donna l ague comments

8/8/2019 Donna l Ague Comments

1/10

1 of 10

TO: California Department of Transportation (CalTrans) [email protected]

FROM: Donna Lague, 2020 Woodmoss Court, Encinitas, CA

RE: Comments relating to the Interstate 5 North Coast Corridor Draft EnvironmentalImpact Report/Environmental Impact Statement

DATE: November 22, 2010

The following are my comments and questions regarding the Interstate 5 North CoastCorridor Draft Environmental Impact Report/Environmental Impact Statement. In additionto my Overview I am including 30 of my detailed questions relating to Draft EIR.

OVERVIEW:I find the Draft EIR deficient in several areas. I have three main areas of concern:

My main concern is that there is no analysis of Mitigation Measures to reduce theamount of traffic on I-5 within in the project area, as well as coming into theproject area from the North, South and East. The only project alternativesexamined were all build out for projected vehicle traffic with total disregard toPublic Transportation Options and effects. Public Transportation Options would

decrease the amount of ADT on the !-5 North Coast Corridor thus reducing theneed for a project scale of that proposed in the Draft EIR of !-5 North Coast

Other areas of the state have incorporated Public Transportation Options into theirFreeways, such as the Metro Gold Line connecting the Pasadena to Los Angels.

Why was a similar Public Transportation System not included in the analysis ofthis project?

This is a pivotal moment for San Diego County. The I-5 North Coast Corridor, theI-805 Mid Corridor and sections of !-i8 all have proposed CalTrans expansionplans being developed, studied and approved. It is fool hardy of us to let thisopportunity for an integrated transportation plan slip away.

Were considerations for Public Transport and accommodations for PublicTransport omitted from all three projects?

My second area of concern is the validity of the SANDAG ADT Data projected fromyears prior to the increase in gasoline prices and prior to the housing crisis that

have both caused reduced traffic and changes in traffic patterns.

How do the SANDAG project ADT 2010 compare with actual 2010 ADT? How havethese impacts effected ADT projections beyond 2010?


2/10

2 of 10

Due to the questions about the underlying data on which this project was basedand the omission of critical data needed for completing the EIR, I believe that the

Draft EIR for the to Interstate 5 North Coast Corridor needs to be amended,updated, completed and reissued for Public Comment.

Specific Draft EIR Comments & Questions:

Wheres Waldo? The Traffic Data, what is there and what is missing?

There is little information in the Draft EIR Summary or the I-5 NCC Traffic Reports or theI-5 NCC Traffic Technical Report No. 5 that explains how 2030 projections werederived.

SANDAG uses a regional transportation model to produce highway and transitforecasts for individual forecast years between 2003 and 2030. These forecasts areupdated periodically to incorporate the most recent planning assumptions. Trafficforecasts shown here were completed in October 2007 in sup

Forecasts differ from the TFIC Series 10, which was based on the RegionalTransportation Plan (RTP) adopted in 2003 and Series 10 growth forecasts.

Question 1a, b, c and d

How were these number derived and updated?

What data were used in these projections?What agency(s) provided these data?What recent planning assumptions were used in the projections?

Question 2 a & b

The Summary Draft EIR repeatedly calls 2006 the Existing Conditions while in

the Traffic Technical Report No. 5 and the I-5 Traffic Reports refer Existing Dataas 2005. And then again there are references to the measured data being from2003. Please clarify.What real-time data were used for the ADT numbers presented in the report?

How do these data relate to existing 2010 traffic patterns?

Question 3 Request for clarification

Different parts of the EIR Traffic Data use different years for characterizing the

baseline conditions of the I-5 NCC as a basis for analysis and projection. TheDraft EIR (not the supporting reports) should clarify, amended or delete the termExisting so as to eliminate the confusions caused by referring to Traffic Data from2003, 2004, 2006, 2007 as all being Existing conditions. Especially as it relatesto the Traffic Data, that defined the need for the scale of the I-5 NCC Project, it is

important for a reviewer of the Draft EIR to understand the basis for the Trafficanalysis and projections.


3/10

3 of 10

Question 4a & b

Projecting traffic data is not a linear growth from baseline traffic conditions.Especially in this last decade, the influences on traffic growth have beenextremely varied and at times have caused a decrease in traffic volumes alongthe I-5 NCC impact zone. The baseline data, traffic pattern changes, growth

assumptions, and economic and energy influences significantly impact the trafficin the NCC zone of influence.

