stating that the project cannot be con- structed because of Section 4(f). The Section 4(f) Evaluation in the EIR/EIS 01/31/91(TCA9018%INDEXV-4) 4 F - 1 4 meets the requirements of Act through provision of the following items: 1) identification of the Corridor-s effect on 4(f) resources, 2) evaluation of potential alternatives and 3) recommendation of measures to minimize harm to these resources. By definition, Section 4(f)'applies only to publicly owned areas, except for historic places, which may be in either public or private ownership. Although not required by judicial interpretation of Section 4(f), Appendix A goes beyond the requirements of Section 4(f) and analyzes privately owned areas offered or which may be offered for dedication to a public entity as well as areas that have been designated on a formal plan as future park, recreation or wildlife areas under public ownership and which may be developed prior to project con- struction. Analyses of these "non-publ.ic" areas are provided in the event the areas are ultimately conveyed to the public, or it is subsequently determined that Section 4(f) applies to such areas. Please refer to Response to Comment 7=56-1 under Purpose and Need. 0 7-22-6 See Response to Comment 4-24-5 under Air Quality. 7-45-5 As stated at the public meeting on November 14, 1990, the information presented was a brief overview of the major environmental issues contained in the DEIR/ EIS and was not meant to be a comprehensive discussion of all impacts iden- tified in the document. 7-56-42 Please refer to Response to Comment 7-56-1 under Purpose and Need. 7-86-28 Please refer to response to comment 2-7-3 under Biology. 7-86-29, 7-86-30 Modification of these figures do not alter the conclusions of the analysis presented in.the EIR/EIS and have not been incorporated into the FEIR/EIS. • 01/31/91(TCA9018,INDEXV-4) 4 F - 1 5 7-86-31 As discussed in Section 4.15 of the EIR/EIS and shown on Figure J-16, from this vantage point the Corridor will not be visible. 7-88-62. 7-88-65, 7-88-66 Please refer to Response to Comment 2-7-14 under Biological Resources. 7-118-2. 7-134-2 Please refer to page 23 of Appendix A of the DEIR/EIS for a discussion of an alternative route for bicyclists to access Avery Parkway to the north. 8-6-1 Please refer to Responses to Comments 2-8-43 and 3-5-140 in this Chapter. 8-9-3 0 Please refer to Responses to Comments 3-4-76 and 4-25-3 in this Chapter. 01/31/91(TCA9018%INDEXV-4) 4 F- 1 6 • EXHIBITS Ia01/31/91(TCA9018%INDEXV-4) i TABLE OF CONTENTS EXHIBIT 1 - FINANCING PLAN EXHIBIT 2 - AESTHETIC DESIGN GUIDELINES EXHIBIT 3 - BUSINESS RELOCATION INFORMATION EXHIBIT 4 - STAMINA NOISE MODELING EXHIBIT 5 - MYTHS AND FACTS ABOUT TRANSPORTATION AND GROWTH Is 01/31/91(TCA9018%INDEXV-4) CJ EXHIBIT 1 FINANCING PLAN 0 01/31/91(TCA9016%INDEXV-4) • • • • 1 e w lop it TRANSPORTATION CORRIDOR AGENCY FINANCING PLAN �lil�l 'il 7� 0 TABLE OF CONTENTS Executive Summary ...................................... i Recommendations...................................... 1 Financing Plan Objectives .................................. 5 Project Feasibility ....................................... 8 Interim Financing Plan .................................. 23 Potential Risks and Mitigation Measures ...................... 35 0 San Joaquin Hills Transportation Corridor Agency • Financing Plan Executive Summary EXECUTIVE SUMMARY I. Objectives of Financing Plan The primary objectives in developing a Plan of Finance for the San Joaquin Hills Transportation Corridor ("SJHTC") toll road project were to determine the project's long-term financial feasibility and to design the most flexible, least costly method of financing the project. Feasibility was examined based on the following information: • Costs estimates for various corridor configurations provided by CDMG with adjustments by TCA staff. • Toll revenues as forecast by Wilbur Smith Assoc. as of May 1990. • Administrative and Operating Costs provided by CDMG. • Grant of $46.5 million to be provided by the California Transportation Commission. • Availability, constraints, and costs of debt financing estimated by First Boston and Public Resources Advisory Group. When the SJHTC was conceived, it was apparent the project could not be funded on a pay-as- you-go basis. Since inception of this project, the need for external debt financing has always been an integral component of various financing alternatives and has always been taken into account when analyzing the project viability. Given these facts, the Plan of Finance focused on the availability, structure, timing, amount, and cost of any debt financing and the impact of various debt financing alternatives on project feasibility. In an attempt to minimize debt service during construction and recognizing that toll revenues would be available only once the road had opened, the Plan of Finance analyzed construction financing options and options for interim financing. Every effort was made to limit the need for and the cost of interim financing. Since substantial expenditures are projected to be made by the TCA prior to the availability of construction financing for design, right-of-way acquisition, and environmental costs, the following scenarios were examined: • The SJHTCA's ability to spend at current rates given its cash balance and projected developer fee revenues. • The SJHTCA's flexibility to adjust the amount/timing of expenditures and revenues to eliminate or delay the need for an interim financing. • If a cash shortfall exists, the amount of interim financing necessary to close the gap. • For any interim financing, the availability, sources, and costs of such financing. II. Project Feasibility The fundamental premise for determination of project feasibility is that projected revenues must be sufficient to cover toll collection and operating expenses plus repay any borrowed funds -i- San Joaquin Hills Transportation Corridor Agency Financing Plan Executive Summary (principal and interest) given an assumed amortization schedule. Revenues must also be sufficient to provide a certain level of coverage above debt service requirements and to provide for operating and capital reserves. Various measures of feasibility were examined and are discussed in detail in the report. Projects which did not meet the feasibility criteria were analyzed to determine whether cost reduction measures, phasing of expenditures or revenue enhancements would satisfy the requirements. Various financing mechanisms were also reviewed in order to meet the above tests. The impact of changes in the following assumptions were analyzed: • Project Costs and Configuration • Projected Revenues • Project Start/Completion Dates • Financing Structures and Costs IIL Interim Financing Requirements Construction bond proceeds necessary to provide funds for the construction of the SJHTC toll road cannot be spent prior to the receipt of all Environmental Clearances, expected by the last quarter of 1991. Such approval is subject to delays both in the review process and as a result of potential environmental challenge. The length of delay, if any, cannot be predicted and is out of the SJHTCA's control. To expedite the opening of the corridors, the TCA Board has pursued a dual -track process of design and environmental clearance. H this current schedule is maintained substantial expenses will continue to be incurred prior to the availability of construction financing and the developer fees available to meet these expenditures will be depleted by late 1990 or early 1991. Thus, two major options were reviewed: • Adhere to current schedule and spend developer fees until funds are insufficient and secure external interim financing at that time. • Reduce expenditures and/or accelerate receipt of revenue to eliminate (if possible) or minimize the need for external interim financing. The TCA has options that would delay the need for and/or reduce the amount of interim financing required to continue to move the project forward. These options include: Increasing revenues by: - deferring developer fee credits. - Negotiating for the advance payment of developer fees. Decreasing expenditures by: - deferring the acquisition of certain right-of-way. - discontinuing or delaying work currently underway on final design contracts. - negotiating fee deferrals with service vendors. C7 San Joaquin Hills Transportation Corridor Agency Financing Plan Executive Summary Each option was reviewed for its impact on the need for interim financing, the overall cost and feasibility of the project, and the scheduled project opening date. Under every scenario, some interim financing will be required. Therefore, the availability, sources and costs of interim financing was reviewed. The amount and timing of any interim financing depends, in part, on the decisions made by the Board as outlined in the Report. Sources of external financing are limited and expensive because of the uncertainty that surrounds the TCA's ability to pay back any monies advanced to it due to a delay in receiving environmental clearance or in the worst case scenario, the project abandonment. Absent take-out construction financing, developer fees would be the only source available to pay back the loan. Potential sources of interim financing include: • Letter of credit supported variable rate bonds • Developer fee advances • Bond anticipation notes • Loans from other governmental agencies in Orange County • Direct loans from financial institutions Each potential source was reviewed for costs, availability and constraints on further TCA activities. IV. Summary of Results A. Project Feasibility Based on current revenue projections, it is possible to finance the construction of the demand management alternative (six lanes initially) for opening in July 1995, and satisfy the feasibility criteria. Specifically, the proposed project cost is $680 million in $1990 and can be financed with a construction bond issue of approximately $883 million. The report assumes that the construction bond issue will bear interest at a floating rate during the construction period and be backed by a letter of credit. Upon opening the toll road it is assumed that the bonds will be converted to a fixed rate of interest if the long-term market conditions are favorable. Summary of Feasibility Results (in millions) Project Financing Interest % Cost Requirements Coverage CABs Phase I - No HOV $680.0 $883.2 131x 10.4% The optimal plan of finance would include the Board taking a number of actions to minimize the amount of permanent- financing required and implement a finance plan which maximizes the strength of the credit which will result in the lowest cost of funds for any given bond structure. While the long-range project feasibility is positive, there still exists the need for 0 San Joaquin Hills Transportation Corridor Agency Financing Plan Executive Summary some level of interim financing prior to the issuance of construction financing if the SJHTCA continues its concurrent design and environmental processes. B. Interim Financing Requirements Interim financing will be required, the amount and timing of which is dependent upon certain steps taken by the TCA and certain actions beyond the control of the TCA. The range of the amount of interim financing required is $5 million to $50 million and monies may be needed as early as December 1990. An extensive delay in receiving environmental clearance could require the extension of additional loans in addition to the initial interim financing. Staff believes that interim financing is available but sources diminish as the amount approaches $40 million. While no provider of interim financing has been asked to give a firm commitment at this time (pending the submission of the final toll rate study, the adoption of the recommended developer fee levels, and the establishment of certain revenue and expense policies by the TCA Board). Staff is confident that interim financing can be obtained at an acceptable cost. Amount of Interim Financing Required I. Current Dual Approach $ 50,087,000 H. Defer Design and Non -Critical ROW $ 11,602,000 0 -iv- 0 San Joaquin Hills Transportation Corridor Financing Plan RECOMMENDED BOARD ACTIONS Recommendations The following items summarize the primary issues upon which the San Joaquin Hills Transportation Corridor Agency Board must take action in order to direct staff to pursue a financing plan. The action the Board takes will shape the future policy for the corridor, and will affect the feasibility of the project and project schedule. 1. What criteria should the Board adopt for annually calculating developer fee rates? Staff believes the SJHTC Board should set rates based on (1) a feasible project, not the ultimate project (including HOV lanes, for example); (2) a 10% construction contingency, not the 25 % to 30 % contingency used for financial feasibility purposes; and (3) financing costs based on a formula as described in this report. Based. on Board direction, staff will instruct Deloitte and Touche to calculate new developer fee rates. Once the Deloitte information is available, staff suggests that this information be provided to the Board and to the development community for review and discussion. After that review, staff will provide a recommendation to the Board on the final criteria for determining the developer fee formula and the rates which result. Staff also recommends that these rates be adjusted annually. 2. Should the TCA continue the existing Developer Fee Program policy of maintaining developer fee credit unit values for dedicated right-of-way at $50,000 per acre escalated annually by the Construction Cost Index? Yes. The intent of the fee program was to place a nominal value on the additional right-of- way required by the TCA in excess of the 120 foot corridor to the hinge points. The program was designed based on the premise such right-of-way had limited other use and its value was less than fair market due to constraints on its use. In June, 1987 the Board decided to utilize the California Construction Cost Index (CCCI) for the previous calendar year and apply any increase to the collection period commencing with the next fiscal year. The rate in effect before last year's interim rate increase was $54,737. When adjusted for a CCCI increase of 1.84% (89-90) the new rate for right-of-way credits for fiscal year 90-91 is $55,774. 3. Should all fee credit agreements for completed grading and other improvements excluding right-of-way dedication be executed by September 30, 1990? Yes. Deloitte & Touche has recommended that the TCA obtain executed fee credit agreements for grading and other improvements by a date certain, at least 60 days prior to financing, in order to more accurately project developer fee revenue. TCA staff recommend a date of September 30, 1990, in the event a letter of credit backed interim financing is needed. If the letter of credit financing is not needed, this date could slip to January 1, -1- San Joaquin Hills Transportation Corridor Financing Plan Recommendations 1991, prior to taking bids for the construction manager or design/build firm. Landowners that determine after September they wish to grade certain portions of the corridor or provide other improvements in the future may enter into separate agreements providing for a subordinate fee credit or cost reimbursement at later dates. The fee credit estimates used in this report are based on all right-of-way expected to be dedicated by landowners and on grading that had been completed as of January 1990. This policy would allow the TCA to quantify its fee credit liabilities and better manage its cash flow requirements. In lieu of a fee credit agreement, landowners who agree to defer fee credits should be permitted to enter into fee credit agreements at any time prior to construction. 4. Should the TCA negotiate deferral of developer fee credits until construction financing is obtained (which is expected to occur in July 1991)? Yes. This policy would postpone and possibly eliminate the need for external interim financing, depending on the level of landowner participation. Landowners would be repaid for their fee credits, plus accrued interest, from the proceeds of a construction financing. If certain of the revenue assumptions used in this report are not realized, or if assumptions should change in the future, it may be necessary to postpone repayment of deferred fee credits until after the SJHTC opening date in 1995. If this becomes necessary, landowners would be repaid for their fee credits, plus accrued interest, through project cash flow on a subordinate basis to the SJHTC senior toll road revenue bonds. Should the Board decide to pursue fee credit deferrals, TCA staff will begin negotiating fee credit deferral agreements with each landowner. 5. Should the TCA fund its share of improvements to the I-73/405 confluence ($13 million) as part of the SJHTC? Yes. TCA staff, Caltrans, OCTC and the Cities of Costa Mesa and Newport Beach have determined TCA's share of funding responsibilities for the 73/405 confluence improvements to be $13 million based on traffic impacts. The feasible project presented in this plan assumes the $13 million ($1990) is in the project cost estimate. These funds will be utilized to construct meaningful interim improvements to the 73/405 confluence. 6. Should the TCA revise expenditures prior to receipt of environmental clearances, in order to minimize the amount of interim financing? Yes, if the Board wishes to minimize the amount of interim financing. Potential expenditure deferrals are listed below: (a) Reduce design expenditures by taking all design contracts to the level of 35 % completion on a current basis and then await environmental clearance. C -2- San Joaquin Hills Transportation Corridor is Financing Plan Recommendations • (b) Require further design management work to be completed by firms that agree to defer all or a portion of compensation until after receipt of construction financing. (c) If a design build approach is adopted, require, as a condition of bid award, that the firm agree to defer all or a portion of final design compensation until after construction financing is obtained. (d) Defer purchase of major right-of-way parcels that are not to be dedicated until after receipt of construction financing. Begin working on securing land through option agreements or other contracts so that land can be purchased quickly once construction financing is obtained. Exclude parcels for which the SJHTCA has an obligation to acquire by specific date. 7. Should the TCA pursue external interim financing to meet its funding gap, if any, prior to construction financing? Yes, if determined to be necessary. The amount of interim financing required will depend on the degree to which design expenditures are scaled back and whether developer fee revenues are increased as assumed in this analysis. Staff s preference is to minimize the need for interim financing and to meet expenditure requirements from fee credit deferral and developer fee advances (internal sources). However, interim financing is available from third parties (external sources) to meet expenditure needs that cannot be funded through internal sources and would provide the TCA with a sufficient working capital balance. The SJHTC interim financing needs of approximately $50 million (through June 1990) can be met as follows (in 000's): Savings or Revenue Produced Stop final design at 35% level $15,978 Defer purchase of right-of-way 21,389 Landowner Assistance 11,602 Defer construction related expenses 1.118 $50,087 If the Federal Highway Administration approves the SJHTC environmental documents, as scheduled, in April 1991, staff believes that a July 1991 construction financing is achievable. If the date of construction financing is delayed, additional sources of internal interim financing from developer fee advances are believed to be available to take the SJHTC to December 1991. Delays beyond this date would require additional interim financing. -3- San Joaquin Hills Transportation Corridor Financing Plan Recommendations S. Should the TCA investigate the use of a design/build alternative for the SJ= that would place the responsibilities for design, construction and completion of the corridor on a single firm? This alternative is believed to have significant financing benefits by providing credibility to the TCA in the area of construction expertise and ability to complete the corridor within an agreed upon time frame and cost. As an alternative to design/build, a fixed price construction contract from a single contractor should be pursued under a conventional construction approach. • • -4- • San Joaquin Hills Transportation Corridor Agency Financing Plan Financing Plan Objectives FINANCING PLAN OBJECTIVES The financing plan recommended in this report has been developed to establish a clear, credible plan for providing the funds to construct the San Joaquin Hills Transportation Corridor. ("SJHTC") A preliminary financial feasibility report is concurrently being prepared for the Foothill/Eastern Transportation Corridor ("F/ETC") projects. The financing plan accomplishes the following objectives: (1) Establishes parameters of project feasibility; (2) Determines the maximum feasible project based on available and projected revenues given the feasibility criteria; (3) Identifies alternatives for meeting short-term cash flow needs and discuss `advantages and disadvantages of each; and (4) Presents the SJHTC Board with general recommendations and a list of policy decisions it must make in order to implement a plan of action. The report is separated into two sections: (1) Project Feasibility and (2) Interim Financing. Project Feasibility discusses the projected costs and resources of the SJHTCA and the ability to leverage those resources to assure timely completion of the project. Based on the cost and revenue estimates used in the analysis, and review of the other start-up toll road financing plans and anticipated requirements of letter of credit banks, the SJHTC is shown to be a financially feasible project. This section also analyzes the impact of changes in certain assumptions on the financial feasibility of the SJHTC. Because it is not possible to spend toll road revenue bond proceeds for construction until the environmental approvals necessary to build the corridors have been obtained, the TCXs financing needs have been split into three different time periods: Interim Financing, referring to the period from today until the EIS for each corridor is certified, the record of determination from the Federal Highway Administration, and all permits necessary for construction have been obtained. Construction Financing, referring to the period after environmental clearance to the date of completion of each corridor; and Operations, referring to the period from completion of construction to the repayment of all outstanding debt obligations of the SJHTCA. -5- San Joaquin Hills Transportation Corridor Agency • Financing Plan Financing Plan Objectives Exhibit One depicts a matrix of the types of resources and project needs in the various time periods considered by this finance plan. Interim Financing discusses the SJHTC cash flow requirements in the period prior to its ability to obtain construction financing. This section analyses how much external financing is required under various expenditure and revenue scenarios and the alternative means of obtaining the required funds. The plan discusses options to maximize the amount of revenues available to the TCA especially during the critical interim and construction financing time periods in order to reduce the TCA's ultimate debt burden (financing requirements). The plan reviews the impact of deferral of developer fee credits and increasing developer fee revenue during these periods. Deferring all or a portion of payments to service vendors is also a means reducing costs prior to the TCA's ability to obtain construction financing. 