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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 II - COMMENTS RECEIVED ON THE DEIR/EIS (1-1 to 4-21) SUBMITTED PURSUANT TO: (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. Army Corps of Engineers California Department of Fish and Game U.S. Department of the Interior, Fish and Wildlife Service The following persons my be contacted for additional information concerning this document: Judith L. Heyer James J. Bednar Steve Letterly 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) 557-3293 x297 • FHWA-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 II - COMMENTS RECEIVED ON THE DEIR/EIS (1-1 to 4-21) • SUBMITTED PURSUANT TO: (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. 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. Bednar Steve Latterly Department of Transportation Federal Highway Administration San Joaquin Mitts 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 0 • INDEX OF COMMENTS RECEIVED ON DEIR TCA EIR/EIS 1 The following is a list of the agencies, groups and persons who commented on TCA DEIR/EIS 1. The comments received have been organized in a manner that makes finding a particular comment or set of comments easier. Each comment has been organized into one of the following eight categories: Federal Agencies (1), State Agencies (2), Regional or Local Agencies (3), Private Organizations and Groups (4), Utility Companies/Public Services (5), Corporations/Businesses (6), Other Interested Persons (7). This division is the basis for numbering each of the comments. Each comment is numbered using a trinomial (set of three numbers), with the first number reflecting one of the eight codes identified above. The second set of numbers identifies the sequence in which the comment letter was received by the TCA. Finally, the third set of numbers signifies the location of the comment within the letter. Thus, comment number 1-1-15 refers to the 15th comment in the U.S. Department of the Interior letter, which was the first federal letter received by the TCA. FEDERAL AGENCIES (1) 1-1 U.S. Department of the Interior Office of the Secretary 1-2 U.S. Environmental Protection Agency - Region 9 STATE AGENCIES (2 2-1 Office of Planning and Research 2-2 California Integrated Waste Management Board 2-3 California Regional Water Quality Control Board - Santa Ana Region 2-4 University of California, Irvine - G.J. (Pete) Fielding 2-5 California Department of Parks and Recreation 2-6 University of California, Irvine - Department of Ecology and Evolu- tionary Biology 2-7 University of California, Irvine - San Joaquin Freshwater Marsh Re- serve 2-8 California Coastal Commission 2-9 University of California, Irvine - Museum of Systemic Biology 2-10 California Transportation Commission 2-11 University of California, Irvine - Office of the Vice Chancellor CITIESICOUNTIES/REGIONAL AGENCIES (3) 3-1 South Coast Air Quality Management District 3-2 City of Newport Beach 3-3 Southern California Association of Government 01/2'./91(TCA901C%1NDEXV0L.2) 3-4 City of Laguna Niguel 3-5 City of Laguna Beach 3-6 City of Mission Viejo 3-7 City of San Juan Capistrano 3-8 City of Irvine 3-9 County of Orange Environmental Management Agency 3-10 Natural History Museum of Los Angeles County 3-11 Saddleback Area Coordinating Council, Inc. PRIVATE ORGANIZATIONS AND GROUPS (4) 4-1 Turtle Rock Glen Association - Art Bruington 4-2 Laguna Greenbelt - Norman Grossman 4-3 Laguna Canyon Property Owners Assoc. - Sandy Lucas 4-4 Laguna Canyon Conservancy - Sarah Rapuano 4-5 League of Women Voters - Linda Rushing 4-6 Spyglass Hill Community Association 4-7 Sierra Club Angeles Chapter - Stanley Hart 4-8 Orange County Recreational Trails Committee - Marlene P. Sandler 4-9 Women for Orange County - June Bickford 4-10 Coalition of Neighborhood Associations in Laguna Beach (CONA) - Molly King 4-11 North Laguna Homeowners' Association - Pauline Walpin 4-12 Laguna Hills Community Association - Joel Lautenschlegar 4-13 Women for Orange County - Francesjane Kapsch 4-14 Leisure World Residents to Save the Canyon - Dave Blodgett 4-15 Nellie Gael Homeowners' Association - Meserve, Mumper and Hughes 4-16 Alliance for Survival - Marion Pack 4-17 Committee to Stop the Toll Road - Jean Kennedy 4-18 Committee to Stop the Toll Road - Karl T. Jenks 4-19 Friends of the Irvine Coast - Fern Fickle 4-20 Sierra Bonita Homeowners Association - Barry Partners 4-21 Stop Polluting Our Newport - Don Harvey 4-22 Natural Resources Defense Council - Joel R. Reynolds 4-23 California Wildlife Campaign - Garven L. Walker 4-24 Temple Hills Community Association - Sharon Heath 4-25 Friends of Historic San Juan Capistrano - Mark B. Clancey 4-26 Rancho Niguel Homeowners Association - Audrey Grider 4-27 Coronado Homeowners Association - Herb Boswell 4-28 California Native Plant Society - David Bramlet 4-29 Laguna Greenbelt - Jeanette T. Merilees 4-30 Laguna Canyon Property Owners Association 4-31 The Laguna Canyon Conservancy - Carolyn Wood 01 /21 /91(TCA901 C A NDUVOL . 2) II -i i n U 4-32 Sea & Sage Audubon - Susan L. Gallagher 4-33 The Laguna Greenbelt, Inc. 4-34 Laguna Environmental Outreach - Jean K. Jenks 4-35 Sierra Club, Orange County Group - Allyn Cooksey 4-36 Village Laguna - Si Jones 4-37 Aliso Viejo Community Association - Larry Dees 4-38 North Laguna Homeowners Association and LATMA - Arthur W. Casebeer UTILITY COMPANIES/PUBLIC SERVICES (5) 5-1 Southern California Gas Company 5-2 County Sanitation Districts of Orange County 5-3 Metropolitan Water District of Southern California CORPORATIONSIBUSINESSES (6) 6-1 6-2 6-3 6-4 6-5 6-6 6-7 6-8 6-9 60 6-11 6-12 6-13 6-14 6-15 6-16 6-17 6-18 6-19 6-20 Buffy's Restaurant The Atchison, Topeka and Santa Independent Service Mission Viejo Company Mission Yamaha John Mel Saddleback Wholesale Electric, Euro Performance World Eiki International, Inc. In-N-Out Burger Shell Oil Company C.J. Segerstrom & Sons Sepulveda Building Materials Costco Wholesale Fe Railway Company Inc. Allen Oldsmobile - Cadillac, Inc. The Buie Corporation The Irvine Company Forbes Road Association Express Oil Company M.Y. Management & Talet Radwan OTHER INTERESTED PERSONS (7) 7-1 7-2 7-3 • 7-4 J. Dunn Vicki Borthwick Joel A. Couser Carol Deglman 01/21/91(TCA901C%1NDEXV0L.2) 7-5 Richard Deglman 7-6 Beth Leeds 7-7 Terri Quam 7-8 Jill Scheetz 7-9 Curtis Scheetz 7-10 William Strauss 7-11 Patricia Turnier 7-12 Jay Jones 7-13 Louis H. Davis 7-14 Richard Henrikson 7-15 James B. McDonough 7-16 William T. Samways 7-17 Michael Cartwright 7-18 Joan J. Carter 7-19 Marjorie Shearer 7-20 Robert W. Wells 7-21 A. McCormick & C. McCormick 7-22 Robert S. Smith 7-23 Genevieve Hapgood 7-24 James W. Schmidt 7-25 Christine and Patrick Conales 7-26 Cyndie Held 7-27 Rob J. Ramsey 7-28 Robert J. Healey 7-29 Michael J. Pinto 7-30 Paul Beier, PhD 7-31 Bob Reed 7-32 Mary B. Benson 7-33 Dr. Phillip Ellison 7-34 Mark Walpin 7-35 John J. Cirincione 7-36 Elizabeth Brown 7-37 Mary Lou Ripley 7-38 Wayne Held 7-39 Adele Mann 7-40 Joyce Tausenberry 7-41 Yasuo Kurata 7-42 Steven J. Wilson 7-43 Mel Burland 7-44 Ruth Evans 7-45 Lida Lenney 7-46 Loyola Seymour 7-47 Edith Donahue 01/21/91(TCA901C%INDEXVOL.2) II -iv 0 • • • C7 7-48 Max Holiday 7-49 Lauren Miskinnis 7-50 Herbert N. Morgan 7-51 Judith R. Hance 7-52 Brian Phillips 7-53 Richard Peckman 7-54 Rebekah Pauly 7-55 Danielle Ritz 7-56 Janie Cowlin 7-57 R.A. Maxwell 7-58 Barbara Stuart 7-59 Felix Dupuy 7-60 Paul S. Sarizia 7-61 Eric & Laurie Kirkland 7-62 Tecla Miceli 7-63 Bruce R. White 7-64 Humberto Boccardo. M.D. 7-65 John Miceli 7-66 Laura La Ferla 7-67 Gary La Ferla 7-68 Bob McCarty & Joy Bradford 7-69 Connie Bergquam 7-70 Maria J. Bertran 7-71 Dorothy Felten 7-72 Donald E. Robinson 7-73 Natasha King 7-74 Judy & Kurt Topik 7-75 Fred Topik 7-76 Dean Steinke 7-77 Frances G. Carrillo 7-78 M.R. Benjamin 7-79 Ruth Sturn 7-80 K. & Wendy Milette 7-81 Jane H. Stewart 7-82 Marian Blacketer, Beth and Marielle Leeds 7-83 Dr. & Mrs. Fred S. Topik 7-84 Ken Kube 7-85 Herman Indrapradja 7-86 Wesley. Marx 7-87 Margaret E. Hedden 7-88 Peter A. Bowler, Ph.D. 7-89 Mary Fegraus 7-90 Eden Lorenzen -Nolan, Keith Fowler & Marian Farieu 01/21/91(TCA901C%INDEXVOL.2) II-V 7-91 7-92 7-93 7-94 7-95 7-96 7-97 7-98 7-99 7-100 7-101 7-102 7-103 7-104 7-105 7-106 7-107 7-108 7-109 7-110 7-111 7-112 7-113 7-114 Mrs. Ann Weisbrod Robert A. Merkle, Sr. Rita Walker Leo Schacter Verna Stock Eugene & Mildred E. McFelea Ivera Marshall Zelma Lloyd Lucy Wallace Elaine Rosenwald Barbara Chapla T. Jackson Ernest C. Webb Charles A. Lewis Lee H. & Stephanie Penny Lorenzen, Marty Glorfeld, Edward Thornfield Albert'E. Nasser Jan D. Vandersloot, M.D. Corinne Fowler Paul L. Root Robert C. Gray Paul Kennard Donald W. Harvey Bruce Nolan & Mrs. Marty Glorfeld Pam Fowler Alan Thornhill, Cynthia Veit, Alistair Cullum, Eric Woehler, Dana Kamada & Alice Gibb 7-115 Ronald W. Hitter 7-116 Sieglinde Johnson 7-117 Walter & Dilys C. Gresham 7-118 Nancy King 7-119 Jill J. Millette 7-120 Dorothy Boynton 7-121 Richard & Carol Deglman, Bruce Jo Shurstad, Jerry & Carol Denham 7-122 Debbie Conyer 7-123 Scott Miklos 7-124 T.C. Rogers 7-125 Brigette Bukowski 7-126 Melody Schulte 7-127 Phyllis Gilmer 7-128 William G. Butler, Jr. 7-129 Martha Exline 7-130 Terry Barman 7-131 Joe Cabral 01/21/910 CA901CA NDEXVOL.2) & Gayle Anderson, Tom & Mary and Don and Jane Crusius • • 7-132 Joel & Susan Atkinson 7-133 Charles E. Redding 7-134 Les Gilmer, Fred B. Green, Mrs. Richard T. Anderson 7-135 Mary D. Robb 7-136 Dave Smith 7-137 James Davison 7-138 Cindy M. O'Neal 7-139 Sandra Humphrey 7-140 Carol Roberts 7-141 Gene and Johanna Felder 7-142 Maureen Tilton 7-143 Nancy & Rod Boone 7-144 Bob & Patricia A. Spence 7-145 Russell Burkett 7-146 Rick Delanty 7-147 Alan & Janet Remington 7-148 Joan Richardson 7-149 Ellis 7-150 Richard Shaw 7-151 Jack E. Cotler PUBLIC HEARING COMMENTS (8) Bob Messersmith, Richard Cardillo, Dr. & 8-1 Jay Salsburg 8-2 Milton Adamson 8-3 Robert Wells 8-4 Jean Jenks 8-5 Joel Lautenschieger 8-6 Margo Beauchamp (San Clemente Village Association) 8-7 Beth Leeds 8-8 John Hamil (Laguna Canyon Property Owners) 8-9 Mark Clancy (Friends of Historic San Juan Capistrano) 8-10 Tom Rogers 8-11 Allyn Cooksey 8-12 Dan McClintock (Precision Auto Collision) 8-13 Russell Burkett 8-14 Joel Reynolds (Natural Resources Defense Council) 8-15 Alan Remington 8-16 Ken Kube (Sycamore Hills Residents Against the Toll Road) 8-17 Tom Larson 8-18 Clarence Black 8-19 Marielle Leeds 0 01/21/91(TCA901C%INDEXVOL.2) II-vi i • COMMENTS RECEIVED ON DEIR TCA EIR/EIS 1 0 01/10/91(TCA901C%INDEXVOL.2) 0 • • sEN_ Or TyE N United States Department of the Interior C. a� OFFICE OF THE SECRETARY Rh 3 �,,WASHINGTON, D.C. 20240 L7619(774) ER 90/0864 DEC 2 0 1990 Mr. Bruce E. Cannon Division Administrator Federal Highway Administration Post Office Box 1915 Sacramento, California 95809-1915 Dear Mr. Cannon: This is in response to the request for the Department of the Interior's comments on the Draft Environmental/Section 4(f) for SR-73 Extension (San Joaquin Hills Transportation Corridor), Orange County, California. SECTION 4(f) STATEMENT COMMENTS This document contains an outstanding Section 4(f) analysis, and is the first) major highway project to give comprehensive attention to constructive use issues. We concur with your determination that there will be no actual or constructive uses of San Juan School, Capistrano Bluff Open Space, Goeden Equestrian Trail, Aliso Viejo Local Parks 9 and 10, Orange County Bicycle Trail 66, San Joaquin 1-1-2 Marsh, Bayview Park, Upper Newport Bay Ecological Reserve, Northwest Park, and Crystal Cove State Park. We do not, however, concur with your determination that there will be no actual use of Arroyo Trabuco Equestrian Trail/Orange County Bicycle Trail 81, San Diego Creek/Santa Ana Heights Equestrian Trail/Orange County Bicycle Trail 40, Oso Creek Corridor, Niguel Equestrian Trail and Orange County Bicycle Trail 72. All 1-1-3 of the these involve the acquisition of aerial easements from the protected lands. Although your determination is in accord with item 19 of your Section 4(f) Policy Paper, this Department holds that such easements are a direct actual use of a Section 4(f) resource. We also question your determination of no constructive use of Niguel Equestrian Trail (25 dBA noise increase), Orange County Bicycle Trail (23 dBA noise increase), Aliso/Wood Canyon Regional Park and Aliso Creek Trail System (22 dBAJ noise increase, wildlife barrier, and lack of access between residual parkland), Sycamore Hills Open Space (visual impacts, 18 dBA noise increase, wildlife barrier, and lack of access between residual parkland), Laguna Laurel Dedication Areas (visual impacts, 18 dBA noise increase, wildlife barrier), Bommer Canyon Park (visual impacts), and Bonita Creek Park (10 dBA noise increase). However,we are willing to accept the opinion of the local officials with jurisdiction over these areas with regard to constructive use of their lands, and request that such opinion be documented in the final statement. We note in passing that your argument, that trail users pass through high noise zones too quickly to be affected, does not find a sympathetic audience in this Department. -1-4 • We concur with your determination of actual use of the Rancho Viejo Bicyclell_1_5 Trail. Notwithstanding the above, we would concur that there are no feasible and prudent alternative to the proposed use of Section 4(f) lands, if the Federal Highway Administration (FHWA) finds that a build alternative is essential in meeting the transportation needs of Orange County. We would also concur that all possible planning had been done to minimize harm, if a special effort is made during project design to fully integrate the proposed facility into the area's park and recreation plans, and to accommodate wildlife 1-1-7 resources (which, in addition to their intrinsic value, are also a recreational amenity). Specifically, we recommend full compensation or replacement for all protected land used (including air rights), payment of incidental damages, noise abatement, visual impact abatement, provisions to reduce the wildlife barrier effect of the road, measures to prevent bridge and roadway drainage from reaching underlying or adjacent parkland, and other items that may be recommended by the local officials with jurisdiction. We are aware of the joint planning efforts that have occurred during the project's corridor/location stage. We urge that a strong commitment be made to 1-1-9 continue and expand such cooperative planning with park, recreation, and wildlife officials, and the general public, during project design. ENVIRONMENTAL IMPACT STATEMENT COMMENTS General Comments: • In general, the document has not adequately addressed concerns pertaining to the protection and preservation of public fish and wildlife resources that are present in or near the two alternative route study areas. In particular, the 1-1-10 U.S. Fish and Wildlife Service (FWS) continues to have major concerns with the following issues: 1) The proposed, unmitigated destruction of extremely high quality riparian habitat at Bonita Canyon, used by a male least Bell's vireo (vireo; Vireo 1-1-11 bellii Pusillus), a species which is both State and federally listed as endangered; 2) The proposed, unmitigated destruction of other sensitive habitats that acccmmodate a large number of additional sensitive, significant populations of plant and animal species, including but not limited to the following: orange -throated whiptail (whiptail; Cnemidophorus hypervthrus), San Diego horned lizard (horned lizard; Phrynosoma coronatum blainvillei), California gnatcatcher (gnatcatcher; Polioptila californica), Pacific little pocket mouse (pocket mouse; Perognathus lonzimembris pacificus), spotted bat (Euderma maculatum), greater mastiff bat (Eumovs perotis californicus), Orange County turkish rugging (Chorizanthe staticoides ssp, chrysacantha), and many -stemmed live -forever (Dudleya multicaulis), that are candidates for listing as federal threatened or endangered species; 1-1-12 3) The failure to adequately identify and address direct and indirect project 1-1-13 impacts to, and mitigation for, wetlands and waters as required by Section 404 of the Clean Water Act; 3 4) The cumulative impacts of this and other related projects on said sensitivel1-1-14 habitats and plant and animal resources; 5) Direct and indirect impacts of the area -wide growth induced by this�l_1-15 proposed project. If a Federal discretionary action is involved, or if a project is proposed on federally owned or administered lands that "may affect" an endangered species or its critical habitat, a Section 7 consultation is required pursuant to the endangered Species Act of 1973, as amended (Act). This would lead to the issuance of a biological opinion from the FWS. The vireo, a federally listed endangered species, is present in each of the proposed alternative alignments. At least one additional sensitive species, the gnatcatcher, currently a "category 2 candidate" for listing, is present in the area. The FWS is reviewing the status and distribution of the gnatcatcher and a preliminary analysis of the data accumulated to date suggests rhat its proposal for listing is probably warranted. As a result of this review, it may likely be proposed for listing, and later may potentially be listed before the project is begun or ultimately completed. 1-1-16 1-1-17 The gnatcatcher is widely distributed and relatively numerous in both proposed alignments. The ongoing and expected rate of destruction of the gnatcatcher's coastal sage scrub habitat, combined with the paucity of efforts to adequately mitigate these impacts, could prompt the FWS to emergency list this species in order to assure its continued existence. The preliminary data supplied by the draft statement, biological consultants, and FWS biologists strongly suggest that the proposed project will result in substantial, significant, unmitigated impacts 1-1-18 to the gnatcatcher and its habitat. The Federal Highway Administration should coordinate frequently (i.e., every 90 days) with the FWS to check on the current status of the gnatcatcher and other candidate species so that project impacts may be avoided and/or appropriately and adequately mitigated. If and when the listing of the gnatcatcher occurs, the species would be protected from "take" (e.g., harass, harm, kill) pursuant to Section 9 of the Act unless and until a Section 10a permit is issued. Or alternatively, if a Federal discretionary action is involved, a formal consultation pursuant to Section 7 1-1.19 of the Act must be completed. Please note that the vireo is already afforded this protection by virtue of its status as a federal endangered species, as are all listed species that presently or potentially occur within the project area. The FWS advises that it cannot issue Section 10a permits or incidental take statements pursuant to Section 7 of the Act unless all prudent avoidance and alternative measures have been identified and evaluated. Further, if "take" is permitted, the permit issued under Section 10a, or biological opinion rendered 1-1-20 under Section 7, will require implementation of substantial mitigation measures prior to the "take" in order to offset actual and/or potential threats and impacts to the protected species. The specific comments outlined below are designed to eliminate or minimize project impacts to public fis. and wildlife resources. They should assist you and other government entities in complying with applicable Federal statutes, and 1-1-21 . in anticipation of related federal permit requirements. Until the issues mentioned above are satisfactorily resolved, the FWS advises that it would endorses only the No Build Alternative. Specific Comments: 1. Pages 3-29, Table 3.6.A Vireos were shown as "not sighted within the corridor area of effect," when in fact a singing male vireo was found in the Bonita Canyon area of the proposed corridor during the May 1990 surveys conducted by Larry Seamon and Associates (LSA). It appears that the biological data in Technical Report #5 were not 1-1-22 incorporated into, nor appropriately considered in the draft statement. It further appears that the status of the vireo, a federally listed endangered species, was inadequately represented in the Draft Environmental Impact Statement (DEIS) document. The FWS recommends that comprehensive surveys be conducted for the vireo, 1i-1-23 gnatcatcher, and other listed and candidate species whose geographic ranges include the project area. The following federally listed endangered species would be expected to occur occasionally within the project area but were not mentioned in the document: peregrine falcon (falcon; Falco peregrinus), light- 1-1-24 footed clapper rail (rail; Rallus longirostris levipes), and California least tern (tern; Sterna antillarum browni). The DEIS also lists the spotted bat (Euderma maculatum) and greater mastiff bat (Eu.movs perotis californicus), both federal category 2 candidate species, as "potential sensitive species within corridor area of effect." However, it appears that no focused surveys for these sensitive bat species were conducted; no bats were included on the LSA survey list (Tech. Rept. #5, pages 20-30) . Several substantial and unique caves in Upper Bommer Canyon (Tech. Rept. #5, pages 22-23) and elsewhere within the proposed project area may provide important habitat for these sensitive bat species and should therefore be the subject of focused surveys. 1-1-25 0 Given this apparent omission of information, the FWS contends that potential impacts to listed and sensitive fish and wildlife resources have not been adequately addressed. The FWS strongly recommends that deficiencies in the 1-1-26 collection and reporting of biological survey results, and related errors and/or omissions in impact analyses and mitigation proposals be addressed prior to the preparation and release of the final statement. 2. Pages 3-30, Table 3.6.A The Pacific little pocket mouse (Perognathu.s longimembris pacificus), also a federal category 2 candidate species, is listed in the DEIS as "not sighted within the corridor area of effect." The results of the spring 1990 surveys conducted by LSA (Tech. Rept. #5, Spring 1990 Survey Results, page 29) show a "Little pocket mouse (Perognathus longimembris)," but do not indicate which subspecies. Based upon the documented, known distributions of populations of this species, the FWS assumes that the subspecies located during LSA's surveys was P. 1. pacificus. The occurrence of this sensitive animal within the proposed project area should be properly addressed in the final statement. 1-1-27 With regard to the gnatcatcher, there is very little information provided in the document regarding its status and distribution. Table 2, "Plant communities - acreage lost" (Tech. Rept. #5, General Environmental Impacts, page 62) purports 1-1-28 that only 156 acres of coastal sage scrub habitat would be impacted by the C] 5 corridor. Although the document does not attempt to quantify impacts to gnatcatchers, or mention them in project impact analyses, approximately 17 birds were observed during surveys conducted by LSA (Tech. Rept. #5, spring 1990 survey results, page 4). From the description given, it appears that these observations were concentrated in the area of Bonita Canyon Reservoir, "an area more intensively covered by us than anywhere else along the route" (op. cit., page 4). Other data available in previous documents, when compared to gnatcatcher locations contained in the draft statement, Figures 4.73 - 4.77 (pages 4-76 thru 4-80), "Impacts to Sensitive Resources," indicate that at least 32 gnatcatchers may be present within the proposed corridor. This leads the FWS to believe that either a focused gnatcatcher survey was not conducted for the entire length of the corridor, or if it was, all of the data collected in this and in previous surveys were not included in either the draft statement or the Technical Report. In any case, the data presented are unclear and incomplete, and the FWS cannot adequately assess potential, direct or indirect impacts to the gnatcatcher. Further, when the entire length of the corridor is considered, the total acreage of coastal sage scrub habitat lost may actually be much greater than that reported in the draft statement. If one includes the sections of the proposed corridor route which have already been constructed in conjunction with residential and commercial subdivisions and for which coastal sage scrub habitat has already been destroyed, the total project impacts to this sensitive species and habitat type (and possibly others), may be substantially greater than is reported. 1-1-28 1-1-29 The FWS also believes that project impacts related to erosion, stockpiling, heavy equipment/vehicle parking, and construction and use of haul roads, as well as 1-1-30 indirect effects of the project (e.g., human activities and noise), will impact areas of habitat much greater in scope, and outside of, the corridor itself. The secondary, indirect impacts of the proposed corridor include significant growth inducement along the route which would result in the further loss of 1-1-31 coastal sage scrub habitat and gnatcatchers. The magnitude of this loss will be substantial and is not adequately addressed. 3. Pages 4-70, Mitigation Measures The draft statement recognizes that "complete mitigation of the habitat impacted by the corridor through revegetation would be difficult due to the large size of the impacted area and poor likelihood of successful regeneration," and does not contain specific proposals to mitigate potentially substantial and significant impacts to the gnatcatcher or other sensitive species such as the whiptail, horned lizard, Orange County turkish rugging, and many -stemmed live - forever which occur in coastal sage scrub habitat. It is estimated that approximately 90 percent of the coastal sage scrub historically present in California has been destroyed in recent times. 1-1-32 The FWS does not consider crushing instead of blading or ripping above -ground vegetation, nor revegetation of corridor slopes with native plant materials, to be appropriate mitigation for. the destruction of large tracts of coastal sage 1-1-33 scrub habitat. These measures only very slightly minimize permanent reductions in losses of habitat quantity and quality. The FWS suggests that appropriate mitigation for the loss of coastal sage scrub consists of in -kind habitat replacement and/or the dedication of lands of sufficient size to sustain biologically viable populations of gnatcatchers and/or 1-1-34 other sensitive species. If the gnatcatcher is federally listed, the FWS may well recommend mitigation requirements similar to these in conjunction with a habitat conservation plan. 4. Page 65, Technical Report 05, Impacts to Wetlands, Table 3 Direct wetland impacts for the conventional and demand management alternatives are purported to be only 15.2 and 13.8 acres, respectively. However, this table 1-1-35 appears to be incomplete when compared to the wetland delineation sheets for Coyote Canyon, which indicate that wetlands were present there as well (op. cit. , App. 1, Att. 1). Further, as many as 14 watercourses will potentially be impacted by the proposed project. These areas include wetlands and waters under the jurisdiction of the U.S. Army Corps of Engineers (Corps) through Section 404 of the Clean Water Act. As such, they will likely require the project to apply for and receive a permit 1-1-36 for 404-regulated activities for the entire project prior to the commencement of any project construction activities. However, the amount and extent of Waters within the proposed project area was not described or quantified. The FWS recommends that a Section 404 (b)(1) evaluation be included in the final document. The final statement should include all information necessary to I1-1.37 satisfy the Corps' requirements for permit applications. In addition, the draft statement does not adequately address nor quantify the growth inducing, secondary impacts of the proposed project to wetlands. This information is essential to 1-1-38 the FWS and the Corps in evaluating direct and indirect, and cumulative, impacts of the entire project to watersheds, water quality, streams, wetlands, and wildlife habitats. In the 404 (b)(1) analysis, there must be a "tiering" of considerations in analyzing the impacts of a project to aquatic ecosystems. The sequencing of these considerations, in order of priority, should be: 1) Avoidance of impacts; 1-1-39 2) Use of the least damaging, practicable alternative to minimize impacts; 3) Mitigation of unavoidable impacts, with no net loss of wetlands habitat in quantity or quality. The FWS offers the following guidance for mitigating direct and indirect impacts to wetland habitats. It has been suggested elsewhere that a 1:1 mitigation ratio is appropriate for impacts to wetlands of degraded quality. However, the FWS believes that this ratio does not adequately mitigate impacts to well developed, fully functioning habitats. 1-1-40 Due to time delays inherent :.. replacing mature wetlands habitats, and frequent lack of success in creating viable replacement habitats, the FWS recommends a minimum mitigation ratio of 2:1 to offset losses to nondegraded habitats. The FWS maintains that higher ratios are appropriate for structurally complex habitat types such as high quality riparian habitat for vireos and sycamore/oak woodlands. 7 The FWS recommends that, at a minimum, any and all mitigation plans should: 1) Identify the location and current condition of the proposed mitigation site; 2) Identify the agencies or parties ultimately responsible for the plants success and implementation; 1-1-41 3) Contain clear language and stipulations pertaining to enforceable performance standards and provisions for routine evaluations by the FWS and State wildlife agencies and local, State, and federal permitting authorities; 4) Contain clear provisions for the dedication of the riparian and sensitive upland mitigation sites to the appropriate State or local government entity or conservation organization. We suggest that the project use the riparian mitigation success criteria as set forth and described in "High Quality Restoration of Riparian Ecosystems" by 1-1-42 Kathryn Baird (Restoration and Management Notes, 7:2; Winter, 1989; pages 60- 64) as a guideline. The conceptual mitigation plan should be prepared prior to, and included as an integral part of, the 404 permit application package sent to 1-1-43 the Corps. Prior review by FWS would expedite the permit process. • 5. Page 76, Technical Report *5, Mitigation Measures - Species of Concern We disagree that "There are no listed federal or State plants or animals within 1-1-44 the APE of the corridor." This section omits the confirmed occurrence of the vireo, a federally listed endangered species (previously described in the report), within the APE at Bonita Canyon Reservoir. No mitigation provisions for impacts to the vireo are described in the document. The FWS would, therefore, likely make a "may affect" determination in consultation under Section 7 of the Endangered Species Act given this current 1-1-45 omission of avoidance or mitigation measures for real or potential, direct or indirect, negative project impacts to the vireo. The FWS recommends that impacts to the wetland and riparian habitats at Bonita Creek/Canyon be avoided and/or minimized by elevating the corridor on a bridge 1-1-46 spanning the area, or by realignment of the route. Mitigation for the vireo - quality, mature riparian woodland and wetlands should be substantial and done on -site. In addition, FWS recommends that mitigation be provided for the numerous federal candidate species of wildlife and plants known or potentially within the APE, which were not mentioned and for which mitigation was similarly not provided. These include the southwestern pond turtle (Clemmvs marmorata 1-1-47 pallida), whiptail, horned lizard, spotted bat, greater mastiff bat, pocket mouse, ferruginous hawk (Buteo re ag lis), southwestern willow flycatcher (Empidonax trailii extimus), gnatcatcher, Orange County turkish Tugging, and many -stemmed live -forever. 8 6. Pages 78 - 80, Technical Report *5; DEIS, Pages 3-46, 3-47 We believe that the project as currently proposed would create impacts to wildlife movement that could not be mitigated to a level less than significant, regardless of which alignment is selected. Therefore, the FWS recommends that 1-1-48 the design and implementation of viable wildlife movement corridors be incorporated into project plans. Revegetation of corridor slopes, installation of wildlife "guzzlers", and oak tree replacement are not adequate mitigation for the loss of wildlife movement corridors. Nor is the installation of only one wildlife undercrossing of 1-1-49 undetermined design adequate mitigation for the loss of corridors along the entire length of the proposed rotate. 7. Technical Report 05, Wildlife Crossing Technical Memorandum, Memorandum from Caltrans The impacts of the proposed project include the subdivision of large, contiguous parcels of wildlife habitat into smaller, biologically less viable parcels. This parcelization has particularly negative affects on large ungulates such as the California mule deer (deer; Odocoileus hemionus californica), which occur within the project area. The FWS has concerns that the proposed undercrossing design will not be used by the deer. The document alleges that this proposed undercrossing is a viable deer corridor, but •the data used are based upon a 200 foot length, 15 foot height, and 20 foot crossing width. It further states that the "height and width (requirements) increase as the crossing length increases." The proposed undercrossing is 400 feet long, but maintains the 15' height and 20' width in spite of the recommended increases in dimension. We suggest that alternative wildlife corridor designs such as wide overcrossings with native vegetation and restricted human traffic be considered instead. Mitigation for all known and potential wildlife movement corridors impacted by the proposed project should be included in the final statement. Further, a site -specific mitigation plan should be formulated for the Bonita Canyon/San Diego Creek/Upper Newport Bay wildlife movement corridor. This corridor is a critical link in the interaction between the freshwater and upland habitats at Bonita Canyon and San Diego Creek, and the intertidal habitats at Upper Newport Bay. The movement of native predators along this corridor is essential in controlling the numbers of non-native meso-predators which prey upon the federally listed, critically endangered light-footed clapper rail. These habitats are unique in Orange County and southern California, and are extremely sensitive. The wildlife corridor mitigation plan should provide a means for maintaining this vital corridor. :n part, this might be accomplished through the revegetation (with native plant species) of the agricultural fields occurring along the proposed San Joaquin Hills route at its intersection with MacArthur and Bison Streets and southward. However, a means for wildlife to cross MacArthur Boulevard and University Drive must still be provided. 1-1-50 1-1-51 Given the real and potential impacts of noise to avian and mammalian species in or near both study corridors, _:Ze FWS recommends that all potential noise impacts 1-1-52 resulting from project -related sources should be adequately abated, and/or appro- r� U ! 9 priately mitigated. The FWS strongly recommends that such action be taken whenever or wherever possible to reduce the impact of the documented effects of 1-1-52 noise on wildlife or, at the extreme, the possibility of an unlawful "take" of a migratory bird or a federally listed threatened or endangered species. 0 Numerous published studies have concluded that excessive noise levels, such as those from heavy traffic or the operation of heavy equipment, can result in the disturbance of or actual harm to avian and mammalian species. For example, noise levels of approximately 60 decibels or more are thought to adversely affect the vireo (and, by extension, other bird species) by: 1) reducing their ability to establish and defend territories and communicate with their mates and young, 2) subjecting them to physiological stress, and 3) exposing them to increased predation by reducing their ability to near and avoid predators. Ambient noise levels in the Bonita Canyon/Creek area are currently ranging between 48-54 dB (Table 3.5.A, pages 3-26), dangerously near the 60 dB threshold for negative impacts to vireos. The FWS believes that additional noise from construction of the proposed corridor and the resultant increase in ambient traffic noise levels would exceed the 60 dB level in the Bonita Canyon/Creek area where the vireo occurs (pages 3-23 thru 3-26). Noise mitigation measures specific to the vireo should be developed. 1-1-53 If the proposed project is permitted to proceed, the FWS recommends that measures be taken to perpetually reduce ambient, exterior noise levels below 60 dB. Otherwise, documented noise impacts to the vireo, other avian species, or any 1-1-54 federally listed threatened or endangered species may result in violations of the Endangered Species Act or Migratory Bird Treaty Act. Other potential impacts to protected species that may result from project -related activities are the increased rates of depredation or nest parasitism resulting from increased human presence and/or the conversion of habitats adjacent to the occupied habitats of said species. Specifically, human -induced increases in the food supply or feeding habitat for the brown -headed cowbird (Molothrus ater), a parasitic brood species, and other domestic or wild predators (e.g., American crow, Corvus brachyrhynchos; cats; dogs; non-native rodents) would almost certainly result in impacts to protected and/or sensitive species. A management plan should be proposed to offset these impacts. When a management plan is incorporated into mitigation proposals, the FWS suggests that the plan should, at a minimum, contain provisions to insure: 1) Frequent monitoring of listed and/or sensitive species and their respective habitats (e.g., vireos and vireo -quality riparian woodlands); 2) Timely removal of brown -headed cowbirds, all problem predatory species, and all noxious, non-native habitat constituents; 3) Substantially reducing or eliminating food and/or foraging habitat and access provided to all brood -parasitic or predatory species; 4) Legal and operational mans to address and mitigate any of the potential impacts to listed and sensitive species (including, but not limited to, • all those listed elsewhere in this document) resulting from construction and secondarily from subsequent human occupation of the transportation corridor and surrounding environs. 1-1-55 1-1-56 10 The FWS would not endorse any mitigation proposals that include sites or habitats that are otherwise appropriate, yet wholly or partially dysfunctional because of noise, predation, fragmentation, or other impacts. Further, if a Section 7 consultation should become necessary to address a "may affect" determination for a listed species (and it appears that it may, at least in the case of the vireo) , it is likely that many or all of the above management considerations and stipulations will be included in the biological opinion rendered by the FWS. 1-1-57 For a thorough discussion of direct or indirect impacts to the vireo and other wildlife management considerations, please see the "Draft Comprehensive Species 1-1-58 Management Plan for the Least Bell's Vireo" by Regional Environmental Consultants (RECON), January 1990. The FWS has carefully examined and considered the data presented in the draft statement, and concludes that the proposed project will have significant impacts 1-1-59 to hydrology and water quality, and cause significant impacts to wetland species and habitats. The FWS agrees with the authors that the project "would add significant quantities of pollutants into drainage areas immediately adjacent to the proposed corridor alignment" (page 4-27). The document states, "The concentrations of pollutants would exceed the State and federal critical levels 1-1-60 of pollutants," but purports to mitigate this with a "Runoff Management Plan and Sediment Control Plan" in Section 4.18, which appears to be missing from the document. The FWS cannot adequately evaluate water quality issues without the opportunity to examine the mentioned plans. However, the FWS agrees that "the project could potentially contribute incrementally to cumulative water quality impacts in the form of residual materials such as heavy metal components...." 1-1-61 Indeed, hydrological considerations alone may be sufficient to trigger a Section 7 consultation involving the vireo and/or other listed species. The FWS recommends that further measures be proposed to prevent: 1) Anticipated discharge or runoff of toxic or turbid aqueous waste plumes 1-1-62 generated by the construction or utilization of the transportation corridor; 2) Potential impacts to wildlife habitats (i.e., dewatering) that could occur 1-1-63 as a result of the alteration of existing hydrological conditions in and adjacent to the project area; 3) Project -caused erosion and resultant siltation of wetlands andl1-1-64 watercourses. The FWS contends that significant growth inducement impacts can be ascribed to the proposed project. When this project is considered cumulatively with other projects that are inter -connected with, and were or will be facilitated by its construction (e.g. Foothills [FTC) and Eastern Transportation [ETC] Corridors), the cumulative impacts are significant and substantial. These impacts have not been, and cannot be, mitigated to a level less than significant. Because of the growth patterns and development history in Orange County, and because the CEQA guidelines state "that it n,ust not be assumed that growth in any area is of... little significance to the environment" (page 6-1), we conclude that construction of either alternative will result in significant and substantial impacts to biotic resources (including federally listed and sensitive species) in and near the project area. 1.1-65 0 11 0 11 Because of the similarity of wildlife resource issues, extraordinary cumulative impacts from, and the inter -relatedness of the mentioned transportation corridors (San Joaquin Hills, ETC, FTC), we recommend that all three be considered under one county -wide environmental statement. We recommend that this overview 1-1-66 document be based on the geographic information system (GIS) currently under development by the County's Environmental Management Agency. The GIS system will be invaluable in the planning of and management for viable, "natural" open space lands and the wildlife corridors essential in connecting them. SUMMARY COMMENTS The Department of the Interior has no objection to Section 4(f) approval of this 1-1-67 project providing the measures to minimize harm recommended above are included in your final statement. For technical assistance on park and recreation matters please contact the Regional Director, Western Regional Office, National Park Service, 450 Golden Gate Avenue, P.O. Box 36063, San Francisco, California 94102 (telephone: FTS 556-8313, commercial (415) 556-8313). For technical assistance on fish and wildlife matters, the Endangered Species Act,' and the Fish and Wildlife Coordination Act please contact the Field Supervisor, U.S. Fish and Wildlife Service, Federal Building, 24000 Avila Road, Laguna Niguel, California 92677 (telephone: FTS 796-4270, commercial (714) 643-4270). Thank you for the opportunity to provide these comments. Sincerely, J#nathan P. Deason erector Office of Environmental Affairs cc: Ms. Judith L. Heyer California Department of Transportation 2501 Pullman Street Santa Ana, California 92705 Mr. Steve Letterly San Joaquin Hills Transportation Corridor Agency 345 Clinton Street Costa Mesa, California 9262r, UNITED STATas Z21VIRObD OM" POTECT10N AG"Cy REGION 9 75 ELMORNZ 9TRZET sax TNrClsoo, CAi zroua XA 9410 S 10 JAN 1991 Mr. Ed Wood Regional Administrator Federal Highway Administration 211 Main Street, Room 1100 San Francisco, CA 94105 Dear Mr. Wood: OFFICE OF TIE NUIau MUNISTaraa RECEIVED JAN 1 1 1991 The Environmental Protection Agency (EPA) has reviewed the Draft Environmental Impact Statement .(DEIS) for San Joaquin Hills Transportation corridor, Orange County, California. Our comments on this DEIS are provided pursuant to EPA's responsibilities un- der the National Environmental Policy Act (NEPA) and section 309 of the Clean Air Act. We have classified this DEIS as Category 3­ Inadequate In- formation (see enclosed "Summary of Rating Definitions and Follow -Up Action"). Our 3 rating reflects the DEIS's failure to provide enough information to adequately assess potentially sig- nificant environmental impacts of the proposed project. Our detailed comments are attached. The DEIS evaluates transportation actions for north/south highway linkage between Interstate 5 and State Route 73 in Orange County, California. The stated primary project objectives are to alleviate existing and projected peak period traffic congestion on regional circulation systems and minimize regional through traffic use of arterial highways. The alternatives discussed in the DEIS are: (1) Demand Management Alternative, (2) Conventional Alternative, and (3) No Action Alternative. The Demand Manage- ment Alternative would consist of six general purpose lanes and.a wide median (as - 116 feet) reserved for potential future expan- sion to reversible lanes, dedicated high occupancy vehicle (HOV) lanes, and/or mass transit. The Conventional Alternative would consist of six to ten general purpose lanes and a median of suf- ficient width .(64 feet) to accommodate either dedicated HOV lanes or'a fixed guideway rail/transit. Both build alternatives would initially operate as toll facilities until the construction bonds are retired. Under the No Action Alternative, no corridor or as- sociated facilities would be built. The DEIS does not include a proposal to select a specific alternative. 1-2-1 b00I3Sdd Wn/:3ADN 01 Sd01 3H1 W08.� Ib:bi 19. It NHf The project proponents are the San Joaquin Hills Transporta- • tion Corridor Agency (TCA), California Department of Transporta- tion (Caltrans), and Federal Highway Administration (MA). Al- though private sponsors may provide much or all of the funding for the Corridor, as much as 35 percent of the construction costs could potentially be funded by FHWA. Upon completion of financ- ing and construction of the Corridor by 'MCA, Caltrans would as- sume ownership and maintenance responsibilities. EPA believes that FHWA has not met .its requirements under NEPA because the DEIS does not provide adequate information for the FHWA decision -maker to make an environmentally sound decision regarding the proposed. Federal action. Specifically, the docu- ment does not consider the San Joaquin Hills Transportation Corridor's (SJHTC) strong relationship with other highway projects in orange County, particularly the Foothill (FTC) and Eastern (ETC) Transportation corridors. The DEIS also does not substantiate the need for the project or whether the project's objectives would be met. In addition, the DEIS alternatives analysis is inadequate. Moreover, the DEIS is inadequate in its, assessments of direct, indirect, and cumulative impacts to air and water quality, wildlife, and other resources as required by NEPA. EPA has previously recommended that MA evaluate the East- ern, Foothill, and San Joaquin Hills Transportation corridors in a single, comprehensive Environmental Iiapact Statement (EIS) (EPA letter to FHWA, March 17, 1989; and EPA letter to FHWA, January 24, 1990). All three corridors are located within the South Coast Air Basin, which suffers the nation's worst air quality. The basin violates the National Ambient Air Quality Standards (NAAQS) over half of the days of the year for several different pollutants resulting in serious human health impacts. Taken together, the corridors could pose serious cumulative impacts to the resources of a single geographic area. Although the document concludes that the three corridors would have a significant ef- fect on the location, pattern and rate of development in Orange County, it does not discuss the environmental impacts of all three corridors on Orange County. FRWA should have analyzed regional transportation impacts of there planned projects earlie in the regional transportation planning process. This was not done, but significant development has occurred and is planned to occur, which is now used as justification for the project need. 1-24 The DEIS does not effectively justify the need for the proposed project; nor is it clear whether the project objectives 1-2-3 would be met. Furthermore, the DEIS assumes that the project would affect route choice but not trip generation or destination E • WOi3ADN 01 6dOl 3H1 WOa.� ib:bl 16, it Ndf • • The availability of additional highway capacity could temporarily reduce traffic congestion and reduce travel times. EPA believes, however, that reduced travel times could encourage more trips, thereby satisfying latent demand and longer trips by making fur- 1-2-3 ther destinations more appealing. The DEIS does not address this possibility or the potential negative effects on demand manage- ment strategies that could result from reducing travel times in mixed flow lanes. In addition, the DEIS does not provide an adequate alterna- tives analysis, which is the heart of a-NEPA document. In accor- dance with the Council on Environmental Quality's Regulations for implementing the Procedural Provisions of NEPA (40 CFR Parts 1500-15017), the DEIS should explore and evaluate all reasonable alternatives and include reasonable alternatives even if they are not within the jurisdiction of the lead agency (40 CFR 1502.14). The document evaluates only two build alternatives, which are limited to the -existing right-of-way, and a no action alterna- tive. The differences between the two build alternatives are minor. The DEIS does not consider in detail any alternative that would reduce congestion without construction of this Corridor in this location. several non -alignment alternatives are dismissed for unsubstantiated reasons. Down zoning and other land use al- ternatives, transportation system management, mass transit, limited widenings of existing facilities, and other transporta- tion demand management strategies are individually dismissed without consideration of an alternative that would combine ele- ments from these various alternatives. While perhaps none of the alternatives would independently meet the project needs, FHWA needs to discuss whether.a combination of strategies might. The DEIS does not adequately analyze the.growth-inducing im- pacts of the project, particularly the cumulative impacts. Al- though a substantial portion of the land in the Area of Benefit was committed to development based on construction of this Cor- ridor, the DEIS concludes that growth in the area. would occur in much the same manner with or without the Corridor. As discussed in..our detailed comments, this claim is not substantiated in the DEIS. The DEIS does not address the significant market demand effects that the proposed Corridor could have on development in the area. 1-2-4 1-2-5 Further, the DEIS does not discuss whether the project threatens a violation of other Federal environmental laws, in- cluding the Clean Air Act and Section 404 of the Clean Water Act 1-2-6 (40 CFR 1508.27(b)(10)). The DEIS does not adequately discuss how the project would meet the conformity requirements as defined in the Clean Air Act, as amended. The SJHTC is not in a eil 3 son • ;t)Hrq W1/ 71AqN n t 4Hn I 7N I WnH a 7b:bT TF. it WHr federally -approved transportation improvement program as required • by the Clean Air Act. Furthermore, the proposed project could result in a significant increase in carbon monoxide (CO) con- centrations along the Corridor and could potentially cause ex- ceedences of the 8-hour CO standard. The DEIS does not discuss 1-2-6 how the proposed Corridor would result in, a reduction or elimina- tion of the severity and number of Co violations. In addition, the DEIS does not include a firm commitment to build and operate high occupancy vehicle (HOV) lanes, as required by the 1989 Air Quality Management Plan (AW). The proposed Corridor would require that fill material be discharged into waters of the United States, including wetlands, and, thus, would require a permit under Section 404 of the Clean Water Act from the U.S. Army Corps of Engineers. The DEIS does not discuss how the proposed project would comply with the 404(b)(1) Guidelines for Specification of Disposal Sites for Dredged or Fill Material ("Guidelines") (40 CFR 230), which is required for issuance of a permit. -EPA has met with MA in San Francisco on several occasions (November 1 and 6 and December 5 and 11, 1990) since our receipt of the DEIS in order to discus our concerns and specific issues regarding the SJHTC. EPA staff have also met in Los Angeles with several agencies, including FHWA, California Department of Transportation, San Joaquin Hills Transportation Corridor Agency, Southern California Association of Governments,. South Coast Air Quality Management District, and Orange County (December 10, 1990) to articulate 'the. document's deficiencies and suggest ways to augment and supplement the DEIS. Nevertheless, EPA is obligated to comment on the DEIS in the form in which it was released for public review. Any additional information that may be available but is not included in the document is not part of the DEIS. Given the large volume and potential environmental relevance of missing information, we have classified the DEIS as Category 3 - Inadequate Information. We strongly urge FHWA to prepare a tiered programmatic EIS, which would consider the interrelation- ship of all significant planned transportation projects in Orange County, adequately analyze all reasonable alternatives, and properly assess the direct, indirect, and cumulative impacts of these projects to air and water quality, wildlife, and other resources as required by NEPA. Subsequent, corridor -specific EISs should then be prepared for the transportation projects found to be necessary based on the findings of the programmatic EIS. Failing this, MA could revise the current DEIS to address the deficiencies identified in this letter and attached comments. 4 1-2-7 1-2-8 1�1 ) on ' t1tiHA I.1') i 7'AMKJ fl 1 qH') I 'AW I I.If1?I 4 7h ! b T T C . T 7 ww f 0 '­' In either case, opportunity for additional public comment wou be necessary prior to issuing a final EIS. If the issues raised 1-2-8 in this letter are not satisfactorily resolved prior to publica- tion of a final EIS, we may refer this project to the Council on Environmental Quality in accordance with 40 CFR Part 1504. We appreciate the opportunity to review this DEIS. We are available to discuss these serious issues with you further. Please invite your staff to contact Ms. Deanna Wieman, Director of the Office of External Affairs, at (415) 744-1015, or Dr. Jac- queline Wyland, Chief of the Office of Federal Activities, at (415) 744-1584. Please send five copies of the tiered or revised DEIS to this office at the same time it is filed with cur Washington, D.C., office. Sincerely, Daniel W. McGovern Regional Administrator Enclosures - cc: Lyle Renz, FHWA-Sacramento 9J hn Bates, FHWA-San Francisco eve Letterly, TCA William Woollett, Jr., TCA Walt H. Hagen, Caltrans - District 12 Judith Heyer, Caltrans - District 12 Barry Wallerstein, South Coast Air Quality Mgmt. District Anne Geraghty, California Air Resources Board Anne Baker, Southern California Association of Governments Augustine Anijielo, Regional Water*Quality Control Board Gerry Chalmers, California Coastal Commission Esther Burquette, California Department of Fish and Game Charles Holt, U.S. Army Corps of Engineers -LA District Kim Falzone, U.S. Fish and Wildlife Service Dick Sanderson, EPA HQ Office of Federal Activities Phil Lorang, EPA office of Mobile Sources 5 Soo ' ?St a W1 i gNgN n 1 S87 1 aH 1 wnx a F:b : b T T R, TT NHr £dly i ror� nta l il: Jac f or LI1C ru t L A& --lack of objections he EPA review has not identified any potential environmeental impacts requiring ubstantive changes to the prowl. MD -se review may have disclosed c,Qportunities for pplication of mitigation measures that, could be accomplished with no more than minor narges to the proposal: —Environmental Concerns he EPA review, teas identified environmental impacts that should be avoided in order to ully protect the environment.. corrective measures vey require changes to the preferred lternative or application of mitigation masures that can reduce the environmental impact. Sri would like to work with the lead agency to reduce these impacts. o—ewirorvental objections he EPA review has identified significant environmental impacts that mist be avoided in =der to provide adequate protection for the environment. Corrective measures may require ;ubstantial changes to tie preferred alternative or consideration of some other project lternative (including the no action alternative or a new alternative). EPA intends to Boric with . the lead agency to reduce these iTVacts. u--£nvirormental1y Unsatisfactory Ae EpA review has identified aQverse environmental impacts that are of sufficient magni- _ude that they are unsatisfactory from the standpoint of enviroramtal quality, pubic )ealth or -welfare. EPA intends to work with the lead agency to reduce these irQacts- If he potential unsatisfactory impacts are not corrected at the final EIS stage, this =posal will be rea=x=rk3ed for referral to the Counc:il on Environmental Quality (CEQ). Adeauacv of the ct state :ateoory 1--4xleauate MA eves the draft EIS adequately sets forth the environmental impacts) of the ,referred alternative and these of the alternatives reasonably available to the project or action. No further analysis or data collection is necessary, but the reviewer may ;UWest :he addition of clarifying language or infoaaation. :,'ateoory Z—Insufficient Information Me draft £ZS does not contain sufficient inf=ation for EPA to fully assess envlronmen=a, uuaacts that should be avoided in order to fully protect the environment, cc the EPA reviewer has identified new reasonably available alternatives that are within the spectrum of alternatives analyzed in the draf t EIS, which could reduce the es3 !r0nmeatal imP& is of the action: The identified additiasa information, data, analyses, or discussion should be included in the final EMS. Category 3—inadeoua to EPA does not believe that the draft EIS adequately assesses potentially significant ea iroc=aent:al i= acts of the action, or the EPA reviewer has identified new, reaseoably available alternatives that are outside of the spectrum of alternatives analyzed in the draft EIS, which should be analyzed in order to reduce the potentially significant environ- mental impacts. FAA believes that the identified adrditional iido=ticn, data, analyses, or discussions are of such a magnitude that they should have full public review at a draft stage. EpA does not believe that the draft EIS is adequate for the pmposes of the NEPA and,/or Section 309 review, and thus should be forma llY revised and made available for public comment in a supplemental or revised draft EIS. On the basis of the potential significant impacts involved, this proposal coed be a candidate for referral to the CEO. *Pram: M Manual 1640, 'policy and Procedures for the Peview of Federal Actions impacting the Environment.' 9 600 ' 39dd wn/ INON n I sun I qH I WON-4 t7tP : b T T R . TT NHr • San Joaquin Hills Transportation Corridor DEIS EPA Cowmen s January 1991 GENERA NEPA ISST7E5 1. EPA believes that the San Joaquin Hills Transportation Cor- ridor (SJHTC) DEIS is inadequate for purposes of compliance with the National Environmental Policy Act (NEPA). in fact, based on the lack of information provided in the DEIS, EPA believes that MA has not met its burden under NEPA to provide the FHWA decision -maker with adequate information so as to make an en- vironmentally sound decision regarding the proposed Federal ac- tion. EPA has previously recommended that FHWA evaluate the Eastern, Foothill, and San Joaquin Hills Transportation corridors in a single, comprehensive Environmental Impact Statement (EIS) .(EPA to Cannon, FHWA, March 17, 19s9; and EPA to Cannon, FHWA, January 24, 1990). All three corridors are in Orange County and, taken together, could pose serious cumulative impacts to the resources of a single geographic area. We commented in previous scoping letters that FHWA does not appear to be appropriately using the NzpA process to define the Federal role in meeting Orange County's transportation needs. In particular, there has been no tiered EIS to. evaluate al- ternative highways or other transportation modes which would relieve peak load congestion in this geographic area. Pursuant to 40 CFR 1502.20, 1508.25, and 1508.28, EPA believes that a tiered EIS should be used to evaluate the need for and environ- mental impacts of the three corridors and other related projects on a regional level. Subsequent, corridor -specific EISs should then be prepared for the transportation projectsfound nd to be necessarybased on the findings of the programmatic Fail- ing this., a revised or supplemental DEIS regarding the SJHTC, in- cluding a thorough cumulative impact analysis of all other re- lated projects planned in the region, should be prepared prior tc a final EIS in order to meet NEPA's objective of full public dis- closure of information with opportunity to -comment. The tiered or revised DEIS should thoroughly address EPA's•comments providec herein. 2. Local planning for the SJHTC has been ongoing for over four- teen years, far in advance of implementation of the NEPA process. According to the DEIS (page 6-11),-approval of 'the Corridor is not expected to greatly influence growth in the Area of Benefit (AOB) between 1990 and 2010 because the SJKTC has been assumed in all of the local governments' land use plans since the Corridor was adopted in the 1976 Master Plan of Arterial Highways. The DEIS states that 98.5 percent of the land in the AOB is committed to either existing or planned land uses and that development of 1 1-2-9 0T0'3sud W7/;N9 N 01 gH11 ;HI WnNA bb:bT TF. TT NNr San Joaquin Hills Transportation Corridor DEIS EPA comments January1991 9 the committed land is not contingent upon construction of the Corridor. It also reveals, however, that only 56.5 percent of the land is currently in "existing land uses" and that the other 42 percent is only in "planned land uses" that are not yet exist- ing (DEIS, page 6-9). However, according to page 2-30 of the DEIS, eliminating the demand for the Corridor by altering coun- tywide land use is considered infeasible because each General Plan in the AOB was premised on the Southeast Orange County Cir- culation Study, which included the SJHTC as a "significant regional transportation facility." According to page 6-11 of the DEIS, the major effect of the Corridor on growth in south Orange County occurred after the Corridor was identified on the Master Plan of Arterial Highways in 1976. The recent history of planning within Orange County effec- tively illustrates the need for earlier NEPA analysis of transportation planning by FHWA. A tiered NEPA document on the Regional Mobility Plan, for example, would provide Federal agencies with the opportunity to evaluate regional transportation, needs as a whole, rather than in piecemeal fashion. By the time the NEPA process was implemented for the: SJUTC, innumerable as- sumptions were represented as foregone conclusions, which biased the DEIS and prevented a thorough NEPA analysis. Irxal planning efforts should not preclude a thorough NEPA analysis, and the en- vironmental impact statement (EIS) alternatives analysis should not categorically dismiss alternatives :simply because.they are not already included in local plans. NEPA specifically requires a full examination of reasonable alternatives, including those which may require implementation by agencies other than the lead and cooperating agencies (40 CFR Part 1502.14). 3. At an inter -agency meeting on December 10, 1990, the San Joa- quin Hills Transportation Corridor Agency (TCA) suggested that this DEIS could not -encompass all of the information EPA recom- mends be included because document length is limited by Section 1502.7 of the Council on Environmental Quality's Regulations for Implementing the Procedural Provisions of NEPA ("NEPA Implementa- tion Regulations"). MA should keep in mind that the page limits given in section 1502.7 are not absolute limits. In light' of the broad geographic scope of the proposed project, par- ticularly in relation to other projects in the area, and the tiered nature of the analysis required, we do not believe that it is appropriate for FHWA to strictly adhere to the "normal" limit of 300 pages. 2 1-2-10 1-2-11 C I10'39dd W0/3X9 N 01 Sl0% 3H1 WOad Sd:bt 16. It Nbf 0 l�J San Joaquin Hills Transportation Corridor DEIS 32 =Ments January 1991 4. The DEIS (page s-5) states that EPA is a cooperating agency for the SJKTC EIS. EPA is not a cooperating agency on this project, and this statement should be removed from the document. If EPA is solicited for and accepts cooperating agency EPA and the lead agency negotiate responsibilities and formalize them in a memorandum of understanding (MOU). As stated in FHWA's "Guidance on Cooperating Agencies," prepared December 23; 1987, lead and cooperating agencies should work out specific respon- sibilities on each project. An MOU between FHWA and EPA was never prepared. The extent of our involvement as a cooperating agency could range from submitting early scoping comments to ac- tually writing portions of an EIS. EPA was never given the op- portunity to review a pre -draft of the EIS, which is encouraged in FHWA's "Guidance on Cooperating Agencies." Furthermore, al- though we submitted scoping comments on the SJHTC, the DEIS fails to respond to several of these comments. 5. In a December 23, 1987, memorandum from FHWA Director, Office of Environmental Policy, to Regional FEWA Administrators, Ali Sevin stated that one NEPA document should be used to integrate the requirements of all other Federal permits and any State and local environmental regulations. The SJHTC DEIS does not ac- complish this, however, as is illustrated in our comments regard- ing the project's apparent failure to comply with EPA's 404(b)(1)j Guidelines for Specification of Disposal Sites for Dredged or Fill Material (40 CFR 230) (see discussion below). Although the project would require Clean Water Act Section 404 permits issued by the u.S. Army Corps of Engineers, we understand that. the Corps was not provided with a pre -draft or draft EIS for review. This lack of coordination with the Corps, which is also identified in the DEIS as a cooperating agency, does not lend itself to timely and integrated review of one "comprehensive" environmental docu- ment. We wish to encourage FHWA to solicit earlier involvement from EPA and other agencies on future NEPA projects. 1-2-12 1-2-13 6. In a December 11, 1990, meeting with Dr.'Jacquelint Wyland, Chief of EPA Region 9's Office of Federal Activities, John Sates (FitWA Region 9) stated that MA would not consider the Record o Decision (ROD) resulting from this EIS as the formal approval or denial of the proposed action. It is not clear, therefore, what kind of decision FHWA will document in -the SJHTC ROD. While we 1-2-14 understand that a favorable NEPA decision is a necessary but not a sufficient basis to approve a FHWA action, we believe an un- favorable environmental analysis should preclude the proposed Federal action. The tiered or revised DEIS-should identify MA's objectives in implementing the NEPA process and the pur- pose of a ROD on this project. 3 2 T 0*' Sdel W1/gNgN n I SHn I qW 1 WnN 4 gb : b i i R. T T NHf San Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 7. In a November 6, 1990, meeting with EPA, FaWA told EPA that, in the event that Federal funding is not requested by the local sponsors, FEWA would still need to approve the I-5 interchange tie-in to the Corridor. FEWA stated that the agency often con- siders such tie-ins either in a Finding of No Significant Impact (FONSI) or as a categorical exclusion from. the NEPA process. In reviewing FHWA's list of actions that could be categorically ex- cluded from NEPA, EPA has found no mention of interstate tie-ins (23 CFR 771.117). In fact, pursuant to 23 CFR 771.117, the fact that a NEPA document has already been prepared and has indicated that serious environmental impacts could. result would disqualify any related Federal action from a categorical exclusion. Moreover, pursuant to 23 CFR 771.111(f), the action evaluated in an EIS shall connect logical termini and be of sufficient length to address environmental matters on a broad scope as well as have independent utility or independent significance. The I-5 inter- change would not have independent utility if the SJHTC were not built, and the project objectives would ultimately be the same as those stated in the DEIS. Given the scope of the projectes potential environmental impacts, a thorough NEPA analysis of the entire Corridor would be warranted. A decision to categorically exclude the interstate tie-in from the NEPA process would be ua- acceetable in the case of the SJHTC project jsee Davis vi Coleman, 521 F.2d 661 (9th Cir. 1975)). Inadequate Justification for Proiect 1-2-15 The DEIS identifies two primary project objectives: 1) Al- leviate existing and projected peak period traffic congestion on the regional circulation system; and 2) Minimize regional "through traffic" use of arterial highways. Secondary objectives include providing an alternative access route to the University of California - Irvine (UCI), relieving traffic on State Route 1 (SR-1) and other roads, and providing access from inland areas to the -recreational areas along the coast and various open space and greenbelt areas (pages S-4 to S-5). In addition to inadequately analyzing Orange County's transportation needs and the need for this particular project (see pages 1 and 2 of this enclosure), the DEIS fails to effec- tively justify the stated project need. for relieving peak period congestion on I-405 and I-5. Moreover, it is not clear whether 1-2-16 the project objectives would be met. The data provided in the DEIS section "Purpose and Need for Region" only include current and projected average daily traffic (ADT) volumes and level of service (LOS) based upon ADT, not peak period information. 4 0 0 610'?9Hd WI/gAgN nl SH01 qHI WON -I 9b:b1 1S. IT NHf San Joaquin Hills Transportation corridor DEIS EPA Comments January 1991 Therefore, with the information provided, it is not possible to judge exactly how the project would affect peak congestion or whether the project objectives are met. More importantly,- while the LOS (based on ADT) on I-405 is projected to improve noticeably With the project, most of the section of I-5 in ques- tion would remain at LOS E or F. This MS is not acceptable ac- cording to the DEIS. T Specifically, Table 1.3.A (page 1-5) presents ADT and LOS information for I-405 and I-5, with and without the Corridor. Traffic on the portion of I-405 that parallels the SJHTC cur- rently operates at LOS E or F. The DEIS asserts that, in 2010, I-405 would operate at LOS C through LOS F without the Corridor and LOS C or D with the Corridor. I-5 currently operates at LDS F for the between I-4o5 and the Corridor and LOS E just south of the proposed SJHTC connection. Based on information in Table 1.3.A, without the SJHTC A= volumes would increase, but LOS . would apparently remain about the same. With the Corridor, ADT would reportedly increase south of the Corridor (no change in LOS) -and decrease parallel to the Corridor, with LOS improving to C, D, or E in some locations, but remaining at F for over half of the length parallel to the Corridor. The DEIS-estimates that 'congestion on I-5 would still occur during three to four hours per day (page 5-9). While the DEIS does not state which hours the highway would still be congested, it is likely that these would be peak periods. Therefore, con- trary to the DEIS's conclusion, the project -objective of reducing peak period congestion would not necessarily be met. In addition, the data in Table 1.3.A. assume a toil -free condition on the SJRTC in 2010. Under toll -operations, which are proposed by the local sponsors, volumes on the SJHTC could be 10-20% lower (page 5-4). For the period while tolls are in place, traffic volumes on I-405 and I-5 would be higher, and, therefore, the congestion relief benefit is overstated. Further, the.document does not clearly state when tolls would be abolished. ALTERNATIVES ANALYSIS 1-2-16 The DEIS does not provide an adequate alternatives analysis. The alternatives analysis in the DEIS only evaluates two build alternatives, which are limited to the existing Right -of -Way 1-2-17 (ROW), and a no build alternative. The differences between the two build alternatives are minimal. Both are essentially multi- lane, freeway -type roadways with large medians that can accom- �� 0 to ' 39tid W0/ 3ADN 01 SU01 3H1 W02i.� 4V : D t 16. 11 NUf' San Joaquin Hills Transportation Corridor DEIS EPA comments January 1991 modate HOV lanes in the future. The DEIS does not present an al- ternative that would reduce congestion without building this par- ticular road in this location. Instead, it discounts several 1-2-17 non -alignment alternatives and withdraws them from consideration. We believe the DEIS does not clearly justify withdrawing these alternatives. 1. Alternative Land Use Concepts. one non -alignment alternative that is withdrawn is "Alternative Land Use Concepts." The DEIS refers to a study and Environmental Impact Report (EIR), prepared pursuant to the California Environmental Quality Act, that evaluated one alternative which did not :include the Corridor but considered alternative land use patterns. Although the DEIS does not include an adequate description of this study and the alter- native, the DEIS concludes that the alternative is infeasible. This conclusion is not substantiated by information in the DEIS. The study referred to was conducted fifteen years ago, and its use therefore seems inappropriate. More importantly, the logic behind the conclusion in the DEIS is flawed and circumvents NEPA. The DEIS states that every general plan in the area assumes that the Corridor will be built and, therefore, the only land use al- ternative, besides that which is already planned, would be down zoning. In other words, by assuming that the Corridor would be built and serve proposed development, no other alternative is possible. This completely circumvents the purpose of the NEPA alternatives analysis. NEPA requires a thorough examination of reasonable alternatives even if they aria not within the lead agency's jurisdiction (40 CFR 1502.14). Furthermore, down zoning is not the only land use alternative. Another land use alterna- tive could involve jobs/housing balance and/or increased den- sification for improved transit service. The DEIS gives four "significant' reasons why down zoning is not feasible. EPA does not believe these reasons are sufficient to withdraw down zoning as an alternative. a. .The DEIS argues that down zoning would reverse ten years of planning, which would undermine General Plan law. by creating in- consistencies between the land use and circulation elements of the general plans. This statement is misleading. Both the land use and circulation elements of general plans could be amended to accommodate a different land use and transportation alternative. The DEIS gives no reason why one would be revised and not the other. General Flans are amended on a regular basis. The DEIS does not explain how General Plan law would prevent consideration of an alternative land use. 6 1-2-18 1-2-19 • 0 0 St0'39ud Wni'ADN 01 StlO1 3H1 WOa_� 817:171 IS- it NHf 0 San Joaquin hills Transportation corridor DEIS EPA Comments January 1991 b. The DEIS (page 2-30) states that, "(because each city's General Plan reflects different functional and economic inter- relationships, down zoning would probably h«ve a greater socioeconomic effect on some jurisdictions than others. There- fore, a coordinated regionwide reduction in planned growth in unlikely." This conclusion is too speculative and is not sup- ported by facts or examples in the DEIS. while regionwide coor- dination is difficult, it is not impossible. In fact, the TCA is an example of such coordination: it is a joint powers agency formed between the cities along the Corridor and the County that could form the basis for such a regional land use effort. The EIS must include reasonable alternatives even if they are not within the jurisdiction of the lead agency (40 CFR 1502.14). Furthermore, the possibility that various jurisdictions would be affected differently is not a sufficient reason to dismiss down zoning. _ c. Much of the area is governed by existing development agree- ments and/or vesting tentative maps. According to the DEIS, changing the land uses would be subject to various remedies, "which would include specific performance and/or financial responsibility" (page-2-30). But, the tiered or revised DEIS should acknowledge that construction of the Corridor also in- volves substantial costs. A land use alternative should not be dismissed simply because it may involve financial costs. Fur- thermore, down zoning is not the only land use alternative. d. Twenty percent of the traffic is expected to be through traf-I fie. The DEIS concludes that a land use alternative affecting this traffic is unlikely. However, while a land use alternative may not address this portion of the traffic, other alternatives, such as rail, might. Also, the .DEIS .does not state whether through traffic is a substantial`gvrtion of the traffic growth causing the anticipated congestion, or whether the current cir- culation system is adequate for through traffic. 2. .Transportation System Management. Another non -alignment alternative withdrawn from consideration in the DEIS is "Transportation System Management (TSM)." This alternative in- cludes facilities and activities which maximize the efficiency ofl the existing transportation system. The DEIS concludes that "an alternative solely using TSM on the existing circulation system would not meet the project objectives" (page 2-31). However, the TSM measures discussed only include HOV lanes and transitwaya. There should be a discussion in the tiered or revised DEIS of more TSM measures such as "smart streets", improved signal timing, message signs, and incident management. 7 1-2-20 1-2-21 1-2-22 1-2-23 9I0139ud WJi3ADN 01 SdOl 3H1 WOa.� Bbsbl 166 It Ntif San Joaquin Hills Transportation Corridor DEIS FyPA Comm nts Jant ary 1991 3. Mass Transit Alternatives. The DEIS dismisses mass transit alternatives. These alternatives were dismissed based on a study of providing public transportation along the Corridor, which con- cluded that HOV lanes was the best method of providing transit capacity. The DEIS contains a summary of the SCAG Regional Mobility Plan that identifies the Corridor as having medium tran- sit capacity on HOV lanes. The DEIS's transit analysis then dis- cusses the possibility of providing transit in the median in the future. This alternatives analysis, however, does not consider transit along parallel routes, particularly I-5 and I-405. In particular, the tiered or revised DEIS should analyze the ability of planned transit projects, including Orange County Transit District's proposed transitway system along. 1-5, I-405, SR-57, and. SR-55 and the LOSSAN Corridor along I-5, to carry Cor- ridor traffic. The DEIS does not clarify whether these projects were assumed in the traffic modeling, as they are not listed on Table E-A in Appendix E or in section 2.10, Related Transporta- tion•Projects. The tiered or revised DZIS should analyze expand- ing these and other planned transit projects, as well as other reasonable transit improvements, as part of a non -alignment al- ternative. 4. Alternatives to widen Other Routes. The DEIS analyzes and dismisses alternatives to widen SR-1, I-405 and I-5. On page 2-35, the DEIS states that, "[ajs shown. in Table 2.8..A, I-405/I-5 would need up to six additional lanes beyond the currently ap- proved two HOV lanes in order to maintain travel service com- parable to conditions on the freeway when the Corridor is assumed." However, Table 2.8.A indicates that only zero to two additional lanes would be required on 1-5 without the Corridor as opposed to with the Corridor. A maximum of four additional lanes (in one location) and an average of two would be needed on I-405, with -some locations needing no additional lanes. The discrepancy stems from the fact that I-405 and I-5 would need additional lanes even with the Corridor in place. The discussion should make this distinction and also state what level of service is as- sumed for these calculations. 1-2-24 1-2-25 5. A Combination of Alternatives. The tiered or revised DEIS should consider an alternative that includes optimal combinations of land use, TSM, transit, limited wid.enings of other facilities, and other demand management (TDM) strategies. While each option 1-2-26 individually may not meet project objectives, a combination of the strategies might. Several statements throughout the DEIS refer to components suitable to such an alternative. However, 8 0 0 0 L10'3SUd W0i3ADN 01 SdOl 3H1 WONT 6bab1 16, 11 Nbf • 0' San Joaquin Hills Transportation Corridor DEIS Epp, Comments January 1991 there is not enough information to show whether such an alterna- tive is feasible. For example, the DEIS (page 2-40) states that 30% of the projected daily travel demand of 156,00o vehicles for the Corridor could be accommodated by a six lane arterial. On page 2-55, the DEIS briefly mentions plans to widen I-5 from I-405 to SR-1. In discussing the land use impacts if the project were not built, the DEIS concludes that "this would require major improvements to the arterial highway system (including super streets) and possible reorientation of land use patterns" (page 6-14). Technical Report No. 8 also mentions improvements to ar- terials that would not be necessary if the Corridor is built. An alternative that should be considered would combine these road improvement projects with the transit, land use, TSM, and TDM measures discussed above and in the DEIS. INDIRECT AND CUMULATIVE IMPACTS 1. The DEIS does not.adequately analyze the growth -inducing im- pacts of the project, particularly the cumulative impacts. The document cites Orange County's conclusion that growth would occur "much in the same manner with or without the Corridor" (page 6-11). This is based upon evidence that 98.5 percent of the land in the AOB is already "committed" to either existing or played land uses. It is stated on page 6-9 of -the DEIS, however, at only 56.5 percent of the land is currently in "existing land uses," while another 42 percent is only in "planned land uses" that are not already existing. Land that is "committed" to fu- -ture planned -uses is subject to approved development agreements, tentative maps, or permanent dedicated open space. The DEIS does not discuss whether the currently planned demand for that level of growth is independent of this project. Access to the area would be significantly altered without this project, which could affect the market demand for develop- ment. Simply because a certain amount of development is approved does not preclude a developer from reducing -project size to reflect market forces. In fact, the DEIS states that "the major effect of the Corridor on growth in south Orange County occurred after the Corridor was identified on the Master Plan of Arterial Highways in 1976. Since 1976, a substantial portion of the Area of Benefit has been the subject of considerable planning efforts" (page 6-11). These statements reveal that the planned develop- ment occurring in the area is a result of this project, and, without this project, that development would not have occurred to the same extent. Furthermore, the DEIS does admit that develop- ment of transit in the median "is likely to increase the feasibility of higher density development" (Page 6-11). The 9 1-2-26 1-2-27 8 T 0' 99Hd W71g1AgN n 1 SH1 1 ;H 1 WOM A 01cz: b T T F. Ti NHr San Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 tiered or revised DEIS should explain why, if improved transit access increases the demand for development over that currently 1-2-27 planned or committed, limiting access would not reduce the demand. 2. Currently, 42 percent of the land in the AOB is "committed" to specific future land uses (DEIS, page 6-9), but is as yet un- developed. This is a significant portion of the AOB, especially considering that much of the land use allocation was planned with and possibly induced by the assumption that the Corridor would be built. The cumulative impact analysis in the tiered or revised DEIS should indicate the proportions of this 42 percent that are planned for open space, residential, and commercial/industrial uses. The tiered or revised DEIS needs to assess all potential environmental impacts associated with the planned growth as well as any foreseeable growth that is as yet unplanned. The DEIS has attempted to do this, but the summaries provided in Appendix E of the DEIS are inadequate for the purposes of assessing impacts -to air and water quality, vegetation, wildlife., wetlands, riparian areas, and energy and service resources in these areas. The tiered or revised DEIS should include acreages of wetlands, riparian areas, and sensitive habitats that would be lost; pol- lutants and loads to surface water from, construction -and long- term area use; specific impacts to air quality from non -mobile sources; and energy and utility needs, including.landfill and sewer capacity. 3. EPA believes that if the SJHTC were constructed, its area of impact would be much more extensive than the DEIS reflects. The proposed Corridor's Area of Benefit (AOB), depicted on Figure 6.2, essentially encompasses the area between 2-405/1-5•and the coast from State Route 55 (SR-55) south to the San Diego County line. The AOB for this Corridor is not independent of the AOBs for I-405, I-5, SR-55, SR-91, or the planned Foothill (FTC) or Eastern (ETC) Transportation corridors. By alleviating conges- tion on the existing routes, the SJATC would influence their respective AOBs and, in turn, other adjacent AOBs. Taken together with these existing routes, the planned Foothill and Eastern corridors could greatly influence growth in other areas. The DEIS concludes that "development of all three corridors may also encourage growth in areas currently not planned for urban development, particularly in areas directly affected by the FTC and ETC. Development of all three corridors may also be a factor in inducing growth in portions of Riverside, San Bernardino and San Diego Counties as the transportation corridors network would provide improved access into areas in Orange County with siq- nificant employment centers" (page 6-14). The specific potential) 10 1-2-28 1-2-29 0 6i0'=9dd WO/IAC)N nl Sd'1 IHl WOa_� OS:bI 16, 11 Nur C 0 San Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 impacts of this growth to air and water quality, riparian and wetland habitats, vegetation and wildlife, energy resources, and services in these areas should be discussed in detail. EPA understands that draft environmental impact reports and DEISs regarding the Foothill and Eastern Transportation corridors will be released in the near future. Since it is a reasonable assumption that much of the information on the direct, indirect, and cumulative impacts of these projects is available, we recom- mend that the information be incorporated into tiered or revised DEIS. 4. The lack of an adequate discussion of the emulative impacts upon air quality is problematic, given the DEIS's conclusion that 'the three corridors will have cumulatively significant growth facilitating effects. ... [23t can be anticipated that the cor- ridors will, cumulatively, have a significant effect on the 4o eloa. loca- tion, pattern and rate of development in the County" (page Appendix E). The cumulative impacts analysis for air quality (page 7-4) simply refers to the primary air quality section and summarizes that the projects have been included in the regional growth projections. This does not address the cumulative growth impacts identified in the statements cited above. Furthermore, it appears that the air quality section only accounts for the emissions from travel on the Corridor, and not the other impacts of planned (or unplanned) development. These impacts should be addressed in the tiered or revised DEIS. 5. Potential cumulative impacts to air quality from the Eastern Transportation Corridor would include minor long-term regional and subregional air pollutant emissions (DEIS, Appendix E, page 4). The tiered or revised DEIS should identify the types, sources, and amounts of these air pollutant emissions and discuss how they factor into regional air quality. In.addition, the tiered or revised DEIS should discuss how any adverse air quality impacts could be mitigated. AIR.OUALITY ISSUES Air Qu litY Impact Analysis The DEIS concludes that the project would improve air quality in the year 2010 by reducing carbon monoxide (CO), oxides of nitrogen (NOx), total organic gases (TOG), and particulate emissions (14.7%, 2.5%, 12.4%, and 0.4%, respectively). This conclusion is based upon the assumption that the project would not affect the number of trips made, but would reduce vehicle- 11 1-2-29 1-2-30 1-2-31 080 ' ?9dd W1i gNL)N n 1 SH11 qW1 WnN4 TC:bT TC. 11 wHr San Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 miles travelled (VMT) because people could take less circuitous routes. Furthermore, the DEIS claims that congestion would be reduced -and speeds would increase, which would reduce co and TOG emissions. The DEIS also projects co concentrations at 29 locations along the Corridor for 1995 with initial. operations of six mixed flow lanes and for 2010 for both alternatives. Current CO levels were measured at 8 parts per million (ppm) for one -hour con- centration and 3.4 ppm for eight -hour concentration (second highest maximums). The National Ambient Air Quality Standards (NAAQS) for one- and eight -hour concentrations of CO are 35 ppm and 9 ppm, respectively. The projected 1995 eight -hour CO levels along the Corridor range from 4.3 to 8.7 ppm. At 18 of the loca- tions, co levels are projected to be higher in 2010 than in 1995 with either build alternative. Predicted eight -hour concentra- tions of CO in 2010 range from 4.7 to 8.9 ppm. several problems exist with the air quality analysis presented in the DEIS: 1. The DEIS assumes that the project would affect route choice but not trip generation or destination. By providing an alterna- tive route and reducing congestion -on some existing facilities, travel times could be reduced. This reduction in time could en- courage shifts in travel demand. For Example, the time savings between a free -flowing, high -occupancy vehicle (NOV) lane and a congested mixed -flow lane could affect demand by encouraging NOV use (Draft Technical Memorandum TM 2-6) San Joaquin hills July 1990, page 5, in volume II of DEIS Technical Studies). 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 ap- pea l ing . . EPA's scoping comments on the NOI requested that the DEIS address this issue. The response in the DEIS appears in Techni- cal Report No. 8, TSI4/TDM Implementation Strategies Reoort, pages 33-35. However, the response only addresses the growth induce- ment issue, not effects on travel demand independent of growth. The tiered or revised DEIS should directly respond to the follow- ing question: 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 af- 12 1-2-32 0 i s 120'3Ddd WOi3ASN 01 SdOl 3H1 WOa.� ZS:bi 16, 11 Ndf C 0 0 fect travel (not induced tions? San Joaquin Hills Transportation Corridor DEIS EPA comments January 1991 demand from existing and planned/committed land uses 1-2-32 growth), specifically trip generation and destina- 2. The DEIS does not adequately examine the effect of the 1 project on made choice. As discussed above, 'the DEIS acknow- ledges that the reduced travel time on HOV lanes might encourage .HOV use. Analogously, by reducing travel times on mixed flow lanes (for example, I-405 and some arterial roadways), the project could discourage transit/HOV use. This impact is not analyzed. The DEIS includes a short paragraph entitled "Impacts to Other Modes of Travel" (page 5-13). however, the discussion simply identifies the provision of express bus service on the Corridor. Again, EPA's scoping comments on this issue were not addressed: "The DEIS should discuss the potential negative effect of the facility on demand management strategies' (page 6 of at- tachment, EPA to Cannon, FHWA, 1/24/90). The tiered or revised DEIS should directly address the potential mode shift effects of reducing travel times for mixed flow lanes. In particular, Technical Report No. 8 states that "if general purpose lanes are operating at Level of Service D or bet- ter, little time incentive is provided by a free -flow HOV facility and most benefits -of HOV facilities are lost" (page 18). Table 1.3.A in the DEIS (page 1-5) indicates that in 2010 with• the SJHTC, I-405 from I-5 to Bristol Street will operate at LOS C and D, compared to current LOS of E or F. HOV lanes opened on this section in early 1990 and have been called a "tremendous success" by Caltrans (Orange County RaCister, August 31, 1990). HOV lanes are an integral part of the regional air quality strategy. However, based upon the information in the DEIS-, it appears that the SJHTC could negate the benefits of the I-405 NOV lanes by improving LOS to C and D. The tiered or revised DEIS must address this issue and the potential negative effects on air quality. 1-2-33 3. The DEIS states that the emissions analysis uses "the latest Caiifornia specific vehicular air pollution emission factor model (EMFAC7D)" (page 4-34). However, Appendix A of the Air Quality Study (Technical Report No. 3) explains that, in fact, EMFAC7C was used, and a correction factor was applied to account for the difference between versions C and D. The correction factors were 1-2-34 based upon an April 28, 1988, memorandum from the California Air Resources Board (CARS) presenting the expected percent change be- tween ENFAC7C and EMFAC7D for the years 1987 and 2000. Since the analysis year in the DEIS is 2010-, the applicability of these correction factors is questionable. In addition, the tables of 13 220' 39tid WOi3NON 01 SUDi 3H1 WOa_� 29:bt 16. it NHr San .Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 emission factors generated by EHFAC7C reveal that the CO emis- sions were increased by-16 percent according to the CARE memo, 1-2-34 but the other pollutants, TOG and NOx, were not adjusted. Fur- thermore, the latest such model is now EHFAC7E. The tiered or revised DEIS should address these discrepancies. 4. The project would result in a significant increase in CO con- centrations along the Corridor (Table 4.4.B). While the analysis in the Air Quality section (Section 4.4) does not predict that a violation of the NAAQS would occur, at some locations projected levels are close to the 8-hour standard of 9 ppm (e.g. 8.4 and 8.9). Given that the DEIS does not account for induced trips or growth and employs a population projection that is at least five percent lower than SCAG's projections (page 6-12), these levels may be understated. Furthermore, in the Traffic and ciraula ion section of the DEIS (Chapter 5), CO levels are estimated using a never land use and traffic model, OCTAM II. Using this model, the DEIS predicts that, in 2010, the federal-8-hour co -standard would be exceeded in at least two locations. This is an unaccep- table impact, particularly because the Clean Air Act attainment deadline for CO for the region is December 31, 2000. 5. The DEIS does not adequately analyze: the air quality impacts of toll -free conditions along the proposed Corridor. The DEIS does -not state`whethez toll or toll -free: conditions were modeled for the regional air quality analysis (Table 4.4.A). The docu- ment does state that for the 2010 CO analysis, traffic volumes were based on no -toll projections, except for the mainline toll plaza (shown in Table 4.4.B). In Table 4.4.C1 eleven locations are analyzed for toll versus toll -free CO conditions. However, the CO concentrations for toll conditions are identical to the levels for those locations in Table 4.4.B, which are supposed to be toll -free conditions (except for the mainline toll plaza). This discrepancy must be corrected. If, in fact, the CO levels in Table 4.4.B reflect toll con- ditions, the difference in CO levels without tolls could be sig- nificant, since the DEIS states that traffic would be 10-20 per- cent higher without tolls (page 5-4). With higher traffic levels, CO levels would likely increase:, with the possible excep- tion of the locations near toll plazas that would be removed. Techrdical Report No. 3 claims that the "small differences betveeni toll and toll free traffic volumes ... fall within the tolerances of regional traffic projection models" (pages 22-24). A 10-20 percent difference in traffic is significant. If a 10-20 percent difference is indistinguishable in regional traffic models, the justification for this project does not appear demonstrable: 14 1-2-35 1-2-36 0 0 • C20 ' 39tid WOi 3NON 01 'Sd% 3H1 WOa .� ES : b 1 16, 11 Nt r 0 San Joaquin Hills Transportation Corridor DEIS EPA Cowmen s z7arm-ary 19111 with only one exception, the predicted reductions in I-405 and I-5 traffic attributable to the Corridor all fall below the 20% level (Table 1.3.A). In fact, of the 17 locations where the DEIS predicts reductions in average daily traffic (AM), below 10 percent. Table 1.3.A also shows that a reduction in AM between 10 and 20 percent can result in level of service (LOS) improving from F to D or C. 6. The DEIS does not clearly explain assumptions used in the traffic analysis. In particular, the document should state whether the transportation measures in the Air Quality Management Plan were assumed in the modeling. If these measures were as- sumed in the analysis, -the tiered or revised DEIS should identify the specific numerical assumptions. In addition, the DEIS should explain whether the neighboring jurisdictions are implementing the measures to verify -whether the assumptions are reasonable. If these measures were not assumed in the modeling, the document should provide some analysis of how these measures would decrease demand for the Corridor.. The measures could also be incorporated into -an alternative, as discussed previously. conformity Issues The DEIS does not adequately discuss how the project would meet the conformity requirements as. defined, in the Clean Air Act, as amended. Under -section 176(c) of the Clean Air Act, no federal agency may approve or support in any way any activity that does not conform to an air quality implementation plan. Similarly, metropolitan planning organizations (MPOs) cannot ap- prove projects that do not conform. The 1990 Clean Air Act Amendments further define conformity to mean that the activity will not "(i) cause or contribute to any new violation of any standard -in any area; (ii) increase the frequency or severity of any existing violation of any standard in any area; or.(iii) delay timely attainment of any standards or any required interim emission reductions or other milestones in any area." Further- more, the 1990 Amendments have specific conformity provisions ap- plicable to transportation plans and programs, and the Amendments give States until November, 1992, to revise their State Implemen- tation Plans (SIPs) to include criteria and procedures for as- sessing the conformity of such plans and programs (Section 176(c)(4)(C)). Until the SIP can be changed to satisfy these new requirements, the Amendments have provided interim conformity criteria in Section 176(c)(3), which provides in part that: 4_1 1-2-36 1-2-37 1-2-38 V20'39tid WOi3NON 01 SdOl 3H1 WOa.� bS:bI I6, It Nur San Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 Until such time as the implementation plan revision referred to in paragraph (4)(C) is approved, conformity of such plans, programs, and projects will be demonstrated if -- (A) the transportation plans and programs-- (i) are consistent with the most. recent estimates of mobile source emissions; (ii) provide for the expeditious implementation of transportation control measures in the applicable implemen- tation plan; and (iii) with respect to ozone and carbon monoxide nonattainment areas, contribute to annual emissions reduc- tions consistent with sections 182(b)(1) and 187(a)(7) [of the Clean Air Act]; and (B) the transportation projects-- (i) come from a conforming transportation plan and program as defined in subparagraph (A) or for.12 months after the date of the enactment of the Clean Air Act Amend- ments of 1990, from a transportation program found to con- 1-2-38 form Within 3 years prior -to such date of enactment; and (ii) in carbon monoxide nonattainment areas, eliminate or reduce the severity and number of violations of the carbon monoxide standards in the area substantially af- fected by the project. Because the Amendments became effective just a few months ago, the applicable SIP has not yet been changed to provide con- formity criteria in accordance with the Amendments. Therefore, in order to demonstrate conformity, the interim criteria -quoted above must be used. With respect to the first criterion for project approval (Section 176(c) (3) (B) (i)), the current federally approved plan and program for the region were approved prior to the Amendments and, therefore, conformity was not demonstrated using the criteria in subparagraph (A). Therefore, the second clause of subparagraph (i) would apply (i,e., that the project come from "a transportation program found to conform within 3 years prior to such date of enactment"). 1." According to FHWA (personal communication between Jeanne Dunn Geselbracht, EPA, and Jay Bates, FAWA, and between Ms. Geselbracht and Gary Jacobi, FHWA) the project is not in the cur- rent, federally -approved transportation improvement program (TIP) for the SCAG region (SCAG Regional Transportation Improvement Program FY 1990-1994). We understand that SCAG and TCA believe the project is in the TIP. Unless inclusion can be demonstrated, this project should not bs approved or funded by the FHWA until and unless the TIP is amended to include the project or the project is included in the next TIP. 16 1-2-39 0 S20'39dd WOi3ADN 01 SdOl 3H1 W08J tPGsb! T6. 11 Ndr San Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 0 2. The DEIS does not demonstrate that the proposed Corridor would result in a reduction or elimination in the severity and number of Co violations. The document shows a significant in- crease in Co levels along the Corridor compared to current condi- tions, and a reduction in 2010 CO emissions in the larger area affected by the project compared to the no project alternative. Under the new Act, the CO attainment deadline for the region is December 31, 2000. This should be considered in the conformity demonstration by including a CO analysis for the year 2000. 3. Because FHWA has not taken final action nn this project, the project must demonstrate conformity using the new Clean Air Act definitions and criteria. EPA understands this was not possible in the DEIS because the Amendments were enacted after the DEIS was issued. However, this must be done in the tiered or revised. DEIS.. The DEIS attempts to demonstrate conformity with both the 1979 State Implementation Plan (SIP) and the 1989 Air Quality Management- Plan (AQXP) by showing that 1) the Corridor would help to implement transportation control measures (TCMs) in the 1979 SIP; and 2) the analysis follows and conforms with the SCAG Con- formity Procedures in the 1989 Air Quality Management Plan (AQMP). Even if conformity with the 1979 SIP and 1989 AQMP were a sufficient demonstration, the DEIS does not make this • demonstration for the following reasons. a. Conformity with the 1979 SIP cannot be demonstrated. As the DEIS admits, the Corridor was not incorporated into the 1979 SIP, nor does the DEIS use the 1979 SIP population projections (page 3-14). Therefore, the project could not demonstrate consistency with the 1979 SIP emissions projections, which would be necessary to show conformity. Nonetheless, the DEIS claims that the project will help implement several TCiKs in the 1979 SIP. As discussed elsewhere in these comments and in our previous scoping comments regarding the Eastern Transportation Cotrjdor (EPA to Cannon, FHWA, March 17, 1989), EPA believes that the project could have a negative impact on TCMs such as HOV facilities on freeways and other trip reduction programs. with the 1989 "Under regulations promulgated by the Federal Highway Ad- ministration, a transportation project is in conformity with 1-2-43 the SIP if that project is a Transportation Control Measure from the SIP. Since the Corridor is part of the SCAG- prepared Regional Mobility Plan, the highway improvement b. The DEIS (page 3-15) also analyzes conformity AQMP in relation to Federal approvals: 1-2-40 1-2-41 17 1-2-42 920'39dd WOi3A SN 01 SU01 3H1 WON.d S'StbI IS, 11 Nbf' San Joaquin Hills Transportation Corridor DEIS EPA Ca ents January 1991 portion of which is a TCH from the :1989 AQMP, the Corridor is included in the SLAG prepared Regional Mobility Plan which has been identified as a TCM in the 1989 AQMP." While not explicit, these statements seem to imply that the project would conform by virtue of being included in the AQMP. Since the AQMP has not yet been approved as part of the SIP, and EPA, in its September 5, 1990, Notice of Proposed Rulemaking (55 Federal Register, 36458-36576), did not propose to include TCM 13 (which includes this project) in the SIP, this conclusion is not justified. Federal approval from FHWA will now require that con- formity be determined in relation to the: 1990 Clean Air Act Amendments, as discussed above. Any other Federal approval (e.g., by the Army Corps of Engineers) will also require this demonstration of conformity. c. In addition, the DEIS analyzes conformity with the 1989 AQMP in relation to local approvals (pages 3•17 - 3-18). The DEIS refers to the Regional Mobility Plan (RMP) as having an "emphasis on 'connectivity and completion'" (page•3-16). While this project was included in the RIP as three mixed -flow and one HOV lane in each direction, it does not appear to support this em- phasis. And, without a firm commitment to the HOV lanes required in the RIP, consistency with the RXP is not demonstrated. (See also comment letter from Anne Baker, SLAG, to Steven Letterly, TCA, November 26, 1990.) d. In the same section, the DEIS.concludes that the proposed Corridor supports the implementation of the Growth.Management Plan (a part of the AMQP). by providing an efficient transporta- tion link between housing and employment centers in the Southeast Orange County subregion. Additional reasons for this include the following: "The Corridor is located solely in the Southeast Orange County subregion, and therefore does not encourage com- mutes between subregions or land uses that are inconsistent with the RMP and GMP.... Within the Southeast: subregion, the Corridor facilitates shorter commutes for work -trips by more directly linking residential areas with employment centers" (page 3-19). These statements are not substantiated. Simply because the Cor- ridor is located within a single "subregion" does not preclude long-distance commuting. The location, type (freeway standards) and length of the Corridor would seem amenable to long distance commuting. in fact, other statements in the DEIS support this pos- sibility. For example, "20% of the traffic on the Corridor is expected to be regional through traffic," including that from San 18 1-2-43 • C 0 Zz0'39dd W3i3X9N 01 Sd31 3H1 W08J 99:bi 16, tt Ndr �J San Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 Diego, Los Angeles, and Riverside Counties (page 2-31). "Development of all three corridors may also be a factor in in- ducing growth in portions of Riverside, San Bernardino and San Diego Counties as the transportation corridors network would 1-2-43 provide improved access into areas in Orange County with Sig- nificant employment centers" (page 6-14). The tiered or revised DEIS should address these conclusions and assess the direct, in- direct, and cumulative impacts that would result in these other areas from the potential induced growth. e. Reliance on inclusion in the AQMP, RMP, and GMP to demonstrate conformity- depends upon an underlying assumption that these plans will be successfully implemented. Portions of these plans require actions by local governments. The DEIS does not provide information on whether the local jurisdictions are im- plementing the AQXP, GNP, or RMP. This was specifically re- quested in EPA's scoping letter (Wyland to Cannon, FHWA, January 24, 1990, page 6 of attachment). Therefore, the tiered or revised DEIS should demonstrate the enforceable commitments of the local governments affected by the Corridor to these regional plans. In contrast to typical highway projects, the sponsor of this project is an association of neighboring cities and the County of Orange. Consequently, it should be straightforward to include commitments in the tiered or revised DEIS, FEIS and Record of Decision. Impacts on Transportation Control Measures The DEIS does not adequately assess the impact of the proposed project .on transportation control measures (TCMs) in the AQMP and other demand management programs. As discussed above, this would include the impact of this project on HOV use (specifically I-405 HOV lanes) and local government commitment to the AQMP TCMS. The overall effect of improving travel speeds for single -occupant vehicles on the demand management strategies in the AQMP and regional ridesharing efforts should be analyzed. In addition, the California Clean Air Act sets a goal that by 1999 the average vehicle occupancy rate must be I.S. if HOV lanes are not provided until after 2000, as anticipated, this goal is jeop- ardized. The impact of the Corridor on I-405 may also affect at- tainment of this goal. EPA understands that TCA will be propos- ing an alternative pricing strategy to help address these issues. The tiered or revised DEIS should include a detailed discussion of the pricing strategy and provide supporting documentation for the assumptions made. provision for High occupancy Vehicle Lanes 4-: 1-2-44 1-2-45 820'39Ud W0i3X9N 01 SU01 3H1 W08J 9S:b1 TS, 11 Ndf San Joaquin Hills Transportation Corridor DEIS EA Comments January IS91 • As noted above, HOV lanes are an important transportation control measure in the 1989 A and are necessary to demonstrate conformity with the AQ". The AQMP identifies NOV lanes for the SJHTC, but the DEIS does not propose HOV lane construction for initial operation; nor does it provide a specific commitment for future construction. EPA encourages adoption of the NOV-lanes because they are an effective means of reducing the number of automobiles in use, with their attendant: air emissions. There are three major problems with the DEIS regarding the provision of HOV lanes: 1) Lack of a specific, binding commitment to the lanes; 2) Lack of adequate justification for not providing lanes when the facility opens; and 3) Conflicting information on when the lanes would be built. 1. The commitment to building HOV lanes must be clarified and defined with more specificity. The impact of abolishing tolls and transferring the facility to Caltrans must be clearly ex- plained and considered in this commitment. There should be specific criteria for building the HOV lanes, along with a schedule and funding mechanism. For example, the financing plan could include a provision that excess revenues be automatically deposited into a dedicated account to fund construction of -the HOV lanes•. The commitment, which should be included in the EIS and the Record of Decision, should be binding and enforceable. Without such commitment or criteria, neither of the proposed t-2-46 build alternatives should be approved. 2. Three primary reasons are given for waiting until 2000 to build the HOV lanes (p. 3-21): 1) Opening day (1995) traffic would not be congested enough to encourage HOV use; 2) HOV lanes would add $100 million to the initial financing cost, but would not increase toll revenues in the early years; and 3) it is not feasible to reconfigure the Corridor to include NOV lanes by reducing mixed flow lanes because off-peak traffic requires more than two lanes in the first five years. Given the fact that the AQMP calls for HOV lanes on this facility and the severity of the traffic and air quality problems in the region, the DEIS does not adequately analyze the provision of HOV lanes. The DEIS does not provide enough information on the feasibility of providing two mixed -flow and one NOV lane in each direction. HOV lanes could be operated only during the peak period in each direction, which would provide adequate capacity in the off peak direction. In addition, the DEIS does not provide information about the availability of public funds for the HOV lanes. 20 0 620 ' 3DUd W0/ 3ADN O1 SU31 3H1 WOa .� LS b I t 6 1 It Ntif 0 San Joaquin Hills Transportation Corridor DEIS EPA comments January 1991 EPA understands that TCA will propose a pricing mechanism to encourage HOV usage prior to building HOV lanes. In developing the proposal, TCA should consider that 'the best incentive to promote KOV travel is to provide a time savings, for the ROV user" (Technical Report No. 8, page 18). While a discounted toll for HOVs offers some financial incentive,. it is not evident -that there would be a time savings without NOV lanes. Only by offer- ing free use to HOVs would a pricing mechanism also provide a time incentive. In addition, the pricing mechanism should con- sider the income levels of the people using the facility. The pian would also need to include a method of adjusting prices if Hov goals were not met. This plan should be included in the tiered or revised DEIS. For both alternatives, "construction of the HOV lanes would 1-2-46 be initiated when traffic volumes indicate a demand for ROV -lanes" (DEIS, page 2-27). The volume criterion is not specific, nor is it clear when this would probably occur. In describing the Demand Management Alternative (DMA), the DEIS states that the six general purpose lanes are "anticipated to meet short-term travel demands (approximately ten years)".(DEIS, page 2-20). The Corridor is projected to open in 1995. Therefore, ten years from startup would be 2005. In contrast, in the air quality confor- mity discussion, the DEIS states that "current traffic estimates indicate that HOV lanes would need to be constructed by the year 2000a (page 3-21). Elsewhere, the document only states -that the HOV lanes would be built within the RMP timeframe -- before 2010. These contradictions must be clarified in the tiered or revised DEIS. Impacts of Construction Activities on Air Ouality Short-term air quality impacts would result from combustion emissions from construction equipment. The DEIS claims that due to the local nature of these emissions, no single receptor is ex- posed for any length of time. The tiered or revised DEIS should include estimates of these emissions for selected, representative times during construction. WATER QUALITY ISSUES Wetlands and Waters of the -United States The proposed Corridor would require that fill material be discharged into waters of the United States, including wetlands, in order to construct either the Demand Management or conven- 21 • 1-2-47 0SO'39dd WOi3ADN O1 SdOl 3H1 W08d 8S:bI t6, it Nd!' San Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 tional alternatives. - it would thus require a permit under Sec- tion 404 of the Clean Water Act from the U.S. Army Corps of En- gineers (ACE). We are concerned that FKWA apparently did not coordinate with ACE to prepare a discussion in the DEIS of the likelihood that either build alternative would be permittable. EPA has reviewed the DEIS for compliance with the 404(b)(1) Guidelines for Specification of Disposal Sites for Dredged or Fill Material ("Guidelines") (40 CPR 230). Failure to comply with any of the restrictions stated in the Guidelines precludes ACE from issuing a permit for the project. We believe that the proposed project as described in the DEIS does not comply because: o Practicable, less environmentally -damaging alternatives appear to be available; o The project could cause or contribute to significant degradation of the aquatic environment; o The DEIS proposes no specific measures that would ade- quately mitigate impacts to wetlands; and o Cumulative impacts of the project and those of other im- minent highway projects are not fully considered in the DEIS. In summary, the DEIS does not provide adequate information to determine whether the project complies with the Guidelines (40 CFR 230.12(a)(3)(iv). While the DEIS focuses on wetlands avoidance and impacts, it does not discuss impacts to other waters of the United States (40 CPR 230.3(s)). Other waters of the United States are -,not given the same consideration in alter- natives analyses as are special aquatic sites including wetlands (see below, under subsection A), but otherwise, impacts to them must be avoided as outlined below. The tiered or revised DEIS should document impacts to and mitigation for other waters of the United States as well as wetlands. Further, Endangered Species Act (Section 7) consultation has not yet been initiated by the applicant, nor has state water quality (Clean Water Act 401) cer- tification been received. A. Alternatives (40 CFR 230.10(a)) The goal of the Clean Water Act is to maintain and restore the physical, chemical and biological integrity of the nation's waters by guarding against unnecessary (avoidable) discharges 22 1-2-48 • • t E0 ' 39ud W3/ 3ADN O1 '.Still 3H1 W08 3 8S : b t 16, It Nbf n LJ • San Joaquin Hills Transportation Corridor DEIS PA Comments J nu 99 into the aquatic ecosystem. This goal is implemented by requir- ing that any permitted discharge be the least-daamaginq prac- ticable alternative available to achieve the project purpose. When special aquatic sites such as wetlands (40 CPR 230.3 [q--] and 230.41) are proposed for filling for a non -water -dependent project (i.e., a project which does not require siting in or im- mediate proximity to water in order to meet the project purpose) the regulations presume that practicable alternatives are avail- able unless clearly demonstrated otherwise. The DEIS does not present adequate information to determine whether the preferred alternative meets this objective as required by the Guidelines. 1. The two alternatives analyzed (Conventional and Demand Management) differ primarily in operational characteristics, not alignment, and thus wetlands impacts only differ by 1.4 acres. We have the same concerns about project purpose and alternatives under Section 404 as under NEPA,-i.e., whether the proposal would meet'the stated project purposes (page 4 of this enclosure), and. the failure to analyze alternatives that -would avoid construction of a new highway (pages 5-9 of this enclosure). The comments below focus on alternatives -to the proposed alignment as discussed in. the "Analysis of Avoidance Alternatives - Wetlands Impacts" (volume II of the Technical Studies). This document states that alignment alternatives which would avoid wetlands to a greater extent than the preferred alternatives were considered and rejected in EIR No. 267. These less -damaging al- ternatives were eliminated in the DEIS without a clear den nstra- tion of their impracticability (i.e., why they are -not available or capable of being implemented, or why the basic project purpose could not be achieved based on cost, logistics, or technology), as required by the Guidelines. The DEIS-does not clearly demonstrate why some alternative alignments are not practicable. The DEIS claims that the various constraints to wetlands avoidance are illustrated on figures in Sections 3.5, 3.7, and 3.10 and Appendix A of the DEIS (page 4-25). However, there are no figures in Section 3.10, and the figures in Section 3.5 and 3.7 do not illustrate constraints. ,In addition, the Section 4(f) resources delineated in Appendix A may not pose constraints when weighed against wetlands impacts (see discussion below). 1-2-49 An example of the lack of demonstrated impracticability is the discussion of alternative alignments which would avoid the 1-2-50 Bonita Canyon Reservoir, the largest (2.8 acres) and most siq- nificant wetland area on the corridor (see below under subsection ewo 23 2SO139dd W3i3N9N 01 SdOl 3H1 WONJ 65oVI 16, 11 NdC San Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 C). The alternative alignments were eliminated because they "would infringe on University of California Irvine Property and known cultural resources to the north, with significant grading impacts* (Analysis of Avoidance Alternatives - Wetlands Impacts, page 4). However, the proposed corridor alignment already in- fringes on UCI property (DEIS, page 2-40). The corridor also would "totally destroy" five archaeological sites elsewhere along its alignment and affect several other sites to varying degrees (DEIS, page 4-110). The DEIS states that "with the inclusion of project mitigation measures, no significant unavoidable adverse impacts (to archaeological sites) would -occur' (page 4-112). Thus, it does not appear that the presence of these sites makes the alternative alignments impracticable. The analysis states also that alternative alignments to the south would "pass near to existing residential development at Harbor view Knoll and nearby communities," with no clear explanation as to why this justifies their elimination. Alternative alignments that avoid wetlands near Laguna Canyon Road were not considered further because they would "intersect the Laguna ridgeline and open -space areas identified in the Orange County General Plan ... and planned open space in the City of Laguna Beach:" We recommend more discussion in the tiered or revised DEIS of the values being protected other than the.zoning status Rgx se. EPA may determine that these sites are available for freeway construction within the meaning of 40 CFR 230.10(a)(2) regardless of local zoning restrictions. In areas where zoning variances or zoning changes are common, the zoned status of a parcel may not rule out the practicability of using that site under the Guidelines. 1-2-50 1-2-51 The tiered or revised DEIS should clearly demonstrate why the less environmentally damaging alignments discussed in the al- ternatives analysis are impracticable. If this cannot be clearly established, these alignments should be given full consideration 1-2-52 as project'alterz�ives. The DEIS should also establish whether the alternatives outlined on pages 5 through 9 of this enclosure are practicable, and if so, whether they would be less environ- mentally damaging than the proposed alignment. 2. Under the proposed alignment and others analyzed in EIR No. 267, Bonita Creek is proposed for realignment, resulting in the loss of the entire wetland habitat value of the creek and preven- tion of wildlife movement through Bonita Canyon. The tiered or 1-2-53 revised-DEIS should discuss the feasibility of bridging the cor- ridor over Bonita Creek, in order to avoid channelization of the 1.4-11 24 • • EEO ' 3Et a WOi 3X9N 01 SU31 3H1 W08 � OO t S I 16, It NUr San Joaquin Hills Transportation Corridor DEIS Epa Comments January 1991 • creek and to allow for some wildlife movement. If channelizaticn 1-2-53 is unavoidable, the banks of the channelized creek should be planted to create wetland habitat. B. Significant Degradation (40 CF'R 230.10(c)) The Guidelines prohibit discharges of dredged material that cause or contribute to significant degradation of aquatic habitat. The project could significantly degrade aquatic habitat because it would directly eliminate at least 13.8 to 15.2 acres of wetlands. Indirect losses would also occur. According to the U.S. Army Corps of Engineers (ACE), Los Angeles District, no Sec- tion 404 permit application has been received for this project. Thus, the wetlands delineation conducted by LSA Associates, Inc.,. has yet to be verified by ACE. In addition, the total impacts to wetlands and waters of the U.S. are not included in the DEIS. The wetlands data forms indicate that wetlands are present in Coyote Canyon (Technical Report No. 5, Appendix 1, site no. 17), but this is not revealed in the DEIS table documenting wetlands losses (Table 4-7-A, page 4-82). The DEIS does not discuss im- pacts of the proposed Corridor on waters of the U.S. other than wetlands, although it would cross at least nine watercourses (DEIS, page 4-20). • • The loss of 13.8 or more acres of wetlands from the proposed freeway is considered significant degradation, because 75 percent of all wetlands have already been lost along the southern California coast (California Department of Parks and Recreation, "California wetlands," September 1988). Diverse habitats such as forested wetland, scrub -shrub wetlands, emergent marsh and riverine intermittent streambed would be removed -by freeway con- struction. In particular, the Bonita Canyon reservoir/Bonita Creek area (approximately 3.6 acres) is considered irreplaceable. Technical Report No. 5 documents the high value of the reservoir*s wetlands to Wildlife (including 90 species of birds and the endangered least Bell's vireo). Impacts to wetland species that would result from the freeway include habitat fragmentation, barriers to migration, noise, glare, road kills and other disturbances. The freeway design would cut off wildlife movement from Bonita Creek and Reservoir to upper Newport Bay, a State Ecological Reserve. According to EVS, this wildlife corridor is a critical link in the ecological community interactions between the fresh- water and upland habitats at Bonita Canyon and San Diego Creek, and the intertidal habitats at Upper Newport Say. 25 1-2-54 1-2-55 VE0139ud W3i3MDN 01 SU:)l 3H1 WON.l 00:5I 16. 11 NUr San Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 Other crucial wetlands functions'of the reservoir such as sediment and flood control, and groundwater recharge would be lost (page 66). Sediments that would otherwise be deposited into the Newport Back Bay State Ecological Resarve are trapped by 1-2-55 Bonita Canyon Reservoir. Loss of the Bonita Canyon Reservoir and Bonita Creek wetlands habitat is considered regionally sig- nificant (page 68) . The tiered or revised DEIS should document whether impacts would occur to Coyote Canyon wetlands and discuss impacts to other waters of the U.S. The document should include an estimate 1-2-56 of wetlands losses based on a ACE -verified wetlands delineation. C. Mitigation (40 CFR 230.10(d)) The Guidelines prohibit the placement of fill unless'ap- propriate•steps have been taken to minimize potential adverse im- pacts on the aquatic ecosystem. The first priority is avoidance of adverse impacts by selecting the least environmentally -damag- ing alternative. Mitigation to offset any unavoidable losses is then required. 1. The DEIS presently includes only a conceptual mitigation plan with no commitments to specific actions. It states that "actual replacement acreage, location and value of replacement sites will be determined through extensive coordination with the agencies" (page 4-85). The tiered or revised DEIS should specify: a) the exact location and size of the mitigation area; b) water sources to maintain the area; c) revegetation plans; d) maintenance and monitoring -for mitigation areas, including criteria by which to measure mitigation success; and e) contingency plans should the mitigation efforts fail. 2. No mitigation for other waters of the u.S. that would be lost is proposed. The tiered or revised DEIS should include a mitiga- tion plan as outlined above for other waters of the u.S. D."Cumulative Impacts (40 CFR 230.11(g)) The Guidelines require that cumulative effects (impacts that are attributable to the collective effect of a number of in- dividual discharges of dredged or fill material) be predicted to the extent reasonable and practicable. 1. The DEIS provides no specific information on impact 26 1-2-57 1-2-68 s • P_� SE0139ud W3/3X9N 01 SW01 3H1 WOa.� 10*9I 16, I1 Ndf U San Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 other proposed highway corridors in Orange County). According to - the DEIR for the Foothill Transportation Corridor, this corridor would directly impact 24-68 acres of wetlands (DEIS, page 4-16). The Eastern Corridor would also have wetlands impacts. The DEIS states that these cumulative impacts "will be fully mitigated as the result of protection, enhancement or replacement." EPA does net consider "the'preservation of open space" as mitigation for wetlands losses, since preservation without creation or enhance- ment would result in net losses to wetlands. We also contend that these impacts cannot be mitigated to an insignificant level, given the significant degradation to wetlands that would result from the proposed San Joaquin Hills alignment and planned Foothill Transportation Corridor. -The tiered or revised DEIS should disclose the total direct and indirect losses to wetlands and U.S. waters that are expected to result from the three corridor projects. 2. The DEIS also does not consider the secondary or growth - inducing impacts of the project on aquatic resources. In a list of induced growth effects on environmental resources, wetlands losses are not included, although the list does include "elimination of wildlife habitat" and "conversion of agricultural land to urban uses" (page 6-13). EPA recently rated a DEIS for the Southeastern Expressway in Virginia as Environmentally Unsatisfactory -Inadequate because of its failure to adequately describe secondary impacts of the project, particularly to wet- lands. The tiered or revised DEIS should include estimated acreages of these indirect wetland losses, and measures that could be used both to protect these wetlands and/or avoid and reduce secondary wetlands impacts. E. Endangered/Threatened Species; Water Quality Certification (40 CFR 230.10(b)) 1. The Guidelines and Section 7 of the.Endangered Species Act of 1973, as amended, require that the project not jeopardize the continued existence of any listed threatened or endangered species. According to the V.S. Fish and Wildlife Service (FWS),- Laguna Nigel Office, neither informal nor formal Section 7 con- sultation (pursuant to the Endangered Species Act) has been in- itiated for the proposed project, although the least Bell's vireo, an endangered species, and the California gnatcatcher, a candidate for listing, are known to occur in the project area. We recommend that the tiered or revised DEIS include the biologi- cal opinion of the FWS resulting from the Section 7 consultation. 27 1-2-59 1-2-60 1-2-61 9E0'39dd W0/3X9N 01 SU31 3H1 WONJ 10:51 i6. it Ntr San Joaquin Hills Transportation Corridor DEIS ERA Comments January 1991 2. The Guidelines require that the proposed project not violate State water quality standards. The DEIS states that "the con- centrations of pollutants would exceed State and federal critical levels of pollutants. However, the actual pollutant loadings within each stream channel would not be significant with success- ful implementation of the Runoff Management Plan and Sediment Control Plan" (p. 4-27). The DEIS does not state whether Section 401 certification has been received from the Regional Water Quality Control Board. We recommend that the tiered or revised DEIS establish that 401 certification .has been received, both as an indication of compliance with the Guidelines and as one aspect of impact analysis. Water Quality Standards I. "Operation of the Corridor would add significant quantities of pollutants into drainage areas immediately adjacent to the proposed Corridor alignment" (DEIS, page 4-27). Pollutants in- clude oil, gasoline, grease, lead, zinc,, nitrogen, chemical oxygen demand, dust and filterable residue. The concentrations of pollutants would exceed State and Federal water quality stan- dards in drainages adjacent to the Corridor. According to the DEIS (page 4-27), however, the actual pollutant loadings within each stream channel would not be significant -with successful im- plementation of the Runoff Management Plan and Sediment Control Plan in Section 4.18 of the DEIS. The DEIS does not contain a Section 4.18, and the Runoff Management Plan and Sediment Control Plan appears to be missing from the document. The tiered or revised DEIS should include this mitigation plan. In addition, water quality impacts related to Corridor construction would be significant. According to the DEIS (page 4-138), newly con- structed cut and fill slopes would cause a short-term increase in erosion, and the sediment loads would be particularly damaging to watersheds and streams. It is likely that construction and operation of the Corridor would result in a•significant long-term incremental increase in pollutants and sediment in streams and reservoirs. The tiered or revised DEIS should analyze the poten- tial for and impacts of the incremental increase of pollutants in watersheds. BIOLOGICAL IMPACTS 1-2-62 1-2-63 1. According to the DEIS (pages 4-81, 4-82), the proposed Cor- ridor would directly impact up to six acres of wetland/riparian habitat in Bonita Canyon. This area is considered by the U.S. 1-2-64 Fish and Wildlife Service (FWs) to be extremely high quality riparian habitat and supports the least Bell's vireo, a Federally 28 0 0 4EO'3Edd W3i3AS N 01 Sd01 3H1 WOaj 20:GI IS, 11 NFif 9 San Joaquin Hills Transportation Corridor DEIS EPA Comments January 1991 listed endangered species (personal communication between Jeanne Dunn Geselbracht, EPA, and Rim Falzone, FWS). As stated above in our comments entitled, "Wetlands and Waters of the United States," EPA understands that neither formal nor informal con- sultation pursuant to section 7 of the Endangered Species Act has been initiated. Section 7 requires Federal agencies to consult with the Secretary of Interior to ensure that any action the agency authorizes, funds, or carries out is not likely to jeop- ardize the continued existence of listed species or result in the destruction or adverse modification of critical habitat. The tiered or revised DEIS should document the Section 7 consultation and include any mitigation measures necessary to ensure the con- tinued existence of the vireo and its habitat. This would in- clude any mitigation necessary for indirect impacts, which could occur in planned developments such as the one adjacent to Pelican Hills Road. 2. Figure 3.6.6 of the DEIS depicts approximately sixteen wildlife movement corridors, which provide water, food, and cover for wildlife, and are important links to the ecological integrity and biodiversity of the area. Wildlife in these corridors would be adversely affected by the SJHTC due to significant degradation of habitat (see page 23 of these Comments). The DEIS proposes only one wildlife undercrossing (tunnel) in the Shady Canyon/Emerald Canyon area to mitigate for the significantly reduced wildlife access along the SJHTC. It is not clear why other such corridors are not proposed to mitigate the disruption of wildlife movement along the SJHTC. EPA recommends that fur- ther mitigation efforts are made to provide for substantially greater access to wildlife in the proposed project vicinity and that commitments to these mitigation measures are included in the tiered or revised DEIS, FEIS, and ROD. 3. The discussion of cumulative impacts to biological resources should be expanded in the tiered or revised DEIS. According to Appendix E of the DEIS (page 36), the cumulative impacts to biological resources would only be partially mitigated. However, in -the area -specific discussions, Appendix E does not disclose the locations or acreages of Category 3 and 4 habitat that would be lost. In fact, the assessment of potential project impacts on biological resources was limited to the area that would be dis- turbed by highway construction, within approximately one -quarter mile of the Corridor (DEIS, page 3-28). Thorough biological as- sessments were not conducted for those areas that would in- directly be impacted by the Corridor (i.e., future planned developments in the AOB). 29 1-2-64 1-2-65 1-2-66 BEO ' 39dd WOi 3XON Ol SdOl 3H1 W08.3 EO:Si 16, 11 Ndf .. cz2 = "= ....=.C- .� San Joaquin Hills Transportation corridor DEIS EIPA Comments January 1991 4. It is unclear whether th3 6,800 acres and 1,300 acre:* wf open space that would be preserved in the Irvin. Coast and Laguna Laurel Planned Community areas, respectively, would actually mitigate the loss of habitat there. If these acreages are al- ready dedicated to open space, their use as credit toward re- placement habitat may not be legitimate. The tiered or revised DEIS should clarify what the current statue of thee* paraele in. The DEIS (page 4-61) indicates that significant unavoidable noise impacts would occur at sites R14, R15, R45, R46, and R47, and that mitigation would be infeasible. According to page 4-59 of the DEIS. however, TCA would conduct a study to determine the feasibility of implementing improvement to the noise attenuation properties of the impacted houses (such as double paving windows). The tiered or revised DEIS and ROD should document TCA'c commitment to mitigating for noise impacts to th* extant possible. 1-2-67 1-2-68 • 30 PRO ' anHH WIi q AqN 01 !;H7 I iH I WOH � rFl : r i I R , 11 NHf IAI! Of ( AWORNIA 0111'1 Of THI GO'.fRN(1R GiORGF DFUKMFIIAN Governor OFFICE OF PLANNING AND RESEARCH '.A! F'A M.i N10 l A 9S8I4 0 Oct 26, 1990 STEVE LETTERLY TRANSPORTATION CORRIDOR AGENCIES 345 CLINTON STREET COSTA MESA, CA 92626-6011 Subject: SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR EIR/EIS SCH # 90010230 Dear STEVE LETTERLY: The State Clearinghouse has submitted the above named draft Environmental Impact Report (EIR) to selected state agencies for review. The review period is now closed and the comments from the responding agency(ies) is(are) enclosed. On the enclosed Notice of Completion form you will note that the Clearinghouse has checked the agencies that have commented.' Please review the Notice of Completion to ensure that your comment' package is complete. If the comment package is not in order, please notify the State Clearinghouse -mmediately. Remember to refer to the project's eight -digit State Clearinghouse number so that we may respond promptly. Please note that Section 21104 of the California Public Resources required that: "a responsible agency or other public agency shall only make substantive comments regarding those activities involved in a project which are within an area of expertise of the agency or which are required to be carried out or approved by the agency.'$ Commenting agencies are also required by this section to support the comments with specific documentation. These comments are forwarded f your use in preparing your final EIR. Should you need more informati or clarification, we recommend that you contact the commentk agency(ies). This letter acknowledges that you have complied with the State Clearinghouse review requirements for draft environmental documents, pursuant to the California Environmental Quality Act. Please contact Terri Lovelady at (916) 445-0613 if you have any questions regarding the environmental review process. Sincerely, David C. Nunenkamp Deputy Director, Permit Assistance Enclosures cc: Resources Agency 2-1-1 nautice of Compietion • --- Appendix F See NOTEberw. Afail ro: State Clearinghouse, 1400 Tenth Street, Sacramento, CA 95814 9161445-0613 SCH # d n 7 n e) i [t San Project Title: Joaquin Hil is Trans ortation Corridor • Ck'—Lead Agency; 1Lancnnrtari r riA r ea Street Address: 345 Clinton Street Contact Peron: _ Steve "I" *ly Cit Costa Mesa. A Phone: (714) 557-3298 P, &E SE SEE ATTACHMEIIT 1 FOR zip: uul-ull Coutsy Orange - _ . -� ��rFeA1ScR 11I�OMT.l :— — — — _ _ _ _ _ _ _ _ Project Location - Please see Project Description Below. — -' Co` .y- � � City/Nearest Conmunity: Cross streets: Assessor's Puce! .No. Total Acm: -------- Sacmaar -- _"— Tap. Range Base: . Within 2 Miler: Stye Hwy K: wsarways; A`pons: Raa ---------- ----------- Document Type --'---------- — ----_.•— CEOA: ❑�+ NOP ❑SupPsar/Suteagoeat NEPA: ❑ Fariy Coax ❑ EIR (Prior SCH No.) ❑ Noi Other: j1 Joint D� kNeg Doc ❑Other ❑ Dr is ELs OEA o Ogler lrttos� Draft EiR —-------- ❑PoNSI Local Action Type _ —_.--.--_.-----•-------_.------ ❑ General clan Updre 0 Specific Plm ❑ General Plm Arsasdowu ❑ Maser Pun ❑ Rezone ❑ Amisastion ❑ General Pia Element ❑ Pleased Unit De,-, ❑ Comna>ity PLa ❑ Use Parmit ❑ Sid Pia Div 0 Comm Panrdt❑ Land a isp4 M Other Co rridor ----------�.-.--�.------ P+oelMap, Tract map, rac) � ------- roval DPP- -----� — -._--- Development Typo ❑ Roklentw: V ks ,des ❑ offix; Sq,R• Acres ❑ Waoer Futlities: Type f�eloy— AIGD ❑ ConuneroiaL•Sq,ll. Acres E„® Tm-portuion: Type Transportation eorr-r or Cl soil• Awes to P: a� prat ❑Educational Type❑ Wias Recreational ❑ Wasse Treamsat: ❑ Hundotu Waste:Tjps ❑ other ----------- Project Issues Discusaod in Doctunent ---------------------------- ® AathetWVi ual ® Flood PApiculaull lain/Elooding ❑ Schoob/[fruversttaes Land ® Forest Lan Wsm Hazard ®Wan Quaky Septic Systs ® Quality ❑ ran ir�Sewer Capacity ® Winer~' ®ArcheobgicaUFiistorical 0 Mina! U0p°� ® Noise a Sor3 Em"Or Coatpactg rsding El Wildlife P small rption Solid Waste ❑ Economic/lotx ® Population/Housing Balance ® TozicJyazudous ® Gtowd, inducing ❑ Fiscal ® Public Sesvioea/FaciULies ® Traffic/Circulation ® Lrrduse ® Recie+tionMarks ® Ctrnuladve Effects ® Vegetation — — — — — — — — — — — — ❑O ther — — — Present Land Use/Zoning/General Plan Use ------------•--'----------_. ----------- Project Description --—"--------_ -- _----- SEE EXHIBIT "A" ATTACHED. CLEARINGHOUSE CONTACT: 916/445-0613 TRUI LOV=LADY CMT SIR OR "T STATE REVIEN BEGAN: s Aseacy -�Re� DEPT REV TO AGENCY: _ Coastal Coates -- -- _-_ --- AGENCY REV TO SCHri*a Conssryat� SCH COMPLIANCE PLEAS— SE �)tT»�r _ Y AQMD/APCD: (Resources:� �_ �. up � _. � rr.alte , � ,_, —Scat—StAtO j 0 State of California Environmental Affairs Agency M e m o r a n d u m To Terri Lovelady Date s 10-24-90 State Clearinghouse 1400 Tenth Street Sacramento, CA 95814 Steve Letterly Transportation Corridor Agencies 345 Clinton Street Costa Mesa, CA 92626-6011 Judith L. Heyer Caltrans 2501 Pullman Street Santa Ana, CA 92705 • From : ohn D. Smith, Manager ocal Planning Division CALIFORNIA INTEGRATED HASTE KANAGEKENT HOARD Subject: SCH# 90010230, Draft Environmental Impact Report/ Environmental Impact Statement (DEIR/EIS), for the San Joaquin Hills Transportation Corridor, Orange County. Staff of the California Integrated Waste Management Board (CIWMB) have reviewed the above document and offer the following comments: Project Descrip ion The proposed San Joaquin Hills Transportation Corridor (Corridor) project involves constructing State Route 73 from the I-5 Freeway in the City of San Juan Capistrano to its existing terminus at Jamboree Road. Ramp improvements on the existing SR-73 will be constructed between Birch Street and Jamboree Road. Portions of the proposed project are located within the cities of Newport Beach, Irvine, Laguna Beach, Laguna Niguel, Mission Viejo, San Juan Capistrano, and unincorporated areas of Orange County. The facility will include ramp toll plazas and a mainline plaza for the collection of tolls south of the Sand Canyon Avenue interchange. 0 Background As stated on page 1-3 of the DEIR/EIS, A DEIR No. 494, was previously prepared and distributed for review on July 1, 1988. Prior to the preparation of the Response to Comments (RTC) and a final EIR (FEIR), the decision was made to prepare another document evaluating the Corridor as a toll facility. 3.0 - The Affected Environment' As stated on Page 3-61 of the DFIR/EIS, the proposed corridor would intersect the Coyote Canyon Sanitary Landfill, which closed on March 3, 1990. It is the CIWMB's policy to require issuance of a Solid Waste Facility Permit (SWMP) to the contractor, if solid waste is to be excavated prior to construction of the corridor. The Orange County Solid Waste Enforcement Agency should be contacted for assistance in this matter. In addition, a thorough analysis of the impacts and mitigations for the following issues should be included in the FEIR: 1. Methane Gas Landfill gas monitoring wells may be displaced during the construction of this corridor. Alternative gas control measures should be included in the FEIR. The document should thoroughly discuss employee and public health and safety. 2. Hazardous Materials Hazardous materials may be detected during the excavation of the landfill. The FEIR should include a contingency plan, which includes separation, and handling of hazardous wastes, and indicate the Class I facility to which these wastes will be disposed. 3. Displacement of Nonhazardous Wastes The FEIR should describe the handling methods and indicate the final destination of the nonhazardous solid waste which would be displaced by excavation. The FEIR should also describe slope stabilization methods, indicate depth of excavation, and measures to protect groundwater quality. 4. Closure/Post-Closure Plan Construction of the corridor should be consistent with the Coyote Canyon Landfill Closure/Post-Closure Plan. Waste containment, gas migration and collection systems, leachate collection and control systems, and final cover should remain • intact. The, FEIR should address mitigation measures from 2-2-1 2-2-2 disturbances to these systems. For more information, the Board's Closure/Post-Closure Branch of the Permits Division 2-2-2 should be contacted. General Comments The FEIR should include a Response to Comments section. Please send a copy of the document to: California Integrated Waste Management Board 2-2-3 Local Planning Division, Environmental Review Branch 1020 9th Street, Suite 300, Sacramento, CA. 95813. Mitigation Monitoring and Implementation Schedule Public Resources Code section 21081.6 requires that the Lead Agency 2"24 adopt a Mitigation Monitoring and Implementation Schedule to address the impacts identified in the DEIR/EIS. Thank you for the opportunity to review this DEIR/EIS. We look forward to receiving the FEIR. If you have any questions regarding these comments, please contact Martha Diaz of the Board's Local Planning Division at (916) 327-2444. 0 UNIVERSITY OF CALIFORNIA, IRVINE a�`SY of F, C 2 BERRELEI DAVIS . IRVINE • LOS ANGELES RIVERSIDE . SAN DIEGO • SAN FRANCISCO �� _ •O SANTA BARBARA • SANTA CRUZ 'i666• DEPARTMENT OF ECOLOGY AND EVOLUTIONARY BIOLOGY SCHOOL OF BIOLOGICAL SCIENCES Mr. Steve Letterly Transportation Corridor Agencies 345 Clinton Street Costa Mesa, CA 92626 Dear Mr. Letterly: IRVINE. CALIFORNIA 92717 FAX (714) 725-2181 21 November 1990 I take this opportunity for public comment on the San Joaquin Hills Transportation Corridor DEIR/DEIS and for the TCA's extension of the comment period upon the document. As I have not had time to review the entire Technical Studies Document I will address only issues -that impact the UCI campus and that were revealed (or not revealed) in Volume II of that document. I take the liberty of addressing you on letterhead from my position of employment in the Department of Ecology and Evolutionary Biology, School of Biological Sciences, University of California, Irvine. As a professional ecologist I have voluntarily agreed to serve the campus both officially and unofficially as an individual with the expertise to comment on matters that relate to perturbation of natural habitats on campus. It is in this context that I provide these comments that apply to a very explicit site of the proposed San Joaquin Transportation Corridor, that that impinges on the UCI campus. The site, as nearly as I can make out on your rather vague map and description, appears on the map, Figure 4 of Volume II of the Technical Studies document. The map indicates that the projected corridor will extend along the existing course of Bonita Canyon Road between Bonita Canyon Road on the south and UCI's Ecological Preserve to the north; it only vaguely 2-6-1 indicates the extent of intrusion into the Ecological Preserve, but it does indicate that two populations of Many -Stemmed Dudleva Dudle a multicaulis) will be transected and that a substantial stand of the endangered habitat, coastal sage scrub, will be eliminated. As you know D. multicaulis is a Federal Category 2 Candidate Species for threatened/endangered 2_6_2 listing, and is listed by the California Native Plant Society (CNPS, list 1 B) as rare or endangered in California; further it may be considered as significant under CEQA. At the same time that your Draft EIR/EIS was submitted, a final draft of the Biological and Sensitive Species Assessments of the University House site, the University of California, Irvine, was submitted to the UCI Environmental Planning and Campus Design Office by the Chambers Group, Inc. The University House site is immediately adjacent to the Ecological Preserve (AKA Campus Open Space Reserve) and therefore the Chambers Group's assessment extended to consider that portion 2-6-3 of the Preserve/Reserve that overlooks Bonita Canyon Road. That report identifies the presence (Figure 3, Chambers Group Report) not only of populations of D. multicaulis, but also a rather large population of Orange County Turkish Rugging (Chorizantha staticoides - also a Federal . Category 2 Candidate Species and listed by CNPS), and a California Gnatcatcher concentration - all within the Corridor ROW as indicated on your map. On visits that I personally have mader2-6-3 41 to that site within The Corridor ROW I have observed both Gnatcatchers and Cactus wrens - The Gnatcatchers, as you know, are Federal Category 2 Candidate species, and a second priority specimen on the Special Concern List of California Department of Fish and Game with Federal 2-6-4 official listing imminent, while the Cactus Wren is under study by CDFG as a sensitive species. Thus at this one site are four sensitive species; two plants and two birds. I have been greatly concerned about this proposed incursion onto our campus, and that 2-6-5 these issues are either not addressed or dismissed. More recently I have been appalled at the transmission to me by Richard Demerjian of our Campus and Environmental Planning Office of a "new" map from the San Joaquin Hills Transportation Corridor dated 16 Nov. 1990. This map shows Even further incursion into our Ecological Preserve and, in fact, the incursion of The Corridor onto our campus is at its greatest on the Ecological Preserve, at a specific locality 2-6-6 designated by the Chambers Group (and I concur) as one of the most environmentally sensitive on campus, if npacting directly four sensitive species and threatening them vvith local e tinctlyn (my opinion as an ecologist). I find this situation both deplorable and intolerable, and request that you address directly my concerns. You must be aware of the reality that extinctions cannot be mitigated. Further, if these oversights at this specific site that I have reviewed in detail are indicative of the thoroughness of your documents for the entire corridor assessment, then it only sickens 2-6-7 me to imagine the numerous populations of sensitive species that are being ignored and/or dismissed. These are luxuries that we can ill afford. 0 Lastly, I will reiterate that the "new" map that was received from your office on 16 November appears substantially different from the one that accompanied the Sept. 1990 EIR/EIS. 2-6-8 And that difference threatens even more drastically the ecologically most sensitive spot on our campus. REM/mac 2 Sincerely, Richard E. MacMillen Professor and Ecologist is FROM:FARR'S STATIONERS t115 T0:714 557 9104 NOV 26, 1990 4:48PM P.02 UNIVERSITY OF CALIFORNIA, IRVINE ZKpX D.EY • DAV" • Mvjmx • xm AmOELM • 7tl USM • 8" D=00 • SATs r$"C = SAWTA bAASAAA • sANTA 0= SAN JOAQUIN TRFSHwATEk MARSH RWRRVH IRVINE, CALIFORNIA 92717 DURN5 FINON RIUCE DESERT RRURVe DEPARTMENT OF ECX)I.(X:Y AND £•VOLLMONARY WOLOCY 26 November 1990 504WL 01; b1OLOGCAI. SC:IENCLS Attention: Steve Letterly Transportation Corridor Agencies 345 Clinton St. Costa Mesa, CA 92626 FAX 714-557-9104 Dear Mr. Letterly: I am FAXing to you these brief comments so that you might receive them in time as my official comments on the Sap .Joaquin Hills Corridor DEIR (DEIR/DEIS State Route 73 Extension, San Joaquin Hills Transportation Corridor FHWA-AC-EIS-90-20, $CH. NO. 90010230, TCA RJR/EIS ]). I am writing to you in my capacity as Manager of the San Joaquin Freshwater Marsh Reserve, a component of the University of California Natural Reserve System, which is itself deaignnated in CEQA (Section 15386) as a Trustee Agency for the People of the State of California. I have considered the environmental documentation prepared for this project so far, and have the following comments for the record: 1) "No Project" is my preferred alternative for protecting the interests of 2-7-1 the UC Natural Reserve System, and therefore the People of the State of California with respect to protection of natural wildlife resources, and 2) the DEIR and related environmental documentation is too inadequate and incom- 2-7-2 plete to meet the full spirit, intent, and legal requirements of CHQA. I will expand briefly on these two comments below, in order to guide your response to them appropriately. No Project Preference for Public IntLrest. This project, both directly and indirectly, contributes substantially to the further fragmentation and disintegration of the remaining remnant natural plant and animal wildlife communities that aboriginally occuppied the landscapes of this part of Southern California. The project cuts across 2-7-3 the San Diego Creek Flood Control Channel between Upper Newport Bay State Ecological Preserve and the UCNRS San Joaquin Freshwater Marsh Reserve, and it slashes up the Bonita Canyon Creek drainage that connects these irreplaceable, threatened habitats with the preserved upland habitats of the San Joaquin Hills. These are critically important components of a tenuous network of wildlife movement corridors utilized by endangered or potentially listed species, as well as by keystone species (i.e., coyote 2-7-4 necessary for the long term survival of these endangered and threatened species of concern. None of this ie.adequately analyzed in the environmental documentation, nor' is there adequate discussion of alternatives to the project to avoid these significant 2-7-5 impacts. NOV 26 190 15:47 1 619 442 5164 PAGE.002 FROM:FARR'S STATIONERS #0 TO:714 557 9104 NOV 26, 1990 4:49PM P.03 Bretz to Latterly Page 2 26 November 1990 At this point, society has gone geyond the point of no return: no imaginable mitigation measures can adequately compensate the Public for the losses that will be associated with this project. Society needs an intact wildlife habitat in the 2_7_6 San Joaquin Hills along with a restored and protected upland -riparian habitat corridor along the drainages of bonita.Canyon Creek and San Diego Creek, far more that it needs additional subsidization of an automobile -dominated landscape. In order to promote the CEQA-mandated role of the UCNRS as a Trustee Agency, i consider it to be my responsibility as Manager of a UCNRS Reserve potentially impacted, directly and indirectly by the project, to provide my analysis and 2-7-7 recommendations: only the "No Project" alternative will protect and preserve the public interests in a balanced way. There are no substitutes or mitigations for the wildlife habitat losses that would be generated by the project; however, there are possible alternatives to the proposed project for meeting societal transporta- tion needs. Unfortunately the environmental documentation for this project is nit complete enough to provide for objective public debate and decision -making in 2-7-8 this regard. Despite the lacks of the official documentation, it is not difficult to envision alternatives to this project that could alleviate automobile traffic loads on existing streets and freeways, while causing less environmental damage (i.e., public mass transit projects, light rail., etc.). But 1 cannot, no matter how hard l try, imagine alternatives or satisfactory replacements for the losseas 2-7-9 of wildlife habitat function that will be associated withthe construction of the proposed project, even with the proposed mitigation measures. Inadequate DEIR. The environmental documentation for this project has not, in 2-7-10 my opinion, adequately described the potential impacts of the project on the light footed clapper rail and the least tern, two endangered species, and also on the southwestern pond turtle, a candidate for listing species. The project will directly impact the critical wildlife habitat corridors between the Upper Newport 2-7-11 Bay Preserve and the San Joaquin-Preshwater Marsh Reserve, as well as the Bonita Canyon Creek channel. This part of the project affects the Coastal Zoh* , yet the requirements and ramifications of this fact are not addressed adequately in this 2-7-12 DEIR. This must be remedied. The extension of California Avenue across the San Diego Creek Channel on yet another bridge over this fragile wildlife corridor, and its connections to the project via University Drive North and otherwise has not been analyzed, yet these 2-7-13 are potentially significant impacts associated with the project that should be analyzed and mitigated, if need be. This project, which in reality is only part of a larger automobile -subsidising series of projects (Eastern -Foothill -San Joaquin Hills Corridors), contributes to a cumulative impact load upon the remnantnatural wildlife habitats of Orange County 2-7-14 that have not been adequately described in the environmental documentation for this (or any other) project. This is a violation of CEQA. not to describe and analyze the cumulative scopeand impacts of this project in r1kation to others. Or b, I do not think that mitigation for this project has been^ designed that can adequately compensate for the destructive, adverse iinpac:ts that this project will impose upon 2-7-15 • the regional environment. My recommendation is that the "No Project" alternative be adopted, perhaps with addi.ttional environmental review allowed. NOV 26 190 15:47 1 619 442 5164 PAGE.003 • 0 C] FROM:FARR'S STATIONERS #iS TO:714 557 9104 NOU 26, 1990 4:49PM P.04 Bretz to Letterly Page 3 26 November 1990 If additional environmental documentation should be persued, I request that, as a CEQA—designated Trustee Agency, that the UC Natural Reserve System be included 2.7-16 in preparing the scope of any additional environmental review of the project, at least with respect to impacts to regionally important wildlife corridors and wildlife movements. ��5incere]y yours, William L. Bretr., Reserve Manager UCNRS San Joaquin Freshwater Marsh Reserve CC. J. R. Samuelsen,_Director, UCNRS T. Bradley, UCl/UCNRS Faculty Advisor NOV 26 '90 15:48 1 619 442 5164 PAGE.004 t P f ri �/< tl /� i v—��� STATE OF CALIFORNIA—THE RESOURCES AGENCY GEORGE DEUKMEJIAN, Governor CALIFORNIA COASTAL COMMISSION 45 FREMONT, SUITES 1900 AND P00 SAN FRANCISCO, CA 94105.2219 VOICE AND TDD i415 904.5200 November 26, 1990 Steve Letterly San Juaquin Hills Transportation Corridor Agency 345 Clinton Street Costa Mesa, CA 92626 RE: San Juaquin Hills Transportation Corridor DEIR/DEIS Comments Dear Steve: Thank you for the opportunity to comment on the above DEIS/DEIR. We have a number of substantive and procedural comments, which will be generally described in the following paragraph, with details provided in the text that follows. The proposed highway described in the above DEIS/DEIR would have a number of impacts on the coastal zone. Additionally, portions of the project would be within the coastal zone. These facts, combined with the fact of a number of 2_8_1 federal permits and licenses, as well as potential federal funding, lead us to the conclusion that formal Coastal Commission review, either through the coastal development permit process, or the federal consistency process, are likely to be triggered by the proposal. Under the Federal Consistency regulations (15 CFR 930 et seq.) the California Coastal Commission reviews federal projects and support for activities which are located partially or completely outside the coastal zone. This review occurs when such activities affect resources of the coastal zone through spillover impacts. The San Juaquin Hills Transportation Corridor (SJHTC), as a federally licensed (or potentially federally funded) project, has the potential to create significant spillover impacts to the coastal zone. The procedural elements of potential formal future Coastal Commission review are not the focus of our comments below; rather this letter focuses on the DEIS/DEIR itself and the potential impacts on the coastal zone. We intend at a future date to inform you more specifically how the permit/consistency provisions could be most appropriately complied with. With respect to the project's impacts on the coastal zone, we have identified below potential coastal concerns over geologic hazards, hydrology, water quality, biological resources (including wetlands and other environmentally sensitive habitat areas), planned land uses, landform alteration, visual resources, recreation, and growth inducement. On these subjects, the comments below will identify concerns we believe are raised by the document, and will recommend additional information and analysis that we believe should be included in the Final EIS/EIS and any future formal consistency certification submittal. (Page numbers refer to DEIR/DEIS for this project, unless otherwise indicated). • Letter to Steve Letterly November 26, 1990 Page -2- SECTIONS 3.2 and 4.2 GEOTECHNICAL. The DEIR/DEIS identifies slope instability problems known to occur in the project area. These include unstable soils located in canyon bottoms and creek beds, and soil creep and landslides occurring on the steeper slopes. As presented on the Geotechnical Constraints map on p. 3-5, these hazard areas are shown only within the immediate vicinity of the corridor right of way. Certain of the site constraints and/or geotechnical hazards are elements in a larger interactive system. However, as the physical description implies and as the map on p. 3-5 of the DEIR/DEIS shows, only those constraints within a study area boundary have been discussed or shown. Page 25 of the GOEFON Geotechnical Study indicates that the types of geotechnical constraints identified in the report (and on the constraints map) "may exist over large areas considerably beyond the Alignment that is under study." This statement raises concerns to the reviewer that some relevant constraints may not have been included in the area of study for this document. Due to the interactive nature of these systems, and the effects and hazards which could be produced, identification and analysis of additional areas of site constraints or geologic conditions located within, or in close proximity to the coastal zone (but outside of the geotechnical study area), should be included in the Final EIS text and shown on the Geotechnical Constraints Map (p.3-5). Such areas should include those with inherent site constraints which, in structure or in process, are unified with site constraints identified in the document (e.g., landslide areas which are part of a landslide area shown/discussed in this document, but which may also extend outside of the study area as defined for this -project). Other supplemental areas for identification of site constraints or geologic conditions should include those areas which may or may not possess constraints, but which could receive damage from, or otherwise interact either directly or indirectly with, a geologic constraint or condition in the project study area (e.g., areas of landslide potential inside the study area could cause mudflow events downslope or downstream). In addition, areas of site constraints/hazards and geologic conditions located outside of the study area which are indirectly related to physical attributes or processes in the project study area should be identified (e.g., downstream slopes with landslide potential which could be triggered by fluvial undercutting of slopes due to flooding from upstream/project area). Site constraints as identified by the DEIR/DEIS which include compressible/collapsible soils, expansive soils, slope instability (landslide areas) and high groundwater are all seen to possess such interactive characteristics, and therefore additional information, as described above, is needed on such constraints, especially for our purposes to the extent.they could affect the coastal zone. Neither the DEIR/DEIS or the Geotechnical Report identify areas/slopes which are prone to non -fluvial erosional processes, particularly dry soil erosion (other than soil creep) and rockfalls (as could contribute to debris/mudflows). These and other areas of slope instability which are distinct from landslides (as defined in the DEIR/DEIS and Constraints Map) (such as soil creep and slope wash) should be discussed in the DEIR/DEIS and shown on the Geotechnical Constraints Map. 12-8-2 2-8-3 2-8-4 2-8-5 2-8-6 • Letter to Steve Letterly November 26, 1990 Page -3- The landslide areas described on p. 3-6 are complex and substantial enough to warrant larger scale maps/site plans and/or air photos showing their current 2_8_7 placement and condition, particularly for our purposes those in close proximity to the coastal zone boundary. Discussion of project activities' interaction with geotechnical constraints//hazards other than seismic is too general and therefore vague. Further information is needed as to the extent to which project activities 2-8-8 will alter, interrupt, lessen, or increase the soil instability or other geological problems present in the project area. The analysis of project geotechnical effects and mitigation measures are specific to the project site area. However (as described above), there is the potential that activities and alterations at the project site could contribute to downstream/downslope slope stability or other geologic problems which are systematically related to the geologic processes/structures altered at the 2-8-9 project site. Therefore, the extent to which project activities and existing project -site -related mitigation measures will alter (beneficial or negative) slope stability and other geologic characteristics outside the project area (particularly within the coastal zone) need to be included in this DEIR/DEIS. • Similarly, mitigation measures as may be needed to eliminate or minimize adverse geotechnical impacts downslope/downstream from the project area should 2-8-10 be included. In the discussion of Excavation and Embankment (p.4-17) information is needed on the location and number of stream channels through which these activities will occur, and a comprehensive discussion of downstream/downslope effects 2-8-11 (stream alteration, erosion, etc.). Removal of landslide material is discussed. Additional information is needed as to how this will affect connected/related geologic structures/processes, particularly downslope/downstream (in the coastal zone). The bottom of p. 4-17 describes some mitigation for compressible/expansive soils, such as relief wells and Surcharges. How will these mechanisms alter the surrounding hydrologic/groundwater system, particularly as could 2-8-12 contribute to seepage elsewhere (adjacent and downstream) and/or leading to slope destabilization? While grading activities "on site" are addressed through mitigation measures mentioned on p. 4-18, more information is needed as to grading effects on 2-8-13 downstream/downslope natural structures/systems and/or hazards, with particular attention to drainages and watersheds within the coastal zone. Under the Seismic and Landslides subsections, how might project related alterations to geologic systems and structures affect adjacent/related units, 2-8-14 such as areas where landslide material has been removed? (Could adjacent inactive landslides be retriggered?) Also, would these areas be more • sensitive to a seismic event? Letter to Steve Letterly November 26, 1990 Page -4— Mitigation measures need to be analyzed for effectiveness in preventing negative impacts to downslope/downstream areas which could be affected by project site alterations, and new measures need to be designed as needed. SECTIONS 3.3 and 4.3 WATER RESOURCES. Due to the interconnected nature of the hydrological system and the wide geographic range exhibited by impacts to the system, the coastal zone is particularly sensitive to alterations of inland water resources, both within and outside the coastal zone. Alterations to inland water resources and hydrological systems can directly affect coastal water resources of streams, rivers, lakes and wetlands, as well as nearshore ocean resources. Processes of erosion, sedimentation, groundwater migration, and the nearshore sand supply system are are all closely related to the condition of inland water resources and systems. In addition, flood and geological hazards can be contributed to and triggered by alterations to these systems. At least twelve watersheds as identified within the DEIS (p. 3-8) occur within the coastal zone, several of which are encroached upon by the corridor. In addition, these watersheds within the coastal zone are contiguous with and systematically connected with watersheds outside the coastal zone which are crossed by the corridor. Alterations along •the corridor will cause changes to a number of natural processes which are bound within these watersheds, as discussed above. In order to properly evaluate impacts to the coastal zone, the water resources setting should include a clear description of the geographic and systematic relationship of the various systems and their current interactive operations (water drainage, erosion, sedimentation, runoff) as occur within the major watersheds, watercourses, and floodplain areas as identified on p. 3-8 of the DEIS. The area of this detailed description should commence from the corridor ROW and follow the watershed(s) to their discharge points in the Pacific Ocean, clearly identifying the relationships of each geographic area and process as occur along the way (e.g., Laural Canyon drainage provides a major source of surface water flow to the Laguna Canyon watershed, providing essential fresh water flows to riparian habitat areas as occur within Laguna Canyon). This description should include an analysis of the current "health" of the larger interactive system of water resources as made up of the many "subsystems" as described above (i.e. Bonita Canyon Reservoir has experienced sedimentation problems from erosion occurring upstream in Coyote Canyon....). In short, while description and analysis of the different systems which occur in the watersheds are included in separate sections of the DEIR/DEIS, they also should be discussed as they interact as a systematic unit within the watersheds affected by the corridor. 2-8-15 2-8-16 The watersheds of Buck Gully, Los Trancos Canyon, Muddy Canyon, Morro Canyon, Emerald Canyon, Boat Canyon, Lower Laguna Canyon, Wood Canyon, Aliso Creek and Aliso Canyon as well as Upper Newport Bay/San Diego Creek/San Juaquin Marsh 2-8-17 all occur within the coastal zone. The Coastal Commission staff considers that these areas will be directly impacted by the project (either through • • Letter to Steve Letterly November 26, 1990 Page -5- project actions occurring within these watersheds themselves or upstream from these watersheds). Of particular concern are the several watersheds where it 2-8-17 appears that the corridor will be built at the head of a watershed (see Map p. 3-8), and thus has the potential to alter all watershed components. In the Beneficial Waters uses of section 3.3 more information is needed as to how the existing water sources, and similarly the water volume, rate and 2-8-18 quality of these sources, contribute to the current condition of these areas (i.e. freshwater/salt water balance), and effects on such by project caused alterations to these sources (in Impacts section). In the discussion of Floodplains (p. 3-9), the setting needs to include information on the geographic location and history of flood prone areas (FEMA FIRM maps delineate flood planning areas, and do not necessarily indicate specific areas which have, or continue to experience, flood events). Of particular concern are areas which have demonstrated destructive mudflows and soil slips related to flooding events. The impacts section should discuss the extent that past/current flood problems will be altered (negative or positive) by the project (i.e. increase runoff). Section 4.3 describes streambed modifications required by the project. The coastal zone would be affected by such modifications. The concerns raised include stream alteration impacts to watershed hydrology and dynamics (freshwater supply, stream volume and velocity, watershed/stream morphology), erosion and sedimentation, habitat interference or removal, effects on stream species, and flood hazards. Such issues need to be included in the impacts analysis of streambed alterations. Streambed alterations which involve fill within channels are especially significant. Comprehensive information on such channel fill impacts is needed. Such impacts analysis should include, but not be limited to, effects on downstream erosion (headcutting) or deposition, flood hazards, wildlife, environmentally sensitive areas, water quality, water impoundment and beach sand supply. Areas experiencing increased runoff from the project are discussed on p. 4-22. Many of these feed or are within watersheds of the coastal zone. While additional flow is identified, further clarification of effects from increased "design discharge" or "additional flow" is needed. Possible effects which need to be addressed here include freshwater mix/balance, increased sedimentation/siltation, increased erosion, and flood hazards (the reference to the technical study with no summary/discussion here is inadequate). P. 4-22 to 4-26, Floodplain. The DEIR/DEIS focuses only on an area of impact within the project vicinity, which has included some areas within the coastal zone. There are other areas" within the coastal zone which will be affected by floodplain encroachments which have not been mentioned. Analysis and discussion of the various issues and impacts discussed in this section need to include the extent that they would affect all the coastal zone watersheds as identified above. 2-8-19 2-8-20 2-8-21 2-8-22 Letter to Steve Letterly November 26, 1990 Page -6- P. 4-26 to 4-27 discuss impacts to water quality from project generated pollutant runoff. P. 4-27 states that the project would add "significant quantities of pollutants" into drainage areas "immediately adjacent" to the proposed Corridor. At the same time the relationship and interactive nature of the watersheds of the coastal zone with project the project area is acknowledged, "sediment would be transported by storm runoff to local water courses and to coastal beaches." However, the discussion of impacts to coastal waters is vague and does not contain a level of detail warranted by the level of impact. It appears that only coastal waters "immediately adjacent" to the project have been discussed adequately. Runoff/pollutants impacts need to be addressed for all watersheds which will be affected within the coastal zone (as identified above). Exemplary of how such impacts should be addressed is the level of detail presented for San Diego Creek/Upper Newport Bay (p.4-28). Any degradation of wager quality of coastal waters is of concern to the Coastal Commission, particularly in sensitive areas such as riparian areas, marshes, wetlands and estuaries. On P. 4-28, reliance is made on storm activity to dilute pollutants. This raises concerns over what would occur during drought years. Such an assumption should not be relied on for any long-term scenario. P. 4-29, Marine Environment Impacts. This discussion is inadequate as to possible coastal zone marine impacts. The Coastal Commission staff does not believe the DEIR/DEIS has established that pollutant levels would be insignificant. Further information/data is needed to support this determination. The basis for the DEIR/DEIS conclusions may be based on questionable assumptions (storm dilution and nearshore mixing). Particularly in light of cumulative circumstances (from other development, recreational boating, agricultural runoff), any additional sources of pollutants being introduced into these waters would be significant to water quality which is already stressed by runoff from existing uses of the highly urbanized areas which drain into them (see p. 4-32 cumulative water quality impacts). The Runoff Management Plan is a major portion of the mitigation for water quality impacts. However, this Plan is incomplete at this time. The implementation of this plan must be completed and there must be adequate mechanisms to achieve its goals (e.g., performance bonds). The Coastal Commission staff would like to be kept apprised of the design of measures to assure implementation of this plan. The Commission staff also wishes to participate in the review of the Runoff Management Plan, due to the major role it will play in reducing water quality impacts to the coastal zone. For the purposes of this DEIR/DEIS, an example of a similar plan which has been implemented should be included, with an assessment of such plan's effectiveness in actually controlling runoff. Alternatively, the Coastal Commission staff would appreciate the forwarding of any studies which show the effectiveness of such plans. 2-8-23 2-8-24 2-8-25 2-8-26 • • Letter to Steve Letterly November 26, 1990 Page -7- P. 4-30. Due to the amount and scope of alterations to streams this project entails, stream alterations should be subject to a more stringent and complete/comprehensive environmental review than the requirements of the California Department of Fish and Game Stream Alteration Agreement (1601), a process which we have found may inadequately address cumulative impacts. The Coastal Commission staff wishes to be included in any such review. Mitigation of floodplain impacts include numerous drainage alterations and installations (p. 4-30 to 4-31). Effects of such installations further downstream (in the coastal zone) need to be considered. Mitigation measure 3-8 states that no net increase in runoff in Laguna Canyon will be generated by the project. This is assumed to be in response to the area's existing flood problems. Other flood -prone areas need to be identified and similar appropriate measures taken. P. 4-31. The Best Management Practices (BMPs) present ways of trapping runoff -generated pollution. What is not clear is whether these mechanisms will remove pollutants permanently from the hydrological system, or will act as holding reservoirs. Issues and questions raised include final location of discharge points, entry into municipal treatment systems, ability to treat pollutants, and possible accidental re-entry into hydrological system. If trapped pollutants are "held" for removal (trucked away, etc.), the role of maintenance is crucial. If facilities are not properly serviced, their effectiveness could be impaired, possibly causing release of pollutants. Additionally, the location of final (transported) disposal points need to be identified for holding/storing mechanisms. Sections 3.6 and 4.6 BIOLOGICAL RESOURCES. P. 3-28 identifies the study area (impact area) for the project. The limits of disturbance as brought about by the corridor are defined as 1/4 mile on either side of the ROW. While this definition appears adequate for consideration of project ground coverage as affecting plant species, the Coastal Commission staff believes that this definition is not broad enough when considering wildlife impacts. The consideration that these plant communities are major components of habitat for wildlife in the area demonstrates the broader range of project impacts. These portions of wildlife habitat will be permanently lost. P. 4-64 through 4-69 discuss the pressures placed on wildlife in southern Orange County, particularly through the loss of habitat. Because wildlife populations in these habitat areas "are at carrying capacity," loss of habitat in one area will force further crowding into adjacent habitat areas. P. 4-64 states that "there is no available habitat for wildlife moving into an° -area." It goes on to describe how overcrowding into remaining wildlife areas may result "in an overall reduction in local wildlife populations," brought about by increased competition for food and resources. Therefore, wildllife and their habitat areas within the coastal zone are directly affected by the loss of habitat in the immediate 2-8-27 2-8-28 2-8-29 2-8-30 2-8-31 Letter to Steve Letterly November 26, 1990 Page -8- vicinity of the project ROW. Additionally, the corridor impacts wildlife of the coastal zone in several other major ways as described in the DEIR/DEIS, including: fragmentation of habitat areas, interruption of wildlife movement/dispersion patterns, road kills and noise impacts. These impacts will occur both in areas where the coastal zone is contiguous with or intersected by the corridor, and through spillover effects to coastal zone wildlife which moves into and out of the corridor ROW area. While major impacts to the coastal zone occur from loss of plant species which constitute habitat, as discussed above, the physical loss of plant species (especially sensitive plant species), as identified in the DEIR/DEIS, will occur within the coastal zone boundaries. These are significant impacts to the coastal zone. Additionally, some plant species located downstream from the project area could suffer, namely those occurring in wetlands which could be affected by the project. T2-8-31 2-8-32 2-8-33 Table 3.6 A would be greatly enhanced, for purposes of Coastal Commission 2-8-34 review, if it were modified to identify which species are coastal species. P. 3-45 acknowledges the effect of the project on wildlife species within the coastal zone in its analysis of the California mule deer. Again, it would be 2-8-35 . useful for our purposes if similar analysis were to be conducted for other species affected by the project which occur in the coastal zone. P. 3-47 maps major wildlife movement corridors in the project area. These corridors feed into the coastal zone in at least seven entry points. These include Emerald Canyon, Morro Canyon, Tributary to Morro Canyon, Muddy Canyon, Los lrancos Canyon, Coyote Canyon, and Bonita Canyon/San Diego Creek. The corridor would significantly disrupt movement into and out of the coastal zone by wildlife (p. 4-64). 2-8-36 P. 4-68 and 4-69 describe the importance of large, permanently protected contiguous areas of open space in mitigating the effects of habitat loss caused by the corridor. It cites as an example the Irvine Coast Open Space Dedication program. However, it is unclear as to the status of several of the large areas proposed for dedication. While the Coastal Commission staff agrees with the DEIR/DEIS that protection of open space cannot completely offset negative impacts from the Corridor (in this case to habitat and wildlife), we support the concept that completion of this dedication program as soon as possible (i.e., all lands dedicated and permanently protected) would be partial mitigation for such impacts. However, as is stated in the DEIR/DEIS, even if the current dedication program is completed as planned, the Corridor will still result in a net loss of habitat and open space. To improve its effectiveness as mitigation for corridor impacts, the Irvine Coast Dedication program (or similar program such as the Laguna Greenbelt) could be be expanded to include other uncommitted vacant land in the area not currently 2-8-37 part of the program. Similarly, such vacant areas could be added to other area open space protection programs, such as state, regional and county parks. Finally, planned, but not built, residential uses could be Letter to Steve Letterly November 26, 1990 Page -9- 0. redesignated as open space and dedicated to any of the open space programs described above. The completion or improvement of such permamently protected open space programs, and as such the habitat protection they provide (and mitigation for other project impacts discussed under different headings in 2-8-37 this DEIR/DEIS), could be presented as mitigation for project impacts, and possibly as conditions or stipulations for approval. (This comment similarly applies to comments on the sections below addressing Wetlands, Land Use, Visual; and Growth Inducing impacts.) Sections 3.7 and 4.7 WETLANDS. P. 4-73. The definition of the area of impact needs to include wetlands in the coastal zone which, while not in project area, could experience spillover 2-8-38 impacts from upstream project activities (such as sedimentation or polluted runoff). Interactive elements which could be impacted by alteration of Bonita Canyon Reservoir (p. 4-81) would be likely to cause impacts to coastal zone wetlands downstream (this is a good example of spillover effects). P. 4-81, bottom provides further indication of this potential (increased siltation). The other similarly impacted areas in the coastal zone should be similarly 2-8-39 analyzed. Again P. 4-82, top, is a good discussion of downstream effects caused from site alteration in the project vicinity. This case includes reducing/increasing water flows to wetlands, increased erosion, and scouring of vegetation. These impacts are discussed generally, but should be related to specific wetland/drainages occurring in the coastal zone. There is extensive discussion of wetlands mitigation to offset wetlands loss from the project. However, the mechanism identified to address this, a Wetlands Mitigation Plan, is incomplete. We agree with the DEIR/DEIS statement on p. 4-73 that "all acreage impacts to wetlands habitat are considered significant." Wetlands replacement, while not a complete mitigation for wetlands loss, could lessen the impacts on such as created by the Corridor. However, we do not believe the DEIR/DEIS has established, in its statement under Significant Unavoidable Adverse Impacts, that all wetlands 2-8-40 impacts would be mitigated below a level of significance through wetlands replacement and other mitigation measures. Accordingly, we wish to participate in all phases of the creation, review and implementation of the Wetlands Mitigation Plan, and we would appreciate being sent a copy of plan as 24-41 it currently exists. Without a finalized Plan, we are unable to determine whether it would take into account regional and cumulative impacts to wetlands, and whether mitigation measures will be adequate to implement the goal of "no net loss of wetlands." Section 3.8 and 4.8 LAND USE. Within the coastal zone, the Local Coastal Plans (LCPs and LUPs) establish the allowable locations, densities, and types of development which can occur in their planning areas. The Coastal Commission believes the Corridor has the 1 2-8-42 Letter to Steve Letterly November 26, 1990 Page -10- potential to create pressures to develop areas in the coastal zone which would not be consistent with certain areas' LCPs/LUPs. The types of development which would be considered inconsistent would be characterized by: higher than allowable densities, or expansion of land area devoted to development beyond that allowed by the LCPs/LUPs (e.g., conversion of open space or agriculture 2-8-42 to residential development). The discussion of project impacts to land use, which includes discussion of applicable LCPs and LUPs, does not provide adequate information/data to evaluate whether or not the types of land use changes described above could result directly or indirectly from the planning or construction of the Corridor. For more discussion see comments under Growth Inducing Impacts. P. 4-91 discusses permanent open space to be dedicated west of corridor. More detail is needed on the size and status of this proposed land dedication. Also, it is unclear if the dedication will only occur if the corridor ROW is also dedicated, or whether it would or could occur without the Corridor. In general this would be a good section to present a clear explanation of the 2-8-43 status (e.g., protected, not protected, permanent, dedicated, etc.) of the various open space programs in the area (Irvine Coast, Laguna Greenbelt). Such discussion should include a clear map (the land use map in section 3.8 is good for other purposes but not this purpose) of all open space in the area (planned, not planned, committed , not committed). 10 P. 4-95. The discussion of local coastal programs does not include mention of I2-8-44 the LCP/LUP for the the City of Laguna Beach. This needs to be included. P. 4-94 and 4-96 do not give enough information as to the consistency of 2-8-45 wetlands impact from the corridor (San Diego Creek/Bonita Creek) with the City of Newport Beach's LUP. Conversion of "prime farmland" appears to be within 1000 feet of the coastal zone (p. 4-97). Is any portion of it within the coastal zone? P. 4-97. The discussion of impacts to recreation areas needs to identify and assess impacts to local coastal recreation destinations. Main issues of concern here would be impacts to local roads and parking used for heavy recreation demand. Newport Beach, Corona Del Mar, and Laguna Beach already experience severe congestion problems during peak periods. How would the Corridor add to current congestion of roads and parking in the local vicinity of these coastal recreational resources? Section 4.14 LANDFORMS. 12-8-46 2-8-47 Potential significant adverse effects of project related grading as presented on p. 4-118 have the potential to create spillover effects into the coastal 2-8-48 zone (See comments on Geotechnical, Water Resources, Wetlands and Biological Resources). Specifically, we have questions based on P. 4-118, where the DEIR/DEIS discusses of 4.5 million cubic yards of "excess material" as having12-8-49 . • Letter to Steve Letterly November 26, 1990 Page -11 - already been utilized by developers "during site grading operations." Does this mean that some grading for the Corridor has already occurred? If so 2-8-49 please supply information as to when, how much and the type of permit granted for such activity. Section 4.13 and 4.15 RECREATION and VISUAL RESOURCES. Our concerns over visual impacts on the coastal zone are primarily based on impacts mainly from a recreational user perspective. The activities of the project most likely to impact these viewsheds are landform alteration and grading/cut and fill. These impacts would be considered significant impacts to the coastal zone. Therefore, the EIR/EIS should identify coastal areas with prominent viewsheds as described above and include them in the Visual Resources analysis. Section 6.0 GROWIH-INDUCING IMPACTS. The Coastal Commission staff believes the project has the potential to cause growth inducing impacts "either directly or indirectly, in the surrounding environment (CEQA guidelines)," which includes the coastal zone. The primary mode of growth inducement includes the following forms as identified in the DEIS/DEIR (p. 6-1): (1) "provide access (for growth) or eliminate other constraints (to growth) which (by their elimination) encourage growth that has already been approved and anticipated through the General Plan Process;" and (2) "provide new access and/or otherwise encourage growth which is not assumed as planned growth" (e.g. conversion of open space designations). With respect to the coastal zone, our primary concern with respect to growth inducement is that increment which would be induced above and beyond that amount planned for in the area's certified Local Coastal Programs (LC -Ps and LUPs). We do not believe the DEIR/DEIS provides sufficient information or analysis supporting a conclusion that development in excess of planned growth would not be triggered by the proposed highway. Similarly, the DEIR/DEIS does not provide sufficient information or analysis supporting a conclusion that the Corridor would not contribute to the conversion of unplanned, undesignated or otherwise not permanently protected open space areas into more intensive use, such as , residential development. We also seriously question statements, such as that on p. 6-2, that new highways do not induce growth. The DEIR/DEIS appears to rely on statements that the Corridor is shown to be referenced in nearly all of the area's city and county plans. The DEIR/DEIS states: "since 1976, (when the Corridor was first identified on the Master Plan of Arterial Highways) a substantial portion of the Area of Benefit has been the subject of considerable planning efforts. The Corridor has been assumed in all the resulting land use approvals approved since...." The discussion which follows presents the view that if plans and development approvals in the Corridor's Area of Benefit have taken into account construction of the corridor, that the corridor would not induce growth in the areas covered by these plans. This simply supports a conclusion that the highway has already induced growth, notwithstanding the fact that it has not yet been constructed. Further the L2-8-54 2-8-50 2-8-51 2-8-52 2-8-53 Letter to Steve Letterly • November 26, 1990 Page -12- DEIR/DEIS provides insufficient evidence supporting a conclusion that the �2-8-54 growth induced would be limited to planned growth. The credibility of the document is further weakened by its failure to acknowledge the growth 2-8-55 inducement potential of new highways. Furthermore, at the bottom of p. 6-11, a clear recognition of the potential for the transit facility (light rail) to cause growth -inducing impacts "beyond what is currently planned" is presented. The transit element is an integral component in one of the two major alternatives, and is mentioned as essential for the project to fulfill requirements of other area plans (such as transportation and air quality). 2-8-56 Thus it is considered a major part of the project as a whole. The fact that phasing would cause the implementation of such transit operations to occur later does not remove the transit element from consideration as a unified part of the project currently under review. Finally, we note that the document anticipates one growth inducement in north San Diego County (p. 6-12); however the document does not provide sufficient information to enable a determination as to whether the growth inducement would be for planned or unplanned growth in that area. Therefore, all aspects of the project which could induce growth (regardless of phasing considerations) will be considered in any analysis by the Commission on growth inducing impacts from the Corridor. thank you again for the opportunity to comment. We look forward to working with you further on coordinating a formal Coastal Commission review process that addresses those elements of the project which trigger review through our permit or federal consistency procedures, and again, we intend to write you with further details on those processes in a separate letter. If you have any questions, please do not hesitate to contact me or Gerry Chalmers of my staff at (415) 904-5280. Sincerely, MARK DELAPLAINE Federal Consistency Supervisor cc: Teresa Henry, Long Beach District Office Deborah Lee, San Diego District Office 2-8-57 8128P 0 STATE OF CALIFORNIA—THE RESOURCES AGENCY GEORGE DEUKMEJIAN. Governor CALIFORNIA COASTAL COMMISSION 631 HOWARD STREET, 4TH FLOOR SAN FRANCISCO,,- CA-94105-3973 / (415) 543.8555 Hearing Impaired/TDD- (415) 896-1825 0:0 jw,s _ • December.21, 1990 Steve 1._et:terly San Juaquin Hills Transportation Corridor Agency 345 Clinton Street Costa Mesa, CA 92626 Re: San Juaquin Hills Transportation Corridor. Dear Mr. i. ottorly : The Coastal Commission has requested input from the office of Ocean and Coastal Resources Management (OCRM) on the issue of the Commission's review of the San Juaquin Hills Transportation Corridor (SJHTC) project for consistency with the California Coastal Management Plan. Our request to OCRM is necessitated by the fact that the Federal Highway Administration's licensing of the project's connection to Interstate 5 is an "unlisted" federal activity as defined in the California Coastal Management Program (CC:MP). Therefore, by this letter, we are providing you notice that we have requested permission to review from the OCRM, or a statement from the OCRM that the need for such review has nut yet Men triggered at this phase in the licensing. For further details on this request, please see the attached letter to OCRM. For other questions regarding federal consistency pertaining to the SJHTC, pl.ea3e contact, me at (415) 904-52.89, or Gerry Chalmers, Project Manager, at (415) 904-•-5272. Sincerely, )1�, 1.-3 4L.— Mark Delapl.aine Federal Consistency Supervisor cc: Timothy Keeney, OCRM Rudy Chavez, Caltrans Teresa Henry, Long Beach District 8320P 0058 STA'E OF CALIFORNIA—THE RESOURCES AGENCY GEORGE DEUKMEJIAN. Governor iFORNIA COASTAL COMMISSION 6 OWARU STREET, 41H FLOOR :�•� / AN MUMS �4151 54 ;055.- •'' Read ' A+�ir�?T$61d15� 89,�28.�5 45 FREMONT STREET, SUITE 2000 SAN FRANCISCO, CA 941D5.2219 ,415) 904-5200 December 21, 1990 Timothy Keeney, V rector Office of Ocean and Coastal Resources Management 1825 Connecticut Ave., N.W., 8th Floor Washington D.C. 20235 RE: Poten 'al, Request to Review Unlisted Federal Activity Dear Mr. Kpyy On Novem er 26, 1990, the California Coastal Commission received notice indicating that the Federal Highway Administration (FHWA) would, at some future date, be considering approval of the proposed San Juaquin Hills Transportation Corridor freeway connection to Interstate 5, in southern Orange County, California. This federal authorization includes the preparation of a new connection report by Caltrans and its review and approval by the FHWA (23 CFR 625 et seq). The Coastal Commission staff believes this connection approval could be perceived as constituting notice of an application for a federal permit or license for a project affecting the coastal zone within the meaning of those terms as they are used in CZMA section 307(C)(3)(A). While the majority of the project, including the interchange/connection site, is physically located outside the coastal zone (Exhibit C), we have concluded that the entire project will affect coastal zone resources through both direct and spillover impacts. Therefore we believe the connection license triggers project —wide review for federal consistency with the CCMP. Coastal concerns raised by the project and as identified in our recent comments to the project's DEIS include, but are not necessarily limited to, project effects on geology/geomorphology, hydrology, water resources, biological resources (including wetlands and other environmentally sensitive habitat areas), planned land uses, landform alteration, visual resources, recreation, and growth inducement (please see Exhibit A, Coastal Commission comments to the DEIS dated 11/26/90, for detailed discussion of such impacts). 2-8-58 Timothy Keeney December 21, 1990 Page 2 It is our belief that this November 26 FHWA letter does not constitute the formal notice triggering the need for us to ask for your approval at this time. However, because the potential exists for an assertion that the November 26 FHWA letter does constitute such formal notice, and because the connection license is'an unlisted activity under the CCMP, we feel compelled to write you this letter requesting that you either: (1) Confirm in writing that the November 26 FHWA letter does not constitute the formal notice triggering the need for us to ask for your approval to review the activity for consistency at this time; or (2) If you disagree with us and believe that :he November 26 FHWA letter does constitute the requisite formal notice, we would ask that you approve our request to review this project for consistency with the CCMP (in which case please consider this letter our formal request). To assist you in your decision, we have attached: (1) a copy of the Coastal Commission staff's comments on the DEIS for the SJHTC (Exhibit A); (2) a copy of the letter from the FHWA describing its involvement with the project (Exhibit B); and (3) a map depicting the project right—of—way, the location of the coastal zone boundary, and the interchange/connection site (Exhibit C). If you need more information or have any questions, please contact Mark Delaplaine, Federal Consistency Supervisor, at (415) 904-5289, or Gerry Chalmers, Project Manager, at: (415) 904-5272. Thank you for your consideration of this matter. Si rel , /WE4DOUGLAS Executive Director cc: Steve Letterly, Transportation Corridor Agency Jim Bednar, FHWA Rudy Chavez, Caltrans Teresa Henry, Long Beach District 8279P 2-8-58 • L' 0 Museum of Systematic Biology University of California, Irvine, CA 92691 Steve Letterly San Joaquin Hills Transportation Corridor Agency 345 Clinton Street Costa Mesa, CA 92626 November 23rd, 1990 Mr. Letterly: Thank you for the opportunity to comment on the San Joaquin Hills Transportation document, EIR/EI8 1. I have several concerns regarding this document and its associated technical reports. Controversy/Issues be resolved (S-6): One issue that should be discussed is premature grading. This issue is a very significant environmental impact and is contrary to the CEDA process. There are three segments that have been graded prematurely and are of high biological resource value. Furthur more, there is no discussion of these gradings and their existing impacts in the biological resource section. - The first segment was graded in 1987. This is a segment running from El Toro road to the top of the ridge crest east of El Toro Road (approximately one-half mile). In addition to excellent quality coastal sage scrub and chaparral habitat, this area the base of the hill ` removed for the clover leaf interchange has been determined as the 2_9~1 possible Type -locality for many -stemmed Dudleya <Du�lev� m�l±j�� >° This plant is listed as List 1B by the California ��ative Plant Society and is a Federal Candidate List 2. A Type Locality represents the population from which a species description is based. The significance of the destruction of a Type Locality can not be stressed. If there is future taxonomic work required on this species, we will have nxxthi,ng but a handful of decade old specimens to work with. Fresh material will be unavailable. ' Ironically, the very hill that may represent the Type Locality of many - stemmed � stemmed Dudleya has now been' eliminated from the project with the deletion of the clover -leaf structure. Of course now, the hill is already gone. This is an excellent example of why a project should be �approved through due process before grading begins. -1- The �a��n� ����p�e uf preinaTure qraOio� fool- p|sco `n Upper WooJT Canyon and along the Moulton-Aliso Crest during late 1989 or early 1990. This portion removed coastal sage scrub habitat and destroyed known sites for the California Gnatcatcher, Orange -Throated Whiptai1v Many -stemmed Dudleya and Orange County Turkish Rugging. At the time of report preparation, all three species were listed as Federal Candidate species for listing as Threatened or Endangered (Orange County Turkish Rugging is no longer a Federal Candidate but remains a CNPS List 1B species). The plant species are mentioned in the report but there is no qualifying statment indicating that these species have already been removed. The EIR should include such information. The third and most recent example* of premature grading took place at the University of California, Ir*ine's Ecological Preserve. In September 1990, a hill was removed that contained coastal sage scrub and an associated population of California Gnatcatchers and Cactus Wrens, Many -stemmed Dudleya and Orange County Turkish Rugging. This grading was reported to be part of the Pelican Hills Road project but the resources eliminated are not addressed in the Pelican Hills Road EIR and that EIR clearly indicates that no such grading is required by the Pelican Hills Road project. 