Where are the baseline data, traffic pattern changes, growth assumptions, andeconomic and energy influences clearly described?

How were the projections from these data calculated and where are theeassumptions and calculations described in sufficient detail for review by localgovernments and concerned citizens?

Question 5

Since 2003, 2005 and 2006 there have seen significant increases in gasolineprices with an associated decrease in traffic levels. Currently, we are in a difficulteconomic climate with as associated reduction in travel. Construction, businessoperations and retail traffic have decreased. We have a significant inventory ofunoccupied housing, The expected impact on slowing housing development isprojected to last as much as 10 years. This in turn will dampen the growth post

2020 as compared to projections made only a few years ago.

Traffic projections performed for many areas of the County without incorporatingthese influences on traffic are questionable. How have these global, statewideand local influences effected the SANDAG traffic projections for 2010 and goingforward?

Question 6

Several North County Coastal cities are coming up for a review of their respectiveGeneral Plans.Do the SANDAG Traffic Data reflect the prevailing opinions of these cites as itrelates to controlling populations growth, changes in traffic patterns and how itwill effect ADT?

A picture is worth a 1000 words Where is all this traffic coming from?

The I-5 NCC EIR speaks to the traffic data projections and estimates in very general

ways.

The project area has recurrent traffic congestion affected by population growth,increased goods movement, and economic growth in the region.


4/10

4 of 10

What appears to not be presented in the Draft EIR is that a much more significant

impact on the ADT of I-5 is the traffic entering the Corridor from the outside, i.e. OutsideSan Diego County, from I-805 and from I-15 via Route 56.

In order to more clearly represent these outside influence please see Figure 1. Thegraph of 2006 ADT shows that the basic traffic levels on all segments of the NCC are

greater than 156,000 ADT. The graph of the Projected No Build ADT shows that trafficlevel on all segments of the NCC are greater than 246,000 ADT. To obtain the dataused to plot the Non-Pass Through ADT it was necessary to extrapolate this information

from the limited data provided in the Draft EIR. The data in the report projects that in2030 the ADT for the I-5 segment Mission Ave to R 76 will be almost 250,000 ADT.Clearly this is not traffic just coming from or going to Mission Avenue, R 76 or CampPendleton. Clearly these number show that the most significant influence to the ADT onI-5 is generated outside the North Coast Corridor. AAA and similar sources reportreduced discretionary travel, also there is a reduction in business and goods movementin all areas effecting I-5.


5/10

5 of 10

Figure 1. ADT Data for Existing, No Build 2030 and Approximated Data RegardingTraffic Generated Inside the North Coast Corridor. The lowest plot on the graphrepresents the underlying or thru-traffic on 1-5. This is apparently traffic generated

outside the project area.

Note that ADT levels at SR-78 are higher that at Palomar Road indicating thatconsiderable traffic is exiting in Carlsbad, an argument for local Public Transportation.The ADT volumes increase slightly all the way to Via de la Valle and then jump due to

the traffic associated with the higher density housing east of I-5, Carmel Valley andtraffic from Highway 56.

No Mitigation or Energy Reductions Measures were proposed for any ADT in any

scenario.


6/10

6 of 10

Question 7

The question must be asked were these new economic realities reflected in theSANDAG 2030 Traffic Data for vehicles originating outside the I-5 NCC?

Question 8

Mentioned in the Draft EIR is the double track rail system being developed for theNCC. For what purpose is the double track rail system being developed?

Question 9

If the double track rail system is being developed for increased Coaster servicedid the NCC Projections for 2030 reflect the decrease in traffic due to thisincreased Public Transportation Option?

Question 10

Did the ADT Projections for 2030 reflect the proposed improved Public

Transportation being discussed for transport between San Diego and LosAngeles, in particular the LOSSAN Rail Improvements (double tracking of railcorridor between Los Angeles and San Diego?