0 San Joaquin Hills Transportation Corridor Agency • Financing Plan Financing Plan Objectives IWAwoI M it • ►I AVAILABLE RESOURCES VS. PROJECT NEEDS THROUGH EIRJEIS APPROVAL AND PERMIT 11ING CONSTRUCTION PERIOD AVAILABLE Developer Fees on hand Revenue Bond Proceeds RESOURCES Developer Fees net Developer Fees net of fee credits of fee credits Interest Income CTC Grant External Financing Interest Income PROJECT Administrative Costs Right-of-way NEEDS Design & Environmental Construction Costs Financing Costs Right-of-way -7- OPERATION Projected Toll Revenues Developer Fees net of fee credits Interest Income Toll Operations Debt Service Coverage Requirements Reserves Median Improvements Insurance Repayment of subordinate obligations Fee Credit Deferrals San Joaquin Hills Transportation Corridor Agency Financing Plan Project Feasibility • PROJECT FEASIBILITY The projected resources of the SJHTC were analyzed to determine the maximum affordable project that could be initially completed. Given the most current cost and revenue projections, the financial resources available to the SJHTC will support the construction of a six -lane facility to open in 1995. From an operational, as well as a financial perspective, median improvements, such as High Occupancy Vehicle ("HOV") lanes, should be added to the facility as traffic demand requires. Postponing HOV lanes will not impact toll revenues unless delayed beyond 2000. It is expected that HOV lanes and additional corridor improvements will be funded out of excess cash flow generated by toll revenues. Based on projected revenues, this project appears able to generate revenues sufficient to repay the toll revenue bonds issued for the project and provide sufficient debt service coverage levels. Measures of Project Feasibility There is no single "correct" measure of a financially feasible project. A fundamental requirement for a feasible project is that projected toll and developer fee revenues must be sufficient to cover toll collection and operation expenses and repay any borrowed funds within a specified period of time. In addition, annual project revenues must be sufficient to provide a certain level of coverage in excess of debt service and to provide for certain operating and capital reserves. The measures of project feasibility described below together comprise a target which must be met in order for the SJHTC to present a viable project to the financial markets. The plan of finance presented in this report used these measures as targets to develop a feasible project. A project which did not initially meet these targets was analyzed to determine whether cost reduction measures, project phasing alternatives or additional revenues could be developed to cause the project to become financially feasible. L Cash flow in the first year of operations must cover, at a minimum, operating expenses and estimated interest expense on borrowed funds plus a 2001.o to 30% cushion for a debt service coverage ratio of 120x to 1.30x. Opening year cash flow is a critical determinant of feasibility. To calculate this measure, it is assumed that the tax-exempt variable rate construction bonds remain outstanding at a cost of 7.625% (including letter of credit and remarketing fees) through the first operating year. If the target ratio of 1.20x is met, the SJHTC has a certain amount of cushion above the assumed variable interest rate. This target is not an indicator of long-term feasibility, but measures opening year feasibility. Although a coverage ratio of 1.20x has been established as a minimum target, the preferred coverage ratio is 1.30x. 0 IF:10 San Joaquin Hills Transportation Corridor Agency Financing Plan Project Feasibility IL Average increase in annual debt service is limited to Z50%. The SJHTC toll revenue projections increase significantly from year-to-year. Opening year revenues are projected to be $90 million while fiscal year 2010 revenues, for example, are projected to be $165 million and the average annual increase exceeds five percent. This increase is due to projected development which will result in growth in ridership and from the assumption that tolls rise at the rate of inflation. Because opening year revenues can only support a limited amount of debt service, it is necessary to have higher debt service in later years when project revenues can retire a Iarger portion of the debt. Debt service in the early years can be reduced through the issuance of capital appreciation bonds ("CABs"). However, steep annual increases in debt service will not be viewed favorably by the financial markets. Investors and rating analysts will be concerned that the SJHTC may be unable to meet its debt service obligations if revenues do not rise as sharply as projected Therefore, in order to issue long-term fixed-rate revenue bonds, it will not be possible for debt service to rise as sharply as projected revenues. In fact, most investment grade revenue bonds are repaid with level debt service. The 2.50% escalation rate was determined based on a comparison of the TCA projects with other toll roads and the fact that average annual toll revenues are projected to grow at 5.00%. In most toll roads, debt service expenses are generally kept level and do not vary significantly from year-to-year. However, the costs of maintenance comprise a much larger portion of most toll road operating budgets than is expected for the SJHTC since the State will be responsible for maintaining the corridor. Because operating costs generally are assumed to increase annually due to cost inflation and the increased maintenance needs of the roadway, most toll roads meet these higher operating costs from toll increases. The SJHTC will experience moderate increases in operating costs and increasing levels of debt service in order to repay the bonds within 30 years. By limiting annual debt service growth to 2.50% (one half of the projected toll revenue increase), the TCA can present the financial markets with a project that limits sharp debt service increases which hopefully will be viewed as comparable to other toll road financings. In addition, it is expected that the SJHTC will have sufficient revenues within its first 10 operating years to amortize its remaining debt on a level basis. HL Debt is repaid within 30 years from opening year at coverage ratio of 1.20x- This measure of long-term feasibility indicates whether the revenue bonds can be repaid within 30 years given the projected available revenues and the limitation on the annual increase in debt service of 2.50%. Although it may be possible to issue bonds with a maturity greater than 30 years for certain types of projects, the uncertainty of toll revenue projections for a start-up toll road may cause concerns for a financing greater than 25 to 30 years. One of the covenants required by the issuance of toll road revenue bonds will be a pledge of the SJHTC to establish tolls at a level sufficient to pay the costs of maintaining the toll collection system, pay debt service on all bonds issued, and each year provide a cash flow cushion equal to a certain percentage of annual debt service. The later revenue requirement is referred to as the coverage amount and typically has ranged from 1.20x to 1.30x on toll revenue financings. Coverage is important because ME San Joaquin Hills Transportation Corridor Agency Financing Plan Project Feasibility it provides a degree of comfort to investors that the net revenue projections could be off by as much as 20% to 30% and continue to cover debt service payments. Coverage will be particularly important to investors of the SJHTC because it will be a "start-up" toll road where there is no performance history and the projected toll and developer fee revenues will be discounted heavily as they are based on future growth assumptions and thus subject to economic downturns. Determination of Maximum Project Based on Project Revenues Project costs for the corridor will be funded through three primary sources: 1) developer fees paid by developers pursuant to the Major Thoroughfare and Bridge Fee Program; 2) proceeds from the sale of toll road revenue bonds to be issued by the TCA and repaid from the tolls and developer fees collected during operation of the corridor; and 3) toll revenues above those necessary to pay debt service on TCA revenue bonds. Other sources of funds are expected to include a $46.5 million grant from the CTC, potential SB 140 funds and interest income. Additional funds may be generated from arbitrage earnings on borrowed funds, franchising alternative uses of the right-of-way such as fiber optics, service areas, air rights, etc; however, due to the uncertainty of these sources, and questions concerning who (TCA or Caltrans) would benefit from the revenue, they are not taken into account in this financing plan. The finance plan recommends the maximum feasible project cost that can be supported by the revenues currently projected to be available to the TCA. The goal of the finance plan is to fit the TCA's project needs within its available financial • resources and those financial resources projected to be available over time. The project funding sources identified above are limited in amount. The levels and timing or the receipt of funds are subject to change. Developer fee income depends on the level of the fees assessed by the TCA, the actual rate of development in the areas of benefit during the construction and operation of the corridor, and the amount and timing of fee credits for which certain developers are eligible. Toll revenues to be collected by the TCA are limited by the amount of traffic projected on the corridor, the willingness to pay the established tolls, and the sensitivity of corridor traffic to the level of tolls. The financing plan has been prepared using assumptions on developer fee revenue and toll revenues provided by Wilbur Smith Associates ("WSA"). Developer Fee Revenue Estimates Deloitte has provided a forecast of developer fee receipts and fee credits based on the interim rates which became effective in December 1989. Until certain Board actions are taken which will provide the information necessary to generate new forecasts based on revised project costs and schedules and certain assumptions as to the amount of contingencies and financing costs, Deloitte cannot provide a revised forecast. The feasibility analysis assumes increases in developer fees based on the policies recommended below. Once the Board takes action on the issues mentioned above, Deloitte will generate new developer fee rates and provide a anew developer fee forecast. A discussion and staff -10- San Joaquin Hills Transportation Corridor Agency • Financing Plan Project Feasibility recommendations on the specific issues are listed below- (1) The Board's approval of a certain project will be the basis for determining the project cost in calculating the new developer fee rates. For example, if the Demand Management Alternative is selected as the preferred alternative, should the project cost for purposes of calculating fees include approximately $100 million for median improvements, even if the median improvements are not constructed as part of the initial phase? TCA staff and financial advisors recommend that the project cost should be based on a feasible project, which suggests only the initial phase project cost be included. (2) Currently, the project costs include a 25% - 30% contingency for the construction component of the total project cost. It has been argued that contingency is a "soft cost" that should not be included in the project cost base for purposes of determining developer fees, particularly if the fee program is revised on an annual basis and contingencies lessen or disappear over time as more accurate or actual costs are known. Past developer fee rates and all estimated project costs include contingencies. Since there is merit to arguing for and against including contingencies, a policy should be adopted that allows for some contingency, but that a level of contingency less than the full 25 - 30% be included in the developer fee project cost base.. TCA staff and the financial advisors recommend that a 10% contingency is reasonable. (3) Financing costs have been identified by legal counsel, TCA staff and advisors to be a legitimate cost of the project and a cost contemplated under the Developer Fee Program. Because of unknowns as to market interest rates which will be in effect in the future, the exact financing cost amount will not be known until the construction period is over. Therefore, TCA staff and the financial advisors recommend using and have developed a formula for determining the financing cost amount. The formula would include the upfront, one time issuance costs associated with doing a debt issue (assumed to be 3.5% of the bonds issued) and the ongoing interest costs, remarketing fees and letter of credit fees on all bonds issued calculated for one half of the construction period (estimated to be 7.625% for two years). This assumes unexpended bond proceeds would generate investment income to cover the financing costs for the other half of the construction period. (4) The project construction schedule will impact the amount of financing costs to be included in the project cost base for purposes of determining the new developer fee rates. Until the roads are open and generating revenue to pay interest costs, remarketing and letter of credit fees, those fees will be capitalized as part of a bond issue. An additional year in the construction schedule will mean an additional year of this component of the financing cost number derived from the formula described above. 0 -11- San Joaquin Hills Transportation Corridor Agency Financing Plan Project Feasibility • Traffic and Toll Revenue Projections WSA has prepared revisions to their traffic and toll revenue projections that were provided to the SJHTCA in September 1989. The revised toll revenue estimates are based on the use of an enhanced modeling approach, updated income and value of time information, improved trip tables and differing assumptions regarding competing routes. Toll rates are projected to be significantly higher than projected in the original WSA forecast presented in September 1989. The table below summarizes the differences in the toll rate and revenue assumptions between the WSA September 1989 and May 1990 estimates. Optimum Mainline Toll Rate Average rate per mile Opening year revenues (000's)t September 1989 MU 1990 $1.25 $2.25 $0.08 $0.15 $ 40,447 $ 62,043 WSA analyzed toll sensitivity by making projections at four alternate rates of $0.08, $0.133, $0.15, and $0.20 per mile. Exhibit Two shows the results of this sensitivity analysis. Based on this analysis, WSA has concluded that the SJHTC is less sensitive to tolls that the Foothill Transportation Corridor ("FTC") or Eastern Transportation Corridor ("ETC") and that a mainline • toll rate of between $2.00 and $2.25 would be optimum for opening year. Corridor Cost Estimates The Corridor Design Management Group ("CDMG") has prepared revised cost estimates and project timelines for each corridor as described in the Concept Report and Cost Estimate Report. These revised estimates were provided in 1990 dollars. The cost estimates were provided for both the conventional eight -lane facility and the demand management alternative (phasing the initial six -lane facility and median improvements) in order to determine which phasing alternatives could be financed using the initial construction financing. A summary of the cost estimates used in the analysis is provided below. CDMG has included a 25% contingency factor in their construction estimates. While this appears to be a larger than needed contingency for a project that is in final design, staff believes this approach is prudent to minimize the impact of increased project costs and for purposes of assessing project feasibility. Assumes opening of Foothill Transportation Corridor southern connection with I-5 in 1996. If FTC -South opens at a later date, SJHTC revenues are projected to be higher in opening years. -12- EXHIBIT 2 s Ln o u v g sm8llo© 10 suolillW anNEA31d moi idnNNV N N N O P. r 0 .9 L -13- San Joaquin Hills Transportation Corridor Agency Financing Plan Project Feasibility San Joaquin Hills Transportation Corridor Summary of Project Costs (000,000's) Inflated to $1990 Project Completion Conventional (8 lane) Alternative $804.0 $897.7 Demand Management (6 lane) Alternative: Initial Project 666.9 744.7 Median Improvements (HOV Lanes) 101.4 - 116.5 Confluence Improvements 13.0 15.0 Full Project $781.3 $876.2 Analysis of Long -Term Feasibility This section of the report describes the financial analysis underlying the financing plan for the SJHTC. The report analyzes the Demand Management Alternative with and without median HOV improvements available on opening day. In addition, the report analyzes alternative financing assumptions as to structure and cost of funds, the impact of a delay during construction, and revenue raising measures on the long-term feasibility of the project. The model developed for the financial analysis shows quarterly project cash flows during the construction period and annual cash flows during the operating period. The CDMG construction cost estimates are inflated on a quarterly basis at an annual rate of 5.00%. Estimates for design and right-of- way are not escalated because these figures were provided in future dollars. Operating costs fof toll collection were also provided by CDMG, and were escalated at an annual rate of 5.00%.. The operating cost estimates assume full utilization of AVI equipment. Financing Assumptions The Base Case developed for the analysis assumes federal approval of the EIR/EIS is obtained in April 1991 and the construction financing is able to occur by July 1, 1991. If all permits for construction have not been obtained by July 1, 1991, and they may not be obtained until December 1991, the July financing would be an interim financing with limited ability to spend bond proceeds, until all permits are obtained. The interim and construction financing is assumed to consist of tax-exempt variable rate toll revenue bonds secured by a letter of credit. Interest on the construction financing is capitalized in the bond issue for the full four-year construction period. -14- San Joaquin Hills Transportation Corridor Agency . Financing Plan Project Feasibility As the financing plan is refined, the SJHTC may decide to issue the construction bonds in amounts that can be expended within two year period in order to maximize permitted investment earnings as is discussed further under Additional Revenue Sources. The variable rate bonds are assumed to be converted to fixed rate bonds at the start of project operation in order to limit the exposure of the project to adverse variable interest rate movement during the operating period. The interest rate assumptions used in the financial feasibility analysis are as follows: Average interest rate on variable rate bonds: 6.500% Annual letter of credit fees: 1.000 Annual remarketing fees: 0.125 "All -in" financing cost: 7.625% Earnings on Invested Funds: 7.625 Average interest rate on fixed rate bonds: 8.25% It is impossible to predict the ultimate long-term take-out rate for the permanent financing because of the uncertainty over market conditions at the time of financing. A rate of 8.25% has been used as the rate the bonds would be expected to carry assuming they were rated at a BaaBBB level. The current (May 30, 1990) rate for 30-year BaaBBB Toll revenue bonds would be approximately 8.00%. The report tested the sensitivity to higher and lower long-term take-out • rates and average short-term construction period rates. The impact of changes in assumptions regarding (1) project configuration, (2) project revenues, (3) project start and completion dates, and (4) financing cost on the feasibility results is discussed below. All cases are described in terms of their impact on the feasibility criteria discussed in Section Two, including such measures as opening year interest coverage, ability to repay project bonds within 30 years of opening date, and the amount of CABS required. The results of the analysis are summarized in Table One. -15- p W� Q enn M w u 'w zw o p 5 o U�U x U o M �-+ .� 'r e� .-i a p o CA O A W OON N C t� cn p a• zad 0 14 a Z E- w H E* o z `s Up o ,..a .. Z a x W WJ M o 0 0 0 0 0 00 o Z Z az s ° O V F�1 T U eo a N O` C 7 1(•yl ° im ►�+ w e d ►+r p O o a kf) (� �w y Q � p tu 0 p O o a 8 E C7 ° z O A ca a a ¢ ca U L1 Gtl c a O U a �a San Joaquin Hills Transportation Corridor Agency Financing Plan Project Feasibility L Project Cost and Configuration The first configuration tested was the ultimate project of the Demand Management Alternative with HOV lanes available on opening day. The result is shown in Table One ("L Phase One - with HOW). This project configuration fails to pass the minimum feasibility criteria. Coverage of interest in opening year is l.11x which is less than the minimum criteria of 1.20x. In addition, the take-out financing cannot be repaid within 30 years and a Iarge amount (24.2%) of interest -deferring capital appreciation bonds is required. The fact that the HOV lanes cause the Phase I project to fail the financial evaluation criteria is consistent with the traffic projections. These projections indicate that initial traffic demand can be accommodated by a six -lane facility and that • HOV lanes are not needed initially from an operational standpoint nor will they provide additional revenue until the year 2000 or later. Because project revenues were unable to support a $781.3 million project in initial project years, the analysis looked at project reduction alternatives such as postponing the median improvements. The improvements to the median are expected to cost approximately $101.4 million in 1990 dollars. By deleting this phase of the project the required financing is reduced by approximately $155 million due to the additional financing costs associated with the bond financing. Because revenues are not impacted by the loss of the HOV Ianes, the feasibility of the project improves as shown in Table One ("II. Phase One - No HOW). Opening year interest coverage rises to 1.30x from 1.11x the amount of CABS needed drops to 10.4% from 24.2% and the bonds can be repaid within 28 years. This project configuration appears to be financially feasible and is utilized as the .Base Case against which alternative funding and schedule sensitivity analyses have been tested. EL Impact of CTC Funding Assistance The Base Case assumed that the $46.5 million grant from the California Transportation Commission ("CTC") is a source of revenue during the construction period. It is assumed to be available in fiscal year 1995. However, if Proposition ill fails and the State is unable to fund all the projects in the State Transportation Improvement Plan ("STIP"), and the SJHTC is one of the projects that must be deferred or eliminated from the STEP, the loss of this source of funding will negatively impact the financial feasibility of the SJHTC. (Table One "II. A. No CTC Funds"). If the $46.5 million is not received during the construction period, the construction financing increases by $55 million and opening year interest coverage drops from 1.31x to 1.23x and the amount of capital appreciation bonds required rises to 15.6% from 10.4%. HL Impact of One -Year Delay in Opening Date The financing plan analyzed the impact of a one-year delay in the project's assumed opening -17- San Joaquin Hills Transportation Corridor Agency Financing Plan Project Feasibility date due to events which occur after the construction bonds have been issued. The construction period is assumed to be lengthened by one year, causing additional construction period interest and inflation in construction costs. The full opening year becomes 1996 rather than 1995. The impact of a delay is shown in Table One ("II. C. Delay in Opening Date"). The added costs of the delay result in an increased financing requirement of $29 million. This causes 'opening year coverage to drop from 1.31x to 1.16x and the amount of capital appreciation bonds required rises to 20.5% from 10.4%. If the delay occurs pdor to the issuance of construction bonds, the impact on project feasibility would depend on whether interim financing had been obtained and the level of expenditures made during the interim period. The impact of a delay during the interim period will be less than that of a delay once construction bonds have been issued. IV. Impact of Deferring Fee Credits Until Opening Year Current policy permits landowners to apply fee credits for dedicated right-of-way and grading improvements against their developer fee liabilities at their discretion. The Deloitte developer fee forecast assumes that a landowner will use up all eligible fee credits first, before paying fees to the SJHTC. Consequently, most fee credits are used up in the first years of construction. By deferring the taking of fee credits until construction is finished, the amount of • bonds required is reduced and opening year coverage improves significantly. The impact is shown in Table One ("II. C. Defer Fee Credits"). Coverage improves from 1.31x to 1.39x and the amount of capital appreciation bonds falls from 10.4% to 4.7%. Landowners would receive fee credits plus accrued interest from excess operating revenues after the payment of debt service on the senior lien revenue bonds. This would reduce the amount of available cash flow available for other purposes, such as median improvements, until landowners are repaid. The model assumes that the landowners can be repaid within 10 years of opening date. V. Impact of Higher Interest Rates The financing plan tested the sensitivity of project feasibility to higher interest rates than have been used in the Base Case and the other alternatives discussed above. Because the Base Case assumes a variable rate construction financing at an average rate of 6.50% is available, the plan tested the impact of a 7.50% average construction interest rate. It should be noted that the current seven-day variable rate is approximately 6.00% and the average from 1983- to 1990 has been 5.44%. The impact of this higher interest rate is to increase the financing requirement by $44 million due to the higher construction interest carrying cost and to reduce opening year coverage to 1.10x from 1.31x. The amount of capital appreciation bonds increases to 14.7%, see Table One (H. D. 7.50% Construction Rate"). In addition, the financing plan tested the impact of a higher long-term take-out rate on IME • San Joaquin Hills Transportation Corridor Agency Financing Plan Project Feasibility project feasibility. The Base Case uses a take-out rate of 8.25%. The impact of a 9.00% take- out rate has is shown in Table One (M M 9.00% Take -Out Rate"). The amount of bonds is not affected by this assumption, however the amount of capital appreciation bonds required rises from 10.4% to 17.8% and the long-term pay out rises from 28 years to 30 years. If actual interest rates are lower than those assumed in the Base Case, project feasibility improves. Additional Revenue Sources In addition to the major revenue sources described above, the financing plan looked at additional revenue sources that could be available to the SJHTC. TCA staff will continue to pursue additional revenue sources through out the construction and operating period of the corridor. Among additional revenue sources potentially available to the SJHTC, are: (1) deferral of developer fee credits; (2) permissible arbitrage earnings on funds borrowed with tax-exempt debt; and (3) revenues from non -transportation uses of the SJHTC. Deferral Of Fee Credits The existing Fee Program allows landowners to provide right of way, grading, drainage and other improvements (to the extent they are included in the project cost estimates) and receive credits to be applied against their fee obligations. Right of way and grading credit unit values are stipulated in the Fee Program. A fee credit agreement between the TCA, the County and • landowner serves as the vehicle to identify the quantities (e.g., acres), unit values (e.g., dollars per acre), and total value of developer fee credits to be awarded for agreed upon dedications or services. These credits are drawn down as fees are owed at the time of building permit issuance. To date, approximately $14 million in fee credit agreements have been executed and it is anticipated that approximately $20 million more fee credit agreements will be executed in the future for right-of-way dedication as well as corridor grading for those areas which a landowner may be prepared to grade prior to construction of the SJHTC. There are no restrictions on the number or dollar value of fee credit agreements that can be executed. Staff has developed a standard fee credit agreement which all developers interested in obtaining a fee credit must sign prior to dedicating right-of-way or completing