2.9 Environmentally Superior Alternatives ` �Once again, the "No project alternative" has not been fully addressed. Assumptions here indicating a general worsening of traffic, overall living, air quality and other aspects if the corridor is not built does not take into account the possibility of removing cars from the road �and presuading the population to change its life style. This corridor �is a band -aid approach to traffic problems. A no project alternative was also adressed in the FTC document with the same conclusion. I both � . n cases, the EIR is not looking at the problem objectively, rather being used as an advicating document. Both corridors create significant impact into important and unique wildlife regions. Neither corridor is truely necessary and the "No project" alternate could be used as a medium to explain some of the ways we could get around building in high �quality habitat. 3.6 Biological Resources: There is no on of studies conducted for P & D Technologies made in 1988. Several of these studies are cited in A Biological Resource , June 1988 with references to additional needed 2~9~5 studies. At least a portion of these studies were completed. It appears that none or little of this information, particularly of the fo%lowup studies, were incorporated into the present document. Some of my following concerns were addressed in these earlier documents. % see no reason why these documents were not encorporated into the present �document. 0 2-9-6 Table 3.6.A Where as th4 s table addresses a number of species with virtually no chance of occurance along the SJHTC, it has left out other sensitive species that are definately known along the corridor route or are known to occur within several miles of the corridor route. The following plants should be addressed in this document: Calochortus catalinae - CATALINA MARIPOSA LILY (CNFS List 4) Comarostaphylos diversifolia ssp. diversifolia - SUMMER HOLLY (CLAPS List 1B) Dichondra occidentalis - WESTERN DICHONDRA (CNFS List 4, FedCan 3c) Harpagonella palmeri - PALMER'S GRAPPLING HOOK (CNFS List 2) Hemizonia australis - SOUTHERN SPIKEWEED (CNFS List 4) Polygala cornuta ssp. fishae - FISH'S MILKWORT (CNFS List 4) Physalis greenei - GREENE'S GROUND CHERRY (CNFS List 3) Quercus dumosa - COASTAL SCRUB OAK (sp. of local concern) Verbesina dissita - BIG -LEAVED CROWN BEARD (CA Th, CNPS 1B) At least two of these species were addressed in the 1988 document. Infact, in 1988, Catalina Mariposa Lily was simply a species of local concern, now that it is a CNFS listed plant, it has been removed from 2-9_7 consideration. This is precisely how List 4 plants become List 2 or lb plants and eventually end up listed by the agencies. These reports, by their very nature should be somewhat complete so that cumulative impacts can be understood. There are at least two more Federally endangered, animals that should be addressed by this report: The Least Tern and the Light -Footed Clapper Rail. Both of these animals would be impacted by bridging San Diego Creed-. The California Least Tern forage along San Diego Creek. Discussion should be expanded to include Coyotes and how the building of the corridor will impact coyote movement. Coyotes are necessary to 2-9.8 the ecology of both birds by keeping out the threat of red foxes invading Newport Backbay. If the corridor blocks the coyotes from access, the project will be violating the Federal Endangered Species Act. Figures 3.6.3 and 3.6.4 Sensitive species recorded in the 1988 surveys were left off these figures. See discussion under Gnatcatchers, Orange -Throated Whiptails and Figures 4.7.1 to 4.7.7. 2-9-9 Coastal Sage scrub habitat was more common along the central portion of the alignment than indicated on these maps. Premature grading has eliminated an additional 21 acres between March 1989 and August 1990 in the vicintity of Upper Woods Canyon. An additional undetermined aceage was eliminated in pre-1989 activities. These areas should have been included as part of this EIR. Again this is another example of why this remature grading activity is environmentally harmful. -3- Grassland (pg. 3-37) 2.9-10 Native and Introduced Grassland should be seperated. The Fish and Game Natural Heritage Program currently lists Native grassland as a threatened plant plant association. 2-9-11 2-9-12 2-9-13 |Coastal Sage Scrub - Mixed (pg. 3-37) The title of this community is unclear in context of the definition. The definition describes coastal sage scrub (briefly)v why not just �call it that, or conversely, qualify the designation. Coastal Sage Scrub is a vegetation community with increasing concern attached to it, both on a local and statewide scale. There are mixed and ill-defined stands of the various shrub communities along the corridor, but there are also pure stands of coastal sage scrub. With the amount of time and money spent on this project, these associations should be clearly deliniated. Sensitive Plant Species (3-39) As stated earlier, there are many species missing from this section. Additionally, there is good data that appeared in the 1968 document that should have appeared in this document: clear and conscise tables that describe the nu'ber of populations of Orange -County Turkish Rugging and many -stemmed Dudleya. The spring data often mentioned should have been added to these tables and the whole lot of them reproduced here. As presented, is difficult to get any clear idea as to just what an impact the SJHTC will really have on these populations. Orange County Turkish Rugging (3-39) The eastern extent of- this taxon is poorly understood. Plants desplaying characters indicative of Orange County Turkish Rugging also occur in Rancho Mission Viejo and Mission Viejo. James Reveal also stated (Phytologia 66: 96, 1989) that this form is "arguably distuishable". Reveal's statments on OCTR have at times been confusing" During one discussion sponsered by MBA in 1989 he indicated that there probably is some recognizable variations within this species but it would take at least 5 years to understand them. His project at the time concerning the genus Chorizanthe did not have that type of time line so he argued it was better not to recognize subtaxa at this time. Reveel's arguments were based only on herbarium specimen examination, not growth studies. I conducted relatively simple growth comparison studies in spring 1990 and found that genetic variation did occur between inland and coastal populations. Reveal argued these differences were strictly ecological. This is now known not to be true. Further study is warrented and populations of this plant should continue to be mwf concern. 0 The EIR destroyed • 2-9-13 the U. C. Excellent available report. 2-9-14 should state that populations of this plant have already been in association with this project in Upper Wood Canyon and on Irvine Ecological Preserve. tables discribing the distribution of this plant are in the 1988 report. These tables should be included in this Many -stemmed Dudleya (3-40) The EIR should state that populations of this plant have already been destroyed in association with this project in Upper Wood Canyon and on the U.C. Irvine Ecological Preserve. The EIR should also address and research the possibility that pre- mature grading near E1 Toro Road has destroyed the Type Locality of this species. Without the Type Locality, future taxonomic work relating to this species could be considerably more difficult. Certainly, a population of rare plants representing a Type Locality for the species should be allowed the full CEGA process before removal. See final remarks under last entry. Orange -Throated Whiptail This rare lizard has been sighted 2-9-15 the corridor alignment in 1988. though biologist associated with of it. Of course, this portion is why it is no longer considered California Gnatcatcher (3-42) 2-9-16 on the Aliso-Moulton ridge portion of It is not addressed in this document previous studies were definately aware has already been graded and maybe that important. The data supplied with the EIR on this bird is completely inadequate. There is information available that indicates widespread occurrence along the SJHTC. This information was made available as a supplement to the 1988 Biological Resource Analysis. I see no reason why it was not included in this document. At least one additional record exist just east of the Pelican Hills Road interchange, numerous records occur in the vicinity of Sand Canyon Road and are found scattered toward Laguna Canyon. Gnatcatchers are frequently reported from the Syscamore Hills and a large population was known from the Aliso-Moulton Ridge area. Of course this later population has been completely eliminated within the last sir, months by premature corridor grading and an agressive August "weed abatment" program by the Mission Viejo Company. Of course that could be why they are not mentioned - afterall there are no Gnatcatchers there now. Unfortunately guys, the EIR should address this anyway. Again, premature grading impacts in the U.C. Irvine Ecological Preserve should also be addressed. -5- Cactus Wren (3-43) 2-9-17 See remarks for California Gnatcatcher, again, much more information is available for the Cactus Wren and it indicates that the birds are fairly widespread in the corridor's western portion. 2-9-18 2-9-19 Pacific PocE::etmouse Although listed in Table 3.6.A, this species is not discussed. Since the mouse was known to occur in the vicinity of San Joaquin Reservoir and Puck Gully during the 1970's it seems very likely that this species could occur along the corridor route. No recent sightings have been made and for all we know, the mouse is already extinct. Before we severely impact more of its dwindling habitat, it might be a good idea to look for it. The mouse is not easy to trap. Studies made by UCI graduate students indicated that even when present, they were infrequently caught. Trappings must necessarily be longer than single night foray, rather organized over a more extended periods. With projects on Pelican Hill, Buck Hill and proposed projects west of Signal Hill, the SJHTC just might signal the end of this subspecies. The status of this mouse has been continually set aside and put off. If we are going to make any attempt to save this species, now would seem like a good time to address it. Aggressive surveys should be carried out in appropriate habit before this document is certified. California mule Deer (3-45) The information supplied on populations of Mule Deer in the San Joaquin Hills are completely inadequate. More information was supplied in the 1988 document. In both cases, the deer population is considered to be small and apparently unimportant. I disagree with the findings. My own casual observations in the San Joaquin Hills indicate there are plenty of deer present although the populations may not be as large as in other areas. Still, more information and data should be made available in this report. Even the value given here indicates there must be at least 125 deer present west of E1 Toro and Laguna Canyon Roads. Lets see some more precise data on this. Or at the very least, some comparison qualifying why this is a small number of deer should be included. Table 4.6.A. This table should differentiate introduced and native grassland associations. The values given here are misleading. For example, there is at least another 21 acres of coastal sage scrub that was graded after January 1989 along the corridor alignment in the vicinity of 2-9-20 Upper Wood Canyon. An undetermined amount was lost in 1987 in the first such grading activity along with chaparral habitat. These values should be added to the values displayed in these tables. It is unethical to a=Ileatr Ilamd an cc(mm-tuimactitan wdth the SZHMC par®jiecct and then discount the -b- 0 habitat value when the EIR comes out because there is nothing there now. This is a disturbing trend that is begining to show increased 0 favor in southern Orange County planning. Other examples in the same 2-9-20 area include an agressive "weed abatment" policy by the Mission Viejo Company and clearing at least 11 acres of wetland in Oso Creed: though projects for these sites are still years away or not approved. 2-9-21 9 2-9-22 2-9-23 C Sensitive Plant Species (4-64) The populations on Aliso-Moulton Ridge, E1 Toro Ridge and in the UCI Ecological Preserve have already been destroyed by premature grading. This section should diferentiate between what has been lost and what is expected to be lost. Ironically, though the coastal sage scrub is not shown in the document in the vicinity of Upper Woods Canyon, no Gnatcatcners, Cactus Wrens or Orange -Throated Whiptails have "survived", we still have our populations of Orange County -Turkish Rugging and many -stemmed Dudleyas shown just as if they were still there. Wildlife Movement (4-64 to 4-66) Although this document reports eleven different wild corridors that will be impacted by the SJHTC, it indicates that a single tunnel structure in Upper Shady and Emerald Canyons will be sufficient. Not only is the proposed design completely incompatable with wildlife movement (only bats are going to use this proposed mine shaft), to parahrase wildlife expert Paul Bier on comments relating to the FTC, it is completely ridiculous to assume that an animal that wants to cross from Bommer Canyon into Moro Canyon has to travel two miles eastward. first when Bommer and Moro Canyons are adjacent. Sorry folks, but unless the SJHTC project is planning to put up a lot of signs and start giving English lessons to the wildlife (now that would be an expensive project!), it just won't work. Culverts and tunnels are not adequate mitigations for wildlife movement. Paul Bier has studied wildlife movements in east Orange County and found that bridges are the only acceptable mitigations short of not building the road or moving it. Wildlife can coexist with the SJHTC in the San Joaquin Hills but as presently concieved, the road will simply add to habitat fragmentation. The proposed crossing should be bridged. In addition, bridges should be considered west of Laguna Canyon Road (or perhaps just raise the entire Laguna Canyon-SJHTC interchange structure) and in the vicinity of Bommer-Moro Canyon. Additionally the bridge over San Diego Creek should be raised significantly (mcre like that over MacArthur) and definately not like the bridge at Jamboree. We can get away with one such bridge, but two will significantly impact wildlife movement. between the bridge at California (not even mentioned in this report), MacArthur, Jamboree and the SJHTC, San Diego Creek will be like a tunnel unless steps are taken now to rectify the problem. A better connection should also be found for the Bonita Canyon connection. The mitigation presently -7- proposed will just not do it. There should be some form of buFfer zone, 2-9-23 with little or no concrete, again perhaps a r a sed structure. Sensitive Wildlife Species (4-68) More attention and discussion 2-9-24 giving. In addition, further distribution should be included. 2-9-25 2-9-26 Figures 4.7.1 to 4.7.7. of California Gnatcatcher should be studies of Orange-THroated Whiptail These figures are incomplete and even a little confusing. Figure 4.7.3 shows only populations of Orange County Turkish Plugging and many - stemmed Dudleya. There should also be a fair number of California Gnatcatcher symbols on this map and a number of cactus wrens indicated. At least two Orange -Throated whiptails were also located along this segment. It would also be helpful to indicate which ares of this (segment were graded when. In reality, none of this segment is still in Tits natural condition. Which returns my discussion once again to the premature gradings along this road. Somewhere, this document should e-plain just how this grading fits into the CEQA process. I was always of the understanding that CEQA requirements came first, followed by project approval and finally alteration of existing habitat. This one map shows more clearly than any I have seen in any other document why this important and why the process is so ordered. If I and others had been unaware of this, it would never have been illuminated and simply slipped through the cracks as if it never occurred. Figure 4.7.4 also should indicate the presence of Gnatcatchers, Canyon Wrens and Orange -Throated whiptails. Such data is available through 2-9-27 earlier studies. 2-9-28 JFigure 4. 7. 5 is out of order in addition to not showing Gnatcatcher localities in the vicinity of Sand Canyon interchange. JFigure 4.7.6 should have been placed before 4.7.5. What happened to the 2-9-29 3000ft segment between 4.7.5 and 4.7.4? There were Gnatcatcher localities along this segment as well. Figure 4.7.7. More Gnatcatcher localities are available in earlier documents. One should be placed in the middle of the corridor north of Bonita Canyon Reservoir. Premature grading along the UCI Ecological 2-9-30 preserve should have been indicated. Additionally, sensitive resources impacted by both the SJHTC and Pelican Hills Road should have been clearly shown. There is a debate at UCI brewing over illegal grading in this area. Grading that is clearly associated with the SJHTC is being 2-9-31 attributed to Pelican Hills Road even though the PCH EIR shows no such activity is required. -8- • • General Remarks: According to the dEIR, the impacts to wetlands were only determined to the limits of grading. Impacts of the construction zone almost always extend a significant distance beyond the limits of grading. This area should be determined and included in the area of wetlands impacted. 2-9-32 Fences should be installed around wetland areas located outside of the construction zone to insure that those wetlands are not impacted. 2-9-331 The dEIR (pg 4-20) discusses the impacts of the streambed modification noting the potential fro proposed impacts to create streambed headcutting or downstream deposition. This will likely cause indirect wetland impacts not considered by the dEIR, and not included in the amount of compensatory habitat proposed to mitigate for wetland losses. These impacts should be included when determing wetland impacts. The proposed channelization of portion of Bonita Creek, Laguna Canyon Channel, Coyote Canyon Channel, Oso Creek (Conventional Alteration only) will prevent the use of these waterways as wildlife movement corridors. If a 50' wide riparian corridor consisting of native 2-9-34 vegetation (which is not to be cleared) is located within these channels, the impacts on wildlife will be reduced. A grass -lined channel is not adequate; grass does not provide adequate cover. Underground culverts do not act as wildlife corridors and should be avoided. IThe dEIR comments that impacts to wetlands will be mitigated to a level below significance, while at the same time acknowledging that streambeds (which provide the water to wetlands), floodplains (often the location of wetlands), and water quality (the driving force behind wetlands) will be subject to significant unavoidable adverse impacts. Wetlands and wetland values cannot be preserved merely by providing 2.9-36 replacement habitat at a one to one or greater ratio. If water quality is significantly adversely modified, then all wetlands (both preserved and created) fed by that water will be significantly adversely modified. If alterations to streambeds and floodplains are significant and adverse, then wetlands located in or downstream of those areas will be adversely modified. The dEIR lists impacts to floodplains and streambeds seperately from impacts to wetlands. If floodplains and streambeds are wetlands (i.e., 2.9-36 if they contain hydric vegetation - hydrology can be assumed and soils -- do not need to be considered because of the sandy soil exception in the Federal Manual) then they should be included in the total acreage of wetlands impacted by the proposed corridor. In in addition to the specific known some concerns which I can 2-9-37 EIR. The mainline Toll fascility of a large tract of natural open • remarks above, I would like to make not find a specific reference in the appears to be situated in the middle space, possibly within the boundaries -9- of Crystal Cove State Park. The EIR should discuss this in some detail. For one thing, there are plenty of places along the alignment where 2_9_3such a station could be placed that would have a minimal effect on U ^natural habitat, which is going to be impacted enough as is. Discussion of alternatives is too limited and nothing is said about what support fascilities and roads the Toll station will require and what impacts these will have on the surrounding environment. At the very least, this 2_9_38 station should not be adjacent (or buildt within) Crystal Cove State VPark. As a final remark on the main text of the dEIR, the mitigation measures suggested for sensitive species is completely inadequate. Several options are infact available. One possiblity would-be acquire habitat 2~9~39 or populations with similar sensitive species (such as California Gnatcatcher or many -stemmed Dudleya) that is adjacent to or very near the corridor and give them permanent protection. This could be oone in Kthe vicinity of Upper Woods Canyon, Shady or Bommer Canyons. 2-9-401 BIOLOGICAL TECHNICAL REPORT No. 5 Although the Technical report expands somewhat on plant community descriptions by giving area accounts, the report suffers from the same basic flaws presented in the dEIR. There is no reference to all the premature gradings and associated sensitive species, nor does it include all the sensitive species that should have been addressed. Since much of the information I see here is basically identical to what appeared in the dEIR, I will not duplicate my comments. On a positive note, I am pleased to see that a discussion, even though brief, of the Pacific Pocket Mouse has finally turned up. It is clear, however, from this report, that no serious attempt was made to locate it. This subspecies, if not already extinct, should be treated much more thoroughly and sought after with greater effort. Figures 1-10: These figures are identical to those appearing in the dEIR and suffer the same flaws: coastal sage scrub and sensitive species are not shown 2~9~41 in numerous places were they did occur prior to the grading that was Udone in conjunction with the SJHTC project that should also have been U "deliniated. BIOTIC RESOURCES BY AREA: JAs in the dEIR, the corridor is much more sensitive species "rich" than 2-9.42 indicated in this section. See earlier remarks. All information +rom available 19BB surveys should be added to this document. TABLE 2: As in the dEIR, at least 21 acres of coastal sage scrub, in addition to other habitats, was graded prior to completion of the CEGA process. This table should reflect these values. Perhaps more appropriately this table should seperate still occurring habitat from those graded between. 2-9-4311987 and 1990. APPENDIX. A: WETLAND IDENTIFICATION AND DELINEATION (pg 1): The Identification states "Wetlands possess three essential characteristics: (1) hydrophytic vegetation, (2) hydric soils, and (3) 2-9-44 wetland hydrology. These characteristics are mandatory and must all be met for an area to be identified as wetland." While this usually true, the Federal Manual for Identifying_ andVDel_ineating Jurisdictional Wetlands_ lists numerous exceptions. 2-9-45 IS Throughout the delineation (as indicated on the "Data Form, Routine Onsite Determination Method") the hydric vegetation criteria was misapplied. As determined from the Data Forms, the actual percent cover of a particular species was used in determining the percent of dominant species that are hydrophytic (OBL, FACW, and /or FAC).. According to the Federal Manual, the procedure is to identify dominants within each vegetative stratum and then determine when more than 50% of the dominant species are hydrophytic. Thus if for the shrub strata the dominant species were hydrophytic (accounting for 40% of the vegetative cover) and the dominant tree species was upland (and accounted for 60% of the vegetative cover), under the Federal Manual, 67% of the dominant species are wetland and 33 of the dominant species are upland thus this area would be considered to contain hy'drphytic vegetation. According to the method apparently used in this survey, this area would have benn considered an upland because the vegetative cover (60% upland) would have been incorrectly used to determine percent of dominant species. The criteria is percent of dominant species, not percent cover. We are currently in the fifth year of a drought. No mention was made of this fact in the Identification, thus presumably, it was not considered in determining wetland boundaries. This is important in determining whether the vegetation of an area is hydrophytic. The Federal Manual notes "be particulary aware of drought conditions that. permit invasion 2-9-46 of upland species (even perennials)." Given that drought conditions have prevailed for five years, upland annuals have probably invaded many areas which would ordinarily have hydrophytic vegetation. Consequently, annual species should not be considered in determining the dominant species. Also, the hydrology of an area can be obscured by drought. After five years of drought, groundwater supplies are likely to be significantly reduced, as are surface water supplies. In -11- n whether the hydrology criteria is met, an effort should be made to determine the hydrology for a normal year, not the fifth year 2-9~46Idetermining of a severe drought. 2-9-47 In several locations throughout the report, mention was made that the soils of an area did not meet the hydric criteria. Drought plays a part in this determination. Also important are the sandy soils of the region. No mention was made in the Identification of the Federal Manual's discussion of soils along western streams in arid and semiarid parts of the country. The manual notes: ...some river bars and [adjacent] flats may be vegetated by FACU species while others may be colonized by wetter species. If these areas are frequently inundated for one or more weeks during the growing season, they are wetlands. The soils often do not reflect the characteristic field indicators of hydric soils, however, and thereby pose delineation problems. Many of the areas considered in the Identification are in sandy areas 2~9-48 adjacent to intermittent streams. Thus this exception to the soils �criteria would apply and such areas should be reevaluated. 0-9-49 More particularaly, I am concerned about the following sections of the Identification: The flood retention basin adjacent to Oso Creek to the west was not considered to be a wetland. If, as the Identification suggests, this area was a wetland prior to construction of retention basin, it should be determined determined if the construction of the retention basin was authorized by the Corps of Engineers. If not, the area would be considered a wetland until otherwise determined by the district engineer of the Corps of Engineers. The retention basin was not considered a wetland because it lacked vegetation and because there was no evidence of hydric soils. This determination is questionable because (1) the need for a retention basin suggests hydrology, (2) teh vegetation within the flood control basin had been removed and regrowth may have been inhibited by drought, thus under normal conditions the vegetation criteria may be met, and (3) according to the Federal Manual, soils adjacent to streams in arid and semiarid regions "often do not reflect the characteristic field indicators of hydric soils, however, and thereby pose deliniation problems." If, during a normal year, the ground it saturated +or %#Yom or more daysv the soils criteria is considered to be met. ELTORO CANYON CREEK: ding to the Identification, recent road building associated with he flood retention structure to the east of El Toro Canyon Creek has Uresulted in the elimination of some wetlands. As with the Osc� Creek^� -12- • 2-9-50 "retention basin, it should be determined if the road construction was authorized by the Corps of Engineers. If not, this area should be considered a wetland until otherwise determined by the district engineer of the Corps of Engineers. An area vegetated primarily with rush and willow was not considered a wetland. However, according to the Federal Manual, when obligate species comprise all dominants in the plant community, the area can be considered wetland, provided significant hydrological modifications are not evident. The Identification claims that stream cutting has isolated populations of these obligate species. If so, the stream cutting must have been extremely rapid because these species need large quantities of water to survive. If the stream cutting was a result of the road building, it should be determined if the Corps of Engineers authorized the destruction of the downstream wetlands. If not, the area should be considered a wetland until the district engineer of the Corps of Engineers determines otherwise. LAGUNA CANYON: The Identification comments that heavy grazing in this area has decreased the quality and extend of wetlands in this area. If a 2-9-51 predominance of wetland species remain, this area should be considered a wetland because (1) the soils of this area are mapped as hydric, and (2) the creel, provides evidence of hydrology (possibly groundwater -- this may be more evident during periods of normal rainfall). 2-9-52 COYOTE CANYON AREA: The dense stand of mulefat located below where the Arroyo crosses under Arroyo Canyon Rd. was not considered a wetland. This area meets the vegetation criteria. The deposition of the bed loads indicate that the area has appropriate hydrology tit is, appparently, in a stream). The soils were not found to be hydric, however, the Federal Manual notes that the soils of westef=fi 3tP@a it §ft@h dO hot ditplAy hydric characteristics. It should be determined if, under normal (not drought) conditions, this area is saturated during the growing season for one or more weeF::s. If so, this area is a wetland. BONITA CREEK The Identification notes that there appears to be a natural spring in this area. In determining the impact of the corridor on wetlands in this area, it the spring is filled, both the spring itself and all wetlands fed by this spring should be considered as being impacted. At 2-9-53 the intersection of Bonita Canyon Road and Coyote Canyon Road is an area dominated by willows and fed by runoff from the road. Regardless of the source of the water, an area is considered a wetland if it is saturated for one or more weeks during the growing season of a normal year. Because of the road runoff, this is probably true for this area, otherwise willows would not be able to survive. The disturbance in this -13- • 2~9~53 area resulted from road building may have obscured the presence of hydric soils, thus given that this area probably meets the hydrology criteria and does meet the vegetation criteria, it should be considered a wetland. In the Identification, areas with mulefat were not considered to be wetlands due to their "xeric nature." Mulefat is considered FACW, found in wetlands between 67% and 99% of the time. Given that this is the fifth year of a drought, these areas deserve more consideration that to simply be determined to be upland because of their "xeric nature." The hydrology during a normal year should be determined. Soils will be difficult to assess because of drought and becausemany of the soils are sandy, and, as the Federal Manual notes, sandy soils in arid and semiarid regions do not often reflect the characteristics of hydric soils. A minor side drainage, described as a head -cut drainage that is dominated by mulefat was not considered a wetland. Head cutting often indicates the presence of groundwater, and certainly inicates the presence of water, thus the hydrology criteria is met. The vegetation criteria is met because the dominant species is a wetland indicator. The soils criteria need not be met (because soils are sandy) thus this area would be considered to fall into the exceptions listed in the Federal Manual provided the hydrology criteria is met. Thank you for considering my concerns, Fred M. Roberts, Jr. Assistant Curator 0 WILLIAM E. LEONARD. Chairman STATE OF CALIFORNIA BRUCE NESTANDE, Vice Chairman JOSEPH A. DUFFEL i ELAINE L FREEMAN J.T. (TOM; HAWTHORNE yl n STANLEY W HULETT -Pb !� KEN KEVORKIAN JOE LEVY ua " JEROME F. LIPP +"r ROBERTI REMEN, Executive Director CALIFORNIA TRANSPORTATION COMMISSION 1120 N STREET, P.O. BOX 942873 SACRAMENTO 94273.0001 FAX (916) 445.5856 (916) 445.1690 November.21, 1990 Steve Letterly Manager, Environmental Impact Transportation Corridor Agencies 345 Clinton Street Costa Mesa, California 92626 Dear Mr. Letterly: GEORGE DEUKMEJIAN GOVERNOR California Transportation Commission at its November 1990 meeting reviewed the Draft EIS being circulated for the Route 73 San Joaquin Hills Toll Road corridor in Orange County. The Commission understands that the project would cost $745 million for a six -lane toll highway, $815 million for an eight -lane toll highway, or $838 million for an eight -lane toll highway including two HOV lanes (in escalated dollars), and would be completed by late 1995. The project is proposed to be funded from a mix of sources: federal\state .funding, local development fees for 48% of cost, and local bonds backed by future toll revenues. Under federal law, federal funding participation is capped at 35%, and taken from regular federal apportionments. The Commission in adopting the 1988 STIP agreed to participate with federal\state funding up to $46.5 million, which was 10% of the project cost at that time. This Commission policy was modified during adoption of the 1990 STIP, to offer three alternative levels and methods of state participation (with federal funding). A copy of the Commission's revised policy for the San Joaquin Hills Toll facility, dated September 1990, is attached. The Commission modified its policy on funding participation to allow a broader range of options, including an initial eight - ..lane toll highway with two HOV lanes, and to help defray the added cost of building more lanes initially rather than adding lanes later. 2-10-1 The Commission requests that the Final EIS provide enough information for the Commission to assess which alternative would be the best use of state funds, from the standpoint of least overall cost for this project, and maximum benefit from the timing of state investment on this corridor versus elsewhere on the state transportation system. The Commission asks that more detailed traffic 12-10-2 projections be provided, for total traffic and HOV traffic, including interim year projections (perhaps five-year intervals), tied to development build -out, that can allow determination of when demand would indicate that a seventh and eighth lane would need to be added. Steve Letterly Transportation Corridor Agencies November 21, 1990 Page 2 Pursuant to CEQA, the Commission is a responsible agency, which programs state and federal funds for highway improvement projects and must eventually approve allocation of funding for construction. The Commission wants to ensure that it is making a wise investment with maximum return before it allocates federal or state funds to the project for construction. The Commission will follow with interest the progress of work on this corridor. Sincerely, WILLIAM E. LEONARD Chairman WEL:PH:73:GK9:K18 cc: Russ Lightcap, Attention Walt Hagen, Caltrans District 12 E.W. Blackmer, Caltrans Office of Environmental Analysis Bart Gauger, Caltrans Division of Highways & Programming Stan Oftelie, Orange Co. Transportation Commission Attachment 2-10-3 0 • September 20, 1990 REVISED POLICY FOR ORANGE COUNTY SAN JOAQUIN HILLS TOLL FACILITY (ROUTE 73) Whereas, in April 1987, under Section 120 of the 1987 Federal Surface Transportation Assistance Act, P.L. 100-17/(i.e., HR 2), the Secretary of Transportation was directed to "establish a pilot program which permits Federal participation in 7 (publicly owned) toll facilities on the same basis and in the same manner as in the construction of free highways" including one such facility in Orange County, with the federal share payable for construction not to exceed 35%, without increasing a State's apportionment under any apportionment formula; Whereas HR 2 was later amended to specify that the toll facility in Orange County may be located in more than one highway corridor to relieve congestion on existing Interstate routes in such county; Whereas, in the 1988 STIP, the California Transportation Commission programmed $35 million in FY 1992-93 toward the Orange County/San Joaquin Hills Toll Road (Route 73) as an eight -lane facility with an estimated cost of $465 million (escalated); Whereas the Commission limited any further State/federal participation in that project to no more than an additional $11.5 million and, beyond that, to $75 million to be later reembursed to the State; Whereas the Commission required, as a condition, that an independent analysis be prepared of the project's financial plan and submitted to the Commission prior to the issuance of any bonds; Whereas, since the adoption of the 1988 STIP, significant changes have occurred related to that project, including: o an increase in cost for an eight -lane facility from $465 million (1993 $) to $815 million (1995 $); a six -lane facility is now estimated to cost $745 million and an eight -lane facility including 2 HOV lanes is now estimated to cost $'838 million --both escalated to 1995 $; o proposed increases in developer fees to maintain a 48% share of capital costs and a proposed increase in toll rate to $2.25; o a 30-month delay in completion, from April 1993 for the full eight - lane facility to October 1995 for a first phase six -lane facility, with a second phase delayed until after 2000; o the initial use of a toll -pricing strategy, rather than dedicated HOV lanes, as a means of encouraging high vehicle occupancy, with HOV lanes scheduled as a second phase facility after 2000; o change in financing strategies from a single up -front bond issuance to a two -phased strategy of construction financing and post - construction financing; o anticipated reliance of "design -build" for completing the project; • o identified need for improvements to the confluence between I-405 and Route 73 toll facility. Whereas, a Joint Policy Statement was issued by the Cities of Irvine and Newport Beach on October 31, 1988 calling for an ultimate facility of eight lanes, including two additional HOV lanes and two fixed guideway transit lanes, and an initial phase of six traffic lanes; however, if independent financial analyses and analyses of traffic demand indicate the necessity of constructing a full eight lanes of initial phase, the two added lanes will be HOV lanes; Whereas, Commissioners have expressed concern with the cost-effectiveness of phased construction, rather than building to meet 20-year projected demand; Vnereas, Commissioners have further expressed concern with the cost- effectiveness of reversible HOV lanes versus conventional HOV lanes, both in terms of construction costs and on -going operational costs; Whereas, in July 1987, the Commission adopted a Policy for Bus and Carpool Lanes, which calls for the Commission to give "serious consideration to the inclusion of at least a commute hour bus and carpool lane in every new freeway or freeway capacity addition in and around a metropolitan area when it. is demonstrated to be both feasible and of likely benefit within either the short or long term"; Whereas, per March 1990 action of the Executive Committee of Southern California Association of Governments (SCAG), transportation projects must be consistent with SCAG's Regional Mobility Plan in order to be deemed in conformity with the South Coast Air Quality Management P1'an and that the Regional Mobility Plan states that "transit and ridesharing facilities shall be given priority over mixed flow capacity expansion"; Whereas, it may not prove to be financially feasible to initially construct HOV lanes concurrently with mixed flow improvements for Route 73; Whereas, in the absence of concurrently built HOV lanes, alternative means to encourage HOV usage, such as a pricing policy and phased HOV lanes built at a later date, each carry their own uncertainties: o whether the effectiveness of a pricing policy can be demonstrated through an economic analysis of the price elasticity of travel demand and HOV usage; o whether phased HOV lanes can carry a legally enforceable commitment to assure their construction within a reasonable time frame following construction of the mixed flow facility; Whereas, even with proposed increases in developer fees and toll rates and the State's full participation at $46.5 million, the project's financial plan indicates that optimum bonded debt coverage will not be maintained if all eight lanes (i.e., six mixed -flow lanes and two HOV lanes) were constructed at one time; Therefore, be it resolved that the Commission hereby modifies any previous commitments and conditions to participate in the Orange County San Joaquin Hills Corridor (Route 73) as follows: o if the corridor is to be built initially as a six -lane facility, the state's participation in that initial phase is to be capped at no more than $46.5 million and the state's participation in the construction of 7th and 8th lanes, at a later date, is to be limited to no more than 10% of the escalated capital cost of that construction; o if independent financial analyses and analyses of traffic demand and air quality indicate the necessity of constructing a full eight lanes of initial phase, with two lanes used as IIOV lanes, the state's participation is to be limited to no more than $83.8 million, which is 10% of the escalated construction cost --OR, as an alternative, state participation is to be limited to no more than $46.5 million in direct participation as well as the advancement of up to $75 million in State/federal funds for later rembursement to the State, pursuant to the Cor.•�mission's September 1988 policy; o State/federal funding for the Route 73 Corridor shall be programmed in the 1990 STIP at $40.0 million; any additional funding proposed for this corridor above $40.0 million and in conformance with the above provisions shall be sought through the STIP process by Orange County Transportation Commission and prioritized against other projects; o Caltrans, in cooperation with the Transportation Corridor Agency, shall study and report back to the Commission prior to adoption of the 1992 STIP, on the cost-effectiveness of reversible versus conventional HOV lanes in this corridor; o interim phased improvements to the confluence between I-405 and the Route 73 toll facility, as determined to be needed in the confluence project EIR, be funded and built in time for the toll facility's operation; o any further State/federal funding may be proposed only after any necessary increases in developer fees, toll rates, and other local revenue needed to assist construction of the designated facility, have been committed; o the required final report from the independent financial advisor shall be submitted to the Commission in time sufficient for review and comment prior to the issuance of any bonds but after the final project scope, cost and funding participation has been determined; o in consideration of provisions in HR 2 pertaining to a single toll facility in more than one corridor in Orange County, the Transportation Corridor Agencies shall take no action, including but not limited to entering into any contract, that would prohibit or impede consolidating the agencies into a single agency at any time in the future. UNIVERSITY OF CALIFORNIA, IRVINE BER3rr.T DAVIS IRVINE LOS ANGELLS •RIVERSIDE SAN DIECO SAN FRANCISCO o =:} „ SANTA HARBARA • SANTA CRUZ OFFICE OF THE VICE CHANCELLOR ADMINISTRATIVE & BUSINESS SERVICED IRVINE, CALIFORNIA 92717 November 27, 1990 Mr. Steve Letterly Manager, Environmental Impact Transportation Corridor Agencies 345 Clinton Street Costa Mesa, California 92626 Re: Comments on the San Joaquin Hills Transportation Corridor Draft Environmental Impact Report/Environmental Impact Statement - TCA EIR/EIS 1 Dear Mr. Letterly: We appreciate the opportunity to review and comment on the Draft Environmental Impact Report/Environmental Impact Statement for the San Joaquin Hills Transportation Corridor. The University of California, Irvine (UCI) has reviewed the document, and requests that the following questions and issues be addressed and incorporated into the Final EIR. They are as follows: Biological Resources EIR/EIS, Page 2 - 40 and Volume II, Page 20 We do not concur with the findings that Alternative "R" has less impact on regional biological resources than Alternative "U". Alternative "R" significantly impacts high value coastal sage scrub habitat on campus which is currently inhabited by several pair of California gnatcatchers and cactus wren, while Alternative "U" is based on a single siting of the Least Bells Vireo. Provision needs to be made for replacement of coastal sage scrub areas impacted by Alternative "R". EIR/EIS, Page 4 - 71 and Volume II, Page 19 A detailed mitigation plan needs to be developed for impacts to Dudleya muticaulis and other coastal sage scrub on the UCI campus which have been identified for removal. The option of reestablishing this resource to the UCI coastal sage scrub open space reserve would appear to be a preferred approach for this replacement and other coastal sage scrub impacts in the vicinity. A copy of the report General Biological and Sensitive Species Assessments for the UCI Campus prepared for the campus is attached for your reference. 2-11-1 2-11-2 Mr. Steve Letterly November 27, 1990 Page 2 EIR/EIS, Figure 4.7.7 Figure 4.7.7 identifies a wetland area adjacent to the MWD water line at existing Bonita Canyon Road which will be impacted by Alternative R. Provision needs to 2-11-3 be made for replacement of this wetland in keeping with federal requirements for no net loss. Please provide a detailed description of this mitigation including the process, location, and monitoring. We request a mitigation measure that provides protection for existing habitat and adjacent landowners during construction. This would include interim fencing immediately after fence removal to avoid trespassing in biologically sensitive areas and other lands, and commitment to replace habitat damaged during construction due to trespassing. 2-11-4 The commitment to develop mitigation programs for habitat replacement in the future rather than specifying these at the present time is unacceptable to the campus. A detailed mitigation program stating acreage numbers, location of proposed replacement, replacement methods, and monitoring of replaced habitat 2-11-5 is needed prior to document certification. As a responsible agency, the University is particularly concerned with the lack of detailed mitigation for the areas impacted on UCI. Noise Volume I, Figures 7-4 and 7-5 The 65 CNEL noise contour in Figure 7-4 appears to impact planned campus faculty and staff housing with no mitigation proposed. Figure 7-5 indicates that the 65 CNEL noise contour impacts the planned office and research uses on the 2-11-6 campus with no reference made to this land use or mitigation proposed. Please clarify this issue and develop appropriate mitigation measures if necessary. Archaeoloev EIR/EIS, Appendix D, Table 1 We would like to request a copy of the archaeological report for each of the following sites listed in Table 1, Appendix D which pertain to the UCI campus: CA-Ora-123 CA-Ora-181 CA-Ora-218 CA-Ora-1119 2-11-7 0 Mr. Steve Letterly November 27, 1990 Page 3 Site CA-Ora-1041 has been omitted. It is impacted by the Bison Avenue ramp which connects to California Avenue. Please add it to the inventory and analysis 2"� 1-8 in the Final EIR. Circulation EIR/EIS, Page 2 - 10 and 2 - 56 Please verify that the Bison Avenue ramp connecting to California Avenue on the UCI campus is a part of the project description evaluated as a part of this EIR, 2-11-9 and that it will be funded as part of the project. Traffic EIR/EIS, Page 5 - 3 Table 5.A Please clarify what data bases were used for UCI land uses in the traffic 2-11-10 projections. Volume II, Appendix C Projected capacities are not included for the intersections of California Avenue at University Drive, and California Avenue at Bridge Road. Please include these in 2-11-11 the Final EIR. Air Ouali1y Volume I, Page 20 and Figure 4 In figure 4 of Volume I of the Technical Studies it appears that a Park -and- Ride facility is mistakenly located in the ecological reserve on the UCI campus. Please 2-11-12 verify. Future Land Uses EIR/EIS, Appendix E, Page 12, Table E-E Please clarify how "employees" were arrived at for UCI land uses in Table E-E of 2-11-13 Appendix C. Adopted land use plans on the campus utilize faculty, staff, and students for planning purposes rather than "employees". 0 EIR/EIS, Page 4 - 94 What data bases were used for UCI population projections on page 4 - 94 of the 2-11-14 EIR/EIS. Mr. Steve Letterly November 27, 1990 Page 4 Thank you for the opportunity to review this document. We would be glad to consult with the Transportation Corridor Agency to discuss these issues prior to the preparation of the Final EIR. If you have any questions or require further information, please contact Meredith Van Steenwyk at (714) 856-7674. Sincerely, Leon M. Schwart Vice Chancellor Attachment cc:- ASLUC Chairman T. Bradley Director R. Demerjian Assistant Executive Vice Chancellor J. DiMento J. Zimmermann 0 0 DRAFT GENERAL BIOLOGICAL AND SENSIT117E SPECIES ASSESSMENTS FOR T UNTTVERSItY., :OF CALIFORNIA , IRVINE CAMPUS .. <. try �i• Prepared for:=: OFFICE OF ENVIRONMENTAL PLANNING AND CAIV US DESIGN UNIVERSITY OF CALIFORNIA, IRVINE Prepared h., : OCTOBER 1990 ('Chambers Group, Inc. Ll GENERAL BIOLOGICAL AND SENSITIVE SPECIES ASSESSMENTS FOR THE UNIVERSITY OF CALIFORNIA IRVINE CAMPUS Prepared for: OFFICE OF ENVIRONMENTAL PLANNING AND CAMPUS DESIGN University of California Irvine, California 92717 Prepared by. - CHAMBERS GROUP, INC. 1761 East Garry Avenue, Suite A Santa Ana, California 92705 (714) 261-5414 OCTOBER 1990 GENERAL BIOLOGICAL AND SENSITIVE SPECIES A.S.SE 3MF.NTS FOR THE UNIVERSITY OF CALIFORNIA, IRVINE CAMPUS TABLE OF CONTENTS Page SECTIONI- INTRODUCTION ..................................... 1 SECTION 2 - GENERAL BIOLOGICAL ASSESSMENT ...................... 3 2.1 METHODOLOGY ....................................... 3 2.2 VEGETATION ......................................... 4 2.3 WILDLIFE ............................................ 9 SECTION 3 - SENSITIVE SPECIES ASSESSMENT ........................ 12 3.1 METHODOLOGY ...................................... 12 3.2 VEGETATION ........................................ 15 3.3 WILDLIFE ........................................... 18 SECTION 4 - ANALYSIS OF POTENTIAL IMPACTS ...................... 31 4.1 SIGNIFICANCE CRITERIA AND SUMMARY OF POTENTIAL IMPACTS . 31 4.2 VEGETATION AND WILDLIFE ............................. 32 4.3 SENSITIVE SPECIES •••..••••.••.••••..•••.••••..••••••• 33 4.3.1 Vegetation 33 4.3.2 Wildlife ...................................... 33 SECTION 5 - MITIGATIONS ...................................... 34 SECTION 6 - CONCLUSIONS ..................................... 41 SECTION 7 - REFERENCES ....................................... 42 APPENDIX A - PLANT SPECIES LIST APPENDIX B - WILDLIFE SPECIES LIST i • GENERAL BIOLOGICAL AND SENSITIVE SPECIES FOR THE UNIVERSITY OF CALIFORNIA, IRVINE CAMPUS LIST OF FIGURES Floe page 1 Survey Areas ....................................... 2 2 Plant Communities on UCI, North Campus ................... 5 3 Plant Communites on UCI, Main Campus .................... 6 4 Sensitive Species Locations on the UCI Campus ............... 7 LIST OF TABLES Table Page 1 Sensitive Plant Species Known to Occur and Potentially Presenton UCI Campus ................................ 13 2 Threatened, Endangered and Candidate Wildlife Species That Could Occur on UCI Campus ......................... 19 El 0 SECTION 1 - INTRODUCTION A Long Range Development Plan (LRDP) for the University of California, Irvine (UCI) campus was prepared in 1989 and is the third land use plan developed since 1960, when the campus site was officially designated to become part of the University of California. The 1989 LRDP is also the first to be developed after 1970, when the state Legislature enacted the California Environmental Quality Act (CEQA). In conformance with CEQA, an Environmental Impact Report (EIR) was prepared for the LRDP by Sanchez Talarico Associates (STA), Inc. A biological resources assessment was prepared by Western Ecological Services (WESCO), Inc. for the LRDP EIR, based on field surveys conducted in late June, 1988. Pursuant to WESCO's recommendations for spring field surveys and surveys for rare species, UCI requested Chambers Group, Inc. to conduct an additional biological resources and sensitive species assessment of the undeveloped lands on the campus which are shown in Figure 1. The information provided in this assessment will supplement the biological analysis in the 1989 LRDP EIR as well as be incorporated into future site -specific environmental assessments prepared as development proceeds. Section 2 of this report describes the methodologies of the surveys and the results of those surveys for the general assessment of biological resources of the campus. Section 3 describes survey methodology and results of the sensitive species assessment. Section 4 • discusses the potential impacts of LRDP implementation on biological resources and sensitive species, and Section 5 discusses the LRDP EIR mitigation measures with respect to those impacts. Section 6 discusses the conclusions of the general biological and sensitive species assessments. 6165A-9/90 FIGURE SURVEY AREAS SECTION 2 - GENERAL BIOLOGICAL ASSESSMENT This section provides the methodologies and results of the general surveys of plant and wildlife resources observed in the areas shown in Figure 1. These areas are hereafter referred to as "the campus". 2.1 METHODOLOGY General botanical surveys of the campus were conducted by two Chambers Group botanists during the periods of April 3-4 and May 2-3, 1990. During the May survey it was apparent that the majority of plant species on the campus had flowered or were flowering, making general surveys after that date unnecessary (with the exception of a specific survey for a summer -flowering rare plant -- see Section 3.1). Parallel belt transects approximately 30 to 100 feet apart (depending on habitat variability) were walked in upland areas, and single transects were walked either in or above and parallel to each drainage, with the choice of method dependent on the width and vegetation content of the drainage. Plant community boundaries were drawn in the field on a topographic map provided by the University. Acreages of each community were estimated from the map using Sigma Scan (Jandel . Scientific, Inc.) digitizing software. This method does not account for topographic relief and therefore tends to underestimate actual acreage values, but provides good estimates of the relative proportions of.plant communities which are present. During the surveys, all plant species encountered were identified to the species level whenever possible. A species list was developed based on these observations and on lists provided by campus biologists. Wildlife surveys of the campus were conducted by four Chambers Group wildlife biologists on four separate occasions between April 2 and May 23, 1990. One of the biologists focused his surveys specifically on identifying the presence of burrowing owls and suitable burrowing owl habitat. Another biologist, who specializes in reptiles, surveyed the campus for amphibians and reptiles. A third biologist, who specializes in wetlands and riparian habitat, surveyed the riparian areas on the campus. The fourth biologist conducted general wildlife surveys, which included birds, mammals, and reptiles, on repeated visits to the campus. In general, belt transects were walked over the entire campus. In locations such as the riparian drainages and where two or more plant communities meet (ecotones), more intensive surveys were conducted. All wildlife species seen during the surveys were identified to the species level. The general condition and health of the wildlife habitats on the campus were assessed and their potential to support wildlife species was documented. An observed and expected wildlife list was formulated based on field visits, previous surveys in the area; observations by - University biologists, and experience in surveying similar wildlife habitats in the Orange County region. 0 3 2.2 VEGETATION • Figures 2 and 3 show the distribution of plant communities on the North and main campuses, respectively. Appendix A provides a list of plant species observed during the 1990 survey by Chambers Group and during previous surveys (Bowler, 1989). Approximately 669 acres of annual grassland, 17 acres of mixed native perennial and annual grassland, 68 acres of coastal sage scrub, 30 acres of riparian habitat, and 17 acres of freshwater marsh are present. General features of each of these communities are described in this section. It should be noted that the map and acreage calculations represent the results of the field surveys as of early May, 1990. Removal of vegetation has occurred subsequent to the field surveys conducted for this assessment, as a result of grading for Bison Avenue, grading associated with the San Joaquin Hills Transportation Corridor, and (presumably) ongoing flood control activities in a channel adjacent to California Avenue on the west side of campus. Annual Grassland Annual grassland is the most widespread community on the campus, comprising 85.3 percent of the vegetation on the campus. The community is composed primarily of non-native grasses and herbs, including wild oat (Avena fatua), slender wild oat (Avena barbata), foxtail chess (Bromus rubens), hare barley (Hordeum murinum ssp. leporinum), common ripgut grass (Bromus diandrus), black mustard (Brassica nigra), globe artichoke (Cynara cardunculus), sweet fennel Woeniculum vulgare), and long -beaked filaree (Erodium botrys). Frequency of native annual herbs in the grassland community varies significantly across the campus, and appears to be sensitive to grazing intensity. The east side of the campus is heavily grazed by horses, and is also the area where most of the native grassland herbs were observed. These species include doveweed or turkey mullein (Eremocarpus setigerus), cudweed aster (Corethrogyne filaginifolia), fascicled tarweed (Hemizonia fasciculata), common pineapple weed (Matricaria matricarioides), and big gumplant (Grindelia robusta). Other common herb species, observed elsewhere on campus, include blue -dicks (Dichelostemma pulchellum), western goldenrod (Euthamia occidentalis), guard lupine (Lupinus excubitus ssp. halliil, and tansy -mustard (Descurainia pinnata). Of particular importance, because of its regional rarity in Orange County, is the occurrence of mesa brodiaea (Brodiaea jolonensis) in the grassland community west of the Open Space Reserve. The observations of these populations are discussed further in Section 3. Patches of prickly pear cactus (Opuntia occidentalis complex) occur at scattered locations in the grassland community, as shown in Figure 2. This "species" is a hybrid complex of native coastal prickly pear (Opuntia littoralis) and cultivated prickly pear varieties. The larger patches provide nesting habitat for the coastal race of the cactus wren, a sensitive taxon (see Section 3). 4 0 FEET 0 500 10, r--7-0-Q PERENNIAL/ ANNUAL ° o0 o ANNUAL GRASSLAND 'o° °'o GRASSLAND ;' �• ' ti` '. ^.� WILLOW DEVELOPED PLANTED /PROPOSED COAST LIVE " DEVELOPMENT OAK �i.:.i.i`si^.' SETBACK UNPAVED ;f ; '`" .: :::i • / ROAD SOURCE, ENVIRONMENTAL •:•' • :`" `MCI : 1 :`i' '' I/ TOPO MAP SOU N PLANNING CAMPUS DESIGN �.. 1, •O`�. •:1: ••' ::T ::�Y ~fit •. �},�::::: ._.. apt •/ .... j * • �• _ SAN JOAQUIN-' ;FRESHWATER => ,, .I k•. - =;r.a4 MARSH PRESERVE vz� =.� _ �+.. fir=;: iy ": `'� i' { •r ;, �- � •``�. e a t is ,a �. R�' •'``/�'•'��' :.':: �� > _ .. ;,^`Y it ln �y..;. i •1 :"� ^�• K. ;,r••+�''.✓, �•�•': is .. �.. i ,�: � ,.•,c�'y.�,.t:.: ''•r.,: Erb:;:: i:r::°:it.:::� i v::::.?E \ -.• , . _ ` 4 � > c:�.>�. :-_�•.�•¢�'� r `� �i:� :. ��t;E;i_ Ets:� iEiiF4Etii;F:':►i � Q r :. \•...�' - / `..� 3� ,1t ".7 : `:'•1%a:: i•.•;''i=iiiE iil;3').. _ Ant � �,. i! mil• .��f `t•�„�, ., \�, � �' wit':. t Z -a ..\ _ \•, -% : •l`\ ., \�� FIGURE PLANT COMMUNITIES ON UCI, NORTH CAMPUS 2 F1 m i T z 0 z m Cl) 0 z CD III m co F E'F,l� l l\I,�/I1�///���/ � ••"`4L'•��y.; .,;t;, •r•v,4:j1 :�i. g 1 x 0 V) m m V) -0 m 0 m -0 > > Fog =):b>o(= m z z zzmcopmm G)0 (n m O>O>V)MOZOZ3:ZZ M- > 2 > >c > > x >,> n > 0 > z z < tS 3:) 8—j i Z r- — m (3) 0 -4 Q Q Q M rrl C) >006>zw>mD > 0 ow w U) :1) V) M M--i ZOWWO 00 MZ P z r- m 0 OM am�=5: . S;T-� < n > n >cnZ=Z ZZM m > m m r- ll� C: o X C3 cl c cn a) 1-10, )07 in aim 0 0 0 • Mixed Native Perennial and Annual Grassland ^ Small but surprisingly widespread patches of native perennial grasses mixed with non-native annual grasses occur on campus, especially southwest of the Open Space Reserve and along the southeast edge of the North Campus parcel (Figures 2 and 3). This community comprises 2 percent of the acreage in the survey area, consisting primarily of purple needlegrass (Stipa pulchra) but with occasional individuals of foothill needlegrass (Stipa lepida) near and in the Open Space Reserve. At the appropriate time of year, especially the April period during which the Chambers Group survey was conducted, the tall inflorescences of needlegrass are readily visible. By early May of 1990, substantial growth of the annual grasses had occurred, making the needlegrasses less readily distinguishable from the annual grasses at a distance; this phenology may explain the general lack of observations of this community in previous surveys (Bowler, 1989; Wesco, 1989). The widespread occurrence of needlegrass on the campus is surprising because of the campus's long history as pasture for livestock. Unlike their annual relatives in the grass family, needlegrass species grow more slowly and tend to occur in areas where grazing and competition from annual species are less intense. On campus, the largest patches of needlegrass were observed on the edges and bottoms of narrow gullies. Native grassland is sparse in coastal southern California. Historical causes of this scarcity have been variously attributed to overgrazing, invasion by non-native grasses, fire suppression, and dry -farming practices that include disking (Heady, 1988; T. St. John, .personal communication). However, the present cause of the continued decline of native grassland in Orange County is urbanization, and the California Natural Diversity Database (a program operated by the California Department of Fish and Game) has assigned high - priority protection status to the needlegrass grassland community (Holland, 1986). Coastal Saze Scrub gscrub Approximatent ofthe survey area is occupied by coastal sage scrub, with nearly all of this acned to the Open Space Reserve south and west of University Hills. The coastal scommunity in general is characterized by semi -woody and shallow - rooted shrubs which are typically 1-3 feet in height. Individuals may shed some or all of their small leaves during the summer months, with the degree of loss depending on the intensity of the drought. Common species in this community on the campus include California buckwheat (Eriogonum fasciculatum' ssp. fasciculatum), California sagebrush (Artemisia californica), and California encelia (Encelia californica). Other shrub species include bladderpod (Isomeris arborea) and Mexican elderberry (Sambucus mexicana). Open areas between shrubs are occupied by a large diversity of herbs and grasses, including California wishbone bush (I frabilis californica var. californica), common fiddleneck (Amsinckia intermedia), blue dicks (Dfchelostemma pulchellum), common golden stars (Bloomeria crocea), mock parsley (Apiastrum angustifolium), coastal goldfields (Lasthenia 7 californica), foxtail chess (Bromus rubens), hare barley (Hordeum murinum ssp. leporinum), goldentop (Lama kia aurea), and needled ass (Stipa spp.). Patches of prickly pear cactus also occur within the community and, as in the grassland areas, provide nesting habitat for the cactus wren. Four types of coastal sage scrub have been described for southern California by Westman (1987 and references cited therein): Diablan (distributed from coastal Santa Barbara County north through Contra Costa County), Venturan (Santa Barbara County through western Los Angeles County), Riversidean (interior Los Angeles, Riverside, and San Diego Counties), and Diegan (coastal Orange and San Diego Counties). These types have certain species in common, such as buckwheat (Eriogonum fasciculatum) and California sagebrush, but differ in the frequency of others. The composition of the coastal sage scrub community on the campus closely conforms to that which has been described for the Diegan type, which has been assigned high -priority protection status by the California Natural Diversity Database (Holland, 1986). It should be noted that the distribution of coastal sage scrub on the west and south sides of University Hills and in the adjacent Open Space Reserve corresponds to a particular type of soil profile, called Calleguas Clay loam, that is found only as two isolated patches elsewhere on campus (Soil Conservation Service, 1978). This soil type is moderately alkaline and moderately permeable, with an effective rooting depth of 10 to 19 inches. In contrast, the annual grassland east of the Open Space Reserve is associated with Bosanko clay, a type of soil with a greater effective rooting depth (20 inches or more) but substantially less permeable than Calleguas clay loam. Soils west of the Open Space Reserve are classified as Myford sandy loam, a type of soil that is slowly permeable and with an effective rooting depth of 10 to more than 60 inches depending on the plant species. These soils would provide the highest potential for successful establishment of coastal sage scrub mitigation areas. However, it should be recognized that choice of planting method and species will also affect the success with which coastal sage scrub can be established (Bowler, n.d. and Hillyard, n.d.). Freshwater Marsh Approximately 2 percent of the natural plant community acreage on the campus consists of freshwater marsh species associated with drainages and seeps. The distribution of the community is confined primarily to low-lying depressions southwest of the Farm School and adjacent to Bonita Canyon Drive (Figure 3). The relative abundance of different species varies significantly with location, but in general some of the more common taxa include yerba mansa (Anemopsis californica), California bulrush (Scirpus californicus), three -square (Scirpus pungens), coastal salt grass (Distichlis spicata ssp. spicata), and broad-leaved cattail (Typha latifolia). With the exception of yerba mansa, which is known to occur only in the marsh area furthest from Bonita Canyon Drive, these species also occur in the riparian habitats described below. The small marsh habitat located in a drainage channel 8 adjacent to California Avenue on the west side of campus (Figure 3) is intensively disturbed by periodic clearing, presumably for purposes of- flood control (E. Read, personal observation). It.should be noted that a rare plant species, southern tarplant (Hemizonia australis), was discovered during the summer surveys in the seep areas adjacent to Bonita Canyon Drive and in some of the riparian habitats described below. This observation is discussed more fully in Section 3. Riparian Approximately 3.8 percent of the acreage surveyed consists of riparian willow woodland and/or scrub. This community is distributed along perennial and intermittent streamcourses on the east side of campus, as well as in an intermittent drainage west of the School of Medicine. A few willows also occur on the North Campus parcel, adjacent to an unpaved road which borders the San Joaquin Freshwater Marsh. The riparian willow woodland community near the School -of Medicine is especially well -developed, consisting of tall, mature arroyo willow (Sallx lasiolepis). Gooding's willow (Salix goodfngiil also occurs in the riparian areas, particularly in the drainages near the Farm School on the east side of campus. These drainages are also occupied by one of the largest populations of southern tarplant on the campus (see Section 3). 2.3 WILDLIFE Appendix B provides a list of wildlife species observed on campus by Chambers Group biologists and campus personnel, as well as species which would be expected to occur in association with the plant communities present. The annual grassland on the campus provide habitat for a number of birds, reptiles and small rodents who use this habitat for foraging and for shelter.' Some of the smaller species of birds who were observed in the grassland community on the campus are; horned lark (Eremophila alpestris), western meadowlark (Sturnella neglecta), western kingbird (Tyrannus verticalis), brown -headed cowbird (Molothrus ater), killdeer (Charadrius _ vociferus), lesser goldfinch (Carduelis psaltria), European starling (Sturnus vulgaris), and house sparrow (Passer domestfcus). Of special note is the utilization of the grazed grassland on the east side of campus by Canada geese (Brenta canadensis., Bowler et. al., 1590). Some of the more common reptiles found in the grasslands are; gopher snake (Pituophis melanoleucus), coachwhip-(Masticophis flagellum), common kingsnake (Lampropeltis getulus), southern alligator lizard (Gerrhonotus multicarinatus), western fence lizard • 9 (Sceloporus occidentalis), side -blotched lizard (Uta stansburiana), and western skink (Eumeces skiltonianus). • In addition to the reptiles, a wide variety of rodents occur in grassland, such as: deer mouse (Peromyscus maniculatus), house mouse (Mus musculus), California vole (Microtus californicus), western harvest mouse (Rheithrodontomys megalotis), and valley pocket ` gopher (Thomomys bottae). Rabbits (desert cottontail, Sylvilagus audubonii; possibly brush rabbit, Sylvilasus bachmanil and California ground squirrels (Spermophilus beecheyi) are most abundant on the North Campus parcel and the east side of the main campus near the Farm School. A number of raptors and large mammals utilize the grassland community as a foraging resource. Some of the raptors that were seen foraging over the grassland on the campus were; red-tailed hawk (Buteo jamaicensis), turkey vulture (Catharses aura), and American kestrel (Falco sparverius). A few of the larger mammals that may visit the campus are: Coyote (Canis latrans), gray fox (Urocyon cinereoargenteus), and bobcat (Lynx rufus). Although most of these predator species that forage in the grassland spend much of their time nesting and taking cover in other vegetation communities, such as oak woodland, riparian woodlands, chaparral, or coastal sage scrub, the grasslands are vital to their existence. The north campus parcel is the least diverse in terms of raptors and large mammals, probably due to the close proximity of development. The grassland on North Campus has also been heavily grazed in the past, such that wildlife species diversity in general is expected to be low relative to diversity on the main campus. The coastal sage scrub community supports a wide variety of wildlife due to the increased amount of cover and forage opportunities associated with the wide diversity of plant species present. The coastal sage scrub near University Hills and in the adjacent Reserve is particularly important for wildlife on the UCI campus as a whole because this habitat does not occur anywhere else on the entire campus. The reptiles present in this community are basically the same as those in the grassland with the addition of few species that are more typical of brush habitats. Many birds, such as California gnatcatcher (Polioptila californica, formerly the California black -tailed gnatcatcher), cactus wren (Campylorhynchus brunneicapillus), California towhee (Pipilo criissalis, formerly the brown towhee), California thrasher (Toxostoma redivivum), bushtit (Psaltriparus minimus), and scrub jay (Aphelocoma coerulescens) utilize this community for nesting and foraging and are found almost exclusively in coastal sage scrub vegetation. Some of the small mammals found in the grassland community also utilize the coastal sage scrub but several others are known to occur on and in the vicinity of the University House site. These are; Pacific kangaroo rat (Dipodomys agilis), dusky -footed woodrat (Neotoma fuscipes), desert woodrat (Neotoma lepida), little pocket mouse (Perognathus longimembris pacificus), and San Diego pocket mouse (Perognathus fallax fallax). Larger mammals, such as the striped skunk (Mephitis mephitis) and striped skunk (Spilogale gracilis), as well as rabbits, coyote, gray fox, and bobcat also can be found in the coastal 10 0 sage scrub. In addition, an occasional raccoon (Procyon lotor) may venture onto the site. A number of raptors were seen foraging in the University Hills area during the repeated surveys of the site. The most common raptors seen around the site were turkey vulture and red-tailed hawk, but northern harrier, American kestrel, and Cooper's hawk (Accipiter cooperii} were also seen on one or more of the campus surveys. Because of the extremely productive nature of riparian habitat, it is very valuable for wildlife, usually supporting.a higher density and diversity of species than adjacent upland areas. This productivity also permits riparian communities to exhibit great regenerative powers; in fact, some wildlife species are dependent upon the dense growth which often occurs in riparian habitat following flooding episodes. Amphibians, including several species of toads, frogs, and salamanders, are usually abundant in the riparian communities. In addition, many of the reptiles that are present in the other vegetation communities also frequent the riparian communities to obtain water when it is present. Nearly all of the bird species found in adjacent habitats also frequent riparian areas at some point in time. Some of the more common types of birds found here are; hummingbirds, vireos, flycatchers, warblers, and finches. Many migrating birds utilize this habitat for cover and as feeding areas as they move through in the spring and fall. One species of hawk, the red -shouldered hawk, is generally confined to oak and riparian woodlands. Other species of hawks, falcons, kites, owls, and doves specifically require woodland situations for nesting and perching. The San Joaquin Freshwater Marsh located adjacent to the North Campus parcel provides habitat for approximately 6 species of amphibians, 16 species of reptiles, 212 species of birds, and 24 species of mammals (Gustafson, N.D.). Many of these species are not restricted to the marsh habitat and would be expected to utilize the grassland and willow woodland on the adjacent parcel. Raptors that nest in the woodland surrounding the marsh like the red -shouldered hawk (Buteo lineatus) and black -shouldered kite (Elanus caeruleus), may utilize the grasslands on the North Campus parcel as foraging habitat. Of particular importance are areas on the campus where two communities meet. These areas are called ecotones and are significant because of the wider variety of opportunities they offer to wildlife. Ecotones are transitional communities, having characteristics of both kinds of neighboring vegetation as well as characteristics of its own (Cooperrider et al., 1986). The increased structural diversity of ecotones enhances wildlife species diversity. This is true especially in the riparian willow woodland/grassland ecotones on the west and east sides of campus, and the coastal sage scrub/grassland ecotones of the Open Space Reserve. CTION 3 - SENSITIVE SPECIES ASSESSMENT This section discusses the methodology and results of field surveys for threatened, endangered, candidate, and other rare or sensitive species of plants and wildlife. 3.1 METHODOLOGY The spring surveys for rare plants species were conducted concurrently with the general vegetation surveys described in Section 2, using the same methodology. This methodology is in accordance with guidelines proposed by the California Native Plant Society and adopted by the California Department of Fish and Game. Essential features of these guidelines include complete coverage of all habitats in the survey area and repeated surveys that cover the range of flowering periods for the area. This methodology is preferred over focused surveys for rare plants in order to minimize the probability of overlooking unexpected species. In order to determine whether or not rare species are known to occur in the area, Chambers Group botanists consulted the California Natural Diversity Database (CNDDB) and the California Native Plant Society's Inventory of Rare and Endangered Vascular Plants (CNPS; Smith and Berg, 1988). Fred Roberts of UCI's Museum of Systematic Biology was consulted prior to and during the survey period. The summer survey for rare plants was conducted separately from the general vegetation surveys during the period of August 24 - September 7. The survey was conducted by Fred Roberts, in cooperation with Dr. Edith Read of Chambers Group. Dr. Read accompanied Mr. Roberts during his surveys on the east side of the main campus. Other less extensive areas with at least some potential for rare species, especially the tarplants (Table 1), were surveyed independently by Mr. Roberts. Surveys for sensitive wildlife species were conducted both concurrently and separately from the general wildlife surveys on the campus. Several different survey methods were used depending on which wildlife species was involved. The general wildlife assessment consisted of walking parallel transects approximately 10 to 30 meters apart. During these general surveys, any sensitive wildlife species that were seen were noted. Areas consisting of potential habitat for sensitive wildlife species were examined more intensively than those areas deemed unsuitable for sensitive species. A list of observed, expected, and potential sensitive wildlife species was compiled from previous surveys in the area, from the California Natural Diversity database, from observations of UCI personnel and University Hills residents, and from field surveys. The survey for burrowing owls was quite intensive. Initially, the area to be surveyed was scanned using binoculars in hopes of seeing burrowing owls standing near their burrows. 12 . • LpLpLpS N o a r c A a o L O i �Y r L0 L 50 r 4 S- +y+ O d ENE C78 �Q a NZ dy" dIn r yyaa W� L� L t d ++ r Y O A O r r A O Iss ti 2 W C N �� L W Q d ICO yC 61 yG d 7N O y (Lj Qf U 7 .O7 6Ni L y p EG U i Vd N p O N pp 00 O iUU L N iUU C d N UU i+ Co L a i+ C a d b r CN � N Nspssp L d a d a 8 r Ch W DI OI� N C A N 1rO N^ h tAh W N r L Q>I L N r 44 C N Ql a 8o O + r N � g i AS r �c1 Y IS ADO r N i fe ACL a L udi O g� a� �L. c�s go m 4.)o A d A N ptp a 7 19 a N �paO C c ICO la 0; a- LW LW 'p L C L. L+1 L4 r r$ gn y (4 a C a r r L a a A L L QEt a a A C T a s a.— A N L ul a L c G +/ 8 A U L T A a 06 U a ({�,� L LCL U) U)N 10 N 4S N CO. r c 7 T TCS C A T C T �01 jpp � ytii � U W r WOOL O LO 4 1i 7 a ti d U > en Ih 7 m M rh 1 N In N N M l; INp }/ VJ I m m N R! !o N N N r _ U m L) V U I I I W N to ii 10 U H l i da � N � L Y g i Ic0 C on,A ro Iq yd j U V� Ca �ti r � Q 0 r R E h CU is w 'q q w41 S. A Ip L ai C L r UO j C dp� r6 C i L 41 M L �E SS. "[t` A *` c r N 4j va 13 r Z T r • s LAJ • i . y • � �CC�. r' r G Cood I •r• LL y� �Ir •Ct' Tr A : T. �•� •b+ .A ,� :.11 U fl •• _:� A• •N �•il .�' . :y •• N -N A U . !Am lops 1: 14 • 0 • i Then parallel belt transects, approximately 10 to 30 meters apart depending on the terrain �l and the density of ground squirrel burrows, were walked within the boundaries of the site and in the surrounding areas. In addition, the locations of ground squirrel activity, in the form of burrows and trails, were also marked on the map. The survey for California atcatcheerr was conducted in the coastal sage scrub habitat in and adjacent to the n Space Reserve. A recording of the call of the California gnatcatcher was pla on a number of occasions during walkover surveys of the area. This was done to attemp to elicit a response from any individuals of this species that might be present. The survey for least Bell's vireo was conducted in the riparian habitats on campus. A recording of the call of the least Bell's vireo was played near the riparian habitat on a number of occasions to attempt to elicit a response from any individuals of this species that might be present. Other sensitive bird species, such as the cactus wren, were surveyed for by site and sound because they are a very vocal and easily observed species. Surveys for cactus wrens were centralized around the cactus patches on the campus. No other sensitive bird species were expected on the campus other than some species of raptors, but no special methods were required to survey for these species. In addition, no sensitive mammal species were expected on the campus so no specific survey methodology was required. The survey method for orange -throated whiptail (Cnemidophorus hyperthyrus) and San Diego Coast horned lizard (Phrynosoma coronatum) consisted of a meandering walking pattern that is used to increase the likelihood of encountering these animals. Brush and shrubs were prodded to elicit movement in concealed lizards. Lizard scat was also examined for the purposes of identification. In addition of surveys to individuals and fecal remains, habitat quality relevant to the species of concern was recorded. Quality was assessed based on the following criteria considered important for orange -throated whiptail and San Diego Coast horned lizard: o the presence of loose, sandy substrate; o the amount of patchy, open substrate fragmented by shrubs and dense brush; o the presence of ant colonies, primarily species of the genus Pogonomyrmex. } 3.2 VEGETA i ION The information provided by the CNDDB and CNPS sources prior to the field surveys, as well as discussions with Fred Roberts of UCI's Museum of Systematic Biology, indicated that the species listed in Table 1 have some potential to occur on the campus. Four of 15 these species were observed during the surveys: Orange County Turkish rugging (Chorizanthe staticoides ssp. chrysacanthe), many -stemmed dudleya (Dudleya multicaulis), southern tarplant (Hemizonia australis), and mesa brodiaea (Brodiaea jolonensis). Figure 4 shows their locations. Orange County Turkish Rurin� Orange County Turkish rugging is a low -growing annual plant with minute pinkish -white flowers which appear in late spring to early summer. Populations were observed by Chambers Group botanists on two south -facing rocky slopes in the Open Space Reserve, but not at any other locations on the campus. The taxonomic status of this member of the buckwheat family (Polygonaceae) is currently in dispute, with Reveal and Hardham (1989) arguing that the Orange County populations are ecologically rather than genetically distinct from populations of the more common taxon (ssp. staticoides). However, Reveal and Hardham (1989) acknowledge that more study is necessary before their analysis can be regarded as conclusive. The United States Fish and Wildlife Service (USFWS), as of February 21, 1990, downlisted Orange County Turkish rugging from candidate category 2 (possibly endangered but more information needed) to category 3b (taxonomic validity in question). Fred Roberts of UCI's Museum of Systematic Biology regards the populations on the campus and elsewhere in Orange County as of high scientific value because of the possibility that they may provide specimens which would help resolve the controversy (F. Roberts, personal communication). Many -Stemmed Dudleya Many -stemmed dudleya is a succulent perennial member of the stonecrop family (Crassulaceae), with a perennial underground root system and above -ground vegetation which dies by mid- to late April. When its small yellow flowers are not present, plants are cryptic and easily overlooked during a survey. Chambers Group botanists confirmed nearly all of the locations of many -stemmed dudleya populations described by Cesares (1989), except for one small population which apparently occurred on a hilltop just south of the end of Los Trancos Drive (on a site proposed by UCI as the University House site). A visit to this location by Fred Roberts of UCI's Museum of Systematic Biology and Dr. Edith Read of Chambers Group failed to relocate the population. All of the other populations occur either in or immediately adjacent to the Open Space Reserve. The typical habitat is rocky, protected from southern exposures, and in open areas away from dense cover by grasses. The species is a federal category-2 candidate, meaning that it may be endangered but more information regarding its distribution and threats to habitat is needed before listing is considered. Currently, the species is distributed widely over areas of Orange County and western Riverside County, but individual populations are typically small and many are threatened with development. Past experience in reseeding plants has not been highly 16 40 114t5- 0 co NZ CIO LC) 10 CID ............ 2140 9 cv, P> .... . ....... LU U.1 z w w 0 5 z w w'-'cr 0 CC =: CC W cf) 3: < 0 Co CL z Z., cr C/) 0 < W U) F - cc w w E &I LQ < C/) <F- z w ci F z LLI LL C7 cc z 0 0 X �6 D cr: w -j A m z u �ZD 1A\ IN 7-1 WE cr) I CL U LLI z 0 C/) z 0 0 LU C-) Lij CL U) uj z LLJ co I n . 00 successful, with typical mortality greater than 90 percent (F. Roberts and G. Marsh, personal communications). Southern Tarnlant Southern tarplant is a herbaceous annual member of the sunflower family (Asteraceae), with yellow flowers that appear in late summer. Typical habitat is in drainages, in semi - moist and alkaline soil. Prior to the UCI surveys, the only known population in Orange County was adjacent to Upper Newport Bay. In cooperation with Dr. Edith Read of Chambers Group, Fred Roberts surveyed all areas of the campus with at least some potential to support the species. Given the grazing history of the campus and the disturbed nature of many of the drainages, the populations of southern tarplant which were discovered on the campus were unexpectedly large and healthy. All of the populations were found on the east side of the main campus, the largest of which occurs in a drainage just north of the Farm School. Sizeable populations also occur in association with the seep areas along Bonita Canyon Drive. - Southern tarplant is not a listed threatened, endangered, or candidate species, but is on the California Native Plant Society's List 3. This status means than there is not enough information to assign it to any other category, but its known occurrence in grassland and drainage habitats in coastal southern California make it vulnerable to development. 0 Mesa Brodiaea Mesa brodiaea is a perennial member of the amaryllis family (Amaryllidaceae). It produces violet flowers and grass -like leaves from an underground corm (bulb) and violet flowers. Individuals are virtually invisible when not in flower. At least one population was known to occur on campus (F. Roberts and G. Marsh, personal communications) prior to the survey, and additional populations were observed during the survey (Figure 3). All of the populations occur in annual grassland habitat adjacent to gullies west of the Open Space Reserve. The species is not considered rare by the USFWS, the California Department of Fish and Game (CDFG), or the California Native Plant Society, but is regarded as regionally unique. The populations on ' campus represent one of two known locations in Orange County (F. Roberts, personal communication). 3.3 WILDLIFE Table 2 presents the possible listed endangered, threatened or candidate wildlife species which were observed or could potentially occur on the campus. Figure 4 shows the locations of three sensitive wildlife observed during the surveys: California gnatcatcher, cactus wren (most probably the coastal race), and burrowing owl. The following 18 • «W. V) F <^ U Z� Z N U O F= < U co V V Z OU Z < V Z rCr•, W U F" IT rr F L > c g d U O Y In A n 4. g L d L N N C O O L C T p N 41 C L U U C 9 In'N L yCy A 6. O C 41 O > 10 T > L •' dl Y C T O T > V C V „ to to In g � 41 � � O T' T th L O i N 00 yy G yy IUO � � s+ a T r N a)�- 61 L^ N N C o g 44QQ V 414110 S. 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L. g og 0 AC C Q i Qr W 10 Q Cl �yyt�pU� UtoC7: 1-WA, " O 0 C: descriptions focus on these species as well as others with at least some potential to occur on the campus. California Gnatcatcher The California gnatcatcher (Polioptila californica, formerly the black -tailed gnatcatcher) is currently designated as a Federal Category 2 Candidate species by the U.S. Fish and Wildlife Service. This species, which is non -migratory, nests and forages in moderately dense stands of coastal sage scrub occurring on and hillsides, mesas, and washes. Coastal sage scrub communities dominated by California sagebrush, California buckwheat, white sage, and black sage seem to be preferred by this species. Loss of suitable habitat for this species and fragmentation of habitat from expanding development has been a major factor in the declining numbers of this species in Southern California. It appears that, at the present time, California gnatcatchers may vary in abundance from fairly common to Quite rare in those regions where they still persist. In addition, California gnatcatchers may or may not occur in areas of apparently ideal habitat. The entire coastal sage scrub community within and adjacent to the Open Space Reserve is considered confirmed habitat for this species. The CNDDB does have past records of California gnatcatchers within the Open Space Reserve. Figure 3 shows the locations of where California gnatcatchers were found during the Chambers Group 1990 surveys conducted on the UCI campus. It is estimated that 5 to 7 birds inhabit the coastal sage scrub habitat in the reserve. The highest concentration of this species was found in coastal sage scrub, adjacent to a barbed wire fence and the drainage within the proposed alignment of California Avenue. A recent bird watching trip (June 1990) through the Reserve, sponsored by some of the residents in University Hills, confirmed the presence of at least 5 to 7 gnatcatchers and one active nest containing four newly hatched young (Reed, personal communication, 1990). Although not verified by Chambers Group wildlife biologists, the locations of the sightings indicate that the entire opern space Reserve is utilized by individuals of this species. Cactus Wren F The cactus wren (Campylorhynchus brunneicapillus), a federal Category 2 can species and state species of special concern seems to be relatively abundant on the UCI campus as a whole. The coastal race of this species is being considered for listing pending a review of its taxonomic status. Cactus wrens typically build their nests in among the thorns of cholla cactus or prickly pear cactus. The range of the coastal race of this species is declining due to the loss of habitat and the fragmentation of habitat resulting from urban and agricultural development. Prickly pear cactus is usually associated with coastal sage scrub vegetation and is common within and in the vicinity of the reserve. All areas of 0 21 prickly pear cactus on the UCI campus must be considered potential habitat for the cactus wren. Figure 4 shows the locations where cactus wrens were observed. 0 Burrowing Owl The burrowing owl (Athene cunicularia) is a small, diurnal, stilt -legged owl that inhabits desert and open grasslands of western and midwestern North America. This species commonly perches conspicuously during the daytime on fence posts or stands at the entrance to its nesting burrow. It is definitely an owl of open country and is commonly found on golf courses, road cuts, and at airports. Both sexes are sandy -colored over the head, back, and wings, with barring on the breast and belly. The long, exposed lower legs and the characteristic "bowing" behavior that the bird displays when approached or otherwise disturbed quickly distinguish it. Burrowing owls nest in abandoned rodent burrows which they modify yearly by digging and scraping with their beaks, wings, and feet. Nocturnal flight is low and undulating and it often hovers like a kestrel. The burrowing owl is protected during the breeding season under the Migratory Bird Act. Under this Act, the burrowing owl cannot be disturbed or displaced during the nesting and fledgling season, but once fledgling of the young is complete then burrowing owls can be displaced. This species is also considered a Species of Special Concern by the California Department of Fish and Game which is a species whose populations are actively being monitored by the CDFG. Loss of suitable habitat has been one of the main causes of the decline of this species. The Orange County Breeding Bird Atlas has confirmed that the burrowing owl is a confirmed nester within Orange County. Historically, the UCI campus supported a large population of burrowing owls, but as the campus became developed the number of burrowing owls decreased (Bowler, 1989 and C. Elphick, personal communication). A survey for this species was conducted by Peter Bowler on portions of the UCI campus in May, 1989. He found seven individuals inhabiting the area of the campus surrounded by California Avenue, Campus Drive, Culver Drive, and the Farm School. The May, 1990 survey conducted for this report identified five burrowing owls in this same area. Figure 4 shows the locations where the burrowing owls were found. One pair was found inhabiting a dry arroyo between Campus Drive and the Farm School. This arroyo is just south and almost adjacent to the drainage channel that has been proposed as an open space corridor in the Long Range Development Plan for the UCI Campus. Enhancement and diversion of the drainage channel in the vicinity of the existing burrowing owls will probably have some impact on these individuals. The other three burrowing owls were found in the open area east of the Farm School. At the present time, these individuals do not seem to be threatened by any disturbances but enhancement of the drainage channel, in the form of large machinery, may also impact these other individuals. Almost the entire area from Campus Drive south to the fenceline that runs southeast from the Farm School to Culver Road, is excellent habitat for burrowing owls (see Figure 3). The only exception is the spoils area located at the corner of Campus Drive and California 22 0 Avenue which was graded in the spring of 1989 (Bowler, 1989). According to Bowler, the f spoils area supported burrowing owls prior to grading activities but once the area was disturbed the burrowing owls disappeared. The spoils area is partially encompassed by the northern boundary of the Group Housing Site. Several environmental factors contribute to the existence of the burrowing owl habitat on the campus; including horse grazing, ground squirrel activity, and the lack of much human intrusion. The removal of the horse grazing and eradication of ground squirrels will most likely ensure the extirpation of the burrowing owls from the UCI campus. Least Bell's Vireo The least Bell's vireo (Vireo bellii pusillus) is a state and federally endangered species of bird that usually inhabits willow riparian areas with a dense understory of mulefat. In addition, this species has been known to inhabit other types of vegetation, such as sycamore woodland (J. Griffith, personal communication). Destruction of habitat and parasitism by the brown -headed cowbird are the major causes of the decline of this species. Due to the recent control efforts on the brown -headed cowbird the least Bell's vireo population seems to be increasing (J. Griffith, personal communication). The largest concentration of least Bell's vireos in Orange County and its vicinity occurs in the Santa Ana River channel and Prado Basin. Suitable habitat for the species occurs in the large woodlands that comprise part of the San Joaquin Freshwater Marsh Reserve. Least Bell's vireos were not seen or heard in the willow woodlands on campus during the 1990 surveys, but a male of this species was sighted in May of 1990 in the riparian woodland at Bonita Canyon Reservoir, located just south of Bonita Canyon Road. s" Golden Earle The golden eagle (Aquila chryseatos) is a large species of eagle that is fully protected under the Bald Eagle Act of 1940. Protection under this act was extended to golden eagles in April 1963. This species is also considered a California Department of Fish and Game Species of Special Concern. Adult golden eagles have brown body plumage while the nape and the crown feathers are edged or tipped with golden -buff or tawny. Subadults and immature golden eagles are darker brown than the adults, they lack the tawny -edged nape and crown feathers, they show well-defined white patches at the base of the primaries, and they have a white tail with a distinct dark terminal band. This species typically inhabits mountainous or hilly terrain, where it hunts over the open country for small mammals, snakes, birds, and carrion. Nesting usually takes place on a rocky ledge or crag rather than in a tree. The home range of this species in California has been found to vary between 19 and 59. square miles (Chandler, 1989). The golden eagle's susceptibility to environmental changes makes it a sensitive and important biological indicator species. Like most raptors, golden eagles are likely to abandon their nests during the incubation period if disturbed. 23 Rock climbing and hiking, off -road vehicle traffic, low -flying aircraft, bird watching, photography, and shooting are potential negative disturbances, that can sometimes be regulated by limiting human access to sensitive areas used by golden eagles. This species occurs throughout the Santa Ana Mountains and foothills and it is a confirmed nesting species in Orange County. One golden eagle was recorded near Irvine Lake during the 1989 Northeastern Orange County Christmas Bird Count. The habitat on the campus in general can de considered suitable foraging habitat for golden eagles although no individuals of this species were seen during the spring, 1990 surveys. Black -shouldered Kite The black -shouldered kite (Elanus caeruleus) is a fairly common raptor of brushy grasslands and farmlands, and may even be found along highway median strips. This species can be identified by its long, pointed wings and long tail, its mostly white underparts, and black shoulders that show in flight. The black -shouldered kite is easily identified by its habit of hovering while hunting for rodents and insects. This species is a California Department of Fish and Game "fully protected" species, as described in Section 4700 of Chapter 8, Section 5050 of Chapter 2, Division 6, Chapter 1, Section 5515 of the California Fish and Game Code. In the past, the populations of this species have fluctuated strongly, but now they seem to be on the increase (Scott, 1987). Loss of suitable habitat for this species may play a role in the future abundance of this species. No individuals of this species were seen during the survey for this project in May, 1990 but campus residents (C. Reed, personal communication) have reported the occurrence of this species in the past. Habitat on the campus is in general considered good for the black -shouldered kite. This species is a confirmed resident and nester in Orange County. Cooper's Hawk The Cooper's hawk (Accipiter cooperiil is a secretive woodland hawk that preys on medium- sized birds, small mammals, and reptiles. It occurs in various types of mixed and deciduous forests, streamside groves, and open woodlands during the breeding season but they occur in a wide variety of habitats during migration and during the winter. Cooper's hawk is a medium-sized raptor that is characterized by short, rounded wings, and a very long rounded tail. Adults are blue -gray above, and white, barred with rufous or cinnamon below. The tail is crossed by four dark straight bands and has a wide white terminal band. This species is considered a California Department of Fish and Game Species of Special Concern, which is a species that is being actively monitored by the CDF&G. Loss of suitable habitat has played a role in the declining numbers of this species. The CNDDB contains records of occurrences of this species throughout the Orange County. Individuals have been seen on the UCI campus (Bowler, 1989) and may frequent the riparian woodland habitat on the campus Parcel. 24 is Sharp -Shinned Hawk The sharp -shinned hawk (Accipiter striatus), the smallest of the accipiters, is a shy and retiring species that usually hunts from an inconspicuous perch in wooded areas for small birds, almost its only prey, which are captured after a brief, rapid chase. This species soars almost everyday, usually for a while in the morning, and this is when it is most visible. Sharp -shinned hawks are usually found in mixed woodlands but this species is relatively common and widespread, particularly in winter. This species is slightly smaller than the very similar Cooper's hawk. A shorter, squarer tail and proportionately smaller head and neck help to distinguish this species from the Cooper's hawk. In addition, the adult sharp -shinned lacks the Cooper's strong contrast between the crown and back. According to Bowler (Bowler, 1989), sharp -shinned hawks have been seen on the UCI campus in the past but no individuals were seen during the spring, 1990 survey. The willow woodlands on the campus would be considered good habitat for this species. Red -shouldered Hawk The red -shouldered hawk (Buteo lineatus) is a slim, narrow -winged, long-tailed raptor that inhabits moist deciduous woodlands, often near streams, but it seem to prefer mature forests. This species is most easily identified by the extensive black and white checkering on the back and the rufous -colored breast, belly, and wing linings. The tail is blackish with 4 to 7 narrow white bands. It obtains most of its prey by still hunting from perches. Typical prey items include snakes, frogs, mice, crayfish, and sometimes young birds. This species is a year-round resident in Orange County. The California Department of Fish and Game considers this species as a State Species of Special Concern that is not in immediate danger of extirpation. Loss of woodland habitat has played a role in the declining numbers of red -shouldered hawks. The Orange County Breeding Bird Atlas has identified the red - shouldered hawk as a confirmed nester within Orange County and a pair of nesting birds was seen in May, 1990 in the San Joaquin Marsh area. Individuals may frequent the willow woodland areas on the campus. Swainson's Hawk The Swainson's hawk (Buteo swainsonil is a lanky, small -footed hawk that preys on small mammals, birds, large insects, reptiles, and amphibians. Swainson's hawks usually hunt from perches such as fence posts and low trees, or from vantage points on the ground. This ~ species is most commonly found over open plains and prairies in the Great Plains and relatively and areas of western North America. It builds rather flimsy nests in shrubs and trees along wetlands and drainages and in windbreaks in fields and around farmsteads. The primary wintering grounds for this species is in Argentina. Adult birds have dark brown heads with a dark breast band which is set off from a lighter -colored belly in the lighter phase of this species. The Swainson's hawk is listed as a threatened species by the 25 California Department of Fish and Game and is considered as a Federal Category 3C . Candidate Species. Category 3C comprises taxa that are now considered to be more abundant and/or widespread than previously thought. Should new information suggest that any such taxon in this subcategory is experiencing a numerical or distributional threat, it may be considered for transfer to category 1 or 2. Currently, the number of breeding pairs of Swainson's hawks in California is only about 550 pairs but historically the number may r have been as high as 17,000 pairs (CDF&G, 1988). Expansive grasslands, pasturelands, and appropriate croplands, with nearby woodlands or groves are critical to the survival of this species. If current trends of agricultural and urban expansion continue, the remnant population of Swainson's hawks may decline to the point of endangerment. The Swainson's hawk is not a frequent visitor to the Orange County area but this species has been sighted in the county, and according to Bowler (Bowler, 1989) it has been sighted on the UCI campus. Suitable habitat for this species occurs on the UCI campus as a whole. Ferruginous Hawk The largest of the North American buteos, the ferruginous hawk (Buteo regalis), is a long - winged, pale -headed bird that inhabits unbroken terrain in the Great Plains and and intermountain regions of western Canada and the United States. This hawk can be identified by the rusty back and shoulders, paler head, and white tail washed with pale rust. On the upperwing surface, large white crescent -shaped patches make a bold flash in flight. The diet of the ferruginous hawk is restricted, consisting primarily of rabbits, hares, and ground squirrels, although it will take other prey. It often watches for prey from a perch • or on the ground, while soaring with wings above the horizontal, or in low, rapid flight over open country. This species is a rare winter visitor west of the Santa Ana Mountains but is more numerous in the open areas of Riverside County. This species is fairly common, but its numbers may be declining over much of its range. At the present time, the ferruginous hawk is considered a Category 2 candidate species for listing by the United States Fish and Wildlife Service. The open habitat on the UCI campus is considered good foraging habitat for this species although no individuals of this species have been recorded on the campus. Northern Harrier Formerly called the marsh hawk, the northern harrier (Circus cyaneus) is a bird of the marshlands, grasslands, and prairies. It feeds on a variety of animals including, mice, rats, frogs, and other prey which it detects by means of its keen hearing. This species typically perches low or flies close to the ground with its wings upraised as it searches for prey. The northern harrier can be distinguished by its slender body, long tail and wings, long slender yellow legs, distinct facial disk, and a conspicuous white rump patch. The adult male is pale gray on the head, back; and wings, and the tail is gray crossed with six to eight pale gray -brown bands. Adult females are brownish rather than gray. Northern harriers nest on the ground in dense cover, or occasionally in deeper, more bulky nests built in shallow 26 0 water. This species is considered a Species of Special Concern by the California Department of Fish and Game. Destruction of -habitat for the purpose of urban development is the greatest threat to this species. Northern harriers are year-round residents in Orange County but it is not known whether they nest within the UCI campus area. No northern harriers were seen on the campus during the spring, 1990 surveys, but potential habitat is present. Prairie Falcon A large falcon of and regions, the prairie falcon (Falco mexicanus) is a locally uncommon to fairly common bird that breeds in the mountains, foothills, and riverine escarpments of western North America. This species is considered a Special Concern Species by the California Department of Fish and Game. The prairie falcon is identified by being pale brown above, creamy white and heavily spotted on the breast and belly, and barring on the thighs. In flight, the dark axillaries and dark bar on the wing are distinctive. This species nests almost exclusively on suitable ledges of cliffs and low escarpments or, occasionally, in stick nests constructed on cliffs by ravens, hawks, or eagles. It preys on a variety of mammals, birds, reptiles, and insects. The prairie falcon generally hunts from perches or in a low, rapid, searching flight, usually capturing prey on or near the ground. The UCI campus area falls within the year-round range of the prairie falcon, and in fact, one prairie falcon was counted near Irvine Lake, located east of the campus, during the 1989 Christmas Bird Count. Suitable foraging habitat but no individuals were seen during the spring, 1990 surveys. Peregrine Falcon The peregrine falcon (Falco peregrinus anatum) generally inhabits open wetlands near cliffs where they prey chiefly on ducks, shorebirds, and seabirds. Occasionally this species is seen in cities, on bridges, and on tall buildings. At present, the peregrine falcon is rare and local in the western United States but a program of reintroduction in parts of their former range has resulted in year-round sightings of this species. The decline of the peregrine falcon in North America was mainly due to persistent pesticides and DDT. Both the California Department of Fish and Game (CDFG) and the United States Fish and Wildlife Service (USFWS) have lilted the peregrine falcon as endangered and this species is also considered a CDFG "fully protected" species. The peregrine falcon is a large, dark falcon with a thick, dark mustache mark. The dark head appears hooded with a white to 'buffy chaek and throat. The white breast is unstreaked or lightly streaked, and the white belly is barred with black. The back and upperwing coverts are dark slate with blue -gray bars and feather fringing. Recently, peregrine falcons have been seen nesting in the cliffs adjacent to the Newport Back Bay, and in April one peregrine was seen flying over the buildings east of the Newport Freeway (55) near Dyer Road. Due to the close proximity of the campus to the nesting population at the Newport Back Bay, it would not be improbable to see 27 peregrine falcons hunting for prey over campus and the San Joaquin Marsh Preserve. According to Bowler (Bowler, 1989), peregrine falcons have been recorded on the UCI campus. Long-eared Owl The long-eared owl (Asio otus) is a medium-sized slender owl with long, close -set ear tufts and long wings that extend beyond the tail. The breast and belly are boldly streaked and barred while the flanks and wing linings are tawny. The facial disk is typically bright orange -chestnut, but is tawny brown on the pale western race, Asio otus tuftsi. Long-eared owls typically live in thick woods but they hunt over open fields and marshes. By day this species usually roosts in a tree, close to the trunk. Little is known about the long-eared owl because it is typically so nocturnal in its habits and so retiring during the day that it is rarely seen. This species is uncommon and it is considered a Species of Special Concern by the California Department of Fish and Game. There is some dispersal of this species south in the winter months but its year-round range does include the UCI area. Suitable foraging habitat for this species does occur on the campus as a whole, although no individuals of this species were seen during the spring, 1990 surveys. Short -eared Owl The short -eared owl (Asio flammeus) occurs exclusively in open areas, frequenting marshes, 0 grasslands, agricultural fields, and various other open habitats. This medium-sized owl has long wings that extend well beyond the tail, a relatively small facial disk, and a short, thick neck that gives it a stout, blunt -headed look. The small ear tufts are set close together and are usually difficult to see. The dark brown upperparts are heavily mottled with buff spots and bars while the neck and upper breast are streaked with dark brown. The belly and flanks are buff with distinct, neat, dark stripes and the tawny facial disk has dark centers surrounding the bright yellow eyes. In its buoyant, loose flight, this species bounds from side to side with frequent glides on wings angled forward and slightly ahead of the body. The short -eared owl hunts chiefly at dawn and dusk for small rodents but insects and small birds are of secondary importance as prey. During the day this species roosts on the ground or on low perches. Short -eared owls are fairly common and typically winter in southern California. In fact, one short -eared owl was spotted near the Rattlesnake Reservoir, Siphon Reservoir, and adjacent foothill area located approximately eight miles northeast of the UCI campus, during the 1989 Christmas Bird Count. The California Department of Fish and Game considers the short -eared owl a Species of Special Concern. Suitable habitat for this species occurs on the UCI campus as a whole, although no individuals were seen during the spring, 1990 surveys. A report prepared by Bowler (1989) indicates that short -eared owls have been recorded on the UCI campus in the past. 28 0 0 Yellow Warbler The yellow warbler (Dendroica petechia) is a plump, short -tailed warbler that is common in wet habitats, especially in willows and alders, open woodlands, gardens, and orchards. This species is generally yellow overall with a dark prominent eye surrounded by a yellow eye ring. The back, wings, and tail are a yellowish -olive color, with yellow wing markings ". and tail spots. The males are bright yellow with thin chestnut breast stripes. Yellow warblers breed and nest in California, and according to the Orange County Breeding Bird Atlas this species is a possible nester within the vicinity of the Group Housing site. Yellow warblers typically winter from southern Mexico to Peru and Brazil but small numbers regularly winter in southern California. During the 1989 northeastern Orange County Christmas Bird Count one yellow warbler was seen in the Lion Country and southern 405 freeway region. Due to declining numbers this species is considered a Species of Special Concern by the California Department of Fish and Game. Yellow warblers nests are heavily parasitized by the brown -headed cowbird, and this fact combined with loss of suitable habitat has caused a decline in the numbers of this species in southern California. This species has been sighted on the Campus and does occur in the willow woodlands adjacent to the North Campus parcel in the San Joaquin Marsh Reserve. Willow Flycatcher The willow flycatcher (Empidonax traillii) is an average sized (5.75 in.) flycatcher with a brownish -olive back contrasting with a pale throat and breast. This species closely resembles other Empidonax species in California, but the slightly browner coloration, generally lighter appearance through the breast and throat, and lack of an eye ring helps to distinguish it from other species. The willow flycatcher was formerly a common summer resident throughout California, breeding wherever extensive willow thickets occurred. It has now been extirpated as a breeding bird from most of its California range. This species is now seriously threatened in a significant portion of its range in California due primarily to habitat loss and degradation and nest parasitism by brown -headed cowbirds. Over ten years ago, this species was designated a California Department of Fish and Game Species of Special Concern. It has also been included in the National Audubon Society's Blue List t and is considered a Species of Special Concern by the USFWS. Recently, a petition was submitted to the State of California Fish and Game Department to list the willow flycatcher as an endangered species pursuant to Section 2062 of the California Fish and Game Code. Suitable habitat for this species does occur in the willow woodland on campus and in the San Joaquin Freshwater Marsh Reserve. No individuals of this species were seen during the surveys, but in Bowler's report on the avifauna of the UCI campus (Bowler, 1989), he documents that willow flycatchers have been seen on the UCI campus. 29 Orange -throated Whiotail The orange -throated whiptail (Cnemidophorus hyperythrus beldingtl is a small, slender, active lizard that inhabits coastal sage scrub and chaparral communities on hillsides, wash bottoms, and sandy mesas in the lower elevations of Southern California. This species is a Federal Category 2 candidate for endangered or threatened status, and is considered sensitive by other agencies. The sensitive status of this species is the result of habitat destruction caused by extensive urban and agricultural development. The recent survey for individuals and fecal remains, conducted in May 1990, did not reveal the presence of any orange -throated whiptails on the campus. Marginal to poor habitat for the species is present on the campus in general, probably due to grazing, encroachment of non-native grasses and development. San Diego Horned Lizard The San Diego horned lizard (Phrynosoma coronatum blainvilleil is found in fine soils in a variety of plant associations including canyon, coastal sage scrub, grassland, and open chaparral habitats. This species is considered a candidate for endangered or threatened status by the USFWS (Category 2 candidate), and is considered sensitive by other agencies. Habitat destruction caused by extensive urban and agricultural development is the major cause of the decline of this species. The recent survey, conducted in May 1990, did not reveal the presence of any San Diego horned lizards on the campus. Good habitat is present in the vicinity of the Open Space Reserve, but is generally lacking on the campus as a whole. 30 0 APPENDIX A PLANT SPECIES LIST :0 SPLANT SPECIES OBSERVED ON THE UCI CAMPUS * Non-native species Scientific Name Common Name AIZOACHEAE CARPET -WEED FAMILY Mesembryanthemum crystallinum * crystal ice plant AMARYLLIDACEAE AMARYLLIS FAMILY Allium praecox .-early onion Bloomeria crocea common golden stars Brodiaea jolonensis mesa brodiaea Dichelostemma pulchellum blue -dicks ANACARDIACEAE SUMAC .'FAMILY Rhus integrifolia lemonade berry Malosma laurina laurel suniac APIACEAE " . CARROT'FAMILY Apium graviolens * common celery Bowlesia incana American bowlesia Caucalis microcarpa California hedge -parsley Foeniculum vulgare var. vulgare * sweet fennel Sanicula arguta sharp -tooth sanicle ASTERACEAE ..: SUIVFI.O WER'FAMIL:Y-'''::: `'':.-'-"': Ambrosia sp. burweed Artemisia californica California sagebrush Artemisia douglasiana California mugwort Baccharis salicifolia mulefat Centaurea melitensis * tocalote Cirsium vulgare * bull thistle Conyza canadensis common horseweed Corethrogyne filaginifolia cudweed aster A-1 PLANT SPECIES OBSERVED ON THE UCI CAMPUS * Non-native species Scientific Name Common Name COMM australis * Australian brass -buttons Cotula coronopifolfa African brass -buttons Cynara cardunculus * globe artichoke Encelia californica California encelia Ericameria pachylepis Box Springs goldenbush Euthamia occidentalis western goldenrod Gnaphalium bicolor bicolored cudweed Gnaphalium californicum California everlasting Grindelia robusta big gumplant Hazardia squarrosa var. grindelfoides saw-toothed goldenbush Hemizonia australis southern tarplant Hemizonia fasciculata fascicled tarweed Hypochoeris glabra smooth cat's ear Isocoma veneta var. vernonioides coastal goldenbush Lasthenia californica coastal goldfields Matricaria matricarioides common pineapple weed Microseris douglasii Douglas' microseris Microseris heterocarpa derived microseris Picris echioides * bristly ox-tongue Senecio aphanactis California groundsel Senecio vulgaris common groundsel Sonchus asper * prickly sow -thistle Sonchus oleraceus * common sow -thistle Stephanomeria sp. wreath plant Xanthium strumarium var. canadense * cocklebur A-2 0 s 0, 0 PLANT SPECIES OBSERVED ON THE UCI CAMPUS Y. 'Non-native species_ Scientific Name BORAGINACEAF, d mein/iria intprm'-dia Common Name BORAGE FAMILY common fiddleneck Cryptantha clevelandii Cleveland's cryptantha Cryptantha intermedia common cryptantha Cryptantha microstachys Tejon cryptantha Heliotropium curassavicum ssp. oculatum salt or alkali heliotrope Pectocarya linearis ssp. ferocula slender pectocarya Plagiobothrys acanthocarpus adobe popcorn flower Plagiobothrys collinus ssp. californicus California popcorn flower Plagiobothrys collinus ssp. gracilis San Diego popcorn flower BR .SSICACEAE :. - : .= :.,: ` -; : ;::.:..::: _.::. A MUSTARD FAMILY :.;:: : ;:.......:. Brassica geniculata * shortpod mustard Brassica nigra * black mustard Capsella bursa pastoris * shepherd's purse Descurainia pinata tansy mustard Lepidium nitidum shining peppergrass Raphanus satfvus * wild radish Sisymbrium irio * London rocket Sisymbrium orientale * hare's-ear cabbage Thelypodium lasiophyllum var. lasiophyllum California mustard CACTACEAE;--:__.. `:._' .:.:`::>; :` ' ```:`<:' `: '. '' : A FAMILY C CTUS :... ;...:.:.. . Opuntia occidentalis complex prickly pear hybrid Opuntia prolifera coastal cholla A-3 PLANT SPECIES OBSERVED ON THE UCI CAMPUS * Non-native species Scientific Name Common Name CAPPARACEAE CAPER FAMILY Isomeris arborea bladderpod CAPRIFOLIACEAE HONEYSUCKLE FAMILY Sambucus mexicana Mexican elderberry CARYOPHYLLACEAE PINK FAMILY Silene gallica windmill pink Spergula arvensis corn spurry Spergularia villosa * villous sand spurry CHENOPODIACEAE GOOSEFOOT FAMILY Atriplex lenti,"ormis ssp. breweri Brewer's saltbrush Atriplex semibaccata Australian saltbrush Beta vulgaris garden beet Chenopodium album lamb's quarters Chenopodium ambrosioides * Mexican tea Salsola australis Russian -thistle CONVOLVUL.ACEAE MORNING-GLORY FAMILY Calystegia macrostegia morning glory Calystegia macrostegia spp. intermedia short -lobed morning glory Convolvulus arvensis * field bindweed CRASSULACEAE. STONECROP Crassula connata var. erectoides sand pigmy-stonecrop Dudleya lanceolata lance -leaf live -forever Dudleya multicaulis many -stemmed dudleya Dudleya pulverulenta chalky live -forever A-4 is • PLANT SPECIES OBSERVED ON THE UCI CAMPUS Non-native species Scientific Name Common Name 'CURCURBITACEAE :' - ... ::.: ` -GOURD FAMILY- '-.: '. Curcurbita foetissima calabazilla Marah macrocarpus wild cucumber CYPERACFAESEDGE -FAMILY ....... :..::. - ..: Cyperus eragrostis tall umbrella sedge Scirpus californicus California bulrush Scirpus pungens three -square EUPHORBIACEAE :.. _._::,:: `.:.:;;,.: .SPURGE FAMILY:; ... .:::.:::•'•,:, °...',::::. - Eremocarpus setigerus doveweed Euphorbia sp. spurge FABACEAE ..,:.. .:..: ::::::::::. PEA FAMILY: Lotus scoparius deerweed Lotus strigosub varihirtellus hirsute lotus Lupinus bicolor var. umbel latus California miniature lupine Lupinus sp. lupine Lupinus succulentus arroyo lupine Medicago polymorphia * bur -clover Medicago sativa * alfalfa Melilotus indica * yellow sweet -clover Trifolium amplectens pale sack clover •FAMILY:>�::'::'»:»;:::->s>::-.°��'°`'<>•:.:::>: Quercus agrifolia coast live oak (planted) ::::::;>::::: :: ::;:;::>.>::::::::_: CEAE:;;...:::<:::......,..:::..:.::..:>:;::•::....:•.,:;; :F tANKE..... . .::;>°<::::::>:::::>.::::::: Frankenia saliva alkali heath A-5 PLANT SPECIES OBSERVED ON THE UCI CAMPUS Non-native species Scientific Name Common Name s GERANIACEAE GERANIUM FAMILY, Erodium botrys * long -beaked filaree Erodium cicutarium * red -stemmed filaree Erod:um moschatum white -stemmed filaree HYDROPHYLLACEAE WATER EA F FAMILY - - - Eucrypta chrysanthemifolia var. chrysanthemifolia common eucrypta J IRIDACEAE - - IRIS FAMILY F Sisyrinchium bell= California blue-eyed grass JUNCACEAE RUSH FAMILY Jucus bufonius common toad rush LAMIACEAE MINT FAMILY ; Marrubium vulgare * horehound Stachs ajugoides bugle hedge -nettle LILIACEAE LILY'FAMIL:Y - ,:,::. : :: ..:......:.::....:.:.•' ::: _ ..;; ;. Calochortus splendens splendid mariposa lily Chlorogallum pomeridianum wavy -leaved soup plant LYTHRACEAE LOOSESTRIFE FAMILY' . ::::. •;'.:::. : . Lythrum hyssopifolia grasspoly MALVACEAE.._::..::':.. :::.:::::::::::::;::: MALLOW,.FAMILY... .... ;:;<:;:'::: `;:.::`•.::::.:::, .::<::' °: Malva parviflora cheeseweed MYRTACEAE: ......:::.. :. : ..: ::.: ;> ::::.:. ::::. -MYRTLE FAMILY Eucalyptus sp. * eucalyptus NYCTAGINACEAE'::: FOUR-0'CLOCK FAMILY'. Mirabilis californica var. californica California wishbone bush A-6 • • • .. Ll PLANT SPECIES OBSERVED ON THE UCI CAMPUS * - Non-native species Scientific Name Common Name ONAGRACEAE MORNING-GLORY FAMILY Epilobium canum ssp. angustifolium California fuchsia PLANTAGINACEAE PLANTAIN FAMILY. . Plantago erecta ssp. erects California plantain POACFAF ::. :;... ...:.. GRASS FAMILY Avena barbata * slender wild oat Avena fatua * wild oat Brachypodium distachyon * purple false brome Bromus diandrus * common ripgut grass Bromus hordeaceus ssp. hordeaceus soft chess Bromus rubens * foxtail chess Distichlis spicata saltgrass Distichlis spicata ssp. spicata coastal saltgrass Elymus sp. wild rye Elymus triticoides beardless wild rye Hordeum depressum low barley Hordeum murinum ssp. leporinum * foxtail barley Hordeum vulgare * cultivated barley Lamardia aurea * goldentop Lolium multiflorum Melica imperfecta small -flowered melic grass Muhlenbergia microsperma littleseed muhly . Parapholis incurra European sickle -grass Phalaris aquatica Harding grass Phalaris minor littleseed canary grass A-7 PLANT SPECIES OBSERVED ON THE UCI CAMPUS Non-native species : Scientific Name Common Name Phalaris paradoxa paradox canary grass Poa secunda malpais bluegrass Polypogon monspeliensis rabbitfoot grass Stipa lepida foothill needlegrass Stipa pulchra purple needlegrass Vulpia myuros var. hirsuta foxtail fescue POLEMONIACEAE : 'PHLOX Gilia angelensis grassland gilia Linanthus alanthiflorus ssp. dianthiflorus ground pink POLYGONACEAE BUCKWHEAT FAMILY..:: Chorizanthe staticoides ssp. chrysacantha Orange County Turkish rugging Eriogonum fasciculatum' ssp. fascicula tum California buckwheat Rumex conglomeratus * whorled dock Rumex crispus * curly dock PORTULACACEAE.: ; : <:.:.:.::: :.:::. ..>::... :;::::.. - .. PURSLANE :.FAMII:Y: Calandrinfa ciliata var. menziesii red maids Claytonia perfoliata miner's lettuce PRINIULAC EAE - ...:::::.: PRIMROSE:�'AMII:'Y:: ;:. ::::........: : . Anagallis arvensis * pimpernel Dodecatheon clevelandii ssp. clevelandii Padre's shooting star ;.' ROSE'FAMILY>``::''€':>> Heteromeles arbutifolia toyon ' -MADDER °FAMLL :>: > ;..:.> >; Galium aparine * common bedstraw A-8 9 0 0 11 0 PLANT SPECIES OBSERVED ON THE UCI CAMPUS Non-native species' ..:....:. Scientific Name Common Name SALtCACEAE WJ1MOW.FAMILY_ . Salix goodingii Gooding willow Salix lasiolepis arroyo willow SAURURACEAE.,:.:.:: Anemopsis californica yerba mansa FIGWORT -FAMILY,:::::-;:: Antirrhinum nuttalianwn Nuttall's snapdragon Mimulus aurantiacus monkey flower hybrid SOLANACFAF`':.NIGHTSHADE FAMILY..::< .. ::: Datur, stramonium var. stramonium * pale -flowered thornapple Nicotiana glauca * tree tobacco Solanum douglasii Douglas' nightshade .TYPHACEAE.::::<.> AIL:FAMILY.... :::;:: CATT .... :..:..<.;:.:...:...:....:::.:.. Typha latifolia broad-leaved cattail NETT .. . Parietaria floridana western pellitory Urtica urens * dwarf nettle A-9 0 APPENDIX B WILDLIFE SPECIES LIST 0 lie \ a m a \ \ 3 \ Z to 0 0 \ \g c a D m m m �.i ssEEEy T W W W cp�i O n W vpNi O v\i poi a W p%i 8 a W a W p�i R p%i R O O a O AL r p C A •p r toI�Ntl A L a Ai t0 N O� O 61 y ti Obi L Yal Cil Mi- Q v T r s r JOi 10 y r C N L ci�a 1 1 I ms 1 N ,p � yy 61 61 ipo C 1�pp6 C r r � 10 a %d O O 0 c S.0 G S. aSC A Y � ,ppssI j.i wr i Oi Y C y i O T w C 61 C L d -0, C i 01 d d= r_ C N 3 a 3 3 N pIp� Cps Af O pyp�� �77 N r V yN 2 Yfp1� L pi L (J CJ N T 2 QI C T in C ~ fu .O >, � L in to Ip E N + ^ to N y Q h In C A uvi N 6 y � � � i •� to m m S Ste' d r Im m � N A d G Oocto a O IYO N 1 1 N -p C to ITp N 0 JI 2 q A +1 0 16 x IO U T N fa ' 1 . yy+t1.•xI W ' LU Q! 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I . . . , a In E 2 2 ®® . -®\- c c I § in .$ t } t to 2 § b I \ a � � k ƒ B § - k} a S2\§] to k � k In / fA $_ § 7 ■ § E B ; E - � - 2 § ƒ } � a £ 2 k/ / i Izƒ J 4£ 2 £ G . §■ e . .( $ o� co a 3 - b i .A I } _ I to k \ $ } ■c ■ Q 0 J c ..: jcr 2 2 k fd ' } -uau • � � 2§§ . � § 5- 2 a � � 7 # @ 7 2 � k k\\ x LAJ LAJ LAJ a22� � ■- ■ - ■ } � � S / ] ) 2 to k .'k •�I 2 .. $ ) ) J/ cc . $�§ \ $ �ƒ J $� LM E 0 0 South Coast AIR QUALITY MANAGEMENT DISTRICT 9150 FLAIR DRIVE, EL MONTE, CA 91731 (818) 572-6200 November 14, 1990 Mr. Steve Letterly Manager Environmental Division Transportation Corridor Agency 345 Clinton Street Costa Mesa, CA 92626 Dear Mr. Letterly: Subject: Drab EIR: San Joaquin Hills Transportation Corridor SCAQMD # ODP9009119-02 The South Coast Air Quality Management District (District) provides the followinj comments on the Draft Environmental Impact Report (DEIR) for the proposed Sar. Joaquin Hills Transportation Corridor (SJHTC), (an extension of State Route 73), prepared by the San Joaquin Hills Transportation Corridor Agency (SJHTCA Based on the review of the DEIR, District staff has identified some important issues that need to be further clarified and/or included in the Final EIR. The District is responsible for adopting, implementin&, and enforcing air quality regulations in the South Coast Air Basin (Basin) which includes Orange County. In addition, as a responsible agency, District reviews and analyzes environmental documents for projects (within the jurisdiction of the District) that may generate significant adverse air quality impacts. The District's role is advisory to the lead agency. The SJHTCA proposes to bring greater mobility to the West Orange County region by constructing the proposed 19.4-mile corridor as an extension to the existing Corona del Mar Freeway from Jamboree Road in Newport Beach to Interstate 5 in the City of San Juan Capistrano. A six -lane corridor with auxiliary lanes for general- purpose traffic is proposed to be constructed by 1995, while a median, 64 to 116 feet in width, capable of providing High Occupancy Vehicle (HOV) Lanes or a fixed- guideway/rail transit system is planned for future use. The SJHTC runs in between and parallel to the San Diego Freeway and the Pacific Coast Highway in western Orange County. The proposed SJHTC presents significant air quality issues because of its size and scale, mobility goals, and its role in the regional transportation network. It is a constrained project under the Regional Mobility Plan. There is also a provision for a 3-1-1 Mr. Steve Letterly -2- October 9, 1990 toll plaza to collect a fee from freeway users as a means of recovering the' investment. The use of the center median for the future construction of HOV lanes is proposed, but no construction date is provided in the DEIR. District staff commends the SJHTC for the introduction of the latest technology into the corridor plan that will permit automatic vehicle counts and identification, variable message signing, video surveillance, incident management planning, and ramp metering. The District staffs comments are meant to advise the SJHTCA in addressing and mitigating the potentially adverse air quality impacts and strengthen the strategy to reduce the emissions caused by the project during and after construction. A detailed discussion of the environmental impacts, both short -and long -term -is provided in the Attachment to this letter. The District staff recommends that priority should be given to HOV lanes and that their construction schedule be identified in the Final EIR. The growth -inducing impacts of the corridor, as well as the cumulative impacts relative to traffic caused by the associated Foothill Transportation and the Eastern Transportation Corridors that are planned as regional transportation corridors, should also be evaluated in the Final EIR. The Transportation Demand Management(TDM) programs anticipated in the surrounding cities and the unincorporated county areas adjacent to the corridor, should also be addressed. If you have any questions regarding these comments, please contact Mr. Jack P. Broadbent, Planning Manager, at (818) 307-1519. Sincerely, Barry R. Wallerstein, D.Env. Director of Planning BRW:JPB:PF: Attachment 3-1-1 L� 0 ATTACHMENT ASSESSMENT OF SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR November 14,1990 Introduction The San Joaquin Hills Transportation Corridor (SJHTC) proposes the extension of the SR-73 Freeway from the I-5 Freeway in the City of San Juan Capistrano to its existing terminus at Jamboree Road. Portions of the project will be located within the cities of Newport Beach, Irvine, Laguna Beach, Laguna Niguel, Mission Viejo, San Juan Capistrano and unincorporated areas of Orange County. Project Description The SHJTC, together with the I-5 connection, creates a corridor of 19.4 miles on the existing SR-73 between Birch Street and Jamboree Road. There are two alternatives proposed: (1) Demand Management Alternative with 6 general-purpose lanes 3 in each direction with auxiliary lanes for weaving and steep grades), and with an 84-to 116-foot median for additional capacity (HOV lanes); and (2) Conventional alternative with 3 to 5 general-purpose lanes in each direction, with a 64-to 116- foot median for additional capacity. The median under each alternative could be used for a guideway/transit system. No schedule is provided for HOV lane construction. Air Quality Setting The DEIR accurately characterizes the air quality setting of the proposed ppro ect. According to our air quality measurements conducted in 1989 at our El Toro monitoring station, which is the closest station to the study area, the national ambient air quality standards (NAAQS) for ozone were exceeded by a wide margin Oil 7 days. Particulate matter (PM10) levels periodically exceeded the state standard, but only one measurement in excess of the federal PM10 standard has been recorded in the last 6 ycars. Background carbon monoxide levels recorded byy Caltrans at the corner of Bonita Canyon Road and Sunnyhill Road in Irvine, for a 6- week period during the winter months of - 1989 were below federal and state standards. C7 3-1-2 2 Short -Term Air Quality Impacts The Draft EIR estimates an average daily PM10 generation of about 1.75 tons during a typical week day of construction activity. Additional PM10 emissions are 3-1-3 expected from on -site construction and other equipment, including vehicles hauling concrete and roadbed materials. Fugitive Dust Control Fugitive dust should be controlled by regular watering, paving of construction roads, or other dust -preventive measures. After excavation, there should be seeding and watering until plant cover is established. Soil binders should be 3-1-4 spread. The area should be kept wet and a crust on the surface maintained. Street sweeping may also be necessary if silt is carried over to adjacent public thoroughfares. Construction Activity Construction activity and length of construction will also lead to activties such as lane closures, detours, and slowing down of traffic. The following are recommended as ways of reducing or eliminating congestion caused by such activities, or by equipment used on -site: o The cities in the corridor should be notified of lane or arterial closure at least one month in advance. Notices should also be posted near the closures. o Freeway closure, should occur during off-peak hours whenever possible. o There should be adequate parking for construction equipment when it is not in use. Construction personnel should be provided with adequate parking as well. o Construction equipment engines should be maintained by keeping them properly tuned. Long -Term Air Quality Impacts The air quality impacts arising from the project are primarily due. to vehicle miles traveled. There will also be impacts due to the potential growth -inducing nature of the project, which may provide impacts beyond county boundaries. The localized growth projection is expected to mirror the growth forecast found in the General Plans of the surrounding cities. However, the SJHTC, together with the Foothill Corridor and the Eastern Corridor (also in the region), may provide an additional impetus to growth, with resulting impacts on the traffic flow and circulation in the area. Long-term emission estimates given in the DEIR are based on a modeling grid that includes all primary arterials and controlled access roads affected by various roadway alternatives in the SJHTC area. The Direct Travel Impact Model (DTIM) used in the emission analysis considers all changes in travel patterns, volumes, speeds and types of fuel used. By 2010, the SJHTC is expected generate the following emissions with eight lanes of mixed -flow traffic without HOV lanes: CO, 3-1-5 3-1-6 0 0 • 0.8 tons day1; NOx, 0.05 tons day; ROG,0.07 tons a day; PM10, 0.02 tons a day 3-1-6 (DEIR Volume Technical Report No. 3, Page 12c). Recommendations District staff provides the following recommendations relative to the air quality analysis in the DEIR: Emission Model EMFAC7D which was available at the time of the DEIR preparation, should 3-1-7 have been used to calculate the forecasted emissions of the project. Since the preparation of the DEIR, however, EMFAC7E has been released, and is currently available. EMFAC7E provides the latest factors for in -vehicle use for the state of California. FEIR emissions data should be recalculated using EMFAC7E. Growth -Inducing Impacts The growth -inducing impacts should be analyzed in the FEIR to assess the VMT and mobility levels of the SJHTC in light of Orange County's predicted 3-1-8 population growth of 96 percent and employment increase of 111 percent by the year 2010, and the impacts brought about by the construction of both the Eastern and Foothill corridors. Low -medium -and high -growth projections (in 3-1-9 the region), with accompanying VMT and mobility levels to match, should be I a guide to realistic emission levels of the SJHTC. Mitigation The DEIR defines mitigation measures relative to short -and long-term impacts of the project. Others, including potential mitigation measures attached to this letter in Exhibit A, should be evaluated and incorporated into the project. Staff recommends the following specific mitigations for inclusion in the FEIR: 3-1-10 The DEIR does not provide a construction schedule for the HOV lanes and hence, does not analyze the traffic flow efficiencies and emission reductions associated with HOV lanes. Any attempt to delay the HOV lane construction will adversely impact the overall emission reduction goals stated in the DEIR. The HOV lanes and their impacts on emission reductions should be analyzed in the FEIR. The HOV lanes could also be used as additional peak -hour lanes (with change in direction -morning and evening) to meet the extra capacity needs warranted by the growth -inducing impacts.. Conversion to concurrent HOV lanes and the possibility of adding fixed -guideway facilities 3-1-11 and transit systems need to be examined ,in the Final EIR. HOV lanes could be used in transportation corridors as effective Transportation System Management (TSM 'tools for capacity enhancement (through shorter delays and faster traffic flow). Providing maximum service to HOVs through barrier -separated priority lanes within the freeway right-of-way may also add capacity to the proposed TSM. TDM comprises one of the two alternatives proposed in the project. As a mobility -enhancing tool, the TDM alternative is the best alternative, and will ensure that HOV lanes are utilized to maximum levels, resulting in reduced emissions. The TDM strategy for the project should include broad goals for incorporating the local agencies' TDM programs in the SJHTC region -cities and unincorporated county areas. These goals should encompass the 3-1-12 formation of Transportation Demand Management Associations (TDMAs) within the cities and unincorporated county areas within the SJHTC region. The requirements of higher vehicle occupancy and a reduction in vehicle miles traveled are goals that should be analyzed. For the HOV lanes to 3-1-13 operate efficiently, as well as achieve their peak performance, a system of TDMs must be in place. The Final EIR should address these goals.. The potential for transit alternatives such as light -rail, express busway etc., may be limited at this stage due to funding constraints. However, these could be introduced in the future. These alternatives should be discussed in the Final EIR. There is potential for a high -capacity Transit Corridor in the SJHTC. This is discussed in detail in the Regional Mobility Plan (Pages V-23 3-1-14 to 25), and also in the Transit Plan of the Orange County Transportation Management Plan. Increases in ridership level within the SJHTC median envelope should be studied. The project design should allow these changes to occur later, while still meeting the immediate capacity needs. e 11 0 EXHIBIT A POTENTIAL MITIGATION MEASURES A. Minimize Construction Activity Emissions o Water site and equipment morning and evening. o Spread soil binders on site, unpaved roads, and parking areas. o Reestablish ground cover on construction site through seeding and watering. B. Reduce Construction Equipment Emission o Wash off trucks leaving site. o Properly tune and maintain construction equipment. o Use -low sulfur fuel for construction equipment. 3-1-15 3-1-16 C. Reduce Construction -Related Traffic Congestion o Provide rideshare incentives for construction personnel. o Provide transit incentives for construction workers. o Configure construction parking to minimize traffic interference. o Minimize obstruction of through -traffic lanes. 3-1-17 o Provide a flagperson to ensure safety at construction site. o Schedule operations affecting roadways for at off-peak traffic hours. D. Limit Emissions From Vehicle Trips, VMT and Roadway Construction o Operate a Transportation Management Plan per Regulation XV o Provide commuter rideshare incentives. o Provide commuter transit incentives. o Promote Transportation Demand Management Associations. o Establish a program of alternative work schedules. o Establish a telecommuting program. o Schedule goods movements for off-peak traffic hours. o Promote local shuttle and regional transit systems. o Provide dedicated turn lanes as appropriate. o Provide transit shelters. o Provide bicycle lanes, storage areas and amenities. o Ensure efficient parking management. o Prioritize construction of HOV lanes. o Work closely with cities in the region to implement TDM goals. E Minimize Indirect -Source Emissions o Implement energy conservation measures beyond state and local requirements. o Install energy -efficient street lighting. o Include energy costs in capital expenditure analyses. o Landscape with native drought -resistant species to reduce water consumption and to provide passive solar benefits. 3-1-18 3-1-19 P0R1 'r D CITY OF NEWPORT BEACH �!- = 1)['131.1C %\0RKS 1)E1)ARF\1E\T -,11It- � FO BOX I-F,r. \1=\V11UR r RE:\C'H. CA 92t,�9_176,1, November 21, 1990 Mr. Steve Letterly Manager, Environmental Agencies Transportation Corridor Agencies 345 Clinton Street Costa Mesa, CA 92626 Subject: San Joaquin Hills Transportation Corridor TCA EIR/EIS 1 Comments Dear Mr. Letterly, The Newport Beach City'Council adopted the attached Resolution No. 90-108 on November 13, 1990. The resolution serves as the City's comments on TCA EIR/EIS 1. The resolution also expresses the City's current position on Corridor related facilities and issues. 3-2-1 Please take the items discussed in Resolution No. 90-108 into consideration in the final design of the San Joaquin Hills Transportation Corridor. Thank you for the opportunity to review and comment on the EIR/EIS. Very truly yours, Don Webb City Engineer DW:so • 3300 Newport Boulevard, Newport Beach RESOLUTION NO. 90- 108 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF NEWPORT BEACH EXPRESSING THE CITY'S COMMENTS ON THE SAN JOAQUIN HILLS- TRANSPORTATION CORRIDOR ENVIRONMENTAL IMPACT REPORT; ENVIRONMENTAL IMPACT STATEMENT (TCA EIR/EIS 1) AND THE CITY'S POSITION ON CORRIDOR RELATED FACILITIES AND ISSUES WHEREAS, the approved Master Plan of Streets and Highways of the Circulation Element of the Newport Beach General Plan incorporate the proposed San Joaquin Hills Transportation Corridor; and WHEREAS, the City Council of ,the City of Newport Beach has previously expressed support for the San Joaquin Hills Transportation Corridor as a way of directing traffic around portions of Newport Beach and as a facility which will accommodate traffic needs in the nearby area; and WHEREAS, a draft Environmental Impact Report Environmental impact Statement (TCA EIR/EIS 1) for the proposed San Joaquin Hills Transportation Corridor (hereafter "CORRIDOR") has been prepared by the Transportation Corridor Agency; and WHEREAS, the City Council has previously considered comments and recommendations from interested parties; and WHEREAS, there is a need to express the CITY's comments on the draft EIR/EIS and to set forth the CITY's current position on CORRIDOR related facilities issues in accordance with the latest information available; NOW, THEREFORE BE IT RESOLVED that the City Council of the City of Newport Beach expresses the following comments in response to the draft EIR/EIS and as a statement of the CITY'S CURRENT POSITION ON corridor related facilities and issues: 1. The CITY supports acceptance of the EIR/EIS and continues to support construction of the San Joaquin Hills 3-2-2 Transportation Corridor, with implementation at the earliest practicable date. 2. The CORRIDOR and related facilities should be designed to distribute traffic to the arterial street system in a 3-2-3 balanced fashion, in which the interests and concerns of all affected areas are recognized equally. 3. The City supports both the Conventional Alternative and the 3-2-1 Demand Management Alternative, with preference for the Demand Management Alternative. The CITY supports the Ford Road connection to the CORRIDOR; 14. 3-2-5 subject to realignment of existing Ford Road northerly of Im its present location, preparation of a traffic circulation plan for San Miguel Drive intended to minimize through 3-2-5 traffic, and supports the relocation of the proposed Ford Road/Bonita Canyon Road Park and Ride facility to a location easterly of the CORRIDOR. 5. The connection of San Joaquin Hills Road to Pelican Hill Road shall not occur until Pelican Hill Road (Newport Coast Drive) is fully operational between Coast Highway and 3-2-6 MacArthur Boulevard. The extension of San Joaquin Hills Road east of Pelican Hill Road (Newport Coast Drive) to the Corridor shall not occur. 6. An additional mitigation measure should be included to provide for review by local agencies of construction 3-2-7 phasing, traffic control plans, and detours. These items should be structured to minimize impacts on the existing street system during construction. 7. Transparent noise barriers should be considered for use 3-2-8 where views may be affected. 8. Design features and construction specifications should be 3-2-9 structured to minimize any potential siltation impacts on Newport Bay. 9. The CITY supports incorporation of design features intended to minimize grading impacts and to result in an aesthetically pleasing scenic highway route. These 3-2-10 features should include slope rounding and blending, variable slope ratios, contouring, split-level roadways where feasible, and fully landscaped slopes and medians. 10. The City supports the construction, at an early date, of 3-k-11 the missing connector ramps (NB to WB and EB to JB) at the SR-73/SR-55 Interchange. 11. The mitigation program should be identifed and 3-2-12 implementation of these mitigation measures required, rather than being classified as recommended when. feasible. This resolution supercedes Resolution 88-89 Adapted this 13th day of Novemhe ,1990 MAYOR ATTEST: CITY CLERK C'- • 818 West Seventh Street,12th Floor . Los Angeles, California EXECI TI\ E COMMITTEE Pi: vdrnt R:p.. C'iur• o: L, An_rlr, Count.\ Christine E. Reed.( Sam., \L,:n..i k: sic nt,no,• \ rnnn, ('Unix 1a,ond \,,r Pi e.i,'.enl Ru)l,ert Farrell. I. . •„i:.. ta, n:", r P.:.t President I "ne bans. , Or.,ner C..,.n!, Hurnstt \\ iedsr. kne : C. v\ \1elbu Dunlap. Sao B;:::n.?:: ,. C••:.on Jon Mikels. s.r,• Stella \lendoia. V.: Ir„ in Fried. < ) orh., L:n:.. Cine, of Rncisra, .lack Clarks. Rn Cur. , d S.rn li,-n r d on, .John Lung,ille. 11...,, (Stir. of \ eat.:r : C•=unt% John Mellon. C. , , :.n„ nil,, , San !.I P.ru I., Ct% of Los \nc:l:• Ioin Bradt e,. 11x, . 'iluria Molina. C -I .... In", , Cn% of Lon,-, 13 ., h Clarence Smith. C.ao„ din, nih, , POLICY CHAIRS Judy \\ right. C',aun dmnnher Cl.uenChan. h nr. Transport.nion and Communications Robert Gentrt, Coup, dmcmh, r Laeun r Beach: Churn L-nere\ and En%ironment Robert Wagner. t 1, , \Ann, Lake%%nod. Chute. Conununn\. E%onon,ic.and Human De\ektpmeni AT -LARGE DELEGATES Robert Bartlett, Manor 't1onro\ to Vick% Ho%%ard. Cnua, ilnu mh, i Simi \ alle\ iouthelIn Plummer, ll,n,n c%,port Bcslt ALTERNATES November 26, 1990 �.. IOUTHERA CALIFORAIA A/fOCIATIOtt OF GOVERnME11TJ 90017-3435 (213) 236-1800 c, FAX (213) 236-1825 Mr. Steven Letterly Transportation Corridor Agencies 345 Clinton Street Costa Mesa, CA 92626 RE: San Joaquin Hills Transportation Corridor Draft EIR/EIS Dear Mr. Letterly: Thank you for submitting the Draft EIR/EIS for the San Joaquin Hills Transportation Corridor to SCAG for review and comment. As areawide clearinghouse for regionally significant projects, SCAG assists cities, counties and other agencies to review projects and plans for consistency with the Regional Housing Needs Assessment (RHNA), the Regional Mobility (RMP), Growth Management (GMP), and Air Quality Management (AQMP) Plans. The attached comments are meant to provide guidance for completing the proposed project within the context of our regional goals and plans, which are based in part upon state and federal mandates. Specifically, they focus on the issues that will have to be addressed before SCAG can find the project in conformance with the State Implementation Plan (SIP). If you have any questions about the attached comments, please contact me, Debbie Whitmore, or Diane Collins at (213) 236-1800. SCAG will be happy to work with you to address the comments presented herein and, if necessary, develop a mitigation plan which meets.regional, state and federal requirements. Sincerely, ANNE BAKER Director of Environmental Planning cc: James J. Bechar, FHWA Judith Heyer, Caltrans, District 12 Imperial County o Jeanne Vogel. Superroor . Los .Angeles County o Ed Edelman, Supervisor and Pete Schabarum, Supervisor . Orange County o Gaddi Vasquez, Supervisor • Ric- erside County o I \ acann , San Bernardino County o Larry Walker, Supervisor . Ventura Counn o James Dougherh, Superrrmr . Cities of Imperial County o Victor Sanchez, Jr., .4fu%nr. Westmorland - Cities of Los Angeles Count\ o John Cro%%Iey. Car Director. Pasadena . Cities of Orange Count\ o John BaneL .4lavor. Cypress . Cities of Riverside Countv o Richard Deininger„ Ir., Coun, rhnember. Corona . Cities of San Bernardino Count\ o Larry Rhineharl. Muvnr. Montclair . Crites of Ventura County o Vicky Houard, Councilmeniher, Simi Valley - City of Los Am_eles a Richard Alatorre. Comic ilmenrher o Joy Picus, Cuuncilmernher o Michael \\ oo, C incilmemhei . Long Beach 2nd position o Jeffrey Kellogg. C,rrnu ilnu•nrher - At Large o Jvdy Wright. Coum ilmenrher. Claremont o Judy Nieburger, Councibnenrhei. Moreno Valley o John Erskine. Ciun, -iluretnher. Huntington Beach .41W,S, Mr. Steven Letterly Page Two November 26, 1990 SCAG Comments on Draft EIR/EIS for the San Joaquin Hills Transportation Corridor The conformity review process for projects (to be) included in the Regional Transportation Improvement Program (RTIP) is divided into two steps. A finding of conformity must be made for each step before a project is considered in full conformance with the Regional Air Quality Management Plan (AQMP)/State Implementation Plan (SIP). A finding of conformity is made on a project by project basis and on the RTIP as a whole. The finding that a project conforms is required to be based strictly on those aspects of the project which have constrained funding. Step 1 1. The improvements entering the outyears of the RTIP are required to be identified in the RMP. 2. Priority shall be given to the constrained transportation control measures • to maximize long term air quality benefits. Both constrained and unconstrained control measures can be programmed in the outyears of the RTIP, however, priority is given to constrained control measures. Finding: The San Joaquin Hills Transportation Corridor is identified in both the RMP and the RTIP. The constrained project includes three mixed flow lanes and one HOV lane in each direction. Step 2 The conformity criteria for Step 2 requires analysis of individual regionally significant projects as well as the Biennial Element as a whole. For the purposes of this letter, focus is placed on Step 2 (A) only, which reviews individual projects such as new corridors. 1. The projects's draft EIR/EIS is required to be submitted to SCAG for review and must demonstrate the following: A. That the project is phased, sized and located according to the pattern and magnitude of growth shown in the Regional Growth Management Plan (GMP). Transportation projects included in the RMP for which location (general alignment in the case of new corridors), number and type of lanes are identified (either in a map in the RMP or in the list of projects in Appendix A of the Conformity Guidelines), are deemed to be located and sized according to the pattern and magnitude of growth in the GMP for purposes of this paragraph. 3-3-1 3-3-2 Mr. Steen Letterly Page Three November 26, 1990 Projects included in the RMP for which environmental documentation shows project completion by 2010 are deemed to be phased according to the pattern and magnitude of growth in the GMP for purposes of this paragraph. The annual Reasonable Further Progress Report will be used to monitor project development. HOV lanes, new transit service and park -and -ride lots shall be provided for as specified in the RMP and shall be implemented within the 20-year time frame of the RMP. Finding: The proposed project is identified in the Regional Mobility Plan (RMP) as as consisting of three mixed flow and one HOV lane in each direction. The draft EIR/EIS identifies the project as being located between I-5 and Jamboree Road (with additional improvements up to Birch Street) and as consisting of three mixed flow lanes in each direction with auxilary lanes in specified locations to reduce weaving on steep grades. Four mixed flow lanes will be added at the north end of the corridor where the project joins State Route 73. A median for future HOV or transit has been provided in the preferred design. The HOV or transit median will be constructed based on funding and traffic demand conditions. ' The proposed project does not include a firm commitment to construct HOV lanes on the facility within the 20-year time frame of the RMP and is, therefore, inconsistent with this first requirement. Although park -and -ride facilities are identified in the EIR/EIS, no commitment is made by the Transportation Corridor Agency to purchase right-of-way or constrict the HOV lanes. B. That the impact on the project on air quality in the long term is analyzed on a transportation corridor level. The overall project is analyzed even if the project is phased or incrementally developed; Finding: The air quality analysis conducted for the project was done on a transportation corridor level. C. That the impact of the project on air quality is compared to the impacts of the project alternatives on a transportation corridor level. The alternatives are also compared to each other; Finding: The impact of the project on air quality was compared to the impacts of the project alternatives on a transportation corridor level. 13-3-2 3-3-3 3-3-4 LI • 0 • Mr. Steven Letterly Page Four November 26, 1990 D. That demand management strategies, HOV improvements, and transit are required to be evaluated as alternatives (and as mitigation measures, if necessary); Finding: Demand management strategies, HOV improvements, and transit were evaluated as project alternatives. E. That the project is consistent with the RMP's policies relating to air quality benefits; and, Finding: RMP Policy 11 states that HOV lanes shall be provided for in new construction in accordance with the HOV program. The reserved median provides the right-of-way to construct a future HOV lane or a transit alternative based on funding availability and traffic conditions. We do no believe that this constitutes an enforceable commitment to construct the HO lane or transit alternative withint the 20-year horizon of the RMP. RMP Policy 15 states that priority will be given to transit and ridesharing facilities over mixed flow projects if both types of facilities are include( in the constrained program of the RMP. According to the draft EIR/EIS, construction of an HOV lane or transit alternative is to be phased in after the year 2000, based on the availability of funding and traffic demand. However, on page 3-19 the document states that HOV lanes for the corridor will be constructed within the planning horizon of the AQMP -- by the year 2010. The intent of these seemingly contradictory statements should be clarified. F. That the results of the air quality analysis conducted for the project demonstrate that the project will not inhibit attainment of the national ambient air quality standards (NAAQS). The project should have a positive neutral impact on air quality in the South Coast Air Basin. Finding: The results of the air quality analysis conducted for the project predict that all receptor sites will be in compliance with both the State and federal one hour and eight hour carbon monoxide standards at all locations and concludes that there are, therefore, no significant air quality impacts associated with either Build Alternative. 3-3-5 13-3-6 3-3-7 Mr. Steven Letterly Page Five November 26, 1990 2. Based on an analysis of the draft EIR/EIS and the conformity criteria, the project is to be defined in the Biennial Element of the RTIP, including, but not limited to such factors as the sizing and types of project, and identification of the number of lanes to be HOV and/or mixed flow. Finding: Prior to programming the project into the Biennial Element of the RTIP, SCAG will need evidence that the project satisfies each of the requirements discussed above. Specifically, commitment to construct an HOV lane on the facility within the 20-year horizon of the RMP must be demonstrated. Other Issues 3-3-8 Auxilary lanes are identifed in a number of locations for the project. In order to avoid further conformity review, the final document should clearly state that 3-3-9 these auxilary lanes do not continue through ramps and interchanges. The project description identifies a four -lane segment in the north part of the corridor. In order to avoid further conformity review, the final document 3-3-10 should clearly state that thise design is intended/necessary to transition into the existing project on the existing portions of State Route 73. Two other Orange County AB 680 projects -- Route 57 and Route 91-- should be analyzed in conjunction with this project. Technical Report No. 8 identifies a number of issues that need to be pursued with TCA, including the HOV pricing and park -and -ride issues. TCA staff should meet with SCAG staff to disucss theses issues so that appropriate additions and/or changes to the EIR/EIS can be developed. 0 L] • CITY OF LAGUNA NIGUEL City Council Patricia C. Bates Paul M. Christiansen James F. Krembas. Ed. D. Larry A. Porter Thomas W. Wilson 0 November 26, 1990 Transportation Corridor Agency 345 Clinton Street Costa Mesa, California 92626 Attention: Steve Letterly, Manager, Environmental Impact Re: San Joaquin Hills Transportation Corridor, Draft Environmental Impact Report/Environmental Impact Statement (TCA - DEIR/EIS 1); Comments of the City of Laguna Niguel Dear Mr. Letterly: I. INTRODUCTION The City of Laguna Niguel has reviewed the San Joaquin Hills Transportation Corridor ("SJHTC" or "Corridor") Draft Environmental Impact Report/Environmental Impact Statement ("DEIR") and the purpose of this letter is to set forth the City of Laguna Niguel's comments concerning the DEIR. The substance of the comments included in this letter has been reviewed and approved by the City Council of the City of Laguna Niguel at its November 20, 1990, regular meeting. The City of Laguna Niguel appreciates the opportunity to comment on the DEIR. Although the comments included in this letter are highly critical of the DEIR, it should be understood that these comments are made in the context that the City of Laguna Niguel supports the construction of the Corridor and appreciates that it is an important part of the regional transportation system, but is extremely concerned that the construction of the Corridor with Alignment #2 would result in serious adverse impacts to the City of Laguna Niguel. 3-4-1 27821 LA PAZ ROAD, LAGUNA NIGUEL, CA 92656 (714) 643-1610 FAX: (714) 643-9071 Transportation Corridor Agency November 26, 1990 Page 2 II. MAJOR DEFICIENCIES IN THE DEIR A. Summary of Major Deficiencies The DEIR fails to comply with the requirement of the California Environmental Quality Act ("CEQA") and the State CEQA Guidelines in that it has the following major deficiencies which will require substantial additional information and analysis to be included in the DEIR before it can be considered by the Board of Directors of the San Joaquin Hills Transportation Corridor Agency ("SJHTCA" or "Agency"), and a decision is made regarding the approval of the Corridor, and, most significantly to the City of Laguna Niguel, the selection of the appropriate alignment for the confluence of the Corridor with Interstate Route 5 (11I-511). 1. The DEIR fails to identify and analyze the impacts that will result from the construction of Alignment #2, including the taking and removal in the area of the confluence of the businesses identified in the DEIR, including Costco, Allen Oldsmobile/Cadillac, Inc., and Sepulveda Building Materials. The taking of these businesses will result in the loss of sales and property tax revenue to the City of Laguna Niguel of $989,000 annually, which annual revenue has a present value that is in excess of $32 million and accounts for approximately 21% of the City's discretionary general fund budget. The impacts that this loss of revenue will have on the City's ability to provide municipal services and facilities in the future are required to be identified and analyzed in the DEIR, along with the impacts of measures the City would be required to take to offset the loss of revenue. Further, 1 The SJHTCA will provide benefits to the cities located in the area of the confluence between the Corridor and I-5, including Mission Viejo, San Juan Capistrano, and Laguna Niguel. However, as can be seen from Appendix I, Housing and Business Displacement, including Table I, which summarizes housing and business displacement impacts and Figure 1, which illustrates the location of impacts, under Alignment #2 the vast majority of businesses taken and residences affected are located in the City of Laguna Niguel, and the only major sales tax revenue -generating businesses taken are located in the City of Laguna Niguel. 3-4-2 3-4-3 • 0 0 0 0 Transportation Corridor Agency November 26, 1990 Page 3 the DEIR fails to identify the impacts that will result from the construction of Alignment #2 on the businesses located in the confluence area, including those that will be taken, and also those that will be left in place, but adversely affected by construction activities during the construction of the Corridor and by the permanent loss of the present access to those businesses. Further, the DEIR fails to identify and analyze any mitigation measures for the impacts that will result to the City from the construction of Alignment #2, and it fails to include any meaningful mitigation measures for the impacts on the businesses in the confluence area. 2. The DEIR fails to identify and analyze alternatives to the project. The focus of the DEIR, including the identification and analysis of impacts, is entirely on the construction of Alignment #2 as the method of connecting the SJHTC to I-5. (DEIR, page 2-23.) The impacts from the construction of Alignment #1 in the confluence area should have been identified and analyzed. This is necessary in order to make a meaningful comparison between Alignment #2 and Alignment #1. The DEIR is required to identify and analyze the impacts from the construction of Alignment #2 on the City of Laguna Niguel and the businesses in the confluence area. These impacts and the other impacts caused by Alignment #2 must be compared and contrasted in the DEIR with the impacts from Alignment #1. Without such a comparison, the Board of Directors of the SJHTCA cannot, as required by CEQA, make a meaningful and informed decision on the approval of the project or the selection of an alignment. 3. The DEIR indicates that there are a number of road facilities for the SJHTC such as HOV lanes, access ramps, the Paseo de Colinas/Avery Parkway flyover, and the Via Escolar underpass for which CEQA documentation will be prepared in the future. These facilities are an integral part of the project and the environmental impacts and the mitigation measures for the impacts are required to be included in the DEIR. Identifying these facilities and then indicating -.that the environmental impacts will be analyzed subsequently is a splitting of the whole SJHTC project into parts which is impermissible under CEQA. 13-4-3 3-4-4 3-4-5 Transportation Corridor Agency November 26, 1990 Page 4 4. The traffic projections for Crown Valley Parkway, La Paz Road, and other streets, both with and without the Corridor, contain numerous significant and obvious errors. The existence of these errors raise serious doubts about the credibility of the conclusions made regarding the project as to need for and capacity of related facilities such as on -ramps and off -ramps. Each of the above items is discussed in more detail later in this letter. 3-d-6 5. In addition to the deficiencies outlined above, there are numerous instances in the DEIR where there is a failure to adequately identify and analyze the impacts of various aspects of the project, and where the analysis is based on 3-4-7 omitted or erroneous information. These deficiencies are discussed below in Section III of this letter. B. Physical and Economic Impacts of Alignment #2 1. Failure to Identify and Analyze Impacts It is clear that the construction of the Corridor with either Alignment #1, or especially Alignment #2, will have an obvious physical impact on the environment, namely, the taking and removal of businesses in the confluence area, impacts of construction on the remaining businesses, and impacts resulting from the elimination of access to the remaining businesses on Camino Capistrano. These impacts of the project create secondary economic, social and physical impacts on both the City of Laguna Niguel and the confluence area businesses. For the City, the impacts include the loss of sales and property tax revenue, and the impact that this revenue loss will have on the City's ability to provide services and facilities to its 2 Alignment #2 would result in an encroachment on 28 ^ commercial/light industrial properties with the encroachment resulting in the full taking of 16 commercial structures, the partial taking of land and parking from 8 properties, and temporary construction takes or easements for construction of retaining walls and sound walls from the remaining properties. (DEIR, page 4-101, and 9-1, and Table 1 of Appendix I, including Figure 1, which illustrates the location of the housing and businesses that would be impacted by Alignment #2.) 3-4-8 0 • Transportation Corridor Agency November 26, 1990 Page 5 residents. To the businesses, there is the loss of revenue and the impact that will have on the businesses' ability to continue operations and maintain their facilities. 3-4-8 It appears from the DEIR that the SJHTCA is under the misapprehension that it is not required to identify or analyze the physical, economic, and social impacts that will result to the City from the loss of revenue, or identify and analyze appropriate mitigation measures for those impacts. However, it is clear under CEQA and the Guidelines that the SJHTCA is required to identify and analyze these impacts and mitigation measures. There must be a physical change resulting from the project directly or indirectly before CEQA will apply. However, CEQA does not focus exclusively on physical changes, and it is not exclusively physical in its concern. Thus, if an economic impact will cause physical change, or a physical 3-4-9 change will cause economic impact, then the impact should be considered. In addition, economic or social effects of a project may be used to determine the significance of physical changes caused by the project. For example, if the construction of a new freeway or rail line divides an existing community, the construction would be the physical change, but the social effect would be the basis for determining that the effect would be significant. State CEQA Guidelines, Section 15131(b); Citizens Association for Sensible Development of Bishop Area v County of Inyo (4th Dist. 1985) 172 Cal.App.3d 151, 169-171 [217 Cal.Rptr. 893, 904-905]; Citizens for Quality Growth v City of Mount Shasta (3d Dist. 1988) 198 Cal.App.3d 433, 445-446 (243 Cal.Rptr. 727, 734]. The physical removal of businesses from the City, including especially, Costco, Allen Oldsmobile/Cadillac, Inc., and Sepulveda Building Materials, by the construction of Alignment #2 will result in the loss to the City of more than $989,000 in annual revenue, which annual revenue has a present value of in excess of $32 million. In contrast, 3-4-10 the construction of Alignment #_1 will cause the City to lose approximatefiy-$25,520 in annual revenue, which has a 3 present value of lost revenue estimated at about $750,675. 3 The City of Laguna Niguel has commissioned Alfred Gobar Transportation Corridor Agency November 26, 1990 Page 6 First, the economic impacts associated with Alignment #2 will cripple the City of Laguna Niguel's ability to provide and maintain necessary services, facilities and infrastructure to its residents and businesses. When related to the City's Fiscal Year 1990-91 Budget, a $989,000 annual loss of revenue equals 16% of the City's unrestricted General Fund revenues and 21% of the City's discretionary General Fund expenditures. After excluding general government functions and fee -supported services, cuts would have to occur in the following areas: law enforcement, emergency preparedness, advanced planning, zoning and code enforcement, civil and traffic engineering, and street maintenance. Such cuts substantially impair the City of Laguna Niguel's ability to: provide basic public safety services to its residents; properly plan for orderly physical development, traffic control and environmental protection within the City; enforce environmental laws; and improve and maintain the local street system that will support the Corridor. To offset revenue losses, existing open space and recreational resources may have to be rezoned and altered to accommodate revenue generating commercial development, there may have to be an intensification of sales tax generating commercial development for areas that are already planned for or devoted to commercial uses, and there may have to be a conversion of areas planned for residential use to revenue generating commercial uses. All of these changes in land use would result in numerous physical and economic impacts. 3-4-11 3-4-12 C 0 Second, the DEIR fails to address the physical and economic impacts to long established Laguna Miguel businesses in the Corridor/I-5 confluence area. There are over 290 3-4-13 (footnote continued from previous page) Associates, Inc., to prepare an analysis (the "Lobar Report") of the loss of revenue that will result from the construction of either Alignment #1 or Alignment #2. The information on loss of revenue included in this letter is taken from the Gobar Report. A summary of the comparison of the businesses taken and loss of sales tax revenue for both Alignment #1 and Alignment #2 is contained in Attachment "A" to this letter. This information is also taken from the Gobar Report. A copy of the final Gobar Report is enclosed as Attachment "B". • Transportation Corridor Agency November 26, 1990 Page 7 businesses in the confluence area. Collectively, these businesses account for over $146 million in taxable annual retail sales and more than $98 million in assessed valuation. The DEIR fails to address or quantify. the 3-4-13 economic disruption these businesses, their employees and their customers will suffer during the lengthy Corridor construction period. 4 Third, the DEIR fails to adequately address the unique and permanent hardship imposed on Camino Capistrano businesses under Alignment #2. There are over 110 businesses on Camino Capistrano in Laguna Niguel. Currently, the only access to these businesses from within Laguna Niguel is via the Paseo de Colinas hook. Under Alignment #2, this access is eliminated and replaced with a circuitous route through the Cities of Mission Viejo and San Juan Capistrano. The resultant adverse impacts on emergency vehicle access and response times, customer access, the economic viability of the businesses without access, and ability of the businesses to continue operations and maintenance of facilities have not been identified or analyzed in the DEIR. 4 The City Council of the City of Laguna Niguel has been advised by a number of the owners of businesses located in the confluence area that they not been, until just recently, provided with notice regarding the DEIR or its focus on the use of Alignment #2. It was indicated that they were aware of the Corridor and Alignment #1, but were unaware of the prospective change to Alignment #2 and the impact that it would have on their businesses. Because of the direct impact that the Corridor and the selection of Alignment #2 would have on the businesses in the confluence area, the owners are entitled under CEQA to direct and personal notice of the DEIR and its contents. The owners in the confluence area should be provided with specific written notice of the DEIR, the consideration of Alignment #2, and the potential impacts of that alignment on their business, and given the full 45 days in which to review and comment on the DEIR. 5 The elimination of customer access to businesses located on Camino Capistrano that are northerly of Avery Parkway raises serious questions as to the economic viability of 3-4-14 Transportation Corridor Agency November 26, 1990 Page 8 On page 4-105, the DEIR states that: "The overall impacts to the surrounding communities are considered minimal when compared to the overall benefit the facility will provide to these communities." The impacts on the City of Laguna Niguel and the businesses in the confluence area are clearly not minimal. A proper identification and analysis of impacts will disclose that there is absolutely no support for the allegation that the impacts are "minimal.116 The DEIR is required to fully identify and analyze the impacts that will result to the City and businesses from the construction of the Corridor, and especially, the construction of Alignment #2. Above, we have indicated the types of impacts that will occur. The DEIR fails to identify any impacts. What is required is a full analysis of the loss of revenue to the City, the prospective magnitude of that loss, the types of services and facilities that will have to be eliminated or reduced because of the loss, the impacts that will result from the elimination and reduction of municipal services, and especially the impacts that will result from the City having to find alternate sources of revenue, including the (footnote continued from previous page) this area, and the potential that existing businesses will move out leaving vacant buildings and/or not generate sufficient income to continue to maintain their facilities, which will result in the physical deterioration of this area. This potential impact needs to be more fully identified and analyzed with potential mitigation measures developed. 6 The impacts of the Corridor Alignment #2 may be minimal on the areas located in the City of Mission Viejo, the City of San Juan Capistrano, and the unincorporated areas that are located in the vicinity of the Corridor/I-5 confluence. However, as can be seen from Table I and Figure 1, of Appendix I, on housing and business displacements, there are a substantial number of businesses located in the City of Laguna Niguel that will be taken by the construction of Alignment #2, including major sales tax -generating businesses, especially when compared to the businesses taken from the areas located outside of the City of Laguna Niguel. 3-4-15 0 ,s 0 Transportation Corridor Agency November 26, 1990 Page 9 use of open space and recreational areas for commercial developments, the potential intensification of existing commercial zoned property, and the potential change in use 3-4-15 from residential to commercial of other properties. 2. Failure to Identify Mitigation Measures CEQA and the State Guidelines require that an EIR identify and evaluate mitigation measures. Guideline Sections 15002(a)(3), 15021(a)(2), and 15126(c). It is required that for an EIR to be legally adequate it must identify mitigation measures which are capable of avoiding the impacts altogether by not taking a certain action or parts of an action, minimizing impacts by limiting the degree or magnitude of the action and its implementation, rectifying the impact by repairing, rehabilitating, or restoring any impacted environment, reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action, or compensating for the impact by replacing or providing substitute resources or environment. Guidelines Section 15370. Public agencies cannot defer the obligation to formulate and adopt mitigation measures until a specific development project is proposed. Citizens for Quality Growth v. City of Mount Shasta, supra, at 442. For each significant effect, the EIR must identify specific mitigation measures, or if several mitigation measures are available, each should be discussed separately, and'the reasons for choosing one over the other should be stated. Guidelines Section 15126(c). The DEIR'contains absolutely no mitigation measures for any of the impacts that will result to the City from the taking of businesses in the confluence area. CEQA requires that appropriate mitigation measures be identified and analyzed in the DEIR for each of these impacts, and prohibits the deferral of the identification of such mitigation measures as, it appears that, the SJHTCA plans to do. CEQA specifically provides that a public agency is forbidden from approving a project which has significant adverse impacts when feasible mitigation measures and feasible alternatives can,substantially-lessen such impacts. Public Resources Code Section 21002; Citizens for Quality Growth v. City of Mount Shasta, supra, at 440-2. 3-4-16 Transportation Corridor Agency November 26, 1990 Page 10 The City of Laguna Niguel proposes, at a minimum, the following mitigation measures be included in the DEIR, and made a part of the project that is ultimately approved by the SJHTCA, especially if Alignment #2 is selected. 3-4-17 1. Current access to Camino Capistrano, through the City of Laguna Niguel, be preserved and/or improved. 2. Prior to the beginning of Corridor construction, the SJHTCA shall relocate all displaced Laguna Niguel businesses to other comparable locations within the City of Laguna Niguel. Relocation 3-4-18 shall be carried out in a manner to ensure continuous operation of displaced businesses. 3. The SJHTCA shall seek an amendment to its State authorizing legislation to permit toll and other TCA revenues to be used to mitigate adverse 3-4-19 economic impact to the City of Laguna Niguel. 4. The SJHTCA shall establish an economic mitigation fund for the benefit of the City of Laguna Niguel to be financed by other member cities and the 3-4-20 County of Orange. The project that is considered in the DEIR is the Corridor with Alignment #2. (See DEIR, page 2-23.) To the City of Laguna Niguel and the businesses in the confluence area, especially those such as rostco and Allen Oldsmobile/Cadillac, Inc., that would be taken by the construction of Alignment #2, the most obvious and significant mitigation measure for the Corridor construction is the use of Alignment #1 instead of Alignment #2. The Corridor, as initially planned, was with Alignment #1, and most of the required right-of-way has already been acquired. Thus, selection of Alignment #1 involves substantially less taking of property and damages and 7displacement to existing businesses than does Alignment #2. 3-4-21 PJ From information provided by the SJHTCA, the construction of Alignment #2 will cost $43 million more than the construction of Alignment #1. We seriously . s- 4. Transportation Corridor Agency November 26, 1990 Page 11 Because of the substantial adverse impacts of Alignment #2, Alignment #1 should be considered as a mitigation measure for those impacts and fully analyzed as a mitigation measure. Feasible mitigation measures for the impacts of Alignment #2 are required to be identified and made part of the approved project. Simply based on a comparison of the impacts of Alignment #2, and Alignment #1, that can be made from the information that is available, namely, number of properties required to be taken for the construction of Alignment #2 versus what is required for Alignment #1 (see DEIR, page.9-1), Alignment #1, considered as a mitigation measure, should be considered the environmentally superior alternative. C. Alignment #1 as a Project Alternative 1. Failure to Make Alignment #1 a Meaningful Alternative CEQA requires that reasonable alternatives to the project be identified and analyzed. Guideline Section 15126(d). The requirement to include project alternatives within an EIR is crucial to CEQA's requirement that avoidable significant environmental damage be substantially lessened or avoided where feasible. Public Resources Code Section 21002, State Guidelines Sections 15002(a)(3), 15021(a)(2), and 15126(d). Further, a EIR must produce information sufficient to permit a reasonable choice of alternatives so far as environmental aspects are concerned. San Bernardino Valley Audubon Society Inc v County of San Bernardino (1984) 155 Cal.App.3d 738, 750-751 (202 Cal.Rptr. 423, 428]. (footnote continued from previous page) question whether the $43 million reflects all of the additional construction costs, and especially, the right- of-way acquisition costs, including such things as relocation of, businesses and loss of business goodwill caused by taking and relocation of businesses. Further, we question whether this number includes the relocation of approximately 7,000 feet of I-5,near Avery Parkway approximately 10'O feet westward, the regrading and lowering of I-5 at Avery Parkway, the reconstruction of Avery Parkway at I-5 to link up with Paseo de Colinas, and required construction of 3,500 feet of 72" storm drain. 3-4-22 .* Transportation Corridor Agency November 26, 1990 Page 12 The DEIR appears to identify both the Demand Management Alternative with Alignment #2 and the Conventional Alternative with Alignment #1 as project alternatives (DEIR, page 2-23 to 2-25), but it fails to comply with the mandates of CEQA by failing to provide a detailed identification of the environmental impacts that would be caused by Alignment #1, and an analysis of those impacts. Most significantly, it fails to contain any sort of comparison of the impacts of Alignment #1 with the impacts of Alignment #2. 3-4-23 The SJHTCA Board is provided with information regarding Alignment #2 in the DEIR. As indicated above, this information is incomplete because it fails to contain an identification of the physical and economic impacts associated with the construction of Alignment #2, including 3-4-24 especially those impacts on the City of Laguna Niguel. The DEIR fails to contain an adequate analysis of the impacts of Alignment #1 gr a comparison of those impacts to those of Alignment #2. Without this comparative environmental 8 As discussed in footnote 7 above, the SJHTCA estimates fL that it will cost approximately $43 million more to construct Alignment #2 than Alignment #1, and we question whether this number includes all of the additional construction costs that will be incurred. The existence of the adverse impacts to the City of Laguna Niguel from the taking of sales tax revenue -generating businesses by Alignment #2, and the $43 million cost differential indicates the need to meaningfully compare as project alternatives Alignment #2 and Alignment #1. Specifically, there should be some sort of a chart or a table that lists and compares all of the impacts of both alignments and the benefits and detriments of both alignments. Further, if Alignment #1 was developed as a Demand Management Alternative, it might be less costly than Alignment #1 as a conventional alternative, and the cost deferential between Alignment #2 and Alignment #1 would be even greater than $43 million. 9 The DEIR tends to indicate that Alignment #2 is the preferred alternative. CEQA Guidelines Section 15126(d)(1) specifically requires in this situation that the DEIR contain an analysis of why other alternatives are rejected • Transportation Corridor Agency November 26, 1990 Page 13 information, the SJHTCA Board cannot make the informed decision required by CEQA for selection of project alternatives. Simply considering the known impacts of Alignment #1 and Alignment #2 on the City of Laguna Niguel and the businesses in the confluence area, Alignment #1 is 3-4-24 the environmentally superior alternative. Alignment #1 would significantly mitigate the disastrous fiscal impacts to the City of Laguna Niguel. In addition, it would not exacerbate the inadequate access to the Camino Capistrano business district as does Alignment #2. 2. Alignment #1 with Improved Access to Camino Capistrano Should be Considered as a Project Alternative The alternative of Alignment #1 with improved access to all of Laguna Niguel (additional on and off ramps), and improved access to Camino Capistrano, should be explored i the DEIR as an additional alternative, and a Demand Management version of Alignment #1 should be developed and analyzed in the DEIR. The cost comparisons and relative merits of the two alternative alignments are skewed in favor of Alignment #2 because Alignment #1 has not been developed as a Demand Management alternative or been 3-4-25 refined to include an improvement to the Paseo de Colinas - Camino Capistrano -Avery Parkway connection. It is the City's opinion that Alignment #1, developed as a Demand Management alternative with additional access ramps and enhanced access to Camino Capistrano, would prove to be an environmentally superior alternative to Alignment #2. Under CEQA and the CEQA Guidelines, the purpose of i "project alternatives" section of an EIR is to ideni alternatives that reasonably meet the project object and minimize adverse environmental impacts. Clear13 Alignment #1 with refinements offers such an alterna It is not sufficient to offer Alignment #1 as an alternative when the analysis of it is contrived to desirable in terms of access, roadway cross section, HOV capabilities than Alignment #2, and then reject (footnote in favor the need Alignment continued from previous page) :he Ify .fives t ive . 3-4-26 be less and it of the preferred alternative. This illustrates for there to be a comparison of impacts from #2 with Alignment #1. Transportation Corridor Agency November 26, 1990 Page 14 based on those shortcomings as not being a feasible alternative. Reportedly, the SJHTCA was requested by the Cities of San Juan Capistrano and Mission Viejo to abandon the serious pursuit of Alignment #1 in favor of Alignment #2, because of perceived adverse impacts in those communities. Because of the devastating fiscal consequences to the City of Laguna Niguel, Alignment #1 should be revisited, further developed, and evaluated against Alignment #2 with the impacts on all three cities fully identified. This complete evaluation of a refined Alignment #1 would then satisfy the requirements of CEQA relative to alternatives. At this time, adequate information is not included in the DEIR to enable the SJHTCA to make the necessary CEQA findings required to reject Alignment #1, as either a project alternative or a mitigation measure, and approve Alignment #2. D. The DEIR Does Not Analyze the Environmental Impacts of the Entire Project All project impacts have not been identified and adequately mitigated. The DEIR, by failing to analyze all of the impacts of the various components of the project, has violated the mandate of CEQA that the project, for purposes of a DEIR, be considered as a "whole of the action" and cannot be split or bifurcated into parts. CEQA and the CEQA Guidelines require analysis of the entire project (Guideline Section 15378(a)), and do not allow critical and. essential components to be excluded from the environmental analysis of the project, from the mitigation program for the project, or from the requirements that findings be made relative to selection and rejection of project alternatives. Several essential components of the project have not been adequately addressed, as follows: 1. HOV Lanes and access ramps - The DEIR relies on the use of HOV lanes to meet future traffic demand and Air Quality Goals, yet denies that they are part of the "project". 13-4-26 3-4-27 3-4-28 3-4-29 3-4-30 3-4-31 • Transportation Corridor Agency November 26, 1990 Page 15 2. Paseo de Colinas/Avery Flyover - This critical part of the local circulation system in the 3-4-32 confluence area is not considered part of the "project". 3. Via Escolar underpass - Under Alignment #2, the connection of Paseo de Colinas and Avery Parkway to Camino Capistrano is completely eliminated. The only possible access to Camino Capistrano in 3-4-33 the area is the Via Escolar underpass which is not considered part of the "project". 4. Changes to I-5 in confluence Area - 7,000 feet of I-5 are realigned to the west (toward Laguna Niguel) and include drastic changes in elevation., This realignment effects homes and businesses in Laguna Niguel, yet it is not considered part of the "project". 3-4-34 The roadway improvements are part of the "project", and their impacts are required to be thoroughly analyzed in the DEIR and mitigation measures are required to be identified. 3-4-35 E. Errors in Traffic Information Various errors and omissions in the traffic information for the highways impacted by the Corridor are discussed in the letter dated November 26, 1990, from Austin -Foust Associates, Inc., Traffic Engineering and Transportation Planning. The information contained in this letter indicates that the traffic errors and omissions 3-4-36 raise substantial questions as to the credibility of the information contained in the DEIR and the conclusions drawn from it as to the need for various facilities. A copy of the letter is attached as Attachment licit, and is included by this reference. F. Recirculation of the DEIR is Required As discussed both above and below, the DEIR contains material deficiencies, including the absolute failure to identify the physical, economic, and social impacts that 3-4-37 would result from the construction of Alignment #2 on the City of Laguna Niguel and the businesses in the Av Transportation Corridor Agency November 26, 1990 Page 16 Corridor/I-5 confluence area. Further, the DEIR fails to identify and consider any mitigation measures for these impacts. The DEIR fails to adequately analyze the impacts of Alignment #1 and fails to compare and contrast those impacts with the impacts of Alignment #2. The information and analysis on these points is required to be developed and added into the DEIR. CEQA and the State Guidelines required that when significant new information is developed and added to an DEIR, it is required that that document be recirculated for comment. Public Resources Code Section 21092.1. The City of Laguna Niguel appreciates that the SJHTCA is having a study performed by P & D Technologies that will hopefully, examine the issue of appropriate mitigation measures for impacts that would result from a selection of Alignment #2. This study apparently will not be completed until substantially after the close of the period for providing comments on the DEIR. The type of information that will be in that study along with, and more significantly, the information identifying the impacts of Alignment #2 is required to be included in the DEIR. This requirement is important because it provides a sufficient opportunity for the public, including in this case both the City of Laguna Niguel and the owners of businesses in the confluence area, to (1) review and analyze the DEIR as to (a) the physical and economic impacts of the construction of Alignment #2, including from the City's perspective, the impacts from the loss of sales tax, and (b) as to the proposed mitigation measures, and to (2) be able to have sufficient time to make comments on the identified impacts and analyses and the proposed mitigation measures. The physical, economic, and social impacts of Alignment #2 on the confluence area and proposed mitigation measures must be included in the DEIR and this information is so significant that the DEIR must be recirculated for comment, and any decision on the certification of the EIR, the selection of an alignment, and the ultimate approval of the project cannot be made until this information is developed and included in the DEIR, and done so in such a manner as to allow sufficient time to comment on the information. 3-4-37 3-4-38 3-4-39 9 0 0 Transportation Corridor Agency November 26, 1990 Page 17 III. ADDITIONAL COMMENTS ON THE DEIR ALTERNATIVES 1. Non -automobile Alternatives (Page S-1) The alternatives to the proposed project are 3-4-40 limited to automobile conveyance alternatives. Non -automobile alternatives should be presented and discussed. 3-4-41 3-4-42 ALIGNMENT ALTERNATIVES 2. Inadequate Analysis of Access Options (Page 2-23) Analysis of the I-5 connection consists of a simple statement: "In general under Alignment #1 access to the Corridor is indirect... [Traffic] would use an interchange at Greenfield Drive. This very sensitive issue deserves a complete section devoted to this question, including consideration of traffic costs, and other associated impacts, rather than this overly brief statement. 3. Demand Management with Alignment #1 (Page 2-23) Except for a statement on page 2-23 "Impacts of the Demand Management Alternative with Alignment #1, I-5 connection would be the same as described for the Conventional Alternative in the portion of the Corridor associated with I-5 connection," the document does not reference any review of Alignment #1 with Demand Management Cross - sections. ACCESS TO CAMINO CAPISTRANO AREA 4. Public Services Access (Page 2-25) As a result of the construction of Demand 3-4-43 Management Alternative #2, the existing access between Camino Capistrano and Laguna Niguel, via Paseo de Colinas (Avery) will be eliminated and Transportation Corridor Agency November 26, 1990 Page 18 3-4-43 5. 3-4-44 6. 3-4-45 7. 3-4-46 8. 3-4-47 replaced by a new access (Via Escolar) which would require travel through two other jurisdictions (Mission Viejo and San Juan Capistrano) in order to provide necessary City services such as police protection as well as by business patrons. The impact from the removal of reasonable access should be considered a significant impact and be included in the document's cumulative impact analysis. The DEIR refers to impact to "Public Services" as not significant. However, it is the City's opinion that limited access can create a significant impact in times of an emergency situation or natural disaster. Impacts to Emer ency Response Times The DEIR does not evaluate how emergency vehicle response times for such services as paramedics, fire, and police will be impacted as a result of limited access. A table depicting the change in emergency response times should be provided in the document. No Identification of Miti ation for Impacts to Emergency Res onse Times . The DEIR does not provide mitigation measures to offset the impacts to paramedics, fire, and Police emergency response times. Lack of Exhibit It appears that the DEIR does not contain any map showing access from Via Escolar to Camino Capistrano. Distance Between Access Points The document should include information/mileage showing the distance between access points in the Camino Capistrano area. In order to alleviate 0 • • • Transportation Corridor Agency November 26, 1990 Page 19 the hardship for businesses, 3-4-47 residents, the SJHTCA should access ramp to serve Camino TRAFFIC 0 3-4-48 10. 3-4-49 11. 3-4-50 patrons, and design an additional Capistrano. Paseo de Colinas/Avery Interchange The DEIR does not include any assessment of impacts on the expanded use of Paseo de Colinas as access to both I-5 and SR-73 under Alternative #2. The DEIR and Technical Memorandum 2-60 do not include any volume information/interchange analysis or arterial impact analysis of Paseo de Colinas and its expanded use as a direct access to both I-5 and SR-73. TM 2-60 analysis addresses Greenfield as the Corridor's most southerly interchange although it appears to assume the construction of a Paseo de Colinas/Avery flyover as part of implementation of Demand Management #2. Greenfield Interchange (Page 2-5/Table 2.2A It is the City's conclusion that the construction of the Greenfield interchange as a partial diamond (northbound and southbound off) may not adequately meet future volumes of traffic. Construction of a full interchange at Greenfield would seem to relieve the anticipated heavy traffic on CVP between I-5 and the SJHTC. Discrepancies in 2010 Traffic Volume Pro-iections On Page 5-12, the DEIR refers to the South End Traffic Study as describing traffic impact to Crown Valley Parkway and the "South -End" area. The traffic volume projections forecasted in this study (Technical Studies volume II) differ substantially from the projections included in TM-2-6'7A. While the SJHTC South'End Traffic Study projects 2010 daily volume on Crown Valley Transportation Corridor Agency November 26, 1990 Page 20 Parkway to be 48,000 ADT, the DEIR Figure 1.3.1 (page 1-4) forecasts for this location 24,000 ADT, or 50% of the South End Study. 3-4-50 The discrepancies in the various traffic projections contained in the Technical Studies Volume II, and how those discrepancies may have affected the cumulative impact analysis of the DEIR must be addressed. 12. Under -Estimation of Future Traffic Volumes (Table 1-4) The City has concerns that the future traffic forecasts both with and without the Corridor may 3-4-51 be under -estimated. As a result, this may lead to the SJHTCA designing on and off ramps to meet lower traffic volumes. For example, it is the City's opinion that the Post-2010 travel forecasts indicated for Crown Valley Parkway and La Paz Road are questionable. Crown Valley Parkway is forecast to decrease to 50 percent of its current volume without the SJHTC and 60 percent with the Corridor despite having an interchange at Greenfield. Likewise, with the 3-4-52 Corridor, the volume on La Paz Road will drop from a current 20,000 ADT to 8,000 ADT, again despite its having an interchange. These future volume forecasts seem to cast considerable doubt on the reliability of the basic design volumes upon which the design of the Corridor is based. In addition, if such questionable volumes are 3-4-53 used for the interchange/ramp configuration design or sizing the number of lanes then seriously under -designed facilities could result. A great deal of the technical analysis is based on these volumes. The City's intention is to 3-4-54 prevent any design of ramps which would not adequately meet traffic demand. L Transportation Corridor Agency November 26, 1990 Page 21 3-4-55. TOLL PLAZAS 13. Toll Plaza Locations After several conversations with SJHTCA staff, the City of Laguna Niguel does not fully understand the toll booth system. The City needs to know if there are opportunities for free entry and exit from the Corridor which may potentially affect traffic on local streets. The result of having the Greenfield interchange located south of all toll plazas may make it possible for traffic to exit at Greenfield without paying a toll. This could cause traffic to divert and use City streets to "double back" to their original destination, thereby exceeding traffic forecast. +� HOV LANES 3-4-56 3-4-57 14. Lack of HOV Lane Analvsis (Page 2-20) The DEIR states that the I-5 Direct Connectors (HOV) would require separate environmental documentation. If there are impacts resulting from construction activities for HOV lanes, then the related environmental analysis should be included in the DEIR. 15. Location and Desi n of HOV Access Ramps (Page 2-23) The DEIR does not consider the potential changes to the local circulation system with and without an "optimistic" use of HOV lanes as well as potential changes due to the locations of HOV access points as a result of implementing the Demand'Management Alternative #2. For example, on page 2-23 the document refers to a "slip ramp" between Crown Valley Parkway and Greenfield Drive but does not provide specific information regarding this HOV access. Evaluation of this issue is necessary so that traffic considerations may be included prior to the final construction Transportation Corridor Agency November 26, 1990 Page 22 of the Corridor. This will ensure that issues 3-4-57 that effect ramp design are discussed prior to adoption of a final design. 