We cannot build this project in a vacuum

Looking at the ADT for the 2030 No Build Scenario the data show that there are going tobe more than 160,000 additional ADT on the I-5 to I-805 road segment. While the ADTat this Interchange will not be at 2030 levels at build out, Ii appears that we will have tobuild these two corridor projects together in order to not significantly adversely impacttraffic flow from Oceanside to Fashion Valley. These two projects are so co-dependent

that we will have to build some of simultaneously in order not to create a horrendoustraffic standstill. What is the impact of this joint construction? Or is CalTrans proposing atemporary transition solution?

Question 11

What mitigation measures will be in place to cope with the I-5 to I-805 increasedtraffic burden?

The geographic area examined in the traffic impact assessment will include all localroadway segments and intersections where the proposed project will add 50 or morepeak-hour trips in either direction to the existing roadway traffic. The Area of Influence

has been previously defined following this general guideline and input from the key localjurisdiction staff representing each of the affected communities.

Question 12

Who were the local community representatives, specifically from elected officialsor City Planning Departments, consulted in order to obtain data relating to theNCC Area of Influence and where is the documentation of thesecommunications?


7/10

7 of 10

If you build it they will come.

In the Direct Access Ramps/ Local Circulation System Impact Study for the I-5 NCCTechnical Report 3 states that, The traffic impact assessment will include a detailedanalysis of existing conditions, as well as analysis of long-range traffic impacts underforecasted Year 2030 conditions. The Year 2030 analysis will be conducted based on

the change in traffic volumes resulting from the implementation of the direct accessramps as compared to a no project condition.

History has shown that the mere act of increasing roadway capacity increases trafficlevels. After completion of the I-5 NCC improvements all new residential, commercialand industrial development projects will have less freeway capacity constraints on theirprojects size and scope until these new developments fill up the 2030 I-5 NCC Buildroadway. Also, people will change their driving patterns due to this new roadway option.Just look at what happened in Orange County when they built the I-73 Toll Road, thisToll Road once traversed through rolling hills devoid of housing, commercial and

business structures and associated traffic. The new development in this corridor coversthe once peaceful hills. This development could not have taken place without I-73capacity.

In the more Northern Communities of I-5 NCC we are just now beginning to face strongopposition to existing General Plans constraints on building heights and developmentdensity. Were these considerations in the SANDAG Projections?

Question 13 a & b

Were the Traffic Impact Analysis criteria of Direct Access Ramps/ LocalCirculation System applied to studying changes the impact of the chosen Build

Configuration will have on the I-5 NCC? Since freeway expansions of thismagnitude generate increased traffic, were the impacts of these increases

analyzed and mitigation measures determined?

Question 14

As described in Technical Report 7, the purpose of a traffic impact study is to

forecast, describe, and analyze the traffic effects a development would have onthe existing and future circulation infrastructure. Was this analysis performed forany increase in traffic generated by the HOV lanes?

Energy Use Minimization

The following is a list of what CalTrans will do on the I-5 NCC Project to reduce energyconsumption.

Energy

Efforts to minimize energy consumption include: Public awareness campaigns to encourage carpooling and commuting duringnon-peak traffic hours The recycling of materials


8/10

8 of 10

The use of recycled materials

The salvage of material such as roadside sign posts, and sign structures, chainlink fence fabric, lighting standards, and/or traffic signal standards andappurtenances. The use of energy-efficient construction and maintenance vehicles

Question 15

Why are there no mitigation measures to reduce the energy consumptiongenerated by the traffic increases accommodated by this project?

Including a Light Rail or Public Transportation element in the project wouldaddress this glaring omission.

CalTrans stated in the EIR that,A range of alternatives was developed to meet the purpose and need of the project.

Build Alternatives also include: adding auxiliary lanes, adding noise barriers, addingramp meters; utility relocations and utility avoidance through design exceptions;

drainage facilities modifications; transit opportunities; and equipment for value pricingprogram to allow single occupancy vehicles to purchase use of HOV/Managed Lanes.

Question 16

What transit opportunities were analyzed for this EIR?

Question 17

Why was a Light Rail Public Transportation Option not included in the

Alternatives considered?

Question 18 a & b

In the Draft EIR CalTrans presented the Environmental Consequences RemainingSubstantial After Mitigation (CEQA) Part of CEQA is to analyze the Change inCharacter and Cohesion which will be experienced along much of the proposed BuildOption of I-15 NCC. Where is the analysis of this adverse impact?