work that will be eligible for fee credits. Deloitte projections of fee credits by type are provided as follows: Dedicated Right -of -Way $16,573,000 Grading 14,000,000 Other 3,122,000 $33,695,000 Because fee credits are permitted to be taken by landowners at their discretion, it is reasonable to assume that they will be used in lieu of paying developer fees as long as a credit is outstanding. This feature of the fee credit program reduces the SJHTCA revenues during go San Joaquin Hills Transportation Corridor Agency Financing Plan Project Feasibility interim and construction periods when additional revenues are most needed. Therefore, the landowners have been asked by staff to consider the deferral of fee credits. As shown above, this action is not critical for the long-term feasibility of the SJHTC. But it can have a significant impact on the amount of external interim financing required as shown in the following section of the financing plan. Therefore, the report recommends that landowners eligible for fee credits on the SJHTC defer the taking of these credits until construction financing is obtained. However, because the long-term feasibility of the SJHTC would be enhanced by deferral of fee credits until after the project's opening date, it is recommended that landowners be so encouraged. Fee credits that are deferred until completion of the corridor will be repaid, with accrued interest, from available revenues after the payment of operating costs and debt service. Fee credit deferrals in a sense are a form of subordinate borrowing by the corridor with the landowner being the lender. The need to repay the landowner through available revenues will limit the ability to spend these revenues on other corridor projects and reserves. Maximize Permissible Arbitrage Earnings on Invested Bond Funds The Revenue Reconciliation Act of 1989 permits the issuer of tax-exempt bonds to invest bond proceeds in higher yielding investments and to retain the income from these investments that exceeds the yield on the tax-exempt bonds as long as certain expenditure requirements are met. If these conditions are not met, the issuer is required to rebate to the federal government the excess earnings above the tax-exempt bond yield (so-called "arbitrage earnings") or to pay certain penalties. One of the conditions that must be met under current tax law is the expenditure of proceeds from each tax-exempt bond issue within a two-year period. The financing plan assumes that no arbitrage income is earned by the SJHTCA. Investment earnings on bond funds are assumed to be equal to the all -in financing cost of the bonds (7.625 q ). Under current financial market conditions, however, the SJHTCA could earn a spread of approximately 130 basis points (1.30%) on invested bond proceeds. In order to take advantage of these excess earnings under current tax law, the SJHTCA must structure its financings such that the proceeds are expended within two years. Because the construction period for the SJHTC is four years, compliance with this requirement would require the issuance of the construction bonds in at least two series. The benefit to the SJHTCA of retaining excess arbitrage earnings is significant. Assuming a constant spread of 130 basis points, approximately $12 million in additional interest earnings can be generated after deducting the additional issuance costs associated with the second series of construction bonds. It is not wise for the SJHTCA to assume the availability of these revenues in a feasibility analysis because their availability depends on market conditions as well as federal tax law, both of which can be expected to change over time. However, arbitrage earnings represent a significant revenue source to the SJHTCA and one that will be revisited as the financing plan is finalized. • -20- San Joaquin Hills Transportation Corridor Agency • Financing Plan Project Feasibility Revenues from Non -Transportation Uses of the Corridor TCA staff have begun to explore the possibilities of maximizing revenues from non - transportation uses of the SJHTC. Ideas under consideration include (1) the leasing of corridor land to private parties for development that provide amenities to users of the corridor, such as rest areas and restaurants; (2) franchise revenues from corridor uses such as fiber optics, cellular phone networks, utility corridor, or other uses; and (3) advertising revenues. Such alternative uses will need Cal Trans approval and support. Staff is beginning discussions with the appropriate agencies and parties on these issues. Uses of Available Cash Flow The model developed for the SJHTC incorporates the various uses for available cash flow and permits TCA staff to program uses for the funds. The types of uses for this cash flow are expected to include: (1) provision of an operating reserve for the activities of the SJHTCA; (2) pay-as-you-go capital expenditures for median improvements and other additions to the SJHTC; (3) debt service on subordinate toll revenue bonds issued for corridor improvements; (4) incremental contributions to the debt service reserve fund to maintain the fund at its required level; (5) a capital reserve for corridor improvements; (6) self insurance for future liabilities; (7) transfers to the FTC or ETC, and (8) payments to landowners for deferral of fee credits. A sample schedule of potential uses for the available cash flow is provided in Table Two. This table is provided solely as an example and is not necessarily meant to recommend uses for the excess revenues. -21- San Joaquin Hills Transportation Corridor Agency Financing Plan Project Feasibility TABLE TWO SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR POSSIBLE USES FOR AVAILABLE CASH FLOW FIRST TWENTY YEARS PROVIDED FOR ILLUSTRATION ONLY (000'S) Capital Increment Self Improvements to Debt Fiscal Projected Operating Insurance Capital or Subordinate Service Year Amountit) Reserve(') ReserveM Reserve(" Debt Service() Reserve(') 1996 $14,216 2,000 $2,000 5,000 5,216 0 1997 13,114 0 5,000 0 8,114 0 1998 13,350 0 5,000 0 8,350 0 1999 13,992 0 5,000 0 8,992 0 2000 14,774 0 5,000 0 9,774 0 2001 22,387 500 5,000 0 16,887 0 2002 30,258 0 0 0 30,258 0 2003 32,852 0 0 0 32,852 0 2004 35,644 0 0 0 35,644 0 2005 38,125 500 0 0 37,025 600 2006 39,139 0 0 5,000 31,339 2,800 2007 56,509 0 0 0 52,009 4,500 2008 59,977 0 0 0 55,977 4,000 2009 62,343 500 0 0 59,843 2,000 2010 63,736 0 0 0 63,736 0 2011 64,272 0 0 0 64,272 0 2012 91,390 0 0 0 87,390 4,000 2013 91,885 500 0 0 86,385 5,000 2014 91,625 0 0 0 87,125 4,500 2015 91,261 0 0 0 88,861 2,400 2016 90,617 0 0 0 89,617 1,000 Amount projected to be available afar payment of operating costs and debt service on senior lien toll revenue bonds. Equal to four months of operating expenses, excluding debt service and capital expenses. Use and occupancy insurance, or self insurance, of some form may be y required and could be funded with available cash flow. The SJHTC may wish to establish a nominal capital reserve which could be tapped for emergency repairs. n The major use for available cash flow, after satisfaction of all other requirements, will be to fund capital improvements to the SJHTC and potentially REfC). Such funding may take the form of cash expenditures (pay-as-you-go funding) or a subordinate borrowing. "' The debt service reserve fund is assumed to be funded at a level equal to 10% of the take-out financing from take-out bond proceeds. The SJHTC will likely need to keep this reserve fund funded at a level equal to maximum annual debt service. • -22- San Joaquin Hills Transportation Corridor Agency is Financing Plan Interim Financing Plan. Introduction The fundamental objective of the interim financing plan is to ensure that the TCA has sufficient funds to meet its fiscal year 1991 and 1992 budgeted expenditures on design, environmental certification and administration prior to receipt of the environmental clearance necessary to obtain construction financing. As discussed below, the TCA has the options to: (1) continue on its current spending schedule causing it to require external financing prior to December 1990; (2) reduce expenditures to a level where it can exist on its expected developer fee receipts during the interim period; or (3) pursue a combination of these two alternatives. Another objective of the interim financing plan, therefore, is to analyze the cost and risk exposure associated with each alternative external borrowing source and to present the TCA Board with its most realistic interim financing options. The length of the interim period and the amount of funds needed prior to construction are difficult to predict because they are determined by receipt of environmental clearance from the FHWA and permitting requirements and are beyond the control of the TCA. The current expected environmental clearance schedule is shown below; however, the EIR/EIS review process or the permitting process may be prolonged. Furthermore, the findings of the EIR/EIS may be the subject of environmental challenge which could delay the start of construction. Such challenge r could also be restricted to certain portions of the corridor and not impact the ability to begin construction on other portions of the project. In such a case the TCA may find it beneficial to have secured an external source of interim financing that could be used to begin construction. It is unlikely that the TCA would be able to issue any construction financing while a challenge was pending unless it was determined to have no merit by a nationally recognized bond counsel firm. The draft EIR/EIS currently is being reviewed by the FHWA and is scheduled for public hearings in September 1990. Schedule of Environmental Clearance Event Date Public Hearing September 1990 TCA Board Certification of EIR January 1991 Record of Decision from the Federal Highway Administration April 1991 Final Permit Approvals December 1991 Construction Financing July 19910) (t) Alt► mgk all permits seeded for construction will not be obtained until December 1991, TCA staff have indicated that sufficient prosrat as permits to issue construction bonds for the SJ= occur by July 1991. Proceeds may not be fullly available for construction until all permits 3R received. -23- San Joaquin Hills Transportation Corridor Agency Financing Plan Interim Financing Plan INTERIM FINANCING PLAN Introduction The fundamental objective of the interim financing plan is to ensure that the TCA has sufficient funds to meet its fiscal year 1991 and 1992 budgeted expenditures on design, environmental certification and administration prior to receipt of the environmental clearance necessary to obtain construction financing. As discussed below, the TCA has the options to: (1) continue on its current spending schedule causing it to require external financing prior to December 1990; (2) reduce expenditures to a level where it can exist on its expected developer fee receipts during the interim period; or (3) pursue a combination of these two alternatives. Another objective of the interim financing plan, therefore, is to analyze the cost and risk exposure associated with each alternative external borrowing source and to present the TCA Board with its most realistic interim financing options. The length of the interim period and the amount of funds needed prior to construction are difficult to predict because they are determined by receipt of environmental clearance from the FHWA and permitting requirements and are beyond the control of the TCA. The current expected environmental clearance schedule is shown below; however, the EIR/EIS review process or the permitting process may be prolonged. Furthermore, the findings of the EIR/EIS may be the subject of environmental challenge which could delay the start of construction. Such challenge could also be restricted to certain portions of the corridor and not impact the ability to begin construction on other portions of the project. In such a case the TCA may find it beneficial to have secured an external source of interim financing that could be used to begin construction. It is unlikely that the TCA would be able to issue any construction financing while a challenge was pending unless it was determined to have no merit by a nationally recognized bond counsel firm. The draft EIR/EIS currently is being reviewed by the FHWA and is scheduled for public hearings in September 1990. Schedule of Environmental Clearance Event Date Public Hearing September 1990 TCA Board Certification of EIR January 1991 Record of Decision from the Federal Highway Administration April 1991 Final Permit Approvals December 1991 Construction Financing July 1991(1) The interim finance plan also considered methods available to the SJHTCA to increase the available revenues and decrease budgeted expenses during the interim period. Each of these expenditure deferral alternatives was analyzed for its impact on (1) the interim financing requirement, (2) the overall cost and • • Although ail permits needed for construction will not be obtained until December 1991, TCA staff have indicated that sufficient progress on permits to issue construction bonds for the SJHTC occur by July 1991. Proceeds may not be fully available for construction until all permits ate received 0 -24- San Joaquin Hills Transportation Corridor Agency Financing Plan Interim Financing Plan Amount of Interim Financing Needed Revenue and expenditure estimates for the SJHTC were used to analyze cash flow requirements prior to construction financing. In addition to the interim financing required, the TCA must maintain a certain minimum working capital balance to provide flexibility in meeting projected expenditures. Based on the budgeted expenditure cash flow for the first few months of the period following environmental clearance it is recommended that the TCA attempt to maintain a minimum working capital balance of $5 million to $7.5 million which will provide two to three months of working capital, excluding right-of-way acquisition, prior to construction and provide a reserve for potential delays. Table Three presents the results of the cash flow analysis for the SJHTC. Without any modifications to current revenue and expenditure budgets, the corridor will require interim financing that provides useable proceeds in the amount of $50.0 million beginning in December 1990. However, the Table points out how the TCA can reduce its need for interim financing by making modifications to its expenditure budget and by increasing revenues. For example, the interim financing requirement is reduced to $28.7 million by deferring the acquisition of non - dedicated right-of-way until the construction financing is obtained.. Although this action may result in further increases in the cost of the properties and can delay construction, it may be possible to negotiate an option on certain properties in advance in order to fix the price that must be paid • at a later date. If the TCA also reduced design expenditures, the amount of financing required would be reduced to almost $11.6 million. Reducing design at the 35% level can be expected to cause a delay in project opening under the traditional construction approach. If a design/build option is adopted, it may be possible to mitigate the delay. Other options, such as deferral of fee credits, are shown in Table Three, but these are not expected to provide a significant reduction in the interim needs. Beginning Fund Balance Since inception, the SJHTC has been financing its operations through developer fee income received on a quarterly basis from its members. The revenues and expenditures of the SJHTC to date, and the available balance are summarized below: SJHTCA Historical Revenues and Expenditures (in 000's) Developer Fee Revenue $35,986 Interest Income 4,793 Project Expenditures <23,921> Available Balance at 4-30-90 16 858 �r -25- c •o yV � 0 M A M M N~OCqC pNp C 00 `� y C [t< q Z O� 00 M C M 01 C . O, I �n �O OV, ago �+ 3 o W O 3 U W " V � A q •a 3 a Q� N y L c°�' (aW�ZQ3 woo Al V~1 M f~VO ��.~i O S ON N 1\0 6Li [ Qn z q " V r, �° 3 A M M N pNppp M Q�p�� A g O O $ C GL(:+W�00 M M MQ� M v1 M� Zi Z n a Q\ '.i Op M M h V1 E u p q O i'w W H V er e z o u v o A o0 00 A O m 3 U Z ' az 0 n ��'$rM,�o g Z c z = � '�"cp� tn 00 00 Oaz y AA" V N G v U 6 0 ca N Waza N 00M A h M�� n 00 �U M 00 g r Z y w V N a ,�y-. cpp�pp R r o o oQ Wi M a z a 1-D ° y ° Ca 4 low 8 w q) i7' E °; a r. 78 e o w a $ i E"" C a � 6� � � �R„ � 3 •O W � O C. .O ° ° � a � tto' � 1 C �, w LL+ LL. C � � C "• a iv�3 .O � Q» O. � � $ a $ F F° j m A z 0 0 • • San Joaquin Hills Transportation Corridor Agency Financing Plan Interim Financing Plan Impact of Delay in Ability to Obtain Construction Financing The estimate of interim financing required is based on the assumption that the SJHTC is able to obtain construction financing by June 1991. If environmental approval is delayed or other events cause the construction financing to be postponed, the amount of interim financing required will rise in all cases. The amount required will depend on the SJHTC expenditures during any delay. TCA staff have estimated that if a delay of six months or more occurs, all design and right-of-way expenditures would cease and the major expenses would be environmental and administrative. These expenses have been estimated to be approximately $3 million annually and could be more depending upon services and work program accomplished during the delay period. Analysis of Interim Financing Options The SJHTCA has essentially three options available to it as it nears the date when environmental approvals are expected to be obtained. The advantages and disadvantages of each of these options are discussed below. L Keep on schedule, obtain external interim financing to provide approximately $50 to $60 million to fund final design, environmental and right-of-way acquisition. If the SJHTCA Board wishes to maintain its current and projected project expenditure levels until construction financing is obtained, it must secure interim financing to produce net proceeds of approximately $50 million by December 1990. Deferring fee credits during this period Advantages No delay in current schedule. Access to large interim financing may permit SJHTCA Board to begin construction expenditures if environmental challenge prevent the issuance of construction financing. -27- Disadvantages Delay in ability to secure construction financing would result in additional carrying cost and delay in opening date. External financing would most likely be secured by a letter of credit; the letter of credit bank may require control over project expenditures prior to construction financing. Landowners are not expected to lend the SJHTCA the full $50 to $60 million required San Joaquin Hills Transportation Corridor Agency Financing Plan Interim Financing Plan • IL Delay Expenditures Until Construction Financing is Obtained The major expenditure requirements during the interim period consist primarily of final design and right-of-way acquisition expenses. In the Base Case, these expenses are based on current project cash flows and assume that the SJHTC continues to fast track the design process prior to receipt of environmental clearance. It is also possible for the TCA to delay certain design and right-of-way expenditures in order to reduce the amount of interim financing required with an associated delay in the project under the conventional construction approach. It is important to note that the interim period expenditure reductions result from the deferral of costs and do not provide cost savings and may delay the opening date. The deferral of these expenditures could actually result in increased costs, depending on the length of postponement and the impact of deferral on the project completion schedule. In addition, it may not be possible, or wise, to defer the acquisition of certain right-of-way parcels. For example, deferral of right-of- way acquisition could increase the cost of the right-of-way if the price of the right-of-way increases during the delay. Other parcels may be critical path items that would delay construction if not acquired by a certain date. Furthermore, the SJHTC has secured options on certain properties which provide an incentive to purchase prior to June 1991. Another option is to defer all or a portion of design management compensation. The impact of the expenditure delay option on the project completion, if any, is not known. It is possible that if the TCA were to adopt a design/build or turnkey approach for construction of the corridor that the completion date would not be impacted. Also, expenditure delays could possibly be made up by use of double shifts during the grading and construction process. This design and construction management approach is continued, project completion can be assumed project costs than assumed in the feasibility analysis. However; if the current design and construction management approach is continued, project completion can be assumed to be delayed by an amount of time equal to the delay between stopping design and its resumption after the issuance of construction financing. This option does not appear to be sufficient on its own. Additional revenues will be required to provide a cushion against receipt of developer fee revenues at levels lower than projected and to maintain a minimum cash balance. A loan from the ETC or FTC is not an option due to project expenditure requirements on those corridors. • .W."11 0 E San Joaquin Hills Transportation Corridor Agency Financing Plan Interim Financing Plan Advantages Reduces financing risk of delay or abandonment because no external financing is obtained Reduces risk of unnecessary design expenditures if the scope of the project changes as a result of the environmental approval process. Disadvantages Right-of-way that may be deferred is critical to ability to meet construction schedules. The SJHTCA should consider alternatives that include negotiation of a settlement and buyout in advance of construction financing so that purchase of land can occur quickly. Deferral of design could cause delay in construction and opening date. May not permit construction expenditures to be made if environmental challenge delays issuance of construction bonds. Once available cash is depleted, all expenditures would stop if environmental challenges delay issuance of construction financing. IIL Combination of Eanenditure Reduction and Securing Additional Revenue The deferral of developer fee credits prior to construction financing, combined with expenditure reduction, is expected to be sufficient to cover the SJHTCA interim financing requirements. This option provides flexibility to secure certain parcels of right-of-way if deemed appropriate. Advantages Permits critical right-of-way to be acquired. Reduces external financing risk and additional costs. Sources Of External Interim Financing Disadvantages All landowners may not be willing to defer fee credits. The TCA finance team has identified several alternative sources to meet the interim financing requirements of the SJHTCA. Financing �of the interim requirements is not as straight forward as a conventional borrowing. The only "certain" revenue source available to repay debt of the TCA prior to environmental clearance is developer fee revenue. This revenue is subject to fluctuation in amount and timing of receipt and is difficult to package into an attractive loan by itself. Ideally, the lender to the TCA during the interim period would be a party who becomes -29- San Joaquin Hills Transportation Corridor Agency Financing Plan Interim Financing Plan a partner of the TCA with an interest in seeing that the project is completed. As discussed below, the most likely candidates for this partner are either a letter of credit bank or a landowner. The interim financing must provide the working capital necessary to take the Agency through the pre -construction period and provide the flexibility to increase the funding if environmental approval is delayed In addition, repayment of the interim financing will be uncertain due to the potential for delays. The risks faced by the lender in this situation are not the usual types of financing risks or ones that can be easily evaluated. Consequently, the number of interim financing options is limited The financial analysis of this report describes a variety of sources of interim financing that were considered, however it concludes that the SJHTCA realistically has only two options for external Financing. Letter of Credit/Variable Rate Bonds - Variable rate bonds backed by a letter of credit is the primary interim financing option that has been recommended by First Boston as the most viable alternative after their review of other potential options. If environmental approval is obtained as scheduled, the interim financing will be repaid upon the issuance of construction bonds. If approval is delayed, the TCA's ability to spend bond proceeds on the project would be subject to the bank's approval. Furst Boston has developed a credit structure which they believe will be sufficient to make the interim financing attractive to the banks. In essence, the recommended structure would require • the TCA to acquire fee title to as much of the corridor as possible through landowner dedications and to agree not to alienate the right-of-way for the corridor in the event that the project was abandoned. The banks would then be in a position to control the disposition of the right-of-way if the project was significantly delayed or abandoned. The TCA would be required to repay the banks prior to sale of the right-of-way, so the cost to another party, such as the County or a private entity who might want the right-of-way to be used for roads or transit, would be impacted by the amount owed under the letter of credit obligation. A summary of other terms and conditions anticipated from this structure is provided in Appendix One. The ability to secure a letter of credit for the interim financing is uncertain at this time. TCA staff and advisors have met with representatives of several potential letter of credit banks to reacquaint them with the TCA projects. Assuming cooperation among the SJHTCA, its members and the landowners; TCA Staff and First Boston are confident that a bank will agree to provide the TCA with a letter of credit under these terms. Bank interest in the projects continues to be strong. While the banks are concerned about the risks involved in lending prior to environmental approval, the banks have incentive to participate in such a financing given the attractiveness of providing construction period lending. Because of the expense involved in providing a firm letter of credit commitment, the TCA has not asked for firm letter of credit commitments from potential banks. In addition, prior to development of the SJHTC financing plan, the financing requirements of the SJHTC were not well enough defined. If the Board decides to pursue this option for interim financing, the process for selecting a lead bank would be completed between July and December 1990 when the interim funds are expected to be required. 