16. Construction Impacts (Page 3-21) The DEIR does not evaluate the HOV construction impacts to the operations of the existing Corridor during the construction of HOV lanes and 3-4-58 HOV access points. The DEIR states that unless HOV lanes are constructed by year 2000 (assuming Corridor completion by year 1995), the Corridor (Demand Management Alternative *2) will be congested and may not meet its objectives as outlined on page S-4. 3-4-59 3-4-60 ECONOMIC IMPACTS 17. Housing and Business Relocation (Page 3 54) CEQA defines "significant effects" as those which "disrupt or divide the physical arrangement of an established community" (CEQA Appendix G) and states that "the social and economic effects of a project may be used to determine the significance of physical changes caused by a project (CEQA 15131.b)". The DEIR does not address economic impacts in its "Housing and Business Relocation" Section and includes only a statement that the economic impact to the City of Laguna Niguel is currently subject to additional studies. 18. Public Services (Page 3-56) The DEIR does not evaluate the potential reduction in the City's revenues and how that bears upon its ability to provide services as a result of the loss of revenue from the displacement of businesses. 0 0, • • • Transportation Corridor Agency November 26, 1990 Page 23 3-4-61 119. Proposed Maintenance Facility (Page 4-29) The Corridor's Maintenance Facility would require about 3 acres. As further noted on page 4-29, the facility would occupy an existing profitable building materials site (thus further reducing revenues to the City). If not displaced, the building materials site could probably continue to function beneath the Demand Management Alternative #2 bridge. The SJHTCA should research the available opportunities for relocating the Maintenance Facility in order to minimize any impacts to Laguna Niguel's loss of revenue generators. By relocating the Facility, the SJHTTCA will allow an already existing business site to remain. 20. Business Relocation within Laguna Niguel (Page 4-105) 3-4-62 The document does not provide any information about relocation opportunities within Laguna Niguel, and fails to present a program for acquiring desirable sites for relocation. 3-4-63 21. Business Impacts In addition to the inadequate analysis of the significant impacts from the "taking of", "partial taking of," and "during construction" impacts to businesses in Laguna Niguel, the DEIR fails to address the significant "social and economic effects" resulting from Demand Management Alternative #2, which, by dividing the physical arrangement of an established community, deprives a (remaining) commercial district of reasonable access. The document should acknowledge the social and economic impacts to the remaining Camino Capistrano commercial establishments and to'the City of Laguna Niguel. Transportation Corridor Agency November 26, 1990 Page 24 22. Employment Impacts The document does not address and should address the number of long term and short term jobs to be provided/lost as a result of the project. It may not be possible for employees of dislocated 3-4-64 businesses to commute outside of the area. It should be researched how much of the affected employment population can be maintained and whether the change in numbers will be significant. It should also be determined how much employment will be generated as a result of 3-4-65 the Corridor's construction. 3-4-66 3-4-67 3-4-68 PW 23. Short Term Construction Impacts There are 291 businesses in the affected confluence area. The DEIR does not identify the short term construction impacts to remaining business owners in the Corridor's vicinity and how that bears upon access to business establishments during the Corridor's construction. 24. Access to Business The SJHTCA should make every effort to ensure that access to potential relocation sites within the confluence area is maintained. It is the City's goal to prevent creating an area which not only is economically dislocated as a result of the Corridor's construction, but, is also permanently handicapped as a result of having limited access to such areas as the Alex Michaels Property or the remaining businesses along Camino Capistrano. SOCIAL IMPACTS 25. Non -Peak Hour Use The DEIR does not mention that the Corridor will go unused during non -peak hours. Analysis should be provided explaining how commuters opting to • • • • Transportation Corridor Agency November 26, 1990 Page 25 use the I-5 during non -peak hours will affect 3-4-68 projected toll/corridor revenues and the balance of the transportation system. 26. Socioeconomic Impacts Although the goal of the Corridor is to improve the efficiency and services of the network of highways in Southern Orange County, the expense 3-4-69 of the toll corridor may pose a barrier to achieving this objective because those who need to use the route may not afford the toll. The DEIR should provide a demographic profile of potential users. COST AND FUNDING ESTIMATES 27. HOV Lanes (Page S-8) The City finds that in Table A and throughout the document, the data used as the basis for comparison includes a Demand Management Alternative #2 assessment which is based upon an 3-4-70 operational and "optimistic use,, of HOV lanes. The DEIR does not include a complete impact analysis of all components of Demand Management Alternative #2. For example, the DEIR does not present data to show the additional construction cost and financing of HOV lanes in the cost information presented in Table 1A. In order to better explain the impacts related to each of the alternatives, the DEIR should compare conventional to conventional and demand management to demand management alternatives. 3-4-71 Within those comparisons, estimates should be included for all costs including HOV lanes and I-5 improvements. To further equalize the comparisons, Alignment #2 should be designed to include an additional access ramp to the Camino Capistrano area. Transportation Corridor Agency November 26, 1990 Page 26 28. Funding Sources 3-4-72 The DEIR does not address the funding sources for the project and associated road improvements. 3-4-73 LAND USE DATA 29. Overestimation of Dwellincl Units in Laguna Niguel (Appendix E/Pa a 6) The document makes reference to the City of Dana Point's pending projects, while on page 19 of Appendix E the document refers to the City of Laguna Niguel as having 58,917 residential units committed, approved or reasonably anticipated. It should be noted that over 30,000 units identified as the City of Laguna Niguel's projects are not located within the City of Laguna Niguel and that the units within the City's jurisdiction include existing as well as "reasonably anticipated" development. It is the City's concern that the inconsistencies in referenced developments and jurisdictions may 3-4-74 have affected the data used in impact assessments made throughout the DEIR. The document needs to be revised to remove doubts associated with such errors and inconsistencies. 3-4-75 INFRASTRUCTURE/PUBLIC FACILITIES 30. Local Expenditures (Pale 2-55) The costs to localities, such as the City Laguna Niguel, for funding infrastructure improvements resulting from the Corridor be discussed. of need to 31. Oso Creek Trail 3-4-76 The potential trail alignment should be addressed in the DEIR with a provision made for recognition of the trail. 0 • • 0 Transportation Corridor Agency November 26, 1990 Page 27 3-4-77 3-4-78 3-4-79 3-4-801 32. Multi -Modal Station The DEIR does not address the OCTC Commuter Rail Study which identifies two station sites in close proximity to the Corridor. 33. Oso Creek Multi -Use (Page 4-21) Under the Conventional Alternative, about 1700 feet of Oso Creek would be realigned as shown in Figure 4.3.1. The proposed maintenance facility site would include covering a flood facility. The Final EIR should identify additional, practical, multiple uses for altered flood facilities. VISUAL IMPACTS 34. Greenfield Interchange (Pa es 4-120 to 4-130) There appears to be a prospect for creating significant visual impacts in the vicinity of the Greenfield interchange. However, the DEIR does not discuss visual impacts resulting_ from the construction of the partial diamond at Greenfield. The final document should evaluate the resulting visual impacts associated with the construction of a full and partial diamond at this location and make an effort to reduce any visual impact to a level of insignificance. 35. Visual Impacts of Noise Walls The DEIR identifies significant adverse visual impacts at Paseo de Colinas which cannot be mitigated; however, it would seem that several other local areas would be subject to similar impacts from not only the Corridor itself, but also from corridor -associated noise walls. The SJHTCA should make every effort to minimize visual impacts for adjacent residents. The Final EIR should -provide graphics depicting sound wall construction and placement within the City of Laguna Niguel. Transportation Corridor Agency November 26, 1990 Page 28 PROCEDURAL DEFICIENCIES 36. Environmental Checklist (Page 4-15) 3-4-81 37. 3-4-82 38. 3-4-831 39. 3-4-841 40. 3-4-85 It is the City's opinion that as it relates to Laguna Niguel, the Environmental Checklist should be checked as significant for items #38 (affect employment, industry or commerce or require displacement of businesses) and #39 (affect property values or local tax base) for the reasons previously mentioned. Criteria/support should be provided within the context of the Initial Study to support the finding that no significant impact (to employment, industry, commerce property values, or local tax base) will result. No Identification of Mitigation for Impacts to the City The DEIR does not provide mitigation measures to alleviate the impacts to the City. Impacts to the City Not Identified as an Area of Controversy The DEIR does not identify the impacts to the City of Laguna Niguel as an Area of Controversy/Issue to be Resolved. Impacts to the City Not Identified as a Significant Impact The DEIR does not identify the impacts to the City of Laguna Niguel as a Significant Unavoidable Adverse Impact. Impacts of I-5 Connection and HOV Lanes The DEIR refers to additional environmental documentation being required for both the I-5 connection and for the construction of HOV lanes. To the extent that these studies are necessary to determine the significance of the project's • 11 Transportation Corridor Agency November 26, 1990 Page 29 impact, they should be available for public review concurrently with the DEIR. Additionally, if they are intended to address proposed mitigation measures they must be considered and 3-4-85 analyzed in terms of their impact as part of this EIR process. Since HOV lanes are proposed as mitigation measures, the required HOV environmental documentation should be part of the DEIR. 41. Local Circulation Local circulation is not discussed in the DEIR; it is the City's opinion that local access issues 3-4-86 should be addressed in the document. The result of selecting one alternative over another may impact the City's ability to provide goods and public safety services by inadvertently limiting access for residents and public safety officers. 42. Cumulative Impacts of Associated Projects Although CEQA Guidelines (Section 15131) require consideration of Significant Cumulative Impacts (15131), the DEIR does not address impacts associated with construction (including cost, funding, relocation, and construction) necessary 3-4-87 to implement the south end I-5 connection of the Demand Management Alternative #2 such as: Paseo de Colinas/Avery Flyover Via Escolar "Underpass" Relocation of 7000 feet of I-5 both horizontally and vertically 43. CEQA Guidelines (15126(d)) Require that an EIR Address a Range of Reasonable Alternatives to the Project Which Could Feasibly Attain the Project's Basic Objectives 3-4-88 Subsequently, the DEIR should provide a discussion of Alternative #1, with Demand Management -design, providing additional access ramps to Paseo de Colinas. Presently, the DEIR 3-4-88 3-4-89 3-4-90 Transportation Corridor Agency November 26, 1990 Page 30 does not meet the CEQA requirement in that it does not address an alternative to Alignment #2 with Demand Management cross -sections. IV. CONCLUSION As indicated above, there is substantial additional identification of impacts, analysis of impacts, and identification and analysis of mitigation measures that are required to be completed and included in the DEIR before it can be certified and used by the Board of Directors for approving the project and selecting an alignment. Also, additional information is being developed in the P & D Technologies' Study that should, after completion, be included in the DEIR. Once all this additional information is developed and included in the DEIR, the DEIR should be renoticed and recirculated to the public,- including the City of Laguna Niguel and the business owners in the Corridor/I-5 confluence area, to provide an adequate opportunity and time in which to analyze and comment on that information. If you have any questions regarding the contents of this letter, please contact the undersigned at (714) 643-7000. Sincerely, Tim Casey, Q'aty Manager, City of Laguna Niguel TC:dv attachments: A. San Joaquin Hills Transportation Corridor Economic Impact on City of Laguna Niguel B. Fiscal Consequences to the City of Laguna Niguel of Various Transportation Corridor Interchange Alternatives, Alfred Gobar Associates, Inc. C. Memorandum dated November 26, 1990, from Austin -Foust Associates, Inc., to Bob Lenard, City of Laguna Niguel 0 40 ATTACHMENT A SA_N JOAQUIN HILLS TRANSPORTATION CORRIDOR ECONOMIC IMPACT ON CITY OF LAGUNA NIGUEL GENERAL AREA OF IMPACT No. of Businesses: 180+ on Cabot Road, Cape Drive, Crown Valley Parkway, Forbes Road, Getty Drive 110+ on Camino Capistrano Taxable Retail Sales: $146,260,000 Assessed Valuation: $ 98,619,000 Sales lax to City: ,1, 462, 000 Property Tax to City: $134,122 Bed Tax to City: $26,000 FULL STRUCTURE. TAKES PER DEIR Alternate No. 1: Timberline Lumber, Emergency Animal Clinic, Earl's Plumbing, Morena Tile, Western Exterminator, Capistrano Used Cars Alternate No. 2: Costco, Sepulveda Building Materials, Allen Cadillac/Oldsmobile, Shell Gas Station and Mini -Mart, Exxon Gas Station, A's Burgers, Buffy's Family Restaurant, Travel Lodge, In and Out Burgers, Timberline Lumber, Emergency Animal Clinic, Earl's Plumbing, Morena Tile, Western Exterminator, Capistrano Used Cars DIRECT REVENUE LOSS TO CITY Alternate No. 1 Alternate No. 2 Sales Tax $23,280 .$924,340 • Property Tax 2,242 39,127 Beck Tax 0 26,000 TOTAL PRESENT VALUE $25,522/year $750,657 $989,467/year $32,335,523 FISCAL CONSEQUENCES TO THE CITY OF LAGUNA NIGUEL OF VARIOUS TRANSPORTATION CORRIDOR INTERCHANGE ALTERNATIVES ALFRED LOBAR ASSOCIATES, INC. ATTACHMENT "B" 0.1 is TABLE OF CONTENTS CHAPTER ALFRED GOBAR ASSOCIATES .PAGE I INTRODUCTION ............................................. 1 Objective........................................... 1 Methodology......................... .............. 1 Analysis............................:............... 2 Mitigation.......................................... 2 II SUMMARY AND CONCLUSIONS .................................. 5 III DETERMINATION OF FISCAL IMPACT ........................... 9 PrimaryImpact... ............................... 10 OverallExpected Outcome ............................ 11 BestCase Outcome ................................... 14 IV POSSIBLE MITIGATION MEASURES ............................. 21 V FISCAL IMPACT RELATIONSHIPS .............................. 44 EXHIBIT I-1 Map of Laguna Niguel Transportation Corridor StudyArea ............................................... 4 III-1 Map of Laguna Niguel Transportation Corridor StudyArea ............................................... 17 III-2 Economic Impact Summary of Transportation Corridor Interchange Alternatives City of Laguna Niguel .................................... 18 III-3 Economic Impact of Transportation Corridor Interchange Alternatives City of Laguna Niguel .................................... 19 IV-1 -Population Summary Trade Areas for Laguna Niguel Corridor Impact Analysis... 23 i • TABLE OF CONTENTS EXHIBIT ALFRED GOBAR ASSOCIATES PAGE IV-2 Map of Existing Retail Surveyed 3.0-Mile Trade Area for the San Joaquin Hills Corridor Market Impact Area LagunaNiguel ............................................ 24 IV-3 Existing Retail Surveyed 3.0-Mile Trade Area for the San Joaquin Hills Corridor Impact Area April 1990 LagunaNiguel ............................................ 25 IV-4 Map of Future Retail Projects 3.0-Mile Trade Area for the San Joaquin Hills Corridor Impact Area LagunaNiguel ............................................ 36 IV-5 Future Retail Projects Under Construction, Approved or in Planning April 1990 City of Laguna Niguel .................................... 37 IV-6 Demand Analysis for Community Level Retail Floor Space 3.0-Mile Trade Area Laguna Niguel Corridor Impact Area ....................... 40 IV-7 Five -Mile Trade Area Boundary Map ........................ 42 IV-8 Demand for Regional Anchor Store Floor Space Five -Mile Trade Area Laguna Niguel Corridor Impact Area ....................... 43 V-1 Impact of Feasible Types of Land Use for Laguna Niguel Transportation Corridor Study Area ................ 46 APPENDIX List of Businesses and Square Footages in the Laguna Niguel Transportation Corridor Study Area and Assessor Parcel Information for Laguna Niguel Transportation Corridor Study Area ....................... 47 ii 0 CHAPTER I INTRODUCTION Objective ALFRED GOBAR ASSOCIATES The purpose of the analysis described in this report is 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. Methodology The study area likely to be affected by each of the alternative development plans for the interchange was delineated in terms of Primary, Secondary, and Tertiary Impact Areas derivative of each freeway alignment alternative. The overall study area is shown on the map in Exhibit I-1. The City of Laguna Niguel provided the Consultants with a list of businesses in the study area generated from a reverse directory and various other records. Additional information provided by the City included County Assessor's records and detailed maps for the study area. Alfred Gobar Associates, Inc.'s staff physically surveyed the area to verify names, addresses, and the types of businesses in the impact areas and to measure the size of each business. The Consultants also accessed Orange County Assessor's data for land uses that were omitted from the information provided by City Staff. Assessor's maps were used to measure acreages for the land uses for which this data was not provided by Staff. 1 ALFRED GOSAR ASSOCIATES A comprehensive list of businesses in the Impact Area was then provided to the Research Department at the California State Board of Equalization in order for this agency to generate information about reported levels of taxable sales. Of the 189 businesses in the study area of a type likely to generate sales tax revenues, information was available from the State agency for only 109. Taxable sales and, therefore, the City's revenue from sales tax for the businesses for which empirical data was not available from the State agency were estimated on the basis of square feet of gross leasable area and typical dollar volumes for these types of merchants in South Orange County. The omissions were primarily new businesses or ones for which the business name differs from the name of the entity reporting taxable sales to the State agency. Analysis The Consultants then estimated which businesses would be most severely impacted by each alternative and quantified the loss of City revenue derivative of these impacts for each alternative interchange configuration. Mitigation The Consultants also reviewed a wide range of potential land uses that could be developed in the study area which could generate City revenues to mitigate some of the financial impacts of construction and eventual completion of each alternative interchange configuration. This process involved an analysis of consumer support for a broad range of retail activities as well as a less detailed evaluation of the fiscal impact potentials for the City of Laguna Niguel from office and 2 • ALFRED GOBAR ASSOCIATES hotel/motel uses that might represent alternative land uses in the study area. The Appendix to this report includes detailed listings of businesses represented within the study area by type of business, floor space occupied, etc., as well as assessor parcel information for all properties in the study area. 3 �J! ♦ - I '►';;+ EXHIBIT I-1� LAGUNA NIGUEL TRANSPORTATION CORRIDOR STUDY AREA �•,,.� ras• wfr ,C� �d ., / :W�?•}Yf r ~ .ter � � a : ` i• tiry.n � a�`. 't's retc'� .' 3 �• .»rr.� / ro .•'t'r_ d• •'S�J .f� �f3 ` � •q,.r i�.Y 5 7x! ��+' S� J„' }'t �j��a wF �A��i �^# ��; ~i���� •>� ,gr,��! . / _S~~',,»:!t ,• jt _�+ .r � t •� .'► i t -�"' � �� y}, .li.�,` via; r j���• •� I .1.r.. mac+_•. r `. 1 �.� t ,="G�" ►�ii`� s ` / ♦ ..' �T.'.. r•c �+� cower •.0 sr s y•_y�� �••� + z"' a ,' �I1`� / ••, /.•; ` r •`� ti _ d' ``it'�� _ of / '•'•°° a' 4,s. vir( 3'� / %= ..� ge`�� `y •, ear. �iF• .r� � :•'� `i.��er9 a'c+iS'ei: .:='r �,•. � + .'; .°' ^4 r•.! �.. MISSIO b _' d —� •_ra,.• b ' ! = '_,,.pig j 3 tom: �,IEJO 44,111 j fir••. +•,.r:. •m d .�•r•f•T � / :' w��� „ram+ •� / rr••i v SAWMACK a- owm �' �! ♦ur ysd'•r' c.,:r. SSW P % if • i • e I COLLfG(' •rr I % • rr �s .... '•, _ , � i''� �, y�.=f , `tl f .�y��e, r'� .' �tsv-Sri•.+. rs � D 4' T' '' � + ` . , J 'a, '^r `` •+. 7 tF•� .� f� _ 5; _ � � _ •.c T. t:'• = 3 �? r tea:$ !.;d .'.✓' . 9"." Laguna r = . b .4,•r.! ��` a • n7'� : '_-'e�a.;G, • Niguel r 1'D, • .: cC t,; i • S'" a r"'•_ iy /�' i iJ ..Di�� '` \ • �'' s.. � . • .y rc•.•'n .` -.. 'i...u__aD ,..lra•�r �•,c. 3 Cx� � _ ,-I � -" •i � f �1f a • ` •.Is�l dr �!' 3 `,• ,•• ✓!�= _ f�L w,i- Z :fir * aer:ri I s �•wM'e.if aT i� M f,`� • `c: �, : f•,iga I _ it '' :: ;iD `- �'•!". rS'�•'•t'`9 ••"=:hri4' :I _ .'.•,� sd •� • s•rd l • i .. `N•.•• L f :I _: • '�yr4r•"�� S..•_.r:.rr. :. • '_'�'-" ,� .1'•. •'••#•��r.en'i ••R �,••+ �'' 'y�j' ^h �r� ,• ,� ' .,':•, • '' ��Ir ♦y•^+•'+s.caMr„�. i R + '? C• r•t 1 �R � Dpr • r j # �• _•y. •b O x �'•"� r+•ry,r/�.'�OD S'u i •• T: �';I� ,tTf I � ••� . "si J .-~�__ - - � i� may. . �ti ; '►•r�f i :wrs.- IRrynO ii� t1 • �i j.�.i. - • , + mod: •4. i,•.c',. °,r 3 �;"�. r y r, • �j� ` • �' l-sro c. •\, �; ��, •� � . • - / i S � pp ♦ �.a. ` poi ,d,` j � +rt •�. •�`+ s, ' ?�i • J• '� t; e�' fry M s `,r► 1 4,-''' ' . •h. :' : �q�,� r i �� i' �. F �• ` •.• i �i "tie • � owr+ I + � f�� • , , : _-•••, : ' w w•K ?j.. ' I '♦• ss Taws ' I * „oN �• 4 '? 1/i.! LA.r- rr...`'ii � w. r♦ ^yfd f �• r. a s'' / t �•.,,• ��''°.yt •t !„rs•a,i /��•-.+• a� J'fH.�:s ` �df: �'7' � tom` �� �+'+ +O` ♦ '% V 1 '�= •� I ap��` • � DtDN�w'- `• ,.r,.d��� ! ? `'� d ` ? ,..rf �Ifr M.'•' o.w ` 1i� 11..'i i'1 �' '�T,p:'� �•.•i,s ••'.`•l''J ; '.r�i 1� +-fOf.�n "Pool tt\1L7• !� �� Z ♦ > F Ir 1 i r i ci w �j+ �.. � ~ � I n:+� � D't ;e • , t� )� � {s �� �� t,1. R , w. 0"* ` .a4 I�,r�1 Q •lt +•a Ir,.` S / CAR ram•• #.M±�f :s �� v..'wrar'• n-� .• �• .'•. :�.s'8�. °•".� r P �: .... ♦..roq..a -' �iuWui� f .••.• •�.. r �?rtrr MM •/ ALFRED 008AR ASSOCIATES CHAPTER II SUMMARY AND CONCLUSIONS Development of the San Joaquin Corridor/I-5 Interchange represents a potentially significant loss of sales tax and property tax revenue to 3-4-91 the City of Laguna Niguel. A comparison of the potential economic impact of the two alternative development schemes for the interchange, considering only those properties which are in the Primary Impact Area or that area designated for "full structural take" in the Draft Environmental Impact Report, is as follows: Alternative #1 Alternative #2 Loss of Annual Revenue To City In Perpetuity: Property Tax $2,242 $39,127 Sales Tax 950,340 Total $25,522 $980,467 Total Present Value of Loss of Income Streams to City: (Assumes 7.5 Percent Interest Income, 3.0 Percent Inflation in Property Tax and 4.5 Percent Inflation in Sales Tax) $750,657 $32,335,523 3-4-92 The present value of the projected stream of future income that is likely to be lost under Alternative Number 1 is $750,647 on the basis of a 7.5 percent investment yield or debt service assumption and the loss 3-4-93 of potential increases in revenue at an annual rate of 4.1 percent per year compounding because of inflation. Alternative Number 2 represents the potential for the most significant losses of City revenue. In order to generate a comparable stream of revenue, 'it would be necessary to 3-4-94 invest a fund of $32.3 million at 7.5 percent interest to create a long- term stream of revenue consistent with the anticipated loss of revenue Al 5 3-4-94 3-4-95 3-4-96 ALFREO GOBAR ASSOCIATES under the assumptions related to Alternative Number 2 above. Implicit in the long-term projections is an anticipation that revenues from business activity lost because of the development scenario under Alternative Number 2 would otherwise grow at a rate of 4.44 percent per year compounding through inflation and periodic increases in the ad valorem tax base value of the underlying property. In addition to the long-term losses sustained by the City by having businesses closed in perpetuity, it is anticipated that shorter - term losses will be experienced in the area surrounding the interchange development as a result of construction activity in the area. Two areas of impact have been defined - the Secondary Impact Area or properties located in closest proximity to the interchange and the Tertiary Impact Area which consists of all other properties in the general vicinity of the interchange. The expected impact on these two areas is based on the following set of assumptions: ASSUMPTION A - EXPECTED I. All businesses in the Secondary Impact Area are closed for an average of at least one year during the construction period and have taxable sales reduced by an average of 30.0 percent of the remaining three years of construction. 2. Businesses in Tertiary Impact Area are impacted as follows: a. Twenty percent of taxable sales generating businesses move out of area and are not replaced until construction is complete (four years). b. Taxable sales of remaining businesses are reduced by 30.0 percent for at least two years during construction. 0 2 ALFREO GOBAR ASSOCIATES Resultant Loss of Annual Revenue to City: Alternative #1 Alternative #2 For Four -Year Period: Sales Tax $213,068 $101,714 For Three -Year Period: Sales Tax $120,000 $8,913 For Two -Year Period: Sales Tax $255,682 $122,057 For One -Year Period Sales Tax $400,000 $29,710 Total Present Value of Loss of Income Streams to City From Secondary and Tertiary Impact Areas: (Assumes 7.5 Percent Interest Income, 4.5 Percent Rate of Inflation) $1,897,543 $631,195 Add In Present Value of Longer -Term Impacts in Primary Impact Area: 750,547 32,335,523 Total Present Value of Expected Outcome $2,648,190 $32,966,718 A best case interpretation of the value to the City of Laguna • Niguel of the short-term lost revenue potential inherent in Alternatives Number 1 and 2 relative to the development of the interchange is as follows: ASSUMPTION B - BEST CASE 1. Businesses.in Secondary Impact Area are shut down for an average of at least six months during construction and have taxable sales reduced by an average of 20.0 percent for remaining three and one-half years of construction. 2. Businesses in Tertiary Impact Area are impacted as follows: a. Ten percent of taxable sales generating businesses move out of area and are not replaced until construction is complete (four years). b. Taxable sales of remaining businesses are reduced by 20.0 percent for at least two years during construction. 7 3-4-96 3-4-97 3-4-97 ALFRED GOBAR ASSOCIATES Resultant Loss of Annual Revenue to City: Alternative M1 Alternative #2 For Four -Year Period: Sales Tax $106,534 $50,857 For Three -and -One -Half -Year Period: Sales Tax $80,000 $5,942 For Two -Year Period: Sales Tax $191,761 $91,543 For Six -Month Period: Sales Tax $400,000 $29,710 Total Present Value of Loss of Income Streams to City: (Assumes 7.5 Percent Interest Income and 4.5 Percent Rate of Inflation) $1,152,215 $376,657 Add In Present Value of Longer -Term Impacts in Primary Impact Area: 750,647 32.335.523 Total Present Value of Best Case Outcome $1,902,862 $32,712,180 I The primary difference in these two estimates occurs in the case of Alternative Number 1 due to the fact that major sales tax revenue 3-4-98 generators are located outside of the Primary Impact Area in this configuration, thus the short-term impacts become a significant portion of the overall impact. 3-4-99 A review of alternative land uses that could mitigate the loss of sales tax and property tax revenues projected as an outcome of the interchange construction identifies few development alternatives that are feasible in terms of the scale of the relevant consumer support base and the existing and projected inventory of competitive retail floor space in the applicable trade areas. 0 1�1 lei ALFRED GOBAR ASSOCIATES CHAPTER III DETERMINATION OF FISCAL IMPACT The study area analyzed (the boundaries of which are shown on the map in Exhibit III-1) encompasses 346.22 acres. At the time of the survey, the study area had 1,297,178 square feet of developed floor space in place. A total of 291 businesses were identified in the analytical process described in Chapter I - 189 of which are types of businesses that generate at least some sales tax revenue. Total assessed value of the study area was $98,618,788. Property tax revenues to the City of Laguna Niguel from the study area (13.6 percent of the 1.0 percent ad valorem property tax rate) amounts to $134,122 a year. Total taxable retail sales in the study area are $146,261,600 a year generating revenues to the City of Laguna Niguel equivalent to 1.0 percent of total taxable sales, or $1,462,616 a year. An additional $26,000 per year is generated in bed tax revenue from the study area. Total revenue to the City from ad valorem taxes and sales tax revenues related to the study area's business inventory is $1,622,738 a year. This overall study area was evaluated in terms of subareas based on the anticipated severity of the negative impact on businesses in each of the three areas - Primary, Secondary, and Tertiary Impact Areas - related to construction of one of the two alternative interchange configurations. The Primary Impact Area under each alternative includes those properties which are designated as "full structural takes" as described in the Draft Environmental Impact Report. These properties E ALFRED GOBAR ASSOCIATES 0 will be removed from the tax rolls and the businesses will have to relocate. The Secondary Impact Areas are defined to include those properties which are located in close proximity to the interchange right-of-way but not directly impacted by it in terms of having to remove existing structures. However, it is felt that the businesses located on these properties are at risk of being severely impacted during the construction phase, with the possibility of businesses being shut down for some period of time. The remaining businesses located in the study area are also considered as being in the general impact area and are designated as being located in the Tertiary Impact Areas for each alternative. These businesses are expected to sustain impact and, therefore, loss of revenue due to traffic problems, lack of access, and general visual problems during the construction phase. The revenue assumptions based on 1989-1990 circumstances for the Primary, Secondary, and Tertiary Impact Areas related to the two alternative interchange configurations are summarized in Exhibit III-2. Primary Imoact The Primary Impact Area in which the most severe impacts will occur is considerably smaller under Alternative Configuration Number 1 than it is under Alternative Configuration Number 2. Only four businesses with taxable sales are in the Primary Impact Area under Alternative Number 1, while twelve businesses with taxable retail sales will be in the Primary Impact Area under Alternative Number 2. Assuming that all businesses in the Primary Impact Area for each alternative are effectively displaced in perpetuity, the loss of 10 ALFRED GOBAR ASSOCIATES property tax and sales tax revenues under Alternative Number 1 in the Primary Impact Area would amount to $25,522 a year. The Alternative Number 2 configuration (assuming that all existing businesses in Primary Impact Area defined by Alternative Number 2 are lost) would result in the loss of $989,467 a year in income to the City in perpetuity. A summary of the fiscal consequence to the City of the loss of all revenues from the Primary Impact Areas for each interchange configuration is as follows: Alternative #1 Alternative #2 Loss of Annual Revenue To City In Perpetuity: Property Tax $2,242 $39,127 Sales Tax 23,280 950,340 Total $25,522 $989,467 Total Present Value of Loss of Income Streams to City: (Assumes 7.5 Percent Interest Income, 3.0 Percent Inflation in Property Tax and 4.5 Percent Inflation in Sales Tax) $750,657 $32,335,523 Overall Expected Outcome If it is further assumed that businesses in the Secondary and Tertiary Impact Areas are somewhat impacted during the development phases, the City's loss in revenue will be considerable but only temporary - during the development interval. Two sets of assumptions regarding these impacts were developed. Under the first or expected assumptions, it is projected that all businesses in the Secondary Impact Area will be forced to close for an average of one year during the four- year construction period and that their sales will be reduced by an average of 30.0 percent during the remaining three-year period. It is 11 ALFREO GOBAR ASSOCIATES further assumed -that 20.0 percent of the taxable sales generating businesses in the Tertiary Impact Area will move out of the area and not be replaced until construction is complete and that the taxable sales of the remaining businesses will be reduced by 30.0 percent for at least two years during the construction period. These assumptions are summarized as follows: Alternative #1 Alternative #2 Primary Impact Area Lost In Perpetuity: Property Tax $2,242 $39,127 Sales Tax 23.280 950,340 Total $25,522 $989,467 Secondary Impact Area Sales Tax Loss for One -Year Period $400,000 $29,710 (All Businesses Closed for Average of One Year) Annual Sales Tax Loss for Three -Year Period $120,000 $8,913 (All Businesses Have 30.0 Percent Average Reduction in Sales) Tertiary Impact Area Annual Sales Tax Loss for Four -Year Period $213,068 $101,714 (20.0 Percent of Businesses Removed for Full Period) Annual Sales Tax Loss for Two -Year Period $255,682 $122,057 (30.0 Percent of Sales for Remaining Businesses) Presumably, sales tax revenues will increase with inflation if the study area's businesses are not affected by the interchange, while property tax revenues will be subject to increase at a much lower rate under the provisions of Proposition 13. Assuming a 4.5 percent per year inflation rate for sales taxes and approximately 3.0 percent per year for property taxes (allowing for some sales of property to return the tax base to market value periodically), the anticipated growth rate in revenue in the Primary Impact Area is a combined rate of 4.10 percent 12 • 0 • ALFRED GOBAR ASSOCIATES per year for Alternative Number 1 and 4.44 percent per year for Alternative Number 2, if businesses in the study area were to be immune to the effect of highway construction. The present value of the future stream of income from the Primary Impact Area in perpetuity, assuming a 7.5 percent return on investment or a 7.5 percent debt service and allowing for the potential growth in revenue, which would otherwise occur if the businesses were not displaced, is summarized below. The present value of the short-term loss of revenue from the Secondary and Tertiary Impact Areas - assuming that the funds are invested at.7.5 percent and that the foregone stream of sales tax income available to be spent would increase by 4.5 percent per year - is also shown below: Present Value of City Loss Alternative #1 Primary Impact Area Loss of Income in Perpetuity $750,647 Short -Term Loss of Income From Secondary Impact Area (Present Value at 7.5 Percent) 681,362 Short -Term Loss of Income from Tertiary Impact Area (Present Value at 7.5 Percent) 1,216,181 Present Value of City Loss Alternative #2 $32,335,523 50,608 580.587 Total Present Value $2,648,190 $32,966,718 The implication of the calculations above is that $2.65 million invested today at 7.5 percent would generate an income stream that would match the sales tax and property tax revenues projected to be derived from the Impact Areas (including an allowance for 4.1 to 4.5 percent per year increase due to inflation) if the businesses were not to be affected as assumed under Alternative Number 1. 13 ALFRED GOBAR ASSOCIATES A fund of $32.97 million invested today at 7.5 percent would produce a stream of income equivalent to the anticipated income lost from all three Impact Areas under development Alternative Number 2 after allowing for a 4.44 to 4.50 percent per year increase in these revenues as a result of inflation. The present value cost to the City of Laguna Niguel of the loss of revenue from each of these two alternatives, therefore, is $2.65 million in one case and $32.97 million in the other. Best Case Outcome A more optimistic outcome can be based on the following assumptions: I. All businesses in the Primary Impact Area are closed permanently creating a loss of both sales tax and property tax from the Primary Impact Area (same as in expected outcome assumption). 2. Businesses in the Secondary Impact Area are closed for an average of at least six months during the construction period and have taxable sales reduced by an average of 20.0 percent for the remaining three and one-half years of the construction interval. 3. Businesses in the Tertiary Impact Area experience a 10.0 percent loss of taxable sales for the full four-year period. Taxable sales of the remaining businesses are reduced by 20.0 percent for at least two years during the construction interval. • 14 • ALFRED GOBAR ASSOCIATES Alternative #1 Alternative #2 In Perpetuity: Property Tax $2,242 $39,127 Sales Tax 23.280 950,340 Total $25,522 $989,467 For Four -Year Period: Sales Tax $106,534 $50,857 For Three -and -One -Half Year Period: Sales Tax $80,000 $5,942 For Two -Year Period Sales Tax $191,761 $91,543 For Six -Month Period Sales Tax $400,000 $29,710 The resultant loss of City revenue under these assumptions is equivalent to the net present value figures shown below: Alternative #1 Alternative #2 Present Value of: Permanent Loss of Income $750,647 $32,335,523 Short -Term Loss of Sales Tax 1,152,215 376,657 $1,902,862 $32,712,180 The estimates provided above with regard to Alternative Number 1 assume that $1.90 million invested today at 7.5 percent would yield enough revenue to produce a stream of income (increasing at 4.1 percent per year) equivalent to the stream of income that would otherwise flow from the businesses that would be permanently lost. In addition, the stream of income from a $1.90 million indemnification fund would replace the lost income (after adjustment for inflation) during the interval in which businesses achieve lower sales volumes that would otherwise be the case. • 15 ALFRED GOBAR ASSOCIATES • An indemnification fund of $32.71 million invested at 7.5 percent would generate a stream of income that would match the projected stream of income for the businesses that would be permanently lost under Alternative Number 2 and replace the lower level of income from businesses that will be affected only temporarily by the construction process allowing for a 4.44 to 4.50 percent per year increase in these incomes over the 1989-1990 base year assumptions. Detailed estimates of revenue potential by specific land use within the three Impact Areas are provided in Exhibit 111-3. is • 16 r EXHIBIT III-1 --- - LAGUNA NIGUEL TRANSPORTATION CORRIDOR STUDY AREA .: n4 a' '0,'�� .. ;iI � •Ci'n Jl "• ,i•�'C^`' �i � �� �•.Oyi r•i=i�, / / '� ''• - ` ,t. 3"'s •%�` a s.i `� . si,onf '.tea �;py y�J� / ' �a _pp.0 .�„K,: `y/ .t�i'• •`!+ �Olt.'yl1/ jj • J Al/ i R�+� ..•ft•L 1��t` a'tl?a 0 • i 1' ac':o` c .•:tt- �r Close couMt�r [{=i- si... >. •: '1 £ p' �` �1� / +.It`^i,+ •. ■ d 1 eO,��� wml�.nro �'//J y.•C :1,: 4.r*: •n•.F �„•.•J, ,y •r.=, :: ;. •`F >i ° t-T• '�' •��''-�� s '/1 6.. ,� d �- / a.'� `>,;•�'i.Krn :i rn °/ �, a i �f yt:' " f•ca'c : 4' s�: ' �'••� •' �� ao+in� " - c „ w?`�.?��• -�`0i, +��, ?' •��u i /i •�� a'�, �.-/" �cx � a//�!n-4t YhM� ,s�� � •/ ,rYvaf!•i'!' ! �;• ''�.l+a 7n, �; •'� .'' � , y �?,,,,: .•4 �;� MiSSI� °� , � - yr• K�`K:/ 44, •' �•` pq w •'' T� 'isf•` . dr. l '� ••:� .)Vb a �.y ucCMol . •' ! t ' -�� �/ .ee.w ; � 1 I '0 SADOLEUCK 1 -1.•�.'y••.'=� . •��.I,,•who�i a .r� • +i;�'4ya ,J.,�?�� ��i 1 �. �� � 1 �. MCU6` \ ••♦ ,,,�',/� mot, "•w.��� ,--x °r ' / / .w:.iE4!# '!, "+r'•t s _ r CClt1EGF J� a 7 ., �' \iG a 3� _ •_ �: 4;ya ,• Jam^ ! . r : w.� 4�. •• _,.,, �,11 1-'k, - i s� F'":` 1�� �` 1f1 �� �; •.a ••'� - • �sY„y c.ri..�. ws. •= 'a` \ ,n.�'• •..'����.� � y K, ' �:u.• y c�.r _ ya': �>> . A•S. j� ,yes ..s i -s.: ., ♦ J ,.�, •••11•,. _- :y: ., �."•• o1e ._.-►'' s /9 - Laguna _ �-- • = ,, > •r,= Niguel •�°,. ,,.., ',o', ttrr -��"^',""Fri I ��.._•; yam, a• - ' •• i • . • :b, c_ •h, a` r�'�.. _r•__o.3 ,a wie!'_?r.,yp S M \`,` 1 �: J •' ,• .... ; ._� .•.ta�'1 �•` r• a..• •r �'^?'�+ ..c; � rat. •+% ' � ; L f E.L - 1A': '� � rarr.sd.{�. V �� e. .•.,:•'.•' _ `ars ! �•'• d,> -' =.*f er:i+"= v.`i -' ;I w"+,�� ams, �` '• �/ ss•-., .. . ��. •, •4.•'i•-;.?'d. ia•Ma�Cax•+'+� ;I .,'• by tyt'p!4h "h �.. ` ti'T ,` •r.•r,••e•.'+':. ♦�� ` 17 •,aay� •�,� r�f+y tcAtI 1 •'�-.•'il. �•,� •' r .�,• \ i ?�_ ••'+a . i - - y�; 1.d'o'tc...co ttute - i`,J t •' •,, t r`� o✓•`•s �' .; j"���..r. I Z 7,eu A Y �•:•ii.4� 41 ,:,�.`�.�,y �' • ' j i /nl•: /aJ' . �� i� �� ij^ �%' r -�! • jK•r. :' .' - :+'°'ee :! rr�,,i/- �/" / F {' . •.. j i ad ,•r•• CPCN `+! t`t► '• .''�' ••'c ,`•' a31..�`yi~�� r •t+.'� � � *� � t- 4% ✓I /�T� ,v,71 i�1t�j� ��r" �� I i I�� i 11 i1 ' •�= _J r.«�' = ��;.•'�� ��l rIr,JPf �+,,.,�'f�r�S�e.•�° vaMn IF` I 1��,`�`; ,•`., �;•'/� 3 �''!. K.t,H • . r r, f �,i ae �% 9i �.gf •,:r �` �..�• d`''= � • � ,r.,.-F_ . .. ,,ate � � ; �j.. '_.•'' * � .rt nna � f ✓' �^ ! •O7" ""+al � •! Z. •ilric�?•i_ _� . -� �' • / � s R�. .. 3 17 1. � a ; •� 't ~� 'p�.a)� � 'wo"4�y: .9 i'�"s .d r 4�y`a• •.L. '.ura• , I_ — a•„r I e,d ra••b' T_ 6�o .,wn;♦a•�'Cw�i�/�• -` ~hIF��-•-,if - _ j �,av` ,; ;r� �F••i�.d,�a •- F• 1 � .i4�}3'�' EXHIBIT III-2 ECONOMIC IMPACT SUMMARY OF TRANSPORTATION CORRIDOR INTERCHANGE ALTERNATIVES CITY OF LAGUNA NIGUEL Alternative #1 Alternative 12 PRIMARY IMPACT AREA' Number of Businesses 6 15 Number with Taxable Sales 4 12 Land Area (Acres) 1.72 34.79 Square Footage (Buildings) 26,121 214,197 Assessed Valuation $1,643,697 S28,769,610 Property Tax Revenue to City $2,242 $39,127 Sales Tax Revenue to City $23,280 $950,340## SECONDARY IMPACT AREA" Number of Businesses i 19 Number with Taxable Sales Land Area (Acres) 18.40 6.46 Square Footage (Buildings) 118,250 110,027 Assessed Valuation $19,110,0000 $4,993,684 Property Tax Revenue to City $25,990# $6,791 • Sales Tax Revenue to City s400,000$ 129,710 TERTIARY IMPACT AREA` Number of Businesses 284 266 Number with Taxable Sales 184 168 Land Area (Acres) 326.10 304.98 Square Footage (Buildings) 1,152,807 972,954 Assessed Valuation $77,860,091 $64,855,494 Property Tax Revenue to City 8105,890 888,203 Sales Tax Revenue to City $1,06563400# $508,570 'These properties will be removed from the tax rolls and the businesses will have to relocate. "These properties will be severely impacted during the construction phase (estimated up to 40 months) and many of the businesses will have to be shut down for a period of time. Some businesses may also decide to relocate out of the area. ""These properties/businesses will sustain impact (real or perceived) from disruption of traffic flows, lack of access and general visual problems in the area during the construction phase. $Consultant's Estimate ##Includes annual bed tax revenue of $26,000. Sources: City of Laguna Niguel; Orange County Assessor's Office; California State Board of Equalisation; Field Survey and Calculations by Alfred Cobar Associates, Inc. 18 Ie r m w s M p■' l erl O /w 10 1 1 r' h pop e iI M w e w Y r M r r !Nr N r r r N♦ 1 N S ~ • M M N in N r M w w e r N r N a,* O in 1 h 1.^7 ►hl .I w.i.I 1 V4 �. w so NN1�MO•rN.0 Ni.0 N.rn P O 1 N M N h M M lf! t� r .1 r w M w 0. 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I�IVr .44 :IV `N Y NI PI !•I N N N N N N N N N N Y r Y t t +Y+ >• •' 1 +Yi Y C ' • M M 1 N Y ■ M M e y Y ■ w Y Y Y r• w r 1 Y L .iel M 3 w w/r S got M V + +sq S w / O r w r 3 r r 11 481 r A■r w .q w v Go M C •.i• w ; 3w r 0 v Y Y • a-" ." 16 +1 r 1 w w • 4 it 1 i L 1 x$s 16 16 t wl w • 6■t 1 ' w■i A• S: 1 _S i S: C Y Y= v yN/ C t> Y Y 1 ■ ►� L 7 L L w■ Y Y i Y L w ►..I 1.r I. r• r• I ft.f 0 {.O r• Y Y w g • i >■ • Y w/ w W=rW /• �Y r Si S ►. ■ ■ Y V w w � ysI S 01 w/ 1 • Y W! W VO! :iO .I .•I i 4 M Y P. s 19 r • rw Y M • r a ♦ h ►■- w �= v OR L IL NN YM'! h � � h A O O 1 h y1 N 1 !wV 1 N M .. i1 w w Y^ •'e OOOO�Or.r• 1 1� I= • t w•.•IAhiOwh• 1 • M r.r lrfr-• • • 1 h • h N •• 1 w y 1• • W `� uq N IA N w) 1 .• 1 1 Y L i N h O N N N IL h r r r M ! r id 0 Cc Y �=1 L L IOU M ..r ■ r S I d Gor 04 C C Y S y Y i i ■ 4,■i 10. e Y ^ Pq r r s r •r .� p do 0 t a H C40 r r „- ! V O Y O M ^ ■ Y O u r ■ a■1 {> J L • Y O A,! Y r w f V ■ ^` J L.�+ Y L co w9 h 7 r ! O Y V O w �� •r .O.• i .ri V) IN `. ■ ... C rr wr 1 a w r r w• 1► • r L O -. ,,,., Y. yrl ■h r • L r of aM&6 � i �,,,• :: F O Y O 1• M ■ PI r Y • VA w Y -- L r _ •r • ~ 4.3 �" Vj {■� • s.h w.C. rLih 7..Oi ■"r C Y i V V ■ ON L r i ! Y• r ,� CirAAr-J 16 Multf C W. Y O x ,+ y LiJ 11d V R y v 0 s 2 •.1 w•1 � O w r M LamL,, � M Y y • u Y a r Y F w•1 O � � W r•� w • M • f r rs Y -•+ IV ~ • .q166 iY W � r • r �. L � 7 • r Y e• Y • "• Y 3 ! w ` ' Y M ! M ri : .w • w w ^•• r .~ M r • +• 4 Y Y L • L r y r A.Y ■ ■ �. - G 4/ w Y • N ■ Y Y L w •.• • Y {. w i i {;■1 i Y Y• w r r r ~16 �r i ++ Y 60 • i Oda •. y � w... e .rr� � s a. i a Y w i awr,r Y 7 n • s „• ! f f s 3 J w .q •Yi Y Iyil 1• Y •ql Y Y L {I w e Y t li O �o ,A r • r• •r it iw Y 10.i Y w us Y Y r ~ � 01 ! v y • rL- � � O w h 20 L ALFRED GOBAR ASSOCIATES CHAPTER IV POSSIBLE MITIGATION MEASURES The Consultants reviewed land uses that appear to be feasible in the study area that could represent alternative land uses to replace some of the lost revenues derivative of the assumptions described in Chapter III. The retail uses that represent potential mitigation to the losses projected as a result of development of the interchange were defined on the basis of a market research analysis based on two-mile, three-mile, and five -mile trade areas around the study area. Population data for these three definitions of the trade area(s) are included in Exhibit IV- 1. Based on the land use inventory in the trade area (discussed in Chapter I of this report) and the support potential defined by each definition of the trade area, it is possible to identify commercial retail uses that are underrepresented in the trade area and, therefore, constitute additional development potential and potential replacement for City revenues likely to be lost as a result of the interchange development. Exhibit IV-2 is a map showing the boundaries of the three-mile trade area and the locations of existing concentrations of retail floor space within the three-mile trade area. Exhibit IV-3 summarizes the characteristics of each of the major concentrations of retail floor space surveyed. 3-4-100 3-4-101 21 ALFRED GOBAR ASSOCIATES Exhibit IV-4 is a map showing the locations of future retail 3-4-101 development in this area. These developments are summarized in Exhibit IV-5. The combined comparisons of demand and supply for retail uses in the three-mile trade area are summarized in Exhibit IV-6, showing 3-4-102 relatively little unexploited opportunity for additional retail development in the study area. 3-4-103 3-4-104I A less restrictive definition of the applicable trade area support base - a five -mile ring - is illustrated on the map in Exhibit IV-7. This represents a "regional" trade area. The comparisons in Exhibit IV- 8 identify untapped support for relatively few types of retail activity even on this basis. Planned construction of a regional mall in the Golden Triangle (the I-5 and 405 Junction) will effectively minimize the untapped market support for most types of regionally -oriented merchandisers in the study area. These comparisons are shown in Exhibit IV-8. There does not appear to be significant potential to mitigate the anticipated losses of City revenue through the replacement of revenue. generating land uses in the study area. The next chapter in this report (Chapter V) discusses the fiscal impact implications of various land uses including non -retail that ultimately might be developed in the site area. 0 0 0 22 EXHIBIT IV-1 BENCHMARK: POPULATION SUMMARY URBAN DECISION SYSTEMS, INC. TRADE AREAS FOR LAGUNA MIGUEL CORRIDOR IMPACT ANALYSIS 04/23/90 2.0 MILE 3.0 MILE 5.0 MILE RING RING RING POPULATION 1994 Projection 42676 78112 203303 1989 Estimate 32276 58292 166403 1980 Census 13496 22222 99904 1970 Census 2159 6657 36763 % 80-89 Change 139.2% 162.3% 66.6% % 70-80 Change 525.2% 233.8% 171.8% In Group Qtrs 1989 0.0% 0.0% 0.3% HOUSEHOLDS 1994 Projection 14208 25506 72325 1989 Estimate 10716 18944 59994 1980 Census 4339 6981 37061 1970 Census 593 1775 13180 % 80-89 Change 147.0% 171.3% 61.9% % 70-80 Change 632.1% 293.3% 181.2% FAMILIES 1989 8870 15909 45749 AVERAGE HOUSEHOLD SIZE 1989 3.01 3.08 2.76 RACE 1989 White Black 93.9% 0.5% 92.8% 93.4% 0.6% 0.6% Other 5.5% 6.6% 6.0% SPANISH ORIGIN 1989 6.4% 5.9% 6.7% MEDIAN AGE 1989 31.43 31.62 35.15 OCCUPATION White Collar 77.4% 78.5% 74.9% Blue Collar 22.6% 21.5% 25.1% MEDIAN SCHOOL YEARS 14.47 14.68 14.03 INCOME 1989 Per Capita $ 20922 21584 20312 Median Household $ 53177 57687 48026 Average Household $ 63017 66418 56338 $ 0-14,999 8.9% 8.1% 11.9% $15,000-24,999 7.9% 6.9% 11.0% $25,000-34,999 10.8% 9.0% 11.7% $35,000-49,999 19.1% 17.2% 17.9% $50,000-74,999 27.0% 28.7% 25.3% $75,000+ 26.4% 30.2% 22.2% Median Family $ 58829 62727 56277 Average Family $ 68543 71963 64193 TENURE 1989 Owner Households 79.7% 83.6% 82.5% Renter Households 20.3% 16.4% 17.5% SINGLE FAMILY HOUSING UNITS 90.9% 91.3% 72.0% Source: 1970, ------------------------------------------------------------------------ 1980 Censuses, Jan. 1,1989 UDS Estimates (XP1) Urban Decision Systems/PO Box 25953/Los Angeles, CA 90025/(800) 633-9568 23 i - - - - - - - - - - Av 00 ' 1� .,.-.+�•„'�a,R �N r t� _ _ ---- -------. w-� .r,�e1 -� ��St T lNV '?''' 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PIl:POOOdPd NMI, It, fl*rl*M* 4 P:1; 0 O df� MM I� Od Olo dN 0 O u E M .+ .+ �q M .I 10 w N r+ ►o .+ .r 00 N .N 00 w .y N M u JZ o u N E J ~ 0 A � A 4 0 /�4 C L A 0 O F L y�+ A 10 {Li w •40 Of�A tDy0 0>• AO A �p L i0 m -W Q OA Y AOFA CO a ++ L 0*+ 0 go 0 -+C' O C orr .+ 0 A A 0 41 0 41 0 W 41 0: 0 a •+ L N �+ 0 0 J w< 0 +I G L •+ O F C L •I 4+ • 0 0 ++ C 0 U' ! 0 1� i+ po .r fL .ti p < <.�+ N 0 0A Q A 4>aZ+A+ <,.I Or �N�4P w0•�1< C 0 4 0 L w< C r. s A A N uc o-•++Lao N V= 0 .tl +• L 01 L a it O J LC++ 0 N.r w V N L L jCOSI �j [ �0� 0 •+Y 0 13, � 010 d o +� A.4 C i0.1 4 Q 0.0+ > w p 0 C 0 L4pp •4 0 yx� d01L- 1� J<m�Ar0i4~O.ZI c 0 0 0 10, Cia Vt� JZ « W W<.= L� « 41 1 `•R •� EXHIBIT IV-7 •` �, `� �c ;.• �� ; FIVE -MILE TRADE AREA BOUNDARY '"i;�" •°•' r^ wan • Ar w -{- • V,r• 1W11d0c^^r•^ z z S ^ .• r.... _ •°� �^ ! r•. 4+.s 1VAT10NAL Aft..it, sh et ti C.«,. 1 ' w • e 'r r a r• l FOREV aw e ♦♦ • w.° . i ,roe` • C * � - • ro a M 0 ( �o t '� •,./:.h .:• '"� ..• :\ � :fta FLake w,� • �i —'! w• el \Toro �' i Laguna Hills.1' ,< i �I,� .1 ��• S PP4a , ^'pro. � H �.. ce i a rse s h�' I} lr,,, r P• Is ream tvF.Jo /dl ALM �r r •� LAGUN Y.r r••.r. y •. L f • c r-. BEACH jx�' ,' SM� r A \\ � ram. ' • A rr•r,� 1� \ 1 erc I i �.l°° t ` • W Derr N IAA UNA t•tMl••/H '� w wu O �, •r', rfrt r< UL ada am r f? L s r•r.r'.ur MJI �• k• �r ;; 01 .. SAN 1U N PISTRANO Y ~' Af�rr�l � •.�r r�^ • DANA O a•r, .•o-� a 'S4 rn �e � `° MNT a• \ PONT 42 0 EXHIBIT IV-8 DEMAND FOR REGIONAL ANCHOR STORE FLOOR SPACE Five Mile Trade Area --Laguna Niguel Corridor Impact Area 1990 1995 Population in Trade Area Total Gen'l Merchandise: Floor Space Demand Floor Space Supply Residual Demand Gen'l Merchandise --Off Reg Mall: 10 Floor Space Demand Floor Space Supply Residual Demand Total Home Improvement: 173,200 211,600 1,210,841 1,479,296 1,610,434 -399,593 363,200 530,375 -167,175 1,610,434 -131,138 443,725 530,375 -86,650 Floor Space Demand 273,829 334,540 Floor Space Supply 324,767 324,767 ------------------ Residual Demand*-50,938 9,773 *While this analysis does not indicate sufficient residual demand to support a regional -type home improvement store, the freeway location would provide visibility advantages not available to -the maJor competitors, thus enhancing the viability of a site in this area. Source: Alfred Gobar Associates, Inc. 43 ALFRED GOBAR ASSOCIATES CHAPTER V FISCAL IMPACT RELATIONSHIPS Exhibit V-1 is a summary of generic projections of City revenue potential from various types of land uses that might represent potential to mitigate loss of sales tax and property tax revenues associated with development of the freeway interchange. The most fiscally efficient land uses on a per acre basis are hotels and motels. Some types of retail uses, especially auto dealerships, can also generate substantial sales tax revenues. Revenue estimates in Exhibit V-1 are based on "average" market performance of new car dealerships in Orange County. Major home improvement stores such as the Home Depot generate substantial sales tax revenues and moderate ad valorem property tax revenues. Home improvement outlets of this type are a regional use that may be feasible in the study area despite the rather thin estimates of untapped demand for this type of use described in Chapter IV. Regionally -oriented appliance stores can generate very high volumes, although a conventional appliance store is not a significant source of sales tax. The bulk of City potential revenue from offices is derived from ad valorem taxes and the high value per acre associated with office development. Other studies which are being carried out concurrent with this analysis are attempting to formulate land use and circulation plans for each of the two alternative interchange configurations. These studies 44 0 ALFRED GOBAR ASSOCIATES may identify potential locations for development of mitigating revenue generators based on the uses described above. Preliminary discussions have also mentioned the possibility of locating a regional transportation center somewhere within the study area. This type of a development may provide additional opportunities for mitigation of the fiscal impact of the Transportation Corridor on the City of Laguna Niguel. Analysis of what these may be are beyond the scope of the current analysis. s 45 < �+ 4)0 N ND O O O -4W q N M N NO ao N .D ao .0 N ►� > > 41 oe O i+ ac O O I 1 t 1 1 a C q N 1 1 1 1 1 1"1 •• a w O U C U 00 .0 V < q U M L O Z L I- o u IL I— < O H a N q r 00 n •C Co N 10 OC ++ L •i O .+ M M •D N 9L c a (n u O M N Z AJ L < O CL w IL v J 7 W C W ac O N O O O V u c N GD > -+ f- N o0 O O a a ►+ V O N u Z w N O Z = •O I Z H � m V 01 u N M M dl HI UI• N L L 41 u u 41 a 41 = O -4 V U L L L L •.4 -4 X IL N < U U U U L L yj u � < •[ < < q q U N q O O N ►Gi � U N N C N LU W < Y t L � a q W S G O J v V 67 m E ►r r h V � < YI L W a •• G ++ •• .+ L V L6 r .. u G a q a U q u -. I- u E u u u E G •4 M < U. a+ < E a1 G rr q w +r o u o < ..+ .. 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? 0 ? p 6=311 3.11? ? 0 ? 63603106 1.227 ? 0 ? ? 636MI08 1.00 4MM 115590 U98M S W-73 I -DAY PROrERTTES DIC 636031D9 t.O7 LUM 49" 9178% MID-90, IPb3-79, A 79 PICO, RIOT& 63603110 1.03 291107 7991811 IMU7 GEM, ROMRT 63 ill .(A 60055 6i692 121717 Kul DOME &%03112 .51 W71 96W 115021 I ARIOI Be 63603113 1.51 6MU7 1%5U 1133131 iP77-15 SOUTATID, GEORGE 63603111 2.10? ? 0 ? ? 63603115 1.0 ? 0 ? ? 63603303 5.32 41W 919951 MUM LP77-58,A26 GLASS, GEWAE 63603301 1.71 2215 2215 OC FLOW COPW 636033a5 1.11 %O15 206930 4979 12201 318158 SAIWO, IDUARM 63603306 1.00 291%0 199UI 191281 Hills, 300% 63603307 .77 65M 127218 193213 VU-123,1955 LAG M ASSOCIACTI4 fvms 63603308 .% 292360 519754 812111 OL15M XItM, DOIWD 6360= 1.13 574113 "3959 Imam IF LAM MIGLEL LTD 636CUM 1.25 129235 560M IMOI 1123233 LP79-52,1P38I5,1P3d67,CP133d,AUI MMIDUALD 6360u 1.31 162511 309623 472331 CAPE ORIVE DMWATIML 63603c06 1.12 933369 2YA27 11701% UP77-50 CAMP", ROBS 63603i07 1.03 42MIL 79M 1216095 LP3566,LP36O<J,LP6147,tP86-28 C>LKH' ORISTIAM PITSSIOI 63603i08 .81 316121 NO 3169 13152 4180 5P87-15 ILAIR, DWMLD 63603110 1.29 574739 60M 1183675 OLIM2 LAG MA MIME DOUSTRIAL AM 63603111 .13 610% 2759 66M5 LA6t)w MIGLEI DCIL WAL ASSM 6%6D3112 1.08 98W 27" M162 4172 39%17 WAZM, RR 63601102 2.93 6SM7 65517 U1589t MI61E1 DMO'IM CO 63606 1.33 67297 206322 271619 CP1050, CP1238, CP13O9, CP1501 KLM81, STUNK 63601303 2.10 65363 I1t013 117901 11003 412313 OL276 KnJO 1, STUNK 63600M .18 2%37 2%V OC FLOW COITRO< DIST 63WIl 1.09 7M151 237783 316237 UV5371,C1195 P10I1.M LO U 6UW12 .21 tms 3006 OC FLOOD COI DIST 6UW13 2.17 19001 1%a% 16740 216806 627331 W%70,V5671 MARK, MOM 63601314 1.89 26982 26982 OC FLOOD CONTROL DIST 63601316 1.89 15580 080 MIRR DMORMT CO 6360L317 5.51 13313 133128 TT5569 MIGLE1 OEVELOPMT CO &%W19 . it 3366 3366 MIM DEVFIO'PFIIT CO Mum .72 173H 17359 con DEVE3 WMT CO 63606120 23.72 572332 572332 TM11-I01 MIM DEVELO?UT CO 63613I01 3.11 15575m 71915 2271315 WIE-L" MIQEI LTD 636i3ID2 2.79 IO O US36m 21%1510 WIE TIEATMES LID 63613I03 2.10 1000 tam via DE4i1011 TT CD 63613IO1 .27 6631 6631 con DEVELOPYEITT CO 63613I05 18.51 90 9000 COE1 DEVELO'IEMT CO 63613106 6.41 I%w 156082 MIGLEL DEVF1OUT CO 636U107 1.89 1000 1® MIM DEVELOPUT CO 63613106 .19 %59 96" MIGM DMOPfi)fT CD 6.WI09 .86' 0 Me DEVElaPf' w CO 63613110 I." 131 IM31 NUTM- 1OR MIER DIST 6360111 .29 938 938 MIGLB OEVELO UT CO 53 • Assessor Pw=I Intwutim for Lon Miguel Trwnportatim Corridor Sh* Ara (Pave 2) REAL PflOMlY VALUE: Kim TOTAL pyQ AP MD AM LAID B UIW# OTHER PROP VALUE ACTIONS 63720 M 3.06 90M 1610602 251%77 UP78-1207M6,SP78-11 STATE FAM WW 63720102 .92 =71 UM63 M4i36 tr4,42,UR81-50, tU o, JAPES 63M03 .93 617180 U9820 8670M LfiCl(,RICLw 6372D106 lD I29291 213W 362931 Mm' Loa 63MO5 .86 202779 287271 190050 SMINS, SRFRYLJ. 6372O1o6 .83 13" 366156 681836 ACTIVE RENTALS 1 SALES 63720107 .82 295W 5111% SOW UP79-62,979-71 FORMS Roo ASSOC 63720108 5.66 %975 373M 937160 I F]!S, JN 63720201 7.66 iom 1® CC FLOW COTTIROU DIST 63720202 3.51 1550697 1902762 3653269 LP78-11,W78-12,UP78-87,t>r78-88 ALLSI2i STORAGE 6372M 18.0 163Lla11O 6730000 19110WO t1f78-11,1�78-d8,5P78-11,SP8b-85 JAPES, RALM 6372MM .14 3617 1732 5369 !OLLTOM COR MTFR DIST 63720206 .69 1275M 1275M CAEOT ASSOCIATES 63720207 9.57 17O85LD 126551% 1WA96 I1P36-8t,lt°78-i3,IP82-73,YA82-d,SP82-53,5PE5-13� CAEDT ASSOCIATES UM107 1.06 599271 311%5 71OL6 1P83-81,1 81,011322 LA TIUMA BIEMA 6MI09 2.13 27M69 662917 ° 733386 VNIO SCMT, JMES Y. 6=109 3.61 o ? 63MIll .67 22dfl65 653812 69313 IZ313 872513 1P82-19 EI)a INTERMATID A INC 6Ml12 .76 16M 265103 6L55 62697 661TA TP82-112 BAMEE, RICH D 637221M 1.50 19M 119136 311193 AL11N, DENNIS 63722102 3.50 1178053 1297669 266M U%-W,tP3198,UPYA2,UP3U9,MM,DL130< ALLDN DENNIS 6 MlO3 .30 2m1M 2OMM LPU-79 ALIED, DENNIS 63722106 .31 25532 25532 ALM, DENNIS 6Y=06 .63 215575 39751 58" LP81-92,LPM4,VAM-2,UV6II9,W6976 %flL OIL CO. 63=07 1.90 18730 18730 COLIM OF ORAIR 637222D1 .03 60 60 ALLE71, DENNIS 637122Q2 .09 8s 8a AL1 N, STAIILEY 6372M 637231M .07 .67 88 162M 70006 ea 232W9 TPM78-61,Y7219 OI,FFY, TH01A8 MOM CORP 63723102 .21 70361 1685" 238885 VAAB)A MTAS, EVAME.OS 637231M .56 276719 1227M 3975M SMTER, YILLIM 637231% 1.11 3711OD 15219M 1005M 2®581 W85-77,9%-183 PATEL, PAAsml M. 63723105 .61 261319 3560 617766 tP81-23 I*4W SIMS 63723106 .6L 2616M 65695 rAM UY6676,DL1072 ROOT, PAIL 63723107 .69 6160M 2D91m C5130 UM1-10, V8162,Y7E29,YOM,SP89-135,9%-336? VEMIMRY pumm ow 6372310s .21 65763 61607 107170 Elm, EML 63723109 .13 1750" 98692 273791 V3267,OL1617 OTRA TWO 63723110 .01 6913 1251 6169 imS, W,M 63723111 .18 61557 67731 129M JOLES, MYIE 63723201 .06 88 86 AYM MIKITY DEVELOPM 637232D2 .03 60 tD SANGERSTER, YILLIM 6=3203 .03 60 60 0-CAL F3WIROI. DEVELOPERS 63723206 .03 60 to LE5-Gil ELW". DEVElWW 63723205 (D 0 CALVIN, TOW 637232m .09 88 8a BASK EDWLD 63735122 3.76 ism 1800 RO114 KUS ASSOC 63735123 5.m 290 2400 RULING HILLS ASSOC 63769106 11.92? 0 TT7776,LP86-15,SPM-13,AP86-0l,fPdL-01,1P83-82,SPs3-102 MUMS DE CAPISTRAIO ASSOC W74M 8.55' 0 T711219 COLITM.S DE CAPISTRAID ASSOC 63769202 7.37 303890 305890 TT11218,UMI-95 CUM OF DRANK 637492M .v 0 637.9206 5.56 367MI 367MI BRIDGEPORT TERRACE ASSOC 63769207 3.56? 0 PACESETTERS MCFES x 6374M 6.93 0 COUNTY OF ORAM 6375 m .632 0 ? VD.LAfUA ASSOC 54 �I Assessor Panel lrrfwution for Laguna Nivol Trarxatgtion Corridor Study Ara (Page 3) REAL PROPERTY VAUE: PERSOIML TOTAL OWER AP NO ACRES LAND d11LDDS OTHER PRO! VALLE ACTIONS 63750106 .66' 0 VILL MQRA ASSOC 63=09 12.03' 0 TT11217/E?,It83-13/ 11,1RE3-a3/ 103, VILLARM COW uPa3�o1sPa3-n, uPa3-13/sP13-11 63750110 6.74, 0 eauMQRA coons 63756I01 .99 96L3 9663 Calm' OF ORAW 63756102 3.69 3" 3" COUNTY OF MAK 6MI03 4.10 40567 60567 MOM OF WSE 63156105 .0 752 751 MO',LT*K16M ATM DIST W%106 .61 5912 W CMLIDATED SAN JACINTO 813 6MI07 1.03 99" 99d1 CWSMIDATED SAX 19D170 HILLS 63756106 2.56 2WI 2WI CO MIDATED SAN JACINTO HILLS 63756109 .17 f63 663 COIMir OF ORME 63 ilo 16.59 3L57D1 1760 52M CONSOLIDATED SAN 39MO MDLS 65i502Dd ? 139200 ATM 706933 65t50207 ? 4720M M90 676KI 65�50206 9.21 CM35 50767Lt 91S7979 654721M 1.97 92d91 9M RM5 tl6,TMWI37 OWL DE9F OPST CO W2102 1.E6 351M 351M PlE5-416,TM-137 NICK DEY OPM CO/M m 65412103 3.95 2MMO 269MC Ova OE CPIENT Coma CO 65c7210i Aga Iva 13m OWL DEYLOr1EOtF COME CO 3i6.22 OWN 0510299 3975M 76259i 9Al618789 Sam: City of Uwe Niguel ad Alfred Solar Associates, Ina. a 55 TRAFFIC ENGINEERING AND TRANSPORTATION PLANNING 2020 NORTH TUSTIN AVENUE • SANTA ANA, CALIFORNIA 92701 • TELEPHONE (714) 66;-0496 FAX (714) 667-7952 MEMORANDUM TO: Bob Lenard, City of Laguna Niguel FROM: Joe Foust SUBJECT: TRAFFIC REVIEW COMMENTS: SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR EIR DATE: November 26, 1990 I have reviewed traffic aspects of the draft SJHTC EIR and offer the following comments: 1. The Post-2010 travel forecasts indicated for Crown Valley Parkway (CVP) and La Paz Road appear to be substantially understated. CVP is forecast to decrease to 50 percent of its current volume without the SJHTC and decrease even more (68 percent) with the Corridor despite having an interchange at Greenfield. Likewise with the corridor the volume on La Paz Road will drop from a current 20,000 ADT 3-4-105 to 8,000 ADT, again despite its having an interchange. These future volume forecasts cast considerable doubt on the reliability of the basic design volumes upon which the design of the corridor is based. In addition, if such low volumes are used for the interchange/ramp configuration design or sizing the number of lanes, seriously under designed facilities will result. A great deal of the technical analysis is based 3-4-106 on these volumes and more realistic forecasts are essential. A number of other examples of questionable comparisons between existing and Post- 2010 forecasts occur but the point is that prediction of such dramatic reduction in 3-4-107 existing traffic on city streets, particularly those where new interchanges will be constructed is difficult to rationalize. 2. The Greenfield interchange is indicated as only a partial diamond (northbound on and southbound off). Construction of a full interchange at Greenfield would relieve the heavy traffic on CVP between I-5 and the SJHTC by providing a connection 3-4.108 to/from I-5 (south) at Greenfield. Considerably more analysis of this option should be conducted than is indicated in the EIR in order to make an informed decision on the configuration of the Greenfield interchange. ATTACHMENT "C" Bob Lenard • November 26, 1990 Paue 2 The Greenfield interchange is located to the south of all the toll plazas. As a result, it appears possible for traffic to exit at Greenfield without having to pay a toll. This will cause traffic to "divert" from their otherwise intended exit to Greenfield and 3-4-109 use city streets to "double -back" to their original destination arterial street. This would have significant negative impact on CVP -- an arterial that is already expected to be substantially over -burdened. 4. The analysis of the I-5 connection consists of a simple statement: "In general under Alignment #1 access to the corridor is indirect: ..(traffic) would use an interchange at Greenfield Drive." This very sensitive issue deserves a complete section devoted entirely to this question including development of a third alternative which includes full interchange capability at Avery/Pasco de Colinas consideration of traffic costs, and other associated impacts, rather than this overly brief treatment. The primary difference between Alignment 1 and 2 from a traffic circulation viewpoint is that Alternative 2 provides full interchange with I-5 and the SJHTC at Avery Parkway/Paseo de Colinas, whereas Alternative 1 does not. Additional evaluation of the potential to incorporate the circulation advantages of a full interchange at Avery/Paseo de Colinas with Alignment 1 needs to be included in the EIR. Such information is essential for a comparison of the two alternatives, and in fact, may represent a third alternative whose benefits exceed either of the other two. Such an alternative would retain a direct connection to Camino Capistrano and preserve existing businesses. Both of these are critical issues with the City of Laguna Niguel. 3-4-110 I* 3-4-111 G UN9�� c �p q</F O RN November 26, 1990 Mr. Steve Let ter ly Manager of Environmental Impact Transportation Corridor Agencies 345 Clinton Street Costa Mesa, California 92626 Dear Mr. Letterly: This correspondence documents official comments by the City of Laguna Beach relative to the draft Environmental Impact Report for the San Joaquin Hills Transportation Corridor. The comments are in three portions: 1. Some brief comments regarding air pollution and drainage which are contained within the body of this letter. 2. A report dated November 1, 1990 which describes in detail our concern with the environmental documentation. 3. A set of attachments numbered Exhibits 2-8. The City Council authorized the submittal of these comments at its meeting of November 20, 1990. During that meeting, members of the Council referred to the comments which are being submitted by the South Coast Air Quality Management District. The Council is extremely 3-5-1 concerned that the growth -inducing impacts of the new roadway will actually exacerbate air pollution in South Orange County rather than reduce pollutants as intimated in the Environmental Impact Report. The City Council is also concerned that the information in the EIR discussing storm drainage facilities is inaccurate. First, the EIR references a 400 cubic foot per minute drainage channel along Laguna Canyon Road; such a channel does not exist. Also, the large retention 3-5-2 basin on El Toro Road is currently being modified by Orange County. The characteristics of that modified basin need to be incorporated into the EIR since that basin will no longer have its previous capacity to retain water at the 100-year flood level. Very truly yours, Kenneth Frank City Manager cc: City Council Enclosures 505 FOREST AVE. 0 LAGUNA BEACH. CA 92651 TEL (714) 497-3311 FAX (714) 497-5672 f COMMENTS ON DRAFT ENVIRONMENTAL IMPACT REPORT/ ENVIRONMENTAL mWACT STATEMENT FOR THE SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR November 11 1990 The following comments regarding the Draft Environmental Impact Report/Environmental Impact Statement (hereinafter "DEIR") are submitted by the City of Laguna Beach (hereinafter "City"). General comments are followed by more specific comments related to the adequacy of the DEIR and conformance of the proposed project with ocher applicable statutes and local regulations. Laguna Beach has consistently opposed the development of the San Joaquin Hills Transportation Corridor (hereinafter "Corridor"). The City is in the unique position of supporting their opposition to the Corridor with specific actions to limit development which 3.5.3 would require that a Corridor be built in the San Joaquin Hills. Most recently, the City has supported the purchase of the land comprising the Laguna Laurel Planned Community. The Corridor poses the largest threat to the Laguna Greenbelt and other contiguous open space lands of any recent development project to date in Southeastern Orange County due to the magnitude of the project and extent of its adverse environmental effects. Development of the Corridor through the heart of these committed open space areas is the equivalent of painting with indelible ink 3.5.4 a thick black line down the face of the Mona Lisa. Surely, any 16 year old link between the open spaces and the Corridor warrants rethinking given what is now known about the fragility of ecosystems and the irreversible effect of fragmenting open space habitats. In August 1988, the City submitted extensive comments on Draft Environmental Impact Report 1494, hereby incorporated by reference and attached as Exhibit 2. Kmong the comments raised by the City was that the Corridor project was an outgrowth of a study completed over 14 years ago, the Southeast Orange County Circulation Study (SEOCCS). The City commented: "It would make good planning sense to reevaluate the course set by the 1974-76 SEOCCS study prior to taking any action which simply carries out a twelve -year -old mandate". The Draft Summary 1991 AQMP Amendment supports the logic of rethinking old solutions to traffic congestion: 1 3-5-5 "No matter what the legal mandate, funding . sources or political emphasis, the solution to traffic congestion and air pollution will contain some basic elements. We will need to alter the course of our travel behavior, work habits, and land uses from the past". Draft Summary 1991 AQMP, at page 3 of Introduction Section, incorporated by reference and attached as Exhibit 1. Contrary to such logic, Caltrans and the Transportation Corridor Agency (hereinafter "TCA") approach has been, and continues to be one which assumes the inevitability of the Corridor and facilitates a continuation of past behaviors. The DEIR goes to great lengths to justify the obsolete proposal. For example, the DEIR concludes, based on faulty analysis and assumptions, that a massive new highway project can be designed to offset all air quality impacts. To the contrary, any project which increases the physical capacity of the roadway system, will only increase the number of vehicle trips and associated air quality emissions over time. The DEIR's assertion is illogical and unsubstantiated. Further, Caltrans and the TCA continue to ignore the possibility that alternatives to a primarily single occupancy vehicle oriented 3-5-7 Corridor may be the only route to a long-term solution. The City of Laguna Beach believes for the specific reasons set forth herein that the revised DEIR fails in every respect to comply 3-5-8 with CEQA and NEPA. The DEIR, like its predecessor, obscures the truth about both the problem and the possible solutions. Specific comments are set forth below in the following sections: I. The DEIR for the Proposed Corridor Project is Inadequate II. Major Unanswered Questions III. DEIR and Project Compliance with Other Applicable Laws IV. Exhibits i 2 • 3-5-6 The DEIR for the proposed project is deficient is at least the following respects: The DEIR Fails to Adequately Describe the Environmental Setting The environmental setting provides the basis for evaluating the impacts of a particular project. As such, if the description of 3-5-9 the environmental setting is flawed, the DEIR's analysis of potential environmental effects is likely to be fatally flawed. Aspects of the environmental setting which have not been adequately described include, but are not limited to, the following: 1) the number of significant animal species inhabiting the area affected by the project including but not limited to deer, mountain lions, 3-5.10 coyote, reptiles, birds and other animal species, (it is noteworthy that as part of the Foothill and Eastern Transportation Corridor studies, extensive deer tracking and study of the herds is being done, but no such study is being done for the SJHTC) , 2 ) the I3-5-11 nature of the natural sedimentation system in the area affected by the project, 3) the true extent of affected wetlands, and other aquatic resources (i.e. the affected area is described as only one - 3-5-12 quarter mile from the Corridor, yet impacts of grading and long- term runoff effects do not respect this arbitrarily constrained study area), 4) an accurate and complete description of theJ3-5-13 existing background air quality and 5) a complete list and description of affected public open space areas affected by the �3-5-14 project. Documents included in our comments as Exhibits should be evaluated 3-5-15 as part of the effort needed to accurately complete the setting sections. The DEIR Fails to Adeguately-Describe the Project The DEIR fails to adequately describe key features of the project in sufficient detail to allow adequate analysis of project impacts 3-5.16 and mitigation measures. Such features include but are not limited to the following: - The proposed grading of the project. Graphics should be provided which show major cut and fills linked to geographic features as shown in Exhibit 3, attached hereto. Currently the text only states that the cuts and fills in excess of 40 feet are considered significant. To the contrary, the DEIR should indicate 3-5-17 with clear graphics and text what specific canyons are subject to filling and what ridgelines and hills will be cut, and illustrate the extent of such cuts and fills, (e.g. X feet of cut/Y feet of fill for each landform) 3 so that the public and the decisionmakers can visualize 3-5-17 the true extent of such earthwork on the landscape. Economic aspects of the proposed project. The DEIR contains allegations that other alternatives are infeasible for financial reasons including but not 3-5.18 limited to a dedicated HOV facility. Yet there is no information in the DEIR to support such claims. This key economic information must be provided in the DEIR. Key aspects of project construction including but not limited to construction phases, duration of construction, effects on traffic congestion, number of truck and employee trips associated with construction, 3-5-19 areas subject to dewatering and blasting, duration of dewatering and blasting, spoil sites and extent of spoils in terms of duration and coverage, sites for disposal of excess fill, as well as other aspects of construction. Information about the operational aspects of the project such as how long the project will exclude HOV lanes, how long the project is expected to be functional, (i.e. over what duration will project impacts continue to cumulate) over what period will tolls be collected, how much will travel on the road cost now and in the future, as well as other operational information which will have physical environmental ramification. Absent this information, the public and decisionmakers cannot weigh project alternatives such as increased tolls with up- front HOV lanes. impact discussion 3-5-21 analyzed. In addition, it is not clear in each what the specifics are of the project 3-5-20 The description of the design of drainage features, retarding measures and other engineering features, 3-5-22 including a foreseeable light rail component of the project, is incomplete. The failure to disclose in adequate detail, key project components will impair decisionmakers ability to balance the projects benefit 3-5-23 against its true environmental consequences and to weigh other alternatives fairly. For example, failure to adequately describe the construction impacts associated with the project make it impossible to accurately quantify air quality, traffic, hydrologic 3-5-24 and biologic effects, among others. A revised and thorough project description must be developed and 3-5-25 impacts reanalyzed based on the complete information for the DEIR to be adequate. 4 • 0 J r 0 0 Caltrans and the TCA have improperly described the project as just the San Joaquin Hills Transportation Corridor. Clearly the project is not limited to the San Joaquin Hills Transportation Corridor, it is the SJHTC in combination with the Eastern (ETC) and Foothill (FTC) Transportation Corridors. As described in the DEIR: "The SJHTC and the ETC and FIC are identified as integral components of the regional transportation system designed to serve the circulation needs of the existing and planned development in Orange County and the surrounding area". DEIR at Appendix E, page 1. The Corridors are being planned at the same time, by the same Agency. They are interlinked and dependent upon each other to purportedly solve the regional traffic problem. Indeed, one TCA member has referred to the three Corridor links as the "beltway", implying that a single transportation system improvement is being planned and constructed. The City believes that the only legitimate approach under CEQA would be to complete a single EIR/EIS on what is clearly one integrated new freeway system. Absent this approach, the true impacts of the total project cannot be known or considered in the decisionmaking process. More importantly, true project alternatives will not be addressed. The Study Area Boundaries Are Artificially Constrained and Therefore Comprise a Faulty Foundation for the DEIR Analyses A key guiding factor in the selection of project alternatives as well as impact analyses, are the study areas established for analyzing project -related and cumulative effects. Where the study area is limited in size to an area smaller than the area in which impacts occur and cumulate, a fatal flaw exists that carries through all impact and alternative discussions throughout the document. The largest study area boundary for any impact appears to be the Southeastern orange County Subregion as shown on DEIR Figure 4.4.1. The Area of Benefit (AOB) for the Corridor was used in the cumulative impact analysis. This area appears to be similar in size to the Subregion. The selection of these artificially limited study areas are nothing short of remarkable since the DEIR itself describes reasons why the DEIR should at the very least have based impact analyses on the entire County plus areas outside of the County. Excerpts from the DEIR which suggest a larger study area is warranted include but are not limited to the following: 1. 11... the TCA and Caltrans are presently participating in studies for the Eastern and Foothill Transportation Corridors. 'These studies may eventually affect the .' 5 -26 3-5-27 3-5-28 transportation system in this area of the County and 3-5-28 ultimately growth in the region." Appendix E, at 1. 2. "The SJHTC and the ETC and FTC are identified as integral components of the regional transportation system designed to serve the circulation needs' of existing and planned development in orange County and 3-5-29 the surrounding area. Specifically, all three Corridors are included in the Regional Mobility Plan (RMP) as necessary links in the regional circulation network." Appendix E, at 1 and 2. 3. "...20% of the traffic on the Corridor is expected to! be regional through traffic which will traverse the entire Corridor. Reduction in these long-term traffic volumes would require down zoning in more than one County. It is unlikely that San Diego County, Los Angeles County and Riverside County and a multitude of local jurisdictions could act to eliminate the existing and future sources of regional through traffic." DEIR at 2-31. 3-5-30 The geographical size of the project area is "artfully" and artificially constrained so that the project -related and cumulative 3-5-31 impacts are minimized. A study area for each impact and each cumulative impact should be identified which reflects the true extent of the area in which impacts will occur and cumulate. Other 1� deficient specific study areas identified in the DEIR include but are not limited to the study are for wetland impacts in only one - quarter mile from either side of the Corridor centerline. DEIR at 3-5-32 4-73. This area cannot possibly encompass the area of impact of the Corridor runoff, sedimentation and grading on such resources areas. Perhaps the best example of how this constrained study area renders the DEIR inadequate is the air quality analysis. A severe air quality problem exists in the South Coast Air Basin. The Air Basin is a non -attainment area for ozone, carbon monoxide, and particulate matter less than 10 microns in diameter. Given these 3-5-33 severe air quality problems, it is crucial that the DEIR and decisionmakers carefully consider air quality impacts of this and other related Corridor and roadway projects. See Exhibit 4, "Inventory of Current Conditions", incorporated by reference and attached hereto. To the contrary, the DEIR confines its analysis of air quality impacts, both project -related and cumulative, to a fraction of the approximately 13,350 square mile air basin in which air pollutants cumulate. Because air quality depends upon the synergistic effects 3-5-34 of air emissions generated by projects throughout the air basin, consideration of the cumulative air quality impacts solely within an area that represents a very small percent of the entire air 6 0 basin will necessarily understate the severity and significance of 3-5-34 cumulative air impacts. The DEIR could have reasonably and practically considered the air quality impacts generated by projects within the entire air basin. 3-5-35 Such information could have readily been obtained from the South Coast Air Quality Management District. Similarly, the geographical size of the study area used to analyze traffic impacts is artificially constrained. The DEIR could have, and should have, at the very least used a study area that 3-5-36 encompassed Othe Countytwhere the impacts ofand the areas theimmediately rridorto eNorth System and South of (SJHTC, ETC and FTC) will cumulate. The Alternatives Discussed in the DEIR Represent an ' nadeaua a Range of Alternatives The alternatives analyzed in the DEIR are also artfully and l artificially constrained by the narrowly defined study area and the project focus on single -occupancy vehicles, allegedly in part due to the funding connection. Contrary to the approach taken in X the DEIR, CEQA requires the alternatives analysis to describe a range of reasonable alternatives to the project and to its location that could feasibly attain the project's legitimate objectives. The discussion must focus on alternatives capable of eliminating any significant adverse environmental effects or reducing them to a level of insignificance, even if it would be more costly or would impede, to some extent, the project objectives. The instant DEIR appears to both take credit for former alternatives analyses contained in prior DEIR 494 and at the same time states that "Draft EIR No. 494 has been superceded by this EIR/EIS..." . DEIR at S-6. The fact is that no environmental review document to innthe addition, r nor has analysisadequately hasbeenaddressed made projectof an alternative to the Corridor System (e.g. the SJHTC, ETC and FTC). 3.5-37 3-5-38 The approach Caltrans and the TCA have taken to attempt to solve traf f is problems is a piecemeal approach based on outdated planning documents, including the County Master Plan of Arterial Highways, the SEOCCS study, and largely outdated technologies. - Single- 3-5-39 occupant vehicle oriented roadway projects have never improved traffic flow over the long-term. See Exhibit 50 "Eight Myths of Traditional Traffic Planning" and Exhibit 61 "Traffic Congestion and Capacity Increases" hereby incorporated by reference and attached hereto. Because the environmental consequences of the proposed Corridor are so severe, and the project"s 'contribution to a traffic 3-5-40 solution, particularly a long-term solution, is dubious, this 7 ro'ect should not be pursued prior to a comprehensive analysis of13-5-40 . p 7 needed and potentially effective region -wide solutions. In order to determine what may be effective region -wide improvements, a revised County Circulation Master Plan is needed along with a comprehensive review of options. Such options on a region -wide basis which should be evaluated include but are not limited to the following: 1. Regional and subregional land use changes that would make use of the existing network at its present size and foster transit use, walking and other modes of non - single -occupant vehicle transportation. Such subregional land uses changes might include the addition of employment in lieu of more housing to South - Southeastern County and City areas so that fewer people would need to use the I-405 during the peak periods to commute to work. Clearly the I-405 is adequate to serve existing population demand for travel in a south direction in the a.m. peak period and north in the p.m. peak period within the subregion. The congestion problem comes from southern commuters to northern area jobs. As such, the creation of additional jobs in the southerly communities of the subregion, and affordable housing within the northerly communities of the subregion (e.g. within Irvine Spectrum and IBC) could go a long way to alleviate the need for the Corridor. However, the DEIR is silent on this possible alternative. In addition, "committed" projects could be revisited by the County based on health, safety and welfare of the residents of the County including long-term declines in air quality and traffic circulation. Housing commitments could be traded out for job generating land uses, and/or development rights purchased or transferred so that jobs and housing truly would be balanced within a smaller subregional area than that contemplated by the DEIR. 3-5-41 3-5-42 3-5-43 2. County roadway improvements only for High Occupancy Vehicle Use (HOV). One alternative would be to construct additional HOV dedicated lanes on existing routes with carpool occupancy requirements of 2 and 3 3.5-44 persons per vehicle. Another would be to modify existing roads into toll roads to pay for the construction of HOV dedicated Corridors. Again, the DEIR is silent on the feasibility of such alternatives. • 3. Light rail on existing freeways and/or major arterials. The SJHTC quite possibly precludes future use for light rail due to the steep terrain. Given the passage of 3-5-45 numerous transit funding measures (e.g. Propositions 8 0 • 111/116/la8), it would seem premature to implement single -occupancy vehicle oriented roadway improvements which preclude future development of light rail, until alternatives made possible by the passage of these 3-5-45 Propositions are studied in full. The DEIR is silent on possible alternatives based on these and other recently approved funding sources. The DEIR is also silent on how these funding sources may affect the feasibility of rejected transit/HOV oriented alternatives. 4. Maintenance of a capacity constrained transportation 3-5-46 system, with the addition of HOV lanes and other transit opportunities, to encourage trip reduction. According to "Traffic Congestion and Capacity Increases", Exhibit 6, the list of types of impacts congestion has on 3-5-478 behavior include the following: - People forego trips thex would otherwise like to make; - People leave for work earlier or later, and return 3-5-47b from work earlier or later, resulting in spreading t the peak periods; - People will try to find alternative routes that • are less congested, often moving off the freeway 3-5-47c onto arterial streets, until the streets are as congested as the freeways; - To avoid some of the time taken up in travel, people will chain trips together, such as stopping 3-5-47d at the bank or cleaners on the way to or from work; - People will choose closer destinations, exchanging a more desirable but more distant location for some 3-5-47e activity for a closer, but less desirable one; - If alternatives exist, people will change mode of travel, electing to use carpools or transit in 3-5-47f preference to driving alone; and - In the long run, people will relocate. their residences to be closer to work or other attractions and reduce the amount of travel 3-5-479 required to conduct their normal day-to-day activities. In fact, there is no analysis of what incentives will be necessary to achieve an.. --.average vehicle occupancy rate of 1.5 • persons by 1999 as required by the Clean 3-5-48 Air Act. It would seem that such an analysis is �tIV 9 integral to the approval of the proposed project • inasmuch as the project DEIR assumes that this 3-5-48 requirement will be met. Empirical evidence suggests that as long as new roads are made available, people will not change entrenched habits such as driving alone. These and other alternatives should be evaluated in the DEIR at an I3-5-49 equal level of detail as the proposed project. Alternatives Described in the DEIR Are TnadeSZ a iy nalyzea Discussions of alternatives in the DEIR are deficient in at least the following respects: 1. Numerous alternatives are rejected for reasons which are not adequately substantiated by information or evidence contained in the DEIR. Such prematurely rejected alternatives include but are not limited to no project at this time, an HOV dedicated project, additional HOV lanes on this or other existing roadways, 3-5-50 additional provisions for animal crossings, and a wetlands avoidance alternative. Particularly in light of the passage of new funding sources for transit and HOV dedicated improvements, the DEIR should provide a revised analysis of the feasibility of rejected alternatives. Given the likelihood that the proposed project will not achieve stated project objectives, (see discussion 3-5-51 below), additional evidence to support rejection of these and other alternatives is warranted. 2. The discussions of comparative impacts of the various project alternatives to the preferred alternative(s) are vague and non -quantitative. Discussions comparing the various project alternatives should be revised to include specific, quantified information about their 3-5-52 respective impacts to sensitive resources, air quality, traffic, noise, land uses and the like. Absent quantitative information regarding the alternatives, informed decision -making is not possible. The Proposed Project Is Unlikely To Meet Project bjectiyp& As the "Eight Myths of Traditional Traffic Planning", Exhibit 5, points out, the legitimate objectives outlined in the DEIR will likely not be achieved by the proposed project for the following .3-5.520 reasons: 1. Traffic expands to fill the available road space. r� 10 } 2. Travel patterns are the direct result of government 3-5-52b policy. 3. nigger roads do not improve people's mobility. I 3-5-52c Excerpts from "Traffic Congestion and Capacity Increases", Exhibit 6, regarding the affects of expanding roadway system capacity further support these reasons as follows: 3-5-53a Trips that have been foregone because of congestion will not be made. This will result in an absolute increase in numbers of trips using the facility that has been axpanded. eak Surea There will be a reduction in peak -spreading from people no longer delaying trips or starting.early to avoid congestion. This will result in a shift of trips between the traditional 3.5-53b off-peak periods to the peak periods and is likely to restore the pre -capacity increase level of congestion in the peak. Route Changes Trips that may have used parallel or nearly alternative } routes, in order to avoid congestion, may now divert and take 3-5-53c the new facility, if the capacity increase boosts travel speeds above those of competing routes. Chained Traps Trips that have been made as part of an existing trip through trip chaining may now be "unchained", effectively adding more trips to the total. In particular, home -to -work trips that 3-5-53d may have been used for side trips to shopping, banking, other personal errands, etc., may now be replaced by several "out - and -back" trips from home for the sam purposes. Destination Chan Trips made to nearby, but less -desired locations may now be made further -away, more -desired locations, leading to an increase in trip lengths and therefore lengthening the 3-5-53e distances that trips are made on the expanded facility. Mode Changes People who have chosen to use transit or carpools will now return to using solo drive. This will also result in an 3-5-53f absolute increase in auto trips on the expanded facility. li �Zrmwblm"- in the longer term, if congestion levels are lowered for sufficient time, developers can be expected to seek 3 -53g additional development that will increase the number. of residents and jobs in the vicinity of the expanded facility. Exhibit 6 at pages 9 and 10. Not only does the DEIR fail to address these likely impacts of the proposed project, it fails to adequately analyze alternatives which would reduce or avoid the above -listed impacts. According to the publication "Traffic Congestion and Capacity Increases", "To ignore the effects we have listed here will result in severe overestimates of the beneficial effects of capacity -increasing projects and severe underestimations of the negative impacts of such projects". Exhibit 6, at page 10. The City believes, based on this, that the project DEIR has grossly overestimated the beneficial effects of the project as well as grossly underestimated adverse project -related and cumulative effects. The DEIR Fails to Adequately Address A Number of Probable Significant Adverse Effects of the Project 3-5-54 Impact discussions contained in the DEIR are inadequate, incomplete and in some cases, flawed, for at least the following major 3-5-55 reasons: 1) the bases for adequate impact evaluation, adequate setting and project description discussions are missing, 2) the study area boundaries for all discussions do not include the whole I3-5-56 area where project impacts will occur or cumulate, and 3) faulty assumptions have been made about project impacts. 3-5-57 Discussions of impacts that have either been omitted or are inadequate and must be revised include the following: 1. Traffic -related Impacts Traffic -related impacts to the local and regional roadway network which will result from implementation of the Corridor as a toll facility are inadequately addressed in the DEIR. According to "Traffic Congestion and Capacity Increases": "[w]hen capacity is added to the system, several impacts can be expected to follow, particularly when the capacity is added for congestion relief". Exhibit 6, at page 9. Such impacts include those listed above at page 11. The DEIR analysis failed to consider or analyze these impacts as well as the beneficial impacts of capacity constraints (e.g. foregone trips, carpooling, increased use of transit, and the like). As a result of these omissions, traffic benefits of the project are very likely to be greatly overstated and impacts severely understated. 3-5-58 12 • In addition, the traffic analysis is based on a number of other faulty and unsupported assumptions including but not limited to that 1.5 will be the prevailing number of persons 3-5-59 per vehicle, that other regional road projects will be completed including but not limited to the ETC and the FTC, among others. other faulty assumptions upon which the analysis is based include but are not limited to: faulty trip distribution and analysis based on buildout of the MPAH projects. An analysis should be done which assumes no such buildout. 3-5-60 - All traffic forecasting is imperfect. The DEIR should provide tables and graphics which show the 3-5-61 likely error rate in such estimates and the worst case implications of such error rates. - The traffic data utilized represents only a 2010 time -frame, no where close to the period the Corridor will be in operation. The traffic analysis likely understates true impacts because 3-5-62 of this relatively short time frame from the standpoint of traffic and air quality analysis where a major improvement is being proposed. - County data should be correlated with City traffic . data. What specifically are the differences between the County data and City traffic model data as used in the Corridor DEIR? How are the 3-5-63 differences accounted for and what implications do the differences have on traffic and air quality? The cumulative traffic analysis is also grossly deficient due to the artificially limited study area which in -turn limits the cumulative projects considered in the study. It 3-5-64 is not clear whether the ETC and FTC, as well as other major related projects were considered. Where related projects are not grouped together for air quality analysis purposes, 3-5-65 segmentation masks the full air quality impacts of a project. Traffic impacts are only discussed within the limited study area, despite the fact that at least 20% of trips are projected to be through trips, and thus will cumulate beyond the AOB study area. Similarly, the land uses which may 3-5-66 contribute trips to the Corridor, but that lie outside the AOB are not included in the cumulative traffic analysis. As a final note, the Final Report of the Growth Management and Transportation Task Force to SCAG suggests that an update of the transportation model database is badly needed. This 3.5-67 in tern suggests :..,that air quality improvements currently being predicted as part of the AQMP update are overestimated 14-4 13 2. 3. 4. and unsupported. Sze Exhibit 7, at page E, hereby 3-5-67 incorporated by reference and attached hereto. Nuisance Water Discharge Impacts Impacts to wetlands, riparian corridors and the Pacific Ocean as a result of discharged nuisance water are underestimated due to the faulty analysis contained in the DEIR. While the DEIR suggests that such impacts will be insignificant, there is no evidence to support such a conclusion. The DEIR relies 3-5-68 upon a report, the 1987 Ford Report, completed for the Irvine Coast project, to conclude that impacts to the quality of water in the marine environment would be insignificant. Quite clearly, this report did not address the impacts of the proposed Corridor. Sedimentation Impacts The impacts of the addition of a massive roadway coupled with mitigation such as retarding measures on natural 3.5-69 sedimentation processes has not adequately been addressed. A complete evaluation of how the project will affect sedimentation of wetlands, riparian corridors and beach sand I 3-5-70 replenishment must be included in the DEIR. Impacts Associated with Spoils Disposal • Spoils sites alone can be extensive in size and result in additional runoff problems, as well as other impacts such as loss of habitat and air quality impacts. The DEIR fails to identify the selected spoils sites and to address the likely impacts of the use of these sites for spoil disposal until 3-5-71 spoils can be permanently disposed. Since this DEIR is likely to be the last opportunity for public review of the project, spoils disposal sites, both long and short term, must be identified and the secondary impacts associated with the proposed sites addressed. 5. Cumulative Impacts to Wetlands The DEIR fails to address the cumulative loss of wetlands as a result of the implementation of the project in combination with other committed and foreseeable projects in the region including but not limited to the ETC and FTC. Absent such 3-5-72 an analysis, the loss.of.even an acre of existing wetlands cannot be' adequately weighed in terms of its significance. The analysis should include an overview of the historic loss of wetlands in Southern California. In addition, the extent of existing wetlands are underestimated. Some existing wetlands have even been 3-5-73 omitted from the DEIR including but not limited to the 14 . 0} 6. 7. wetlands near Laguna Canyon road, impacted by the proposed 3-5-73 project. Impacts to Wildlife Impacts to wildlife populations and interrelationships must be evaluated as a result of the Corridor interfering with natural wildlife movement and direct loss of wildlife as a result of the project. Both project -related and cumulative 3-5-74 potential losses must be quantified. Cumulative impacts must include the combined effects of the SJHTC, the ETC and FTC on wildlife populations. The fact that the SJHTC will cut in two a large, contiguous habitat area carries with it the potential for dooming the 3-5-75 area to no sustainable wildlife population over the long term. This likelihood has been born out in the San Diego area as Canyons have been separated. Among the specific questions in this regard that must.be addressed in the DEIR� are as follows: Based on current reputable scientific research, how large must contiguous open space areas be to sustain viable ecosystems including the species currently present or reliant on the area for habitat? 3-5-76 - Will the contiguous open space areas including the Irvine Coast, Aliso Viejo, Laguna Canyon and Irvine be fragmented to a. degree that the large mammals will 3-5-77 slowly decline and be lost from the area? - What are the current populations of large mammals in areas affected by the,project? How many of each of these are likely to be killed or relocate as a result 3-5-78 of project implementation? Where are such animals likely to migrate if the project goes forward? If the ETC and FTC go forward? - What is the long-term likelihood the ecosystem of the area will survive over the long-term (i.e. more than 3-5-79 the next 20 years) with implementation of the Corridor? Also, the DEIR underestimates the projects effects on wildlife because the document fails to represent the significance of wildlife in the County. See Exhibit 8, 3.5-80 "Endangered Wildlife and Habitats in Southern California", hereby incorporated by reference and attached hereto. Impacts to Recreation Areas The Corridor DEIR has historically pointed to the need for 3-5-81 additional access to serve regional recreation areas. Yet, 15 to date no analysis has been provided regarding the impacts of unlimited access to such areas or the need for additional of access. The DEIR should state the likely impacts of opening 3-5-81 up these areas to additional use and possibly overuse. 8. Air Quality Impacts Air quality impacts are based upon a number of faulty assumptions including but not limited to: 1) that traffic will be more free flowing and thus result in less emissions, 2) the County traffic information, which is imprecise 3) a 2010 study time -frame for the analysis, 3-5-82 4) an artificially constrained study area, 5) and omitted cumulative projects outside of the project study area, particularly projects within adjacent Counties. If the result of the Corridor is free flowing traffic, this result is likely to be quite temporary. A revised traffic analysis which considers the list of likely project affects summarized 3-5-83 at pages 9 and 11 herein, will likely demonstrate that free flowing traffic is an unlikely long-term result of the Corridor. The study area for the air quality analysis illustrates the general inadequacy and self-serving nature of all impact study areas utilized in the DEIR. The air quality analysis study area is confined to the Southeastern Orange County Subregion or, as stated in the DEIR, the "Corridor -level" region. The receptor sites for purposes of the analysis lie along the Corridor. Since the study area is subject to prevailing winds that according to the DEIR push the locally generated air pollutants toward Riverside County by day, it is not surprising that the receptor sites are predicted by the DEIR to be in compliance with State and Federal standards. (DEIR at 3-11, 4-34/35; "The onshore flow and nocturnal offshore flow keep much of Southern Orange County well ventilated". DEIR Technical Report 13 at page 2). The constrained study area in combination with the location of receptor sites along the Corridor alignment, the lack of cumulative projects considered outside of the study area and the limited project impact horizon (2010), among other faults of the analysis, render the air quality analysis inadequate for purposes of CEQA and NEPA. The DEIR should evaluate the air quality impacts beyond the study area, where the pollutants generated by the Corridor System will cumulate. In addition, the worst case air quality been done with toll operations in full likely to reduce traffic flow speeds. 16 analysis should have effect, since this is 3-5-84 3-5-85 13-5-86 0 0 •f 9. All Other Cumulative Impacts The DEIR fails to adequately identify and discuss cumulative impacts related to traffic; air quality; loss of wetlands, agricultural lands, open space and habitat' areas; water quality; growth inducement; wildlife; among other cumulative effects of the project in combination with similar projects both within and outside of the TCA's authority. Clearly air quality, traffic and growth inducing impacts cumulate with projects as far away as Riverside County. DEIR at 3-11. Traffic impacts cumulative with projects all over Orange County, as well as with Counties to the North and South. Yet, the cumulative analysis study area is confined to the subregion. 3-5-87 3-5-88 An adequate cumulative analysis must be completed for a realistic area in which project effects cumulative with other 3-5-89 projects. The analysis should at the very least ,Quantify the cumulative impacts of the Corridor System (SJHTC, ETC and FTC). 10. Construction Impacts s " The DEIR fails to adequately disclose and analyze construction impacts including but not limited air quality impacts. The DEIR does not quantify impacts such as 3-5-90 0' particulate matter released during construction despite the fact that the air basin is non -attainment for particulate matter. 11. Growth Inducing Impacts As stated in Exhibit 3, the likelihood is that developers will seek additional development once added road capacity is in place. The DEIR fails to analyze this likelihood that existing developed areas will redevelop at more intense levels, and areas not yet developed may be targeted for plan amendments to accommodate more intense development. Growth inducing impacts of the Corridor System should be analyzed in the DEIR. 3-5-91 The DEIR Fails to List Feasible Mitigation.Measures Reasonable mitigation measures to offset project -related and cumulative impacts which should be included in the DEIR include but are not limited to the following measures: QRen Space and Habitat Impacts 3-5-92 1. Dedication of a minimum of 2,000 acres of open space lands to compensate for lands impacted by, plus acres committed to 17 the Corridor. Areas for consideration should include land T3- 5-92 • within Laguna Canyon and the Irvine Coast. 2. Construction of bridges over the canyons for wildlife crossings. Fill of canyons, tunnels and culverts shall be 3-5-93 prohibited. 3. The entire length of the Corridor shall be fenced with I3-5-94 minimum 7 foot high fencing. 4. Mule deer tracking for the SJHTC herd to be undertaken prior to construction with results of the study used to refine 3-5-95 project mitigation measures related to the herd. 5. 3:1 mitigation for wetland loss in same watershed of impact. Bonding to be provided in case of replacement wetland 3-5-96 failure. 6. All Corridor planting shall consist of native plants. �3-5-97 7. A -mount from each toll to be placed into a fund for open space I3-5-98 purchase, maintenance and/or enhancement. S. Oak trees destroyed directly or indirectly by the Corridor project shall be replaced on a 15:1 basis from same species, minimum 20 gallon nursery stock. Alternatively the dollar 3-5-99 amount of each destroyed tree shall be placed in an open space fund. See Exhibit E. Water Ouality and Hydrology Impacts 1. Send replenishment to all beaches shall be ensured through 13-5-100 Corridor design. 2. Water quality in all discharge channels shall be Rec. 1. Water quality shall be monitored to ensure this standard is 3-5-101 met, and where not met, additional measures shall be implemented including but not limited to treatment. 3. The Corridor runoff plan shall ensure that runoff flows from the Corridor are less than or equal to existing runoff flows. Impacts 3-5-102 Tangportat; on and Air Quality The first phase of the toll road shall include HOV lanes. 1. At such time as the Corridor is paid for, all lanes shall be 3-5-103 converted to HOV lanes. 2. Bridges shall be constructed as fly-overs at Laguna Canyon Road and El Toro Road in lieu of berms. 3-5-104 1s • 1. Aggressive traffic reduction design measures shall be incorporated in all developments which generate trips on the 3-5-105 Corridor. 2. Where development rights have not been "vested" in projects that generate Corridor trips, the density/intensity of the 3-5-106 project shall be reduced to the maximum extent feasible. 3. All new development projects within the County shall be assessed to pay for additional open space purchases which 3-5-107 would eliminate future trips on the Corridor system. Mitigation measures that are included in the DEIR are inadequate for at least the following reasons: First, a number of purported "mitigation measures" are not mitigation measures but merely statements that promise future studies or plans will be completed. This approach to impact mitigation is inadequate because the approach does not allow for public scrutiny of the future studies or plans, and no certainty exists that project impacts will be mitigated. For example, Mitigation Measure 3-9 is as follows: 3-9 Prior to construction, a Runoff Management Plan will be submitted for review to the Manager Flood Program Division, OCEMA. The plan will include facilities required to route and detain runoff for the purpose of reducing pollutant levels in downstream drainages to below a level of significance... The public will have not opportunity to evaluate or critique the Plan, nor are the "facilities" called for in the Plan subject to review in this DEIR. Preparation of such a plan is not unreasonable at this stage of project review. The Plan should be prepared and made part of the project description for purposes of this DEIR. Another example of a non -mitigation measure is Mitigation Measure 7-3, as follows: 7-3 During the process of obtaining the required permits for encroachment into habitat areas, the TCA will prepare a wetlands mitigation plan and will coordinate with the affected resource agencies and local jurisdictions.... Again, the public will have no opportunity to evaluate and critique the Plan, nor can the efficacy of the Plan in reducing project 19 3-5-108 109 related impacts be determined at this time. A wetlands mitigation plan should be prepared and made part of the project for review in this DEIR. Specific mitigation measures, including the location, 3-5-110 extent, enhancement and monitoring program, should be set forth in the DEIR. A Plan, to be developed at a future date does not suffice as mitigation. In addition, it is not clear from the DEIR which mitigation measures are necessary to reduce impacts to a less than significant level. The extent to which specific measures reduce project- 3-5-111 related and cumulative impacts must be identified and where possible, quantified. Finally, contrary to CEQA, no mitigation measures are described in13-5-112 the DEIR to reduce or eliminate cumulative impacts. Contrary to CEQA, the DEIR does not reflect the independent judgement of the lead agency concerning the environmental effects of the project. The TCA, advocacy agency for the Corridor, along with other Corridor advocacy agencies, oversaw the selection of the EIR consultants and the preparation of the DEIR. Indeed, non - advocacy oriented Jurisdictions are not allowed to participate in the Agency. Thus, the DEIR does not reflect objective analysis and conclusions. 20 3-5-113 0 • .: i� MAJOR UNANSWERED QUESTIONS In addition to the above -stated questions, major unanswered questions which should have been addressed in the DEIR or response to comments document include but are not limited to the following: 3-5-114 1. To what extent is existing access to serve the regional recreational facilities inadequate? Please quantify the response. 2. What is the recreational user capacity of the existing open space areas, including future dedication areas which will be served by the Corridor? Are these facilities already used 3-5-115 to capacity during peak periods of use? Are support facilities for these areas at capacity during peak periods? 3. On what basis is it concluded that all MPAH projects will be implemented by 2010? Specifically, for each project, what 3-5-116 funding sources are being relied upon to reach the conclusions contained in the DEIR? 4. What is the likely reserve of fossil fuel for use as gasoline and the term of that reserve? If the term of the reserve is only 50 years as some reputable estimates suggest, what is the justification for completing a major new freeway project 3-5-117 ., for single -occupant vehicles. The DEIR states that the grade is conducive to rail 'or other types of of the route not transit. As such, does it make sense to dedicate this open space area at this time to what may be a major facility with short-term usefulness? ,5. How will the newly adopted Congressional amendment to the Clean Air Act affect the State Implementation Plan, (SIP) and the Federal Implementation Plan (FIP), and thus project.3-5-118 conformity with the SIP and FIP? Please describe applicable components of the Clean Air Act to the South Coast Air Basin and their likely affects on the proposed project. 6. What kinds of incentives will it take to achieve an average vehicle occupancy of 1.5 persons? Please provide specific 3-5-119 examples of jurisdictions where such incentives have proven successful and what those methods are. 7. Please provide examples of areas where massive new roadway projects have been constructed and the average occupancy of 3-5-120 vehicles has gone up, if any? S. What other major roadway projects are being contemplated in adjacent Counties? What other roadway projects, including major expansions, are being considered in Orange County? 3-5-121 (e.g. the proposed road through the mountains to Riverside County, others?). 21 • 9. At what point in time would light rail be considered along the Corridor? Is light rail feasible in the Corridor terrain? If light rail is likely to be considered over the 3-5-122 long term, why were the impacts of this part of the project not analyzed in the DEIR? 10. What is the anticipated cost of maintaining the Corridor each year once it is constructed? Are there sufficient sources of funds to maintain the Corridor along with other demands 3-5-123 for State funds to maintain roads? How will the anticipated 2 billion dollar deficit affect maintenance of roads? 11. Please provide a breakdown of the sources of funds anticipated•to construct the Corridor. Are sufficient funds presently available? What compromises have been made in the 3-5-124 design due to funding constraints? (e.g. wildlife corridors). 12. Exactly what approvals and by which agencies are needed between now and Corridor construction? Please provide an 3-5-125 anticipated chronology of future actions, including public hearings and opportunities for public input. 13. Exactly what approvals and by which agencies are needed between now and SIP/FIP approval? Please provide an 3-5.126 anticipated chronology of future actions, including public hearings and opportunities for public input. 14. Exactly what approvals and by which agencies are needed for a 4f sign -off? Please provide an anticipated chronology of 3-5-127 future actions, including public hearings and opportunities for public input. 15. Exactly what approvals and by which agencies are needed between now and construction of the ETC and FTC? Please provide an anticipated chronology of future actions, 3-5-128 including public hearings and opportunities for public input. 16. What, if any, funding commitments and by which agencies are l anticipated prior to construction of the Corridor? 3-5-129 17. In what specific respects does the traffic analysis in the DEIR differ from the methodology prescribed in Exhibit 6, at page 11? What would be the results of an analysis performed 3-5-130 pursuant to that proposed in Exhibit 6? 22 �� The Proposed Project is Inconsistent with the State Implementation Plan (SIP) Thereby Precluding Federal Agency Approval and Federal Financing of the Corridor We respectfully disagree with the conclusion contained in the DEIR that the project is consistent with the SIP. First, the governing SIP, the 1979 SIP, does not include or assume the Corridor. Even 3-5-131 if the Corridor would partially implement several of the transportation control measures listed in the 1979 SIP, this is insufficient for a consistency determination. the project should not be approved before the following' .Second, actions occur: 1) final action is taken -on the Federal the revised 13-5-132 Implementation Plan (FIP) required by Court order and SIP, expected in July 1991 and 2) the project is found to be13-5-133 consistent with the approved FIP and SIP. Again, it is not sufficient to find that the Corridor allegedly conforms with the 3.5.134 AQMP, since this document has not been approved as part of the SIP by the EPA. We incorporate by reference our comments of August 24, 1988 related 3-5-135 9` to specific inconsistencies between the project and the SIP. See Exhibit 2, at 27, attached hereto. The Proposed Project is Not Consistent with the Coastal Act Chanter 3 Policies The DEIR fails to analyze the proposed projects inconsistencies 3.5.136 with the California Coastal Act. We incorporate by reference our comments of August 24, 1988 related to specific inconsistencies between the project and the Coastal Act. See Exhibit 2, at 33, attached hereto. The Project Approval Would Be Invalid Because the County's Seneral plan is Inadequate In Ways Which Implicate The Project State law requires all land use approvals to comply with the applicable general plan. Development projects cannot be lawfully approved when the applicable general plan or one of its elements is inadequate and that inadequacy implicates the project._ Because 3_5-137 the County's general plan is out of date and internally inconsistent, project approval would be invalid. Specifically, the Master Plan' of Arterial Highways (MPAH), the County's circulation element, is over a decade old and based upon even older data. Since the MPAH was developed, countless specific development projects have .been approved. Yet, the MPAH has not been evaluated to ascertain whether, correlation between the approved land uses and -the proposed circulation element exist. '�l While EIR's have been completed for individual development projects 23 which purportedly address the correlation issue, no comprehensive, County -wide evaluation has been completed. Nor has the County -wide general plan undergone a comprehensive update since its adoption over a decade ago. 3-5-137 We incorporate by reference our specific comments regarding the General Plan of August 24, 1988. See Exhibit 2, at 29, attached hereto. The Proposed Project is Contrary to the Goals And Policies Contained in the Laguna Beach General Plan 3-5-138 We incorporate our comments of August 24, 1988 in this regard. See Exhibit 2, at page 36, attached hereto. The City believes that the alternatives analysis contained in the DEIR fails to demonstrate that there is no feasible and prudent alternative to the use of the land for the Corridor. As such, the 3-5-139 Secretary of Transportation is precluded from approving the project. In addition, the 4f analysis is deficient for among other reasons, the following: 1. A number of affected resources are not included in the analysis. Such areas include but are not limited to the Irvine Coast dedication area and the Laguna Laurel Planned Community. 3-5-140 1& 2. The analysis fails to adequately consider visual impacts to all affected resources including but 3-5-141 not limited to Crystal Cove State Park, the Laguna Laurel property and the Irvine Coast dedication area. 3. The analysis fails to identify feasible mitigation measures to minimize harm to affected areas. 3-5-142 The 4f analysis should be revised to correct the deficiencies-3-5-143 contained in the DEIR. s 24 LIST OF EXHIBITS 1. Draft Summary 1991 AQMP Amendment 2. 1988 Comments on the San Joaquin Hills Transportation Corridor 3. Example of Grading Graphic 4. Inventory of Current Conditions 5. Eight Myths of Traditional Traffic Planning 6. Traffic Congestion and Capacity Increases 7. Growth Management. and Transportation Task Force Final Report to SCAG 8. Endangered Habitat and Wildlife in Southern California 0 0 TABLE OF CONTENTS SECTION PAGE THE PURPOSE AND NEED FOR THE PROPOSED PROJECT HAS NOT BEEN ADEQUATELY ESTABLISHED 3 THE EIR FOR THE PROPOSED CORRIDOR PROJECT IS INADEQUATE 10 MAJOR UNANSWERED QUESTIONS AND UNSUPPORTED ASSUMPTIONS 25 EIR AND PROJECT CONFORMANCE WITH OTHER LAWS 27 THE PROJECT IS CONTRARY TO LAGUNA BEACH GENERAL PLAN 36 EXHIBIT 2 EXHIBITS 0 1. Newspaper Article, Los Angeles Times, August 12, 1988 2. Excerpt from Irvine Coast Development Agreement Draft Environmental Impact Report #486, page iv-2 3. Relevant State Park Practices Related to Carrying Capacity Limits 4. Toll Road Articles 5. Letter from CalTrans to Jerry Bennett, TCA, July 8, 1988 6. Information Table 7. Excerpt from Laguna Beach General Plan - Sensitive Species; Newspaper Article - Endangered Species a COMMENTS ON DRAFT ENVIRONMENTAL IMPACT REPORT # 494 FOR THE SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR SUBMITTED BY THE CITY OF LAGUNA BEACH August 24, 1988 The following comments regarding Draft Environmental Impact Report #494 (hereinafter "EIR") are submitted by the City of Laguna Beach. General comments are followed by more specific comments related to the adequacy of the EIR and conformance of the project with other applicable statutes and local regulations. Laguna Beach has publicly taken a position of opposition to the proposed San Joaquin Hills Transportation Corridor (hereinafter "Corridor"). The City has supported this position with specific actions to limit development which would require that a Corridor be built in the San Joaquin Hills. Specifically, the City has sought to preserve vast areas of open space within and outside the City in the vicinity of the proposed Corridor. Together these areas comprise the Laguna Greenbelt. The City is distressed that providing access to these protected recreational and resource areas is now being singled out as a primary objective for the Corridor's construction (EIR at 17). Clearly there is sufficient existing access to these areas to fill them beyond capacity. In addition, many of the areas are designated as "wilderness parks" whose principal purpose is the protection of the resources they contain. The failure to establish and document credible objectives for the project is but one of the flaws of the EIR. Equally disconcerting to the City is the deceptive and incomplete project description contained in the EIR. The project description describes the Corridor as a maximum 210-foot-wide facility. Elsewhere in the document are glimpses of the true nature of the proposed corridor: "The dimensions discussed [in the project description] are widths of the facilities without on and off ramps, or weaving and merging lane widths." EIR at S-8. "Alternative A right-of-way will vary from approximately 220 to 1,400 feet in width, with wider widths at interchanges from approximately 500 to 2,100 feet." EIR at 220. The faulty project description is the basis for evaluation of virtually all project -related impact analysis. For example, the water quality analysis is based on a Corridor 220 feet in width. The result is that the project impacts reported in the EIR are incomplete and inaccurate. In addition, the EIR fails to analyze a reasonable array of alternatives and mitigation measures which might reduce project impacts. If the true project and project -related impacts were revealed, the need for complete evaluation of alternatives to the Corridor would be apparent. "The purpose of an environmental impact report is to provide public agencies and the public in general with detailed information about the effect which a proposed project is likely to have on the environment; to list ways in which the significant effects of such a project might be minimized; and to indicate alternatives to such a project." California Environmental Quality Act (CEQA), Public Resources Code section 21000 et seq., 521061 The City of Laguna Beach believes for the specific reasons set forth herein that EIR #494 fails in every respect to comply with the requirements of CEQA and NEPA. In particular, EIR #494 fails to provide decisionmakers with complete and accurate information on which to base an intelligent and informed decision regarding the proposed Corridor project While the City has -taken a position of opposition to the Corridor, the City is also committed to participating in efforts which will lead to regional traffic solutions. The City looked forward to a Corridor EIR which would provide accurate and complete information about the traffic problem and describe a reasonable array of alternatives to solve the problem. Instead, EIR #494 obscures the truth about both the problem and the possible solutions. 2. THE PURPOSE AND NEED FOR THE PROPOSED PROJECT HAS NOT BEEN ADEQUATELY ESTABLISHED. 9r A clear statement setting forth the purpose and need for the project (project objective) is fundamental to both CEQA and NEPA requirements. This is because the ultimate decision related to a project may rest on which proposed alternative achieves the objectives of the project with the least amount of harm to the environment. If the stated project objective or objectives are not valid, a critical standard for the selection and analysis of adequate alternatives is missing. In the absence of a clearly articulated statement of legitimate project objectives, decisionmakers cannot properly weigh the choices between the "no project" alternative and other alternatives set forth in the EIR. In addition, since the project objective is the main criterion for selection of project alternatives for evaluation, the range of project alternatives is likely to be inadequate. In addition, since the Corridor's proposed alignment involves the discharge of fill material into waters of the United States, a permit from the United States Army Corps of Engineers will be required under section 404 of the Clean Water Act (13 U.S.C. 51344). Under section 404 (b) (1) of the Clean Water Act (33 U.S.C. & 1344 (b) (1) , the Environmental Protection Agency has promulgated guidelines governing the issuance of such permits by the Corps under section 404. that: The 404(b)(1) guidelines provide in pertinent part No discharge of dredged or fill material shall be permitted if there is a practicable alternative to the proposed discharge that would have less adverse impact on the aquatic ecosystem so long as the alternative does not have other significant adverse environmental consequences. (40 C.F.R. §23010(a).) In determining "practicability," the applicant's purpose and need with respect to the project must be considered. (Friends of the Earth v. Hintz 800 F.2d 822 (1986); Louisiana Wildlife Federation v. York 761 F.2d 1044 (1985). In addition, NEPA requires that the statement specify the underlying purpose and need to which the agency is responding in proposing the alternatives. 40 CFR, Section 1502.13. follows: The stated purposes of the proposed project are as 3. 1. Accommodate planned development in • southeastern Orange County by providing new additional freeway capacity to meet current and future traffic demand; 2. Minimize regional through traffic use of arterial highways; 3. Provide an alternative access route to the University of California, Irvine (UCI); 4. Alleviate existing peak period traffic congestion on existing circulation systems, including circulation for recreational access, by relieving peak recreational traffic on SR-1, MacArthur Boulevard and Laguna Canyon Road; and 5. Provide recreational access from inland areas to the coast and various open space and greenbelt areas and minimize impacts on such areas. EIR at 11. The EIR fails in two ways to substantiate the • Purpose and need for the proposed project. of the stated projFirst, a number ect purposes are of questionable merit. Second, there is insufficient evidence contained in the EIR that the proposed project is the best alternative to satisfy the legitimate objectives articulated in the EIR. Purposes Not sufficiently Established 1. Accommodate Planned Development: The arguments outlined in the EIR related to this Objective focus on the Corridor's role as a link between residential concentrations in southeastern Orange County and six major employment centers identified by the EIR. It is asserted in the EIR that in linking these areas, the Corridor will foster balanced development patterns. Both the "Plan" for the land use in southeastern Orange County and the Corridor were outgrowths of a 1974-76 study called the Southeast Orange County Circulation Study (SEOCCS), which study purportedly resulted in the adoption of a balanced land use program for this area of the County. The flaws in this identified objective of the Corridor are numerous, and include, but are not limited to, _ the following: a) The EIR fails to establish • t the "six" concentrated employmentacenters (really five, since two of the centers 4. identified are one project) themselves or in combination with committed •� residential developments, justify the development of the project as proposed. In addition, the EIR discussion omits the identification of proposed additional major employment centers in the County which are undefined in total intensity. These County business parks in combination with County approved residential areas will create a development pattern along the Corridor alignment between Newport Beach and San Juan Capistrano which, with the exception of dedicated open space areas, will result in one continuous path of dense development., Contrary to SCAG policies calling for balanced development patterns, the creation of a massive corridor through the area facilitates the continued long distance commute and sprawling development patterns characteristiy,of Los Angeles and now Orange County.— b) The "balanced" pattern of land use and circulation established by SEOCCS was never balanced (since such balancing is precluded in the absence of intensity data for non-residential land uses) and is now obsolete. For example, both the Cities of Newport Beach and Irvine are currently proposing dramatic changes to their respective general plan land use intensities in areas which directly affect the need for the Corridor. Also, since SEOCCS was adopted, Laguna Beach has actively sought and won permanent protection for major open space areas near the proposed Corridor. Clearly, the SEOCCS study did not consider these changes. In addition, changes to County plans have occurred since the SEOCCS study was prepared. The decision made over a decade ago that the Corridor and 1. There is a growing body of literature which suggests the majority of people will continue to commute between their residence and work for up to 45 minutes. The creation of a new roadway, which -for a time improves traffic flows, only facilitates a pattern of longer acceptable distances between home and work. then -proposed land uses made good planning sense must be entirely • reevaluated given current information and changed circumstances since the SEOCCS study was adopted. c) If indeed access to major employment centers is constrained, such constraints to travel may provide the impetus for people to car pool, van pool and reside in closer proximity to work. Current vehicle occupancy is approximately 1.27 persons per car. If this occupancy statistic were increased by only J% freeway congestion would disappear. (See Exhibit 1, attached.) It is clear, however, that unless there are strong incentives for carpooling, people will continue to drive alone. The need for the proposed Corridor to accommodate planned development should be reevaluated given the above comments, and the EIR should be revised to include the following information: substantiation that a new, major Corridor will foster balanced growth versus urban sprawl: substantiation that the employment centers which warrant construction of the Corridor are those listed at page 12 of the EIR versus the proposed tajor centers in the County (e.g., Aliso Town Center); changed circumstances since the SEOCCS study was completed in 1976 including, but not limited to, changed land use patterns and plans, and alternative technologies and strategies to solve traffic congestion; information regarding the short and long-term supply of affordable fuel for private automobiles. 2. Minimize Regional Through Traffic Logic would argue that until the increase in through traffic is stemmed, such traffic will only temporarily diminish on arterials as a result of rerouting traffic onto a new major roadway. Eventually the capacity of the new roadway will be exhausted and traffic will spill back onto the arterials. Any relief to arterials in the absence of better, inter -regional transportation planning is V. IW at best a short-lived solution to the problem. The Corridor EIR should discuss this likely scenario. In addition, a number of arterials and major freeway segments do not benefit in the short or long term from the construction of the Corridor. These arterials include: MacArthur Boulevard north of Jamboree Road Jamboree Road south of Ford Road Ford Road east of MacArthur San Joaquin Hills Road west of Route 73 Sand Canyon Avenue south of Route 73 Laguna Canyon Road north of Route 1 Laguna Canyon Road south of Route 73 La Paz Road east of Moulton Parkway Crown Valley Parkway west of I-5 Rancho Viejo Road south of Juniperro Serra I-5 near Spotted Bull Lane I-5 north of Ortega Highway I-5 north of Juniperro Serra I-5 south of San Juan Creek I-5 north of Route 1 Route 1 west of Jamboree Road Route 73 west of Jamboree Road A number of other routes experience no change with or without the corridor: Pacific Park Drive west of I-5 Crown Valley Parkway east of Golden Lantern Avery Parkway east of I-5 Untold lesser streets will also suffer increased traffic as a result of the Corridor. These routes are not analyzed in. the EIR, but have been the subject of analysis in other recent EIR's. For example, exhibit 2 indicates that traffic on Marguerite in Newport Beach will double and triple on some segments as a result of the Corridor. Likewise, traffic on portions of San Miguel and Culver Drives will be worse with the Corridoi than without. See exhibit 2, excerpt from EIR on Irvine Coast MCDP, 1988. Increased traffic on a number of these routes will have severe impacts on the neighborhoods they traverse. A complete analysis of routes affected by the Corridor, including local streets, should be done in order to determine exactly what streets suffer from the Corridor and whether those impacts are adequately offset by benefits on other streets. The longevity of purported benefits should also be addressed. 3. Provide An Alternative Access to UCI The Bison connection to the Corridor and entry to UCI would facilitate new growth at the University. The EIR 7. fails to discuss recent proposals for new private research related development at UCI and the Corridor's facilitation • of such growth. Details of recent proposals should be included in EIR analyses. In addition, the EIR fails to substantiate the inadequacy of current roadways to serve the campus. The specific origin of alleged future congestion on University Drive and Campus Drive should be corroborated. Also, the status of improvements to those roadways which might alleviate congestion in the absence of the Corridor or a reduced Corridor should be described. 4. Alleviate Existing Peak Period Traffic on Existing Circulation System by Relieving Peak Recreational Traffic Impacts on SR-1, MacArthur Boulevard and Laguna Canyon Road/ Provide Recreational Access from Inland Areas to the Coast and the Greenbelt Area. The EIR fails to establish the validity of these two objectives. First, the EIR fails to establish what the traffic counts are on key routes during peak summer days. A vague reference is made to traffic counts by the City of Newport Beach, but no data is provided. Second, the analysis does not identify the percent of peak summer traffic which is through traffic as opposed to traffic bound for recreation areas. If through traffic is a small percent, the Corridor will not relieve the major non -parallel routes to recreation areas, such as Laguna Canyon Road, MacArthur Boulevard and Jamboree Road. L�! Instead, it will bring more vehicles to those routes which they will not be able to accommodate. In order to effectively argue that the Corridor will alleviate existing summer peak traffic on these -routes, substantiating data must be obtained and additional analysis must be completed. Table S-1 in the EIR actually shows that portions of these key recreation routes benefit from no Corridor. How can these figures be reconciled with this objective? In addition, it is not logical that the Corridor will benefit recreational areas when most, if not all, existing, accessible recreation areas the Corridor may serve are already over capacity. The existing road system is adequate to more than fill up these areas (including, but not limited to, the Laguna and Newport beaches, established events and quaint downtowns). The evidence for this fact is empirical. Long before the roads cease delivering the cars to these areas on a summer day, the parking areas are full. The assertion completely ignores current trends in recreational planning which call for establishing and enforcing carrying capacity limits in sensitive recreational areas by limiting access, parking and other means. See exhibit 3. The EIR fails to analyze the extent to which additional roads are needed, if at all, to provide adequate access to recreational area. Questions that should be 10 8. answered in this regard before conclusions are reached related to the merits of this objective include: - What are current agency goals and policies on levels of use in the open space areas along the Corridor route? - What is the carrying capacity of each of these areas consistent with resource protection and stated park objectives? - Are these areas adequately accessed by existing routes? If the response is that they are not adequately accessed,•the response should specify in detail those areas inadequately served by roads and provide data corroborating the response. What other planned new routes will serve these areas, in addition to the Corridor? How would increased access from the Corridor, above and beyond the existing routes plus planned routes, affect the recreational uses and resources of the areas? What development areas not already served by routes to these recreation areas can be served by the Corridor (i.e., Does the Corridor really provide a needed new link?). How will the Corridor interfere with the recreational and resource integrity of open space areas it traverses? (This question could best be answered by a questionnaire of people enjoying these areas.) How, specifically, will the Corridor minimize impacts on these recreational areas? a THE EIR FOR THE PROPOSED CORRIDOR PROJECT IS INADEQUATE The draft environmental impact report (DEIR 494) prepared for the proposed San Joaquin Hills Transportation Corridor is deficient in at least the following respects. The Project Description Contained in the EIR Fails to Adequately Describe the Project. Failure to Adequately Describe The Project Renders Impact Discussions Inadequate and Incomplete. The project as described in the project description section of the EIR differs from the project as described elsewhere in the EIR as follows: Project Description Section: "The project cross section Alternative A varies from six to ten general travel lanes, and includes climbing lanes in areas with steep grades, auxiliary lanes to assure smooth function of interchanges, a separate median for transit and HOV, and HOV ramps and appurtenances. This cross section would be designed to accommodate truck traffic, and would have a total width, • excluding climbing lanes; ranging from 162 feet to 210 feet." (DEIR at 2). Geologic Section: "The width of the corridor, including graded areas, will vary depending on right-of-way requirements and topographic conditions. Cross section Alternative A right-of-way will vary from approximately 220 to 1,400 feet in width, with wider widths at interchange from approximately 500 to 2,100 feet." (DEIR at 220). One explanation for this tremendous discrepancy in the basic project description is found in the EIR at page S-8: "The dimensions discussed above are the widths of the facilities without on and off ramps, or weaving and merging lane widths. Because these lanes are common factors to each of the alternatives, and will thus change the total width by the same increment, the addition of these widths to the total dimension is not necessary for a comparative evaluation. Another possible explanation is that the DEIR misrepresents the true magnitude of the project so as to avoid alarming the public. 10. Failing to define the true extent of the project and project alternatives contravenes CEQA by obfuscating the true project and thus the true project impacts. CRQA requires that the impact of a project be measured in relation to the existing environmental conditions. Environmental Planning and information Center v. County of E1 Dorado, 131 Cal.App. 3d 350, 182 Cal.Rptr. 317 (1982). Project impacts cannot be measured against existing environmental conditions if the extent of the true project is not revealed. The flawed project description results in underestimated project -related impacts. Project related impact analyses throughout the EIR appear to be based on an inaccurate corridor width. See, for example, discussion at page 266 regarding water quality. Clearly, the incorrect and misleading project description results in an underestimation of project related impacts. In addition, the project description section fails to adequately describe key components of the project. Failure to clearly describe these aspects of the project results in inadequate impact assessments including, but not limited to, the following: 1. The EIR fails to accurately describe the corridor width of key segments and intersections. 2. The EIR fails to describe the total acreage required by the corridor and alternatives. At page 214 the DEIR states that the corridor will grade 1,100 acres. However, this figure does not appear in the project description section and is not substantiated. In addition, comparative data is not provided for alternatives. 3. The EIR fails to describe the true nature of climbing lanes, on and off ramps, and weaving and merging lanes. Illustrations do not adequately describe these features. 4. The EIR fails to describe the probable operation of the corridor as a toll road and fails to evaluate the physical components of a toll road (e.g., toll gates, etc.). See Exhibit � . 5. The EIR fails to describe in sufficient detail improvements related to the corridor including but not limited to park and ride facilities, other necessary roadway • improvements, including widening, bridges, interchanges and the like. These related 11. engineering features should be specifically described in terms of land area, design, • grading, height, width, cost and location. 6. The EIR fails to describe key engineering features of the Corridor including, but not limited to, the location and size of spoils sites and the location of disposal sites for 8 million cubic yards of soil removed from "cut" areas. 7. The EIR fails to describe total amount of grading associated with the Corridor and related improvements. The reference in the EIR to grading 25 million cubic yards refers only to Corridor grading. 8. The EIR fails to describe impacts related to blasting and other construction techniques needed to build the Corridor in areas of geologic constraints. The project description should be revised to accurately reflect the total project, including planning, engineering, construction and operational aspects of the project. The EIR Fails to Describe A Reasonable Range of • Alternatives to The Project. The concept of the corridor was conceived in 1974 and formally adopted as part of the MPAH in 1976. Since that time major changed circumstances have occurred, including but not limited to the following: The California Coastal Act was enacted in 1976, which establishes numerous policies relevant to the Corridor; The Aliso Viejo Specific Plan was modified to allow 20,000 instead of 10,000 units; Communities throughout California, including San Jose, Los Angeles, Sacramento and San Mateo, approved major transit programs in lieu of street improvements to solve traffic problems; Transportation Systems Management (TSM) programs have become a major source of additional roadway capacity in lieu of road widening programs; Cities including Newport Beach, Laguna Beach, and Irvine have modified, or are in the process of modifying, land use in a manner which eliminates • or reduces the need for the corridor. 12. These and other changed circumstances over the . last 14 years since the corridor concept was initiated warrant a complete evaluation of all possible alternatives to the project. The EIR should contain a detailed analysis of the relevant circumstances that have changed since SEOCCS and former EIR 267 were prepared. Such changed circumstances would include changed land use plans, new developments in traffic and transportation technology and the like. In addition, regardless of changed circumstances, the range of alternatives analyzed in the EIR is not sufficiently broad to satisfy CEQA and NEPA requirements. The only alternatives that are the subject of any depth of analysis are "freeway" conf�'prations, narrowly ranging in width from 128 to 210 feet.— DEIR at S-8. Other alternatives which should be thoroughly evaluated include:!' 1. A new "SEOCCS" study which would analyze current conditions and evaluate state-of-the- art planning solutions, including land use and transportation options. The prior SEOCCS study is out-of-date. It would make good planning sense to reevaluate the course set by the 1974-76 SEOCCS study prior to taking any action which simply carries out a twelve -year -old mandate. 2. Light rail or other transit use of the corridor in lieu of vehicle use. The EIR excuses the need to analyze public transit as follows: "HOV lanes are a part of the proposed project. The conversion of these HOV lanes_ to accommodate a light rail transit facility is a possibility that is highly dependent on future development densities, land use patterns, and patronage developing a positive image of mass transit. These transit factors have not yet begun to emerge and consequently it is not appropriate to consider mitigation 2. All of these alternatives have the same additional width for ramps, merging lanes, etc. EIR 267 and the SEOCCS study also failed to evaluate a reasonable range of alternatives. 3. A thorough review of alternatives is required under NEPA. See pages 290-294 of DEIR. 13. measures that result from transit at this time." (at page 507). Transit is a reasonable alternative and should be thoroughly evaluated. Given increasing congestion on other roads, the current incentive for people to use transit should be evaluated. In addition, transit may better foster the type of alternate land use configuration called for by the county and SCAG than a new road which will facilitate long commutes from home to job. The analysis of a transit alternative should consider the comparative advantages of different types of transit from a freeway in terms of cost, environmental impact and long-term relief of traffic congestion, among other issues. 3. Mandatory TSM related trip reductions for new employment areas. 4. Widening of existing roadways to their maximum widths including I-5, SR-22, I-405, SR-55, SR-57, SR-39 and others. The brief discussion of this option fails to look at the total of resulting traffic benefits if all roadways were widened to the maximum extent feasible, short of eliminating homes or business. The information contained in Table 3-1 seems to indicate that even with the Corridor, major widening of Routes I-405, I-5 and arterials will be required. The EIR should analyze the differential impacts between widening these roads to lanes required with the Corridor and adding only an additional 2 lanes in most cases to satisfy demand without the Corridor. 5. All of the above -stated alternatives in combination with modified land use scenarios. 6. Modified land uses in non -committed (e.g. vested) county unincorporated areas. The EIR provides three reasons why regional down -zoning (land use changes) are infeasible as follows: An effort to reverse over ten years of regional planning would undermine general plan law and mean that regional land use planning such as SEOCCS could no longer be relied upon in local plan regulation; 14. Plans are interrelated and the loss of components could jeopardize the plans in functional and economic terms; and A large part of traffic on the Corridor will be through traffic which cannot be controlled. None of these reasons is sufficient to ignore an alternative based upon land use changes. First, general plan law supports the notion of planning as an ongoing process. General plans are intended to be updated every five years. The reason for this is that circumstances may change, warranting reevaluation of the course of local planning. In addition, as will be explained in greater detail herein, the SEOCCS study failed to establish proper correlation between land use and the circulation system. Second, the purpose of evaluating an alternative is to determine its impacts. The impact evaluation of a modified land use plan should focus on functional and economic impacts to present plans. A "guess" that alternative land use plans are not feasible because they might jeopardize interrelated plans is not an adequate reason to ignore such alternatives. 00, Finally, the notion that through traffic cannot be controlled is a reason to look at alternatives that won't be "attractors" of through traffic, but will instead move people within the -sub -region. Transit alternatives may serve this purpose better than new roads. This should be evaluated along with a process which would lead to interregional planning. 7. Four -lane expressway with only two access points. 8. Four -lane facility for bus use only. 9. Limited facility for car pool and van pool use only. Alternatives Discussed in the EIR Are Inadequately Analyzed. Discussions of alternatives contained in the EIR are deficient in at least the following respects: 1. The description of impacts related to project alternatives is incomplete in that the true description of the alternatives is not revealed, precluding adequate analysis of 15. alternatives. Specifically, the road dimensions subject to analysis do not include on and off ramps, weaving and merging lanes and climbing lanes. EIR at S-8. 2. Analysis of alternatives is constrained to a narrow area along the alternative alignments which does not include the.true width of the roadways or the true width of grading along the roadways. 3. Alternative analyses are based on the same flawed assumptions regarding projected land uses and population growth as the proposed project analysis (e.g., the extent of commercial areas is undefined; land use data is out of date, etc.). 4. Numerous alternatives are rejected for reasons which are not adequately substantiated by data or factual material. Such prematurely rejected alternatives include, but are not limited to, the following: - alternative land use concepts; - improvements to other routes; - six -lane arterial; - transit route only; - deletion of an interchange at Laguna Canyon Road; and - deletion of an interchange at E1 Toro Road. The EIR Fails to Properly Incorporate Other Studies by Reference. Both CEQA and NEPA require that studies incorporated by reference be briefly summarized in relevant part. The list of studies incorporated by reference to supplement the impact evaluation of the corridor are not summarized. In addition, it would be impossible for the public to discern which discussions in the various documents are intended to supplement discussions in the instant EIR. (DEIR of page 209). The EIR Fails to Adequately Address A Number of Probable Significant Impacts. Impact discussions contained in the EIR are inadequate for at least the following reasons: 1. Discussions of key impacts are omitted from the EIR. The EIR should discuss the following probable impacts: 16. a) Impacts upon habitat areas, water quality, neighborhoods, traffic flows • likely to result from project -related modifications to local arterials, streets and intersections; b) Impacts upon neighborhoods as a result of increased traffic flowing to the corridor on local streets. See, for example, Exhibit 2; c) Other impacts as a result of increased traffic flows on some local arterials and streets; d) Impacts associated with the corridor's facilitation of-a''continuing pattern of long commutes from jobs to housing (e.g., constraints to redevelopment and development of job centers in south, center, and north county; dispersed growth patterns; facilitation of continued use of the car; threat to TSM program efficacy and possible undercutting of the feasibility of a transit option for the south county); e) Impacts upon areas in the county targeted for revitalization as a result of opening up vast new areas for growth at this time. Specifically, by facilitating new development revitalization programs in older areas may be threatened. The EIR should analyze the relationship between the anticipated demand for jobs and housing and the possible areas in Orange County where anticipated growth could be accommodated. Are there existing and committed areas adequate to accommodate growth for the next 10, 20, 30 years? If so, the opening up of vast new areas for development may be premature, inefficient and impact the successful redevelopment of other areas; f) Impacts to existing residential neighborhoods as a result of traffic, noise, light and glare and air quality degradation resulting from the corridor. The discussions contained in the EIR are not sufficiently detailed to provide decision -makers with information regarding localized impacts. For example, the EIR discloses that "[t]he 17. County's regional model, while providing reliable system wide analysis on the 'macro' scale, is not expected to duplicate local traffic study forecasts for small localized areas." Page 465. It is incumbent upon the EIR drafters to arm decision -makers with detailed data related to local impacts. The project is not of such a large magnitude that such detailed analysis is unreasonable. Moreover, most of the data already exists in other EIR's and traffic studies. See, for example, traffic studies done in conjunction with the Irvine Coast Master Coastal Easement Permit, 1988. g) Impacts as a result of the probable operation of the corridor as a toll road. Such impacts could include reduced use of the corridor and commensurate increased reliance on other roads, among other impacts. h) Intensified development at interchanges and related impacts of such development. i) Impacts to recreational and resource areas as a result of access to these areas over and above their respective capacities. j) Impacts as a result of disposal of 8 million cubic yards of spoils from grading and cut and fill. k) Impacts from grading and disposal of spoils as a result of the widening of related routes. 1) Impacts as a result of blasting required to construct the Corridor, including noise impacts on wildlife, airborne dust, etc. m) Other impacts to wildlife from construction, light and glare,.noise, etc. 2. Discussions of project -related impacts underestimate or misstate true impacts due to faulty underlying assumptions or incomplete information, including but not limited to the following: 18. a) Many impact discussions rely upon a flawed project description that does not describe the true extent of the project. For example, water quality impacts are based on a "210 foot wide paved corridor." At 266. Yet, in other sections the corridor is described as up to 2,100 feet in width. In addition, the analysis of water quality impacts is based on a shorter corridor than planned, thereby further underestimating likely impacts. See Table 4-8. It is not clear what width corridor is used in the analysis on wetland impacts: "The assessment of project impacts or wetland areas is based on the mapping of plant communities within an area extending approximately } mile on either side of the corridor." At 283. Similarly, impacts upon biological resources were based on an area }-mile from the Corridor alignment. Grading related to Corridor clearly extends beyond a quarter mile from the proposed alignment and appears to extend into a mile beyond the Corridor in some places. Impacts of this grading on wetlands and other sensitive resources are not evaluated. These and other'impact discussions in the EIR which rely on faulty project description data should be entirely revised; b) The air quality analysis is based on the faulty assumption that the Corridor will result in more "free flowing" traffic. Recent projections by SCAG indicate to the contrary that by the year 2010, the Corridor could be gridlocked if billions of dollars of other improvements are not in place. The air quality analysis must be revised to consider this likelihood. c) These same analyses exclude areas subject to grading as a result of needed ancillary road and interchange improvements. d) Traffic, cumulative and growth inducing discussions are based on incomplete information regarding planned, committed and foreseeable land use in the area. For example, no data is provided on the potential floor area of commercial, industrial -and related uses in county 19. unincorporated areas within the study area. In addition, potential buildout of local plans is not tabulated, nor are possible intensifications of proposed uses adjacent to interchanges and ramps considered in the analysis. Each of these impact discussions must be revised if the EIR is to be adequate. 3. Impact discussions which are contained in the EIR are inadequate and incomplete. Examples of inadequate and/or incomplete discussions are as follows: a) Impacts related to construction are understated since the geologic analysis is only preliminary and does not reveal many potential constraints to the Corridor construction, including the extent of seepage forces, active pressures, fractured rock and bedrock formations. DEIR at 221-222. b) Impacts to vegetation and wildlife are not adequately described as a result of incomplete and outdated surveys of possible resources. c) Impacts to archaeological resources are not sufficiently discussed since the RFP for Phase II testing is only now being released: See exhibit 5. The EIR should not be finalized until the results of such testing are incorporated into the document. Absent such incorporation, the EIR will omit data essential to the Corridor decisionmaking process. d) The water quality discussion concludes that "[t]he significance of residual material would depend upon the . . . characteristics of individual storm events, such as duration and intensity of rainfall. Those storm characteristics would determine the amount of materials which would settle in channel bottoms or remain suspended in the runoff to be flushed downstream to the area." Clearly the key to meaningful information regarding water quality impacts lies in some discussion of likely storm events. Yet the EIR does not provide a full discussion of 20. the possible impacts of major storm events or provide data to corroborate the incomplete discussions contained in the EIR. The EIR should provide detailed information about likely major storm events for each watershed and data corroborating projected storm events and related impacts. e) The growth inducing discussion fails to quantify the likely number of acres and ultimate level of new development which the corridor could support. Instead, the section erroneously concludes that "the corridor does not induce development." At page 589. This statement is contradicted in the EIR at page 591 as follows: "The corridor will, therefore, facilitate development which may not otherwise be allowed, or which would be delayed by the absence of adequate infrastructure." The discussion should be revised so that it is complete and internally consistent. At a minimum, the discussion should provide the following information: (i) the number of acres within the study area for which development is neither existing nor vested; (ii) the amount of excess capacity the Corridor will have at buildout of development currently existing plus vested; (iii) the amount of excess capacity on the Corridor at buildout of all planned development under current general plans. f) The cumulative impact discussion fails to disclose true cumulative development impacts in that the list of projects considered does not include full information regarding potential buildout of county allowed business parks and commercial areas. In addition to this information, the cumulative analysis should describe the total impacts resulting from this corridor in combination with other planned corridors, particularly the growth inducing impacts. g) , The study area upon which impact discussions are based does not include the total area subject to impacts. For air quality impacts and growth inducing impacts, all of Orange County should be 21. EIR. included in the cumulative analysis. Growth projections and projects outside of Orange County should be included in traffic impact calculations since these areas contribute to through traffic. Each of these discussions must be revised in the The EIR Fails to List Feasible Mitigation Measures. Reasonable mitigation measures to offset project -related and cumulative impacts which should be considered in the EIR include the following measures: 1. Impact: Loss of open space and habitat areas to corridor and related growth. 2. 3. 4. 5. Mitigation: Dedication of major open space to compensate for that lost to corridor and related, non -vested growth. Impact: Growth inducing impact to non -vested areas. Mitigation: Dedication of non -vested areas for open space; adoption of a meaningful County -wide growth management program which limits growth to that which can be adequately served by a reasonable level of services as opposed to a program which relies on the unrealistic possibility that development will be halted if services become inadequate to meet demand. Impact: Threats to successful revitalization/rehabilitation programs in north county communities. Mitigation: Postpone decision on corridor until demand for new residential/commercial space exceeds ten-year anticipated supply. Impact: Foster development of new major high density development nodes at corridor interchanges. Mitigation: Limit the number of major interchanges; restrict development allowed at interchanges. Impact: Inadequate service levels on corridor. Mitigation: Monitor service levels on corridor and halt growth when corridor reaches Level of Service D. is • 22. 6. Impact: Failure to meet state and federal air quality standards. Mitigation: Modify land uses to foster less auto -dependence; mandate TSM programs of new businesses; approve a transit facility in lieu of a freeway. Mitigation Measures that are Included in the EIR are Inadequate. Mitigation measures included in the EIR are inadequate for at least the following reasons. First, a number of the mitigation measures call for additional studies and plans rather than specific measures which could contribute to actual reductions in impacts. Examples of such studies and plans, in lieu of actual mitigation, include, but are not limited to, the following: 1. Preparation of a wetland mitigation plan. EIR at 303. There is no measure which requires replacing wetland on a one-to-one acre basis as "intended" in the EIR. (EIR at 305. 2.- A pilot test program for sensitive plan salvage. (EIR at 396). The test program should be done prior to listing salvage as an adequate mitigation measure. Second, the efficacy of other specified measures in reducing project impact, such as noise barrier and wildlife overcrossings, are not described. The EIR must provide information regarding the extent to which impact reductions are based on specified mitigation measures. In addition, a number of feasible measures are omitted due to flawed assumptions contained in the EIR that there will be no air quality or growth -inducing impacts. Impact assessments must compare the project -related impacts to present conditions and not to future conditions absent the proposed project. Environmental Planning and Information Center v. County of El Dorado, 131 Cal. App. 3d 350; 182 Cal. Rptr. 317 (1982). For this and other reason's described herein, it seems improbable that the project will not have significant adverse air quality and growth -inducing impacts. Therefore, mitigation measures should be discussed in the EIR for each of these impacts. 23. The List of Unavoidable Adverse Impacts Contained in The EIR Is Incomplete and Fails to Quantify or • Adequately Describe the Severity of Such Impacts. The list of unavoidable adverse impacts omits the following likely unavoidable adverse impacts: I. Water quality impacts: since the discussion of such impacts was inadequate in many respects (see discussion herein) the characterization of such impacts as - incidental may be inaccurate; 2. Traffic levels which will increase on many arterials and local streets as a result of the project; 3. Impacts to neighborhoods as a result of increased traffic on local streets. 4. Growth inducing impacts on 71% of the land surrounding the corridor which is currently vacant; 5. Growth inducing impacts at interchanges (e.g., major intense development); 6. Overutilization of sensitive resource and recreational lands due to excessive access to these areas; 7. Air quality impacts including both Corridor -related and cumulative impacts; 8. Dispersed and sprawling pattern of growth facilitated by new roadways. r] 24. 0 MAJOR UNANSWERED QUESTIONS AND UNSUPPORTED ASSUMPTIONS Major unanswered questions and unsupported assumptions which should be addressed by the EIR include the following. We request that these be discussed in the response: to comments: 1. If all other planned improvements to major roadways were completed, would there still be a need for the corridor as proposed? If yes, document the demand for the corridor. 2. What: changes to planned land use would be needed to eliminate the need for the corridor? In the unincorporated area? The total area? What changes to planned land use would be needed to allow the corridor to be reduced to four lanes total? 6 lanes total? 8 lanes total? 3. To what extent is access currently inadequate to serve recreational areas? What is the current use to capacity ratio of the recreational areas served by the corridor? 4. Exactly what is the contribution to corridor demand . related to existing land uses? Vested land uses? Non -committed but planned land uses? Respective projects? Other? Please fill out the information requested in the table attached as exhibit 6. 5. What is the excess capacity of the corridor once planned land uses are built out? What build -out land use scenario is assumed? 6. What will be the annual cost of maintaining the corridor? From what state fund will the money come? 7. Is state and/or federal money needed to construct the Corridor? If yes, from what specific sources will the money come? How can federal money be allocated to the Corridor if the Corridor is inconsistent with the SIP? 8. Could anticipated growth be accommodated in existing, committed growth areas? For the next 10 years? 20 years? 9. If anticipated levels of growth mean future freeway travel demand on I-5 of 330,000 vehicles per day, what is to stop over -commitment and congestion of the corridor in the future? 10. What is the anticipated and potential intensity of county business parks and commercial areas? (List and quantify by project area.) 25. 11. What arterials and local roads will experience increased congestion as a result of the project on • opening day? In 2000? In 2010? 12. How wide is the proposed corridor at interchanges and segments? How many acres will be consumed by the total project? 13. What is the source of the cost estimate for the corridor? What are the respective sources of funds for corridor construction? 14. Is the corridor intended to be a toll road? What are the impacts associated with operation of the corridor as a toll road? When will the decision be made as to whether the Corridor will be a toll road? Who will make the decision? 15. What are the exact entitlements and actions required before the corridor can be built? By what agencies? What is the anticipated schedule of these actions? 16. Specifically, what consultations have already taken place or will take place related to the EIR with local, state and federal agencies? What has resulted from these consultations? Who has participated in these consultations? 17. What, if any, agency actions will take place related to • Corridor funding prior to the certification of the EIR? EIS? 18. Specifically, who are the contact people in the agencies responsible for the project, their addresses and phone numbers? Who comprise the decision -making bodies listed, their names and addresses? 26. EIR AND PROJECT CONFORMANCE WITH OTHER APPLICABLE LAWS The Proposed Project is Inconsistent with the State Implementation Plan (SIP) Thereby Precluding Federal Agency Approval and Financing of the Corridor. States are required to prepare and submit to the Environmental Protection Agency for approval State Implementation Plans (SIP's). The SIP provides for implementation, maintenance and enforcement of established National Ambient Air Quality Standards (NAAQS) for air pollutants that might endanger public health or welfare (42 U.S.C. §7409). Orange County is currently a non -attainment area for both carbon monoxide and ozone. The 1982 SIP for the South Coast Air Basin (SCAB), Orange County, was invalidated i�,Abramowitz v. U.S. E.P.A., 832 F.2d 1071 (9th Cir.) (1987).— In response, the EPA took final action to disapprove the ozone and carbon monoxide SIP in early 1988. Therefore, the 1979 SIP is the governing SIP for Orange County. The 1979 SIP does not include or assume the Corridor. This affects the Corridor in the following ways. 1. Contrary to the assertions in the EIR, the Corridor is clearly inconsistent with the operative 1979 SIP. A"freeway" cannot conform to a plan that doesn't mention it. 2. Also contrary to the EIR's claim, the Corridor contributes to the fact that the South Coast Air Basin is a non -attainment area for both ozone and carbon monoxide. This fact indicates that there are cumulative adverse air quality impacts associated with 1. The precise holding of Abramowitz v. EPA was that EPA could not approve the control measures in the 1982 revision to the State Implementation Plan without determining whether those measures would ensure attainment of the National Ambient Air Quality Standards by 1987. The court ordered EPA to (1) rescind its approval of the control measures, and (2) disapprove the state implementation plan as a whole. Accordingly, the aftermath of Abramowitz is as follows: (1) The control measures and other criteria in the 1979 SIP remain in effect. (2) The control measures in the 1982 SIP have been disapproved by EPA. 27. the project, if not project -related adverse impacts contrary to the conclusions regarding air quality contained in the EIR. 3. The EIR provides insufficient evidence that the Corridor is consistent with control measures contained in the 1979 SIp. Specifically, a• The construction of the Corridor, by encouraging the continued use of single occupancy vehicle and facilitating greater distances between jobs and housing, is likely to interfere with the adoption and implementation of a number of transportation control measures (TCM's), including: - modified work schedules; - car pooling/van pooling; - trip reduction program; - bicycle and pedestrian facilities (the Corridor eliminates bike paths); employee ridesharing. In addition, the Corridor may exhaust funds which could have been spent on other measures, such as HOV use of existing roads and other measures. It will be difficult to encourage ridesharing and car Pooling until the Corridor too is gridlocked. By that time, the Corridor will have been used to • justify the construction of multiple, dispersed employment centers and housing areas, making it difficult to organize and implement successful transportation systems management techniques such as ridesharing.. At best, the Corridor will provide only temporary relief to congestion, at cross purposes with TCM's directed at long-term solutions to air quality problems. b. The land use data used to develop the SIp is outdated, suggesting that Orange County may be even further from compliance with air quality standards. Approval of the project should await a thorough analysis of cumulative air quality impacts and realizable mitigation measures to determine whether the Corridor is consistent with a program to attain mandated air quality standards. C. The EIR comes to the dubious conclusion that the Corridor will improve air quality. However, this assertion rests entirely on the unsubstantiated assumption that traffic, due to the Corridor, will be more freely flowing and vehicle miles travelled will be reduced thereby reducing emissions. Among 28. the flaws in the analysis underlying these • assertions are the following: (1) Absent land use controls, the Corridor is likely to be gridlocked due to growth induced by its approval, thereby eliminating air quality emission reductions. (2) The cumulative air quality analysis is inadequate in that it does not consider total increased emissions due to the Corridor, growth induced by the Corridor as well as other foreseeable roadways and development in the air basin. (3) This argument ignores the fact that impacts must be weighed against present conditions. New roads will allow for new trips, not fewer trips, over existing conditions. The Proposed Project is Inconsistent with the Orange County General Plan. The proposed project is inconsistent with the Orange County general plan in the following respects. First, the project is inconsistent with a transportation corridor as defined in the Transportation Element of the county general plan which provides in pertinent part: ". a multimodal facility, having six to ten lanes based on projected volumes and a median of sufficient width to be utilized in the future for transit. . . ." (Emphasis added.) The descriptions of the Corridor contained in the EIR are carefully contrived to camouflage the clear inconsistency between the proposed corridor and the general plan definition of a corridor. Careful review of the various descriptions of the proposed Corridor reveal that it is anything but a six to ten lane facility: "The project cross section Alternative A varies from six to ten general travel lanes, and includes climbing lanes in areas with steep grades, auxiliary lanes to assure smooth function of interchanges, a separate median for transit and HOV, and HOV ramps and appurtenances. This cross section would be designed to accommodate truck traffic, and would have a total width, excluding climbing lanes, ranging from 162 feet to 210 feet." (DEIR at 2). However, "[T]he dimensions discussed above are the widths of the facilities without on and off ramps, or weaving and merging lane widths. Because these lanes are common factors to each of the alternatives, and will thus change the total width by the same increment, the addition of these widths to the total dimension is not necessary for a comparative evaluation." 29. (DEIR at 5-8). Including these additional lanes, the facility is well beyond six to ten lanes in • width. "The width of the corridor, including graded areas, will vary depending on right-of-way requirements and topographic conditions. Cross section Alternative A right-of-way will vary from approximately 220 to 1,400 feet in width, with wider widths at interchange from approximately 500 to 2,100 feet." (DEIR at 220.) The EIR must discuss the true nature of the project and accurately evaluate its compliance with the general plan. If a general plan amendment is required, the full effect of this action should be considered. Second, the general plan is legally inadequate in ways which directly affect the Corridor. California law requires that all cities and counties prepare and adopt "a comprehensive, long-term general plan for the physical development of the county or city . ." Gov't Code § 65300. The general plan serves as the guide for growth and development. All development decisions must be consistent with a valid general plan. Consistency between a general plan and a later implementation action cannot be achieved unless each of the required elements is legally adequate. Where an element directly involved in a project being reviewed is legally inadequate there can be no finding of consistency between the project approval and the general plan. Camp v. Mendocino County Board of Supervisors, 123 Cal. App. 3d 334, 176 Cal. Rptr. 6201 (1981). The Orange County general plan is deficient in at least two major respects which directly involve the project. First, the land use element fails to provide standards of population density and building intensity as required by law. Government Code section 65302(a) provides in pertinent part: "The land use element shall include a statement of standards of population density and building intensity for the various districts and other territory covered by the plan." No such standards are provided in the general plan for non-residential uses in the County. Absent the required standards the general plan provides insufficient guidance for development of this area and provides no basis for evaluating total development allowed. Second, the circulation element is legally inadequate in that it fails to provide for a circulation system which is correlated with the land use element of the general plan. Government Code section 65302(b) requires that a general plan contain: 30. "[a] circulation element consisting of the general location and extent of existing and �-- proposed major thoroughfares, transportation routes, terminals, and other local public utilities and facilities, all correlated with the land use element of the general plan." (Emphasis added). The requirement of correlation between the land use element and the circulation element is: "designed to insure that the circulation element will describe, discuss and set forth 'standards' and 'proposals' respecting any changes in demands on the various roadways or transportation facilities_.. . . as a result of changes in uses of land contemplated by the plan . . . [and] to prohibit a general plan from calling for unlimited population growth in its land use element without providing, in its circulation element, proposals for how the transportation needs of the increased population will be met." Concerned Citizens of Calaveras County v. Board of Supervisors, 166 Cal. App. 3d 90, 100, 212 Cal. Rptr. 273 (1985) . The county's circulation element fails to meet this requirement. Since the general plan does not contain adequate population density and intensity standards for non-residential uses, correlation between the circulation element and the land use element is not possible. In addition, there are serious funding gaps hindering completion of needed roadway improvements, and insufficient funds for operation and maintenance of existing roadways. As the County Development Monitoring Report (DMP) points out, specific phasing of improvements in the coastal areas' and funding and implementation programs are not yet established. As a result, roadway and other improvements ancillary to the project may not be built in a timely fashion. The County's prior responses to the allegation that the county -wide general plan is legally inadequate are confirmation of the fatal deficiencies in the general plan. Specifically, the County responded to the comment that the land use element fails to provide standards of building intensity by admitting that the general plan does not govern building intensity by limiting allowable square footage or building Floor Area`Ratios (FARI,$). Indeed, the County's land use element includes only "projections" of employment for each statistical area, from which the density of employees and building intensities must be estimated. The 31. County argues that the number of employees is the most accurate measure of building intensity. • The County's argument on the surface sounds logical. However, there is no mechanism in the general plan to restrict the ultimate number of employees in an area to that number projected by the land use element. As can be seen from the attachments, employment per square foot and per acre varies tremendously by actual land use. For example, specific land uses are not prescribed for the business park areas in the Aliso Planned Community, and could range broadly from high-rise office which could generate approximately 260 employees per acre to warehouse use which could generate as few as approximately 2.0 employees per acre depending on the specific use. The ultimate number of employees and, thus, the intensity of buildings in the Aliso area, as well as other areas, is not adequately set forth in the general plan. Clearly, the general plan does not provide adequate standards or definitions for either land uses or building intensity. In the absence of project consistency with the County general plan, and a legally adequate general plan, the County is precluded from taking action on the project. The EIR Fails to Adequately Disclose and Protect Endangered, Threatened and Concerned Species. The existence of endangered species must be • verified and steps undertaken to ensure their protection pursuant to the Endangered Species Act. The biological analyses contained in the EIR are based upon analyses which are outdated and inadequate in scope. Specifically, the major analysis referred to in the EIR was conducted in 1980 with even earlier studies listed in support of those findings. (DEIR at 52.) In addition, the analysis only considered a one-half mile wide segment along the length of the Corridor. Multiple cuts and fills needed to construct the Corridor extend well beyond one-half mile. Also, the area studied fails to include other key features of the project which may impact vegetation and biotic resources, including, but not limited to, spoils sites (unknown), other related transportation route improvements (e.g., widenings ramps, etc.), toll plazas and the like. There is sufficient evidence that candidate species exist in the area of the corridor to warrant further surveys in that area.- These include the San Diego horned lizard, candidate for the federal endangered species list, the many -stemmed dudleys and the Orange County Turkish Rugging, among others. Additional species which should be the subject of surveys prior to a decision on the Corridor, in addition to the ones listed in the EIR, include: Northern Harrier Black Tailed Nutcracker 32. Black Shouldered Kite �l Osprey Yellow Billed Cuckoo Peregrine Falcon Southern Bald Eagle Great Horned Owl Red Tailed Hawk Cassins Kingbird Badger See also exhibit 7, excerpt of species in the area from the Laguna Beach General Plan. In the absence of more up-to-date and complete survey data, the EIR conclusion that no threats to these protected species exist is not adequate. The Proposed Project is Not Consistent with Coastal Act, Chapter 3 Policies. The following comments are made with the recognition that where conflicts occur between one or more policies of the Coastal Act, the legislature intended that "such conflicts be resolved in a manner which on balance is the most protective of significant coastal resources." Public Resources Code Section 30007.5. This provision provides the basis for the concept of a dedication program to offset specific development impacts. However, to date no such open space dedication has been seen to offset significant direct and indirect impacts of the Corridor on coastal resources. Specific inconsistencies between the proposed Corridor and the Coastal Act include the following: 1. In conflict with Coastal Act policies, the Corridor will provide additional, unnecessary access to the sensitive coastal recreational and resource areas overburdening the capacity of these areas to sustain the resulting activity levels. The recreational and resource areas which will be served by the Corridor already are served by adequate transportation routes which will result in visiters to these areas in excess of their respective capacities. While the Coastal Act encourages public access, it does so conditionally as follows: "The public access policies of this article shall be implemented in a manner that takes into account the need'- to regulate the time, place and manner of public access depending on the facts and circumstances in each case including, but not limited to, the following 33. (1) Topographic and geologic site characteristics. i (2) The capacity of the site to sustain use and at what level of intensity . . . Section 30214. Other sections of the Coastal Act also call for new or expanded public works facilities to be consistent with the needs generated by development or uses permitted pursuant to the Act. See Sections 30254 and 30252. In particular, section 30252 calls for the facilitation of transit service, provision of non -automobile circulation in coastal areas, provision of substitute means of serving development with public transportation and ensuring that the recreational needs of new residents will not overload coastal recreation areas by correlating development with facilities. No analysis was completed that documents the need for additional access to the coastal resources. Many existing resource areas are suffering from overuse. As such, this basis for the Corridor should be dropped unless such correlation can be established. 2. The construction of the Corridor is inconsistent with development policies contained in the Coastal Act related to erosion, natural land form protection, air quality and special communities. The Coastal Act provides that new development shall: (1) neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or surrounding area; (2) be consistent with requirements imposed by an air control district; (3) minimize vehicle miles travelled; and (4) protect special communities. In each of these respects, the EIR's analysis of the Corridor falls short of establishing conformance with Coastal Act policies. 3. The Corridor is in conflict with Coastal Act policies calling for maintenance, enhancement and restoration of marine resources. The project does not ensure adequate protection of the offshore marine resources from erosion and runoff as a result of the Corridor and associated development. Short-term effects of massive grading, coupled with long-term effects of urbanization and vehicle -related pollution, could lead to severe and irreversible impacts to 34. offshore marine life including highly sensitive kelp beds and tide pools. The analysis of these potential impacts in the EIR is inadequate in many respects with the results that marine -area impacts are underestimated and inadequately mitigated. Thorough evaluation should be undertaken in the EIR to establish the true severity of these impacts. 4. The Corridor will result in alteration of natural streams and interfere with surface water flows contrary to Coastal Act policies. The Corridor will result in major alteration to streams and natural surface water flows. Mitigation measures proposed for these impacts are insufficient and of uncertain efficacy (e.g., wetland mitigation areas have yet to be selected). 5. Contrary to Coastal Act policies, the Corridor will result in significant disruption to habitat values and impacts upon parks and recreation areas. Since the evaluation of Corridor -related impacts to habitat, parks and recreation areas is incomplete (see arguments herein), total impacts to such sensitive areas generated by the Corridor are not known. Inasmuch as Coastal Act policies call for maximum protection of these areas, and disruption only if absolutely necessary, alternatives to the Corridor proposal which avoid these sensitive areas should be seriously considered. 35. THE PROPOSED PROJECT IS CONTRARY TO GOALS AND POLICIES • CONTAINED IN THE LAGUNA BEACH GENERAL PLAN. The EIR fails to describe the potential conflicts between the proposed Corridor and the goals and policies of the Laguna Beach General Plan. While the City acknowledges the need to participate in regional transportation planning efforts and work toward solutions to regional transportation problems, the City does not view the development of new "freeways" as an acceptable solution: It is essential that the City should participate in transportation corridor studies and planning done at a County or regional level. However, the City's position must be that additional freeways and highways cannot be viewed as acceptable transportation solutions. Emphasis should be placed on using existing, in use right-of-way for alternate forms of transportation, for example, busses, mono -rails, or other forms of transit. Source: Transportation and Circulation Element of the General Plan, City of Laguna Beach, page 4. By ignoring any legitimate evaluation of alternatives to a freeway, the EIR has ignored any legitimate evaluation of a project which is consistent with the Laguna Beach General Plan. In addition, the EIR fails to evaluate project conformance with Laguna Beach general plan goals and policies. The EIR should analyze the consistency of the project and alternatives to each of the following policies: Water Quality Policies 4-A Protect fresh water lakes, streams, waterways and riparian habitats, and preserve the borders and banks of lakes and streams in their natural state. 4-B Encourage the planting of drought tolerant and native vegetation as a means of conserving water. 4-E Oppose any physical alteration to the Laguna Lakes shoreline or adjacent habitat areas that may result in adverse effects to the the lakes or would depreciate the visual quality of the lakes. 4-F Coordinate with the County of Orange to maintain and • enhance the ecological quality of the Laguna Lakes. 36. 4-H oppose activities which degrade the quality of offshore waters. Park Policies 5-B Support the recreational use and development of surrounding open space lands, where environmentally feasible, to relieve demand for parklands within the City. Encourage preservation of Laguna Greenbelt in a natural state, with recreational access limited to passive activities such as nature trails and wildlife observation areas. Visual Resource Policies 7-F As a condition of approval for new building construction, require the dedication of open space easements, development rights, or the use of some similar instrument for the purpose of protecting unusually significant natural features. 7-G The Design Review process for an individual project shall include criteria for treatment of the urban edge between existing development and open space in areas designated "Hillside Management/Conservation" on the Land Use Plan Map. The criteria shall be developed to reflect topographic constraints and shall include at a minimum: a. Treatments to screen development, including the use of vegetation, variable setbacks and modified ridgelines or berms; b. Fuel modification techniques for new development which provide the following: Result in graduated fuel modification zones in which on the minimum amount of native vegetation is selectively thinned; prohibit grading or discing for fuel modification; confine fue-1 modification to the development side of the urban/open space edge to the maximum extent; avoid fuel modification encroachment into environmentally sensitive areas; locate structures with respect to topographic conditions to incorporate setbacks, minimize fuel modification requirements and maximize hazards; and provide requirements for ongoing maintenance. C. Treatments for fuel modification and maintenance techniques for existing development consistent with standards in (b) above to the maximum extent feasible. 7-H For new development proposed on property adjacent to the Aliso Greenbelt, a site -specific view analysis shall be required. Said analysis shall identify 37. appropriate measures to ultimately screen the development and shall be approved by the Design Review Board. Such measures may include but shall not necessarily be limited to: (a) setback of structures, (b) landscape screening, (c) berms or "false ridges," (d) use of earthtone cr color and materials which will serve to blend the structures with the natural landscape. If the analysis indicates that development cannot feasibly be screened by the measures above, such that the trails or the canyon bottoms of Wood and Aliso Canyons, then the City shall impose other conditions of development so as to protect the viewshed and integrity of the greenbelt. Such measures may include limitation on building height, bulk or footprint, lot line adjustment or other similar measures. Vegetation & Wildlife Policies 8-A Preserve the canyon wilderness throughout the city for its multiple benefits to the community, protecting critical areas adjacent to canyon wilderness, particularly stream beds whose loss would destroy valuable resources. 8-B Prohibit vehicular use in open space areas, unless it is required for public health and safety, and monitor these areas to ensure enforcement of this policy. 8-C Identify and maintain wildlife habitat areas in their natural state as necessary for the preservation of species. 8-D Protect rangeland for deer population in the City; pursue such protection in areas adjacent to, but outside the City. 8-E Protect the remaining stands of native Coastal Live Oak (Quercus Agrifolia) and Western Sycamore (Platanus Racemosa) located in upper Laguna and E1 Toro Canyons, and in Top of the World Park as a unique and irreplaceable resource. 8-F Require detailed biological assessments for all subdivisions and fuel modification proposals located within areas designated as high or very high value on the Biological Values Map. 8-G When subdivision or fuel modification proposals are situated in areas -designated as "high value habitats" on the Biological Values Map and where these are confirmed by subsequent on -site assessment, require that these habitats be preserved to the greatest extent possible. 38. 8-H When subdivision or fuel modification proposals are situated in areas designated as "very high value habitats" on the Biological Values Map and where these are confirmed by subsequent on -site assessment, require that these habitats be preserved and, when appropriate, that mitigation measures be enacted for immediately adjacent areas. Watershed Policies 9-A Promote the preservation and restoration of Laguna's natural drainage channels, freshwater streams, lakes and marshes to protect wildlife habitat and to maintain watershed, groundwater and scenic open space. 9-B Prohibit filling and substantial alteration of streams and/or diversion or culverting of such streams except as necessary to protect existing structures in the proven interest of public safety, where no other methods for protection of existing structures in the flood plain are feasible or where the primary function is to improve fish and wildlife habitat. This provision does not apply to channelized sections of streams without significant habitat value. 9-C a. Streams on the Major Watershed and Drainage Courses Map which are also streams as identified on the USGS 7.5 Minute Quadrangle Series, shall be identified and mapped on the Coastal Environmentally Sensitive Areas Map of the Land Use Plan. For these streams, a minimum setback of 25 feet from the top of the stream banks shall be required in all new developments. A greater setback may be necessary in order to protect all riparian habitat based on a site -specific assessment. No disturbance of major vegetation, or development, shall be allowed within the setback area. This provision shall not apply to channelized sections of streams without significant habitat value. Where development is proposed on an existing subdivided lot which is otherwise developable consistent with all City ordinances and other policies on this Plan except that application of this setback would result in no available building site on the lot, the setback may be reduced provided it is maintained at a width sufficient to protect all existing riparian habitat on the site and provided all other feasible alternative measures, such as modifications to the size, siting and design of any proposed structures, have been exhausted. b. Require a setback of a minimum of 25 feet measured from the centerflow line of all natural drainage courses other than streams referenced in 9-C(a) 39. above. Such setback shall be increased upon the recommendation of the city engineer and environmental planner through the environmental review process. However, a variance may be given in special circumstances where it can be proven that design of a proposed structure on an affected lot will preserve, enhance or restore the significance of the natural watercourse. At no time shall grubbing of vegetation, elimination of trees, or disturbance of habitat be allowed within the setback area before or after construction. 9-H Coordinate, wherever possible, natural and man-made drainage structures so that natural channels will contribute to transport a volume of runoff equal (or as close as possible) to that which would have occurred if the project watershed were in its natural condition before development. 9-I Require new development projects to control the increase in the volume, velocity and sediment load of runoff from the greatest development areas at or near the source of increase to the greatest extent feasible. 9-J Require new developments to maintain runoff characteristics as near as possible to natural discharge characteristics by maintaining the natural conditions of the watershed. 9-K Promote preservation and enhancement of the natural drainage of Laguna Beach. 9-L In conjunction with the -County of Orange, prepare a flood control plan and program of implementation for Laguna Canyon and all tributaries, pending funding availability. 9-M Where feasible, require flood control programs to incorporate non-structural methods, such as preservation of watershed lands and natural drainage channels, rather than structural methods such as concrete flood channels and engineering works. 9-0 Investigate methods of establishing and maintaining debris collection devices at suitable locations in the major canyon areas prior to the rainy season, pending funding availability. 9-Q Oppose new development within the City's surrounding areas that would result in significant adverse impacts to the City's hydrology. 9-T All graded areas shall be planted and maintained for erosion control and visual enhancement purposes. Use of native plant species shall be emphasized. 40. Natural Hazards Policies 10-A Require that plan review procedures recognize and avoid geologically unstable areas, flood -prone lands, and slopes subject to erosion and slippage. 10-B Require the incorporation of open space into the design of new development in hillside and canyon areas, where feasible, for the purposes of reducing the potential for spread of wildfires from structure to structure. 10-C Require projects located in geological hazard areas to be designed to avoid the hazards where feasible. Stabilization of hazard areas for purposes of development shall only be permitted where there is no feasible alternative location or where such stabilization is necessary for public safety. In any case, development should be generally discouraged within geologic hazard areas. 10-D Reevaluate existing flood plain management regulations to ensure the potential for damage from debris is reduced. 10-E Development in the areas designated "Hillside Management/Conservation" on the Land Use Plan Map or within potential geologic hazard areas identified on the Geological Conditions Map of the Open Space/Conservation Element shall not be permitted unless a comprehensive geological and soils report is prepared pursuant to Title 22 of the City's Municipal Code, and adequate mitigation measures have been approved and implemented by the City's geologist. For projects located in areas subject to hazards as identified on the Geologic Conditions Map or subject to erosion, landslide or mudslide, earthquake, flooding or wave damage hazards confirmed by a geologic assessment, as a condition of approval of new development a waiver of liability shall be required through a deed restriction. 10-F To minimize risk to life and structures, new development located in established floodprone lands shall incorporate all appropriate measures pursuant to the City's "Flood Damage Prevention and Prohibition Ordinance." Air Quality Policies 11-A Promote the establishment of effective regional, state and federal standards and programs for control of all airborne pollutants and noxious odors, regardless of s source. 41. 11-B Participate in planning of land use and transportation developments in adjacent areas to ensure adequate consideration of air quality. 