Why did CalTrans only analyze the Changes in Character and Cohesion of one 47-

apartment building?

Question 19Where is the analysis of the change in character and cohesion of the coastalcommunities of North Coast San Diego due to the proposed project?

The elephant in the room not discussed in the EIR Regional opportunity lost.

In addition to the i-5 North County Corridor I-5 Project, CalTrans is also developing thefollowing projects


9/10

9 of 10

I-5 Mid-Coast Freeway Improvements (10+2HOV facility from I-8 to I-805)

I-805 North improvements (8+4HOV/Managed Lanes facility from SR-52 tonorth of Mira Mesa Boulevard in San Diego)

LOSSAN Rail Improvements (double tracking of rail corridor between Los

Angeles and San Diego).

San Diego County is at a pivotal juncture and we have a unique opportunity to develop aRegional Plan to deal with the new energy realities. Going out to 2030 the reality will beless gasoline, much higher gas prices at the pump, reduced traffic, more carpooling,more bicycling, more alternative vehicles needing places to replenish power sources,and a much larger percentage of the population embracing Public Transportation. Thecurrent Build Scenario for the I-5 NCC seems to ignore these realities.

The vision for the Coastal Communities of San Diego, indeed for much of San DiegoCounty, should be to nurture what makes us such a desirable place to live and work,

We should be looking for solutions to maintain our lifestyle, esthetic and energy choices.We should not build a freeway that will urbanize us from Oceanside to I-8.

This is the moment for us to all work together to create unique transportation solutionsthat are visionary, energy efficient, people friendly and befitting a community with one ofthe most stellar scenic roadways in the country. When we significantly urbanize I-5 wewill decrease our property values as well irreparably alter the coastal communityenvironment and esthetic that nurtures us and draws tourists to our communities.

Question 20

Did the SANDAG 2030 Projections take into account any of the new energy and

environmental realities or priorities?Question 21

What Mitigation Measures were analyzed to reduce traffic levels on I-5?

Question 22 a & b

Given that the Draft EIR states that all the Build Options will significantlyUrbanize the look of our freeway and surrounding neighborhoods, where is the

analysis of the decreased tourism dollars to the NCC due to the alter esthetic andperception?

Where is the analysis of possible changes in housing values due to the loss of

the community esthetic and perception?

The Coaster is the major Public Transportation link between the NCC and San Diego.The Coaster schedule is limited by constraints on availability of the rail line. The route ofThe Coaster is limited by the location of the rail line. For example, there are no Coaster

stops between the Sorrento Valley Station and the Old Town Station.


10/10

10 of 10

If you want to use Public Transportation to get to work in UTC, La Jolla or the area in

the I-805 Corridor it is effectively non-existent.

Question 23

Looking to the Bay Area Light Rail Systems, the Denver Light Rail System and

the I-210 Metro Line (to name just a few) we can see that forward lookingcommunities are incorporating light rail and trolley systems into their significantroadway system upgrades. Why is CalTrans not seeing this as a necessary partof the I-5 NCC Project??

Question 24

Why did CalTrans not incorporate Light Rail solutions and other Public

Transportation opportunities into the I-5 NCC design? Are there political,jurisdictional, or financial considerations that kept this obvious necessity off thetable?

Question 25

If there are political, jurisdictional, or financial considerations that constrain

CalTrans from incorporating Public Transportation Options into the I-5 NCC, howdo we remove these obstacles from CalTrans planning so the an Amended DraftEIR can be issued that incorporates traffic and travel considerations more alignedwith the reality of the next 2030 and beyond?

QuestIon 26

What is the cost of the opportunity lost by not incorporating Public Transportationin the I-5 NCC Project?

QuestIon 27

What is the cost of the redoing the I-5 NCC Project in another 5 years toincorporate Public Transportation Options?

Question 28

Is CalTrans planning Public Transportation Options in other projects in otherlocations in the State?

Question 29

If CalTRans is building and planning Public Transportation into other projects why

not along the I-5 NCC?

Question 30

When compiling the questions to the Draft EIR at what level is the existing DraftEIR deemed incomplete and it will be necessary to compile an Amended Draft

EIR to the Interstate 5 North Coast Corridor Project to re-release for final Public

Comment?

donna l ague comments

Documents