0 -30- San Joaquin Hills Transportation Corridor Agency • Financing Plan Interim Financing Plan 0 Developer Fee Advances - Landowners have a significant stake in the success of the SJHTC. They have already committed over $35 million in equity to the project in the form of developer fees. In addition, they are expected to dedicate 330 acres of land for use by the corridor. This option relies on the landowners to serve in a lending capacity to the TCA for its interim financing needs. Landowners would be asked to commit to prepay a certain amount of their future developer fee commitments and/or provide Development Agreement stipulated funds earlier than contractually required. These forward commitments would become available to the SJHTC to be used as needed during the interim period. Upon receipt of environmental approvals the SJHTC could either repay the advanced developer fees from the proceeds of the construction financing or defer repayment in the form of a developer fee credit to be taken after completion of the corridor. The terms of the developer fee advances, such items as interest rate and conditions, have not been negotiated with the landowners. This option would entail less up -front financing costs than the letter of credit approach and would avoid the public issuance of securities prior to receipt of environmental approvals. However, the terms and conditions of the landowners may include adoption of a design/build approach as well as delaying certain expenditures and may not be attractive to the TCA when compared to the letter of credit option. If the amounts required for interim financing can be handled through deferral of fee credits, this deferral becomes, in essence, a developer fee advance. Because the amounts required to meet the SJHTC Interim needs are greater, landowners could be requested to form one or more Community Facilities Districts on their unimproved land expected to benefit from completion of the corridor. If the landowner were to approve a special tax on this unimproved land, the TCA could issue Mello - Roos bonds for the developer in return for a portion of the proceeds being advanced to the TCA for corridor purposes. TCA staff has received preliminary indications from landowners in the SJHTC area of benefit of their possible willingness under certain circumstances to advance developer fees and to defer fee credits until the construction financing is obtained. Discussion of Interim Financing Options TCA staff and advisors believe that both the letter of credit and developer fee advance can provide the SJHTC with a source to fund a portion of its interim financing needs. Based on discussions with landowners, TCA staff and advisors believe it is unlikely that developer fee advances can provide more than $40 million in usable proceeds. Therefore, if the SJHTC interim needs will exceed $40 million, the most likely source of financing is the letter of credit bank option. The analysis in Table Three indicated that by deferring design and right-of-way purchase, the interim needs can be reduced from $50.0 million to $11.6 million. This level of interim financing is believed to be obtainable from developer fee advances. In addition, if the construction financing is delayed beyond July 1, 1991, it is expected that the developer fee advances could be obtained at a level which would meet the SJHTC expenditure needs through November 1991. -31- San Joaquin Hills Transportation Corridor Agency Financing Plan Interim Financing Plan The cost of a developer fee advance is subject to negotiation with each landowner and is not known at this time. The cost of a letter of credit backed variable rate bond issue can be estimated based on past letter of credit backed financings for start-up toll roads. The cost of a public agency loan is also subject to negotiation. Table Four shows the estimated costs for a $30 million interim financing. The $30 million amount was chosen for illustration purposes only and is based on an interim financing plan that consists of expenditure deferral as well as an external interim financing. The up -front issuance costs for a publicly offered letter of credit backed variable rate bond issue are estimated to be approximately $1 million for a $30 million financing. The costs of a developer fee advance or a public agency loan are not expected to exceed $100,000. Which of the two alternatives provides the funds at the least cost is dependent on two factors: (1) the rate on developer fee advances or the public agency loan, and (2) the term of the interim financing. If the current schedule is met and the interim funds are required only through June 1991, the developer fee advance and/or public agency loan are expected to be less expensive. However, if delays are encountered, which cause the interim financing to be outstanding for more than 18 months, the letter of credit option may be less expensive, depending on the terms of the other option. Other alternatives considered, but not recommended, are described below: Bond Anticipation Note - This option would require the TCA to obtain the interim financing through the issuance of short-term notes secured by the ability of the TCA to issue its construction financing by a certain point in time. This option places the risk of environmental approval on the investor rather than a third party letter of credit bank or a landowner. Because this risk cannot be quantified, it would not be possible to obtain a rating on the notes, and they would be viewed as a high yield/high risk investment. The amount of funds that could be raised through this source is uncertain due the unusual nature of the financing. Estimates from the financial community have ranged from $30 million to $100 million, which, at the low end, would not meet the SJHTC maximum interim financing need of $60 million. Another BAN option considered was to secure the notes through a Mello -Roos special tax imposed by the TCA on the unimproved land that will be subject to the payment of developer fees. This special tax would require the landowners to commit to pay the developer fees even if the corridor projects were abandoned and to pay the taxes irrespective of when development actually occurs, thus removing many of the risks of the interim financing. Although this is one of the least expensive financing options, its implementation required the support and vote of the affected landowners and is beyond the control of the SJHTCA. There fore, this option may not provide the funds in the time required by the SJHTC. In addition, a review of the ability of the undeveloped land in question to support such a special tax has not been undertaken. -32- San Joaquin Hills Transportation Corridor Agency • Financing Plan Interim Financing Plan 0 Bridge Loan - First Boston has committed to provide the interim financing as a lender of last resort. Because First Boston is not in the business of lending money, the terms of their proposed bridge loan are designed to encourage the TCA to repay the loan as soon as possible. -33- San Joaquin Hills Transportation Corridor Agency . Financing Plan Interim Financing Plan TABLE FOUR EXPECTED COSTS OF INTERIM FINANCING ASSUMING $30 MILLION FINANCING REQUIREMENT Developer Fee Advance Letter of Credit or Public Variable Rate Bonds Agency Loan (t) Interest Rate: 6.50% 8.50%(2) Other Fees: 1.13% 0.0 Total Financing Cost: 7.63% 11.50% Costs of Issuance• Letter of Credit $500,000 $ 0 Commitment Fee Legal 200,000 100,000 Issuance 150,000 0 Underwriting Takedown 150.000(31 0 $1,000,000 $ 100,000 Six-month Carrying Cost $ 1,144,500 $1,725,000 Cost of 18-month Delay $ 3,433,500 3,825,000 (1) Provided for example only, actual terms not known. (2) Assumed rate. (3) Assumes Lead Underwriter defer management fee and issuance expenses. 0 -34- 10 San Joaquin Hills Transportation Corridor Agency Financing Plan Potential Risks POTENTIAL RISKS AND MITIGATION MEASURES Project Risks L Delay in Environmental Approval or Permitting Processes Delays in the receipt of environmental approval or permits will postpone the start of construction and result in an extension of the interim financing period. If the TCA has issued pre -construction bonds to provide interim financing, the extension of the interim financing period will increase the interest cost of the borrowing and raise the size of the construction financing by the higher interest cost. The size of the pre -construction financing, the amount of expended pre - construction bond proceeds and the length of the delay could have a negative impact on the ability of the TCA to issue construction bonds for a feasible project. Quantification of this risk depends on the level of expenditures and length of the interim period. The risk is essentially equal to the carrying cost of the interim financing beyond the July 1991 date, assuming that the construction financing is obtained at some point in the future. If interim financing of the entire $50 million expected to be required without the deferral of expenses is obtained, the six-month carrying cost is approximately $1.9 million assuming the letter of credit option is followed. If certain right-of- way expenditures are deferred until after construction financing is obtained and pre -construction expenditures are reduced to the $30 million level, the six-month carrying cost drops to $1.2 million. Thus, the risk of interim financing is dependent on the level of expenditures undertaken and length of the interim period. If the SJHTC is able to control and defer non -essential expenditures, this risk will be lower. The most significant risk of proceeding with an interim financing is the possibility of significant project delay or project abandonment. Under such a scenario, however unlikely it may be, the TCA would risk loosing developer fee revenues equal to the issuance costs of the interim financing, expected to be $1.2 million for a $50 million interim financing and the carrying costs referenced above, which will depend on the length of delay and amount of expended proceeds. In addition to the financing risk, the SJHTCA is already at risk for the funds already expended on the project (approximately $22 million as of April 30, 1990). The risk of an interim financing can be mitigated through controlling expenditures to limit the use of borrowed proceeds. Under any interim financing approach, the terms and conditions proposed by the lender must be acceptable to the TCA. IL Construction Cost Escalation The estimated construction costs used for the financing plan are the best estimates available to the SJHTCA at this point in time and include a 25% construction contingency. Prior to the issuance of the toll revenue bonds, the SJHTCA will receive bids from contractors for at least the major sections of the corridor and will have a better estimate of the total project cost. However, -35- San Joaquin Hills Transportation Corridor Agency Financing Plan Potential Risks even after receiving the section contractor bids, the SJHTCA could be faced with change orders from the contractors and the design engineers as construction progresses. If the contingency is exceeded by changes in project scope, the SJHTCA would need to find additional revenue sources, such as project completion bonds, to finance the additional costs or reduce the scope of work. Such a financing would have a negative impact on the feasibility of the outstanding project bonds and could limit the SJHTCA's ability to address future project needs. One manner in which public agencies have attempted to mitigate the risk of construction cost overruns is to modify the nature of the construction contracting process. Rather than separate the design and construction responsibilities among two or more firms, it is possible to appoint a single firm to take responsibility for the project's design and construction. The TCA could retain an independent engineer to review the reasonableness of the current project schedule. In addition, the design/build contract would provide for the payment of a fixed fee, subject to escalation due to delays beyond the contractor's control, for completion of the corridor. There would be limited ability for the contractor to request change orders, thus the opportunity for cost overruns would be restricted to events beyond the control of the contractor. Because of the importance of the fixed price feature of a design/build contract, there is a limited number of firms which could perform this function for the TCA and it is critical that they meet certain minimum performance bond and financial criteria. The design/build approach has many benefits for enhancing the attractiveness of the TCA • projects to potential lenders, letter of credit banks, rating agencies and bond insurers. These institutions will appreciate the greater accountability that arises from placing the responsibility for ensuring that the project comes in on time and within budget. This option also allows for the design/build group to fund, at their liability, design work before completion of the environmental process. Cost overruns become the responsibility of the contractor, who will agree to pay all or a portion of the cost of cost overrun if it is within their control. A variant on the design/build approach would be a turnkey project in which two separate parties are responsible for the design and construction respectively and each firm can be required to provide fixed price contracts for their portion of the project. IIL Construction Delay If the opening date for the corridor is postponed due to construction delays, the outstanding project bonds will accrue additional interest. The construction financing will include an additional 6 to 12 months construction period interest as a contingency, however a prolonged delay could require the issuance of completion bonds if the toll revenues that were expected by a certain date could not be generated because the project had not been completed. It is very difficult for the TCA,, on its own, to mitigate this risk. The design/build or turnkey approaches referenced above could be negotiated so the selected firm would pay penalties to the TCA for any delay in completion within its control. Such penalties could be calculated on a daily basis and could be equal in amount to the interest that would accrue on the TCA revenue bonds during the delay. However, it is likely that any significant project delays would be caused by factors beyond the -36- • San Joaquin Hills Transportation Corridor Agency Financing Plan Potential Risks • contractor's control and would not be eligible for liquidated damages payments. Financing Risks L Interest Rate Fluctuation The feasibility analysis is based on the assumption that the construction financing for, the corridor will be obtained using tax exempt variable rate bonds. Variable rate bonds tend to provide lower interest cost and are useful in Iarge construction projects as a means to lower the cost of construction period interest. The average seven-day variable rate for the period 1983 - 1990 has been 5.44% and the current rate for the week ending May 18, 1990 was 6.00%. As demonstrated in Exhibit Three the actual interest rate can vary dramatically depending on market conditions and investor demand for variable rate securities. The feasibility analysis has assumed that the variable rate during the four-year construction period will average 6.50%, (with letter of credit and other fees the "all -in" cost is assumed to be 7.625%) however the impact of higher and lower rates was also tested Since the TCA's revenues from developer fees and project tolls can not be expected to float with interest rates, it generally is not advisable to finance projects such as the toll road over a long- term basis using variable rate debt. If a short-term rates were to rise sharply to double digits for a prolonged period, the TCA may find itself unable to raise tolls to the level necessary to cover debt service. Consequently, the finance plan calls for the issuance of fixed rate bonds as soon as possible upon completion of the corridors. One way, of course, to remove the risk of interest rate fluctuation is to issue fixed - rate bonds from the start of the construction period Based on current expectations for short-term vs. long- term interest rates, this option would be expected to increase the cost of the project due to the higher cost of construction period interest that must be financed. However, if long-term rates rise significantly above their current levels during the construction period, the TCA would have been better off in the long -run by having issued fixed rate bonds from the start. The cost impact of fixed-rate bonds could be mitigated by issuing a three- to Eve -year bond anticipation note to finance construction costs, which note would carry a fixed interest rate. Other options would include interest rate swaps or the purchase of an interest rate "collar" to limit the rise in short- term rates. The decision on whether to issue fixed-rate bonds, variable -rate bonds, or a combination of the two, will be made at a later date and will largely be dependent on market conditions at the time construction financing is required. During the construction period, if variable rate bonds are issued, the SJHTCA will monitor the long-term fixed rate market for opportunities to convert its debt to fixed rates. However, based on current rating agency policies, it is unlikely that the TCA could obtain an investment grade rating on fixed-rate revenue bonds on its own credit while variable rate bonds were outstanding. A more likely scenario would be to convert all construction fmancing to fixed rates simultaneously, within one to two years of project opening date. -37- San Joaquin Hills Transportation Corridor Agency • Financing Plan Potential Risks IL Market Access for Take-out Financing As long as the financing is separated into two parts, construction and take-out, there will be a degree of market risk for the long-term take-out financing. As discussed above, the interest rates in effect upon completion of the project could be much higher than assumed in this feasibility analysis and could impair the over-all feasibility of the project. The financial analysis section of the report found that the project can withstand a 9.00% take out rate. The letter of credit to be obtained for the construction financing will have a minimum 7-year term for an expected 4-year financing. Therefore, even assuming that the letter of credit is not extended, there will be some time available after completion to continue in a variable rate mode if long-term market conditions are unfavorable. Exhibit Three shows that the seven-year average revenue bond index has been approximately 8.60% One other means to mitigate this risk is the issuance of fixed bonds for construction, avoiding the need for a take-out financing. This alternative imposes certain additional risks in that construction period interest would be higher and the long-term market at completion may be lower than when the fixed-rate construction bonds were issued The best way for the TCA to mitigate this risk is to structure its financing plan to permit the flexibility of either fixed or variable rate financing and to make decision based on market conditions and advice at the time of financing. ]IL Credit Risks 0 As start-up toll roads, the TCA projects will be viewed much differently from existing toll roads by the credit rating agencies, investors, and other capital market participants. - Existing toll roads are able to demonstrate a historical record of toll collections and generally have a track record of their ability to construct additions to their capital facilities. Both of these items are critical to the evaluation of the credit of a toll road financing. In its initial financings, the TCA will be unable to supply investors with either a construction record or toll collection history. Consequently it will be necessary for the TCA to address as many other areas where investors may be concerned about project risks in order to offset this liability. The major risks perceived by investors in start-up projects are project construction risk, completion risk and revenue projection risk. Construction risk and completion risk were discussed above as risks the TCA itself faces. The means described above to mitigate these risks also can mitigate the concerns of the credit markets. By entering into a fixed price contract with a reputable contractor with a track record of its own and a strong balance sheet, the TCA can address the construction risk. The completion risk can also be addressed by requiring that the contractor pay liquidated damages for failure to complete the corridor on schedule. The revenue projection risk cannot be addressed through a third party. The SJHTCA should expect investors, letter of credit banks, rating agencies and others who evaluate the project to discount the toll and developer fee revenue projections. After one or two years of toll collection history, the credibility of the toll revenue projections will rise. 0 -38- • San Joaquin Hills Transportation Corridor Agency Financing Plan Potential Risks of Capital Appreciation Bonds The traditional debt service structure used for revenue -supported projects is level debt service, wherein annual debt service remains relatively constant for the term of the financing. A level debt service structure requires a certain amount of principal to be amortized each year, in addition to paying the interest that has accrued on the financing. The level debt service structure is similar to the typical mortgage payment structure which calls for equal monthly payments. The TCA projects are not expected to generate sufficient revenues in the first few operating years to permit the debt service to be structured on a level basis. In fact, the amount of net operating revenue projected to be available in the opening years is only sufficient to cover interest on the construction financing, assuming the construction financing remains in a variable rate mode, plus provide a small operating "cushion" or coverage factor. However, the coverage factor that can be provided is not high enough to issue investment grade bonds. In order to demonstrate that the project can provide coverage of debt service at the 1.20x level generally expected from revenue financings of this type, the TCA may need to issue a certain amount of Capital Appreciation Bonds ("CABs") as part of the long-term financing. CABS, also known as zero coupon bonds, permit the issuer to defer the payment of interest until the maturity of the bond. By deferring interest, CABs can reduce the annual debt service payable on a financing in the initial years. However, debt service in later project years, payable when the CABs mature, will be higher due to the deferral of interest. CABS represent a useful financing tool for the TCA because they permit the debt service to be structured to fit within the available revenues of the TCA projects. In an efficient market conditions, investment grade CABS would yield the same interest rate as similarly rated current interest bonds. If the demand for CABS is not strong or if an issuer is offering a large number of CABS at one point in time or if they are rated below an A level, there may be an interest rate penalty attached to the CAB as opposed to a current interest bond. In addition, it may be necessary to issue the CABS with no call feature whereas a current interest bond would be able to be called. The underwriting costs of CABS tend to be slightly higher than for current coupon bonds due to the strong interest from the retail market for these investments and the need to pay a higher sales commission to reach retail investors. The financing team feels that the optimum amount of CABs for the TCA to offer at any one time will be determined by market conditions at the time of issuance; however, the financing plan is based on a preference for not more than 10% to 15% of the total amount of permanent debt in order not to pay a premium for the amount of CABS being offered, assuming they are rated investment grade. Because CABS defer debt service until maturity, most investors prefer CABs to be rated at the A level or higher. It may be difficult, and expensive, for the TCA to issue a large amount of CABs rated less than A. Consequently, it may be advisable to obtain municipal bond insurance or other credit enhancement for the CABS. -39- • • PIZU - 40 - Transportation Corridor Agencies Corridor Financing Plan Appendix One SAN JOAQUIN BH1S TRANSPORTATION CORRIDOR AGENCIES . POTENTIAL CREDIT COVENANTS FOR EXTERNAL I '17MIM FINANCING 1. PIedge of unexpended proceeds of borrowing. 2. Use of first proceeds of subsequent borrowing to repay pre -construction debt. 3. Development fees, cash on hand, interest earnings and other available revenues of the SJHTCA expended on project costs ahead of proceeds of borrowing. 4. Additional parity borrowing subject to approval of credit provider. 5. Negative pledge precluding alienation of SJHTCA property or other assets without (i) satisfaction of outstanding indebtedness or (ii) approval of credit provider and property must be in SJHTCA control before financing. 6. Payment of eligible project expenditures out of borrowed proceeds by trustee subject to voucher and approval of credit provider. 7. Monthly review of all project expenditures and management report on interim progress toward project milestones. & Expenditures from borrowed proceeds only at discretion of credit provider when project fails to achieve specified milestones. 9. Preservation of tax-exempt status of borrowing. 10. Limitation on instruments for reinvestment of borrowed proceeds and reinvestment management subject to control/approval of credit provider. 