11-C As part of the review of development proposals, recognize the importance of open space as a clean air generator that helps buffer the community from inland pollution. To this end, establish a system for recognizing and preserving permanent open space lands. 11-E Maintain and encourage the use of innovative non-polluting modes of city transit. Archaeology Policies 12-A Promote the conservation of land having archaeological and/or paleontological importance, for its value to scientific research and to better understand the cultural history of Laguna Beach and environs. Ridgeline Policies 1.3-A Preserve the function of ridgelines, hillsides and canyons as a link between adjoining open space areas. 13-B Require that development proposals, including additions and alterations to existing buildings, incorporate protection of the natural profile of ridgelines as visual resources. 13-C Discourage ridgeline development in order to protect highly visible and exposed portions of the ridgeline, including outstanding physical features, such as rock outcroppings, vertical slopes and caves, and study the feasibility of prohibiting development on the prominent ridgelines. 13-D Require environmental impact reports for ridgeline development projects include a viewshed analysis with cross -sections and recommended mitigation measures. 13-F Require all ridgeline development to be reviewed and approved by the Design Review Board. 13-G Encourage the dedication of suitable ridgeline sites for public viewing and access purposes. 13-H Preserve public views of coastal and canyon areas from ridgelines. Hillside Slope Policies 14-C Prohibit new building sites that would require LI-I co4struction of a street of 15% or more in grade. MP 4?. 14-E Require all development on slopes of 30% or greater to . be reviewed and approved by the Design Review Board. 14-F Require grading projects to minimize earth -moving operations and encourage preservation of the natural topographic land features. • 14-G Prohibit the dumping of excess fill within hillside areas unless necessary for the public's health and safety. 14-H Encourage inaccessible hillside property to be dedicated to the city as permanent open space. 14-I Discourage new roads or extensions of existing roads in to currently inaccessible areas. 14-J As a condition of approval of any new development in the "Hillside Management/Conservation" designation, the offer of a permanent open space easement over that portion of the property not used for physical development or service shall be required to promote the long-term preservation of these lands. Only consistent open space uses shall be allowed by the easements. Except for passive recreation, trails or trail -related rest areas, development shall not be allowed in this easement area. The offer of easement shall be in a form and content approved by the City -and shall be irrevocable for 21 vears from recordation. The creation of homeowner's or other organizations, and/or the preparation of open space management plans may be required by the City to provide for the proper utilization of open space lands. 045/laguna 43. • Exhibit C7 Survey Finds Typical Driver on Solo Run to Irvine Job By DONN WALKER, times Ste;; Writer Driving alone. Reynaldo Sacayanan commutes 26 miles to worst each day in Irvine .from his home in La Puente. He travels four freeways: the Pomona, the Orange. the Santa Ana and the Costa Mesa. Life is fine until he hits the Sang Ana Freeway, where commute congestion leaves him sitting in his barely moving car each mormng, "bothered and waiting." Sacayanan, an engineering draftsman at Van Dell & Associates, has much in common with other drivers on the county's freeways. according to the results of a mil -In traffic survey conducted in May. *Irvine, home to cozens of corporauons. is by far the most likely destination for Orange County drivers, according to the survey which was commissioned by the Transportation Corridor Agences to help in desigrung three proposed freeways for the southern part of the county. e Most motonsts on county freeways are going to or from work. e And four out of five tunes, they're alone in the r cars. "I7is confirmed a whole lot of mforma- don we swmeeted." TCA spokeswoman Susan ?darzec said of the survey, the results of which were released Thursday. The study "turned theory into fact" Response Frequency of 304 The survey did offer one suronse: Of 400.000 surveys distributed. 125,000 were completed and returned. Most such mail -in surveys show an average response rate of about 15%, but Lhc rate in Grange County was more than 30%. said Ed Regan, vice president of Wilbur Smith & Associates, the San Francisco firm that conducted the survey. That shows a lot of perceived need for the (fmwayj pro)ccts," Regan said i The consulung firm next month will make public its recommendations on traffic gpaw,y and ramp locations for the planned freeways. County Supervisor Thomas F. Riley, ebairaan of both the Orange County TrAnspo; tation Commission and the Saa Joaquin Hills Transportation Corridor's board of directors. sand he is "meimerized*% by the cotmty's high response rate. "It proves to all of us once again." Riley said Thursday, "that Orange County does have a personality all its own," Some other survey findings, e Orange f ounty drivers don'i like to Fleese see COMMUTE. Page 5 wuy lr'•83 1b 54 r^.i�1 COMMUTE: 80.7% of Trips Related to Jobs Coatioued from tap 1 car-pool. According to the survey, 81 % of the cars on the county's freeways contain lust one person. creating an avr!ragc of 1.27 persons per vehicle. Regan said this is lower than the national average, which some estimates have placed at about 1.4 persons per vehicle. e Most freeway trips in the county arc overwhelmingly related to work or buaness. During peak hours-7 to 9 am. and 3 to 6 p.m.-80.7% of itavers on the road are making such trips. The average rate of work -related trips during all hours is Ci8.7%. e The county's No. I destination for freeway travelers is Irvine. More than 342.000 tnps are made to there each weekday. The next most popWsr destination, Santa Ans. isn't even close, with 116.347 trips made every weekday. Dania for Error hard to Figure Regan said that because some of the survey questions had an infi- nite number of possible responses, a margin of error was "very hard to calculate." But he said the survey's sample stze was "more than adequ to to measure traffic patterns" and made the study statistically valid. The survey was conducted by distributing response cards at 60 freeway ramps in the county. Be. -cause chic proposed new freeways are to be in the south county, the northwest area of the county — from Huntington Beach to Buena i Park— wasn'tpolied. One planned freeway, through the Eastern Transportation Corri- dor, will extend from the Rivernde Freeway to the Santa Ana F ve- i way in East Tustin and Fast Irnne. The proposed Foothill Corridor freeway would Wilt the sasteri co-, dor with the San Diego Free- way, new San Clement& And the San Joaquin Hills Cori idor freeway j would run from the Corona del Mar FT"way near UC :rune to the San Diego Freeway near San Juan Capistrano. Construction of the San Joaquin Hills Corridor freeway, the first to be built, is scheduled to begin at the and of 1989. 41A6-W 7 - i2, i nos Angeles dimes HOW WE DRIVE Vehicle Oee�oncy i The sverage 11 cle occupsncv is 1.27 persons. 6 or more: 0.3 % 4: 1 person: j 80.9% • t 3: 2.9% 2: 14.4 % Trip "ose Recreation: 2.3% Social: io/from '� 2.6% I .4 :•� ;r • - a School: Shopping; hraonai Company 5.3% business: buarms: 13.0% 21.5% The four locations that are . the destination or starting pant for the greatest number of motorists are: teoiies ateternw Irvine ...... 342.354 Seams Ans ....# .. 116,347 North Orange County . $0.573 Laguna MNis . 79.439 7.9 8.nu:3.69.i i.)- `-•ear,.. Irvine .............. 93.554 Santa Ana .......... 30.392 North Orange County . 29,356 Laguna Nibs . 28,035 aovow: WAk* ST th AUee.twfm Vw Trantpon*wn CWrKW AeRra7w� 0 0 Exhibit a a a a �31 0 . a a t. h c ram, .4 sc : �,� l5, % ? _ 3 . N < Vn C ti 0' Exhibit 3 RELEVANT STATE PARK PRACTICES RELATED TO CARRYING CAPACITY LIMITS One consistent challenge to recreation planners, suppliers and managers is balancing the level of actual use for a resource with the ability of the area's resources to accommodate that use. This challenge is often tackled by identifying a "carrying capacity" for the recreation area. The California Department of Parks and Recreation has a number of policies, regulations and guidelines that address this issue. Two California State Park and Recreation Commission Statements of Policy and Rules of Order that apply are: "Recreation. Planning - Such planning shall anticipate the types, qualities, and extent of public needs for recreation, and shall determine the potential areas, the land -carrying capacities, and the developments and services to meet those needs with estimated costs for acquisition, development and operation. . ." (Policy Number 1 - Planning (Amend 11-4-83), Department of Parks and Recreation Policies, Rules & Regulations, p.43.; and, 0-11 "Where there are conflicting, though legitimate, recreational demands for use of the same unit of the State Park System, every consideration may be given by the Department of Parks and Recreation to provide opportunities, consistent with public safety, for such conflicting recreational uses by a time or space zoning or by other controls and devices. If the commission finds that a specific recreational use is damaging to the natural and cultural resource values or the health, safety, or welfare of visitors, it shall be re-evaluated and may be restricted." (Policy Number 16: Conflicting Recreational Use (Amend 12-13-86), Department of Parks and Recreation Policies, Rules & Regulations, p.59. The California Public Resources Code (Div. 5, Chapter 1, Article 1) states: 5001.96. Attendance at state park system snits shall be held within limits established by carrying capacity determined in accordance with Section 5019.5" (Added by Stats 1971, Ch. 1722.), Department of Parks and Recreation Policies, Rules & Regulations, p.101. Article 1.7, Section 5019.5 sets up a classification system for all "units" that are part of the state park system. The term "State Park" is one such unit classification (as EXHIBIT 3-1 compared with State Recreation Area, or State Beach). As such, a broad guideline about the relative purpose (preservation vs. use levels) of the State Park is established through these designations. A state "wilderness" is more restrictive of use than a state "Preserve". A state "Park" is more balanced between use and resource protection than a State "Recreation Area" where extensive human impact is possible. Attached are the definitions for these various units. The purpose of a State Park is "to preserve" a resource. It is managed to "restore, protect, and maintain its native environmental complexes". Improvements for recreation access and use are to be made in a manner "consistent with the preservation_ of natural, scenic, cultural, and ecological values". The Department of Parks and Recreation uses a deliberate process for preparing General Plans for its units to assure that resource protection has pre-eminent priority over recreation. use. Chronologically, the first element of a General Plan to be prepared is the Resource Element. Among other things, a determination is made in the Resource Element about the level of use appropriate for different areas within the unit. A map is prepared that establishes zones of "allowable use -intensity" based on the carrying -capacity of the natural and cultural resources present. Only once these levels of use -intensity are established are appropriate facilities and management techniques planned to accommodate the use. (Guidelines for Resource Documents, California Department of Parks and Recreation, Resource Protection Division, November, 1984). A General Plan for Crystal Cove State Park, that includes allowable use intensities, was adopted by the State Parks Commission in March, 1982. (source: Allan Tong, Development Division, State Parks). In. Orange County there already exists a well -documented demand for what is called "dispersed" outdoor recreation activities on the county's open space resources. One common attribute between most dispersed recreation activities (like hiking, horseback riding, nature observation, etc.) is that they all depend on "access" to the open space resources. Access in this case takes the form of: highways leading to the area; parking/staging areas (trailheads) at the area; and trails leading through the area and to popular destination points. Any of these features can and have been used as the basis to limit use. As a siphon point, the parking/staging area becomes the operative location where use of an area is most often controlled, when the demand clearly exceeds the supply. When the parking area is filled, the gate is simply closed and people are turned away. it should be recognized that this kind of management gets expensive at times. Policing an easily accessible (i.e. popular) area and dealing with the irate public that EXHIBIT 3-2 '� has driven an hour only to find the place "filled" is not an easy, or desirable, task. Carrying -capacity is a standard tool used at all levels of government to plan and manage park, recreation, and open space areas. Back in the 1970's, for example, the Bureau of Outdoor Recreation (now the National Park Service) published guidelines for determining "Optimum Recreation Carrying Capacity" covering many forms of outdoor recreation. Slide Rock State Park in Sedona, Arizona is one specific example where parking capacity was purposefully sized to accommodate a limited number of visitors targeted to the resource's capacity for use. Also, at Brannan Island State Recreation Area, beach capacity estimates to size the nearby parking area were used. There has certainly been significant publicity this year about the National Park Service limiting entrance into Yosemite (and even considering banning Californians on certain days of the week to make room for out-of-state visitors). To discourage use to some areas, access roads are sometimes left unpaved. Open space areas are sometimes not signed from nearby roads to reduce use pressures. This was done at the Nisqually National Wildlife Refuge along Interstate 5 in Olympia, Washington. EXHIBIT 3-3 2M ASSOCIATES P. O. Box 70M Landscape Station Berkeley, Ca19fomic 94707 Guidelines for RESOURCE DOCUMENTS NOVEMBER 1984 California Department of Parks and Recreation Resource Protection Division II. RESOURCE POLICY FORMATION x A. Classification B. Declaration of Purpose Discuss the unit's general background including why and when the unit was acquired and classified. Quote the significant parts of the Public Resources Code that describe broad management objectives and improvements that are appropriate within the existing classification. If the unit or portion of the unit is proposed for reclassification, the reasons for such action should be discussed. St ate the the unit's Declaration of Purpose: If a revised Declaration of Purpose is proposed, include both the old and new declarations. If a new Declaration of Purpose is needed, state the purpose of the unit including; 1) identification of prime resources, 2) long-range management objectives in conformity with the unit's specific classification in the Public Resources Code, and 3) the relationship between unit resources and appropriate .recreational use. As part of the Declaration of Purpose, briefly state the significant resources, drawing distinction to resources of statewide significance. C. Zone of Primary Interest Discuss zones outside the unit in which i land use changes could adversely impact I the stated purpose of the unit and resource management objectives. _J D. Resource Management Policies State policies for the specific management of resources in the unit. Do not quote or repeat information given in the resource summary. 3.5 Organize policies by subject following the same order as presented in the r� resource summary. Include preservation, protection, restoration, enhancement, reconstruction, removal of intrusive features, corrective actions, resource management programs, resource 1 monitoring, midden stabilization, wildfire control, etc. as warranted. Cite known resource problems requiring policy guidance as individual items, describing each problem briefly and concisely. The problem statements are important in clarifying or amplifying the intentions of the policy. Follow each problem statement with the required policy as a separate paragraph i using appropriate subheadings. Each policy must be written as a complete sentence that can be quoted and understood without detailed explanation. For cultural resources, provide specific management policies for archeological sites, structures, or artifacts when needed. Resource management policies and directives that are already approved for the State Park System as a whole should be included here when they are especially pertinent to existing or potential resource problems in the unit. Policies and directives that apply to the unit, but only in a nonspecific way, should not be included here but can be referred to by their Public Resources Code or Resource Management Directives numbers. Policies which call for actions should .I indicate priorities in timing. These should not be given as deadlines (e.g., I within 5 years), but in sequence with other general plan activities (e.g., before, after, concurrent, etc.). . For units with historic structures, policies should be included which set , policy concerning adaptive re -use, potential for house museums, concessions development, etc. 3.6 I E. Allowable Use Intensity Determine the level of use appropriate for areas within the unit. Discuss the controlling factors, including major constraints and sensitivities. Constraints are factors which would make visitor use or facility development unsafe, economically impractical, or undesirable. Examples of constraints include slope, erosion potential, flood hazard, or seismicity. Sensitivities are characteristics of an area that warrant restricting use and/or development to protect resources. Examples of sensitivities include a rare plant population, a fragile or unusual ecosystem, an archeological site, or a historic building. Include a map which integrates constraints and sensitivities and designates zones of allowable use intensity. The areas with the least constraints and sensitivities should be mapped as high allowable use intensity zones; areas where the most intensive developments would be permitted. 3.7 ...................... 111116 2wr ISE DEPARTMENT OF PARKS AND RECREATION' LATIONS POLICIES, RULES & REGU sr OF now W619A 01 XL Gordon K. Van Vleck George Deukmejian secrelarY Governor for ResourCes State of California Wm. S. Briner Director Depamment of Parks and Recreation State of California - The Resources Agency Dcpmurient of parks and Recreation P.O. Box 942996 Sacramento, CA 9429&"1 .w 1 PUBLIC RESOURCES CODE Sol$ (Div. 5, Chapter 1, Article 1) money for the acquisition, development, or construction of such state beach or park or recreational area, the department shall forthwith commence with such acquisition, development, or construction. (Added by Stats. 1959, Ch. 2164.) $019. When property is deeded to the State for park or beach purposes, oil and mineral rights in such property may be reserved in such deeds by the grantor, provided, that any prospecting or extracting of oil and minerals shall in no manner disturb the surface of such property or any improvements placed in or upon the property in pursuit of its use for recreation. (Added by Stats. 1947, Ch. 441.) $019.5. Before any park or recreational area developmental plan is made, t>. department shall cause to be made a land carrying capacity survey of the propo•, park or recreational area, including in such survey such factors as soil, moisture,.,; . natural cover. (Amended by Stats. 1959. Ch. 2164.) Article 1.7. Classification of units of the State Park System (Article 1.7 added b), Stats. 1978, Ch. 615) 5019.50. All units which are or shall become a part of the state park system, except those units or parts of units designated by the Legislature as wilderness areas pursuant to Chapter 1.3 (commencing with Section 5093.30) of this division, shall be classified by the State Park and Recreation Commission into one of the categories specified in this article. (Added by Stats. 1978, Ch. 615.) 5019.53. State parks consist of relatively spacious areas of outstanding scenic or natural character, oftentimes also containing significant historical, archaeological, ecological, geological, or other such values. The purpose of state parks shall be to preserve outstanding natural, scenic, and cultural values, indigenous aquatic and terrestrial fauna and flora, and the most significant examples of such ecological regions of California as the Sierra Nevada, northeast volcanic, great valley, coastal strip, Klamath-Siskiyou Mountains, southwest mountains and valleys, redwoods, foothills and low coastal mountains, and desert and desert mountains. Each state park shall be managed as a composite whole in order to restore, protect. and maintain its native environmental complexes to the extent compatible with the primary purpose for which the park was established. Improvements undertaken within state parks shall be for the purpose of Makin the areas available for public enjoyment and education in a manner consistent wit the preservation of natural, scenic, cultural, and ecological values for present an future generations. Improvements may be undertaken to provide for recreation;. activities including, but not limited to, camping, picknicking, sightseeing, natur study, hiking, and horseback riding, so long as such improvements involve no majc modification of lands, forests, or waters. Improvements which do not direct! enhance the public's enjoyment of the natural, scenic, cultural, or ecological values c PUBLIC RESOURCES CODE (Div. 5, Chapter 1, Article 1) SOtY'S6 the resource, which are attractions in themselves, or which are otherwise available to the public within a reasonable distance outside the park, shall not be undertaken within state parks. State parks may be established in either the terrestrial or underwater environments of the state. (Amended by Stats. 1981, Ch. 714, Sec.'363.) 5019.56. State recreation units consist of areas selected, developed, and operated to provide outdoor recreational opportunities. The units shall be designated by the commission by naming, in accordance with the provisions of Article 1 (commencing with Section 5001) and this article relating to classification. In the planning of improvements to be undertaken within state recreation units, consideration shall be given to compatibility of design with the surrounding scenic and environmental characteristics. State recreation units may be established in the terrestrial or underwater environments of the state and shall be further classified as one of the following types: `' =' "^A�consisting of areas selected and developed to provide m:::'plr rvcreauonai opportunities to meet other than purely local needs. The areas shall be selected for their having terrain capable of withstanding extensive human impact and for their proximity to large population centers, major routes of travel, or proven recreational resources such as manmade or natural bodies of water. Areas containing ecological, geological, scenic, or cultural resources of significant value shall be preserved within state wildernesses, state reserves, state parks, or natural or cultural preserves. Improvements may be undertaken to provide for recreational activities, including, but not limited to, camping, picknicking, swimming, hiking, bicycling, horseback riding, boating, waterskiing, diving, winter sports, fishing, and hunting. Improvements to provide for urban or indoor formalized recreational activities shall not be undertaken within state recreation areas. (b) Underwater recreation areas, consisting of areas in the underwater environment . selected and developed to provide surface and subsurface water -oriented recreational opportunities, while preserving basic resource values for present and future generations. (c) State beaches, consisting of areas with frontage on the ocean, or bays designed to provide swimming, boating, fishing, and other beach -oriented recreational activities. Coastal areas containing ecological, geological. scenic, or cultural resources of significant value shall be preserved within state wildernesses, state reserves, state parks, or natural or cultural preserves. (d) Wayside campgrounds, consisting of relatively small areas suitable for overnight camping and offering convenient access to major highways. (Amended by Stats. 1982, Ch. 994. Sec. 7.) 5019.59- Historical units, to be named appropriately and individually, consist of areas established Primarily to preserve objects of historical, archaeological, and scientific interest, and archaeological sites and places commemorating important persons or historic events. Such areas should be of sufficient size, where possible, to encompass a significant proportion of the landscape associated with the historical objects. The only facilities that may be provided are those required for the safety, comfort, and enjoyment of the visitors, such as access, parking, water, sanitation, — 128 — 0 • PUBLIC RESOURCES CODE SOt=.62 (Div. 5, Chapter 1. Article 1) interpretation, and picknicking. Upon approval by the commission, lands outside the primary historic zone may be selected or acquired, developed, or operated to provide camping facilities within appropriate historical units. Upon approval by the State Park and Recreation Commission, an area outside the primary historic zone may be designated as a recreation zone to provide limited recreational opportunities that will supplement the public's enjoyment of the unit. Certain agricultural, mercantile, or other commercial activities may be permitted if those activities arc a part of the history of the individual unit and any developments retain or restore historical authenticity. Historical units shall be named to perpetuate the primary historical theme of the individual units. (Added by Stats. 1978, Ch. 615.) 5019.62. State seashores consist of relatively spacious coastline areas with frontage on the ocean, or on bays open to the ocean, including water areas seasonally connected to the ocean, possessing outstanding scenic or natural character and significant recreational, historical, archaeological, or geological values. State sea- shores may include underwater areas within them, but may not be established solely in the underwater environment. The purpose of state seashores shall be to preserve outstanding natural, scenic, cultural, ecological, and recreational values of the California coastline as an ecological region and to make possible the enjoyment of coastline and related recreational activities which are consistent with the preservation of the principal values and which contribute to the public enjoyment, appreciation, and understand- ing of those values. Improvements undertaken within state seashores shall be for the purpose of making the areas available for public enjoyment, recreation, and education in a manner consistent with the perpetuation of their natural, scenic, cultural, ecological, and recreational value. Improvements which do not directly enhance the public enjoyment of the natural, scenic, cultural, ecological, or recreational values of the seashore, or which are attractions in themselves, shall not be undertaken. (Added by Stats. 1978, Ch. 615.) 5019.65. State reserves consist of areas embracing outstanding natural or scenic characteristics of statewide significance. The purpose of a state reserve is to preserve its native ecological associations, unique fauna or floral characteristics, geological features, and scenic qualities in a condition of undisturbed integrity. Resource manipulation shall be restricted to the minimum required to negate the deleterious influence of man. Improvements undertaken shall be for the purpose of making the areas available, on a day use basis, for public enjoyment and education in a manner consistent with the preservation of their natural features. Living and nonliving resources contained within state reserves shall not be disturbed or removed for other than scientific or management purposes. State reserves may be established in the terrestrial or underwater environments of the state. (Added by Stats. 1978, Ch. 615.) 5019.68. State wildernesses, in contrast with those areas where man and his own works dominate the landscape, are hereby recognized as areas where the earth and its — 129 PUBIC RESOURCES CODE 5018.71 (Div. 5, Chapter 1, Article 1) community of life are untrammeled by man and where man himself is a visitor who does not remain. A state wilderness is further defined to mean an area of relatively undeveloped state-owned or leased land which has retained its primeval character and influence or has been substantially restored to a near -natural appearance, without permanent improvements or human habitation, other than semi -improved campgrounds, or structures which existed at the time of classification of the area as a state wilderness and which the State Park and Recreation Commission has determined may be maintained and used in a manner compatible with the preservation of the wilderness environment, or primitive latrines, which is protected and managed so as to preserve its natural conditions, and which: - (a) Appears generally to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable. (b) Has outstanding opportunities for solitude or a primitive and unconfined type of recreation. (c) Consists of at least 5,000 acres of land, either by itself or in combination with contiguous areas possessing wilderness characteristics, or is of sufficient size as to make practicable its preservation and use in an unimpaired condition. (d) May also cantain ecological, geological, or other features of scientific, educational, scenic, or historical value. State wildernesses may be established within the boundaries of other state park system units. (Amended by Stats. 1980, Ch. 1234, Sec. 3. Effective September 29. 1980.) 5019.71. Natural preserves consist of distinct areas of outstanding natural or l scientific significance established within the boundaries of other state park system units. The purpose of natural preserves shall be to preserve such features as rare or • endangered plant and animal species and their supporting ecosystems, representative examples of plant or animal communities existing in California prior to the impact of civilization, geological features illustrative of geological processes, significant fossil occurrences or geological features of cultural or economic interest, or topographic features illustrative of representative or unique biogeographical patterns. Areas set aside as natural preserves shall be of sufficient size to allow, where possible, the natural dynamics of ecological interaction to continue without interference, and to provide, in all cases, a practicable management unit. Habitat manipulation shall be permitted only in those areas found by scientific analysis to require manipulation to preserve the species or associations which constitute the basis for the establishment of the natural preserve. (Added by Stats. 1978, Ch. 615.) 5019.74. Cultural preserves consist of distinct areas of outstanding cultural interest established within the boundaries of other state park system units for the purpose of protecting such features as sites, buildings, or zones which represent significant places or events in the flow of human experience in California. Areas set aside as cultural preserves shall be large enough to provide for the effective protection of the prime cultural resources from potentially damaging influences, and to permit the effective management and interpretation of the resources. Within cultural preserves. complete integrity of the cultural resources shall be sought, and no structures or improvements which conflict with such integrity shall be permitted. (Added by Slats. 1978. Ch. 615.) — 130 — 0 Exhibit Tofl-WOsMay � Need State Aid, Seymour Says By DANIEL M. WEI TTRAL'B, Times Staff Writs SACRAMENTO—Orange Coun- ty's proposed toll roads. promoted for two years as a novel way to build new highways without using state funds, may need state money after all, state Sen. John Seymour disclosed Thursday. That- the Anaheim Republican conceded. could jeopardize legisla- lion he is sponsoring that would designate two of the toil roads as state highways, and thus delay their construction. One state senator, whose support was key to passage of Seymour's legislation in the upper house in June, said Thursday he will work to defeat Seymour's bills if they are changed to permit state funding for design and construction of the toll roads. I'm going to oppose the bill and do everything I can to kill it." said Sen. Daniel E. Boatwright (D-Con- cord) . 10 Seymour is the author of two bills that would declare the Foot- hill and Eastern toll road routes to be state highways so they can qualify for state maintenance funds after they are built Seymour's Assurance But passage of those measures, needed to help ensure such long- term maintenance financing, has hinged on Seymour's assurance that no state tax dollars would be needed to design or build the roads. which instead would be paid for with bonds backed by projected revenue from tolls, developer fees and federal funds. Now Seymour says a financial study he saw for the first time this week indicates that the roads may not be feasible without state fund- ing. The study, completed by pri- vate consultants for the Orange County Transportation Corridor Agencies in May, suggests that the agencies "actively pursue state and federal funding" for the roads. The study, which Seymour shared with The Times. shows that several of the possible alternatives for phasing in construction of the roads would not provide enough Please see TOLLS. Page''-9 v V 0 0 v �• Lpyp�vR3� �oe.r�vz amisayq � �. 07 Ow7 e�e�� R 3 pdj ,t°�' R � � L 67 VGJ y R = R S 'O R G, .O .r = m m L v 3 .* O r R Y • = v � � .°.. Z V owl IID � � d .°+ 6�i— �::E3����$� *0 4167aL ,U�w 3 L i C O L v 3 35. E.cs c>,o aoa..4!50E 3v= 7�� -� = v 3 � i.1 � �"" C i VO^ > 4 0��0Cp3v4C� v=0R0•2 °c v E. v+_a v v„ or c i •� �o o R� `' s � c la,R _ eo 3 mo cc 0 3 _ v > R- = C y s R'vl CODoO =- m %me�n3 Fj��L...v 3-0 E E _ ,:, � a E �� L O R L L 0 v 'fl •- •- m�y. O v CC 02 °: o org - `� `° L e c° o c R M m �d.� `���c=3E�va 8 y:. R m w 00i v M -- = ;`aco`W��o°3a�i�o3 o .M� d1 6.2 r E t—Et Q7 = O V d C= _ m'C.: t� O C w�'p O� OOo= v v 0 3�.. ?a v Z Or� o CR Z _ _ = O i v �70�v ,earCJ°0yR30y aE e3oR3 'Z�eo-- __-°'��.vEt�`� :.Xri—B—':' Lr 1 Vil Y.\.Vau "Ina ► an Through Panel With Land Deal Amendment By DANIEL M. WEINTRAUB, Times Stay Writer SACRAMENTO--Legislation to move Orange County's proposed toll roads a step closer to construc- tion breezed through an Assembly committee Thursday after Sen. John Seymour (R-Anaheim) amended the bills to remove objec- tions from key lawmakers. The two bills were approved by the Assembly Transportation Com- mittee on identaca) 8-1 votes after a hearing that lasted less than a minute. The measures now go to the Ways and deans Committee. The legislation designates the Eastern and Foothill transportation corridors as state highways. ensur- ing that the roads can be turned over to the state for maintenance after they are built with money from tolls, developer fees and the federal government. The third cor- ndor, the San Joaquin Hills. is already designated as a state high- way. Although the content of the bills themselves has never generated much controversy, Seymour has faced obstacles at every turn from legislators who tried to extract concessions from him after they realized how badly the bills are wanted by Orange County officials and the major developers whose pro)ects would be served by the roads. Amendment Accepted And so Thursday, Seymour ac- cepted an amendment that will scuttle the bills unless the Irvine Co. agrees within 90 days after the bills take effect to donate as open space up to 5.300 acres of land in Limestone Canyon east of Orange. That amendment was demanded by Assemblyman Richard Katz (D- Sepulveda), chairman of the Transportation Committee and a bird lover who wanted the land set aside as a home for birds of prey. Seymour said he accepted the amendment because the Irvine Co. was prepared to forfeit the land anyway. But he said he did not like the idea of writing the deal into state law. "I think it's bad public policy to in the state Legislature !xtract private property. That should be none :n the environrr. n,a1 :mtiact process," Seymour said. "It's a local matter to be determined between the Board of Supervisors and the private property owners." Seymour accepted another amendment Thursday that would allow the state to pay for mainte- nance of toll bridges, just as it would for the toll roads if his bills pass. That amendment was de- signed to overcome the objections of two powerful Bay Area senators who threatened to block the bills unless they contain concessions for that region's bridges. By accepting the toll bridge amendment, Seymour may also have helped himself overcome yet another problem with the bills, the opposition of Sen. Daniel E. Boat- wright (D-Concord). Opposition Vowed Boatwright. whose support was crucial to the bills' passage in the Senate. has vowed to oppose both measures. because last week Sey- mour backed away from his earlier pledge that no state funds would be used to plan or build the Foothill or Eastern toll roads. That provision, which was inserted into the bills at Boatwright's insistence, was re- moved by the Transportation Com- mittee at Seymour's request Thursday night. Seymour said he abandoned the guarantee after he saw a prelimi- nary study conducted for the Transportation Corridor Agencies. The study concluded that state funds might be needed to help repay the bonds that the agencies will sell to finance construction of the roads. Seymour noted that Boatwright may find it more difficult to oppose the bills now that they would provide money to maintain the Bay Area bridges, some of which are in his district "If he votes against the bill, he's going to be votingagainst his bridges." Seymour said. Boatwright could not be reached for comment Thursday night. Although Gov. George Deukme- jian has taken no position on the two bills. Seymour said Caltrans has assured him that the depart- ment will recommend th:t he g ;ver^.or �gn the bills. EXXHIBIT 4 • dos,Angeles Mazes Friday, August 12. 1988 / Part 11 3 0 E Exhibit (213) 620-3755 July 8, 1988 File: ORA-73 SJHTC 12209-102540 Mr. Jerry Bennett Transportation Corridor Agency 3347 Michelson Dr., Suite 450 Irvine, CA 92715 Dear Mr. Bennett: Caltrans has completed its study of potential NEPA-protected resources located within the proposed San Joaquin Hills Transportation Corridor area, a portion of which is currently being graded for the Aliso Viejo development. Our studies revealed the following for the area between El Toro Road and Alicia Parkway. Archaeological Resources An archaeological site (CA-ORA-389), determined to be potentially eligible for listing on the National Register of Historic Places is located within the limits of the study area. The precise location of the. site is illustrated on the SJHTC "APE" maps on file at the County EMA. This site is included in the SJHTC Phase II (test level) RFP being prepared by the County. It is anticipated that under a normal processing approach it will take approximately 6 to 8 months (from the time the contract is awarded) to determine the eligibility of the site. If it is found to be eligible, and if it cannot be avoided, it may be necessary to salvage the site. This work is anticipated to take approximately 4 to 6 months. Any disturbance to this site prior to the completion of the 106 processing could jeopardize future state and federal funding on the SJHTC. Biolocical Resources The Caltrans studies also identified two wetland systems within the Corridor study area. These wetlands are located along E1 Mr. Bennett -2- July 8, 1988 r Toro Creek and Aliso Creek. Before these areas are impacted, Section 404 permits would need to be processed through the U.S. Army Corps of Engineers and 1601 permits would need to be processed through the Department of Fish and Game. Consultation with the US Fish and Wildlife Service and Department of Fish and Game would also need to occur to determine the significance of the wetlands as well as to develop mitigation for any unavoidable impacts. Caltrans and FHWA would need to be involved in the consultation efforts. Four species currently listed as Candidate Category 2 species on the Federal Threatened and Endangered Species List have also been identified within the study area. These species include the Mary -stemmed Live Forever (Dudleva multicaulis), Orange County Turkish Rugging (Chorizanthe staticoi es chrvsacantha), Black - tailed gnatcatcher (Polioutila melanura californica), and San Diego Coast Horned Lizard (Phr nosoma coronatum blainvellei). The latter two species are also identified as being o "special concern" in the State of California. The locations of the populations or the sightings are illustrated in Figures 4-20 in the DEIR and in Chapter 2 of the "Biological Resource Analysis." Caltrans and FHWA normally consult with the US Fish and Wildlife Service and the Department of Fish and Game prior to initiating any action with potential to impact candidate species on the federal list of threatened and endangered species. Mitigation measures for impacts to candidate species proposed by these agencies is commonly incorporated into the overall mitigation program. It is our understanding that as of this writing, the area where the San Diego Coast Horned Lizard had been sighted has been graded and that a haul road has impacted about 30% of an intermingled population of Dud_ 1_ eya and Chorizanthe. In conclusion, our research has revealed the existence of an archaelogical site, wetlands, and candidate endangered species within the Corridor study area between E1 Toro Road and Alicia Parkway. It is incumbent upon the County and TCA to ensure that no disturbance occurs to these federally protected resources, or prior to any disturbance, a mitigation package is developed and approved by both Caltrans and FHWA in order to preserve the opportunity for future state and federal funds/participation. Wr. Bennett -3- July 8, 1988. All future communications on the three proposed -Corridors related to environmental issues involving Caltrans should be directed to Jeff Bingham or Lew Bedolla of District 12. Very truly yours, i!GINAL SIGNED BY RONALV INSKI Senior Environmental Planner Environmental Planning Branch DH:rm cc: Glenn Clinton, FHWA-Division Lew Bedolla, District 12 Jeff Bingham, District 12 Robert Rende, OCEMA Pat Lee, OCEMA Elizabeth Brown, Laguna Greenbelt Andrette Adams, CAA 0 0 Exhibit 6 FOR EACH ALTERNATIVE, THE FOLLOWING INFORMATION SHOULD BE PROVIDED: 0 Capacity (ADT) Traffic Demand From Existing Development (ADT) & (LOS) Existing Through Traffic (ADT) & (LOS) ADT & LOS For Existing Conditions Foreseeable Planned County Development Traffic Demand (ADT) (2010) Planned City Development Traffic Demand (ADT) (2010) Projected Through Traffic Demand (ADT) (2010) ADT & LOS For 2010 Conditions 044a/lag r* Table 1 Corridor Alternative A . Segments Interchanges A B C ... 1 2 3 ... • 0 • Exhibit 7 0 • TABLE 3-4 ENDANGERED, RARE OR DISTRIBUTIONALLY RESTBICTED.SPECIES IN TEE. UNITED STATES SPECIES LOCATION Calior..ia Adder's Tongue Fern Rancho Laguna watershed Oohioslossum Iasi=anic•:m Cali�ornicua Crows beard Verbesi^.a dissita Western dichondra Dic oral_ a ccci.centali.s :�.arv-steed dudleya D- dieva ='u" caulls Laa•.u:a Beac^ dudleya 1 DL'Cleya stolori:era _ sh s milk -wort ?olv_ala cornuta -ishiae Oranze County 7"'Urkish Ruggi.ng Chorizart` a stat4 coides ssp. Chr,rsacar.c..a Bus:: r,-,e Cneoric� u^ cumosu^ *Excludes Sycm=e ?.ills. Data for this area is on f�Ie -= the Dent. of Cc m m ity Development, City of Lag = Beach. South city watershed Temple Hills Rancho Laguna watershed Big Bend Laguna Canyon South city watershed Upper Dripping Cave and Pcta Rock Canyon Canyon Acres Big Bend Canyon Acres Agate Canyon Diamond Canyon Crestview/Juanita Ridge Canyon Aces Big Bend Park Canyon Ri.mrock Canyon Rancho Laguna watershed South city watershed Irvine Bowl Canyon Acres Park Canyon Rancho Laguna watershed Agate Canyon Diamond Canyon Crestview Canyon South city watershed Crestview/Juanita Ridge Cc:.s_cerec :::e tost sensitive plant species = the City 40 TABLE 3-4 (COST.) Sce_._. es Coast horned lizard Phrv.osoma coronatum blainvel e- Orange-throated whi?tail Cne=jdophorss hvpervthrus Golden eagle Acuila chrvsaltos Pereg-ine :alcon Falco ceresr inns LocationI Sycamore Hills Arch Beach Heights Temple Hills area Laguna Canyon Sycamore Hills Nest site - Irvine Ranch Mig_ atirg through area Source: Biological Resources Inventory City of Laguna Beach October 1982 41 • 9 0 �i UNT :I)6 11gClC.v (Tiimcs ORANGE CO Y Vedioc y.July 17.19M LOCAL AND S.OUTHLAND NEWS a EDITORIAL FACES Site la Mission viM CO.'s Alimo V*o ohernted wrefe nity meet intereeataon of El Toro Rood am La Carryon Rood. Builder Digs in Fragile Habitat Error Brings U.S. Warning on Toll Route By JI M CA RLTON. mmn Sfalf Warr road mistakenly cut by a betiding contractor threufh an env+rpm, ftta fly eerotuve uee east of Laguna Canyon has promoted ledtral otflelalt to al wile" that mtlar nliriak" In the future may ?tooardlae leo"ll funding for the San Joaeuln Hills Tnnsponauon Comdor. Canty orlidlols and Tummy that they acknowledged the rrrtw after State Offkws, who were eanduetlns an en•nor"""tal riudy at"eered tax dirt rood a few weeks ago Culung through the sm. which d hw" to two pre pant opmeq and a in reetened aneeles of hur& After the irtetake wu found, F'"MI Highway Admire itrstion uflewls warned the courtly that main such ineuradrta Could hsnn OW eountY's Monett of wtrn"ng federal funding of uo to 35% of the Cori of whot will to be California'a nrri toss rend. The c mdw will be in the fare general ."I as the hoOing red. and environmentalists have raised concerns about the threat to the hshftat. Above $tain Milllo" at Stake Smee the San Josaon Hills 'iramoortauon Corridor is protected to cost about 1466 mflhon to build, the federal money It alike ainounu to scout sl6o fmnbn, Singe then. county officials have oroKld the rood —owls to Mu nwtenall to and from the Aline Y,rto tonetructlon Ine—cordoned off until state end fMeral •nvnronmen(sl Impact YINIIP are eomOfeted for the ,rrn,Mr, wnlrh ,a (hr Subteen of IwMK nennngl tan a pfopooed nineananment County oenners, who ad the oevefoper and MIMOntraetor did son ofew ha rw« as.rd .f�.raaaff Seattle A CW~o W the _ seers, w ,-M, pwwa mer, s +� we teeeaa N tewawf COrtCern, y Mere Cmr,v„en rser-M. w rM al"o, tfax arnesoaoao a the coin" tin Mrnad fftaro hax Men toned N orange Cann. it puffs t wfeavera0ax weed avM and Is are feet' in graxwefdv. me, ewOlw lereol. oraea-he.ed -90deb xte and In W.ImnOt o" eende wn%g , ns elaet" moms" We a111 butts to loss of limn" and Oflwow vehkfs tram. Mwry-aerwrW NiaYe it7ir7trre ntMnw:d uloaKaE efneenw and rock aatvoae w w Coaxial aaa and nests, pad. a" 0 of losan e" in Awge COaw r. Coreha Os, Mar. Lor ft "Do. Me -OCR Bee. War C.rr rL parMta t«a. Owrrea ranee --,,—M Ogee" w Of"llo Cetnuv: are tvarww w Alva am. Los Afneawa. Son Oppe are San dwnar it" evens. /'/Ofveal hf"Orr naxw alwwrfanf Thrsetw nothing wrong, will revive nawtd county mocea—M to tn. wire that Wren envflat of Laity setiwuve are" we pteteetod In the hwurt. Carol CIMIL a planner for the county Environmental Management Agency, sold the eomuwtor. whose name she said she did net know, cut the hauling rood while working On •grading for the Mission - v1e10 Ct...'I MOM -home AI110 Wep planned community, south of ill Toro Read. ' The teed out through 3D% of two plant speetes, the ntany•stel"med dudloys Ind Turktsh rug imq. which we both wndida/es for the federal fist of thrfste"ed and endangered .%ex. according to limit Deoanment n( Transamtauon senior wanner Ronald J. 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The Conceptual Grading Plan (see Figure 3.2.3) was utilized to identify modifications. To determine whether an impact is significant, the following three criteria were applied (if any one criteria is met, there would be a significant impact): 1) Modification or elimination of landform features (e.g., filling in a drainage or removing a hill); 2) Areas where the elevation change along the length of a graded slope exceeds 100 feet; and 3) Areas where the depth of cut or fill exceeds 50 feet. Table 4.1.A summarizes impacts to the sites's landform features identified in the Setting section by code. Specific depths of cut and fill and level of significance for each impact associated with each of these landform features are identified in the text below. A large graded cut is planned along the northern project boundary. This area is planned as the main parking lot/arrival piazza for the proposed project (Area 1 per the project site plan, see Figure 3.2.1). Landform features af- fected (i.e, removed or modified) by this cut include the prominent hilltop (PA 13C-a) and ridgelines which extend from PA 13C-a (i.e., PA 13C-b, and the northern sections of c and d). Depths of cut range from two feet along the western edge of this cut area to a maximum of approximately 24 feet in the vicinity of PA 13C-a. These cut depths are not considered to be significant per Criterion 3 as identified on Table 4.1.A. However, grading of the site will modify features PA 13C-a, b, c and d. Removal of the hill identified as PA 13C-a as a result of project grading is a significant impact per Criterion 1 (see Table 4.1.A). The central portion of PA 13C-c (ridgeline) will be filled to depths rang- ing up to 20 feet in the vicinity of the ballroom/conference room (Area 3). The southern portion of PA 13C-c will be subject to cuts ranging in depth from 2 to 12 feet in the vicinity of the proposed spa (Area 11). These depths of cut and fill are not considered significant per Criterion 3. 08/15/90NDC901\SECT4A.EIR) 29 0 Source: RBF SCALE IN FEET 0 60 120 LEGEND PA13C - Planning Area a - Landform Feature Code • A. � n A I J r-luur,lG 4. I. 1 EXISTING TOPOGRAPHY Lsa 115/l/90:AS .00, Ummmommommm ■ ATTACHMENT 2 CHAPTER 2: INVENTORY OF CURRENT CONDITIONS -01 AND FUTURE PROSPECTS EXHIBIT 4 Ll I. INTRODUCTION The dynamic growth of Southern California has earned it the status of being the eleventh largest economic center in the world. If the growth trends of the last ten years continue, the region will experience almost a 50% increase in population in the next 20 years. This growth has manifested itself in three regional problems which are closely related: rapid growth, transportation, and air quality. Population growth means more traffic and more businesses, and each of these has adverse effects on air quality. No single national resource has such a direct bearing on the public health, safety and welfare as air. It is one of the basic ingredients of the environment, essential to all forms of life. Unlike other resources it has no substitutes, cannot be imported when local supplies are deteriorated, and allows no reduced -use conservation measures. However, like other resources, urbanization has deteriorated its quality. Orange County lies within one of the most severely air polluted regions of the country. An adverse combination of heavy pollutant emissions, meteorology, topography, and air chemistry result in a situation in which state and national standards for air quality are exceeded regularly. -1- II. HISTORICAL BACKGROUND A. Historical Legislation In 1970, Congress passed the Clean Air Act. It requires the administrator of the United States Environmental Protection Agency to establish National Ambient Air Quality Standards (NAAQS) for six major pollutants: carbon monoxide, hydrocarbons, oxides of nitrogen and sulfur, particulates and photochemical oxidants. The Act requires each state to attain and maintain federal standards through the development of State Implementation Plans. Each state is to develop a plan and submit it to the Environmental Protection Agency (EPA) for approval. State Implementation Plans (SIPs) require emission restrictions and timetables for compliance, inspections, air monitoring systems and adequate staff and funding. In cases where a state does not draft a satisfactory SIP, the EPA is required to supply one. Because the EPA failed to meet its August 1974 deadline for publication of guidelines for the SIPs, the EPA Administrator defined individual deadlines for each state. California's deadline for submission of its first SIP was July 1, 1979. The California Legislature, recognizing that air quality was a regional problem in Southern California, enacted the Lewis Air Quality Management Act of 1976. The Act reorganized the Southern California Air Pollution Control District into the South Coast Air Quality Management District (SCAQMD) with authority to regulate stationary sources of air pollutants in the region. The SCAQMD in conjunction with the Southern California Association of Governments (SCAG) is charged with developing a comprehensive plan for attaining and maintaining state ambient air quality standards. The Air Quality Management Plan (AQMP) is to be adopted by SCAG and SCAQMD and submitted to the California Air Resources Board. The AQMP is then to be included in the SIP for EPA's approval. The Act further requires continuous implementation monitoring and updates of the original plan every two years. For detailed information regarding the Air Quality Management Plan, refer to Section V, Subsection B. of this chapter. -2- In 1977, Congress amended the Clean Air Act. The new law placed additional requirements on SIPS from non -attainment areas. A non -attainment area was defined as one unable to demonstrate attainment of the NAAQS for oxidants and carbon monoxide by December 31, 1982 after implementation of all reasonably available control measures. The South Coast Air Basin (SOCAP) is designated as such a non -attainment area. The 1977 Amendment required non -attainment areas to prepare a SIP in 1982 outlining additional standards designed to meet NAAQS by 1987. It also required the adoption and implementation of a motor vehicle inspection and maintenance (I/M) program as part of the 1979 SIP. B. Air Quality Management Plan Process SLAG and SCAQMD, in a joint effort, elected to meet state and federal requirements through the Air Quality Management Plan. SCAG and SCAQMD were also required by the Lewis Act to designate subregional planning agencies responsible for preparing preliminary plans for each of the six subregions within SCAG's jurisdiction as a Metropolitan Planning Organization. This was intended to ensure the participation of local governments in the development of the AQMP. The County of Orange was designated as the subregional agency for AQMP planning in Orange County. SCAG and the SCAQMD forwarded the 1979 AQMP to the California Air Resources Board (CARE) ir. January 1979. After revisions, the CARE approved the AQMP and submitted it to the EPA. Because the AQMP did not contain a legislatively adopted inspection and maintenance program, the EPA placed the Clean Air Act mandated sanctions on California. These sanctions prohibited construction of new major pollution sources. z- Additional sanctions were placed on California in 1980 in response to the continuing delay in adopting an I/M program. The latter sanctions involved the loss of federal funds for transportation and sewer projects. The 1982 AQMP Revision built upon the process established earlier. Utilizing a refined emissions inventory and improved modeling techniques, both the SCAQMD and SCAG determined that it would be impossible to attain the 1987 ozone and carbon monoxide deadlines even -3- with the strictest feasible controls on both motor vehicles and industrial sources. Attainment of the ozone standard would require major shifts away from petroleum products and was unlikely to come before the year 2000. The AQMP contained many control measures which relied on new technologies expected to become available, as well as a long-range strategy. The two agencies committed to revise the plan in three to five years to better define future control efforts. The 1988 AQMP revision establishes the regional attainment of federal air quality standards by the year 2007. The 1988 AQMP process is an attempt to promote ways in which growth can occur, yet provide mitigation for externalities such as traffic congestion and the resultant impact on air quality. In order to make significant progress toward the regional attainment goal, the 1988 AQMP contains a series of control measures. Each measure proposes a set of actions designed to cause a reduction in emissions. For a detailed chronology of air quality legislation and planning, see Appendix D. Prior to the 1982 AQMP revision process and throughout the 1988 revision • process, various sub -regional processes were incorporated to solicit local jurisdiction participation and aid in the AQMP revision process. Among these sub -regional processes are the Reasonable Further Progress report, the Reasonable Extra Effort Program, and the Early -Action Plan. The Reasonable Further Progress (RFP) report is an annual survey of local governments and other implementing agencies. The analysis focuses on control measures scheduled for implementation during the report year and previous years. Whenever possible, the potential effectiveness of individual measures in reducing air pollution is discussed. The Reasonable Extra Effort Program (BEEP) is a response by EPA Region IX (California) to the problem of non-compliance to the Clean Air Act by 1987. Under BEEP, EPA has identified existing and new control measures, and has requested that affected districts (South Coast, Fresno, Sacramento, and Ventura) develop schedules for adoption. These schedules are to be submitted as amendments to the State Implementation • Plan. Additionally, these post-1987 areas are to revise the New Source -4- Review regulations, develop transportation control measures where ifeasible, and participate cooperatively in audits of their enforcement and permitting programs. As an important component of this program, the Air Resources Board is also developing short-range measures to further reduce emissions from motor vehicles. SCAG and AQMD first actively participated in EPA's REEP in 1985. In late 1986 and early 1987, the AQMD took some significant actions to directly address the less -than -expected progress in reducing Reactive Organic Gas (ROG) emissions in the Basin. An Early -Action Plan (ZAP) for Short -Range Control Measures for the projected 1987 revision to the AQMP was completed. The EAP commits the AQMD to expedite development and begin adoption proceedings for 13 control measures, some of which are new, on an earlier schedule than contained in the 1982 Plan update. Included in the EAP is a revision of Regulation XIII and New Source Review with the objective of significantly reducing emissions from those new sources which fall below the current thresholds of Regulation XIII or are exempt from its provisions. Q-M III. AIR QUALITY OVERVIEW • A. Regional Overview Although overall air quality in the South Coast Air Basin has shown improvement in recent years, levels of two pollutants, ozone and nitrogen dioxide, are still the highest in the United States. The Basin consists of the non -desert portions of Los Angeles, Riverside and San Bernardino counties and all of Orange County. Its area is approximately 6,600 square miles. The Basin is bounded on the west by the Pacific Ocean, on the north and east by the San Gabriel, San Bernardino, and San Jacinto Mountains, and on the south by the San Diego County line. The 1980 census showed a population of 10.9 million, with 7.4 million people concentrated in the Los Angeles County portion. Meteorological conditions in the Basin are more conducive to photochemical pollution formation than those in any other large urban area in the nation. • As a result, increasingly stringent pollution controls have been placed on industrial sources in Los Angeles County since the late 140s and in the other three Basin counties since the 150s. California was the first state in the country to require controls on motor vehicles. Because of these controls, there has been a gradual decline in atmospheric pollutant concentrations, despite a 125 percent population increase between 1950 and 1980. By the 180s, peak ozone levels had dropped more than 30 percent from the highs recorded in the 150s and by 1985 all stations in the Basin were in compliance with state and federal standards for lead and sulphur dioxide. B. Orange County Climate Climate is probably the most important factor in the growth of Orange County. Implications for the health and well-being of County residents as well as the environmental quality are such that it is essential that we know more about the weather and climate, and the relationship between land use, -6- transportation, and air quality. Such characteristics as temperature, rainfall, winds, humidity and cloud coverage affect our energy needs, recreation activities, air quality, water resources, fire protection programs, flood control, airport management, agricultural crops, native vegetation, and much more. Weather in the County, and in the South Coast.Air Basin as a whole, is a function of a semi -permanent high-pressure zone over the eastern Pacific Ocean. The resulting climate is mild, typified by warm temperature and light winds, the dominant wind pattern being a.daytime sea breeze (on -shore) and a nighttime land breeze (off -shore). This prevailing condition of alternate light winds tends to carry pollutants inland during the day, and drift them back toward their point of origin during the evening. The topography of the area creates local distortions in the prevailing meteorological pattern. Air currents are directed by advection through mountain passes or deflected aloft by a 'chimney effect' produced by the solar heating of mountain slopes. The most significant effect of this general topographic distortion in the Orange County area is a predominant daytime air mass transport across the Long Beach/San Pedro area, through northern Orange County, and into the San Bernardino/Riverside vicinity. The average monthly temperatures range from about 52 degrees F. in the coastal areas in January to 72 degrees F. in the inland areas of the coastal plain in August. The difference in temperatures between the coast and inland areas is greatest in the summer months. The winter maximums are about the same while inland minimums are lower throughout the year because the ameliorating influence of the ocean is weaker. Temperatures are significant in terms of their effects on agriculture and outdoor recreation. The County's rainfall regime In characteristic of mediterranean climates. A modest average of 14 inches falls principally during the winter months (December to March). The County's rainfall also exhibits characteristically wide variations annually (from a low of 3.6 inches in 1961 to a high of 32.1 • inches in 1940). It is not unusual for winter storms moving in from the Pacific to produce 3 to 10 inches of rainfall within a 24-hour period. The -7- implications for water supply, irrigation, flood, fire and erosion control are considerable. Fog is a distinctive feature of the County's weather. During April, May and June, fog or low clouds form at night and often persist until noon. Visibility in the fog remains adequate for travel, however. During the summer, with the semi -permanent low in the desert areas and a relatively high pressure area off the coast, varying degrees of fog or cloudiness occur in the coastal area. Many people seeking relief from heat waves and brilliant sunshine of the interior coastal plain are surprised by coastal fog and low temperatures which may also persist until noon. Heavy fog in December and January is also a predictable occurrence. Annual average relative humidity is 70% at the coast and 56% in the eastern inland areas. with very light average wind speeds, the South Coast Air Basin atmosphere -has a limited capacity to disperse air contaminants horizontally. The `prevailing northwest winds of the summer months associated with high pressure off the coast give way to those generated by the passage of storm fronts in winter months. Summer winds speeds average slightly higher than • winter wind speeds. The dominant daily wind pattern (daytime sea breeze and a night-time land breeze) is broken only by occasional winter storms and Infrequent strong northeasterly Santa Ana flows from the mountains and deserts north of the Basin. Santa Ana winds, with velocities of up to 70 miles per hour, send dry air from the desert to the coastal plain. On the way, temperatures are increased, often to 100 degrees F. This combination of high temperatures and velocities, and low humidity coming at the end of the dry summer months, creates an exceedingly hazardous potential for wildland fires. Boat harbors are also seriously affected. More common are gentler daily sea breezes and nightly offshore breezes and moderate coastal temperatures. 'On practically all spring and early -summer days, most of the pollution produced during an individual day is moved out of the Basin through mountain passes or is lifted by the warm, vertical currents produced by heating of mountain slopes. In those seasons, the Basin can be •flushed" of pollutants by a transport of ocean air of sixty miles or more during the afternoon. • -8- from late summer through the winter months, the flushing is less pronounced because of lighter wind speeds and the earlier appearance of off -shore (drainage) winds. With extremely stagnant wind flows, the drainage winds may begin near the mountains by late afternoon. Pollutants remaining in the Basin are trapped and begin to accumulate during the night and the following morning. A low average morning (6:00 a.m. to noon) wind"speed in pollution source areas is an important indicator of air stagnation potential. Under ideal meteorological conditions and irrespective of topography, pollutants emitted into the air would be mixed and dispersed into the upper atmosphere. However, the Southern California region frequently experiences temperature inversions in which pollutants are trapped and accumulate close to the ground. The inversion, a layer of warm, dry air overlaying cool, moist marine air is a normal condition in the southland. The cool, damp and hazy sea air capped by coastal clouds is heavier than the warm, -clear air aloft which acts as a lid through which the marine layer cannot rise. The heights of the inversion is important in determining pollutant iconcentration. When the inversion is 2,500 feet or so above sea level, the sea breezes carry the pollutants inland to escape over the mountain slopes or through the passes. At a height of 1,200 feet, the terrain prevents the pollutants from escaping and it backs up along foothill communities. Below 1,200 feet the inversion puts a tight lid on pollutants, concentrating them In a shallow layer over the entire coastal basin. Usually, inversions are lower before sunrise than during the daylight hours. The mixing height normally increases as the day progresses, because the sun warms the ground, which in turn warms the surface air layer. As this heating continues, the temperature of the surface layer approaches the potential temperature of the base of the inversion layer. When these temperatures become equal, the inversion layer begins to erode at its lower edge. If enough warming takes place, the inversion layer becomes weaker and weaker and finally 'breaks". The surface air layers can then mix upward without limit. This phenomenon In frequently observed in the middle to late afternoon on hot summer days when the smog appears to clear up suddenly. Winter inversions frequently break by mid -morning, thereby preventing contaminant build-up. During winter months, the inversion layer is broken up by passing storms. In the spring, April through June, the inversion layer is normally high and air -9- quality is good. The inversion layer descends progressively during summer with the most adverse air quality conditions in August and September. Ccmpounding this problem of pollutant concentration is the phenomenon of photochemistry in which certain original, or "primary,' pollutants (mainly reactive hydrocarbons and oxides of nitrogen) react under the influence of the ultraviolet radiation of sunlight to form 'secondary" pollutants (principally oxidants, the most serious problem in this region). This photochemical process is time -dependent which weans that secondary pollutants can be formed many miles downwind from the emission source of their primary precursors. Photochemical smog levels are Bauch lower during winter due to the lack of strong inversions during the daylight hours and the lack of intense sunlight which is needed for the photochemical 'reactions. The potential for high concentrations varies seasonally for many contaminants. During late spring, summer and early fall, light winds, low mixing heights and brilliant sunshine combine to produce conditions favorable for the maximum production of photochemical oxidants, :vainly ozone. In the summer, the longer daylight hours and the brighter sunshine combine to cause a reaction between hydrocarbons and oxides of nitrogen to • form more of the typical photochemical smog. Carbon monoxide is not as great a problem in summer because inversions are not as low and intense in the surface boundary layer (within one hundred feet of the ground) as in winter and because horizontal ventilation is better in summer. IV. AIR QUALITY ANALYSIS Almost without exception, human activities all create some type of pollution. When these activities are concentrated in space, and when climate and geographic and atmospheric conditions restrict air currents, waste products collect in the air. The result is air pollution. Pollutants can be smoke, dust, fumes, vapors, pollens or any toxic substance that Interferes with the use of air by humans and other living things. Many economic as well as health effects of pollutants have been identified: they can erode and discolor building materialst break down rubber, paint and fabrics; slow the growth of and/or kill plants; and increase the risk of -10- cancer and respiratory ailments. It is reasonable to assume that there are other effects that have not yet been identified. Air pollutant emissions are generally grouped into three source categories: natural, stationary and mobile. A major form of naturally produced air pollution is photochemical smog which is caused by complex atmospheric reactions involving oxides of nitrogen and reactive organic gases with ultraviolet energy from sunlight. "Photochemical Oxidants" can include several different pollutants, but consists primarily of ozone (more than 90 percent) and a group of chemicals called organic peroxynitrates. Photochemical oxidants are created in the atmosphere rather than emitted directly into the air. Stationary sources are man-made facilities or structures which generate emissions. Examples are as follows: fossil -fueled electric generation plants; domestic and commercial boilers and furnaces; asphalt batching plants; dry cleaning operations; and auto painting establishments. The major air pollutants emitted by stationary sources are carbon monoxide (CO), hydrocarbons (AC), oxides or nitrogen (NOx) , oxides of sulfur (Sox) , and total suspended particles (TSP). Mobile source emissions are divided into on -road and off -road sub -categories. on -road sources are licensed motor vehicles operating on the public road system, including motorcycles; automobiles; and light, medium, and heavy-duty trucks. There are five major air pollutants emitted by motor vehicles: carbon monoxide (CO), hydrocarbons (BC), oxides of nitrogen (NOx), oxides of sulfur (Sox) and total suspended particles (TSP). Emission inventories, both current and projected, are maintained for each of these pollutants by the South Coast Air Quality Management District. Gasoline engines account for the majority of on -road CO, NOx, and AC, while diesel buses and trucks account for most of the Sox and TSP. Mobile sources are presently a major contributor to air pollutant emissions In urban areas. As a result, projects that increase vehicle use are acknowledged by the label "indirect sources". An indirect source is any 91 facility, plant, installation, or activity that has a significant amount of -11- mobile source activity associated with its operation or use. Parking facilities, roadways, and airports are examples of indirect sources. Included in the parking facility category are shopping centers, sports complexes and other large facilities. Most indirect sources include emissions from stationary sources. Airports, for example, have stationary source emissions associated with refueling operations, as well as space heating and cooling of the terminal. Aircraft operations also contribute to the total emissions. This is an example of how a project's contribution to mobile source emissions and stationary source emissions must be considered. To assist in the evaluation of the air pollution situation, the various contaminants and their health effects are discussed briefly below. Carbon monoxide (CO), by weight and volume the most common air pollutant in the South Coast Air Basin, is a product of the combustion of organic compounds, including wood, coal, and hydrocarbon -based fuels. It is a colorless, odorless, tasteless gas that is slightly lighter than air. CO acts as a poison by interfering with the blood's ability to carry oxygen and transfer it to other tissues. In order to present a clear threat to human life, CO needs to be highly concentrated under very stagnant air conditions. In the case of transportation facilities, such stagnant air is extremely rare. Ozides of nitrogen emissions result from high -temperature combustion of fossil fuels. Accordingly, the high-speed internal combustion engine contributes heavily to NOx emissions, as do various industrial facilities (stationary sources) . Nitric oxide (NO) In the most prevalent form of such emissions, while other oxides, (NO2 and NO3) are formed by chemical oxidation of the lower -order nitric oxide. Like reactive hydrocarbons, oxides of nitrogen are important ingredients in the formation of photochemical smog and, hence, are important to air quality analysis. Nitrogen dioxide MOO In the most toxic pollutant in this group. it has been shown to contribute to respiratory problems and, in high • -12- concentrations, can be fatal as a result of pulmonary edema (swelling and degeneration of lung tissues). Sulfur oxides are also a product of combustion. Among on -road sources, diesel trucks and buses are the main contributors because of the combustion characteristics and sulfur content of diesel fuel. The species of concern Is sulfur dioxide (S02). It is a non-flammable, colorless gas that has a pungent odor. By chemical reaction, sulfur dioxide plays a role in the formation of various sulfate compounds including, under the correct atmospheric conditions, a sulfuric acid mist. Low -sulphur fuels have tended to reduce the impact of motor vehicles as a source of sulfur oxides pollution. Photochemical oxidants are created in the atmosphere. Reactive organic gases, including hydrocarbons, and oxides of nitrogen are the emitted contaminates which participate in the reaction. Ozone is.a toxic gas which Is produced by the photochemical process. Photochemical oxidant is a characteristic of Southern California type smog, and reaches its highest concentrations during the summer and early fall. The common manifestations of oxidants are damage to vegetation and cracking of untreated rubber. Photochemical oxidants in high concentrations can also directly affect the lungs, causing respiratory irritation and possible changes in lung functions. Hydrocarbons emissions, in and of themselves, are not generally regarded as a health hazard. Methane accounts for a significant portion of total hydrocarbon emissions (TEC). Because it is rather inactive chemically, it is of little importance to air pollution analysis. The remaining hydrocarbons are chemically reactive and are important precursors to photochemical smog. Hydroca:bon emissions result from the incomplete combustion and evaporation of hydrocarbon -based fuels such as gasoline. Atmospheric particulates consist of soot, dust, aerosols, fumes, and mists. Particulate matter consists of particles in the atmosphere resulting from many kinds of dust and fume -producing industrial and agricultural operations, from combustion, and from atmospheric photochemical reactions. -13- In areas close to major sources, particulate concentrations are generally • higher in the winter, when more fuel is burned, and meteorolcgicsl conditions favor the build-up of directly -emitted contaminants. However, in areas remote from major sources and subject to photochemical smog, particulate concentrations are higher during summer months. In the respiratory tract, very small particles of certain substances may produce injury, or may contain absorbed gases that are injurious. Suspended in the air, particulates of aerosol size can both scatter and absorb sunlight, producing haze and reducing visibility. They can also cause a wide range of damage to materials. For modeling purposes, sources are classified according to the following geometric configurations: point, line and area. Examples of point sources are fossil -fuel electric power generating plants and large municipal Incinerators. Roadways and airport flight patterns are classified and modeled as line sources. oil refineries and residential housing tracts are typical area sources. • • -14- COMMON SOURCE TYPES HC NOx CO SOx Part Point Sources: Fossil -fueled Electric Power Generating Plants x 0 x 0 0 Industrial Boilers 0 0 0 0 0 Processing Plants 0 x x x 0 Line Sources: Highways, Roadways 0 0 0 x x Aircraft x o 0 x x Railroads x 0 0 0 0 Area Sources: Indirect Sources 0 0 0 x x Refineries 0 x x 0 x Residential Tracts x 0 x o x Surface Streets (Aggregated) 0 0 0 x x o - Primary Emphasis x - Secondary Emphasis As stated earlier, the three most relevant emission species in a transportation analysis are carbon monoxide, reactive hydrocarbons (RHC), and oxides of nitrogen. 7t is important to examine the behavior of these types of emissions with respect to the operation of road systems. Carbon monoxide and reactive hydrocarbon emissions are related to the engine's air -to -fuel ratios that is, •1 they decrease as fuel is burned more efficiently and, beyond the point of -15- maximum efficiency, continue to decrease as engine speed increases. Therefore, as delay is reduced and operating speeds increase in a given transportation network, these kinds of emissions are lessened. Oxides of nitrogen, however, behave somewhat differently. NOx is formed during high temperature combustion; as the Combustion rate (i.e., engine speed) increases, the rate of formation of NOx increases slightly. Therefore, improved transportation network speeds result in somewhat higher emission levels of NOx. However, since the marginal decreases in hydrocarbon emission rates are much greater than the corresponding changes in NOx emission rates, the general conclusion is that higher transportation system speeds are beneficial to air quality. Higher levels of emissions (tons/day) can be anticipated as vehicle miles traveled WMT), vehicle hours traveled WHT) and delay time increase. The horizon year 2000 represents the amount of urbanization for that time period. Tables 2-7A and 2-7B illustrate the emissions levels for 1985 and 2010 as assumed in the 1982 AQMP revision. The emissions reduction between 1980 and 2000 occurs as older more polluting vehicles are replaced by newer cleaner vehicles. Thus, the technological improvements more than offset the growth in VMT. Emissions from mobile and stationary sources are given in tons of pollutant emitted per day for each of the five species. There is no direct conversion between emissions in tons per day and pollutant concentration in parts per million (ppm). Therefore, emissions cannot be readily compared to the species concentrations required by the National Ambient Air Quality Standards (NAAQS). Nonetheless, the Southern California Association of Governments (SCAG), charged with assisting The South Coast Air Quality Management District in p_eparing the Air Quality Management Plan (AQMP), was required to estimate levels that must be obtained to meet the NAAQS. In an attempt to relate tons of emissions to pollutant concentrations, computerized air quality models were used. These models predicted that at the emissions levels projected the South Coast Air Basin would not meet the NAAQS by 1987. 0 -26- • TABLE 2-7A SUMMARY OF EMISSIONS BY MAJOR SURCE CATEGORIES: 1985 BASE YEAR (tons/day) SOURCE CATEGORY ROG NOx SOX CO PM PM10 STATIONARY SOURCES Fuel Combustion 17 254 18 67 11 10 Waste Burning 1 1 1 4 1 1 Solvent Use 382 - - - 1 1 Petroleum Process Storage & Transfer 81 10 27 3 4 3 Industrial Processes 24 9 8 6 17 12 Miscellaneous Processes 85 11 2 110 1,514* 652 TOTAL STATIONARY SOURCES 590 285 56 190 1,548 679 MOBILE SOURCES On -Road Vehicles 578 620 35 4,752 84 50 Other Mobile Sources 78 135 30 488 13 12 TOTAL MOBILE SOURCES 656 755 65 5,240 97 62 TOTAL 1,246 1,040 121 5,430 1,645 741 *Includes Paved Road Dust Source: Path to Clean Air: Policy Proposals for the 1988 Air Quality Management Plan Revision, June 1988. South Coast Air Quality Management District and Southern California Association of Governments. -17- TABLE 2-7B SUMMARY OF EMISSIONS • BY MAJOR SURCE CATEGORIES: 2010 BASE YEAR (tons/day) SOURCE CATEGORY ROG NOx SOX CO PM PM10 STATIONARY SOURCES Fuel Combustion 24 241 31 114 18 15 Waste Burning 1 1 1 5 1 1 Solvent Use 469 - - - 1 1 Petroleum Process Storage & Transfer 79 7 27 4 5 3 Industrial Processes 29 7 9 3 19 13 Miscellaneous Processes 97 15 3 79 2,254* 973 TOTAL STATIONARY SOURCES 699 271 71 205 2,298 1,006 MOBILE SOURCES On -Road Vehicles 326 570 30 3,938 111 56 Other Mobile Sources 129 192 38 781 17 15 TOTAL MOBILE SOURCES 455 762 69 4,719 128 71 TOTAL 1,154 1,033 141 4,924 2,426 1,077 *Includes Paved Road Dust Source: Path to Clean Air: Policy Proposals for the 1988 Air Quality Management Plan Revision, June 1988. South Coast Air Quality Management District and Southern California Association of Governments. -18- A comprehensive emergency program has been adopted by the SCAQMD (Regulations VII and XV). This program sets forth actions to be taken by industry, business, • commerce, government, and the public to prevent air pollution concentrations from reaching levels which could endanger or cause significant harm to the public, and/or to abate such concentrations should they occur. In the event of elevated levels of air pollution, the episode program can require substantial reductions in the amount of pollution that may be emitted. In addition to the reductions in emissions, there are also provisions for advising the public to take precautionary measures. Such an advisory includes recommendations to the public to curtail unnecessary physical activities during 'episode" conditions and to remain indoors as much as possible. Episodes occur when the concentration of an air pollutant has reached a level at which a potential health hazard exists. Depending upon the episode level (first, second, or third stage), various segments of the public can be affected. A first stage episode may affect persons with chronic lung or heart disease, the elderly, the chronically ill and the exercising young. Advanced episodes may 16 cause significant aggravation of symptoms and decreased excercise tolerance in healthy persons. V. COUNTY AND REGIONAL AIR RESOURCES MANAGEMENT The management of air resources is dependent on both local and regional activities and controls. The resource itself is clearly regional, since air cannot be confined to the boundaries of any political jurisdiction. For this reason, air quality surveillance and pollution abatement authority Faust be vested in an areawide agency. However, the generation of air pollution Is local in nature and can be substantially affected by local land use and transportation decisions. Following are descriptions of the agencies and plans which comprise the air resources management framework for Orange County and the surrounding region. -19- A. Regional Agencies • In its efforts to improve air quality, the South Coast Air Quality Management District (SCAQMD) has developed the nation's most comprehensive air pollution control program. The District covers California's most populous region - Los Angeles; Orange and Riverside counties, and the non -desert portion of San Bernardino County - 13,350 square miles where approximately 12 million people live and work. The District traditionally has controlled emissions from stationary sources of air pollution. Senate Bill 151 (Presley) amended the Public Health and Safety Code to provide the District with authority to adopt transportation control measures and indirect source controls consistent with Section 40414 of the Public Health and Safety Code. As part of a multi -faceted control program► SCAQMD develops and enforces rules regulating emissions; prepares and regularly updates the Air Quality Management Plan; maintains a network of air monitoring stations to track pollutant levels throughout the region 24 hours a day; coordinates public outreach; and notifies the public of potential air pollution • alerts and the associated health hazards by providing information directly to the public and to the local media on the quality of the ambient air. SCAG is the Southern California Association of Governments, and it has been working to improve the region since 1965 - planning its growth and development, improving relationships between levels of government, and providing an open forum for cities, counties, and the public. As the name implies, its members are governments: six counties - Los Angeles, Orange, San Bernardino, Ventura, Riverside, and Imperial - and 160 cities. SCAG is designated by state and federal governments as the official planning agency for our area: its staff writes plans for, among other things, transportation systems, air and water quality, housing supply, and growth management. • -20- B. Air Quality Management Plan The Federal Clean Air Act, as amended in 1977, requires states to have State Implementation Plans (SIPs) to achieve established air quality goals - the National Ambient Air Quality Standards (NAAQS). The Act requires that urban areas such as the South Coast Air Basin (SCAB) which do not meet these standards for carbon monoxide (CO) and/or photochemical oxidants (ozone, 03), implement transportation plans to achieve the standards for these pollutants. The California Legislature has designated the,SCAQMD and SCAG as the agencies responsible for development of the Air Quality Management Plan (AQMP) which would represent the basin's section of the SIP. A Memorandum of Understanding (MOU) between the District and SCAG, allocates to SCAG the responsibility for non -technical strategies in three areas: transportation, energy conservation, and land use. The original AQMP was jointly published in January 1979 by the District and SCAG; the next AQMP revision was prepared by the same agencies in October 1982. The AQMP, in accordance with the federal guidelines for implementing the Clean Air Act Amendments of 1977, calls for a graduated decrease in air pollution emissions to a level that will permit attainment of the National Ambient Air Quality Standards. Because it is technically difficult to forecast ambient air quality, this analysis was performed on the basis of emission (tons) rather than concentrations (parts per million). The 1988 AQMP establishes the regional goal of the attainment of the federal clean air standards by the year 2007. In order to make significant progress towards this goal, especially in light of the dramatic growth forecast for the region, tough choices must be made. The regional choices for air quality improvement involve not only the issues of demand management, but even more fundamentally the question of how the region will power its growth machine. The 1988 AQMP process is an attempt to promote ways in which growth can occur, yet provide -21- mitigation for externalities such as traffic congestion and the resultant impact on air quality. I. Control Measures In order to make significant progress towards the regional goal of attainment by the year 2007, tough control measure choices have been presented. The trade-offs between stationary source controls, area source controls and mobile source controls can only occur if a major commitment is made by local, county and regional governments. The regional choices for air quality improvement involve not only the issues of demand management, but even more fundamentally the issues of fuel and power. The measures have been divided into three categories: { Transportation, Land Use, and Energy Conservation. There are 25 Transportation measures, one major Land Use Measure and three Energy Conservation Measures. Of these measures, Orange County is . currently implementing 15 measures, to some degree, on the County level. Each measure proposes a set of actions designed to cause a reduction in emissions. The measures are as explicit as possible; although, in many cases, multiple options exist for implementation. C. Regulation XV: Trip Reduction/Indirect Source Regulation XV was adopted by the Southern California Air Quality Management District on December 11, 1987. This regulation sets forth the actions employers which employ 100 or more persons at any worksite must take to promote employee participation in trip reduction and ridesharing programs. These programs are intended to reduce emissions from vehicles used for commuting between home and the worksite. It is the intent of the District to work with affected employers and local jurisdictions in improving trip reduction activities to encourage small employers to join transportation management organizations, and to • -22- evaluate the effectiveness of this regulation two years after it has been fully implemented to insure that it is as effective as possible. The implementation of this regulation began July 1, 1988. D. Orange County Traffic Reduction Incentive Program (TRIP) Regulation XV permits exemptions where employers are subject to a city or county ordinance requiring employer trip reduction strategies as stringent as those found in Regulation XV. The County of Orange has pursued exemption status for local agencies adopting the Traffic Reduction Incentives Program (TRIP). The TRIP program was developed to address Orange County traffic problems by reducing congestion and to improve regional air quality. The program encourages a partnership of local governments, landowners, developers, businesses and commuters to develop realistic and achievable strategies for improving traffic congestion and air quality. The TRIP program is intended to be as flexible as possible by offering a list of strategies • for employers to choose from to implement the combination best meeting their specific needs. U The objective of the TRIP program is to provide congestion relief measures that will result in equivalent emission reductions as in Regulation XV. The TRIP program would be applied to all employers and employment complexes with 100 employees or more and would utilize a point system. Various point values would be given for carpools, vanpools, public transit, bicycling, walking, alternative work hour programs, living within 5 miles of work and non -peak travel. The employer must achieve an average of 34 points per 100 employees. Employers would be required to submit annual reports demonstrating reasonable efforts to achieve the trip reduction objective. CL:jcPA44-36 -23- $239 0 • e �y GA E7 8risbcwe , `'4QSMl lia.. 14 1. Eight Myths of Traditional Traffic planning -his chapter is not an attack on planners, bureaucrats and politicians. The bad manning of the past was not deliberate: it was the result of tunnel vision and an appaiiing lack of accountability. This chapter attempts to expose eight of the most common myths upon which traditional traffic planning is based. IT IS A CONVENTION FOR TRANSPORT STUDIES to forecast future traffic by projecting current trends. population growth and present travel habits. then use these projections to decide what roads are needed for the future. Such an approach looks eminently sensible and forward thinking, until one realises it makes a prior assumption. It assumes the present is ideal and that present travel habits are worth projecting into the future. As Plowden observes: Tfansportation studies hardly ever contain an explicit analysis of the problems of the town under study. There is a very particular view inherent in the whole method of approach... even though very few practitioners seem to have realised quite what they have implicitly committed themselves to... Deeply embedded in this procedure is the idea that the present situation is satisfactory.5 A classic example of this kind of traffic study is a document produced by SKP which 'proves" via computer -generated predictions that traffic on Route 20 will increase by 57% by the year 2006.6 But the study in no wav addresses the hard auestions about the desirability of encouraging this massive increase in traffic or how and why present traffic patterns have developed (the basis of the predictions) and whether what has been encouraged to develop is good or bad. The myth that traffic projections are important in deciding what roads are needed is closely related to Myth 2: planners are not responsible for how much people want to use their cars, and Myth 3: predicted traffic growth must be provided for. EXHIBIT 5 A worid designed by engineers. K'cl41� Traffic projections are important in deciding what roads are needed. Such an approach looks eminently sensible and forward thinking, until one realises it makes a prior assumption - it assumes the present is ideal... =iGHT MYTHS OF TRADITIONAL TRAFFIC PLANNING MYTH 2: PRESENT TRAVEL HABITS WERE NOT FORMED IN A VACUUM. Nor Planners are not responsible for were they inevitable. They are the results of choices and policy decisions by how much people want to past and present governments and councils. Other cities have developed in use their cars. entirely different ways. In every city of the world the volume of traffic is limited, intentionally or unintentionally, by measures adopted by governments. If these measures were relaxed, there would be more traffic, if they were strengthened, there would be less. In other words the volume of traffic in a city is not something like the rainfall that has to be accepted... The volume of traffic in a city is not something like the rain fall that has Paris and Los Angeles are good examples of how past policies shape travel patterns. Both have almost identical to be accepted... populations. Yet roads and sidewalks in Paris only occupy 87 sq km while in Los Angeles they occupy 1201 sq km. Roads and sidewalks represent 24% of the total area of Paris, 37% of Los Angeles. (Off-street parking accounts for another 23% of the Los Angeles central business district) e Houston residents consume two and a half times more petrol per person than Brisbane residents, six times more than London residents, and eight times more than Amsterdam residents.9 Are we really expected to believe that these dramatically different levels of car use are to be attributed solely to some unseen force that decrees that Deopie in Houston or San Francisco will have a greater desire to use their car than in London Amsterdam? people or Even in Australia, Svdnev and Melbourne have very different patterns of public transport and car usage to Brisbane. Adelaide and Perth. MYTH 3: Predicted traffic growth must be TRADITIONAL PLANNERS CLAIM it is irresponsible not to build bigger roads to cater for forecasted traffic growth. But it is universally acknowledged provided for. that new or upgraded roads generate new traffic for the following reasons: 1. New trip destinations are made possible. (For example, the Gatewav Arteriai opened up the Gold Coast as a more attractive day trip for those • on the north of the city.) Traffic expands to fill the available road space. 2. The frequency of some trips increases because access is now easier. 3. People take jobs further from their homes. 4. Some people shift from public transport to private car due to the trip time for the car being reduced. 5. As patronage for public transport decreases public transport becomes less viable and service deteriorates encouraging even more people to use their cars. What have we learnt Mayer Hillman in taking a critical look back 20 years after the landmark Traffic from history... in Towns study by Buchanan in London, had this to say: Heavy emphasis was placed on forecasts of future levels of vehicle ownership and traffic so that these could be used to determine what scale of mad network and parking provision should be planned for. These forecasts necessarily required a confident view of the medium -to - long -term future. However, it was certainly erroneous to make no provision for a future in which economic growth and population did not rise at the anticipated rate. To some extent, an optimistic forecast can be seen as a self-fulfilling prophecy, for it is clear that more traffic is generated by a network of roads designed to accommodate high levels of vehicle ownership. Perhaps the primary objection that can be levelled at the use of traffic forecasts in the Report was that no change in public policy on car use or policy influencing ownership was assumed of sufficient magnitude to affect previously observed behavioural links... Instead forecasts simply 10 EIGHT .MYTHS OF TRADITIONAL TRAFFIC PLANNING 6. New or upgraded roads displace people, spreading the city and therefore requiring that more people travel longer distances, again reducing the viability of public transport. This has caused many planners to talk of a Parkinson's Law of traffic: "Traffic expands to fill the available road space". 10 Or as Porter has commented. "Ironically enough, most communities are trying to overcome the traffic crisis in Nvays that actually perpetuate it."" Even more serious was the failure (of planners) to realise the connection between road -building and traffic volumes: the fact that providing more road space itselfgenerates more traffic...12 With this phenomenon in mind we can see why acceptance of the myth that all predicted traffic demand must be met results in more and more of our cities being handed over to roads. This is best summed up in the diagram opposite. 1. A traffic study is done (year zero) basing future traffic predictions on past trends and travel habits. These trends have not occurred in a vacuum but have been the result of catering for predicted traffic demand. 2. These traffic predictions show that in 20 years time the present road will not cater for the predicted traffic. 3. So the road space for that traffic is created now. This road, by its yen, design has spare capacity to take traffic for the next twenty years. 4. But the generated traffic fills the road to capacity within a couple of years of its completion, causing the traffic planner to congratulate himself for his foresight in foreseeing the need for the new road or upgrade. 5. It also causes the planner to do a new traffic study based on the higher than expected road usage. This of course leads to the conclusion that the road will be hopelessly inadequate before the twenty years is up so it must be further upgraded. This type of planning is termed "predict and provide". It is spiral planning t at encourages an exponential growth in traffic. Understanding this process is the key to why some local residents are so opposed to even a "minor" upgrade of "Route 20". They know as sure as night follows day that unless planners reject "predict and provide" planning, the upgrade will be "minor" today, "major" tomorrow, and "mammoth" soon after. included the caveat that "...no proper allowances can be made... for possible changes in Government policies, for instance on restraint and road provision ", even though these obviously influence traffic levels. It is not surprising that forecasts of traffic levels and of vehicle ownership have been notoriously unreliable. Had the 1965 forecasts of car ownership in the Report for 1980 been realised, there would have been an additional 15 million cars rather than the actual additional 8 million. Moreover, the reliability of more recent forecasts has tended to deteriorate. It is not surprising that a TRRL sponsored study led researchers to conclude that British transport studies which have relied heavily on these forecasts have "a chronic tendency to over -predict almost everything".13 i 5. New tudy j based on / new trends, i i i i 13. Road space 4_Traffic expands created no :: y Vol 2. Past trends 2. Study , projected done into future •10 s 0 S 10 15 :0 25 YEARS Broadly spealdng, the amount of traffic is governed by what is regarded as a tolerable level of congestion. If the capacity of the road network is increased, whether byroad constructian.or by traffic management measures, the mileage will increase until the same conditions obtain. If the capacity of the toad network?s not increased. the mileage performed will stabilise, and if the capacity is reduced. the mileage will be reduced correspondingly24 Sinclair Knight and Partners, in their review of Route 20, continue the above 25 year old tradition of'chronic over -prediction' with predictions of a 57% growth in traffic on Route 20 by the year 2006. They, too, claim they cannot take account of future social trends or political decisions. ...nothing.' 11 =IGHT MYTHS OF TRADITIONAL TRAFFIC PL4NNING MYTH 4: Bigger roads are safer roads While planners build roads that encourage greater speeds thev must bear some of the blame fora rising road toll. New speed Old speed Added Added risk factor risk factor ' Upper saaffety limit safety limlet' Before new After new safety feature safety feature Wnp new saje{v measures can be self defeating IF IT IS TRUE as many planners claim that "bigger roads are safer roads", why does the road toll keep escalating? The answer is simple. Planners are ignoring two fundamental factors. Firstly, while "upgraded" roads decrease the number of accidents per vehicle kilometre, researchers such as Jeff Kenworthy and J. Michael Henderson show that such figures are misleading. They do not take into account the extra trips which such upgrades encourage or the increased length of trips encouraged. Accident rates per trip or per hoar spent on the road remain much the same. Urban freewgvs have lower crash loss rates per unit vehicle mile travelled, but may have little effect on the total number of casualties.ls According to German researchers, from 1960 to 1980 the number killed in relation to the number of cars has increased by 72% and in relation to the number of trips by 71 %. In relation to the number of pedestrian trips, pedestrian deaths have risen 49%.16 Secondly, straighter wider roads encourage greater speed. Accidents that do happen are therefore more severe, resulting in more injuries or a greater likelihood of death. The death rate for pedestrians hit in a 30km/h zone is only 15%. In a 50km/h zone it is 60%.17 There is also a large body of research which suggests that increasing the safety of a car or road simply encourages the driver to take greater risks.18 Drivers are willing to take a certain amount of risk in exchange for the benefit of faster travelling time. This risk is added to safety limits of the car or road. The new safety features also lull the driver into a new sense of security. Vigilance, concentration and attentiveness wane. Kenworthy argues that the most successful measures in reducing the road toll are those which "force a level of car use in a direction away from the available limits of the car and its driver".39 In other words, force drivers to drive at speeds and in a manner which are below the safety limits of the car and road. During the 1974 fuel crisis, America reduced its speed limits to 55 m/h. The result was an estimated saving of 3000 to 5000 lives - basically because people were forced to drive below the design speed of the highway. Denmark, Finland, France. New Zealand, Ontario. Sweden, UK. West Germanv and Victoria have all experienced drops of up to 48% in fatalities on major roads with a reduction in speed limit.20 Of course there are those who complain that reducing the speed limit is an infringement of people's freedom. But imposition of early death on another is an even greater infringement of freedom, and while planners build roads and streets that encourage greater speeds, they must bear some of the blame for a rising road toll. ?MYTH 5: Bigger roads increase people's IT IS WIDELY ACCEPTED that the more roads a city has the greater the level of mobility the residents enjoy, but mobility one researcher claims that since 1950 the average number of trips made by each person has hardly increased.21 It sounds unbelievable until you think about it. Building bigger roads has a number of consequences which have we already mentioned. • The city is encouraged to spread out. The result is that people must travel further to reach facilities - for example their jobs. Instead of a The net result of bigger roads is fifteen -minute tram ride from an inner-city suburb, it becomes a 45 that the are condemned to spend more and more time behind the minute commute in stop -start traffic froma new residential development, through the inner-city suburb which has been carved up for roads and it -heel of o car to reach fewer and parking lots. fewer destinations. Believing the miah that "bigger roads improve •Compact, functioning communities are destroyed by the new roads. Instead of a five-minute walk to the local shops it becomes a twenty- mobility" has put us on a minute drive to the large regional shopping complex. technological treadmill. We have to ' Larger roads encourage a decline in public transport. This puts more run faster just to stand still. cars on the road. Each new car requires 30 times more road space to move each person than a bus or tram it replaces. The result is that the new road quickly becomes just as clogged, or even worse, than the old one. In spite die of all new roads in Brisbane, in the last ten years average speeds have 12 0 0 • r 11 EIGHT MYTHS OF TRADITIONAL TRAFFIC PLANNING largely remained the same. In many cities the average speed has gone down as road space has increased. The net result of bigger roads is that we are condemned to spend more and more time behind the wheel of a car to reach fewer and fewer destinations. Believing the myth that "bigger roads improve mobility" has put us on a :ethnological treadmill. We have to iun faster just to stand still. This myth is based on confusion about what "mobility" really is. As one writer puts it. "'Mobility is being able to achieve many destinations, not being able to travel faster further".z= For example, Person A who spends two hours driving to and from work is less mobile than person B who spends 30 minutes busing to work and with the 90 minutes saved has time to walk to the shops, call in at the library on the way, cycle to see a friend and then stop off at the local park for a jog. PLANNERS ARE FIRMLY CONVINCED that bigger roads benefit society overall - otherwise they would stop building them tomorrow. So let's look at those who don't benefit from bigger roads (groups usually ignored by traffic planners) and see whether they are a majority or minoritv group in society. 1. Those without cars - the poor. the elderly, the handicapped, the disadvantaged. Roads provide mobility for those with access to cars. Those who cannot drive, cannot afford a car, or choose to do without one must rely on other forms of transport: public transport, shared rides, bikes or walking. - Each increase in the provision for private motor vehicles is usually made at the expense of the only means of transport available to these people. • Increasing road provision expands the city making public transport less viable. • Increasing road Drovision encourages more people to use their cars more often making public transport less viable. • Road provision is usually made at the expense of walking and cycling space. Mobilitv is beine able to achieve many destinations. not betn_e able to travel faster further. i"dpvm Bigger roads advantage more people than they disadvantage Contrary to popular belief, bigger roads disadvantage everyone and advantage no-one - except for the planners and engineers who build them. • Increased traffic volumes make walking and cycling conditions increasingly unsafe and unpleasant, making these modes difficult or impossible. • The elderly, the poor and the disadvantaged are usually over- represented along major traffic routes. They are therefore the ones who are uprooted to widen roads, usually having to move to places with less viable public transport. The elderly, poor, handicapped and disadvantaged in our society suffer a double disadvantage. Not only is their own mobility limited by increasing car usage, but they also bear the major costs of other people's mobility - the noise, the air pollution, the invasive grime, an unsafe environment for their children, restricted access to their property, parking restrictions and a degraded outlook. E S UM E Those who can afford a car can also usually afford to buy a house divorced from its negative effects. 'N While it may not be possible to turn this injustice around overnight - it is ��1 a moral responsibility of planners and local communities to at least try. The least ROTE S we can do is to avoid adding to the disproportionate amount the poor and elderly pay for something from which they receive little benefit. Present planning tends to pander even further to those of us who can afford a car while restricting the already limited mobility choices of others. To any fair-minded person, this must seem both immoral and unjust. Z. Children. Like the above groups, children must rely on walking, cycling, public transport or shared ride. Bigger roads have the following disadvantages for children: ; • Loss of mobility. (Parents restrict movement for safety reasons.) • Loss of play space. (Remember when children played in streets - safely?) Dons Hams protestfng the Hole stint Fling Road "Development". Mother classic example of all that is wrong with Brisbane planning. 13 EIGHT MYTHS OF TRAD=TIONAL TRAFFIC PLANNING IThe social costs of freeways fall on the poor.24 The automobile has given improved mobility pnmarily to the middle cl=, middle-aged. But these oHner-dnvers have not merely gained new mobility through the car, they have also rearranged the physical location patterns or societyto suit their own pnvate neeas. and ! unwitangly in the process oestroved and severely booted the mobilty and access of all others.23 I • Increased chance of death from traffic accident - the number one killer of children aged i to 16 in Australia. Retardation in learning skills if exposed to excessive traffic noise either at home or school. 3. Residents. The landmark "Livable Streets" study by Appievard demonstrated the dramatic effects traffic has on the quality of life in a neighbourhood. It showed, for example, that people living on a iight traffic street (2000 vehicles per day) had an average of 3 friends and 6.3 acauaintances in their street. On moderate traffic streets (8000 vehicles per day) this dropped to 1.3 friends and 4.1 acquaintances. On heavy traffic streets (16,000 vehicles per day) it dropped even further to .9 friends and 3.1 acquaintances. Other effects on quality of life included: less time spent gardening and relaxing outdoors, greater fear of crime, greater noise and pollution (with its medical consequences) and a shrinking of the area considered by residents to be their "home territory". Applevard conc:uded his study by saying, 'People had withdrawn altogether from HEAVY street, leaving it to the traffic... The contrast between the two streets [heavy and light] was striking. On the one hand alienation. On the other friendliness and involvement." 23 4. The small businessperson. Large road developments carve up compact local communities. The viability of small businesses which reiv on local trade - for example, the small corner store - is seriously eroded. Some close. Local employment opportunities decrease, further affecting the viability of the remaining businesses. 5. Motorists. We have already shown how motorists are worse off in real terms once.a road network develops past a certain size. This is not to mention the problem of a rising road toll and increasing congestion. 6. The City. A spread -out city is much more expensive to service with water, sewerage, roads and electricity than a more compact city, in addition, roads often destroy historic buildings, parks and natural features that give a city its distinctiveness. This loss reduces the attractiveness of the city for both tourists and businesses. Contrary to popular belief. bigger roads disadvantage everyone and advantage no-one - except for the planners and engineers who build them. MYTH 7. It is not the job of traffic planners to WHEN SKP WERE ASI= BY LOCAL RESMENTS to consider broader issues such as the Greenhouse Effect, they replied that this was not their job. In look at wider social. political and environmental trends fact most traffic planners are not "planners" at all. Thev are traf:.c "facilitators" or road "builders". Generally, these "planners" passively defend the status quo and are committed to its continuation. They do not examine the eventual results of continuation of present directions or how appropriate these results may be in a changing world. A narrow prognosis on future traffic growth is allowed to dictate "solutions". The attitude is, "What is, shall be". Planning which merely reacts to the past will leave the city ill-equipped to handle tLe social, environmental and political changes of the future. While we cannot predict the future we can map out a range of possible scenarios based on current trends and knowledge. In the words of Friend and Jessop, we can then design "robust" planning solutions. "ones that leave the widest possible set of full solutions still available by providing f1e :'iMity in the face of uncertain ty".26 Planning which merelt• reacts to the past will leave the cirt• ill-equipped L:nfortunately current planning does not first look at possible future economic, social, environmental to handle *he social, environmental and political changes of the future. and political trends, and then creatively shape solutions that allow for the maximum flexibility. For example, it is considered by many residents to be planning lunacy to be planning for mcreaseu car usage in the light of the threats posed by the Greenhouse Effect. As a recent CSIRO publication, "Greenhouse - Planning for Climate Change" says: "To continue to plan on the basis of perpetuating the current profligate use of the private car can no longer be justified... " =" Or as the USA Senate hearing on the environment was told: 14 0 • 0 0, EIGHT :MYTHS OF TRADITIONAL TRAFFIC PLANNING We cannot negotiate with the climate. Instead. the nations of the world must make choices, unilaterally and collectivel}: to adapt our behaviour in order to have the stable climate on which so much human endeavour depends... 'Motor vehicles are responsible for 50% of all the carbon dioxide generated released into the atmosphere in this countn• by human activities. That is a segment of the problem which cannot be ignored.L8 A recent conference on world climate change convened in Toronto by the Canadian Government called for a 20% cut in global emissions of carbon dioxide by the vear 2005 with the ultimate goal of reducing emissions by 50% - the cut needed to stabilise the amount of gas in the atmosphere.29 Many residents consider it prudent to voluntarily restrict growth in traffic before such measures are forced on us. There are fears that changes such as shrinking oil supplies may leave us with a massive infrastructure which will oniy serve as a monument to our stupidity and lack of foresight. Even though governments in Australia are discovering "community MYTH g: consultation" there is still a strong belief, both in the community and amongst planning should be left planners. that planning should be left to the experts, to the experts. "Community consultation" as seen by these people consists of "experts" presenting a prognosis for the future and telling the community what three alternative solutions there are. The "consultation" is allowing the community to chose one of the solutions which are simply three variations on the same theme. It's like being condemned to death and being "consulted" about whether you want to be shot, poisoned or hung. In the case of Route 20. residents were told they would be getting a 57% increase in traffic and "consulted" about how it could be accommodated. If "community consultation" is genuine and not merelv an exercise in The communitv must have an tokenism or manipulation, then ultimately it must be the wishes of the opportunity to undo some of the community - those whom the decisions directly affect - which prevail in forging mistakes of the past and to a solution. creatively shape their future. After all it is our lives. and the future of our children which are at stake. A paternalistic attitude on the part of planners. engineers or politicians is indefensible. An imposition or values by these people on local communities breaks a basic principle of natural justice - the right to decide one's own future.30 Or as Stephen Plowden put it when discussing the role of "experts": The most important questions that arise are not matters of expertise. The problem is to establish values and priorities and to decide what lines of attack are legitimate and what are not; in other words, to define the framework and terms ofreference within which experts should work. This is a problem for society, not for the experts themselves.31 If community consultation is to be "fair dinkum", the first step must be.a critical review by the community of the results of past planning. This includes discussing what kind of city we will have in 20 years time if current trends and policies are continued. And the community must have the opportunity to say a firm "yes" or "no" to these trends. The community must have an opportunity to undo some of the mistakes of the past and to creatively shape their future. Many local residents feel they have been denied this opportunity. Projected figures are presented (implicitly or explicitly) as being inevitable. When residents say thev don't want to encourage a 57% growth in traffic running through their neighbourhood - particularly when there is no projected growth in population in their local area - they are told they are being "unreasonable" or "unrealistic". To this point SKP have been unwilling or unable to- grasp the nettle and put the problems of Route 20 in their widest context - a re-evaluation of where our city is going. A WINDSCREEN VIEW OF THE WORLD The job ofhighwav engineers has been to build highways. They have not generally been asked to first arrive at some understanding of the form of a city and see what effect their mad would have on it.32 Most planners still have a false, car -oriented concept of travel patterns. In an expert questionnaire traffic planners and engineers were asked to estimate the pemntoge of total trips undertaken by car. On the whole they overestimated the perrentage of car travel, and put trips by bike and foot at half their teal level. The reason is obvious. Tmffic plane: are almost all professional men, making a good income. They are all motorists. Many drive big, sporty cars. In daily Life they have hardly any experience of travelling by foot, bike or public transport. They are seldom shoppers, and do not genemlly look after children. Because of this, their own private, windscreen view of the world influences all theirplanning.33 WE CANNOT CONTINUE PLANNING on the basis of these eight myths. Time for a fresh start To do so wi'1 create a sterile city in which quality of life has been strangled by an ever-increasing road network. There is an obvious need for a new approach. One of these new approaches is "traffic calming" is L` Examples of LATM treatment (Local Area Traffic Management) - one of the techniques used in Traffic Calming. 1. Driveway link. Road has been closed mid. block ana is connected oy a onvewov. 2.0 ffset Intersection and roundabout. Notice how sight Imes are interrupted. 3. Slow points. Provides protected narking, tisuahv nonows the road ana arov1aes regular changes in direction. 16 .7 0" What is Traffic Calming and how does it work? Where there was a perceived need. it was satisfied regardless of the impact upon the community as a whole. The growth of technology clouded vision. Quality of life was sacrificed to that equallvhacimevedlabel, "progress*. None of it was deliberate. Most other cities have suffered similarly. The thing now is what to do about those eroded features of our life which aught be salvaged, and to decide what kind of city we want to be in the future. Don Petersen 34 We have lost the feeling for quality in everything we do: we must win the feeling back and base our lives again in quaUtv.. Dietrich Honhoffer 194235 It is obvious that traditional planning techniques don't work. Cities can not go on indefinitely handing over more and more of their living space to cars. Many city and state planning authorities overseas have abandoned these destructive planning methods and in their place have adopted a new planning outlook. In some countries this new planning approach has even been enshrined in federal law. A broad term that covers this new approach is "Traffic Calming". Traffic calming is a holistic, integrated traffic planning approach based on common sense which seeks to maximise mobilitv while creating a more livable city by reducing the undesirable side effects of that mobility. One definition of traffic calming is "environmentally compatible mobility management". This chapter discusses the nuts and bolts of how traffic calming actually works. It looks at the principles of traffic calming, the techniques used in traffic calming and the results of employing these techniques. The next chapter traces the history of how this new approach developed. The Principles THE FUNCTION OF ROADS is not solely to act as a corridor for traffic. PRINCIPLE 1: They are also for social interaction, walking, cycling and playing. Different roads Roads are not just for cars. will have these ingredients in differing proportions - but no one function must dominate to the exclusion of all others. RESIDENTS HAVE A RIGHT to the best quality of life a city can provide. PRINCIPLE 2: This includes the least noise possible, the least pollution possible, the safest Residents have rights environment possible and an environment which fosters a rich community life in which each individual is free to reach their fullest potential. All residents regardless of age, financial status, or social standing, have rights to an equal share of the mobility which a city can responsibly provide for 17 WHAT IS TRUFFIC CALMING AND HOW DOES IT WORK? its residents. No person or group has the right to increase their mobility at the expense of another person's mobility. This means recognising that an over- emphasis on car transport discriminates against a large section of society. PRI ICPLE 3. Maximise mobility while TRIPS ARE USUALLY ONLY A MEANS to achieving a desirable end. Therefore a trip is a "cost" we must to "benefit" decreasing the costs pay enjoy a at journeys end. That cost" involves time, monev, energy and social and environmental ili-effects. It therefore makes sense to minimise the "costs" a city and its residents must pay to enjoy access to a wide range of destinations. This principle involves managing the already existing road and public transport resources of a city with maximum efficiency. It means maximising the efficiency of a grossly inefficient road and public transport network before new infrastructure is built. Techniques The following techniques are some of those emploved to achieve results consistent with the above principles. It must be emphasised that this list is not exhaustive as part of the challenge of traffic calming is to find new ways of fulfilling the above principles. TECFMIQUE 1: Reduce the speed limit REDUCING SPEED has the following effects: I. Slower traffic emits less noise and _�—"""n 30km/h 0 60km/h TECFMQUE 2: Change the road design to force traffic to travel at a slower. more even pace 18 fumes 2. There are less accidents 3. Accidents that do happen are less severe 4. The canacin, of existing road space is increased. The latter point surprises manv people. It is natural to think that the faster traffic is travelling the more traffic the road would be able to handle in an hour. What is overlooked is that as you increase speed you must increase the safe travelling distance between each vehicle. There is an optimum speed for all roads. At speeds below or above this optimum level the number of vehicles the road can move in an hour drops. The optimum level for most roads lies between 25 and 40 kph. �1 O O O F R 0 v � /,• l �L r1�'! 30km/h 60km/h ROAD DESIG:: ,'YSETHODS emploved to slow traffic include: • Narrow traffic lanes. 'Vide lanes encourage greater speed. • Interrupted sight lines. If motorists can see a long way into the distance, their speed increases. The interruption of sight lines with changes in the roads direction. roundabouts, "neck -downs" or breaking the road into smaller visual units with paved strips across the road causes the dri-rer to slow down. It also means thev widen their vision field becoming much more aware of pedestrians and cyclists. • Changes in road surface. Paved or cobblestone strips across the road cause a Slight vibration in the car which causes the driver to slow down. • Paved speed tables. A speed table is a slightly raised section in the road. It varies from a speed bump in that it must be wide enough for both sets of wheels 11 0 0 • WHAT IS TRAFFIC CAUUNG AND HOW DOES IT WORK? to be on the top of the table at once. They can be placed at pedestrian crossings or whole intersections can be raised to the same level as footpaths. These speed tables can be crossed at 30-40 km/h quite comfortably, but not at higher speeds. Besides slowing speed this measure gives cyclists and pedestrians easier access across intersections. • Protected parking. The carriageway can "appear" to have been narrowed simply by building landscaped islands out from the footpath to provide protected parking bays. • Neck -downs. Landscaped islands intrude into the carriageway to form a narrow "gate" through which the driver must pass. • Changes in direction. Forty-five degree bends can be introduced into the road by having end -in parking on alternating sides of the road. Other methods include roundabouts and offset intersections. To encourage traffic to move at a more even Dace, traffic lights and signs are removed and replaced with strategically placed -Ian dscaDing and paving to regulate the traffic flow. Because the traffic is moving at a slower pace the risks of collisions at intersections is reduced and traffic can enter the traffic stream much easier than at higher speeds. Neck -down WIDE EXP.A,NSES OF BITUMEN say to a motorist, "This is vour turf'. TECHNIQUE 3: Streets using paved strips, landscaping and narrowed lanes have a relaxed, Change the psychological feel of pedestrian feel that says to the driver, "Beware! This is a shared space". the street A recent Australian Bureau of Road Transport publication entitled "Children and Road Accidents"36 reported the following: • The higher the speed the more drivers put the onus on the pedestrian or cyclist to get out of their way. • The attitude of drivers at marked pedestrian crossings is "astoundingly ruthless". • Skills of judgement reouued to interact with traffic are oniv acouired by experience. Young children do not have these skills. Safety education is only of limited value - it cannot impart these skills. The report concludes: Solutions to the problems require countermeasures which look beyond the child, being primarily aimed at other road users. The only wav to do this is not by legislation or regulation (speed signs) but by physical measures. Professor Stina Sandels, a world authority on children and road accidents, argues that "even the best road safety education cannot adapt a child to modern traffic, so that traffic has got to be adapted to the child".37 PRIVATE CARS USE 30 TIMES MORE ROAD SPACE to move each person TECHNIQUE 4: than trams or buses. This means more efficient use can be made of existing road Increase incentives to space and the existing public transport network by encouraging people to use public transport transfer to public transport. This is done by increasing the efficiency of public transport, by giving it a time advantage over cars and by offoring an attractive fare system which may include discounted passes for particular markets. DISCOURAGING THE USE OF PRIVATE MOTOR VEHICLES is usually TECHNIQUE 5: used in tandem with incentives for using public transport. Measures that can be Discourage use of used include parking restrictions in the central business district, higher parking private motor vehicles. fees or banning cars from the central -business district altogether. A combination of these two management techniques was emploved by authorities to move an extra 15 million people over a 6 month period in and out of Brisbane's inner city during Expo without creating any traffic chaos and using only our existing public transport.network and facilities.3e_ IF IN THE PEAK HOUR the average number of people in each vehicle is TECHNIQUE 6: only 1.2 then traffic levels can be halved by doubling the number of people in Optimise the number of people each vehicle to 2.4. This can be done through car and van pooling programmes. using each car 19 V,*HST IS TRAFFIC CALMING AND HOW DOES IT WORK? TECHNIQUE 7: THROUGH THE COMBINATION of a public education campaign and the Encourage people to organise their introduction of traffic restraint measures, authorities can encourage people to own travel more efficiently organise their own travel more efficiently. This may mean making a greater effort to find a job close to home or when buying a new home, to buy one which is close to a number of high use activity centres (job, school and shops). It may mean combining a number of trips into one, or using public transport for work instead of buying a second car, or organising a car pool. TECHNIQUE 8: Optimise choices for travel IF AUTHORITIES ARE GOING TO ENCOURAGE new patterns of travel, viable alternatives must be provided: improved public transport, and increasing the attractiveness and safety of the walking and cycling environment. TECHNIQUE 9• Create strong, viable local RATHER THAN BUILDING LARGE ROADS to large centralised facilities, the facilities are brought to the people. Strong, compact communities are communities created with a wide range of facilities at hand. This policy reduces the amount of traffic on the road because: • People have to drive shorter distances to get to where they want to go. • Trips which had to be made by car can now be made by walking, cycling or public transport. • Children and the elderly are given independent mobility through walking and cycling, resulting in less chauffeuring. • A strong local economy leads to a higher level of localised empioyment. Measures that can be taken include making local shopping centres more attractive places to shop, grouping of activity centres, and encouragement of local festivals and entertainment. Most important is the need for a long-term commitment to avoid carving up existing, viable communities with large roads. The Results THE STREETS - A PLACE FOR HUMAN CONTACT The crucial question is whether or not the city, which was formerly built on the human scale, and in which the street existed prunarily as a means of contact, is to oe replaced by megalopolis whets the dimensions of the street are on the scale required for its pr7mmy use by mechanical transport? Are we going towards cities with specialised 'meeting facilities', all iinked to each other by high speed motorways? JO The urban environment should again become a place favourable for human encounter. for loolang around. listening and tolling to people, walking about and sitting down. Streets and squares should once again be treated as outside rooms within the city, cs places whew the opportunity of contact between people is the primary considemtion.40 BASED ON RESEARCH from Denmark, Holland. Sweden. Tapan. Italy, Switzerland. Germany, America. England and Australia, where these new planning initiatives have been tried the following results can be expected. • Noise and pollution reduced by up to 50% • The top speed of traffic down by 50% (Even though speed is dropped by 50%, journey times only increase by 11% because there is less stop -start driving.) • Less heavy traffic and less rat -running • Smaller roads to move the same number of people. The extra space created by closing lanes or narrowing existing lanes is transformed into tree -lined avenues, bike -ways or walk -ways, mini -parks or squares • Greater safety for drivers, pedestrians, cyclists and children plaving in the street • For those unfortunate enough to be involved in an accident. 43-600i6 less chance of being killed or seriously injured • 30% to 50% less traffic on the roads in peak hour • Greater choice of travel methods for everyone - particularly for those who don't have access to a car • Increased vitality of community life • Less stop -start driving • Enhancement of neighbourhoods with an increase in greenery and a decrease in the visual intrusiveness of the roads and parked cars and a decrease in the number of traffic lights and signs, Traffic calming gives you the best of both worlds - mobility and a better quality of life. Clearly traffic calming is not a narrow concept. It involves cars, roads, public transport, layout of the city and the education of residents. It is a holistic planning approach that is aimed at improving quality of life. It involves a whole new attitude and outlook. i • 20 - � Traffic calming - anew c� r planning ethos emerges The ethos and extent of present traffic calming practice can be best understood by looking at its historical development. THE SEEDS OF TRAFFIC CALMING were sown in Germanv in the late 1920s - eariv 30s when four German towns built pedestrian malls in their inner- city areas. The trend increased with urban reconstruction after the war. These developments were generally opposed by shopkeepers until the mid-60s when shopkeepers realised the economic advantages of pedestrianised areas. In the 70s, this resulted in a "mall explosion", not only in Germany, but around the world. But the Germans led this mall explosion, progressively giving over more and more of their central business districts to pedestrian mails. Peter Hall observes: "It is now generally true that the central business districts of German cities are almost completely vehicle -free areas" 41 Nuremburg, a city about the size of Brisbane, has 5 kilometres of pedestrian mail in its central business district. When the program was begun in 1972 there were predictions of traffic chaos. But as Rolf Monheim reports: The predicted chaos on the roads did not occur because a large part of the previous motor traffic simply disappeared.42 This "disappearing traffic" encouraged some planners to begin thinking that traffic could be restrained and that growth was not inevitable. Meanwhile, in the late 60s and early 70s angry residents in a number of cities around the world took to the streets demanding reductions in the level of traffic on their residential streets -,.,Some even went so far as to barricade their streets. As Vera van der Does, General Secretary of the International Federation of Pedestrians reported to a Brussels conference in 1976: In my countryyou can see indignant. protesting parents waving banners as thev march to the Town Hall or to the Houses of Parliament to make it • quite clear that they will dig up "their" street if steps are not taken to tame the motor car in residential areas.;' The mall explosion brought people back into the streets to enjoy their cin: The predicted chaos on the roads did ,not occur because a large part of the previous motor traffic simply disappeared. in November 1962 cats were banned from the first shopping street in Copenhagen. Shop owners feared economic ruin - but in three years trade rose by 30%. 21 "RAFFIC CALMING —.- \T11' PLANNING ETHOS EMERGES FIVOTMEREILYEQUAL RIGHTSter things being equal, one should presumably start w7th the pnnctpie that all travellers have equal rights, reearaless of Me means by which thev choose :o travel. But since travellers by moor :•emcie are j better armed and better protected than pedestnans and cvchsts tnev zero to take paontywhenever anvcontlictonses. One I arm of policy should be to correct tnis bias. Jforeoverfrom the general social point of view, otner things are not at ou equal. Pedestnans and cvchsts are much cheoper I to accommodate than motor verities and do no environmental harm. This is a J strong reason forgiving them notmerely equal, butpreferential tieatment.44 LEFT: The woonerf is a ";rune yard ... which even includes play equipment! RIGHT.:.4 Dutcn wooneri showine the extent of mouildine. 22 This movement, combined with the lessons learned from the pedestrianisation of city centres, led many cities to experiment with Local Area Traffic Management (LATM). Streets were classified into a hierarchy and traffic encouraged to stay on the major through routes and off "residential" streets. A variety of techniques were used including: • Turning some local streets into cul-de-sacs • Speed bumps • Narrowing of entries to streets or placing "neck -downs" mid -block • Tight roundabouts. IN AUSTRALIA, Woodville in South Australia (population 80.000) first experimented with traffic restraint in 1970 when four intersections were converted into T junctions. Since that time LATM (Local Area Traffic Management) schemes have been implemented in Adelaide. Melbourne and Sydney. It must be stressed that these schemes are entirely aimed at taking traffic off local "residential" streets and putting it onto major roads. LATM schemes result in lower traffic on the lower order roads but higher on the higher order. IN 1975, THE DUTCH built their first woonerf. These varied from the LATM because the primary aim of LATMs was to stop rat -running and improve safety in the residential street. The primary function of streets remained the carrying of traffic. But implicit in the concept of the woonerf, which means "livins yard", was the belief that streets were not just for cars, thev were also for social interaction. children. cyclists and pedestrians, and that the car must be subservient to these other functions - not vice versa. This attitude is best summed up in the letter sent by the local council to residents in Delft whose streets were about to be rebuilt: Every car should behave like a guest in your residential street, which in a tva , is vour terrltorv.. The Dutch realised that simply erecting signs that asked cars to go no faster than 20 km/h and to act as if they were guests in someone else s front _yard was not good enough - the traffic had to be physically restrained. So the woonerf was a totally rebuilt street. Footpaths, gutters and roadway were dispensed with. The whole area was paved and obstacles introduced to physically slow the traffic. The streets literally became a paved courrard, an extension of people's front vards. Obstacles were placed so that sight -lines were interrupted with changes in traffic direction at least every 50 metres. The obstacles used included trees, planted areas, playing equipment, seating or parking areas for cars. OTHER COUNTRIES WATCHED the Dutch experiment with interest. While the Dutch schemes were successful in reducing accidents and creating a much more acceptable environment, they were also extremely expensive. Germany in particular took a keen interest in the Dutch experiment • TRAFFIC CALMING — A NEW PLANXENIG ETHOS EMERGES because of their own success with pedestrianisation of their inner cities. They - also had similar attitudes to the Dutch regarding the function of streets. As the Federal Ministry of Regional and Urban Planning's official publications stated: Yourhome street must become like a living room45 The streets of tomorrow make traffic more bearable by creating a home environment in the street. The streets iilll belong to the people and be part of their homes.46 On the streets of tomorrow, road users will be partners, not opponents.4% In 1976, an experiment was initiated by the state of North Rhine- Westphalia. Aplications were called for cities to have areas of 5000 to 20.000 people traffic -'managed with wohnstrasses - the equivalent of the Dutch woonerf. One hundred and thirty areas were nominated and 30 chosen. In 1979 a final report showed that injuries had been reduced by 44% and serious accidents and deaths by 53% in the 30 areas4i In response to this experiment the federal minister for urban planning proposed a new traffic law (1980) which allowed the "mixed use of streets by all traffic participants, each with equal rights",so IN 1981, THE FEDERAL GOVERNMENT took a bold step past LATMs and past the woonerf. As alreadv discussed, LATMs and woonerf schemes are for local streets with low traffic flows. But the Germans introduced the idea of area -wide traffic restraint - or what has become known as traffic calming. Implicit in this idea of area -wide traffic restraint was a belief that LATMs and woonerf did not go far enough and were in fact unjust. Traffic restraint (LATM and woonerf in its strict interpretation leads to the often grotesque situation that quiet streets with light traffic become even quieter while the actual traffic problem zones remain areas of high traffic flows. ruined residential environments. high noise level and high accident risks.sr They argued that traffic must be calmed on all roads -including major roads, highways and even expressways. Clearh; area -wide traffic restraint includes also, and above all, main roads. This is first of all a breath -taking conceptual combination for manv This planners: traffic restraint on main roads? Not with the same policies as on residential roads but still with a clear speed reduction and land use change at the expense of the width of the carriageways. Out of ruined main roads will again come avenues, boulevards and thoroughfares in the true sense of the word.52 But area wide traffic restraint or traffic calming was seen as much more than just narrowing roads, closing traffic lanes and planting trees. Area -wide traffic restraint without including main roads must remain partial, and can never achieve the ambitious aims of relating to urban improvement, noise protection and road safety. Therefore the whole road network, the public transport system and all transport modes must be included. Programmes of promotion of the bicycle and public transport also belong to area -wide traffic restraint policies as do parking space policies, operational or price strategies for public transport and psychologically orientated marketing campaigns for sensible traffic behaviour... Area -wide traffic restraint aims at. as the name implies. the coverage of a large built up area.53 In 1981 the Federal Republic of Germany began an experiment in area - wide traffic restraint in six cities and villages. The cities and villages were chosen to see how traffic calming ;would work in a wide.variety of situations and living densities: from inner-ci'to ty°outer suburbs: from a 120 }ia area in Berlin containing 30,000 people down to a village of just 2300 people (250ha). The largest experimental area calmed was 610 ha in Mainz (15,000 people). (On a recent visit to Australia Professor Rolf Monheim was asked whether •, traffic calming would work in Australian cities with their low density. A mcior road Traffic Calmed. THE CASE OF THE DISAPPEARING TRAFFIC Local residents surrounding Washington Square: Park in New York were threatened with a plan to build a major highway through the park to replace an existing main rood, the capacity of which was not thought adequate to cope with proposed developments in the surrounding area. Instead they managed after a political battle to have the existing rood closed, first on a trial basis and then permanently. The traffic commussionerin opposing this scheme. had forecast immediate and very severe increases in the number of vehicles in the nearbv streets, to the extent that residents themselves would be obheed to ask for the par* road to be reopened. In fact, none of the surrounding roads experienced an increase in traffic, and most experienced some decrease. Nor was there any sign that the traffic had chosen more distant alternative routes in other parts of the city: it had simply disappe=08 23 TRAFFIC CALMING — A NEW PLANNING ETHOS EMERGES 73% e7% 39% 27% Before After Before After MOTORISTS RESMEN73 Approval of 3o km/h speed limit. A speed table. Traffic calming on a ma/or road. Notice paved cycle paths, protected parking. use of paving strips across road when approaching an intersection, use of trees in centre of road, narrowing of entries to minor roads and removal of trofnc lights. 24 He replied that the German experiment had proved that traffic calming worked equally as well in low density areas as in high density areas.) The initial results of this experiment were as follows:s+ • TRAFFIC VOLUMES - same • AVERAGE SPEED - reduced from 37 km/h to 20 km/h • TM E FOR AVERAGE TRIP - increased from 283 sec to 316 sec (an increase of 33 seconds) • ACCIDENTS - same number but less severe - fatalities 43-53% reduction - injuries 60% reduction • AIR POLLUTION - 10-50% reduction • NOISE - up to 14dBa reduction • FUEL CONSUMPTION - 5% increase to 10% decrease (depending on driver). Part of these traffic calming experiments involved reducing speeds on residential streets to 30 km/h and on major roads to 40 km/h. The German auto club, the equivalent of our RACQ, was skeptical and decided to do their own research. They interviewed motorists and residents before the schemes were introduced and after, asking if they considered 30 km/h to be an acceptable speed limit. The diagram opposite shows the results To physically control speed in traffic calmed areas. the Germans employed many of the techniques developed by the Dutch, but without the need to rebuild whole streets: • deliberate narrowing of roads (space saved used for bikeways, parking, bus bays and landscaping) • pinch points or "gateways" using strong vertical features such as trees • creation of sharp bends, usually by creation of parking bays no longer than 50 metres on alternating sides of the road. • the raising of the carriageway to the same level as the footpath to form speed tables' particularly at intersections or at bends • the elimination of defined priorities at junctions in favour of the general priority from the right • use of paved strips across the road. On major roads carriageways were narrowed, paving strips used and in some cases lanes removed. Waldstrasse, a major road in Berlin-Moabit was reduced from four lanes to two and the redundant lanes turned into a park. The main business street is to be narrowed from six lanes to four. What is interesting in the German experience is the progressive attitude of the politicians. There has been a change in the use of prognoses. In the entire post-war period, forecasted increases in volumes of car traffic inevitably resulted in decisions to construct new roads. INhai was overlooked was that subsequent actual increases in car traffic were largely generated by the new roads themselves: in other words, classic cases of self-fulfilling prophesies. Now politicians have dared to become disobedient to trend- i • TRAFFIC CALMING — ANEW PLANNING ETHOS EMERGES Sbound planning. Placing greater weight on the political goal of improving environmental quality, they have been asking planners how to prevent their prognoses from becoming reality.. While the concepts articulated here may seem revolutionary or utopian, one should stress that thev recentiv have become the officiall✓ acknowledged state-of-the-art in Germany.55 OTHER CITIES AND COUNTRIES HAVE NOW FOLLOWED the German lead. Copenhagen has just closed two lanes of a four -lane freeway as part of an area -wide traffic restraint scheme. Other cities adopting area -wide traffic restraint are Odense in Denmark: Goteborg and Malmo in Sweden; Groningen, Delft. Tilbure. Den Haag and Amsterdam in Holland: Bologna and Parma in Italy; Zurich and Basel in Switzerland: Osaka, Tokyo and Nagoya in Japan. Heiner Monheim concludes a report on these schemes: With %ildespread use of planning policy repertoires it has been possible in these rowns to increase considerably the use of public transport and bicycle and perceptibly reduce car traffic in some areas. For a long time this was seen as impossible for towns in the western, technologically - advanced and highh, motorised world. In contrast, fears were stirred up that a reduction of car traffic would ruin the cities economically. The opposite is true. The towns and cities listed above flourish... The decline of car traffic and its domestication in the cities listed led to a remarkable decline of accidents, pollution and deficits of public transport... It is clear that if society is Killing to change its priority and investment policies, then large reductions in car traffic can be achieved.ss The results of these experiments in Holland, Sweden and Japan have been staggering. Daily traffic has been decreased by 30-50%.57 The government in Germany is now planning a major program of area - wide traffic restraint and is predicg that by the year 2000 public transport patronage wiii have increased by at least 206/o. Community action groups have now sprung up all over Germany demanding their areas be traffic caimed like the experimental areas. Several German states have instituted competitions amongst their cities and citizen groups to promote and stimulate innovations in making cities more livable. TRAFFIC CALMING INVOLVES A CITY-WIDE POLICY of traffic restraint. While not calling it traffic calming, some American cities have introduced policies consistent with the ideas of area -wide traffic restraint. Pleasanton, California. has passed a local ordinance requiring developers and employers to reduce single -occupant car trips in the peak period by 45% over four years. After just two years, cars carrying just one person have fallen by 36% - far exceeding the city's goal of 25% 58 • Montgomery County has established a "transportation management district" in Silver Spring, Maryland. All employers of more than 25 employees and all new developments are required to develop traffic mitigation plans and participate in annual commuter surveys. To encourage participation, the County will provide a set of financial incentives in the form of discounted transit and commuter rail passes and discounts for car or van pool vehicles in county car parks. Employers who exceed the goals of the programme will receive additional incentives. Northern Virginia has introduced two priority high -occupancy vehicle lanes on one of their major freeways and decreased commuter traffic in the beltway by 20% and traffic entering the Washington D.C. central business district by 10%. The USA has also seen a proliferation of 7ansportation Management Associations" which seek the cooperation of local authorities, private enterprise. developers and employers in limiting traffic through "demand "management". Singapore introduced a form of area -wide traffic restraint by introducing a pass system for entering the central portion of the city. All vehicles entering the central city during certain hours must have first purchased a pass. BEFORE .METER Knoten oderfttz Wi TRAFFIC CALMING — A NEW PLANNING ETHOS ENMRGES EXPO... our experiment with traffic calming. The Expo experience proves three things. 1. Our public transport network is grossly under-utilised. 2. People will use public transport and leave their cars of home if the right conditions are created by planners. I We are capable of cooperative. creative, far-sighted planning. Ottawa. Canada. introduced variable work hours and a dedicated busway service (roads for buses only) and in five years saw public transport patronage climb by 36%. Stockholm has restricted all vehicles weighing over 3.5 tons fully laden to a special road haulage network from 10pm to 6am. The result has been a 60-70% drop in heavy trucks in the city centre at night. Further measures introduced by other cities include: Reduction of parking spaces in the inner city Increasing parking fees in peak periods Marketing of public transport. AUSTRALIA HAS NOT AS YET ADOPTED traffic calming in the true sense of the word. A number of cities are using LATM schemes. Brisbane has a few isolated LATM streets but nothing on the scale of Melbourne, Sydney and Adelaide. Our biggest experiment with the principles of traffic calming was Expo - an outstanding success. Like so many experiments with traffic calming overseas the results were above planners' wildest expectations. After the tall ships traffic fiasco, people were predicting traffic chaos for Expo, but authorities had the presence of mind to put their heads together and work out a strategy. The plans were to move an extra 7.2 million people in and out of the inner city over a six-month period using the existing public transport infrastructure and the existing road network. This was to be accomplished by a combination of parking restrictions and promotion of public transport. This strategy was so successful, we not only moved twice the expected number of people but car parks had to take out' advertisements to try and attract customers! THE HISTORY OUTLINED ABOVE SHOWS countries "leap -frogging" each other in the development of traffic calming techniques. Our experience with Expo now puts Brisbane in a strong position to take the lead in traffic calming in Australia, jumping from the back of the pack to the front. The principles of traffic calming are not revolutionary or new. Many of these principles have been understood for 25 years. What is new is the drawing together of those principles into a cohesive, comprehensive planning approach. What could distinguish the "Brisbane Traffic Calming Experiment" from all others could be its "completeness". Most cities have emphasised one side or other of the traffic calming equation. Europe has tended to emphasise changes to road design and greater use of bicycle, walking and public transport while America has tended to emphasise increasing the efficiency of existing resources - for example, the use of car and van pools. By synthesising the best from all these sources, we could take our place in the avant-garde of city planning that puts quality of life first. Before and after drawings of a molar road in a small German vriiage 1Boreentreichl..vouce visual narrowing of road with paving. The trees also act to visually narrow the road. • • 26 Transportation Consultant Services Traffic Congestion and Capacity Increases Prepared for. Sierra Club Legal Defense Fun4 Lac. and Citizens for a Better eat Prepared APPUFD MANAGEMENT & PL4NNING GROUP Anpst 1990 EXHIBIT 6 0 TRAFFIC CONGESTION AND CAPACITY INCREASES Traffic Congestion and Capacity Increases Introduction The primary issue of concern in this document is the relationship between traffic congestion and proposed increases in the capacity of transportation facilities, with particular reference to environmental documents produced by public agencies in the San Francisco Bay Area. The questions to be addressed are: • Do capacity increases in a congestion -constrained transportation system produce long-term relief of congestion with concomitant reduction in air pollutants from vehicles? • Are these issues addressed adequately in current environmental documents prepared in connection with proposed highway projects in the Bay Area? • Are current Bay Area transportation forecasting procedures capable of providing quantitative estimates of the impacts of capacity increases? To address these issues, this paper first outlines the issue of traveler behavior in response to capacity increases. Next the paper explores the capabilities of travel -forecasting procedures in current use in the Bay Area to deal with the impacts of capacity increases. Third, the paper examines the environmental documents and supporting methodology documents to determine the extent to which these issues are addressed in the current environmental documents. MANAGEMENTrp c Page 1 TRAFFIC CONGESTION AND CAPACITY INCREASES is Travel Behavior Responses to Capacity Increases The issue to consider here is how people actually can be expected to behave in a capacity -constrained transportation system, when capacity additions are provided. In other words, the questions is: what does common sense tell about how people will react to added opacity when the transportation system is already heavily congested? A capacity -con- strained system is defined as one in which use of the transportation system is limited by its opacity, because there is already sufficient de- mand being placed on the system to fill all available capacity. This des- cribes the state of the transportation system in the Bay Area. Behavior under Congestion First, a capacity -constrained transportation system is defined as one in which many highway (and/or transit) facilities are overloaded for substantial periods of the day, resulting in low average travel speeds and prolonged • peak periods. One can put together a list of the responses that individuals make to traveling in such conditions. While transportation planners have not had funds available that would allow the sort of consistent measure- ment that is required to prove the effects of congestion, simply by general- izing from one's own behavior and that of colleagues, and observing what happens to traffic in general in a congested urban area, one can list the types of impacts that congestion has on behavior: • People forego trips they would otherwise like to make; People leave for work earlier or later, and return from work earlier or later, resulting in spreading the peak periods; • People will try to find alternative routes that are less congested, often moving off the freeway onto arterial streets, until the. streets are as, congested as the freeways; A"M EAdENr tXPWYN/NG Page 2 • GROUP . TRAFFIC CONGESTION AND CAPACITY INCREASES • To avoid some of the time taken up in travel, people will chain trips together, such as stopping at the bank or cleaners on the way to. or from work; • People will choose closer destinations, exchanging a more desirable but more distant location for some activity for a closer, but less desirable one; • If alternatives exist, people will change mode of travel, electing to use carpools or transit in preference to driving alone; and In the long run, people will relocate their residences to be closer to work or other attractions and reduce the amount of travel required to conduct their normal day -today activities. There is some evidence available on reactions to congestion. Congested urban areas tend to exhibit longer peak periods than uncongested ones, Oand the phenomenon of peak spreading, i.e. the lengthening of the peak period, is at least anecdotal and often measurable. Peak spreading is evidence of people shifting certain trips to other times of the day in an effort to avoid the severity of congestion at the height of the peak. For example, people may decide to get to work earlier in the morning in order to avoid the worst congestion. They may also leave earlier or later from work to go home for the same reason. Such rescheduling tends to lower the worst of the peak but creates peaks that last longer. In the Los Angeles area, the peak periods in the 1970s were defined as being from 7 am. to 9 am. and from 2:30 p.m. to 6 p.m. It is now being proposed that - planners use a morning peak of 6 am. to 9 am. and an evening peak of 230 p.m. to 7 p.m., representing a lengthening of the peak periods by about 2 hours per day. There is often a decline in average trip lengths as congestion levels increase, indicating the choice of nearer locations than before for various trips. However, as we discuss further below, the overall time spent in travel within a 24-hour period tends to stay constant, so that as travel gets RAMGEMENDrr &DIMMING Page 3 9 GROUP TRAFFIC CONGEST70N AND CAPACITY INCREASES • slower, the total distances that people can travel are reduced. The trip purpose least susceptible to the change in travel distance is the work trip, which is dictated by affordable housing and location of jobs, while discre- tionary trips like recreation, social visiting, etc. are much more likely to be affected. The stability of certain time -based phenomena in travel provide additional evidence of response to congestion. Measurements taken at various times ;n the past century on average travel times to and from work in such cities as Chicago, New York, Philadelphia, and also overseas in such cities as London, Munich, and Paris, show a surprising stability in the average and maximum amounts of time that people spend traveling to and from work. In spite of numerous changes in transportation technologies, nature of work, housing development, etc., the average time spent getting to and from work has stayed close to 20 minutes, with an average distance just under ten miles [11, and approximately 99 percent of all work trips are completed in no more than 90 minutes. This stability in travel times indicates that longer travel times are not found to be acceptable, so that workers are forced by congestion to accommodate to this perceived maximum time by time -of -day shifts, job or home location shifts, and • rearrangements (trip chaining, or making minor diversions on the way to or from work to accomplish other errands that would normally require a separate trip out from home and back) of other requirements for travel so that traveling to or from work is chained with other activities. The American Association of State Highway and Transportation Officials (AASHTO) published a manual on computing user benefits from transporta- tion improvements (21 that notes the constancy of travel time budgets for all travel, not just travel to and from work. On page 18 of that manual, the following is stated: "A final qua/iricabon of the use of a value for automobile and transit travel time savings is the indication from recent stud- ies that total average personal travel time has, over many years, been extremely invariant in different urban areas, at about 1.1 hours per capita per day (40). This means that the long -tern — or, in some cases, the short term — results of APPLIED MANAGEMENT PG OUP G Page 4 9 0 TRAFFIC CONGES77ON AND CAPACITY INCREASES reductions in travel time caused by improved personal trans- portation facilities or operations usually show up in two ways: " Longer trips— the tendency in large urban areas to increase spatial opportunities and decrease resid- ential density. " More frequent trips— such as increases in trips for cultural and social purposes. "The argument for ascribing values to personal travel time savings must; therefore, regard time savings as a surrogate for other values that travelers seek, rather than as an end in itself, since the average daily time budget remains unaf- fected." [21 The citation says that an individual living in an urban area has been shown to have a fairly constant amount of time that, on average, he or she is willing to spend on travel, and that is fib minutes. The citation then deals & with the response to capacity increase and points out that it will be most likely to have one of two effects: a lengthening of the distance people travel in large urban areas and a long-term consequent decrease in resid- ential density; and more travel being undertaken, particularly for cultural and social activities. The citation concludes by saying that the justification for putting a 'monetary value on travel time savings (as is frequently done in cost -benefit analysis of transportation projects) is justified not so much because people are willing to spend money to avoid travel, but rather because they will trade off activities they would like to do with time spent in travel. The reference within this citation is to a paper presented by Yacov Zahavi j3J that investigated the evidence for constant time budgets and the impact of these on urban sprawl. In another document [41, Zahavi notes on page 46: "...shorter trips times may be traded off not only for more trips but also for either longer trips distancewise or savings in daily travel times," [41 40, AurwGEMENT &PL NNING Page 5 GROUP TRAFFIC CONGES77ON AND CAPACl7y INCREASES • Later in the same document (page 64), he goes on to say: "It may be Inferred from the above results that an increase in travel speed (such as brought about by an improved trans- portation system) may not necessarily save travel times; in the short run it may be traded off for a combination of more and longer trips, while in the long run it may be traded off for shifts in residence location." [4] Similar results have been shown in a more recent paper [5]. Taken to- gether, these various sources are clearly agreed that adding capacity to a congested system results in people making longer distance trips (within the same amount of time), traveling to a larger variety of places, and eventually even relocating their residences further from many of the activities that are involved in daily living, resulting in a commitment to longer travel distances. To a large extent, the congestion responses noted above also provide evidence that congestion is a seff-regulating phenomenon. This is also ID by Remak and Rosenbloom, who state: "Congestion in itself acts as a deterrent to drivers choosing to add their vehicles to an already overcrowded roadway. When road capacity is increased, this deterrent is weakened, and although, for a time, traffic flows more smoothly, new users are soon attracted to the improved route until conges- tion conditions reappear." [6J Remak and Rosenbloom also add: "The self4egulating phenomenon is more pronounced in large urban areas than in smaller ones ... the larger, more volatile economy of major urban areas produces an almost endless supply of commuters, who quickly adjust their travel - to -work patterns to take advantage of improved traffic condi- tions." [61 MANAGEMENT &tANN/NG Page 6 GAouP 0, L] TRAFFIC CONGESTION AND CAPACITY INCRF4SFS Research which suggests that congestion acts as a limit on additional traffic is confirmed by data which show that adding new transportation capacity lifts such limits and triggers additional new traffic. In other words, adding capacity permits traffic from the pool of unsatisfied demand to be added to existing traffic. This idea of a reservoir or pool of unsatisfied travel is pointedly discussed in two documents that reviewed the impacts of the construction of the Bay Area Rapid Irransit (BART) system. Original- ly, BART was expected to reduce daily travel on the Bay Bridge by 9,000 trips in each direction. At around the time that BART began trans -Bay operation, there were also some significant increases in gasoline prices that probably had an additional impact on trip reduction on the Bay Bridge. Nonetheless, in total, trip making across the Bay Bridge dropped by only 3,000 trips per day within the first year after trans -Bay operation, about one-third of the expected drop. On page 80 of the Final Report on the impacts of BART ['71, the following conclusion is drawn: "It is believed that the 6,000 'new trips' were caused by travelers reacting to the lessened congestion on the bridge by malting trips that were previously suppressed or trips which had previously been diverted from other destinations or routes. This new traffic appears to have nearly completely offset BARTs contribution to reducing travel volumes." [7] On the following page (81), it is added: "Because of the small net reduction in traffic volumes (BARTs reduction offset by 'new' trips), there has been little impact on highway travel times and traffic congestion." P1 in a second related report, the following explanation is offered [81 on page 14: "This resurgence of (Bay Bridge) traffic cannot be idenfirled with certainty... (I)t might represent induced travel — trips that previously had been discouraged by congestion on the APPUED • MANAGEMENr &LUVNING Page 7 GROUP TRAFFIC CONGES77ON AND CAPAC17y /NCRF4SFS 0 bridge, but became attractive as soon as BART began to relieve that congestion. ._ "induced travel is a common phenomenon. Wherever an automobile route is heavily used, there exists a reservoir of trips that people do not make because the route cannot accommodate them. If a second route is provided, both routes will draw traffic from this reservoir, and the net loss in traffic by the old route will be considerably less than the gain in traffic by the new route. This result sometimes is surpris- ing to officials and to the public, who reason that the con- struction of new transportation facilities (such as BAR7) must substantially reduce the load on others." A further argument on this topic is offered by C. Kenneth Orski [91, who states: "On the traffic congestfon front there is some good news and some bad news... The bad news is that it seems unlikely we can build our way out of it permanently." . He then goes on to say: "New roads will not eliminate traffic congestion. They fill up with cars almost as soon as the ribbon is cut: This should come as no surprise, for new roads improve accessibility, and greater accessibility increases the value of land. Higher land values, in tum, dictate a more intensive use of land, which generates more traffic, which rills up the highways." [9] This argument• relating to new roads applies equally well to adding capacity to existing roads. Thus, the conclusion that can be drawn from Orski's words is that "...added highway capacity will not eliminate traffic conges- tion, but will be filled up almost immediately with additional traffic that retums congestion to the same level as before the capacity addition." These various authors seem to conclude quite clearly that there is a vast pool of unsatisfied demand for more travel in large urban areas that will MANi1 EMEM &LANNI a Page 8 nWFIC CONGESTION AND CAPACI7Y INCREASES show up as increased volumes whenever new capacity is added into the system. Such increased volumes mean that.added capacity will bring with it growth in total vehicle miles of travel and often a growth in total numbers of trips made in the urban area. These various citations also establish rather dearly that the common-sense idea that increases in capacity result in people making more trips and longer trips is indeed widely held in the transportation profession. In summary, the effects of constraints of capacity on people's travel be- havior is confirmed by research, particularly the references cited in the above paragraphs. Furthermore, research clearty indicates that congestion also has the effect of limiting travel in an urban area. In the event that there is a desire to reduce overall travel and vehicle miles of travel in an urban area, particularly one in which there is a sufficient excess demand for travel that new capacity additions will be unlikely to be adequate to satisfy demand for more than a very short period, congestion itself can be utilized as a means to reduce or, at least, limit vehicle travel. . Response to Capacity Increases Based on the foregoing, it is then quite straightforward to deduce how people will react to a capacity increase that reduces travel times initially. It will be the opposite of the reactions described above as occurring under increasing congestion. When capacity is added to the system, several impacts can be expected to follow, particularly when the capacity is added for congestion relief. Foregone Trips. Trips that have been foregone because of congestion will now be made. This will result in an absolute increase in numbers of trips using the facility that has been expanded. Peak Spreading. There will be a reduction in peak -spreading from people no longer delaying trips or starting early to avoid. congestion. This will result in a shift of trips between the traditional off-peak periods to the peak periods and is likely to restore the pre -capacity increase level of congestion in the peak. MAM EED M&,rr &LANN/NG Page 9 GROUP TRAFFIC CONGES77ON AND CAPAC17Y INCRF4SFS 0 Route Changes. Trips that may have used parallel or nearby alternative routes, in order to avoid congestion, may now divert and take the new facility, if the capacity increase boosts travel speeds above those of com- peting routes. Cbained Trips. Trips that have been made part of an existing trip through trip chaining may now be "unchained," effectively adding more trips to the total. In particular, home -to -work trips that may have been used for side trips to shopping, banking, other personal errands, etc., may now be replaced by several "out -and -back' trips from home for the same purposes. Destination Changes. Trips made to nearby, but less -desired locations may now be made to further -away, more -desired locations, leading to an increase in trip lengths and therefore lengthening the distances that trips are made on the expanded facility. Mode Changes. People who have chosen to use transit or carpools will • now return to using solo drive. This will also result in an absolute increase in auto trips on the expanded facility. New Development In the longer term, if congestion levels are lowered for sufficient time, developers can be expected to seek additional develop- ment that will increase the number of residents and jobs in the vicinity of the expanded facility. In conclusion, if the effects of new capacity on future traffic levels are not estimated, based on the changes in travel behavior noted above, then accurate forecasts of the effects of new capacity additions cannot be obtained. To ignore the effects we have listed here will result in severe overestimates of the beneficial effects of capacity4ncreasing projects and severe underestimates of the negative impacts of such projects. K4WAEMED EHr &PLANNING Page 10 GaouP 0 • TRAFFIC CONG=ON AND CAPAWY INCREASES Travel -Forecasting Methodology Travel forecasting methodology is the means by which the impacts of additional capacity on travel patterns on be, at least partially, quantified and assessed. There are three fundamental issues that need to be ad- dressed in looking at the travel forecasting methodology. These are: Are the Say Area travel forecasting models capable of estimating the impacts of opacity increases on travel behavior, just outlined; If not, are state-of-the-art models capable of doing so, where the Bay Area models do not; and In either case, are the models used in -such a way that the • impacts of capacity increases on travel behavior are routinely estimated. In order to answer these questions, we first provide a brief description of the Bay Area travel -forecasting models, known as MTCFCAST. To assist someone who is not familiar with the various steps required to forecast travel, we have also provided a brief description as to the functioning of ' each model step. The standard metropolitan -area travel -forecasting methodology uses a series of steps to produce forecasts of person travel within an urban area. These are: Demographic and land use forecasts; Trip generation; Network construction; Trip distribution; Mode choice; and Network assignment APPLIED Page 11 MANAGEMENT GROUPG 9 TRAFFIC CONGES77ON AND CAPACITY INCRF 4SFS _ . The models used in the Bay Area are among the most sophisticated in current use in North America, but are also typical of the standard models in their overall structure and operation. The sophistication of the MTCFCAST models comes with a heavy overhead, in that the models are complicated and time-consuming to run, with the result that shortcuts are often made in applying them, resulting in a failure to capture marry of the important effects of transportation system changes on travel behavior. In this chapter, the steps in the process are described, and the typical pro- cess of application is also outlined. Figure 1 shows the steps involved in the process and the flow of information through the process, as it is currently applied throughout the United States. Details of the form and structure of individual steps in the procedure will vary from locality to locality, but the overall process is the same. Documentation used for this chapter includes the three -volume set of reports prepared by Cambridge Systematics, Inc. for the MTC in June 1980 [10] [111 [12] and subsequent reports by MTC staff describing subsequent recalibrations and modifications to the models. j13J [141 Step 1: Demographics and Land Use The first step in the process is to forecast the demographics of the region- ai population and employment and to forecast the distribution of land uses in the region. Demographic forecasting in the State of California generally works at the regional level from control totals of population and employ- ment forecast by the State Department of Finance. These may or may not be modified by local agencies. The Department of Finance makes its forecasts based on past trends and "cohort -survival" models (i.e., models based on the proportions of different age groups of the population that can be expected to live over the next twenty years), modified by overall estimates of the region's capability to accept growth. The specific demographics of the population are forecast locally by the Association of Bay Area Governments (ABAG) using past census data to estimate proportions of the population by income levels, household size, MAVM EMEMr &�PG Page 12 11 U FIGURE 1 The Travel -Forecasting Process Regional STATE ESTIMATES Population and Employment Zonal LAND USE Population Employment MODELS Demographics Trip Productions TRIP GENERATION and Attractions Trip Tables of TRIP DISTRIBUTION Zone -to -Zone Movements Trip Tables MODE CHOICE by Travel Mode Assigned NETWORK Trip Volumes ASSIGNMENT* on Highway and Transit CAPACITY Congested Highway RESTRAINT Speeds Highway and Transit Networks TRAFFIC CONGES77ON AND CAPACITY INCREASES • dwelling types, etc. Population and employment totals are also split among subregions, based on a land -use model called POLLS (Projective Optimization Land Use Information System). This model is driven primarily by current land uses and estimates of "holding capacities" of subregions or analysis zones, and include some sensitivity to the supply of transportation facilities. However, the linkages between land use and transportation supply, while reasonably well understood, have never been modeled very successfully, so that the impacts of transportation supply on this process are not strong in the forecasting procedures. Generally, a single set of forecasts are made to a horizon year that is usually chosen to be approximately 20 years from the present Thus, during the late 1980s, forecasts have been made of population and emp- loyment in the year 2010. Probably, these will be updated and modified occasionally by the regions- in the state, but the pressures to have a single set of "official" forecasts mean that there is generally little modification once the agencies within a region. have signed off on a particular set of fore- casts and these have been adopted as the official figures. it can be expected that the next change in these figures will occur in the late 1990s, when forecasts are produced for 2020. In the meantime, the Bay Area projections, known as 'Projections 90" have been produced by ABAG, modified by member jurisdictions, and accepted as the basis for planning in the region. Step I Trip Generation Following the forecasting of land use, the next step in the procedure is to run a set of models known as trip generation. These models estimate the numbers of daily person trips that will be produced by and attracted to each traffic analysis zone in the region. The models are normally a func- tion of characteristics of households for the production of trips and of characteristics of employment or land use for the attraction of trips. The result of using this model is a set of forecasts of the numbers of daily person trips that will be made for each of a number of trip purposes (e.g., home -work, home-nonwork, nonhome-nonhome) for the entire region. APPMANAGEMENT EN &PL NNING Page 14 GROUP • TRAFFIC CONGEST ION AND CAPACITY !N CREASES For at least the past three decades, various papers and research disserta- tions have been written that develop theories of the relationship between the numbers of person trips that will be made and the supply of transpor- tation. In other words, it has been argued quite dearly that the amount of transportation capacity in a region or locality will impact the amount of travel made by people that live in the region. However, all attempts to reflect this in travel -forecasting models have failed. The primary reason for this failure is that modeling is done at the regional level and is an ag- gregate phenomenon. It is difficult to describe the supply of transporta- tion at this aggregate level in such a way that the sensitivity of trip -making to it can be captured. The result of this is that there will generally be a single forecast of the amount of trip -making in the region that is associated with a single set of land use and demographic data The total amount of trip -making in the region for a horizon year becomes fixed. Thus, despite that effect of transportation capacity on the amount of travel that will occur on the system, most analyses simply assume a single level of demand for the purposes of analysis that does not consider the effect of supply. This is also true of MTC with respect to forecasts generated with MTCFCAST. The MTCFCAST model for trip generation is unusual, compared to any other region in the country. In the MTCFCAST model, the first step in the modeling procedure is to estimate the proportions of households with workers and without workers, before undertaking the trip -generation model- ing. From this step, auto ownership of households without workers is estimated prior to further analysis. However, an estimation process for the number of home -based work trips is applied next to the worker house- holds, and auto ownership for worker households is one of the elements of this estimation process. The procedure is also modeled differently from most current models, in that separate estimating procedures are used for the primary worker in the household and for secondary workers. In summary, the MTCFCAST models contain some additional capabilities for trip generation modeling that are not found in other models. By es- timating worker and nonworker households initially, the model is able to be tic VAGEME ° &�Pe Page 15 TRAFFIC CONGESTICN AND CAPACITY INCREASES • more discriminating in estimating the numbers of trips made by house- holds. By estimating auto ownership based on workers in the household, the model also adds an element of sophistication, compared to other models that forecast auto ownership directly from income. However, the models still fall short of permitting the number of trips made by a house- hold to vary with the supply of transportation, as measured by the capacity of the system. Step 3: Network Construction The next step in the process is to construct highway and transit networks for the region. These are the representations to the computer of the systems of freeways, streets, and roads that exist on the ground, together with the bus routes and rail lines providing transportation service to the region. Usually, this will be done in three distinct phases. In the first phase, base -year networks are constructed to represent what is on the ground now. In the second phase, networks called "Existing plus Funded" (E & F) are created for each of transit and highways. These networks • contain what is on the ground now, together with projects that are included in the Transportation Improvement Programs for both transit and highways, which generally represent those projects for which funding is already committed by the various state and local agencies. In the third phase, future horizon year networks are created, representing various scenarios of what may exist in twenty years in the region. This procedure is not only the one followed by MTC, but is also the standard procedure used by all regional planning agencies in California. Phase One The highway system of a region the size of the Bay Area is extremely complex and extensive. In order not to exceed the capacity of modern- day computers and to control the costs and time required for processing the information, the networks are constructed by using varying levels of approximation about the transportation facilities. It is important to repres- ent freeways and major arterials quite accurately, so that the models that MANA EM&Vr &p�NING Page 16 TRAFFIC CONGESTION AND CAPACITY INCREASES use the network information can perform realistically with theso facilities. However, this system of models is not used (and should not be) for very localized planning, so the detail and accuracy about residential access streets, alleys, etc. is unimportant and represents the main area where one can reduce the complexity. For the highway system, the network contains a hierarchy of accuracy, with freeways being represented most accurately, then major arterials, minor arterials, and finally the remaining access streets and roads, which will not be represented accurately. Any streets on which buses run will also be represented accurately, to make sure that the transit services are also represented to the computer as accurately as possible. The transit network will usually be constructed in the most up-to-date regions by using the information contained in the highway network to define the locations of bus routes, and by using the geography -of the highway network to determine the locations of separate rights of way for transit, such as light rail and heavy rail facilities. The representation of rail facilities and express bus routes on High Occupancy Vehicle (HOV) lanes are usually equal in accuracy to the definition of freeways in the highway network. These are the procedures used by MTC to construct its regional networks. Individual bus routes are represented by listing the links of the arterial street system on which they travel. In the same way that the highway network cannot show every residential street, so too the transit network cannot show every bus stop. However, care is taken to include sufficient detail to allow the models to replicate current use of the system reasonably accurately. In the base year network, the speeds of buses and trains are carefully tuned in the network so that they provide a dose approximation to actual running times experienced by riders on the systems. ,uPpuEo Pa a 17 MMIAGEMENT LPG 9 TRAFFIC CONGESTION AND CAPAC17Y INCREASES 0 Phase Two The second phase involves creating the Existing plus Funded networks, as defined previously (p.16). These networks represent the inclusion of projects that are currently included within five-year improvement programs for each of the transit system and the highway system, and for which funds are currently programmed. For both transit and highway, local, regional and state governments are required to develop and maintain five- year improvement programs, based on currently available and committed funds. Because these plans are supposed to be updated each year, the Existing plus Funded networks may be redefined as often as once each year. The third and final phase is to build future highway and transit networks, to represent what is expected to exist in the horizon year. These networks will usuaily start from the Existing plus Funded networks and then add a • number of investment projects that it is hoped the region can afford to build over the next twenty years. Frequently, there will be several different such networks, one pair of which may represent a wish list of all the investment projects that have been created in the region, while others may represent various alternative funding scenarios. Step 4: Trip Distribution This is the first step in the travel forecasting procedure that makes use of the transportation supply. This step (inks the production ends of trips to the attraction ends to form a set of trip 'Interchanges," or zone -to -zone movements in the region. This is done on the basis of the relative size of the numbers of trip productions and attractions in a zone, and on the travel impedance or difficulty between pairs of zones. The model is called a "gravity" model, because it is very similar to Newton's Law of Gravitation that says that the force of attraction between two bodies is equal to the APPUED MANAGEMENT &PLAWNING GROUP Page 18 0 0 VRAFFTC CONGESTION AND CAPACITY INCREASES product of the masses of the two bodies and inversely proportional to the square of the distance between them. Substituting trip productions and attractions for the masses, and travel impedance for the distance provides a very dose approximation to the form of the trip distribution model. In the MTCFCAST model, the travel impedance is a function of travel times between zones and is a function of both the highway and transit travel time. At the point in the model chain when trip distribution is performed, there is no knowledge available to the model of actual travel times for the levels of trip attractions and productions forecast. Therefore, the transpor- tation planner has the dilemma of deciding what values to use for travel times. There are two pieces of information that are usually known and included in the network data. • First, the posted speed or maximum safe speed on each link of the highway network is known. • Second, the actual speed has usually been measured for the peak period, representing the slowest speed on each part of the network. For the MTCFCAST networks, these two speeds are coded onto each link of the highway network. Bus speeds are also calculated based on a relationship to the auto speeds on the streets (slower to account for frequent stops and the slower accelerations of buses). So, the MTCFCAST model has available two known speeds for each of autos and transit — the maximum speed that can legally be used on each part of the network and the current (or most recentfy-measured, sometimes from several years back) slowest speed under most -congested normal conditions. In some instances, where a highway is known always to experience travel condi- tions that produce a speed significantly below the maximum posted speed, this lower speed is coded into the network in place of the maximum. It is also important to keep in mind that no region in the United States can inventory the speeds on every piece of the highway and transit systems. Therefore, the convention that is used in all regions, including the Bay Area, is to classify each rink of the highway system into one of five to eight APPUED MWAGGEMENr &.LNNING Page 19 GAOUP TRAFFIC CONGESTION AND CAPACITY INCREASES • different highway facility types and five area types. This results in up to forty possible classification combinations of the facility and area, for each of which a speed for each of the two conditions (congested and uncon- gested) is estimated from survey data. To illustrate, one facility type may be "freeway" and another may be "primary arterial" highway (4 or more lanes, divided by a median). One area type may be the "Central Business District" and another may be "suburban." One speed will be selected for all 'freeway" in the "Central Business District," and another for all "freeway" in "suburban" areas. The same will apply to the "primary arterial" highways. . In a few cases, MTC will replace these speeds on individual links of the highway, where it is known that conditions are very unlike the average. A good example would be the bridges across the Bay, which do not operate the same as freeway and arterial facilities in other locations. However, the amount of the highway system that is given these replacement individual values amounts to less than one percent of the entire system. To run the trip distribution model, the conventional approach, which is also used by MTC in the MTCFCAST models is to do the following: • For home -to -work and work -to -home trips, use the peak period • speeds for transit and autos, to reflect the fact that most home- work trips take place in the peak periods when traffic is con- gested. For all other trips, use the maximum speed on the networks, to reflect the supposition that most of these trips take place outside the peak periods, when traffic is not congested. The result of this step in the process is the production of a set of trip tables, representing the zone -to -zone movements for the region for each of the trip purposes that was used in the trip generation step. A set of trip tables is usually produced for each of the base year and the forecast horizon year. The base year trip tables are based on population, employ- ment, demographics, and transportation supply for the year selected as the base year (currently 1989 in the Bay Area); while the forecast horizon year trip tables are based on the population, employment, demographics, and GF.,M Nr L LANN/NG Page 20 r,Roup TRAFFIC CONGESTION AND CAPACITY INCRE4SES the highway and transit networks representing the most probable future scenario for the horizon year, currently 2010 for the Bay Area In the MTCFCAST models, the future. networks are different from the base year networks by having included a number of improvements and addi- tions that are planned to be built in the next twenty'years. However, no changes are made to the uncongested speeds on the networks, and only limited changes are made to the congested speeds (increasing these where new facilities are to be added, and decreasing them where conges- tion is expected to worsen). Changes made to the congested speeds are a matter of judgement, and are applied both by changing the speed for particular combinations of facility and area, and by changing speeds on some individual segments of the system. For the horizon year forecast, the same convention is used for home -work trips and for all other trips, so that the trip tables are based on the as- sumptions of changes in the highway system and the assumed effects of both growth and facility construction on speeds in the congested periods i of the day. Step 5: Mode Choice In this step, the trip tables generated in the previous step are allocated to each of the different travel modes (solo driver, shared ride auto, carpool, and various forms of mass transportation) in the region. The allocation in the MTCFCAST models is based on population demographics and the relative service levels (usually travel times, but possibly also including travel costs) provided by the alternative travel modes. The MTCFCAST model is a state-of-the-art model in this respect Thus, this step is a function of transportation supply, but like the trip distribution step that precedes it, the transportation supply is still described in terms of average estimates of performance .of the system, i.e., the pre -coded congested and uncon- gested speeds on the highway networks and scheduled running times of transit. • APPLIED MANAGEMENT &PLANNING Page 21 GROUP TRAFFIC CONGESTION AND CAPACITY INCREASES The result of this step of the process is the creation of a much larger number of trip tables, each one of which represents the regional zone -to - zone movements that are estimated or forecast to take place for a specific trip purpose and on a specific travel mode. it is customary that this step will define different transit modes as a function of the access travel mode to transit, so that transit alternatives may be walk to transit, drive to transit, and driven to transit, for example. In the MTCFCAST models, a novelty is the provision of feedback proce- dures between mode choice for the work trip, auto ownership for worker households, and trip distribution. Trip distribution is therefore affected by the mode choice, an interaction that is widely accepted in theory by trans- portation planners but rarely implemented in practice. Standard practice elsewhere in the country is to apply the models in the strict sequence of trip generation, trip distribution, and mode choice, with auto ownership es- timated directly from household characteristics prior to trip generation. This means that trip generation affects trip distribution, which affects mode choice. However, effects in the other direction, e.g., of mode choice on trip distribution, are not modeled. In contrast, the Say Area models make auto ownership of worker households a function of the choice of travel • mode for the primary workers work trip, and also make trip distribution dependent on auto ownership. There is also a feedback loop provided for the secondary worker's work trip between mode choice and trip distribution, so that selection of the destination for the work trip is made partially dependent on the choice of travel mode for the work trip. In addition, the model contains a step that estimates the shared -ride occupancy for auto for the secondary worker. For non -work trips, the more conventional sequences of trip generation, trip distribution, and mode choice are used, with auto ownership, as mentioned previousty, estimated prior to the generation steps. The output of these combined procedures (fcr work trips, non -work trips, and for non- worker households) are the standard trip tables for each of highway and transit and for the various purposes. � EM&,f &P� oNI G Page 22 • 7R4FFIC CONGES77ON AND CAPACITY 1NCRF,4SFS Although these capabilities wrist in thie MTCFCAST models, they are rarely employed in practice by MTC staff. The feedback loop takes considerable computer time to accomplish and also adds days into the time required to process a complete set of forecasts. As a result, the feedback loop is usually cut out, and the more normal progression of trip generation, trip distribution, and mode choice is employed. Step 6: Time -of --Day Trip Tables Up to this point, all of the trip tables that have been produced by the modeling process are trip purpose tables, that is, they are tables of work trips, nonwork trips, and trips that have neither end at home. Before the modeling process can proceed further, it is necessary to combine these trip tables in such a way as to produce time -of -day trip tables. These are needed because estimating the travel impacts on the highway and transit systems are clearly a function of time -of -day travel loadings, and trip purpose trip tables cannot tell the planner and decision maker much about these loadings. Unfortunately, this step of the process also represents an inconsistency in the process. Up to this point, the simplifying assumption has been made that all work trips take place in the peak period and all nonwork trips take place outside the peaks. Now, this assumption is dropped, and factors are used to split each trip table between peak and off-peak hours, and factors are used also to estimate the peak highest hour. The product of the modeling procedure at this point is a set of nine trip tables and two summary tables [101 representing 24-hour weekday estimates ' that can be factored to provide one -hour trip tables for peak and off-peak. The factors* that are used by MTC are based on surveys conducted over the past decade, and provide estimates of the fractions of work and nonwork trips in each of the peak and off-peak periods and in the highest peak hour. These fractions are used for both the base -year and future year forecasts. As a result of this step, trip tables are now produced for the peak hour (defined as the hour of highest travel volumes), the peak period, an off - APPLIED LX.PLANNING Page 23 GROUP TRAFFIC CONGES77ON AND CAPACITY INCREASES • peak hour, and the entire 24-hour day. Each trip table resulting from this is a combination of all trip purposes in varying proportions. Step 7: Network Assignment in the seventh step of the process, the factored trip tables are loaded on (assigned to) the networks. The basis for assigning trips to the networks is first to determine paths (routes) between the pairs of zones through each of the transit and highway networks. Paths are found in the MTCFCAST procedure by finding the shortest travel -time path from each zone to every other zone. In other words, everyone traveling from one point to another in the Bay Area is assumed to choose the route that gives the shortest travel time. - On the highway network, the assignment of trips in the first instance is performed using so-called "free -flow- travel speeds on the network. These are simply starting speeds that would be appropriate if little or no other traffic was on the facility. These speeds are defined, like the peak and off- peak speeds used in trip distribution and mode choice, as a function of the facility type and the area type. Once the initial assignment has been completed, travel speeds and times are reestimated for each Gnk of each highway facility. Many facilities will have been assigned more volume than they have capacity to handle, while nearby parallel facilities may be nearly empty. This occurs because of the modeling assumption that everyone uses the single shortest -time route between each pair of places. The next step (iteration) is to find a new set of routes or paths through the network, using the travel times resulting from the first loading of trips on the network. A "capacity -restraint" function is used to reestimate all travel While a few regions in the country have introduced a capability to find multiple paths between each pair of zones for each of highway and transit, most regions, Inciuding MTC, continue to use a single -path pro- cedure. The capability of finding multiple paths adds considerable com- plexity to the process and also poses problems of determining the proportions of trips that will use each path — a process that is not yet well -understood by the profession. APPLIED MANAGEMENT &LANNING GROUP Page 24 TRAFFIC CONGESTION AND CAPACITY INCREASES times based on the relationsnip between the assigned volume and the capacity of the facility. reassign traffic, using the newly-caiculated travel times to produce a new set of zone -to -zone paths. This step has the effect of moving much of the traffic from the heavily -congested facilities of the first step, while loading traffic onto the under-utilized facilities of the first step. Some traffic will remain on the heavily -congested facilities, because the next possible path is so much poorer in travel time than even the con- gested time on the initial path. However, many paths will shift in the second step. This procedure is continued through several more iterations, because each of these produces a different assignment, always with a mix of overloaded and underloaded facilities. Most often, the procedure is continued through five iterations, and an average is taken of the last two iterations to produce the estimated most likely final assignment of traffic. No such procedure is available for the transit system, and a single assign- ment is often the only one made to transit It is also a single -path, all -or - nothing assignment and may result in apparent overloads generated on some bus routes with close -by routes being left largely empty, as a result of the same features of the process described for the highway network. However, overloading in transit does not affect running times appreciably, so that there is no basis for iterating the assignment. Manual adjustments will usually be made to the resulting assignment to represent most prob- able realistic loads on bus routes and rail lines. Impacts of Capacity increases In this section, we review first what the MTCFCAST model system is cap- able of producing. Second, we review the- different responses to capacity increases and assess what the models should be able to show. Third, we discuss how the system is used in practice. These are then used to draw conclusions about what MTCFCAST does in practice in providing estimates of traveler responses to capacity increases. MANAG .PM�ENT �L NNING Page 25 GROUP TRAFFIC CONGESTION AND CAPACITY INCREASES MTCFCAST Model Capabilities When a transportation system experiences significant congestion, the MTCFCAST models can reflect the degradation of speeds on facilities through the capacity -restraint process used to load the highway network. The process does not, however, shift highway trips to transit, as a result of congestion, unless at least the mode -choice and assignment steps are recycled, with mode -choice using the travel speeds calculated from a loaded highway network. If the procedure is recycled back through trip distribution, with the es- timated peak and off-peak speeds used from the final network assignments instead of the pre -coded ones, then changes will be reflected in both the destinations of trips and the allocations between highway and transit modes. Trip distribution will be affected, because it is a function of travel time. As speeds degrade, the distance that can be traveled in a given amount of time decreases, so that under congested conditions, nearer destinations will be selected by the model than under less -congested conditions. Similarly, as highway congestion increases, the relative levels of service of transit and highway, particularly where rail and busway fac- 111bes exist (or buses on HOV lanes), will change so that transit becomes more favorable. Therefore, the model will shift trips from drive modes to transit modes. It is important to note, however, that because of the restricted sensitivity of land use modeling and trip generation, congestion will have no effect in the models on the distribution of population and employment forecast, nor will it affect the total forecast of trip -making by the population in the region. In other words, no matter how congested travel becomes, or how much capacity is added, speeding up travel, the MTCFCAST models cannot show any change in the amount of travel taking place in the Bay Area. if recycling of the model system is performed, as described here, then the forecasts can be made sensitive to levels of congestion, within the limits that total amounts of trips and the distribution and total amount of popula- tion and employment will not change. NAAPPENLIED Page 26 MAGEMT LX.PLAWN/NG GAWP 0 •; 7RAFFIC CONGEST70N AND CAPAC17Y INCREASES ft follows, therefore, that if a future scenario includes the addition of new capacity in areas where highways are ci�rrentfy congested, the MTCFCAST models can respond, within certain limits, to this additional capacity. Additional highway capacity will show up initially in the network assignment process as increased speeds of the traffic on the faciiity. Through cap- acity -restraint steps, the network assignment procedure will then shift additional trips to the facility that has added capacity, indicating the route changes that take place when capacity is added. if the procedure is not recycled through trip distribution or mode choice, this will be the only effect that will be estimated by the model system. If the model system is recycled back through mode choice, with the newly - estimated travel speeds on the expanded facility, the mode -choice model can be expected to shift trips out of transit and high -occupancy vehicles and into solo drive and shared ride, because levels of service for the latter two modes will have improved relative to the former modes. In the follow- ing network assignment, additional highway trips will be assigned to the expanded facility, and speeds may drop again from the initial estimates. Therefore, these steps may require several iterations in order to reach an equilibrium or stable result, in which the speeds on the new facility are successively adjusted and the amount of shifting between other highway routes and between aftemative travel modes stabilizes. if the models are recycled back through trip distribution and newly es- timated speeds on the expanded highway system are used, then the trip distribution model will adjust the origin -destination pattern of trips, reflecting the improved speeds obtained from the capacity addition, and lengthening trips that can take advantage of the new facility. This -will occur provided that the following conditions hold: 1) The initial peak and off-peak speed estimates were dose to actual loaded speeds at the end of the original assignment, or the entire modeling process was recycled originally to use loaded speeds from the highway network; and tianu EMENr &LUVNING Page 27 iORCUP TRAFFIC CONGESTION AND CAPAC11Y INCREASES r 2) The new speeds after capacity addition improve travel times by at least one or two minutes for some trips that can use the expanded facility. A single pass through trip distribution, mode choice, and assignment, after a capacity addition will not be sufficient if the capacity increase has a significant impact on travel times. Rather, it will be necessary to perform several iterations of this process, in order to obtain reasonably stable estimates of the traffic impacts. There is no guarantee that this process will converge, but the same steps as in highway capacity restraint can be used in which results are averaged from two or more successive iterations. Travel -Forecasting Responses Some of the effects of capacity increases can be captured by the travel - forecasting models while others cannot. In this section, we describe how each of the responses described earlier in this paper are related to the travel -forecasting process. • Peak Spreading Peak spreading involves the proportion of trips that are made in a given time period. In the standard travel -forecasting procedure, the only point where time of day enters the picture is when the trip purpose tables by mode after mode choice are prepared for assignment to the networks. This is a purely exogenous process, utilizing factors that are derived from data sources such as past origin -destination surveys. Therefore, the travel - forecasting process can reflect the peak -spreading phenomenon and reactions- to it only through exogenous changes made to the factors by the analyst. Given that peak spreading is not fully understood, and its relation- ship to travel times is not known specifically, any changes made by the analyst to the time -of -day factors would necessarily be judgmental. Hence, the MTCFCAST models cannot show the Impacts of capacity changes on the duration of the peak periods. � EM�NO Page 28 TRAFFIC CONGES77ON AND CAPACITY WCREASFS Route Changes Travel -forecasting models base route selection strictly on travel time. If a opacity increase is provided in the highway network, speeds will increase over the c apacity4nc ceased segment of highway, and new minimum time paths are likely to shift trips onto the enlarged facility. Therefore, the travel -forecasting procedure is fully capable of reflecting route changes consequent upon capacity increases. Hence, the MTCFCAST models can show the effects of capacity changes on route choices. Foregone Trips We have noted previously that the amounts of trip -making estimated by the models are not sensitive to the supply of transportation, even though it is • widely recognized by transportation professionals that they should be. As a result of this deficiency in the models, no estimates would be obtained from the models of trips foregone as a result of congestion, nor of trips added - because of a decrease in congestion. To the extent that the mod- els in the travel -forecasting process were originally calibrated with data collected when a state of congestion already existed, the models may embody some level of foregone trips. However, this is not explicit and is not readily available for manipulation through the modeling process. Hence, the MTCFCAST models cannot reflect the impact of capacity changes on the numbers of trips made or not made. Chained Trips The travel forecasting process treats trips as being single purpose. Chain- ed trips are generally represented as a series of apparently independent events, not as a linked chain. As a result, the travel -forecasting process is unable to show changes in the linking of trips as a result of congestion or, conversely, the relief of congestion. The relative proportions of trips for • MAMOEMEN7 LX.PLANNING Page 29 GROUP TRAFFIC CONGES77ON AND CAPACnY INCREASES r different purposes is a function of trip chaining in the calibration data, but the model system is not able to handle explicitly the trade-offs between chained trips and single -purpose trips. The MTCFCAST models are unable to show the effect of capacity changes on trip chaining behavior. Destination Changes The travel forecasting models are sensitive to levels of service as they relate to the choices of destinations. When travel speeds are low and traffic is congested, more trips will be given a destination in a short dis- tance from the origin than when travel speeds are higher and traffic is less congested. As noted in the preceding section, the ability of the model to show these effects is contingent on two conditions: first, that the initial distribution of trips was made using loaded (congested) travel times from the highway network; and second, that the models are recycled back to trip distribution to test the effects of new capacity, with appropriate ac- • counting made of the extent to which speeds appear to have increased with congestion relief. However, as a general statement, the models are capable of providing a good estimate of this phenomenon under capacity increases. The MTCFCAST models are capable of showing the effects of capacity changes on destination choices. Mode Changes Choice of mode of travel is explicitly a function of comparative service levels among the available travel modes. Therefore, a change in travel time that results from a capacity increase on a highway is able to be included within the travel -forecasting procedure. As with destination changes, it will require that the service levels on the highway network are generated from a first pass of the forecasting procedure that results in a loaded highway network and capacity -restrained speeds. Given that highway travel times MWGEMENr & NNI G Page 30 • TRAFFIC CONGESTION AND CAPACITY INCREASES are derived from a loaded network, however, the mode -choice model will produce changes in the shares of each travel mode as a result of capacity increases on a highway segment The MTCFCAST models are capable of showing the effects of capacity changes on choice of travel modes. New Development As we have noted previously, the land -use modeling component of the travel -forecasting procedure is not transportation supply sensitive and the forecasts use a fixed, static forecast of land use. Therefore, the forecasting procedure is unable to provide estimates of the new development effects of capacity increases in the highway system. Further, because POUS is only an allocation model, it will not show how location decisions might affect the overall level of growth in the Bay Area The MTCFCAST models are not capable of estimating the effects of capacity changes on development within the region. Conclusions Based on the above assessments, the travel -forecasting procedure is able to provide explicit estimates of three of the seven potential travel behavior changes that result from capacity increases, namely: route changes, destination changes, and mode changes. While the other four potential travel behavior changes are not susceptible to estimation from the model- ing process, some judgmental adjustments to travel volumes could be made, based on prior evidence of the magnitude of the changes. • MAM GEMEN NPNG Page 31 TRAFFIC CONGESTION AND CAPACITY INCREASES • MTCFCAST Models in Practical Application While the foregoing has described the procedure that the models are capable of providing, what is done in practice is far below the capabilities of the models. Each time that the entire model system is rerun, either from trip generation or trip distribution, a considerable amount of computer time is required and several days are required to perform all of the steps in the procedure. The- auto ownership and workers per household steps in the MTCFCAST model make the process even more time-consuming and expensive than standard models in use elsewhere in the country. The result of this is that, in practice, a number of shortcuts are used in the modeling process. First, the auto ownership and workers per .household steps of the process are run only once for a given horizon year There- fore, although theoretically the models can show how capacity increases would affect auto ownership in the Say Area, this capability is not exer- cised. In fact, the models are run much more like conventional models, not utilizing the "upward pass" capability between mode choice and trip distribution, but running these models in the conventional sequence from • trip distribution to mode choice. Second, when MTC planners examine alternative opacity additions to the transportation system, the models are not rerun, to estimate the impacts on destinations and mode shares. Performing several iterations of the models from trip distribution through assignment, and readjusting the speeds on the network after running each iteration, is considered too expensive and time-consuming and is not performed. In looking at the impacts of alterna- tive capacity additions, the models are only rerun to look at the assignment of trips to the network for different projects, with no rerunning of mode choice or trip distribution. Also, a procedure for changing travel times on the highway and transit networks rapidly is not available and poses some difficulties because of the need to average results from two successive assignments. This also means that a procedure would be required that could estimate the average volume on each link from two successive assignments and then compute the travel time on the link from that vol- MAMA EMiM NING Page 32 0 TRAFFIC CONGES77ON AND CAPACITY INCRE4SES ume. Such a procedure would not be difficult to create, but does not wrrentiy exist St m nary of the MTCFCAST Travel Forecasting Procedure Given that the MTCFCAST models contain not only the usual elements of the travel -forecasting procedure, but also contain some refinements that are not usually found in applications contexts, three conclusions can be drawn at this point. • First the MTCFCAST models offer some capabilities that other regions in the United States do not have. • Second, the models are certainly capable of providing estimates of three of the seven responses to congestion -relieving capacity increases described in the previous chapter, i.e., route changes, destination changes, and mode changes. • Third, because of the way in which the models are applied, the capabilities of the models to estimate the impacts of capacity increases are not utilized and only route changes are reflected in the results. Furthermore, the MTCFCAST models are capable of reflecting an additional change not included in the discussion of that chapter, namely a change in auto ownership. To the extent that increasing congestion degrades solo driving compared to carpooling and transit riding, the MTCFCAST models could show a decline in auto ownership. If the initial estimates from a capacity increase are, as expected, of improved solo driving times, then the MTCFCAST models contain the capability to show increasing auto ownership as a response, which in turn will reinforce the mode shift from carpooling and transit riding to solo driving for work trips. -Also the in- creases in auto ownership will generate lower levels of shared -ride oc- cupancy for secondary worker work trips. However, this capability is not used in practice by the MTC planners. WNAGEM Nr &PL NNING Page 33 GROUP TRAFFIC CONGES77ON AND CAPACITY INCREASES Additionally, the "upward pass" between mode choice and trip distribution contained in the work -trip estimation procedure for both primary and secondary workers provides the capability to make a more accurate assessment of the impacts of- a service -level change on destination choices. This is because destination choice in the MTCFCAST models is a function of both highway and transit levels of service (compared to just highway levels of service in conventional models), and the model system contains the capability to adjust trip distribution as a result of both highway and transit service level changes. Again, this capability is not exercised by MTC planners. Impacts of Capacity Changes in Environmental Documents First, this chapter reviews procedures used by MTC and Cattrans to assess the environmental impacts of capacity increases, as shown in general methodology reports. Second, the chapter reviews a number of environ- mental documents to determine their consistency with the methodology and evidence of the impacts assessed for capacity increases. The MTC Forecasting Models Using the MTCFCAST Models to Predict Congestion and Response to Capacity Increases The normal procedure that is used by MTC to predict congestion and examine the impact of a range of congestion -relieving strategies is to apply the steps described in the preceding chapter as Phases One, Two and Three of the network construction and forecasting process. Prior to load- ACANAGEM� &LAN ING Page 34 caoua 0 TRAFFIC CONGESTION AND CAPACITY INCREASES ing forecast trip tables on the 2010 network, the forecast trip tables are assigned to the base -year networks, providing an estimate of the amounts of congestion that could be expected under a 'no -build" scenario. This procedure should reflect mode shifts, destination shifts, and route shifts caused by high congestion levels on primary highway routes and resulting from congestion on all routes within a specific corridor. Assuming that there is substantial growth projected in the region over the twenty-year forecast period, and given congestion in the present system, much of the future highway system would be projected to be heavily congested. Re- flection of destination and mode changes will occur only to the extent that the MTC planners change congested and uncongested speeds on the transportation system description. The MTC analyst may also make an exogenous change by inserting revised factors for peak period duration, in order to decrease the peak levels of congestion. However, the application of this "no -build" estimation procedure generally has resulted in estimating levels of peak congestion that are so high that they will never actually occur. In the real transportation system, it is not •, unusual to find a ratio of volume to capacity of up to about 12 for short periods of time. (By definition, a long-term volume -to -capacity ratio in excess of 1.0 is impossible, if capacity is correctly assessed, because this would imply that one could accommodate some volume in excess of capacity on a long-term basis. However, volume -to -capacity ratios in 4 excess of 1.0 can be obtained for short periods of time, and inevitably lead to a partial breakdown of the transportation system.) Applying the "no-buiidu procedure to future trip levels has produced vol- ume -to -capacity ratios in the range of 1.75 to 125 and even higher on the highway network. In other words, attempting to assign the traffic estimated to be generated in the region with future growth and no increase in the capacity of the transportation system leads to gross overloading of all transportation facilities in certain corridors, to the extent that the models may attempt to assign over 12 times the amount of traffic to some facilities than they are actually capable of carrying. These volume -to -capacity ratios cannot be sustained even for short periods of time in reality and indicate simply that the forecast levels of trip making are inconsistent with the no - build transportation supply scenario. Either changes must occur in trans- 0 MMlAGFM� &PLMN/NG Page 35 GROUP TRAFFIC CONGESTION AND CAPACITY INCREASES portation demand beyond those of which the models are capable of esti- mation, or the growth of the region will not occur to the level predicted by the land -use and demographics models. This no -build scenario is useful as a device to identify where the most severe shortages of capacity will be located and thereby to pinpoint where priority corridors lie for addition of capacity, but they do not represent a realistic description of any possible future. If the no -build scenario is to be used as a realistic assessment of a possible future, then it is imperative that volume -to -capacity ratios greater than about 1.5 be removed by estimating or assuming other changes to the region (lack of growth, peak - spreading, mode changes, trip chaining, etc.). If such modifications are not made to the no -build scenario, it is incorrect to use it for such pur- poses as estimating the travel delays that will occur under no -build versus some alternative scenario that involves addition of capacity, or to estimate the comparison of pollutant burdens from transportation sources. Following this, the Existing plus Funded and future networks are created and trips assigned as described previously. By comparing the results of • the assignments of trips to these two networks to the original one, the impacts of capacity increases can be seen as reductions in the volume/ca- pacity ratios. A comparison of speeds derived from the original assign- ment of future trips to the unchanged network to the speeds derived from the new network provide the basis for statements of the speed increases that will result from implementing the capacity -increasing projects. As noted before, trip distribution is not rerun with the capacity increases in place, so that destination shifts resulting from the capacity increases are not included in the process. Documentation of the application of MTCFCAST indicates that the trip tables that are used for assignment to the network are generated once only, using data from the base year network. Thus, in common with most other urban areas in the state, and with the tacit approval of Caltrans, the abilities of the models to estimate more of the impact of capacity increases on network loading are ignored, and the only impacts that are included in the standard application are those of MAM FMB &L NI c Page 36 TRAFFIC CONGESTION AND CAPACITY INCREASES route change and, to a very limited extent, mode shift In many instances, Caltrans ignores the issue of mode shift, and uses one estimate, -of transit trips from each of the base and future year. This is fairly common practice by Caitrans staff, but is not discussed explicitly in methodology documenta- tion. Furthermore, once the future network has been loaded with future trips, subsequent changes in projects are analyzed without returning to the system modeling step. Procedures for Identifying Impacts of Capacity Increases The draft 1990-1994 Transportation Improvement Program [151 contains a chapter that explains the procedures for Air Quality Assessment. Several versions of this chapter have been reviewed. it is notable that the later versions are less clear in describing the assessment of air quality impacts of transportation projects than were the earlier versions. In the final version of the Air Quality Assessment chapter, towards the end of the document on page I1-10-26 [151 it becomes apparent that projects receive an automatic "beneficial' or "potentially beneficial" rating if they institute Transportation Control Measures (TCMs) in conjunction with increased capacity. Moreover, to be rated as beneficial, a project must either have no impacts, or provide mitigation of negative impacts. In contrast, a project must have both negative impacts and no transportation control measures in order to be rated as a "detrimental" project Because MTC works with project sponsors "...to ensure that all appropriate transpor- tation control measures are included in the project design and to ensure commitments to air quality mitigation measures are in place..." j151, pre- viously detrimental projects can be upgraded to beneficial simply by adding mitigation measures. Consequently, it can be concluded that the process is set up to assist projects to receive a beneficial rating, rather than requiring- a stringent analysis of the air quality impacts of each project Resolution No. 2107, "...establishing the criteria for review of the air quality impacts of highway projects, and the criteria for determining which pro- jects with significant adverse impacts on air quality will be considered for MANAGEMENT &L4NNWG Page 37 GAOUP TRAFFIC CONGESTION AND CAPACITY INCREASES delay...", adopted on October 30, 1989 and revised on December 20, 1989, has a very similar structure. Pages 5 and 6 of Attachment A of Resolution 2107 show an almost identical set of statements and criteria as the Air Quality Assessment Chapter cited above. Given this situation, whereby the inclusion of TCMs in a project will guaran- tee a beneficial or potentially beneficial rating, it is appropriate to examine what TCMs can be implemented as part of a project. The TCMs required by the current state implementation plan are shown in Table 1. As can be seen from a brief review of Table 1, all but one of the TCMs involve transit or parking management. However, Measure 4 indicates HOV lanes as a TCM, which is also the only TCM that can actually be included in a capac- ity increase project This generates a conflict. In the Air Quality Assess- ment chapter [151, HOV lanes are listed as being one of the types of capacity -addition projects that may have potential air quality impacts (page 11-10-23). Yet, provision of HOV lanes, in conjunction with other improve- ments that may have negative air quality impacts, will automatically provide a beneficial rating on the project. The issue clearly becomes one of the degree to which HOV lanes are beneficial to air quality. This is a complex issue, but there are several circumstances surrounding this that provide some fairly dear indicators. First, in Califomia, Caftans established an internal policy, following the debacle of the diamond lanes on the Santa Monica Freeway in Los An- geles, that existing capacity cannot be removed in order to provide HOV lanes. Therefore, to comply with Caltrans policy, which is a requirement in order to receive any state or federal funding for a highway project, when- ever HOV lanes are provided, they must, necessarily, represent an overall increase in capacity. As has already been discussed in this document, capacity increases in a congested urban area are likely to result in in- creased trip -making and longer trips, both of which will increase Vehicle Miles of Travel (VMT). Brittle et al. [161 state "...to the extent that traffic mitigation programs lower the number of vehicle miles of travel, they will also have environmental benefits — reduced emissions and reduced (fuel) consumption..." Therefore, because adding capacity through adding HOV lanes over and above existing lanes on a facility means that VMT in- creases, such projects are, by definition, a negative impact on both emis- APPLIED MANAGEMENT UWN/NG GROUP Page 38 0 • TRAFFIC -CONGESTION AND CAPACITY INCREASES 0 'fable 1 List of Mmuportation Control Measum from the State Implementation Plan, ::. HYdrocarbon;:::.:Carbort Monoxide Control: Measure., .. ... ...:.::... ... commitment•ta 2896 increase in•trans' .;::..:.:: rt •:.:. < <'<: >:.