11. Acceleration of repayment obligation at discretion of credit provider in the event of significant project delay or abandonment 12. Access by the credit provider or its representative to examine all TCA books, records, data, memoranda, studies, minutes, notes, etc 13. Credit provider to have exclusive option to provide required credit support on market terms for TCA's public indebtedness for the entire construction period. Additional Agreements: 1. By major vendors and/or service providers to accept a portion of their payment in subordinated, interest accruing notes to be paid out of construction financing proceeds. 2. By major landowners to acknowledge existence of the financing and the partial reliance for repayment thereof on development fees under signed, standard form Development Fee Agreements acceptable to the credit provider. 3. By the TCA to pay for updates of third -party revenue forecasts, feasibility studies, audits and progress reports all as reasonably requested by the credit provider. 4. By Caltrans to acknowledge existence of the financing and reliance for extension of credit upon Caltrans conditional acceptance of maintenance responsibility for completed facility. 0 SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR CASH FLOW MODEL BASE CASE: 11. PHASE ONE - NO HOV LANES Revenue Assumptions: Toll Revenues as provided by Wilbur Smith Associates Developer Fee Revenues Adjusted for Project Cost California Transportation Commission Grant of $46.5 million Interest Earnings on Cash Balances at 7.625% Expense Assumptions: Developer Fee Credits as provided by Deloitte & Touche Construction Cost (excluding HOV lanes) provided by CDMG Corridor operation costs provided by CDMG Financing Assumptions: Interim Financing (variable rate) at ail -in cost of 7.625% Construction Financing (variable rate) at ail -in cost of 7.625% Permanent Financing (fixed rate) at rate of 8.25% 0 I a 1 m Y 1 \ t0 a � 1 / omf I / i a i • t m a 1 I ■ m I 1 ■ Io ti L 1 - r ■ f a i E / ♦ W 1 } m / J 1 a / fIo Q I 1 ■ a U. 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C y e a• • • L r 0 0 0 0 w • otc ^ u j O = • q G y O osyyyy w i IL y\ C • ! ILW yYyy 01 es O yv w L•. 00 • i i o.-csee c c_ o c• o s \ • J A A O y M ~ IL • * y • y 0. 1. 40 y • Y ■ y• Y J O.O p L• • li ! L L {. L U IL L i 0 • O i i p OL SEL L.r6Y Y00 Or Ot•Gi O.A Lw w 40 • • 010 wc 7 O • Y�rMir •y C • •.� • • O a ��uO •ee • w•• S N U N u u J O O 6 b O w O011 O O 1 O 1 w OOi INp m w N N 1 1 O pmi .m► w w f N w INDO p b 1 0 I N mO p 0 Nn 1^ nm .f-1 N Y f n • O_ w m m N m w m i•. h OI m V N • �' • m O • a y c N � u • c N L a Y c y 6 y rm w y O • C CL a � w M O • L y -O J N Y H IL U m N 0 EXHIBIT 2 AESTHETIC DESIGN GUIDELINES 0 01/31/91(TCA9018%INDEXV-4) El The attached exhibit contains a Draft version of the Aesthetic Design Guide- lines, which does not in all cases include mitigation measures outlined in the EIR/EIS. Upon certification of the FEIR/EIS, the Aesthetic Design Guidelines will be revised to incorporate the mitigation measures adopted by the decision makers. 01/31/91(TCA9018%INDEXV-4) Lqq T; .1 JEJUI F�0 BER 1990 Pmpamd by ft CORRIDOR DESIGN MANAGEMENT GROUP hbwwd NOWIM Twww A Swyendoff Parsons &ftftftff Qua* A -Douglas, Inc. Fh" Daniel, Inc. Chwch &Vtwwft, Inc. .......... Propaw for ft . . . . . . . . . . . . . . . . . MM&WRTA#W CORRIDOR AGENCIES ..... ....... TOLLOOV.PM3 INTRODUCTION This document is one of a series of references prepared for the Transportation Corridor Agencies (TCAs) that establish aesthetic design guidelines. Standards and criteria to be applied to bridges, walls, barriers, grading, landscaping, sign supports and lighting are presented. BACKGROUND The TCAs were established by joint powers agreements among cities in Orange County and the County in order to collectively deal with a regional transportation problem and plan accordingly. Staffed by a small group of professionals, they are responsible for the planning, financing, designing, and constructing of three major corridors. There are two TCAs, the Foothill/Eastern Transportation Corridor Agency and the San Joaquin Hills Transportation Corridor Agency. Each agency is administered by the same staff, but policy decisions are made by separate boards, consisting of elected officials. In August of 1976, the San Joaquin Hills Transportation Corridor (SJHTC) was added to the County's Master Plan of Arterial Highways. ' This addition represented the first time in decades that action was taken to plan for a new freeway in Orange County. It occurred as a result of extensive transportation, land use, and environmental studies which indicated a pressing need for the Corridor. In November of 1979, the Board of Supervisors completed a comprehensive Environmental Impact Report (EIR) based upon the California Environmental Quality Act (CEQA) and approved the present alignment plan. The Corridor was • officially placed on the State Highway System in September of 1983 by the State legislature making it eligible for State and Federal funding. • In August of 1981, the Eastern Transportation Corridor (ETC) was added to the County Master Plan of Arterial Highways.. This addition occurred as a result of several comprehensive transportation studies. All strongly suggested that a corridor connecting the Riverside 91 freeway to the Santa Ana I-5 freeway near north Tustin be developed as soon as possible. Phase 1 environmental planning, which included several public participation activities, was completed in February of 1986. The Corridor was officially added to the State Highway System as State Route 231 in August of 1988, making it eligible for State and Federal funding. The notion of a freeway along the flanks of the Santa Ana mountains through southeast Orange County was first considered in 1974. The concept was then included in several comprehensive transportation studies, which verified the need for the Foothill Transportation Corridor (FTC) and helped to determine its general location. The FTC formally became part of the Master Plan of Arterial Highways in 1981. Community -wide consideration of various routes for the FTC was followed and a basic alignment was selected by the County Board of Supervisors in 1983. The FTC was officially added to the State Highway System as State Route 241 in August of 1988, making it eligible for State and Federal funding. WP\AESTH\TB 1 PURPOSE Standards and criteria have been developed based upon an understanding of the historic, natural and visual values which reflect community preference in aesthetic options based upon land use characteristics. The guidelines presented here provide detailed design treatments intended to achieve the desired visual effects. These treatments are intended for use by those who are responsible for preparing final design and construction documents, as well as those constructing the corridors themselves. STUDY PURPOSE The approach used to develop these standards and criteria is based upon a series of workshops and meetings with an aesthetic committee established in September of 1989. Committee representatives included: Local Agencies City of Newport Beach City of Irvine Orange County Caltrans Tollroads Oversight • Landowners Mission Viejo Company The Irvine Company Professional Associations American Society of Landscape Architects American Institute of Architects The committee met on a regular basis. Issues included a review of the requirements associated with the designation of the corridors as scenic highways and the development of a statement of principles. STATEMENTOF PRINCIPLES The following statement reflects the principals which are depicted here as aesthetic standards and criteria: "The biggest and best contribution that the corridors can make is to emphasize the existing natural landscape; emphasize natural features, views and vistas; and, emphasize added landscape in areas that are dominated by built structure. The corridors should be experienced as an enjoyable passage through both urban and rural regions. They should reflect the highest regard for the need to experience open space and the natural environment." WP\HESTH\TB 2 GOALS • Specific visual goals adopted by the aesthetic committee include the following: 0 General o Reduce the amount of hardscape in one place Break up toll plazas into section/separate the two directions Minimize toll plaza structures/develop the landscape relationship o Maintain and enhance views and vistas Bridges o Simplify bridge structures and develop the engineering potential o Keep the structure as thin as possible o use curves to relate to land forms o Minimize the number of columns Walls and Barriers o Carefully detail walls and barriers o Consider color Grading o Shape cuts and fills to surrounding contours o Use beams and change of grade to increase landscape effects o Develop slopes consistent with hydroseeding and erosion control requirements. Landscape o Preserve existing trees o Replace or relocate trees that are removed o Develop revegetation techniques o Landscape only where practical Add landscape at interchanges with trees and low shrubs Use trees and grasses with wild flowers in open areas with no shrubs o Add landscape to walls o Use indigenous materials Sign Supports o Develop sign supports as simple as possible WP\AESTH\TB 3 • 0 BRIDGES • BRIDGE DESIGN GOALS o Adhere to the overall design goal to alter the existing natural landscape as little as possible by visually minimizing and simplifying the bridge structures through the emphasis of specific lines and shadows that contribute to making the bridges appear thin and light. o Minimize the girder depth to help make bridge appear thin and light. o Use strong horizontal shadow lines and horizontal line details to visually streamline and reduce the massiveness of the bridge. o Use longer bridge spans and fewer columns. o Use the slab edge as the visual focus line and- minimize the appearance of the girder face with deep shadows and visual separation by using long deck overhangs. o Minimize the visual impact of columns so the bridge appears to be as clearspan as possible to contribute to apparent thinness. o Use simplicity, horizontal emphasis, and exaggerated thinness to provide continuity throughout the corridor. o Use the same shapes and details for all bridges unless special bridges are appropriate for major canyons, long -span crossings, or for community imposed design variations. o Minimize the visual size of the abutment and reduce its massiveness with strong shadow lines. o Reduce the apparent height of the barrier by shadow lines and foreshortened distance to the slab edge. o Use applied protective color coating to unify the bridge surfaces, to help unify all the corridor structures, to reduce the visual dominance of the bridges by relating to the color of the surrounding terrain, and to provide effective uniform graffiti control.2 WP\OTOLL2\TB BRIDGE STANDARDS • Superstructure Cross -Section o The concrete box girder cross-section will be proportioned so that the slab overhang is relatively long, which will increase shade on the girder face. o A horizontal step will run continuously along the exterior face of the box girder throughout the bridge's length. o Wide bridge superstructures will consist of two separate parallel box girders connected at the roadway slab. o Superstructures for bridges with two or more spans will consist of a single box girder with three columns. o Recesses will run entire length of superstructure. o Use applied color on all exposed surfaces. 1/23 max. W-0• absolute max.), 112Bait mmiwum Concrete Barrier Type 23 Modified I �s s 1 s S Is preferrably aoff equal to 2D —Adjust slop• If necessary for structural requirements or clearance to Std. !ridge Ciraln. I T ' C; _+ 0 1 N O Width of eteo 's a' (typ. for all bridges) X slopes shown are relative to cross -slope of bridge QM/t f11 -O roeo" if sbeM MM �'' to ease of eefll6�', isswat mom Rose" (as drfe free' me"". Tye. dews• C Soon leaf SECTION O 1— T a, • • Y s' (Shift bar as reo'd.) 2' RECESS DETAIL (Full length of bridge) Asia of column sersael to htseway below. SECTION AT BENT Aalen W seises• own sae asaw to as Masses* useser so esst*s* oMwe a 000" en Maw. WPNAESTH\TB Span Length and Depth • o Continuous spans with a minimum number of hinges or joints will be used. o Superstructure depth will be virtually consistent throughout the bridge . length. Necessary variations will be gradually proportioned. o Generally, superstructure will be minimized. L1 O 2'-0' Nominal (TYP-) T L2 01 "Ma". Move oo• Treatment (TY0.) For Cut section. match roadwsY slooa. For Fill section, use 1 112:1 sloos.-- ELEVATION SAID'. C =c- '; -1"': Pier Caps and Columns o Supporting pier cap beams will be integral with the box girder and hidden from view to promote aesthetic appearance and minimize structural size. o Prismatic columns (rectangular in cross-section, with rounded or oblong ends) will be used to preserve simplicity, and the number employed will be minimized. o The projecting band at the top of each column will be parallel to the grade of the roadway below. o Columns under parallel bridges will be located along a common line at each bent (a framework support running transverse to bridge length). o Use applied color on all exposed surfaces. X. STRAP DETAIL a i7 W 1.5 to 2.0T 71 Coltrane std. AreaMesfaetai Coamm, — frbwatto Typo 1WR FYNan.a Ground Una r-o•. Typ. Where T preferaop MWais to 4',s�-11•, or T TYPICAL COLUMN 1'. (11" utr"d) RECESS DETAIL (Fuu "Kwh or txtog• Wider than 2T COLUMN OPTION Type 1WR is preferred. A widened Type TWR way be Weed to aet:omodate Seismic or other design requirements. 0 • 0 WP\AESTH\TB • Railings o Bridge rails will be similar to Caltrans Type 25 and 27, except that they will all be squared and protruding. o Use of this kind of rail will minimize the appearance of depth in the bridge and draw attention away from girder massiveness. o Square and protruding shape will be consistent size on undercrossings and overcrossings. o Use applied protective color coating on all exposed surfaces except top of deck and sidewalk. Peo(rslratn fr"ce / C� S =0' /=5' COMM* da"ac., A 27 OtMr(s /0 De `s"Ot �' °%t of per 'endgr Ots/gn QrAw/s farnisWby TCA 4bless no/ed a#v waist. See G ?& PO* I4(jP/6� I3;;�fJO .. N o ,sx to /s ties. �M(Ses Abtt) -- — (Typ1 o5 Can/ Tofi/•6-' 6x6-W/d 0Wi4 Ny/d'#d WiV /rwbr%C kk May be ftrea m /b prwnt 9u/Aer /*W OVERCROSSINGS Motet Refer Came&* ttt""M Dip for Ntafts am ••tees• Isere 11-0' 2' *' N Coat. Tot. • •sai'-a'S ti •' Nominal (Varies with roadway seems •lore) +a• tf Max. • ♦Il 90 is Mox. —t.atutwatloa Joint Vie Dock Ra. +{ Gem. +i�• to Max. TYPE 25 BARRIER (MODIFIED) ,. UNDERCROSSING, AND RAMPS %ArP1 GCC-njt -ro Abutments o Use abutments that will be placed high on the bridge embankment slope and shaped to simulate the superstructure cross-section by creating a shelf at the height of the superstructure step. o Use applied protective color coating on all exposed surfaces. i a1.o 7_-__ `.i SECTION A —A ABUTMENT ISOMETRIC :, c._ 11 WP\AESTH\TB Slope Treatment o Use standard slope treatment for corridor bridges that is pre -cast, semi - open masonry slope paving overlayed with seed mixes . o Limits and shape of the slope treatment are part of the landscape design. o Use slope paving that is integrally colored masonry unit that has been selected for the corridors. S LANE ARTERAL ROAD OVERQROUNG N r i i •r1 i�' �. .'..1 r � L pti _Tounm or r..r OuniE OF 011.5m (_..00"a— I �-WON O SLOPE PAVEMENT II FILE -CAST CONVATE KWOPEN SLOPE PAVEM09 �- RQADIMAI' -+ VARIES LIMITS OF SLOPE PAVING PRECAST CONCRETE SEMI -OPEN SLOPE PAVING FINISH GRADE SUBGRADE COMPACTED TO 70% ��'' f10ADWAY 16 ," j SLOPE PAVING BURIED 12' BELOW FINISH GRADE AT BOTTOM OF SLOPE NOTE SIMILAR CONSTRUCTION AND LAYOUT FOR 2:1 SLOPES SLOPE PAVEMENT DETAIL WF"":,=STHkTB Pedestrian Rail o Use rail material that will consist of square -welded wire fabric 2" opening. o Use tube steel support frame for structure rigidity and simplify number of visual lines. o All exposed surfaces will be galvanized and painted. N T.S. 2X2XI/4 2'X2'X W.W.F. 2'X2'X W.W.F. T.S. 2X4X1/4 T.S. 2XAX1/4 3' SEC' ION SPACERS o2' O.C. T.S. 2X4XI/4 T.S. 2X4X1/4 3' SECTION SPACERS 02' O.C. T.S. 2X2X1/4 TYPCONS. BAWER TYPICAL SECTION A -A SCALE13/4' -0' I 0 'IV C04;, SARR-ER - wine U,KUU1N,. WWt, I • r: WP\AESTH\TB I* Applied Protective Color Coaxing o Use applied protective color coating on structures in the form of a textured coating sprayed onto the surface of concrete. o Use of applied protective finish coating will be capable of uniformly covering graffiti. o Finish the bridge with applied protective color coating from color that has been selected for the corridors. WF AFSTH\TR -- • 0 0 WALLS &BARRIERS WALLS DESIGN GOALS o Adhere to the overall design goals of the corridor by minimizing the visual impact of the walls and by using elements visually consistent with other corridor structures. o Minimize the use of walls, and when they are required minimize the length and height of all walls as much as possible. o Construct two short walls separated by landscaping rather than one high wall wherever possible and appropriate. o Use horizontal and vertical curves that will help the walls fit the surrounding natural landforms. o Use the most economical construction methods for each of the three types of walls: retaining cut walls, retaining fill walls, and sound walls while still achieving the design goals. o Use a consistent type of retaining wall construction for walls facing the mainline roadway. o Use alternate types of retaining wall construction for walls facing away from the mainline roadway. o Add landscape to visually soften walls and to help blend the wall into the surrounding landscape. o Use large wall planters where very long walls are required, and where right-of- way is available, to add visual interest and landscape to the wall. o Emphasize horizontal lines and minimize vertical joints with details consistent with the other corridor structures. o Use applied protective color coating to help unify corridor structures and to reduce the visual dominance of walls by relating to the color of the surrounding terrain. WP\OTOLL2\TB WALLS DESIGN STANDARDS Retaining Walls for Cut Slopes . * Generally, cut slopes are above and face the mainline roadway. o Use cast -in -place concrete. o Use cast -in -place concrete for abutments and for retaining walls in close proximity to the bridges. o Curve wall ends to blend them into the surrounding topography. o Construct walls with a 2' high by 4" deep stepped top that runs with the profile of the wall and with 6" high by 2" deep reveals at variable spacings (as illustrated) that run level the length of the wall. o Maintain a minimum 5' landscape margin between the face of walls and the roadway shoulder. o Step back the wall 2' minimum and 1/3 the total height from the top of the wall for walls exceeding 20' in height. Construct the lower wall so that it is level and the stepped top follows the same specifications as the top wall. o Finish the walls with applied color coating from the colors selected for the corridor. o Use modified Cal Trans cable safety railing where required. WP\OTOLL2\TB Retaining Walls for Cut Slopes SLOPE TOP OF WALL 2'-0' MIN. PLANTER BED CURVE ENDS OF WALL TO BLEND INTO SLOPE N TYPICAL CAST -IN -PLACE CUT RETAINING WALL - SECTION ELEVATION GREATER THAN 20'-0- HIGH - PREFERRED STEP BACK SECTION CURVE END OF WALL CURVE WALL IN PLAN AWAY FROM TRAFFIC -� ROADWAY TYPICAL CAST -IN -PLACE CUT RETAINING WALL - PLAN TO BLEND INTO SLOPE TYPICAL CAST -IN -PLACE CUT RETAINING WALL - ELEVATION LESS THAN 20'-0- HIGH or SECTION W P'iOTOLL2ITB Retaining Walls for Cut Slopes o • N X Q � N W W=a p Cr0 0 STEP BACK 0 co 0 in io 0 ip io TYPICAL CAST -IN -PLACE CUT RETAINING WALL - DIMENSIONS GREATER THAN 20'-0' HIGH - PREFERRED STEP BACK SECTION 0 TYPICAL CAST -IN -PLACE CUT RETAINING WALL - DIMENSIONS LESS THAN 20'-0* HIGH W F • CTC LL2',TB :7 Retaining Walls for Cut Slopes 0 N O D TYPICAL CAST -IN -PLACE CUT RETAINING WALL - SECTION PLANTERS AT LONG SOUND WALL OR RETAINING WALL W P1 OTO LL21TB Retaining Walls for Fill Slopes * Generally, fill slopes are below and face away from the mainline roadway. o Use Reinforced Earth or cast -in -place concrete as determined by cost- effectiveness. o Match the appearance of cut type walls in those situations where a fill wall faces the mainline roadway. o Provide a minimum 5' wide planting area at the base of the wall for ivy that will grow over the entire wall face. o Step back the wall a minimum of 2' and 1/3 the total height down from the top for additional ivy planting. Where the top of the wall is sloping, the step back should run level and step down as required to maintain a general distance of 1 /3 the total height from the top. o Provide no special finish texture or color because the wall will be covered with ivy. ROADWAY PLANTER AT STEP BACK TYPICAL REINFORCED EARTH FILL RETAINING WALL — PLAN CAST -IN -PLACE CONCRETE CAP a. 2'-0' MIN. PLANING BED TYPICAL REINFORCED EARTH FILL RETAINING WALL — SECTION ELEVATION WP\OTOLL2ITB C I* Sound walls o Use concrete masonry with an applied stucco finish. o Use walls that follow the contour of a slope to a maximum grade of 69'o. o Use stepped walls to follow slopes greater than 61,7o grade. o Build walls to the minimum height required for sound control. o Reduce the visual height of sound walls with berms were right-of-way is available. o Construct sound walls with 2' high by 2" deep stepped tops and with 6" high by 2" reveals 6' below the top of the wall that both run horizontally with the profile of the wall. o Avoid placing sound walls on jersey barriers or any other type of wall construction wherever possible. o Finish the walls with applied color coating from the colors selected for the corridor. WP\OTOLL2\TB Sound walls 2- 0 N D t+5 tD TYPICAL SLOPED SOUND WALL - ELEVATION SECTION GRADE 0% TO 6% STEP AT EVEN LENGTHS 8`0' MIN • TYPICAL STEPPED SOUND WALL - ELEVATION SECTION GRADE GREATER THAN 6% WF'\U I ULL2\ I ti • 9 0 SIGNAGE &LIGHTING SUPPORTS 0 SIGNAGE AND LIGHTING SUPPORTS DESIGN GOALS o Adhere to the overall design goals of the corridor by minimizing the visual impact of the supports and by using elements visually consistent with other corridor structures. o Minimize the size and number of structural elements. o Use structural shapes that relate to corridor structures or structural shapes that have the least visual impact. o Use visually simple supports. o Simplify connections. o Use freestanding supports,not roadway bridges, for all signs. o Use applied protective color coating to help unify corridor structures and to reduce the visual dominance of structures by relating to the color of the surrounding terrain. W P\OTOLL2\TB SIGNAGE AND LIGHTING SUPPORTS DESIGN STANDARDS Signage o Use verendiel trusses with the optimum number of web members and the optimum smallest member sizes. o Use all rectangular members. o Vary the member sizes proportionately for various support lengths and heights. o Use single -posted frame supports wherever possible. o Minimize the use of double -posted frame supports. o Vary the support height and length for the Signage required in a locations. o Use concealed connections. o Galvanize and finish the supports with applied color coating from the colors selected for the corridor. SINGLE POST SINGLE CANTILEVER CANTILEVER SIGN SUPPORT e PREFERRED. UTILIZE AVAILABLE 40'-0* SINGLE CANTILEVER BEFORE UTILIZING EXTRA 16'-0' DOUBLE CANTILEVER, F 0 W P\OTOLL2\TB • Lighting o Use CalTrans standard for roadway lighting at standard mounting heights for specified high pressure sodium lights. o Use cut-off luminares with flat glass lens and a flat profile with a curved shape. o Finish the lighting supports with galvanized and color coating from the colors selected for the corridor. o Use modified Type 21 on overcrossings. ru 4 OWW4 ELEVATION TYPE 15 Y MIseW LOW, awk Of i11tw. ELEVATION TYPE 21 BRIDGE MOUNTED e WP\0TOLL2\TB 0 • GRADING • GRADING DESIGN GOALS o Fit the roadway to existing topography to retain the natural character of the slopes and to minimize cut and fill slopes. o Use split profiles to blend the roadway into existing topography, to improve the visual quality of the � roadway, to enhance views from the roadway, and to optimize cut and fill requirements. o Integrate cuts and fills with existing topography. o Undulate cut and fill slopes in the areas of unconstrained right-of-way to provide natural slope shapes. o Provide rock materials and slope variations that resemble existing land features and natural slope shapes where the use of slope undulations is limited. o Reduce the dominance of roadway structures by using berms. o Use landforms and landscaping in medians to reduce views of opposing roadways, to dispose of fill material, and to provide foundation material for future HOV lanes. o Control erosion by using maximum 2:1 slopes and serrated slopes. o Use serrated slopes to improve revegetation. o Develop cost-effective methods to implement grading design goals. o Provide testing to determine types and locations of surface and subsurface soils to assist in the design of cut and fill slopes. WP\0T0LL2\TB Slope Rounding o Provide a natural blending of cut and fill slopes into existing slopes. o Utilize slope rounding at all sides of cut and fill slopes. Use a minimum of 10' to transition to existing slopes, subject to right-of-way constraints. o Blend natural slope, adjacent ridges and depressions into cut and fill slopes. o Provide a Caltrans access bench for rounding where the right-of-way is within 5' to 10' horizontally from the cut. SLOPE ROUNDING ADJACENT SLOPE > 2: 1 =' EXISTING ROCK OUTCROPPING l/ PRESERVATION '`--• -� SLOPE ROUNDING MIN. 20' FROM EDGE OF PAVEMENT ROCK TALUS EXCAVATED FROM SITE RECLAIMED ROCK /LANDSCAPE • WP\OTOLL2\TB CJ Split Profiles o Maximize the use of split profiles where topography is hilly and adequate right-of-way is available. Maximize use of split alignments where topography is level or depressed. o Make split profiles and alignments as long as possible between the constraints of interchanges, bridges, or HOV connections. o Evaluate split profiles for bridges on a case -by -case basis. o Design split profiles to maximize three types of views: 1. Adjacent. properties viewing roadway 2. Motorists viewing landscape 3. Motorists viewing roadway o Vary the height of separation between roadways. Ideally, make the height between 15' and 24' but not less than 12'. o Locate the higher level roadway uphill on the slope. o Crossing of vertical profiles is acceptable. o Use three road levels (two splits) when feasible if the total vertical variation between the roads exceeds 24'. o Locate reversible HOV lanes with lower roadway, if possible, on two level splits. o Provide a maximum 2:1 slope between roadways, although flatter slope is desirable (refer to slope standards). o Design split profiles to optimize cut and fill requirements. Split Profiles 36 9015 A8 24 14 R1 4, 36 10 15, . . . . . ............... TWO LEVEL SPLIT 5'10' 36' 4'12' 10'5' 5'10' 12' 4' 36' in' TWO LEVEL SPLIT CONCURRENT H.O.V. t w 5 [101 36 10151 24 514 1 24 1425. 24 5,10. 36 1210,5 i, N11, I I{ II II dililu THREE LEVEL SPLIT 0 0 GRADING STANDARDS Special grading o Concentrate slope variations near the base of fills and top of cuts (subject to maximum slope rate), and leave areas near the roadway more geometrically regular. o Preserve natural rock outcroppings by increasing the 2:1 slope, subject to a geotechnical report. o Make a horizontal rounding of cut or fill slopes to existing slopes 10' to 15' wide. o Emphasize existing landforms in areas of swales, canyons, and ravines by horizontally rounding the transitions between graded slopes and existing slopes to a width of 15'. o Build berms and use relocated boulders in infields greater than 50' in diameter, providing the infield is not to be used as a drainage area. Raise infield grades 6' to 8 to a high point 75' from ramp entrances, subject to horizontal sight distance requirements. o Re -use large excavated rocks and boulders in the 2:1 slope to forms talus rock landscapes adjacent to major rock outcroppings for a distance of 100' in both directions, horizontally. o Develop slope undulation at 250' intervals where slopes exceed 30' in height and soils do not contain rock. in a 250' section, provide a transverse section that varies as follows: *Approximately: (see diagram) - Lower 1/3 at 3:1 slope - Middle 1/3 at 2:1 slope - Upper 1/3 at 2:1 slope (not to exceed 1 1/2:1) The slope may vary to a maximum of 3' in depth within 100' horizontally. *All subject to a geotechnical report W P • OTO LL2JB Special grading 1/9 Tr) 1 q rPF r� UNDULATED SLOPE Benning Against Walls o Berm soil against walls located inside the right-of-way as follows: o < 15' wall: Place earth fill to 1/3 the wall height using 2:1 maximum slope. o > 15' wall: Place earth fill to 1/3 the wall height with a 5' to 8' horizontal bench and use 2:1 maximum slope from bench. o Use a minimum horizontal berm length of 500' at 1/3 the height of the wall. o Use maximum transverse slope of 2:1. o Make transitional longitudinal sections at least 100' long with a maximum 3:1 slope that is 1/4 the height of the wall. o Round all top, side, and transitional slopes. o Berm soil against walls located outside of the right-of-way to provide screen wail or enhance slopes as follows: o Make berms at least 250' long with 3:1 transitional side slopes. o Use a maximum transverse slope of 2:1. o Provide swales at 2% grade along ROW and channel them toward shoulder drainage. WF\OTOLL2\TB Berming Against Walls )OR WALLS INSIDE THE R.O.W. It BENCH 'E 2:1 WALLS OUTSIDE THE R.O.W. • L1 Serrated Slopes o Provide in soft rock conditions only, a 1 1/2:1 or 2:1 cut to facilitate growth of vegetation on slopes and control of erosion with regularly spaced steps which enhance "natural" cut appearance. o The location of serrated slopes usually occur in "rural" areas with slopes varying from 25 feet to 200 feet vertically. o Normally, the site section applicable for serration is where the tollroad traverses a two cut section or a cut/fill section where the cuts are highly visible. o Serrated slopes provide a 1 1/2 foot to 2 foot shelf where seeding can germinate with rainfall supplemented with water tanker. o Hydro -seeding erosion control of seed mixtures, such as bromes, vetches, buckwheat and saltbushes, especially legumes, will be used in specific locations to assure stability and coverage. o On long cut/fill slopes, a "waving" effect will be achieved and accentuated by selective re -vegetation wherever possible. o Provide 'sheeps foot' 6" to 9" prones roller surface in all fill slopes. PROVIDE ROUNDING IN TEMPORARY EASEMENT TO MINIMIZE RIDG VAR 2' 7 �1' 5' 10' CORRIDOR 1 SHOUILDER W 00 N m Q ROADWAY WP,AESTH',TB Maximum Slopes o Make all cut and fill slopes a maximum of 2:1 . Flatter slopes are desirable and should be used when compatible with surrounding slopes and when right-of-way is available. o Develop horizontal undulations in the 2:1 slope at 500' intervals by increasing 2:1 with rock (talus) at the toe of the slope, if the slope is at least 50' wide and has non -erodible soil conditions. RIGHT OF WAY ,3'-5' HORIZONTAL BENCH VARIES lolllnn��.,,... �1111 0 TYPICAL MAXIMUM SLOPE rn W Q 5' 10' CORRIDOR ROADWAY 0 0 C7 WP\OTOLL2',TB • Erosion Control HYDRO -SEED MI;'�' BENCH DRAIN WHERE REQUIRE UNDULATED SLC REVEGETATION SLOPE CONDITIONS WP\OTOLL2\TB Median Grading and Planting o Minimize grading or contouring in medians so that drainage swales and vegetation can be adequately maintained. o Landscape medians with revegetation in rural and urban areas. Also, utilize 6' to 8' shrubs in urban areas, informally planted, to screen adjacent roadway. o Connect the drainage swales at the median centerline and at drainage structures, subject to drainage evaluation. o Meander swales in medians greater than 40' wide to resemble a water course with horizontal variations from centerline of 10' to 15' maximum, dependent upon drainage criteria. o Utilize landforms in the median where split profiles do not occur. Design landforms so that future HOV lanes could be incorporated where appropriate. DRAINAGE SWALE • LAND FORM/TO 6-8 FT AT/fl.P. SHRVR_OCATION AA AND FORM H.P. 1p AA i MEDIAN GRADING/PLANTING CENTERLINE 21 i 6 F�i SECTION�MEDIAN PLANTING WP\OTOLL2\TB Pi 0 � LANDSCAPING LANDSCAPE DESIGN GOALS is o Adhere to the overall design goal of the corridor to alter the natural landscape as little as possible by reshaping the land to be like the natural land and by using landscaping that is like the natural landscape. o Use native plant materials and natural planting rhythms throughout the corridor that are in the eco-environment of lowland, upland, or chaparral through which the roadway is passing. o Modify the use of native plant materials and natural planting rhythms as the roadway transitions from rural hill areas to urbanized areas to provide landscape contrast between areas and to visually relate to the surrounding environments. o Use specific locational criteria for planting in urban, transition, and rural areas in the lowland, upland, or chaparral eco-environment in which the area occurs. o Integrate specific community planting programs at interchanges into the native/natural corridor landscaping. o Select plant materials requiring low water use and that have low fire potential. • o Use typical dominant native trees and shrubs as consistent landscape elements throughout the corridor. o Increase planting intensity at interchanges that compliments the bridge structures. o Preserve existing trees wherever possible. o Develop permanent revegetation techniques for cut and fill slopes and medians. o Use landscape and berms to soften walls and blend into the existing landscape. WP\OTOLL2\TB ECO-ENVIRONAIENT California has a varied landscape character. The interaction of marine and continental climate forces, in combination of topographic variety, has indicated many types of landscape conditions. These zonal characteristics were the basis for the planting approach to the upland, lowland and chaparral environments. RRIDOR ECOSYSTEMS �`-LOWLAND CHAPARRAL UPLAND- Predominant marine climate influence Coastal Ocean Coastal Foothills Inland Foothills LEGEND 1 LOWLAND 2 CHAPARRAL 3 UPLAND Inland Inland Foothillsl Mountains Continental climate influence Intermediate i ' I Inland I I Interior Valleys and Plains Valleys Valleys Interior Foothills !44 Point Conception Santa Barbara TRANSPORTATION CORRIDORS • EASTERN • Long Beach SAN JOAQUIN MILLS Laguna ennrwi i Southern Plant Environments 0 Intermediate Valleys, Plains Inland Valleys Coastal Foothills I Inland Foothills Inland Mountains 7 Low Deserts 8 Interior Valleys M*%v DOW San Clemente Palm Spring • ,.T 7 _J OVERALL CONCEPT DIAGRAM Conceptually, the diagram illustrates the idea to blend and extend native environments in and through all three corridors: San Joaquin Hills, Eastern and Foothill. PLAN ILLUSTRATIONS Rural: Provide for lower planting intensity emphasized through shrub/grasses and wild flowers. Urban: Develop layered plant material to create interest, provide informal rhythm and avoid monotony dominated with tree/shrub. Transition: Create a simple but continuous planting standard to bridge hillside to urban areas. Tolls: Provide intense planting to highlight slower viewing and administrative buildings. RURAL SPECIAL TRANSITION URBAN (Toll Plaza) 0 R a _a C W 0 vj J J rE H Q z . m c m E= E 0 >�`m� m� ;L 0 Q c a c a¢ m 0 o C m Cf o �v m� a a �Zco E m 10 E m c° 0Zcoc <m�� mmc a. n «m o s c E o 0 0 o c 0 C v 0 a l� A1 ' v" % �I , W-n.-Jtrl-d I El 0 DESIGN STANDARDS 611 Rural o Develop planting at interchanges which consists of a minimum of 15 - 20 trees which parallels ramp geometry and grasses/wild flower. Accent trees should be 35 - 45 height planted in front of corridor trees for continuity to the community. o Provide revegetation steps on cut/fill slopes as follows: 1. Hydro -seed with annual grasses, ground small shrubs for immediate ground cover. 2. Mixture of woody materials follows the more rapid annual grasses. 3. In the mixtures use tree species which require additional time but help the natural progression. 4. On fill slope, to speed re -vegetation plant tree and shrub stock as large as possible to force natural progression. 5. Mulch all 2:1 cut/fill slopes to hold moisture and provide for germination. 6. Use 'sheeps foot' roller in fill slopes to facilitate enhanced revegetation. 7. On serrated cut slopes, at nominal 2 foot intervals, slope the horizontal shelf 1" to hinge point to facilitate long lasting vegetative stabilization. 8. Areas to be topsoiled should be scarified to a minimum depth of 3" prior to placement of top soil. 9. In most instances, rural cut/fill slopes will not be irrigated and therefore a preference is to seed, fertilize and mulch by September 15 or provide tanker watering in non rainfall periods to assist germination. 11 o Integrate container planting within rural areas as part of revegetation slope treatment. Ravines/Canyons o Provide for seed mixtures which integrate plant environment and would not invade native materials. o Develop preservation techniques for oak, sycamore, etc. trees adjacent to roadway through providing barriers and permanent fencing. o Provide an inventory of soils and plant species to precisely determine plant compatibility. WP\OTOLL3\TB DESIGN STANDARDS Transition o Develop within a minimum of one quarter to one half mile corridor segment between interchanges a combination of grasses, legume, low shrubs and wild flower seed mixtures as the dominate planting approach. o Provide beyond 400 - 500 feet ramp location native canopy tree groupings of 3 - 5 which integrate into high shrub/low shrub plants at the top of the slope to buffer adjacent communities. o Develop informal rhythm for hydro -seed mixtures and container covers/shrubs/trees. o Provide irregular spacing for container planted shrubs and trees. o Develop seed mixtures two thirds up the slope with first one third of slope wild flowers. Provide temporary irrigation near the top of slope for shrubs and minimal trees. o Provide medians with non -irrigated meadow grasses with seasonal wild flowers. • 0 WP\OTOLL3\TB DESIGN STANDARDS 0 Urban r] o Accent screen trees shall be planted between 15' and 20' apart and a minimum of 5 - 10 feet from soundwall or retaining walls. o Develop a minimum of 15 trees in infields and horizontal segments from ramps. o Develop a layered planting composition with accent shrub/tree groups consisting of a minimum group of 5 - 7 trees between 15 and 30 feet apart and a ratio of 3 shrubs per tree. o Provide 500 feet from intersection spreading low shrub of 18" - 24" minimum height with drought tolerant ground covers 6' to 10' apart informally planted as a triangular pattern. o Develop 4 - 6 cultivated different plant species planted within one half mile segment of the corridor. Repeat this plant material on the opposite side of the corridor. o Develop interchanges and above grade plantings fully irrigated and provide a focal point. Large masses of native plants should also incorporate trees and shrubs that have an identify with the adjacent community adjacent. o Develop ground cover a minimum of 3 - 4 feet from edge of shoulders and guardrails. o Provide all shrubs (not including ground cover varieties) a minimum of 8 feet from edge of shoulders, side walks and guardrails. o Develop irrigation for plantings at grade and depressed sections of the corridor with pressure compensating bubbler heads for each individual grouping and overhead watering for mass shrubs and groundcovers. o Provide vines at a minimum of 8 - 10 feet apart with 3 lower shrubs per vine at retaining walls. o Develop wildflower at high visual impact areas like intersections, infields and transitional slopes. WP\OTOLL3\TB • 0 SPECIAL AREAS Tolls o Develop a minimum of 5 - 7 accent/tree/shrub groupings, informally spaced to accentuate sight distance from administration buildings. o Hydro -seed with wildflower and low growing accent shrubs on the lower two thirds of surrounding cut slopes. o Preserve upper one third of existing slopes in natural vegetation and clear growth for fire -control. o Add revegetation on fill slopes and hydro -seed lower one third of newly contoured slope. o Low shrubs on bermed slopes spaced informally 10 feet apart at administrative building. WP\OTOLL3\TB W T N � W -K Y! • O % W ¢ < +I I�r ; z O f T N I ° ° cc a � a U_ W O < O J N x � W o ��l � • � I 0 3 2 rI J ¢ 7:. = W v' x e < N z < '^ < rn J L �j W W = F ` j ; 2 c M 3 > < < � 6 !Z N �I O O z L � Z i LTA "�i fl i' y W > O W z N W ` Nzu W O JJ z N h 4 Z _ JLU got U i ~ V U a a n � '�• J W T a 4 ` <Az z < O a Y! - cr.o a c 3 < Z �• + 1 ) i� N W W < N U . a W CL C IL V J '.�'-•:tom Z O r `� Q Q •��v W O 4 J -01 W w i W. � LL Z Q ; > Q W >V 4 0 f U aaW. J 4 Q cc 3 3 �l.re�ar O 1 r� DESIGN STANDARDS OVERVIEW o Planting density is illustrated -on the following pages which conveys the character of the landscape approach and plant selection. o Interchanges vary within all three corridors, however, the principle planting rhythm has been illustrated. o Plant selection and palette is provided for the variety of native and modified materials considered to be appropriate for the upland, lowland and chaparral environment, contingent on soils, water and planting period. o Recognize all Caltrans landscape and maintenance requirements. o Major arterial planting programs existing or proposed needs to be coordinated with communities. o For conditions with existing dense landscape screening located adjacent to the right of way, planting for corridor at those locations should be compatible. WP\OTOLL3\TB I • URBANINTERCHANGE o Develop dominant tree planting approach with a minimum of 2 - 3 species. o Provide integration of tree planting along arterials to include a mixture of "natives," indigenous and minimal ornamentals. o Develop raised berms at the infield to screen and highlight tree/shrub edges. o Use "wildflower" (annuals) at ramp and infield location facing the driver. 11 r WP\OTOLL2\TB �A Y \1� h' 1 ( i 0 0 I tit rd M 0 11 Ll • I C� W � M •i li � J }tO.: �i i i a� s H O m J J WATER CONSUMPTION ILLUSTRATION o Develop a water usable measurement which illustrates the following principles: 1. Planting area irrigated with potable water requirement for an average of 3 AFY throughout the corridor. 2. If reclaimed water is utilized, 201,7o additional area could be planted. 3. Assumed budget is approximately $19,000/acre with irrigation. 12 FT 35 FT 1 1 ACRE OF TYPICAL LANDSCAPE IF POTABLE WATER SS USED. 20% INCREASE IN LANDSCAPE IF RECLAIMED WATER • IS USED. WP0 7 OLL2`TB • PLANT LISTS 0 Develop plant list which is derived from the various eco-environments, concurrent with Cal -Trans standards and quality of texture, color and similar "native" characteristics. Plants should be selected as a family of materials. WP\OTOLL2\TB El ON cy3ods AdONVO 2 W I— r co O W = LU W E 3� LU QW Z `'S Q Z U Z Z O 2 42 Z O 00 m Q� Oil Q�l J�l 0 j a�l 0'1 Oil a s -a d 0. a a y .. U) Vf 0 Oz zW W t U iA Vfj < < S W U Z W IL z IL U) w W O O < O = 2 Z < d a O oW. O < N O O d d d d J J J d J J < IL 0 S O O O S O O S .j U J '� J U J J Q > > > > Z > > > > m S 6 Q W 0 ¢ Q Q to y iA W Z N y (A N W O O O O yaj O O O O U U U U O U U U U A I J I W W J W W Z 2 < 2 J U U < C V1 w w U)W Q W o O 2 2 Z = J < J a a a > > J ° g g o 3 5 3 3 j a J O 0 0 c j o 0 0 0 W ¢ LU CC Z W W Z W O W y U) H N N N 2 to W z W O aai O O IL w O O O W O U O U U O U V V O U aAj 0 0 • • (•j "n w w w .� L 99 • L a C a L O Y G, a a .0 0 w C C M G t 0 Y C. 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C a Y M G / O r w ■• S~ G �c ■ u Q 6� so r 7M4_ ` �+ a CO u O iY A. y.Ki.y7M7 . too �.GJ{mar9r!gtt- OC.•( �.00Y.�.r+IEy��1 O ow � N{O W 1�I. Si pSJpiC pw Ni 0 ►G - ■ O�°� Y 9.,YkY w�■O8/6 .Yui!ynk wU G � .tluS�Ug>• tT U M +Op.k s S1+ K5■'0 i■7Y«�p■l KStIO•0 8y~�/ !! NG! to 0 0 O O 0 0 0 0 0 0 0 0 0 0 0 O O O O J Z°`°�ooc Trees for Screening 1. Lowland 2. Chaparral 3. Upland TREE HEIGHT ECO-SYSTEM o Casuarina Spp. 20 - 70' 1 Beefwood o Pinus halepensis 30 - 60' 1,3 Aleppo pine o Quercus ilex 40 - 70' 1,2 Holly Oak o Laurus nobilis 25 - 30' 1,2,3 Sweetbay o Ligustrum lucidum 30' 1,2,3 Wax Tree o Prunus caroliniana 35' 1,2 Carolina Cherry o Lagunaria patersonii 20 - 40' 1,2 Primrose Tree o Acacia melanoxylon 40' 1,2 Blackwood Acacia o Eucalyptus cladocalyx 75 - 100' 1 Sugar Gum o Eucalyptus ficifolia 40' 1 Red Flowering Gum o Pinus canariensis 60 - 80' 1,3 Canary Island Pine 00192-Do Shrubs for Screening 1. Lowland 2. Chaparral 3. Upland SHRUBS HEIGHT ECO-SYSTEM Callistemon citrinus 10 - 15' 1,3 Lemon Bottle Brush o Cassia artemisoides 5' 1,2 Feathery Cassia o Ceanothus 'Ray Hartman' 10 - 15' 1,2 Feltleaf Ceanothus o Ceanothus rigidus 6 - ?' 1,2 Snowball Ceanothus o Dendromecon harfordii 6 - 20' 1,2 Island Bush Poppy o Dodonaea viscosa 12 - 15' 1,2 Hopseed Bush o Elaeagnus pungens 8 - 15' 1,2,3 Thorny Elaeagnus o Grevillea thelemanniana 5 - 8' 1 Hummingbird Bush o Helianthemum nummularium 6 - 8' 1,2,3 Sunrose o Myrtus communis 5 - 8' 1 Myrtle o Rhamnus alaternus 12 - 20' 1,2 Italian Buckthorn o Teucrium fruticans 4 - 8' 1,2 Bosh Germander E C0192-90 Groundeovers & Vines for Bridge Slopes All Eco-Systems . GROUND COVERS o Eriogonum fasciculatum 'Dana Point' Buckwheat o Eriogonum parvifolium Coastal Buckwheat o Hedera helix English Ivy o Hedera helix (Hannii) Hahn's Ivy o Hypericum calycinum St. Johns Wort • o Myoporum parvifolium prostratum Myoporum o Pachysandra terminalis Japanese Spurge o Vinca minor Dwarf Periwinkle o Zauschneria californica California Fuchsia VINES o Ficus pumila Creeping Fig o Lonicera japonica 'Halliana' Halls Honeysuckle o Parthenocissus tricuspidata Boston Ivy 00192.90 �I. • y 3:;••••00 Quercus agrifolia Common Name: Coast Live Oak. Leaves: Evergreen. Finely to coarsely -tipped. Leathery. Nearly round sometimes. Dark green above. 1 to 3 inches long, 3/4 to 2 inches wide. Flowers: Male catkins occur in February to April. Fruit: Acorns that mature the first year. Cup is broadly top - shaped. The nut is slender, pointed. Light chestnut -brown in color. Borne singly or 2 to 4 in a cluster. 1 to 111 inches long. Environment: Full sun, partial shade. Best in the coastal area. Tolerant to heat, some cold, but not prolonged freezing. Rate of Growth: Moderate to rapid. Pruning: Only if needed. Seasonal Value: Foliage, fruit. Shape: Massive, wide -spread. Spread: 60 to 100 feet. Diameter to 8 feet. Height: 30 to 75 feet. Soil: Best in light, well -drained soil. Tolerant however. Has a deep, extensive root system. Use: Specimen, shade, erosion control. Bark used for tanning. Origin: Coast Ranges from Sonoma County to Baja California. Comments: Should have sufficient room to grow. Planting Zones: Urban, special and rural. Lowland, upland. CORRIDOR DESIGN MANAGEMENT GROUP A -Am1Nr Fa- -W--C NIEDLLS IAL�A L IINCt ND?:f •cSM! Sc NCA IN-W, DLADI L DDUC.AS. INC. CIb 3 Hw.rs_f�✓/C Lvonothamnus floribundus (var. asplenifolius) Common Name: Fernleaf Catalina Ironwood. Leaves: Evergreen. Fernlike. Dark green above. Leaf blades 3 to 6 inches long. About 1/2 inch wide. Flowers; White. About 1/4 inch across. Frangrant. Summer. Fruit: Brownish, woody capsule. About 1/4 inch long. Usually with 4 seeds. Environment: Best in coastal area. Not tolerant to prolonged cold. Neither extremes of heat and cold. Best in full sun. Not for inland valley areas. Rate of Growth: Rapid. Pruning: Train to a single trunk when young. Seasonal Value: Foliage, flowers, bark. Shape: Variable. May be multi-trunked. Spread: 15 to 40 feet. Height: 25 to 50 (80) feet. Soil: Should be well -drained. Fertile. Tolerant to some drought. Roots are moderate in depth. Use: Specimen, hedge. Origin: Southern California. Santa Catalina, San Clemente, Santa Rosa, Santa Cruz Islands (Channel Islands). Comments: The reddish brown bark peels in long vertical • strips. These weather to a silvery gray color. Planting Zones: Urban, special. lowland, upland. 'CORRIDOR YAMAOtYEMs. YIIOUP _ • .aR'nt ..b+ � �- -*--R +D�a�D KCDa I-"-LS taw ► \C�Ctny� •, rac Sr.. M_t aCRhCi OUADt ► DOUCI at. ,MC . '. 0- Caw Ci. •C Aeo�l 1 (.Y *a•.%: :'�•• - jf:..�•__j$ ••y �'r'�.a � 1'1 'L {• s,• `�-�....L��. .a�� i. 5�. _ "•�',��►'••�- ti`�.r� • ' '`��`;'t'1-• •�';� -: •. t-= -�� • : is :�•:•wl F � w=' Z f- .. •-•- ••: _ • .{.•.ter _ ._ '.. - _ _�'- , _'� _ y 1410 C Rhus ovata Common Name: Sugar Bush, Sugar Sumac. Leaves: Evergreen. Glossy. Pinkish -green. Thick and leath- ery. Reddish at maturity. 3/4 to 11,12 inches wide, 1 to 4 inches long. Flowers: Whitish or pinkish. In dense terminal cluster. Pink buds. Fruit: Reddish drupe. Coated with a sugary secretion. In tight clusters. Flattened. 1/4 inch in diameter. June to October. Environment: Full sun. Tolerant to seacoast it not exposed directly to salt spray and direct sea winds. Dry slopes below 2500 feet. Rate of Growth: Moderate to rapid, Pruning: Thin as needed. Not severe. Seasonal Value: Foliage, flowers, fruit. Shape: Roundish, erect or spreading. Spread: 21,2 to 10 feet. Height: 21R to10 feet. Soil: Tolerant to summer water if well -drained. Taproot. Use: Specimen. Background. Screen. Hedge. Espalier. Origin: The dry hills in Southern California from Santa Barbara to San Diego Counties. Santa Cruz and Santa Catalina Islands. Comments: Indians used the fruit for sugary drink, Planting Zones: Urban, rural, speciai,upland, transitional chaparral. 0 C011111D011 DESIGN MANAGEMENT GROUP SUGGESTED PLANT SPECIE Lam% ••S7.S 64.N;. (Ilw(ff ON.J, I. Oml'.S. .Nt •i 1Y O.N t.. NC . Platanus racemosa Common Name: Western Sycamore. Leaves: Deciduous. 5 to 10 (18) inches across. To 12 inches long. Lobes longer than wide. Light green above. Hairy be- low. Flowers: Greenish. In dense heads (globular clusters). February to April. Fruit: One -seeded nutlet covered with long hairs. 3/4 to 1 inch in diameter. Environment: Full sun. Tolerant to heat, cold. Adaptable. Below 4000 feet. Rate of Growth: Rapid. Pruning: Tolerant. As needed. Seasonal Value: Foliage, bark. Shape: Variable. Round top. Often multiple-trunked. Spread: 20 to 35 feet. Height: 25 to 40 feet. Soil: Tolerant. Best in deep, rich, moist soil. Tolerant to alkali. Has a shallow, spreading root system. Use: Erosion control, shade. Origin: Along the streams in California foothills and in the Coast Ranges. Comments: Bark is palish or whitish and it exfoliates in thin plates. Planting Zones: Urban, special, rural, upland, transitional. a,eR COIIIIID011 OEt10N MANAGEMENT YIIOYP .C'/� •- o N, pill;, NEEDLES -l1Y(h \ Bf NC111 i4_\ Xfn.�ct . Diu;GY �� Quercus engetmanii 0 Common Name: Mesa Oak, Engelmann Oak Leaves: Evergreen to briefly deciduous thick. Light to deep blue-green many shapes, from oblong to rounded. Flowers: Fruit: Heavy acorns. Large 1 to 1112. Environment: Full sun. Dry coastal and inland foothill regions. Rate of Growth: Moderate. Fast with water. Pruning: Thin as needed. Seasonal Value: Foliage, fruit. Shape: Broad, round dome. Spread: 30 to 50 feet Height: 30 to50 feet Soil: Deep well drained. Use: Specimen, shade. Origin: Southern California San Gabriel and Palomar moun- tains. Comments: Deeply furrowed grey -brown bark. A prized specimen tree. Planting Zones: Urban, rural, special,upland, lowland. 0 I:OIIRI0011 DESIGN MANAGEMENT RE GROUP M-1 1.60- D•w.C-. It.. CCNFAVM AdVAW �i �:• .gal ,C �i Quercus lobata Common Name: Valley Oak, California White Oak. Leaves: Deciduous.- Green above, paler, with yellow veins below. Leaves 212 to 4 inches long, 11,2 to 3 inches across. Flowers: Male flowers are catkins. March and April. Fruit: Acorns which mature the first year. Reddish -brown at maturity. 1114 to 2 inches long. Environment: Full sun. Tolerant to high temperatures. Rate of Growth: Rapid. Pruning: Thin as needed. Seasonal Value: Foliage, fruit. Shape: Massive, wide -spread. Spread: 70 feet or more. To 9 feet in diameter. Height: 70 feet or more. Soil: Best in deep soils. Tolerant to some alkalinity Use: Specimen, shade. Origin: In Sacramento and San Joaquin Valleys south to the San Fernando Valley. Comments: California's largest Oak tree. Bark is thick, light gray. Planting Zones: Urban, rural, special, lowland, upland. CORRIDOR DESIGN MANAGEMENT GROUP c••• ,• nc 916Mtt OUAOI f. OOjC. •5. j,C. •..SI Qu L.. i•.0 i F lopm�p G Al c� >= Fremontodendron mexicanum Common Name: Southern Fremontia Leaves: Evergreen. Dark green above. White or rusty hairy below. Leathery. 1 "4 to 3 inches across. 5 to 7 main veins from base. Flowers: Orange -yellow. Reddish at the base on the outside. 