°; : ;:' °'»::::::::::::::::° :: ':::.....::::: ::.:::. :....:.::..:..:...::..; :.. ....:..::......: ...:.::....:. . ndershi o adcr onat reductions =2:':. Su rt.transn im rovements iri: ...:..:::...:..:.:..::.. . o raiors.S- ear-• ans:::;::;;::; s:3 k1c: d:,: transit` lie ori: levels•:- ::>.::•: --.::.�.:::...:::::..:. . �� :..::::.::�•::� ;:::•:::;:_>:::<:°.:::::;:s:;.::>:;::;;:::;::::°�::0:3T..;:,>.:�::::;:...:.:.::.:.;;3.6�<;:-:..:..::....::.-:. : �::.' :.. upport: development :of: HOV. canes:`-::::.:::.;,:{Qepends•�oR.:specrfiG:pcoject�;:.:':::�-.::•._::• :.:;:,';;::::;-:Sup . ..................... rt.RtOES`effort°;;::::.:;:: �::>::;::°.>-:.::::: �:::.�;: a•:•addrtionai�::ced�ons sions and fuel consumption. MAIMGEM� O PLANNING Page 39 • GROUP TRAFFIC CONGESTION AND CAPAC17Y INCREASES Second, if new HOV lanes are provided in addition to a capacity increase for low occupancy vehicles (LOVs), the project has a doubled capacity and VMT4nc ceasing impact Furthermore, because use of the HOV lane is dependent on the degree to which the HOV traffic moves at a faster speed than mixed -flow traffic, the addition of more LOV lanes can actually reduce the number of vehicles using HOV lanes. For the period of time that speeds on the LOV lanes are improved because of the additional capacity, the competitive position of new HOV lanes is degraded, and use of the lanes is likely to be relatively low. As a mechanism for removing some cars from the road, then, new HOV lanes will be ineffective in the short run. In the longer run, as additional trips are made on the LOV lanes and congestion reattains pre -project levels, there will be an increase in use of the HOV lanes, but for each vehicle that is removed from the LOV lanes by an occupant of a HOV, a new LOV is likely to be added to the facility. Again, VMT will continue to increase, until a new equilibrium between supply and demand is reached. This phenomenon will lead to re-creation of current congestion but affecting now a larger number of vehicles than before, because more LOV lanes are involved. This type of situation is shown up clearly by the forecasting procedures in use by MTC and others, and has been encountered recently in work in Southern California on planning transitways. The simultaneous addition of LOV and HOV lanes was found to improve LOV speeds sufficiently in the short run that use of the HOV lanes, even with an added lane, decreased to levels below the pre -project levels, because LOVs were traveling as fast as the HOVs. There appear to be no arguments that can be offered to suggest that new HOV lanes can reduce VMT, except where the demand for travel prior to providing the new HOV lane was fully satisfied. In such a case, each LOV removed from the "mixed flown lanes by a HOV occupant represents a net decrease in vehicles in the system (if average occupancy in the. LOV lanes is 12 persons per vehicle and average occupancy in the HOV lanes is 24 persons per vehicle, then the same number of people traveling on the HOV lanes will travel in half the number of vehicles as traveling in the LOV lanes). It is highly unlikely that such a situation will occur, because, if demand were fully satisfied already, there would be no incentive to use a new HOV lane and the project would not be warranted. AUNAGEME T &PL NNING Page 40 GROUP Is TWFIC CONGESnON AND CAPAC17Y INCREASES Finally, the MTC Contingency Plan [171 states quite plainly that Congestion Relief Projects (HB42) can be subject to delay, because of negative air quality impacts. The addition of HOV lanes, when existing LOV lanes must not be reduced in capacity, represent congestion relief in most situations within the Bay Area. This further points up the circuity of reasoning in the Air Quality Assessment chapter and Resolution 2107: a project that in- creases rapacity as a congestion relief project is subject to delay as a negative air quality impact project; however, such a project can be miti- gated to beneficial if any TCMs are included, such as the addition of HOV lanes; however, HOV lanes themselves represent a congestion -reducing strategy and are therefore subject to delay. However, since HOV lanes are a TCM, the project will not be delayed regardless of its impacts on air quality. The implication of the above discussion is that a detailed air quality impact assessment is not considered necessary as part of the environmental documentation. Rather, a project can be classified as to its air quality impacts, simply on the basis of the nature of the project and the inclusion or not of TCMs, one of which is itself a project that can actually have negative air quality impacts. Two other issues are appropriate to consider in this topic, relating to HOV lanes and capacity increases. First, Brittle et al. [16] also state on page 2: "Traffic mitigation actions are designed to reduce the number of vehicle trips, shorten trip lengths, and change the timing of trips so that fewer people will travel during the most congested parts of the day." Given this definition, it is unclear how HOV lanes become classified as traffic mitigation actions, or TCMs. First, most HOV lanes are operative only during the peak hours and in the peak direction. Therefore, they encourage HOV users to travel during the most congested parts of the day. Second, HOV lanes are often designed to have relatively few entry and exit points, compared to the mixed -flow lanes on the same freeways (except where they are created simply by restriping an existing facility). • APPLIED MANAGEMENT &LANNING Page 41 GROUP TRAFFIC CONGEST ON AND CAPACITY INCRE4SFS When the lanes are added other than by restriping, there may he three to five miles between segments where transition between mixed -flow and HOV lanes can occur. Therefore, HOV lanes may often encourage long trips as opposed to short trips. Third, HOV lanes reduce vehicle miles of travel only when there is no pool of unsatisfied demand for travel, so that person trip volumes before and after addition of the HOV lane are exactly the same; or when the HOV lanes replace existing LOV lanes and the HOV lanes run below capacity', so that fewer vehicles are in operation than before creating the HOV lane. In general, the addition of HOV lanes will increase vehicle miles of travel, particularly when the system is congested, and when the HOV lane is added without taking away any mixed -flow lanes. Hence, HOV lanes appear to violate all of the conditions considered neces- sary by Brittle et al. to be classified as TCMs. Second, Caltrans indicates in its System Management Plan j181 that: '...the extent of [addin g g capacity] will not be adequate to prevent a deterioration in the overall levels of. service on Bay Area freeways and will only marginally relieve the negative impacts caused by incident and recurring congestion." (page 67) The capacity of a mbced-flow freeway lane Is estimated to be 2,000 vehicles r per lane per hour. The capacity of a HOV lane Is estimated to be about 1,600 vehicles per lane per hour. if average occupancy of the mixed -flow lane is 1.2, then the carrying capacity of such a lane is 2,400 persons per lane per hour if average occupancy of the HOV lane is 2.5 persons per vehicle, then it can carry 4,000 persons per lane per hour. At volumes above 960 vehicles per hour, the HOV lane carries more people than the maximum capacity of the mixed -flow lane. ,,PPUEo Page 42 . MMIAGEMENT LWN/NG GROUP :7 TRAFFIC CONGESTION AND CAPACITY INCREASES They also add: "Experience has shown the effects of adding capacity alone may only temporarily relieve congestion which recurs as demand continues to build." (page 225) This leads to a question as to why Caitr ans then supports capacity expan- sion as a congestion -relieving strategy. This is not addressed dearly in the Systems Management Plan. However, a further issue of importance is raised by statements in the System Management Plan concerning HOV lanes and ramp metering [18]. A heavily stressed note is printed on page 91 that states: "Once the freeway system is managed using ramp meters and HOV bypass lanes, there may not be the need for HOV lanes on all sections of freeways. Sec- tions identified for HOV lanes, which already have been metered at on -ramps, may attain LOS D (speeds in excess of 40 mph). Under these conditions, the incen- tive for ridesharing along the entire route would be increased. This sifuatlon will be evaluated carefully. if HOV lanes are not needed on freeway sections, HOV lanes on freeways could be converted to mixed -flow lanes." (page 91) Thus, it appears that Caltrans would encourage the provision of HOV lanes as a TCM for a freeway project, thus permitting a D* project to be reclas- sified to a B project. Subsequently, Caltrans would encourage conversion of the HOV lane, under circumstances that are not explicitly described, to a mixed -flow lane. This appears to be a loophole in the process that would permit MTC, among other agencies, to add mixed -flow lanes to freeways in the Bay Area without considering the air quality impacts of those lanes, simply by adding HOV lanes at the same time; and subsequently convert- ing the HOV lanes to mixed -flow, thereby creating even graver consequen- ces for regional air quality. MawGEM� &PLANNING Page 43 GROUP TRAFFIC CONGESTION AND CAPAC17Y INCREASES In summary, the entire prescribed process for assessing the air quality impacts of capacity additions to the freeway system in the Bay Area ap- pears to be riddled with loopholes that permit projects to avoid air quality impact assessment, and that also open the potential for substantial degrad- ation of air quality through subsequent conversion of HOV lanes to mixed flow. All of this is done against a background in which Caltrans itself seems to admit that adding capacity is not a procedure for solving con- gestion problems. Review of Environmental Documents A number of environmental documents have been reviewed from the Bay Area. These documents represent as many of the 48 projects whose D* (potentially detrimental) rating was changed to B (beneficial) as we were able to locate. These are the documents that were identified by MTC as the basis for redesignation. In the following discussion, we have drawn conclusions about the entire group of projects, bolstered by specific ex- amples drawn from those documents that were obtained for review. The • basis for review, as outlined in the previous section of this chapter, is: 1. To determine if the project is a congestion -relief project; 2 if it is a congestion -relief project, to determine how air quality assessment was performed on the project; 3. If it is a congestion -relief project, to determine what TCMs are included, if any, and whether the inclusion of TCMs was the basis for a beneficial or potentially beneficial rating; and 4. If TCMs are included as the mitigation measures that provide the basis for a beneficial rating, in how many instances are the TCMs HOV lane additions? Before looking in detail at the specific projects, there is one additional point that should be made. As indicated much earlier in this chapter, there is APPLIED 0 MAIJAGEMEKr GWYOUPlNG Page 44 •" TRAFFIC CONGESTION AND CAPACITY INCREASES usually a single travel forecast made with a highway and transit network that includes all programmed projects. This forecast effectively examines the combined impacts of all projects as part of the entire transportation system. It is deficient only insofar as the planners do not redistribute trips prior to estimating mode choice and network assignment This procedure provides one set of estimates of traffic conditions, namely those that would occur d all projects were implemented by the horizon year. Following this one forecast of all projects, each individual project that is defined for an -environmental impact assessment may be examined in isolation. In this case, it is customary to simply reassign the trips in the no -build or Existing -plus -Funded (see page 15) assignment with the one project in place. A repeated criticism of the IV TC Transportation Improve- ment Program is that it frequently provides an assessment of impacts for the isolated project, even though the project in question may be part of a series of projects affecting one facility. For example, comment 4 on Air Quality Assessment [15] (page 8) states: • "Projects should be grouped together in logical seg- ments for air quality analysis purposes; segmentation masks the full air quality impacts of a project." While MTC responds that they agree, there is no evidence that they have changed the methodology to do so. Furthermore, since the air quality assessment is generally performed superficially, by using the guidelines outlined in the preceding section for rating the impact and the results of a local assignment to estimate actual reductions in pollutants, there is in fact no real analytical air quality assessment performed. It would have been more appropriate to respond by pointing out that a full analysis of air quality impacts is not performed, so that the comment is somewhat ir- relevant to the actual methodology. In general, reviews of the documents show the following conditions to exist: 1. Some documents provide no evidence of any traffic modeling; • APPLIED MANAGEMENT &PLANNING Page 45 GROUP TRAFFIC CONGESTION AND CAPACITY INCREASES 2. The "build" and "no -build" analyses do not consider the effect of capacity (or its lack) on demand; 3. There is no evidence that volume/capacity ratios have been checked and unreasonable or impossible values removed prior to developing the findings for the analysis; and 4. There is no modeling of the effects of any TCMs to verify their effect as being sufficient to mitigate adverse impacts of capacity additions. Table 2 shows the projects for which documentation was obtained from MTC and other agencies. It represents only a small proportion of all 48 projects, but apparently also includes all of those for which documentation can be located. The table shows a total of 14 projects for which doc- umentation was obtained. 0 Most of the documents reviewed rely on MTC forecasts or on forecasts generated by Caltrans District 4 Office. In both cases, these forecasts • appear to follow the standard approach of MTC and use a "no -build" projection to 2000, 2005, or 2010, and a "build" projection that includes other projects, besides the one that is the subject of the environmental document. The no -build forecast frequently shows levels of travel demand that could not be sustained by the facility in question. For example, the environmental document for the 1-680 widening from I- 580 to Rudgear Road shows am. peak volumes for one direction that are on the order of 16,900 vehicles in 2010 (see Exhibit 1, attached). The a.m. peak period is normally considered to be two hours long, the facility is three lanes in each direction, and the maximum capacity of a freeway lane is 2,000 vehicles per hour per lane. The facility therefore has a capacity for the a.m. peak of 12,000 vehicles. The 2010 projected volume is clearly far in excess of capacity. From a review of the document, it appears that this volume of traffic was used in air quality modeling to estimate the pollutant burden if the project were not built. It is also the basis of deter- mining travel times on the facility, under no -build conditions, and these travel times are also used in the air quality analysis. MANAUME T tXPUWNING Page 46 GROUP 0 7RAFFIC CONGES77CN AND CAPACITY INCREASES • APPUED ,Q�. MANAGEMENT IXPLANNING Page 47 GROUP E7 TRAFFIC CONGESTION AND CAPACITY INCREASES • Because no account is taken of the extent to which travel demand would be suppressed by the lack of capacity in the peak period, the no -build volume is too high and speeds of travel too low. Further, the project analysis concludes there will be no change in travel volumes on the facility, if the facility is widened. Rather, because the addition of a lane in each direction will increase the capacity in the peak period to 16,000 vehicles, which is just slightly below the demand level of 16,900, traffic is assumed to move faster under the "build" option, and the pollutant burden is as- sumed significantly less. Not surprisingly, the conclusion is then drawn that this project has no adverse effect on air quality, but rather will improve it To show that the level of demand for travel is 16,900 vehicles in the peak link, peak direction for the a.m. peak is relevant for identifying the potential need for the project However, the use of that volume for computing air quality impacts under the no -build scenario is dearly incorrect, because such a volume would not occur, nor would congested speeds be as low as projected with that volume on the existing facility. In several other of the documents listed in Table 2, the exact same proced- • ure appears to have been used. Traffic volumes are not always reported in the document, so that the reasonableness or not of the no -build fore- casts cannot always be determined. However, its use in the air quality analysis seems quite clear. This can be seen, for example, in the docu- ments for Route 880 widening from Alvarado -Niles Road to Davis Street, and for US 101 widening from 280/680/101 to the De La Cruz Boule- vard/Trimble Road Interchange. In almost every case, ramp metering and HOV lanes are considered as possible TCMs. However, because most of the documents conclude that there will be no negative air quality impacts from the capacity addition, TCMs are not required in order to obtain a B or N rating, and the recom- mendation is made consistently that these operational options should be examined after the public hearings and environmental clearances are completed. There is a minimal analysis performed of the potential impacts of HOV lanes. It is minimal in that no effort is made to model the changes to travel demand patterns resulting from addition of a HOV lane. Rather, a APPLIED MANAGEMENT &PLANNING GROUP Page 48 • 0 TRAFFIC CONGESTION AND CAPACITY INCREASES volume of use on the HOV lane is assumed and subtracted from the LOV lanes. An estimate is made of the reduction in vehicles that would result from the increase in vehicle occupancy, and this is used to estimate (generally negligible) changes in emissions. Each project also references the TIP in summarizing the air quality impacts. Generally, this reference indicates that, because the project is part of the 71P, and because the TIP includes TCMs, the project conforms and there are no relevant air quality impacts. Despite this statement, several docu- ments still undertake a microscale analysis for Carbon Monoxide, although this analysis is flawed by comparing the no -build and build options with no accounting for unrealistic volume/capacity ratios and travel speeds. Conclusions The primary conclusion to be drawn from this review of the environmental documents is that almost any project that adds capacity to an existing con- gested facility will be assessed as having no negative impacts on air quality and may be considered beneficial. This situation arises because com- parison is made between an unrealistic "no -build" option and the "build" option, in which the traffic volumes and speeds in the no -build would not in fact occur, and the volumes remain generally unchanged for the build option. In addition, the only TCM whose effect is even superficially estimated is that of HOV lanes, where an oversimplified analysis leads to the conclusion that a slight reduction in emissions would occur if HOV lanes were used for the Capacity addition, but that the effects within the accuracy of the models are undetectable. APPED MANA FMENr &LANNJNG Page 49 GROUP TRAFFIC CONGES 7ON AND CAPACITY INCREASES 0 References 1. Lowry, I.S., "Planning for Urban Sprawl,' Transportation Research Board Special Report No. 220, Washington, D.C., 1988, p.302 2. AASHTO, A Manual on User Benefit Analysis of Highway and Bus - Transit Improvements — 1977, American Association of State Highway and Transportation Officials, Washington, D.C. 1978. 3. Zahavi, Y., "The Effects of Transportation Systems on Spatial Distribution of Populaiion and Jobs,' presented at the Joint Nation- al Meeting of the Operations Research Society and Institute of Management Sciences, Miami, Florida, November, 1976. 4. Zahavi, Y. Travel Characteristics in Cities of Developed and Develop- ing Countries, Staff Working Paper #230, World Bank, Washington, Q.C., March 1976. 0 5. Reno, A.T., "Personal Mobility in the United States," Transportation Research Board Special Report No. 220, Washington, D.C., 1988, p.374. 6. Remak, R. and S. Rosenbloom, Peak Period Traffic Congestion, Transportation Research Board Special Report 169, 1976, p.62 7. Metropolitan Transportation Commission, BART in the San Francisco Bay Area. The Final Report of the BART Impact Program, U.S. Depart- ment of Transportation, Washington, D.C., September 1979. 8. Sherret, A., 'BARrs First Five Years: Transportation and Travel Impacts. Interpretive Summary of the Final Report, U.S. Department of Transportation, Washington, D.C., September 1979. MANAGE EENT &PLANNING Page 50 GROUP • TRAFFIC CONGESTION AND CAPACITY INCREASES 9. Orski, C.K, 'A Realistic Appraisal of Traffic Congestion,' Urban Land, Volume 48, No. 10, October 1989, page 34. 10. Cambridge Systematics, Inc., Travel Model Development Project Phase 2 Final Report: Volume 2• Detailed Model Descriptions, Report to Metropolitan Transportation Commission, Berkeley, CA, June 1980. 11.Camb.►idge Systematics, Inc., Travel Model Development Project Phase 2 Final Report: Volume 1: Summary Report, Report to Metro- poiitan Transportation Commission, Berkeley, CA, June 1980. 12.Cambridge Systematics, Inc., Travel Model Development Project Phase 2 Final Report: Volume 3: MTCFCAST Users Guide, Report to Metropolitan Transportation Commission, Berkeley, CA, June 1980. 13. Metropolitan Transportation Commission, 'A Disaggregate Work -Trip Mode Choice Model forAggregate Forecasting (Model MO, Technical Summary, Travel Model Update with 1980/81 Data Base, MTC, Oakland, April 1988. 14. Kollo, H.P.H. and C.L Purvis, 'Regional Travel Forecasting Model System for the San Francisco. Bay Area', Metropolitan Transportation Commission, Oakland, CA, July 1988. 15. Metropolitan Transportation Commission, 1990-94 Transportation Improvement Program for the Nine -County San Francisco 'Bay Area: Volume IL• Highway and Other Elements, MTC, Oakland, CA (Draft, undated). 16. Brittle, C. et al. Traffic Mitigation Reference Guide, Metropolitan Transportation Commission, Oakland, CA; December 1984, page 2 17.Association of Bay Area Governments, 1982 Bay Area Air Qualify Plan, Bay Area Air Quality Management District, Metropolitan Transportation Commission, December 1983, page 11-2. MAMA E EET &L4NNING Page 51 GROUP TRAFFIC CONGESTION AND CAPAC17Y INCREASES • 18. Callfomia Department of Transportation, State Highway System Management Plan District 4, Prepared by District 4 Transportation Planning Branch, System Planning, December 1988. 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GROWTH MANAGEMENT AND TRANSPORTATION TASK FORCE ,v,./.}};.�:?: �: v?{S4:?{n:?v: :n:i•<�:•�ti4::;:0:?. v::A;.!:v':Y $?4�i2: \•: x..kv.4it2:2As \Yl\Cnvv4$Y iY :ti \�viii 4::::•S:•$:�iiiti i:•i:<ti?:�::•:v,..:..:n nx•:•R�::iiivi:i::nA�fvitii%:i?7iJ�++viv:4Atiti�4:•:<C(•iC?S.A•l•.iv .P:C%�'v'" FINAL REPORT June, 1990 Prepared by Southern California Association of Govemments 818 W. Seventh St. 12th Floor Los Angeles, Co. 90017 (213) 236-1800 EXHIBIT 7 • CONTENTS ACKNOWLEDGEMENTS EXECUTIVE SUMMARY SUMMARY OF RECOMMENDATIONS ES-1 ES-3 CHAPTER 1. GROWTH MANAGEMENT PLAN IMPLEMENTATION (AQMP MEASURE 17) 1 • CHAPTER 2. REGIONAL MOBa= PLAN IMPLEMENTATION 10 CHAPTER 3. CONFORMITY GUIDELINES 15 CHAPTER 4. LOCAL GOVERNMENT AQMP II&MV ENTATION 18 CHAPTER 5. LOCAL GOVERNMENT OUTREACH RVIPLEMENTATION PROGRAM 19 CHAPTER 6. FUNDING FOR PLAN IMPLEMENTATION 22 CHAPTER 7. MARKET -BASED STRATEGIES FOR ACHIEVING AIR QUALITY AND MOBILITY GOALS IN SOUTHERN CALIFORNIA 24 ACKNOWLEDGEMENTS GROWTH MANAGEMENT AND TRANSPORTATION TASK FORCE MEMBERS Chair: HON. JON MIKELS Supervisor, County of San Bernardino Vice Chair: HON. CLARENCE SMITH Councilman, City of Long Beach HON. PAT BATES, Mayor, City of Laguna Niguel, Orange County Growth Management Committee JANE BLOCK, Riverside County Growth Management Committee CHARLES CARRY, Sanitation Districts of Los Angeles County BOB DUNEK, City of Los Alamitos (thru April 1990) DAN GARCIA, Munger, Tolles do Olson SHARON HIGHTOWER, County of San Bernardino, Environmental Public Works Agency JOHN HUNTER, Building Industry Association of Southern California (from Jan. 1990) GERRI KARIYA, County of Los Angeles, Office of the Chief Administrative Officer HON. LEO KING, Mayor, City of Baldwin Park, SCAQMD (thru Dec.1989) NEIL KLINE, Santa Ana Watershed Project Authority (from March 1990) HON. ARDYCE KOOBS, Councilmember, City of Loma Linda MARGO KOSS, Sierra Club -Angelus Chapter HON. AL LOPEZ, Councilman, City of Corona (thru March 1990) RICHARD MARTINO, Teamsters Union #42 WES MC DANIEL, San Bernardino Associated Governments WALTER MOSHER, Valley Industry and Commerce Association, Regional Advisory Council TOM NIELSEN, The Irvine Company STAN OFTELIE, Orange County Transportation Commission NEAL PETERSON, Los Angeles County Transportation Commission JAMES T. POLLARD, Southern California Gas Company (thru Jan. 1990) JACK REAGAN, Riverside County Transportation Commission RAY REMY, Greater Los Angeles Area Chamber of Commerce JIM SIMS, Los Angeles County Transportation Commission (thru Nov.1989) KEN TOPPING, City of Los Angeles, Planning Department HON. JAMES A. VAN HORN, JR., Councilman, City ofArtesia HON. HENRY WEDAA, Councilman, City of Yorba Linda, SCAQMD (from Dec.1989) HON. HARRIETT WIEDER, Supervisor, County of Orange KEN WILLIS, Building Industry Association, Southern California (thru Jan. 1990) RON. JUDY WRIGHT, Councilmember, City of Claremont EXECUTIVE SUMMARY ,' Clean air for Southern California. While it is a straightforward goal, the attainment of clean air in this region is a complex and complicated undertaking. The South Coast Air Quality Management Plan (AQMP), adopted by the Southern California Association of Governments (SLAG) and the South Coast Air Quality Management District (SCAQMD) in March 1989, is an ambitious plan that sets forth a vast array of measures that are intended to bring the region into compliance with national air quality standards by the year 2007. When the AQMP was adopted, a number of issues and concerns remained regarding its implemen- tation. In order to assure that those issues would be addressed, the AQMP called for the formation of two task forces, one to deal with growth management and transportation issues, the other with socio-economic and public health impacts. The Growth Management and Transportation Task Force was therefore convened in June 1989 to provide recommendations that would foster implementation of the 1989 AQMP as well as to recommend revisions to be incorporated into the 1991 Plan. (Tbe California Clean Air Act requires adoption of the next plan by June 1991.) Task Force recommendations focus on the growth management and transportation control measures found in Appendix TV-0 of the Plan. The Task Force, comprised of elected officials from city and county governments, representatives of transportation agencies, public and private sector organizations and other public agencies, have met . monthly to grapple with the complex array of issues associated with AQMP implementation. Task Force participants have provided much guidance and insight in developing recommendations that seek to answer the question, "How do we make the regional plans work?" C] In its review and consideration of AQMP implementation issues, the Task Force raised many questions — What logistics are involved in Growth Management Plan and Regional Mobility Plan implementation? What benefits are to be achieved from job/housing balance implementation? Air there better ways (i.e. market mechanisms) than regional regulation, for effective implementation? to name a few — and also tackled some of the institutional and financial constraints to plan implementation. The following are the highlights of Task Force accomplishments: • Growth Management Plan (GMP) Implementation (Chapter 1) Three key policies highlight the Task Force's recommendations for implementing the 1989 Air Quality Management Plan/Growth Management Plan Measure 17. Foremost, the Task Force has focused the emphasis of GNP/job-housing balance implementation on the goal of vehicle miles traveled (VMI) and congestion reduction. The TaskForce recommends that subregional VMT and congestion reduction targets be developed so that local governments have flexibility in how they achieve VMT reductions equivalent to those attributed to job/housing balance. Further, the Task Force recommends market incentive measures as primary means of imple- menting VMT/congestion reductions or job/housing balance (page 1). Significantly, an alternative Growth Management Plan measure, incorporating the above principles, is proposed for inclusion in the 1991 AQMP revision. The alternative measure ES -1 recommends a non -regulatory process through 1994 aimed at achieving VMT and congestion reduction objectives. The Task Force encourages voluntary subregional demonstration projects (in both job -rich and housing -rich arras) to implement these objectives and also recommends implementation of this alternative measure through market incentives (page 7). Regional Mobility Plan (RMP) Implementation (Chapter 2) An institutional framework for inter -county regional transit to address the institutional hindrances to RMP Transit Element implementation (page 10) has been proposed. The Task Force also endorsed Propositions 111/108 on the June ballot (bothpassed) as priorities forF.W implementation and proposed that funds generated through pricing mechanisms could be - invested in transit programs. In addition, the Task Force recommends that completion of the emerging High Occupancy Vehicle (HOV) network should continue to receive high priority forRMP implementation, and that parking pricing strategies and other AQMP measures which encourage modified travel behavior needed to support transit objectives should be implemented uniformly within subregions (page 12). V._ • Market Incentives (Chapter 7) The Task Force recommends that market incentive programs be utilized as primary mecha- nisms for implementing transportation demand management and growth management meas- ures in the AQMP. To facilitate implementation of this recommendation, an amendment to the Federal Clean Air • Act which would allow the use of market incentive options in the AQMP was developed, with broad -based support, and forwarded for Congressional action (page 24). A market incentives concept paper has been prepared (page 28) and six demonstration projects recommended for inclusion in the 1991 AQMP (page 47). A joint SCAG/SCAQMD Public Outreach and Educational Program was developed to facilitate local government participation in AQMP implementation (Chapter S). Recommendations were provided to the Conformity Working Group and the Planning Director's Committee regarding development of AQMP Conformity Guidelines and Air Quality Element Guidelines (Chapters 3 and 4). • Several recommendations were made regarding plan implementation funding. The Task Force developed a legislative proposal to fund local government AQMP implementation efforts and recommended that all activities that implement Task Force recommendations (such as market incentive and subregionai entities demonstration projects) be eligible for funding under AB 2766. It also supported public and private sector funding for a new Origin and Destination survey to update the database for the regional transportation model after the 1990 Census (Chapter 6). 0 ES-2 • SUMMARY OF RECOMMENDATIONS The Growth Management and Transportation Task Force is one of two Task Forces jointly created by the Executive Committee of the Southern California Association of Governments (SLAG) and the Governing Board of the South Coast Air Quality Management District (SCAQMD) in June 1989 to review growth management and transportation issues that affect implementation of the South Coast Air Quality Management Plan (AQMP). In establishing the Growth Management and Transportation Task Force, the SCAG Executive Committee set three goals: 1. To develop enforceable implementation programs for growth management and transportation programs; 2. To identify funding mechanisms for regional transportation needs- and local air quality elements; and 3. To identify amendments to the 1991 Air Quality Management Plan in the context of the state and federal review process. The Task Force reviewed these broad categories of concerns and addressed specific issues within those categories. This summary is provided as a convenient reference of Task Force recommenda- tions as they relate to each of the objectives set forth for it by the Executive Committee. OBJECTIVE 1: Review and provide a recommendation to the Executive Committee on the implementation guidelines for the transportation, growth management and wastewater portions of the AQMP. GROWTH MANAGEMENT PLAN IMPLEMENTATION A. IMPLEMENTATION OF THE JOB/HOUSING BALANCE POLICY The Task Force adopted several key polices regarding implementation of the job/housing balance policy of the Growth Management Plan. They are: 1. Local governments should have flexibility in how they achieve better job/housing balance. 2. Market incentive programs should be the primary strategies for job/housing balance policy implementation in the 1991 AQMP revision. 3. The major focus of growth management measure implementation in the RMP and the AQMP should'be VMT (vehicle miles traveled) reduction. ES-3 4. Subregional VMT and congestion reduction targets should be developed in amounts equivalent to those attributed job/housing balance implementation so that local govern- ments have the flexibility to trade-off job/housing balance performance goals with equivalent VMT reduction measures. 5. To protect a healthy regional economy, affordable housing and disadvantaged groups, indicators of regional housing growth and regional job growth should be monitored 6. SCAG should seek funding from both private and public sector sources to conduct a new Origin and Destination Survey after the 1990 Census. Anew survey will update the travel behavior assumptions upon which job/housing emissions reductions and transportation system needs are modeled and may lead to modifications in the 1994 AQMP update. When undertaken, the database and subsequent modeling effort should be open for public review at hearings before the Executive Committee. 7. An alternative growth management measure should be included in the 1991 AQMP revision. This measure would include a non -regulatory process through 1994, and be based on the voluntary participation of the public and private sectors in AQMP implementation efforts that reduce VMT and congestion by amounts equivalent to those attributable to job/housing balance implementation. In 1994, VMT reductions gained through growth management measure implementation should be assessed and the measure re-evaluated 8. Assessment of job/housing balance implementation should include comparison between • housing affordability and job -type, taking into account the dynamic nature of job mixes, and job and housing locational decisions over time. B. FORMATION OF SUBREGIONAL ENTITIES 1. Creation of workable subregional entities should be encouraged for Growth Management Plan implementation and for the implementation of market oriented efforts to reduce VMT and manage congestion. In forming subregional entities, it is recommended: that existing institutional structures be utilized; that they be voluntary associations that are single- or cross -county and incorporate sensible "commute sheds"; that they focus on transportation measures directed at VMT reduction and congestion management; and that they include participa- tion by both public and private sector interests. 2. A demonstration project should be established to measure, test and monitor the subregional entities concept. Any association volunteering to participate in the demonstration project would be accepted • ES - 4 REGIONAL MOBILITY PLAN UAPLEMENTATION A number of institutional and financial concerns hinder implementation of the Regional Mob Plan allAP). The Task Force has developed a number of recommendations that address: 1) institutional considerations for implementation of the RMP Transit Element; 2) phasing of RMP implementation; and 3) financing of Plan implementation (see recommendation under Objective 2.) A. INTER -COUNTY REGIONAL TRANSIT INSTITUTIONAL FRAMEWORK The Task Force has recommended that SCAG convene the County Transportation Commis- sions and the LOSSAN Rail Corridor Agency to develop a specific agreement and program to plan and develop the inter -county regional mass transit system. This system is identified in the RMP as the regional system ofheavy and medium capacity lines and the commuter rail network. This system should be coordinated with the local feeder systems in order to function as an integrated network serving the entire region. Should this effort not be successful, this issue should be brought to the SCAG Executive Committee for further consideration and development of a plan for further action. B. PHASING OF THE IMPLEMENTATION PROCESS 1. Completion of the emerging regionwide HOV (high occupancy vehicle) network should continue to receive high priority for RMP implementation as an effective form of transit that will be available in the near term. An expansion of the HOV network to significant arterials and expressways should be investigated. • 2. Parking pricing strategies and other AQMP measures which encourage -modified travel behavior needed to support transit objectives should be implemented uniformly among job centers within subregions. • C. NON -MOTORIZED TRANSPORTATION CONTROL MEASURE 1. A non -motorized transportation control measure should be considered within the frame- work of the 1991 RWAQMP. AIR QUALITY MANAGEMENT PLAN BWLEM ENTATION A. IMPLEMENTATION OF AQMP CONFORMITY PROCEDURES 1. The Conformity Guidelines should reflect a systems rather than a project -by -project review approach. 2. SCAG and SCAQMD should coordinate the CEQA and AQMP conformity review processes for regionally significant projects reviewed under the 1989 AQMP and subsequent AQMP updates. 3. SCAG and SCAQMD should develop common thresholds for CEQA and AQMP conformity reviews under the 1991 AQMP. These thresholds should be based on equivalent VMT impacts. ES-5 4. The Conformity Working Group effort should be extended in order to moni*or and review the operation of the adopted Conformity Guidelines and to make recommendations for revisions to the 1991 AQMP Conformity Procedures and Regional Mobility Plan, if necessary. 5. The following issues should be considered in development of the 1991 AQMP Confor- mity Procedures: a. Conformity review df projects should occur at the earliest possible point in time in the planning process. b. Local governments should achieve conformance with the AQMP by adopting and implementing a comprehensive plan for AQMP implementation, so that all general development projects approved consistent with the plan are also conforming to the AQMP. c. A process should be developed to consider balancing and integrating air quality, growth, transportation and wastewater system needs in making conformity determi- nations. B. INDIRECT SOURCE MEASURES Local government actions and market incentive approaches should have adequate opportunity and funding to meet AQMP deadlines for implementation before the SCAQMD considers • moving forward with development of indirect source rules. C. LOCAL GOVERNMENT AQMP IMPLEMENTATION The following Task Force recommendations have been incorporated in development of the Air Quality Element Guidelines: 1. The Air Quality Element Guidelines should include aprocessforself-certificationbylocal jurisdictions. 2. The deadline for local governments to adopt general plan amendments for air quality should be extended one year, from January 1,1991 to January 1,1992. Target dates for 1994 should be specifically set in order clarify deadline dates for local governments. 3. The Air Quality Element Guidelines should, to the extent possible, provide attainable and quantified objectives for emissions categories. Local governments should be allowed flexibility to design programs to meet those objectives. 4. Local governments should be encouraged to prepare air quality elements/AQMP implem- entation plans in a subregional context, • ES-6 • OBJECTIVE 2: Review and provide a recommendation to the Executive Committee on a funding program for transportation and local air quality elements, as well as an assessment of the ,financial impacts. of Growth Management Plan implementation. CJ A. FUNDING FOR REGIONAL MOBILITY PLAN IMPLEMENTATION 1. The Task Force endorsed Propositions i 1 l/108 as priorities for plan implementation. 2. Market incentives, including the pricing of automobile use to better reflect its social costs (congestion, parking, emissions), should be utilized to promote transit and other air quality strategies. Funds generated through market incentive programs could be invested in transit programs. Market incentive programs should be integrated into future updates of the AQMP and RMP. B. FUNDING FOR LOCAL GOVERNMENT AQMP IMPLEMENTATION The Task Force recommended a set of guiding principles for the development of a -legislative proposal for funding local government implementation of the AQMP. These principles were utilized in the development of a formula for disbursement offends in the South Coast Air Basin which was incorporated into AB 2 766 (Sher). This bill authorizes a $4 vehicle registration fee to assist local government implementation of the California Clean Air Act and regional air qualty management plans. All activities that implement the recommendations of this Task Force report should be eligible for funding under AB 2766. Local government participation in, and implementation of, subregional entities demonstration projects should receive priority for funds available in the "discretionary funding" provisions of the bi1L ES - 7 0 OBJECTIVE 3: Develop market incentive implementation alternatives and pro vide a recom- mendation to the Executive Committee. The Growth Management and Transportation Task Force established a Market Incentives Subcom- mittee to explore practical application of market incentives for implementation of land use, transportation, and energy conservation measures of the AQMP. A conceptpaper, "A Market -Based Program for Air Quality and Mobility in Southern California," is included in Chapter? of this report. The Task Force recommendations on implementation of the market incentives concept areas follows: 1. The Federal Clean Air Act should be amended to allow market incentive options. 2. Market incentive strategies should include safeguards against adverse or unintended consequences to lower -income persons and to the environment. 3. Market incentive programs should be considered as primary mechanisms for implement- j ing the growth management and transportation demand management measures in the j AQMP. '1 4. Market incentives should be incorporated into all appropriate elements of the 1991 AQMP revision. Six demonstration projects -- auto buy back, congestion pricing, parking management, commercial vehicle management, growth management, telecommuting are proposed 5. Intergovernmental transfers of resources (such as tax increment funds) should be examined as a mechanism to meet housing and job goals. OBJECTIVE 4: Develop a joint SCAG/SCAQIKD recommendation to enhance each agency's Public Outreach and Educational program. Local government participation is an essential component for successful implementation of the AQMP. A joint SCAG/SCAQMD Public Outreach and Educational Program was therefore - developed in order to facilitate this process and to provide assistance to local governments in taking implementation actions. The Task Force adopted the program with the emphasis that the lead forthis effoi t should take place through the SCAG Service Offices in Orange and Riverside/San Bernardino counties. • ES-8 CHAPTER 1. GROWTH MANAGEMENT PLAN IMPLEMENTATION (AQMP MEASURE 17) + ::::,.F.; ,,• � +•�„++rx•.;,.;t., •...:::•:.: t�:tt �:+:+t+:o:;t•�:+::•:+..,•:::•:•r,,;•r•a::.,,,:.;::•:•:; :: ..,+•;:: t.:+:::.:;•.;• iu::a::,,.•sc:t:>?.'is8::;•A:o-N.V:oy.•.,w.•a,...xAY>��aa� "'"`a°"�` r+n'''^ww�"""":, '�'"+:. •• .. . The Task Force raised a number of major institutional, financial and technical concerns associated with implementation of the Regional Growth Management Plan (GNP). These issues included implementation of the job/housing balance policy, the social and economic impacts of GMP implementation, local government options in GNP implementation, and formation of subregional entities. The modeling/emissions benefits associated with implementation of the job/housing balance measure were also examined The Task Force concluded its efforts by developing a proposal for an alternative Growth Management measure to be included in the 1991 AQMP revision. A. POLICY RECOMMENDATIONS The Task Force recommended that three key policies govern Growth Management Plan implementation efforts: 1. The major focus of growth management measure implementation in the Regional Mobility Plan and Air QualityManagementPlan should be VMT (vehicle miles traveled) and congestion reduction. 2. Local governments should have flexibility in how they achieve VMT reductions equiva- lent to those attributed to job/housing balance implementation. • 3. Market incentive measures should be the primary strategies for implementing VMT reductions equivalent to those attributed to job/housing balance implementation. B. JOB/HOUSING BALANCE The regional Growth Management Plan seeks to develop balanced communities throughout the region in order to reduce congestion and air quality impacts of projected levels of growth. One way to facilitate this goal is to plan for a better match of job opportunities and housing opportunities in the same general area or subregion. This is the concept behind job/housing balance. Implementation of the job/housing balance policy of the Regional Growth Management Plan (GMP) could contribute significantly to emissions reduction in the Air Quality Management Plan. This measure is also a major factor for the success of the Regional Mobility Plan (RMP) for in addition to the emissions. -eduction, it reduces by one-third the projected cost of RMP im- plementation. Job/housing balance involves both private and public efforts to achieve better balance between future jobs and housing within subregions and will be a factorin reducing the number and length of vehicle trips within the air basin. One possible distribution of growth which fulfills the goals of reducing transportation and air quality impacts is presented in the GMP growth forecast. 9 The ratio between (rather than amount of) additional jobs and additional housing is the objec- tive indicator of job/housing balance in an area. However, since the focus of the growth management policy is the reduction of vehicle miles traveled (VMT1) and associated air emissions reductions, it is the VMT equivalent to the job/housing balance ratios that is the important indicator of GMP goal achievement, rather than the attainment of specific housing or job targets. Social and Economic Impacts of GMP Implementation When the GMT was developed, it was recognized that job/housing balance and mobility were not the only policy concerns associated with growth in the region. The plan states that care should be taken when implementing the job/housing balance policy and specifically identifies the following issues which should be considered by local implementing agencies: • Provide adequate investment and renewal in aging or depressed areas that happen to be job -rich, and design a system to assure that the needs of these areas are met; Avoid creation of a net job loss in the region which could occur if employment growth were overly restricted in areas such as ports or airports; " • Recognition that, with changes inthe economy and increases in the numberof small firms, local government actions affecting the location of employees may be less applicable; • Where communities are already built-up, redirect to them only enough housing growth to • relieve problems associated with in -commuting, and only if there is infrastructure adequate for the added housing units; • To the degree possible, achieve a subregional balance between the type of jobs and the price of housing; Accommodate a fair share of low- and moderate -income housing in areas where job growth will be redirected. Coordinate regional fair share with the growth management system to avoid imbalances of social groups and governmental service costs; and • In achieving job/housing balance, avoid measures that are punitive, legally questionable, or excessively burdensome. Each of these issues are aspects of the social and economic impacts of implementing the GNP. There will be situations when concerns over one or more of these issues may outweigh the need for attaining job/housing balance. However, there were no criteria on how these concerns or other issues should specifically interact with the implementation of the job/housing balance policy of the GNP. The Task Force considered four general social policies to guide implementation of the job/ housing balance policy: 1) If annual estimates of regional housing production indicate a significant shortfall relative to the forecasted need, housing construction should be encouraged and take precedence . over subregional job/housing balance goals for the period of the shortfall. 2 2) If annual estimates of regional unemployment significantly exceed levels assumed in the development ofthe regional jobs forecasts, creation of jobs should be encouraged and take precedence over job/housing balance for the period of the excess. 3) Projects that added jobs forlow-income groups ineconomically depressed areas which are located in job -rich subregions should be exempt from the job/housing balance policy review process. 4) Projects that add low-income housing, and housing for the disabled and elderly in housing -rich subregions that are not meeting their fair share housing goals, should be exempt from the job/housing balance policy review process. 7bese types of policies are important because they may override a simple review of the number of jobs and housing units and their ratio when comparing them to the GNP forecast. While policies #3 and #4 above were found to be acceptable, it was suggested that independent indicators were necessary for determining whether regional economic (job) growth or housing growth should override the job/housing balance distribution policy in the GNP. Task Force Recommendation: Should adequate reductions not be achieved through alternative VMT reduction measures, the social policies identified above should apply when implementing the growth management policy and the following indicators should be monitored in order to further the goals of those policies. Ifthese indicators reach the levels noted, then SCAGExecutive Committee review and • approval of implementation impacts would be required for an actual override of the job/ housing balance policy to occur. 0 1. RegionalHousing Growth Indicator - The housing growth indicatorfor theJob/housing balance policy would be a decline in residential permit rates (seasonally adjusted) to levels of less than 70% of the level of the previous year for two consecutive quarters or an entire yeas. The concern would end when permit rates returned to above 70% of the previous year for two consecutive quarters or one entire year OR when net additional unitsper California DepartmentofFinancefor the calendaryearfollowing (the concern) equaled at least 70% of Regional Housing Needs Assessment (RHNA) net future need levels. 2. RegionalJob Growth Indicator - The job growth indicator for the job/housing balance policy would be an increase in the region's unemployment rate of one percentage point or more from the prior year. The concern would remain in effect until the unemployment rate declined by one percentage point in a single year or one and a half points over a two yearperiod. Finally, the concern would not be triggered if theprioryear's unemployment rate was less than the 35% rate assumed for the region in 2010. 3. Projects thatadd jobsforlow-income groupswho reside in economically depressed areas which are located in job -rich subregions should be exemptfrom the job/housing balance policy review process. 3 4. Projects that add low-income housing, and housing for the disabled and elderly in housing -rich subregions that are not meeting their fair share housing goals, should be exemptfrom the job/housing balance policy review process. Options for Local Government Implementation of the Growth Management Measure Implementation of the GMP policies, including the job/housing balance policy, rests with local jurisdictions. Although some jurisdictions already incorporate job/housing balance goals in their plans, the policy is not implemented fully across the region. The job/housing balance concept is not new, but implementation of the policy as a regional strategy for mobility and air quality is a new approach which needs to be further examined and elaborated. The policy and evaluation criterion contained in the mobility and air quality plans is to achieve the vehicle miles traveled (VMT) and associated air emissions reductions, not to achieve specific housing or job targets. The job/housing balance ratios and targets provide surrogate measures which local governments can monitor for achieving the VMT reductions. In concept, cities can use other methods for achieving the VMT targets through such things as mixed land use policies, centers development, transit support or pricing mechanisms such as parldng management and peak hour pricing. Thus, for purposes of plan evaluation, VMT reductions through job/housing balance or equivalent VMT reduction through other local actions are sought. The Growth Management Plan presents an illustrative list of optional measures that can be pursued by implementing agencies towards achievement of the regional job/housing balance goals. The GMP does not recommend or emphasize any specific strategy or set of actions. Possible implementation policies and actions that can be utilized by local jurisdictions to attain jobs/housing balance goals are found in Appendix 1 of the GNP. Task Force Recommendation: 1. Subregion! VMT reduction and congestion targets should be developed in amounts equivalent to those attributed to joblhousing balance implementation so that local governments have the flexibility to trade-off`' job/housing emission reductions with equivalent VMT reduction measures. 2. Assessment of job/housing balance implementation should include comparison between housing 4ffordability and job -type, taking into account the dynamic nature of job mixes, and job and housing locational decisions over time. 3. Local governments should have flexibility in haw they will achieve better job/housing balance. 11 n 0 Formation of Subregional Entities The Growth Management Plan proposed the formation of subregional entities to facilitate implementation of the job/housing balance policy. the nature of such entities --their role in the implementation process, their responsibility and relationship to local jursdictions--has been the subject of much debate. Although key responsibility for implementing job/housing balance rests with local govern- ments, the CUP does not establish specific job/housing balance goals for individual jurisdic- tions. From a regional perspective, it is important for balance to occur at a "commute shed" level, rather than at the individual city level. Furthermore, not all cities may wish or arc able to be completely balanced within their boundaries. Applying the job/housing balance policy at a subregional level allows for differences between communities. The intent is toleave the region's local governments the flexibility to design their own futures but also to encourage those plans to be made within the context of neighboring communities and the region as a whole. The Task Force was asked to consider how the subregional entities should be formed, how boundaries should be determined, their role in the implementation process, their authority, and relationship with existing local governments. Task Force Recommendation: !' 1. Workable subregional entities should be formed for regional growth management plan implementation and for the implementation of market oriented efforts to reduce VMT and manage congestion. 2. The framework for the formation of subregional entities for implementation of the job/ housing balance policy should include the following elements: a. Existing institutional structures should be utilized in their formation; b. Subregional entities should be voluntary associations that can be single- or cross -county and incorporate "commuter sheds" that are sensible. Subregional transportation agencies implementing VMT reduction(congestion management plans should be considered as prime candidates for or as subregional entities. c. Subregional entities should implement VMTreduction and congestion management programs. d. Both public and private sector interests should be included to maximize implemen- tation success. 3. A demonstration project should be established to measure, test and monitor this concept. Any association volunteering to participate in the demonstration project would be accepted. F Market Incentives Implementation Options \10 The 1989 AQMP calls for investigating the potential power of the market place to reduce air pollution in Southern California. Initial investigations by the Market Incentives Subcommittee ofthe Task Force have revealed that broad support radsts for the use ofincentive-based measures as an emissions reduction strategy. Support has come from government, industry, and the environmental community. Task Force Recommendation: Market incentive measures should be considered as primary implementing mechanisms to _ achieve job/housing balance. Two demonstration projects (one in a job -rich area, another in a housing -rich area) are proposed to test implementation of job/housing balance through market incentives. These demonstration projects are to be carried out through voluntary subregionl entities, are to focus on VMT reduction, be monitored annually and evaluated for effectiveness after three years. (The demonstration projects are described in Chapter 7.) C. FUNDING FOR LOCAL GOVERNMENT IMPLEMENTATION (See discussion in Chapter 6.) D. UPDATE OF TRANSPORTATION MODEL DATABASES In response to concerns regarding the assumptions utilized in the modeling effort and the benefits to be gained from job/housing implementation, the Task Force reviewed the Transpor- tation Modeling System. i The regional transportationmodeling system is a setofmodels whichtranslates socio-economic and transportation system data into information regarding travel demand or system usage. It provides important information upon which the current transportation system is simulated and future transportation needs are forecast. In addition, impacts on congestion and air emissions reductions attributable to the implementation of various plan measures (including growth management) are assessed through this modeling system. A fundamental source of information utilized in modeling efforts is the Origin and Destination Survey. The survey provides information regarding trip generation, purpose, distribution and mode choice. An Origin and Destination Survey was first conducted in 1967 and most recently updated in 1976. As significant changes have occurred in the region since that time and trip -making has most likely also changed, the need for an updated survey is evident. Task Force Recommendation: SCAGshould seek fundingfrom both private andpublic sector sources to conducta new Origin and Destination Survey after the 1990 Census, in order to update the travel behavior assumptions upon which job/housing emissions reductions and transportation system needs are modeled. When undertaken, the database and subsequent modeling effort may lead to modifications in the 1994 AQMP update and should be open for public review at hearings before the Executive Committee. 6 E. RECOMMENDATION FOR 1991 AQMP REVISION In reviewing the AQMP Growth Management measure, the Task Force grappled with a number of significant issues associated with its implementation. As identified previously in this chapter, the Task Force's primary recommendation is that the focus of GNP implementation be on attainment of VMT and congestion reduction goals. As indicators of air quality improvements, job/housing performance ratios were viewed as being possibly too restrictive. Instead, VMT and congestion reduction performance goals were suggested as more direct indicators that would allow greater flexibility to local governments in their implementation efforts. Additionally, the Task Force recognized the difficulties associated with implementing job/ housing balance through subregional entities and recommended that this concept be tested and monitored in a practical setting through demonstration projects. Incentive -based measures were recommended to be utilized, wherever possible, to implement job/housing balance. The Task Force therefore recommends that an alternative Growth Management measure, incorporating its recommendations on GNP implementation, as well as the elements identified below, be included in the 1991 AQMP revision. Recommended Alternative Growth Management Measure: • Synopsis The Growth Management measure should be identified in the 1991 AQMP as a non - regulatory process through 1994. Its implementation should be based on the voluntary participation of the public and private sectors to revise general plans and/or implement alternative market incentive approaches that reduce VMT and congestion by amounts equivalent to those attributed to job/housing balance implementation. • Goal of the Growth Management Policy The reduction of VMT (vehicles miles traveled) and congestion is the major focus of the 1989 Growth Management Plan (GMP) and should continue as the focus of the Growth Management measure in the 1991 AQMP. Implementation Timeline The GMP policy forecasts, used in modeling the transportation system, incorporate the job/housing balance policy. These forecasts allow an appraisal of the amount by which commute distances can be reduced regionally, and of the resulting reduction in air emissions. TheAirQualityManagementPlan (AQMP) assumes that 96% ofthe emissions reductions attributable to the Growth Management measure will occur between 1994 and 2010. Substantial VMT reduction benefits of Growth Management policy implementation are not expectedto,be accrued until after the year2000. 7 The Task Force recommends that the 1991 AQMP Growth Management measure therefore be a non-regulatoryprocess until1994. In 1994, after three years of experience, VMT reductions due to implementation of the growth management measure should be assessed and the measure re-evaluated. To facilitate this process, SCAG should develop subreg'ional VMT and congestion reduction targets in amounts equivalent to those that would be attained through jobl housing balance implementation. The VMT reduction targets will be the objective indicators ofattainment of the objectives of the job/housing balancepolicy. These targets will be used to assess co.1fbrmity of plans and projects; achievement of job/housing balance performance goals will automatically result in VMT reduction credit. CongestionManagementPlansofcitiesand counties shouldbe consistentwith these VMT reduction targets and with the AQMP and Regional Mobility Plan (RMP). Subregional Demonstration Projects Key responsibility for implementing the VMT reductions rests with local governments, however, from a regional perspective, it is more important to attain the benefits of the policy at a subregionl or commute -shed level. The Growth Management Plan therefore proposes the voluntaryformation of subregional entities to facilitate implementation of the job/housing balance policy. The Task Force recommends that demonstration projects be formed to measure, test and monitor the subregionl entities concept. SCAG should work with several existing groupings of local jurisdictions to organize subregional demonstration projects and. assist them in the development of implementation procedures. Demonstration projects should represent both public and private sector interests. ' Implementation Options The reduction of VMT can be accomplished through a variety of means. The Growth Management Plan presents an illustrative list of optional measures and actions that can be implemented by local agencies to achieve job/housing balance. No single strategy or set of actions is specifically recommended or emphasized. The 1989 AQMP calls for investigating the potential of market incentive strategies to reduce air pollution in the Basin. Broad support exists for the use of incentive -based measures as an emissions redu;tion strategy. The Task Force recommends that market ineentives be considered a primary implemen- tation program to achieve VMT reductions equivalent to reductions to be achieved through job/housing balance implementation. SCAG should therefore collaborate with implementing entities and the private sector in the development of action programs based on market incentive measures. 0 8 • Development of Local Programs One strategy that can befollowed by local governments to implement the GMP is to revise and update their General Plans to reflect the VMT reduction objectives. The Task Force recommends thatSCAG assist local governments to formulate and adopt implementation plans consistent with regional plan, and/or to revise Land Use, Circula- tion, Air Quality, or other elements of the General Plan to incorporate VMT reduction objectives. Annual Monitoring A consistent and replicable monitoring system should be developed to provide annual feedback on the extent and effectiveness of actions taken_ by implementing agencies, as well as changes that occur due to market forces. The system should track trends in employmentand housing growth, the VMT reductions attributable to job/housing balance implementation, and the effect of market incentive measures. It is therefore proposed that SCAG, with the participation of local governments, develop a system toevaluateprogress in attainingsubregional VMTand congestion reduction and other benefits. CHAPTER 2. REGIONAL MOBILITY PLAN IMPLEMENTATION :::.}:.}•::•.i:..}•:::::::.i'::::.i;.};{,T:!i•i:•i:•i:•i:•i::.;.};.n,��:..}:•:Y:.:•Y:•:i•,v,•'r::.:•.:.,:m:{.},,:•:.v,......ir...�,:.}•.: .}•:•.n.J.:.h .+.nyix .. ivvi:0}:::::.iJ:::,,•:v.vmvwi.xvv:nw:x..W:•>.vvJnvv.,,•nvn•.vvwG.w.•nA„w.W.\v:J.J.vC„ w. •• •• •• •••Siv`:W}yiv'1„v,i; \..,vtiJvv The goal of the Regional Mobility Plan (RMP) is to recapture and retain the transportation mobility levels of 1984. The Plan attempts to balance the use of existing and new facilities, the provision of alternative modes, and demand management in order to address the plan goal and to meet the region's mobility requirements. A number of financial and institutional concerns that hinder implementation of the RMP have been discussed by the Task Force. Recommendations have been developed that address: 1) institutional considerations for implementation of the RMP Transit Element:; 2) financing for plan implementa- tion; and 3) amendments to the 1991 RMP/AQMP. A. INSTITUTIONAL FRAMEWORK FOR INTER -COUNTY REGIONAL TRANSIT The Regional Mobility Plan (RMP) and the Air Quality Management Plan (AQMP) have established the goal of 19% transit share of home -to -work trips by 2010, which is equivalent to 6% of all trips throughout the region This goal represents a near quadrupling of transit ridership for work trips. The Mobility Plan also recommends that the regional transit system be restructured into three subsystems: the regional linehaul system of express lines connecting the 66 major activity centers in the Region, the network of feeder lines which support the linehaul routes, and local • circulation routes. There are a number of obstacles to the implementation of the RMP's Transit Element. A significant barrier to the effective development of a regional transit system is the current multiplicity of jurisdictions responsible for planning, funding and operating it. Inter -jurisdic- tional coordination remains a constraint on maximizing the potential of transit, and leads to both gaps and duplication in service. In addition, implementation of the transit development program of the RMP would require virtually all construction of the "unconstrained" portion of the regional transit network to take place in a ten-year period. This is due to the length of time required for planning, design and permitting. Such a schedule imposes tremendous requirements on the organizational structure of the transportation system, both public and private. Recognizing that SCAG is legally designated by AB 1246 to coordinate among the County Transportation Commissions, as well as among the Region's transit operators through the Short Range Transit Plan (SRTP) and Regional Mobility Plan processes, it is recommended that SCAG initiate a process to bring about the necessary coordination for development of an inter -county regional transit system. Task Force Recommendation: SCAG should convene the County Transportation Commissions and the LOSSAN Rail Corridor Agency to develop a spec lc agreement and program to plan and develop the 10 inter-couruyRegionalmasstransitsystem, identUled in theRMP as the regional system ofheavy •, and medium capacity lines and the commuter rail network. This system should be coordinated with the local feeder systems to function as an integrated network serving the entire region. Should this effort not be successful, this issue should be brought to the SCAG Executive Committee for further consideration and development of a plan for further action. The organizational structure suggested in this recommendation would establish a regional public/private compact or an authority empowered to plan, design, construct and operate the regional line haul system. The Task Force suggested that such a unified approach was clearly indicated, given the past history of trandrin the Region Several organizational principles for the compact or authority have been suggested: • It should be sufficiently flexible that it does not impose solutions inappropriate to the problem through excessive or irrelevant controls or demands placed on it. • It should follow the principle of leaving responsibility in the hands of the lowest level agency which can effectively and efficiently carry out the activity. • Each level within the system should have the legal and financial means to achieve its mandate, and the ability to effectively coordinate and, where necessary, control the levels below. • New functions should be given new sources of funds rather than reallocating existing sources. In particular, regional level functions would be funded from such possible • sources as a regional fuel tax, regionally collected congestion fees or paricing surcharges, etc. However, given the shortage of public funds, the organizational structure developed should also include mechanisms for encouraging private investments in facilities and/or specific services. • Each level should produce a set of "nested plans", ranging from the long-term strategic plan to detailed implementation action plans appropriate to the degree of responsibility placed on it. Mechanisms should exist at each level to effectively resolve conflicts at the level below. • Implementation/execution of plans and projects should be reviewed and monitored on a routine basis, -to provide the information required for periodic updates. in addition to the Regional line haul function, the Task Force recommended that the feeder/ distributor and local circulation systems be planned and operated by subregional scale agencies. Such subregional scale operators would also provide the initial approach to implementation of jobrnousing balance, assisting the subregions to organize effective and coordinatedinstitutions. Such subregional operators would be more responsive to local concerns and would be held accountable at the local level to provide both local and feeder service to the regional system. This would reflect the policy of maximum use of local agencies to implement the plan. 11 B. PHASING OF THE IMPLEMENTATION PROCESS Limitations in existing funding sources for programs and projects impinge on an implementa- tion sequence which would maximize program integration. The sequence of action plan implementation is primarily established by existing program funding availability, constraints to use of available funds, and is furthered by decisions on timing of local government implementation, as well as the priorities established in the constrained and unconstrained facility improvements. Task Force Recommendations: 1. Completion of the emerging regionwide HOV network should continue to receive high priorityfor R_HP implementation as an effective form of transit that will be available in the near term. An expansion of the HOV network to significant arterials and expressways should be investigated. 2. Parking pricing strategies and other AQMP measures which encourage modified travel behavior needed to support transit objectives should be implemented uniformly within subregions. (See Demonstration 3: Parking Management on page 53.) r 3. Market incentive programs should be considered as primary mechanisms for implement-ing transportation demand management strategies. 4. Rail priorities should be incorporated into the institutional framework described in • Section A. above. C. COORDINATION BETWEEN AQMP CONTROL MEASURES, CONFORMITY GUIDELINES, LOCAL AIR QUALITY ELEMENTS AND CONGESTION MAN- AGEMENT PLANS The Task Force explicitly recognized the linkage between transportation and land use, and in particular the function of HOV/transit facilities in serving the Region's major activity centers. It was suggested that the best point of entry into the job/housing balance issue was through the creation of subregional groupings of county, local and transit operating agencies tied to the implementation of the Congestion Management Programs (CMPs) mandated under AB 471. A great deal of similarity between the AB 471 requirements for congestion management programs and the AQMP requirements for adoption of transportation control measures, within and outside the general plan. Both require trip reduction and travel demand elements, a program to analyze the impacts of land use decision made by local jurisdictions on regional transporta- tion systems, and a program to mitigate the regional transportation impacts identified in that analysis. The bill also calls upon SCAG to evaluate the consistency of the congestion management program with the Regional Mobility Plan. If the agency responsible for preparation of the approved congestion management program determines that a city or county is not conforming to elements of the approved congestion management program, a finding to that effect may be made, leading to potential loss of subvention funds. • 12 U Local government should seriously consider how work initiated under the AQMP requirement of aii air quality element or other AQMP implementation program may also prove necessary under CMPrequirements. It is very likely thatmajorportions of suchimplementationprograms will satisfy the requirements for congestion management programs. Task Force Recommendation: Congestion Management Plans of cities and counties should be consistent with the VMT reduction targets of theAQMP and theRMP. These targets should be used to assess conformity of plans and projects. D. FUNDING FOR PLAN IMPLEMENTATION The cost for implementation of the Regional Mobility Plan (RMP) is significantly beyond available resources. Full implementation of the RMP is estimated to cost $44 billion. The total expected level of funding is $21 billion. In order to achieve RMP goals, all projects and actions identified in the Plan must be implemented According to the RMP Financial Element, revenues from existing sources will not cover the cost required to fund all programs called for in the RMP. For transit, the RMP forecasts a capital shortfallof $18 billion, which represents approximately 2/3 of all the capital investment for transit required by the plan. The plan, however, does not specify the mechanisms which would be used to raise this sum. The Task Force considered two issues associated with the financing of plan implementation: • How do we to address current deficits identified in the plan and also meet future needs? What financing strategies are available for implementing RMP measures for which funding sources are not currently available? Which of these are the most feasible? 1. The Traffic Congestion Relief and Spending Limitation Act (Proposition 111) and the Passenger Rail and Clean Air Bond Act (Proposition 108) In June 1990, Propositions 108 and 111 were voted upon by California voters. These propositions, which were approved will provide about $3.5 billion in state transportation funding to the SCAG region over the next 10 years and will require the development of congestion management programs for every urbanized county. Task Force Recommendation: The Task Force endorsed Propositions 108 and I M (position taken in January 1990 Interim Report) as priorities for plan implementation. 13 2. Implementation through Market Incentive Measures Market incentives provide opportunities for plan implementation through measures such as pricing automobile use to better reflectits social costs (congestion, parking, emissions), and inducing changes in travelpattems and behaviorto reduce congestion. Revenues from fees generated through pricing mechanisms can be invested in HOV/transit programs identified in the RMP. Specific market incentive implementation proposals for transportation demand manage- ment measures are discussed in Chapter 7. Task Force Recommendation: As indicated previously, market incentives should be considered as primary mechanisms for implementing transportation demand management strategies. Funds generated through market incentives programs could be invested in transit programs. These market incentive strategies should be integrated into future updates of the AQMP and RMP. E. Recommendation for Revision to 1991 AQMP The current AQMP does not include a non -motorized transportation control measure. Such a measure, which would encourage development of pedestrian and bicycle transport systems that are coordinated with other transit facilities is desirable for implementation at the local level. Task Force Recommendation: Consider non -motorized transportation control measures within the framework of the RMP 0 14 CHAPTER 3. CONFORMITY GUIDELINES The Federal Clean Air Act (CAA) specifies conformity review as part of the Air Quality Management Plan. The conformity process included in the AQMP was developed to ensure that governmental actions will help to achieve attainment of the National Ambient Air Quality Standards in the South Coast Basin by year 2007. A Conformity Working Group was established by SCAG's Executive Committee and SCAQMD's Governing Board to address significant issues and concerns raised during the public review of the Conformity Chapter of the 1989 AQMP. This Working Group was charged with clarifying the roles and responsibilities of agencies involved in the conformity review process and with relating the framework described in the Conformity Chapter to the planning process in three subject areas (General Development, Wastewater, and Transportation). A set of handbooks ("Conformity Guidelines"), that provides step-by-step guidelines for implementing agencies, was developed by the Working Group. Several important policy issues were raised by the Task Force and Working Group during the Conformity Guidelines development process. The Working Group addressed and resolved most issues and incorporated them into the Conformity Handbooks. Additionally, the Task Force made recommendations for consideration in development of the 1991 AQMP. A. ISSUES INCORPORATED INTO THE 1989 AQMP CONFORMITY GUIDELINES 9") 1. Relationship Between General Plan Elements and AQMP/SIP Conformity • The relationship between general plan elements and AQMP/SIP conformity is addressed in the ' `Conformity Guidelines Related to General Development." The guidelines state that once a local jurisdiction updates its general plan for consistency with the AQMP/SIP, F conformity review will be limited to a annual cumulative impact review performed in conjunction with the Reasonable Further Progress Report (RFP) submitted to EPA. Prior to the general plan revision, project -by -project review for consistency with the AQMP/ SIP is required for regionally significant general development projects. 2. Cumulative Review of Development Projects Task Force Recommendation: Conformity Guidelines should be based upon a systems rather than a project -by project approach. As indicated above, the Conformity Guidelines state that project -by project review is not required for regionally significant general development projects once the local jurisdic- tion has developed an air quality element (or equivalent) revision to a general plan that is consistent with the AQMP. The Conformity Guidelines also state that projects limited to localized impacts are not individually reviewed for conVormity with the AQMP. Instead, the conVormity process 15 calls for an -annual review of the cumulative impacts of such projects on the basin's air to quality through the RFP reporting function. 3. Responsibility for Wastewater Conformity Findings The California Regional Water Quality Control Boards are responsible for including a finding of conformity when issuing National Pollutant Discharge Elimination System (NPDES) permits pursuant to Section 176(c) of the federal Clean Air Act. However, the Boards do not have the resources to accomplish that task. Task Force Recommendation: x In the absence of an updated Areawide Water Quality Management (208) Plan, a Memorandum of Understanding between SCAG and the afj'ected Regional Boards should be approved for SCAG to execute the conformity analysis for consideration by the Regional Boards in the issuance of NPDES permits. 4. Conformity Review of Transportation Projects The "Conformity Guidelines Related to Transportation," describe the process for determining conformity of transportation projects in the South Coast Air Basin. S. Conformity Review of Locally Funded Transportation Projects Locally and privately -funded transportation projects which are not included in the RTIP, but are linked to a regionally significant development project, will be subject to conformity review under the general development conformity procedures which are built from the Intergovernmental Review Process. B. THRESHOLDS FOR REGIONALLY SIGNIFICANT PROJECTS The General Development Conformity Guidelines identify regionally significant projects that are subject to SIP conformity review. Included among them are projects that meet the minimum criteria for project review identified in the Inter -Governmental Review Process Handbook. For its review purposes, the SCAQMD has developed a protocol for comment on regionally significant projects. Concern has been raised that there was need for consistency and parity among the threshold levels for the various types of projects considered "regionally significant." Task Force Recommendation: In order to eliminate unnecessary expense and confusion for local governments in the regional review process: 1. SCAG and SCAQMD should coordinate the CEQA and AQMP conformity review processes for regionally significant projects reviewed under 'the 1989 AQMP and subsequent AQMP updates. M. 2. SCAG and SCAQMD should develop common thresholds for CEQA and AQMP confor- mity reviews under the 1991 AQMP. These thresholds should be based upon equivalent VMT impacts. C. REGULATION OF EMISSIONS FROM INDIRECT SOURCES Local governments, through the Conformity Working Group, have expressed concern that premature development of rules forindirect source measures that are the primary responsibility of local governments will (1) not allow the time prescribed in the plan for local governments actions, (2) potentially create confusion and, duplication of resources, and (3) remove the incentive for local, regional, and state governments to secure the resources and commitments necessary to conduct effective implementation. Task Force Recommendation: Local government actions and market incentive approaches should have adequate opportunity and funding to meet AQMP deadlines for implementation before the SCAQMD considers moving forward with development of indirect source rules. D. EXTENSION OF WORKING GROUP EFFORT Task Force Recommendation: 1 The Conformity Working Group effort should be extended in order to monitor and review the operation of the adopted Conformity Guidelines and to make recommendations for revisions to 1991 AQMP Conformity Procedures and Regional Mobility Plan, if necessary. E. RECOMMENDATIONS FOR CONSIDERATION IN DEVELOPMENT OF 1991 AQMP Task Force Recommendations: r 1. In developing the 1991 RMPIAQMP, consideration should be given to amending'the RMP/AQMP to include greater specificity regarding sizing and type of transportation projects. • 2. A process for balancing and integrating air quality, growth, transportation, and wastewater system needs in making conformity determinations should be further defined in development of the 1991 AQMP. 3. Conformity review of projects should occur at the earliest possible point in time in the planning process. 4. Local governments should achieve conformance with the AQMP by adopting and implementing a comprehensive plan for AQMP implementation, so that all general development projects approved consistent with the plan are also corbrming to the AQMP. 17 CHAPTER 4. LOCAL GOVERNMENT AQMP IMPLEMENTATION t� .. ...........................♦:.....s.............:...??<.•::•A�:::�:ib'x?s.•.�:.t�..............?,�.......�..�.:...:.?:•.x:....\kw.w.�.i?r�a`aCOriA,FR.w�a. r�..��s:a•::•i�rx•Rv�.iii�::iiV Implementation of the local government measures in the AQNT is important for meeting the federal clean air standards by the year 2007 goal set forth in the AQNT. Since full implementation of all the Tie: I control strategies will still leave the Air Basin far from complying with the federal and state clean air standards, local government implementation of the measures within its responsibilities is viewed as essential to the full and effective implementation ofthe transportation, land use, and energy conservation control measures. Local government adoption of an air quality element would increase the perception that achieving air quality is a mandate as important as achieving mobility and balanced land use, and indicates to the public and other agencies that the local entity understands its responsibilities for air pollution control. Given the life-style implications of many of the AQMP measures, an element may also help to communicate with local citizens the changes in individual transportation behavior, energy consumption, and land use patterns necessary to achieve clean air. The Guidelines therefore stress the objective that local government must address air quality issues comprehensively, however, they provide the flexibility for these issues to be addressed in an air j u quality element or through other means. �n The SCAG Planning Director's Committee assisted staff in preparation of the "Guidelines for the Development of Local Air Quality Elements". The Guidelines were reviewed by the Task Force and the following recommendations incorporated: ` Task Force Recommendations: 19 To the maximum extent possible, provide attainable and quantified performance -based objectivesfor emissions categories. Local governments should be allowed flexibility to design programs to meet those objectives. 2. Air quality elements should be self -certified by local jurisdictions. 3. The deadline for local general plan revisions to incorporate air quality elements should be extended one year, from January 1,1991 to January 1,1992. Target dates for 1994 should be specifically set in order to clarify deadline dates for local governments. 4. Funding assistance should be provided to local governments for development of air quality elements. (This recommendation formed the basis for development of the local government funding proposal discussed in Chapter 6.) S. Local governments are encouraged to prepare air quality elementsiAQMP implementation plans in a subregional context. Coordination of local air quality elements/AQMP implementation plans within counties or subregions is desirable as it allows more flexibility in planning for future growth consistent with regional goals. In addition, itprovides local governments with shared -cost opportunities, • and facilitates coordination of transportation and growth management measure implementa- tion. 18 CHAPTER 5. LOCAL GOVERNMENT OUTREACH IMPLEMENTATION PROGRAM :"::...,�.r:•.";`.•`...>.;:;:^.R> ;:>.'::; :•Y:�:•arx.'3x' '""i"w`e7axao'�'ice.`a'.�c"Lrfit'"'.x`•u:C:tisk'+:.'a''oi±a%S::i�'.}•.c}r•.;R.`.w`i,^,`:;"�v:>.": �'�YS Local government participation is an essential component for successful implementation of the AQNT. A joint SCAG/SCAQMD Public Outreach and Educational Program was therefore developed in order to facilitate this process and to provide assistance to local governments in taking implementation actions. Task Force Recommendation: The Task Force adopted the following Joint SCAG/SCAQMD Local Government Outreach Implem- entation Program, emphasizing that the lead in this effort should take place through the SCAG Service Offices in Orange and Riverside/San Bernardino Counties. A. Statement of Overall Program Goals 1. Secure local government commitments to implement applicable AQMP measures through city council resolutions from the maximum number of cities in the basin. 2. Assist local governments in the identification of appropriate implementation actions that can be achieved with available resources, as well as actions that require additional resources. f 3. Provide technical assistance to local government to implement applicable first year AQMP measures. B. Program Design Organization ,L• l a. Local governments willbe grouped forpurposes of communicating information and providing technical workshops. 9)1 b. These local government groups will be consistent with existing subregional organi- zations and with ongoing SCAG transportation area studies whenever possible. SCAG will facilitate the grouping of cities (consistent with policies set forth in Chapter 1, Subregionat Entities), that will include all cities in the basin, and provide the groupings to the SCAQMD for concurrence. c. Each gaup of cities/counties may have: 1) A Coordinating Comndttee - composed of elected officials. The purpose of this Committee would be to provide policy direction for implementation actions and to provide the leadership for securing individual city counci]/board commitments to the AQW local government measures. M 2) A Technical Committee - composed of city/county staff members. The \ purpose of this committee would be to provide technical direction for actions and measures to be adopted by members of the cities/counties group. 2. Staffing a. Each agency will assign staff so that, at a minimum, one staff person from SLAG and one from the SCAQMD will attend eachofthe meetings of the local government groups. After an initial presentation to each coordinating committee (group of elected officials), these committees will meet as necessary to develop the policy leadership required for cities/counties to adopt applicable measures. b. Technical staff from each agency will be made available, to the extent practicable, to provide support to the technical committees. c. Any data generated by either agency for use by the local government groups will be shared with the other agency before it is shared with the groups. 3. Work Program a. SCAQMD will develop a general presentation about the AQMP, and SCAG will develop a presentation describing the general requirements for local government �^ under the Plan and the specific requirements for the first year actions. The presen- tation should also identify the proposed committee structure for providing informa- tion and technical assistance. b. SCAG with SCAQMD concurrence will identify, within each group of cities, one to two city managers and/or planning directors who will "host" a general orienta- tion for the group's city managers/planning directors. They would also be requested to assist in the development of the committee structure for the group. c. Jointly coordinate the logistics and conduct the city manager/ planning directors orientations. d. Jointly coordinate the logistics and conduct the technical committee presentations. e. Where SCAQMD and SCAG determine that a presentation before a city council is needed to secure a resolution of support, SCAQMD will be prepared to explain the need for a resolution from an air quality perspective along with the legal framework, and SCAG will then explain the need for action based on transportation and land use needs. f. Provide progress reports to SCAQMD/SCAG Interagency Committee, SCAQMD Interagency Implementation Committee, SCAG Executive Committee, SCAQMD Executive Board, SCAQMD Advisory Board, Regional Advisory Council, SCAG Policy Committees and other policy committees as needed, such as the Growth Management and Transportation Task Force. (0 0 10) g. SCAG will compile, on a semiannual basis, information concerning resolutions, ordinances and other relevant information adopted pursuant to the AQMP, and submit this to SCAQNID for joint submittal to ARB pursuant to ARB Resolution 89-66. SCAG will monitor regional progress by local governments to demonstrate local government performance in implementing the AQMP and submit it to SCAQMD for inclusion in the annual "Reasonable Further Progress Report" prepared for EPA. IL Each agency will independently derive the funds needed to support its respective portions of this program. 21 CHAPTER 6. FUNDING FOR PLAN IMPLEMENTATION Resources necessmy to effectively cant' out the regional planning program at both the local and regional level significantly exceed the level of funding currently available. As a result of this shortfall, regional planning priorities addressed in the plans will not be addressed completely. Local governments will be involved in multi -year efforts to implement regional policies in the AQMP, GMP, and RMP. These efforts will include preparation of air quality, circulation and land use elements of general plans, and development of various demand management, growth manage- ment and transportation system management programs. Regionally, funds will be necessary to carry out technical planning and assistance programs, public information, intergovernmental coordination and plan monitoring activities. Specific funding for these activities is not currently available. In addressing these issues, the Task Force made the following recommendations: A. THE TRAFFIC CONGESTION RELIEF AND SPENDING LIMITATION ACT 1 (PROPOSITION 111) AND THE PASSENGER RAIL AND CLEAN AIR BOND ACT (PROPOSITION 108) Propositions ill and 108, approved in June 1990, will provide about $3.5 billion in state transportation funding to the SCAG region over the next 10 years and will require the development of congestion management programs for every urbanized county. These funds • will begin to cover a portion of the revenue shortfall identified in the RMP for highway and I transit programs. Task Force Recommendation: Propositions 111 and 108 were endorsed in the January 1990 Task Force Interim Report as priorities for plan implementation. B. MARKET INCENTIVES The Task Force recommended that market incentives be used to facilitate implementation of transportation demand measures in the Regional Mobility Plan, and that funds generated through market incentives programs could be utilized to fund transit programs. A full discussion of market incentive measures is included in Chapter 7. C. STATE LEGISLATIVE PROPOSAL FOR IMPLEMENTATION FUNDING The Task Force developed a set of guiding principles which were incorporated into a legislative proposal for funding local government implementation of the AQMP. The overriding principle was the concept that fees be collected from the sources of emissions and that they be returned to fund reduction programs specific to those sources. This principle was intended to provide source equity. 22 These principles were utilized in the development of a formula for disbursement of funds in the j South Coast Air Basin which was incorporated into AB 2766 (Sher). This bill authorizes a $4 vehicle registration fee to assist local government implementation of the California Clean Air Act and regional air quality management plans. The bill is. currently pending action in the Legislature. Task Force Recommendation: All activities that implement the recommendations of this TaskForce reportshould be eligible for funding under AB 2766. Local government participation in and implementation of subregional entities demonstration projects should receive priority for funds available in the, "discretionaryfunding" provisions of the bill. D. FUNDING FOR UPDATE OF ORIGIN AND DESTINATION SURVEY The regional transportationmodeling systemis aset ofmodels which translates socio-economic and transportation system data into information regarding travel demand or system usage. The regional model provides important information upon which the current transportation system is simulated and future transportation needs are forecast. A fundamental source of information utilized in modeling efforts is the Origin and Destination Survey. The survey provides information regarding trip generation, purpose, distribution and mode choice. An Origin and Destination Survey was first conducted in 1967 and most recently updated in 1976. As significant changes have occurred in the region since that time, and trip -making characteristics have most likely also changed, the need for an updated survey is evident. It is likely that database modifications that result from a new survey will lead to modifications in the 1994 AQMP update. Task Force Recommendation: SCAG should seekju' nding from both private and public sector sources to conducta new Origin and Destination Survey after the 1990 Census, to update the travel behavior assumptions upon which job/housing emission reductions and transportation system needs are modeled. When undertaken, the database and subsequent modeling effort should be open for public review at hearings before the Executive Conunittee. 23 CHAPTER 7. MARKET -BASED STRATEGIES FOR ACHIEVING AIR QUALITY AND MOBILITY GOALS IN SOUTHERN CALIFORNIA ................,.,.............,.,.,..,....... zza:r,zz,...H.,...,.xxzxwxt.•;,,.,<s:�xzzw,zz•:�.�:::z�:xs..,..w:a,�:w�xszv:.zrzzxa�axxc`,za�:zr•:zxvzzz,..,.•...,w•.ax The 1989 AirQualityManagementPlan calls forinvestigating the potential powerofthe marketplace to reduce air pollution in Southern California. The Growth Management and Transportation Task Force therefore established a Market Incentives Subcommittee to explore practical application of market incentives for implementation of land use, transportation, and energy conservation measures of the AQMP. The use of market incentives in support of the implementation of the Air Quality Management Plan has received broad -based support from government, industry, and the environmental community. Acceptance of market incentives as an alternative approach and a complement to "command and control" strategies is considered a powerful policy tool which will greatly benefit both the public and private sectors in reaching VMT reduction goals. As used here, "market incentives" are economic incentives and disincentives that are designed to reduce congestion and air pollution. They include measures such as tradeable emission permits, congestion pricing and emission charges. A concept paper, "Market -Based Strategies for Achieving Air Quality and Mobility Goals in . Southern California," preparedby the Subcommittee, is the second partof this chapter. The complete report, including an implementation strategy, is expected to be finalized in September 1990. The policy recommendations of the Task Force, set forth below, provide the framework for the concepts discussed in the paper. A. FEDERAL CLEAN AIR ACT AMENDMENTS Current federal regulations may impair the ability to employ economic incentives from being included in federally required air quality implementation plans. While the current federal clean air law itself does not preclude economic incentives --in fact, it expressly mentions road fees as a possible control strategy --the law is written in such a way that administrative discretion is granted to the Environmental Protection Agency (EPA) to determine whether such measures can be used. In the case of economic incentives, current EPA regulations must be amended to permit local regulators the discretion to use incentive -based measures. The present federal Clean Air Act amendment process presents an important opportunity for changing the current law on economic incentives. Accordingly, the first effort of the subcommittee was to draft language which, if included in the final act, would permit the State to propose economic incentive measures to the EPA as part of the State Implementation Plan (SIP). i7] Task Force Recommendation: The Federal C1eanAirActshould be amended to allow market incentive options. The proposed amendment language is as follows: "an implementation plan for an extreme area revised in compliance with this section may include measures providing economic incentives and disincentives, such as differential emission fees, marketable permits, road use and congestion fees, and emissions charges, in combination with or as a supplement to regula- tory requirements." (This language has since been incorporated into the Senate bill and similar language has been adopted into the House version of the Amendments that are now before Congress.) B. PREVENTION OF UNINTENDED ADVERSE IMPACTS The Task Force stressed the importance of developing market -based strategies that would not, in their implementation, result in hardship to lower -income persons or cause adverse environ- mental impacts. Task Force Recommendations: 1. Incentives and disincentives should be designed so as to prevent hardship for lower - income people, while still providing them with incentives to act in ways that reduce �j congestion and lower emissions. 2. To forestall potential environmentally adverse unintended consequences of incentives, such as threats to public health and the quality of designated open space, incentives such as marketable permits should be implemented within the framework of local land use plans, zoning regulations, and other protections, and should not be allowed to override them. C. IMPLEMENTATION OF TRANSPORTATION DEMAND MANAGEMENT MEASURES Task Force Recommendation: Market incentives should be considered a primarymechanismfor implementing transportation demand management measures. Strategies to be investigated should include: 1. Reducing public and private parking subsidies and correcting counterproductive tax policies, as appropriate, consistent with the objectives of the plan. 2. Pricing and charging vehicle emissions based upon use (variable based on number of miles driven and level of emissions) and utilizing revenue derived to implement HOW transit programs. 411 3. Establishing an Emissions Reduction Trust to "bank" emission reduction fees collected from all emission sources other than those for direct pricing of automobile use. These funds would be used to hasten phaseout of emission sources through efforts such as incentive buyout programs and grants/loans for equipment and fleet modernization. D. GROWTH MANAGEMENT MEASURE IMPLEMENTATION Incorporating market incentives with other environmental policies put market forces to work in achieving VMT and congestion reduction goals by offering incentives to promote life-style changes which would otherwise be difficult to attain. Many of the measures in E. below would also promote job/housing balance implementation Task Farce Recommendation: Market incentives should be considered a primary implementing mechanism to achieve jobl housing balance. The Task Force has recommended that market incentives be tested that (1) encourage job creation in housing -rich subregions, and (2) encourage housing development in job -rich areas. ; Two demonstration projects are proposed to test implementation of joblhousing balance through market incentives. (They are described beginning on page 56.) 1 E. INCORPORATING MARKET INCENTIVES IN THE 1991 AQMP REVISION Task Force Recommendation: I,*,) Market incentives should be incorporated into all appropriate elements of the 1991 AQMP. Six market incentive demonstration projects have been proposed. They are more fully described in the attached paper. 1. Old automobile buyback — A short-term, temporary mobile source offset for emissions reductions mandated by other control measures which are currently prohibited either by technical d#fiiculties or for economic reasons. 2. Congestion charges — Charging peak period travel in single -occupant vehicles. The experimentwould be targeted at corridors with convenient transit systems orHOV lanes. 3. Parking Management — Changing parking prices in several Job centers to examine the effect that parking pricing has on mode -choice behavior. 4. Commercial Vehicles Management — Issuing medallions for Commercial Vehicle use that can be traded in an open market. Would use a graduated fee structure based upon the number of vehicles operating in peak periods, totalfleet leet emissions and VMT. 5. Telecommuting — A program that gives employers Regulation XV credits for providing employees or other firms with telecommuting equipment and services. f 26 to 6. Growth Management -- Two demonstrations (in job -rich and housing -rich areas) are proposed to test implementation of joblhousing balance through market incentives. F. PROMOTING MARKET INCENTIVE CONCEPTS A crucial element for implementing the market incentives concept is the education of policy -makers and the general public regarding its feasibility and applicability for addressing air quality needs in the region. Task Force members undertook a number of outreach tasks — e.g. communicated with key Congressional policy -makers, secured endorsement from major organizations, placed opinion editorials in regional newspapers — to promote inclusion of market incentives language in the Federal Clean Air Act amendments. In addition, a strategy to encourage public acceptance of the proposed market incentive demonstration projects is under development and is to be included in the final Subcommittee report 27 MARKET -BASED STRATEGIES FOR ACHIEVING AIR QUALITY AND MOBILITY GOALS IN SOUTHERN CALIFORNIA Report of the Market Incentives Subcommittee to the Growth Management and Transportation Task Force June 1990 0 28 MARKET INCENTIVES SUBCOMMITTEE MEMBERS Honorable Judy Wright, Chair Councilmember, City of Claremont Jane Block, Riverside County Growth Management Committee John Hunter, Government Affairs, Building Industry Association of Southern California (from January 1990) Margo Koss, Sierra Club, Angeles Chapter (from January 1990) Robert Mack, Public Affairs Coordinator Southern California Gas Company Tom Nielsen, Vice Chairman, The Irvine Company , Vice President, Southern California - James T. Pollard, Past Subcommittee Chair, Senior. Gas Company (through January 1990) Ray Remy, Executive Director, Greater Los Angeles AreaChamber o Southern California erce Ken Willis, Executive Vice President Building Industry .f (through January 1990) The Subcommittee wishes to acknowledge the following individuals for their assistance and invaluable contributions to this report: i Dr. Larry Arnn, President, The Claremont Institute Michael Cameron, Analyst, Environmental Defense Fund i Edric Guise, Building Industry Association of Southern California Norm King, City Manager, City of Palm Spring Dr. James Ortner, Principal Scientist, Automobile Club of Southern California • 29 TABLE OF CONTENTS PAGE I. Introduction.................................................................................................................. 32 H. Strategies to Enhance the Markets for Public Goods .................................................... 33 III. Market -Based Strategies --Some Examples.................................................................... 34 A. Congestion Pricing.................................................................................................. 34 B. Smog Fees on Vehicle Use......................................................................................37 C. Alternative and Mobile Source -Reduction Offsets .................................................. 38 D. Improving Centers' Access......................................................................................38 E. Removal of Parking Subsidies................................................................................ 39 F. Establish an Emissions -Reduction Trust.................................................................. 39 IV. Issues of Importance....................................................................................................40 • A. Equity....................................................................................................................40 B. Predictability..........................................................................................................41 C. Growth Management and Commuting....................................................................41 D. Increasing Public Awareness..................................................................................41 " E. The Need for Further Study....................................................................................42 V. Conclusion .................... .............................................................................................. 42-' VI. Footnotes....................................................................................................................44 VII. Suggested Further Readings........................................................................................44 VIII. Plan of Work..............................................................................................................46 30 0 APPENDIX A: PROPOSED DEMONSTRATIONS OF MARKET -BASED STRATEGIES Demonstration 1: Auto Buyback Proposal........................................................................48 Demonstration 2: Congestion Charges.............................................................................. 51 Demonstration 3: Parking Management............................................................................53 Demonstration4: Growth Management............................................................................56 It Demonstration 5: Commercial Vehicles Management........................................................60 Demonstration6: Telecommuting......................................................................................62 r 31 MARKET -BASED STRATEGIES FOR ACHIEVING AIR QUALITY AND MOBILITY GOALS IN SOUTHERN CALIFORNIA i. INTRODUCTION Southern California's air quality is the worst in the nation. The problem, stems from many sources, as numerous as the people who live here and the decisions and activities they undertake. If the region is to achieve the Federal and State standards of clean air that everyone desires, everyone must help. Achieving these standards solely by regulating the region's millions of individuals and firms, each making dozens of decisions daily that affect our air quality, is difficult to imagine. Yet this has been the approach used in the past to control emissions, for instance, dictating technology and methods of operation for industries. Still, emissions must be reduced even further. What entity can hope to spread its net so wide? What regulations can hope to achieve such miracles of detail and variety? There is one approach that has broad -ranging influence over many activities, is efficient, and preserves individual freedom of choice: the market. Market based strategies are used throughout the economy in ways that touch ourlives everyday. We save money by making telephone calls at night, by using our appliances at non -peak hours, by flying on airplanes on weekends. Through the use of congestion pricing, utility' companies, airline companies or any company that must use expensive capital facilities to provide goods and services can avoid having to build or expand its facilities through costly capital expenditures. This saves money for these firms and their customers. It also means that the public can obtain the things they need at lower cost. If pricing were associated with traffic congestion, people would have an incentive to reduce their congesting behavior. Likewise, ifcharges were associated with emissions, people would reduce their emitting behavior. Behaviors that produced less congestion and pollution would thus tend to increase. Market -based strategies have another advantage: they do not require centralized decision -making: As can be seen from events around the world, centralized rationing of scarce resources is rarely, efficient or effective. Market -based strategies complement the.existing regulatory approach, while offerin" g to do so in a more efficient, impartial, and flexible manner. In this paper, changes in the cost of transporting ourselves and using our scarce air resources --by increasing prices --are examined. The reasons behind this should be easily understood. Today, travel costs are primarily personal out-of-pocket expenses, exclusive of social costs, which contribute to our supply and demand inconsistencies. The desire for more transportation resources (e.g., roads and clean air) considerably outpaces our ability to provide (or finance) them. This results in congested roads and polluted air. Market -based strategies --smog fees, congestion pricing, transportation allowances --provide indi- viduals and firms with strong incentives to reduce air -polluting and traffic -congesting behavior. They preserve freedom of choice. They make polluters pay in proportion to the burden they place upon the system; and they do so by providing economic incentives to pollute less by changing 32 behaviors and furtheriirg technological change. Revenues from fees can be invested to increase mo- • bility and improve the attractiveness of ride -sharing. Today, multiple -occupant modes of vehicular travel (such as vanpools, carpools, buses and trains) are less advantageous forms of travel than d.-iving alone, which is subsidized and provides the greatest traveling discretion. Multi -modal transport should be encouraged by removing the subsidies on driving alone that make other modes of travel relatively less desirable. So we see that market -based strategies offer considerable promise. They are complementary to "command and control" regulations and can provide greater mobility, flexibility, and cost -efficiency. They may also be more equitable. 11iis paper explores the advantages and challenges of market -based solutions. It describes the basis and rationale for exploring market -based approaches and outlines potential strategies. Examples of potential strategies that could or might be pursued are provided; also described are impediments, practical means ofimplementing, and barriers associated with particularmarket strategies. Important issues (such as equity, predictability, public awareness, and further study) are then discussed, and are followed by conclusions. Appended to this paper are six promising market -based demonstrations, ready for immediate implementation, and considered to be best -suited for transitioning into market -based solutions. The r Market Incentives Subcommittee's near -term work program is also included, which addresses unresolved issues, questions, and investigations to be accomplished this Fall. II. STRATEGIES TO ENHANCE THE MARKETS FOR PUBLIC GOODS Market -based strategies hold immense promise for achieving the goals that are desired by all: a cleaner and safer world in which to live. Recently, a number of proposals have surfaced, linking market -based strategies and environmental policy. To establish their full potential, market -based strategies should be implemented as soon viable dem- onstrations can be identified. Market -based strategies offer the potential of reducing pollution and achieving mobility more quickly than regulations alone. Thus, the use of market -based strategies can expedite attainment of air quality goals. Several different approaches are discussed below. They are intended to illustrate and suggest; their order does not indicate preference. Market -based strategies seek to levy equal charges for equal amounts and types of polluting activi- ties. One approach could involve the establishment of a maximum level of regionally -allowed emissions. Once emissions rights are initially allocated to funs or to individuals (the sum of the rights equaling the regional maximum), no one would be allowed to pollute beyond the maximum level. The price of emissions rights would be set by the free market. The rights would first be issued by an authority, in the way that common stocks are issued by the company in whom the shares reflect ownership. Later, the emissions rights, like stocks, could be traded among parties on a secondary market. Their price would rise and fall to reflect the supply and demand for them. Any person or business owning emissions rights could sell them at any time on the secondary market. 0 33 :7 If it became necessary to reduce the overall level of emissions, emissions rights could be bought by the authority and/or recirculated. If it became possible or prudent to increase the level of emissions, new rights could be issued by the authority. Such a system could have several advantages. It would be simple to implement and administer and would 'involve a minimum of intervention by government, potentially minimizing the cost of regulation. It would give businesses an incentive to reduce their emissions because emissions would cost money, reducing them would be a cost savings. There would also be incentive to produce additional or new pollution -reducing equipment. Over time, such a system might well emerge, but it needs to be encouraged and fostered. It will not happen quickly, and will require altering federal, state, and local laws. Other options may be more readily available, and they can be gradually introduced into the existing system of environmental protection. In some cases, fees canoe applied where more indirect controls (or no controls) are now being used. Trading of emissions credits among polluters can be fostered, so that the greatest amount of pollution can be removed at the earliest possible time. Alternative pricing mechanisms should be considered to encourage companies and individuals to change their polluting behavior, and to promote conservation and innovation. At the same time, itmustbe recognized thatpeople and businesses have made investments, both small and large, in automobiles and productive machinery, in manufacturing plants and many other activities. Sufficient opportunities- must be provided for people to work and better themselves. III. MARKET -BASED STRATEGIES -- SOME EXAMPLES The Market Incentives Subcommittee ofthe Growth Management and Transportation TaskForce has reviewed a number of specific strategies that appear promising. The following examples illustrate how we might proceed. A. Congestion Pricing No urban problem is more recurring or aggravating than traffic jams. Time spent in congestion is wasted, lost forever. Pollutants emitted from cars in heavily -congested traffic contribute substan- tiallyto smogin Southem Califomia. Whileno one opposes an effective resolution of theseproblems., how to solve these problems has been a matter of constant debate. The Southern California Association of Governments recently sponsored a survey assessing the public's response to the transportation control measures contained in the regional plans.' Overall, . the results indicate that the public is sophisticated in recognizing the complexities of the traffic congestion and air quality problems and in understanding that complex solutions are required. While the survey results show that the public is generally less supportive of "disincentive" than "incentive" types of measures, measures that•require fees for specific actions are supported These results indicate that policy makers must carefully consider the public's perceptions when promoting strategies that are intended to reduce, traffic congestion and air pollution by pricing automobile use. Reseai� h'to develop appropriate administrative and pricing mechanisms is necessary in order to develop strategies that will achieve and maintain strong public support. 34 A. . Furthermore, when implementing these strategies, the linkage between any additional charges and desired transportation and air quality improvements needs to be communicated to the public through public participation and education programs that reinforce the nexus between the problem and solution. Given the financial and environmental constraints, traffic problems cannot be solved by building enough roads to cant' all who want to travel at peak hours. Congestion pricing offers promise by treating equally two primary means of lessening traffic congestion -- time shifting and ride sharing -- and can do so fairly and at a low cost. It is quite possible that traffic congestion can be eased to a vast extent in the very near future without large capital expenditures. It can be done in a way that will raise more money to improve and support transit, while it also improves our air quality. Part of the solution became apparent in the last decade. A substantial amount of traffic congestionis caused by drivers who might well take theirtrips at other times. Much peak -period driving involves people who are not commuting to or from work.2 This non -commute driving activity is increasing rapidly, more than any other type of trip -making. In the future, non -commute drivingis likely toinerease in proportion to total driving, given changing family structures, work locations, and socio-cultural trends. In order to relieve rush-hour congestion at peak traffic times, people must be encouraged to shift their non -work driving to uncongested times. This practice, if more widely followed, could result in dramatic improvements in peak -period traffic flow. This was illustrated by the Los Angeles Olympics experience in 1984.3 During that time, driving increased in the basin by I I %, but . congestion was practically nonexistent. Because of the special circumstances and incentives associated with the Olympics, businesses and people changed their habits. These types of changes need to be encouraged on a regular basis. One way is to charge for driving at congested times. Those who drive at those preferred hours will have to pay for the use of the limited resources. Some people may find peak -period congestion charges impossible to avoid and costly to afford. They should and will have a variety of options to avoid them. These could include transit subsidies, low-income tax deductions, exemptions, and need -to -transit vouchers. Above all, those who wish to avoid the charge could shift their times of travel to periods when congestion is not a problem, or travel with others while traveling in the peak periods. This illustrates another point: them is excess capacity in our roadways. That excess capacity is in the cars that could carry several people at a time, but usually carry only one. Each day Southern Californians drive over 240 million miles.s Nine out of ten cars on the road during peak periods have only the driver in them.' Small increases in average vehicle ridership during the peak periods would have a dramatic effect on the overall vehicle -miles traveled and, consequently, on congestion and air quality. Using our excess vehicle capacity more efficiently would cant' many benefits, if we could encourage commuters to do it. 35 • Much time and money are spent to encourage people to shame rides. This is usually not as convenient for them as going alone. But if the pricing system were altered so that people actually paid for the congestion their travel caused, things would change. Ride sharing would become more common, because people would be able to avoid the cost of congestion charges at peak hours. Transit systems would be better used, and with higher, more reliable operating revenues, could be improved andmade more efficient. Small buses and vans might operate more successfully. And more options for all commuters could become available. So congestion pricing could help. It could encourage time shifting, ride -sharing and mass transit. Driving alone at peak hours would carry a cost commensurate with its value, as do all activities which involve the use of scarce resources. Once that cost is borne by the single -occupant vehicle commut- ers, ways to avoid that cost will be encouraged. Recent technological innovations permit congestion pricing without causing additional road delays. Laser beams can read special decals (displayed on vehicles), that can be purchased at convenience stores, or similar retail outlets. Cards with magnetic strips (like credit or bank cards) also offer promise. Such technologies are currently being used on a limited basis on the Coronado Bridge in San Diego and at San Francisco International Airport. Another useful approach maybe to implement congestion -charging schemes that are more localized: In Singapore, one must have a decal to enter the central business distrlct.4 Hong Kong considered using small, inexpensive ` `transponders" (which emit signals identifying the vehicle and indicating that the fee has been paid) to drive vehicles on the roads there. Both of these cities art -very densely populated, but congestion charges were effectively implemented. Some of their ideas might be copied in the region's most crowded areas. Implementation of congestion charges raises the question, what will be done with the moneys collected? Indeed, the amounts could be very substantial, more than enough to improve our roads to reasonable standards. In order to understand how moneys raised could be spent, the purpose of congestion charges must be understood. The first purpose of these charges istopay forthe facility being used --a user fee. User fees, especially for roads, are an old, well -established device in American public finance, offering many advantages. They allow revenue for facilities to be collected from those who benefit from them, and assure -those who pay that their money is being well -spent. Congestion charges also serve to limit access to roadways at times when they are overused"that is, crowded and clogged. Since roadways are public goods, demand for them can exceed their supply, as we are already experiencing. This needs to be prevented. By charging fees and depositing moneys raised into enterprise or revolving funds, they are available to spend on improvements. Such moneys should be spent on increasing alternatives to free roads. First, funds should be used to improve facilities (e.g. by electrifying them, or installing automatic vehicle identification equipment). Next, high -occupancy vehicle (HOV) lanes should be augmented, followed by transit improvements. Any moneys still remaining should be spent to offset inequities created by the charges. 36 • The charging of fees could be circumvented by simply issuing certificates to commuters for a limited amount of peak -time driving. These certificates could then be traded Those who wanted or needed more peak -period driving certificates could buy them, not from the government, but from other people. Those needing or wanting to travel at peak times would be able to do so; those who did not would have more money to spend, rewarding them for not traveling in the peak periods. Other variants of this approach would be to charge single -occupant vehicles for use of the HOV lanes during peak periods, or to treat the entire corridor as an HOV corridor. Those choosing to pay for HOV lane use would benefit, while travelers in the non-HOV lanes would also benefit by the reduced numbers of vehicles traveling in the regular traffic lanes. Congestion pricing could be a very powerful policy tool that improves the convenience, health, and quality of our urban lives. While obstacles remain, a first step would be to move this approach into Tier I of the Air Quality Management Plan, for practical demonstration of the viability and utility of congestion pricing. B. Smog Fees on Vehicle Use Automobile emissions performance has vastly improved as a result of effective regulation. Auto makers are now required to produce cars that offer improved emissions performance. In the last five years, emissions have been cut down to a fraction of their former levels. But there is still a way to go. 17 Smog fees, based upon total emissions from vehicle use, offer considerable advantages over regulation. Current regulations require improvements in one part of the equation --tailpipe standards. But they do little or nothing to encourage us to moderate the amount of driving we do or to make our driving more efficient. " A program is needed that is bolder than the current smog -check program -- a system of direct smog charges. It could work more powerfully and efficiently to reduce emissions than the current smog -check program and will help us to understand what must be done to clean up the air. Already, newer cars are equipped with computers that record the performance characteristics of their engines. Such equipment can be readily adapted to record average and total emissions. Charges could then be set based upon the car's actual emissions. A simple, though less direct, way to implement this would be to vary the gasoline tax according to the amount of pollution the fuel causes, since some fuels are cleaner than others. In general, such fees will encourage more efficient use of vehicles and the transportation system while reducing air pollution. If each person pays a charge for the pollution their vehicle emits, it will encourage a reduction of emissions. It might mean using a vehicle that uses natural gas, or methanol, or. some other clean -burning fuel. Auto -makers might post on their cars the amount of average annual emissions, just as the gasoline mileage is now posted. Drivers might look for passengers who pay to ride with them, to share the cost of their vehicle's emissions charges. Others may wish to take public transit, thereby driving (and emitting) less. 0 37 Once again, by addressing the problem of emissions directly, by treating the cause and not the symptom, it is left to the individual to decide how to resolve the problem in his own best interest. Charges will result not only in more costs, but more choices and freedom to choose. C. Alternative and Mobile Source -Reduction Offsets Businesses face further emissions -reduction targets that are increasingly costly to attain, andin some cases unreachable at any cost consistent with economic survival. Compromises have been made to allow firms to delay these emissions reductions. Yet there is another way to structure the rules to allow firms to achieve the same or greater emissions reductions, in an innovative and flexible way. if a business cannot meet the emission -reduction targets for its operations, but can make the region's air cleaner by other means --such as by reducing emissions from its employees' cars --it should receive credits for that reduction. These credits might allow an otherwise threatened firm to stay in business, saving employees' jobs, and could result in cleaner airsooner. It may also stimulate invention and investment in emissions abatement equipment and technologies. An example of such a system is now operating in Salinas, California. In this program, old cars (which emit a large share of auto pollution) are purchased and destroyed.' Old vehicles are purchased at a price that enables their owners to buy better, cleaner vehicles. Such plans are strictly voluntary. - Auto buy-back programs have been considered in Southern California forsome time, but arejustnow beginning to get under way. Such programs could achieve dramatic results here in the next five to r� seven years, especially whenmany cars that are heavy polluters mightotherwise remain on the roads. in addition, these reductions will be achieved in a way that supports economic growth in jobs, income, and output. Companies that undertake such programs should be given credit for the emissions they reduce, and for expediting attainment of air quality goals. Source -reduction credits might also be used by companies to encourage increased average vehicle -ridership of their employees, or of employees of other companies. In general, credits should be available for anyone who achieves a measurable level of emissions reductions by any meansAn this way, flexibility is increased and ingenuity and problem -solving are encouraged. D. Improving Centers' Access Localized congestion would benefit greatly from improving access within or to -and -from centers. Centers are geographically confined areas that experience periodic, high -traffic demand. They include shopping malls, special -events venues (e.g. the Hollywood Bowl), special attractors (e.g. LAX or UCLA), and multiple -use areas (e.g. the Warner Center or Century City). Many examples exist ofinnovative approaches that improve access at activity centers. For example, shuttle buses ferry patrons from remote park -and -ride lots to the Hollywood Bowl. Portland, Oregon operates a shuttle in its downtown commercial area. State Street, a commercial area in the Loop of Chicago, has been transformed into a transit mall. These are just some of the approaches that have been tried and found successful. One plan currently being discussed to improve access in the central business district of Los Angeles is a medallion system, like that used to control taxicab operations. Another strategy that may work 38 better in local commercial areas is to meter parking, which permits access while accelerating patron turnover. E. Removal of Parking Subsidies Benefits are an important component of employee compensation packages, and company benefits often include free parking. This "free parking" is quite valuable. Parking, whether in lots or structures, is expensive to provide. And free parking, unlike cash payments of wages or salary, is not taxable compensation. These two forms of "pay" should be treated equally. One possible way to do so might be to lower taxes on cash payments for transit, while taxing free -parking benefits. Free parking is one way commuting is subsidized in the current tax system, and in Southern California, most commuting is done alone. If the removal of tax subsidies on free parking is not selected as a strategy, an approach that neutralizes the effect of the subsidy should be explored. People should be allowed to deduct from their taxes what they spend on commuting, whether on buses, trains, and taxis. The playing field should be leveled across travel modes. Those who pollute less and cause less congestion than those who drive alone should not be penalized. Experiments can be conducted without altering the tax laws. Firms could provide "transportation cafeteria benefits" instead of free parking. The amount of the benefit could equal the actual and social cost of the parking. The employee would not be worse off from the change, but would have increased ` their options, because such transportation benefits could be used to pay for commuting on buses, vanpools, carpools, and trains. Another option would be to reduce office parking requirements, while encouraging that the use of space no longer necessary for parking purposes be dedicated to child-care or other service activities. This could drastically cut employee trips. F. Establishing an Emissions -Reduction Trust An obstacle to alternative source -reduction schemes, such as old car buy -backs, is the reluctance of businesses to administer the programs. An alternative is an emissions -reduction trust, with a trustee(s) to execute such program(s). This offers a solution to the problem of administration, and might offer other advantages as well. The trust could be administered in a number of ways, for example, as a business overseen by local governments. It could be authorized to accept in -lieu source -reduction fees, structured in a manner similar to the Community Redevelopment Agency's "air rights". In -lieu fees could be set in a number of ways. For example, they could be set at the industry average cost/ton to reduce emissions, or at the difference between a firm's marginal cost/ton to reduce emissions and its industry average cost/ton to achieve the mandated reductions. The trustee could investigate other cost-effective emissions -reduction measures, strategies, or technologies. The trustee might sell source -reduction credits to the highest bidder. The trustee might also identify and fund more emissions -reductions than in narrowly defined program, such as old -car buy-back administered by a single company. 39 • Creating the trusthrustee could also eliminate equity problems arising under a program where individual companies are granted the right to pursue alternative source -reduction strategies. With the creation of atrustArustee and an open bidding process, companies facing high compliance costs could choose from a number of options — outbidding others, raising funds by selling their emissions -reduction credits, making payments to the trust, or pursuing new opportunities created by the existence of the trust. Rather than two options, to shut down or pay high emissions-reduatior. costs, business would have additional options and opportunities from which to choose. IV. ISSUES OF IMPORTANCE There has not, to date, been widespread implementation of market -based strategies to achieve our air quality and mobility goals. Where attempted, they have usually worked In order to prove their potential here, several issues need to be addressed. Equity must be ensured and additional research is necessary. Practical tests and demonstrations need to be conducted and laws need to be changed. Most importantly, broad public support must be gained. A. Equity for All If charges are imposed on activities that have high social costs, it is important to ensure that inequitable burdens are not placed on low-income persons. As the Bay Area Economic Forum said in its recent paper. One possible concern about some market -based measures is that they are too costly to the low-income driver. We too are concerned, and our plan has remedies for this. The ... crucial difference between our recommended measures and most regulatory schemes is that our measures generate revenues to remedy equity problems, while others do not. For example, the revenues raised by a smog fee can be used to off set the costs of low-income drivers through a tax credit or direct financial assistance to bring their vehicles up to code. A person with an income below some defined amount, who can prove the need to commute by car, could be given a voucher for $200, payable to the repair shop, which redeems its value from the government. Revenues raised though a bridge toll could be used to pay for expanded bus service overthe same bridge or for park -and -ride lots near the entrances. The gas tax can pay for lower transit fares. There are many possible variations on the theme. The point is that money paid by the polluter becomes available for both transportation options and to offset hardships on the low-income driver.' Market measures can be tailored to avoid or offset inequities in a way that regulations cannot be. Market approaches should address equity concerns for those of low-income, the disadvantaged and for small businesses. In the quest for cleaner air and less congestion, the best measures are those that not only do the job but maximize everyone's prosperity. M B. Predictability Air quality regulations based on "command and control" strategies may seem more predictable in their effects than do market -based measures. After all, regulation can specify to a fine level of detail exactly who must do what. Market strategies, on the other hand, allow individuals and funs the freedom to say in what manner and to what degree, based on their. own self-interest, they will contribute to an overall goal. But the predictability of regulations is overstated --people will always find ways to evade them; indeed, people have ignored laws since time began However, they rarely act against their own comfort and self-interest, and therein lies the strength of market strategies. The Federal and California Clean Air Acts require that modeling show that projects attain mandated air -quality standards. Market -based strategies may result in highly -diverse, difficult -to -quantify (at the outset) emissions reductions. Improved methods for monitoring and projecting expected reductions are needed to evaluate such approaches, and to make comparisons between the market measures and regulation in achieving reduction. C. Growth Management and Commuting Market strategies, if properly structured, can support the policy of managing growth They can increase the incentives for people to live nearer their work, or work nearer to where they live. This should result in a reduction of commute -related vehicle miles traveled, and associated emissions. in Market incentives can also help remove pressures on local governments by assisting them to manage the expected increase in jobs, houses, and people from now into the next century. D. Increasing Public Awareness A successful market -based system will require broad public support. It will be difficult to impress T upon the electorate the idea that imposing fees on actions that were formerly free will lead to overall 1 lower costs for society as a whole, and should be supported. Thus the kind of public education or advertising campaign associated with implementing market strategies will be crucial. A two -pronged strategy for increasing public awareness should be pursued, public education and an advertising campaign. Education can draw upon successful examples of market forces at work, and impart information on them. An advertising campaign would not necessarily attempt to educate people or deal with the issues; it would arouse emotions -- fear of gridlock, anger at the other fellow for polluting the air -- that could be directed at authoring necessary legislation and sustained until the laws were passed The difficulty in convincing elected officials and the public on the merit of market incentives is that a market -based approach calls for making explicit the costs which are presently real, but hidden. The average person will not easily accept the idea that increasing the price for some things will actually reduce the total cost, and result in cost savings for most people. Innovative educational and marketing techniques are called for, and public and private dollars must be put to work on this. Our society spends billions of dollars promoting products, and artificially differentiating among them. Overcoming initial barriers of public acceptance Is an absolute priority. Research into how these concepts can be made attractive to elected officials and the public is necessary if awareness and understanding of market -based strategies is to be promoted 41 • E. The Need for Further Study Research into the theory and practical applications of market -based air quality and mobility strategies is well under way but must continue to be advanced. The manner and form in which practical examples of market -based strategies are implemented should be strongly considered. Additional surveys should be conducted to reveal how the public will respond to various charging schemes, what level of charges produce the optimum behavioral changes, and which remedies are most desired. Academic research must be continued and expanded, especially in measuring air quality and mobility benefits, so that improvements and their costs can be estimated with greater precision. Also needed are thorough, well -documented studies and proposals on the implementation and evaluation of market -based measures and how they work in the particular context of Southern California. Demonstrations that prove the benefits and viability of these measures in achieving several regional goals at once --air quality, mobility, and better land use — are also needed. For example, peak -period pricing could be tested on the new Orange County toll road. One way to test this strategy would be to vary rates charged according to the congestion prevailing at particular times and places. Another would be to make the H OV lane a priced lane for single -occupant vehicles. To avoid charges in either case might require four passengers per vehicle — all vehicles carrying fewer passengers would be charged a price for entry. The revenues generated would make it possible to -improve the facility --for example, extending or widening it. It might also be used to implement strategies that remove some vehicles from the non-HOV lanes, improving their flow somewhat. These are examples ofthe many that are possible. Experience with peak -period pricing in other areas, such as time -of -day and seasonal pricing of electricity and natural gas, suggests that this kind of solution can help. Feasible demonstrations should be implemented and studies conducted to see how system usage, vehicle usage, and demand respond. Offset and credit approaches have been permitted underfederal and local regulations forseveral years. These approaches have not been fully explored or used. Flexible alternatives for achieving emissions -reductions should be key features of the Air Quality Management Plan. Research and viable proposals demonstrating flexible and alternative reduction strategies -are needed, showing how successful these measures can be, and how they can be improved and extended. Lastly, the impact of market -based strategies -- whom they affect, the opportunities and challenges they create -- must be investigated. Market strategies should be structured so that they increase op- portunities, reduce costs for non-polluting, non -congesting behavior, while they raise costs for those whose activities cause pollution and congestion. Strategies must be structured in ways that safeguard the interests of working and non -working people, and must implement measures that protect the commonwealth. V. CONCLUSION This paper has proposed to expand our system of regulation by adding a new, complementary track: market -based strategies. These offer greatpotential to help us collectively affect individual decisions and behaviors that impose costs from which we all suffer. They do this by unmasking what have heretofore been hidden'dosts, by making them overt and noticeable. 42 We know that most "things" in life are not free. Everyday, each of us make decisions that incur costs for ourselves and impose costs upon others. If we hope to attain the improved quality -of -life we all desire, for ourselves, our children, and their children, we must face up to the consequences of our choices. Southern California is now at a point where future air quality gains can only be had at greater expense and cost. Air quality and mobility are two of the major challenges faced by this region. Market -based strategies hold promise as new ways to address these problems. While they have been under discussion for many years, they have not had broad -based support in the public and private sectors until recently. Research has been undertaken, but their demonstration has not been forthcoming. Public education is just beginning. It is now time to vigorously pursue research, demonstration, public education and awareness of these strategies. The agencies concerned — SCAG, the SCAQMD, county and city governments, the CARE, the CEC, the EPA, and others -- are urged to supportthe undertaking ofextensive, vigorous programs that refine our understanding of market strategies and their expected impacts. Elected officials and business leaders are urged to seek out and encourage broad -based funding of such initiatives. Andthe citizenry of the region are urged to individually and communally support these efforts. We will enter the next century as the the largest metropolitan area in the country -- our challenge is to lead the way. Without any mandate or requirement do so, we, a broad -based coalition of interested and concerned parties, have explored in this paper the potential of the incentive -based concept. Our 7 next steps are outlined in our work plan, described further below. We believe that the public is ready • for solutions that will work. Market -based strategies certainly merit consideration. 43 �J VI. FOOTNOTES ' "Survey of Public Attitudes Towards Transportation Control Measures", (May 1990), Fair - bank, Bregman & Maullin, Los Angeles: Southern California Association of Governments. 4 Peter Gordon and Harry W. Richardson, "Counting Nonwork Trips: The Missing Link in Transportation, Land Use, and Urban Policy" (Sept. 1989), Urban Land Paper, pp. 6-12. 3 Olympic Impact Report: Effectiveness of Transportation Strategies Implemented during the 1984 Summer Games in Los Angeles, Executive Summary, (May 1985), Los Angeles: Southern California Association of Governments, p.9. 4 Wall Street Journal, Sept. 4,1987, editorial page; Kiran Bhatt, "Road Pricing Technologies: A Survey" (Washington, D.C.; Urban Institute, 1974), Urban Institute Paper, pp. 1211-12; Ward Elliott, "Road Use Charges and Jitneys: Some Thoughts on How to Introduce Them to Los Angeles" (Claremont: Rose Institute, 1976); Robert Poole, "Private Tollways: Resolving Gridlock in Southern California" (Santa Monica: �:cason Foundation,1988). Breaking Through," Air Quality Digest (Winter, 1989), El Monte: South Coast Air Quality .vianagement District, p. 2. Travel Forecast Atlas, 1984 Base Model, (August 1985), Los Angeles: Southern California ,ssociation of Governments, p.16. -: ogeneration Emissions to be Offset by Purchases of Older Cars in Salinas Area," 20 Environment Reporter 36 (Jan. 5, 1990), Bureau of National Affairs, Inc., pp.1512-13. s "Market -Based Solutions to the Transportation Crisis: An Executive Summary", (February 1990), San Francisco: Bay Area Economic Forum, p. 13. VII. SUGGESTED FURTHER READINGS 1. Kenneth A. Small, Clifford Winston, and Carol A. Evans, 1989, Road Work: A New Highway Pricing & Investment Policy, The Brookings Institution, Washington, D.C. 2. Bay Area Economic Forum, 1990, Market -based Solutions to The Transportation Crisis: the Theory and Application. 3. Elizabeth G. Hill, Air Quality Improvement: An Alternative Strategy, Series Report of the 1990-91 Budget: Perspectives and Issues, California State Legislative Analyst's Office. 44 4. Control Strategies,1982 State Implementation Plan Revision, by SCAQMD, December 1980. See Chapter III, Economic Incentives, which presents detailed analyses and evaluations of emission -offset banking, the bubble concept, and emission charges. 5. Long-range Strategies For Improving Air Quality, by SCAQMD and SCAG, September 1985. See Chapter IX: Emission Charges Strategy, and Chapter XVH: Economic Approaches Strategy. • 45 r i 0 VIII. PLAN OF WORK Due Date Task: 6/14/90 1. Submit Market Incentives Subcommittee Report To Task Force 7/l/90 7/l/90 7/31/90 7/31/90 10/1/90 10/1/90 10/1/90 • introduce concept • identify pilot projects/draft measures • initiate long-term study II. Long -Term Study A. Inventory Possible Mechanisms: conduct literature search to identify theoretical and applied mechanisms B. Establish Criteria for Mechanism Selection C. Narrow List to Measures for Further Consideration D. Outline Implementation Plan/Agency Responsibilities E. Investigate Likely Impact of Possible Measures on: • air quality • mobility • regional economy • equity (i.e., low-income and minorities) F. Investigate Implementation Obstacles • legal • administrative • political G. Identify Measures for Recommendation and Implementation Strategy • legislative • regulatory • education (government, business, citizens) 46 C7 APPENDIX A: PROPOSED DEMONSTRATIONS OF MARKET -BASED STRATEGIES u 0 • DEMONSTRATION 1 : AUTO BUYBACK PROPOSAL I. ASSESSING EMISSIONS REDUCTIONS Stage 1: All passenger cars older than model -year 1980 will be repurchased at $1,500/ car beginning in 1990. Stage 2: All passenger cars older than model -year 1990 will be repurchased at $2,500/ car beginning in 2000. Item 1990 2000 Number of cars in SCAB 1,875,145 2,084,050 Buyback subsidy/car $1,500 $2,500 TOTAL SUBSIDY MILLION$ 2,813 5,210 EMISSION REDUCTIONS: ROG tons/day in SCAB 121.64 35.98 CO tons/day in SCAB 960.80 573.80 NO. tons/day in SCAB 84.89 47.35 PROGRAM IMPLEMENTED IN ONE YEAR: Tons of ROG removed from SCAB 654,125 193,484 Cost/ton ROG removed $4,300 $26,927 PROGRAM IMPLEMENTED IN 10 YEARS: Tons of ROG removed from SCAB 446,206 131,984 Cost/ton ROG removed: $6,304 $39,475 Effect of ARCO EC-1 Gasoline ROG Reduction, tons/day 3.82 0 CO Reduction, tons/day 34.10 0 a NO. Reduction, tons/day 1.63 0 Equivalent NonCat cars: ROG 36,373 0 CO 42,625 0 NO. 23,680 0 0 48 H. MARKET INCENTIVES EXPERIMENT Buying back automobiles manufactured prior to the requirement of a catalytic converter (1974) and putting them out of circulation is an effective short-term measure to reduce mobile source emissions. Use of market based incentives to achieve this reduction is preferable because it is more effective than regulatory means of achieving emission reductions from this source. A. Demonstration It is proposed that the buyback of old cars be used as a short -tens, temporary mobile source offset for emissions reductions that are mandated by other control measures, but are currently prohibited by technology difficulties or economic hardship. This demonstration should be undertaken to determine which of the following will occur, and to what degree this helps reduce emissions: 1) achieve greater emissions reductions, 2) identify additional control measures beyond command and control, 3) minimize overall control costs, 4) achieve efficiency, effectiveness, flexibility, and equity, and 5) stimulate additional research and development. 0 The experiment can be targeted to: 1) small firms that are not subject to Regulation XV, • 2) firms covered under Regulation XV, 3) industries that cannot meet the emissions reduction standards, 4) area sources, primarily produced by consumer products like deodorant, charcoal r lighter fluid, felt tip pens, aerosol sprays and house paint. An emissions -reduction trust should be established as part of this demonstration, to administer and manage the contributions, buy back old cars, and dispose of them. The trust may also be used to finance additional demonstrations. An example of the auto buy back proposal is currently being implemented by UNOCAL. Under their proposal, known as the SCRAP program, the company pays individual owners $700 per vehicle for the fast 7000 vehicles of model year 1970 or older registered in Los Angeles Basin. UNOCAL estimates that the program will reduce 3000 tons per year of pollutants at a cost of $5 million. B. Measuring Success Success will be measured in number of ways: 1) the number of old cars removed from the basin, 2) total emissions reduction achieved with and without this strategy, and 3) control costs with and without this strategy. • CE: C. Evaluating the Demonstration Evaluating the success of the auto buyback demonstration wiI be one measure of the success of the emissions -reduction trust. Actually, buying back old cars is just one of many options that the trust executor or managing board may use to reduce airpollution. The emissions -reduction trust should also finance air -pollution reduction research and development; other creative methods or technologies offering promise in reducing emissions; design, implementation, monitoring and evaluation of other market -incentives demonstrations, etc. D. Opportunities/Challenges and Barriers to Implementation 1. Opportunities/Challenges One advantage of this strategy is that it allows industries more time to develop new emissions -control technologies while at the same time achieving equivalent (or higher) emissions reductions. Another is that this program saves jobs and provides for continued economic growth in industries that might otherwise find it uneconomical to continue operations in this basin. A third advantage is that it would stimulate research and development on cost-effective control technologies. A disadvantage of this strategy is how to begin and maintain it, especially assuring that the trust's management is sound, able, and creative enough to further emissions reduction. • 2. Barriers n 1� A possible barrier to implementation is that the EPA requires for approval of emissions reduction credits that an entity prove: an emissions surplus (i.e., that emissions need to be removed), and that the program or action be quantifiable, permanent, and enforceable. 50 DEMONSTRATION 2: CONGESTION CHARGES I. ASSESSING EMISSIONS REDUCTIONS Potentially, there could be significant emissions reduction associated with a successful congestion -charging scheme. Congestion charges are currently being studied separately by SCAG and The Claremont Institute staffs. II. MARKET INCENTIVES EXPERIMENT A. Demonstration It is proposed that peak -period travel in single -occupant vehicles be charged a fee to help relieve congestion. Single -driver, peak -period users would pay in proportion to the marginal congestion " cost" they impose by using the limited capacity ofthe transportation system at those times. In return, these users could enjoy travel -time reductions as congestion is reduced, since not all single -occupant vehicle users desiring to use the system in peak periods will be willing to pay the charges required for its use. The congestion charges collected would be used to compensate those unwilling to pay for use of the highway system at peak times, and to fund transportation improvements and n services in the corridors in which the fees were collected The people who find it is too expensive to use the roadways in peak -periods may choose to carpool, change their travel • times, or take transit systems to avoid the charges. The experiment should be targeted at corridors with convenient transit systems or HOV lanes. Congestion charges could be tried on the new Orange County toll road as it is built --collecting charges of various rates according to congestion conditions prevailing at different times of day, in different roadway directions, and at heavily -congested locations. In addition, local governments could also adopt ordinances to experiment with congestion charges on local surface streets and arterials. B. Measuring Success The success of this experiment could be measured by: 1) increases in average vehicle ridership in the targeted corridors, 2) increases in mode -split in the targeted corridors, 3) decreases or plateauing in total VMT in the targeted corridors, 4) changes in the average travel speed during peak periods in the targeted corridors, S) changes in number of trips made during off-peak periods in the targeted corridors, and 6) changes in the number of vehicles using HOV lanes. n �I 51 0 C. Evaluating the Demonstration Determine the effectiveness of congestion charges by analyzing the indicators listed above. Identify issues arising from congestion charges, such as equity, collection and use of funds, identification of approaches that are most effective, efficient, and equitable (e.g., permits that could be traded versus straight fees). D. Opportunities/Challenges and Barriers to Implementation 1. Opportunities/Challenges The greatest advantage of congestion charges is that it can provide additional funds for transit investment and facility improvement. The disadvantages of this strategy are its political acceptability, potentially adverse equity impacts, and creating and maintaining a sound, reliable, and effective system of setting, collecting, and managing the charges. 2. Barriers There are several barriers to implementing congestion charges: 1) uncertainty about the elasticity of demand (i.e., it is not known at this time how much to charge for this demand to be effectively reduced, but not excessively so), -9, 2) whetherthere will be a shift to higher -occupancy vehicles at peaktimes, and whetherthere are sufficient numbers of viable alternatives (such as transit systems, HOV lanes) available for users to choose, 3) the legality of charging tolls on federally -funded roads, and 4) the best way to collect congestion fees. is 52 DEMONSTRATION 3: PARKING MANAGEMENT I. ASSESSING EMISSIONS REDUCTIONS It is estimated that if allTier 1 demand -management measures are successfully implemented by 1994 there will be a reduction of 0.62 toniday in ROG. It is also expected that there will a proportional reduction in NO. and CO from affected mobile sources. The emissions reductions associated with each of the five demand -management measures were not provided for specific measures, so no measure of the effectiveness of parking management is available. H. MARKET INCENTIVES EXPERIMENT A. Demonstration It is proposed that a parking management demonstration be initiated to change the price of ' parking in several job centers or large firms to examine the effect that parking pricing has on mode -choice behavior. Some employers have already embraced this trip -reduction strategy, notably Los Angeles County, the cities of Los Angeles and Pasadena, Twentieth Century Insurance, and indirectly, SLAG. The experiment would be undertaken to determine the impact of increasing the price of parking on individual trip behavior, i.e., the change in single -occupant vehicles versus multiple -occupant vehicles or non -vehicular transport (i.e., transit, carpooling, van- • pooling, walking, and cycling). The demonstration should encompass both private and public employers, in any reasonably sized firm or location, but only involve employers not primarily engaged in outside sales or field services. r One method the demonstration could employ to raise the price of parking is to "cash out" free employee parking with a "transportation benefit" that the employee could use for parking, transit, vanpooling, or could simply pocket. The Bay Area Economic Forum has recently recommended that a $75 per month "transportation allowance" be offered to employees, with formerly free on -site parking charged a fee equal to the "allowance", leaving the employee free to choose how to spend the benefit. The experiment is suitable to all areas, but current literature suggests that a mix of alternatives (some transit, some carpool) may give a wider range of results. We may choose to monitor and assess the effectiveness of this experiment on employers who are pricing or have already priced parking to their employees. The experiment would consist of assessing current mode split and alternate commute incentives offered. A transportation allowance would then be introduced which would equal the value of parking. Then a parking charge equal to the "allowance" would be imposed The employee would then have the choice of paying for parking, or of finding an alternative means of coming to work without the need for parking, and keep the "allowance". 0 53 B. Measuring Success The success of the experiment would be relatively easy to assess in terms of trip-mlated emission reductions, by examining: 1) changes in average vehicle ridership or percentage of single -occupant vehicles of total vehicles, 2) changes in mode split, 3) changes in the total number of cold and hot starts, 4) changes in the total VMT, and 5) changes in the number of secondary trips. C. Evaluating the Demonstration Determine the effectiveness of the demonstration by analyzing the indicators listed above. Identify issues arising from charging employees for formerly free parking, such as neighborhood intrusion, or use of nearby off -site parking. Analyses should also consider the need for enhanced parking enforcement, residential parking permits, or validation of parking for legitimate users. D. Opportunities/Challenges and Barriers to Implementation 1. Opportunities/Challenges The clearest advantage to charging employees for free on -site parking is that it promises to • induce significant shifts in n.: ,,je-split to carpools and transit, based upon previous studies. A disadvantage is that it will oe unpopular with employees who have previously regarded free parking as a "right". A disadvantage of the "transportation allowance" is that the federal tax code currently Cconsiders employee transportation allowances of more than $15 per month as taxable ' income. Local parking codes also have the effect of oversupplying parking, which is then passed -through in most commercial and office leases, whether the tenant needs parking or not. This is why most employers provide free on -site parking to employees. Employee parking is also a tax-deductible business expense under federal and state tax codes. Current survey data suggest significant public resistance to such "parldng disincentives" asstand-alonemeasures. Transportationincentives'mitigationmustbeconsidered tomake employee parking charges more attractive. 2. Barriers One barrier to successful implementation is that the substitutes to driving alone to a work site are not perceived as equally advantageous. Previous studies indicate that the quality and quantity of transit service and TDM alternatives can have a substantial impacts on mode -split. • 54 Other barriers to successful implementation are the manner of levying and the amount of charges for formerly free, on -site parking. Pay -on -exit -per -use pricing appears to be the most effective method of diminishing trips, both primary and secondary. Monthly permit parking may be less successful in diverting trips, because once a permit is purchased, it is a sunk cost, and maximizing its use (i.e., parking) maximizes the permit's value to the user. Setting a parking price that is too low may fail to alter mode -split. The price set must be effective in creating real advantages to alternatives to drive -alone travel. • 55 • DEMONSTRATION 4: GROWTH MANAGEMENT I. ASSESSING EMISSIONS REDUCTIONS It is estimated that if all Tier 1 actions for Growth Management are successfully implemented by 1994 that 1.86 tons/day reduction in ROG will be achieved. Proportional reductions in NO,, and CO are also expected. These figures represent region -wide reductions, and would not be directly attributable to the proposed demonstration. II. MARKET INCENTIVES EXPERIMENT A. Demonstration Two demonstrations are proposed to evaluate the effects of growth management and job/ housing balance. The first, sponsored in cooperation with the San Bernardino Associated Governments (SANBAG), would be located in the area represented by the Baldy View Public Private Coalition. This is a job -poor, housing -rich area located in western San Bernardino and eastern Los Angeles counties. The second demonstration area would be located in the South Bay of Los Angeles County, a job -rich, housing -poor area. The demonstration described below is for the Baldy View Public Private Coalition. The recently adopted Regional Growth Management Plan proposes using subregional entities to implement job/housing balance locally. Achieving job/housing balance at a subregional level allows for differences between and among communities. The intent is to preserve local governments' flexibility in designing their futures while encouraging their plans to be drafted in consideration of their neighboring communities and the region as a whole. Baldy View Public Private Coalition is a public -private coalition of representatives from 11 cities in Los Angeles and San Bernardino Counties. The group was formed to deal with subregional issues, such as transportation, environmental issues, economic development, and jobs/housing balance. The Baldy View PublicPrivate Coalition areais currently job-poorand housing -rich. Many of its residents commute to jobs in Los Angeles and Orange Counties, contributing to congestion and poor air quality. The purpose of the demonstration is to attract jobs and reduce the number of commute trips (or VMT), thereby reducing emissions and improving air quality. The focus of this project should be to attract well -paying jobs so that area residents will no longer have an incentive to commute long distances to work. The demonstration project would focus on efforts underway to foster the creation and growth of small businesses in the Baldy View Public Private Coalition area. The first step would be a detailed market study, examining the area's economic base and its comparative industrial and occupational advantages. The emphasis will be on identifying growing industries and occupations that have the greatest potential to create new jobs (especially high -skill, high -wage jobs). The effort would complement current activities of local economic development organizations. 56 The next step would be a baseline study analyzing the travel behavior of resident workers in the targeted industries and occupations. It would examine their current commuting behavior and places of work, and analyze their attitudes toward changing jobs if appropriate opportunities were available closer to home. Next, a series of market -based incentives would be developed to foster the creation and expansion of targeted industries (small businesses) in the area. Targeted industries would be surveyed about the criteria most important to their location decisions, e.g., land costs, labor availability, local taxes, zoning requirements, etc. Baldy View Public Private Coalition would examine these criteria and decide what would be needed to attract small businesses, and allow them to grow and flourish. Government ao iom and market incentives that could be utlized in the job -poor, housing -rich area are: 1) Tax credits to encourage start-up small businesses to locate in a particular area; 2) Small-business loan programs (with reduced interest rates), to encourage businesses to locate in the Baldy View Public Private Coalition area; 3) Small-business incubators, to provide businesses with shared services at a single site, such as accounting, personnel, maintenance, legal etc. These facilities reduce costs for small businesses, provide valuable assistance, and diminish the risk of small-business failures. Cities could offer tax credits, reduced land costs, and loan programs to allow private development of these facilities. There is an Inland Business Network in the Baldy View , Public Private Coalition area, a private organization working to foster small business development. In addition, Chaffey College in Rancho Cucamonga has applied for " designation as a small business development center. r 4) Local governments could also adopt policies to reduce regulation of small businesses and reduce their paperwork. This would reduce business costs, increasing small businesses' chances of survival. Individual cities or groups of cities within the area could adopt such measures (as well as others) in order to foster small business growth. Possible incentives and government actions that could be utilized for stimulating housing production in the job -rich subregion (e.g. the South Bay demonstration project) include: 1) Streamline review and approval process for residential developments/ redevelopments; 2) Provide incentives (such as eliminating or reducing developer fees) to encourage developers to build housing in job -rich subregions. 3) Seek changes to state redevelopment laws to increase the minimum percentage of tax -increment revenues that must be spent on moderate housing within redevelopment projects. 57 4) Seek state legislation (or possibly inter -governmental agreements) to restricture the way • property and sales tax revenues are distributed to local governments so as to encourage job/housing balance. In job -rich subregions, incremental increases in tax revenues from job growth above and beyond regional targets could be required to be contributed to a regionwide pool. B. Measuring Success The success of the demonstration could be measured by: 1) Changes in resident workers home -to -work commute patterns, employer locations, distance traveled to work, etc. This would enable Baldy View Public Private Coalition to determine if their efforts are successful by determining the number and length of trips that are reduced. Examining wage levels before and afterthe project would also be useful. 