1112 to 2 "I inches across. March to May and July to August. Prolonged flowering, Fruit: Conical capsules covered with bristly hairs. Persisting for a long time. Seeds black and shinny. About one -eighth of an inch long. Environment: Full sun in dry areas. Rate of Growth: Moderate. Pruning: Pinch back when young to shape. Seasonal Value: Foliage, flowers. Shape: Loosely branched. Spread: 8 to 15 feet Height: 8 to 20 feet Soil: Dry, well drained. Drought- tolerant. Use: Specimen. On sunny slopes. Erosion control. Origin: On the dry slopes in the extreme southern area of San Diego County and south into Baja California. Comments: Leaves distinctly veined and lobed. Seeds, black shiny. • Planting Zones: Rural, upland, chaparral, transitional. COIIIIID011 DESIGN MANAGEMENT a110U► cac•v(>•_ .... •a•.c �rrc r. +•Wr. � �t•cr•rt^�+ . J.i Ua•.�(•, , _t "t.. sew Isomeris arborea Common Name: Bladder Pod. Leaves: Evergreen Pale grey -green. Divided into three leaflets. Flowers: Pale yellow. February to May. Fruit: Seed pods emerge green, turn tan. Environment: Full sun. Coastal sage and grassland plant. communities. Does not need supplemental summer water. Rate of Growth: Rapid. Pruning: None. Seasonal Value: Foliage. flowers. Shape: Dense mounding shrub. Spread: 3 to 6 feet. Height: 3 to 6 feet. Soil: Accepts marine clays to rocky soils. Prefers good drainage. Use: Specimen, massing, erosion control. Origin: San Diego to Los Angeles counties to edge of Mojave and Colorado deserts. Comments: Provides moderate fire resistance. Grows easily from seed. Planting Zones: Rural, special.upland, transitional. WW•.. • - .: CORRIDOR DESIGN MANAGEMENT GROUP _a.« „ao_•. N. c «umLS �s lak".ri, •.•»•. e• ,:.t.._. ou.uf S a,.....s. , 1 c.. •«c.. }I�TiW Rhus integrifolia • Common Name: Lemonade Berry. Leaves: Evergreen. Thick and leathery. Dull green above. 1 to 2 f2 inches long, 3/4 to 1 112 inches wide. Flowers: White or pinkish. In dense terminal clusters. Individ- ual flowers about 1/4 inch across. Mostly from February to March, but sometimes from January to July. Fruit: Reddish at maturity. Hairy and sticky. Rounded, some- what flattened. July to September. Environment: Full sun or partial shade. Best near the coast. Tolerant to seacoast conditions, wind. Below 2500 feet. Rate of Growth: Moderate to rapid. Pruning: Thin if necessary. Seasonal Value: Foliage, flowers, fruit. Shape: Large shurb or small tree. Spread: 3 to10 feet. Height: 3 to10 or to 25 feet (rarely) Soil: Tolerant. Best if irrigated about once a month during summer Use: Formal hedge, speciman, screen, background, ground cover. Origin: On the bluffs and mesas on the coast of Southern California from Santa Barbara County to Baja California. Comments: Will grow taller away from the wind. Planting Zones: Urban, rural, special, lowland, upland, transi- tional. CORRIDOR DEl10M MANAGEMENTGROUP .p-utAaK.\D NSC$E! i\Y[N It PCI N^,'s.. Nf-tawr o.u)C ► 3wc,s N! '.. Rhus laurina Common Name: Laurel Sumac. Leaves: Evergreen. Aromatic. Veins reddish. 1 irz to 5 inches long to 2 inches wide. Flowers: White. February and March. Fruit: Whitish drupe. Very small, one -eighth of an inch across. Environment: Ocean bluffs and canyons, dry slopes below 3000 feet. Full sun. Rate of Growth: Moderate. Pruning: As needed. Seasonal Value: Foliage, flowers. Shape: Rounded. Large shurb or small tree. Spread: 5 to 7 feet. Height: 5 to7 to 13 feet. Soil: Tolerant. Dry. Use: Specimen. . Origin: Along the coast, from Santa Barbara County south to lower California to Riverside County. Comments: Good honey bee plant. Planting Zones: Urban, rural, special,upland, lowland.transi- tional. CORRIDOR DEMON MANAGEMENT 41ROUP •••'Nfit. • a. -001R? MEEOttS t•YfM ► IBM:h:AV �. •-tittis Ya •Mt •CF.4f OWOE \ DWCI•S. -K •tuO. 0—ft. -MC.. W. fMG c C CAI ila,� ti .1.. • 0A CORRIDOR DESIGN MANAGEMENT GROUP • ccciyC oa-,c �. �•�C .FFD•CS tort. S �FDc[.Dr+t ••c :;,,,' D� �:•.F►.G%t 0646C S DOuGt •S. �.0 .JD- Prunus lyonii Common Name: Catalina Cherry. Leaves: Evergreen. Thick and leathery. Dark green above. 2112 to 5 inches long, 1 to 2112 inches wide. Flowers: White. Each about 1/4 inch across. In dense racemes that are 3 to 5 inches long, each with 20 to 40 flow- ers. March to June. Fruit: Dark purple to black . About one inch in diameter. July to October. Environment: Full sun, partial shade. Best in sun. Rate of Growth: Rapid. Pruning: As needed. Tolerant to severe cutting. Seasonal Value: Foliage, flowers, fruit. Shape: Variable, a larqe shrub or small tree. Spread: 15 to 30 feet. Height: 15 to 45 feet. Soil: Tolerant, but best on dry side. Good drainage. Summer water until established. Use: Specimen, screen, hedge. Origin: On the islands - Santa Catalina, San Clemente, Santa Cruz. Comments: Easy to train as tree. Planting Zones: Urban, special, lowland, upland. Encelia californica Common Name: California Encelia. Leaves: Evergreen. Bright green leaves Flowers: Bright yellow. Daisy -like. Spring through summer. Fruit: None. Environment: Full sun. Best in coastal areas. Dry slopes, canyons near coast. Rate of Growth: Rapid. Pruning: None. Seasonal Value: Foliage, flowers. Shape: Many branched, rounded shrub. Spread: 3 to 6 feet. Height: 2 to 4 feet. Soil: Tolerate clay soils. Use: Massing. On sunny slopes. Erosion control. Origin: Coatal bluffs and foothills from Santa Barbara county to Mexico. Comments: Grows easily from seed, tolerates wind. Planting Zones: Rural, special, lowland, upland, transitional. CORRIDOR DEBIGN MANAGEMENT GROUP ". • -0.." WiO:II T-_k- \ 11 RG. • 8- .UI N-0W: OJ X L 00u[. AS. -1A •..JOt G.w•IL. INC.. Cercis occidentalis Common Name: Western Redbud. Leaves: Deciduous. Nearly round. Green when young, dark bluish -green later. Yellow to red in the fall. New growth is copper -colored. 2 to 3112 inches across. Flowers: Magenta -colored. On short stalks of from 6 to 12 flowers. Before the leaves. Last about three weeks. Best if temperature goes below 28 degrees in the winter season. March to April. Fruit: Oblong pods. Flattened. Dull red color. Seeds matu- ring in the fall. 11,2 to 3 inches long, with 3 to 4 seeds. May to August. Environment: Full sun or partial shade. Effective on dry slopes. Grows most places except in desert areas. Rate of Growth: Rapid. Pruning: To shape, if necessary. Seasonal Value: Foliage, flowers, fruit, fall color. Shape: Compact, multi -branched. Spread: To 16 feet. Height: 8 to 20 feet. Soil: Best if slightly acid. Good drainage essential. Use: Specimen, groupings, background. Effective with other natives such as Ceanothus griseus. Origin: Mostly in the south central part of California, between 1,000 and 4,500 feet. Also in the Sierra Foothills and the Cbast Ranges. Comments: Widespread in California. Branches are often reddish -purple. Interesting plant all year. Planting Zones: Urban, rural, special, lowland, upland. oases CORRIDOR DESIGN MANAGEMENT p110U► '. UCI ••[. .w[ a� 3 C •U O C w rn .E ti H RT H E ° R o � O ii C N � O O 00 � 7 co a� O 3 • u CV 1. O co m O a '43 a a O N N Z—dS O 5 ' Z W o. 'p d Q o ' z E N Ci Os < < N W In OF Q o u z �.. p,pr' It, m N N u 0 G L) � 8S8 •c� V n u u u ~ O v Z C � Z � m u '2 O xF] ii v o J Q Z o Q m OV FZ JZ J < z< z ! a A Q 0 N N V Q oV Z �z W J Z A H Z N x Y q r *021-_ 0 ZW Ov �_ << J Z J W < ~ Z z� ' dl tlf J f. N ui C ziW J' "= T O WI > >. • 01/31/91(TCA901B%INDEXV-4) EXHIBIT 3 BUSINESS RELOCATION INFORMATION i` 0 0 E i (40 a) a� v U ^O a ctsCL co .r cm N 0 T Q SON C CIO O Q O I.-Qr cri O O N CC CL Oam E a Q 0 Cd � Q c C (ts • 0 Cc o m r i� C rn--0aEbm a) s(D CO pp)= co'0, O m Na ai o O L=44 a)- 0 cm —CIS 0 N.�.00a) aco O O �, c� � a E (a a 73,0 �+U ` tLC U me.COLV1o0a 4Zm vaiv ccoaaa) ~ 4) " Z Z :rs 0 = — 0 0 $..-CEO(Daj O O N L O O C Ew Ow U II Ma _—>.aCD tnOa4)"t''"Oa) .. Y a) >. O O O) A co : cC C O 0= o'v'3 O V C U 0 00 3 C CD a) L — L N L 0 2 a) U c9 Nt �.0 O m rn co a M m oc —Cv a rn ca CL ca c>O ) n ca E a) :oC. 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CL H(a..C.+.—>..mO�...cc Ua)CIS UEa)asU? a. cm ca 0 .«r GC O EGIMIT 17 When you sell your properly to the State there is the same obligation as in private transactions for you to pay in escrow the amounts needed to remove trust deeds, mortgages or other liens affecting your property. It is recommended that you contact directly the persons to -whom you are malting payments under trust deeds or otherionsvand to clreach an agreement with them as to the amount of money Y will escrow ur property -of these encumbr"pos. : When you sell your property to the State. Your obligation for payment of property tacos is the same as if you were selling to a private individual. The method of payment is different, - however. : Current Taxes are NOT prorated through escrow, but ra..her are handled as indicated below; pursuant to the provisions of Sections 4986 and 5096.7 of the Revenue and Taxation Code:"?. ,_, If at close of escrow you ha e_ I. Already said taxes for a period which extends beyond the close of escrow, YOU ARE FNT1T E0 TO A REFUND of that portion of said tax which applies to the period after the sale. Such refund will be made by the taxing agency upon proper application by you. You may use the attached request form in making.such application. Instructions for CompletingQefund Application: Paragraph 1: Strike out either the words "a portion" or the word. mall'," so that the form will indicate what was acquired from you by the state: also strike out the words "including the imporvements thereon," if not applicable. Paragraph Ili: Mark an "X" in the appropriate box to indicate where and to whom the refund shouId be sent. After completing the form as indicated above, date and sign it and send to the appropriate tax office whose address will be supplied you by the State Representative with whom you are dealing. Note_ 1: 00 NOT SEND THE APPLICATION UNTIL SIX WEEKS AFTER PAYMENT IS RECEIVED FROM THE STATE. Note 2: BE SURE TO ENCLOSE YOUR RECEIPTED TAX BILL WITH THE APPLICATION. II. Not paid taxes for the current fiscal year, the Tax collector will issue a now bill for the amount due from you. (Said bill may not reach you for same time after your State transaction is closed.) Payment of the new bill is due when received. III. Not paid taxes for previous fiscal year(s), such taxes must be paid from proceeds by the escrow holder. 12-EX-04-01 (Rev. 7/89) COUNTY OF ORANGE AUDITOR -CONTROLLER TAX UNIT B0X 687 SANTA ANA, CA 92702- STATE REFERENCE:__• P.M. PARCEL NO. I. Enclosed is receipted bill showing taxes paid on property described herein. Part of. said taxes covers a period during which the State of California was the owner, of (a portion) (all) of said propertyg (including the improvements thereon). I1. Under the provisions of Section 5096.T of the Revenue and Taxation Code, entitled to a refund of those prepaid taxes which apply to: 1. The portion acquired by the State's purchase. Please send the refund to the refund to the undersigned at the address indicated,` or ( ) Please send the refund'to: Name Address .who actually paid taxes. I hereby declare under penalty of perjury that,the foregoing is true and correct. Dated this day of 19 Name Name Address p0 O �r0+1 Y C C O u G 'C �• m C C •^ Y w w lr..• �..: u Y A 3 4 p a C '•� L .0 '? L C N C C V Z N 4 .0 m Y .0 ° r c 4! ° A U~ .� V O 'fl u .0 O. p O %C� 40 Y Y O Y= y N N '� V N 7 '^ O i` ya Euto You vc.O �°°' •vy.o wuc a! .of M .:. �. • O. p 'a' N ^ .°.! u C `� u al C V V �' Q• p' ° > L�` A ►, p... r :: o aS.c ,j u. ti v u o cou 0.-3`„ "° A R `v y c 8 go 3 E 4 °'Z po bog.. °i'`d•C�o > �..csT °, Jiie cLw� u� + o� �c•�Y oa.o`�a V G .Q Y' u ,o Y V N 00 ` CZ a Q. o. C C. y v O 0. 7 N .O C .0 p; o u '+ 4 u °i u A o. ° a W u u E u o u k N L. .. -a •° » °• L .b .0 Yr 3 L .. V c > 'v o a .0 r, a ,i. co p L .o u M o c .. a•t.. o •v y u u y t-+ pp u o > p o .c C CL w G..x 01 •3 .0 °' Y oo .. 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Euo• N'cuC a^ou C'0E no Ou EZ =m °Oaxg E p-0 YAM -EvU., o vs uJ EaY 0 a a-ua.�3u'& E o c"�:-N u our4E�o1.cu L. o v u u'<u O a $ > uuac 0.0a u °A .� o E buoES S. r.O �d` u — z°A. °.Oo ;°' La3rE'OoG ::Cuo•a °Aa 'a`r.odb-2aE~i u=oz-caoO'C xc� ° N� "u uno o cu u o lu •. u APPLiCATIgN FOR ASSESSMENT UNDER SECTION 68 R & T CODE ' Applicant ,,,,,Ose mailing address C is requests assessment under Section 68 of the Revenue and Taxation Code and declares that he acquired real property after March 1, 1975 as a replacement for comparable property in California from which he has been displaced by eminent domain proceed- ings, by acquisition by a public entity, or by governmental action which has resulted in a judgment of inverse condemnation. PROPERTY FROM WHICH APPLICANT WAS DISPLACED: "'o Address street city state zip Assessor's Parcel Number Public agency acquiring property Selling -price $, county Date of transfer Recorder's Document No. Use of property rest ence, apartment building, store, factory, etc. REPLACEMENT PROPERTY :WHICH APPLICANT ACQUIRED: Address street city state zip county Assessor's Parcel number Purchase price $ Date. of transfer Recorder's Document No. Use of property (residence, apartment building, store, factory, etc. I certify (or declare) under penalty of perjury under the laws of the State of California that the fore- going and all information hereon, is true, correct and complete to the best of my knowledge and belief. Executed at , California, this day of 19 Telephone r ) AADLEY L. JACOBS — ORANGE COUNTY ASSESSOR P.O. Box 1948. 630 N. BROADWAY ADDITION Signature of Applicant SANTA AA. CA 92702 PHONE 17141 834.5031 0 EXHIBIT 4 STAMINA NOISE MODELING n U r• 01/31/91(TCA901B•••INDEXV-4) SAN JOAQUIN T.C.: NOISE ANAYLSIS CONVENTIONAL 6-7PM (R20.CON) • 0 RD 8 _RD )K z 7 RD 4 STAMINA 2.0/BCR FHWA VERSION (MARCH 1982) TRAFFIC NOISE PREDICTION MODEL DEVELOPED UNDER CONTRACT BY BBN MODIFIED FOR CALIFORNIA VEHICLE NOISE EMISSIONS LEVELS *** REGRESSION EQUATIONS *** PUT UNITS- ENGLISH , OUTPUT UNITS- ENGLISH ) SAN JOAQUIN T.C.: NOISE ANAYLSIS CONVENTIONAL 6-7PM (R20.CON) PROGRAM INITIALIZATION PARAMETERS HEIGHT CODE DESCRIPTION .00 1 RECEIVER HEIGHT ADJUSTMENT 1.00 2 A -WEIGHTED SOUND LEVEL ONLY .00 3 HEIGHT ADJUSTMENT FOR PASSENGER CARS (CARS) 8.00 4 HEIGHT ADJUSTMENT FOR HEAVY TRUCKS (HT) 2.30 5 HEIGHT ADJUSTMENT FOR MEDIUM TRUCKS (MT) ROADWAY 1 RDWY 1 ; 15 NB VEHICLE TYPE VEHICLES/HOUR SPEED CARS 8004. 40. HT 359. 40. MT 837. 40. ------------ COORDINATES ............. X Y Z GRADE PT01 200. 580. 217. 0 #PT4 850. 1300. 1340. 1720. 224. 235. 0 0 1850. 1980. 2". 0 PT05 2500. 2040. 248. 0 PT06 3500. 2020. 229. 0 PT07 4750. 1820. 229. 0 ROADWAY 2 RDWY 2 ; 15 NB VEHICLE TYPE VEHICLES/HOUR SPEED CARS 5545. 55. HT 238. 55. MT 793. 55. ------------ COORDINATES ------------- X Y Z GRADE PT07 4750. 1820. 229. 0 PTA 6500. 1480. 240. 0 PT7B 7300. 1370. 240. 0 PT7C 8280. 13.40. 240. 0 ROADWAY 3 RDWY 3 ; 15 SB • VEHICLE TYPE VEHICLES/HOUR SPEED CARS 8526. 40. HT 382. 40. MT 892. 40. ------------ COORDINATES--'---------- X Y Z GRADE PT08 4750. 1920. 229. 0 PT09 3500. 2140. 229. 0 PT10 2500. 2180. 248. 0 PT11 1850. 2100. 244. 0 PT12 1300. 1850. 235. 0 PT13 850. 1500. 224. 0 PT14 200. 740. 217. 0 ROADWAY 4 RDWY 4 ; I5 SB VEHICLE TYPE VEHICLES/HOUR SPEED CARS 5742. 55. HT 257. 55. MT 601. 55. ------------ COORDINATES ------------- X Y Z GRADE PT8AA 8300. 1440. 240. 0 PT8A 7300. 1470. 240. 0 PT88 6520. 1580. 240. 0 PT08 4750. 1920. 229. 0 ROADWAY 5 RDWY 5 ; SJ NB VEHICLE TYPE VEHICLES/HOUR SPEED CARS 3100. 55. HT 90. 55. MT 220. 55. ------------ COORDINATES ------------- X Y Z GRADE PT7 4750. 1820. 229. 1 S1 4980. - 1680. 220. 1 S2 5500. 1670. 242. 1 S3A 6950. 1950. 304. 1 S3 7440. 2050. 300. 1 S3B 8750. 2330. 300. 0 S3BB 9000. 2370. 300. 0 ROADWAY 6 RDWY 6 ; SJ SB VEHICLE TYPE VEHICLES/HOUR SPEED CARS 3500. 55. HT 110. 55. MT 240. 55. ------------ COORDINATES ------------- X Y Z GRADE S48B 9000. 2500. 300. 0 S48 8740. 2410. 300. 0 S4 7420. 2160. 300. 0 S4A 6950. 2080. 294. 0 S5 5960. 1870. 271. 0 S6 5630. 1860. 262. 0 S7 5310. 1880. 250. 0 • • S8 5100. 1920. 228. 0 PT08 4750. 1920. 229. 0 WY 7 RDWY 7 ; PASEO DE COLINAS WS VEHICLE TYPE VEHICLESAOUR SPEED CARS 819. 30. HT 24. 30. MT 57. 30. ------------ COORDINATES ------------- X Y 2 GRADE P1 7770. 1500. 265. 0 P2 7600. 2120. 268. 0 P3 7620. 2350. 282. 0 P4 7800. 2740. 299. 0 ROADWAY 8 RDWY 8 ; PASEO DE COLINAS ES VEHICLE TYPE VEHICLES/HOUR SPEED CARS 637. 30. HT 19. 30. MT 44. 30. ------------ COORDINATES ------------- X Y Z GRADE Pb 7760. 2780. 299. .0 7570. 2350. 282. 0 Pr 7570. 2120. 268. 0 P8 7750. 1500. 265. 0 RECEPTOR CO-ORDINATES ------------ COORDINATES ------------- X Y Z R20 7480. 2270. 280. 8*0.5 SHIELDING FACTORS - ROADWAY ACROSS,RECEIVER DOWN 8*0.0 SAN JOAQUIN T.C.: NOISE ANAYLSIS CONVENTIONAL 6-7PM (R20.CON) **** ORANGE 35 ROADS 300 RECP **** RECEIVER LEQ(H) SIG L10 L50 L90 R20 74.1 2.1 76.2 73.6 71.0 SAN JOAQUIN T.C.: NOISE ANALYSIS OPTIMISTIC 6-7PM (R20A.DAT) ii RDIS C: STAMINA 2.0/BCR FHWA VERSION (MARCH 1982) TRAFFIC NOISE PREDICTION MODEL DEVELOPED UNDER CONTRACT BY BBN MODIFIED FOR CALIFORNIA VEHICLE NOISE EMISSIONS LEVELS *** REGRESSION EQUATIONS *** PUT UNITS- ENGLISH , OUTPUT UNITS- ENGLISH ) SAN JOAQUIN T.C.: NOISE ANALYSIS OPTIMISTIC 6-7PM (R20A.DAT) PROGRAM INITIALIZATION PARAMETERS HEIGHT CODE DESCRIPTION .00 1 RECEIVER HEIGHT ADJUSTMENT 1.00 2 A -WEIGHTED SOUND LEVEL ONLY .00 3 HEIGHT ADJUSTMENT FOR PASSENGER CARS (CARS) 8.00 4 HEIGHT ADJUSTMENT FOR HEAVY TRUCKS (HT) 2.30 5 HEIGHT ADJUSTMENT FOR MEDIUM TRUCKS (MT) ROADWAY 1 RDWY 1 ; I5 ES BEFORE RAMP TO PASEO DE COLINAS VEHICLE TYPE VEHICLES/HOUR SPEED CARS 8004. 40. HT 359. 40. MT 837. 40. ------------ COORDINATES ------------- X Y Z GRADE PT01 1900. -301. 228. 0 PlQ2 1980. 500. 232. 0 ROADWAY 2 RDWY 2 ;• I5 EB AFTER RAMP TO PASEO DE COLINAS VEHICLE TYPE VEHICLES/HOUR SPEED CARS 5545. 55.- HT 238. 55. MT 793. 55. ------------ COORDINATES ------------- X Y Z GRADE PT02 1980. 500. 232. 0 PT03 2190. 2350. 250. 0 PT04 2180. 3650. 257. 0 PT05 2170. 4570. 262. 0 ROADWAY 3 RDWY 3 ; I5 EB AFTER RAMP TO P. DE COL. VEHICLE TYPE VEHICLES/HOUR SPEED CARS 5545. 55. HT 238. 55. MT 793. 55. 1 • ------------ COORDINATES ------------- X Y Z GRADE PT05 2170. 4570. 262. 0 PT06 2080. 5880. 262. 0 ROADWAY 4 RDWY 4 ; 15 WB BEFORE RAMP TO P. DE COL. VEHICLE TYPE VEHICLES/HOUR SPEED • CARS 8526. 40. HT 382. 40. MT 892. 40. ------------ COORDINATES ------------- X Y Z GRADE PT07 1980. 5900. 262. 0 PT08 2040. 4700. 262. 0 ROADWAY 5 RDWY 5 ; I5 WS AFTER THE RAMP TO P. DE COL. VEHICLE TYPE VEHICLES/HOUR SPEED CARS 5742. 55. HT 257. 55. MT 601. 55. ------------ COORDINATES ------------- X Y Z GRADE PT08 2040. 4700. 262. 0 PT09 2090. 2300. 250. 0 PT10 1900. 520. 232. 0 PT11 1830. 200. 232. 0 • ROADWAY 6 RDWY 6 ; IS W8 AFTER THE RAMP FROM P. DE COL. VEHICLE TYPE VEHICLES/HOUR SPEED CARS 5742. 55. HT 257. 55. MT 601. 55. ------------ COORDINATES ------------- X Y Z GRADE PT11 1830. 200. 232. 0 PT12 1780. -300. 228. 0 ROADWAY 7 RDWY 7 ; ES RAMP TO P. DE COL. VEHICLE TYPE VEHICLES/HOUR SPEED CARS 319. 30. HT 9. 30. MT 22. 30. ------------ COORDINATES ------------- X Y Z GRADE PT2 1980. 500. 232. 0 R1 2290. 1800. 230. 0 R2 2330. 2440. 228. 0 ROADWAY 8 RDWY 8 ; EB RAMP FROM P. DE COL. BEFORE S.J. VEHICLE TYPE VEHICLES/HOUR SPEED CARS 956. 30. HT 28. 30. • MT 66. 30. ------------ COORDINATES ------------- X Y 2 GRADE R3 2330. 2480. 228. 0 R4 2380. 3040. 250. 0 ROADWAY 9 RDWY 9 ; ES RAMP FROM P. DE COL. AFTER S.J. VEHICLE TYPE VEHICLES/HOUR SPEED CARS 774. 30. HT .23. 30. MT 54. 30. ------------ COORDINATES ------------- X Y Z GRADE R4 2380. 3040. 250. 0 R5 2360. 3360. 250. 0 R6 2250. 3910. 255. 0 PT5 2170. 4570. 262. 0 ROADWAY 10 RDWY 10; WB RAMP TO P. DE COL. BEFORE S.J. VEHICLE TYPE VEHICLES/HOUR SPEED CARS 1251. 30. HT 37. 30. MT 87. 30. ------------ COORDINATES ------------- X Y Z GRADE PT8 2040. 4700. 262. 0 R7 2010. 4050. 255. 0 R8 1970. 3500. 247. 0 ROADWAY 11 RDWY 11; WS RAMP TO P. DE COL. AFTER S.J. VEHICLE TYPE VEHICLES/HOUR SPEED CARS 1729. 30. HT 51. 30. MT 120. 30. ------------ COORDINATES ------------- X Y 2 GRADE R8 1970. 3500. 247. 0 R9 1990. 2940. 235. 0 R10 1990. 2490. 224. 0 ROADWAY 12 RDWY 12; WB RAMP FROM P.DE COL. VEHICLE TYPE VEHICLES/HOUR SPEED CARS 296. 30. HT 9. 30. MT 20. 30. ------------ COORDINATES ------------- X Y Z GRADE R11 1990. 2450. 224. 0 R12 1990. 2330. 226. 0 R13 1830. 500. 229. 0 PT11 1830. 200. 232. 0 ROADWAY 13 RDWY 13; S.J. NB VEHICLE TYPE VEHICLES/HOUR SPEED CARS 2467. 45. HT 80. 45. MT 170. 45. ------------ COORDINATES ------------- X Y 2 GRADE R4 2380. 3040. 250. 0 PT13 2290. 3530. 267. 0 PT14 2080. 4120. 282. 0 PT15 1770. 4730. 291. 0 PT16 1380. 5200. 310. 0 PT17 1030. 5500. 325. 0 ROADWAY 14 RDWY 14; S.J. SB VEHICLE TYPE VEHICLES/HOUR SPEED CARS 2772. 55. HT 80. 55. MT 190. 55. ------------ COORDINATES ------------- X Y Z GRADE PT18 1080. 5200. 323. 0 PT19 1500. 4700. 286. 0 PT20 1750. 4200. 274. 0 R8 1970. 3500. 247. 0 ROADWAY 15 RDWY 15; PASEO DE COLINAS NB BEFORE RAMP VEHICLE TYPE VEHICLES/HOUR SPEED CARS 637. 30. HT 19. 30. MT 44. 30. ------------ COORDINATES ------------- X Y Z GRADE 01' 2840. 2470. 226. 0 02 2470. 2480. 227. 01 Rl 2330. 2480. 228. 0 ROADWAY 16 RDWY 16; PASEO DE COLINAS BETWEEN RAMPS NO VEHICLE TYPE VEHICLES/HOUR SPEED CARS HT 637. 19. 30. 30. MT 44. 30. ------------ COORDINATES ------------- X Y Z GRADE R3 2330. 2480. 228. 0 R10 1990. 2490. 224. 0 ROADWAY 17 RDWY 17; PASEO DE COLINAS AFTER RAMP NO VEHICLE TYPE VEHICLES/HOUR SPEED CARS 637. 30. HT 19. 30. MT 44. 30. ------------ COORDINATES ------------- X Y 2 GRADE R10 1990. 2490. 224. 0 03 1690. 2490. 250. 0 04 1230. 2660. 280. 0 ROADWAY 18 RDWY 18; PASEO DE COLINAS SO BEFORE RAMP 0 VEHICLE TYPE VEHICLES/HOUR SPEED CARS 819. 30. HT 24. 30. MT 57. 30. ------------ COORDINATES ............. X Y Z GRADE 05 1230. 2620. 280. 0 06 1690. 2450. 250. 0 R11 1990. 2450. 224. 0 ROADWAY 19 RDWY 19; PASEO DE COLINAS SB BET. RAMPS VEHICLE TYPE VEHICLES/HOUR SPEED CARS 819. 30. HT 24. 30. MT 57. 30. ------------ COORDINATES ------------- X Y Z GRADE R11 1990. 2450. 224. 0 R2 2330. 2440. 228. 0 ARO WAY 20 RDWY 20; P. DE COL. AFTER RAMPS SO VEHICLE TYPE VEHICLES/HOUR SPEED CARS 819. 30. HT 24. 30. MT 57. 30. ------------COORDINATES------------- X Y Z GRADE • R2 2330. 2440. 228. 0 07 2470. 2450. 227. 0 08 2840. 2430. 226. 0 RECEPTOR CO-ORDINATES ------------ COORDINATES ------------- X Y 2 R20A-#2 1350. 2500. 280. 20*0.5 SHIELDING FACTORS - ROADWAY ACROSS,RECEIVER DOWN 20*0.0 SAN JOAQUIN T.C.: NOISE ANALYSIS OPTIMISTIC 6-7PM (R20A.DAT) **** ORANGE 35 ROADS 300 RECP **** RECEIVER LEQ(H) SIG L10 L50 L90 R20A-#2 67.6 3.6 70.8 66.1 61.5 0 e • EXHIBIT 5 MYTHS AMD FACTS ABOUT TRAMSPORTATIOM AMD GROWTH 01/31/91(TCA901B%INDEXV-4) 1 o� and FACTS about Transportation and Growth n many of the most desirable areas of the United States, economic growth has become a two-edged sword: the same new jobs that offer employment op- portunities and tax revenues also bring traffic. The inability of many communities to provide adequate facilities has made traffic congestion a leading concern. The problem has been aggravated by a general pullback in federal and state funding, which traditionally has accounted for about three out of every four highway dol- lars, mostly from fuel taxes and other user charges. Clearly, a reduction in such a major revenue source places an almost impossible burden on local governments to fi I I the gap. The question is asked by concerned communities: What is the value of eco- nomic development if (continued) Stopping development will stop traffic growth. The common tendency is to associate all increased traffic with new de- velopment. Even during periods of rapid growth, however, traffic has grown faster than development. The nation's increasing mobility is due to both social and economic changes —growth in the number of jobs, women in the workforce, disposable income, and cars; and a suburbanizing lifestyle that requires more travel than that of its city counterpart. These trends came together during the 1970s as the baby boom generation entered the prime working years. Had this generation been no more auto -oriented than its parents, the amount of driving would have increased only 25 percent. Between 1969 and 1983, total highway travel increased 56 percent —more than three times the growth in overall population, and twice the increase in the number of persons of driving age.z More people were driving and were also more likely to own their own cars. In other words, the average person was driving more: per capita driving increased 17 percent between 1969 and 1983. It is estimated that during the 1970s and early 1980s, growth in population, housing, and employment accounted for about one-third of the . increase in highway travel, while two-thirds was attributed to increased per - capita travel.l Census -data show that even in areas of the United States where the population has declined, employment levels and travel have in- creased. While new development obviously brings new traffic to an area, the growing mobility of the population has a more far-reaching effect on travel growth. FACT 1. Even with no new development, traffic would increase due to the population's growing mobility. Mobility Trends [ FAIRFAX COUNTY, VIRGINIA, TRENDS: 1978-19851 + 77% " PUGET SOUND REGION TRENDS: 1980-19882 M177n; NATIONAL TRENDS:1969-19833 + 43% +55% +56% 38% + 22% %M 1N POPULATION LICENSED VEHICLES VEHICLE DRIVERS MILES 1 Source: Fairfax County Office of Research and Statistics. 2. Source: Seattle TImeslSeattle Post Inlelligencer, "Suburban Crawl," April 16, 1989. 3. Source: U.S. Department of Transportation, Personal Travel in the U.S., Vol I (Washington: D.C.: author. 1986.) �2. Growth is unpredictable and therefore adequate planning is not possible. There is a widespread feeling that growth is occurring in areas where it could not have been anticipated, and therefore could not have been planned for. In fact, the spread of development into more remote suburban and rural areas has rarely come as a surprise. New York City was de- centralizing by the 1850s. During the 1950s, virtually all of the population increase in the largest 27 metropolitan areas occurred in the suburbs. Be- tween 1960 and 1980, two-thirds of the job growth was in the suburbs. In most cases, this growth has been a logical extension of existing market trends. There were early harbingers that such a phase was beginning —a small shopping center, a research laboratory, or the assembly of land. Land speculation has been an early indicator that something was about to hap- pen. But all too often officials were unable, or unwilling, to accept the real- ities of growth and communicate them to the community. The result — growth occurs without the transportation facilities needed to support it. FACT 2. Growth generally is predictable; plans made in advance are essential to cope with it. (21*a Growth in a community primarily serves newcomers. Many attitudes toward growth are shaped by the notion that the houses and office buildings built to serve it are occupied primarily by new resi- dents. Charging newcomers for the facilities needed for growth appeals to elected officials as a means to gain revenue without alienating voters. It can also placate community attitudes by assuring existing residents that newcomers are paying their fair share. But how can a "new" resident or worker in an area be identified? Contrary to the usual assumption that any- one who moves to a new home or works in a new office building is a new- comer, a large share of new housing and office space is purchased or leased by existing members of the community. A 1988 national survey of new homebuyers found that half of them —ranging from 41 percent in the Northeast to 60 percent in the West —already lived in the county where they purchased their new homeS.3 U.S. Census Bureau statistics show similar trends for all household moves. In many communities, most of the growth is due to natural increases in the existing population. FACT . 3 Much of the development in growing areas is needed to serve existing residents, not people moving in. Prior Residence of New Homebuyers NORTHEAST 1 NORTH CENTRAL SOUTH WEST SAME STATE. DIFFERENT COUNTY DIFFERENT STATE Source: See Note 3 for text. Prior Residence of All Movers: 1975-1980 DIFFERENT STATE 25% SAME STATE. DIFFERENT COUNTY 21% SAME COUNTY ` 54% Source: 1980 U.S. Census, City and County Data Book (Washington, D.C.: U.S. Department of Commerce, 1983). C 4 y W 2 za W a o 2 0 -U-1 1 W W , -J y G.1 W ' 4 LA. 1 LU W W Son W O C O W r 4 W rL Trip Generation Rates for Office Buildings 200,000 400,000 600,000 800,000 GROSS SQUARE FEET OF BUILDING Source: Institute of Transportation Engineers, Trip Generation, 4th edition (Washington, O.C.. author, 1987). Residential Trip Generation Rates 13 12 11 10 9 x cm 8 z _, 7 W 3 6 a ac W n 5 H a. tZ ►- 4 3 2 1 0 u 014W�211414. Reducing densities will reduce traffic. Reducing the density of development through zoning may seem like one way to reduce traffic. Obviously, a three-story building on a site will gener- ate fewer trips than eight stories of the same floor plan. But traffic does not respect boundaries, and such a policy, while limiting traffic at individual sites, causes sprawl —a low -density, auto -dependent development pattern. Thus, a reduction in traffic in one area is likely to be matched by traffic in- creases elsewhere —unless density is reduced over an area so extensive that it decreases the total level of market development. In addition, re- search shows that higher -density residential and office projects generate fewer driving trips and more transit use per unit than do low -density proj- ects.4 (Density is necessary to provide the critical mass needed to support transit.) Moreover, clustering uses in mixed -use centers makes possible a pedestrian orientation, with shopping, services, restaurants, and recreation within walking distance. FACT .4. Limiting density of development does not reduce traffic except in the immediate area. Lower -density residential, retail, or office projects generate more, not less, overall traffic. 15 20 25 DWELLING UNITS PER ACRE 35 40 45 Source: 1964-1970 Research Studies, California Division of Highways, District 4. oxlyr� s. Urban transportation's major challenge is improving commuting to downtown jobs. According to the 1980 U.S. Census, there were twice as many subur- banites commuting to suburban jobs in metropolitan areas as there were to jobs in the central cities. Between 1960 and 1980, intrasuburban commut- ing accounted for 57 percent of the increase in metropolitan commuting.5 Although the downtowns of our major cities are generally the most impor- tant single destination, they no longer are the dominant location for jobs; less than 8 percent of regional workers —ranging from 3 percent in Los Angeles to 10.9 percent in San Francisco —are employed in the 10 largest urbanized areas.B The new transportation challenge is how to meet the diverse needs of suburban destinations. In addition, nonwork trips are be- coming a larger share of travel. In 1983, the number of miles traveled to earn a living, including work -related business, was only 27 percent of daily travel in metropolitan areas.? Moreover, during rush hours in large regions, much of the growth in auto traffic has been for nonwork trips. By 1983, it was estimated that in urban areas of at least 3 million people, travel on the roads during the evening rush hour was almost evenly divided between commuting and nonwork trips. For a typical area, the central business dis- trict commuter probably represents less than 10 percent of all highway trav- elers during the heaviest rush hour. FACT s. P. most growing areas, a diversity of transportation needs —dispersed suburban employment, reverse commutation, and nonwork travel —are as important, if not more important, than the problem of downtown commutation. Where Commuter Growth Occurred: 1960-1980 4.50 Z OVER 3 MILLION 1-3 MILLION Relative Sizes of Main Flow Markets for Commuting: 1960-1980 2 CENTRAL CITY CENTRAL CITY SUBURBS TO SUBURBS TO TO CENTRAL CITY To SUBURBS CENTRAL CITY SUBURBS Shares of the Total Increase in Commuters by Market: 1960-1980 CENTRAL( CENTRAL( 9% 9% Source: Alan E Pisarski, Commutingin America (Westport, Connecticut: ENO Foundation for Transportation, Inc., 1987). Weekday Auto Travel in Regions with More Than 3 Million Population: 1983-1984 DOWNTOWN WORK TRAVEL ■ WORK TRAVEL Source: Compiled from 1983 Nationwide Personal Transportation Study data, U.S. Department of Transportation; Peter Gordon, Aiay Kumar, and Harry Richardson, "Peak Spreading: How Much," unpublished.paper, University of Southern California, 1988; ULI estimates, assuming 10 percent of employment in central business district 0 CENTRAL CITY TO CENTRAL CITY CENTRAL CITY TO SUBURBS CENTRAL CITY TO OUTSIDE SMSA 3 SUBURBS TO CENTRAL CITY SUBURBS TO SUBURBS SUBURBS TO OUTSIDE SMSA .5-1 MILLION .25—.5 MILLION .1—.25 MILLION AREA POPULATION Source: Alan E. Pisarski, Commuting in America (Westport, Connecticut: ENO Foundation for Transportation, Inc., 1984 (21*9 Suburbanites will not ride buses. Many local officials believe that suburbanites will not ride buses be- cause they consider them slow, unreliable, and designed primarily for poor central city residents. This myth is used frequently to justify new rail sys- tems, which are thought to cater to a higher -income, more mobile subur- ban market. In fact, an analysis of national data for 1983 found that there were as many bus riders with annual household incomes over $30,000 a year as there were riders with incomes below the poverty level of $10,000. Moreover, between 1970 and 1980, while the number of suburban resi- dents working in cities increased by 55 percent, transit maintained its share (the only market in which it did so) at slightly over 11 percent8 Since most of the growth in suburban -to -city commuting was in western and southern cities served exclusively by bus transit, suburbanites clearly will ride the bus where good service is provided. What about high -growth cities? The most striking examples are five cities in the West —Portland, Denver, Sacramento, Los Angeles, and Phoe- nix —in which, during the 1970s, the number of transit commuters more than doubled as a result of substantial transit investment combined with fast-growing commuter markets. (See graph.) An excellent way to provide high-speed suburban transit service with buses is through exclusive bus - ways on freeways. Some of the more successful of these projects bring suburbanites into downtown New York, San Francisco, and Washington, D.C.8 Each of these facilities carries over 50,000 daily riders —more than the new light rail systems opened during the 1980s. FACT s. Suburbanites will ride buses when the service is reasonably fast and convenient. Change in Transit Share for Cities with Greater Than 100 Percent Growth in Transit Commuting: 1970-1980 20% 1910 51980 o� 10% 83% 61% ~ iff 42% 38% qZ% 50% 2 m t Z=IA 0% PORMND DENVER SACRAMENTO LOS ANGELES PHOENIX TRANSIT MARKETS Source: U.S. Department of Transportation, Journey to Work Trends. Based on 1960, 1970, and 1980 Decennial Censuses (Washington, D.C.. author), pp. 6-11. Trends in Relative Transit Use Home -to -Work Travel: 1970-1980 \ CENTRAL CITY TU CENTRAL CITY SUBURBS to CENTRAL CITY CENTRAL CITY TO Source: U.S. Department of Transportation, SUBURBSSUMS The Status of the Nation's Loral Mass SUB RI 10 Transportation: Performance and Conditions, IT report to Congress, data redrawn from Figure 3-1 (Washington, D.C.: author, 1988). Overall, new rail transit systems are needed to reduce traffic congestion. It is believed that in high -growth areas with low levels of transit ridership, major capital investments in new rail systems will reduce driving substantially. Newly emerging cities in the South and West believe they can build rail systems that will serve their downtowns and focus development in the same way that those of New York, Boston, Chicago, and Philadel- phia have done. But the facts indicate otherwise. Even in San Francisco and Washington, which seemed to be logical candidates for subways, the systems that opened in the 1970s have had mixed success. Both systems have played important roles in serving their downtowns, although less sig- nificant than hoped by their planners. In both regions, however, most of the job growth has been in the suburbs, where a rail system cannot compete with the car. Therefore, neither system has been able to increase the overall percentage of commuters using public transportation, and the traffic prob- lems in the suburbs of each city have become legendary. Where does rail transit work? An intensive study of criteria for new tran- sit systems found that the travel volumes needed to justify fixed guideway systems are: dense residential corridors, high levels of downtown employ- ment and low levels of car ownership.9 Many of the newer Sunbelt cities considering rail systems fill none of these criteria. Although that study found that 10 cities had a potential for new light rail systems, a 1988 Ur- ban Mass Transportation Administration (UMTA) report identified nine other cities with systems in the planning stages that did not meet the ini- tial criteria.8 Moreover, the light rail solution has been proposed in many other cities that have not begun formal systems planning studies. While these cities clearly are concerned about congestion, this particular option is diverting attention from more effective solutions. FACT 7. Rail transit works best in high -density cities that already have it. It is an expensive and ineffectual way to reduce congestion in a city that does not develop around rail transit. Trends in Urban Transit fixed Assets and Passenger Trips 320 —FIXED ASSETS 280 — PASSENGER TRIPS 0 240 r n 200 160 120 80 1960 1965 19170 1975 1980 Source: National Council on Public Works Improvement, fragile foundations: A Report on Americas Public Works (Washington, D.C.: author, 1988). 01/*98. roads should not be built, because they only fill up with traffic. A prevailing belief is that a new road that attracts a large volume of traf- fic has not been a good investment because it generates increased travel without relieving existing facilities. The weakness of this argument be- comes clear if it is applied, say, to new schools (they just fill up with stu- dents) or libraries (they only fill up with books). The fact that a new high- way is well used demonstrates its success in offering a shorter or cheaper route for users; or access to new markets for industry; or better job, hous- ing, or shopping opportunities for travelers. Not surprisingly, a new road in a congested area will attract traffic, especially when there has been little new construction. Attracting traffic and relieving other facilities are exactly what it was supposed to do. The Federal Highway Administration has cal- culated that each $1 invested in improving the interstate highway system saves $5 in costs to users —a substantial economic benefit.10 Clearly, great economic value is attached to highway improvements. Many also believe that new roads encourage growth, opening up areas to unintended development. Certainly, that is a possibility and must be dealt with according to the specific situation. An extensive number of high- way impact studies was compiled in 1976 and summarized to show not only some of the traffic benefits, but also the economic and social advan- tages of highway improvements." Perhaps the most comprehensive lesson an be gained from a look at the U.S. interstate highway system —funded through the Highway Trust Fund established in 1956—which now carries one -fifth of all highway travel in the United States. It was not until 1982 that one-half of the urban interstate travel had begun to occur on roads 1r-ated as congested during peak hours. As the standard period for design is E years, the planners of the interstate highway system were generally "in the ball park." Moreover, the latest federal highway statistics show that out of 11,200 miles of interstate roads in urban areas, only 5,200 experienced traffic volumes greater than 70 percent of capacity during peak hours.12 With many areas struggling with the problem of congested traffic arteries, the argument that building new roads is not part of the solution makes no sense. FACT a. Highway improvements are essential to a balanced regional transportation system. Their use is an indication of the need for them, not a sign of their failure. Congestion* Based on Percentage of Total Miles 30 1975 L'SJ 26 1978 Z 22 U. 1g 01981 tu 14 01983 W 10 fflu 6 . 2 INTERSTATE ARTERIALS COLLECTORS Congestion* Based on Percentage of Total Travel 60 UA 50 1 40 U. 30 '�- 20 LU s 10 f< d a.; 0 INTERSTATE ARTERIALS COLLECTORS 'Congestion=Vehicle-to-rapacity ratio greater than 0.80 during peak periods. Soufoe: U.S. Department of Transportation, The Status of the Nation's Highways: Conditions and Performance, report to Congress (Washington. D.C.: author, 1987). ! //�, 9. Highways can no longer be built in urban areas. This myth is sometimes related to Myth 8, and is subscribed to by many highway critics as well as some transportation professionals. People believe that the problems involved in building metropolitan highways are insurmountable. In addition to the normal difficulties encountered in build- ing highways in established areas, today's engineers must cope with re- sentment over past projects that were insensitive to the surrounding com- munity. This myth has spread to the suburbs as well, even affecting areas where roads have been planned and rights -of -way have long been set aside. A general decline in funding nationwide, the cost of land and con- struction, and growing sensitivity to environmental and community impacts will continue to rule out highway improvements in many areas. But the facts demonstrate that highways are still being built, even though they may require substantially more effort than in the past. Recent experience shows cases in which highway improvements have overcome considerable opposition, as well as those for which there was significant support. The most difficult facility to build is a downtown freeway, as illustrated by the defeat of the controversial Westway project in Manhattan. Nonethe- less, there are cities that have overcome considerable political and finan- cial problems to build highway projects even in built up areas —typically as part of the interstate system. These include Boston with the $3.5 billion reconstruction of the Central Artery, and Los Angeles with the $1.8 billion construction of the Century Freeway. Such projects are expensive and con- troversial, but while there are differences of opinion about whether they make sense, they demonstrate that given sufficient political support and money, they still can be built. In Phoenix, citizen attitudes toward freeways have changed as the diffi- culty of accommodating growth almost entirely on an arterial highway net- work has become apparent. As a result, voters have approved a sales tax increase in order to build a 233-mile freeway system with the $5.8 billion the increase will produce. In Orange County, California, private initiative has combined with changes in state legislation to create three new toll road corridors that are planning to spend $2 billion —almost half of it from development fees. Plans for a similar project in Denver are to build E-470 as a toll road, with substantial contributions of land and fees from the private sector. In suburban or fringe locations, where land is cheaper, impacts less damaging, existing highways primarily two-lane roads, and political senti- ment considerably more favorable, highways can still be built. Perhaps the most troubling aspect of this particular myth is that it can easily become a self-fulfilling prophesy. FACT 9. New roads can, and are, being built in urban areas all over the United States. 10. People must change their attitudes so that they depend less on the automobile. Frequently expressed is the opinion that much of the problem in resolv- ing traffic congestion is due to America's fixation with the car. If it were possible to change this attitude, it is argued, it would be possible to change travel behavior, making people more willing to carpool, ride buses, or walk to work. In fact, transportation analysts have recognized that consumer choices are made based on rational comparisons of time and cost, rather than on abstract values or attitudes. (See graph on next page.) Thus, calling on cit- izens to reduce their driving and conserve oil imports as their patriotic duty has little effect. But raising the price of gas will quickly encourage them to consider measures of conservation. A survey of commuters who drive alone in highly congested Silicon Valley found that, contrary to be- liefs, fewer than one in 10 were —that is, described themselves as —die- hard car lovers. The remainder drove because they needed their cars —for picking up children, for work -related or personal business, or because of problems with the alternatives (the bus takes too long, carpools are diffi- cult because of different schedules or other problems). When asked how they coped with growing congestion, most commuters said that they tried to avoid travel during rush hours and that they changed routes to avoid congestion.13 A similar approach was reported in New Jersey, where four out of 10 commuters said they had changed their time of travel —many by 30 minutes or more.14 In both cases, however, a sizable share of commut- ers was willing to consider alternatives. FACT 10: Commuters' choices are based on comparisons of cost and convenience, not on abstract values. It is not attitudes that must be changed, but the relative service and cost of options offered to commuters. Selected Surveys of Solo Drivers Willing to Consider Alternatives PERCENTAGE OF DRIVERS WILLING TO CONSIDER: RIDESHARING VANPOOLING TRANSIT New Jersey (urban)' 54% 63% N/A San Jose, CA2 54% 68% Connecticut3 32% Through neighbor or coworker 63%4 Through employer 43%4 'Eagleson Institute for Politics, The Crowded Road: A Survey of New Jerselans' Opinions about Transportation, Growth, and Development (New Brunswick: New Jersey: State University of New Jersey, 1988). 2Crain and Associates, Santa Clara County Solo Driver Commuters: A Markel Research Study (Los Altos, California: author, 1984). 3Mount Vernon Research Associates, State of Connecticut Statewide Transportation Sludy: Public Opinion Research Executive Summary, for Connecticut Department of Transportation and Creamer Dickson Basford, Inc. (Wethersfield, CorineciCut aulfwr,198% 'Combined ndesharkng and vanpooling. Relative Importance of Different factors in Choice of San Francisco Bay Area Commuting — Auto, Bus, or BART: 1977 FACTORS DETERMINING COMMUTERS' CHOICE BART ■ COST -OVER AUTO1.2 TIME .I CONVENIENCE DEPENDABILITY" TRANSFER TIME BART -OVER BUSS AUTO -OVER BART4 - �•� BUS -OVER BART5.6 0 MOST IMPORTANT FACTOR = 100% 100 PRIMARY REASONS FOR CHOICES 'LOWER COST OF A BART TRIP 2CAN AVOID DRIVING IN TRAFFIC AND ELIMINATE PARKING PROBLEMS 3TRAVEL TIME SAVINGS 4CONVENIENCE AND TIME SAVINGS 5CHEAPER 6GREATER DEPENDABILITY OF BUS that during this survey period, BART was not operating at its full service level. Since then, I eqM Y of trains, the operating speeds, and the reliability and capacity have been im- subsmrNially Sonia: Metropolitan Transportation Commission, BART in the San Francisco Bay Ams: The Finai Report of One BART #row ftram, for the U.S. Department of Tmnsportaton, Washing- ton, D.C., 1979. We should not make capital investments because they will be outmoded by new technology. The hope is that a technological "fix" will some day offer a more conve- nient, less environmentally damaging alternative to urban travel than to- day's mix of cars, buses, and trains. But for now, no such fix appears to be on the horizon. A recent National Research Council study concluded that the primary means of transportation, at least until the year 2020, will con- tinue to be private vehicles and buses.15 Research is underway to develop advanced technology to make the vehicle, highway, and operator more effi- cient. Like most new technologies, however, this one will likely be intro- duced incrementally —for example, by converting an existing facility or by gradually expanding the system. Although telecommunications and home offices will allow more people to work at home and avoid commuting, this option is not likely to affect more than a small percentage of travelers. In fact, between 1960 and 1980, changing patterns of work have resulted in a decline of 2.4 million people who regularly work at home. These changes have been caused by a migration of jobs to the suburbs, where walking is much less likely; and a decline in farming, an ideal walk -to -work occupation.5 FACT 11. Transportation options for the near future will be much like those available today. We should continue to work with these options while seeking better technologies for the more distant future. Notes This booklet was prepared under the auspices of ULI's Growth Problems Task Force, whose members are: 'Trends in driver licensing and components of travel from ULI analysis of data from U.S. Department of Transportation, Federal Highway Administration, Personal Travel in the United States: A Report on findings from the 1963-1964 Nationwide Personal Transportation Study (Washington, D.C.: U.S. Department of Transportation, 1986). 2U.S. Department of Transportation, Federal Highway Administration, Highway Statistics: 1969 and Highway Statistics: 1981, Table VM-1 (Washington, D.C.: author,1969, 1981). 3National Association of Home Builders, What Home Buyers Want, special survey tabulations (Washington, D.C.: author, 1989). ^Institute of Transportation Engineers, Trip Generation, 4th edition (Washington, D.C.: author, 1987), pp. 887, 1,151. 5Alan E. Pisarski, Commuting in America: A National Report on Commuting Patterns and Trends (Westport, Connecticut: Eno Foundation for Transportation, Inc., 1987). 6Peter Gordon, Ajay Kumar, and Harry Richardson, "Congestion, Changing Metropolitan Structure, and City Size," International Regional Science Review (Morgantown, W. Virginia: University of W. Virginia, forthcoming). 7U.S. Department of Transportation, Personal Travel in the U.S.: Vol.1 (Washington, D.C.: author, 1986). 8U.S. Department of Transportation, Urban Mass Transportation Administration, The Status of the Nations Local Mass Transportation: Performance and Conditions, report to Congress (Washington, D.C.: author, 1988). 98oris Pushkarev and Jeffrey Zupan, Urban Rail in America: An Exploration of Criteria for fixed Guideway Transit, for U.S. Department of Transportation, Urban Mass Transportation Administration (Washington, D.C.: U.S. Department of Transportation,1980). t0American Association of State Highway and Transportation Officials, Keeping America Moving: The Bottom Line (Washington, D.C.: author, 1989). "U.S. Department of Transportation, Social and Economic Effects of Highways (Washington, D.C.: author, 1976). 12U.S. Department of Transportation, Federal Highway Administration, Highway Statistics: 1977, Table HM-61 (Washington, D.C.: author, 1977). 13Crain and Associates, Santa Clara County Solo Driver Commuters: A Market Research Study (Los Altos, California: author, 1984). 14Eagleton Institute for Politics, The Crowded Road: A Survey of New Jerseyans' Opinions about Transportation, Growth, and Development (New Brunswick, New Jersey: State University of New Jersey, 1988). 157ransportation Research Board, A Look Ahead. Year 2020 (Washington, D.C.: author, 1988). Thomas Hodges Greenbelt Companies Little Rock, Arkansas Ranne P. Warner President Centros Properties USA, Inc. Boston, Massachusetts Byron R. Koste President Westinghouse Communities of Naples, Inc. Naples, Florida Ed Henson Henson -Williams Realty, Inc. Tulsa, Oklahoma Richard Ortwein Division President The Koll Company Newport Beach, California George Nolte, Jr. President Nolte & Associates San Jose, California Pike Oliver Eldorado Hills Communities Eldorado Hills, California Susan Giles Arthur Young Corp. Citicorp Center San Francisco, California William Eager TDA, Inc. Seattle, Washington James DeFrancia President Lowe Enterprises Sterling, Virginia About ULI—the Urban Land Institute ULI—the Urban Land Institute is an independent, nonprofit research and educational organization incorporated in 1936 to improve the quality and standards of land use and development. The Institute is committed to conducting practical research in the vari- ous fields of real estate knowledge; identifying and interpreting land use trends in relation to the changing economic, social, and civic needs of the people; and disseminating pertinent information leading to orderly and more efficient use and development of land. ULI receives its financial support from membership dues, sale of pub- lications, and contributions for research and panel services. David E. Stahl Executive Vice President ULI Proiect Staff Frank H. Spink, Jr. Staff Vice President, Publications J. Thomas Black Staff Vice President, Research Robert T. Dunphy Director of Transportation Research and Project Director Nancy H. Stewart Managing Editor M. Elizabeth VanBuskirk Art Director Diann Stanley -Austin Production Manager ULI Catalog Number M31 ISBN 0-87420-690-1 Copyright 1989 by ULPhe Urban Land Institute, 1090 Vermont Avenue, N.W. Washington, D.C. 20005