2) The effect incentives had on small business location decisions. In addition, employment levels and revenues of impacted firms could be analyzed to determine the effects of the incentives. Firms that were contacted ortargeted but which declined to relocate could also be studied. Other proposed demonstrations (e.g., congestion pricing) may also have an impact upon job/housing balance in the area. Increasing the cost of travel could induce area residents to look for employment closer to home. C. Evaluating the Demonstration 19 The key means of evaluating the success of the demonstration are examining the changes in the home -to -work travel behavior of area residents to see if they were affected by an increase in local employment opportunities, and whether the incentive program was effective in attracting and retaining small businesses. D. Opportunities/Challenges and Barriers to Implementation 1. Opportunities/Challenges One advantage of approach taken in the SANBAG/Baldy View Public Private Coalition demonstration project is that it focuses on small businesses, which are the greatest source of the region's recent new job creation. Since a large percentage (approximately 70%) of firms in this area have fewer than 250 employees, it suits local conditions. In addition, infrastructure exists to support small businesses. Another advantage is that it attempts to target firms that need higher -skill, higher -wage employees. This is crucial to enticinglocal residents to work forlocal businesses and reduce sthe tendency for long commutes. A third advantage is that it provides a specific focus that could be implemented in a single city or group of cities,. 58 One disadvantage is thatitmay not be possible to collectthe needed information from small business about employment levels and revenues. It may also be difficult to get information about their labor forces. The South B ay demonstration project provides the opportunity to explore the feasibility of utilizing mechanisms such as intergovernmental transfers of resources to achieve housing goals within a job -rich subregion. 2. Barriers A possible barrier to implementation is the lack of staff resources and budget available to the affected cities to properly evaluate the project. Another possible barrier is difficulty in getting the full cooperation from small businesses, which are usually suspicious of government intervention. Is • 59 DEMONSTRATIONS: COMMERCIAL VEHICLES MANAGEMENT I. ASSESSING EMISSIONS REDUCTIONS It is estimated that if all Tier 1 actions for commercial vehicles dispatching, rescheduling, and rerouting, and diverting port -related traffic to rail are successfully implemented by 1994, a 0.85 tons/day reduction in ROG will be achieved. Proportional reductions in NO, and CO are also expected. These figures represent region -wide reductions for the two measures, and would not be directly attributable to the proposed demonstrations. II. MARKET INCENTIVES EXPERIMENT A. Demonstration 1. Fees and Permits Issue medallions that allow commercial vehicles to operate during peak periods, using a graduated fee structure based upon the number of commercial vehicles operating in the peak periods, the total emissions of the fleet, and their VMT. It is proposed that the medallions be allowed to be freely traded in an open market (like cab tokens). Such a program could be applied to peak -period commercial vehicles traffic in employment centers, commercial vehicles operated by certain industries or by fleet sizes, etc. The structure and application of the demonstration should be explored further. Consider a program similar to that described above that applies fees or permits for peak -period shipping and receiving operations. Another proposed demonstration would require inspection for commercial vehicles registrations or renewals. The inspection fees should be used to establish centralized mechanical shops for inspection of commercial vehicles. Graduated fines (based upon emissions levels and VM7) would be levied for noncompliance. Establish criteria for revoking licenses from commercial vehicles operators involved in "X" number of accidents (to. be determined) caused by negligence or mechanical problems. Levy charges based upon the cost of resources needed to clear accidents and/or the amount of congestion the incident causes. 2. Emissions -Reduction Trust Using trust funds, develop and implement programs to train commercial vehicles dispatch- ers, study and evaluate commercial vehicles routes to maximize efficiency and minimize conflicts with other traffic, and develop, implement, and evaluate commercial vehicles -congestion pricing strategies. .5 B. Measuring Success • Effective emissions reductions for heavy-duty commercial vehicles could be measured by: 1) the reduction in the percentage of commercial vehicles operating and/or commercial vehicles VMT during peak hours, 2) the number of commercial vehicles accidents prevented or reduced, 3) vehicle -hours of delay saved from improved incident management for commercial vehicles accident clean-up or breakdowns, and 4) vehicle -hours of delay saved by re-routing commercial vehicles away from congested areas. C. Evaluating the Demonstration Success of the demonstration will be based on the reduction in heavy-duty commercial vehicles operations (either VMT or numbers) during peak periods. Need to establish a procedure for measuring reduced commercial vehicles emissions during peak periods. Another element of success will be the reduction in emissions from commercial vehicles accidents prevented or more quickly cleared (i.e., a commercial vehicles incident manage- ment program). This element could be measured by analyzing the changes in operating speeds on congested segments of routes with and without a commercial vehicles incident IT management program. D. Opportunities/Challenges and Barriers to Implementation 1. Opportunities/Challenges One advantage of this approach is that it focuses on heavy-duty commercial vehicles which are perceived to cause more congestion and impact air quality beyond their numbers in the overall traffic stream. Another advantage is that it provides a specific implementation focus that could be implemented in a single central -city area, in "commercial vehicles" corridors, or among industries with large commercial vehicles fleets. One disadvantage of the demonstrations is that they may not get the needed cooperation from industry, commercial vehicles, and local governments. 2. Barriers A possible barrier to implementation is the lack of staff resources and budget available to cities to implement the demonstrations. Another possible barrier may be getting the cooperation of independent commercial vehicles and industries with large commercial vehicles fleets, who are likely to be suspicious of the demonstrations. 61 0 DEMONSTRATION 6: TELECOMMUTING I. ASSESSING EMISSIONS REDUCTIONS It is estimated that if all tier 1 strategies designed to reduce work -related trips and shift them to off-peak periods, and increase telecommuting (i.e., working athome, eliminating commute trips, or working at satellite or neighborhood work centers, reducing commute trip lengths) are successfully implemented by 1994, a 1.48 tons/day reduction in ROO will be achieved. Proportional reductions in NO, and CO are also expected. These figures represent region -wide reductions for implementing the two strategies, and would not be directly attributable to the proposed demonstration. H. MARKET INCENTIVES EXPERIMENT, A. Demonstration 1. Regulation XV Credits Devise a program that gives employers Regulation XV credits for providing its employees or another firm's with telecommuting equipment and services, which are used at satellite/ neighborhood work centers or homes. 2. Emissions -Reduction Trust Use trust funds to develop satellite work centers and/or reduce the cost of equipment, services, or planning needed to successfully implement telecommuting programs. Work would include a program to test which incentives are most effective in gaining employer support for telecommuting, and/or eliminating commute trips or their lengths. B. Measuring Success Criteria forevaluating the effectiveness of telecommuting is the elimination or reduction of commute VMT. The reduction is based on total work -trip VMT from an assumed five-day work week C. Evaluating the Demonstration Success of the demonstrations will be based on the reduction in commute VMT. D. Opportunities/Challenges and Barriers to Implementation 1. Opportunities/Challenges One advantage of this approach is that it focuses on eliminating commute trips (which tend to be made in the already -congested peak periods) and/or reducing commute trip -lengths. Commute trips impact air quality beyond their percentage of average daily traffic. 62 Another advantage is that it provides a specific focus that could be implemented in a single • city or group of cities, or among a single (probably large) employer or cluster of employers. One disadvantage is that it may not be possible to get the needed cooperation from employers and commuters. 2. Barriers A possible barrier to implementation is the lack of staff resources and budget available to the cities and/or firms to properly plan and implement the demonstrations. Another possible barrier is difficulty in getting cooperation from commuters. E� 63 0 A MEMOIRS OF THE NATURAL HISTORY FOUNDATION OF ORANGE COUNTY; VOLUME 3 ENDANGEREa WILDLIFE AND HABITATS IN SOUTHERN CALIFORNIA Edited by Peter J. Bryant and Janet Remington Published by the Natural History Foundation of Orange County EXHIBIT 8 0 MEMOIRS OF THE THE NATURAL HISTORY FOUNDATION OF ORANGE COUNTY A Collection of Occasional Papers Published by the Natural History Foundation of Orange County VOLUME 3 ENDANGERED WILDLIFE AND HABITATS IN SOUTHERN CALIFORNIA Edited by Peter J. Bryant and Janet Remington July 19 1990 0 19 Preface Southern California, and Orange County espe- cially, is suffering massive losses of natural biological resources as development spreads through our hills, canyons and coastal areas. The few remaining fragments of wildlife habitat are becoming more and more precious to the wildlife as well as to the millions of residents that value association with the natural world. Not only is it vitally important to preserve as much as possible of our wildlife habitat, but in many cases the land has been so seriously degraded by human use that it also needs restoration to enhance its biological diversity and productivity, and its ability to sup- port rare and endangered species of wildlife. Some animal and plant species have been so depleted by human incursion and the effects of pollution that restoration projects are needed for those individual species. The papers in this volume of The Memoirs of the Natural History Foundation of Orange County deal with some of our local rare and endangered species and threatened wildlife habitats, as well as some of the efforts that are under way to restore and enhance them. Most of the papers in this volume originated as talks delivered at two symposia on the Natural History of Orange County, held at the University of California, Irvine on October 29,1988 (Habitat and Wildlife Restoration in Southem California) and May 21, 1989 (Rare and Endangered Species in Southern California). The symposia were cosponsored by the Natural History Foundation of Orange County, the University of California Natural Reserve System, the University of Califor- nia, Irvine, Student Activities Office and the Na- tional Audubon Society. We thank Peter Bowler and Bill Bretz for their help in organizing these two symposia. We have endeavored to be consistent in ter- minology, and for scientific plant names we have relied on A Checklist of the Vascular Plants of Orange County, California by Fred M. Roberts, Jr. (Museum of Systematic Biology, University of California, Irvine Special Publication No.6;1989). The present volume goes beyond the geographic limits of Orange County, but it is by no means comprehensive, and we hope to publish papers on other similar issues in future volumes. We are grateful to Karen Smith for providing the cover illustration of Canada Geese, and to Karen Christensen for redrawing some of the maps. No part of this volume may be copied or reproduced in any manner without the written permission of the Natural History Foundation of Orange County and the respective authors. vie Copyright C 1990 Natural History Foundation of Orange County P.O. Box 7038 Newport Beach, California 92660 THE NATURAL HISTORY FOUNDATION OF ORANGE COUNTY BACKGROUND AND PURPOSE The Natural History Foundation of Orange County was incorporated in 1974 as a nonprofit corporation dedicated to protect and preserve the natural resources of Orange County, and to establish a permanent natural history museum for scientific research and interpretive public display. FACILITIES AND STAFF The Foundation maintains the following facilities and staff: * A leased 32,000 square foot Natural His- tory Center and Museum in Aliso Viejo. The facility includes administrative of- fices, fossil preparation laboratory, gift shop and exhibit space. * A 4,000 square foot warehouse in Santa Ana, provided by the Orange County Board of Supervisors under the auspices of the Orange County Historical Com- mission. * An executive director, assistant director for public programs, exhibit and educa- tion specialists, and receptionists. PROGRAMS The Natural History Foundation's programs include * Recovery and care of fossil and artifact collections. * Preparation and curation of natural his- tory collections for use in research and exhibits. * Museum exhibits in Paleontology, Ar- chaeology, Earth, Space, and Life Scien- ces. * Display of educational scientific exhibits in the Natural History Center/Museum and in outreach projects. * Classroom docent presentations and field study tours of the Natural History Center/Museum. * Educational Programs on Saturdays and during school vacations. * Lecture series featuring major speakers. * Local Speakers Bureau and public field trips. SUPPORT The Foundation receives * Growing membership and museum ad- mission fees. * Donations and grants from corporations and foundations. * Volunteer effort from over 500 in- dividuals who participate in varied projects and programs. * In -kind support from local companies and businesses. * Collaborative support from many area educational institutions and organiza- tions. PUBLICATIONS The Foundation has an active program of pub- lications in the natural sciences, including * Memoirs of the Natural History Foun- dation of Orange County: Volume 1,1984 (available) Volume 2,1988 (available) Volume 3,1990 (herein) * Nature Notes (a series of one -page ar- ticles on a variety of informative topics). * NHFOC Newsletter (a bimonthly newsletter published courtesy of the Mission Viejo Company). s s C7 Table of Contents The Flora and Fauna of Upper Newport Bay,1940-55 byJohn W. Johnson ......................................... 1 The Plants of Upper Newport Bay,1982-89 byRobert DeRuff ..........................................10 Coastal Sage Scrub Restoration in Orange County: Two Approaches by Deborah Hillyard......................................... 20 Ecological Landscaping: Creating Bird Habitat in Suburban California Gardens and Public Landscapes byDavid Bontrager..........................................26 The Ecology and Conservation of Two Endangered Southern California Butterflies by Richard A. Arnold........................................36 Management of the Winter Foraging Habitat for Canada Geese at Quail Hill by Peter A. Bowler, Fred M. Roberts, Jr., and John Simon ...................48 The Status of Wintering Canada Geese at Quail Hill byRobin Butler............................................56 The Reintroduction of Bald Eagles on Santa Catalina Island, California by David K Garcelon and Gary W. Roemer ............................63 Peregrine Falcon Recovery in California byBrian Walton...........................................69 Stevens' Kangaroo Rat: Natural History, Distribution, and Current Status by Michael J. O'Farrell ........................................78 The Population Biology of the Bottlenose Dolphin along the Coast of Orange County, Southern California byDennis L. Kelly..........................................85 Reintroduction of Sea Otters to San Nicolas Island, California: Preliminary Results for the First Year by Galen B. Rathbun, Ronald J. Jameson, Glenn R. VanBlaricom, and Robert L. Brownell, Jr...............................:......99 • I� • THE FLORA AND FAUNA OF UPPER NEWPORT BAY, 1940-55 by John W. Johnson 1731 Medical Center Drive, #165 Anaheim, California 92801 INTRODUCTION In response to a request for a description of the Upper Newport Bay environment before residen- tial development of the mesas west and east of the bay, I will write a brief review of the bayside area as it was in the early 1940s to 1950s (See Figure 1). Although my family lived in Newport Beach in 1918-1919 and visited it repeatedly afterward, my first view of the upper bay was in the fall of 1928. In 1942 my continued residence began. THE BAYSIDE The southwest bayside: Dover Gully (Area 1) In 1942, the mesa or terrace along the west side of the upper bay was used for sweet potato fields and barley as far west as Irvine Avenue and New- port Harbor Union High School. In the gully east of the high school (now Dover Gully) grew black and arroyo willows (SaUrgooddingii, S. lasiolepis), cattails (Typhus spp.), sedges (Carex spp.), anise (Foeniculum vulgare), marsh fleabane (Pluchea odorata), coast goldenbush (Isocoma veneta), coyote brush (Baccharis pilularis ssp, consan- guinea) and mule fat (Baccharis salicifolia). In the spring months there were golden star lilies (Bloomeria crocea) and yellow violets (Viola pedunculata), and in protected holes, goldenback ferns (Pityrogramma triangularis). Tansy mustard (Descurainia pinnata) also was present, with orange -tip butterflies that used it as a food plant for their larvae. In the spring, also, were both poison sanicle (Sanicula arguta) and bipinnate sanicle (Sanicula bipinnatifida), red maids (Calandrinia.ciliata), large -flowered spurry (Sper- gularia macrotheca), bird's foot trefoil lotus (Lotus spp., including deerweed, L. scoparius), dwarf lupine (Lupinus bicolor ssp. microphyllus), com- mon lupine (L. succulentus), corn spurry (Sper- gula mvensis), and other species. McFadden Springs, west side (Area 2) The farming that had removed most native vegetation along the top of the west -side mesa extended as far north as the McFadden Springs and Creek north of 20th Street, beyond the end of Irvine Avenue. At the springs and along the creek grew an extensive cattail marsh (now Cherry Lake). In it, hundreds of red -winged blackbirds nested each year, as well as tule wrens (marsh wrens), soras, and possibly coots and light-footed clapper rails. Large black willows and arroyo willows grew about the springs and along the creek and canyon. The creek contained native fresh- water sponges, leeches, and crayfish, as well as bullfrogs. In the algae on the mudflat, where the waters of the spring and the sea mingled, existed a population of a small nudibranch mollusk (Alderia modesta). In the published literature its most southern known collection point is Elkhorn Slough, near Monterey, California. Where the mesa sloped down abruptly northward to the spring, in the spring months it was purple with thickly grown wild hyacinth (Dichelostemma pul- chellum). Along the rim of the west mesa, beyond the edge of plowing, California trapdoor spiders were abundant. This species is now on the verge of extinction in Southern California. Northeast of McFadden Springs, west side (Area 3) The cliffs along the west side of the upper bay are mostly too sheer to hold much vegetation until one passes the McFadden spring. Thence "o * e-------- son Diego Cr 4 Ar 9/ 6 2 7 V r VLake East 01 Bluff Terrace x CDMHS W O C onyoj) 12 Shellmaker Island � Dover Shores 6A - We) C1C,1x1;Cz--.SIT 14,1 Road FIGURE 1. Upper Newport Bay, showing the areas discussed in the text. 2 0 0 0 0 northward and eastward to the bay end, their slope is more gentle, and the soil is covered with a plant community like that on the south -facing slopes at other points on the bay. San Diego and Delhi Creeks, northwest corner (Area 4) The Delhi Creek, or ditch, that drains the lowlands north of Costa Mesa comes into the bay at the northwest corner. This contained the crayfish and Pacific mud turtles. The Pacific mud turtle is now nearly exinct in California. Dredging and deepening of the Delhi channel by the county flood control agency destroyed the crayfish and turtle populations totally. Also at the upper end of the bay, where the Delhi channel, other springs, and San Diego Creek enter, the tall creek nettles (Urtica dioica ssp. holosericea) grew. These were hosts to larvae of the red admiral butterfly and satyr anglewing but- terfly. North end of the bay (Area 5) Beyond the north end of the bay, against the bottom of the mesa separating the mouths of Bonita Canyon and San Diego Creek, was another grove of black willows and arroyo willows. These willow groves up and down the upper bay were important for the animal life that depended upon them. In them nested black -shouldered (white- tailed) kites, red-tailed hawks, song sparrows, yel- low warblers, blue grosbeaks, Brewer's blackbirds, Bullock's orioles, Cassin's kingbirds, mockingbirds, and shrikes. It was a joy always to see the blue grosbeaks return each spring to the willow groves. Among the butterflies, the tiger swallowtail, mourning cloak, and Lorquin's ad- miral used them as larval food plants, and among moths, the great polyphemus silk moth, the Cerisy eyed sphinx, the Cleopatra underwing, the Irene underwing, and the hornet moth. 3 Eastbluff do Back Bay Drives, northeast corner (Area 6) Continuing southwestwardly from the Delhi and San Diego Creeks past the former willow grove to Back Bay Drive, we arrive at the northeast comer of the bay. There, a slope rose to a 200-foot ter- race, now bulldozed and developed. At the same spot, an Irvine Ranch access road left the bay road, ascending to the top of a 100-foot terrace where Eastbluff Drive now exists. From an airstrip built and paved during World War II on the 100-foot "terrace, runoff of rainwater washed a gully down the gentle slope to the salt ponds. On the slope to either side grew a fine variety of spring wildflowers: yellow violets, goldfield daisies (Las- thenia californica), popcorn flowers (Plagio- bothrys spp. and Cryptantha spp.), pincushion daisies (Chaenactis glabduscula), dwarf lupine, small lotus species, ground pinks (Linanthus dian- thiflorus) and Chia (Salvia columbariae). Blufftop, set back from Back Bay and Eastbluff Drives: northeast corner (Area 7) On top of the 100-foot terrace where Eastbluff, the Bluffs and Corona del Mar High School stand, 150 years of cattle and sheep grazing had removed nearly entirely the native flora, which had been replaced by a red -stem and broad -leaf filaree (Erodium cicutarium, E. botrys) community together with Mediterranean brome grasses (Bromus spp.), com spurry, and short -podded mustard (Brassica geniculata). Dwarf lupine, and gilia (Gilia angelensis) still grew in places. Along the southern, western, and northern terrace edges was a thin population of California sagebrush (Ar- temisia califomica), wild buckwheat (Eriogonum fasciculatum), deerweed, and scattered elderber- ry trees (Sambucus inedcana). Fiddleneck (Am- sinckia intermedia), Cryptantha, sandmat (Cardionema ramosissimum), and canaigre dock (Ruiner hymenosepalus) grew in the spring, as did cream cup poppies (Platystemon califomicus) along the west edge. On a sand dune on the north side above the toyon trees (Heteromeles ar- budfolia) was a handsome cover of sunup eve- ning primroses (Camissonia bistoita). Northeast end of the bay (Area 8) North and east of the salt -pond dike, the cliff and terrace face north. On abrupt surfaces near the top, California polypody ferns (Polypodium califomicum) grew in clumps. Elderberry trees and arroyo willows and large toyon trees formed much cover. In the grass below the trees, where the sun did not reach for several winter months, and temperatures were cool and humidities high, grew miner's lettuce (Claytonia perfoliata), wind poppies (Stylomecon heterophylla� Parry's blue larkspur (Delphinium panyi) and Chinese houses (Collinsia heterophylla). On the toyon and elder- berry, vines of wild cucumber (Marah macrocar- pus) draped themselves each spring. On the upper cliff, above the trees and the polypody ferns, were a strip of native grassland, and as the cliff rounded onto the terrace, a border of California sagebrush. Beneath the sagebrush were abundant baby blue -eyes (Nemophila menziesii). Scattered poison oak (Toxicodendron diversilobum) grew in the protection of the toyon. In winter, solitaires, robins and cedar waxwings relied on the toyons for food. Across the road from the cliff a long grove of willows, black and arroyo, screened the salt ponds from view. The water of the ponds extended up to the willow fringe and road edge at that time. The grove has since become much wider. At the point where the road along the salt ponds turns south toward the salt pond dike is a plot of ground between the road and the cliff. This area was once mostly part of the bluff. Rock and soil were excavated from it for fill for the dike in the 1920s, creating a wide space between the road and face of the cut (see 1898-1900 geodetic survey maps). At the base of the cut grew a small grove of arroyo willows. On two occasions in the spring months I ob- served a large wood nymph butterfly in flight on the grasses of the north rim of the terrace. They probably were the Boopis (ox-eyed) wood nymph, a northern species never known to exist in Southern California. Its most southern known population is recorded at Elkhorn Slough near 4 Monterey. The Newport Bay population probab- ly survived as a relict from ice age times. The population and grassland was destroyed by the Eastbluff residential development. The cliffside north of Big Canyon southerly of dike: east bayside (Area 9) South of the salt -pond dike the cliff is very steep. But on ledges and in crevices were choice spring plants: goldenback ferns, California maidenhair ferns (Adiantum jordani), Lunularia liverworts. Near the top of the bluff, buckwheat and Califor- nia sagebrush extended to the terrace above. Lar- vae of the Electra buck moth (Hemileuca elects) could be found on the buckwheat bushes in February. On the terrace rim, beyond the grazing of the sheep, was a a strip of cream cup poppies. California trapdoor spiders also occupied the ter- race edge. The west -facing cliff of the terrace carried a flora of wild hyacinths, paintbrush (Castilleja sp.), and clumps of dudleya (Dudleya lanceolata) each spring. Also at several points along the road southward were caterpillar phacelia (Phacelia ramosissima). The cliff -base freshwater marshes: Backboy & Eastbluff Drives to Big Canyon (Area 10) At the base of the cliffs on the east side of the bay were freshwater seeps and spring -fed patches of freshwater marsh. In these, sora rails, bitterns, coots, red -winged blackbirds, marsh wrens and light-footed clapper rails were found. At many points, in addition to varied populations of sedges, reeds, and cattails, were clumps of arroyo and black willows. North side of Big Canyon (Area 11) On the north side of Big Canyon, the cliff faces south and experiences high insolation both in summer and winter. Moisture dries out quickly, temperatures are high, and there is much wind and air movement. On this slope grew coast prick- ly pear and coast cholla cacti (Opuntia spp.). In 0 0 10 0 these plants, cactus wrens nested. Buckwheat bushes, California sagebrush, desert thorn (L)cium califomicum), California four o'clock (Mirabilis califomica), coyote brush, saltbushes (Atnplex spp.), encelia daisy (Encelia califomica), several species of cudweed (Gnaphalium spp.), giant ryegrass (Elymus condensatus), elderberry trees, lemonadeberry (Rhus integrifolia) and tree tobacco (Nicodana glauca) formed the principal cover. Residences now occupy the blufftops, and water moves from lawns and landscaping to the edges of the terrace, then seeps down beneath the surface of the cliff faces. This. is deleterious to the root systems of the native vegetation, which are adapted to a long, seasonal drought. At the same time, pampas grass (Cortaderia selloana), Brazilian pepper (Schinus terebinthifolius), Chinese elms (Ulmus parvifolia), acacias (Acacia spp.), palms, succulents -- all cultivated plants that require more water -- are seeding in and displac- ing the native vegetation. Big Canyon, east bayside (Area 12) In Big Canyon, east of Back Bay Drive several hundred feet, in the lee of the high cliff on which Park Newport is built, was a broad grove of black willows under which were the sheds of the Irvine Ranch sheep ranch. On the steep cliffside on the south side of the canyon -- now with Park Newport atop it -- white - throated swifts regularly nested for many years. With the building of Park Newport, the colony vanished. Following up the south branches of Big Canyon to Jamboree Road, the branches become deep clefts. Along them grow bush monkey flower (Mimulus aurandacus). Effort should be made to save this plant of the canyon. The canyon flora is not well known. At San Joaquin Hills Road, east bayside (Area 13) Reaching the San Joaquin Hills Road intersec- tion with Back Bay Drive, one finds large patches • I 5 of encelia daisy. Below the road, on sand deposited years ago by dredging for shells, is a large patch of saltmarsh bird's beak (Cordylanthus maritimus) and a mat of typical saltmarsh plants: pickleweed (Salicomia spp.), batis (Bads maridma), jaumea daisy (Jaumea camosa), and others. North from San Joaquin Hills Road alkali heath (Frankenia salina) is abundant, and on the steep cliffs, clumps of dark green pickleweed (Anthrocnemum subtenninale) grew in crevices where seepage exists. South of San Joaquin Hills Road, east bayside (Area 14) Leaving Big Canyon going south, one observes a heavy black layer filled with shells at the top of the bluff ahead: an old Indian kitchen midden. On the steep north -facing cliffside below the midden, covered by California sagebrush with scattered bladderpod bushes (Isomeris arborea) and an elderberry tree, in the spring one finds a mat of fiesta flowers (Pholistoma auritum). Golden yar- row (Eriophyllum confertiflorum), and Eucrypta chrysanthemifolia are abundant here. Landside of the road opposite Shellmaker Island, east bayside (Area 15) Passing the bank of Pholistoma, one rounds the point opposite the old Shellmaker works and en- counters a spring and freshwater marsh to the land -side of the road. Here sora rails could be seen slipping among the cattails, toles (Scirpus spp.) and sedges. In the 1940s, in the canyon behind the spring eastward, San Diego jewe flowers (SWptanthus heterophyllus) bloomed u March. At Newport Dunes, southeast bayside (Area 16) Continuing south along Back Bay Drive, on the south -facing hillside north of the present New. porter Inn, a community of plants characteristic of south, west and east exposures consisted of coast prickly pear, buckwheat, California sagebrush, encelia daisies, desert thorn, and California four o'clock. In the spring, white morn- ing glory (Calystegia macrostegia ssp, cyclostegia) cl;mbed among the shrubs. Promontory Point, southeast bayside (Area 17) Continuing south along the east side of the bay to the Coast Highway, one reaches Promonotory Point. Along its north slope near the upper edge, encelia daisies and California sagebrush formed most of the cover. In April, golden star lilies bloomed among the shrubs and in the grass. North of the Coast Highway, south and (Area 18) North of the Coast Highway at the bay, the salt marsh had been covered by sand when the bay was deepened in 1930. On these sandy fields popula- tions of native sea fig iceplant (Carpobrotus ae- quilaterus), scattered deerweed, and abundant beach evening primrose (Camissonia cheiran- thifolia) had established themselves. Also, away from the highway, an extensive grove of arroyo willows had developed. The willows were host to the large, handsome polyphemus silk moth larvae and the Cerisyi eyed sphinx moth larvae. The Lorquin's admiral butterfly and tiger swallowtail butterfly also used these as larval food plants. These are a few of the plants and their distribu- tion along the bay as they existed before 1955. In the 1980s, Robert DeRuff (see following chapter) has photographed and compiled a much more complete list of the vegetation of the bay, includ- ing escaped and introduced species now to be found there. ADDITIONAL FAUNA OF THE AREA, 1942 Arthropods The Upper Newport Bay, with its plant com- munities, served as a habitat for a surprising variety of small animal life. Tarantula spiders, California trapdoor spiders, large millipedes, R large centipedes, and scorpions were present. A variety of insects could be found: walking sticks, mantises, many kinds of bugs and beetles, dragonflies and damsel flies of many species in the springs and creeks, and a fine display of butterflies and moths. In addition to those mentioned ear- lier, on the buckwheat bushes were larvae of the colorful day -flying Electra buckmoths, the large Medusa moths, the Behr's metalmark butterfly, the bramble hairstreak, western elfin hairstreak butterfly, and Bernardino blue. The pygmy blue was abundant on the saltbushes. In the spring the California ringlet was present on the grasses. A variety of skipper butterflies were on grasses, cud - weeds, and the saltmarsh plants. Common and western whites, cabbage butterflies, and common sulfur butterflies were on lotus and clovers; anise swallowtails were on celery and anise. Virginia ladies were on cudweeds. Buckeye butterflies were on plantains. Long-tailed skippers in rare years built up populations on deerweed. Purple coppers were on dock. The acmon blue was present on deerweed. Amphibians Amphibians included Pacific toads, tree frogs (Hyla regilla), bullfrogs, and yellow -legged frogs. Reptiles Reptiles included Western fence lizards, al- ligator lizards, Utas, horned toads (lizards), Western and red racers, gopher snakes, Southern and Northern color phases of Boyle's kingsnakes, red and Pacific rattlesnakes, lyre snakes, patch - nosed snakes, worm snakes, garter snakes, and Pacific mud turtles (now extinct in much of California, and perhaps entirely so in Orange and Los Angeles Counties). Mammals Among the mammals were ground squirrels, kangaroo rats, whitefooted mice, common and spotted skunks, weasels, badgers, raccoons, grey • is 0 11 TABLE 1. Some Flora of Upper Newport Bay and its Surroundings,1942-1955. In parentheses are the areas in which the plant was found. s, non-native. FAMILY NAME SPECIES NAME COMMON NAME Adiantaceae Adiantium jordani (9) California Maidenhair Fem Piomgramma triangularis (1,9) Goldenback Fem Aizoaceae Carpobrotus aequilaterus (18) Sea Fig, Iceplant Amaryllidaceae Bloomeria crocea (1,17) Golden Stars Dichelostemma pulchellum (2,9) Wild Hyacinth Anacardiaceae Rhus integrifolia (11) Lemonadeberry Toxicodendron diversilobum (8) Poison Oak Apiaceae Apium graveolens * Celery Foeniculum vulgare* (1) Sweet Fennel, Anise Sanicula arguta (1) Poison Sanicle S. bipinnatifida (1) Bipinnate Sanicle Asteraceae Artemisia califomica (7,8,9,11,14,16,17) California Sagebrush Baccharis salicifolia (B. glutinosa) (1) Mulefat Baccharis pilularis ssp. consanguinea (1,11) Coyote Brush Chaenactis glabriuscula (6) Pincushion Daisy Encelia califomica (11,13,16,17) Encelia Daisy Edophyllum conferrijlorum (14) Golden Yarrow Gnaphalium spp. (11) Cudweed Isocoma veneta (Haplopappus venetus) (1) Coast Goldenbush Jaumea eamosa (13) Jaumea Lasthenia califomica (L. chrysostoma) (6) Goldfields Pluchea odorata (P. purpurascens) (1) Marsh Fleabane Batidaceae Batis maritima (13) Batis, Saltwort Boraginaceae Amsinckia intermedia (7) Fiddleneck Cryptantha spp. (6,7) Popcorn flower Plagioboduys spp. (6) Popcorn flower Brassicaceae Brassica geniculata* (7) Short -podded Mustard Descurainia pinnata (1) Tansy Mustard Streptanthus heterophyllus (15) San Diego Fiesta Flower Cactaceae Opuntia spp. (11,16) Prickly Pear, Cholla Capparaceae Isomeris arborea (14) Bladderpod Caprifoliaceae Sambucus madcana (7,8,11,14) Elderberry Caryophyllaceae Cardionema rmnosissimum (7) Sandmat Linanthus dianthifolius (18) Ground Pink Spergula wvensis* (1,7) Corn Spurry Spergularia macrotheca (1) Large -flowered Spurry Chenopodiaceae Andmxnemum subterminale Pickleweed (Salicomia s.) (13) Ampler spp. (11) Saltbush Salicomia spp. (13) Pickleweed Convolvulaceae Calystegia macrostegia ssp. ryclostegia (16) White Morning Glory Crassulaceae Dudleya lanceolata (9) Dudleya Cucurbitaceae Marah macrocarpus (8) Wild Cucumber ei TABLE 1. (continued) Cyperaceae Fabaceae Frankeniaceae Geraniaceae Hydrophyllaceae Lamiaceae Nyctaginaceae Onagraceae Papaveraceae Poaceae Polemoniaceae Polygonaceae Polypodiaceae Portulacaceae Ranunculaceae Rosaceae Salicaceae Scrophulariaceae Solanaceae Typhaceae Urticaceae Violaceae Carer spp. (1,10,15) Scirpus spp. (15) Lotus scoparius (1,7.18) Lotus spp. (1,6,8) Lupinus bicolor ssp. microphyllus (1,6,7) Lupinus succulentus Frankenia Salina (F. grandifolia) Erodium botrys• (7) E. cicutahum • (7) Eucrypta chrysanthemifolia (14) Nemophila menziesii (8) Phacelia ramosissima (9) Pholistima auritum (14) Salvia columbariae (6) Mirabilis californica (11,16) Camissonia bistorta (7) C. cheiranthifolia (18) Eschscholzia californica (8) Platystemon callfornicus (7,9) Stylomecon heterophylla (8) Bromus ssp. (11) Elymus condensatus (11) Gilia angelensis (7) Linanthus dianthiflonts (6) Eriogonurnfasciculatum (7,9,11,16) Rumer hymenosepalus (7) Polypodium californicum (8) Calandrinia ciliata (1) Claytonia perfoliata (8) Delphinium panyi (8) Heteromeles arbutifolia (7,8) S. gooddingii (1,2,5,8,10,12) Salir lasiolepis (1,2,5,8,10,18) Castilleja spp. (9) Collinsia heterophylla (8) Cordylanthus maritimus (13) Mimulus aurantiacus (12) Lycium californicum (11,16) Nicotiana glauca' (11) Typhus spp. (1,2,10,15) Urtica dioica ssp. holosericea (U. holosericea) (4) Viola pedunculata (1,6) 8 Sedge Tule Deerweed Lotus, Trefoil Dwarf Lupine Common Lupine Alkali Heath Broad -leaf Filaree Red Filaree Eucrypta Baby Blue -eyes Caterpillar Phacelia Fiesta Flower Chia Calif. Four O'clock, Wishbone Bush Suncup Evening Primrose Beach Evening Primrose California Poppy Cream Cup Poppy Wind Poppy Bromegrass Giant Ryegrass Gilia Ground Pink California Buckwheat Canaigre Dock Polypody Fern Red Maids Miner's Lettuce Parry's Blue Larkspur Toyon Black Willow Arroyo willow Paintbrush Chinese Houses Saltmarsh Bird's Beak Bush Monkeyflower Desert Thom Tree Tobacco Cattail Creek Nettle Yellow Violet 0 • • • foxes, bobcats, (rarely) deer, coyotes, and saltmarsh shrews. Birds Birds included black -shouldered (white-tailed) kites, marsh hawks (Northern harriers), red-tailed hawks, ospreys as winter visitors, American kestrels (sparrow hawks), turkey vultures, blue grosbeaks, Belding's savannah sparrows, killdeer, meadowlarks, horned larks, song sparrows, lark sparrows, grasshopper sparrows, white -crowned sparrows, house finches (linnets), mockingbirds, California thrashers, shrikes, black phoebes, Cassia's kingbirds, mourning doves, roadrunners, golden -crowned sparrows, ravens, crows, Say's phoebes (in the winter), hermit thrushes (in winter), burrowing owls, barn owls, great homed owls, and screech owls.White-throated swifts nested in the high cliff at the south side of Big Canyon. A great wealth of wintering ducks, marsh birds and shorebirds were present, as well as brants, Canada geese, flocks of white pelicans in some years, and an anhinga, (snake bird) one winter. A TRIBUTE TO JAMES IRVINE These recollections are by no means complete for any of the plants or animals included, but indicate some of what was to be found at Upper Newport Bay. The policies of James Irvine had kept the lands of the ranch as a refuge for many species of plants and animals that had been destroyed in much of the rest of Orange County. James Irvine loved the wild things of his lands and protected them from destruction by poaching or gathering. It is because of his concern for them that so many survived to the present day. 9 THE PLANTS OF UPPER NEWPORT BAY, 1982 - 1989 by Robert De Ruff P.O. Box 1133 Newport Beach, California 92663 INTRODUCTION From December 1982 to October 1989, I photographed the following plants at Upper New- port Bay, in Orange County, California. The study covers the area from the Upper Newport Bay Bridge to Jamboree Road, and from the blufftops to and including the marsh and islands. Of the islands, however, only Shellmaker has been visited, and this was in early 1988. Canyons and draws were included for a distance from the bay, and this distance was arbitrary, depending on the terrain. Big Canyon, for in- stance, was studied for about half the distance to Jamboree Road, but across the bay, where Irvine Avenue dips down, the study went to the road. Developed areas such as Dover Shores were excluded, as were the upper portions of the bluffs if homes were at the blufftops. The bench between the developed areas of East Bluff and the top of the bluff were included, and in the Santa Ana Heights area near Jamboree Road, where there is no bluff, about one third of the distance to Bristol Street was included until this area was subdivided. Now the area studied is below the new horse -and - bike path. The 389 plants listed are those that have been identified with reasonable certaintly. On the list are 178 native plants. Three plants are of unknown origin. SPECIES UST (*, non-native) FAMILY NAME SPECIES NAME COMMON NAME Agavaceae Agave arnericana* Century Plant A. attenuata* Agave Yucca aloifolia* Spanish Bayonet Y. gloriosa* Spanish Dagger Aizoaceae Carpobrotus aequilatents Sea Fig C. edu&* Hottentot Fig Drosanthemum floribundum* Ice Plant Malephora crocea* Ice Plant Mesembryanthemum crystallinum* Common Ice Plant M. no&florum* Small -flowered Ice Plant Tetragonia tetragonioides* New Zealand Spinach 10 0 0 • Amaranthaceae AmaryIlidaceae Anacardiaceae Apiaceae Apocynaceae Araceae Araliaceae Arecaceae Asclepiadaceae Asteraceae Amaranthus albus* A. blitoides x albus* Bloomeria crocea var. crocea Dichelostemma pulchellum Leucojum aestivum Narcissus tazetta Rhus integrifolia Schinus molle* S. terebinthifolius* Toxicodendron diversilobum Apiastrum Ieptophyllum Apium graveolens* Bowlesia incana Conium maculatum Daucus carota * Foeniculum vulgare var. vulgare* Nerium oleander* Zantedeschia aethiopica* Hedera canariensis* Phoenix canariensis* Washingtonia robusta* Asclepias fascicularis Achillea millefolium var, millefolllium Amblyopappus pusillus Ambrosia anthicarpa A. chamissonis A. psilostachya var. califomica Anthemis cotula Artemisia califomica A. douglasiana A. dracunculus Aster subulatus var. ligulatus Baccharis emoryi B. pilularis ssp. consanguinea B. salicifolia (B. glutinosa) B. sarathroides Carduus pycnocephalus* Centaurea melitensis* C, muricata * Chrysanthemum coronarium* C. parthenium * Cirsium vulgare* Conyza bonariensis* C. canadensis C. coulteri Corethrogyne filaginifolia var. latifolia C. flaginifolia var. virgata Cotula australis* C. coronopffolia* Tumbling Pigweed Amaranthus hybrid Golden Stars Blue Dicks; Wild Hyacinth Snowflake Polyanthus Narcissus Lemonadeberry California Pepper Brazilian Pepper Poison Oak Mock Parsley Celery Bowlesia Poison Hemlock Wild Carrot; Queen Anne's Lace Sweet Fennel Oleander Calla Lily Algerian Ivy Date Palm Mexican Fan Palm Milkweed Yarrow Coast Weed Annual Burweed Beach Bur Western Ragweed Mayweed Coastal Sagebrush California Mugwort Dragon Sagewort Slender Aster Emory's Baccharis Coyote Brush Mulefat Broom Baccharis Italian Thistle Tocolate, Star Thistle Centaurea Garland Chrysanthemum Feverfew Bull Thistle Flax -leaved Fleabane Horseweed Coulter's Horseweed Common Corethrogyne Corethrogyne Australian Brass Buttons Common Brass Buttons Cynara cardunculus* Elipta prostrate* Encelia califomica E.farinosa* E. farinosa x califomica* Ericameria pachylepis (Haplopappus palmed ssp. pachylepis) Eriophyllum confertiflonim var. confertiflorum Euthamia occidentalis (Solidago o.) Filago califomica F. gallica* Gazania linearis* (G. longiscapa) G. spp. * Gnaphalium beneolens G.-bicolor G. califomicum G. chilense var. chilense G. luteo-album * G. microcephalum G. ramosissimum Grindelia robusta Hedypnois cretica* Helianthus annuus ssp. lenticularis Hemizonia fasciculata H. pungens Heterotheca grandif fora Hypochoeris glabra * Isocoma veneta var. veronioides (Haplopappus venetus ssp. v.) Jaumea camosa Lactuca serriola• Lasthenia glabrata ssp. coulteri Malacothrix saxatilis var. tenuifolia Matricaria matricarioides Osteospermum amplectans* O. fruticosum* Picris echioides* Pluchea odorata Pulicaria paludosa* Raftnesquia califomica Senecio vulgaris* Silibum marianum • Sonchus asper* S. oleraceus* Stephanomeria virgata ssp. virgata Taraxacum officinale* Verbesina encelioides var. encelioides* Xanthium strumarium var. canadense* 12 Wild Artichoke; Artichoke Thistle False Daisy California Encelia Brittlebush Encelia hybrid Ericameria Golden Yarrow Western Goldenrod California Filago Narrow -leaved Filago Treasure Flower Gazania Fragrant Everlasting Cudweed California Everlasting Cotton -batting Everlasting Weedy Cudweed White Everlasting Pink Everlasting Gum Plant Fragrant Rhagadiolus Western Sunflower Tarweed Spike Weed; Tarweed Telegraph Weed Smooth Cat's Ear Coast Goldenbush Jaumea Prickly Lettuce Yellow -rayed Lasthenia Quillweed Pineapple Weed Osteospermum African Daisy Bristly Ox Tongue Marsh Fleabane Spanish Sunflower California Chicory Common Groundsel Milk Thistle Prickly Sow Thistle Sow Thistle Twiggy Wreath Plant Common Dandelion Crownbeard Cockle Bur • 0 • 0 Batidaceae Bads maridma Saltwort Boraginaceae Amsinckia intemme&a Fiddleneck Cryptantha intemmedia White Forget -Me -Not Echium fastuosum * Pride of Madeira Heliotropium curassavicum var. oculatum Wild Heliotrope Plagiobothrys collinus var. califomicus Popcorn Flower (P. californicus var. californicus) Brassicaceae Brassicageniculata* Shortpod Mustard B. nigra * Black Mustard B. rapa ssp. sylvestris* Field Mustard B. toumefordi * Wild Turnip Cakile maritima* Sea Rocket Capsella bursa pastoris• Shepherd's parse Coronopus didymus* Wart Cress Descurainia pinnata ssp. menziesU* Tansy Mustard Diplotazis muralis Sand Rocket Lepidium lasiocarpum Sand Pepper Cress L. nitidum Shining Peppergrass Lobularia maritima* Sweet Alyssum Matthiola incana * Stock Nasturtium officinale* Watercress (Rorippa nasturtiaum aquaticum) Raphanus sativus* Wild Radish Sisymbrium irio* London Rocket S. orientale* Oriental Hedge Mustard Cactaceae Opunda ficus-in&ca* Indian Fig O. littoralis var. austrocalifornica Coast Prickly Pear 0.1. var. littoralis Prickly Pear O, oricola Oracle Cactus O. prolifera Coast Cholla O. prolifera x littoralis Opuntia hybrid Campanulaceae Lobelia erinus* Lobelia Capparaceae Isomeris arborea var. globosa Bladderpod Caprifoliaceae Sambucus mexicana Elderberry Caryophyllaceae Polycarpon tetraphyllum Four-leaved Polycarp Silene gallica * Windmill Pink Spergula arvensis* Corn Spurrey Spergularia bocconii* Boccone's Sand Spurrey S. marina Saltmarsh Sand Spurrey_ S. villosa* Sand Spurrey Chenopodiaceae Arthrocnemum subterminale Pickleweed (Salicomia subtemminalis) Atriplex canescens ssp. canescens Four -winged Saltbush A. lentiformis ssp. breweri Saltbush; Quail Brush A. patula ssp. hastata Saltbush; Spear Orache A. rosea* Saltbush; Redscale A. semibaccata* Australian Saltbush A. serenana var. davidsonii Bracted Saltbush A. watsoriff " Watson's Saltbush 13 A. spp.* (2) Saltbush Bassia hyssopifolia* Five -hooked Bassia Beta vulgaris* Beet Chenopodium album* Pigweed; Lamb's Quarters C. ambrosioides* Mexican Tea C. berlandied var. sinuatum Pitseed goosefoot C californicum California Goosefoot C macrospemtum var. farinosum Goosefoot C. murale * Nettle -leaved Goosefoot C. pumila * Tasmanian Goosefoot C. rubncm * Red goosefoot Salicomia bigelovii Pickleweed S. virginica Pickleweed Salsola australis* Russian Thistle Suaeda calceoliformis Suaeda (S. depressa var. erecta) S. esteroa Suaeda S. tarifolia (S. californica var. pubescens) Wooly Sea Blite Cistaceae Cistus incanus ssp. creticus* (C villosus) Purple Rockrose Convolvulaceae Calystegia macrostegia ssp. cyclostegia Morning Glory Convolvulus arvensis* Bindweed Cressa tnWIlensis var. vallicola Alkali Weed; Alkali Clover Cuscuta salina var. major Dodder Dichondra repens Dichondra Crassulaceae Aeonium arbomum * Aeonium Crassula argentea* Jade Plant C. connata var. erectoides Pygmy Stonecrop (C. erecta) C tetragona* Crassula Dudleya lanceolata Live -Forever Cucurbitaceae Citrulla lanatus var. lanatus Watermelon Cucurbita foetidissima Gourd; Calabazilla Marah macrocarpus Wild Cucumber; Manroot Cyperaceae Carr praegracilis Sedge Cypents altemifolius* African Umbrella Sedge C. eragrostis Tall Umbrella Sedge C. erythrorhizos Red -rooted Cyperus C. esculentus Nut Grass; Sedge C odoratus Fragrant Umbrella Sedge Eleocharis palustris (E. macrostachya) Spike Rush E. parvula var. parvula Little Spike Rush Scirpus acutus Hard -stem Bulrush S. americanus (S. olneyi) Olney's Bulrush S. califomicus California Bulrush S. cemuus var. californicus California Club Rush S. maritimus Alkali Bulrush S. robustus Coastal Bulrush Euphorbiaceae Chamaesyce maculata (Euphorbia supina) Spotted Spurge 14 0 0 0 0 L� C polycarpa var. po&arpa Sandmat; Golondrina (Euphorbia p.) C. serpens (Euphorbia s.) Euphorbia Croton califomicus var. califomicus California Croton C. c. var. tennis California Croton Eremocarpus setigerus Turkey Mullein; Dove Weed Euphorbia peplus * Petty Spurge Ricinus communis* Castor Bean Fabaceae Acacia cyanophylla* Acacia; Blue -leaved Wattle A. Cyclops* Acacia A. longifolia* Acacia; Golden Wattle A. retinodes* Acacia Erythrina indica* Coral Tree Lotus hamatus Lotus L. purshianus var. purshianus Lotus L. salsuginosus ssp. salsuginosus Coastal Lotus L. scoparius ssp. scoparius Deerweed L. strigosus var. strigosus Lotus; Strigose Hosackia Lupinus bicolor var. umbellatus Miniature Lupine L. succulentus Common Lupine L. truncatus Slender Lupine Medicago polymorpha var. polymorpha* Bur Clover M. saliva* Alfalfa Melilotus alba* White Sweet Clover M. indica* Yellow Sweet Clover Pisum sativum * Garden Pea Spartium junceum * Spanish Broom Difolium macraei * Clover Ycia faba* Horse Bean Frankeniaceae Frankenia salina (F. grandifolia) Frankenia; Alkali Heath Geraniaceae Erodium botrys* Broad -leaf Filaree; Storksbill E. cicutarium* Red -stem Filaree; Storksbill E. moschatum * White -stem Filaree; Storksbill Geranium dissectum * Cranesbill Pelargonium horiontm * Common Geranium A peltatum Ivy Geranium Hydrophyllaceae Eucrypta chrysanthemifolia Common Eucrypta var. chrysanthemifolia Nemophila menziesii ssp. menziesii Baby Blue Eyes Phacelia ramosissima ssp. austrolitoralis Phacelia Pholistoma auritum Blue Fiesta Flower Iridaceae Aristea capitata* Aristea Sisyrinchium bellum Blue-eyed Grass Juncaceae Juncus acutus Sharp -leaved Rush var. sphaerocarpus J. baldcus var. balticus Baltic Rush; Wire Rush J. bufonius,var. bufonius Toad Rush Juncaginaceae Triglochin concinna var. concinna Arrow Grass iv Lamiaceae Lemnaceae Liliaceae Lythraceae Malvaceae Melianthaceae Myoporaceae Myrtaceae Nolanaceae Nyctaginaceae Oleaceae Onagraceae Oxalidaceae Papaveraceae Pinaceae Pittosporaceae Plantaginaceae Platanaceae Plumbaginaceae Poaceae Lamium amplexicaule* Marrubium vulgare* Rosmarinus officinalis* Salvia columbariae var. columbariae Lemna miniscula (L. minima) Aloe saponaria* Asparagus officinalis* A. sprengeri * Lythrum californicum Abutilon theophrasti Lavatera cretica* Malacotharnnus fasciculatus ssp. laziflorus Malva parviflora* Malvella leprosa (Sida 1. var. hederacea) Melianthus major Myoporum laetum Callistemon viminalis* Nolana acuminata* Bougainvillea glabra Mirabilis califomica var. califomica Fraxinus sp.* Ligustrum lucidum Olea europaea * Camissonia bistona C. cheiranthifolia ssp. suffiuticosa C. lewisii C. micrantha Epilobium ciliatum ssp. ciliatum (E. adenocaulon var. parishii) Ludwigia peploides Oenothera elata ssp. hirsutissima Oxalis pes-caprae * Eschscholzia califomica var. peninsularis E. c. cv. rosea Pinus spp.* Pittospontm tobira* Plantago erecta ssp. erecta P. insularis* P. lanceolata * P. major* Platanus racemosa Limonium califomicum L. perezii * L. sinuatum Plumbago capensis* Agrostis semiverticillata* (Polypogon s.) Alopecurus pratensis* Arundo donax* Avena barbara* 16 Henbit; Dead Nettle Mint Horehound Rosemary Chia Least Duckweed Aloe Garden Asparagus Asparagus Fern California Loosestrife Velvet Leaf Tree Mallow Bush Mallow Cheeseweed Alkali Mallow Melianthus Myoporum Weeping Bottlebrush Nolana Bougainvillea Wishbone Bush; California Four O'Clock Ash Wax -leaf Privet Olive Southern Sun -Cup Beach Evening Primrose Small Primrose Small Primrose Willow Herb Yellow Water Weed Hooker's Evening Primrose Bermuda Buttercup California Poppy Pink California Poppy Pine Mock Orange Dwarf Plantain Wooly Plantain English Plantain Common Plantain Western Sycamore Sea Lavender; Marsh Rosemary Statice Statice Cape Plumbago Water Bentgrass Meadow Foxtail Giant Reed Slender Wild Oat • 11 • A. fatua * Bromus cadnatus var. carinatus B. diandrus* B. hordeaceus ssp. hordeaceus* (B. mollis) B.rubens* B. unioloides* Cordateda atacamensis* Cynodon dactylon * Digitaria sanguinalis* Diplachne uninervia (Leptochloa u.) Distichlis spicata ssp. spicata Echinochloa crusgalli var. crusgalli Elymus condensatus E. triticoides Festuca arundinaceae* F. myuros* Hordeum depressum H. murinum ssp. leporinum * (Hordeum 1) H. vulgare* Lamarclda aurea* Lolium muldflorum * s (L. perenne ssp. multiflorum) Melica imperfecta Monanthochloe littoralis Muhlenbergia microsperma Parapholis incurva* Paspalum dilatatum Pennisetum setaceum Phalaris minor* Polypogon intemtptus* P. monspeliensis* Schismus barbatus* Setaria lutescens* S. verticillata* Sorghum halepense* Span ina foliosa Stenotaphrum secundatum Stipa lepida S. pulchra Polemoniaceae Gilia angelensis G. australis G. capitata ssp. abrotanifolia G. clivorum Linanthus dianthiflorns ssp. dianthiflorus Polygonaceae Eriogonum elongatum E.fasciculatum ssp.fasciculatum E. f. ssp. foliosum E. pan ifolium 01 17 Wild Oat California Brome Ripgutgrass Soft Chess Red Brome Brome; Rescue Grass Pampas Grass Bermuda Grass Hairy Crabgrass Mexican Sprangletop Saltgrass Barnyard Grass Giant Ryegrass Beardless Wild Rye Meadow Fescue Rats Tail Fescue Meadow Barley; Low Barley Common Foxtai Common Barley Goldentop Italian Ryegrass Small -flowered Melic Grass Shoregrass Annual Muhlenbergia Sickle Grass Dallis Grass African Fountain Grass Canary Grass Beardgrass Rabbitfoot Grass Schismus Yellow Bristle Grass Bristly Foxtail Johnson Grass Corbgrass St. Augustine Grass Foothill Needlegrass Needle Grass Gilia Southern Gilia Blue -headed Gilia Gilia Ground Pink Long-stemmed Buckwheat California Buckwheat California Buckwheat Coast Buckwheat Persicaria lapathifolia Willow Smartweed (Polygonum lapanthifolium) P. punctata (Polyganum punctatum) Water Smartweed Polygonum arenastrum Polyganum P. aviculare Common Knotweed Rumex conglomeratus" Green Dock R. crispus" Curly Dock Polypodiaceae Polypodium californicum California Polypody Fern Pontederiaceae Eichhomia crassipes" Water Hyacinth Portulacaceae Calandrinia ciliata var. menziesii Red Maids Claytonia perfoliata var. perfoliata Miner's Lettuce Primulaceae Anagallis arvensis var. arvensis" Scarlet Pimpernel Rosaceae Heteromeles arbutifolia Toyon Prunus davidiana Flowering Peach Pyracantha koidzumii" Firethorn Rosa califomica California Wild Rose R. spp." Rose Rubiaceae Galium angustifolium ssp. angustifolium Narrow -leaved Bedstraw G. aparine" Bedstraw Salicaceae Populus fremondi var. frernontii Poplar Saliz discolor• Pussy Willow S. gooddingii var. gooddingii Black Willow S. g. var. variabilis Black Willow S. hindsiana var. leucodendroides Sandbar Willow S. lasiolepis var. lasiolepis ArroyoWillow Salviniaceae Azolla filiculoides Fern -like Azolla; Mosquito Fern Saururaceae Anemopsis califomica Yerba Mansa Scrophulariaceae Antirrhinum nuttallianum Wild Snapdragon Castilleja affinis var. qffinis Indian Paintbrush Cordylanthus maritimus var. maritimus Saltmarsh Birdsbeak Linaria canadensis var. terana Blue Toad Flax Orthocarpus purpurascens Red Owl's Clover var. purpurascens Veronica anagallis-aquatica Speedwell Solanaceae Datura % ghtii (D. meteloides) Jimsonweed Lycium califomicum Boxthorn Lycopersicon esculentum var. cerasiforme." Cherry Tomato Nicotiana bigelovii var. wallacei Indian Tobacco N. clevelandii Cleveland's Tobacco N. glauca" Tree Tobacco Solanum douglasii Douglas Nightshade Tamaricaceae Tamarix chinensis" Tamarisk Tropaeolaceae Tropaeolum majus" Nasturtium Typhaceae Typha angustifolia Narrow -leaved Cattail T. domingensis Cattail T. latifolia Broad-leaved Cattail Urticaceae Hesperocnide tenella Nettle 18 10 0 .7 0 Urtica dioica ssp. holosericea Creek Nettle (U. holosericea) U. urens• Dwarf Nettle Verbenaceac Lippia noiiiflora var. rosea• Lippia Zygophyllaceae Tribulus terrestris• Puncture Vine ACKNOWLEDGMENTS For their help with species identification I wish to thank Fred M. Roberts, Jr., museum scientist, UCI Museum of Systematic Biology and Gordon Marsh, curator, UCI Museum of Systematic Biology. And special thanks to my old mentor, John Johnson, for his encouragement, assistance, and great interest in my project. COASTAL SAGE SCRUB RESTORATION IN ORANGE COUNTY: TWO APPROACHES by Deborah Hillyard State Park Resource Ecologist California Department of Parks and Recreation Sacramento, California ABSTRACT Two Orange County projects were undertaken by the California Department of Parks and Recreation to restore degraded areas of coastal sage scrub, an increasingly impacted and diminishing plant community in Southern Califor- nia. One project was at Crystal Cove State Park and the other at San Clemente State Beach. An ecological succession model was used for both projects. Among the secondary and climax species planted were Lotus scoparius, Encelia califomica, Eriogonum fasciculatum and Isocoma veneta; dominant woody species included Rhus in- tegrifolia, Heteromeles arbutif blia and Isomeris ar- borea. Only the Crystal Cove project was monitored quantitatively. Seedbed condition and nurse crops were major factors in successful re-es- tablishment of the plant community. INTRODUCTION Between 1983 and 1987 the California Depart- ment of Parks and Recreation initiated two projects in Orange County to restore coastal sage scrub in areas damaged by human use. At Crystal Cove State Park approximately 50 acres had been disturbed, primarily for vehicle roads, parking lots and a large equestrian facility with an extensive trail network. At San Clemente State Beach, bicyclists and hikers had degraded 5 acres ad- jacent to the campground and day -use areas. Differences in the department's classifications of the two parks, San Clemente as a state beach, Crystal Cove as a state park, gave the project at San Clemente a great advantage in funding. 0 With a tenth the acreage, the San Clemente project had more than twice the funds. A dif- ference in classification also dictates different management of the parks. As a state park, Crystal Cove is managed primarily to perpetuate natural and cultural values, and there is an emphasis is on restoring natural processes and native ecosys- tems. The primary purpose of San Clemente, as a state beach, is to provide recreational oppor- tunities. Native vegetation, if any, is regarded as an esthetic backdrop for recreation. When this project was begun, Crystal Cove was a new, largely undeveloped park, used by the public mainly during daylight hours. On taking ownership, the department determined ap- propriate types, intensities, and locations of recreational use, and they did this in conjunction with restoration planning. In contrast, San Cle- mente had been operated for many years by the Department of Parks and Recreation. Facilities included day -use areas and a campground, and use patterns were firmly established and difficult to modify to suit the restoration effort. Use at San Clemente is generally heavy and year-round, while use at Crystal Cove is moderate and somewhat seasonal. METHODS The restoration strategy for both projects was based on an ecological succession model of revegetation. Using seeds and other plant materials from each of the seral stages of a natural plant community, this model mimics the natural process of vegetative recuperation after a distur- bance. The primary seral species are typically an- nual pioneer species. The secondary seral species include biennials, herbaceous perennials, and sub -shrubs that invade the site in natural succes- sion. And the climax (dominant) species, general- ly the goal of restoration, are typically woody. This approach has several advantages. The an- nual species need little assistance to establish and • (a 0 0 stablize the site, and they can soften a harsh en- vironment to help establish the woodier species. In addition, all species are already on the site, so if it is disturbed, e.g. by landslide or fire, natural succession can begin again. Much is known about the natural succession of coastal sage scrub after burning, and the available information allowed us to develop species lists for all seral stages. Primary sera] species were limited to those available commercially, and included Camissonia cheiranthefolia, beach evening prim- rose; Lasthenia glabrata, goldfields; Lupinus bicolor, lupine; and Plantago insularis, an annual plantain. Species that are both secondary and climax included Lotus scoparius, deerweed; En- celia califomica, California encelia; Artemisia califomica, California sage; Eriogonum fas- ciculatum, California buckwheat; and Isocoma veneta (Haplopappus venetus), coast goldenbush.. The dominant woodier species included Rhus in- tegrifolia, l emonadeberry; Heteromeles arbutifolia, toyon; and Isomeds arborea, bladderpod. These latter species4end to be dominant only in undis- turbed areas and only on the more mesic sites. After the first year, all seeds and other plant materials (except for the primary species) were collected from the project site or from ecological- ly similar, geographically close populations. Typi- cally the primary (pioneer) and secondary species were seeded into a prepared secdbed and the secondary and dominant woody species were planted out in liner -size containers. Young plants were used; they have better survival rates, probab- ly because root systems developed it response to site conditions are more likely to make plants self-sufficient than those developed in nursery containers. Quantitative plot monitoring, conducted only at Crystal Cove, was done after the first and third growing seasons. After the first growing season, ten .625 m2 plots were randomly chosen in each treament area, and the percentage of cover for each species was recorded. After the third grow- ing season, ten 10-m transects were randomly chosen in each treatment area, and percentage cover, as determined by the 'line -intercept 21 method, was recorded along 1 in segments per- pendicular to the transect. The results of the monitoring are presented in Table 1 for Crystal Cove areas that were hydroseeded, and in Table 2 for Crystal Cove areas that were broadcast - seeded. RESULTS Seed mixes with little or no nurse crop allowed significant germination of other annual species. Hemizonia fasciculata, a native summer annual abundant in the adjacent grasslands, was also abundant on the sites seeded with Mix D, and Mesembryanthemum crystallinum (Gasoul c.) was common on sites seeded with both Mix D and Mix E (Table 2). Although these plants did not appear to depress germination of the desired woody species (most notably Eriogonum fasciculatum) in the overall treatment areas, site -specific visual observations indicate that establishment of exotic species interferes with germination of desired species. Those sites with a high percentage of aggressive exotic species will be monitored close- ly. Both units contained problem areas of greatly compacted soil that tended to recompact with the first rains, effectively preventing infiltration of water. Since organic material appeared to be to- tally lacking at these sites, mulching was used in some of the areas to improve soil structure and encourage infiltration. All of the mulched areas bad been hydroseeded after scarification, with poor results, and then broadcast -seeded after res- carification the following year, again with poor results. How a mulch will affect germination is unknown, and therefore mulching was experimen- tal. It was done at two application rates, and with and without tackifier. Since mulching allows more infiltration of rainwater, provides some protection for new seedlings, and contributes or- ganic material to the soil, germination may be enhanced. If too heavy, however, or too persistent on the site, mulching could interfere with ger- mination. Visual observation of the mulched areas suggested that mulching encouraged a monocul- ture of Mesembryanthemum crystallinum. TABLE 1. Percentage of cover by species, for areas hydroseeded at Crystal Cove. Each area received one of three seed mixes. Indicated are pounds per acre (lb/ac); percentage of cover one growing season (7 months) after germination (% 1); and, except for Mix F, percentage of cover three growing seasons (26-30 months) after germination (% 3)(Hillyard and Black,1988). Mix A Mix C Mix F lb/ac % 1 % 3 lb/ac % 1 % 3 lb/ac % I Secondary & Climax Species Artemisia califomica 3* - 2.0 2* - - 3* 14.1 Atriplex canescens 5* 0.2 0.6 5* - - 5* 2.9 A. lentiformis ssp. breweri 3* 0.2 11.9 - - - - - Baccharis pilularis 3* - - - - - 4* - ssp.consanguinea Encelia califomica 4* - 6.8 5* - 9.2 5* 23.8 Eriogonum fasciculatum 15* 0.2 24.3 20* 0.4 39.4 20* 3.8 Isocoma veneta 2* - - - - 0.1 (Haplopappus venetus) Lotus scoparius 15* - 36.4 8* - 50.0 15* 0.1 Mimulus aurantiacus & - - - - - - 1.3* - M. longiflorus Salvia mellifera 4* - 0.2 1.7* - 0.4 5* - Rhus integrifolia p.** - 5.9 p.- Primary Seral Species Camissonia cheiranthifolia 0.43* 1.4 - - - - 1* - Eriophyllum confertiflorum - - - 2* - - 5.5* - Eschscholzia califomica 3* 0.4 - 1* - - - - Lasthenia glabrata 2* 3.4 - - - - - 0.1 Layia platyglossa - - - 1* - - - - Lupinus bicolor 4* - - 6* - - - - Orthocarpus purpurascens - - - - - - - - Plantago insularis 50* 0.8 - 10* - - 30* - Volunteers Annual grasses: - - - - - - - Avena barbata A. fatua Bromus rubens Brassica nigra - - 1.4 - - 4.7 - 2.0 Erodium cicutarium - - - - 18.4 - - - Eremocarpus setigenus - - - - - - - - Hemizonia fasciculata - 2.8 - - - - - 1.2 Heterothecagrandiflora - - - - - - - - Mesembryanthemum crystallinum - 1.6 1.1 - - - 22.6 (Gasoul c.) Salsola kali - - - - - - - - Others with < 1% each 1.8 1.0 2.0 - 3.1 Total % cover 12.8 91.6 20.8 103.8 73.7 *seed purchased, geographic source unknown; all other seed collected on site. **planted as liner size i L-1 • Table 2. Percentage of cover by species, for areas broadcast -seeded at Crystal Cove. Each area received one of three seed mixes. Indicated are pounds per acre (lb/ac); percentage of cover one growing season (7 months) after germination (% 1); and, except for Mix E, percentage of cover three growing seasons (26-30 months) after germination (% 3)(Hillyard and Black, 1988). Mix B Mix D lb/ac %1 %3 Ib/ac %1 %3 Secondary & Climax Species Artemisia califomica 1.9* 1.0 3.5 1 - 10.8 Atriplercanescens 3.1* - 0.4 - - - A. lentiformis ssp. breweri 1.9* 1.4 13.8 - - - Baccharis pilularis 1.9* - 5.2 0.2 - - ssp.consanguinea £ncelia califomica 2.5* - 9.1 1.5* - 0.1 Eriogonum fasciculatum 9.4* 2.6 21.1 15 3.0 25.6 Isocoma veneta 1.25* - - 1 - - (Haplopappus venetus) Lotus scoparius 9.4* 0.2 6.5 - 0.2 - Mimulus aurantiacus & - - - 0.3 - - M. longiflorus Salvia mellifera 2.5* 0.2 0.4 2 - 0.5 Rhus integrifolia p.** - - p, Primary Sera] Species Camissonia cheiranthifolia 0.25* 11.6 - 0.25 - - Eriophyllum confertiflorum - - - - - Eschscholzia califomica 1.9* - - - - - Lasthenia glabrata 1.25* 5.0 - - - - Layia platyglossa - - Lupinus bicolor 2.5* - - - - - Onhoearpus purpurascens - - - 0.25* - - Volunteers Annual grasses: - - - - - 7 Avena barbata A. fatua Bromus rubens Brassica nigra - 0.2 6.1 - - 4.4 Erodium cicutarium - - - - - Eremocarpus setigerus - - - - 5.4 - Hemizonia fasciculata - - - - 21.6 38.3 Heterotheca grandif7ora - - - _ - 5.2 Mesembryanthemum crystallinum - - .7 - 18.0 6.8 (Gasoul c.) Salsola kah - - - _ - - Others with < 1% each 2.1 - 1.2 1.8 Total % cover 22.6 68.9 49.4 100.5 *seed purchased, geographic source unknown; all other seed collected on site. **planted as liner size 23 Mix E lb/ac % 1 1.5 0.3 - 0.2 0.2 - 15 11.0 1.7 - 24.2 2; 6: There are also problems with the old equestrian site at Crystal Cove (13 acres treated in 1985-6, seven yet to be treated). Due presumably to the previous use of the area, the site is excessively fertile and seems to contain an abundance of weed seed. In 1986-7 vegetation was dominated by ex- otic annual weeds such as Mesembryanthemum crystallinum, Salsola kali, and Brassica nigra. Visual observation of the area since 1987 indicates that the alien species are inhibiting the germina- tion and establishment of the native species even in areas where seeding was done at rates of two, four, eight, and 16 times that normally used. DISCUSSION Two factors appeared to contribute primarily to successful re-establishment of coastal sage scrub: seedbed condition and nurse crop. In general, areas with adequate seedbed preparation and protection produced the most successful germina- tion of all species. Good germination of the various nursecrop species (both seeded and volunteer) was a good predictor of germination of the woodier species. These two factors are re- lated, in that good germination of nurse -crop species helped to maintain a good seedbed, and protection of the seedbed, specifically from recompaction due to trampling, was vital to good germination of the nurse crop. These observa- tions are based on visual and photographic monitoring of the sites rather than on the data collected. The plot monitoring, which does not indicate much presence of nurse -crop species, was conducted after many of the nurse -crop species, primarily annuals, had gone to seed and were no longer on the site. The more generous budget at San Clemente permitted us to contract out the project. Al- though this project went well, thanks to a very able contractor, there are potential pitfalls to contract- ing within the constraints of California regula- tions, particularly regarding contractor selection. By state contract law, the lowest bidder gets the job. Restoration is not an exact science, however, nor has it a code of regulations. The lowest bidder may not have the most, or even any, experience in native ecosystem restoration. Vagueness about 24 what constitutes a successful restoration (espe- cially difficult to assess in the very early stages, when contractors expect to be paid for their work) makes it difficult to enforce a contract. A strong case can be made for allowing an agency to select a restoration contractor by record and reputation rather than by low bid. Also, stringent bonding requirements, designed to protect the state, may eliminate some technically qualified bidders. At Crystal Cove, short funds limited us primarily to the use of California Conservation Corps workers. Although the corps as a labor source appears inexpensive, it necessitated extensive project planning, scheduling and supervision that added costs. Turnover was high, with a new crew to be trained every week, and motivation of corps members, with low levels of skill and low pay, was difficult. In addition, the corps has seasonal obligations, such as flood control and firefighting, that sometimes superceded our work. State budgeting and funding procedures also gave problems. The typical funding cycle allows three fiscal years for expenditures. The July -to - June fiscal year conflicts with schedules deter- mined by seed availability, precipitation and appropriate planting times, and can effectively reduce a three-year program to two years of actual work. Also, it makes it difficult to do preliminary tests, to phase work, and to monitor results in time to modify strategy. CONCLUSIONS Several guidelines can be helpful in planning a restoration project: 1) Do extensive ecological pre -planning. Set and follow a schedule. 2) Do appropriate site preparation. Nothing is more important to revegetation than a good seedbed. 3) Use experienced contractors who can set and keep a schedule within the state's 3-year schedule. 4) Exclude all use within the restoration area. 5) Develop and implement a monitoring pro- gram. Results not in time to benefit the current project may benefit a future one. • 1-1 ECOLOGICAL LANDSCAPING: CREATING BIRD HABITAT IN SUBURBAN CALIFORNIA GARDENS AND PUBLIC LANDSCAPES by David Bontrager Tree of Life Nursery P.O. Box 736 San Juan Capistrano, CA 92693 ABSTRACT During the development of Southern California suburbs, native habitat is typically replaced by an exotic landscape with low plant -species diversity and little structural diversity. As a result there is little diversity of bird species. Of the birds present, all are adaptable generalists, either om- nivorous or granivorous, and non -natives are dominant. Conspicuously absent are 1) native species that forage or nest on the ground, or near it, 2) insectivorous birds, and 3) cavity nesters. To increase diversity of bird habitats, we make the following recommendations: use drought -tolerant native plants; choose plants of known wildlife value; eliminate turf whenever possible; increase the total foliage volume and overall diversity of plant species; maximize the diversity of foliage heights; and provide horizontal patchiness, with bare areas between some plants. Also, where possible, retain standing dead trees and allow leaf litter to accumulate. INTRODUCTION The search for convincing reasons to use drought -tolerant native plants in the Southern California landscape is a short one. The state is in the third year of a serious drought, the second in a decade. Water -management agencies predict a water crisis by the turn of the century, brought on by an ever -burgeoning population and the lack of new water sources. When water rationing be- 26 comes a reality, the irrigated landscape will feel the impact. During the drought of 1977, the East Bay Municipal Utility District reported landscape losses of $100 million as a result of mandated water -use cutbacks. Using California native plants in residential, corporate and public landscapes is a sensible reaction to the situation and a responsible step toward conserving a limited resource. Lower water consumption and lower maintenance costs make the use of natives an attractive and, perhaps eventually, a mandated alternative. Water conservation is integral to any ecological approach to landscaping. The concepts presented here should not be con- fused with what is commonly termed habitat revegetation. Revegetation is typically mandated by wildlife resource agencies such as the U.S. Fish and Wildlife Service or the California Department of Fish and Game, and is an attempt to mitigate the loss of natural habitat through the creation of a like amount of the same habitat. The goal of revegetation is to recreate a natural, functioning biological community. Although many of the same principles are used in ecological landscap- ing, a functioning biological community is impos- sible in a place as small as a backyard or as busy as an industrial park. However, habitat of value to an increased variety of bird species can be created in urban landscapes, and the cumulative effect of many yards throughout a development or com- munity can be significant. Although the focus of this paper is on ecological landscaping to create bird habitat, such landcaping will also benefit other wildlife. BIRD SPECIES OF SUBURBAN vs. NATURAL AREAS In seeking increased habitat for birds in the sub- urbs (or in commercial or open -space areas) an • 10 0 interesting starting point is to compare suburban bird populations with those in natural areas. After development, the number of bird species drops drastically, with much of the loss reflecting specific qualities of the new landscaping. Typical- ly, bird populations in Orange County suburbs differ fi-om those in natural plant communities in several ways: 1) Suburban habitats are dominated by non-na- tive bird species, including the rock dove (Colum- ba livia), house sparrow (Passer domesticus), European starling (Stumus vulgaris), and Chinese spotted dove (Streptopelia chinensis). These high- ly adaptable birds thrive in man-made habitats. 2) The predominant native species in suburban habitats are a small group of seed -eaters and om- nivores that are likewise adaptable generalists, all capable of finding ample food from grasses, weeds, and other non-native landscape plants, in addition to scavenging on human discards. Some of these species are the house finch (Carpodacus mexicanus), mourning dove (Zenaida macroura), and American crow (Corvus brachyrhynchos). 3) Suburban areas have a marked reduction in the number of birds that forage or nest on the ground or near it, such as the rufous -sided towhee (Pipilo erythrophthalmus) and California towhee (P. cris- salis) (formerly brown towhee, P. fuscus). Most landscapes lack well -developed ground layers of both herbaceous and shrub species needed by these birds for protective cover and nesting sub- strate. Another important negative influence on these birds is the domestic cat, which possibly eliminates the ground -bird group from some neighborhoods. 4) Suburban areas have few nesting insectivorous bird species. At least in the Eastern states, re- search has revealed that these are the first birds to disappear from newly developed areas, apparent- ly because they require large, contiguous blocks of tree and shrub cover (DeGraaf and Wentworth, 1981; Ambuel and Temple,1982; Harris,1988). In Southern California landscapes, the overall low volume of vegetation offers insufficient insect habitat, at least at levels high enough to support 0 27 nesting insect -eating birds. This problem is great- ly exacerbated by the use of pesticides to control insect populations. Some large, densely landscaped places such as city parks may be tem- porarily able to support a large variety of migrat- ing bird species, but the same habitat will support fewer breeding species. 5) Suburban areas have few cavity -nesting bird species. Dead or decaying trees, the required sites for cavity nesters such as Nuttall's woodpeck- er (Picoides nuttallii) and the ash -throated flycatcher (Myiarchus cinerascens) are removed completely or almost completely from the subur- ban environment (Bontrager,1987). The Orange County Sea and Sage Chapter of the National Audubon Society is in its final year of compiling statistics for a Breeding Bird Atlas, a project designed to show the distribution of birds breeding in Orange County. This timely study yields valuable information on changes in bird - species diversity in this rapidly developing region. The Breeding Bird Atlas divides the county into 110 census blocks averaging approximately 7 square miles each. For purposes of this paper, six census blocks were selected in suburbs lacking significant natural habitat, and six blocks were chosen that included some relatively undisturbed natural habitat. Breeding bird populations in these two areas were compared to those at the Starr Ranch Audubon Society Sanctuary, a 3,500- acre mosaic of natural habitats in the foothills of Orange County. The number of breeding bird species recorded in the suburban area without natural habitat, the suburban area with natural habitat, and the Audubon sanctuary were, respectively, 23, 47 and 55. If only those species considered common (recorded in three or more of the six census blocks) are included, even greater differences in diversity are found. The totals for the same three respective areas now become 12, 27 and 44. Development displaces the naturally diverse bird populations of the undisturbed sanctuary, leaving only a reduced group of highly adaptable generalists successful in adjusting to a severely altered habitat. SUBURBAN vs. NATURAL HABITATS Bird faunas in suburban areas vary, depending largely on the degree of alteration of pre -develop- ment vegetative cover. Present-day development in Southern California typically begins with the complete removal of all native vegetation, fol- lowed by recontouring and recompaction of soils. A new landscape is then "pasted on" in and around the residential or commercial development. This vegetative cover is characterized by several new features: 1) The man-made landscape is composed primarily, if not exclusively, of non-native plant species. Wildlife resource values -- food, nesting substrate, protective cover -- are not considered when the plants are chosen. Although exotic habitats provide food and cover for some native birds, many non-native plant species are of doubt- ful value compared to native plants with which the native birds have evolved. Birds instinctively select a particular habitat (Lack,1933), probably defined by its physical structure. Beecher (1942) concluded that birds select places according to a "preconceived perception". If an artificially created landscape fails to provide the correct habitat image, a given species of bird may not perceive the area as acceptable nesting habitat. Numerous studies throughout North America have shown that increasing the percentage of na- tive vegetation in urban and suburban habitats results in an increase in the diversity of native bird species (Lancaster and Rees,1979; DeGraaf and Wentworth,1981; Beissinger and Osborne,1982; Tweit and Tweit, 1986; Rosenberg et al., 1987; Mills et al.,1989). 2) Plant species diversity is almost always lower in created landscapes than under natural condi- tions. A close examination of recently developed residential and commercial tracts in Southern California reveals a surprisingly small palette of plants. In nature, as plant species and habitat diversity increase, animal species diversity 28 generally increases. A wider variety of plants with a correspondingly greater variety of food types and nesting substrates will support a wider variety of bird species. 3) Man-made landscapes tend to lack structural diversity in the vertical plane. Numerous studies have shown that bird -species diversity increases as foliage -height diversity increases (MacArthur and MacArthur, 1961; Kan and Roth, 1971; Willson, 1974). Diverse natural habitats often have recognizable vertical layers, beginning with a low herbaceous layer up through various heights of shrubs, perhaps with a tree canopy overhead. A popular method of slope landscaping consists of a solid, low ground layer with widely scattered shrubs, trees, or both. The only well -developed vertical layer is the low (1-to-2 foot) continuous ground cover. If the ground cover is a prostrate woody shrub, the plants are often spaced closely for rapid complete cover of the ground. This cover leaves no exposed earth for ground -foraging birds. Trees included in landscapes are typically widely spaced, so stretches of canopy cannot develop, and rather than being allowed to assume natural shapes, trees are manicured into lollipop shapes, with all lower foliage removed. 4) In man-made landscapes, trees and shrubs tend to be thinly distributed and are often arranged in uniform, geometric patterns. In nature, plants are distributed in random patterns and in higher den- sities. In Southern California scrub habitats (coas- tal sage scrub and chaparral), this results in a mosaic of patches of densely growing plants (horizontal patchiness), with intervening open- ings and large amounts of edge. The absence of this feature in suburban landscapes is a major factor in the loss of low -nesting bird species. Ac- cording to Roth (1976), this horizontal habitat diversity has an even greater influence than verti- cal diversity on the number of bird species in an area. S) A great percentage of residential landscape consists of turf grass. The open -space require- ments of many new communities are largely met by high -water -use and high -maintenance turf greenbelts, parks, and golf courses. In terms of 0 wildlife resource values, turf is one of the most impoverished artificial habitats. With the excep- tion of a small group of adaptable bird species, v«Idtife avoids turf. BIOLOGICAL DIVERSITY The rallying cry of all biological conservation today is: Preserve biological diversity. There is even legislation in Congress with this goal (Block- stein,1988). Diversity will not be maintained and cannot be enhanced through ecological landscap- ing without the recognition of several sound biological concepts: 1) The plants and animals of a habitat are an interdependent assemblage. Modifications to one part of an ecosystem can, and often do, have impacts on other parts of the system. 2) In a healthy ecosystem, species diversity is in- tact, i.e., habitat disturbance has not resulted in a significant loss of plant and animal species. 3) If natural habitat is disturbed, fragmented or removed from an area, plant and animal diversity drops. Although some species are highly adapt- able to man-made environments, most are not, and these fail to survive significant environmental alteration. Ecological landscaping thus becomes an effort to regain wildlife resource values (par- ticularly habitat diversity) lost during develop- ment. Over the past two decades, scores of scientific studies have shown that the surest way to lower the biological diversity of natural areas is to cut them into disjunct fragments. An excellent study per- tinent to developing suburban areas in Southern California is that of Soule et al. (1988). Typically, the fragmentation of natural communities occurs with population pressure and the accompanying conversion of land to industrial, suburban and urban uses. This results in isolated remnants of natural habitat surrounded by development. The success of any ecological landscaping, whether on the small scale of a residential yard or the large scale of a community open -space area, will be 0 0 greatly influenced by its proximity to a fragment of natural habitat and the size of that fragment. If the success of an ecological landscape is to be measured by how many species of birds occupy the landscape, the most successful areas will be those that have natural areas nearby to draw from. SUITABLE SUBURBAN LOCATIONS FOR NATIVE PLANTS There is no substitute for predevelopment plan- ning that preserves blocks and.corridors of natural habitat within developments and adjacent to them. Unfortunately, preservation of habitat within developments is not common practice in Southern California. Even existing develop- ments, however, can be enhanced: in turfed green- belts, along bike paths, in bare areas, or in existing parks. This author's project in one heavily used suburban Orange County regional park has proved that native habitat can be created without compromising the recreational function of parks. The selection of plants for ecological landscaping should depend upon where in the community the plants will be used. Three possibilities for native plantings are: 1) The yards and gardens of private residences. 2) Expanses of land within the city: designated open spaces such as parks, golf courses, and greenbelts, as well as city street right-of-ways, including medians, slopes, and bike pathsides. 3) The outer fringes of the city, or land between development and existing natural areas. The lat- ter includes parks, greenbelts, and golf courses adjacent to blocks of natural habitat. Landscaping toward the center of a community, away from natural habitats, can include cultivars of natives or even species found outside the imme- diate area. At the edges of the community, on the other hand, the landscape should act as a natural buffer or transition zone between development and wildland areas. As a rule, when a planting is in of, directly adjacent to an existing native plant community, all effort should be made to use only native species found in the surrounding region. Palettes for transition zones to natural areas should be determined by biologists familiar with local plant communities. Table 1 presents a palette of native plants of Orange County, California that could be chosen for such transition areas. LANDSCAPING RECOMMENDATIONS Regardless of which palette is chosen, the fol- lowing recommendations can greatly influence the attractiveness of a landscape to birds: 1) Use drought -tolerant native plants whenever possible. Native California birds evolved in habitats of native vegetation and are attracted to the same type of vegetation. This may explain why many non-native plants in landscapes appear un- derused, if not ignored, by birds. 2)Decrease the percentage of turf in the landscape. This homogeneous, artificial habitat is valueless for all but a small group of birds, and many of these are non-native species. 3) Increase the total volume of foliage. The more cover and food available, the greater number and variety of birds. 4) Create landscapes with a high degree of vertical diversity by choosing plants of varying heights. 5) Maximize diversity in the horizontal dimension by arranging plants in a mosaic of random clumps, with intervening open areas to serve as foraging habitat adjacent to protective cover. In terms of general acceptance, this may be one of the most difficult suggestions offered. The typical landscape today is arranged not randomly but in geometrical lines, shapes, or swaths preserved by careful manicuring and maintenance. 6) Increase the overall plant species diversity. Even choosing native plants over non-native plants does not guarantee a sound ecological landscape. A slope planted exclusively with 3,000 K76 Amtostaphylos `Point Reyes', a popular native ground cover, will have very little habitat value for birds. The same slope planted with 20 native species, L% plants each, will attract a much wider variety of birds. 7) Choose plants known to be high in wildlife value. This is particularly important to the in- dividual homeowner trying to maximize the at- tractiveness of a small area. Table 2 presents a list of native plants chosen for their particularly high wildlife value. 8) Allow leaf litter to accumulate under plants. This creates a natural mulch for controlling weeds and preserving moisture, and forms a fertile sub- strate for reseeding. The seeds and insects within it also provide forage for ground -feeding birds. 9) In low -use portions of parks, golf courses, or large open spaces, leave some standing dead trees, or trees with large, dead branches. Without this seemingly valueless material, many cavity -nesting bird species disappear from developed areas. CONCLUSIONS As development proceeds through a region, the widely varied native habitat is removed and replaced by a pasted -on, non-native habitat with greatly reduced diversity. In turn, the natural diversity of wildlife declines as a smaller set of highly adaptable generalists, including numerous non-native species, largely replaces the former populations. Wildlife populations never return to predevelopment levels. But if landscape planning incorporates ecological landscaping concepts, greatly enhanced suburban habitats will increase the opportunities for people to enjoy wildlife while jogging through the neighborhood park, riding the regional bike trail, or relaxing on the backyard patio. LITERATURE CITED Ambuel, B., and S.A. Temple. 1982. Songbird populations in southern Wisconsin forests: 1954 and 1979. J. Field Ornith. 53:149-IM. • 0 0 TABLE 1. Plants for ecological landscaping in Orange County* Plant Community** Gr OW R CS Ch. Acer macrophyllum (Big Leaf Maple) X Alnus rhombifolia (White Alder) X Amorpha fruticosa (False Indigo) X Artemisia californica (Coastal Sagebrush) X A. douglasiana (Mugwort) X X Atriplez lentiformis ssp. brewed (Quail Brush) X Baccharis salicifolia [B. glutinosa] (Mulefat) X B. pilularis ssp. consanguinea(Coyote Brush) X X Bloomeda crocea (Golden Stars) X X Ceanothus crassifolius (Hoaryleaf Ceanothus) X X C. megacarpus (Big Pod Ceanothus) X X C. spinosus (Greenback Ceanothus) X X C. tomentosus ssp. olivaceous (Woolyleaf Ceanothus) X Cervocarpus betuloides (Mountain Mahogany) X C minutiflorus (San Diego Mountain Mahogany) X X Clematis lasiantha (Pipe -stem Clematis) X X Cneoridium dumosum (Bushrue) X Dendromecon rigida (Bush Poppy) X Dichelostemma pulchellum (Wild Hyacinth) X X Dudleya pulverulenta (Chalk Dudleya) X X Elymus condensatus (Giant Rye Grass) X X X Encelia californica (California Encelia) X Epilobium canum [Zauschneris califomicaf (California Fuchsia) X X Eriogonum fasciculatum (California Buckwheat) X Isocoma veneta [Haplopappus venetus] (Coastal Goldenbush) X X Heteromeles arbutifolia (Toyon) X X X Isomeris arborea (Bladderpod) X Keckiella cordifolia (Heart -leaved Penstemon) X X X Lonicera subspicata (Chaparral Honeysuckle) X X X Malosma laurina [Rhus 1.] (Laurel Sumac) X X X X Mimulus cardinalis (Scarlet Monkey Flower) X X M. longif7orus (Bush Monkey Flower) X X M. puniceus (Red Bush Monkey Flower) Penstemon centranthifolius (Scarlet Bugler) X X P. heterophyllus ssp. australis (Foothill Penstemon) X X P. spectabilis (Showy Penstemon) X X Platanus racemosa (Western Sycamore) X Populus fremontii (Fremont Cottonwood) X Prunus ilicifolia (Hollyleaf Cherry) x Quercus agrifolia (Coast Live Oak) X Q. dumosa (Scrub Oak) X X Q. engelmannii (Mesa Oak) X X Rhamnus californica (Coffeeber y X X X 31 TABLE 1. (continued) Plant Community** Gr OW R CS Ch R crocea (Hollyleaf Redberry) X X X X R ilicifolia (Hollyleaf Redberry) X X X X Rhus integrifolia (L.emonadeberry) X X X X R laurina (See Malosma laurina) X X X X R ovata (Sugar Bush) X X Ribes indecorum (White Flowering Currant) X X R. malvaceum (Chaparral Currant) X X R speciosum (Fuchsia -flowered Gooseberry) X X Romneya coulteri (Matilija Poppy) X X Rosa califomia (California Wild Rose) X X Rubus ursinus (Wild Blackberry) X X Sahrgooddingii (Black Willow) X S. hindsiana (Sandbar Willow) X S. laevigata (Red Willow) X S. lasiandra (Yellow Willow) X S. lasiolepis (Arroyo Willow) X Salvia apiana (White Sage) x S. mellifera (Black Sage) X X Sambucus medcana (Mexican Elderberry) X X Satureja chandleri (Yerba Buena) X X Sisyrinchium bellum (Blue-eyed Grass) X X Solanum xand (Purple Nightshade) X X Stipa pulchra (Purple Needlegrass) X X Thalictrum polycarpum (Meadow Rue) X X Trichostema lanatum (Woolly Blue Curls) X Umbellularia califomica (California Bay) X X Vitis girdiana (Desert Grape) X X Yucca whipplei (Foothill Yucca) X X Zauschneria californica. See Epilobium canum X X *This list is intended as a guide for city planners, landscape architects, park planners and rangers, homeowners, and others who wish to create native landscapes resembling those assemblages occurring in five of Southern California's natural plant communities. Other California native species, subspecies, and cultivars not found in Southern California can also be used under landscape conditions but should not be planted within e3dsting natural habitat. This list should not be regarded as all -encompassing. Many other local species would be appropriate. **Plant community abbreviations: Gr = Grassland, OW = Oak Woodland, R = Riparian, CS = Coastal Sage Scrub, Ch = Chaparral. Many of these species are found in a wide variety of communities, but are listed only where they are most common. 32 • 0 0 TABLE 2. Planting for wildlife: selected native plants for wildlife habitat enhancement Acer macrophyllum - Big Leaf Maple. A large deciduous tree (too large for most home gardens, but ideal for parks or nature centers). The seeds, buds, and flowers are eaten by house finches, goldfinches, black -headed grosbeaks and other seed -eating birds. Alnus ,rhombifolia - White Alder. A Iarge, fast-growing deciduous riparian tree. The seeds are eaten by various finches, particularly goldfinches. Aquilegia fonnosa var. truncata - Red Columbine. An excellent border plant for a woodland effect. It attracts hummingbirds, which serve as its primary pollinator. Arctostaphylos spp. - Manzanita. A large variety of short -to -medium -height shrubs are available for a general wildlife cover. The fruit is eaten by birds and mammals. Hummingbirds use its flowers. Atriplex lentiformis ssp. breweri - Coastal Quail Brush. An excellent conservation plant, tolerant of poor soil. The seeds are eaten by small mammals and birds. It also serves as an important cover plant, providing general protection and nest sites for low -nesting birds. Baccharis pilularis ssp. consanguinea - Coyote Brush. An excellent cover plant, with dense foliage. Ceanothus spp. - Ceanothus. Some of our most attractive cultivated shrubs, providing good general wildlife cover. Cercocarpus betuloides - Mountain Mahogany and C. minutcfloms - San Diego Mountain Mahogany. Two important chaparral plants for good general wildlife cover. The seeds are eaten by birds and small mammals. Encelia califomica - California Encelia. An easy, fast-growing subshrub. Its seeds are eaten by many birds and small mammals. Epilobium canum fZauschneria califomica] - California Fuchsia. A fine, small -sized accent shrub. It is a profuse bloomer with bright red flowers. A hummingbird favorite. Eriogonum fasciculatum - California Buckwheat. A good low cover. Its seeds are eaten by birds and small mammals. Galvezia speciosa - Island Bush Snapdragon. A good low cover or a showy accent in small clumps. Hummingbirds use its red tubular flowers. Heteromeles arbutifolia - Toyon. An outstanding wildlife plant and slope stabilizer. It provides a general tall shrub cover. The fruits are eaten by many birds, including the California quail, Northern mockingbird, American robin, cedar waxwing, Western bluebird, and black -headed grosbeak. Isomeris arborea - Bladderpod. Very drought tolerant. It flowers most of the year. The seeds are eaten by finches, sparrows, and doves. Its bright yellow flowers are occasionally visited by hummingbirds. Keckiella cordifolia - Heart -leaved Penstemon. A vining shrub, good in the shade. Its flashy red flowers are visited by hummingbirds. Lonicera subspicata - Chaparral Honeysuckle. A deciduous vining shrub, with attractive orange berries that are eaten by many birds. Malosma laurina fRhus laurinal - Laurel Sumac. A great tall shrub cover. Many bird species nest in it and many eat its flower buds and fruit. M.mulus cardinalis - Scarlet Monkey Flower. A low, herbaceous perennial, spreading readily by underground root stocks. It is good in partial shade. The red flowers attract hummingbirds. M. longiflorus - Bush Monkey Flower andM. puniceus - Red Bush Monkey Flower. A good plant to mix into a low shrub cover. It blooms profusely. Hummingbirds use it. Myrica califomica - Pacific Wax Myrtle. A large, attractive, fragrant tree. Its waxy -coated fruit and its seeds are eaten by a variety of birds. Penstemon cenomthifolius - Scarlet Bugler. A small herbaceous perennial, showy in bloom. Hum- mingbirds are attracted to its red, tubular flowers. 33 TABLE 2. (continued) • Penstemon spectabilis - Showy Penstemon. It produces an abundant bloom of lavender -purple flowers in tall spikes. Hummingbirds use it occasionally. Pinus spp. - Pine. its seeds are eaten by many birds and mammals. Mature trees provide shelter and nest sites. Platanus racemosa - Western Sycamore. A large riparian tree. Its seeds are eaten by finch species. Mature trees provide nest sites for raptors and cavity -nesting birds. Populus fremontii - Fremont Cottonwood. A large native tree in riparian habitats. The flower buds are eaten by numerous birds. It provides raptors with nest sites. Prosopis glandulosa var. torreyana [P. julifora var. t.] - Mesquite. A deep-rooted deciduous shrub with attractive yellow flowers. Its seeds are eaten by birds and small mammals. Prunus ilicifolia - Hollyleaf Cherry. A good general tall cover, very drought tolerant, with lush green growth. Its showy white flower clusters and attractive fruits are eaten by birds and mammals. Quercus agrifolia - Coast Live Oak. As a mature tree, it is one of the most valuable for wildlife. Its acorns are eaten by a wide variety of birds and mammals; it provides a nesting substrate for many bird species, large and small; and it serves as a foraging habitat for many insect -eating birds. Rhamnus califomica - Coffeeberry. A good shrub for tall cover. Many birds eat its fruit. R. crocea and R. ilicifolia - Hollyleaf Redberry. The same as above. Rhus integrifolia - Lemonadeberry. One of the best and most dependable species for general wildlife cover, including bird -nesting substrate. Birds eat its fruit. Its deep network of fleshy roots provides good slope stabilization, as well. Rhus laurina. See Malosma laurina. Ribes spp. Currants and Gooseberries. Several species of low -to -medium shrubs that do well in the shade. Their attractive fruits are eaten by many birds and mammals, and hummingbirds feed at the flowers of R. malvaceum, R. speciosum, and R. sanguineum. Rosa califomica - California Wild Rose. Outstanding as a low shrub cover. It forms protective thickets for nesting birds. Rubus ursinus - California Blackberry. A great protective cover for wildlife. The fruits are eaten by many birds and mammals. Salix spp. - Willow. Important wildlife plants in wetland habitats for general cover and nest sites. The flowers and buds are eaten by various finches. Willows provide foraging habitat for insect -eating birds. Salvia spp. - Sage. Many good low shrub -cover species. Their seeds are eaten by birds and mammals. Hummingbirds visit S. mellifera, S. apiana, S. greggii, and S. elevelandii. Sambucus mndcana - Elderberry. An outstanding wildlife shrub, good as cover. The fruit is eaten by a great variety of birds and mammals. Solanum xand - Purple Nightshade and S. douglasii - White Nightshade. Low shrubs. Their fruits are eaten by many birds and mammals. Trichostema lanatum - Wooly Blue Curls. A beautiful accent shrub, a showy, profuse bloomer. It is heavily used by hummingbirds. Umbellularia califomica - California Bay Laurel. A good tall shrub, growing to tree size under some conditions. Ytis girdiana - Desert Grape. A great cover for shelter and bird -nest sites. The fruit is eaten by a great many birds and mammals. Zauschneria califomica. See Epilobium canum. 34 0 11 Beecher, W.J. 1942. Nesting birds and the vegetation substrate. Chicago Ornith. Soc., Chicago. 69 pp. cited in DeGraff, R.M., and J.M. Wentworth. 1981. Urban bird communities and habitats in New England. Trans. N. Amer. Wildl. Nat. Res. Conf. 46: 396-413. Beissinger, S.R. and D.R. Osborne.1982. Effects of urbanization on avian community organization. Condor 84:75-83. Blockstein, D.E. 1988. U.S. legislative progress toward conserving biological diversity. Cons: Biol. 2:311-313. Bontrager, D.R.1987. The dependency of cavity nesting birds on diseased oaks: implications for management on public lands. pp. 74-81. In Bowler, P. and S. Brown eds. Proc. Calif. Oak Heritage Cons. Conf., Univ. Calif., Irvine. March 11,1983. Sea & Sage Audubon Society.153 pp. DeGraaf, R.M., and J.M. Wentworth. 1981. Urban bird communities and habitats in New England. Trans. N. Amer. Wildl. Nat. Res. Conf. 46:396-413. Harris, L.D.1988. Edge effects and conservation of biotic diversity. Cons. Biol. 2:330-332. Karr, J.R. and R.R. Roth. 1971. Vegetation structure and avian diversity in several new world areas. Am. Natur.105:423-435. Lack, D. 1933. Habitat selection in birds. J. Animal Ecol. 2:239-262. Lancaster, RX and W.E. Rees.1979. Bird com- munities and the structure of urban habitats. Can. J. Zool. 57:2358-2368. MacArthur, R.H., and J.W. MacArthur. 1961. On bird species diversity. Ecol. 42:594-598. Mills, G.S., J.B. Dunning, Jr., and J.M. Bates. 1989. Effects of urbanization on breeding bird communitiy structure in southwestern desert habitats. Condor 91:416-428. 35 Rosenberg, K.V., S.B. Terrill, and G.H. Rosen- berg.1987. Value of suburban habitats to desert riparian birds. Wilson Bull. 99:642-654. Roth, R.R.1976. Spatial heterogeneity and bird species diversity. Ecol. 57:773-782. Soule, M.E., D.T. Bolger, A.C. Alberts, J. Wright, M. Sorice, and S. Hill. 1988. Reconstructed dynamics of rapid extinctions of chaparral -requiring birds in urban habitat islands. Cons. Biol. 2:75-92. Tweit, R.C. and J.C. Tweit. 1986. Urban development effects on the abundance of some common resident birds of the Tucson area of Arizona. Am. Birds 40:431-436. Willson, M.F.1974. Avian community organiza- tion and habitat structure. Ecol. 55:1017-1029. ECOLOGY AND CONSERVATION OF TWO ENDANGERED SOUTHERN CALIFORNIA BUTTERFLIES by Richard A. Arnold Entomological Consulting Services 104 Mountain View Court Pleasant Hill, California 94523 ABSTRACT The endangered Palos Verdes blue butterfly (Glaucopsyche lygdamus palosverdesensis) is en- demic to the Palos Verdes Peninsula near Los Angeles, California, where the butterfly or its sole larval foodplant, Astragalus trichopodus var. lonchus (Fabaceae), formerly occurred at 18 sites in association with the coastal sage scrub plant community. Although the U.S. Fish and Wildlife Service recognized the butterfly as an endangered species in 1980, several of these sites were sub- sequently destroyed by housing or recreational developments. In addition, local fire -control practices have promoted the spread of weeds, crowding out native vegetation at all remaining sites. Together these factors have reduced the numbers of A. trichopodus var. lonchus by more than 90% during the past 10 years and threaten to extirpate the Palos Verdes blue butterfly, if they have not already done so. In contrast, the en- dangered El Segundo blue butterfly (Euphilotes battoides allyni) survives at two small remnants of the El Segundo sand dune system, one at the Los Angeles International Airport and the other at a nearby refinery operated by Chevron USA. Before 1982, habitat quality and butterfly numbers at both remnants deteriorated as introduced weeds and annual grasses outcompeted the butterfly's larval and adult nectar plant, Eriogonum parvifolium (Polygonaceae). There- fore, Chevron implemented a long-term habitat management program to control weeds and in- crease numbers of the butterfly's foodplant. Preliminary findings of this program provide an 92 example of how private industry can assist the federal government in conserving endangered species. INTRODUCTION Two lycaenid butterflies (Lepidoptera: Lycaenidae) indigenous to coastal habitats of the Los Angeles Basin are recognized as endangered by the U.S. Fish and Wildlife Service (USFWS). Both became endangered when urbanization directly or indirectly caused the loss and alteration of habitat. In association with the coastal sage scrub plant community, the Palos Verdes blue (Glaucopsyche lygdamus palosverdesensis) formerly existed at a number of sites on the Palos Verdes Peninsula. Although the butterfly was recognized as en- dangered, several of these sites were destroyed by housing and recreational developments, and habitat at the remaining sites was degraded. Within a few years after the species was listed as endangered these factors resulted in a quick and dramatic reduction in the butterfly's foodplant and the probable extinction of the butterfly. Despite intensive annual searches, no Palos Ver- des blue has been seen since 1983. The El Segundo blue (Euphilotes battoides al- lyni) inhabits the El Segundo sand dune syste which formerly extended approximately 1810 along the shore of Santa Monica Bay, from Marina del Rey to San Pedro (Cooper,1967). Today the El Segundo blue is restricted to two small rem- nants of the dunes, which together comprise less than 1% of the butterfly's past geographic range. Because neither remnant is large enough for natural aeolian sand -dune dynamics to maintain the native vegetation, both areas are encroached upon by weeds and annual grasses. Thus, conser- vation of the El Segundo blue will depend upon • • 11 • long-term management to reduce alien grasses and weeds and to increase numbers of the foodplant. In this paper I will briefly review the natural history and conservation status of these two but- terflies. In the case of the El Segundo blue, habitat management by Chevron USA demonstrates how the private sector, working within the policies of the Endangered Species Act, can collaborate with resource agencies to conserve endangered species. In contrast, the fate of the Palos Verdes blue is an unfortunate example of how both the laws and system designed to protect endangered species can fail. Reasons for the decline of the Palos Verdes blue are reviewed in the hope that other endangered or sensitive plants and animals may benefit from the apparent demise of this butterfly. PALOS VERDES BLUE BUTTERFLY Distribution and Habitat Requirements. The Palos Verdes blue (Figure 1) is associated with the coastal sage scrub vegetation of the cool, fog -shrouded, seaward canyons and terraces on the Palos Verdes Peninsula. The butterfly's larval foodplaut, ocean milk vetch (Astragalus trichopodus var. lonchus), is a short-lived peren- nial legume (Fabaceae) growing in Southern California's coastal habitats. It is found from sea level to elevations of approximately 350 m (Bar- neby, 1964) on bluffs, mesas, rocky slopes and roadcuts, and in sandy fields. Flowering occurs typically from February until June, but occasional- ly also in fall and winter. The flight season of the butterfly's single generation per year is synchronized with the peak flowering of the larval foodplant, usually early February to late March; eggs are laid on the developing flower buds and young leaflets ofAstragalus. Larvae initially feed on sepals and gynoecia but eventually bore into seedpods and complete their development feed- ing on seeds and tissues of the pods. The oldest known museum specimens of this butterfly were collected in 1928 by a local en- 37 tomologist (Perkins and Emmel, 1977). Yet despite its occurrence in a region long populated by many entomologists, the Palos Verdes blue was not recognized as a distinct subspecies until nearly 50 years later (Perkins and Emmel,1977). During this time- livestock grazed on the hills, farmers grewvegetables on the coastal terraces, and grains and row crops were cultivated on many other parts of the peninsula (Gales,1974). Thus the complete historic distribution of the Palos Verdes blue is unknown, because so much of its habitat was al- tered before rediscovery of the butterfly in the early 1970s. Agriculture, urbanization, military ac- tivides, weed abatement, fire-p: evention prac- tices, the spread of exotic plants, and off -road vehicle use subsequently destroyed the native coastal sage scrub vegetation, causing further decline of the Palos Verdes blue. Decline and Current Status. Table 1 lists all known sites of historic and recent colonies of the Palos Verdes blue or its larval foodplant. The locations of these sites are indi- cated in Figure 2. At the time of its description in 1977 (Perkins and Emmel,1977) the butterfly was known only from its type locality, Alta Vista Ter- race (site No. 1 in Table 1 and Figure 2), which was shortly thereafter destroyed by the construc- tion of a residential development. Subsequent field surveys (Arnold,1987) found the butterfly or its larval foodplant at another 17 sites on the peninsula. Between 1977 and 1986, Palos Verdes blue and Astragalus extinctions occurred at five sites (Nos. 1, 2, 3, 4, and 9 in Table 1 and Figure 2). Ap- proximately 280 Astragalus plants (Table 1) were lost at these five locations, and the last Palos Verdes blue seen there was a single adult at colony No. 4 in 1982. During this same period,Astragalus numbers at seven other sites with confirmed but- terfly populations (Nos. 5, 6, 7, 8,10,13, and 15) declined 90% (653 to 63). No Palos Verdes blue has been sighted at these locations since 1983, when two adults were observed at colonies 5 and 15. Similarly, Astragalus numbers at six sites where the status of the butterfly is unconfirmed (Nos. 11, 12,14,16,17, and 18) declined 72% (60 FIGURE 1. Photograph of an adult male Palos Verdes blue perching on a blade of grass. Illustrated are its ventral wing surfaces. 38 0 0 0 • to 17, calculating from the peak year at each loca- tion). Presumably the numbers of butterflies, if there were any to begin with, declined at these six sites as the foodplant numbers declined. By 1985, only 10 of the original 18 sites still supported Astragalus. Between 1984 and 1986, however, total Astragalus numbers at these 10 sites declined 76%, from 328 to 80.(Table 1). During 1986, nine of the 10 sites supported eight or fewerAstragalus plants, while 39 plants grew at Luna say Friendship Park (No. 6). Between 1986 and 1988, Astragalus numbers increased slightly at six of the 10 remaining sites, to a total of 132 plants. Since my annual studies on the Palos Verdes blue began in 1979, Astragalus numbers at the 18 known sites declined nearly 91% (calculating from the peak year at each location). Only one new patch, at Fort MacArthur (No.14), became established during this time. Intensive searches of other canyons and terraces on the peninsula Point Fermin FIGURE 2. Location of 18 sites on the Palos Verdes Peninsula where either the Palos Verdes blue or its larval foodplant, Astragalus trichopodus var. lonchus, have been found. The 18 sites are indicated by the numbers 1-18, as assigned in Table 1. Major roads, canyons; and coastal features are also illustrated. 39 TABLE 1. Status of the Paios Verdes blue andAstragalus at the 18 known localities, from 1977 through 1988. Except for Alta Vista Way, known since 1973, and sites 2 through 5, whose dates of discovery are uncertain, the year under which Astragalus counts first appear is the year the site was discovered. The number of each site indicates its location in Figure 1. Locality 1) Alta Vista Way 2) Agua Armaga Canyon 3) Frank Hesse Park 4) Ridges and road - cuts along Palos Verdes Drive East switchbacks 5) Fields west of - Palos Verdes Drive East switchbacks 6) Friendship Park 7) San Pedro Hill 8) Island View Estates 9) Vista del Mar Last PVB Annual numbers of mature AstcB i alu Observation 1977 78 79 80 81 82 83 84 85 86 87 88 60* 0 0 0 0 0 0 0 0 0 0 0 1976: many adults - 25* 8 6 0 0 0 0 0 0 0 0 1979:1 adult - 75* 120 3 30 20 0 0 0 0 0 0 1982: larvae & adults - 30* 24 21 17 6 6 4 0 0 0 0 1982: adults - 250* 224 156 121 100 18 7 4 4 3 3 1983:1 adult 35 14 45 200 82 39 54 66 50 65 5 15 32 3 4 6 32 20 16 2 2 1 1 1 -- -- 45 5 5 2 0 0 0 0 10) Along old - - - - 27 16 ns ns 4 4 8 11 Crenshaw Blvd. between Altamira and Portuguese Canyons 1981: adult 1981: eggs, larvae & adults 1982: adults 1981: eggs, larvae & adults 1981: eggs, larvae & adults 11) Near the - - - - - 8 10 10 7 3 2 2 none Portuguese Bend Riding Club *No census that year;Astragalus numbers estimated ns = site not sampled that year 40 9 9 0 • • • TABLE 1. (continued) Last PVB Locality Annual Numbers of Mature A Observation 77 78 79 80 81 82 83 84 85 86 87 88 12) Altamira Cyn. - - - - - 5 0 0 0 0 0 0 none near Narcissa Dr. 13) Forrestal - - - - 14 10 6 3 3 8 12 16 1982: eggs, Drive larvae & adults 14) Upper - - - - - 1 0 0 0 8 11 14 none Reservation area (old Ft. MacArthur) 15) Gulfcrest- - - - - - - 65 50 3 4 7 8 1983: adults Heroic Drive area 16) Palo Vista - - - - - - 14 6 0 0 0 0 none Drive area 17) White's - - - - - - 3 3 3 0 0 0 none Point Park 18) Paseo del - - - - - - 12 16 20 6 9 5 none Mar area revealed no new stands. Astragalus numbers in- creased at only -six other sites since their peak years: Friendship Park (No. 6), San Pedro Hill (No. 7), Crenshaw Boulevard (No.10), Forrestal (No. 13), Gulfcrest (No. 15), and Paseo del Mar (No. 18). However, annual rototilling and mowing for fire control wipes out much of each year's new growth at Friendship Park, and planned residential developments will eventually destroy remnant habitat at San Pedro Hill (No. 7) and Forrestal Drive (No. 13). Residential development previously destroyed the butterfly's habitat at Alta Vista Terrace (No. 1), Island View Estates (No. 8), Vista del Mar (No. 9), and Palo Vista Drive (No. 16), while recreational develop- ment wiped out habitat at Frank Hesse Park (No. 3). As human numbers have increased on the penin- sula, residents and local city governments have 41 regarded open -space areas as fire hazards to homes and other structures during the annual dry season. In consequence, local ordinances require landowners to take various precautions to mini- mize the spread of fires. The most popular fire - management practice, annual rototilling, works open -space vegetation into the soil to create fire breaks before the onset of the dry season. Unfor- tunately, this promotes the growth and spread of annual weeds and grasses at the expense of peren- nial native plants. As weeds and grasses spread and then die during the dry fire season, they effec- tively increase the fire hazard, thereby perpetuat- ing the need for this activity. Rototilling extir- pated Astragalus along the switchbacks of Palos Verdes Drive East (No. 4) and has greatly reduced its numbers (Table 1) at the following sites: fields near Palos Verdes Drive East (No. 5), Friendship Park (No. 6), Portuguese Bend (No. 11), Upper Reservation (No. 14), and the Gulfcrest-Heroic Drive area (No. 15). Among them, at site No. 5, annual rototilling reduced Astragalus numbers from 224 in 1979 to four in 1986 (Table 1), a 98% decline. Similarly, increas- ing cover of weeds and annuals grasses has extir- pated Astragalus at Agua Armaga (No. 2) and Altamira (No.12) canyons, and is at least partially responsible for the 86% average decline in Astragalus numbers since 1981 (Table 1) at four other sites: San Pedro Hill (No. 7), Crenshaw (No. 10), Forestal Drive (No. 13), and White's Point (No. 17). Preservation Efforts. Pursuant to provisions of the Endangered Species Act of 1973, USFWS proposed the Palos Verdes blue for endangered species status in 1978 (USFWS, 1978) and critical habitat areas (i.e., areas considered essential for the butterfly's sur- vival) were identified in early 1980 (USFWS, 1980a). Later in 1980, the Palos Verdes blue was officially listed as endangered (USFWS, 1980b). Three sites known to support Palos Verdes blues at that time were also declared critical habitat: Agua Armaga Canyon (No. 2), Frank Hesse Park (No. 3), and the switchbacks of Palos Verdes Drive East (No. 4). However, noAstragalus plants survive at these three sites today. A recovery plan for the species was approved by USFWS in 1984 but has not been implemented. This plan (Arnold, 1984) outlines procedures for protecting and managing known habitat sites. Unfortunately, no governmental or privately sponsored efforts are under way to protect or manage remnants of habitat to benefit the Palos Verdes blue. Thus, even if the butterfly is redis- covered, its long-term prognosis for survival is very poor. EL SEGUNDO BLUE Distribution and Habitat Requirements. Today the El Segundo blue (Figure 3) survives at only two small remnants of the El Segundo sand dune system: a sanctuary (0.6 ha) at the Chevron refinery in El Segundo, and a parcel (122 ha) at 42 the Los Angeles International Airport. Both lar- vae and adults feed on flowers of the seacliff buck- wheat, Eriogonum parvifolium (Polygonaceae). Although this buckwheat is a perennial shrub, it fares poorly where weeds, annual grasses, and ground covers have invaded dune remnants. Like the Palos Verdes blue, the El Segundo blue produces only one generation per year. Its flight season, which coincides with flowering of the buckwheat, begins as early as late June and can last into early September. In a case somewhat unusual among butterflies, all phases of this insect's life history and behavior are closely associated with its buckwheat foodplant, especially the flowers. The larvae of most butterflies feed on one or a few closely re- lated plant species, but adults generally obtain nectar from a variety of plants unrelated to the larval foodplants. Both the larval and adult El Segundo blue depend upon a single plant species for all of their nutritional requirements. Further- more, they are specialists, feeding only on the flowers. Clearly, dual dependence on the seacliff buckwheat greatly increases the butterfly's vul- nerability to habitat deterioration or loss. This dependence, however, also facilitates its conser- vation, as efforts at habitat management can con- centrate on increasing the numbers of flower - producing buckwheats. Decline and Current Status. As is the case for the Palos Verdes blue, the historical distribution of the El Segundo blue is poorly documented. Presumably the butterfly was found throughout much of the El Segundo sand dune system, wherever its buckwheat foodplant thrived. Due to the proximity to Los Angeles, these coastal dunes have been largely destroyed or altered by human activities: ur- banization, industrialization, highway construc- tion, sand mining, airport development and ex- pansion, and planting of ground covers, notably iceplant (Carpobrotus) and other landscape species that stabilize aeolian sands. Capture -recapture studies were conducted in 1984 at both the airport and Chevron dune rem- 9 is CJ • FIGURE 3. Photograph of an adult male El Segundo,blue nectaring on a flower of Eriogonum parvifolium. Illustrated are its ventral wing -surfaces. nants. Seasonal population numbers of adults were estimated at 750 at the airport and 420 at the Chevron refinery (Arnold, 1986). For the long- term maintenance of an insect producing just one generation per year, these numbers are precariously low. Population dynamics of the El Segundo blue are closely allied with those of the seacliff buckwheat. Survival of the butterfly is dependent upon (1) maintenance of prime -age buckwheat plants, which produce more flowers than younger or older plants, and (2) recruitment of younger plants to replace older, senescent individuals (Ar- nold and Goins,1987). Both dune remnants have been protected from human activity. Habitat quality has declined, however, as invading weeds and annual grasses have displaced established buckwheat plants and limited the success of seed- lings. Thus, the age composition of the buckwheat populations has gradually shifted away from the mixture of juvenile, prime -age, and older plants to be expected under more natural conditions. As the surviving buckwheats have aged, they have produced fewer flowers, causing El Segundo blue numbers to decline. Preservation Efforts. The El Segundo Blue has been recognized as endangered since 1976 (USFWS,1976). Chevron fenced its dune remnant and designated it a sanctuary for the species in 1975. In 1982, Chev- ron initiated a long-term management program to improve habitat quality at the sanctuary. Manage- ment efforts have focused on reducing weeds and increasing the numbers of young and prime -age buckwheats. Buckwheat seed has been collected at the sanctuary annually since 1982 and germinated under greenhouse conditions. Since then, ap- proximately 3,000 seedlings have been propagated and outplanted in five batches near the refinery. The status of outplanted seedlings is monitored annually to identify the causes of mortality and determine survival rates. Flower production of buckwheat at various ages is monitored, as well. In addition, butterfly larvae and adults are ob- served, in order to verify that they use the out - plants and to determine the age at which out - planted buckwheats are first used for food. Final- ly, larval and adult use of outplanted vs. resident (i.e. pre-existing) buckwheats is compared an- nually. Arnold and Goins (1987) describe these studies in greater detail, presenting preliminary findings from the first 4 years of the habitat management program. The results here update those findings. As a result of management efforts, the decline in El Segundo blue numbers appears to have been arrested, the numbers even increasing slightly as more and more outplanted buckwheats attain prime age and produce more flowers (un- published data). Buckwheat seedling mortality within the first 2 years after outplanting is typically greater than 50%, but surviving seedlings appear to thrive and flower profusely. El Segundo blue adults are observed perching and nectaring on the buckwheat as early as the second year of plant growth. It appears, however, that plants must be at least 3 or 4 years old before producing enough flowers for successful larval development. Meanwhile, pre-existing plants continue to be- come senescent, to produce few flowers, and to decline in numbers, and as flower production of the outplanted seedlings increases, a greater por- tion of observations of the El Segundo blue occur on outplanted buckwheats. Figures 4 and 5 illustrate El Segundo blue adult and larval use of outplanted and resident buck- wheat at the Chevron refinery since 1984. During the first few years of the project, most adult but- terflies and nearly all larvae observed were on resident buckwheats. Adults on outplanted buck - wheats were first observed taking nectar from flowers. In 1984, a year after the initial outplant- ing, only 14% of all butterflies observed were on the young flowering buckwheats (Figure 4). With each passing year, however, the numbers of adults and larvae on outplanted buckwheats have in- creased, while those on resident buckwheats have declined. In 1988, adult visits to outplanted buck - wheats (56%) exceeded those on resident buck - wheats (44%) for the first time since the start of the habitat management program (Figure 4). Lar- • 0 0 • 0 Buckwheat ...Resident ♦�� MON -- ����� �60 ►�i�i �i�i� i�i�i ��i� -�-� ►�i�i �i�i� i�i�i ��i� �i�i ►�i�i �i�i� �i�i i�i� �i�i ►�i��' �i�i� i�i�i ►�i�i �i�i� ��i�i ►�i�i� ►i�i�i WN ►i�i�i Oi�i !��i� i�i�i ►�i�i' ►i�i�i ►�i�i �i�i� i�i�i ►�i�i� ��i�i ►�i�i �i�i� i�i�i ►�i�i• ' �i�i ►�i�i �i�i� i�i�i �i�i� ��i�i i�i�i �i�i� �i�i �i�i• �i�i�i ♦�. ice♦ ♦�• ♦� i�• val use of outplanted buckwheats has lagged slightly behind adult use, as more flowers per plant are necessary to support larvae. No larvae were observed on any outplanted buckwheats in 1984, but by 1988 nearly 39% of the larvae observed were foraging on outplants (Figure 5). DISCUSSION Because of their exclusive occurrence in diminishing habitats of the Los Angeles metropolitan area and their obligate dependence on the flowers and seeds of their perennial larval food plants, both the Palos Verdes blue and El Segundo blue are highly susceptible to extinction. Populations of the Palos Verdes blue have existed at isolated patches ofAstragalus, a pioneer species that grows best in areas of recent localized distur- bance or in the early successional stages of the coastal sage scrub community. Similarly, popula- tions of the El Segundo blue occurred at patches of Eriogonum parvifohum, which is dependent on aeolian sand deposits for its establishment. Moreover, both Astragalus and Eriogonum are poor competitors, readily displaced by invading weeds and annual grasses. Under natural condi- tions, the location and number of foodplant patches change as new patches become estab- lished and older ones senesce or are outcom- peted. Thus, both butterfly species probably per- sisted as shifting mosaics of fluctuating popula- tions, opportunistically using localized but ephemeral patches of their foodplants rather than occupying any site permanently. The average lifespan of an Astragalus patch was probably no more than about 10 years while that of an Eriogonum patch might have been as long as a few decades, particularly if there was recurring distur- bance, which would allow periodic establishment of seedlings. As man has removed patch after patch of suitable habitat, and exotic plants have displaced more and more native vegetation in habitat rem- nants, the patch dynamics necessary for estab- lishment of new stands of Astragalus and Eriogonum have been disrupted, and butterfly numbers at remnant patches have generally declined. As the numbers of Astragalus have Ell declined at most remaining sites, the Palos Verdes blue has suffered localized extinctions. Further- more, as the number of Astragalus patches has decreased, distances between remaining patches have increased, and no rcolonization by the but- terfly was observed during field studies between 1979 and 1988. If it still survives, the Palos Verdes blue and its larval foodplant face dire circumstances. No in- dividuals of this endangered butterfly at any life stage have been observed since 1983. Between 1984 and 1986, numbers of Astragalus on the peninsula declined dramatically, from 328 to 80 (Arnold,1987; Table 1). Even though food plant numbers increased slightly in both 1987 and 1988 (Table 1), overall habitat quality is extremely poor, and the distances between the few remain- ing small patches of habitat are probably greater than the butterfly would normally traverse. From the poor quality of remaining habitat, it appears unlikely that any one patch of Astragalus could at this time sustain a viable population of the en- dangered butterfly. Thus the Palos Verdes blue could be the first of about 500 animals and plants in the United States supposedly protected under the Endangered Species Act to become extinct. Although the El Segundo blue persists at its two remaining sites, deterioration of its habitat threatens the butterfly. Vegetation management of the two remaining sites is critical for conserving the species. However, because weeds and annual grasses can very quickly reinvade and outcompete the buckwheat, sustained management will be re- quired indefinitely to maintain viable populations of the El Segundo blue. Fortunately, management efforts are under way at both the Chevron refinery and Los Angeles International Airport, although details of activities at the latter site are not yet public. Thus, the prognosis for long-term survival of the El Segundo blue is guardedly optimistic. LITERATURE CITED Arnold, RA. 1984. Palos Verdes Blue butterfly recovery plan. U.S. Fish and Wildlife Service. Portland, Oregon 46 pp. 0) e 0 0 r] Arnold, R.A. 1986. Studies of the El Segundo blue butterfly -1984. California Dept. of Fish and Game, Inland Fisheries Branch. Administrative Report No. 86-4. Sacramento, California 37 pp. Arnold, R.A. 1987. Decline of the endangered Palos Verdes blue butterfly in California. Biol. Conserv. 40:203-217. Arnold, R.A. and A.E. Goins.1987. Habitat en- hancement techniques for the El Segundo blue butterfly: an urban endangered species. In Adams, L.W. and D.L. Leedy, eds., Integrating man and nature in the metropolitan environment. Proc. Natl. Symp. on Urban Wildlife. Natl. Inst. for Urban Wildlife, Columbia, Maryland pp.173- 181. Barneby, R.C. 1964. Atlas of North American Astragalus. Mem. New York Bot. Gard. 13. 1188pp. Cooper, W.S.1967. Coastal dunes of California. Geol. Soc. Amer. Mem.104. Gales, D.M. 1974. Handbook of wildflowers, weeds, wildlife, and weather of the Palos Verdes Peninsula. Calligraphics. San Pedro, California 214 pp. Perkins, E.M. and J.F. Emmel. 1977. A new subspecies of Glaucopsyche lygdamus from California (Lepidoptera: Lycaenidae). Proc. Ent. Soc. Wash. 79: 468-71. U.S. Fish and Wildlife Service.1976. Determina- tion that six species of butterflies are endangered species. Federal Register 41: 22041-22045. U.S. Fish and Wildlife Service. 1978. Proposed endangered or threatened status or critical habitat for 10 butterflies or moths. Federal Register 43: 28938-28945. U.S. Fish and Wildlife Service.1980a. Proposed rule designating critical habitat for the Palos Ver- des Blue butterfly. Federal Register 45:19860- 19861. 47 U.S. Fish and Wildlife Service.1980b. Listing the Palos Verdes Blue butterfly as an endangered species with critical habitat. Federal Register 45:44939-44942. ACKNOWLEDGEMENTS I thank the Wildlife Permit Office of USFWS and California Department of Fish and Game (CDFG) for research permits. Various contracts with CDFG, USFWS, and Chevron, USA partially funded these investigations, which were under- taken while th. author was a research associate with the Entomology Departments at the Univer- sity of California, Berkeley, and the Los Angeles County Museum of Natural History and Science. I also thank the Natural History Foundation of Orange County for financial support to par- ticipate in the symposium at which this paper was presented. MANAGEMENT OF THE WINTER FORAGING HABITAT FOR CANADA GEESE AT QUAIL HILL by Peter A. Bowler, Fred M. Roberts, Jr.2 and John Simon 1Director, Cooperative .Outdoor Program, Stu- dent Activities Office, and academically affiliated with the Department of Ecology and Evolutionary Biology, University of California, Irvine 2Museum Scientist, Museum of Systematic Biol- ogy, University of California, Irvine 3Administrative Aide to City of Irvine Mayor Larry Agran, City Hall, Irvine ABSTRACT As part of its open space plan, the City of Irvine has preserved a winter foraging area for migrating Canada geese (Branta canadensis moffitti and B. c. tavemeri) at Quail Hill, an area supporting flocks of 2,5W to 4,150 birds. In years when there is sufficient rainfall to allow grass and annual herbs to germinate and to produce a forage base, the geese use this grassland area between late November and mid -March; the site is grazed by cattle in winter. The grasslands are predominantly of two types: the first consists of non-native gras- ses mixed with low, weedy species such as filaree (Erodium spp.) and burclover (Medicago polymorpha); the second has a higher density of grasses and is dominated by foxtail fescue (Yulpia myuros). Of the 67 vascular plant species in 22 families, 29 species are introduced. The preferred goose -forage plants have occurred primarily in the first grassland association and include burclover, red -stemmed filaree (Erodium cicutarium), long -beaked filaree (E. botrys), slender wild oat (Avena barbata), and wild barley (Hordeum murinum). Recommended manage - 48 meat strategies for the site include curtailing the further spread of the non-native cardoon, or wild artichoke (Cynara cardunculus). INTRODUCTION Quail Hill lies between Sand Canyon Road and the University Drive southern onramp to the San Diego Freeway (I-Q5). It is approximately 1.5 km from Sand Canyon Reservoir, adjacent to Ridgeline Drive in Irvine. The area grazed by the geese comprises 250 to 300 acres (100 to 120 hectares) (Nelson, 1986) between the San Diego Freeway on the north, Sand Canyon Road align- ment on the east, University Drive on the west, and the Quail Hill ridgeline on the south. The broad, sloping flat at the base of Quail Hill has supported a large population of overwintering Canada goose subspecies for many years. The nearby Sand Canyon Reservoir, a 47-acre impoundment constructed in 1942 and owned by the Irvine Ranch Water District, provides aquatic habitat for these migratory flocks. They spend the nights on the impoundment, departing for diurnal foraging areas after daylight but before actual sunrise, usually between 0630 and 0730. Accord- ing to Nelson (1986), aggregates of birds ranging from a few to hundreds leave the reservoir every few minutes for up to an hour and a half after daylight. The birds return to the reservoir after sunset but before dark. While there have been relatively few studies on the geese using this area (the data base comprises personal communications from Dan Ypar- raguyirre, Carl Wilcox, Jack Fancher, other agen- cy representatives, and the research by Nelson, 1986), this is one of the larger regional winter stopover areas in Southern California. Other regional sites, each supporting several thousand 0 C: • 0 C� migratory birds, include the Seal Beach Weapons Reserve and, on the Santa Ana River, the riparian habitat behind Prado Dam. The Quail Hill - Sand Canyon Reservoir flocks vary from year to year in number of birds, from approximately 2,500 in- dividuals in 1986 (Nelson, 1986; Table 1) to a high of 4,150 on 27 January 1988 (Fred Worthley, Department of Fish and Game, 1988). The geese usually arrive in early -to -mid -November, reach their greatest numbers in January or February, and decline in concentration until mid -March, when all have migrated elsewhere. Two subspecies have been recorded from the site: Branta canadensis mqffitti, breeding in the Great Basin and comprising approximately 90% of the birds, and B. c. tavemeri, a subspecies breed- ing in the interior of Alaska. Both are dramatical- ly present in enormous numbers very close to the San Diego Freeway along the base of Quail Hill and have been the subject of intense local public interest. A few snow geese also graze at the base of Quail Hill with the Canada geese. This significant migratory bird population on eminently developable lands presents substantial TABLE 1. Counts of Canada Geese on Quail Hill from January through March, 1986 (Nelson, 1986). Date of Count No. of Geese counted' Jan 5 1200 Jan 19 2500 Feb 8 2500 Feb 17 1500-20002 Feb 22 22003 Feb 23 2000 Mar 8 2200 Mar 15 20 1 Counts reflect estimates only, due to the dif- ficuly of making close observations of all geese in the study area at the same time. 2 Observation difficult;150 counted at Laguna Reservoir 3 40 counted at Laguna Reservo"K-i. 49 management challenges, especially since land use adjacent to Sand Canyon Road has transformed a great deal of former goose habitat into row -crop agriculture, eliminating it for foraging. Laguna Reservoir and the land surrounding it were formerly used by geese (Nelson, 1986). However, Laguna Reservoir will be drained and developed, and the lands around the lake are already un- usable by geese due to agricultural expansion in the last few years. Though these sites were not as intensively used as Quail Hill, the habitat lost is more than twice that remaining, leaving a greatly restricted local foraging range. Negotiations between the City of Irvine and The Irvine Company resulted in an Open Space Plan for the City of Irvine, which was embraced by the voters in spring 1988 and became law in July of that year. Included in the open space legislation was permanent protection for the Quail Hill foraging area and lands adjacent to Sand Canyon Reservoir. This was a tremendous victory for the Irvine public, and there is every promise that over - wintering geese will remain a visible part of local natural history. Moreover, the Irvine City Council is addressing the problem of managing all of the city's open space, with special emphasis on sensi- tive natural -resource areas such as Quail Hill and Sand Canyon Reserve (Agran,1988). Nonetheless, management challenges remain. From the little access we have been allowed to the site, we will outline briefly some of the emerging problems. Quail Hill, the primary foraging area, has an open topography, with good visibility for long dis- tances that_ precludes surprise attacks by predators. It has been grazed for many years, and parts of it were probably cultivated in the past. Obviously, however, there is still an excellent forage base for geese. What the Quail Hill geese eat is a fundamental question not answered by the Nelson (1986) study or through casual observa- tion. It also remains to be determined how the current, apparently attractive condition can be maintained to optimize continued use by geese; and whether cattle grazing interferes with use by geese, or, rather, if it prevents ecological succes- sion in the plant community that would alter con- ditions unfavorably for the birds. FIELD OBSERVATIONS On -site observations were made between 0900 and 1430 on 21 January 1988, when goose numbers were near their maximum, and again on 14 April 1988, after the geese had departed. In lieu of access to the site, an additional off -site sweep with binoculars in early March censused grass species not easily seen during the January survey. Fred Roberts (UCI Museum of Systematic Biology), John Simon (City of Irvine), and the senior author conducted the surveys. The results are shown in Table 2. VEGETATION The Quail Hill site is predominantly grassland, with scattered shrub -dominated areas on Quail Hill and on the flat just beyond the ravine mouth. The grassland species are mostly non-native, dominated by introduced European species such as wild oat (Avena barbata), brome grasses (Bromus &andrus and B. rubens), and wild barley (Hordeum murinum). Wild artichoke (Cynara cardunculus) is abundant and in places dominant throughout the low-lying areas extending up onto the hillsides. There are two basic types of intro- duced grassland at this site. The first is a hodgepodge of non-native grasses mixed with low, weedy species such as filaree (Erodium spp.) and burclover (Medicago polymorpha); the second community has a higher density of grasses and is dominated by foxtail fescue (Vulpia myuros). The rock outcrops on Quail Hill have small rem- nant stands of coastal sage scrub (a low, open shrub cover) dominated here by California buck- wheat (Eriogonum fasciculatum) and California sagebrush (Artemisia califomica); the sagebrush, in particular, spreads and thins as it penetrates the grassland. Other shrubby species include coast goldenbush (Isocoma veneta), found in patches on Quail Hill and on hills to the east. In the lowlands adjacent to the San Diego Freeway, mulefat scrub dominates the flat to the 0 west of the ravine, indicating subsurface moisture of at least seasonal runoff. Subsequent observa- tion has confirmed that agricultural runoff occurs throughout the summer, and it was still present in October when this paper was prepared. The mulefat scrub is dominated almost entirely byBac- charis salicifolia (S. glutinosa), with scattered patches of prickly pear cactus (Opuntia sp.) and species intruding from the surrounding grassland. Introduced species dominate the site, and during the field surveys no rare or locally sig- nificant species were observed Of the 67 vascular plant species we identified at Quail Hill, 29 were introduced. There is much evidence that the en- tire site, with the exception of Quail Hill itself, has undergone a great deal of disturbance, with a subsequent reduction in native species diversity. It is probable that the entire area was once cul- tivated. The area has recovered substantially, but further restoration is hampered by seasonal cattle and goose grazing. The flat to the west of the ravine mouth is studded with old tree trunks, in- dicating that at least part of the site was at one time an orchard. PRIMARY FOOD PLANTS FOR THE GEESE Most foraging occurred in low-lying areas, but grazed sites continued two-thirds of the way up both Quail Hill and the hill face to the east. The birds also fed in the valley between Quail Hill and the eastern series of hills, in a position more or less behind and south-southeast of Quail Hill. The geese sometimes grazed within 20 yards of Sand Canyon Road, the San Diego Freeway or Univer- sity Drive. All of these areas are dominated by non-native grassland, with a high percentage of non -grass species. The geese tended to avoid rock outcrops, shrubs, artichoke plants, and large, robust herbs. The geese were observed feeding on the broad- leaved annual grasses, such as wild barley and bromes, and several weedy species, particularly the filarees and bur clover. The grasses and weedy plants of grazing areas are strikingly different from those in cactus or artichoke patches, where the geese are reluctant to feed. Wherever these 0 0 TABLE 2. Plant listings for the Quail Hill site based on 21 January 1988 and 14 April 1988 site visits (adapted from Bowler, 1988). A, abundant; C, common; F, frequent; L, local and restricted; O, occasional; R, rare; r, found among rock outcrops; *, introduced or naturalized. FAMILY NAME SPECIES NAME Primary Goose Food Plants Observed at Quail Hill: Fabaceae Medicago polymorpha Geraniaceae Erodium bovys E. cicutarium Poaceae Avena barbata Hordeum murinum General Plant List for Quail Hill Site: Amaryllidaceae Apiaceae Asteraceae Brassicaceae Cactaceae 0 Dichelostemma pulchellum Bowlesia incana Daucus pusillus Sanicula arguta Anemisfa califomica Baccharis salicifolia (B. glutinosa) Cab cadenia tenella Cynara cardunculus Ericameria pachylepis (E. palmed) Filago gallica Grindelia robusta Hemiaonia fasciculata Heter otheca grandiflora Hypochoeris glabra Isocoma veneta Senecio vulgaris Sonchus asper Xanthium strumarium Brassica geniculata B. nigra Descurainia pinnata Lepidium lasiocarpum L. nitidum Opunda sp. 51 X0kyj 13 (4)41%1Ell 31 *Burclover *Long -Beaked Filaree *Red -Stemmed Filaree *Slender Wild Oat *Wild Barley Wild Hyacinth Bowlesia Rattlesnake Weed Sharp -Toothed Snakeroot California Sagebrush Mulefat RELATIVE ABUNDANCE C O C-A C C O LOr O O LC LC -LA Rosinweed O *Wild Artichoke C Palmer's Goldenbush O *Narrow -Leaved Filago Big Grindelia (Gum 'plant Fascicled Tarweed Telegraph Weed *Smooth Cat's-Ear Coast Goldenbush *Common Butterweed *Prickly Sow -Thistle Cocklebur *Short -Pod Mustard *Black Mustard Western Tansy Mustard Hairy Pod Peppergrass Shining Peppergrass Prickly Pear Cactus O O F O C O-LC O R LC O F LOr O O C TABLE 2 (continued). Caprifoliaceae Caryophyllaceac Chenopodiaceae Convolvulaceae Crassulaceae Cucurbitaceae Euphorbiaceae Fabaceae Geraniaceae Hydrophyllaceae Malvaceae Nyctaginaceae Plantaginaceae Poaceae Polygonaceae Scrophulariaceae Solanaceae Sambucus mcdcanus Silene gallica Spurgula arvensis Atn'plex semibaccata Chenopodium murale Salsola aus&Wis Calystegia macrostegia Convolvulus arvensis Crassula connata Cucurbita foetidissima Marah macrocarpus Chamaesyce polycarpa Lotus scoparius Lupinus bicolor L. succulentus L.truncatus Medicago polpnorpha Erodium botrys E. cicutanum E. moschatum Phacelia cicutaria Malva parvif fora Mirabilis califomica Plantago erecta Avena barbata Bromus diandrus B. hordeaceus B.rubens Distichlis spicata Lamarckia aurea Lolium perenne Melica inWrfecta Stipa lepida Hordeum murinum Vulpia myuros Eriogonum fasciculatum Polygonum avicukm Rumex crispus Antirrhinum nuttallianum Orthocarpus purpurascens Scrophularia califomica Nicotiana glauca 52 Mexican Elderberry *Windmill Pink *Corn Spurry *Australian Saltbush *Nettle -Leaved Goosefoot *Russian Thistle S. Calif. Morning Glory *Field Bindweed Sand Pygmy-Stonecrop Calabazilla (Wild Gourd) Wild Cucumber Golondrina Deerweed Miniature Lupine Arroyo Lupine Collared Lupine *Burclover *Long -Beaked Filaree *Red -Stemmed Filaree *White -Stemmed Filaree Caterpillar Phacelia *Cheeseweed Wishbone Bush California Plantain *Slender Wild Oat *Ripgut Grass *Soft Chess *Foxtail Chess Saltgrass *Goldentop *English Ryegrass Small -Flowered Melic Grass Foothill Needlegrass *Wild Barley Foxtail Fescue California Buckwheat *Common Knotweed *Curly Dock Nuttall's Snapdragon Red Owl's Clover California Figwort *Tree Tobacco O R O O O O Or F C O Or Or LO O C O C O C-A O R O Or LF C C C LO O O LOr F C C Cr O O Or C Ur O 0 0 11 • s • petcta some, do tm asd bmbs m %V aid weddeveiops4 edmwise theyarelawaid sesty Owed as imm id to the hems of 1 imL Tie peas WE set put their beads lets or usder do aeaepiadmttI' A 1pfamigdolt,areesishebited by wdelkows ass. hu t io the peeee. Aracnedi■tenespoem h l " jwaadwb* cropped class to do gronad. VAmem do Blareabre+elorer type of bmroduoed grasdtnd rm�ss replaced by fesese t� pm ieeeeased dramsticaly. This is idooy dose to the sac Ws mossrowU2 which mq be vmWwesdmg to the pease, aid abo to the reduction is atmmbet efS es asdbwdlorerphab. Twepeeseavoided hipint (L*bw Owrrcou andL bkoiw). To asoorasm the pone to keep retrrsim k b aasmetid to pow the Qwi! Hill area r it it, tram said Canyon Road to vary Drive aid b do ri f t tope of the sou hers bML Henry tulomobile to dSc does sot sees to bother the pesos; dry appear to tolerate attic pasiap star. fby but ado way wisp of bumms approaching as leosiedb tit peees sre supported by An that segmmirs I& staronal Sawbame, such as pmkr,. sr k sue llle�rawould mewdly be ao+rdedoot. T►oa wady species are avideady oms of the &a. turn drawbg pem to die sits. Toe pone dow Nam perform a stroeg grazing isdreaos so twit aft se Wad be seoema) to maiawk tie die in beFeent klsM* dug F-fBrw sun by do p m retse+do flowsrlog asd seed set. Uafwtwatey, grazing also encourages ar- detoke to spread, both diaooarsgiag the geese ad pndwlly eibmi m6m the grasslmW on which they depend. Artiatoke hat boa pral k - Ming ww MW removal becoiim g � Lmaeae6mgb int. peetaat,sinktl imcdveyaa dsdespeathomeits areas Of domim"L Rommel of toe wdcb lot should be t000mmplisted is two sprig, after Go Pose bm I F The upper areas dthe W prdmlariy wood loci orteeupa, world be sdtmbit ter dr sselmes. ties d s+oastal up scrub pluft dug bees bees aetiepegd by oretpadmeg. As pert of tie mMys- dnfor Wmewn devielopse■e, portio■s di Out Hilsiee siould be c o mid, ed for csvapste tioiwith aysidcant ad ssk" laths pW& Acamto the site byreaemiers isfodame" so *9 graadtstive aid oosmsisteaty domed itt an be vied ii forming and sy:tearsticas vp W- ddMe on the oa ofanmbe: lib smmbspocia; quantitative dxamaKetioi d phr�t fora/. species (nor urines soase eadc�sura seteaea� wH sin be aeeded�, and deteemiamtios at i soed, or Lck dseed, for catdt prolog: Ab % m mmsionaly used portios of do LO coWu behisd toe Farm school Is doed In devsiopmemt. Tice potertisl loss serif w br ter sewed. Usdoubtedytwertareaisirie A% iifrequesdy reed by the pees., fist area/ be arabsted of st addii"imd obseevstioa ad err seatA Tit amub" losses dLapst Rteee` Moir tad tlt former prasahsd, tabW bMm Lapsra Curs Road aid said Caeyos Md taus focused migratory pools torapiap as anti His. A better uiderstmk ft is seeded of les fi+epeaty used @ML Is. addition, amessmeat mret be ands of i impact. of 8400M team activity: doe itle"m raw -crop sptkWhu,4 WA perseasest bones process alomg the Sand Canyon alipnaemt; do planned residential deMelopmeat umby; aid the proposed pelf comae on the Ph se IV sun d Mason Rapiomd PWL As redde■dal devdo'. memt and Sand Canyon Road era mlesded bAm4 aptiwkwd use of 040CM Inds wE be phmtieml out. hie iaap,t dwt .seitfptlrs metererr (r+s�p sadMo ple■s.p dteelies oomaer to avoid pose d awbom) we ssoo wM In amsiocatismj tws hmpacts ddeeeiopmeat. The proposed golf course below the Sand Canyon Reservoir Dam must be carefully con- sidered beforehand, not only because of its nega- tive impact on the goose population, but also because grazing geese could become a significant problem on the golf green itself. "Nuisance geese" on golf cow ses are a well -documented and serious concern (Conover and Chasko, 1985; Waldman, 1989). Clearly there are many other research needs, but little can be accomplished until access is granted. Management Goals A management plan is essential, with funding to manipulate the habitat as necessary. Although we have had little access to the site, several manage- ment needs are apparent. Artichoke removal is increasingly important. Local conservation groups and the UCI (Univer- sity of California at Irvine) Cooperative Outdoor Program have volunteered labor for this, but were also denied access throughout the 1988 spring and summer. This would be an excellent community service project for such groups after the geese have left the site in the late spring. Hillyard (1987) has developed a successful artichoke -removal methodology at similar habitats in Crystal Cove State Park. It is vital to maintain the plant associations preferred by the geese. Preventing successional change on the forage sites is central to providing the geese with the forage needed to remain at the Quail Hill site. Also, with irrigation runoff from the newagdcul- ture areas along Sand Canyon Drive, Bacchads has proliferated along the base of the forage area. Ideally, nutrient -laden runoff is controlled at its source, but this may not be feasible here. If not, rather than flowing into the goose -forage area en route to the flood -control channel, agricultural runoff should be piped directly into the channel. Maintaining Sand Canyon Reservoir as a habitat suitable for geese will require periodic dredging. The retention of water adequate for Canada geese during the winter months is critical. The coastal sage scrub community should be restored along the bluffs and on the face of Quail Hill. This is an important native component needed amid an otherwise introduced flora. ACKNOWLEDGEMENTS We thank Irvine Mayor Larry Agran and City Councilperson Cameron Cosgrove for their en- thusiasm, support and enlightened commitment to preservation of the Quail Hill and Sand Canyon Reservoir Canada goose habitat. Michael Le- Blanc and Dean Bushinger of The Irvine Com- pany allowed us to visit the site twice, for which we are grateful. The Conservancy, an Irvine -based conservation group, and the UCI Cooperative Outdoor Program sponsored several "goose watches" during the 1988 winter season, which allowed careful observation of the geese and enabled us to inform interested citizens about the natural history of this site. The Irvine City Council is to be complimented for addressing the issue of habitat maintenance on Quail Hill and the sig- nificance of the geese as a natural heritage resource at three city council meetings. LITERATURE CITED Agran, L. April 26,1988. Quail Hill Geese and Wildlife Preserve, Agenda Item No. 20. City of Irvine Council Meeting. Bowler, P.A. April 26,1988. Letter to the Irvine City Council. Conover, M.R. and G.G. Chasko. 1985. Nuisance Canada Goose Problems in the Eastern United States. Wildl. Soc. Bull.13:228-233. Hillyard, D. 1987. Artichoke Thistle Control, Crystal Cove State Park. Unpublished Major Capitol Outlay Project Status Report for Crystal Cove State Park. 0 0 Nelson, S. June,1986. On the Use of Quail Hill by Wintering Canada Geese (Branta canadensis). Unpublished report prepared for Community Planning Services, El Toro, California. Waldman, P. 1989. The Canada Goose is a birdie golfers don't appreciate. Wall Street Jour- nal, Jan. 6,1989. Worthley, F. March 14, 1988. Letter from California Department of Fish and Game Region 5 Manager to John Simon. • C] 55 THE STATUS OF WINTERING CANADA GEESE AT QUAIL HILL* by Robin Butler 833 Stanley Ave., Apt. 1 Long Beach, CA 90804 ABSTRACT The Quail Hill/Sand Canyon Reservoir area in Irvine is an important wintering ground for two subspecies of Canada geese, Branta canadensis moffitti and B. c. tavemeri. Except for a flock at Seal Beach in 1986, this is the only population of Canada geese wintering recently in Orange Coun- ty. The birds roost at the reservoir and forage during the day at Quail Hill and several other nearby sites. Urbanization has destroyed most nearby goose habitat and potential habitat, and continued alteration or destruction by develop- ments, some already proposed, could seriously affect the population. From 4,1M geese in 1988, the population declined to 1,350 in 1989, possibly from habitat loss here or from changing condi- tions along migration routes. Management of the area should include preserving the known roost- ing and feeding sites, eradicating invasive exotic plants, restricting places and times for public ac- cess, and weighing the potential impact of proposed developments nearby. Banding and tagging should be initiated to allow monitoring and in-depth investigation, and foraging preferen- ces should be determined. INTRODUCTION Quail Hill and the adjacent Sand Canyon Reser- voir form an important foraging area for a winter- ing population of Canada geese. Two subspecies have been observed there, Western, or Great Basin, Canada geese (Branta canadensis moffitti) • Prepared for the Irvine City Council; April 1989 66 and Taverner's Canada geese (B. c. tavemeri), the former more common. Canada geese in North America are divided into twelve subpopulations, based on their primary regions of breeding and wintering (Bellrose, 1980). In addition, there are eleven subspecies, or races, differentiated by size, coloration, variations in vocalization, and location of breeding areas (BeUrose, 1980). Canada Geese wintering in Southern California are part of the intermountain population, consisting mostly of B. c. moffitti. The subspecies breeds throughout central and southeast British Columbia, Washington, Oregon, northern Utah and Nevada, and northeast California. Primary wintering areas for this population include central California, western Nevada, Washington, and Oregon (Hanson,1965; Bellrose,1980). The Western Canada goose is distinguished from other subspecies by its relatively light colora- tion and its large size, males averaging 10 lb (4.5 kg). The Taverner's Canada goose averages 6 lb (2.7 kg) and has a darker back and breast (Yocum, 1972). The Sand Canyon Reservoir/Quail Hill popula- tion of Canada geese is one of only two groups wintering recently in Orange County (Nelson, 1986). The number using the study area is believed to have increased between 1976 and 1986, although no figures are recorded (Nelson, 1986). Another flock, of approximately 2,000 geese, wintered on the Seal Beach Naval Weapons Center in 1986 (Nelson, 1986). Because of the importance of this area towinter- ing Canada geese, the Irvine City Council is con- sidering plans for future management of the Quail Hill area (Bowler et al., 1988). Although as a species Canada geese are not threatened, in- creased habitat destruction has altered and reduced historic wintering and breeding areas. is 0 0. Continued urban development and agricultural expansion threaten many small regional popula- tions that may be forced to seek less disturbed areas for feeding and nesting. The purpose of this study was to census Canada geese: intering in Irvine and to identify sites of primary use for foraging and night-time roosting. It was not a comprehensive study of the Sand Canyon Reservoir/Quail Hill Canada goose population, but was designed to add to the baseline data for this population and to help pro- Nide a basis for future investigations and manage- ment. STUDY AREA The principal area of interest, Quail Hill, covers approximately 100 to 120 hectares (ha) located north of Sand Canyon Reservoir in Irvine, Califor- nia (Figure 1). This area, between the Sand Canyon Avenue and University Drive exits of In- terstate-405 (San Diego Freeway), was until recently mostly pasture. The Quail Hill area and land extending south along the eastern side of the Sand Canyon Reser- voir are owned and managed by the Irvine Com- pany. Cattle grazed on all parts of the study area during our census. Non-native grasses were the dominant plants, presumably as a result of past cultivation and disturbance (Bowler et al.,1988). Wild artichoke (Cynara cardunculus), an invasive exotic species, has multiplied rapidly over the past several years (Fred Roberts, Universityof Califor- nia at Irvine, personal communication). Sand Canyon Reservoir, managed by the Irvine Water District, is a 19-ha impoundment bordered on the west by the Turtle Rock housing develop- ment and by Irvine Company land on the south and east. Other areas included in the study's regular census route were the Laguna Reservoir, William Mason Park and adjacent golf courses, the San Joaquin Marsh Wildlife Refuge, Upper Newport Bay, and other pasture or cultivated fields between Sand Canyon Reservoir and Upper Newport Bay. METHODS AND MATERIALS Counts and searches were conducted at various times of the day between 14 January and 19 March 1989. Direct observations were made with 7 X 35 binoculars and a 20X spotting telescope. Weekly dawn counts were made at Sand Canyon Reser- voir. In addition, the other likely foraging areas were checked for geese. Weekly observations at Sand Canyon Reservoir typically began a half hour before the first morning light. Counts were made as relatively small groups FIGURE 1. Canada goose wintering areas in Irvine, California, 1989. A, Sand Canyon Reservoir; B, Quail Hill; C, Laguna Reservoir; D; William Mason Park; E, San Joaquin Marsh Wildlife Refuge; F, Upper Newport Bay. A and B were the primary foraging sites of wintering geese in 1989. 57 of geese flew off the reservoir to foraging sites. By beginning observations before departure and con- tinuing until all geese were gonce, we believe fairly accurate counts were obtained, more so than from those counts made when the entire population was dispersed, moving and foraging across the fields. RESULTS AND DISCUSSION Census The Sand Canyon Reservoir/Quail Hill popula- tion peaked at approximately 1,350 geese between 29 January and 12 February (Table 1). Since this study was not initiated until mid -January, the ar- rival date of the geese in Orange County is not known. Previous studies, however, have sug- gested that arrival on wintering grounds occurs mid -November (Nelson, 1986; Garrett and Dunn, 1981). Departure of the majority of the popula- tion occurred between 27 February and 3 March, after which approximately 50 geese remained in the area. By 8 March, just three geese were left. Peak numbers were significantly lower than those previously reported. Nelson (1986) ob- served high counts of approximately 2,5W geese in the same study area in 1986. The 1988 census of the California Department of Fish and Game recorded a high of 4,150 geese (Bowler et al., 1988). The decline in the 1989 winter population could reflect several factors. The entire study area was used for cattle grazing at times between January and March. Whether the presence of cattle ad- versely affected goose foraging is unknown. How- ever, geese were observed actively feeding in the vicinity of cattle several times and did not appear disturbed by their presence. Cattle grazing may have reduced the availabilty of forage crops if they fed on the same plant species as the geese or if the cattle trampled or destroyed preferred forage plants. Loss of other nearby wintering habitats may also explain the reduction in numbers of Canada geese in 1989. Agricultural expansion between Sand 68 Canyon Avenue and Laguna Canyon Road has caused geese to abandon historic goose -foraging areas (Nelson, 1986). Sand Canyon Reservoir was the only night -resting area used by geese in 1989, although Nelson (1986) had previously identified Laguna Reservoir as a secondary night -resting area. New farms and a new tree -and -shrub nurs- ery probably disturbed the habitat enough for the geese to abandon the area. Garrett and Dunn (1981), who attributed the decline of California bird populations mainly to habitat loss or altera- TABLE 1. Counts of Western Canada Geese in the Sand Canyon Reservoir/Quail Hill area of Orange County, California, 1989 Date of Count No. of Geese Observed 14 Jan 9352 15 Jan 4182 18 Jan 7852 19 Jan 03 21 Jan 1,1022'' 26 Jan 28 Jan 1803 29 Jan 1,3301 04 Feb 94e 06 Feb 703 10 Feb 313 12 Feb 1,3501 19 Feb 2503 20 Feb 1,045' 25 Feb 1,0301 26 Feb 6003 03 Mar 513 08 Mar 31 'Numbers are believed to reflect accurate counts of all geese in the Sand Canyon Reservoir/Quail Hill population. 2Census figures reflect incomplete counts result- ing from departure of some geese from Sand Canyon Reservoir before observations began. 3Census figures underestimate the population as a result of unlocated foraging flocks, incomplete searches, or both. i 0 • • tion, noted a general decrease in the numbers of wintering birds the state's coastal slope since the early 1900s. In 1989, groups of only 30 to 50 geese were observed at other Orange County sites, in- cluding the Bolsa Chica wetlands in Huntington Beach; the agricultural fields at the Seal Beach Naval Weapons Center, where 2,000 Canada Geese were recorded in 1986 (Nelson,1986); and Rattlesnake and Siphon Reservoirs in the El Toro area (Esther Burkett, personal communication). Other possible explanations for the reduced population were unusual weather and habitat con- ditions along the migration corridor. Mild weather in northern locations may have allowed geese to obtain food where, normally, low temperatures and snow cover make this impos- sible. Other researchers have found that weather conditions affect timing of migration onset and migration patterns (Koerner et al., 1974; Grieb, 1970; Craighead and Stockstad, 1956). Utah, a possible breeding area for the Irvine geese, ex;, perienced a mild fall followed by an early winter, with snow and low temperatures. All geese left the breeding area after the snowfall (Tom Aldrich, Utah Division of Wildlife Research, per- sonal communication). Aldrich, reporting large numbers of geese in Arizona, suggested that some geese may have overwintered in Arizona rather than completing the migration to Orange County. "Short -stopping," remaining at areas along the migration route, is a fairly common phenomenon among other migratory populations of Canada geese (Raveling,1978). Raveling (1978) also noted that geese respond to creation or restoration of habitat along migration routes, altering typical timing or paths of tradi- tional migrations. Bellrose (1968) suggested that the ability of geese to adapt to new refuges and new foraging areas had resulted in dramatically altered migration routes, and he predicted that changes would continue to occur. To what degree any of these possible explana- tions were a factor in the low numbers of the 1989 Canada goose population in Irvine remains un- known without further investigation. 59 Locations of Night -Resting and Foraging Sites As mentioned above, Sand Canyon was the only Orange County night -resting area for Canada geese in 1989. After morning departures from the reservoir, the majority of the flock flew directly to pasture fields along the north side of Quail Hill, between the University Drive and Sand Canyon Avenue exits of Interstate-405. This (Figure 1) was the most heavily used foraging site. Several times, small flocks flew south and southeast from Sand Canyon Reservoir to pasture fields and hillsides along the southeast edge of the reservoir (Figure 1). This group may have been a subflock made up of family groups; family unity in wintering populations and loyalty of family groups to traditional foraging sites have been well docu- mented in other populations (Raveling, 1969a; Raveling, 1969b). Other daytime foraging areas included an abandoned crop field at the San Joa- quin Marsh Wildlife Refuge (on the northeast side of Campus Drive) and, once, the Rancho San Joaquin Golf Course (at the comer of -University Drive and Harvard Avenue) (Figure 1). Twice, flocks of 30 geese were observed at mid -day at Upper Newport Bay (Kevin Cavanaugh, Environ- mental Field Studies Program, Orange County Department of Education, personal communica- tion). And on several mornings, flocks departed from the south end of the reservoir, and flew west between the hills. We could not determine their destinations, but the San Joaquin Marsh Wildlife Refuge and Upper Newport Bay are in that general direction. Movements of foraging geese during the day were not well followed. Since not all geese were readily seen during mid -day searches, some secondary foraging sites were probably over- looked. At least some geese returned to the reser- voir during the day to rest and forage nearby. From physical evidence in the field and from several later observations, it seems likely that hillside pastures east of the reservoir's south end (Figure 1) were important foraging sites. Daily Activity Patterns Daily activity patterns were consistent with those observed by Nelson (1986). Geese spent the night along the shorelines of Sand Canyon Reservoir, and as the sky grew light, groups congregated out in open water. At the same time, vocalizations and wing stretching occurred. Within ap- proximately 30 minutes the first flock of geese took flight, the initial departure triggering others until all were gone. The last departure took place 20 to 45 minutes after the first. Between 2 and 125 birds made up each flock. Other investigators have reported correlations between weather con- ditions (e.g., the amount of cloud cover and temperature) and the time and duration of morn- ing departure. According to Raveling et al. (1972), overcast skies delay the time of the first departure and extend the duration of the sub- sequent departure period. The geese spent most of each day foraging in pasture fields, but some daytime movement oc- curred between the foraging sites and the reser- voir. As observed by Nelson (1986), returning flights of varied -sized flocks began at sunset and continued into darkness. Tagged Geese Memy Sand Canyon Reservoir/Quail Hill geese had leg -bands, probably attached at their nesting grounds. Unfortunately, it was not possible to read the numbers on the leg bands. One goose, bearing a yellow plastic neck collar with black coding YC38, had been banded, neck -collared and identified as an immature female on nesting grounds in Farmington Bay, Utah (at the south end of the Great Salt Lake) in June 1988 (Tom Aldrich, personal communication). As geese generally exhibit a high degree of cohesiveness to their regional flocks, it is probable that a number of the Sand Canyon Reservoir/Quail Hill geese came from the same nesting area of Utah. MANAGEMENT The Sand Canyon Reservoir/Quail Hill area sup- ports a relatively large population of wintering Canada geese because it can provide both a night - resting site and adequate nearby foraging areas. These geese represented the only significant wintering group in Orange County in 1989 (Esther Burkett, personal communication). As wintering populations of Canada geese have been declining on California's coastal slope (Garrett and Dunn, 1981), the preservation of even small flocks is vitally important. The relatively undisturbed reservoir, with its restricted public access and large expanses of nearby open space, offers refuge and food for wintering geese. However, the ap- parent decline in the 1989 population may be a response to increased urban development and habitat loss to agriculture. Proper resource management of the Sand Canyon Reservoir/Quail Hill area is essential if the area is to continue supporting wintering Canada geese. In addition to providing habitat for Canada geese, this area supports other wild birds, includ- ing ducks and waterfowl, ospreys, raptors, warblers, and cormorants. Two white pelicans, unusual in Southern California except at the Sal- ton Sea, were observed using the reservoir for at least 2 weeks. The area is, indeed, an important resource for Orange County wildlife at a time when open space and green corridors in urban areas are rapidly disappearing. Continued alteration or destruction of habitat in the study area could seriously affect the over. wintering goose population. Restriction of public access to forage sites and to the reservoir from mid -November to late March is essential for minimizing disturbance of goose flocks. Proposed developments, such as golf courses on the study areas (Bowler et al., 1988), should be considered with extreme care. Not only would such a development cause further habitat loss to the geese, but it may also invite the well-known problem of "nuisance geese" that exploit the fertil- ized golf courses, parks, and lawns of cities (Laycock,1982; Conover and Chasko,1984). The inclusion of an observation site in the area's management plan is strongly recommended. Wintering geese in Irvine are a source of pride to • • 0 • 11 many residents, and during every period of obser- vation at the Sand Canyon Avenue off -ramp, the investigator was approached by at least one per- son who had come to observe them. These people were curious about the birds and about the re- search project, sometimes relating stories about the geese of past years. Some watched the geese every week. Reporters and photographers also responded positively to the presence of the geese, and articles about the birds appeared in two regional newspapers. Much research is still needed to answer ques- tions about the Sand Canyon Reservoir/Quail Hill Canada geese. The origin of the flock, its status, and its migration routes all affect management of the geese. It is also necessary to learn more about the food and space requirements for a goose population of this size. An inventory of plants on the study area has been conducted (Bowler et al., 1988), but a study of foraging preferences is neces- sary to determine whether the habitat meets all nutritional requirements of a wintering popula- tion. Leg -banding and tagging with visible identifica- tion codes (e.g., neck collars) would allow re- searchers to monitor movements on the wintering grounds more easily and to identify other foraging sites. Sightings of neck collars would also provide information about migration routes and breeding sites. The California Department of Fish and Game would like to trap and tag geese next winter in a cooperative effort with the City of Irvine (Greg Gerstenberg, California Department of - Fish and Game, personal communication). Knowledge gained from such an effort would allow a more informed management of this valu- able resource. SUMMARY 1) About 1,350 western Canada geese (Branta canadensis mofftti) overwintered in Irvine in 1989. Sand Canyon Reservoir was the only site used for night -resting; adjoining pastures and nearby fields of Quail Hill provided the main foraging sites. 61 2) The wintering population at Sand Canyon Reservoir/Quail Hill declined from 2,5W in 1986 and 4,150 in 1988 to the present size of 1,350. Possible causes of decline include habitat loss from development and agricultural expansion, and altered migration patterns from climatic or habitat conditions on migration routes. 3) The San Joaquin Marsh Wildlife Refuge and Upper Newport Bay provided secondary foraging sites. 4) There is significant public interest in Irvine's Canada geese. 5) Future efforts should involve banding and tagging, to allow in-depth investigation and monitoring of movements on the wintering area. Tagging would also provide useful information about the source of the flock, its migration routes, and its breeding grounds. It is also important to identify foraging preferences of wintering geese, to allow proper management of the area. -The California Department of Fish and Game has ex- pressed an interest in a cooperative research project with the City of Irvine to provide a basis for management plans. 6) Management efforts should concentrate on maintaining and preserving habitat components essential to the geese. Exotic plants (e.g., wild artichoke) that threaten to alter the pastures should be eradicated, while preferred grains and grasses should be encouraged. Foraging areas need to be protected and public access prohibited during winter months. A public observation site would minim, disturbance while allowing in- creased public appreciation for Irvine's unusual wildlife resource. Any proposed developments (i.e., golf courses, houses, etc.) on the foraging grounds surrounding and adjacent to the Sand Canyon Reservoir should be considered carefully. Such developments would no doubt have a detrimental affect on Irvine's wintering goose population. 7) The Sand Canyon Reservoir/Quail Hill site provides an important habitat at a time when open spaces are rapidly disappearing. This site provides habitat essential to an uncommon Orange County wildlife species, the Western Canada goose. The area also supports many other interesting wildlife species. ACKNOWLEDGEMENTS I would like to express my gratitude to all who helped with this research project. The Irvine City Council provided the funds and concern to make the zesearch possible. The Irvine Company and the Irvine Water District were extremely coopera- tive and helpful in allowing access to the study areas. California Department of Fish and Game biologists Greg Gerstenberg and Esther Burkett, provided important historical and current data. I am also grateful to John Simon, Fred Roberts, Peter Bowler, L-Jay Fine, and Linda Varvarinecz, who helped in a variety of ways. LITERATURE CITED Bellrose, F. C. 1968. Waterfowl migration cor- ridors east of the Rocky Mountains in the United States. Illinois Natural History Survey Biol. Notes. No. 61.24 pp. Bellrose, F. C. 1980. Ducks, geese, & swans of North America, 3rd edition. Stackpole Books. Harrisburg, Pennsylvania. 540 pp. Bowler, P., F. Roberts, and J. Simon. 1988. Management strategies for the Canada geese winter foraging habitat on Quail Hill. Presented at Habitat and Wildlife Restor. in S. Calif. Symp. Univ. of Calif. Irvine. 8 pp. Conover, M. R., and G. G. Chasko. 1985. Nuisance Canada goose problems in the eastern United States. Wildl. Soc. Bull.13:228-233. Craighead, J. J. and D. S. Stockstad. 1956. Measuring hunting pressure on Canada geese in the Flathead Valley. Trans. N. Am. Wildl. Conf. 21:210-238. 62 Garrett, K. and J. Dunn. 1981. Birds of Southern California. Los Angeles Audubon Society. Los Angeles. 408pp. Grieb, J. R.1970. The shortgrass prairie Canada goose population. Wildl. Monographs No. 22. 49pp. Hanson, H. C. 1965. The giant Canada goose. Southern Illinois Press. Carbondale, Illinois. 226pp. Koerner, J. W., T. A. Bookhout, and K. Bednark. 1974. Movements of Canada geese color -marked near southwestern Lake Erie. J. Wildl. Manage. 38(2):275-289. Laycock, G. 1982. The urban goose. Audubon 84:44-47. Nelson, S. 1986. On the use of Quail Hill by wintering Canada geese. Prepared for Com- munity Planning Services, El Toro, California. 9pp• Raveling, D. G.1969a. Social classes of Canada geese in winter. J. Wildl. Manage. 33(2):304-318. Raveling, D. G. 1969b. Roost sites and flight patterns of Canada geese in winter. J. Wildl. Manage. 33(2):319-330. Raveling, D. G.1978. Dynamics of distribution of Canada geese in winter. Trans. N. Am. Wildl. Nat. Res. Conf. 43:206-225. Raveling, D. G., W. E. Crews, and W. D. Klimstra.1972. Activity patterns of Canada geese during winter. Wilson Bull. 84(3):278-295. Yocum, C. F.1972. Weights and measurements of Taverner's and Great Basin Canada geese. Murrelet 53:33-34. 41 0 of L� THE REINTRODUCTION OF BALD EAGLES ON SANTA CATALINA ISLAND, CALIFORNIA by David K. Garcelon and Gary W. Roemer Institute for Wildlife Studies P.O. Box 127 Arcata, California 95521 ABSTRACT In 1980 a program was initiated to reintroduce bald eagles to Santa. Catalina Island, California. From 1980 through 1986,33 eagles were released. As of 1988,12 eagles are known to be on the island. Two nesting attempts have occurred. However, both failed, possibly due to problems associated with environmental contamination. INTRODUCTION Historically, bald eagles (Haliaeetus leucocephalus) were distributed throughout California. An inland nesting population ex- tended from Fresno County north to Siskiyou County, and eagles were found along the coast from San Diego to Del Norte Counties (Detrich, 1985). At the turn of the century, between 24 and 40 pairs of eagles nested on the California Chan- nel Islands; at least six of these nesting pairs were on Santa Catalina Island (L. Kiff, personal com- munication). Naturalists began to see a decline in the numbers of Channel Island eagles as early as 1920 (Kiff, 1980). The reasons for the historic decline and eventual extirpation of bald eagles on the Channel Islands are not completely understood (Garcelon,1988). Kiff (1980) suggested several factors that may have led to the decline: shooting, egg collecting, nest destruction, trapping, poisoning, and reproductive failure resulting from environmental contamination. Of the factors related to direct persecution, shooting by island ranchers and by visitors to the islands may have been the most important (Kiff, 1980). In 1930, A. J. van Rossem 63 saw the wings of 20 or more bald eagles attached to the wall of a barn on San Miguel Island; the caretaker of the island claimed he had shot or poisoned all of the birds in the past year (Kill, 1980). Primary or secondary poisoning of eagles reportedly occurred on San Miguel, Santa Rosa and Santa Cruz Islands (Kiff, 1980). On Santa Catalina Island, strychnine and compound 1080 (sodium monolluroacetate) were used to control' - California ground squirrels (Spennophilus beecheyi) in the late 1950s to early 1960s (Gar- celon,1988). Hegdal et al. (1986) found that com- pound 1080 did not generally contribute to the death of raptors. However, deaths have been reported (U.S. Department of the Interior,1972). The effects of secondary poisoning on bald eagles feeding on carcasses of ground squirrels poisoned with either strychnine or compound 1080 has not been reported in the literature. There is no direct evidence to link the decline of bald eagles on the Channel Islands to or- ganochlorine pesticides such as DDT (Dichloro- Diphenyl-Trichloro Ethane) (Garcelon, 1988), but there was a temporal association between the decline of eagles on the Channel Islands and the introduction and widespread use of DDT (Kill, 1980; Garcelon,1988). Bald eagles were observed on a number of the Channel Islands in the 1940s and may have been resident on the three largest islands, Santa Catalina, Santa Cruz, and Santa Rosa, until the late 1950s (Kill, 1980). By 1960 bald eagles were completely extirpated from all of the California Channel Islands (Kiff, 1980). Between 1947 and 1961 Montrose Chemical Company, the largest manufacturer of DDT in the United States, dumped between 37 and 53 million liters of DDT -containing acid sludge into the Pacific Ocean approximately 16 km northwest of Santa Catalina Island (Chartrand et al., 1995). Between 1954 and 1971 another-1,800 metric tons of DDT were discharged into the ocean 33 km offshore of Whites Point, California (Chartrand et al., 1985). Collectively, this represents an es- timated 2,148 to 2,496 metric tons of DDT intro- duced into the Santa Monica Basin within a 24- year period. The introduction of DDT into the marine ecosystem was correlated with the decline of the bald eagle and was implicated in the decline of two other piscivorous bird populations on the Channel Islands, the brown pelican (Pelecanus occidentalis) and the double -crested cormorant (Phalacrocorax auritus) (Risebrough et al., 1971; Gress et al., 1973; Anderson et al., 1975). How- ever, by 1972 the use of DDT was banned in the United States, and by the mid -to -late 1970s brown pelican populations in Southern California were recovering (Anderson et al., 1975; 1977). This prompted the California Department of Fish and Game and the U.S. Fish and Wildlife Service to authorize the reintroduction of the bald eagle to the California Channel Islands (Garcelon, 1988). In 1980, the Catalina Island Bald Eagle Reintroduction (CIBER) project was initiated. The goal of this project was to establish a viable population of eagles on Santa Catalina Island, California (Garcelon, 1988) with the hope that this population would then act as a nucleus for re-es- tablishing the bald eagle on the remaining Califor- nia Channel Islands. CONDITIONS NECESSARY FOR A SUCCESSFUL REINTRODUCTION Reintroduction is a management tool used to re-establish animals in portions of a natural range from which they have disappeared (Garcelon, 1988; Newton, 1988). For a reintroduction to suc- ceed, at least three conditions must be satisfied: (1) Suitable habitat must exist that will allow growth of the reintroduced population; (2) The factors that led to the local extinction of the population must not be present; and (3) A positive public attitude must exist towards the reintroduc- tion, so that released animals are not removed by human action (Newton, 1988; Steenhof,1988). 64 CATALINA ISLAND BALD EAGLE REINTRODUCTION There were four phases to the CIBER project: (a) procuring bald eagle chicks from wild nests, (b) rearing the chicks on hacking or release plat- forms, (c) monitoring the eagles after their initial release, and (d) determining the status of all eagles released on the island and monitoring the nesting activities of adult eagles. Before eagle chicks could be taken from wild nests for release on Santa Catalina Island, hacking or artificial nest platforms had to be constructed. The hacking platforms used to rear the eagle chicks were similar to those used by Milburn (1979); however, they were redesigned to include an observation blind and a different release mechanism (Garcelon 1980; 1988) (Figure 1). Each platform consisted of two chambers: an anterior chamber containing a stick nest and, be- hind it, an observation blind. The front two-thirds of the nest chamber was surrounded by conduit bars, with the remainder enclosed by plywood. A door at the front of the chamber could be lowered from the rear of the platform, out of view of the eagles when they were to be released. The stick nest was constructed at the rear of the nest cham- ber, and a single horizontal perch was placed across the platform just anterior to the nest. Built into the wall dividing the two chambers was a piece of one-way glass for observing the eagles; besides a large access door, there were two small access doors for introducing food into the nest chamber at night. An entrance door at the rear of the observation blind enabled observers to ap- proach and enter the blind without being seen by the eagles. A ladder leading up to the blind and the floor of the blind were carpeted to minimize noise. Three platforms were constructed on the island. The ridge tops on which the platforms were placed afforded the developing eagles a view of the island and the surrounding ocean, and provided updrafts that would assist the eagles in their early post -fledging flights. • 0 0 After the hacking platforms were finished, eagle chicks were removed from wild nests and transported to Santa Catalina Island. In late May or early June, breeding areas were surveyed for active nests containing two or more chicks, since at least one chick was always left for the parents to raise. Chicks 7 to 8 weeks of age were chosen, because at this stage of their development they can feed themselves and thermoregulate without their parents' assistance. Once spec nests were selected, climbers ascended each nest tree and removed a chick. From 1980 through 1986, 33 eagle chicks were removed from wild nests in the Pacific Northwest and released on Santa Catalina Island (Table 1). Eagles were paired according to their stage of development; usually two, but sometimes three chicks were placed on each hacking platform. Once enclosed within the platform, the eagles would not come into close contact with humans for another 4 to 6 weeks. While on the platforms, the eagles were fed prey items theymight naturally encounter on the island: both freshwater and marine fish, California ground squirrels, feral goats (Capra hircus), and feral pigs (Sus scrofa). Every 2 or 3 days, food not consumed by the eagles was removed after dark with a 1.2 m "grabber stick". Behavioral observations were made with a scan sampling technique (Altman,1974) to inves- tigate the ontogeny of behavior in bald eagles. Compared with the behaviors observed in eagle chicks from wild nests, eagle chicks reared on Santa Catalina Island appeared to behave normal- ly. Observations of the birds were made during the day from the blind and with a closed-circuit television system. Birds were kept on the platform until they were approximately 12 weeks old. One week before release they were removed from the platform at night. They were then hooded and equipped with backpack -mounted radio telemetry transmitters, patagial markers, and U.S. Fish and Wildlife Ser- vice leg bands. Before sunrise on the day the birds were released, a rope and pulley were used to lower the front door of the platform, allowing the birds the opportunity to fledge. •i 65 After their release, food was provided for the birds over the next 4 to 7 weeks, untiLthe eagles were foraging independently. Whole goat and pig carcasses were left on the ground in front of the platforms; carcasses were cut open to expose in- ternal tissues. For the first week, carcasses were placed within 30 m of the platforms to ensure that the birds could find the food. After the first week, carcasses were placed in varying directions and gradually moved greater distances (up to 2 km) from the platform. This was done to teach the FIGURE 1. Diagram of bald eagle hacking plat- form used on Santa Catalina Island with a cutaway view of the nest chamber. birds to locate food (Wallace and Temple, 1988). Released eagles were tracked by radiotelemetry to determine their habitat use and to help ensure their survival. Of the 33 eagles released, 1i are known to be alive on the island, two were recovered permanently injured and transferred to educational facilities on the mainland, the status of 12 is unknown, and eight birds are known to be dead. Of the eight birds known to be dead, two died from human -related causes (electrocution and gun shot), one died from an aggressive inter- action with a conspecific, and the causes of the other deaths are unknown. NESTING AND BREEDING BEHAVIOR In 1984 a pair of eagles constructed a nest within an historic territory located on the north side of the island (North Side territory). This was the first nest constructed on Santa Catalina Island by a resident pair of bald eagles in over 30 years (Gar- celon,1985). The birds were never observed to lie in the nest and did not lay any eggs. In preparation for documenting a possible nesting attempt, a closed-circuit television camera was installed overlooking the nest in late 1984. In early March of 1985 both birds of the North Side pair added sticks to the nest and on 15 March were observed copulating. Subsequent to copulation, the birds were observed in incubating posture on the nest. The birds were last seen on the nest on 31 March 1985, and a subsequent visit to the nest by the investigators revealed no eggs or egg remains. Little is known about bald eagle pair -bond forma- tion or the nesting behavior of young pairs, and it is possible that the behaviors observed were re- lated to "housekeeping" (Garcelon,1985). That is, the birds exhibited behaviors associated with nest- ing but may not have been mature enough to have a successful breeding cycle. Bald eagles are known to copulate numerous times, both before and after egg laying (T. Grubb, personal com- munication). The fact that only one copulation was witnessed over several weeks of observation tends to support the idea that the birds were not yet mature enough to breed successfully. Nesting behavior was not observed in 1986. On 17 April 1987 a new nest was located in the North 66 TABLE 1. Location of wild bald eagle nests and the number of eagle chicks removed from each area and released on Santa Catalina Island from 1980 through 1986. Location Number Washington 14 California 11 Canada 8 Total 33 Side territory. On 30 April the adults became inconsistent in their incubation behavior and would leave the nest unattended. Because of this change in behavior, it was decided that the nesting attempt had failed, and on 1 May 1987 researchers entered the nest, collecting eggshell fragments and a small sample of yolk. Pesticide analyses revealed high levels of DDE, a metabolite of DDT, in the yolk. Levels of 470 ppm DDE lipid weight, or approximately 21 ppm wet weight, were found; this is four to five times the critical level thought to impair productivity (R. Risebrough, personal communication). In late 1987 the nest of a second pair was located in a canyon on the east end of the island. This nest was also located in an historic territory (East End territory). On 7 January 1988 a remotely control- led video system was installed at both known nest sites in the hope of documenting the nesting cycle of bald eagles. On 10 February 1988 the female of the East End pair was seen adjusting sticks and lying in the nest; on 20 February a visual confirmation was made of a single egg there. On 23 February the eagles were no longer attending the nest, and a subsequent visit by researchers revealed only eggshell frag- ments in the nest. The fragments were collected, and pesticide analyses revealed high levels of DDE, 740 ppm lipid weight, or approximately 37 ppm wet weight. The levels of DDE found in the eggshell fragments from Santa Catalina Island were high compared to levels found in bald eagle eggs from Northern California and Oregon. 0 Risebrougb and Jarman (1985) found a mean value of 127 ppm lipid weight for 14 eggs collected from Northern California bald eagle nests in 1983 and 1984, and a mean value of 5.6 ppm wet weight was found for 13 eggs collected from southern Oregon (Frenzel,1984). Because of the high levels of DDE found within the reintroduced population of bald eagles on Santa Catalina Island, contaminant levels within potential prey species were assessed to determine where the eagles were acquiring their pesticide loads. Pesticide analyses of mussels (M)Wlus califomianus) and fish species from waters off of Southern California indicated that levels of DDE and other contaminants within the environment were low (Garcelon et al., 1989). Because eagles are known to feed on a variety of birds, three species of gulls were collected from Santa Catalina Island and analyzed for DDE (Garcelon et al., 1989). Average DDE concentrations in the breast muscle tissue of Heerman's gulls (Lanus heermanni, n = 7), California gulls (L. califomicus, n=8), and Western gulls (L. occidenta&, n=7) were 3.2, 2.6, and 2.3 ppm wet weight, respectively (Garcelon et al., 1989). These values are within the range of DDE concentrations reported for herring gulls (L. argentatus) collected from an area in Maine where a population of bald eagles was experiencing low productivity (Wiemeyer et al.,1978; Garcelon et al., 1989). FUTURE RESEARCH AND CONCLUSIONS Because of the unexpected problems associated with environmental contamination, more time may be needed before the reintroduced bald eagles on Santa Catalina Island will be able to reproduce successfully. In 1989, both nest sites will be monitored. An egg laid at either site will be replaced with an artificial one while the real egg is incubated in captivity. If it hatches, the bald eagle chick will be returned to the nest at 2 weeks of age. If it fails to hatch, a bald eagle chick will be removed from a Northern California nest and fostered into a nest on Santa Catalina Island. This will increase the probability of successfully producing a chick on Santa Catalina Island and 67 will enable researchers to document the nesting cycle. Pesticide analyses are being conducted on addi- tional bird species to see if contaminant levels differ between species. These analyses may yield information on which bird species are contribut- ing most to the contaminant levels in the eagles, and where the prey species are- acquiring their contaminants. The reintroduced eagles on Santa Catalina Is- land offer a unique opportunity to document the breeding and nesting behavior of known -age eagles, to study the effects of environmental con- tamination on the productivity of a population of bald eagles, and to educate the public about the plight of our national symbol. UTERATURE CITED Altman, J. 1974. Observational study of be- havior: sampling methods. Behaviour 49:227-267. Anderson, D.W., J.R. Jehl, R.W. Risebrough, L.A. Woods, L.R. Deweese, and W.G. Edgecomb. 1975. Brown pelicans: improved reproduction off the Southern California coast.. Science 190:806-808. Anderson, D.W., R.M. Jurek, and J.O. Keith. 1977. The status of brown pelicans at Anacapa Island in 1975. Calif. Fish and Game 63:4-10. Chartrand, A.B., S. Moy, A.N. Safford, T. Yoshimura, and L.A. Schinazi. 1985. Ocean dumping under Los Angeles Regional Water Quality Board permit: a review of past practices, potential adverse inpacts, and recommendations for future action. Calif. Reg. Water Quality Con- trol Board, Los Angeles Region, March 1985. 47pp. Detrich, PJ.1985. Status and distribution of the bald eagle in California. M.S. thesis, California State Univ., Chico.101pp. Frenzel, R.W. 1984. Environmental con- taminants and ecology of bald eagles in south- central Oregon. Ph.D. thesis,Oregon State Univ., Corvallis.143pp. Garcelon, D.K 1980. An attempt to reintroduce the bald eagle (Haliaeetusleucocephalus) on Santa Catalina Island-1980. Unpubl. report, Calif. Dept. Fish and Game, Sacramento, California. 25pp. Garcelon, D.K 1985. Status of nesting activity and release of bald eagles on Santa Catalina Island 1985. Unpubl. report, Calif. Dept. Fish and Game, Sacramento, California.11pp. Garcelon, D.K 1988. The reintroduction of bald eagles on Santa Catalina Island, California. M.S. thesis, Humboldt State Univ., Arcata, California. 58pp. Garcelon, D.K, R.W. Risebrough, W.M. Jar- man, A.B. Chartrand, and E.E. Littrell.1989. Ac- cumulation of DDE by bald eagles reintroduced to Santa Catalina Island in southern California. Pp. 491-494 in B.U. Meyburg and R.D. Chancel- lor, eds. Raptors in the modem world, Intema- tional Council for Bird Preservation. London. Gress, F., R.W. Risebrough, D.W. Anderson, L.F. Kiff, and J.R. Jehl, Jr. 1973. Reproductive failures of double -crested cormorants in Southern California and Baja California. Wilson Bull. 85:197-208. Hegdal, P.L., KA. Fagerstone, TA. Gatz, J.F. Glahn, and G.H. Matschke. 1986. Hazards to wildlife associated with 1080 baiting for California ground squirrels. Wildl. Soc. Bull.14:11-21. Kiff, L.F. 1980. Historical changes in resident populations of California islands raptors. Pp. 651- 673 in D.M. Power, ed. The California islands: proceedings of a multidisciplinary symposium. Santa Barbara Museum of Nat. Hist., Santa Bar- bara, California. Milburn, E.H.1979. An evaluation of the hack- ing technique for establishing bald eagles 68 (Haliaeetus leucocephalus). M.S. thesis, Cornell Univ., Ithaca, New York.184pp. Newton, I.1988. Reintroduction, and its relation to the management of raptor populations. Pp.1-15 in D.K Garcelon and G.W. Roemer, eds. Proc. of the international symposium on raptor reintroduction, 1985. Institute for Wildlife Studies, Arcata, California. Risebrough, R.W., F.C. Sibley, and M.N. Kirven. 1971. Reproductive failure of the brown pelican on Anacapa Island in 1969. Amer. Birds 25:8-9. Risebrough, R.W., and W.M. Jarman. 1985. Or- ganochlorine contaminants in California bald eagles: origins and potential effects on reproduc- tion. Pit 3,4, and 5 bald eagle and fish study. Final report -Appendix 1. Pacific Gas and Electric Co., San Ramon, California. Steenhof, K 1988. Identifying potential bald eagle nesting habitat: a review of the state of the art. Pages 31-59 in D.K. Garcelon and G.W. Roemer, eds. Proc. of the international sym- posium on raptor reintroduction, 1985. Institute for Wildlife Studies, Arcata, California. United States Department of the Interior.1972. Predator control-1971. Advisory committee on predator control. Report to the Council on En- vironmental Quality and the Dept. of the Interior. 207pp. Wallace, M.P., and SA. Temple. 1988. A com- parison between raptor and vulture hacking tech- niques. Pages 75-81 in D.KGarcelon and G.W. Roemer, eds. Proc. of the international sym- posium on raptor reintroduction, 1985. Institute for Wildlife Studies, Arcata, California. Wiemeyer, S.N., A.A. Belisle, and F.J. Gramlich. 1978. Organochlorine residues in potential food items of Maine bald eagles (Halimetus leucocephahts), 1966 and 1974. Bull. Environ. Contam. Toxicol.19:64-72. • 0 0 r�. 9 PEREGRINE FALCON RECOVERY IN CALIFORNIA by Brian Walton Coordinator, Predatory Bird Research Group* University of California, Santa Cruz Santa Cruz, California ABSTRACT Largely because of eggshell thinning caused by DDT, the peregrine falcon (Falco peregrinus anatum) was virtually extirpated from California during the mid-20th century, and only two pairs could be located in 1970. A recovery program that included surveys of historic peregrine territories, monitoring of current populations, the breeding of captive birds, and incubation of thin -shelled wild eggs resulted in a recovery to nearly 100 territorial pairs by 1989. Over 580 young have been released in California after fostering, cross - fostering, or hacking. We expect to reach the recovery goal of 120 pairs for California in 1991 or 1992. However, overall productivity is slightly depressed and DDT -induced eggshell thinning remains a problem for the entire population, with sections of California severely affected. A com- plete recovery to a stable population will require further pesticide cleansing of the environment. The Santa Cruz Predatory Bird Research Group (SCPBRG) is located on the,cam- pus of the University of California, Santa Cruz. Originally the SCPBRG concerned itself mainly with surveys and manage- ment plans to help restore the peregrine falcon on the West Coast. As the peregrine population has steadily in- creased, both through natural means and human augmentation, we have extended our attention to other raptor species that require assistance,.and to other aspects of research on peregrines. . _ , 69 INTRODUCTION With its extraordinary vision, aerial agility and speed, the peregrine falcon is a natural wonder. Distribution of the bird is nearly cosmopolitan, and throughout its range it inhabits commanding cliffs in varied, ecologically valuable habitats. Fal- coners, who find it the most desirable bird for their sport, have contributed greatly to the knowledge, protection, and management of the species. And many agency personnel finding themselves with peregrine programs under their legal jurisdiction have been inspired to study, observe, and restore falcon populations. Unfortunately for the peregrine, man continues to develop and use chemical compounds for her- bicides, pesticides, and other purposes. These contaminate the food chain and eventually ac- cumulate in peregrine fat, causing known and pos- sibly unknown consequences. Since the development of DDT in the 1940s, the peregrine has been in jeopardy. DDT, in the form of its metabolite DDE, causes eggshell thinning in peregrines and other species. These thin -shelled eggs often break under incubating adults or die from accelerated fluid evaporation through the shell. By 1965 the American peregrine falcon (Falcoperegrinus anatum) was completely absent from the eastern United States, and by 1970, over 95% of an estimated 7,000 + territories were vacant in North America (Cade et al.,1988). At that time only two pairs could be located in California. Application of DDT was restricted by law in the United States in 1972. Peregrines continue to have problems, however, since DDT remains in sinks, sediments, and other sources in the United States, and pesticides containing trace amounts of DDT are still widely used. DDT is accidentally or illegally used as a contaminant in other legal chemicals as well. In addition, many prey species of the peregrine travel to areas in Latin America that still receive legal application of DDT. The historic population size for peregrines is unknown, but there may have been more than 300 pairs in California alone. Because wintering habitat, and to a lesser extent breeding habitat, continue to be severely reduced, the population is unlikely ever to reach past levels, even with com- plete elimination of DDT. Exploitation of urban environments by peregrines extends their current territory without adding to their historic range, since most urban areas replace wilderness habitats used by peregrines before development by man. Despite the odds, the peregrine has made a rapid recovery in the United States, partially due to the efforts of The Peregrine Fund in Boise and its West Coast associate, the Santa Cruz Predatory Bird Research Group. Founded by Drs. James C. Roush III and Kenneth S. Norris in 1975, the Santa Cruz team is dedicated to the study and recovery of endangered raptors, especially the peregrine falcon. The primary goal of the team is to return the peregrine falcon to a self-sustaining population, at which time the species can be downlisted from endangered to threatened. This could occur when the population in California reaches 1M active pairs producing an averge of 1.5 young for 5 years. Another goal is to adapt successful tech- niques developed for the peregrine to other threatened and endangered species. We conduct research to develop methods of captive breeding and release, and to lower the occurence of factors negatively affecting raptor populations. To docu- ment recovery, we survey historic peregrine sites and monitor existing wild populations. MANAGEMENT OF THE CALIFORNIA POPULATION By the end of the 1989 season, The Peregrine Fund had released well over 2,000 young peregrines into the wild. Over 580 of these were released in the western states by the Santa Cruz group (Table 1). The peregrine once again nests 70 east of the Mississippi, and peregrines breeding in over 60 territories wear our release bands. In California the population has risen from a low of two known pairs in the early 1970s to over 90 active territories in 1989 (Table 2). In the recent past, Southern California breeding was restricted to the Los Angeles area; in 1989 there were five docu- mented pairs on the Southern California Channel Islands and one pair in the San Diego area, a substantial geographic increase. Management of the West -Coast peregrine began on a small scale with the double -clutching of a few nests and fostering of young into them (Table 3). In 1977, our first year, two young peregrines were fostered into the Morro Rock eyrie. In 1989 we released 59 young peregrines: 19 from wild eggs hatched at our facility, 27 from eggs produced by our captive breeders, and 13 donated by associates and The Peregrine Fund. This brought our total released young to 583. The origin of the released fledglings is shown in Figure 1. Captive Peregrine Breeding Captive breeding makes it possible to accelerate the rate of recovery of a species. Captive peregrines live longer and produce two to three times the number of eggs the same birds might produce in the wild, even if they survived the > 50% first -year mortality that peregrines face. In addition, their eggs are not subject to pesticide loading and have a very high survival rate. A breeding population of West Coast peregrines is kept at the SCPBRG facility at the University of California at Santa Cruz. The birds are housed in 10 x 20 x 12 foot chambers with slatted roofs that allow plenty of light and exposure to weather. Covered nest ledges are provided, food is intro- duced through a chute in the door, and water in bath pans is changed weekly. Although most cap- tive pairs breed naturally, we maintain a semen donor (hat bird) for artificial insemination of females that produce eggs but do not copulate. Workingwith only experienced pairs, we remove the first clutches of eggs after approximately 10 • 18' e 01 TABLE 1. Survival of young from eggs collected in the wild, and from captive -bred birds at SCPBR G, 1977 -1989. 1977-89 1977 78 79 80 81 82 83 84 85 86 87 88 89 Totals No. of egg sites 0 2 3 7 10 16 21 28 15 16 18 18 13 167 No. eggs collected 0 6 14 27 38 59 66 81 49 47 55 61 52 555 No. hatchable eggs 0. 3 11 20 28 38 54 57 42 31 48 43 31 406 No. eggs hatched 0 2 11 15 26 31 41 46 25 22 28 29 21 297 (73%) Young surviving 0 2 5 15 25 30 40 43 21 20 26 25 20 273 Wild -bred young 0 2 5 9 21 30 40 37 21 20 26 25 19 255 (93%) released Captive -bred 2 0 0 0 6 20 30 44 42 49 46 49 40 328 young released* _ Total number of young released to date 583 *This includes all captive -bred young we have released in California, Oregon, Washington, and Nevada. It does not include young we handle that are released outside West Coast states, or peregrines that are released after fledging age, e.g., falcons rehabilitated from injuries and then released. To be consistent in this regard, the 1987 data have been modified from previous reports. Not all released birds reached independence. days of incubation, to hatch in our laboratory. This induces the pairs to lay a second clutch, which are removed later and replaced with first -clutch young from the lab. These are raised by the parents until ready for release. Imprinted prairie falcons, discussed below, incubate the second clutch of peregrine eggs. In 1989 we had nine pairs of copulating peregrines. An additional four females laid eggs but did not copulate, and produced no fertile eggs. Thirty-five young peregrines were produced by our captive breeders this season despite an un- usually high degree of egg mortality in the first clutches. Although the second clutches did well, we will try to combat the problem with improved nutrition in the future. We are re -pairing unsuc- cessful pairs this fall in the hope of producing more copulating pairs (Linthicum,1989). Raptor breeders and the San Francisco Zoo have assisted our program, donating 13 Califor- 71 nia -type peregrines for release in California. Breeders included Helmut Diener, Bill Murphy, Jim Roush, Tony Robertson, Dewey_ Savell, and Cort Wiegand. Imprinted Prairie Falcons At the SCPBRG we have several imprinted prairie falcons, and these are valuable for two purposes. First, they provide reliable incubation of peregrine eggs. Second, hybrid young, produced by artificially inseminating the prairie falcons, are used for training new peregrine pairs to brood and raise young safely. To avoid their breeding in the wild, the hybrids are later given to falconers. Fostering When eggshells are thin, nesting failures can often be avoided by removing the eggs for incuba- tion, and later fostering the chicks back into nests. TABLE 2. Productivity of peregrine falcons breeding in the wild in California, 1975-1989 (R. Jurek, California Department of Fish and Game, personal communication,1988). No. Sites No. Sites Active No. Youy % Fostemd Chicks No. Young Year Observedl (with copulating pairs)2 Fledged Among Fledglings Wlld-fledged-' 1975 10 7 12 0 12 1976 15 11 17 0 17 1977 17 12 20 5 19 1978 24 19 31 10 28 1979 37 28 37 14 32 1990 48 39 68 12 60 1981 50 38 61 30 43 1982 61 49 63 35 41 1983 67 52 67 49 34 1984 73 63 91 49 46 1985 88 70 105 27 77 1986 92 77 98 28 71 1987 100 79 108 22 84 1988 109 82 117 21 92 1989 109 90 117 15 99 kites where peregrines occupied territories in any year since 1975. 2copulating seen or inferred; excluded are sites observed to have one or more non -copulating birds. 3chicks that fledged, both from manipulated sites (recipients of captive -hatched nestlings) and from non -manipulated sites. ache proportion of fledglings that had been captive -hatched and placed (fostered) into active eyries. From 1981-1989, additional captive -hatched young peregrines were released into California by other methods. -'fledged from unmanipulated sites. At sites scheduled for fostering, a team member is stationed to observe egg -laying. When he judges that a clutch is complete, climbers from the SCPBRG enter the nest and remove the eggs for artificial incubation. Those eggs are replaced with dummy eggs until the young hatch at our facility and can be fostered into existing nests. The chicks are then raised and fledged by the adults. Even though the young peregrines are fairly large when placed in the nest at about 14 days old, the adult falcons invariably accept them. Unfortunately, some wild female peregrines lay eggs so thin that we are unable to reach them before they break. In 1989 we collected 18 72 clutches of eggs from 13 nests. In 10 of the nests, eggs were broken, dented or cracked when we arrived, usually about the tenth day of incubation. Some pairs had broken entire clutches. Although we can often hatch dented or cracked eggs in the lab, the embryos would surely not have lived without our help. High -humidity incubators and such techniques as egg -gluing enable us to hatch chicks that would otherwise have died Chicks that require manual help with hatching or fluid therapy for desiccation would fail to survive in a wild nest, as well. By fostering young into nests with little past fledging success, we enable the adults to fledge • 9 • TABLE 3. Annual Peregrine Greup Releases, 1977-1989,.by the Santa Cruz raptor team. Birds hacked more than once are counted only once in this table. In 1985 two birds were hacked at two sites each, in 1988 a bird was hacked at two sites, and in 1987 a 1986 fledgling was rehacked. Total No. Birds Breakdown of Nos. No. Birds per State Year Released by Method of Release Released by Each Method Cal. Ore. Was. Nev. 1977 2 2 Fostered 2 1978 2 2 Fostered 2 1979 5 5 Fostered 5 1980 9 9 Fostered 9 1981 28 22 Fostered 20 2 5 Hacked 5 1 Misc. release* 1 1982 50 28 Fostered 26 2 4 Cross -fostered 4 18 Hacked 12 3 3 1983 70 34 Fostered 34 6 Cross -fostered 4 2 30 Hacked 24 3 3 1984 81 45 Fostered 45 6 Cross -fostered 4 2 30 Hacked 24 3 3 1985 65 30 Fostered 30 2 Cross -fostered 2 31 Hacked 20 5 3 3 2 Misc. Release* 2 1986 70 27 Fostered 27 6 Cross -fostered 6 36 Hacked 24 3 9 1 Misc. release* 1 1987 73 29 Fostered 27 2 8 Cross -fostered 8 35 Hacked 29 6 73 TABLE 3. (continued) Total No. Birds Breakdown of Nos. No. Birds per State Year Released by Method of Release Released by Each Method Cal. Ore. Was. Nev. 1988 77 25 Fostered 25 12 Cross -fostered 10 2 37 Hacked 31'• 6 3 Misc. release* 3 1989 62 18 Fostered 18 20 Cross -fostered 20 21 Hacked 15 6•' 3 Misc. release' 3 TOTALS 276 Fostered 270 6 64 Cross -fostered 58 6 243 Hacked 184 17 9 33 10 Misc. release* 10 Total No. Birds Released 1977-89 593 522 25 13 33 •a rehabilitated adult, or a bird released by a method not otherwise listed. '•includes one wild bird released at a hack site. chicks successfully, also increasing the likelihood that the territory will continue to be occupied. Cross -fostering Each year some peregrines are cross -fostered into wild prairie -falcon nests. Although prairie falcons are similar to peregrines in many ways, their more generalized diet protects them to a certain degree from pesticide problems, and they are common in areas of California where peregrines are extinct. We began our cross -fostering of peregrines in 1982, placing peregrine young in prairie falcon nests and moving the young prairie falcons to the nests of conspecifics with young of approximately the same age. Twenty-two cross-fosterings have been done: two in 1982, three in 1983, three in 1984, one in 1985, three in 1986, four in 1987, and six in 1988. All were in historic peregrine falcon territory, and all 44 young peregrine falcons have successfully fledged. To assure the young birds of 74 a diet similar to that of wild peregrines, we selected pairs of prairie falcons preying mainly on birds, rather than mammals. Skeptics of cross -fostering are concerned that fostered birds may select mates of the wrong species or nest sites not typically used. Cross - fostering has been tested, however, both by the Peregrine Fund in the Rocky Mountain region and by our team in California. Here we tested the technique in 1980 and 1981 by cross -fostering nine prairie falcons into three red-tailed hawk nests in trees. All nine falcons, three in each nest, fledged successfully. It was difficult to follow each of the birds, but at least two females successfully bred with wild male prairie falcons on cliff's near the Pinnacles National Monument, California. The results showed no detrimental effects from the procedure. There are several examples of cross -fostered peregrines breeding recently in the wild, mated to wild peregrines or those released by other • 0 • 175 150 V 125 • tX V • 100 • 75 2 Z 50 25 0 LEGEND Wild —Hatched Young ® Captive —Hatched Young 191� 11,9111 0�'1 19lb 1919 19$o 19.61 19�2 NO"-'\C019$1519$6, No %9$919$9 FIGURE 1.Origin of California fledglings,1975-1989. methods. A banded male peregrine nested in 1986 in the Columbia River Gorge with an un- banded female; we assume he was cross -fostered nearby at the Rock Creek site. One female peregrine cross -fostered in 1982 in San Luis Obispo County, California, took up residence on the Oakland Bay Bridge in San Francisco Bay and was seen frequently with an adult male peregrine on the Kaiser Building in downtown Oakland. The banded male was from a nest site in Napa countywhere manipulations of eggs and young are conducted. This cross -fostered female peregrine selected an urban, industrialized environment rather than the near -wilderness, mountainous ter- rain of her fledging location. Her diet in the nest had been primarily band -tailed pigeons, swallows, and other small- to medium-sized birds. In Oak- land she fed largely on feral domestic pigeons, but also on gulls and terns. She was a prime example of the opportunistic nature of this highly adapt- able though endangered species. She was found shot on the Oakland Bay Bridge before the 1984 breeding season, having had no opportunity to reproduce. Recently, several other cross -fostered peregrines have been located breeding in Califor- nia. Hacking We first used the hacking technique in 1981, and since then have released 243birds by this method. Its disadvantage is that no adult falcons are there to protect and defend the young from golden eagles, great horned owls, and other .predators. Its advantage is that it allows peregrines to begin to reestablish themselves in areas where the species no longer nests. Under this procedure, instead of being fostered into nests as downy chicks, the young are raised by our captive adults until they are about 35 days old. The nestlings are then transported to a hack site, placed (usually three at a time) in a large box with a bared front, and to avoid an association of food with humans, fed through a chute. After a week of familiarizing itself with the surroundings, each bird has one leg fitted with a small telemetry trans- mitter, designed to fall off after about two weeks. Then the front of the box is opened. The young usually fledge within a few days, first learning to fly and soon thereafter to hunt. For about 6 weeks, until the birds are independent of the hack site, attendants place food out every day, keep track of their progress, and attempt to protect them from predators and other dangers. We generally use a site for several consecutive seasons. Even after the young abandon it, the hack box remains on the cliff or tower as a possible nest site for returning falcons. Hack -site locations are selected mainly for their high probability of fledgling survival, but we cannot predict what location the birds will ultimately select as their territory or nest cliff. CONTINUING PROBLEMS WITH EGGSHELL THINNING By the age of sexual maturity (3 to 4 years), female peregrines in California have accumulated DDE residues at levels that induce eggshell thin- ning (20 ppm wet weight). Eventually, they lay eggs that exceed the accepted 18% threshold level of thinning, and hatching is highly improbable. Relatively old females in coastal habitats and higher elevation regions lay extremely thin -shelled eggs. A female peregrine at the famous eyrie at Morro Rock, San Luis Obispo County, produced eggs from 1977 to 1986 with DDE residue levels ranging from 86 to 160 ppm (dry weight), and shells 25 to 36% thinner than normal pre -DDT eggshells. Her replacement, only 3 years old in 1987, laid eggs that year and in 1988 that were between 19 and 27% thinner than the norm. Several other females in central coastal, Sierran, and north coastal regions of California lay eggs in a similarly poor condition. FI1 Mean eggshell thinning documented in 1989 was 17.7%, with the central coast population showing an average of 22.6% thinning. In 1989, 21 of 52 embryos (40%) were dead, or the eggs infertile, upon collection. Six eggs were dented. Twenty- one (68%) of the live eggs hatched. Fifteen eggs had what we term loose air cells, in which the inner shell membrane is partially detached from the outer shell membrane. This is a fairly new phenomenon in wild California peregrine eggs, and we are investigating possible causes. We estimate that without management, ap- proximately 30 of the 90 + nesting pairs in Califor- nia (relatively old breeding adults or birds in particularly polluted areas) would fail to hatch eggs each year, another 30 would have some eggs lost to breakage or desiccation, and the remaining pairs (relatively young breeders in the population) would fledge normal numbers of offspring. Although we are not able to manipulate all fail- ing sites, we do raise fledging rates significantly in areas of management concentration, e.g., the central coast (Linthicum,1989). In 1989,18 cap- tive -hatched young were released from 11 Califor- nia foster sites that probably would have failed to fledge young without assistance. An additional 35 young were released by other means. Augmenta- tion is essential to maintaining the sub -population of the mid -coast, where we estimate that few if any wild -hatched young would fledge. In addition to eggs we collect for hatching, the SCPRBRG and associates gather egg -shell frag- ments and addled eggs each year from wild peregrine nests. They are analyzed for pesticide contamination by the Bodega Bay Institute of Pol- lution Ecology and the Aquatic Toxicology Pro- gram of UCSC, and for eggshell thinning by the Western Foundation of Vertebrate Zoology. Where possible, those nests with a history of failure from thinning are scheduled for fostering the following spring. In 1989, we decided to manipulate only those nest sites south of Califor- nia Highway 80, where eggshell quality is lowest and peregrines are rare compared to those in Northern California. • 0 • • • CALIFORNIA'S 5-YEAR MONITORING PROGRAM, 1988-92 In 1988, a comprehensive 5-year monitoring pro- gram was initiated for the peregrine falcon in California. Participating parties are the Bureau of Land Management, U.S. Fisheries Service, Na- tional Parks Service, U.S. Fish and Wildlife Ser- vice, and California Department of Fish and Game. A Memorandum of Understanding estab- lished the Bureau of Land Management as the lead agency, and participants include personnel from each of the signing agencies, as well as the Santa Cruz team. In the first year of the program, standardized methods of data collection were developed so that population recovery can be assessed scientifically. Monitoring was aided by the substantial increase in the number of known California nesting sites during the past decade, and in a cooperative statewide survey in 1989, a total of 103 known and suspected peregrine falcon nesting sites were in- vestigated. Helicopter survey continues to be the primary method of monitoring the breeding population of Northern California, with a total of 60 hours and approximately 5,000 air miles covered in this region in 1989. Conventional methods of observation from the ground or at sea continue to be used elsewhere in the state. Although the monitoring program is a joint ef- fort of many agencies, interest groups, and in- dividuals, there are other groups and individuals reluctant to provide information on specific pairs or sites with which they may be uniquely familiar. Whatever the reasons, their reticence makes it impossible to fully document territory occupancy, habitat use, and population status. When this is added to the limited funding and expertise avail- able, today's picture of the peregrine status in California is unclear. CONCLUSIONS Falcons produced in the wild and through our captive breeding programs combine to build the foundation for a significant population expansion. Despite the growth, however, high.failure rates for 77 hatching and depressed fledging success will con- tinue in the wild until we pinpoint the sources of DDT and other contaminants. This information is crucial for the well-being of peregrines, other species, and humans as well. The peregrine is a prime indicator of environmental quality. This project by the Santa Cruz Predatory Bird Research Group will be maintained until the primary causes of the bird's decline are eliminated and the species is downlisted from endangered to threatened. We hope to to increase the numbers of copulating pairs to 3.20 within three additional field seasons,1990 -1992. ACKNOWLEDGEMENTS The Santa Cruz Predatory Bird Research Group has been helped by many government agencies: the California Department of Fish and Game, the U.S. Fish and Wildlife Service, the Bureau of Land Management, the U.S. Forest Service, and others. We also appreciate the support of cor- porations: ARCO, Chevron, PG&E, Union Bank, Rohm & Haas, and others; and of foundations: the New Land, The Peregrine Fund, Francis V. R. Seebe Trust, Wildlife Preservation Trust Intema- tional, and others. Private individuals, members of the California Hawking Club, members of several chapters of the National Audubon Society, and individuals in all of the groups mentioned above have been vital to our organization. Our employees are largely underpaid, highly volun- teer -oriented, and the primary reason our programs have been successful. LITERATURE CITED Cade, T. J., Enderson. K H., Thelander, C. G. and White, C. M., eds. (1988). Peregrine Falcon Populations: Their Management and Recovery. The Peregrine Fund, Inc. 949pp. Linthicum, J., ed. (1989). Peregrine Falcon Monitoring, Nest Management, Hack Site, and Cross -Fostering Efforts 1989. Private publica- tion, -University of California, Santa Cruz. 21pp. STEPHENS' KANGAROO RAT: NATURAL HISTORY, DISTRIBUTION, AND CURRENT STATUS by Michael J. O'Farrell, Ph.D. 2912 N. Jones Boulevard Las Vegas, NV 89108 ABSTRACT The Stephens' kangaroo rat was federally listed as endangered in October 1988. Distribution of the species is limited to a portion of western River- side County and two disjunct areas on either end of the San Luis Rey River drainage in northern San Diego County. The species selects habitat low or lacking in shrub cover, with ground cover dominated by herbaceous annual plants. Disper- sion is patchy, and the colonies are recognized by concentrations of burrow entrances which are in- terconnected by both tunnels and surface run- ways. The species appears adapted for intermediate seral plant communities and demonstrates colonizing ability along dirt roads. Evidence of a prolonged breeding season suggests a relatively high reproductive potential. The County of Riverside has applied for a Section 10(a) permit to allow incidental take of the species. In accordance, a Habitat Conservation Plan (HCP) is being prepared, detailing critical aspects of the biology and identifying adequate preserve sites. A user fee for land development has been established to finance the HCP program. INTRODUCTION The Stephens' kangaroo rat (Dipodomys stephensi) is limited in distribution to a portion of western Riverside County, extreme southwestern 78 San Bernardino County, and a portion of northern San Diego County (Bleich,1977; O'Farrell et al., 1986). Optimal habitat is open grassland in flat or gently rolling terrain, also the ideal topography and soil for such agricultural crops as dryland grains and citrus fruits. Agriculture expanded in the low valley areas of western Riverside County late in the last century and continued unabated until recent decades. Urban expansion has steadily increased near, and more recently on, farm lands. The region is now one of the fastest growing in California. Agriculture and early urban development ac- counted for significant loss of optimal habitat. Urban expansion and associated industrial development later encroached upon agricultural land, pushing cultivation to the base of steep hillsides and rock outcrops. Stephens' kangaroo rats have been pushed into marginal habitat by this activity, in many cases into virtually linear strips of such habitat. The demand for new residential and industrial land has reached the point that the marginal habitat, also marginal for building, is in imminent danger of exploitation. In the past, spot examinations have documented the extirpation of known populations (Thomas, 1973). This trend continues at an alarming rate (O'Farrell and Uptain,1989); 59% of previously known populations have been extirpated by development. A limited geographic distribution, declining numbers, habitat destruction, and the impending threat of further encroachment by urban and industrial expansion have resulted in state "threatened" and federal "endangered" list - Over the past six years, my colleagues and I have examined various aspects of the natural history and behavior of D. stephensi, including a detailed study of habitat selection (O'Farrell and Clark, 0 1• 1987). Recently, we conducted a range -wide sur- vey to locate and map all existing major popula- tions, assess relative abundance and habitat quality, and evaluate current land use and degree of endangerment (O'Farrell and Uptain, 1989). The purpose of the present paper is to summarize the current knowledge of this sensitive species. DISTRIBUTION The current boundaries of Stephens' kangaroo rat distribution are broader than previously thought (Figure 1). The northern border essen- tially follows Highways 91 and 10 and the western edge follows Highway 15. The southern and east- ern limits of the i ange are not as clearly defined. The eastern border roughly follows a line from a point just west of Banning southward to Aguanga. This artificially delineated eastern border is amoeboid in shape, with finger -like projections of occupied habitat following natural drainages and other linear extensions of suitable habitat. The southern distribution is represented by two dis- junct populations, one associated with the western San Luis Rey River drainage and the other ad- jacent to Lake Henshaw, on the eastern end of the San Luis Rey River. Prior to the arrival of Europeans, the range of D. stephensi undoubtedly was somewhat larger than that just described. The westward extension would have been limited by the Santa Ana Moun- tains. The southern and eastern distributions FIGURE 1. The current distribution of Stephens' kangaroo rat 79 would have been stopped by the change in topog- raphy and dominance of sage scrub and chaparral plant communities. The potential for a more ex- panded range to the north is greater, but the history of past development allows only conjec- ture as to actual limits of past occupation. The two disjunct populations in the south are associated with several major drainages that presumably served as past movement corridors. Limited Stephens' kangaroo rat populations are known along Temecula and Wilson Creeks, but the expanse of rugged terrain and unsuitable vegetation from Aguanga to the Warner Ranch precludes this drainage as a viable movement cor- ridor. The present and past known populations associated with the San Luis Rey River drainage appear to be the most likely source of colonization into the Lake Henshaw region. All but a few miles of terrain appears to have been suitable prior to human development. The most reasonable past corridor linking the main body of distribution with the Oceanside area may have been associated with the Santa Margarita River. NATURAL HISTORY No intensive, long-term studies have been per- formed that detail the major aspects ofD. stephen- si ecology. Consequently, much of the biology has been inferred from investigations of other species of kangaroo rats. This may have resulted in er- roneous conclusions, because most species are adapted to shrubland habitats, whereas D. stephensi is a grassland specialist. Many miscon- ceptions exist, which will be addressed below. Habitat Selection The Stephens' kangaroo rat is known as an in- habitant of open habitat (see Bleich, 1977 for a review), which was generally described by Lackey (1967a) and distinguished from that of the shrubland congener, the Pacific kangaroo rat (D. 711 agilis). Lackey described a dispersion of the two species that was contiguous yet separate. Later, unpublished theses presented subsidiary informa- tion on habitat relationships using quantitative plant techniques suited for shrublands (Bleich, 1973; Bontrager, 1973). Hence, habitat affinity was described in terms of shrub species, with the grassland component completely ignored. Con- sequently, some biologists specifically, but incor- rectly, look for certain shrub species common to the sage scrub plant community as indicators of possible D. stephensi presence. A detailed study of habitat selection revealed that although the species may be found in habitats containing up to 30% aerial shrub cover, more than 75% of occurrences were in habitat patches totally devoid of shrubs (O'Farrell and Clark, 1987). Abundance was also positively related to a lack of shrub cover. However, it is misleading to designate preferred habitat simply as grassland. A strong positive correlation has been found be- tween the proportion of annual forbs and grasses (r - 0.76; 0.10 > p < 0.05; O'Farrell and Uptain, 1987). In disturbed non-native grassland, two trends are apparent. Initial invasive weedy species are replaced by intermediate seral stages dominated by annual grasses or by annual forbs. Although both are annual, the grasses tend to persist for several years, resulting in the formation of dense mats of dried biomass. Annual herbaceous species disarticulate rapidly after they dry, result- ing in substantial patches of bare ground. D. stephensi avoids dense grasses and thrives in areas dominated by herbaceous material. Presumably this is due to the presence of a more desirable food resource and the ability to use the specialized bipedal, hopping mode of locomotion in the open areas. The diagnostic plant species in herbaceous grassland is red -stemmed filaree (Erv&um cicutarium), which increases under grazing (Rice, 1987). It is not surprising that the most abundant populations occur in habitats receiving substantial grazing pressure. When grazing is reduced or eliminated, grasses increase proportionately. The 0 0, population described for the Warner Ranch in San Diego County (O'Farrell and Uptain, 1987) has decreased by approximately 90% over the past three years (O'Farrell and Uptain, unpublished data). Livestock has been changed from mixed Hereford stock to Holstein dairy cattle, grazing preware has been reduced by half, and bunch grass (Adstida sp.) has become a dominant species. Dispersion Stephens' kangaroo rat is distributed in patches, even in large, seemingly homogeneous habitats and in the most densely populated areas (O'Farrell and Uptain, 1987). Generally, a patch consists of variously spaced burrow entrances connected by a network of surface runways. Al- though burrow entrances may be clustered, single entrances are most common (81% occurrence). Size of a patch and abundance of burrow entran- ces are affected by topography and soil, and vary through time as vegetation changes occur. Characteristic cleared areas occur at most bur- row entrances. These aprons show signs of various activities. Dust baths, small excavations (presumably for seed caches), and piles of plant duff may be found on or adjacent to aprons. Similar cleared areas at some trail intersections may function in social communication, through olfactory cues left from sand bathing. Much of the surface within an animal's home range is un- exploited; less than 10% of all digging and forag- ing occurs more than 1 m from established trails and entrance aprons. This may reflect predator avoidance: the less time spent above ground, par- ticularly when aerial cover is absent, the less the risk of encounter with potential predators. A unique feature of the patchwork dispersion of burrow entrances connected by surface runways is a corresponding tunnel beneath each trail (O'Farrell and Uptain, 1987). Excavation revealed that entrances are connected by tunnels 21 to 23 cm deep, directly below surface runways and following precisely the twists --and bends of 81 these trails. Such an underground network allows safe travel from entrance to entrance without ex- posing an animal to aerial predators where vegeta- tion provides no cover, or when moonlight heightens the risk of detection. Creation and use of this tunnel system appear specifically adapted to open grassland having limited aerial cover and containing surplus food resources that allow in- complete use of the occupied home range. The concentration of burrows in discrete patches and the interconnection both above and below ground among burrow entrances suggests that multiple individuals probably use a spec patch. If a number of individuals do use the same burrow complex, then a degree of sociality not commonly attributed to kangaroo rats must exist. Eisenberg (1963) described agonistic behavior in kangaroo rats that suggested a primarily solitary existence. This information has been applied dog- matically over the years to all kangaroo rats, in- cluding D. stephensi. However, the assumption is not supported by observed dispersion patterns. The distance between occupied patches varies with topography, vegetation, and soils. However, trace distribution is frequently found between patches, taking the form of one to several burrows not physically connected to the type of patches described above. Although this trace distribution may occur in open grassland, it is most commonly associated with dirt roads and other obvious movement corridors. Disturbed roadsides ap- pear to be the major means of Stephens' kangaroo rat dispersal. All evidence (O'Farrell and Uptain, 1989) indicates that this species has extraordinary colonizing proficiency, due to its ability to exist in linear strips along disturbed roadways. In some cases, such occupied roadsides occur in habitat generally unsuitable for the species. Stephens' kangaroo rat appears adapted for in- termediate seral plant communities. Within the range of the species there is a dynamic habitat mosaic. Natural shrublands are disturbed by fire, grazing, or agriculture and proceed through a series of successional stages. After initial weedy growth, a variety of intermediate conditions develop. When vegetative conditions become ac- ceptable, colonization by D. stephensi occurs as individuals disperse out from occupied patches. This situation is facilitated by trace distribution along roads through marginal or unsuitable habitat. Reproduction Like all kangaroo rats, D. stephensi has been presumed to have a conservative reproductive strategy, with a mean litter size of 23 (Lackey, 967b) and a single litter per year expected. Reproductive data have been few, but early studies indicated a breeding season in late spring and early summer (Lackey, 1967b; Bleich, 1973; Bontrager,1973); scrotal males and pregnant and lactating females were found in June and July, whereas juveniles occurred in July and August. However, Bontrager (1973) did note a juvenile as late as December. More recent information from the technical literature indicates the potential for a prolonged breeding season and multiple litters per year. On 15 February, a pregnant individual was captured adjacent to the San Jacinto River northeast of Sun City; and on 1 March, six scrotal, two pregnant, and three estrous adults were collected with one estrous subadult and a single non -reproductively - active juvenile on Estelle Mountain (O'Farrell et al., 1985). One of the estrous adults contained a fresh copulatory plug. Over a 3-year period on the Warner Ranch, reproductively active males and females were found in September, June, and February (O'Farrell and Uptain,1985). Scrotal males were present during each of these months, but the greatest percentage (84%) occurred in February. Likewise, estrous and pregnant individuals were found in each of these months, with only 17% of the females reproductively active in June but 46% active in February. Long-term, detailed reproductive studies are needed to clarify reproductive potential in D. 82 stephensi. However, a generally milder climate than that encountered by most other kangaroo rats and a habitat with abundant food may account for prolonged breeding activity and a potentially higher reproductive rate than that expected for the genus. The non-native grassland in Southern California is generally at peak germination in mid- winter, in response to the onset of the fall rainy season. This fresh production of greens may ac- count for the apparent strong, early reproductive activity. CURRENT STATUS Encroachment resulting in harm to D. stephensi or its habitat is expressly forbidden by law (USFWS, 1988). The pressures of expanding urban and industrial development in western Riverside County are at odds with the law protect- ing the species. Economic and political realities dictate that some areas occupied by the species will be lost. One way to accommodate develop- ment and still ensure the welfare of the species is to set aside adequate preserve sites. After the formal federal listing became effective, the County of Riverside assumed the lead role in preparation of a Habitat Conservation Plan (HCP). The HCP is a necessary component of a Section 10(a) permit application to obtain the authorization for incidental take of an endangered species. The HCP will address the location, size, and quantity of preserve sites necessary to ensure the long-term survival of the species. The HCP also must address the means by which designated preserve lands may be obtained. A 3-year study is under way to determine preserve -site needs. Ad- ditionally, a county ordinance has been passed requiring all new development within the historic range of the species to be assessed user fees on an acreage basis. These fees are matidated in all unincorporated areas, and participating cities must assess similar fees for development within their boundaries. The fees will finance the HCP program. In order to provide protection for the species during the preparation of the HCP, an Interim HCP has been prepared and an application for a • 01 t Section 10(a) permit submitted to the U.S. Fish and Wildlife Service. The Interim HCP has proposed a number of potential preserve sites throughout western Riverside County (Figure 2). An attempt has been made to include all areas with significant amounts of optimal habitat, so that (1) sufficient geographic variation will exist to maintain the maximum genetic variability pos- sible, and (2) reasonable movement corridors are included to allow gene flow among populations. The Section 10(a) permit will allow limited take of Stephens' kangaroo rat outside the proposed preserve sites. No more than 20% of the total occupied habitat within the HCP area may be subjected to take during the interim period. The establishment of a viable HCP and adequate preserve sites will aid the survival of Stephens' kangaroo rat. However, continued interest by the public in preserving native ecosystems is essential to ensure that such programs will be successful. ACKNOWLEDGEMENTS I wish to thank Curt Uptain for invaluable field assistance and many hours of thoughtful discourse FIGURE 2. The location of proposed Stephens' kangaroo rat preserve sites in western Riverside County. Circles indicate sites encompassing significant acreage. TI angles are small sites containing current protected status (Mott Preserve � Santa Rosa Plateau Preserve). 83 concerning the biology of Stephens' kangaroo rat. Line: Stephens' kangaroo rat mitigation. WES- • T.M. O'Farrell prepared the maps. F.H. Emmer- TEC Services report for Southern California son, Peter Stine, and Art Davenport kindly Edison Co., Rosemead, California. 13 pp. + ap- provided critical reviews of the manuscript. pendices. LITERATURE CITED Bleich, V.C. 1973. Ecology of rodents at the United States Naval Weapons Station Seal Beach, Fallbrook Annex, San Diego County, California. M.A. thesis, California State Univ., Long Beach. 102 pp. Bleich, V.C. 1977. Dipodomys stephensi. Mam- malian Species, 73:1-3. Bontrager, D.R. 1973. Rodent ecology of the Santa Rosa Plateau, Riverside County, California. M.A. thesis, California State Univ., Long Beach. 115 pp. Eisenberg, J.F. 1963. The behavior of heteromyid rodents. Univ. of California Publ. Zool. 69:1-100. Lackey, J.A. 1967a. Biosystematics of Heer- manni group kangaroo rats in Southern Califor- nia. Trans. San Diego Soc. Nat. Hist.,14:313-344. Lackey, JA. 1967b. Growth and development of Dipodomys stephensi. J. Mammal., 48:624-632. O'Farrell, M.J. and W.A. Clark. 1987. Habitat utilization by Stephens' kangaroo rat (Dipodomys stephensi). WESTEC Services, Inc. report to Southern California Edison Co., Rosemead, California, 34 pp. + appendices. O'Farrell, M.J., S.M. Juarez, and C.E. Uptain. 1986. A new addition to the known range of Stephens' kangaroo rat (Dipodomys stephensi) in San Diego County. California Fish and Game, 72:187-189. O'Farrell, M.J., S.B. Lacy, and W.A. Clark. 1985. Southern California Edison mitigation sur- vey for the 500 kV Valley Substation to Serrano 84 O'Farrell, M.J., D.W. Kaufman, and D.W. Lun- dahl. 1977. Use of live trapping with the assess- ment line method for density estimation. J. Mammal., 58:575-582. O'Farrell, M.J. and C.E. Uptain. 1985. LaJet Solar Energy Project -- Phase I impact of con- struction and initial operation on Stephens' kan- garoo rat (Dipodomys stephensi). Report for Dr. Donald Hunsaker, San Diego State Univ. and LaJet Energy Co., Abilene, Texas. 13 pp. O'Farrell, M.J. and C.E. Uptain. 1987. Dis- tribution and aspects of the natural history of Stephens' kangaroo rat (Dipodomys stephensi) on the Warner Ranch, San Diego Co., California. Wasmann J. Biol., 45:34-48. O'Farrell, M.J. and C.E. Uptain. 1989. Assess- ment of population and habitat status of the Stephens' kangaroo rat (Dipodomys stephensi). California Dept. Fish and Game Non -game Bird and Mammal Section Report, 19 pp. + appen- dices. Rice, K.J. 1987. Interaction of disturbance patch size and herbivory in Erodium colonization. Ecology, 68:1113-1115. Thomas, J.R. 1975. Distribution, population densities, and home range requirements of the Stephens' kangaroo rat (Dipodomys stephensi). MA. thesis, California State Polytechnic Univ., Pomona. 64 pp. U.S. Fish and Wildlife Service (USFWS). 1988. Determination of endangered status for the Stephens' kangaroo rat. Fed. Reg., 53(190):38465-38469. 0 0 • THE POPULATION BIOLOGY OF THE BOTTLENOSE DOLPHIN ALONG THE COAST OF ORANGE COUNTY, SOUTHERN CALIFORNIA by Dennis L. Kelly Professor of Marine Biology Orange Coast College Costa Mesa, California ABSTRACT A two-part study was conducted between 1982 and 1986 on the population biology of the bot- tlenose dolphin (Tursiops truncatus) along the coast of Orange County, Southern California. (1) Thirty five photographic surveys covered a coastal strip from Anaheim Bay in the north to San Onofre State Beach in the south. From 581 sight- ings of individuals, 89 dolphins were photographi- cally identified. We estimate those 89 to be approximately 65% of the total population, put- ting the estimated total at 137. This is a far larger population of bottlenose dolphins using the Orange County coast than has been previously documented or assumed. Of this population, 6.9% were calves. There was no indication of a home range within the dolphin community nor of fidelity of any individual to any specific part of the study area. The greatest numbers of sightings, however, were clustered at the north and far south ends of the study area, and we believe they represent sig- nificant habitat to the coastal dolphins. (2) Six dead bottlenose dolphins stranded on local beaches were necropsied and found to have suf- fered multiple pathologies, and DDT and PCB levels in all tissues analyzed (five dolphins) were very high compared to those in previous studies of offshore dolphin species. INTRODUCTION The literature contains numerous descriptions of the biology and ecology of th Pacific bot- 85 tlenose dolphin (Tursiops truncatus) from the coast of Southern California and northern Baja California, Mexico (Scammon, 1874; Norris and Prescott, 1961; Dohl et al, 1978; Orr, 1963 and 1976; O'Shea et al., 1980; Walker, 1981; Kelly, 1983; Hansen, 1990; Defran, 1985; and Shane et al.,1986). There is documentation of extended travel by coastal bottlenose dolphins. Wells et al. (1990) reported that five individuals from Hansen's 1990 sample along the San Diego coast were sighted 750 km to the north in the coastal waters near Monterey. Dolphins seen in Orange County have been identified as far south as Ensenada, Baja California Norte, Mexico (Defran et al., in press). From boat surveys and photo -identification, Kelly (1983) identified 60 dolphins off the Orange County coast. Along the northern coast of San Diego County, Hansen (1983) estimated a popula- tion of 175 to 250 dolphins, based on a count of 118 identified individuals. Defran et al. (1985) suggested that coastal movement rather than local residency is characteristic of this open coastline population. Information on the long-term effect that con- taminants have had and will have on the coastal bottlenose dolphin population is important to any attempt to understand the population biology and ecology of this species. Shafer et al. wrote in 1985: "Since these animals are long-lived and many feed high in the food web, they are most likely to show chronic effects from the accumulation of organic contaminants... and are therefore the most likely candidates for study in our effort to understand the long-term effects of exposure to contaminants in the natural environment." The current research was conducted in col- laboration with Dr. R.H. Defran and personnel of the Cetacean Behavior Laboratory at San Diego State University. It involved extensive observa- tions north of Hansen's study area and made use of a new technology developed by Dr. Defran for identifying animals. The goals of this research were to determine 1) population parameters: group size, composi- tion (calf proportion), and coastal density 2) uses of the habitat, and 3) the organochlorine content of organs and tissues collected from dead, beach -stranded in- dividuals. METHODS Study Area The term "study area" refers to the coast of Orange County from Anaheim Bay, in the north (330 44' 00" north), to San Onofre State Beach, in the south (320 20' 00" north), and offshore to a distance of 2 nautical miles from the beach (Figure 1). Survey Procedure All surveys were done from shipboard, usually one of two 23-foot Seacraft (inboards). 1) Complete Surveys. For complete surveys we traveled, first, 50 to 100 m beyond the surf -line at Newport Harbor, and then north until the team spotted a group of dolphins. At 100 to 200 m from the pod, the boat was stopped for 5 to 10 minutes. The team recorded the time and location, scanned the coast above and below the pod to determine if other dolphins were near, and began the count. At the same time the principal investigator noted behavior within the pod -- feeding, playing, mill- ing, traveling, mating -- and made a judgment as to whether closer contact would harass the dol- phins severely, moderately, or not at all. The boat was maneuvered to pass on the ocean side of the dolphins at slow, continual speed and at a distance of 10 to 20 m. During this initial pass, rr part of the shipboard team attempted to take close-up photographs of each dolphin's dorsal fin, while other team members counted adults and calves. (A calf was defined as an animal estimated to be one half the length or less of an adult, that swam next to an adult so as to be touching it at most times, and that was always accompanied by an adult during the course of the observation.) Contact with the animals was maintained until photographic and other census work was com- pleted. Then we left the pod and resumed the search, continuing up the coast as far north as Anaheim Bay, then south to San Onofre. 2) Partial Surveys. Partial surveys covered either the northern portion of the study area (Newport Bay to Anaheim Bay) or the southern portion (Newport to south San Onofre State Beach). Animal Identification and Census by Dorsal Fin Analysis The majority of our photographs were taken with a Nikkromat 35 mm SLR camera with a Vivitar 80-280 mm zoom lens of F 2.5. We took most with a Kodachrome 64-slide film. Since Dr. Defran prefers to work directly with developed negatives, we switched to Tri-X black -and -white print film in the last year of the research. All dolphin photographs (black -and -white nega- tives and color slides) were sent to Dr. Defran's laboratory, where, by analysis of the natural varia- tions (notches) that develop with time in the dol- phin dorsal fin, coded identifications could be established for all dolphins with two or more fin notches. According to Dr. Defran, this technique is simple and easily learned by laboratory person- nel; it reliably identifies dolphins as resights or new additions to the catalog, in many cases even after new notches appear (Defran, 1988); and it permits laboratories to exchange data on dorsal fins inexpensively. A slide of each dorsal fin photographed is projected and enlarged to fill a 10 x 17 cm frame drawn on white paper, and the contours of the fin are traced. As shown in Figure 2, the top point of r: • • 040'N Seal Beach .......:,.Anaheim Bay 3030'N :::'Surfside Beach Balsa Chico Beach :9 Huntington Beach Newport Beach 5 Km .�Crystal Cove Beach Pacific Ocean Laguna Beach .4 Aliso Beach 1800, W Orange County California 117050'w -Dana Point '.-'-Doheny Beach Capistrano Beach N .0 Son Clemente Son Onof re Beach FIGURE 1. The study area. 01 87 the two largest notches are labeled A (top) and B (bottom). The identification code for each dol- phin, then, is the ratio of the distance between A and B to the distance from B to the top of the fin. Because it is a relative measure, this dorsal ratio is unaffected by the size of the fm in photographs or enlargements, or even by severe cases of paral- lax. Census Data The cetacean behavior lab recorded and filed the fin identification for each dolphin and counted 1) the total number of dolphins photographed 2) the total number of resightings, and 3) the total number of dolphins new to the exist- ing catalog. 10 10C Careass Studies With the aid of lifeguards and citizens, we estab- lished a network for locating dead, beach - stranded marine mammals and set up a necropsy laboratory at Orange Coast College. Carcasses were weighed, measured and necropsied. Also, blubber, liver, muscle, brain and kidney tissues were analyzed for DDT and PCB levels. RESULTS We planned and attempted 45 boat surveys (Table 1). Ten were cancelled due to bad weather or engine problems, and 35 were actually con- ducted. Of the 35, 19 were surveys of the entire area,13 covered only the northern portions of the study area, and three covered the southern por- tion. We spotted no dolphins in eight of the 35 surveys. One was of the entire study area, and TOP 19MM - 439 44mm Dorsal A to B Ratio m B to Top FIGURE 2. Measurement of the dorsal ratio. 88 • • • TABLE 1. Boat Surveys,1982 -1985 Survey No. Dolphins: No. Date Location of Dolphins Adults Calves Behaviors 1 12/21/82 Huntington City Beach- 20-25 2 milling, feeding, foraging Bolsa Chica State Beach 2 12/29/82 San Onofre State Beach 25-30 4 milling, feeding, foraging 3 5/12/83 Bolsa Chica State Beach 6-7 1 traveling 4* 7/18/83 Bolsa Chica State Beach 6 traveling 4* 7/18/83 Newport Beach 25-30 traveling 5 7/24/82) Huntington State Beach 20-25 traveling 6 7/29/83 Newport Beach 40-45 traveling 7 7/31/83 San Onofre State Beach 30-35 4 foraging, feeding 8 8/3/83 Bolsa Chica State Beach 25-30 milling, foraging, feeding 9 8/7/83 Bolsa Chica State Beach 25-30 milling, foraging, feeding 10 11/14/83 none seen 0 -- 11 11/22/83 none seen 0 -- 12 11/30/83 Huntington City Beach 20-25 4 milling, foraging, feeding 13 12/04/83 San Clemente State Beach 5 traveling 14 12/13/83 Newport Beach 25-30 foraging, feeding 15 3/12/84 Huntington State Beach 6 1 milling 16 4/09/84 none seen 0 -- 17 4/18/84 Huntington State Beach 25-30 2 foraging, feeding 18 4/22/84 Huntington State Beach 35-40 play, foraging, feeding 19 5/14/84 none seen 0 -- 20 6/26/84 Bolsa Chica State Beach 25-30 5 milling, play 21 7/03/84 none seen 0 -- 22 7/17/84 Irvine Coast 8 1 traveling 23 9/29/84 Bolsa Chica State Beach 20-25 5 traveling 24 10/28/84 Huntington State Beach 5-6 feeding 25 11/11/84 none seen 0 -- 26 11/18/84 San Onofre State Beach 8-10 2 traveling 27 11/19/84 Bolsa Chica State Beach 15-20 2 play, milling 28 12/02/84 San Onofre State Beach 15 3 play, milling 29 2/23/85 San Onofre State Beach 18-20 2 foraging, feeding 30 3/16/85 none seen 0 31 8/13/85 San Onofre State Beach 25-30 play, milling, feeding 32 9/08/85 Bolsa Chica State Beach 25-30 2 play, feeding 33 9/15/85 none seen 0 34 10/06/85 Newport -Point Loma Beaches 32-39 play, traveling 35 12/15/85 Doheney State Beach 7 traveling *separate pods sighted the same day 89 seven were of either the northern or southern Calves • portions. There were seven spring surveys (March, April May),10 in summc;r (June, July, August),11 in fall (September, October and November) and seven in winter (December, January, February). Number of Pods and Distribution We observed 28 separate pods between 1982 and 1985. Eighteen ,pod sightings occurred at the northern end of the study area: off Bolsa Chica State Beach, south Huntington State Beach, and north Newport State Beach. Seven took place at the far south end of the study area, off San Onofre State Beach. The three remaining sightings oc- curred between Newport and San Onofre State Beach. On only one survey trip did we sight more than one pod; on our fourth trip we spotted two. Pod Sizes Pod sizes ranged from six to 42 dolphins, with a median of 21. There were 22 or more animals in 14 of the groups. We saw only one significantly larger pod, of 42 dolphins. The most common size was between 20 and 30 animals. Pods of six to eight were so rare that we usually followed for some time to see if they regrouped with other dolphins. Individuals Sighted and Identified We sighted a total of 581 individual dolphins, and from all photos, 89 dolphins were identified. Resightings Animals photographed more than once were sighted an average of fewer than three times. Of the 89 identified animals, 59 (66%) were photographed once, 21 twice, and 5 three or more times. The record was of a dolphin photographed five times (Table 2). The proportion of calves to the whole group, summarized by month and across years, was 6.9%. We generally observed and recorded two to four calves in each pod. On two occasions we observed what appeared to be dolphin births. Beach -stranding recoveries, necropsies, and tissue analysis Between 1983 and 1986, ten bottlenose dolphins were examined after stranding on Orange County beaches (Table 3). These included one adult female, six juvenile to adult males, one neonate female, one neonate of undetermined sex, and one dolphin whose sex and age could not be deter- mined because of advanced decomposition. We performed necropsies on six of the stranded dolphins and removed tissue for chemical analysis. Some bore injuries and all bore multiple pathologies that included stomach ulcers, parasitic infestations, enlarged lymph nodes, ver- miniferous pneumonia, infected organs, infected wounds, cysts, and tumors. One, a male juvenile, showed signs of having been entangled and sub- sequently drowned in a gill net: his epidermis bore net cuts, his tail had been sliced off at the peduncle, and his trachea contained frothy foam. All tissue samples (including blubber, muscle, Ever, kidney, and brain tissue) revealed high levels of the pesticide DDT (range 150 to 1,922 ppm; average for blubber 854 ppm) and of the industrial chemical PCB (range 3.1 to 265 ppm; average for blubber 105 ppm). DISCUSSION Distribution Dolphin pods were observed throughout the study area, but never more than 1 km offshore. On most occasions, the dolphins of a pod were spread out over 500 to 1,000 m of coastline in several subgroups that frequently coalesced and then broke apart in a fluid and unpredictable manner. It was not uncommon for one subgroup to swim 0 0 • TABLE 2. Dolphins relighted off the Orange County coast, and the intervals between Orange County sightings. Additional sightings of these dolphins off the San Diego coast are listed in parenthesis and italics. Date Date ID Sighted Location Interval ID Sighted Location Interval 003 5/21/83 Bolsa Chica 055 (7120182 San Diego coast) 11/14/83 Newport Beach 6 mo 11/30/83 Huntington Beach (4110185 San Diego coast) 4/22184 Huntington Beach 4.7 mo (6123185 San Diego coast) 004 (10123181 San Diego coast) 817/85 Bolsa Chica 10/6/85 Newport Beach 2 mo 12/15/85 Doheney Beach 2.3 mo 017 (7127182 San Diego Coast) 7/31/83 San Onofre 8/3/83 Bolsa Chica 3 days (3117184 San Diego coast) (813184 San Diego coast) (511185 San Diego coast) 021 (812182 7/18/83 7/31/83 8/3/83 (6110184 (7113184 (2123186 (419186 (3/24/84 4/22/84 12/2/84 (513186 (617186 047 (6118182 12/29/82 7/18/83 048 (1114182 (8124184 12/2/84 2/23/85 (7131185 (1116185 (4125186 San Diego coast) Newport Beach San Onofre 13 days Bolsa Chica 3 days San Diego coast) San Diego coast) San Diego coast) San Diego coast) San Diego coast) Huntington Beach San Onofre 7.3 mo San Diego coast) San Diego coast) San Diego coast) San Onofre Newport Beach 6.6 mo San Diego coast) San Diego coast) San Onofre San Onofre 2.7 mo San Diego coast) San Diego coast) San Diego coast) 0 1 91 057 (812182 San Diego coast) 8/3/83 Bolsa Chica 10/6/85 Newport Beach 2 yr 2 mo (4-25-86 San Diego coast) 065 (7127182 San Diego coast) 7/29/83 Newport Beach 8/3/83 Bolsa Chica 5 days (11116185 San Diego coast) (419188 San Diego coast) 079 (10123181 San Diego coast) 8/3/83 Bolsa Chica (11116183 San Diego coast) 2/23/85 San Onofre 1.6 yr (6123185 San Diego coast) (6126185 San Diego coast) 090 (3124184 San Diego coast) 4/22/84 Huntington Beach (218185 San Diego coast) 10/6/85 Newport Beach 1.5 yr (12119185 San Diego coast) (4111186 San Diego coast) 095 (8130182 San Diego coast) 4/30/83 Huntington Beach 8/7/83 Bolsa Chica 3 mo 4/18/84 San Onofre 7.4 mo (7113184 San Diego coast) (6123185 San Diego coast) (continued) TABLE 2 (continued). Date Date ID Sighted Location Interval ID Sighted Location Interval 100 (11120181 San Diego coast) 187 11/30/83 Huntington Beach 12/13/83 Newport Beach (1112184 San Diego coast) (3117184 San Diego coast) 10/6/85 Newport Beach 1 yz 10 mo (3124184 San Diego coast) 4/18/84 Huntington Beach 4 mo 209 (319184 San Diego coast) 4/22/84 Huntington Beach 4 days 4/18/84 Huntington Beach 10/28/84 Huntington Beach 6 mo 4/22/84 Huntington Beach 4 days 12/2/84 San Onofre 1 mo (3116185 San Diego coast) (2127185 San Diego coast) (7124185 San Diego coast) 216 (2115185 San Diego coast) (7131185 San Diego coast) 2/23/85 San Onofre 10/6/85 Newport Beach 7.5 mo 106 (1114182 San Diego coast) 7/31/83 San Onofre 217 7/1/83 Newport Beach 8/3/83 Bolsa Chico 3 days 8/3/83 Bolsa Chica 1 mo (3116184 San Diego coast) 9/8/83 Bolsa Chica 1 mo (518185 San Diego coast) (2115185 San Diego coast) (1116185 San Diego coast) (5126186 San Diego coast) 282 7/31/83 San Onofre 8/7/83 Bolsa Chica 1 wk 108 (114183 San Diego coast) 7/31/83 San Onofre (6118184 San Diego coast) 12/15/85 Bolsa Chica 2 yr 5 mo 116 (10123181 San Diego coast) 12/13/83 Newport Beach 12/15/85 Doheney Beach 2 yr 121 (9128181 San Diego coast) 4/22/84 Huntington Beach 2/23/85 San Onofre 10 mo 127 8/3/83 Bolsa Chica 811/83 Bolsa Chica 4 days far away from the majority of dolphins, disappear for 30 to 40 minutes, and subsequently rejoin the larger group. Distribution of the dolphins in the study area did not appear random; the dolphins showed a definite bias for specific locations. Dolphin pods were found more frequently in the northern part 92 285 8/3/83 Bolsa Chica 10/6/85 Newport Beach 2 yr 2 mo 287 8/7/83 Bolsa Chica 10/28/84 Huntington Beach 1 yr 2 mo 291 4/18/84 Huntington Beach 9/8/85 Bolsa Chica 1 yr 4 mo 299 10/6/85 Newport Beach 12/15/85 Doheney Beach 2.3 mo of the study area than in any other place; 64% of the sightings were between north Newport Beach and Bolsa Chica State Beach. Most of the remain- ing sightings, 25% of the total, occurred at the southern extreme in an area, significantly, with similar topography: shallow, sandy -bottomed, low relief beach with few or no rocky headlands, off- shore rocky reefs, or offshore submarine canyons. is 0 :7 TABLE 3. Tursioas ouncatus Stranding Data 1983 - 86. ID No., Sex, Date, Location, Necropsy Tissue Analysis (ppm) Length, Wright Decomposition 'Results DDT PCB DK8318 5/5/83 stomach ulcer, blubber: 1,933 128 male Surfside Beach parasites, emaciated' muscle2: 20 0.8 266 cm, wt. na decomp. slight DK8323 8/11/83 na na na sex undeterm. Newport Beach 89 cm, wt. na decomp. slight DK8324 9/15/83 na na na sex undeterm. Newport Beach 240 cm, wt. na decomp. slight DK8325 9/29/83 stomach parasite, muscle: 17.5 0.2 male Newport Beach emaciated liver4: 121 23 289 cm, wt. na decomp. moderate DK8329 12/27/83 na na na female Crystal Cove 259 cm, wt. na decomp. advanced DK8411 10/25/85 chronic enteritis, blubber: 400 27 male Doheney Beach emaciated liver: 68 7 285 cm, 222kg decomp. slight DK8503 3/12/85 verminiferous blubber: 150 3.1 female Crystal Cove pneumonias liver: 144 15 128 cm,17.2 kg decomp. slight DK8519 10/5/85 large forestomach na na male Bolsa Chica ulcer, pneumonia6 218 cm, 227 kg decomp. slight DK8603 3/30/86 ulcer, gastritis, blubber: 910 265 male Newport Beach abcess kidney: 117 38 312 cm, 590 kg decomp. slight DK8609 5/31/86 na na na male Huntington Beach 244 cm, wt. na decomp. advanced 'L.A. County Museum of Natural History 5Dr. Dawson, Dept. of Psychobiology, UC Irvine 2So. Calif. Coastal Water Research Project 6D. Kelly, Orange Coast College 3Dr. Haight, Orange County Animal Shelter 7Dr. Britt, L.A. County Veterinary Service OOrange County Sanitation District na = information not available This general topography in both areas extends along the coast and off shore for several miles. Within these areas dolphins often exhibited hunting behavior (swimming in echelon formation perpendicular to shore), or were actually ob- served chasing, catching and eating fish. Addi- tionally, pods sighted between those locations were constantly moving either northerly or southerly towards the high -density areas. It is hypothesized that both the northern and far southern areas represent significant forage loca- tions for dolphins. The two possible dolphin births observed were within the middle area (south Newport Beach to San Clemente Beach), where, as indicated above, pods were infrequently observed. Also, both were in sheltered bays (Scotsman's Cove and Niguel Beach), not heavily used by humans and without high -density residences on the cliffs above. Such areas, uncommon now along the Orange County Coast, may also represent significant habitat to this species. Site Fidelity No evidence was found that identified any in- dividual as a year-round or even seasonal resident of the study area. Calf Percentages Our finding of 6.9% calves is high compared to the percentages reported in most studies. How- ever, only a fraction of calf percentages in the literature are based on year-round observations (Gruber,1981; Leatherwood and Reeves, 1980). Data based on long-term observation have been reported by Wells and his colleagues in the Sarasota study area (Wells, Irvine and Scott, 1980); by Shane (1977, 1980); by Gruber (1981), along the Gulf Coast of Texas; and by Hansen (1983). Most of these researchers report calf proportions of approximately 7%.The low proportion reported in the Sarasota study (4%) probably reflects the maximum reproductive rate that can be maintained in that relatively isolated environment. Population Statistics The validity of our population figures rests on the following assumptions: 1) Identified and unidentified animals are ran- domly mixed 2) Animals once idendfed are always correctly identifiable thereafter. (We restricted ourselved to clear slides of distinctively notched dorsal fins. Further, we were often able to document altera- tions in the notch pattrrn of previously photographed animals.) 3) All identifiable (distinctively notched) in- dividuals in a school are photographed. (The proportion of identifiable animals photographed probably approached 100% when the school size was small, and declined when it was large. The net effect of missing any animals would be to err on the conservative side in our estimates.) 4) Our correction factor is accurate. Estimating the number of animals in a study area begins with a consideration of the proportion of photographically identifiable animals in samples. Hansen (1983) identified 118 individuals in his studies along the coast of north San Diego County, and estimated a population numbering between 173 and 240. The number of individuals we iden- tified photographically can be used to make a similar estimate of the minimal number of in- dividuals using the Orange County coast. Since our population estimate from photo-iden- tificatio.i refers only to those animals in the population with distinct dorsal fins, it must be corrected to account for the non -distinct fraction. Our estimates of the proportion of animals with distinct dorsal fins (i.e., possessing two or more notches) ranged from 60 to 70%, averaging 65%. Calves always had smooth fins, and the slightly larger animals, judged to be sub -adults, also had characteristically smooth or single -notched fins. Size/age distribution data presented by Wells (1978) from capture operations on 100 bottlenose dolphins in the Gulf of Mexico showed that 48% of their animals were either calves or sub -adults. • is 0 Even allowing for selection bias in the capture process, their data tend to support our estimate of the fraction of calves and subadults, or perhaps suggest that it may be conservative. .Assuming that the fraction of indistinct animals was 35%, we obtain an adjusted estimate of 137 as the number of individuals seen in the Orange County study area between 1983 and 1985. The role of contaminants All tissue samples (including blubber, muscle, Ever, kidney, and brain tissue) revealed high levels of the pesticide DDT (range 150 to 1,922 ppm; average for blubber 854 ppm) and of the industrial chemical PCB (range 3.1 to 265 ppm; average for blubber 105 ppm) (Table 2). These are extremely high levels of DDT and PCBs in all tissues ex- amined compared to California Sea Lions pre- viously examined (Britt and Howard, 1983), but not quite as high as some levels reported pre- viously in bottlenose dolphins for the same area (O'Shea et al.,1980). De Long et al. (1973) reported a significant cor- relation between premature sea lion births and DDT concentrations, but pointed out that the correlation did not indicate a cause -effect relationship and that other causes were possible. Halle et al. (1976) correlated PCB concentrations with increased uterine lesions and reduced reproductive success in ringed seals fom the Baltic Sea, but the PCB concentrations were higher than those found in California animals. Several inves- tigators (Gaskin, 1982; Britt and Howard, 1983) have speculated that high organochlorine levels may impair the immune system of the marine mammals and therefore increase their suscep- tibility to infection and disease. In studies of dead, beach -stranded bottlenose dolphins reported by O'Shea et al. (1985) from Southern California, tissue sampling revealed ex- traordinarily high body burdens of DDT and PCBs in all tissues examined. Similar findings were reported after a disaster to the East Coast population of coastal bottlenose dolphins between the summer of 1987 and January 95 1988. Unprecedented numbers washed ashore at that time along the Atlantic Coast from New Jer- sey to Florida, with 740 bodies recovered and mortality estimated at up to 2,500 dolphins. Deaths exceeded 50% of the East Coast migratory stock. A comprehensive investigation of proximate and contributing factors unparalleled in cetological history (Geraci, 1989) revealed levels of contaminants (organochlorines) in the dolphins' blubber among the highest ever recorded for a cetacean; in addition, a host of bacterial and viral pathogens produced an array of clinical signs. The dolphins were apparently poisoned by brevitoxin, a neurotoxin produced by the dinoflagellate Pt rhodiscus brevis, Florida's red tide organism. But in his final report, Geraci (1989) stressed the urgency of learning what role contaminants play in dolphin mortality: "The results from the beach -cast specimens ob- viously reflect the levels of contaminants in the nearshore environment, where the dolphins ac- cumulate these substances... Free -ranging animals facing intermittent food supply, or mobilizing fat during lactation, migration or times of illness, release compounds from this depot (body fat) into vital, perhaps more critical organs such as the liver. Geraci concluded: "The overwhelming nature of some of the infec- tions, which probably arose in the lung, may have been related to immunoincompetence, the cause of which cannot be established. The depletion of lymphoid follicles in spleen, lymph nodes, and the intestine supports this suggestion. "Equally important is the need to resolve the growing question of whether contaminants at levels found in the dolphins might have affected their resistance and rendered them more suscep- tible either to the toxin or to the microortanisms that eventually brought them to their demise The present study cannot add evidence to sup- port or disprove the hypothesis that contaminants render dolphins more susceptible to other toxins and microorganisms. CONCLUSIONS A much larger population of bottlenose dolphins (89 to 137) appears to use and visit the coast of Orange County than has been previously reported (Kelly,1983). The dolphins seem very flexible and fluid in their use of the entire coast of Southern California. Pods of dolphins exhibit a preference for areas at the northern end of the coast (north Newport Beach, Huntington Beach, and Bolsa Chica State Beach) and the far southern end (San Onofre State Beach), areas we believe are sig- nificant for foraging. Furthermore, it is hypothesized that certain coves within the middle portion of the coastline (Irvine Coast to Scotsman's Cove and south Lagunas Beach to Niguel Beach) represent im- portant habitat for dolphins giving birth. The cause of this may be the area's relatively low human density -- the lowest on the Orange County coast. The population contains individuals from neonates to adults who carry burdens of DDT and PCBs among the highest recorded for any mam- mal worldwide. This does not bode well for the future health of the Orange County coastal bot- tlenose dolphin population, and indicates the im- portance of further and more comprehensive study if we wish to know what the future holds for these important members of our coastal marine community. ACKNOWLEDGEMENTS This work, carried out at Orange Coast College by the Dolphin Survey Project, was funded and supported by the Associated Students of Orange Coast College, the Marine Research Group (an O CC student club), and both the Marine Science Department and the Math and Science Division of the college. Many individuals contributed their time and help over the years to keep the project afloat. 96 Generous financial support came from the Orange County Chapter of the American Cetacean Society and from individuals. The author is most grateful for all their help. Mike Couffer, Patty Leiberg, Larry Kepko, Lisa Flourney, Don Johnston, Marty Morales, Ted Bennett, Ron Jones, Dave Beeninga, and Robert (Rip) Profeta are only a few of the important contributors to this research effort. The author would also like to thank R.H. Defran, Cetacean Behavior Laboratory, San Diego State University, for his encouragement and support through the many trials and tribulations of the last three years. Special appreciation is also extended to Henry Schafer and his fellow scientists at the Southern California Coastal Water Research Project, in Long Beach; Dr. Robert Haight and Dr. Nyla Kelly, of the Orange CountyAnimal Shelter; Dana Seagars, Larry Hansen, Jim Lecky, and Sheridan Stone, of the National Marine Fisheries Service; and Dr. John Heyning and Dr. Dan Patten, of the Los Angeles County Museum of Natural History. To all of those additional good spirits who lent a hand and helped make this happen: many thanks. SPECIAL NOTE An award -winning documentary film about these dolphins, entitled Dolphins of the Orange Coast, was written, photographed, produced and edited by George Gumbrecht, telemedia director for Orange Coast College. It is available for view- ing, rental or purchase from Orange Coast Col- lege, 2701 Fairview Road, Costa Mesa, California 92626. REFERENCES Britt, J.O. and E.B. Howard. 1983. Tissue residues of selected environmental contaminants in marine mammals. In Pathobiology of Marine Mammal Diseases, E.B. Howard (ed.). CRC Press, Boca Raton, Florida. Defran, R.H. and G.M. Schultz, 1988. A tech- nique for the photographic identification and • .' 0 cataloging of dorsal fins of the bottlenose dolphin (Tursiops ouncatus). International Whaling Com- mission Symposium on the use of non -lethal tech- niques, especially photo -identification techniques in the assessment of cetacean population parameters. La Jolla, California. Defran, R.H., GA. Shultz, MA. Espinoza, and A.C. Weaver. 1985. The population biology of along the Southern California and northern Baja coastline. Sixth Biennial Conference on the Biol- ogy of Marine Mammals, Nov. 22-26, Vancouver, British Columbia, Canada. Defran, R.H., D.L. Kelly, G.M. Shultz, A.C. Weaver, and M.A. Espinoza.1989. The occurence and movements of the bottlenose dolphin in the Southern California bight. Manuscript accepted by Marine Mammal Science, J. Soc. for Marine Mammology. DeLong, R.L., W.G. Gilmartin, and J.G. Simpson.1973. Premature births in California sea lions: association with organochlorine pollutant residue levels. Science 181:1168-1170. Dohl, T.P., K.S. Norris, R.C. Guess, J.D. Bryant, and M.W. Honig.1978. Pinnipedia, Cetacea, and parasitology of the Southern California bight area. Vol. III., No. PB-295-932. National Technical In- formation Service, Springfield, Virginia. 473pp. Gaskin, D.C.1982. The Ecology of Whales and Dolphins. Heineman, Exeter, New Hampshire. Geraci, J.R. 1989. Clinical Investigation of the 1987-88 Mass Mortality of Bottlenose Dolphin Along the U.S. Central and South Atlantic Coast. National Marine Fisheries Service, U.SNavy, Of- fice of Naval Research, & Marine Mammal Com- mission. April 1988. Gruber, JA. 1981. Ecology of the Atlantic bot- tlenose dolphin in the Pass Cavallo area of Madagorda Bay, Texas. M.Sc. thesis. Texas A & M Univ., College Station, Texas. Hansen, L.J. 1983. Population,-' biology of the coastal bottlenose dolphin of Southern California. M.A. thesis, Sacramento State Univ., Sacramento, California.104 pages. Helle, E., M. Olsson, and S. Jensen.1976. PCB levels correlated with pathological changes in seal uteri. Ambio 5:261. Kelly, D.L., 1983. Photo -identification of bot- tlenose dolphins in Southern California. Whalewatcher. J. Am. Cet. So.17(2):6-8. Leatherwood, J.S. and R.R. Reeves.1982. Bot- tlenose dolphin and other toothed cetaceans. Pp. 369-414 in JA. Chapman and GA. Feldhamer (eds.). The John Hopkins University Press, Bal- timore, Maryland.1147 pp. Norris, K.S. and J.H. Prescott. 1961. Observa- tions on Pacific cetaceans of California and Mexican waters. Univ. Ca. Publ. Zool. 63:291- 402. Orr. R.T.1963. A northern record for the Pacific Bottlenose dolphin. J. Mamm. 44(3):424. Orr, J.M.1976. A survey of Tursiops populations in the coastal United States, Hawaii, and ter- ritorial waters. Contract No. MM7AD-028. Marine Mammal Commission. Washington D.C. 13pp. O'Shea, T.J., R.L. Brownell, D.R. Clark, WA. Walker, M.L. Gay, and T.G. Lamont. 1980. Or- ganochlorine pollutants in small cetaceans from the Pacific and South Atlantic Oceans. November 1966-June 1976. Pesticides Monitoring J. 14(2):35-36. Sargent, D.E., D.K. Caldwell and M.C. Caldwell.1973. Age, growth, and maturity of bot- tlenose dolphin from northeast Florida. J. Fisheries Res. Board Canada 30:1009-1011. Scammon, C.M.1874. The Marine Mammals of the Northwestern Coast of North America, described and illustrated; together with an ac- count, of the American whale -fishery. John H. Carmany and Co. San Francisco, California. 319pp. Schafer, H.A., R.W. Gossett, C.F. Ward, and A.M. Westcott. 1985. Chlorinated hydrocarbons in marine mammals. In Southern California Coas- tal Water Research Project Biennial Report, 1983-1984,pp.109-114. Scott, G.P., D.M. Burn, and L.J. Hansen, 1988. The dolphin die -off: long-term effects and recovery of the population. Proceedings of the Oceans '88 Conference. Baltimore, Maryland, October 31- November 2,1988. Shane, S.H.1977. The population biology of the Atlantic bottlenose dolphin, in the Aransas Pas- sarea of Texas. M.Sc. thesis, Texas A &M Univer- sity, College Station, Texas. 239 pp. Shane, S.H. 1980. Occurrence, movements and distribution of bottlenose dolphins in southern Texas Fishery Bulletin (U.S.) 78:593-601. Shane, S.H., R.S. Wells, and B. Wursig. 1986. Ecology, behavior and social organization of the bottlenose dolphin: a review. 2:34-63. Walker, W.A. 1981 Geographical variation in morphology and biology of bottlenose dolphins in the eastern North Pacific. National Marine Fisheries Service/Southwest Fisheries Center Ad- ministrative Report No. IJ-81-03C. La Jolla, California. Wells, R.S. 1978. Home range characteristics and group composition of Atlantic bottlenose dol- phins on the west coast of Florida. M.Sc. thesis, Univ. of Florida. Well, R.S., A.B. Irvine and M.D. Scott. 1980. The social ecology of inshore odontocetes. Pp. 263-317 in L.M. Herman (ed.). Wells, R.S., T.P. Dohl, L.J. Hansen, A.B. Baldridge, and D.L. Kelly. 1990. Extraordinary movements of bottlenose dolphins (Tursiops sp.) along the coast of California. In The Bottlenose Dolphin, Academic Press. 98 • • 0 REINTRODUCTION OF SEA OTTERS TO SAN NICOLAS ISLAND, CALIFORNIA: PRELIMINARY RESULTS FOR THE FIRST YEAR* by Galen B. Rathbun, Ronald J. Jameson, Glenn R. VanBlarlcom2, and Robert L. Brownell, Jr.1 'U.S. Fish and Wildlife Service P.O. Box 70, San Simeon, CA 93452 2U.S. Fish and Wildlife Service Institute of Marine Sciences University of California Santa Cruz, CA 95064 ABSTRACT The sea otter (Enhydra lufts) population in California is considered threatened because of its restricted distribution, small size, and the threat of a catastrophic oil spill. The Recovery Plan for this population calls for a second, disjunct popula- tion to be established by translocation at San Nicolas Island, California. From August 1987 through August 1988, 124 sea otters were cap- tured along the central California coast. Fifty of these were released at capture due to sex and age -class restrictions, and the remaining 74 were taken to the Monterey Bay Aquarium in prepara- tion for transport by air to the island. Four sea otters died at the aquarium, one was returned to its capture site, and 69 were successfully flown to San Nicolas Island and released. By 31 August 1988, the fate of 38 sea otters was known (14 were still on the island), and the fate of 31 was unknown. This paper is also being published in: Proceedings of the 5th Biennial Mugu Lagoon/San Nicolas Island Ecological Research Symposium, Naval Air Station, Point Mugu, California. LZ Preliminary data analyses from the ongoing reintroduction suggest that some life history traits of sea otters, such as susceptibility to capture - stress and strong homing behavior, are important factors to consider in successfully establishing a new colony. The data also suggest that juveniles and adults may have different tendencies to dis- perse from the island. INTRODUCTION Sea otters (Enhydra lutris) historically occurred throughout the Channel Islands of Southern California, including San Nicolas Island (SNI). They were extirpated from Southern California, including the Channel Islands, by fur hunters in the mid -to -late 19th century. By the time protec- tion was afforded, only a small population off the Big Sur coast of central California survived. This population increased by about 5% per year until the mid-1970s (Miller, 1980), when it reached about 1,800 individuals (Geibel and Miller,1984). Sea otter numbers then stabilized, or possibly declined, until the mid-1980s (Riedman and Estes, 1988). Presently, the population appears to be growing again (U.S. Fish and Wildlife Service, unpublished data). In 1977, the southern sea otter was listed as "threatened" on the Endangered and Threatened Wildlife and Plants List mandated under the federal Endangered Species Act. A primary reason for this listing was the potential effect of a large oil spill on this small and geographically isolated population (Ladd,1986a). One of the major objectives of the Southern Sea Otter Recovery Plan (U.S. Fish and Wildlife Ser- vice,1982) is to establish at least one additional population of southern sea otters by reintroduc- tion. This would reduce the threat to the total population in the event of a large oil spill. The events leading to the reintroduction of sea otters to San Nicolas Island have been reviewed in several publications (Ladd, 1986a, 1986b; U.S. Fish and Wildlife Service, 1987; Brownell and Rathbun, 1988). Briefly, not only will the reintroduction reduce the effects of a large oil spill on the existing population, but it also offers an invaluable opportunity to study translocation and containment techniques, gather data on sea otter population dynamics and ecology, and monitor the effect of these animals on the nearshore com- munity around San Nicolas Island. Translocation and reintroduction are defined differently by different authors. We have used the definitions of the International Union for the Con- servation of Nature and Natural Resources (IUCN,1987): "Translocation is the movement of living organisms from one area with free release in another." "Re -introduction" is a subset of trans - location, and is defined as "the intentional move- ment of an organism into a part of its native range from which it has disappeared or become extir- pated in historic times as a result of human ac- tivities or natural catastrophe." After all the documentation necessary to carry out the translocation was completed (i.e., En- vironmental Impact Statement, permits, etc.) cap- ture operations were started along the central California coast in August 1987. In this report, we review the results from the first year of the reintroduction. CAPTURE AND TRANSPORT Three methods of capturing sea otters were used by U.S. Fish and Wildlife Service (USFWS) and California Department of Fish and Game (CDFG) biologists: dip nets, Wilson traps, and tangle nets (Ames et al., 1986). Dip -net teams were most effective in capturing subadults and males, while Wilson -trap teams were most effi- cient at capturing adults and females (Table 1). The differences in the ages and sexes of sea otters captured by the two methods relate to the dis- tribution of sea otters in the capture area, limita- tions of each technique, and selection for subadult females by the capture teams. Generally, along the central California coast subadult females in open water are found closer to shore than are subadult males, and males tend to form larger rafts in kelp beds than do females (Ralls et al., 1988; USFWS, unpubished data). Dip nets are effective only when used in open water during calm weather, whereas Wilson traps are most ef- fective when used within nearshore kelp beds with good water visibility during slightly windy weather. All capture teams avoided large groups of males and concentrated on resting sea otters. A total of 124 sea otters was captured between Point Buchon and Pacific Valley from 24 August 1987 through the end of August 1988 (Figure 1). Fifty of them (38 males,12 females) were weighed, tagged and released immediately at the capture TABLE 1. Summary statistics for sea otters captured for potential reintroduction to San Nicolas Island, August 1987 through August 1988 Dip Net Wilson Trap Tangle Net Total Total Captured 81 37 6 124 Sex Ratio, M/F 51/30 4/33 0/6 55/69 Mean Weight, kg (N) 14.6 (79) 19.3(36) 16.8(4) 16.1(119) Standard Deviation, kg 4.4 4.6 8.2 5.0 Range, kg 8.6-29.9 8.2-30.4 10.0-28.1 8.2-30.4 100 0 site because they did not satisfy age and sex criteria for reintroduction to San Nicolas Island (Table 2). Since we wished to maximize the reproductive potential of the new colony, we selected mostly subadult sea otters, which usually weigh under 40 lb (18 kg) (USFWS, unpublished data). Animals less than 18 lb (8.2 kg) were con- sidered too young and were not retained for the translocation. No sea otters weighing more than 18 kg were retained for translocation after Oc- tober 1987. A male/female sex ratio of 1/4 at San Nicolas Island was desired; therefore, we released at capture numerous males within the acceptable weight range. The 74 sea otters kept for reintroduction were taken to shore bases at Point Piedras Blancas and Morro Bay (Figure 1) by the capture teams or a shuttle boat. They were on the boats for up to 2 hr, but usually less than 1 hr. Once at a base, each animal was transferred from a wooden holding box (Figure 2) or 114-liter plastic barrel to a modified airline pet kennel (Figure 2) and.put into an air-conditioned van (maintained at about 15°C) capable of holding up to six kennels. Sea otters were held in vans for up to 1 hr while additional sea otters were captured, and then driven to the Monterey Bay Aquarium to be prepared for shipment to San Nicolas Island. CAPTIVITY The transport time from the shore bases to the Monterey Bay Aquarium was about 2.5 hr. At the aquarium, sea otters were transferred from the kennels to a temporary holding pool or directly into a restraining box. Most sea otters captured after September were first placed in the 3-m- diameter, 1-m-deep holding pool for about 10 to 20 min to allow them to cool off and calm down before being transferred to the restraining box Three procedures were performed while each animal was restrained in the box First, a colored plastic ear tag (Original Cattle -size, Temple Tag Co., Temple, Texas) was fitted on each rear flip- per. Each sea otter was individually marked by varying the color and position of each tag (Ames 101 et al.,1983). The small plug of tissue taken from the interdigital webbing during tagging was saved for genetic studies. Second, a passive implantable transponder (PIT) tag about the size of a rice grain was injected subcutaneously into each sea otter (Destron/IDI, Inc., Boulder, Colorado; Thomas et al., 1987). An electronic scanning device is required to read the unique code from each PIT tag. Presence of a PIT tag allowed positive reidentification of recovered or recaptured sea otters that were missing one or both flipper tags. Third, a 20 cc sample of blood was drawn from each animal by the project veterinarian, usually from a venous sinus in the right femoral area. Blood samples were immediately treated with heparin, an anticoagulant, and refrigerated. A subsample of the blood was promptly taken to a local commercial laboratory for determination of a standard blood profile (Williams and Pulley, 1983). The remainder of the blood sample, along with the frozen tissue obtained during flipper tag- ging, was sent via air express in a refrigerated container to the National Cancer Institute in Frederick, Maryland, for studies of genetic heterogeneity and mitochondrial DNA charac- terization. The average time required to com- plete procedures in the restraining box was 10 to 12 min (range = 8 to 18 min). Upon removal from the restraining box, each sea otter was transferred immediately to one of two holding pools that were supplied with filtered, continuously circulating seawater that completely turned over about once per hour. Typically, about 30 min elapsed between arrival of a sea otter at the aquarium and its placement in a holding pool, although the time was somewhat longer when several sea otters arrived in the same van. Holding pools were 5.5 in in diameter, with walls 1.5 in high and an additional OS in of wire mesh above the tank wall. Water depth was about 1 m. Each pool was equipped with two haulout plat- forms, as well as surface -skimming weir boxes to remove floating food fragments, sloughed fur, and feces. Up to 12 sea otters were held in each pool at the Monterey B ay Aqu arium for periods ranging from 1 to 10 days (Table 3). During the holding phase, acific Valley 12 (� 2 ) Cape San Martin r Alder Creek N "an C 100 mt Francisco C' �_1 � may 200 km VONTEREY Pt. ConcaptlAn 1. Concbit. Et. Mugu County Line „pa LOS ANGELES ' b Din Diego Salmon Creek 28 SAn Nicolas (23%) Bagged Pt. Island Pt. Sierra Nevada 19 (15%) t. Piedras Blancas San Simeon Pt. 19 (15%) Cambria 0 (D%) Pt. Estero N Estero 46 Bay (37%) Morrr 0 10 mi 1 1 20 km —Buchon y FIGURE 1. Map of Southern California, illustrating important sea otter sites between Monterey and San Nicolas Island. Locations where dead sea otters were recovered on the mainland are also shown (see text). The inset illustrates the distribution of sea otters captured for translocation. The figures between the parallel, solid lines are the total number of sea otters captured per segment. The percentage of the total captured (N = 124) per segment is in parentheses. 102 0 0 0 ,0 0 TABLE 2. Translocation Summary, 31 August 1988 Total Captured 124 Total to Monterey Bay Aquarium 77 4 Died at Monterey Bay Aquarium 4 Returned to capture site from Monterey Bay Aquarium 1 Taken to San Nicolas Island (16 males, 53 females) 69 Fate known Remaining at SNI' 14 Died at San Nicolas Island 3 Dead on mainland 2 Died in fishing gear 3 Dead? (radio implant) 2 Returned to mainland & captured 1 Returned to central coast 13 Total 38 Fate unknown 69 - 38 = 31 • Includes 3 sea otters not individually identifiable because of loss of flipper tags sea otters were monitored 24 hr per day. Ob- servers took notes on activity, feeding, interac- tions with other sea otters, and especially on any behavioral indications of stress. Sea otters were fed (freshly thawed frozen clam and squid, and live rock crabs when available) four times per day, an amount equivalent to about 25% of body weight per day. Holding pools were cleaned at least twice per day. Cleaning involved siphoning or netting debris from the pool in a manner in- tended to minimize disturbance to the captive sea otters. Twenty two sea otters showed some signs of stress while in holding pools. The most frequently occurring symptoms were shivering and refusal of food. Seventeen of the stressed sea otters were treated successfully and eventually transported to San Nicolas Island. Treatment involved isolation, 103 removal from sea water to allow warming, and administration of medication (antibiotics, B-com- plex vitamins, tagumet, dexamethazone, and in- traperitoneal fluids). Four animals died while at the aquarium, and each was necropsied at the National Wildlife Health Research Center (NWHRC) in Madison, Wisconsin. The results showed that three died of acute pathological conditions related to stress. The fourth animal died of acute bacterial pneumonia complicated by stress (Nancy Thomas, NWHRC, unpublished necropsy reports). The pneumonia infection could have been contracted prior to capture. One additional animal that showed signs of stress while at the aquarium was retained for 10 days until it recovered, and then it was released at its capture site (Table 2). A) D) FIGURE 2. A) A plywood box, measuring about 45 cm wide, 85 cm long, and 55 cm deep, was used on capture boats to secure and transport sea otters. The nylon net over the mouth of the box had a purse line around its perimeter to secure the sea otter in a bag after it was dropped into the box. B) A fine - mesh dive bag filled with foam rubber was put into the capture box with each sea otter and served as a pacifier during transport to the shore bases. C) Plastic kennels (Doskocil Manufacturing Co., Arlington, Texas) measuring 55 cm wide, 65 cm high, and 90 cm long were used to transport sea otters. D) The grates supplied with the kennels were modified so that a 3.7 kg block of gel ice (Cold Ice Corp., Oakland, California) could be placed under each grate. The space for the gel ice was created by securing two 2-inch-diameter PVC pipes to each side of each grate with nylon cable ties. RELEASE The sea otters were transported from the aquarium to the Monterey Airport by truck or van, normally in the early morning (0400 to 0900 hrs) to avoid mid -day heat. Sixty nine sea otters (16 males, 53 females) were taken to San Nicolas Island on 13 flights (Table 3). A Convzir 440 aircraft transported the first 50 sea otters in three flights. The remaining 19 animals were taken to San Nicolas in a Cessna 182 in groups of one to three individuals per flight (Table 3). Upon ar- rival, the sea otters were transferred to waiting pickup trucks and driven to the shore. The first 45 animals (Groups 1 and 2, Table 3) were �, released into three floating pens (Ames et al., 1986) anchored approximately 200 m offshore of Sissy Cove (Figure 3). The holding pens were used to acclimate the sea otters to the island before their actual release. An inflatable, 3-m boat ferried one or two animals at a time to the pens. The animals were fed clams immediately upon release into the floating pens, and at about 6-hr intervals thereafter. Considerable care was taken not to disturb the animals unnecessarily while they were in the pens. Both the first and second groups were released from the pens after being.held for about 48 hr. Two animals from Group 1, however, escaped through a small hole immediately after introduction to a pen. The sea t� 0 10 0 0 TABLE 3. Summary of sea otter groups taken to San Nicolas Island for reintroduction August 1987 through August 1988 Days between Group (N) Release Date Capture & Release 1 (24) 29 Aug 87 4 2 (21) 06 Sep 87 6-10 3 (5) 18 Sep 87 4-10 4 (1) 30 Sep 87 1 5 (2) 03 Oct 87 2 6 (2) 24 Oct 87 3 7 (3) 02 Nov 87 3-5 8 (2) 04 Nov 87 7 9 (2) 25 Feb 87 7 10 (1) 22 Mar 88 4 11 (2) 15 Apr 88 2,3 12 (2) 10 May 88 1 13 (2) 09 Jul 88 2 otters were released from the pens at first light by opening one side of each enclosure and allowing the animals to leave at will. Some left immedi- ately, while others took up to 3 hr to leave. Three sea otters from Group 1 died, two while in the floating pens and one soon after release. All three were necropsied by the National Wildlife Health Research Center and were found to be suffering from the effects of stress (Nancy Thomas, NWHRC, unpublished necropsy reports). While in the floating pens the sea otters generally remained agitated and nervous, con- trary to our expectations (Ames et al.,1986). In an attempt to reduce stress, the next 24 sea otters released at San Nicolas Island were taken from the airplane to the beach and released directly into the ocean. Seven sea otters were released at Cor- morant Rock, seven at Cosign Cove, five at Daytona Beach, and five at Sissy Cove (Figure 3). None of the sea otters released directly into the water were found dead near San Nicolas Island. RADIO TRACKING Eleven of the sea otters released at San Nicolas Island during the first year were' fitted with radio transmitters (Table 4). In 1986,30 sea otters were 105 captured in the vicinity of Point Piedras Blancas, implanted with intraperitoneal radio -transmitters designed to last approximately 700 days (Cedar Creek Bioelectronics Laboratory, Bethel, Min- nesota; Garshelis and Siniff,1983; Williams et al., 1983; Ralls and Siniff, 1988), and then released near their capture site. The intent was to collect behavioral and movement data from the radio - tagged animals for about a year and then recap- ture half of the 30 for reintroduction to San Nicolas. Only three implanted sea otters, how- ever, were recaptured, because they became very wary of boats after their initial capture and im- plantation. The process of translocating sea otters is too stressful to combine with implanting radio trans- mitters (K Ralls, personal communication). As an alternative to using the intraperitoneal trans- mitters, 15-g radio tags made by epoxying small transmitters to flipper tags (Figure 4; Cedar Creek Bioelectronics Laboratory, Bethel, Minnesota and Telonics, Inc., Mesa, Arizona; Garshelis and Siniff,1983) were used on eight sea otters (Table 4). These radio tags were attached to the sea otters just prior to their release at San Nicolas Island. The batteries in the 164-MHz transmitters were predicted to last approximately60 days, with 'Vest Point Sissy Cove Cosign Cove �♦ *4Af 4,C0 N Rock Crusher 4 8 All. Band Spit ej Cormorant Rock a Grenadier Point p 2 km l--: Daytona Beach FIGURE 3. San Nicolas Island. Sea otters were released from floating pens off of Sissy Cove. The sea otters released from shore were driven to Sissy Cove, Daytona Beach, Cormorant Rock, Rock Crusher, or Cosign Cove. Sea otters were sighted principally between Grenadier Point and Rock Crusher during post -release surveys. TABLE 4. Sea otters radio tagged at San Nicolas Island from August 1987 through August 1988 ID No. Release Date last Heard Last Seen Longevity (days) Intraperitoneal 175M 29 Aug 87 07 Jan 88 07 Jan 88 132 164F 06 Sep 87 06 Sep 87 06 Sep 87 ... 159F• 10 May88 12 Sep 88 10 Aug88 123 Flipper Tag 2961' 25 Feb 88 25 Feb 88 28 Feb 88 Lost tag 297M 25 Feb 88 07 May 88 17 Jul 88 72 30OF 22 Mar 88 11 May 88 11 Jul 88 51 303F 15 Apr 88 09 Jul 88 11 Jul 88 84 304F 15 Apr 88 04 Jul 88 13 Jul 88 51 307F 10 May88 12 Jul 88 13 Jul 88 63 309M + 09 Jul 88 10 Jul 88 15 Jul 88 1 31OF 09 Jul 88 02 Aug 88 13 Jul 88 25 "See text for details +Telonics radio 106 9 11 0 Transmitter Temple Tag C FIGURE 4. Radio flipper tag used on some of the sea otters reintroduced to San Nicolas Island a pulse rate of about 60/min and a signal duration of about 14 msec. Under ideal tracking condi- tions, the surface-to-surface range of the transmit- ters was 1 to 3 km. Considerable data were gathered on the dis- tribution and movement patterns of the radio - tagged sea otters at San Nicolas Island (USFWS, unpublished data). In general, most of the sea otters settled in an area between Grenadier Point and Rock Crusher, along the western side of the island (Figure 3). Occasional sightings were made outside this area, especially along the southeastern side as far east as Sand Spit and north to West Point. Except for initial post - release movements around the island, sea otters were rarely sighted along the northeastern shore between West Point and Sand Spit (Figure 3). POST -RELEASE RESULTS The fate of 38 sea otters reintroduced to San Nicolas Island during the first year is known (Table 2). By the end of August 1988,16 sea otters were being routinely identified at San Nicolas Island during daily searches (Table 5). Because of the loss of flipper tags, some of the animals could not be individually identified, even though they could be distinguished from each other be- cause of distinctive pelage coloration or mcom- itch plete but unique flipper -tag combinations (Table 6). Three sea otters from Group 1 died of stress -re- lated causes at San Nicolas during, or soon after, release. Two additional animals are known to have died after reaching the mainland; out was found near Point Mugu with a gunshot wound to the head, and the other was recovered at La Con- chita Beach (Figure 1). No cause of death was determined for the second sea otter (Nancy Thomas, NWHRC, unpublished necropsy reports). Fishermen reported two sea otters drowned in lobster pots in the northern Channel Islands, and a third was reported dead in a gill net in the vicinity of La Conchita (Table 2). San Nicolas Island flipper tags were reported or iden- tified from the fishing -gear mortalities, but insuf- ficient information was available to identify individual sea otters. Sixteen sea otters successfully returned to the mainland. Three of these were sighted offshore of the Los Angeles/Ventura county -line area on 10 December 1987 (Figure 1). During a capture ef- fort by California Department of Fish and Game and U.S. Fish and Wildlife biologists on 14 December 1987, one of the three (No. 231, female), with her small pup, was captured, transported, radio -tagged, and released near her original capture site at Alder Creek, about 27 km north of Point Piedras Blancas (Figure 1). She was last sighted near her release site on 26January 1988. The two remaining sea otters (No. 216, female, and No. 278, female) eluded recapture. Thirteen sea otters successfully returned on their own to the mainland population north of Point Conception (Table 7). All were located by sear- ching visually from shore along the coast. The flipper -tag radios provided little information on emigration from San Nicolas Island, because when sea otters swim (disperse from San Nicolas), their flippers (and radio) are under water, where the radio signal is completely attenuated. Sea otter No. 159 had an intraperitoneal transmitter and provided the only detailed information on dispersal from San Nicolas Island. She was last detected at the island on 9 June 1988. During aerial searches she was found near Anacapa Is - TABLE S. Sea otters remaining at San Nicolas Island, 31 August 1988 Capture Date ID No. Sex Weight (kg) Reintroduced 190 M 14.1 29 Aug 87 197 M 15.0 29 Aug 87 213 F 13.6 06 Sep 87 226 F 11.8 06 Sep 87 228 F 16.8 06 Sep 87 232 F 19.5 06 Sep 87 278 F 17.2 24 Oct 87 297 M 16.3 25 Feb 88 303 F 11.3 15 Apr 88 304 F 14.5 15 Apr 88 307 F 15.4 10 May 88 Missing -Missing Dark ? ? ? Missing -Missing Light ? ? ? Red 3/4-Missing F ? ? Mean = 15.0 S.D. = 2.4 land three days later and near Point Buchon on 10 August 1988. She was last successfully radio - tracked at Point Buchon on 12 September 1988. Two additional sea otters, fitted with the reli- able, long-lived intraperitoneal transmitters, are considered dead because,they abruptly disap- peared, despite numerous ground and air radio - tracking searches between Monterey and the Mexican border. Thirty one of the sea otters reintroduced to San Nicolas in the first year disappeared, and their fate is not known (Table 2). Undoubtedly, some of these individuals returned to the mainland population but have not been observed because of the limited time devoted to searching for them and the immense area to be searched. Additionally, these sea otters could have easily escaped detec- tion if they lost oae or both flipper tags, making it impossible to reidentify them. The movements of sea otter No. 278 are par- ticularly interesting. She was initially captured on 108 21 October 1987 off Little Pico Creek, south of San Simeon Point, and transported to San Nicolas and released on 24 October. She was regularly seen at the island until 1 December 1987. She was next seen in the company of two other sea otters on the mainland in the vicinity of the Los An- geles/Ventura county line on 10 December 1987. She was then seen several times back at San Nicolas from 26 January 1988 through 4 February, when she again disappeared. When she reap- peared at the island on 24 April 1988, she was accompanied by a small pup. The pup was last sighted on 26 April 1988. She was not sighted at San Nicolas Island from 2 May through 28 May 1988. From mid -June through August she has been seen regularly at the island. The decline of translocated sea otters at San Nicolas Island during the year was independent of the release method and the number of sea otters taken to, or remaining at, the island (Figure 5). Nor was there any evidence that the decline was related to severe weather, such as the violent storm of 17 and 18 January 1988. However, 0 0 • 0 0 TABLE 6. Missing tags from sea otters reintroduced to San Nicolas Island, August 1987 through August 1988 Color & Position of Missing Flipper Tags (right -left) ID No. Missing -Red 2/3 265 Red 3/4-Missing 270? Missing -Gold 415 201 Missing -Orange 3/4 232 Pink 3/4-Missing 1/2 226 Pink 3/4-Missing ? Missing -Missing, dark head ? Missing -Missing, light head 235? TABLE 7. Sea otters that returned to the California mainland population from San Nicolas Island, August 1987 through August 1988 Capture-resighting SNI-mainland Capture Capture Resighting Distance on Resighting ID No. Sex Wt.(kg) Location Location Mainland (km) Distance (Ian) 199 F 10.9 Piedras Blancas Point Buchon 72 262 202 M 11.8 Ragged Point Cayucos 62 285 282 F 13.6 Jade Cove Pecho Rock 120 323 210 F 14.1 Ragged Point Point Buchon 88 262 204 F 14.5 Ragged Point Shell Beach 112 237 196 M 16.8 Ragged Point Shell Beach 112 237 264 F 17.7 Little Pico Cr. Little Pico Cr. 0 307 194 F 18.1 Ragged Point Ragged Point 0 333 271 F 18.1 Cayucos Point Cayucos Point 0 285 159 F 18.4 Piedras Blancas Point Buchon 72 262 236 F 19.1 Kirk Creek Kirk Creek 0 362 215 F 19.5 Redwood Creek RedwoodCreek 0 346 267 M 28.6 Cayucos Point Cayucos Point 0 285 109 TABLE S. Summary data for reintroduced sea otters by weight class. Only those sea otters reintroduced from mid -August 1987 through October 1987 are included. Sea otters Nos. 175 and 230 were not weighed and were excluded from the analysis. No. (%) No. (%) Mean Weight (kg) N < 18 kg z 18 kg Released 16.0 56 38 (68) 18 (32) Returned 17.2 14 7 (50) 7 (50) Remained 15.4 7 6 (86) 1 (14) resightings of sea otters off the mainland sug- gested that individuals equal to or more than 18 kg returned to the mainland at a rate dispropor- tionate to the number released. To examine this pattern, we analyzed the weight classes (i.e., age classes) of the sea otters released at San Nicolas Island, those that returned, and those that remained. We included in our analysis only those sea otters released at the island from mid -August through October 1987. This was done for two reasons: first, we wanted to analyze dispersal data from individuals that had remained at the island for approximately the same amount of time; second, only one sea otter was released at San Nicolas after October weighing more than 18 kg. The mean weight of sea otters released at San Nicolas (August through October 1987) was 16.0 kg. If sea otters with weights equal to or more than 18 kg are likely to leave the island and those less than 18 kg are likely to stay, then the average weights of these two groups should be respectively higher and lower than the mean of all those released there. This appears to be the case (Table 8), although statistical differences could not be demonstrated. A more revealing analysis is a comparison of the percentages in the two weight classes in the released, returned, and remaining categories (Table 8). Again, the pattern is consis- tent: Thirty-two percent of the sea otters released at the island weighed more than 18 kg, yet 50 % of those returning to the mainland were in this group. An even more dramatic difference was evidenced in August 1988, when only one sea otter with a capture weight greater than 18 kg remained. By 110 contrast, the reverse pattern is true for sea otters with capture weights below 18 kg (Table 8). By 31 August 1988, we could account for 44% of the sea otters with capture weights equal to or more than 18 kg (39% returned to the mainland and 6% remained at the island). However, by 31 August 1988, only 34% of those with capture weights less than 18 kg were accounted for (only 18% returned to the mainland and 16% : emained at the island). This suggests that younger sea otters that leave San Nicolas Island are less likely to survive. DISCUSSION The social structure of sea otters in California is characterized by male home ranges along the coast adjoining or overlapping larger female home ranges. Some males defend these areas ( _ breeding territories) during the summer months. During the winter, many male sea otters leave their summer home ranges and move to areas occupied mostly by males, where they form sexual- ly segregated rafts (Loughlin, 1980; Ribic, 1982; Bodkin and Rathbun, 1988; Jameson,1989). Male sea otters return to the same territories year after year (Jameson, 1989). Ralls et al. (1988) found that some radio -tagged sea otters in California move great distances over extended periods of time (the average distance between extreme loca- tions for juvenile males during a 2-year period = 127.9 km). The spatial organization and move- ment patterns of sea otters in California are probably related to optimal foraging and s • is A. SEA OTTERS REINTRODUCED TO SNI, PENS 100 0-0-0-0-0-0-0-0-0-0-0 90 so 70 O—O Released O60 \ •--• Remaining so (� 40 •` • 30 20. 10 0 S O N D J F M A M J J A o Month (1987 — 1988) B. SEA OTTERS REINTRODUCED TO SNI, BEACH 100 O 90 /0_0� 80 � /O L_ 70.�i� �\ /O'�0 O—O Released "''� 0 0�VZ•��'��` •--• Remaining 50 (n 40 • 30. 20 O 10 0 O N D J F M A M J J A Month (1987 — 1988) FIGURES. Sea otters reintroduced to San Nicolas Island, expressed as the monthly percentage of the total taken to the island (open circles), and individually identifiable sea otters remaining at the island, expressed as the monthly percentage of the theoretical total present at the island during any month (solid circles). Three sea otters present at the island at the end of August 1988, but individually unidentifiable because of missing flipper tags, are not included in the graphs. A) Data from sea otters released from three floating pens off Sissy Cove, San Nicolas Island (N = 45). Six sea otters released by this method remained at the island on 31 August 1988. B) Data from sea otters ieleased from beaches on San Nicolas Island (N = 24). Five sea otters released by this method remained on the island on 31•August 1988. III reproduction strategies (Ralls et al., 1988; Bodkin and Rathbun, 1988; Jameson,1989). The reason sea otters emigrate from San Nicolas Island is unknown, although given the relatively large proportion that have returned to their cap- ture sites along the mainland coast (Tables 2 and 8), there must be strong selection pressure to remain in a familiar home range. The theoretical advantages of homing are the same as having a well-defined home range or maintaining a ter- ritory. The benefits include a favorable cost/benefit ratio in foraging, a greater success in obtaining mates, and perhaps a better ability to avoid predation (Davies, 1978). Apparently the selective advantages to sea otters of returning home are greater than the benefits of staying in a new area. The advantages of remaining at the island include an unusually abundant food supply (USFWS, unpublished data) and low intraspecific competition (Tables 5 and 8). During severe winter storms, sea otters in California might be displaced from their home ranges by relatively short distances (perhaps up to 25 km). It is understandable that homing would be adaptive under these circumstance, as the costs of returning are relatively minor compared to the benefits of foraging in a familiar area and being familiar with the dispersion of potential mates and competitors. However, sea otters taken to San Nicolas Island have no way of assessing the cost of returning the approximately 300 km to their cap- ture sites on the mainland. Based on the number of sea otters unaccounted for (Tables 2 and 8), homing behavior from San Nicolas is clearly maladaptive for these sea otters. Strong homing behavior in translocated mam- mals is not unique to sea otters. Numerous studies of transiocated large mammals have shown that homing is a significant problem in establishing new populations (Nielsen and Brown, 1988). Al- though homing has been found in species as diverse as the mule deer (Odocoileus hemionus), wolf (Canis lupus), and Indiana bat (Myods sodalis), there seems to be a pattern that car- nivores (i.e., predators) exhibit stronger homing than herbivores (Rogers, 1988). There are few 112 data to indicate the r-easons for homing. However, the herbivore/carnivore trophic dichotomy sup- ports the hypothesis that individuals such as sea otters that rely on a familiar home range or ter- ritory for optimal foraging and reproduction are more likely to return home than those that do not, such as many herd -forming herbivores. ACKNOWLEDGMENTS The individuals and groups that assisted with the capture and reintroduction of sea otters to San Nicolas Island are far too numerous to thank in- dividually. However, we greatly appreciated their support and help. Special thanks are due to fellow USFWS personnel that assisted in all aspects of the translocation: Jim Bodkin, Mike Bogan, Ron Britton, Julie Eliason, Brian Hatfield, Mike Ken- ner, Keith Miles, Tom Murphey, Nancy Siepel, and Don Wilson. The initial releases at San Nicolas Island were organized and supervised by Jim Estes. The numerous short-term employees and volunteers that assisted in transporting the sea otters and caring for them at the Monterey Bay Aquarium were also indispensable to the project; especially veterinarians Tom Williams and Diana Soule, and Rachel Saunders. California Depart- ment of Fish and Game Biologists Jack Ames, Bob Hardy, and Fred Wendell formed an untiring cap- ture team. The staff of Air Resorts and Ecoscan owner/pilot Bob VanWagenen did excellent jobs in flying sea otters. Lastly, we are especially in- debted to the Monterey Bay Aquarium and the U.S. Navy for their support and cooperation. Thoughtful comments on drafts of this manuscript by Julie Eliason, Brian Hatfield, Kathy Ralls, and Nancy Siepel were greatly appreciated. LITERATURE CITED Ames, J.A., R.A. Hardy, and F.E. Wendell. 1983. Tagging materials and methods for sea ot- ters, Enhydra luhis. Calif. Fish and Game 69:243- 252. Ames, J.A., R.A. Hardy, and F.E. Wendell. 1986. A simulated translocation of sea otters, Enhydra ludis, with a review of capture, transport L'i • Ll 0 and holding techniques. Calif. Dept. Fish and Game Marine Resources Tech. Report No. 52. 17pp. Bodkin, J.L. and G.B. Rathbun. 1988. Morro Bay Dredging Project,1987. Morro Bay Sea Otter Study. Annual Report to U.S. Army Corps of Engineers, Los Angeles District, Los Angeles, CA. Intra-Army Order No. E86870050. 30pp. Brownell, R.L., Jr. and G.B. Rathbun. 1988. California sea otter translocation: A status report. Endangered Species Technical Bulletin 13:1,6. Davies, N.B. 1978. Ecological questions about territorial behaviour. Pp. 317-350 in J.R. Krebs and N.B. Davies (eds.). Behavioural Ecology, An Evolutionary Approach. Sinauer Associates, Sunderland, MA. 494pp. Garshelis, D.L. and D.B. Siniff. 1983. Evalua- tion of radio -transmitter attachments for sea ot- ters. Wildl. Soc. Bull.11:378-383. Geibel, J.J. and D.J. Miller. 1984. Estimation of sea otter, Enhydra lutris, population, with con- fidence bounds, from air and ground counts. Calif. Fish and Game 70:225-233. IUCN.1987. The IUCN position statement on translocation of living organisms. Introductions, re -introductions and re -stocking. IUCN, Gland, Switzerland. 20pp. Jameson, R.J. 1989. Movements, home range, and territories of male sea otters off central California. Marine Mammal Science 5:159-172. Ladd, W. 1986a. New hope for the southern sea otter. Part I. U.S. Fish and Wildlife Service En- dangered Species Technical Bulletin 11(8 & 9):12-14. Ladd, W. 1986b. New hope for the southern sea otter. Part II. U.S. Fish and Wildlife Service Endangered Species Technical Bulletin 11(10 & 11):5-7. 113 Loughlin, T.R. 1980. Home range and ter- ritoriality of sea otters near Monterey, California. J. Wildl. Manage. 44:576-582. Miller, D.J. 1980. The sea otter in California. Ca1COFI Rep. 21:79-81. Nielsen, L. and R.D. Brown (eds.). 1988. Trans - location of Wild Animals. Wisconsin Humane Society, Milwaukee, WI, and Caesar Kleberg Wildlife Research Institute, Kingsville, Texas. 333pp. Ralls, K., T. Eagle, and D.B. Siniff, 1988. Move- ment patterns and spatial use of California sea otters. Pp. 33-63 in D.B. Siniff and K Ralls (eds.). Population Status of California Sea Otters. OCS Study MMS 88-0021, U.S. Department of Interior Minerals Management Service, Los Angeles, California. 368pp. Ralls, K, and D.B. Siniff. 1988. Overview of the study: Background and general methods. Pp. 1- 12 in D.B. Siniff and K Ralls (eds.). Population Status of California Sea Otters. OCS Study MMS 88-0021, U.S. Department of Interior Minerals Management Service, Los Angeles, California. 368pp. Ribic, C.A. 1982. Autumn movement and home range of sea otters in California. J. Wildl. Manage. 46:795-801. Riedman, M.L. and JA. Estes. 1988. A review of the history, distribution and foraging ecology of sea otters. Pp.4-21 in G.R. VanBlaricom and JA. Estes (eds.). The Community Ecology of Sea Ot- ters. Springer-Verlag, New York. 247pp. Rogers, L.L. 1988. Homing tendencies of large mammals: A review. Pp. 76-92 in L. Nielsen and R.D. Brown (eds.). Translocation of Wild Animals. Wisconsin Humane Society, Mil- waukee, WI, and Caesar Kleberg Wildlife Re- search Institute, Kingsville, Texas. 333pp. Thomas, JA., L.H. Cornell, B.E. Joseph, T.D. Williams, and S. Dreischman. 1987. An im- planted transponder chip used as a tag for sea otters (Enhydra lutris). Marine Mammal Science 3:271-274. U.S. Fish and Wildlife Service. 1982. Southern Sea Otter Recovery Plan. U.S. Fish and Wildlife Service, Portland, Oregon. 66pp. U.S. Fish and Wildlife Service. 1987. Final En- vironmental Impact Statement, Vols. I -III. U.S. Fish and Wildlife Service, Portland, Oregon. Williams, T.D. 1983. Surgical implantation of radiotelemetry devices in the sea otter. Jour. Amer. Vet. Med. Assoc.183:1290-1291. Williams, T.D. and L.T. Pulley. 1983. Hematol- ogy and blood chemistry in the sea otter, Enhydra lutris. J. Wildl. Diseases 19:44-47. 114 :7 • is Christian 6eena Victoria C. Jaffe William S. Craycrafi Robert A. Curtis l - U': '. Norman P. Murrav Ce i of ssionViejo 0 0 Monday, November 26, 1990 BY DELIVERY Mr. Steve Letterly Manager of Environmental Impact San Joaquin Hills Transportation Corridor Agency 345 Clinton Street Costa Mesa, California 92626 Subject: City of Mission Viejo Comments on the San Joaquin Hills Transportation Corridor DEIR/DEIS . (TCA EIR/EIS 1) (FHWA-CA-EIS-90-2D, S.C.H. No. 90010238) Dear Mr. Letterly: In accordance with our prior advancement arrangements with you on this subject, we are hereby transmitting the set of comments that our City Council is being asked to act on tonight. As you know, we are doing this so that you technically receive from us a timely comment submittal before close of business today. Today's date is the formal close of the public comment period on the draft environmental document. Per our prior arrangement with you, if Council elects to :take any additions or changes to this set of comments, we intend to document those changes immediately after the meeting and either hand those changes to you, fax them to your office, or otherwise get those changes to you in writing as quickly as practicable. You have indicated to us that, by following those procedures, we would be able to have the Council's input and action considered as received in time to be responded to and included in the Response to Comments document. If there are any last-minute details of this that we need to discuss further before the deadline passes tonight, please let me know immediately. Otherwise, we look forward to seeing you at our Council meeting tonight. 26522 La Alameda • Suite 190 • Mission l iejo, California 92691 714/582•CITY FAX 714/582.7530 Mr. Steve Letterly November 26, 1990 Page 2 Thanks for your assistance in helping us comply with your submittal deadline given the changeover in the composition of our Council in the wake of the November 6 election. Sincerely, DENNIS R. WILBERG I Director of Public Works City Engineer DRW:bjp 0 0 0 i 0 0 11/15/90 CITY OF MISSION VIEJO STAFF -COMMENTS ON THE SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR DEIR/DEIS (TCA EIR/EIS 1) (FHWA-CA-EIS-90-2D) (S.C.H. NO. 90010230) OVERALL COMMENTS 1. Assessment of the differences between the connection options where I-5 and the San Joaquin Hills Corridor will meet: The draft document still confounds both the comparison between mainline alternatives and the comparison between I-5/SR73 connection options, by implicitly presuming, in key instances, that the Conventional Alternative is paired with Connection Option 1 and and the Demand Management Alternative is paired only with Connection Option 2. As an example, the "Comparison of Alternatives and Major Impacts", Table A, page S-8 in the Summary, includes two line - item differences in particular - "Streambed/Floodplain" and "Housing and Business Relocation" - which seem to be driven by connection option differences rather than by differences in mainline characteristics. To improve the document, we would suggest that a second footnote be added on this table that indicates "Conventional Alternative with Alignment #1 I-5 connection". More importantly, for Mission Viejo to properly assess the relative merits of the two connection options, we request that an 3-6-1 analysis of the two connection options under the Demand 3-6-2 Management Alternative be prepared with a tightly focused comparative matrix that covers at least these topic areas: - Construction cost - Geotechnical risk areas 13-6-3 - Streambed/floodplain impacts on Oso Creek 13-6-4 - Oso Creek Trail impacts 13-6-5 - Business relocation impacts 13-6-6 -- which specific, parcels? 3-6-7 -- nature of businesses requiring relocation nature- Right of Way required: -- in Laguna Niguel -- in Mission Viejo -- in San Juan Capistrano 3-6-8 -- resulting impacts on specific parcels and specific businesses in each city. - Noise -- levels at "Receptor 19" in Mission Viejo -- levels at "Receptor 20" in Mission Viejo 3-6-9 -- mitigations proposed under each option. -- visual impacts of noise mitigation proposed tl 1 under each option. Local air quality impacts Local visual impacts (particularly from the wide range of vantage in Mission Viejo) Light and glare impacts Roadway drainage impacts and roadway flooding risks Traffic/circulation �3-6-9 (3-6-10 points 3-6-11 1 3-6-12 (Relative advantages and disadvantages) Numerous considerations including, but not necessarily limited to: -- Access to the corridor from Mission Viejo. -- Access to Camino Capistrano: --- from I-5 --- from Mission Viejo --- from Laguna Niguel -- Traffic Operations on Crown Valley Parkway. -- Traffic Operations on Avery Parkway. -- Implications for Paseo de Colinas -- Impacts on parcel access. -- Tmplications for Rancho Viejo Road/ Margueritei Parkway -- Implications for I-5 operations: --- future level of service on I-5 --- operation of newly created weaving sections. --- operation of Junipero Serra south of the confluence. - Impacts during construction -- To I-5 -- To Mission Viejo -- To Laguna Niguel -- To Crown Valley Parkway. lane drops and interchange We request that TCA staff and their environmental consultants develop the data and supply this matrix in the Response to Comments document. After receiving it, we need adequate time to review this information at staff level, then time to present this information to our commissions and City Council, to enable them to develop or concur in a recommendation on a preferred, connection option. Time must be allowed for that to be accomplished before the Board hearing date TCA ultimately sets' for selecting a preferred alterative and certifying the EIR/EIS. (That Board hearing date was once scheduled for January 10, 1991; it has recently been pushed back to February 14, 1991; but we question whether even that will allow adequate time to accomplish the steps outlined above). 2. Timing contracting Corridor: 2.1. T evolved - environmental 3-6-13 3-6-14 3-6-16 of concurrent planning, environmental, design, and activities for the San Joaquin Hills Transportation he timing - and the consequential overlap that has 3-6-16 between concurrent design, issues analysis, analysis, and design/build contracting activities, OL 0 n U 2 • is now creating a problem. The P&D Technologies study for TCA will be developing key information germane to recommendations for a south end connection option. That study, as now scheduled, will not be finished until December 21, 1991, nearly a month after the formal comment period closes on the environmental document, and four days after the "design documents" are 3-6-16 scheduled to go out to design/build bidders. This is complicating effective City review of TCA environmental and planning documents, and seems to be• precluding timely and effective City input into important corridor design and connection option decisions. 2.2. We would ask TCA staff to develop a timeline of events to get the P&D study to us, allow us time to review and interpret the data, consult with other agencies, route the information through our commissions and Council, and formulate a final recommendation, prior to the Board hearing date (now scheduled for February 14). We are concerned that the City have adequate time to consider the results of the P&D study, and the Response to Comments document on the DEIR/DEIS, before the Board certification and hearing date. 3. Configuration of the Greenfield Drive Interchange: We believe that the environmental document should clear the Greenfield Drive interchange as a full -diamond interchange, not simply a half -diamond. The environmental document presumes that the Greenfield interchange is a half -diamond interchange with ramps to and from the north only. Yet it is our understanding, based on discussions with TCA engineering staff, CDMG design staff, and the section designers under contract to TCA, that there are no engineering constraints precluding ramps to and from the south. Furthermore, in the South End Study, which is part of the environmental document, the Greenfield' interchange is in all cases presumed to be a full diamond interchange, and the future forecast volumes on arterial streets in the I-5/SR73 confluence area in that report are predicated on that full diamond configuration. The City of Mission Viejo is particularly concerned about future congestion on the already -congested reaches of Crown Valley Parkway in the vicinity of I-5, Forbes Road, Cabot Road,.and the future San Joaquin Hills Corridor. Traffic on the Crown Valley Parkway corridor is of such importance to the City that a City initiated local building fee program is being instituted to fund' long term major improvements to Crown Valley Parkway within the, City and to build a local funding share for much -needed access improvements to I-5 from Crown Valley Parkway. 3-6-17 3-6-18 3-6-19 If TCA were to fail to provide a full diamond interchange at Greenfield, then traffic coming up I-5 from the south and destined for the Crown`Valley Parkway corridor area west of I-5 would have no choice but to stay on I-5 and exit at the Crown 3-6-20 Valley/I-5 offramp, unnecessarily adding traffic to the already - congested ramp terminal intersections at that interchange, and adding traffic to Crown Valley Parkway through signalized 3 intersections at Forbes Road and Cabot Road. It seems to the City that this would defeat one of the main stated purposes of the Corridor - namely, to pull freeway -type travel off of crowded arterials, and to carry that traffic on a suitable freeway -type facility instead. Likewise, having the full diamond interchange at Greenfield would allow traffic from that vicinity destined to the south on I-5 to enter the "freeway system" at Greenfield on the Corridor rather than traversing several signalized intersections to enter at, the congested Crown Valley/I-5 interchange. Since this section of Crown Valley is one of the most critical links in the arterial network affected by the Corridor, we believe the full diamond interchange at Greenfield is essential. 4. Adequacy of the analysis of arterial street impacts in Mission Viejo, —and adequacy of sitigation for those impacts: The City has a major general concern that the future traffic levels on arterial roadways in and near the City of Mission Viejo are substantially understated in the body of the DEIR/DEIS (particularly on Crown Valley Parkway), and that consequently the Corridor impacts on those arterials is underestimated, and mitigations offerred in the document are insufficient. 13-6-20 3-6-21 Furthermore, as noted above, the issue of local access and circulation for Mission Viejo is really not addressed in the EIR; we understand it is to be addressed to some extent in the 3-6-22 forthcoming P&D Technologies study, but the results of that study are not scheduled to be available until well after the review period for this environmental document closes. The Corridor/I-5 connection option chosen will have highly significant circulation consequences for the City of Mission Viejo, the City of Laguna Niguel, and for TCA and the Corridor itself. The issue of local circulation seems to have been given far more prior consideration in the northerly confluence (SR73/I-405), where the TCA has agreed to fund portions of local circulation improvements in Irvine, Newport Beach, and Costa Mesa, to the degree that those facilities are impacted by corridor -related traffic. 3-6-23 The EIR document needs to provide more credible future arterial traffic forecasts, and needs to re -address corridor impacts and 3-6-24 mitigation measures related to local access and circulation. 5. Adequacy of impact analyses and mitigations in a number of impact areas, such as, but not necessarily limiced to, noise, visual impacts, cumulative impacts, and impacts during construction. 5.1. Economic disruption to the City during construction. The City has a substantial issue with the lack of detail on the potential impact to businesses and the corresponding loss of revenue to the City during construction. The document gives the 3-6-26 impression that construction is not considered to cause any significant unavoidable adverse impacts, and the City takes issue • with that finding. This concern would be particularly acute if Connection Option 2 were implemented, requiring major grade modifications to I-5. Marguerite Parkway stands to be substantially adversely affected by construction disruptions on 3-6-25 I-5, and there are substantial sales tax generators that would be affected. The DEIR/DEIS needs to better spell out the projected timeframes and durations of construction and to better assess the corresponding adverse economic impacts to the City of Mission Viejo during the duration of construction: 5.2. Land use, growth impact, and cumulative impact analysis. Generalized statistics for land use in southern Mission Viejo were recently added to the Draft EIR/EIS at the suggestion of City staff. However, there seems to be little or no use of this data throughout the EIR and especially in the analysis of growth -inducement or cumulative impact. Consideration of the growth -inducement of the Corridor seems mainly to be based on the "Area of Benefit"; while just to the east of this Area are the substantial existing and planned land uses in Mission Viejo. This apparent omission may be significant in the analysis of certain aspects of cumulative impact including traffic and local access/circulation. The EIR should give more consideration to Mission Viejo with respect to land use, growth inducement, and cumulative impact. • 5.3. Visual impacts: The EIR identifies significant adverse visual impacts at certain locations which cannot be mitigated; however, it would seem that several other local areas including portions of southern Mission Viejo would be subject to similar impacts from not only the Corridor itself but from Corridor -associated noise walls. The viewshed from Mission `-*Viejo does not seem to be adequately considered in the document, 'and only very limited consideration is given to the visual impacts of sound walls. The EIR should include consideration of views from Mission Viejo including placement and appearance of sound walls along the various hillsides within the City's viewshed. 6. Treatment of planning issues important to the City of Mission Viejo 3-6-26 3-6-27 6.1. Prospects for future transit and a future multimoda?. transportation center. The project description for the Corridor recognizes the potential for accommodating transit. However, 3-6-28 the DEIR/DEIS does not recognize the findings of the OCTC Commuter Rail Study, which identifies two multi -modal transit/commuter rail station sites in close proximity to the Corridor at the boundary --between Mission Viejo and Laguna Niguel. Furthermore, the DEIR/DEIS does not recognize the'.propsects for transit and enhanced rail service in this vicinity as described • in the OCTC Countywide Rail Study; and it does not recognize the 3-6-29 prospects for a train station in this vicinity as described in the adopted Mission Viejo -General Plan. 5 6.2. Implementation of Oso Creek Trail: The implementation of this regional trail is an expressed concern of the cities of Mission Viejo, Laguna Niguel, and San Juan Capistrano, and several trail groups. However, as yet there is no working set of potential trail alignments through the I-5/SR73 confluence area. The trail alignments were to have been explored as part of the P&D Technologies study. Mission Viejo staff met with County EMA staff in December 1989 in an apparently unsuccessful effort to resolve the local Oso Trail issues. TCA should coordinate with County EMA to be sure the Oso Trail issues through the confluence area are clarified, and so the P&D Technolcgies study can properly reflect an appropriate alignment for the trail extending from Mission Viejo southerly through Laguna Niguel (and consequently through the I-5/Corridor confluence area) to San Juan Capistrano. 3-6-30 7. Responses to our prior comments on the screencheck document: Our review of this draft environmental document indicates that very few of our substantive prior comments on the earlier screencheck document were addressed in this draft document. The 3-6-31- attached "issues matrix" summarizes the degree of response in the DEIR/DEIS to the major issues areas we called our previously in our review of the screencheck document. PAGE -SPECIFIC COMMENTS IN THE DEIR/DEIS 1. Main Document 1.1. Summary 1.1.1. Page S-6. The "Areas of Controversy" section does not include previously expressed concerns for displacement 3-6-32 of businesses, resultant loss of revenue to cities, and potential reduction in city services. 1.1.2. Page S-7, 2nd paragraph. As we stated in our comment on the screencheck document, we believe the Issues to be Resolved discussion should also clearly mention that a major issue --to be resolved is determining which connection option to I- 5 (Connection Option #1 or Connection —Option #2) is preferred. That is now rather clearly recognized as a major issue apart from the decision between mainline alternatives (Conventional vs. Demand Management), and this key section in the environmental document should say so. 1.1.3. page S-8. This key table - the "Comparison of Alternatives and Major Impacts" - still appears to be somewhat misleading. The comparison in the table still seems to be comparing the Demand Management Alternative with Connection Option 2 to I-5, to the Conventional Alternative with Connection Option 1 to I-5. If that is true, a second footnote should be added to the table that says so. The difference in connection 3-6-33 3-6-34 0, • options appears to account for at least some of the listed differences between the Build Alternatives, particularly in the 3-6-34 row entries for business relocation and for floodplain impacts to Oso Creek. 1.2. "Purpose and Need for Action" 1.2.1. page 1-4. This is the same figure, with the same data, that was in the screencheck document, which was the subject of extensive comment in our comments to TCA on the screencheck document. It is regrettable that this same figure was carried forward while still containing traffic volume forecasts for Crown Valley Parkway that are artificially low, and that are grossly inconsistent with the forecasts from the South End Study that is part of this DEIR/DEIS package. We refer you back to our comments on the screencheck document to explain the major problems we have with the forecasts that appear in this figure (a copy of those screencheck comments is attached for your reference). We do note the additions to the text in this section on page 1-6, paragraphs 2 and 3; but, as we have pointed out in the past, those considerations do not explain away the ,discrepancies on Crown Valley Parkway. 3-6-35 1.2.2. page 1-5. As we pointed out in our comment on the screencheck document, Footnote 1 is incorrectly applied to the first column of Levels of Service in Table 1.3A. Footnote 1 3-6-36 specifically says the estimates are based on 2010 ADTs, yet the first column of information is for current (1988/1989) conditions. 1.2.3. page 1-7,- first full paragraph. As we pointed out in our comment on the screencheck document, the following sentence is incorrect: "Existing arterials such as University Drive, Moulton Parkway, and the E1 Toro Wye are being utilized by trips diverted from congested regional facilities. 3-6-37 The E1 Toro Wye is not an arterial, it is a freeway -freeway junction; and mention of it should be dropped from that sentence. 1.3. "Proposed Project Description and Alternatives" 1.3.1. page 2-5. In Table 2.2-A, the Greenfield interchange is described as being only a half diamond. Also, 3-6-38 the interchange is located in the City of Laguna Niguel, not in unincorporated area of the County. 1.3.2. pages 2-7 and 2-8. The Figure and Table do not clearly identify and characterize the location of HOV �3-6-39 interchanges/access locations. 1.3.3. page 2-26, Figure 2.13. Please check the accuracy and meaning of'the dashed line in the figure. Judging by the companion figure on page 2-24, it appears that the dashed 3-6-40 line in Figure 2.13 is improperly located for Connection Option 2. Please correct or clarify. 7 1.3.4. -page 2-52, under the heading "Design Alternatives". The discussion on this page relates to which alternative is environmentally superior in various impact categories. Keying off of our similar comment earlier, we wonder if the conventional alternative proves superior under "housing and business relocation" essentially because it was coupled with I-5 Connection Option 1, rather than Option 2. Isn't it the difference in connection options which makes the essential difference in business relocation? 1.3.5. page 2-53, under "Circulation". We concur with this new text, added since the last screencheck document. We believe that this is the first instance where the document discloses that Crown Valley Parkway would he over capacity under Connection Option 1. This seems to be a result carried forward into the document from the South End Study. It is imperative that the volume forecast levels and levels of service findings reported elsewhere in this document be made consistent with this finding and with other data from the South End Study. 1.3.6. page 2-57. Ts the "Crown Valley Park and Ride" actually to be located in the Greenfield area? If so, where :is there land not already developed that is available for this purpose? Would implementing a park and ride at this location require dislocation of any existing development? Ts TCA proposing that the park and ride lot would utilize or share any of the existing commercial parking lots already in the area? Please clarify, please re -review the actual status of existing development at this location in the field, reconfirm the practicality of a park and ride lot at this location, identify the actual location that would be involved, and account for the real business and right of way impacts that will be entailed should that location eventually be developed into the park and ride lot. 1.4. "Affected Environment" 0 3-6-41 3-6-42 3-6-43 9 1.4.1. page 3-49. Figure 3.7.1 does not accurately depict land uses, particularly in the vicinity of the southerlyl3-6-44 confluence. - 1.4.2. page 3-54. Section 3.8 is titled, "Housing ff and Business Relocation", but only describes existing uses in a13-6-45 very generalized way. It does not describe relocation at all. 1.4.3. pages 3-62 to 3-66. The discussion of trails needs additional clarification. For example, Oso Creek regional trail is also in the jurisdiction of the City of Laguna Niguel 3-6.46 and the City of Mission Viejo. In this regard, both cities are currently awaiting further action from the County and the completion of the P&D Technologies study. 1.4.4. page 3-63, figure 3.12.1. The line representing the existing bicycle trail up Rancho Viejo Road is extended too far north: there is no bike route immediately 3-6-47 8 adjacent to I-5 between Avery Parkway and Crown Valley Parkway. T3-6-47 1.5. "Environmental Consequences and Mitigation Measures" 1.5.1. pages 4-13 through 4-16. The Initial Study Checklist should have been checked as significant for items numbers: #38 (affect employment, industry, or commerce, or 3-6-4. require displacement of businesses), #39 (affect property values or local tax base), and #40 (affect community facilities - i.e., regional trail linkages). 1.5.2. pages 4-88 and 4-89. The last paragraph on this page contains outdated information. The City of Mission Viejo has'now completed its General Plan. Other statements in 3-6-41 that paragraph need to be brought into conformance with the actual contents of the plan. 1.5.3. page 4-118. There should be a graphic exhibit to show the location and nature of landform modification, 3-6-50 otherwise it cannot be assessed. 1.5.4. page 4-120 to 4-130. There appear to be prospects for significant visual impacts looking west toward the Corridor from Mission Viejo. Also, there is not sufficient 3-6-51 consideration of the potential visual impact of Corridor - associated sound walls. 1.6. "Traffic and Circulation" 1.6.1. page 5-6. This figure is incomplete. The northbound onramp from Greenfield is not shown at all and the corresponding ramp volume information for that ramp is missing. Also, since there have been many toll traffic studies performed 3-6-52 for the San Joaquin Hills Transportation Corridor, the specific document source of this data, and date of that study, should be clearly shown directly on this figure. 1.6.2. pages 5-12 and 5-13. We note the discussion under "South End Alignment Alternative". We will be deferring comment on our concurrence with the finding of this section until 3-6-53 after we have had an opportunity to review the results of the P&D Technologies study, as we have noted in prior comments. 1.6.3. page 5-13. The subsection on "Impacts to Other Modes of Travel" very briefly addresses the OCTD study of express bus service from the southern area to to John Wayne 3-6-64 Airport. However,.no mention is made of the OCTC Commuter Rail Study or the OCTC Countywide Rail Study, both of which call for rail/transit facilities in this area as may be coordinated with the Corridor project. ' 1.7. "Growth -Inducing Impacts" and "Cumulative Impacts" 1.7.1. pages 6-1 to 7-6. The introductory discussion of growth -inducing impacts provides considerable background data 3-6-55 but does not adequately relate that data to the project. The effects of the project on growth is primarily based upon growth within the "Area of Benefit". This area does not include the 3-6-65 considerable existing and potential growth in Mission Viejo immediately to the east of the confluence, just outside the Area of Benefit. Although the applicable portion of Mission Viejo has now been added to the tables in Appendix E, it is not clear to what extent this additional data has been used in the assessment of cumulative impact. 1.8. "Comments and Coordination" 1.8.1. page 11-10. Please update the list of persons consulted under the listing "Mission Viejo, City of", by 3-6-56 adding the following names: Dennis Wilberg, Public Works Director; Bob Goedhart (Consultant). 1.9. "Appendix A: 4f evaluation" 1.9.1. page A-52, Figure A-3. Important clarifications need to be made on this figure. First, the identifier "Corridor Center Line" needs to be qualified to read "Corridor Center Line (Conventional)". Second, the following physical features are missing: (1) Camino Capistrano, (2) the AT&SF RR, (3) the strip of developed land between Camino Capistrano and the I-5 Freeway, (4) the existing overcrossing structure and "fishhook ramp" from Paseo de Colinas to Camino 3-6-57 Capistrano. Also, won't the corridor right of way for the Demand Management Alternative look different than is shown in this figure, to allow for ramping and the interchange from the corridor at the interchange with the newly connected Avery Parkway - Paseo de Colinas? Please check the accuracy of this figure and have it redrawn correctly with the detail needed to visualize both connection options vis a vis 0so Creek Corridor. 1.9.2. page A-52, Figure A-4. This figure is incorrect. The Niguel equestrian trail is on the west side of Greenfield Drive; Figure A-4 incorrectly shows it on the east side. Also, our review of this situation in the field indicates that no portion of the Niguel Equestrian Trail exists south of 3-6-58 the corridor right of way; what exists is on the west side of Greenfield north of the corridor only- . South of the corridor right-of-way there is new commercial development on both sides of Greenfield, and there is no equestrian trail along that stretch of Greenfield. Please re -research this situation and provide a figure that is correct. 2. Technical Studies Volume 1. 2.1. "Geotechnical Study" 2.1.1. page 18, under the heading. "Landslide Complex at Crown Valley Parkway". Assuming the Demand Management Alternative were built, would the feasibility, cost, or 3-6-59 construction reliability of either 1-5 connection option be 10 0 C7 impacted by this landslide, and if so, specifically in what way? 73-6-59 2.2. "Conceptual Drainage Study" 2.2.1. page 36. Please update this discussion, 3-6-60 which refers to Mission Viejo as an "unincorporated community". The City has been incorporated since 1988. 3. Technical Studies Volume-2 3.1. Traffic Technical Studies 3.1.1. Technical Memorandum 2-60: San Joaquin Hills Transportation Corridor Traffic and Circulation Study. 3.1.1.1. pages B3 through B12. The label "Conventional HOV" which appears on each of these figures is confusing. It is our understanding that these are the turning 3-6-61 movement forecasts for the "Conventional Alternative". Shouldn't the "HOV" part of that label have been deleted? Please explain or clarify. 3.1.2. SJHTC South End Study 3.1.2.1. On the title page, this study is still ' 3-6-62 labelled "draft". Is this in fact the final report, and if so, shouldn't the title page be corrected accordingly? 3.1.2.2. Page A-1. This figure shows traffic volume forecast data for I-5 south of the confluece that is contrary to expectations. This is AM peak hour data, yet the figure shows far higher volumes southbound (11103) than 3-6-63 northbound (3461). This seems to be in error. The same anomaly exists in Figures A-2 through A-12. Please reverify the data on these 12 Figures and provide revised Figures A-1 through A-12 in the Response to Comments document. 3.1.2.3. Pages A-5 through A-12. peak hour volumes, by direction, for the undercrossing? What are the 3-6-64 Via Escolar 11 s ISSUES MATRIX (BASED ON COMMENTS MADE ON SCREENCHECK DOCUMENT) Questions We Asked Major Issues 1. Need for series of strip maps to describe the alternatives in Project Descrip- tion section. 2. Need to assess both south end connection alternatives independent of mainline alternatives. 3. Need to eliminate inconsistency in traffic forecasts for Crown Valley Parkway: future "no project" forecasts are less than current volumes. 4. Need to eliminate inconsistency in traffic forecasts between EIR/EIS, and South End technical study incorporated as an appended technical study into the EIR/EIS. Were They Addressed in the DEIR/DEIS? 1. No 2. Only in part. 3. No. Same numbers appear. 4. No. What We Are Still Looking For 1. As a minimum, documentation of the concept map basis for both alternatives in the EIR/EIS. 2. P&D Technologies Study, compar- ative analysis of both end options under demand managem't alternative. 3. Credible fore- cast volumes in the EIR/EIS . 4. Credible fore- cast volumes for proper consideration of south end connection options,arter- ial impacts, and Greenfield interchange configuration. 3-6-65 3-6-66 '3-6-6T 3-6-68 ISSUES MATRIX (Continued) (BASED ON COMMENTS MADE ON SCREENCHECK DOCUMENT) Questions We Asked Major Issues 5. Full diamond interchange at Greenfield. 6. South End Study data carried over into body of EIR/EIS document. 7. Clarification of specified toll collection aspects of the corridor; correlation of toll traffic forecasts with traffic forecast data in the EIR/ EIS. 0 Were They Addressed in the DEIR/DEIS? 5. No. 6. Only in part. 7. No. What We Are Still Looking For 5. Incorporation of full diamond interchange in EIR/EIS and project plans. 6. Impact analysis carryover from South End Study to body of EIR/ EIS. �7. Answers to the same questions we submitted in comments on the screencheck EIR/EIS. 3-6-69 3-6-70 3-6-71 0 • COMMENTS ON MAY 1990 SCREENCHECK EIR/EIS (TRAFFIC AND CIRCULATION EMPHASIS) SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR MAIN POINTS 1. Need for Better, More Concise, More Detailed Description of the Alternatives in the Environmental Document. Even though the "Proposed Project Description and Alternatives" section is quite lengthy (55 pages), it lacks the kind of figures and mapping essential to understanding the actual physical features of each alternative from one end of the corridor to the other. The document seems to rely on Figure S-1 to accomplish this, which in our judgment is inadequate. This comment was raised before in writing on an earlier screencheck, however it has not been rectified. A series of strip maps is needed in the Proposed Project Description and Alternatives section, one set for each of the two .alternatives, that shows in line form all corridor mainline 'roadways, median roadways, and collector -distributor roadways, and all interchanges, all ramps and all connections between the roadways, in their actual proposed configuration. Those ramps proposed to be HOV only should be labelled as such. The number of lanes should be shown right next to each segment of each roadway, with those numbers shown separately for the corridor mainline, median roadways, and collector distributor roadways. 3-6-72 3-6-73 The screencheck document has strip maps in other sections of the document - for example, Figure 4.5.1 runs several pages and maps the noise receptor locations along the corridor, at about 800 scale, separately for the Conventional Alternative and the 3-6-74 Demand Management Alternative. The same is done for plant communities and sensitive resources in Figure 3.6.3. A mapping base like that could hopefully be used to create the kind of mapping we are talking about here. We would suggest that the figures in the Austin -Foust "South End Study" be referred to as examples of what we are suggesting, particularly Figure 1. Such a format clearly shows mainline 3-6-75 roadways, HOV/median roadways, bridge structures (to know what overcrosses what) and ramp connections in a simple yet clear fashion. 2. Need to Carry the South End Connection Options for Both Conceptual Alternatives. The Austin -Foust South End Study analyzed both "connection options" to I-5. However, the screencheck environmental document presupposes that "Connection Option 2" would necessarily 3.6-76 be applicable only to the Demand Management Alternative, and "Connection Option 1" would only be applicable to the 1 Conventional Alternative. If there is a reason why the Demand ro Management Alternative precludes Option 1, or why the 3-6-76 Conventional Alternative precludes Option 2, that certainly would need to be explained and convincingly defended in the environmental document. Based on our review of the South End Study, it seems to us that both options are viable. Therefore, the environmental document should assess and environmentally clear both connection possibilities on both alternatives, so the south end connection decision can be made independent of the "global" alternative picked for the entire corridor. The south end connection decision should also factor -in local traffic circulation impacts, displacement impacts, visual impacts, and economic impacts; the environmental document should address these and supply the comparative information on which this decision can be made. 3. Inconsistency of Traffic Numbers, East End of Corridor, 2010 No -Project Forecasts vs "Current" Traffic Numbers. Figure 1.5.1, which follows page 1-4, presents "Existing and Projected Average Daily Traffic". A copy of this figure is attached, -with several of the 2010 forecasts highlighted. The ones of greatest concern to the City of Mission Viejo are on Crown Valley Parkway. All of the following forecasts are substantially lower for 2010 "no -project" than they are for 1989/1990 "current" conditions: Location 1989/90 2010 Crown Valley south of La Paz 30,000 26,000 Crown Valley north of La Paz 34,000 20,000 Crown Valley north of Moulton 41,000 20,000 Parkway Crown Valley between SJHTC 46,000 31,000 overcrossing and I-5 We do not believe these are realistic figures. We are aware of the fact that TCA has stated that these "no project" figures assume that the Foothill Corridor is in place. But that can't explain away a drop over the next 20 years of 21,000 ADT on Crown Valley Parkway north of Moulton Parkway. 4. Inconsistency of Traffic Numbers, East End of Corridor, 2010 "With Corridor" Forecasts, between SJHTC EIR/EIS and "South End Study„ The Crown Valley environmental document Austin -Foust numbers on projections appear to be arterials in the area, 3-6-77 3-6-78 traffic assignment numbers in the "with corridor" are inconsistent with the the South End study. The Austin -Foust 3-6.79 more credible sources of numbers for the yet they are not incorporated into the rL • • 2 environmental document. Examples: 3.6-79 Crown Valley north of Moulton Parkway: Austin -Foust - Option 1: Austin -Foust - Option 2: SJHTC EIS/EIR: Crown Valley Parkway between SJHTC crossing and I-5: Austin -Foust - Option-!: Austin -Foust - Option 2: SJHTC EIS/EIR: 5. The Interchange at Greenfield diamond"). 48,000 ("with corridor") 48,000 ("with corridor") 28,000 ("with corridor") 61,000 ("with corridor") 46,000 ("with corridor") 31,000 ("with corridor) ("half diamond" or "full The Austin -Foust south end study portrays the Greenfield! interchange as a full diamond. Yet the environmental document' prescribes it as a half diamond with ramps to and from the north only. j For environmental clearance purposes, it may be premature to presume at this point that the interchange at Greenfield will be only a half diamond. However, if there is some reason not. currently in the environmental document that demonstrates that Greenfield should never be a full diamond interchange, then it needs to be spelled out and defended in the screencheck document. 6. The inclusion and consideration of the Austin -Foust work into the environmental document is incomplete and inadequate. 3-6-80 3-6-81 The traffic volume impact analyses from the South End Study 3-6-82 should be carried over into the environmental document. 7. Toll Collection. There is still a need in the environmental document to provide greater clarification and better presentation of the general toll collection aspects of the corridor. Some of the questions we feel people will ask and that the document does not appear to cover or does not cover adequately include: - How does the toll collection system actually.work? There is no way in the environmental document for the reader to know how the amount of the toll is going to be determined. For any one type of vehicle with a given number of occupants, will the amount of the toll be at all dependent on the distance travelled on the corridor? For instance, will the toll amount collected 3-6-83 3 be the same for a vehicle exiting northbound at El Toro Road, at • Aliso Creek Road, and at Moulton Parkway? Or will the E1 Toro Road "toll" be higher than Aliso Creek Road, etc. And how will the amount of the "mainline" toll compare to the individual ramp tolls? How, generally, will truck tolls compare to passenger car tclls? Will HOV's be toll free? Is there an "existing" 3-6-83 toll facility somewhere on which this corridor tolling strategy is being patterned, and if so, where is it/where are they? This needs to be explained, and if options are still being considered on how this is going to be done, then the range of options needs to be described. - There is a need for a tie-in in the environmental document between the traffic volume forecasts used in toll revenue forecasting and the traffic volume forecasts that appear in this environmental document for project justification, facility sizing, and circulation impact analysis. Other commentors have made this same comment on past screencheck versions, however 3-6-84 it is still not incorporated into this document. With all the questions concerning toll sensitivity, HOV assumptions, OCTAM II vs. SOCTAM I, and the identified discrepancies concerning traffic volume forecasts, it is important that a consistent basis be established between the forecasts for the various purposes. OTHER "MORE MINOR" COMMENTS AND QUESTIONS 1. Page 5. We believe the Issues to be Resolved should also • include "determining the best connection option between the 3-6-85 corridor and I-5 at the south end of the corridor". 2. Page 19.- In Table A, the "Circulation" impacts do not mention any of the adverse impacts to arterial or street segments 3-6-86 or intersections that will feed traffic to and from corridor interchanges. 3. Page 20. There is a paragraph on "No Project Alternative" 3-6-87 at the bottom of this last page of Table A that appears to be out of place. 4. Page 1-2. The explanation of "level of service" on this page, and the accompanying explanatory table in Table 1.3.A on 3-6-88 Page 1-3, appear to be out of place here. 5. Page 1-4. In paragraph 4 under "Existing Traffic Conditions": Sentence reads in part: "Existing arterials such as University Drive, Moulton Parkway, and the E1 Toro Wye are being utilized by trips diverted from congested regional 3-6-89 facilities." E1 Toro Wye is not an arterial, it is a freeway - freeway junction. It should be dropped from the'sentence. 6. Figure 1.5.2. The levels of service volume projections in Figure 1.5.1. We Valley Parkway should show levels of service Niguel Road all the way up to and across implies level of service A-B for these here are dependent on believe that Crown C-D or even E-F from 3-6-90 I-5. The Figure sections which is Al 4 0 unrealistic. 13-6-90 7. Page 1-6, Table 1.5.A. Footnote 1 is incorrectly applied to the first column of Levels of Service; Foothnote 1 3-6-91 specifically says the estimates are based on 2010 ADTs, yet the first column of information is for current (1988/1989) conditions. 8. Page 1-10, Figure 1.5.3. This figure implies that virtually no arterial in the southeastern part of the corridor area will have a level of service worse than B in Year 2010 3-6-92 without the corridor. This includes the entire length of Crown Valley Parkway. This is hard to believe and would suggest you don't need to build the corridor. 9. Page 2-1, in the second paragraph under "Introduction", the text reads, "A preferred alternative has not been identified at this time. All reasonable alternatives are under consideration, a decision will be made after the alternatives' impacts and comments on the draft EIR/EIS and from the public hearing have been fully evaluated." We concur that a preferred alternative should not be identified at this time in the environmental document, and we believe that also should apply to the south end connection options. We believe the exclusive pairing of "Option 1" with the Conventional alternative only and "Option 2" with the Demand Management alternative only, is premature. (See previous comments on this subject). 3-6-93 10. Page 2-1, under the "common characteristics" of the build alternative" what exactly is meant by the term, "common 3.6.94 alignment"? Does it mean a common centerline alignment? Horizontal alignment? 11. Page 2-3, Figure 2.1. The I-5 interchanges at Ortega�3-6-95 Highway and Junipero Serra should be labelled. 12. Page 2-21. Is the "standard" 88 foot width the minimum median width under the Demand Management Alternative? Is the "standard" 64 foot width the minimum median width under the Conventional Alterative? What specifically is the median width 3.6-96 envelope required and reserved for possible LRT? Show a diagram of that envelope, and show how LRT is accommodated in that envelope. 13. Page 2-31. The median width of the Conventional Alternative is given as.64 feet minimum, and a description is given of how the median would be used for single concurrent flow HOV lanes in each direction. Yet, back on Page 2-20, it was stated that "the cross..sections of both design alternatives reserve sufficient area -in the median�to be converted to HOV lanes and a fixed guideway rail/transit system including transit platform stations." How does that 64 foot median provide enough space for both concurrent HOV and light rail? 3-6-9T 14., Page 2-31. Under "I-5 Connection", the text describes how 13-6.98 5 the SJHTC diverges from I-5 and proceeds westerly, and that "Access to Crown Valley Parkway and Cabot Road will be provided by the interchange at Greenfield Drive." But, as pointed out 3-6-98 earlier, the environmental document calls for only a half diamond interchange with ramps to and from the north. Access from the south can't be provided to Crown Valley off of SJH'rC if ramps to and from the south are not provided. 15. Page 2-32. Under the description of the "no project" alternative, it ought to be explained somewhere that the "without 3-6-99 corridor" 2010 forecasts in the document do assume completion of the other corridors (Foothil•1 and Eastern) but not the San Joaquin. 16. Page 2-33. The overall heading of the text on this page is "Alternatives withdrawn from consideration", and yet what is described on this page is actually planning studies and other 3-6-100 "prior study findings and background" that don't necessarily apply to the text heading. 17. Page 2-35. The discussion of light rail transit on this page appears to be somewhat negative, and perhaps needlessly so. 3-6-101 It is our understanding that the corridor is simply supposed to leave the option open for light rail should it prove advisable in the future. 18. Page 2-39. Table 2.8.A. The title of this table does not describe what the table presents. This table is not concerned with the lanes assumed in place on I-5 and I-405 under the "No 3-6-102 Build" alternative analyzed in this environmental document. 19. Pages 4-4 and 4-5, Table 4.1A. These two pages were inadvertantly transposed before the pages were assembled into the 3-6-103 screencheck. They need to be reversed. 20. Page 4-170, Figure 4.16.1. The map is upside down. 13-6-104 21. Page 4-171, Figure 4.16.2. This figure needs to be reproduced with better quality and at a larger image size on the page; the volume numbers and the corresponding ramps which are 3-6-105 referred on this figure cannot be adequately identified. Also, the source of the data needs to be identified on the Figure. 22. Page 4-177, Figure 4.16.3. The, location of these screenlnes must be identified. Screenline 5 is where? (3-6-106 Screenline 2 is where? Screenline 3 is where? 23. Attachment C, the series of 11 or so April 9 letters reproduced from Jerry Bennett to cities and agencies requesting input for Section 4(f) evaluation: Unfortunately, all of these letters reference sites "owned by the City of San Juan 3-6-107 Capistrano", when apparently the word processor was supposed to change the agency name in the text of each letter. This discrepancy needs to be eliminated. 0 y (N > Q w W f— J / Q ^ Z / C� ����+ S Mlbj 0031 ONYa1SIdY0 ONfwYO N� 4' W i-- Z ?� I J 4� U N z 111 ' o J G C� o • 7�d ' S 00310 ONYal dYO NY �HtC ONf►�y0 IN 0 '� �. o A-8 __j 4-1 m 4 % b h 4 rr - (32140�� �'` i r, �I.t 381 f Vo COP, (60)1041 . (61) 68 141 3 2M (84) 4 �'49 4j 41 (33)61 15-1S' Y. HAIWARD C, 6, [481 IT11151291 ( oil 41j, Bt sa C) C) 0 CD C) (D CO 0,� Ir C) CD co C) co Co ID n 0) zv .1 0z zt Cb 4. Jc El' -o -c) 01 CD CD '0 CD 1-0 1 C� CD (0)20[131 nC/) 0 SANG C) \031 0 0 P. A�) CL a 0 0 0 1. 7N766 yo (64)'64 (441 1 / V140 .7 30i22126�- \47 J fi/ ;IIa -�. _. �� �Ir/g\\ 'C� 35(4ij C) (0)101181 (0) M Z;y "GEP p 4 1161 Slow. 0 08J lei 5' 40-[?8j I.... �It tz 03 28 OQL*,,, 0111$po 69i - : ­ -8 to Lli Ep A rN ZVc11 IY O I QCT�� rs �9 0;13'r�j0 \ L" ...—',if•IIA .. _, \ `SS,'f� l ` ` � 1 � Nlf11n7. ~ J . - l^ it ' �i i�° • . AIiJ - �� s . QOLOrN _ Of c1 XMiVA �. 11 (( d \k10 -�/,' b• � � )f 1` ._. �/air /J(// OP 1L .t •, AGee` r JI OiyJp � ,>)�y Httn F('(pl('•� .lid^ ) 17 to I' � .. ^fir .. _ . `'// � �° � •\'\ °s no i/ 1 `�...—`�•.. _ y� BSc' �°'f° y - UNA QNI 1 JI/ NOANYO 1 Oy ONIS ly p 2 (r c/ sn O o4 v v I <' O / 9 0 \ .Qy n H ;� \ 1 166 O W I>z 1 \ / bO / p ��� J J Lu LU ()IIVALIVII W y U r lfriFI1BV3* -r } (c 74fdy �; cn all—/1 0 � . y LL! uj TO w w �-op Q i rl� l r J �,. •� Hrq�r 0 d / � o 4 C S00 r-----j r--�— r �-- --� �`j r--.—t r--1 I "'--1 (.-1 r-^�-j 7-1 �^^� � � T 0 City of Mission Viejo November 29, 1990 Mr. Steve Letterly Manager of Environmental Impact San Joaquin Hills Transportation Corridor Agency 345 Clinton Street Costa Mesa, CA 92626 Subject: CITY OF MISSION VIEJO COMMENTS ON THE SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR-DEIR/DEIS (TCA EIR/EIS 1) (FHWA-CA-EIS-90-2D, S.C.H. NO. 90010238) Dear Mr. Letterly: This letter will confirm that the set of comments we delivered to you midday on Monday, November 26, 1990 did in fact become the set of comments approved by the City Council Monday night, November 26, for official transmittal to you as the City of Mission Viejo's comments on the San Joaquin Hills Transportation Corridor DEIR/DEIS. An official copy of the City Clerk's certification of the Council action taken on this matter is attached to this letter for your files. As you know from your personal attendance at the meeting, this item generated a number of questions and comments from Councilmembers during the discussion of this item; among them were included the i-ollowing: - A request for a strong and serious commitment on the part 3-6-108 of TCA to provide timely and complete responses to these comments in the Response to Comments document; - A request for analysis in the Response to Comments document to demonstrate the projected peak period traffic operational characteristics of I-5 at the Corridor junction, to 3-6-109 insure that this junction does not become simply another congested "El Toro Y". 26522 La Alameda - Suite 190 - Mission Viejo, California 92691 714/582-CITY FAX 714/582.7530 Steve Letterly Page 2 November 29, 1990 Confirmation that our Council wishes to receive and have adequate time to consider the Response to Comments document and the 3-6-110 P&D Technologies study, before being asked to come to a recommendation to the TCA on a preferred I-5/Corridor connection option. Thanks again for your assistance in helping us comply with your November 26 submittal deadline in a way that allowed our new City Council to consider and approve the transmittal or our comments on the environmental document. Sincerely, DENNIS R. WILBERG Director of Public Works City Engineer DRW/el DW-90330 Dennis cc: City Council City Manager Community Development Director Robert W. Goedhart 0 ACTION OF THE CITY COUNCIL OF THE CITY OF MISSION VIEJO, CALIFORNIA NOVEMBER 26, 1990 ADDRESSED TO: Mr. William Woollett, Executive Director San Joaquin Hills Transportation Corridor Agency 345 Clinton Street Costa Mesa, CA 92626-6011 COPY TO: Dennis R. Wilberg Director of Public Works MEETING DATE: November 26, 1990 COUNCILMEMBERS PRESENT: Breton, Cody, Craycraft, Curtis, Withrow COUNCILMEMBERS ABSENT: None AGENDA ITEM NO.: 12.2 SUBJECT: San Joaquin Environmental Statement Hills Transportation Corridor Draft Impact Report/ Environmental Impact MOTION made by Councilmember Breton, seconded by Mayor Pro Tem Cody, carried 5-0 to direct staff to transmit the attached comments (Attachment 4) on the San Joaquin Hills Transportation Corridor Draft Environmental Impact Report/Environmental Impact Statement to the Transportation Corridor Agency. STATE OF CALIFORNIA ) COUNTY OF ORANGE ) CITY OF MISSION VIEJO ) I, IVY J. ZOBEL, City Clerk of the City of Mission Viejo, California, do hereby certify the foregoing to be the official action taken by the City Council at the above meeting. IN WITNESS WHEREOF, I have hereunto set my hand and seal this 29th day of November, 1990. (SEAL) Ivy - be City C erk_ DRUG USE IS B November 19, 1990 Steven Letterly, Environmental Manager Transportation Corridor Agencies 345 Clinton Street Costa Mesa, California 92626 MEMBERS OF THE CITY COUNCIL ANTHONY L. BLAND LAWRENCE F. BUCHHEIM KENNETH E. FRIESS GARY L. HAUSC`ORFER PHILLIP R. SCHWARTZE CITY MANAGER STEPHEN B JULIAN Subject: Review of Draft Environmental Impact Report (DEIR) San Joaquin Hills Transportation Corridor (SJHTC). Dear Mr. Letterly: The City of San Juan Capistrano, as I am sure you are aware, has taken an active and participatory interest in the planning of the San Joaquin Hills Transportation Corridor since its inception. We have been closely involved in monitoring this process and have consistently conveyed our ideas and concerns regarding this project to the Transportation Corridor Agency staff. The City has completed a review of the Draft Environmental Impact Report for the Corridor and concurs with the Report's recommendation to pursue the Demand Management confluence design (option #2). We have been proponents of this design alternative since its inception and its superiority has been validated by the traffic analysis. While the document is rather comprehensive in many respects, it contains notable deficiencies which require further revision. The draft Report should be revised accordingly. Our comments are outlined in detail in the attached document. The City has gone on record as supporting the concept of the proposed Corridor based on the increasing traffic congestion and associated impacts and the need to supplement the regional road system. Historically, the inability of the State, County, and Cities to provide freeways improvements at a commensurate rate of development has heightened the need for the Corridor. However, planning for this important facility must take into consideration its impacts on the adjoining communities, businesses, and residents. 3-7-1 32400 PASEO ADELANTO, SAN JUAN CAPISTRANO, CALIFORNIA 92675 0 (714) 493-1171 Steven Letterly -2- November 19, 1990. As we have noted in the past, the potential environmental impacts of primary concern to our City include: 1. Traffic and circulation. 2. Drainage and hydrology. 3. Noise. 4. Grading and topography (landform alteration). 5. Aesthetics. 6. Growth Inducing Impacts. 7. Construction impacts. Our comments provided on the attached document discuss in relative detail our concerns and recommendations for amendments to the Draft Environmental Impact Report. In some cases, the draft Report does not completely address potential environmental impacts while in other cases, the proposed mitigation measures are either incomplete or not specific to the identified impacts. We look forward to having our concerns with this document addressed in the "Response to Comments" and will review that document closely. My staff would be glad to meet with your staff to discuss revisions to the draft Report which satisfactorily address our concerns. Should you have any questions or want to discuss the attached comments, please don't hesitate to call me or William Ramsey, Senior Planner at 493-1171, extension 505. Sincerely, Thomas Tomlinson, Planning Manager TT: WAR: hs cc: Gary L. Hausdorfer, Mayor Members of the San Juan Capistrano City Council Stephen B. Julian, City Manager George Scarborough, Assistant City Manager Thomas Merrell, Director, Planning Department William A. Ramsey, AICP, Senior Planner Ted Simon, City Engineer Bud Vokoun, Senior Civil Engineer King Thomas, Environmental Planner, TCA Clint Brookhart, P.E., Manager, TCA • 0 REVIEW COMMENTS AND RECOMMENDED REVISIONS TO THE DRAFT ENVIRONMENTAL IMPACT REPORT (DEIR) FOR THE PROPOSED SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR Page CITY OF SAN JUAN CAPISTRANO, CALIFORNIA NOVEMBER 26, 1990 . SUMMARY Comment S-6 "Areas of controversy/issues": This section of the DEIR lists several unresolved issues but does not appear to be comprehensive based on the comments provided on the screencheck DEIR by various groups, Cities, and organizations. Issues/concerns which have been raised by our City and remain unresolved or unaddressed include: o Traffic impacts on arterial streets adjoining 3-7-2 I-5 including Ortega Highway, Del Obispo, Camino Capistrano, Junipero Serra, and Rancho Viejo Road. . o Noise impacts on residential and other sensitive receptors including Village San Juan, Spotted Bull Lane, the Casitas, Mission Flats, 3-7-3 and the proposed Community Park/Open Space Lands at the Trabuco/Oso Creek confluence. o Air quality impacts from automotive sources due_r3-7-4 to the Corridor. o Growth inducing impacts of the Corridor on 3-7-5 undeveloped lands in the study area. o Construction impacts including traffic circulation on Rancho Viejo Road and Camino 3-7-6 Capistrano, and truck traffic and noise. o Grading impacts on hillside areas along Rancho I3-7-7 Viejo Road. o Removal of the Rancho Viejo bicycle trail. 13-7-8 We recommend that you revise this section of the Report to either reference unresolved general issues and indicate that the list is only partial or 3-7-9 provide a comprehensive list of specific unresolved issues. 0 1 SECTION 1.0. PURPOSE AND NEED FOR ACTION 1-3 "Roadway capacity deficiencies": Figure 1.2.1 shows existing and projected traffic levels on arterials based on Corridor/No Corridor alternatives. However, the Figure does not provide an assessment of SR74 (Ortega Highway). The City has repeatedly insisted that the circulation component recognize the potential impact of this project on that regional arterial. We recommend that the I- 5/Ortega Interchange be analyzed and that Figure 1.2. 1 and Table 1.3 . C be revised to include analysis information on the Ortega Highway. SECTION 2.0, PROPOSED PROJECT DESCRIPTION 2-23 11I-5 Connection": This section provides a quite brief description of the two confluence alternatives which are under consideration. The brevity of this section does not recognize the complexity of the differences between the two confluence designs. We recommend that this section be revised to include a more detailed description with narrative devoted to the following topics: o Alignment location and weave merge distances to the I-5/Ortega Highway interchange. o Connection to Avery Parkway. o Local Corridor access options. o Right-of-way takings. o Adjoining land uses. o Arterial road relocations alignment estimates). DISCUSSION OF NO BUILD ALTERNATIVE 3-7-10 3-7-11a 13-7-1lb 13-7-11c 13-7-11d 13-7-11 e (with general 13-7-11f 2-30 "Alternative Land Use Concepts": This subsection briefly discusses alternative land use patterns and summarizes the Southeast Orange County Circulation Study (SEOCCS) completed during 1975-1976. However the DEIR does not include important background information on the study including the author, the assumptions or methodology, the Study's recommendations, and the Corridor Agency Board's and/or County Board of Supervisor's action on the SEOCCS. The DEIR should be revised to include this information. 2 3-7-12 • 11 Also, this section discusses the infeasibility of regional downzoning. The discussion does not include institutional constraints nor potential economic impacts of such an alternative but should do so. The DEIR could reference the findings of the SEOCCS efforts. Also, this section does not include the potential impact of regional downzoning on regional traffic and circulation and the need for the Corridor under such a scenario. We recommend that you revise the DEIR to include a discussion of these topics and conclusion. 2-31 "TSM Alternatives": This section concludes that TSM is relatively infeasible but without a discussion of the general theory/practice and potential trip reduction associated with these approaches. You should consider revising the DEIR to include a brief discussion of the theory and successful practice of TSM Alternatives and an assessment of the applicability to the Corridor project. DISCUSSION OF BUILD ALTERNATIVES 2-49 "Interchange Alternatives": This section discusses alternative interchange configurations for the west end of the Corridor only. Given the pending proposals for the acquisition of the Laguna Laurel site by the City of Laguna Beach and possibly significant other properties by the Nature Conser- vancy, certain interchanges may be unnecessary, especially in the short-term. This section of the DEIR should include a discussion of deleting/phasing certain interchanges related to potential open space acquisition such as Laguna Canyon Road, Pelican Hill/Culver, and Sand Canyon. RELATED TRANSPORTATION PROJECTS 2-54 "Improvements to SR 74 (Ortega Highway)": This section generally refers to planned improvements for the Ortega Highway but lacks important detailed information. If these improvements are to be considered in the context of the Corridor project then the DEIR should indicate the sponsor/initiator, status, construction planning document (CalTrans?), the funding source, and priority/schedule of such improvements. We recommend that the DEIR be revised accordingly. 3 3-7-13 3-7-14 3-7-15 3-7-16 SECTION 3.0, AFFECTED ENVIRONMENT 3-25 "Survey of Existing Traffic Noise": This section documents existing traffic noise levels which in many cases, exceed Federal or State standards. Of fifty-two (52) test sites, sixteen (16) were within our City which recognizes the potential significance of noise impacts on San Juan. Nine (9) of the sixteen (16) sites currently experience traffic noise in excess of FHWA and Caltrans standards. The DEIR should consider mitigation measures for these impacted areas. SECTION 4.0, ENVIRONMENTAL CONSEQUENCES AND MITIGATION MEASURES WATER RESOURCES 3-7-17 4-24 "Subsection 4.3, Water Resources: This subsection states that the "Location Hydraulic Study" deter- mined that impacts would be insignificant but it does not define the potential impacts. Channelizing will further increase the velocity of water in Oso Creek and may possibly contribute to increased 3-7-18 downstream erosion which has become a major problem during the last several years. Actual hydraulic impacts will be contingent upon the specific channelization design. Therefore, the mitigation measures should include City Engineer review and acceptance of final construction design. AIR QUALITY 4-35 "Subsection 4.4, Air Quality": This subsection provides regional scale analysis of CO, NOX, TOG, and PM, but only detailed analysis of CO emissions. State and Federal standards exist for NOX, TOG, and PM and these should also be evaluated in comparable detail to CO emissions to determine potential 3-7-19 impacts on adjoining sensitive receptors, in particular the Montessori School, San Juan Elementary School, Stonybrooke School, and Capistrano Valley High School. We recommend that the DEIR be revised accordingly. 4-35 114.4, Air Quality": This section concludes that the 1995 and 2010 air quality projections would meet Federal standards but it does not indicate what those standards are. The DEIR could discuss the 3-7-20 potential health impacts based on predicted concentrations and researched health effects. The DEIR should be revised accordingly. 4 • NOISE 4-42 114.5 Noise": The "Noise" section identifies two (2) • potential mitigation measures including (1) noise barriers for exterior land uses (2) acoustical 3-7_21 treatment for interior land uses. Other potential mitigation measures are available and should be cited and considered. 4-44 "Table 4.5.A., Predicted 2010 Traffic Noise Levels": This table is difficult to interpret because of its organization and it appears to be missing important information on the ability of mitigation measures to meet Federal and State noise standards. We recommend that the Table be revised to clearly indicate the applicable standard, the predicted noise level, the range of potential measures, and the "recommended" mitigation measure . 3-7-22 The DEIR does not appear to classify residential land uses as "interior land uses". We recommend 3-7-23 that they be classified as such and that the DEIR identify specific noise mitigation measures. The predicted noise levels are based on year 2010 which may be adequate if the Corridor is functioning at or near capacity. However, if the Corridor would not be at capacity, then predicted noise levels could be less than maximum expected. Predicted noise levels should be based on "at capacity" traffic volumes and mix, as opposed to year. 3-7-24 The mitigation measures should be more specific and indicate the location (by station) and height of 3-7-25 proposed noise barriers. Also, because of the potential visual impact and the City's designation of the I-5 as a "scenic highway", the barrier design 3-7.26 including material types and landscaping should allow for City review and approval. The DEIR should be revised accordingly. The Table refers to "end of pavement" which should �3-7-27 probably be "edge of pavement". The future freeway noise may have an effect on horses along the equestrian trails and the ability 3_7_2. of riders to control their horses. The DEIR should provide some discussion of this issue. 0 5 • 4-50 The proposed mitigation measures are based on the location of noise receptor sites and not land uses or structures. The potential noise impacts are not 3-7-29 necessarily limited to tested sites. The DEIR should be revised to relate mitigation measures to land uses and structures which may be impacted as opposed to the test sites. 4-59 Noise test sites R14 and R15 at Spotted Bull Lane call for special study to determine mitigation. The DEIR should include an assessment of the noise 3-7-30 impact study and identify a specific mitigation including possible dwelling retrofitting. 4-62 "Table 4.5.C., Noise Level Changes (No Build Alternative)": This table depicts decimal numbers for various roads in the County but does not indicate the measurement units. Do these numbers represent percentages or dBA. If dBA, is the noise 3.7.31 level measurement in CNEL or Leg. Revise the DEIR to indicate the existing noise levels and projected noise levels for the "no build" and "build" alternatives to allow a relative comparison. LAND USE 4-87 "Section 4.8, Land Use": This section discusses land use compatibility in the context "noise" and "relocation" impacts. The Report concludes that the Corridor would be compatible with land uses within San Juan Capistrano. To the extent that relocation, visual, noise, and air quality impacts are identi- 3-7-32 fied and mitigated, the project may be compatible. However, this section does not summarize all impacts related to compatibility and identify associated mitigation measures. We recommend that the DEIR be revised accordingly. 4-88 "Corridor Consistency with Future Land Uses": This subsection does not discuss the potential Corridor impacts on the City's proposed Open Space Lands. The report should include a discussion of potential 3-7-33 impacts including a land use compatibility determination. Revise the EIR accordingly. HOUSING AND BUSINESS RELOCATION 4-101 "Housing & Business Relocation": This section discusses, in general terms, the potential relocation impacts. Appendix I and Table I list a 3-7-34 number of properties in San Juan Capistrano which 6 may be impacted (partial land takes only). However, plans which have been forwarded to us by the Corridor Agency do not indicate improvements nor needed right-of-way. In the recent past, we have been advised on several occasions by Agency staff 3-7-34 that I-5 improvements would be completely contained within public right-of-way. However, apparently Rancho Viejo Road will require relocation to the east under either confluence alternative which may necessitate additional R-O-W. The DEIR must be revised to specifically discuss these relocation impacts in more detail. 4-106 "Relocation Mitigation Measures": The measures recommended by the DEIR are limited to "relocation assistance" when in fact other alternatives are available. The DEIR needs to discuss potential mitigation measures such as design/alignment 3-7-35 refinements which could further reduce relocation impact. These have been mentioned by TCA staff on occasion as a means of minimizing taking impacts. Also, if Rancho Viejo is to be shifted to the east, what is the conceptual design and how will the adjoining hillside be impacted? The City has 3-7-36 historically cited the Rancho Viejo Road impact as an important concern. The DEIR should be revised accordingly. If it is determined that Rancho Viejo Road must be relocated, such construction needs to precede I-5 3-7-37 construction to minimize local circulation impacts. 4-106 "Mitigation measure #9-211: This measure proposes the development of "Relocation Plans" with County or City staff. The measure should provide that City 3-7-38 staff will be involved in the development of "ROW Stage Relocation Plans". We recommend that the measure be revised accordingly. ARCHEOLOGICAL/PALEONTOLOGICAL RESOURCES 4-111 Mitigation measures #11-1 and #11-4 indicate on - site monitoring but then indicate that if resources are uncovered, the archeologist/paleontologist will be contacted and construction work halted. Who will be responsible for monitoring grading operations. Field supervisors or heavy equipment operators 3-7-39 should not be responsible for any preliminary determinations of resource value. We recommend that these mitigation measures be revised/clarified to providefor professionally qualified monitoring. 0 0 PEDESTRIAN, EQUESTRIAN, AND BICYCLE FACILITIES 4-116 This section does not discuss Rancho Viejo Bike Trail but it will apparently be removed by the Corridor. We discussed this issue with Agency staff and requested conceptual designs/ cross sections which clearly indicate the infeasibility. To date, Agency staff has only provided verbal justifica- tion which is not adequate. The DEIR should be revised to discuss the trail and include specific reasons for its apparently proposed deletion. LANDFORM 4-118 This section generally discusses landform impacts and mitigation measures. The report assumes that disposal of about 2.5 to 5.0 mcy of excess fill will occur in close proximity to the Corridor. The impact of disposing of this fill could be significant. The DEIR needs to include measures to prepare "Excess Fill Disposition Plans" which identify locations, haul routes, quantities, grading and revegetation. Also, if Rancho Viejo is relocated to the east, it may severely impact the hillside. The report should include measures for natural contour grading consistent with the Hillside Development Guidelines of the City and replanting/revegetation to match existing vegetation. For Rancho Viejo Road, a relatively narrow section roadway and/or retaining wall could reduce hillside grading impacts but may be inadequate from a circulation viewpoint and more visibly obtrusive. The conceptual plans should consider these alternative designs and the DEIR should include a discussion. VISUAL RESOURCES 3-7-40 3-7-41 3-7-42 4-120 This section identifies Spotted Bull Lane as a potentially sensitive visual receptor. In terms of distance (short, 2000 L.F.) and screening (incomplete) criteria, the DEIR finds potentially significant impacts without mitigation. However, 3.7-43 the mitigation measures do not include specific provisions. The DEIR should consider a measure to provide landscape screening on residential properties impacted by the Corridor view. 0 8 4-131 We concur with measures #15-10 and #15-14 regarding natural contouring. However, for such work within San Juan Capistrano, the measures should provide the 3-7-44 City with the opportunity to review and provide recommendation on plans. Please revise the DEIR accordingly. CONSTRUCTION ACTIVITIES 4-137 The Corridor will generate as much as 5 mcy of excess fill for disposal. The DEIR indicates that excess fill will be 1.) disposed at development sites in the vicinity of the Corridor, 2.) reused in the project, or 3.) hauled to outside areas. in order to minimize potential impacts, the Agency 3.7-45 should emphasize design modifications and reuse in the project followed by disposal at projects in the vicinity. Hauling to outside areas should only be considered as a last resort. The DEIR should be revised to include a general assessment of each method and prioritize the disposal options. From a cost viewpoint, if reuse or local disposal options are not readily available, the TCA's contractors may have to resort to outside hauling 3-7-46 �. which could significantly raise land preparation costs for the Corridor. This fact should be considered in more depth. 4-143 This section does not address potential impacts to Rancho Viejo Road and local circulation. We presume that this would be covered under measures #17-23, "Specific Traffic Management Plans". The City will 3-7-47 expect the preparation of such a plan to maintain adequate circulation on Rancho Viejo Road and other potentially affected arterials. SECTION 5.0. CIRCULATION 5-10 "Impacts to I-5 South of the Corridor": This section indicates that traffic in the south County will be drawn to the I-5 with an increase of 40- 45,000 vehicles per day. The DEIR cites that mitigation will be provided by I-5 auxiliary lanes between Ortega Highway and the confluence. However what will happen to the I-5/Ortega interchange including circulation and air quality impacts. The DEIR needs to be revised to disclose and address impacts ;within the -Study Area including this interchange. We recommend that you modify measure #T/C-3 to include possible improvements to the Ortega Highway/I-5 interchange. 9 3-7-48 SECTION 10, SIGNIFICANT UNAVOIDABLE ADVERSE IMPACTS 10-1 Under noise, the report lists sites R14 and R15 Spotted Bull Lane as areas where mitigation was determined not to be feasible but a notation indicates that no determination has been made. This aspect of the report is contradictory. The DEIR should be revised to assess the feasibility of measures and provide appropriate mitigation. If the DEIR finds that mitigation is not feasible, it must clearly indicate why. WR:mjm wp50\sp\deirsjht.att Flue 3-7-49 11 DRUG USE IS s December 19, 1990 Drew G. Harper, Property Manager Village San Juan Homeowners Association Pacific Coast Property Management Corporation 2.8261 Marguerite Parkway, Suite 210 Mission Viejo, California 92692 MEMBERS OF THE CITY COUNCIL LAWRENCE F BUCHHEIM KENNETH E FRIESS GARYL HAUSDORFER GIL JONES JEFF VASQUEZ CITY MANAGER STEPHEN B JULIAN Subject: San Joaquin Hills Transportation Corridor, Right-of-way impacts on Village San Juan. Dear Ms. Harper: I've received a copy of your December 6 letter to Cheryl Johnson, City Clerk regarding the potential right-of-way impacts of the proposed Corridor on Village San Juan. In your letter, you indicate that the Village San Juan Homeowners Association has reviewed information which indicates that the Corridor could require the condemnation of some Village San Juan homes in order to provide right-of-way to accommodate the proposed Corridor. In addition, the letter states that the Village San Juan Homeowners Association opposes any Corridor alignment which would "necessitate the removal of residential units." We understand your position on residential takings and we fully agree. In fact, one of the City's primary objectives has been to preclude Agency consideration of any design alternative which would require the removal of someone's home. The City has sought to assure that Corridor improvements are confined to existing right- of-way and in cases where additional right-of-way is necessary, that it be limited to "mirror 'Land takes" and not "structure takes". The City anticipated this issue early in the Corridor design process and was responsible for developing an alternative design concept (Option 2 confluence) which would move the Corridor about 2000 feet north of its originally proposed connection to the I-5 freeway. As a result of the City's efforts, the Transportation Corridor Agency which is responsible for the development of the Corridor, has endorsed Option 2. 3-7-50 32400 PASEO ADELANTO, SAN JUAN CAPISTRANO, CALIFORNIA 92675 • (714) 493-1171 Drew G. Harper -2- We have carefully reviewed the Corridor and they indicate that north of Village San Juan, would fifteen (15) feet to the east. Juan, all road improvements wi. public right-of-way and will not of residential structures. December 19, 1990 conceptual design plans for the Rancho Viejo Road, in the area require relocation approximately In the vicinity of Village San .1 be contained within existing require the removal or "taking" In summary, the position of your Association is one which the City has presumed during the lengthy Corridor process and we wholehear- tedly agree with the Village San Juan Homeowners Association on the issue of residential structure takings. The design plans presently being considered by the Corridor Agency do not propose "residential structure takes". The City's Planning Division and Engineering Division have copies of the conceptual design plans available for inspection and would be glad to show you or other interested residents the location of proposed improvements. If interested, you can contact Ted Simon City Engineer or William Ramsey, Senior Planner. Sincerely, f Kenneth E. Friess Mayor KF:WR:hs cc: Stephen B. Julian, City Manager Thomas Tomlinson, Planning Manager William Ramsey, Senior Planner William Huber, Public Works Director Theodore Simon, City Engineer Bernard Vokoun, Traffic Engineer Jean Foster, Project Engineer, TCA -.6teven Letterly, Environmental Manager, TCA 3-7-50 i :7 November 26, 1990 Mr. Steve Letterly, Manager of Environmental Impact The Transportation Corridor Agencies 345 Clinton Street Costa Mesa, CA 92626 RE: DRAFT ENVIRONMENTAL IMPACT REPORT/STATEMENT #1 FOR THE SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR; FINAL TECHNICAL AND ERRATA COMMENTS Dear Mr. Letterly: Thank you for providing the City of Irvine with the opportunity to review and comment on the subject document. Attached are the City 's technical and errata comments pertaining to the Draft Environmental Impact Report/Statement for the proposed San Joaquin Hills Transportation Corridor. All comments incorporated within the attachment reflect our existing General Plan policies/requirements, memorandums of understanding/agreements with other jurisdictions, and specific development/design standards that are imposed on all future and existing construction within the City of Irvine. Working cooperatively with all members of the Joint Powers Authority (JPA), The Transportation Corridor Agencies, the County of Orange, and the many affected federal and state agencies has always been Irvine's primary commitment. If properly designed, the San Joaquin Hills Transportation Corridor will contribute to solving our transportation problems in the areas of improved roadway efficiency and the inclusion of transportation system and transportation demand management techniques. Through reasonable mitigation, we believe the comments offered by the City of Irvine will make this transportation system highly successful with a design which incorporates the environmental preservation goals and policies contained in our General Plan. We look forward to receiving your response to our comments and request the official TCA "Response" be transmitted to the City of Irvine at a minimum of 15 days prior to certification of the EIR/EIS. • 3-8-1 Mr. Steve Letterly November 26, 1990 Page 2 If you have any questions about the City's comments EIR/EIS, please contact Patricia Shoemaker of Advance 724-6400 or Shirley Land of Circulation Programming a Sincerely, PAUL BRAD JR. City Mana er SW:9-26-90 Attachments on the Draft Planning at t 724-7340. cc: Bernard Strojny, Assistant City Manager Robert C. Johnson, Director of Community Development 0 • E SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR DRAFT EIR/EIS FINAL TECHNICAL AND ERRATA COMMENTS NOVEMBER 26, 1990 I. TECHNICAL A. PROPOSED PROJECT DESCRIPTION AND ALTERNATIVES 1. The grading impacts associated with construction of the Corridor are considered "substantial." A statement should be added regarding the TCA's intent to minimize grading impacts wherever possible. (Proposed Project Description and Alternatives, Section 2.0) Add the following Mitigation -to Page 2-11: Irvine's General Plan, a conceptual grading plan shall be reviewed and approved by the Director of Community or 10t. Relevant caeotechnical geologic, and soils 2. To the extent that cost estimates ar EIR/EIS, the document should clarify ultimate construction and planning guideway transit facility. (Page 3, #4; Page 2-29, Table 2.6A) B. CIRCULATION 3-8-2 e included in the draft funds for initial and studies for the fixed 3-8-3 Phasing and Financing, 1. The EIR/EIS should disclose that while 2010 traffic forecasts may be satisfactory for "design year" projections, they may not fully evaluate toll fare traffic forecasts. 3-8-4 Revenue to amortize the bonds will not flow until the mid to late 1990's and the bond period may extend beyond the year 2025. (Page 5-1, 5-21 5-3 - Traffic Projections) 2. The statement "the SJHTC is the least sensitive of all three proposed corridors to tolls" requires clarification and justification. (Page 5-8, Impacts of Toll Operations on 1 3-8-5 2010 Traffic Volume) T3-8-5 • 3. The Newport/Irvine Memorandum Of Understanding supports the restriction of trucks on the San Joaquin Hills Transportation Corridor (SJHTC). However, the draft EIR/EIS assumes trucks are allowed. It also assumes that tolls and 3-8-6 steep grades will discourage truck drivers from using the Corridor. The document should state TCA support of cities' efforts to restrict trucks on the Corridor (Page 2-16). 4. There are a number of discrepancies between Table 1.3.A, Table 1.3.0 and Figure 1.3.1. Table 1.3.0 has a number of errors on the Levels of Service identified for several 3.8-7 links. Attachment 1 is a list of these discrepancies for EIR consultant review. Figure 1.3.1 shows Michelson Drive extended between Jeffrey Road and Sand Canyon Avenue, and it also shows Culver Drive extended between Bonita Canyon Road and the Corridor. 3-8-8 Projections are even shown for the Culver Drive link. These links are inconsistent with Irvine's General Plan. 5. Table 2.2.A includes a footnote stating that "differences for Conventional Alternative are shaded", however, no 3-8-9 shading is found on the table. 6. Include language in the "Truck Traffic" section of the document (page 2-16) that indicates the features designed to 3-8-10 accommodate the impacts of the truck traffic (see comment No. 14 of our June 19, 1990, comment letter). 7. As mentioned in City correspondence of June 15, 1990, the description of the Barranca Parkway/I-5 Overcrossing states that it will open a major east/west arterial but that the 3-8-11 benefit ends at Sand Canyon Avenue. This overstates the benefits of this arterial. (Proposed Project Description and Alternatives, Section 2.0, Page 2-55) S. Caltrans should be identified as the lead agency in developing park and ride facilities. (Proposed Project 3-8-12 Description and Alternatives, Section 2.0, Page 2-57) C. CIRCULATION - HIGH OCCUPANCY VEHICLE 1. HOV/Transit - The sections describing the design features of the Demand Management and Conventional Alternatives arrive at the conclusion that HOV lanes, and especially transit, are not warranted in the opening phase of the 3-8-13 Corridor. By not providing HOV lanes with initial construction, this may have significant implications for the future provision of any HOV/transit. Fully explain the IL 2 reasons for not constructing HOV lanes in the first phase If and examine alternatives for design/phasing scenarios. Criteria determining when each will be "warranted," or what 3-8-13 Corridor improvements will be needed in order to provide them, must be addressed in the document if the intent is to provide them in the future. C7 2. Regarding alternatives to Phase I construction of HOV lanes, the EIR/EIS should explore strategies such as peak period HOV lanes using the third general purpose lane in each direction and/or HOV pricing incentives that go beyond price 3-8-14 reductions occurring naturally from cost sharing. The EIR/EIS should address the feasibility of traffic impacts from implementing these alternatives. 3. Mitigation measures T/C 1, 2, and 4 define design and program measures to be taken to increase HOV ridership to attain a 30% goal. Through early construction of HOV lanes, peak period HOV lanes, and/or HOV pricing incentives present more effective solutions to the long-range problem of inducing HOV ridership and reducing congestion on existing freeways and arterials. (Circulation, Section 5, Page 4-12 and 5-7) 4. The extension of HOV lanes onto State Route 73 will be evaluated by the Orange County Transportation Commission' (OCTC). This should be clarified in the document. In! addition, the project description should include a discussion of the feasibility of HOV-to-HOV connectors at the two termini. (Proposed Project Description andl Alternatives, Section 2.0, Page 2-2, 2-16 and 2-20) 1 3-8-15 3-8-16 5. The draft EIR/EIS states that the Corridor is included in the Regional Mobility Plan and complies with the 1989 Air Quality Management Plan (AQMP) for the South Coast Air Basin. Both of these documents require specific efforts by local jurisdictions to reduce traffic and air pollution through transportation demand management (TDM/ridesharing) 3-8-17 and transit. The TCA is a subregional agency with membership and support from local jurisdictions. The EIR/EIS should identify specifically how the Corridor will be phased to support TDM and transit efforts of these local jurisdictions. 6. As mentioned in the City's June 15, 1990 comments, the discussion of potential future median use on page 2-16 should identify a range of feet to which the "sufficient size" of the median refers. This should include a 3-8-18 discussion of the implications on HOV lanes and transit of the use of split-level grade design. (Proposed Project Description and Alternatives, Section 2.0, Page 2-16) 3 D. CIRCULATION - TOLLS 1. Toll Impacts - The documentation of the toll feature of the project has been reasonably substantiated in the text by providing informational facts describing the operation and discussing the impacts. References to the estimated period of operation as a toll facility and the proposed method of conversion to a freeway facility merit inclusion in the text, given that these are among the most frequently asked questions regarding tolls by the residents. Figure 5.3 (Toll/Toll Free Screenline Comparisons) needs additional language clarifying its use and interpretation. Also, discuss why arterials in screenline 5 will actually experience an increase in ADT with operation of the SJHTC as a toll -free facility. (Traffic and Circulation, Section 5.0) . 3-8-19 The document must acknowledge the fact that its conclusions about toll sensitivity and toll impacts on the surrounding circulation system heavily rely on the accuracy of the 3-8-20 financial forecasts. This must be supported with provisions for the inherent margin of error. A monitoring system must be included as a mitigation measure to ensure that the impacts of tolls on the local circulation system along the 3-8.21 Corridor route remain insignificant and in accordance with the conclusions of the technical studies on tolls. 2. The Proposed Project section states that "either build alternative would operate as a toll facility until bonds are repaid." A brief statement in that section and in the Proposed Project Description and Alternatives section should identify what will happen to the toll booths, ancillary equipment and buildings, once the bonds are repaid and the facility is converted into a "freeway." The description should address the elimination of the toll facility, modified/downscale design of corridor and restoration/ replanting of affected areas back to its original natural condition. (Summary, Page S-1) 3-8-22 E. WATER RESOURCES 1. The Bonita Reservoir Buffer is identified in the Irvine Master Environmental Assessment as an Area of Moderate Significance. The buffer area is a setback from the edge of 3-8-23 Bonita Canyon Reservoir, an area of high significance. This buffer should be maintained in order to protect the reservoir from construction encroachment. (Water Resources, Section 4.3) �11 • Recommended additional mitigation: 13-8-24 4 0 0 The project sponsor shall Rre are grading_and erosion control plans for corridor improvements between MacArthur Boulevard and the proposed Laguna Laurel protect in accordance with management practices per the 3-8-24 SCAG Management 208 Plan. Said plans shall be subiect F. AIR QUALITY 1. Provide rationale for supporting the number of air quality receptor sites in the Turtle Rock area. Identify whether number of receptor sites are sufficient to assess possible 3-8-25 impacts to the adjacent residential areas and support findings in Air Quality Technical Report 3. (Air Quality, Section 4.4) 2. Expand discussion to address air quality degradation to areas affected by prevailing winds and, if appropriate add mitigation measures such as reduction of idling time at toll 3-8-26 plazas or truck through -travel. (Air Quality, Section 4.4) G. NOISE 1. The Traffic and Circulation subsection, entitled Traffic Projections - OCTAM II contains a brief analysis on the noise effects of OCTAM II projections. This discussion focused on the magnitude of impact based on an overall increase in average daily traffic expected from the yielded change in volume projections. The conclusion was that 3-8-27 volumes would have to double to increase 3.0 dba. This fails to argue that the worst -case scenario for noise studies, which assumes LOS C (or free -flow conditions) for all arterials. Provide discussion on how this methodology (worst -case LOS C) is applied to the assessment of noise impacts. (Traffic and Circulation, Section 5.0) 2. Clarify why an increase of 3.8 dB is "a barely noticeable change in level" (page 4-61) when page 4-42 states that "a 3dB change in sound level is subjectively perceived as a noticeable increase in loudness." Technical Report No.4 (Section 6.2 Noise Criteria) further states that "a 3 dB 3-8-28 difference in noise level is generally accepted by the scientific community as the threshold where the typical human ear can perceive a change in loudness." (Noise, Section 4.5) 3. Expand Noise Section to identify what assumptions were usedl3-8-29 • 5 for projecting noise levels discussion should address whetl are likely to produce the same ramps, and HOV lanes. Also, noise levels are affected by truck traffic. (Noise, Section ind determining impacts. The er the two build alternatives 3-8-29 noise, given the toll plaza, provide a discussion on how the presence or absence of I3-8-30 4.5) 4. Eliminate the discrepancy in the analytical interpretation for Crystal Cove State Park (10) - 4(f) properties. Appendix A, page 35 indicates that an 8 dBA increase in noise levels is due to construction of the Corridor and that the noise effects of the Corridor would not substantially impair the activities, functions or attributes of this resource due to the degraded noise environment associated with the future No Build scenario. The 4(f) Noise Analysis in Technical Report #4 (page 39) indicates that the 2010 build traffic noise level is 8 dB higher than the no -build level and would result in a substantial impairment of noise sensitive activities, features or attributes of this resource. Page 17 of Technical report #4 further states that the FHWA's proposed amendment to their 4(f) rules define that a substantial impairment or impact of a 4(f) resource as occurring when the future noise level with the proposed action is more than 3 dBA over the noise level without the proposed action. (Technical Report #4, Section 10 and Appendix A, Section 4(f) Evaluation) 5. The discussion on local arterial traffic noise concludes that the "No Build Alternative" would result in a change in travel patterns in the region on surrounding arterials and freeways which would in turn result in higher noise levels. However, the noise analysis did not consider the City of Irvine's General Plan land uses. This may represent a significant shortcoming in the analysis. Provide clarification on why some arterials such as Bonita Canyon Drive would experience a decrease in noise if no corridor is built and whether Sand Canyon Avenue (East of Corridor) would experience an increase in noise. If necessary, TCA should conduct a new noise study reflecting pertinent arterials. (Noise, Section 4.5) 6. The City of Irvine recommends use of the same approach and methodology in analyzing and mitigating noise and biotic impacts resulting from the San Joaquin Hills and Foothill Transportation Corridors. Consistency in analytical approach would strengthen the documentation. A discussion/comparison of the approach and methodology utilized for the Foothill and San Joaquin .Hills Transportation Corridors environmental documents, as well as the reasoning or basis, should be provided. 7. Mitigation measures should be added to protect wildlife 6 3-8-31 3-8-32 3-8-33 f roml3-8-34 • • noise impacts. The noise analysis indicates that an increase' of 24 dba (42 to 66 dba) would occur near Receptor Location R42 (Crystal Cove Park). The City Is Conservation & Open Space Element (Objective L-2 Biotic Resources) of the General Plan designates Bommer and Shady Canyons as significant and diverse biotic communities. As identified in the City's Master Environmental Assessment (MEA), these areas include the following significant resources: Regionally Significant Riparian Habitat, Prime Bird of Prey Nesting/Roosting Area and Major Wildlife Movement Corridor. Standard mitigation measures adopted for the protection of these sensitive areas require a 300-foot development setback from the edge of high ecological sensitivity areas. Therefore, the City of Irvine recommends that natural buffer zones including a combination of berming and planting of native materials be installed to lessen the impact of noise on wildlife. (Noise, Section 4.5 and Biological Resources, Section 4.6, Wildlife - Noise Exposure) 3-8-34 H. BIOLOGICAL RESOURCES 1. The initial biological analysis conducted by P & D Technologies utilized a different methodology for assessing project impacts on biological resources than the LSA analysis. Explain why this methodology was changed. Clarify whether the same impacts were analyzed in each study, or 3-8-35 whether the scope was expanded. The LSA analysis is referred to as an updated version of the P & D analysis. Address concerns relative to inconsistencies which exist between the two studies. (Biological Resources, Section 3.6) 2. The City should be named as a participant in all subsequent wetlands) mitigation program(s). Accordingly, all applicable mitigation measures should be amended to include 3-8-36 the City of Irvine in the County and TCA coordination efforts. 3. A portion of the Creek downstream of Bonita Canyon Reservoir is proposed to be rerouted through a box culvert directly under existing rock outcroppings and beneath part 3-8-37 of the Corridor right-of-way. Evaluate the impacts of streambed modifications on wildlife and propose mitigation measures. (Biological Resources, Section 4.6) 4. Since various habitats will be destroyed by the construction of the Corridor, the Draft EIR/EIS should include a discussion on the diminished availability of wildlife breeding grounds, and the cumulative effects of this in 3-8-38 terms of species relocation;'` crowding, and species compatibility at'`the possible habitat mitigation sites. i (Biological, Section 4.6; and Cumulative Impacts, Section • 7) 5. A mitigation measure requiring temporary fencing of construction staging areas should be added to ensure wildlife protection during grading and other construction 3-8-39 activities. The measure should also identify parties responsible for overseeing and monitoring these construction activities and their effects on wildlife. 6. Table 4.6.B identifies birds and upland water fowl as having low capability to withstand insect/disease control operations, and the use of chemicals on non-native vegetation. Sensitive wildlife bird species, such as the nesting grounds for the California gnatcatcher, have been identified within the Corridor area of disturbance, and should be protected (Biological Resources, Section 4.6). The City of Irvine recommends that the following mitigation measures be implemented to minimize this identified impact: A. Prior to the submittal of Preliminary ctradina hermits. The independently selected biologist and City of T Development describing in full the method of approach. 8 3-8-40 3-8-41 0, B. V 3-8-42 Address the purpose, tvpe, frequency, and extent of insect and disease control operations on impervious 3-8-43 surfaces. D. Address the purpose type frequency, and extent of chemical use and controlled burning for non-native 3-8-44 landscape maintenance. E. control operations. 13-8-45 G. Identifv the impacts, and propose mitigation measures for wildlife identified in Table 4.6 B as having low and moderate capability to withstand chemical and 3-8.46 controlled burning for non-native landscape maintenance. 7. Address the accessibility of wildland interface areas. Roads within these areas should be a minimum of 14 feet in width to allow off -road emergency vehicle access and 3-8-47 required maintenance by bulldozers. (Biological Resources, Section 3.6; and Public Services, Section 3.9)- 8. The proposed conversion of Bonita Creek into a grass -lined channel crossing 15 culverts, would result in a significant unavoidable impact to wetland habitat value and wildlife movement corridor. The City of Irvine recommends the routing of Bonita Creek west of the proposed corridor alignment, extending from Bonita Reservoir to the San Diego Creek Channel. Attachment 2 depicts the city -proposed 3-8-48 concept plan for the location, width, and treatment of Bonita Canyon Creek. Furthermore, the City recommends that all landscaping within the boundaries of the channel be native riparian vegetation. This concept would mitigate impacts associated with the disruption of wildlife movement between Bonita Creek and Upper Newport Bay. (Biological Resources, Section 4.6, page 65) 9. Technical Memorandum 3-20, "Wildlife Crossing at San Joaquin Hills Transportation Corridor" (3/19/90), recommends only one wildlife undercrossing. The City strongly recommends additional undercrossing locations 3-8.49 through the use, of spanning wildlife movement corridors rather than through a corrugated' pipe. Attachments 3 and 4 9 identify city -proposed conceptual designs for all wildlife movement corridors. These designs connect preservation areas, state and federal lands, wetlands, and significant 3-8-49 biotic resources, through a series of bridges that span natural bridges to serve as wildlife corridors. In addition, the City recommends that an approved wildlife migration study be incorporated into the final corridor design plans to ensure that the location of all wildlife crossings serve the intended wildlife population. Such 3-8-50 study shall be reviewed and approved by the City of Irvine, the California Department of Fish and Game, and the County of Orange. 10. There has been a substantial amount of wildlife not identified as "Impacts to Sensitive Resources." Figures 4.7.3, 4.7.4, 4.7.5, and 4.7.7 should be revised to include the endangered specie habitat areas identified in Attachments 5, 6 and 7 respectively. These include: 1. Figure 4.7.3 (Page 4-76) : 3-8-51 A. Six additional habitat zones for the California Gnatcatcher. B. Two additional habitat zones for the California Cactus Wren. 2. Figure 4.7.4 (Page 4-77): A. Three additional habitat zones for the California Gnatcatcher. 3-8-52 B. Three additional habitat zones for the California Cactus Wren. 3. Figure 4.7.5 (Page 4-78): A. Six additional habitat zone for the California 3-8-53 Gnatcatcher. 4. Figure 4.7.7 (Page 4-80): A. Assuming the extension of California Avenue Bridge is included, as depicted in the City's General Plan, the Least Tern and Clapper Rail must 3-8-54 be included to the list of endangered species. 11. Expand discussion concerning light and glare impacts on nocturnal wildlife activity (i.e., disruption of nesting or sleeping patterns) and identify mitigation measures such as 3-8-55 the use of earth berms and vegetation to minimize or reduce 10 is L� • light and glare impacts to wildlife in areas adjacent to the corridor. Reference and expand Mitigation Measure 15-18 to 3-8-55 analyze other types of lighting such as "mused" lighting. (Biological Resources, Section 4.6) 12. On November 13, 1990, The Irvine Company entered into an agreement with the Nature Conservancy to conduct a feasibility study which addresses public use and management of approximately 16,000 acres of open space. Approximately half of this land is located on either side of the proposed San Joaquin Hills Transportation Corridor. As part of this 3-8-56 agreement, the Nature Conservancy has been directed to determine whether these wild lands may be opened to the public for hiking, bicycling, and horseback riding, or remain fenced to protect sensitive habitat and threatened animal species. Once the study is concluded (June 1991), the Nature Conservancy will most likely maintain management of these lands. To ensure that proposed San Joaquin Hills Transportation Corridor design meets the intent of this recent agreement, the City of Irvine recommends the following mitigation: maximization of large .continuous and undisturbed Company. I. WETLANDS 1. The Bonita Reservoir is identified in the City's MEA as an area of High Significance. The management goal for this riparian and marsh habitat is to preserve the existing habitat value with no loss. In addition, it is part of the watershed which leads to Upper Newport Bay, a state ecological resource. As the Corridor will intersect the 3-8-57 3-8-58 Bonita Canyon watershed, a realignment and undergrounding of^ the Creek is proposed. Current design proposal would result in pollutant runoff flowing into this sensitive watershed. Pollutants in the runoff flow will have high levels of lead, zinc, grease, and oil and any toxic plume generated from the closed Coyote Canyon Sanitary Landfill. The City -proposed routing of the Bonita Creek Channel north of the SJHTC. would significantly lessen the amount of toxics flowing', into the creek, reservoir, and ultimately, Upper Newport' Bay. This design would also help mitigate impacts associated with the disruption of wildlife movement between Bonita Creek and Upper Newport Bay (4.7, Wetlands; Biological Resources, section). To ensure that the Bonita Reservoir area riparian and marsh habitat value is maintained, expand the following mitigation measures to read as follows: 3-7 Prolect olans (drainage improvements) shall be UUZM .. 3-9 J. PUBLIC SERVICES 1. There is an eight -mile distance between two interchanges, Bonita Canyon and Laguna Canyon. The Irvine's MEA identifies High Fire Hazard Severity zones in the Bonita Canyon Reservoir, Coyote Canyon, and Bommer Canyon areas which the Corridor traverses. Objective J-1 of the City of Irvine's General Plan requires that the City identify actions, in concert with other jurisdictions, to reduce the probability of hazard occurrence. The City of Irvine, along with the Orange County Fire Department, recommends that the following mitigation measures be implemented: 1. Establish criteria for the SJHTC development with emphasis on fire retardant materials, minimization of exposure risk to wildfire and adjacent structure fires, and access for fire fighting personnel and equipment. (Public Services, Section 4.10) 2. To allow emergency and law enforcement access to both 12 �3-8-58 3-8-59 3-8-60 3-8-61 3-8-62 3-8-63 13-8-64 0 0 • east and west bound traffic. Turnouts should be provided in the center median at one mile intervals. 3-8-64 (Public Services, Section 4.10) 3. To allow emergency access in wildland areas adjacent to the Corridor, roads shall be provided in areas identified in Irvine's MEA as Moderate and High Fire Hazard Severity. Access roads shall be provided in the following areas: Bonita Canyon Reservoir, Coyote Canyon, Bommer Canyon. As prescribed by the Orange 3-8-65 County Fire Department, the access roads shall be a minimum of 14 feet in width to allow off -road emergency vehicle access and required maintenance by bulldozers. (Public Services, Section 3.9, and Biological Resources, 3.6) 4. Underpasses shall be provided utilizing the same dimensions described in mitigation measure #3, to allow 3-8-66 accessibility to interface areas on either side of the corridor. (Public Services, Section 4.10) 5. Emergency access turnouts and access to wildland areas, as specified in mitigation measures #2, #3, and #4 above, shall be installed and functional during the 3-8-67 construction phase of the project, and through out the duration of the project. (Public Services, Section 4.10) 1 6. Pre -wired cable T.V. connections for fire and police alarms shall be provided in the toll facility 3-8-68 structures. (Public Services, Section 4.10) 7. Address the potential for joint use of bicycle, equestrian, and pedestrian access routes for animal 34-69 crossings. (Public Services, Section 3.9; Pedestrian, Equestrian, and Bicycle Facilities, Section 3.12) 8. See comment #3, M. Pedestrian, Equestrian, and Bicycle 3-8-70 Facilities. K. HISTORIC/ARCHAEOLOGICAL/PALEONTOLOGICAL RESOURCES 1. The draft document needs to reference City of Irvine and County of Orange master environmental assessments as a 3-8-71 source in documenting impacts to sites of paleontological significance. The identification and discussion of known and probable paleontological sites within the Corridor's Area of Direct Impact (ADI) needs to be included. The Corridor alignment near Bonita Canyon Road and the Route 73 3-8-72 is a designated .as a high sensitivity resource zone. The Irvine MEA identifies ten paleontological sites within this 13 r zone. (Archaeological/Paleontological Resources, Sections 3-8-72 4.11 and 3.10) 2. Page 4-111, Mitigation Measure 11-1. There should be an archeologist present during pre -grading and grading activities along with procedures for redirecting or halting work. Moreover, the procedures should be worked out in advance and discussed at the pregrading conference. (Archaeological/Paleontological Resources, Section 4.11) The following mitigation is suggested: 3. The TCA archaeologist and paleontologist, and local Page 4-110. The numbers do not add up. 16 - 8 8 Technical inconsistencies: 8 - 2 (non ADI) = 6 ADI 6 - 2 Unknown significance -- it is not clear whether their ADI or within an area of potential effect -- the 8/90 version shows 4 4 - 1 One site has already been mitigated which equals 3 3/= "The remaining five sites" will be "totally destroyed" 14 3-8-73 3-8-74 0 4. Relevant paleontological data should be provided to the 3-8-75 project archaeologist and these resources should work in tandem. L. HAZARDOUS WASTE/MATERIALS 1. Mitigation No. 12-4 should require a contingency plan for hazardous waste/material clean-up activities. The responsible parties (i.e Transportation Corridor Agencies and property owner) should conduct a detailed site assessment of the land prior to conveyance. The EIR/EIS should identify the party(s) who will assume clean-up and/or financial responsibility for the removal of hazardous waste/materials. (Hazardous Waste/Materials, Section 4.12, Mitigation Measure 12-4) M. PEDESTRIAN, EQUESTRIAN, AND BICYCLE FACILITIES 1. There are a number of discrepancies between what the Draft EIR/EIS has identified to be a Class I or Class II trail, existing trails, and the City's records. To ensure that the corridor will accommodate natural areas for overcrossings by preserving and creating wildlife and public access, Section 4.17 should address this issue and identify appropriate mitigation measures to promote continuity between local jurisdictions. Such mitigation shall require that a pedestrian, equestrian, and bicycle_ facilities plan be reviewed and approved by local jurisdictions. (Pedestrian, Equestrian, and Bicycle Facilities, Section 4.13) 2. Consider provisions for identified bike trails. Bicycle trails may be utilized by emergency apparatus provided that they are a minimum of ten feet in width and construction of an "all-weather" driving surface having the capability of supporting the weight of a 60,000 pound vehicle. Additionally, it is assumed the bicycle and hiking/equestrian trail crossings shown in the City's Master Plan for Bicycle Trail Corridors and Equestrian/Hiking Corridors are to be constructed as part of the project. Attachment 8 is a list of bicycle and equestrian trail facilities to be included in the final EIR/EIS. (Pedestrian, Equestrian, and Bicycle Facilities, Section 4.13) 3-8-76 3-8-77 3-8-78 3-8-79 3. Figure 3.12.1 does not document the riding/hiking trail for Sand Canyon Avenue. In addition, the bike trail is a "Class I," off-street trail. The figure incorrectly refers to it 3-8-80 as a Class II. All bicycle/hiking/equestrian trails should 15 • be properly identified and labeled (i.e., classification) on all figures. (Pedestrian, Equestrian, and Bicycle 3-8-80 Facilities, Section 3.12) N. VISUAL RESOURCES 1. The use of split-level grade design mentioned in the Visual Resources section (i.e., Mainline Toll Plaza) should be 3-8-81 described in the Project Description and Alternatives section. (Visual Resources, Section 4.15, Page 4-128) 2. As stated in our comments dated June 15, 1990, the view impact analysis should address the mainline toll facility as 3-8-82 viewed from Turtle Rock. This omission should be corrected. (Visual Resources, Section 4.15, Page 4-126) 3. Analyze other types of lighting such as "mused" lighting to mitigate light and glare impacts to adjacent developments. 3_g_83 (Visual Resources, Section 4.15 - Mitigation Measure 15-17) 4. The analysis should reflect th depicted in the Irvine General Bommer Canyon would decrease the road cutting across the base reduce fill slopes and avoid habitats in both Bommer a Resources, Section 3.13) 0. CONSTRUCTION ACTIVITIES e Sand Canyon alignment as Plan. The route west of major visual impacts of the of the canyon, which would bisecting major wildlife nd Shady Canyons. (Visual 1. Identify in Mitigation Measure 17-4 that contractors will also comply with all city sound control and noise level requirements. The City of Irvine Noise Ordinance VI.K 305 requires that: "Construction activities shall only occur between the hours of 7 a.m. and 7 p.m. Monday through Fridays, and 9 a.m. and 6 p.m. Saturdays. No construction activities shall be permitted outside of these hours or on Sundays and federal holidays, unless a temporary waiver has been granted by the Manager of Building and Safety. Any waiver shall take into account the impact upon the community." Therefore, project -related haul trucks and construction equipment traveling through Irvine must comply with Irvine's construction noise ordinances to ensure that noise will not significantly impact Irvine residents. (Construction Activities, Noise, Section 4.17) 16 3-8-84 3-8-85 • 0 0 2. Expand Mitigation Measure 17-8 to require that haul routes for construction equipment and heavy construction related vehicles will be developed with input and approval of the 3-8-86 local jurisdictions (Construction Activities, Noise, Section 4-17) . 3. Expand Mitigation Measure 17-9 to require advance notice of blasting activities to local law and fire enforcement agencies and to nearby Homeowner Associations in residential 3-8-87 areas and compliance with sound control and noise level requirements of the County and cities bordering the corridor. (Construction Activities, Noise, Section 4-17) 4. Upon development of construction Traffic Management Plans for implementation of Mitigation Measure 17-22, public notification program for construction activities and detours similar to and beyond those currently used for the I-5 3-8-88 Widening Project. Coordination and approval by local agencies is mandatory. (Construction Activities, Detours & Traffic Management, Section 4-17) 5. Modify Mitigation Measure 17-23 to state that Specific Traffic Management Plans will be prepared and implemented 3-8-89 subject to review and approval of the affected local jurisdictions. (Construction Activities, Detours and Traffic Management, Section 4-17) 6. Add a mitigation measure to require that an emergency access plan for construction activities will be developed with input and approval of local jurisdictions. (Construction 3-8-90 Activities, Section 4.17 and Public Services, Section 4.10) 7. As noted in comment No. I-1, the Bonita Reservoir is identified in the City's MEA as an area of High Significance. Relative to concerns regarding the possible watershed contamination of these sensitive habitat areas during construction, address the following: 1. Coordinate with the Orange County Integrated Waste Management Department to identify construction - related hazards relative to possible leachate disruption within the Coyote Canyon Sanitary Landfill area. 3-8-91 2. An emergency management plan should be prepared which identifies how incidents will be minimized 3-8-92 to a level of insignificance. P. GROWTH -INDUCING IMPACTS 17 • 1. Reference is made to County of Orange growth projects which conclude that development/growth will occur in south Orange County with or without the Corridor. Development will. likely occur in south Orange County, as a whole, with or without the corridor. However, there are no references made that focus on growth -inducing impacts within the Area of Benefit. Reference studies that conclude that development within the area of benefit (specifically) will not be affected positively or negatively by the construction of the Corridor. (Growth Inducing impacts, Section 6 page 11, paragraph 2) 2. The last sentence states that the development of committed land uses within the area of benefit is not contingent on the construction of the Corridor. However, this contradicts further discussion in paragraph 3 which points out that a substantial portion of the area of benefit has been the subject of considerable planning efforts since the Corridor was identified on the Master Plan of Arterial Highways in 1976. Therefore, the decision making process for substantial development within the area was likely influenced by the Corridor planned for this portion of South County. The draft EIR/EIS discusses impacts of development enable by construction of the Corridor, but in light of the fact that development has been planned with the Corridor in mind, the draft EIR/EIS does not adequately' discuss development impacts that would occur without) construction of the Corridor. (Growth Inducing Impacts, Section 6, page 11, paragraph 2) Q. 4(f) EVALUATION 1. The introduction states that the 4(f) Evaluation will include an analysis of the following: "privately owned areas offered for dedication to a public entity through cooperative planning, 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 construction. Analyses of these "non-public" 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." It seems that Bommer Canyon Park is included in the analysis because it will eventually be dedicated to the City of Irvine at the time of future development approvals. However, Bommer Canyon Park is only one small area within almost 3,000 contiguous acres that will be dedicated to the is 3-8-93 3-8-94 3-8-95 1] 0 C • City by The Irvine Company. This overall area is designated as "Preservation" within the Irvine General Plan. Although not required by existing judicial interpretations of Section 4(f), if the Draft EIR/EIS analysis is to include Bommer Canyon Park, the City requests that the analysis also include all of the adjacent areas that will eventually be 3-8-95 publicly owned for open space purposes by the City of Irvine. This would be consistent with the treatment of the Laguna Laurel Dedication Areas which are also under private ownership, but will be dedicated to the County as adjacent development occurs. (Appendix A, Section 4(f) Evaluation) 2. The discussion on Bommer Canyon Park incorrectly states that there is no planned access between Bommer Canyon Park and Crystal Cove State Park. The Circulation Element of the 3-8-96 Irvine General Plan identifies both a Class I off-street bicycle trail and a hiking and equestrian trail linking Bommer Canyon and Crystal Cove State Park. (Appendix A, Section 4(f) Evaluation and 11-g, p.22) II. ERRATA 1. While Table A (Comparison of Alternatives & Major Impacts, page S-8) and Table 2.6 A (Project & Right -of -Way Costs, page 2-29) show the same ultimate project total costs, the details in Table A are stated incorrectly. Costs shown as right-of-way costs in Table A are listed as Engineering 3-8-97 (Design and Construction) in Table 2.6. A. Table A shows right-of-way as 669.9 and 682.1 acres, respectively. Table 2.6 A shows 972 and 922 acres, respectively. This information should be corrected for consistency. (Proposed Project Description and Alternatives, Section 2.0) 2. Page 4-33 cites a Technical Report without providing a technical memorandum number. Specify that "Technical 3-8-98 Report" is Technical Report #3 (Air Quality, Section 4.4). 3. Page 2-38. The last line is missing. (Alternatives�3-8-99 Withdrawn From Consideration, Section 2.8) 4. Figure 3.3.1 should identify University Drive. (Waterl3-8-100 Resources, 3.3, Page 8) 5. Identify the date of the most recent biological analysis conducted by LSA for the SJHTC area. (Biological Resources, 3-8-101 Section 3.6, page 28) 6. Figures 3.6.1 3.,6.5 should include a compass map symbol in these figures. (Biological Resources, 3.3 page 31-35) 3-8-102 19 7. Technical data does not include referenced Technicall3-8-103 - Memorandum - Revised Corridor Staging Traffic and Revenue Estimate, Task 30. 8. The discussion on Impact of Toll Operations on Other Roadways, makes reference to "an analysis" that should be 3-8-104 specifically documented. (Page 5-10) 9. "Figures V-4 and V-5 of the RMP" should respectively read:l3-8-105 V-5 of the HOV; and V-8 of the Transit. (Page 1-3) 10. The E1 Toro Y has been improperly identified as an arterial. This should be corrected to reflect the E1 Toro Y as a13-8-106 freeway to freeway interchange. (Page 1-7) 11. The SR-1 links have been removed from Table 1.3.A, and should be replaced. Also, Table 1.3.0 references Pacific 3-8-107 Coast Highway links. These links should be renamed to SR-1 to promote consistency. 12. Change "Design Management Alternative" to "Demand I3-8-108 Management Alternative" in third paragraph, page 2-33. 13. Eliminate the inconsistency between Table 4.1.B (states no mitigation measures are required) and on page 4-117, which cites mitigation measure 13-1 requiring tollway final design plan to provide facilities at master planned locations per 3-8-109 the standards of Caltrans and affected local jurisdictions. 10 (Pedestrian, Equestrian, and Bicycle Facilities, Section 4.13, Page 4-9) 20 0 0 0 Table 1.3.A Link: SJHTC FINAL EIR COMMENTS I-405: - Culver Drive/Jamboree Road - not shown on 3-8-110 Figure 1.3.1. I-5: - Ortega/Junipero Serra - shows 2010 ADT with corridor to be 190 (thousand) , while Figure 3-8-111 I 1.3:1 shows ADT to be 210 (thousand). - Junipero Serra/SJHTC - shows 2010 ADT with corridor to be 210, while Figure 1.3.1 shows 3-8-112 ADT to be 220. - SJHTC/Crown Valley - shows 2010 ADT without corridor to be 190 and 2010 ADT with corridor to be 150; Figure 1.3.1 shows ADTs of 190 3-8-113 and 150 respectively. - Lake Forest/Bake Parkway - not shown on Figure 1.3.1. I3-8-114 SR-1: - These links are missing all together from the table. table. Table 1.3.0 Highway Section: - Laguna Hills Drive/east of Aliso Creek Road: I3-8-116 - not shown on Figure 1.3.1. - Lake Forest Drive/west of I-405: - existing LOS, 2010 without corridor LOS, and 2010 3-8-117 with corridor LOS are all shown to be B; should be A, C, A, respectively.* - Lake Forest Drive/east of Bake Parkway: - existing LOS, 2010 without corridor LOS, and 2010 3-8-118 with corridor LOS are all shown to be B; ,should all be A.* - Laguna Canyon Road/south of SR-73: - 2010 without corridor LOS shown to be B; should be13-8-119 A.* - Laguna Canyon Road/south of I-405: - existing LOS shown to be B; should be A.* 1 3-8-120 - Bake Parkway/west of I-405: - considered a primary arterial; is actually a 3-8-121 major.** - 2010 without corridor LOS shown to be E, and 2010 with corridor LOS as B; should be B and A,(3-8-122 respectively.* ATTACHMENT 1 SJHTC Table 1.3.0 Comments October 16, 1990 Page 2 - Bake Parkway/west of Lake Forest Drive: - considered a primary arterial; is actually a major.** 3-8-123 - 2010 without corridor and with corridor LOS both shown to be B; both should be A.* - Bake Parkway/west of Laguna Canyon Road: - considered a primary arterial; is actually a major.** - 2010 without corridor LOS shown to be E, and 2010 3-8-124 with corridor LOS as B; should be B and A, respectively.* - Sand Canyon Avenue/south of SR-73: - considered a proposed commuter arterial; is actually a proposed primary.** 3-8-125 - 2010 with and without corridor LOS both shown to be B; both should be A.* - Sand Canyon Avenue/north of SR-73: - 2010 with and without corridor LOS both shown to 3-8-126 be B; both should be A.* - Pelican Hill Road/south of SR-73: - 2010 with and without corridor LOS both shown to 3-8-127 be B; both should be A.* - Culver Drive/north of Bonita Canyon Drive: - considered a major arterial; is actually a3-8-128 ' I secondary.** - existing LOS, 2010 without corridor LOS, and 2010 with corridor LOS are all shown to be B; should be 3-8-129 A, D, and D, respectively.* - Culver Drive/south of University: - existing LOS and 2010 with corridor both shown to 3-8-130 be B; should be A and C, respectively.* - Ford Road/east of MacArthur Boulevard: - existing LOS, 2010 without corridor LOS, and .2010 3.8.131 with corridor LOS are all shown to be B;.should all be A.* - Ford Road/west of MacArthur Boulevard: - existing LOS, 2010 with and without corridor LOS 3-8-132 are all shown to be B; should all be A.* - Bonita Canyon Drive/east of Culver Drive: - considered a major arterial; is actually a secondary.** - shows 2010 ADT without corridor to be 29 (thousand) , while Figure 1. 3.1 shows the ADT to be 3-8.133 49 (thousand). - existing LOS, 2010 without corridor LOS, and 2010 with corridor LOS are all shown to be B; should be A, F, and D, respectively.* SJHTC Table 1.3.0 Comments October 16, 1990 Page 3 - Bonita Canyon Drive/east of SR-73: - considered a major arterial; is actually a primary.** 3-8-134 - existing LOS is shown to be B, and 2010 without corridor LOS is shown to be D; should be A and F, respectively.* - MacArthur Boulevard/south of San Joaquin Hills: - existing LOS is shown to be B; should be A.* - MacArthur Boulevard/south of Ford Road: - 2010 with corridor LOS shown as B; should be A.* 3-8-135 - MacArthur Boulevard/south of Bison Avenue: - 2010 with corridor LOS shown as B; should be A.* - MacArthur Boulevard/north of Campus Drive: - existing LOS, 2010 without corridor LOS, and 20LO with corridor LOS shown to be B, C, and B, respectively; should all be A.* 3-8-136 - shows 2010 ADT with corridor to be 35, while Figure 1.3.1 shows the ADT to be 36. - University Drive/north of Culver Drive: - considered a major arterial; is actually a primary.** 3-8-137 - existing LOS, 2010 without corridor LOS, and 2010 with corridor LOS are all shown as B; should be A, F, and A, respectively.* - University Road/east of Harvard Avenue: - existing LOS and 2010 with corridor LOS both shown to be B; should both be A.* - University Drive/north of California Avenue: 3-8-138 - existing LOS shown as B; should be A.* - University Drive/north of SR-73: - existing LOS shown as B; should be A.* - Jamboree Road/north of California Avenue: - existing LOS shown to be A, and 2010 without corridor LOS shown to be E; should be A and F, 3-8-139 respectively.* - Jamboree Road/north of Campus Drive: - shows 2010 ADT with corridor to be 36, while Figure 1.3.1 shows the ADT to be 35. 3-8-140 * LOS based on City of Irvine General Plan, Arterial Highway Designation, and OCEMA Transportation Element Roadway Design Standards. ** Arterial type based on City of Irvine General Plan, Arterial Highway Designation. A. San Joaquin Hills Trans Corridor ROW B. Buffer to Preserve Area - minimum 300 feet C. Top of channel D. Bench - wildlife movement requires minimum 30 foot dimension E. Soft bottom channel F. Potential bike trail location 11 Possible second alternative using vertical barrier in place of buffer zone 3-8-141 Preferred Alternative to grass lined channel at Bonita Creek ATTACHMENT *2 Paved Bike trail accomodatesl emergency vehicles 10 min. 3-8-1421 Wildlife corridor Equesti trail ' 10. min Section of crossing structure to accomodate wildlife, bike and equestrian trails at ridgeline and Bonita Creek, Location shown at A and B on Attachment 3 30' minimum Additional wildlife crossings to be located at C, D, and E of Attachment 3 Locations are conceptual. See text for details. 0 0, ATTACHMENT 3 A. Ol Sltn • .'40 r .r J. 02 . �tir'� : • wayrj •' � �` ' .. a �`:�...• ..r L' " �� ,,,r.•`; �_ Wrport _ .ten :- ' icy'�i ��► , ,, - `4-�..� - utn,�'"� !�.r -! ,,. ter` �,.►; , cI' �' ''''� }✓/o a► �� tee, 1'1v •2 "�• i� •r i 't I _ � '-r_ •� ^ . ' \, . � .� � _';�;,,� �; �• � . - •.ram_ ice. Ir�,��•, . i+', I .y- - `• .' • �� _ ' • . f _.. ••:•!r/ .• ;icy;'. - ir_ � :�UMncarpcMted' _lam\'+•`� . � � •/ • , � I { •.�- � - �. .. r V'� / • • •fit r/ •' f .4 - s PA C jr , 0 1 /2 2 LEGEND O • Interchange C '� 4 SCAT E IN Mn.FS 3-8-143I Location of Improvements in Attachments 1 and 2 ATTACHMENT 4 • Corridor ROW 0 O Catifamw �' 3-8-144 II (Sao D�.yo"Cadui wan LEGEND _ �� :-:.;• _ A�,r„r ii90 A - Dudleya Multicau4s C - Chorizanthe Staticoides Chrysacantha Area of Impact SCALE IN FEET 0 420 840 IMPACTS TO SENSITIVE RESOURCES - FIGURE 4.7.3 PACIFIC PARK DRIVE CONVENTIONAL ALTERNATIVE 4-76 ATTACHMENT 5 0 A'� �oA Corridor ROW 10, 3-8-1451 yrKitd prior 1b JinwrY r�89 _ Cal�forn �a Vn�rcatthtr LEGEND 2 - Forested Wetlands 5 - Scrub/Shrub Wetland A - Dudleya Multicaulis Areas of Impact SCALE IN FEET 0 420 840 IMPACTS TO SENSITIVE RESOURCES - FIGURE 4.7.4 EL TORO ROAD/LAGUNA CANYON ROAD CONVENTIONAL ALTERNATIVE 4-77 :ATTACHMENT 6 0 C / V c m U e m N t7 oortcawntr 3-8-146 LEGEND A - Dudleya MulticaLWS C - Chorizanthe Staticoides Chrysacantha SCALE IN FEET Area of Impact rimm""Mi o '420 640 IMPACTS TO SENSITIVE RESOURCES - FIGURE 4.7.5 SAND CANYON AVENUE CONVENTIONAL ALTERNATIVE 4-78 ATTACHMENT 7 i ._ ,Z 0.]ac O J 7•C NO Ae+••o•s •.•••ow 0 i 1 0 2 ae _ — — _ _ — ` l _ fl►X' ` `�Jit Of2JAW tH4A •s�• 9e 3-8-1471 LeastTmv" -- 4 Ua�o , -- y' carver NOW - R! ----- olac , r -- _ Diu o.iae !� 02m u me t E{iErD 'NOTE core `m,Itan of Prfeert ma Rona wr ffm t - Rrverne intermittent Streanreee 6 - Saltwater Marsh Areas of rrasct nThese scagas rMlset mm= ftm CoMmu M 2 - Fan to wettartes A - Oudrep MsticarAs 4 . Emergent Persistent Marsn H • raltorr" Gruteateher _—__ Potanul Mtrgation Site 5 - Sctuo/Shruo wetune c • ocumma Stara aoss cer"Warmr L . least Gels Vnta IMPACTS TO SENSITIVE RESOURCES - BONITA CREEK. BONITA RESERVOIR, SAN DIEGO CREEK CONVENTIONAL ALTERNATIVE 4-80 0 • SJHTC FINAL DRAFT COMMENTS BICYCLE/EQUESTRIAN/HIRING TRAILS Section 3.12: o The following trails are absent from the lists of existing and proposed bike/equestrian/hiking trails: - Pelican Hill Road Trail - Proposed Class II Trail - University Drive Trail - Existing Class II Trail o No cumulative list indicating which bicycle trails will receive crossing provisions is included. Table 4.1.A: 3-8-148 o States that no mitigation measures are required with regard13-8-149 to pedestrian, equestrian, and bicycle facilities. Section 4.13: o Page 4-116: The document states that Jamboree Road has an existing off -road trail (Class I) for which bicycle trail connections will be provided - Jamboree Road currently 3-8-150 has no bicycle trails (nor are any proposed) in the vicinity of the Corridor. The University Drive Trail and MacArthur Boulevard Trails are both referred to as Class I (off -road 3-8-151 bicycle trails); should this be Class II instead? - The document states the "project design shall provide for crossings of (equestrian and hiking) trails at their existing or master planned intersections with the proposed Corridor." - No cumulative list indicating 3-8-152 which equestrian and hiking trails will receive crossing provisions is included. o Page 4-117: - Mitigation Measure 13-1 provides crossings for planned Class I trails, making no mention of planned Class II 3-8-153 trails, or existing Class I and II trails. ATTACHMENT 8 CITY OF IRVINE BICYCLE/EQUESTRIAN TRAILS CROSSING SOMC Existing/Proposed On/Off Street Bonita Canyon Drive E-to be removed On Bonita Canyon Trail P Off Irvine Coast Trail-Bommer Cyn P Off MacArthur Boulevard E-to be removed On MacArthur Boulevard P Off Pelican Hill Road P On San Diego Creek Trail E Off Sand Canyon Avenue P On University Drive E On 3-5-154 0 • • 00 SALLY ANNE SHERIDAN. Mayor ne v^e _ _ S2cx 19575. rvine. Ca ^•a 927'3 '4) 724-6000 November 29, 1990 Mr. and Mrs. Anderson 24972 Sandridge Laguna Hills, CA 92653 Dear Mr. and Mrs. Anderson: Thank you for your letter of November 3, 1990, expressing your opposition to'the San Joaquin Hills Transportation Corridor (SJHTC). While the City of Irvine does support the corridor based on a voter response per an advisory ballot measure, we are equally concerned with the effects it will have on air, noise, wildlife, as well as many other areas. We are working hard to ensure mitigation measures are successfully achieved and support the Demand Management alternative. This alternative reduces overall grading and provides for both High Occupancy Vehicle (HOV) and future transit facilities. Thank you again, Mr. and Mrs. Anderson, for sharing your opinions with me. I know that this is not the response you had hoped to receive, but I can assure you that the City of Irvine is concerned about the quality of life for the future as well as the existing lifestyles. We are lookinei for a balance. if you have any questions regarding the environmental process, please contact Steve Letterly, TCA Manager of Environmental Impact, at 557-3298; or questions regarding the City of Irvine's concerns, Shirley Land, Principal Transportation Analyst, at 724-7340. Sincerely, z .. SALLY NNE SHERIDAN Mayor cc: Steve Letterly, TCA Manager of Environmental Impact 19 Shirley Land, Principal Transportation Analyst 3-8-155 1 _ - < - • ; 24.6045 = -ect L ^e . "-a 724.6233 PRINTED ON RECYCLED PAPER ANE \ MICDIRE M. R, EMA DIRECTOR, EMA 4 NTY O F SA TIAIC CENTER A A, CALIFORNIA ✓ 2 1 MAILING ADDRESS: P.O. BOX 4048 33 RA N G E SANTA ANA, CA 92702-4048 TELEPHONE: (714) 834-2306 ENVIRONMENTAL MANAGEMENT AGENCY FAX # 834-2395 FILE Steve Letterly NCL 90-133 Manager of Environmental Impact Transportation Corridor Agencies 345 Clinton Street Costa Mesa, CA 92626 SUBJECT: Draft EIR/EIS for the San Joaquin Hills Transportation Corridor (SJHTC) Dear M*-. Cerly: Thank you for the opportunity to review the Draft Environmental Impact Report/ Environmental Impact Statement (EIR/EIS) for the San Joaquin Hills Transportation Corridor project. We appreciate the coordination efforts extended by Caltrans and the Transportation Corridor Agencies (TCA) to date. On November 6, 1990, the Orange County Board of Supervisors adopted Draft Resolution No. 90-1403 (Attachment 1) supporting the SJHTC project and Draft EIR/EIS and directed the Environmental Management Agency (EMA) to submit any necessary technical comments on the environmental document to the TCA. These technical comments are included as Attachment 2. An executed copy of final Resolution No. 90-1403 will be forwarded to you as soon as it becomes available. We are available to meet with the TCA regarding these comments at your convenience. We look forward to future coordination on this project. If you have questions, please call Kari Rigoni at (714) 834-2109. Very truly yours, Joan S. Golding rogram alter Regional Coordination Office CH:tk 0112108560269 Attachments cc: Supervisor Vasquez, District 3 Supervisor Riley, District 5 • Ken R. Smith 5 6 7 8 9 10 1I 12� 16 17 18 19 20 21 22 23 24 25 I 26 27 28 RESOLUTION OF THE BOARD OF SUPERVISORS OF ORANGE COUNTY, CALIFORNIA November 6, 1990 On motion of Supervisor , duly seconded and carried, the following Resolution was adopted: WHEREAS, the San Joaquin Hills Transportation Corridor Agency (TCA), Caltrans, and the Federal Highway Administration have prepared a Draft Environmental Impact Report (EIR)/Environmental Impact Statement (EIS) for the San Joaquin Hills Transportation Corridor project; and WHEREAS, the County of Orange has participated in the planning process for the San Joaquin Hills Transportation Corridor project and related efforts for several years; and WHEREAS, the County of Orange has provided data to the TCA for the preparation of the Draft EIR/EIS including the San Joaquin Hills Transportation Corridor traffic projections and Section 4(f) evaluation contained therein, and WHEREAS, the County of Orange concurs with the information and conclusions presented in the regional transportation analysis contained in the Draft EIR/EIS, and WHEREAS, the park, recreation and open space areas identified in the Recreation Element of the County of Orange General Plan have been jointly planned with the San Joaquin Hills Transportation Corridor and are compatible, and WHEREAS, the County of Orange concurs with the information and findings of the impacts of the San Joaquin Hills Transportation Corridor project upon County -owned land as presented in the Section 4(f) evaluation contained within i 5 6 7 8 9 10 lI I 12 13, 14 15 16 17 18 191 201 21 22 23 24 25 26 27 28 the Drafr EIR/EIS, and WHEREAS, the TCA has provided the opportunity for public comment on the Draft EIR/EIS for the San Joaquin Hills Transportation Corridor project; NOW THEREFORE BE IT RESOLVED that this Board supports the San Joaquin :iilis Transportation Corridor project and Draft EIR/EIS including the evaluation pertaining to Department of Transportation Act Section 4(f) compliance and the regional transportation analysis contained therein. BE IT FURTHER RESOLVED that this Board supports the continued participation of the Environmental Management Agency (EMA) and other County of Orange representatives in the San Joaquin Hills Transportation Corridor planning process and hereby directs the EMA to provide additional technical comments to the Transportation Corridor Agencies, Caltrans, and the Federal Highway Administration on the content of the proposed San Joaquin Hills Transportation Corridor Draft EIR/EIS. 3-9-1 2 3 4 5 6 7 8 9 10 11' 12 t 13 14�15 16 17 18 19 20 21, 22- 23 24 25 26 27 28 Chairman -of the Board of Supervisors SIGNED AND CERTIFIED THAT A COPY OF THIS DOCUMENT HAS BEEN DELIVERED TO THE CHAIRMAN OF THE BOARD LINDA D. RUTH Clerk of the Board of Supervisors County of Orange, California AYES: SUPERVISORS NOES: SUPERVISORS ABSENT: SUPERVISORS STATE OF CALIFORNIA ) ) ss. COUNTY OF ORANGE ) I, LINDA D. RUTH, Clerk of the Board of Supervisors of Orange County, California, hereby certify that the above and foregoing Resolution was duly and regularly adopted by the said Board at a regular meeting thereof held on the day of , 19and passed by a vote of said Board members present. IN WITNESS WHEREOF, I have hereunto set my hand and seal this day of 19 MG:tk 0102607284073 LINDA D. RUTH Clerk of the Board of Supervisors of Orange County, California 0 (0 9 NCL 90-133 San Joaquin Hills Transportation Corridor Technical Comments ENVIRONMENTAL RESOURCES 1. Bonita Creek Impacts and Mitigations The analysis concerning impacts to Bonita Creek, which appears in a number of EIR/EIS sections, does not appear to be consistent. The paragraph on page 4-65 beginning with "Bonita Creek/San Diego Creek/San Joaquin Marsh/Upper Newport Bay" states that the project will result "in the loss of the entire wetland habitat value of the (Bonita) Creek." On page 4-20, the EIR/EIS states that this loss occurs along "approximately 8,400 linear feet of Bonita Creek." On page 4-81, the impacts are quantified as the loss of "approximately .3 acre of riverine intermittent streambed, .8 acre of forested wetlands, and .1 acre scrub/shrub wetlands." This amounts to 1.2 acres of habitat. This loss of habitat along Bonita Creek should be accurately quantified and more clearly stated in the EIR/EIS. In addition, the subsection titled "Mitigation Measures" beginning on page 4-84 in the EIR/EIS does not contain the measures recommended for Bonita Canyon in Technical Report No. 5 in the EIR/EIS Appendix. Specifically, the last paragraph on page 76 states that, for Bonita Canyon, "suitable mitigation would be to restore the channel to a natural condition and allow native wetland plants to revegetate the channel. In addition, a revegetation program to replace native wetland plants, including sycamore and willow trees in the channel, should be considered." This vegetation program should also include appropriate understory plantings. Also, the EIR/EIS should include an explanation for not implementing these mitigation measures in project design. 2. Wildlife Movement Impacts and Mitigations The analysis throughout a number of EIR/EIS sections does not appear to be consistent. In Section 4.6 titled "Biological Resources" beginning on page 4-65, the text discusses how a subcontractor was asked to look at three possible wildlife crossings for design feasibility. The text does not discuss, however, why a crossing between Bommer Canyon on the north and Muddy Canyon, Los Trancos Canyon, and the tributary to Moro Canyon on the south (see Figure 3.6.6 on page 3-47 and Figure 3.3.1 on page 3-8) was not considered. Since only one of the three "subcontractor" crossings was found feasible, it now seems reasonable to formally consider this additional option. 3-9-2 3-9-3 3-9-4 In the CDMG report (Technical Memorandum 3-20 included in the EIR/EIS Appendix Technical Report No. 5), CDMG makes a number of qualitative biological judgments that need expanded discussion, such as: "the wildlife may be too frightened" to use one Wood Canyon alternative; "it is 3-9-5 questionable that wildlife will even enter into this area at all"; and "the wildlife may not use the (Sycamore Hills) crossings since a major portion of it is exposed and is too close to (the Corridor and/or Laguna - 1 - Canyon Road)." The qualifications of the subcontractor CDMG to judge the 3-9-5 adequacy of various wildlife crossings should be provided and/or references cited. Finally, additional discussion is needed before Mitigation 6-16 on EIR/EIS page 4-72 can be deemed the most appropriate wildlife movement mitigation. First, the additional option presented above should be considered. Second, evidence that any particular crossing design will actually be used and by which species should be presented. Results of completed 3-9-6 undercrossing wildlife usage studies elsewhere in the Southern California Coastal area should be cited. Third, the potential impact issues of glare light and noise in the immediate vicinity of a structure designed for furtive animal movement should be addressed, with appropriate mitigations proposed. 3. Sensitive Species Impacts and Mitigations The analysis throughout a number of EIR/EIS sections does not appear to b consistent. Specific impacts upon the many -stemmed dudleya, Orange Count Turkish rugging, San Diego horned lizard, Orange -throated whiptail, California gnatcatcher, Cactus wren, and a number of raptors were described in the EIR/EIS (pages 3-39 through 3-43, 4-64, 4-76 through 4-70, and 4-72). However, specific mitigation measures for these impacts are offered only for the many -stemmed dudleya and Orange County Turkish rugging (Measure 6-12 on page 4-71). This is despite the recommendation in the Biologic Assessment, EIR/EIS Appendix Technical Report No. 5 on page 74, for "replacement of roosting sites removed by the Corridor away from the flow of traffic." Further, in view of the discussion on page 3-42 of the extensive mitigations that will become necessary should the California gnatcatcher become Federally protected, specific mitigation measures should be included in the EIR/EIS in preparation for such an eventuality, given the time frame for this project. 3-9-7 • Finally, the EIR being prepared for the Foothill Transportation Corridor is comparable to this EIR/EIS. As such, specific mitigation measures proposed in that EIR for impacts upon the California gnatcatcher and San Diego cactus wren (August 1990 Foothill Corridor Draft EIR Measures 23 and 3-9-8 26), San Diego horned lizard and Orange -throated whiptail (Foothill Measure 23), and raptors (Foothill Measure 28) should also be included in this SJHTC EIR/EIS. 4. Resource Category Habitats Impacts and Mitigations The analysis throughout a number of EIR/EIS sections does not appear to be consistent. Page 3-36 states that coastal sage scrub -mix is a habitat for which the mitigation goals should be "no net loss of habitat value, while minimizing the loss of in -kind habitat value." Page 4-63 states that 3-9-9/10 153-156 acres of this habitat would be lost. Page 4-70 states that complete mitigation of the habitat impacted by the Corridor through revegetation (replacement after construction) would not be possible. However, page 74 of the EIR/EIS Appendix Technical Report No. 5 recommends that where habitat replacement after construction "is not practicable, - 2 - 0 compensate for loss by the enhancement of the remaining communities on -site, pay a fee per acre lost, and preserve/restore comparable vegetation community off -site." Therefore, it is recommended that Measure 6-13, which describes only revegetation, be expanded to include the mitigation provided on page the Appendix Technical Report No. 5. 3-7-9/10 the 74 of In addition, it is recommended that TCA utilize the August 1990 Foothill Corridor EIR as a reference, where Mitigation Measure 23 specifically implements the "no net loss of habitat value" that was stated to be the goal for the San Joaquin Hills Transportation Ccrridor cn EIR/EIS page 3-36. It should be noted that this mitigation measure was considered reasonable and feasible for the Foothill Corridor and recommended for the San Joaquin Corridor EIR/EIS in the Appendix Technical Report 5, page 74. 3-9-11 FLOOD The following changes in 100-year peak discharges at the SJHTC should be made in Technical Memorandum TM 3-16, SJHTC Conceptual Drainage Study, dated July, 1990, in order to agree with the discharges contained in a letter from H.I. Nakasone, Manager, Flood Program Division to Jerry Bennett, Chief Engineer, Transportation Corridor Agencies dated March 14, 1990. 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 3-9-12 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 In addition, the discharge for Bonita Canyon Channel at the SJHTC found in the last paragraph of page 18, should be changed from 2,200 cfs to 2,368 cfs in order to agree with the discharge found in Table 2 on page 11. OPEN SPACE/RECREATION 1. An overall mitigation measure is recommended consisting of a comprehensive corridor landscaping program utilizing native trees and shrubs in natural open space areas and historically consistent exotic tree species in urban areas to enhance the overall aesthetic character of the roadway and 3-9-13 improve the compatibility with adjacent land uses. There may be areas where sound walls are appropriate in conjunction with this landscape program. 2. Further mitigation may be appropriate in the form of bridging canyons and 3-9-14 water courses to foster continued wildlife circulation and minimize negative visual impacts. 3. Additional mitigation may be afforded thi'o'ugh TCA cost -sharing in open 3-9-15 space acquisition efforts in Laguna Canyon. 4. We believe the best way to detail these thoughts is for your office to initiate a meeting for planning coordination on these matters. 3-9-16 - 3 - TRANSPORTATION 1. The "Project Objectives and Expected Benefits" section of the EIR/EIS (page 1-10) should indicate that the section titled "Traffic and Circulation" beginning on page 5-1 contains additional discussion in 3-9-17 support of the circulation objectives of the project. 2. The EIR/EIS focuses on Y2010 traffic conditions with and without the Corridor and provides only cursory discussion of the opening day (Y1995) traffic conditions. Yet, in its discussion of the benefits of the Corridor, the EIR/EIS gives the impression that these benefits will be realized once the Corridor is constructed (Y1995). This should be clarified in the EIR/EIS in light of the fact that changes in interchange 3-9-18 connection and lane configuration will occur between opening day and Y2010. Therefore, we feel that an additional section addressing the opening day configuration of the Corridor, interchange/access and interim impacts, and benefits associated with the phasing of the Corridor should be included in the EIR/EIS. 3. The EIR/EIS indicates that traffic on some segments of arterial highways will increase in the future. It will be useful to discuss whether these increases are associated with construction of the Corridor and whether 3-9-19 these increases will result in changes in levels of service (LOS) on these highways. This discussion is particularly applicable on facilities which are expected to be upgraded from existing conditions. 4. The analysis should also include a discussion on how the project objectives will be met through the project phasing process. 3-9-20 WASTE MANAGEMENT The County of Orange has two concerns that should be addressed in the EIR/EIS: 1. The proposed interchanges shown on Figure 2.2 and listed on Table 2.2.A do not include Coyote Canyon Road. The EIR/EIS indicates that a portion of the Pelican Hill Road (PHR), approximately Station 1030 to Station 1085, will ultimately be part of the SJHTC. Upon completion of PHR, the only access to the Coyote Canyon Sanitary Landfill is off PHR at Coyote Canyon Road (the current landfill access road), located approximately at Station 1074 of Ramp FR-4 of the SJHTC plan. However, the EIR/EIS does not show 3-9-21 any provisions for future access to the landfill at this location. The loss of the access to Coyote Canyon Sanitary Landfill will have a substantial impact on the County's landfill closure and post -closure activities. The County is responsible for maintaining the landfill for at least thirty years after all the required closure improvements are constructed. The construction is anticipated to be completed in May, 1993. Although the ultimate development of the site has not been determined, planning includes such facilities as a park or golf course. The facilities under consideration will require permanent access. 2. The EIR/EIS should include plans for refuse reduction and recycling during and after the construction of the project. The California Integrated Waste Management Act of 1989 (AB 939-Sher) required the County to divert 3-9-22 25% of the solid waste from its landfills by January 1, 1995, and 50% by tl - 4 - C 0 • 0 • the year 2000. To meet these requirements, the amount of waste generated by the proposed project must be minimized. The project should include all the current technology available for minimizing or recycling waste 3-7-22 products. Additionally, special landscape treatment to minimize the amount of yard trimmings and waste should be used. WATER RESOURCES The following revisions are recommended: 1. Page 3-9 - The first paragraph states that "Flood waters are generally of good quality except for sediment...." In contrast, page 4-28 states that "...actual impacts to the Ecological Reserve are dependent upon dynamic storm factors such as intensity and duration. The more significant the storm event, the more diluted the pollutant concentration will be and the more rapidly the run-off is flushed downstream through the drainages." While flood waters are generally of good quality in major flooding events, "first flush" contaminants in typical storm events have been identified as a significant concern by EPA. Additionally, sediment transport is elevated during significant storm events due to erosion, even though other pollutants are generally diluted. These statements confuse the understanding of the issues to be addressed in the water quality section and should be amended. 2. Page 4-3 - In the first paragraph under Water Resources, "mitigation measure 3-8" should be amended to read "mitigation measure 3-9." 3. Pages 4-4 and 4-13, and page 12 of the Water Quality Analysis Report - These pages all contain statements that water quality impacts will be mitigated to levels below significance. This contradicts page 10-1 of the EIR/EIS which states that "the project could potentially contribute incrementally to water quality impacts...." On page 4-4, the third paragraph under the column heading titled "Level of Significance After Mitigation" should be amended to read "Project impacts partially mitigated." Page 12 of the Water Quality Analysis Report should be amended to read "partially mitigated" instead of "below significant levels." 3-9-23 13-9- 24 3-9-25 4. Page 4-31 - A Best Management Practices Plan (BMP) should be submitted for the approval of the County of Orange, EMA/Environmental Resources Division prior to construction. This is in lieu of the inclusion of the BMPs in 3-9-26 the Run-off Management Plan. The Plan should include the exact locations and engineering details of the proposed pollution source control measures as well as the measures proposed to ensure that maintenance of these structures is performed in a timely manner. This plan should include BMPsl3-9-27 to be implemented at the park and ride facilities as well as in the Corridor itself. The EIR/EIS should include -a disclosure of the general types of BMPs that will be used at various sites and the location of these structures. Certain -structural BMPs may`in themselves have an impact on 3-9-28 the environment, thus requiring public disclosure in the EIR/EIS. 5. Page 12, Water Quality Analysis Report - Data is provided for annual pollutant loads of several creeks that would be impacted by the 13-9-29 transportation corridor. This data should be clarified because - 5 - 6. interactions occur between several of the non-specific parameters listed (e.g. the interaction of chemical oxygen demand with oil and grease), 3-7-29 which give the impression of greater pollutant loadings than actually exist. Page 9, Water Quality Analysis Report be added as a beneficial use for San Santa Ana Region of the Water Quality reflect this. MG:tkPA02-311(0325) 0112613505911 - 6 - - "Body contact recreation" should Diego Creek. The Basin Plan for the 3-9-30 Control Board has been amended to • 0 11 i(- r�rrf C NATURAL HISTORY MUSEUM 26 November 1990 Mr. Steve Letterly Manager of Environmental Impact Transportation Corridor Agencies 345 Clinton Street Costa Mesa, CA 92626 Dear Mr. Letterly: of Los Angeles County VERTEBRATE PALEONTOLOGY SECTION Telephone: (213) 744-3329 FAX: (213) 746-7431 goo Exposition Boulevard Los Angeles, California 90007 Subject: San Joaquin Hills Transportation Corridor EIR/EIS. I am quite concerned by what I view as a lack of proper mitigation plans for paleontological resources in the above -cited EIR-EIS. Many studies have demonstrated and\or predicted the existence of massive fossil deposits in the right-of-way. I predict monumental paleontological salvage problems and loss and destruction of many valuable fossil specimens unless the mitigation plan is made more precise. The mitigation plans as written are simply too general and vague to provide proper management of the resource. Item 11-3 calls for "preconstruction salvage of any exposed paleontological resources", and a follow-up report on survey methodology. The methodology for this work should be established Sand spelled out by the TCA in the EIR, not checked after the survey and salvage. All pre-existing localities should be recorded in the advance environmental study, not left to chance once the project is begun. Proper preconstruction salvage and survey could take several person years to complete, and cannot be handled by one person in a few days or even weeks. What is the source of funding'' for this pre -construction survey and salvage, for the necessary staff, supplies, equipment, and excavation machinery? Where will the voucher specimens be curated? Who will clean them and identify them to prepare the report to the TCA? Item 11-4 specifies retaining a County certified paleontologist to be present at "the pregrading conference" and to establish procedures for work. First, as I understand it, there will be many pregrading conferences for the different phases of grading, some linked with various private developments that will contribute right-of-way to the project. How will these projects interrelate with the whole, how will uniform mitigation measures be enforced, and who will fund the paleontologic work? Second, procedures for the work should be set now and follow adopted standards of involved city, county, state and federal agencies, not set after the start of work. 3-10-1 3-10-2 3-10-3 Further under item 11-4, the text should not state that the paleontologist should be notified if fossils are found; if the job 3-10-4 is being done correctly, the paleontological crew will be present at all times, monitoring all grading, and will find the fossils George C. Page Museum, Hancock. Park, 5801 Wilshire Boulevard. Los Angeles, California 9oo36, (213) 857-6311 William S. Hart Museum, Hart Park, 24151 San Fernando Road, Newhall. California 91321, (805) 254-4584 first. When fossils are found, what will be the mechanism and authority for halting of construction and carrying out the salvage work? How will the construction contracts be written to accomodate the salvage time? Who will determine the significance of fossils 3-10-4 discovered? What is the mechanism for collecting from finished cuts as erosion follows, and before completion of the project? Weathering of fresh cuts often yields important specimens. The EIR/EIS should include at least the same provisions as are required by the Federal government, the state of California, and the County of Orange. It should also address the findings and recommendations of the Orange County Master EIR. What will be the ownership of the specimens salvaged? They should all be deposited in a permanent scientific institution, which follows the conventions of the American Association of Museums. It must be remembered that collecting is just the start of paleontological mitigation, not the end. Who will arrange, pay for, and oversee their transportation, storage, preparation, and curation? 3-10-5 Item 11-5, assistance to the Natural History Foundation for onel year to obtain a site, does not satisfy the needs raised in the 3-10-6 previous paragraph. Basically, what the EIR/EIS fails to convey is that the right-of- way passes through some of the richest fossil -bearing terrain in the world, will impact probably thousands of specimens, and that the proper protection of these will require many persons, many years, much money, and lots of excavation and use of heavy equipment, plus the follow-up museum work. I speak from 18 years' experience doing just this on relatively small projects in Orange County. The massiveness of this task for the Transportation Corridor must not be underestimated. Sincerely, lqlot�� Lawrence G. Barnes Curator and Section Head 3-10-7 0 • saaalesack aaea cooRbi nazi nc council inc (714) 830 - 8316 MEETING DATE 19�_jj�g0 Transportation Corridor Agency Attn: Steve Letterly, Manager 345 Clinton St. Costa Mesa, Ca. 92626 LOG NO. 4853 THE SADDLEBACK AREA COORDINATING COUNCIL PLANNING REVIEW COMMITTEE HAS REVIEWED: San Joaquin Hills Transportation Corridor THE SADDLEBACK AREA COORDINATING COUNCIL CONCURS WITH THE APPLICATION THE SADDLEBACK AREA COORDINATING COUNCIL CONCURS WITH THE APPLICATION L_J ON THE CONDITION THAT THE FOLLOWING ITEMS ARE ALTERED OR CORRECTED AS INDICATED. i— —t THE SADDLEBACK AREA COORDINATING COUNCIL RECOMMENDS DISAPPROVAL OF L_J THE APPLICATION FOR THE REASON (s) LISTED BELOW. THE SADDLEBACK AREA COORDINATING COUNCIL HAS NO COMMENT ON THE APPLICATION BECAUSE IT IS OUTSIDE THE AREA OTHER SEE ATTACHED LETTER THANK YOU FOR YOUR COOPERATION. cc: Supervisor Riley Planning Commission PRESIDENT IGLESIA PARK COMMUNITY CENTER, 24671 VIA IGLESIA, LAGUNA HILLS] CALIFORNIA 92653 • saOOLGBAck APeA cooaalnati nc counciL inc (714) 83 0 - 8316 San Jouquin Hills Transpotation Corridor Agency 12/20/90 345 Clinton Street Costa Mesa, Ca. 92626 Attn: Steve Letterly Dear Sir, The Saddleback Area Coordinating Council supports the building of the San Joaquin Hills Transportation Corridor. It is a vital link between the coastal cities of Southern Orange County. This Transportation Corridor is long overdue and construction of it needs to be expiditated to relieve Orange County of daily traffic congestion with its resultant air pollution. SACC specifically endorses the Full -Width Conventional Build Alternative as shown in the Transportation Corridor Agencies EIR/EIS 1. Additionally SACC supports the I-5 connection alignment #t2 as shown in figure 2.13. This alignment will greatly enhance the traffic flow around the interchange of 1-5 and SR-73. It will decrease the traffic build-up on residential streets in the surrounding neighborhoods. The downside of this alignment is that it makes the street Camino Capistrano an orphan for access. Discussions with the neighboring . cities should be entered into that l:4:11 provide new access to the businesses along Camino Capistrano. As for the idea of reversible HOV medians, SACC finds the future for Orange County and mass transit will be in a monorail of some sort. The median area of the Conventional Build Alternative should be reserved for this type of travel. It should also be built to the strength standards needed for a high-speed monorail service. This will provide an alternative for passenger vehicles that can be linked -up to other monorail projects now being designed for Central and Northern Orange County. Sincerely, Saddleback Area Coordinating Council 3-11-1 3-11-2 3-11-3 COMMENT CARD NAME Y 3ra hi q Vd N DATE /o b ADDRESS 4 Cif vS )7w / /t AFFILIATION ly✓f t sso CITY, ZIP ✓vi`1;e 9L1 / Please add my name to your mailing list COMMENTS CONTINUED .5" pl� ."-4 0-0 �'A c- ltx7-% �ore-------------------------------- Please Print Clearly: COMMENTCARD NAME�IoIZMA0 6eo!;s /�''y�Tt DATE /0 f % 9z> ADDRESS 99 l gA L BQ1 A - AFFILIATION b+"IV CITY, ZIP �C-{-q XV R&f=-If 9L6�� PH. # (Optional) 4-k)9 - I /�-Z �w Please add my name to your mailing list ✓YES NO 66, Z-o333 COMMENT: 14w w linvv'T 17o/rI CT iq r Glo�l� STvbV o T- TlA—:-- Or 14 L, L -1 K/,Z;E f RL-'�, C 0-s c-'�) 7-,b L- P-oAb S? COMMENTS CONTINUED 1 //lE CyIZte1bo12 /S 11 �l o X HvsT lac • 4-2-1 Poste' i ase Print Clearly: J COMMENT CARD I ME DATE ►DRESS �2t-ye / rlivAFFILIATION TUNA &wwD,,v rev. rY, zip, y�6sl PH. # (Optional) !ase add my name to your mailing list YES NO Ow,vt,es WMENT:_, 4-3-1 Wes. COMMENTS CONTINUED I. tfId / • _ L / // _ . . .7 / �. . 0 LIZ. 7 f4 / 4-j-"n/S AAla w '//tom N 4-3-1 arc 4-3-2 �d 4-3-3 4 4-3-5 le,wellcr O4x'A/. Please Print Clearly: - COMMENT CARD NAMESL , 69��� DATE 1`71117190 ADDRESSa Ty / At —FILIATION. r CITY, ZIP e-4 PH. # (Optional) Please add my name to your mailing list YES NO COMMENT:. l�tJ� (I R Y� � /vC, gai (Continue comments on back of this page. To submit, please fold page in half, secure with tape, and mail to the address below.) c� 4-4-1 Please note: Comments must be returned to the Transportation Corridor Agencies' office by 5:00 P.M. on November 15, 1990 Told h e Stamp 14-4-2 TRANSPORTATION CORRIDOR AGENCIES 345 CLINTON STREET COSTA MESA, CA 92626 ATTN. SAN JOAQUIN HILLS EIR/EIS COMMENTS COMMENTS CONTINUED U IV 4-4-2 4-4-3 4-4-5 4-4-6 4-4-7 I 0 V 0 0 Pease Print Clearly: COMMENT CARD NAME , I NP A QUSh4(h)C'- DATE 1 7 ho ADDRESS AFFILIATION CITY, ZIP %ate. &Ctr;,% CA PH. # (Optional) Please add my name to your mailing list rES NO COMMENT: 4 S 'ih-F t 31 1 h 45 I iv C4A— S Cal % K 3 (Continue commenfs on back of this page. To submit, please fold page in half, secure with tape, and mail to the address below.) Please note: Comments must be returned to the Transportation Corridor Agencies' office by 5:00 P.M. on November 15, 1990 TRANSPORTATION CORRIDOR AGENCIES 345 CLINTON STREET COSTA MESA, CA 92626 ATTN. SAN JOAQUIN HILLS EIR/EIS COMMENTS Stamp 4-5-1 COMMENTS CONTINUED 41 - .'A % I 4-5-1 4-5-5 f 0 0 0 Please Print clearly: COMMENT CARD NAME 1 ,11VI)A zqUs:�///v 67— DATE / / 9d ADDRESS 77 S Cm---t— �� AFFILIATION CITY, ZIP ZAQwAAA 86�\� PH. # (Optional) Please add my name to your mailing list YES NO COMMENT: T-hf 'It t�L S7fw: 0 (Continue comments on back of this page. To submit, please fold page in half, secure with tape, and mail to the address below.) COMMENTS CONTINUED cr4" 14.5.6 Z • • Spyglass Hill Community Association November 1, 1990 Mr. Steven Leterly Manager, Environmental Impact Transportation Corridor Agencies 345 Clinton Street Costa Mesa, CA 92626 Dear Mr. Leterly: The Board of the Spyglass Hill Community Association would like to take strong exception to the Environmental Impact Report for the San Joaquin Hills Transportation Corridor for the following reasons: Installation of two toll booths will impact upon the Pelican Hills bypass 4-6-1 route constructed by the City of Newport. There is a failure to comply with the wishes of the City of Newport. The City has assumed the position that the extension of San Joaquin Hills Road 4-6-2 only be done in the future only when LOCAL TRAFFIC DEMANDS THIS EXTENSION. No such demand has been demonstrated. We feel that the San Joaquin Hills Road intersection with the Corridor 4-6-3 should be significant enough to warrant a separate EIR report. To amplify these exceptions: The City of Newport has negotiated with the local people in the matter of the constriction of a bypass route to carry traffic from below (Southeast of) Old Corona del Mar to the 405-73-Airport area and back. The route clearly was needed to alleviate heavy traffic densities. The City also added two feeder 4-6-4 roads with the creation of San Joaquin Hills Road to Pelican Hill Road and the extension of Ford Road to the bypass. This alignment of roads was not intended to divert traffic into the city, but rather help the bypass concept. P.O. BOX 4708 0 IRVINE, CA 92716 0 (714) 250-1876 Mr. Steven Leterly November 1, 1990 Page 2 The installation of two toll booths in the area (at Sand Canyon and Pelican Hills Road on and off ramp. The bypass route is to be usurped by the San Joaquin Corridor will cause this newly -constructed route to be abandoned by traffic. This traffic will divert from the bypass route into the City of 4-6-4 Newport along San Joaquin Hills Road and Ford Road onto MacArthur Boulevard to avoid Tolls. In both instances one can SEE VERY HEAVY INCREASES ALONG THESE LOCAL ROADS which was never intended. This matter must be addressed. - The Ford Road interchange is to be a matter for a separate EIR report. (Page 57, Chapter 2) the intersection of San Joaquin Hills Road -with the Corridor is as mentioned contrary to the position agreed to by compromise between Spyglass Hill Community Association and the City of Newport Beach. The matter is important enough to demand further study. One cannot tolerate a simple assumption that these interchanges will exist (Chapter 2, page 50) when our thinking is to the contrary. Sincerely, SPYGLASS HILL COMMUNITY ASSOCIATION Board of Directors cc: Mayor Ruth Ellen Plummer Councilman Donald Strauss Councilman Clarence Turner Councilman Phil Sansone Councilman John Cox, Jr. Councilwoman Evelyn Hart Councilwoman Jean Watt 4-6-5 0 0 SIERRA CLUB - ANGELES CHAPTER ! �Ai�'•.: % FAT -_ter -�..,� �... * nC h � c t� � r **'•l1Q1Lti A�46�l1 S. 1 �� } '}ount Cur,,e Ave. Altaderia, Cy 91001 November 9, 1990 Steve Letterl;: , Manager Environmental Impact Transp:oi•tation Corridor :agencies 3-15 Clinton Street Costa �}esa, C.A q1626 Dra_ }r. Letterly: Re: San Joaquin Hills Corridor. 1;F have read the Draft Environmental Impact Report/Statement with interest. We have several comments which we wish to offer. Tlir DEIF makes the assertion (see par -as. 2, 3 and 4 on p. S- i) th, il. the project is intended to relieve congestion on existing I-5, I-403 and SR-l. This is transparently false. 4-7-1 r =r' fr•onl relieving congestion, building this and its two projects uill hate the effect of inducing far mc,i,: cu>i-estiori than noc; exists. The real purpose of the three c•.:rr•idors is to permit rapid development of about 100,000 acres n t}ie -southeast half of the County. congestion which liow plagues commuters in Orange County not on the f r•eewa� s which parallel this j)rojec t . The principal -_ongest ion is on the I the I-405 ai,d on the SR-1 `upstream' , Wesr -nun northwest of this area, through the cities of Santa Ana and G•-trden Gro\e. Both t}fie I-5 and the I-405 have been notor•i- 4-7-2 �-;11`-•1`' -ridloc-ked in these areas for the past five years. Calti-ans has e�,-haustively surzeyed this phenomenon; the m:_ittEr is thoroughly documented. A well-known stud, conducted in aL,^--} e.stall.:.1 fished that the I-5 would have to be enlarged to 14 lanes to accommodate anticipated traffic. The development of the southeast half of the Count- will exacerbate this congestion. I-5 and I-405, in those sections parallel to this project, a: e not now congested. The DEIR makes an attempt to ,justify its statement on congestion by data generated by mathematical models which attempt to establish that there will be congestion on I-5 4-7-3 and on I-405 through this area at some future time. Aside from other considerations, these models are far from credible; their usefulness, aside from their role as academic curiosities, is limited solely to providing an impressive array of `data' for documents such as this DEIR. The predictable effect of building this project will be to 4-7-4 add more inhabitants; more vehicles and more trips per vehicle to this area. Thus, there will be much more congestion over much larger areas of Orange County. In short, the statement that this project is being under- 4-7-5 taken to relieve congestion is grossly misleading; it will have precisely the opposite effect. The DEIR makes the statement that construction of the project 4-7-6 will have a `positive net impact to air quality-' ( see Table A, and other). Evidently this statement is based on the canard much - Recycled ��Paper 4-7-6 4-7-7 �,r d in highway- EIR/' !Ss that, by reducing cc11gestior1, ail- poliu- iaii will be decreased. }-,ecent studies demonstrate con-,"1nclnE:ly that addin highway :__tj,ri,,-ty, ii, fact, increases both congestion and air pollution:. There are two reasons for this: • Even if we ignore the new development which the project is designed to make possible, additional highway- capa- city, because of latent demand, generates more trips, mcz•e congestion. Experience demonstrates that conges- tion returns at much higher levels of VMT. The net effect is to generate more air pollution. The highway is intended to open up acreage which will accommodate one million more inhabitants. They will bi-ii,c with them 750,000 additional automotive vehicles. These vehicles, in addition to the phenomenon mentioned -x-o,, e, will sul_,stanti ally add to existing levels of c::n_;r�tion and air pollution. 11,e now (_:n;;: two practical constraints on automobile and t_-uch the cost of fuel (almost ne ligible compared to 'sunk' :+r,d s,,}_:sidiztd costs) and congestion. New highway capacity- re- leases this. 'latent' demand. It also generates 'future latent' demand (the demand foi, trips due to building subdivisions on the of the urban area). This project is unique in that it _;F�,ir�rat.e s moth types of 'latent' demand at one and the same time. The statement regarding air pollution is, therefore, inde- fe_isib! tom. One of the important features of the project is the manner of its 4-7-8 finr�ncir,g and the fact that it will be a toll highway. We have ?oo}.cd, in -rain, for a description in the DEIR of these matters. For instance, we have heard that, although it will be a toll the tolls are not intended to cover the full cost of the 1.:ro,ject . Evidently, the right-of-way- will be 'donated' by the developers. There is a hint that the federal government has been maneuvered into paying up to 35% of the cost (see paras. 3 and 4, p. 1-2). Furthermore, it seems clear that these contributions apply only to the costs of the right-of-way and the construction con- 4-7-9 tracts. The cost of policing and of maintaining the highway- will be borne by the property taxpayers of the County. In other words, the project will be funded, at least in part, by public funds, including scarce property tax yields. Its purpose is to accelerate growth in Orange County. The production of more air pollutants would be inevitable if this project were to be constructed. It is shocking that Orange County taxpayers should be forced to participate, without their consent, in the funding of a pro- ject intended to generate business for private developers and which is patently contrary to the public interest. • Igor does the DEIR tell us who will be responsible for paying 4-7-10 off the bonded indebtness in the event that toll collections are 4-7-101= ,=lif'I li leI"lt . 4-7-11 The Fede l'ai District Coul•t of Sail : rand zco 11Lts r'ecenti heal-d a .'Cise Which has signific'urlt implications for this I)rctJect: Siel_r�� Liu_b -, .:,icr.ov,olitan_Trans,Lortation Cullmiission et al. TLe ^ITC case centers or, the obligation of rJPGs to assess their RTPs and TIFs annually for conformance with their local Air Quality Plan. The court found that th(, defendant had not made an adequate assessment. The SCAQ'-ID air basin has existing conditions, of course, i,hich are far horse than those in the MTC. We believe that SLAG,. if it were to make a realistic assessment regarding this project, 4-7-12 ;•:oulu discover that its air pollution effects would be unaccept- ablt:., beii,; directly contrary to the intent of the air Quaiity Y1 • 111 . I iti,_t` :ns of this UEIR are, charitable", disingenuous. The it;. ui t1•purpose of the pro„ect is obvious; t1,e impacts of 4-7-13 -i' i��� thr ;",roject arc• also obvious, despite misleading des- ip+..ions tl� E:ETR. We ask that t]"ie UEIR be r��ti:ritter, to (LI 1,i1,LI ),e piu.jc•ct's impacts and purposes more realistically. doh uments are her•eb: - incorporated in the record by t'E.1'rL"E': "The Air Pollution Transportation Linkage ", Cal i f o rn i s A i r Re - sources Board "Regional Growth Management Plan ", SCAG • "Regional Mobility Plan", SCAG • "Air Quality Management Plan", SCAQ�M • California Public Resources Code, Section 21104(a) Siricerely, Staril.ey Hart, Chairman Transportation Committee 0 • '= SIERRA CLUB - ANGELES CHAPTER 20 3104 Mount Curve Ave. Altadena, CA 91001 November 20, 1990 Steve Letterly, *tanager Environmental Impact Transportations Corridor Agencies 345 Clinton Street Costa Mesa, CA 92626 Dear �; •. Letterly: Re: San Joaquin Hills Corridor We wish to amend our letter of November 9th to incorporate, in addition, the following document in the record by reference: 4-7-14 1. "Cities and Automobile Dependence: A Sourcebook ", Newman and Kenworthy, Gower Technical, 1989 Sincere,y, S anlet Hart, Chairman Transportation Committee Recycled I$ Paper ORANGE COUNTY RECREATIONAL TRAILS COMMITTEE RIDING, HIKING, BIKING 25901 Rich Springs Circle Laguna Hills, CA 92653 Marlene P. Sandler— President 714-643-0396 George A. McLean--Vice-President 714-768-8352 Ted F. Martin --Treasurer 714-770-3012 M. Lauren Ficaro--Legislative Resource Adviser 714-997-4349 Ilae Byrnes --State Legislative Adviser 714-493-4222 Ute Wirth --County Trail Research 714-839-9419 Saddleback Area Co-ordinating Council --Sponsor November 9, 1990 Mr. Steve Letterly Spn Joaquin H"I' ls, Tra..sportatic:: Corr_doz r _r.c_, 345 Clinton Street Costa Mesa, CA 92626 Dear Mr. Letterly: The Orange County Recreational Trails Committee has reviewed the Environmental Impact Report on the San Joaquin Corridor. We would like to express our concerns about the need for technical 4.8-1 information describing recreational trails and crossings in the area of the corridor. The details should be called out before any construction is done. Therefore, we would like to make the following recommendations for constructing trails: 1. The grading for the trails should be included in the mass 4-8-2 as well as the details grading plan. For example: Exactly where are the crossings and how will they be affected. 2. All trails should be a -minimum of 10 feet wide, with an 4-8-3 easement of 20 feet. 3. Fencing where appropriate should be installed to separate 4-8-4 trails from roadway. 4. When the trails are next to existing roads, the trail14-8-5 should be set up as far away from the traffic flow as possible. 5. When the trails are on their own access, there should beI4-8-6 as much separation between user groups as possible. 6. When there are -trail crossings at entrances or exits to I4-8-7 the corridor, they should be signed and signalized. 7. The push buttons for the WALK signals should be set back from the corner and should be approximately 5 feet high. They 4-8-8 should provide a longer walk signal than for regular pedestrian traffic. 8. The standing area at crossings should be 18 feet square 4-8-9 • minimum and the space should be other than smooth concrete. 9. Irrigation runoff on the trail should be held to a I 4-8-10 minimum. 10. Bridge crossings should have guard rails at least 5 feetl4-8-11 high and the pathway at least 8 feet wide. 11. Undercrossings should be sufficiently removed from bridges and should take into account multiple use. The optimum height of bridges is 15 feet. 14-8-12 The above recommendations should apply to all trails within the area of the Corridor. Another matter of concern is that the recreational trails will serve as wildlife corridors. Because the San Joaquin Corridor crosses so many trails, a separate details section should be done 4-8-13 and we suggest steps be taken to produce a document of detail on the trails and wildlife corridors and the mixing of the two in the area of the corridor. We would also like to point out the omission of two trails in the lists: 1. The Aliso Creek Trail is missing from the list of bicycle trails page 3-65 and the list of equestrian and hiking trails page 3-62 which intersect with the corridor. Figure J25 does show a projected view of the Aliso Creek Trail with the 4-8-14 • corridor passing over it. 2. The Niguel trail is missing from the list of equestrian and hiking trails page 3-62. This trail is shown on J-22 of the report. Both of these trails should be included on the lists. The following is from the report page 3-64: Private Trails. The Nellie Gail Riding and Hiking Trail is currently constructed along the west side of Greenfield Drive south of Hidden Trail Road to the location of the proposed Corridor crossing. Additional portions of the trail separated from that section north of the Corridor are located south of Rancho Niguel Road, west of Crown Valley Parkway. The future connection of these existing trail sections is planned to include a linkage south of the Corridor along Greenfield Drive, then westerly to connect with the existing section at Rancho Niguel Road (per discussion with M. Sandler, Orange County Recreational Trails Committee). 4-8-15 Because of work currently being done in the area, our suggestion for a better description follows: Private Trails. The Nellie Gail Riding and Hiking Trail is currently constructed along the west side of Greenfield Drive south of Hidden Trail Road to the location of the proposed Corridor crossing. After crossing under the Corridor, the Niguel trail extends westerly and then southerly behind the Ross shopping center (currently under construction 11\8\90). It then crosses Rancho Niguel Road to join the existing sections of the Niguel trail extending southerly towards Crown • Valley Parkway. r4.8-15 We now call your attention to trails which are incorrectly drawn on Figure 3.12.1: A. The Niguel riding hiking trail is shown in blue indicating it is a future trail. This is an existing trail except for the end which abuts the future Oso Creek Trail. The section from 4-8-16 approximately Marian Bergeson School to the Oso Creek Trail was evidently eliminated around 1986 even though the current County Master Plan of Regional Riding and Hiking Trails still shows it connecting to the Oso Creek Trail. If the Niguel trail extended as shown on your map, it would probably require another undercrossing of the Corridor. B. The portion of the proposed Oso Creek equestrian and hiking trail which extends to Oso Pacific Park has been completely omitted from this map. Also omitted is the existing equestrian and 4-8-17 hiking trail extending west from the Oso Creek Trail across Cabot Road and along the south side of Pacific Park. C. The projected Nellie Gail Trail on your map bears no resemblance to reality and necessitates crossing Pacific Park in 4-8-18 the middle of the road and not anywhere near a crossing. Attached is a copy of the map with the problem areas is highlighted. In addition to this report, the City of Irvine will submit information regarding the Corridor as it affects their city including the recreational trails. We hope this information will be helpful to you, and we would be glad to meet with you to discuss the recreational trails. Yours truly, Marlene P. Sandler, President cc: Ron Sievers, City of San Juan Capistrano Jim Ball, City of Mission Viejo East Orange Open Space Management Corp. John Anderson, City of Laguna Niguel Mission Viejo Company OF --- op / + \ � A + �//� \ OW AW VA 'h Ails 7.3RA .0 Please Print clearly- COMMENT CARD NAME dV'I-P- �� -�o .rdL DATE Y 9 ADDRESS SD l AFFILIATION CITY, ZIP (-7 PH. # (Optional) Please add my name to your mailing list YES NO COMMENT: �� c 4u aAx-,x � •• _ (Continue comments on back of this page. To submit, please fold page in half, secure` with tape, and mail to the address below.) Please note: Comments must be returned to the Transportation Corridor Agencies' office by 5:00 P.M. on November 15, 1990 L' Fold here -- TRANSPORTATION CORRIDOR AGENCIES 345 CLINTON STREET COSTA MESA, CA 92526 ATTN. SAN JOAQUIN HILLS EIRA-E-IS COMMENTS • RECEIVED NOV 13 1990 �t,—Vt L.CA9 a 0 4 r H TG� Of 401.-1 61 Kfoo h � � gr ' � ' Nam--• �-i�Mti ��,L'�'�-a/N o �� , A " �_ 4-10-1 UPC— wo,� 1 a � I ►-o-a.�c L!M S it k p{ I V.,,. Cyr �e..o-�0��•1 r w+�. - --� a�L s.•� b ""'� c.e wt �'w•� i �'' ro Me 'A^ srwy R c g ,- •� s �Z� I1� �i►d Q~ r A..... p S E�t lotto s ��.,o�1'�t-- s �.. t�,•e. �. ,r a.,ti,� .� S t"� w i�Vl 4-10-2 4-10-3 4-10-4 0 r *171- 4-10-4 Aoj^- +A— Ar ,� a,rv'Jr w. air Z#K3T-'v h- +—Ye K C14— . +C, G., c �,d w..l �„ UZLo � C4-- fir M yvu�,+i►•-�--� G0.. �Y"C-O( 6 4-10-5 ylawc _._.---- ►►vw�.s ice- Q-- s a' ►M w1��...,e.C� 1 iv k &kj �.� Ybe p _ ,�_ �__s � r� , r�.l�• L..� Le�k� '�� TvK �c. aC.�►w e.� s � jai • 1 6 -I S h1" Y"e-� 1 owe � eY Vn 1 A a0l"A rit k J ._ f h.�- �VWI� G�►', �,-_._ Cif•.CI„�.., A,,,.,, Ci�4't'�.�1, �-- r /�.t ' ,,,,,o,,,,,�' , --ice.; 1�►�. �. Oc4a.0a ttai 0-.f L. 1a-10-6 Ce Y , l M - — {�.►� G�.r�l�c.� Ow-t. f% I 1^4, - R. CJ+ i V Ah-.d w• c'dln e�-��C, 'fY �.-s r w t' yr • • 4' - v-' s 4--- it- " t" `A) v 1 66) vwv, A— tv i ti i ta,G( ` j I g--�►�.e-� • p,- o--et.�� �,,,� 1' 1 to w OT ham' �..� h � � rw•c h►�.d 1� "' S.c c� A�.. L•w �„ .o.c 4-10-7 46 • COMMENT CARD Please Print CI rly: /3— NAME - DATE 10 !� — ADDRESS S AFFILIATION_ CITY, ZIP;JJW2A&d- �L.�Q�i�C.� �- PH. # (Optional) Please add my ame to your mailing list YES NO' COMMENT i 4-11-1 D ContinueJmAmts&/aenk of this page. T submit, please fold page in half, secure with tape, and mail to the address below.) COMMENTS CONTINUED i • 4-11-2 IPlease Print Clearly: COMMENT CARD NAME 70r �DATE //- " - '? ADDRESS C�14 w D2 AFFILIATION a M� �%�l C oM n✓ CITY, ZIP 109G-�wf- 42 PH. # (Optional) b i (Please add my name to your mailing list t/YES NO COMMENT: C 0^r�,e--ye, W5 /tlo 1, 0,N,v ((Continue comments on back of this page. To submit, please fold page in half, secure with tape, and mail to the address below.) Please note: Comments must be returned to the Transportation Corridor Agencies' office by 5:00 P.M. on November 26,1990 of ere In TRANSPORTATION CORRIDOR AGENCIES 345 CLINTON STREET COSTA MESA, CA 92626 ATTN. SAN JOAOUIN HILLS EIR/EIS COMMENTS Stamp 0 0 .Please Print Clearly: COMMENT CARD ITIAMEF7 c 2 P DATE_���— 9 O ADDRESS �f/ a rtSCtaY AFFILIATION. �� err Fnv ✓ CITY, ZIPS -vL�6L N-Ytox 9'�705 PH. # (Optional) ��V -S*/E& Please add my name to your mailing list YES —NO COMMENT _., /� Cu emu, I r'/ (Continue comments on back of this page. To submit, please fold page in half, secure -Mih tape; and mail to the address below.) Fled- note. C cmniants must be returned to the Transportation Corridor Agencies' -)ffic-j by 6:00, 'P.M. on November 15,1990 L r� role nere TRANSPORTATION CORRIDOR AGENCIES F 345 CLINTON STREET COSTA MESA, CA 92626 AWN. SAN JOAQUIN HILLS EIR/EIS COMMENTS 0 RECEIVED NOV 16 1990 :-Wl Please Print Clearly: COMMENT CARD NAME DAVE BLODGETT DATE 11-15-90 President LW Residents to ADDRESS 3158-A Alta Vista AFFILIATION Save the Canyon (more than 980 paid members) CITY, ZIP Laguna Hills. 92653 PH. # (Optional) 859-9o82 Please add my name to your mailing list X YES NO COMMENT: If I were convinced the San Joaquin Toll Road would achieve its stated goal --relief of present traffic co-igestion-- how could I oppose it? But it will not! By the time all currently -approved developments have been built out (Aliso Vieio is nnly 212 comnlPted--4.200 of 20.000 housing units) the (Continue comments on back of this page. To submit, please fold page in half, secure with tape, and mail to the address below.) Please note: Comments must be returned to the Transportation Corridor Agencies' office by 5:00 P.M. on November 26, 1990 rinMre 1�A cq L THERIDE PMUSA 25 C,)R LIFETIME- 15 r_^•v Z' COLLECT ` �99C. STAMPS TRANSPORTATION CORRIDOR AGENCIES 345 CLINTON STREET COSTA MESA, CA 92626 ATTN. SAN JOAQUIN HILLS EIR/EIS COMMENTS RECEIVED NOV 16 1990 • PACOMMENTS CONTINUED original San Joaquin Transportation Corridor (1701000-cars-per-day 4-14-1 capacity and 6- to 10-lanes wide) would be filled to capacity from new development. Such feeder arterials as Moulton and E1 Toro will Iexperience Rignificantly increased ADT counts. The Wilbur Smith Traffic and Revenue Study clearly demonstrates that trip origin and 4-14-21 4-14-3 4-14-41 destination needs will not be served by the SJHTR but without the SJHTR the county cannot justify the builA-out of presently -approved housing developments --some 65000 units west of the I-5 to be built -- The EIR/EIS completely ignores the detrimental effects of the SJHTR on the health of the 21,000 senior citizens living in the Leisure World retirement community who are now suffering from a high incidence of respiratory ailments (the principal cause for admissions to the Saddleback Hospital serving Leisure World). We suffer now from I-5 air pollution when the Santa Ana winds blow. We shall suffer more from the SJHTR which interdicts clean air from the Pacific'. the prevailing air flow into LW. I so stated at an environmental hearing on July 24, 1984, at Mission Viejo High School. A billion -dollar project that will not achieve its stated goal --relief of traffic congestion --but will generate added traffic congestion destroy air quality and the natural environment --is a bad project and is totally unacceptable to the 21,000 residents of Leisure World whose average age is 76. In speaking for the Toll Road, Mr. Milton Adamson was only speaking for himself, not the Golden Rain Foundation Board and certainly not for the vast majority of LW residents 4-14-5 whose 16,000 voters turn out at elections and typically vote at an 80% rate. We wish the SJHTR were a solution to the traffic mess caused by irresponsible overbuilding in South Orange County. We know it is not. Any county government that can vote 5-0 to double the density of the Phillip Morris company's Aliso Viejo development from 10,000 to 20J000 4-14-6 dwellings is an irresponsible government and cannot be trusted to serve the best interests of South County residents. We have had itl No more development without prior infrastructure and no SJHTR to aid and abet the insatiable appetite of developers to destroy this magnificent countryside. Given an opportunity to vote for or against the SJHTR. 4-14-? I know a large majority would vote NO1 i LAW OFFICES OF MESERVE. MUMPER & HUGHES LOS ANGELES OFFICE 35- FLOOR 333 SCJTw HOPE STREE- LCS ANGELES, C:A, BORN A 90071 TE:EP-ONE (2:3) 620-0300 TELECOP-ER (213) 625-1930 November 16, 1990 18500 VON KARMAN AVENUE EDWIN A. MESERVE 11853-1955) SUITE 600 SHIRLEY E. MESERVE IRVINE, CALIFORNIA 92715 ❑86fl-,fl59) POST OFFICE BOX 19591 HEWLINGS MUMPER (1689-1968) IRVINE, CALIFORNIA 92713 CLIFFORD E. HUGHES (1894-1981) TELEPHONE (714) 474-8995 TELECOPIER (714) 975-1065 OUR REF. NO. Steven Letterly Transportation Corridor Agency 345 Clinton Street Costa Mesa, California 92626 Attn: San Joaquin Hills EIR/EIS Comments Re: TCA E I R 1 Dear Mr. Letterly: The Nellie Gail Ranch Owners Association offers the following comments upon TCA EIR/EIS 1. Rodent Control There appears to be no provision for the control of rodents, insects and wildlife in areas where natural vegetation borders housing. For example, the grading and construction work to be undertaken between Moulton and Greenfield will displace literally thousands of mice, snakes, lizards, insects, rabbits, gophers, and coyotes. These animals will flee into the backyards and houses of Nellie Gail. Some sort of netting, fencing, and insect poison should be positioned prior to any construction in order to avoid a serious infes- tation problem within the residential community. Demand Management Alternative 4-15-1 Nellie Gail is in favor of the Demand Management Alternative rather than the Conventional Alternative. The Demand Management Alternative requires a narrower corridor width enabling the peak elevation of the corridor between Maverick 4.15-2 and Fargo Road to be correspondingly lowered while remaining within the right-of-way and without necessitating walls. Using a 2:1 slope ratio, a 20-foot narrower roadway will lower the corridor peak 5 feet. MESERVE. MUMPER & HUGHES Steven Letterly November 16, 1990 Page 2 Sound Walls Nellie Gail approves of the 12-foot sound wall called for by the EIR between Moulton and Fargo Road to reduce noise 4-15-3 levels. As stated by Mr. Foster at the public hearing on November 14, 1990, the wall will be replaced by a dirt berm or combination berm/wall where feasible. Nellie Gail further agrees with the recommendation of the EIR that no additional sound wall he placed between Fargo Road and Greenfield. Note: Some homeowners may not favor a 12-foot wall; however, 4-15-4 the Association believes the overall community, especially the Association park and equestrian ring adjacent to the Corridor and homes not quite adjacent to the Corridor, will be benefitted by the wall. Timing of Noise Barriers In order to mitigate construction noise and obtain a headstart on landscaping growth, noise and visual barriers should be in place at the earliest possible time during construction. For example, grading will create substantial noise and dust and the completion of the 12-foot block wall and/or dirt berm called for by the EIR between Moulton and Fargo at the earliest possible time during construction will mitigate those impacts. Similarly, landscaping and tree planting should be undertaken as early as possible to maximize size prior to opening day. Very truly yours, �A ANDREW K. ULICH Board of Directors Nellie Gail Ranch Owners Association AKU:lid cc: Gene Foster 4-15-5 0 Please Print Clearly: COMMENT CARD NAME a�j �°AG� DATE 11— Q — 96 y-/-1"wc'r f K 5-02 ald ADDRESS aCC ST. AFFILIATION D.G. 619RT,,�l 124 c/ CITY, ZIP cs'f�ivTf� 4/UYq PH. # (Optional) Please add my name to your mailing list YES NO COMMENT: -7—Arn CaAdCE-R.tJW ,Vtid a600se'19 7-6 1,,9eei.-16 4:?-7" 4-16-1 �,c/d71Si,C'/? r&) ,V, <,Q s fi'.C� �aGcJ Gt>lLL A•yoTNd�2 F"GtJS/ f1E'�e'Ci Os2A.c�G � G'Oy !6'S 4-16-21 61 /.G iT y TO "We-ArT F8"ooe-V G STf}�tJ (Continue comments on back of this page. To submit, please fold page in half, secure with tape, and mail to the address below.) ' COMMENTS CONTINUED �t cover �.c�.c/��� r�rZ ,c��uJ cope a fvB`J �s 4-16-3 ;.dam /L'�iOQi�'� IDS %Y1.4 D'df2 oN� i5 T��"f�c'CU/iGc,��/�lli' rC T d7 7�1yP C'o,� i NWT / 7- 4-16-4 0 • N0V4-.ant+er 16, 19'-WD 4-17-1 Transp,artatlon Corridor Ag•en•ci•es. S45 Clinton ��•r�l?�• C•oe.ta me", Ca. 9262•S F.ub3jecct.: San Joaquin Hills EIR/EI S Gentlemen: 3 AM AGAINST TOLL ROADS IN ORANGE C.. UNTY and, therefore, r•e3ect the S HTC. I refuse. to use. -any t.%ll rtsad, •.ant; I've t.slked, t,•a so aany people wh-o are likewise opposed to tollways. Also, there are all the people. who are n•u�t. RICH an•d cannot afford to pay th•e feem who need t,cs s_s a •c• cxn s id•e:r•ed , and t h l e has not. been •d on•e . I sat in front. cf the local s.uperm,mrket. one day last weye•k and as.k•ed pe•aple if they ---u2.d aff-ord to pray tolls end the V,33•ority -Of the people 3 talk-ed tee --.sid they didn't have array im-c4ney end w�uldn't. be able .t.: pay the. tc+131 or drive -on the t-oll road. Then there Is the matter -Of law traffic � ua;t•E• �•rw t.3ae ia�et#iat�e ,Yse•a c.f .an.f .�1•ony t•he r•o�tt.e tsavesa.e.� by the -%JHTC further pr,3v! .g lack -of need. THE TCA MUST PROVE THAT THE TOLL ROAD WILL BE USED AND NOT B►.EC mE JUST AN EMPTY ASPHALT ROAD DUPING N.n,.b P-Sid HOUR PEPI.ODS., AND THIS THE T-C-A CANNOT DO. SURELY THE SlHT•C PROMISES TO BE A WHITE ELEPHANT1 It. is a fraud t.h•tt. is. being Perpetuated upon the taxpayers and, furthermore-, it. 4-17-2 dis/crieinat••es. against. the pc+ar and the unfortun*t•e. Where is your -analys.is •of the off•r-ct of levying tolls? Why is t.h•era no reliable 4-17-31 ^^•s.t• e.e.t•iamate: for this pr•o3e�ct.? You have failed to prove., ear even .address, the- issue- of reasonablees demand and urge for a tol lway 4-17-4I pr<. Je- t- . When the t.e1 l e fail to pay the bonds., as will be- the •a280e here, the O.C. taxpay-exe. will be. forced to make up the hundreds -of 4-17-5I millicros of .i+ollara' %,h-,rt•fall . In the. past• year alone the tab has risen some 01SO Billion on the pr-03•act. This, in and -of itself, is 4-17-6 'a sign that. the S=HTw In. far too ectonomicmlly prohibitive. to g`+ forward. 'Falk about deep pockets. NOW CAN BUUILDIN+G THE S.1'HT+Cr BE LEGAL? It is discrim1nat7jry, unfair, unreasonable and un3ust for people, who live along the routes of pr.sp s-c-d t.+11 ccorridors to be: charged foes. They will pay at 14mmet. four times higher for t.ollways then -other people molls, developers feas., decreases in property values, poor quality of life). Them people have. already been gouged by developers for `x3,000 end up in 4.17.7 sea-cAelled devaloper'a fees which are really h•om-embuyer's fees, so LEGALLY THEY CANNOT RE CHARGED ONE RED CENT to drive the tall road. They pay statmm and federal gas texas. like -everyone elae, state and federal Income taxes like everyone else., an increased county sales t.•ax for transportation as a result of the passage. of Measure. "N" like everyone -else. Living nest to the "freeway" as they do, their 4.17-8 •dual i t.y of life will go down the ts+i let.. They will have trouble. 4.17.9� se' llin�3 t•h•eir hoses -end will have- to take a Od huge lose. e all know 4-17.9f h•aw aau•--h ►r a¢wer t.y va l uass whan t.h'e r arss•dwor k e b." i n . Thy �e•apla. living in the area of the tall road will be real victinnss, 4-17-10I a c-r•ew-ed .-var r%y•al l y by the in�ec}init.i es anc! in:)us.ti�e. .y3r fr•e-e1.3a•din g bur•e•su•crate. pe.rp-atuat-e. I SHAVE STUDIED THE TOKEN DEIR . It. has. sOra da£i ci�nci est. t.h•an 9 4.17-11 aleve has hol-am, Since th•-- aarly daadliaaa for -aonnente• Am so prohibkt.iv�e •anal the d-c+cuaaent. a.-- pvtlit•i---al and not. to- MentAon all th•e blatant. crrore and the micain•g 3r•Eey data, it is not 4-17-12 �-s.s.it,la tc •traaa etnt. on the issues paSAe by page. am nermes.s.it tted. I'd like t-o, though. No doubt *this. would require. th•e writing of a book. Why i.e. t.he.re insufficient -time. }provided tra writ.�e. yaats in dotail to4.17-13 eeay why th-e 5H.3T•C will have- pro -found and di ssantex<)Iu . •e.nvironans•antal i aR pa c t-s? THE StH IT•C WILL HAVE PROFOUND AND DISASTCROUS ENVIRONMENTAL IMPACTS! 4-17-14 The. review pericbd is ridi-culously short. for any dcscuaaetnt., much 1'es.s. for ctne ss•3 Aocnst.trou s.ly inadssg}.nate. Where. ar•e the faet.ss? How •can we at.iLana b- •ae.k-b t.,,-% deal with t.ha numerous. aponument.•al errors. in t.ho 4-17-15 DEIR and -all th•e falla•cioua assumptions acid animaing data? I may THIS •COMPLETELY BIASED .AND TOTALLY UNSUBSTANTIATED DEIR is but. one. •.re c.t.,ep •s1_-n g t.�z•e Im-4n.gt.hy rrry s e. of r•:e.i1r.�sdan�3 -endcr.qaaain3 t.he.. 4-17-16 S HT•C down the 3sub2l•c' m 3ull•et.. The SJHT•C is not wante-d by t.h•s: PUb l i c and Is n•c-t in t.h-e publ l•c' u. inta.ras.t.. The DEIR <icoee. not. � tsnrPly with eit3s•er thee. l•ett•e.r or th•e spirit -of �CF-QR, and I have 4-17-17 +gr•av�e wit -c-erns ab•czut. the die-c-is.io n-•aaakin•g Pr•c-ce-se under which it. will k%e. reviewed, The S3HT•C in just. am illegal as all th-e. illeq-31 Sradinq t.ta•at. tx•se. •alr+�dy taken 1.e:Q for it. in a411s�-^�lic+yc- and4-17-18 Lagun-a Niguel , THE T-A HAS ABSOLUTELY NOLEGAL PI•GHT OR AUTHORITY TO IMPOSE TOLLS. WhoLa. going t-o st-and up for the. ovexburdene d traxpay .r s.? Wa don't. 4-17-19 want. your a onatr•oait.y. We won't gay your tolls. We. d•ea%and the- "k-0 Build fc-r t•h-e S HT•C:! Wery truly yours, Jean Kennedy, Co -Chair Cc;mmitte-e. t.o Stop the Toll Road Zn, I Ssn, Ni-cholay. octurt. Leguna E-e,%ch , J•o . 9265 01 0 November 17, 1990.1 Transportat.i•on Corridor Agencies S4 5 •r l i n t.o€x St.r•eet Costa me", CS' 92526 Ae: -,Ran Joaquin hills EIA/EIS Camment.s Gentlemen: The. SJHTC should not. be built. This highway represents sn in•cre•arm in •sir •and n-vuse- pollution and a prom•ot•i•os. of South Orange-C•�"t•y d•evelQpmAnt. which generates, in ever Increasing numbpers, the use of f-cssil fuel b::rning vehicleE. :t.iliz&-�d by jkbs'M'use t.h' y hav' n.2 •alt.e►n-mt.ives. Today our cnuntry is conmidsring -going to war over 4-18-1 the. nod f.zr f•ommil fools. FUrth4_-.rin2 •a;+tQ%P.tbil•e CcOUld lead t.>• the death of eany thousands of inn•ocoe-at Men, w•oa,•en and Children. To f•or•ce upon t•he fop l•c of South Or•ang•e C-o-unt.y such •a dest.r•u•ct.ive szd•e of t•r-3nap art-sti•on amm proposed by your Draft EIp for the Saes .b.aa-q•uir. Hills pr•o v`t. when •ot1mr lose costly eltexnst.ivVea. abound is In addition to the above-, I would like to str•esm that MANY, MANY %IGNIF.T.::.ANT ADVERSE IMPACTS ARE WIT A-C-V OWLEM-,ED AS S.i,1jrCFd IN THE DEIR. Air quality, quality of life, n•.ise pollutIona, sore •ears end t•reffic fl+c ing and draina•". pr--4-1-+l•ems, fs:t.Ure. wager s.h-s ta•3es, -grcwth-inducing affects, lose •.f remaining wildlife, vis•u•:¢I and •zestiraet.ic aff•ect.a•, d•eves.tating impacts on neighb.�she►c►da. 4-18-2 4Lrijuna Cenyon pr•.perty -owners, Leia.ur•e 4►llorld, Sycamore, Hills }oan �anera.:, devre>as•ing rr•ope.rt•y v*lmtea• fnr r•--sident•a• ed3ocent• t.• t-he. route, destruction of Indian burial grounds and numerous •srchtAol.�3icr�el s1tea• t•h•at• IWO Und•oubte+dly eligIbl•e for the Nat•iOn•al Register of Himt-oric Places, dimruptive- impa•cta: upon recreational velu-e-s oe. a r-esult of the corridor tramv rsing parka., tar+cn spaces and gr•e• t-nbelts, these -are -only a few of the many ma3or Items your -agency has foiled t- oddr-ess -or h•,�a• blatmnt•ly 31-cm-sed -over. 44e •citi.^-ans currently fa•cx serious •air quality problems. ,At this p. int. in time, -air pollution from cars, trucks and buses has already reache,d intolerable levels :for the health -and safety of the people of -Sout.hoxn aliforni•a. Our children, •as well as the elderly end t.`ae infirm, are musf•e-in-9 greatly and many are dying be.^..auas of air 4-18-3 pollution. The impact. of •ow•erdave-lopment• hoe. generated this poison because it has ressult.ed in the imposition -of "•aarridore" of tranf.portat•ion such as t-he SJHTC/t•oll rsbad. £Abvi.ausly there is. a need for transportati-on. However,. this does not 3ust.ify the affect t.h•st• t•h-a type -of t.r.•ans;%orta.•lcm pro3�t has. 4-18-41Now can anyone 3ustify a 17-mile, long road whose oast is rapidly '%prrc<•s-c-hing the 02 billion mark? Why h.mvmn't• ALL re+ox nablm. • 4-18-51•a2-t.e1-.aat vea t.. the SJUTC/to2l road been id*ntill-od and analymod? Why haven't. the- aeffe•ct.s• of lewying tcalls. been w,e.ighed properly? A tallw•my fcr the _San . oa•quin Hills area will un•doubt.edly be ,empty for t.h•e n.an-rush. hca•ure. f 2l v�r 22) during the day boe.^a.aeo&.: t 1 � many e•3p2e will res.�ae tics use •a t.allway, 42. many p opl•e cann•et. afford 4-18-6 t:c. F.sy 4_t e t! lle•, 47� t•he only s-ignificant. traffic cr+unt.a• in the. area ar•e 4urinj rush h•aurs, and 44) no real, actual -or verifiable n ee-d 'ex i s.t s.. Isn't. it. time. to re tb i nk t•h•e role. of the automobil-e In -Orange County and t-he. •course -of planning for the. South se.ounty area? L.�*ay h•:e4£.v't• •ttp-t.z'-date� planning ec�- ut•ic+na, including meth%de• for •el i minating the nee-d for a "freeway" been •cana•ld•ere4? When can er.•e 4-18-7 r..•zvF a e mal t. t:: t.he: n•cur�_r . l lant;ng n�e.dE. ..f -ur arc*a? A. c'o-o' let.•ely new mt.u•dy with l•on--3 term &,o2uti►ne• that. f•c+at•ss ltt=_•e:. aut.-. d ep end esa c e Is. enre l y need vi •end long oveerduee:. In aectua l i t•y , t.h i s. DEIP' Is baai1cal1y the. eamQ •on•e that was Isdyed in 1968, the Malik4-18-8 •^r••air"3e t`--c>,_n.g the. DEIR numboer. Therm is. lit t•l•e: "new" •about• the new DEIn. I have a eituatiQn to tell you about. Every w•cakdsy I take the AMTRAK fr•zsr Irvine t.•L% downt-own LLns- Angel -es. wheree+ I work. •_gently the traian is bec-om ra•g full and historically t.h•ereL has •z¢lw•sl�e• eria•tec: a large- g•ap In t•hec t•r•ain erh•edulee. for the night.-t•ime r•et.rai trip. When •are. wee going to have. Marc. -evening trains out of 4-18-9 ✓.s. A•ngeelet?s. and an earlier t.r•ain in t.h•e morning -out of San Juan :�tS•r 7. Et 3'�S.^.•� •. r I r i n-e ? A l a , th-e-re is a d•ef inl t e need f•car even more tr-NIns• -- the tracks- •and then. Limilding of fe-4-detr lines. connecting up t:a the ,aNTRAM r-aute sr -an <%thex areas. Put the d•allara along t1he 1- 5 t. •L: s Angeles! Thir. is. where. the. heavy t•r•affic g e.c. -and the. c•znpes•clal Indeusl-rial 4-vve2•cspm•ent.a and Ma3-or employment centers • •s sec . In aonc.leue•ian, this L�EIP. is bami�cally ap•alit.ical productthey- in 4-18-10 t tally lacking inob3ve ct.ive s.citnt.ifi•c •an•aly8.ia. and key data; the pr o3 e.•ct 4e-script-1 on is a•eve-rely flaw d . Furthermore, the DEIA fal l e3• 4-18.11 t.ca des�riL and analyzie. sell r•e:ascanable alt�ernat.ive:s• t•o the STNTr,rt.cl 1 read . The fact. that many, many pT.opl*s will not. use a 4-18-121 t c• l l way has. t.r be a im•s s-ccr f•sct.car An any study of t•h.i e• m•agn i t•ud'e: - An. t nc ccsampetent envIr•oram•entalIMpa•ct anal�faia in the aEIA. end +. r•e:•a l •czn s. iderat•i•can o£ adee�ga water alt orn•stoveers. t.c t.hc •oorridor aa. 4-18-13 -equir•ed by •C:EQA., I hereby f-ormally support the "No Build A l tAnr.aa t•i ve" for the r bad , peer s tance l l y , I feel the. SJH'3';:•✓to2l road is frightening, h-orrifying and unbelievable. Severe -air p.:ll•ut.icn, d•evas.tst•ing visual -and ae:a•t•hetic impacts• to our 4-18-14 c:oast.al area and many fine nei•yhborhood a, w+ildlif•e d•e.cimati•on, ruining Laguna •CL*nycan, destroying the magnificent San Joaquin Hills., and preshibItIvem coate cann-ot possibly Lae In the public interest. Very truly yours., Karl T. Jenkay+C•onsultant Coo—mit•te•e to Stop the Toll Poaed 302 Sass Nicholas Court L- quna "ach , r,a . 92651 0 Steve Letterly SJHTCA 345 Clinton Street Costa Mesa, CA 92626 Dear Mr. Letterly: The Friends (hereinafter "Friends") of the Irvine Coast have reviewed the DEIR/DEIS for the proposed San Joaquin Hills Transportation Corridor and have the following comments on the document. The purpose of the Friends of the Irvine Coast is to protect and preserve the Irvine Coast (most recently designated the "Newport Coast"). For nearly 20 years, members of the Friends have been involved in various efforts to preserve as much of the Irvine Coast as feasible. Consistent with this purpose, the Friends long-standing position on the Corridor has been one of opposition because of the deleterious effects the project would have on the Coast. The Friends supported reevaluation of the need for the Corridor in 1988. Now, just as the Coast dedication areas are 4-19-1 beginning to transfer into the public domain, the specter of a major new Corridor is once again being promoted without an adequate evaluation of alternative solutions to the traffic problem. The Friends believe that the impacts to the Coast as a result of the Corridor project are as follows: 1. The Corridor will segment currently contiguous open space areas. Such segmentation in the Friends view is likely to result in the demise of the coastal ecosystem due to the lack of adequate habitat to support the large mammals integral to the sustainability of the ecosystem. 4.19-2 In combination with the related Corridor projects (e.g. Eastern and Foothill Corridors) segmentation of open space areas throughout Orange County could lead to an ecologically "dead" County. 2. The Corridor will enhance access to the Coast wilderness areas. Such enhanced access may facilitate over -use of 4.19-3 these sensitive habitat areas and eventually lead to Steve Letterly November 18, 1990 Page 2 their demise. T4-19-3 3. Water quality impacts of runoff from the Corridor on the 14-19-4 aquatic habitats on the Coast and in the Pacific Ocean. 4. Direct impacts such as views of the Corridor from public access trails, noise from the Corridor and interruption 4-19-5 of public trails to adjacent open space areas. These impacts have not been adequately addressed in the DEIR/DEIS. The Friends believe that much more in-depth analyses are needed 4-19-6 to ascertain how significant and adverse the above -effects of the Corridor are likely to be on the Coast and other adjacent open space areas. Specifically, the Friends believe the following additional studies and/or information must be included in the l DEIR/DEIS: 1. A study of the migration patterns of the coyote, mountain lions (if any remain in the area) and deer herds in the Corridor pathway. Specifically, it is apparent from observations made by members of the Friends that coyotes migrate between the Coast, the Upper Newport Bay and inland open space areas including Woods Canyon and Laguna Canyon. Yet, adequate studies of these animals did not form the basis for mitigation measures proposed in the DEIR/DEIS. The cumulative evaluation in this regard must include the entire County and all three Corridor projects. Indeed, in light of the recent announcement in The Legislative Quarterly that pursuant to SB 1436 tolls from the San Joaquin Hills Transportation Corridor will help pay for the completion of the Eastern and Foothill Corridors, it may be necessary for one DEIR/DEIS to be completed on all three integrally related Corridors. 4-19-7 4-19-8 2. Additional information on the minimum size geographic area that can sustain a healthy ecosystem over the long- term (e.g. more than 25 years). The Friends encourage 4-19-9 the TCA to hire biological experts in this unique area to address this issue. 3. Additional analysis of the effects of urban runoff on the off -shore marine refuge. The Ford Study relied on 4-19-10 for the Coast does not suffice for the Corridor project. 4. Additional information about the effects of increased access to sensitive resource areas. It is common for 4.19.11 park access to be deliberately limited through parking 9 Steve Letterly November 18, 1990 Page 3 10 or access restrictions so that use does not exceed the carrying capacity of the area. There is no information on whether the existing roadway network is adequate to allow appropriate use of the sensitive areas. The DEIR/DEIS should include a comprehensive analysis 4-19-11 of this issue including the carrying capacity of the Coast open space areas, the adequacy of existing access, the increase in access and use that will result from enhancing access to the area, and the environmental effects of such increased access and use. 5. Additional information on the direct effects of the proposed alignment of the Corridor on the open space areas including Los Trancos Canyon, the State Park, dedication areas and the Moro Sliver (which may become open space under a current proposal). The Friends were informed that the alignment of the Corridor may be shifted toward the Coast open space areas. If this is the case, the impacts of this alignment adjustment must be addressed. 4-19-12 Also, the Friends believe that project mitigation measures are grossly inadequate to address these and other impacts of the project. If the Corridor is to built, the Friends believe that 4-19-13 major open space dedications are in order to off -set the impacts the Corridor will have on the regional open space areas and the regional ecosystem. In addition, the Corridor must be engineered to allow wildlife to cross at all natural wildlife corridors (e.g. canyons, existing wildlife trails). One inadequate animal 4-19-14 crossing, as proposed in the DEIR/DEIS, is insufficient as mitigation for this significant impact of the project. Last, in light of the significant project -related and cumulative impacts on the Coast and adjacent open space areas/ecosystems, the Friends request that alternatives to the project including no project be more seriously considered. The alternatives analysis omits or readily disregards alternatives which the Friends believe to be feasible including but not limited to the following: 1) increased congestion/enhanced transit alternative (e.g. congestion makes transit and car-pooling more attractive); 2) reduced density/density transfer to employment centers alternative to reduce the need for commuter demand for the Corridor, and 3) the no project alternative. • 14-19-15 Steve Letterly November 18, 1990 Page 4 The Friends appreciate this opportunity to comment on the project and urge the TCA to reevaluate the need for the project at this time. Sincerely, g 4&MIO Fern Pirkle, President 0 • • 0 BARRY PARTNERS 19431 SIERRA CHULA ROAD INN NE. CA 92713 PHONE: (7141 854-1600 n',TRIC I1ARRY PRESIDENT November 19 1990 Transportation Corridor Agencies 345 Clinton Street Costa Mesa Ca 92626 Re : San Joaquin Hills EIR/EIS Comments Gentlemen : We are retained by the Sierra Bonita Homeowners Association, an association representing 345 homes and homeowners in the Turtlerock section of Irvine. The Sierra Bonita Homeowners Association has requested that we review the EIR/EIS statement and comment on their behalf. We find many deficiencies in the EIR/EIS. Let us cover a few items. 1. Environmental Impact : wildlife. Your statement is flagrantly flawed in this regards. There are numerous species of wildlife in the area which rely on the area being intersected by the corridor to roam while hunting, nesting, and mating. Your provision of tunnels will not do anything to protect these native animals in the are4 and will lead to the reduction, if not the demise, of several species. A fine example of damage to wildlife is the recent death of a mountain lion in Orange County, hit by an automobile while moving through native territory of the animal. This case has been well publicized, and to suggest that your agency intends to mitigate the impact on these animals by providing tunnels and bridges is absurd and frivolous. 4-20-1 page 2. 2. Environmental Impact : plant species. We have noted in our immediate area several species of cactus which is endangered and will certainly be further endangered by development of the corridor. The corridor will have a magnet effect on development of housing and commercial development in the area, which will lead to the decimation of the many rare forms of plantlife which currently thrive in the affected region. We noted recently that the area of the U.C.I. campus where the college planned to construct the chancellor's home and entertainment area has a problem with a rare species of cactus which will likely force U.C.I. to develop the chancellor's home elsewhere on the campus. Similar forms of plantlife exist in the area affected by the corridor, and your EIR/EIS has done little to effectively examine this problem, other than to discuss mitigation measures which are cosmetic and do not sufficiently address the problem. 3. Environmental Impact : nearby existing communities. The corridor is planned to transit an area of hills, generally open space, and ridges, with interspersed flat land. Terrain is hilly, as stated. Traffic using the corridor will be cars, trucks, buses, possibly light rail, all being heavy air and noise polluters (excepting light rail). In the Turtlerock region, and between Turtlerock and Spyglass Hill in Newport Beach, a long, steep grade will be developed which will result in the trucks and buses slowing to about ten MPH going up the grade, and cars slowing to about thirty MPH. These vehicles will produce vastly greater noise and emissions in this area which will greatly affect the nearby residents of Spyglass and Turtlerock. Your projections of emissions and noise do not adequately address these two areas, and must be studied. You have simply estimated emissions and noise on an average basis, without considering the negative impact in this specific area, which will be dramatic in impact and result. 4-20-2 4-20-3 On a typical day in the area the winds are heading to the northeast. These winds will carry the emissions directly into Turtlerock which will result in a serious health threat to many of the residents, especially the children attending the grade and high 4-20-4 schools in the area, and the numerous elderly residents who are at home in the area every day. 0 It is critical that this area in particular be studied to determine the additional impact from the emissions released on the grade so that a true determination of the health impact can be made, rather 4-20-5 than the vague blanket approximations which have been used in the EIR/EIS. 0 page 3. 4. Environmental Impact : traffic impact generated by the corridor on and from arterial roads connecting to the corridor. We observe that the EIR/EIS inadequately addresses the traffic impact on local arterial roads which will carry'additional traffic to, from, and around the corridor. In the Turtlerock area, we see dramatic traffic increases along Culver and Bonita Canyon roads, directly as a result of the corridor development. Both Bonita Canyon and Culver presently have traffic counts of around 1,500 cars per day (cpd). Projections by the City of Irvine are that Bonita Canyon will increase to 28,000 cpd by the year 2010, and Culver to 23,000 cpd. Although the responsibility for connecting roads within adjoining incorporated cities is that of the cities, we understand that statements have been made indicating that funds are available through the corridor agency for mitigation measures and road improvements where such changes are necessary due to traffic generation by the corridor. Bonita Canyon and Culver are two roads where the traffic will change dramatically due to the corridor, and Imajor realignment of both roads will be necessary as a result of, the corridor. We have been in consultation with staff of the City of Irvine to discuss these requirements, with a recommendation that they examine a number of alternatives to mitigate the traffic impact on the established nearby residences in Turtlerock, presently only fifty feet away from these roads. These alternatives include a) realignment of both roads 1/4 mile away from the homes, b) closing off Culver/Bonita Canyon north of the churches on Bonita Canyon on the north side of the corridor route (approximately 3/4 of a mile from the corridor) which will eliminate the additional traffic impact along those roads, allowing traffic to feed to the Ford Road on ramp along California and University, and Sand Canyon on the east, c)undergrounding both roads along the route where they run next to homes in the area at least twelve feet, which will mitigate the noise impact on the homes, mitigate the visual impact, although do little to mitigate the emission impact, d)underground the roads. and create a tunnel so that the emissions can be swept away by fan. to a remote area for venting, an alternative which will accommodate the visual, noise and emission impacts on the existing residences. The corridor agency has not indicated its position regarding these alternatives, we are',advised, and still wants to push through the Pelican Hill extension to Culver which will be even worse for the _ Turtlerock residen-s and those further down Culver in the University Park area. 4-20-6 4-20-7 page 4. We note that University High School is located on Culver at Campus. With traffic projections by the City of Irvine indicating in excess of 25,000 cpd at this intersection, we project serious problems in 4-20-8 pedestrian and vehicular access to this school, and serious difficulties in conducting an adequate environment for students to learn, work and perform sport and recreational activity. It is clear from your EIR/EIS that either insufficient study has been made of the impact on surrounding established areas, or the corridor agency is manipulating the outcome of the EIR/EIS in order 4420-9 to dilute the true impact of the study so as to gain rapid and unopposed approval of the EIR/EIS and rush into the development of the corridor. 5. Traffic Counts : The EIR/EIS has relied heavily on traffic projections on a present count - with corridor count - without corridor count. Your agency has blatantly weakened its credibility in the EIR/EIS by using `without corridor count' figures which are totally unbelievable. The numbers you have used are arbitrary and have no basis in fact whatsoever, and are clearly being used in an attempt to shock and dismay the public in the anticipation that they will support your flawed plan as being a better alternative to the traffic counts that your agency has outlined in the `without corridor' counts. There is no way that the counts which you have quoted on the majority of roads will typically reach even 50% of your quoted numbers simply because your numbers are wildly outlandish and do not consider the actual capacity of the roads in question. Of the roads we reviewed, for example, we found total gridlock occurring, at less than 50% of your numbers, making any further growths impossible simply due to the impossibility of cramming any more cars onto the roads in question. As an example, Bonita Canyon was shown in your `without corridor' projections as carrying about 40,000 cpd. As it stands, even with Bonita Canyon being doubled in size and capacity, it will be at gridlock at 26,000 cpd, a far cry from your 40,00 cpd figure. Your entire suppositions pertaining to traffic counts are suspect, and destroy the credibility of the entire study, in our estimation. 4-20-10 4-20-11 In summary, the EIR/EIS as presented is seriously flawed in its content and outlook, and must be redone. It inadequately addresses the impact on wildlife and vegetation, and the impact on established nearby residential areas, businesses and schools. 4-20-12 The facts on which the EIR/EIS is based are suppositions, and are inaccurate to such a degree as to render the entire document suspect and, resultingly, flawed to the extreme. 0 e 0 page 5. Credibility is everything in this business, gentlemen. I would not let such a document as the one which your office has produced leave 4-20-13 my shop. From purely a professional level of responsibility you might want to review your findings and present them again. Very Truly Yours, j �, Barry Partners. Patric Barry. PB/epb P.O. BOX 102 BALBOA ISLAND. CALIFORNIA 92662 November 19, 1990 By Federal Express Steve Letterly San Joaquin Hills Transportation Corridor Agency 345 Clinton Street Costa Mesa, CA 92626 Re: Comments on Draft EIR for the Proposed San Joaquin Hills Transportation Corridor Dear Mr. Letterly: The following comments on the above -titled matter are submitted by Stop Polluting Our Newport (SPON) . SPON is a Non -Profit Public Benefit Corporation formed in 1973 for the following purposes: 1 1. To become informed as to all matters affecting the development of the City of Newport Beach, and to take action against such development as may tend to adversely affect the ecology and environment of Newport Beach and its Bay. 2. To work closely with all governmental and private agencies whose regulation or activities have a direct or indirect affect upon the ecology and environment of Newport Beach or its Bay. 3. To establish a continuing education program and to facilitate the exchange of information on all matters affecting the ecology and environment of Newport Beach amongst members and the general public. The purpose of these comments is to apprise the Transportation Corridor Agency (TCA), the California Department of Transportation (Caltrans) and the Federal Highway Administration (FHwA) of SPON's opposition to the proposed San Joaquin Hills Transportation Corridor. SPON opposes the Corridor for among other reasons because it will have significant adverse effects on the ecology 4-21-1 and environment of Newport Beach and surrounding open space lands without long-term improvement to the transportation system. Further, SPON believes that the Draft Environmental Impact Report/Fnvironmental Impact Statement (DEIR) is inadequate for the 1 specific reasons set forth more specifically below. Overall, SPON's major concern is that the DEIR fails to adequately support the major assumptions underlying the conclusions contained in the document that traffic and air quality will improve as a result of the project. To the contrary, as supported by the exhibits hereto, SPON believes that the Corridor will result in increased traffic, and ultimately gridlock on the Corridor along with the deleterious effects that accompany increased automobile traffic. For this reason, SPON believes that the assumptions at the foundation of the DEIR are false and that a revised DEIR, based upon accurate assumptions and scientific information must be completed and recirculated for public review. In addition, because the three Corridors are in fact one major freeway loop, a single DEIR should be completed for all three Corridors (e.g. the Eastern, Foothill and San Joaquin Hills Transportation Corridors). The Fall 1990 Legislative Quarterly, attached hereto as Exhibit 9, contains the following report that indicates how integrally related the three toll roads are: "Construction on the Foothill and Eastern Transportation Corridors may be helped by loans of toll revenues or grant monies from the San Joaquin Hills Transportation Corridor (SJHTC), thanks to legislation permitting loans between tollway agencies. Senate bill 1436, now law, would enable the San Joaquin Hills Transportation Corridor, once it is built, to help pay for construction on the unfunded tollroads... " See Exhibit 9 at page 4. 2 4-21-2 4-21-3 10, r] • THE DEIR IS INADEQUATE "The automobile once promised a dazzling world of speed, freedom, and convenience, magically conveying people wherever the road would take them ... But societies that have built their transport systems around the automobile are now waking up to a much harsher reality. The problems created by the overreliance on the car are outweighing its benefits." 1/ The DEIR Fails to Adequately Disclose and Analyze Project Impacts 1. The proposed Corridor alone and in combination with the Eastern and Foothill Corridors will contribute to serious air pollution problems over the long, if not short-term; impacts not adequately analyzed in the DEIR. The DEIR concludes that the Demand Management and Conventional Alternatives will both result in "positive net benefits to air quality" and that the No Build Alternative will result in "higher regional CO, NOX and PM emissions". DEIR at S-8. This is nothing less than a "Big Lie" approach and is unsubstantiated by the text of the document. ' To the contrary, SPON believes that the project will result in declining air quality over time for at least the following reasons: a) "Improving automotive technology can never completely solve these troubles [traffic congestion and air pollution]. Enhanced fuel efficiency and pollution control are at least partly offset by additional driving, as some 35 million new cars roll off assembly lines each year. Even in the United States, where emissions controls are most - effective, air pollution is worsening". Exhibit 1, at page 5. The DEIR should analyze the long- term effects (post-2010) of facilitating the use of an increased number of single -occupant automobiles in Orange County due to the construction of three major new "freeways". 1/Alternatives to the Automobile: Transport for Livable Cities, Worldwatch Institute',"at 5, attached hereto as Exhibit 1. • 4-21-4 4-21-5 b) "Surveys show that even U.S. drivers choose to drive not out of blind love for cars but rather from consideration of the time and money required for a trip." Exhibit 1, at page 36. The DEIR failed to analyze the likely positive effects of maintaining congested streets and freeways including but not limited to increased car- and van -pooling, increased use of transit, and the like. The DEIR also failed to analyze the increased single -occupancy trip making that is inevitable if using the automobile is made easier through the construction of additional roads. To the extent that trips increase, air quality will decline. c) The DEIR failed to consider the likelihood of new trips due to construction of additional roadways including all three Corridors. In Traffic Congestion and Capacity. Increases, attached hereto as Exhibit 2, the following synopsis of relevant studies is made: "Taken together, these various sources are clearly agreed that adding capacity to a congested system results in people making longer distance trips (within the same amount of time), traveling to a larger variety of places, and eventually even relocating their residences further from many of the activities that are involved in daily living, resulting in a commitment to longer travel distances." at page 6. The DEIR is silent on these likely effects of the Corridor. The DEIR should reconcile its conclusions against the findings contained in Exhibit 2 that essentially conclude that any benefits of the Corridor will be short-lived. Further evidence that the project will have deleterious air quality effects comes from a recent staff report by the Bay Area Metropolitan Transportation Commission Staff that suggests the addition of free -flow lanes to the I-80 Corridor will have significant adverse air quality impacts: "Worried that new freeway construction will jeopardize air quality, a regional transportation panel yesterday rejected the state's latest plan to widen Interstate 80 in the East Bay". Exhibit 3, Headline from San Francisco Chronicle, "MTC Rejects Latest Bid to Widen the I-80 In East Bay", November 10, 1990 at page A-4. Such reports must be reconciled with the conclusion contained in the DEIR that the Corridor project will result in air quality benefits. (See MTC Staff Report, November 9, 1990, 4 4-21-6 4-21-7 1-8 • 0 attached hereto as Exhibit 7. SPON believes that it is important for the TCA to obtain all copies of MTC Staff reports and environmental review documents in this regard, 4-21-8 and state how a minor freeway widening of the I-80, in a "cleaner" air basin, will jeopardize air quality, while three new freeways in Orange County will "improve" air quality.) 2. The DEIR fails to address the contribution of the project to Global Warming. "Automobiles are also the major source of carbon dioxide, the greenhouse gas responsible for over half of the global warming problem. Passenger cars account for more than 13 percent of total carbon dioxide emitted from fossil fuels worldwide, or more than 700 million tons of carbon annually. This figure is projected to increase 75 percent by the year 2010." Exhibit 1, at page 9. 4-21-9 Air pollution is transported well beyond its source. SPON believes that it flies in the face of pure logic for the DEIR to analyze air pollution from the project within a fragment of the region, let alone to ignore the global air quality and other associated problems which are the result of cumulative impacts of roadway and other projects worldwide. The DEIR must address the likelihood that the proposed project in - combination with the other proposed Corridors will facilitate 7/ an increase in the use of the automobile and thus the release of greenhouse gases. 3. The DEIR fails altogether to analyze the project's impacts on use of John Wayne Airport. Use of John Wayne Airport will inevitably increase as a result of building a major vehicle "pipeline" directly to the new terminal in addition to weakening any incentive for the construction of another airport to relieve pressure at JWA. 4-21-10 Yet, the DEIR is silent on this issue. This likely significant impact must be analyzed in the DEIR. Air pollution from increased use of JWA will cumulate with pollution from the Corridors. The DEIR should analyze this potential cumulative effect of the project. 4. The DEIR fails to adequately analyze increased traffic which will result from the Corridor on arterials which will connect -to the Corridor. A number of arterial streets are likely to experience 4.21-11 increased traffic as a result of people trying to gain access to the Corridor." Such increases'are not adequately addressed in the DEIR and'�include among other arterials University Drive in Newport Beach, San Joaquin Hills Road, Pelican Hill (� 5All n LI Road, Marguerite in Corona del Mar, as well as others. Over the long-term as the Corridor becomes congested, traffic may 4-21-11 back-up on some of these "neighborhood" streets as well. The long-term (post 2010) effects of the Corridor in this respect should be analyzed. Also, any inconsistencies between the traffic projections contained in DEIR 494, DEIR 4.21-12 267 and the instant DEIR should be disclosed and the reasons for the differences explained. 5. The DEIR fails to analyze the Corridor's facilitation of urban sprawl. One of the most obvious impacts of the project is that together with the other Corridors, it will facilitate people living greater distances from their work places. See Exhibit 2. Indeed, the Corridor network is likely to foster growth outside of Orange County because it will allow people to reside farther from the employment centers in Orange County. Not only is this impact not adequately addressed, but the concomitant impact of facilitating low density sprawl type development is not disclosed. 4-21-13 The DEIR should address these issues and in addition, explore the needed densities to support transit. An alternative land use configuration option (i.e. densities and land use 4-21-14 modifications needed to support transit) should be included in the alternatives section based on this analysis. 6. The Corridor's impacts to biological resources are grossly understated. The DEIR virtually ignores the deleterious effects of runoff on the Pacific Ocean, the Upper Newport Bay as well as wetlands, riparian corridors and creeks along its alignment. In light of evidence that the dolphin population off of the Orange County coast carry high levels of several pollutants in their bodies that have biologically magnified up their ocean food chain as a result of urban runoff, among other sources, the DEIR must provide more conclusive evidence that the Corridor will not have a significant impact on aquatic habitats of all types. See Exhibit 4, History of the Dol-ph- n Survey Project, 4/20/90 and Memoirs of the Natural History Foundation of Oranae County. Volume 3 Endangered Wil i;fA and Habitats in Sou kern California, Peter J. Bryant and J. Remington, 1990. 4-21-15 In addition, SPON believes that the analysis of wildlife corridors and the mitigation measures provided for the impacts to such corridors are deficient. The DEIR fails to factually support the discussions in the DEIR in this regard 4-21-16 and grossly underestimates the impact of the Corridor on such wildlife movement routes. 6' Last, the llElR does not disclose the actual effects of segmenting wildlife populations. See Exhibit 5, Wildlife 4-21-17 Corridors, Coast and Ocean, Summer 1990, at pages 10-21. 7. The DEIR fails to analyze the health effects of increased air pollution. "Recent U.S. research shows that ground -level ozone causes temporary breathing difficulty and long-term lung damage at lower concentrations than previously believed." Exhibit 6, You Are What You Breathe, at page 28. Among the health effects of pollution from automobiles are possible threats to the growth and mental development of unborn children, likely lowered learning ability in children, aggravation of heart disease, asthma, bronchitis and emphysema, and possibly cancer due to toxic emissions. See Exhibit 6, at page 28. SPON rejects the conclusion that air quality will improve with the Corridor and believes that the DEIR must discuss these and other health effects of automobile emissions. The DEIR Fails to Analyze Feasible Alternatives "Many urban areas are designed around the automobile, • with planners using road building to combat the inevitable traffic congestion. The result is a treadmill effect in which new roads fill to capacity as soon as they are completed, and cities begin to look like Los Angeles, where two-thirds of the urban space is paved over for cars." Exhibit 1, at 27. Among the potentially feasible alternatives that would achieve the legitimate project objectives that should be further evaluated in the DEIR are the following: 1. Reevaluate proposed development and the impact of proposed land use configurations on automobile dependence. Modify proposed land uses through general plan amendments and development agreement amendments to allow for higher density, mixed use developments (e.g. place high density housing in employment centers such as IBC and Spectrum in place of additional employment uses). The latter, amendment of development agreements, is justified based on health and safety reasons including declining air quality. See also Exhibit 1, at page 27. 4-21-18 4-21-19 2. Reduce the number of vehicle trips by making people pay the true costs of driving such as air pollution, municipal services and road construction and repair 4-21-20 through paid parking and tolls on existing roadways for 7 single -occupant venicies. See Exhibit 1. T4-21-20 if 3. Reduce the number of vehicle trips by removing parking altogether in areas well served by transit. See Exhibit (4-21-21 1. 4. Enhance and develop transit. Litigation in the Bay Area over the lack of compliance with the Clean Air Act resulted in Attorneys for the Sierra Club requesting information about the respective transit agencies ability to increase transit. Apparently, the transit agencies came through with numerous programs that could help alleviate traffic problems if funding were available (shifted from road projects). Source: Alan Waltner, Gorman & Waltner Attorneys, Oakland. The DEIR fails to include any discussion about the possible expansion of existing transit programs (e.g. buses, etc.) and the comparative costs of such transit program improvements. The DEIR fails to adequately explore the contribution additional transit, carpooling and bicycling could make towards eliminating the need for additional freeway development. No exploration appears to have been done to determine what incentives could be provided to facilitate transit, carpooling and bicycling and to improve opportunities for non -auto commuting. Without such an analysis, no evidence is provided in the DEIR that such an alternative approach is infeasible. 4-21-22 4-21-23 5. Establishment of a growth moratorium on all major projects in Orange County until the true consequences of cumulative development on traffic and air quality can be evaluated and a long-term regional blueprint of non- 4-21-24 auto dependent land use can be shaped. Such a blueprint might include amendments to planned communities which would result in jobs and housing within biking/walking distance. 6. Construction of a rail line along the I-5, I-405 or other alignment. "Expanding and improving the rail option can help ease highway and airport congestion for a small fraction of the cost of building new highways 4-21-25 and airports". Exhibit 1, at page 37. The DEIR fails to demonstrate the infeasibility of such an option or to describe the comparable costs of such and option. 7. Develop dedicated lanes for buses and privately subsidized bus shuttles to major employment centers in 4-21-26 lieu of single -occupancy vehicle lanes. a. Maintain congestion of roadways to encourage use of public transit and car pooling: "Reducing air pollution in cities is likely to require a major shift away from automobiles as the cornerstone of urban transportation systems. As congestion slows traffic to a crawl in many cities, driving to work is becoming unattractive anyway. Convenient public transportation, car pooling, and measures that facilitate bicycle commuting are the cheapest, most effective ways for metropolitan areas to proceed." Exhibit 6, at page 32. The DEIR fails to analyze the likely reduction in the need for the Corridor through the combined use of incentives for people to use transit and disincentives to the continued use of the automobile by single occupants. The DEIR Fails to Identify Feasible Mitigation Measures -27 The DEIR fails to identify feasible mitigation measures to the project in part because project -related and cumulative effects are 14-21-28 omitted or understated. SPON believes that the following mitigation measures are feasible and would reduce many project - related and cumulative effects to a less than significant level: 1. Measures to Address Open Space and Habitat Losses - Dedication of a minimum of 5,000 acres of open space lands for wilderness uses. The proposed dedication acreage is based in part on the fact that the Irvine Coast project resulted in the dedication of approximately 5,000 acres of open space and resulted in fewer impacts to wildlife and open space (e.g. did not result in the massive segmentation of contiguous areas, among other examples) than the proposed project. Areas which should be considered include but are not limited to lands around the Upper Newport Bay and San Diego Creek, land within the proposed San Joaquin Hills Planned Community, land at the confluence of the Corridor and MacArthur Blvd. in the City of Irvine, future development areas in the Irvine Coast, lands which would connect the Laguna Canyon open space', to the Cleveland National Forest, land that would connect the Laguna Canyon and Irvine Coast to the Upper Newport Bay, lands critical to maintaining the Upper Newport Bay ecosystem. 4-21-29 The DEIR should include a detailed study of the routes coyotes and other animals use to migrate 4-21-30 L 2. 0 between these open spaces. This study should dictate additional mitigation measures as well as lands which should be protected within these migration corridors. In addition, the habitat 4-21-30 mitigation plan should ensure that no isolated habitat islands, which will not survive over the long-term, will remain as a result of the Corridor, or any land uses that have been approved in reliance on the Corridor. Construction of bridges over the canyons for wildlife crossings. One crossing is insufficient to mitigate the impacts of the Corridor in this 4.21-31 regard. Also, no evidence is included in the DEIR which demonstrates that additional crossings are infeasible. The entire length of the Corridor should be fenced with minimum 7 foot fencing, or some other means 4-21-32 provided to ensure animals cannot get onto the roadway. The project should provide at least 3:1 mitigation for wetland loss in the same watershed as the loss and the same type and quality of wetland lost. The replacement wetlands should be monitored and funds 4-21-33 provided for additional replacement should the lei wetlands fail. The Corridor shall include dense tree planting I4-21-34 within all urban areas. A portion of each toll should be placed in an open space fund for purchase, maintenance and enhancement of open space in the area. The TCA shall establish a Conservancy with Board members from the major environmental organizations active 4-21-35 within south Orange County to administer the fund. Such organizations should include the Nature Conservancy, Natural Resources Defense Fund, Sierra Club, Laguna Greenbelt, SPON, the Friends of the Irvine Coast, and the like. Oak trees destroyed or threatened by the Corridor shall be replaced on a 15:1 basis from similar I4-21-36 species, minimum 20 gallon nursery stock. Measures to Address Water Quality Impacts - Water quality in all discharge channels must be Rec. 1 quality at a minimum. Water runoff from the Corridor shall be monitored and where the quality 4-21-37 10 is not Rec. 1 additional measures shall be taken to meet this standard. Funds shall be placed in 4-21-37 a trust fund to ensure this measure is met. - Runoff from the Corridor shall be . equal to or less 4-21-38 than the amount of existing runoff in the channels affected by the Corridor. 3. Measures to Address Transportation and Air Quality Impacts - The first and only phase of the Corridor shall be 1 free HOV lane, and 1 toll lane. The toll shall be adjusted upward as needed to pay for this 4-21-39 operational reconfiguration. On or before January 1, 2010 all lanes shall be converted to HOV lanes (minimum 3 persons per vehicle). - A portion of the tolls shall be used to subsidize transit use of the Corridor and investigate 4-21-40 additional transit improvements on this and other routes in South Orange County. 4. Measures to Address Growth Inducing Impacts - Aggressive traffic reduction design measures shall be incorporated in all development which generates trips on the Corridor including but not limited to pay parking for non -car and van-poolers, pay check subsidies for employees who commute by transit, walk or bike, locker -room facilities for employees, limited parking areas for single -occupant vehicles, 4-21-41 fees from employers for transit services, mandatory flex -time hours and the like. The DEIR should also include a complete list of measures to be instituted as conditions of ,project approval in all projects contributing to the Corridor use. - Where development rights are not vested in projects that generate Corridor trips, the density/intensity of the project shall be reduced to the maximum extent feasible and/or, if a residential project, 4-21-42 density transferred to an existing major employment center where significant environmental consequences would not result. SPON requests that the feasibility of these and other explored in the DEIR, and measures which will reduce c project and cumulative effects adopted as part of the measures be r eliminate 4-21-43 document. The Proiect Is Inconsistent with the SIP The proposed project may not be adopted because it is inconsistent with the State Implementation Plan (SIP) and will frustrate attainment of air quality standards in the air basin and elsewhere. The discussion of project consistency with the SIP appeared to make the assumption that the Air Quality Management 4-21-44 Plan (AQMP) supported the development of HOV lanes at any cost, including the development of toll lanes for single occupant vehicles. If the AQMP supports the construction of new freeways, we question the adequacy of the Plan to meet air quality standards and to meet approval requirements of state and federal government agencies. CONCLUSION "There is a parable: If a frog leaps into a Pot of scalding water, it will leap out. But if it leaps into tepid water which then heats slowly to a boil, the frog will remain... until it perishes. A peculiar quirk of nature, some thought... until we realized that we are like the frog.,, Source: A Guide for Environmental Restoration in Orange County, attached hereto as Exhibit 8. In 1989, some 29 major environmental organizations in Orange County endorsed "A Guide for Environmental Restoration in Orange County". The Guide contains the following words of wisdom regarding transportation: "There are now more than two million vehicles, generating approximately 65% of the air pollution in the County (including some 33,000 tons of CO2 per day). Excessive use of private motor vehicles (mostly carrying solitary individuals) is a major contributor to our unhealthful air, blighted views, increased health care costs, and loss of natural resources. The proposed new freeways will not relieve the congestion. If built, those roadways will provide access and motivation for further destruction of a major part of the remaining rural and natural areas in the County. The resulting influx of population will add to the freeway traffic load, nullifying any relief from congestion which might be achieved through planned expansion of the existing freeway system.', Exhibit 8, at page 13. 12 4-21-45 OF Tne "Transportation Resolution" contained in the Guide calls for the following: 1. Provide clean, safe mass transportation systems as the alternatives to new freeways; 2. Establish incentives to businesses and individuals using and promoting carpools, in -home work, flexible working hours, and use of bicycles or other vehicles which do not use fossil fuels; 3. Adopt and implement a regional bicycle route master plan linking all work centers, cities and recreational areas, with high priority given to effective, integrated bicycle routes in all future transportation systems; 4. Improve community planning to foster self-contained cities that offer places to work and live, rather than promoting the spread of suburbia, resulting in great commuting distances. SPON sincerely hopes that the foresight demonstrated in this citizen sponsored and supported publication is not ahead of the decisionmakers who hold the County's fate in their hands. If we are to keep Orange County from becoming the next Los Angeles, we 01 cannot delay bold action any longer. SPON respectfully requests the decisionmakers at the TCA, the County, Caltrans and FHwA to reconsider the wisdom of the proposed San Joaquin Hills Transportation Corridor. Thank you for this opportunity to comment on the DEIR. 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A._ U .'% ("� y II 6l C R°' Ct C1 G CJ t/1 A M. +- 0 y C? > A Q A C O w ay C 'tn OC L O -Q E> p oc a G u p ti a �e �"i.m -+ c E u° �i y u aac.� > E S+'4,'a-, $.c a C am �3°?� c L0 >>ti �s a w v G'� L A °- ts- ti. L p d II C w L CA - S- 6G v � '> G W�3 `oo�°3a_a. ca�va;a •EEc�°u °' �tiL c 3 o cc... E.8 ot- U E 3 3u Es R= U 2 y E.^'� ¢ 3, �O N Transportation Consultant Services Traffic .Congestion and Capacity Increases lei Prepared for: • Prepared APPLIED MANAGEMENT & PLANNING GROUP Anpst 1990 EXHIBIT 2 k "4 TRAFFIC CONGESTION AND CAPAWY INCREASES Traffic Congestion and Capacity Increases Introducfion The primary issue of concern in this document is the relationship between traffic congestion and proposed increases in the capacity of transportation facilities, with particular reference to environmental documents produced by public agencies in the San Francisco Bay Area. The questions to be addressed are: • Do capacity increases in a congestion -constrained transportation system produce long-term relief of congestion with concomitant i reduction in air pollutants from vehicles? Are these issues addressed adequately in current environmental documents prepared in connection with proposed highway projects in the Bay Area? Are current Bay Area transportation forecasting procedures capable of providing quantitative estimates of the impacts of capacity increases? To address these issues, this paper first outlines the issue of traveler behavior in response to capacity increases. Next the paper explores the capabilities of travel -forecasting procedures in current use in the Bay Area to deal with the impacts of capacity increases. Third, the paper examines the environmental documents and supporting methodology documents to determine the extent to which these issues are addressed in the current environmental documents. A"MGEMFNr &PWYNING Page 1 WOUP TRAFFIC CONGESTION AND CAPAMY INCREASES • Travel Behavior Responses to Capacity Increases The issue to consider here is how people actually can be expected to behave in a capacity -constrained transportation system, when capacity additions are provided. In other words, the questions is: what does common sense tell about how people will react to added capacity when the transportation system is already heavily congested? A capacity -con- strained system is defined as one in which use of the transportation system is limited by its capacity, because there is already sufficient de- mand being placed on the system to fill all available capacity. This des- cribes the state of the transportation system in the Bay Area. Behavior under Congestion First, a capacity -constrained transportation system is defined as one in which many highway (and/or transit) facilities are overloaded for substantial periods of the day, resulting in low average travel speeds and prolonged peak periods. One can put together a list of the responses that individuals i make to traveling in such conditions. While transportation planners have not had funds available that would allow the sort of consistent measure- ment that is required to prove the effects of congestion, simply by general- izing from one's own behavior and that of colleagues, and observing what happens to traffic in general in a congested urban area, one can list the types of impacts that congestion has on behavior: People forego trips they would otherwise like to make; People leave for work earlier or later, and return from work earlier or later, resulting in spreading the peak periods; People will try to find alternative routes that are less congested, often moving off the freeway onto arterial streets, until the streets are as, congested as the freeways; AP A"M EMS &PWVNING GROUP Page 2 7RAFFiC CONGESTION AND CAPACITY INCREASES F • To avoid some of the time taken up in travel, people will chain trips together, such as stopping at the bank or cleaners on the way to or from work; • People will choose closer destinations, exchanging a more desirable but more distant location for some activity for a closer, but less desirable one; • If alternatives exist, people will change mode of travel, electing to use carpools or transit in preference to driving alone; and • In the long run, people will relocate their residences to be closer to work or other attractions and reduce the amount of travel required to conduct their normal day -today activities. There is some evidence available on reactions to congestion. Congested \: urban areas tend to exhibit longer peak periods than uncongested ones, and the phenomenon of peak spreading, i.e. the lengthening of the peak period, is at least anecdotal and often measurable. Peak spreading is evidence of people shifting certain trips to other times of the day in an effort to avoid the severity of congestion at the height of the peak. For example, people may decide to get to work earlier in the morning in order to avoid the worst congestion. They may also leave earlier or later from work to go home for the same reason. Such rescheduling tends to lower the worst of the peak but creates peaks that last longer. In the Los Angeles area, the peak periods in the 1970s were defined as being from 7 a.m. to 9 am. and from 2:30 p.m. to 6 p.m. It is now being proposed that planners use a morning peak of 6 am. to 9 am. and an evening peak of 2:30 p.m. to 7 p.m., representing a lengthening of the peak periods by about 2 hours per day. There is often a decline in average trip lengths as congestion levels increase, indicating the choice of nearer locations than before for various trips. However, as we discuss further below, the overall time spent in travel within a 24-hour period tends to stay constant, so that as travel gets AMG �� 6 &ILIWNINO Page 3 0 GROUP TRAFFIC CONGES77ON AND CAPACITY INCRE,4SES • slower, the tots) distances that people can travel are reduced. The trip purpose least susceptible to the change in travel distance is the work trip, which is dictated by affordable housing and location of jobs, while discre- tionary trips like recreation, social visiting, etc. are much more likely to be affected. The stability of certain time -based phenomena in travel provide additional evidence of response to congestion. Measurements taken at various times in the past century on average travel times to and from work in such cities as Chicago, New York, Philadelphia, and also overseas in such cities as London, Munich, and Paris, show a surprising stability in the average and maximum amounts of time that people spend traveling to and from work. In spite of numerous changes in transportation technologies, nature of work, housing development, etc., the average time spent getting to and from work has stayed dose to 20 minutes, with an average distance just under ten miles [11, and approximately 99 percent of all work trips are completed in no more than 90 minutes. This stability in travel times indicates that longer travel times are not found to be acceptable, so that workers are forced by congestion to accommodate to this perceived maximum time by time -of -day shifts, job or home location shifts, and rearrangements (trip chaining, or making minor diversions on the way to or from work to accomplish other errands that would normally require a separate trip out from home and back) of other requirements for travel so that traveling to or from work is chained with other activities. The American Association of State Highway and Transportation Officials (AASHTO) pubfthed a manual on computing user benefits from transporta- tion improvements [21 that notes the constancy of travel time budgets for all travel, not just travel to and from work. On page 18 of that manual, the following is stated: "A final qualificadon of the use of a value for automobile and transit travel time savings is the indication from recent stud- ies that total average personal travel time has, over many years, been extremely invariant in different urban areas, at about 1.1 hours per capita per day (40). This means that the long-term — or, in some cases, the short term — results of APPLIED �Q�. _ MANAGEMENT LANNING GROUP Page 4 E TRAFFIC CONGESTION AND CAPACITY INCREASES reductions in travel time caused by improved personal trans- portauon facilities or operations usually show up in two ways. " Longer trips— the tendency in large urban areas to increase spatial opportunities and decrease resid- ential density. " More frequent trips— such as increases in trips for cultural and social purposes. "The argument for ascribing values to personal travel time savings mus4 therefore, regard time savings as a surrogate for other values that travelers seek, rather than as an end in itself, since the average daily time budget remains unaf- fected." [21 The citation says that an individual firing in an urban area has been shown to have a fairly constant amount of time that, on average, he or she is willing to spend on travel, and that is 66 minutes. The citation then deals with the response to capacity increase and points out that it will be most likely to have one of two effects: a lengthening of the distance people travel in large urban areas and a long-term consequent decrease in resid- ential density; and more travel being undertaken, particularly for cultural and social activities. The dtation concludes by saying that the justification for putting a 'monetary value on travel time savings (as is frequently done in cost -benefit analysis of transportation projects) is justified not so much because people are willing to spend money to avoid travel, but rather because they will trade off activities they would like to do with time spent in travel. The reference within this citation is to a paper presented by Yacov Zahavi(31 that investigated the evidence for constant time budgets and the impact of these on urban sprawl. In another document [41, Zahavi notes on page 46: "...shorter trips times may be traded off not only for more trips but also for either longer trips distancewise or savings in daily travel times.' [41 • At4MGEMENr &LWN/NG Page 5 • GROUP TRAFFIC CONGESTION AND CAPAC17y INCREASES Later in the same document (page 64), he goes on to say: 'It may be inferred from the above results that an increase in travel speed (such as brought about by an improved trans- portation system) may not necessarily save travel times; in the short run it may be traded off for a combination of more and longer trips, while in the long run it may be traded off for shifts in residence location.' [41 Similar results have been shown in a more recent paper j51. Taken to- gether, these various sources are dearly agreed that adding capacity to a congested system results in people making longer distance trips (within the same amount of time), traveling to a larger variety of places, and eventually even reiocating their residences further from many of the activities that are involved in daily living, resulting in a commitment to longer travel distances. 9- To a large extent, the congestion responses noted above also provide evidence that congestion is a self-regulating phenomenon. This is also • noted by Remak and Rosenbloom, who state: 'Congestion in itself acts as a deterrent to drivers choosing to add their vehicles to an already overcrowded roadway. When road capacity is increased, this deterrent is weakened, and although, for a time, traffic flows more smoothly, new users are soon attracted to the improved route until conges- tion conditions reappear.' 161 Remak and Rosenbioom also add: The self-regulating phenomenon is more pronounced in large urban areas than in smaller ones ... the larger, more volatile economy of major urban areas produces an almost endless supply of commuters, who quickly adjust their travel - to -work pattems to take advantage of improved traffic condi- tions." [61 MAMA EMS �X.PG ONUPG Page 6 0 M FFIC CONGESTION AND CAPACITY INCRE4SES Research which suggests that congestion acts as a Omit on additional traffic is confirmed by data which show that adding new transportation capacity lifts such limits and triggers additional new traffic. In other words, adding capacity permits traffic from the pool of unsatisfied demand to be added to existing traffic. This idea of a reservoir or pool of unsatisfied travel is pointedly discussed in two documents that reviewed the impacts of the construction of the Bay Area Rapid Transit (BART) system. Original- ly, BART was expected to reduce daily travel on the Bay Bridge by 9,000 trips in each direction. At around the time that BART began trans -Bay operation, there were also some significant increases in gasoline prices that probably had an additional impact on trip reduction on the Bay Bridge. Nonetheless, in total, trip making across the Bay Bridge dropped by only 3,000 trips per day within the first year after trans -Bay operation, about one-third of the expected drop. On page 80 of the Final Report on the impacts of BART [71, the following conclusion is drawn: T is believed that the 6,000 'new trips' were caused by travelers reacting to the lessened congestion on the bridge by mating trips that were previously suppressed or trips which had previously been diverted from other destinations or routes. This new traffic appears to have nearly completely offset BARrs contribution to reducing travel volumes." [71 On the following page (81), it is added: "Because of the small net reduction in traffic volumes (BARTs reduction offset by 'new' trips), there has been little impact- on highway travel times and traffic congestion.' 171 In a second related report, the following explanation is offered [81 on page 14: 'This resurgence of (Bay Bridge) traffic cannot be idendfled with certainty... (I)t might represent induced travel — trips that previously had been discouraged by congestion on the 0Ma1w EMFWT &ALWN/NG Page 7 GROUP TRAFFIC CONGESTION AND CAPACITY INCREASES bridge, but became attractive as soon as BART began to relieve that congestion. . _ "Induced travel is a common phenomenon. Wherever an automobile route is heavily used, there wdsts a reservoir of trips that people do not make because the route cannot accommodate them. If a second route is provided, both routes will draw traffic from this reservoir, and the net loss in traffic by the old route will be considerably less than the gain in traffic by the new route. This result sometimes is surpris- ing to officials and to the public, who reason that the con- struction of new -transportation facilities (such as BAR7) must substantially reduce the load on others." A furrier argument on this topic is offered by C. Kenneth Orski [91, who states: • "On the traffic congestion front there is some good news and some bad news... The bad news is that it seems unlikely we • can build our way out of it permanently." He then goes on to say: "New roads will not eliminate traffic congestion. They fill up with cars almost as soon as the ribbon is = This should come as no surprise, for new roads improve accessibility, and greater accessibility increases Me value of land. Higher land values, in tum, dictate a more intensive use of land, which generates more traffic, which fills up the highways." [91 This argument• relating to new roads applies equally well to adding capacity to existing roads. Thus, the conclusion that can be drawn from Orski's words is that "...added highway capacity will not eliminate traffic conges- tion, but will be filled up almost immediately with additional traffic that returns congestion to the same- level as before the capacity addition." These various authors seem to conclude quite clearly that there is a vast pool of unsatisfied demand for more travel in large urban areas that will ac4M,c.iiiED F.h7 &W►Pa Page 8 i TRAFFIC CONGESnON AND CAPACITY INCREASES show up as increased volumes whenever new capacity is added into the system. Such increased volumes mean that. added capacity wilt bring with it growth in total vehicle miles of travel and often a growth in total numbers of trips made in the urban area These various citations also establish rather dearly that the common-sense idea that increases in capacity result in people making more lips and longer trips is indeed widely held in the transportation profession. In summary, the effects of constraints of capacity on people's travel be- havior is confirmed by research, partic ularty the references cited in the above paragraphs. Furthermore, research dearly indicates that congestion also has the effect of limiting travel in an urban area. in the event that there is a desire to reduce overall travel and vehicle miles of travel in an urban area, particularly one in which there is a sufficient excess demand for travel that new capacity additions will be unlikely to be adequate to satisfy demand for more than a very short period, congestion itself can be utilized as a means to reduce or, at least, limit vehicle travel. Response to Capacity Increases Based on the foregoing, it is then quite straightforward to deduce how people will react to a capacity increase that reduces travel times initially. It will be the opposite of the reactions described above as occurring under increasing congestion. When capacity is added to the system, several impacts can be expected to follow, particularty when the capacity is added for congestion relief. Foregone Trips. Trips that have been foregone because of congestion will now be made. This will result in an absolute increase in numbers of trips using the facility that has been expanded. Peak Spreading. There will be a reduction in peak -spreading from people no longer delaying trips or starting early to avoid congestion. This will result in a shift of trips between the traditional off-peak periods to the peak periods and is likely to restore the pre -capacity increase level of congestion in the peak. Or �. KAMOEM� &LWNING Page 9 GROUP TRAFFIC CONGES77ON AND CAPAC17y INCREASES • Route Changes, Trips that may have used parallel or nearby alternative routes, in order to avoid congestion, may now divert and take the new facility, if the capacity increase boosts travel speeds above those of com- peting routes. Gained Trips. Trips that have been made pan: of an existing trip through trip chaining may now be 'unchained,' effectively adding more trips to the total. In particular, home -to -work trips that may have been used for side trips to shopping, banking, other personal errands, etc., may now be replaced by several 'out -and -back" trips from home for the same purposes. Destination Ganges. Trips made to nearby, but less -desired bcations may now be made to further -away, more -desired locations, leading to an increase in trip lengths and therefore lengthening the distances that trips are made on the expanded facility. Mode Changes. People who have chosen to use transit or carpools will now return to using solo drive. This will also result in an absolute increase in auto trips on the expanded facility. New Development In the longer term, if congestion levels are lowered for sufficient time, developers can be expected to seek additional develop- ment that will increase the number of residents and jobs in the vicinity of the expanded facility. In conclusion, if the effects of new capacity on future traffic levels are not estimated, based on the changes in travel behavior noted above, then accurate forecasts of the effects of new capacity additions cannot be obtained. To ignore the effects we have listed here will result in severe overestimates of the beneficial effects of capacity4ncreasing projects and severe underestimates of the negative impacts of such projects. APPUED MANAGEMENT &PLAWNING GROUP Page 10 110 0 TRAFFIC CONGESnON AND CAPACITY INCREASES Travel -Forecasting Methodology Travel forecasting methodology is the means by which the impacts of additional capacity on travel patterns can be, at least partially, quantified and assessed. There are three fundamental issues that need to be ad- dressed in looking at the travel forecasting methodology. These are: Are the Bay Area travel forecasting models capable of estimating the impacts of capacity increases on travel behavior, just outlined; If not, are state-of-the-art models capable of doing so, where the Bay Area models do not; and • In either case, are the models used in such a way that the impacts of capacity increases on travel behavior are routnely estimated. In order to answer these questions, we first provide a brief description of the Bay Area ravel -forecasting models, known as MTCFCAST. To assist someone who is not familiar with the various steps required to forecast travel, we have also provided a brief description as to the functioning of ' each model step. The standard metropolitan -area travel -forecasting methodology uses a series of steps to produce forecasts of person travel within an urban area. These are: Demographic and land use forecasts; Trip generation; Network construction; Trip distribution; Mode choice; and Network assignment i APPLIEDPage 11 MMdAGEMENT,N G 9 TRAFFIC CONGES 7ON AND CAPACITY INCREASES _ S The models used in the Bay Area are among the most sophisticated in current use in North America, but are also typical of the standard models in their overall structure and operation. The sophistication of the MTCFCAST models comes with a heavy overhead, in that the models are complicated and time-consuming to run, with the result that shortcuts are often made in applying them, resulting in a failure to capture many of the important effects of transportation system changes on travel behavior. In this chapter, the steps in the process are described, and the typical pro- cess of application is also outlined. Figure 1 shows the steps involved in the process and the flow of information through the process, as it is currently applied throughout the United States. Details of the form and structure of individual steps in the procedure will vary from locality to locality, but the overall process is the same. Documentation used for this chapter includes the three -volume set of reports prepared by Cambridge Systematics, Inc. for the MTC in June 1980 1101 [111 [121 and subsequent reports by MTC staff describing subsequent recalibrations and modifications to the models.(131 [141 Step 1: Demographics and Land Use The first step in the process is to forecast the demographics of the region- al population and employment and to forecast the distribution of land uses in the region. Demographic forecasting in the State of California generally works at the regional level from control totals of population and employ- ment forecast by the State Department of Finance. These may or may not be modified by local agencies. The Department of Finance makes its forecasts based on past trends and 'cohort -survive models (Le., models based on the proportions of different age groups of the population that can be expected to live over the next twenty years), modified by overall estimates of the region's capability to accept growth. The specific demographics of the population are forecast locally by the Association of Bay Area Governments (ABAG) using past census data to estimate proportions of the population by income levels, household size, APPUED & Page 12 A(M4IGEMENT UNNlNG CAMP 0 11 FIGURE 1 The Travel -Forecasting Process Regional STATE ESTIMATES Population and Employment Zonal LAND USE Population Employment MODELS Demographics Trip Productions TRIP GENERATION and Attractions Highway and Trip Tables Transit of Networks TRIP DISTRIBUTION Zone -to -Zone Movements Trip Tables MODE CHOICE by Travel Mode Assigned NETWORK Trip Volumes ASSIGNMENT' on Highway and Transit CAPACITY Congested Highway RESTRAIN-T Speeds TRAFFIC CONGESTION AND CAPACITY INCREASES dwelling types, etc. Population and employment totals are also spirt among subregions, based on a land -use model cakd PODS (Projective Optimization Land Use Information System). This model is driven primarily by current land uses and estimates of "holding capacities' of subregions or analysis zones, and include some sensitivity to the supply of transportation facilities. However, the linkages between land use and transportation supply, while reasonably well understood, have never been modeled very successfully, so that the impacts of transportation supply on this process are not strong in the forecasting procedures. Generally, a single set of forecasts are made to a horizon year that is usually chosen to be approximately 20 years from the present. Thus, during the late 1980s, forecasts have been made of population and emp- loyment in the year 2010. Probably, these will be updated and modified occasionally by the regions- in the state, but the pressures to have a single set of "official" forecasts mean that there is generally little modification once the agencies within a region. have signed off on a particular set of fore- casts and these have been adopted as the official figures. It can be expected that the next change in these figures will occur in the late 1990s, when forecasts are produced for 2020. In the meantime, the Bay Area projections, known as 'Projections 90" have been produced by ABAG, modified by member jurisdictions, and accepted as the basis for planning in the region. Step I Trip Generation Following the forecasting of land use, the next step in the procedure is to . run a set of models known as trip generation. These models estimate the numbers of daily person trips that will be produced by and attracted to each traffic analysis zone in the region. The models are normally a func- tion of characteristics of households for the production of trips and of - characteristics of employment or land use for the attraction of trips. The result of using this model is a set of forecasts of the numbers of daily person trips that will be made for each of a number of trip purposes (e.g., home -work, home-nonwork, nonhome-nonhome) for the entire region. MMAGEMEE&iAWING Page 14 TRAFFIC CONGES77ON AND CAPACITY INCREASES For at least the past three decades, various papers and research disserta- tions have been written that develop theories of the relationship between the numbers of person trips that will be made and the supply of transpor- tation. In other words, it has been argued quite dearly that the amount of transportation capacity in a region or locality will impact the amount of travel made by people that live in the region. However, all attempts to reflect this in travel -forecasting models have failed. The primary reason for this failure is that modeling is done at the regional level and is an ag- gregate phenomenon. It is difficult to describe the supply of transporta- tion at this aggregate level in such a way that the sensitivity of trip -making to it can be captured. The result of this is that there will generally be a single forecast of the amount of trip -making in the region that is associated with a single set of land use and demographic data. The total amount of trip -making in the region for a horizon year becomes fixed. Thus, despite that effect of transportation capacity on the amount of travel that will occur on the system, most analyses simply assume a single level of demand for the purposes of analysis that does not consider the effect of supply. This is also true of MTC with respect to forecasts generated with MTCFCAST. The MTCFCAST model for trip generation is unusual, compared to any other region in the country. In the MTCFCAST model, the first step in the modeling procedure is to estimate the proportions of households with workers and without workers, before undertaking the trip -generation model- ing. From this step, auto ownership of households without workers is estimated prior to further analysis. However, an estimation process for the number of home -based work trips is applied next to the worker house- holds, and auto ownership for worker households is one of the elements of this estimation process. The procedure is also modeled differently from most current models, in that separate estimating -procedures are used for the primary worker in the household and for secondary workers. in summary, the MTCFCAST models contain some additional capabilities for trip generation modeling that are not found in other models. By es- timating worker and nonworker households initially, the model is able to be Aww�&°r "ING Page 15 0 GROW TRAFFIC CONGESTION AND CAPACITY INCREASES • more discriminating in estimating the numbers of trips made by house- holds. By estimating auto ownership based on workers in the household, the model also adds an element of sophistication, compared to other models that forecast auto ownership direr tty from income. However, the models still fall short of permitting the number of trips made by a house- hold to vary with the supply of transportation, as measured by the capacity of the system. Step 3: Network Construction The next step in the process is to construct highway and transit networks for the region. These are the representations to the computer of the systems of freeways, streets, and roads that exist on the ground, together with the bus routes and rail lines providing transportation service to the region. Usually, this will be done in three distinct phases. In the first phase, base -year networks are constructed to represent what is on the ground now. In the second phase, networks called 'Existing plus Funded" (E & F) are created for each of transit and highways. These networks • contain what is on the ground now, together with projects that are included in the Transportation Improvement Programs for both transit and highways, which generally represent those projects for which funding is already committed by the various state and local agencies. in the third phase, future horizon year networks are created, representing various scenarios of what may exist in twenty years in the region. This procedure is not only the one followed by MTC, but is also the standard procedure used by all regional planning agencies in California. Phase One The highway system of a region the size of the Bay Area is extremely complex and extensive. in order not to exceed the capacity of modem - day computers and to control the costs and time required for processing tie information, the networks are constructed by using varying levels of approximation about the transportation facilities. It is important to repres- ent freeways and major arterials quite accurately, so that the models that ED UAMWM&Ifr O �uP s Page 16 n l� C7 TP FFIC CONGFS ON AND CAPACI Fy INCREASES use the. network information can perform realistically with these facilities. However, this system of models is not used (and should not be) for very localized planning, so the detail and accuracy about residential access streets, alleys, etc. is unimportant and represents the main area where one can reduce the complexity. For the highway system, the network contains a hierarchy of accuracy, with freeways being represented most accurately, then major arterials, minor arterials, and finally the remaining access streets and roads, which will not be represented accurately. Any streets on which buses run will also be represented accurately, to make sure that the transit services are also represented to the computer as accurately as possible. The transit network will usually be constructed in the most up-to-date regions by using the information contained in the highway network to define the locations of bus routes, and by using the geography of the highway network to determine the locations of separate -rights of way for transit, such as light rail and heavy rail facilities. The representation of rail facilities and express bus routes on High Occupancy Vehicle (HOV) lanes are usually equal in accuracy to the definition of freeways in the highway network. These are the procedures used by MTC to construct its regional networks. Individual bus routes are represented by listing the finks of the arterial street system on which they travel. In the same way that the highway network cannot show every residential street so too the transit network cannot show every bus stop. However, care is taken to include sufficient detail to allow the models to replicate current use of the system reasonably accurately. In the base year network, the speeds of buses and trains are carefully tuned in the network so that they provide a dose approximation to actual running times experienced by riders on the systems. AMMGEPU MEti &tANNINO Page 17 GAWP TRAFFIC CONGESTION AND CAPAC17Y INCREASES Phase Two The second phase involves creating the Existing plus Funded networks, as defined previously (p.16). These networks represent the inclusion of projects that are currently included within five-year improvement programs for each of the transit system and the highway system, and for which funds are currently programmed.. For both transit and highway, local, regional and state governments are required to develop and maintain ftve- year improvement programs, based on currently available and committed funds. Because these plans are supposed to be updated each year, the Existing plus Funded networks may be redefined as often as once each year. The third and final phase is to build future highway and transit networks, to represent what is expected to exist in the horizon year. These networks will usually start from the Existing plus Funded networks and then add a number of investment projects that it is hoped the region can afford to build over the next twenty years. Frequently, there will be several different such networks, one pair of which may represent a wish list of all the investment projects that have been created in the region, while others may represent various alternative funding scenarios. Step 4: Trip Distn'bution This is the first step in the travel forecasting procedure that makes use of the transportation supply. This step links the production ends of trips to the attraction ends to form a set of trip Interchanges," or zone -to -zone = movements in the region. This is done on the basis of the relative size of the numbers of trip productions and attractions in a zone, and on the travel impedance or difficulty between pairs of zones. The model is called a "gravity" model, because it is very similar to Newton's Law of Gravitation that says that the force of attraction between two bodies is equal to the APPUED AtM1AGEMENT &PLMNINCI GROUP Page 18 0 0 TRAFFIC CONGESTION AND CAPACITY INCRE4SES product of the masses of the two bodies and inversely proportional to the square of the distance between them. SubsftAng trip productions and attractions for the masses, and travel impedance for the distance provides a very dose approximation to the form of the trip distribution model. In the MTCFCAST model, the travel impedance is a function of travel times between zones and is a function of both the highway and transit travel time. At the point in the model chain when trip distribution is performed, there is no knowledge available to the _ model of actual travel times for the levels of trip attractions and productions forecast Therefore, the transpor- tation planner has the dilemma of deciding what values to use for travel times. There are two pieces of information that are usually known and included in the network data First, the posted speed or maximum safe speed on each rink of the highway network is known. Second, the actual speed has usually been measured for the peak period, representing the slowest speed on each part of the network. For the MTCFCAST networks, these two speeds are coded onto each link of the highway network. Bus speeds are also calculated based on a relationship to the auto speeds on the streets (slower to account for frequent stops and the slower accelerations of buses). So, the MTCFCAST model has available two known speeds for each of autos and transit — the maximum speed that can legally be used on each part of the network and the current (or most recentfy-measured, sometimes from several years back) slowest speed under most -congested normal conditions. In some instances, where a highway is known always to experience travel condi- tions that produce a speed significantly below the maximum posted speed, this lower speed is coded into the network in place of the maximum. ft is also important to keep in mind that no region in the United States can inventory the speeds on every piece of the highway and transit systems. Therefore, the convention that is used in ait regions, including the Bay Area, is to classify each rink of the highway system into one of five to eight A4{N,4cPUED E r &OLM/NING Page 19 GAWP TRAFFIC CONGESTION AND CAPACITY INCREASES different highway facility types and fire area types. This results in up to forty possible classification combinations of the facility and area, for each of which a speed for each of the two conditions (congested and uncon- gestedj is estimated from survey data. To illustrate, one facility type may be "freeway" and another may be "primary arterial" highway (4 or more lanes, divided by a median). One area type may be the "Central Business District" and another may be 'suburban." One speed will be selected for all "freeway" in the "Central Business District," and another for all "freeway" in "suburban" areas. The same will apply to the "primary arterial" highways. In a few cases, MTC will replace these speeds on individual links of the highway, where it is known that conditions are very unlike the average. A good example would be the bridges across the Bay, which do not operate the same as freeway and arterial facilities in other locations. However, the amount of the highway system that is given these replacement individual values amounts to less than one percent of the entire system. To run the trip distribution model, the conventional approach, which is also used by MTC in the MTCFCAST models is to do the following: - For home -to -work and work -to -home trips, use the peak period speeds for transit and autos, to reflect the fact that most home- work trips take place in the peak periods when traffic is con- gested. For all other trips, use the maximum speed on the networks, to reflect the supposition that most of these trips take place outside the peak periods, when traffic is not congested. The result of this step in the process is the production of a set of trip tables, representing the zone -to -zone movements for the region for each of the trip purposes that was used in the trip generation step. A set of trip tables is usually produced for each of the base year and the forecast horizon year. The base year trip tables are based on population, employ- ment, demographics, and transportation supply for the year selected as the base year (currently 1989 in the Bay Area); while the forecast horizon year trip tables are based on the population, employment, demographics, and APPLIED Page 20 AiML1GEMENT CANNING GROUP :0 0 TRAFFIC CONGESTION AND CAPACITY INCREASES the highway and transit networks representing the most probable future scenario for the horizon year, currently 2010 for the Bay Area. In the MTCFCAST models, the future networks are different from the base year networks by having included a number of improvements and addi- tions that are planned to be built in the next twenty'years. However, no changes are made to the unoongested speeds on the networks, and only limited changes are made to the congested speeds (increasing these where new facilities are to be added, and decreasing them where conges- tion is expected to worsen). Changes made to the congested speeds are a matter of judgement, and are applied both by changing the speed for particular combinations of faality and area, and by changing speeds on some individual segments of the system. For the horizon year forecast, the same convention is used for home -work trips and for all other trips, so that the trip tables are based on the as- sumptions of changes in the highway system and the assumed effects of botch growth and facility construction on speeds in the congested periods of the day. Step 5: Mode Choice In this step, the trip tables generated in the previous step are allocated to each of the different travel modes (solo, driver, shared ride auto, carpool, and various forms of mass transportation) in the region. The allocation in the MTCFCAST models is based on population demographics and the relative service levels (usually travel times, but possibly also including travel costs) provided by the alternative travel modes. The MTCFCAST model is a state-of-the-art model in this respect Thus, this step is a function of transportation supply, but, like the trip distribution step that precedes it, the transportation supply is still described in terms of average estimates of performance.of the system, i.e., the pre -coded congested and uncon- gested speeds on the highway networks and scheduled running times of transit A"WGSW N° &X.PIp G Page 21 TRAFFIC CONGESTION AND CAPACITY INCRF4SES • The result of this step of the process is the creation of a much larger number of trip tables, each one of which represents the regional zone -to. zone movements that are estimated or forecast to take place for a specific trip purpose and on a specific travel mode. It is customary that this step will define different transit modes as a function of the access travel mode to transit, so that transit altemattves may be walk to transit, drive to transit, and driven to transit, for example. In the MTCFCAST models, a novelty is the provision of feedback proce- dures between mode choice for the work trip, auto ownership for worker households, and trip distribution. Trip distribution is therefore affected by the mode choice, an interaction that is widely accepted in theory by trans- portation planners but rarely implemented in practice. Standard practice elsewhere in the country is to apply the models in the strict sequence of trip generation, trip distribution, and mode choice, with auto ownership es- timated directtyy from household characteristics prior to trip generation. This means that trip generation affects trip distribution, which affects mode choice. However, effects in the other direction, e.g., of mode choice on trip distribution, are not modeled. In contrast, the Say Area models make auto ownership of worker households a function of the choice of travel mode for the primary worker's work trip, and also make trip distribution �? dependent on auto ownership. There is also a feedback loop provided for the secondary worker's work trip between mode choice and trip distribution, so that selection of the destination for the work trip is made partially dependent on the choice of travel mode for the work trip. in addition, the model contains a step that estimates the shared -ride occupancy for auto for the secondary worker. For non -work trips, the more conventional sequences of trip generation, trip distribution, and mode choice are used, with auto ownership, as mentioned previously, estimated prior to the generation steps. The output of these combined procedures (for work trips, non -work trips, and for non- worker households) are the standard trip tables for each of highway and transit and for the various purposes. APPEND & GAOuP Page 22 btANAGNMNM LWNING .` TRAFFIC CONGESTION AND CAPACITY INCREASES Although these capabilities exist in the MTCFCAST models, they are rarely employed in practice by MTC staff. The feedback loop takes considerable computer time to acxomplish and also adds days into the time required to process a complete set of forecasts. As a result, the feedback loop is usually cut out, and the more normal progression of trip generation, trip distribution, and mode choice is employed. Step 6: Time -of -Day Tap Tables Up to this point, all of the trip tables that have been produced by the modeling process are trip purpose tables, that is, they are tables of work trips, nonwork trips, and trips that have neither end at home. Before the modeling process can proceed further, it is necessary to combine these trip tables in such a way as to produce time -of -day trip tables. These are needed because estimating the travel impacts on the highway and transit systems are dearly a function of time -of -day travel loadings, and trip purpose trip tables cannot tell the planner and decision maker much about these loadings. Unfortunately, this step of the process also represents an inconsistency in the process. Up to this point, the simplifying assumption has been made that all work trips take place in the peak period and all nonwork trips take place outside the peaks. Now, this assumption is dropped, and factors are used to split each trip table between peak and off-peak hours, and factors are used also to estimate the peak highest hour. The product of the modeling procedure at this point is a set of nine trip tables and two summary tables [10] representing 24-hour weekday estimates that can be factored to provide one -hour trip tables for peak and off-peak. The factors - that are used by MTC are based on surveys conducted over the past decade, and provide estimates of the fractions of work and nonwork trips in each of the peak and off-peak periods and in the highest peak hour. These fractions are used for both the base -year and future year forecasts. As a result of this step, trip tables are now produced for the peak hour (defined as the hour of highest travel volumes), the peak period, an off- � EMEr° &G I G Page 23 TRAFFIC CONGES77ON AND CAPAr;ITY INCREASES is peak hour, and the entire 24-Hour day. Each trip tabie resulting from this is a combination of all trip purposes in varying proportions. Step 7: Network Assignment In the seventh step of the process, the factored trip tables are loaded on (assigned to) the networks. The basis for assigning trips to the networks is first to determine paths (routes) between the pairs of zones through each of the transit and highway networks. Paths are found in the MTCFCAST procedure by finding the shortest travel -time path from each zone to every other zone. in other words, everyone traveling from one point to another in the -Bay Area is assumed to choose the route that gives the shortest travel time.• On the highway network, the assignment of trips in the first instance is performed using so-called "free -flout travel speeds on the network. These are simply starting speeds that would be appropriate if We or no other traffic was on the facility. These speeds are defined, like the peak and off- peak speeds used in trip distribution and mode choice, as a function of the facility type and the area type. Once the initial assignment has been completed, travel speeds and times are reestimated for each Gnk of each highway facility. Many facilities will have been assigned more volume than they have capacity to handle, while nearby parallel facilities may be nearly empty. This occurs because of the modeling assumption that everyone uses the single shortest -time route between each pair of places. The next step (iteration) is to find a new set of routes or paths through the network, using the travel times resulting from the first loading of trips on the network. A "capacity-restrainC function is used to reestimate all travel White a few regions in the country have introduced a capability to find multiple paths between each pair of zones for each of highway and transit, most regions, including MTC, continue to use a single -path pro. cedure. The capability of finding multiple paths adds conslderable com- plextty to the process and also poses problems of determining the proportions of trips that will use each path — a process that is not yet well -understood by the profession. APPUED ,Q�._ MANAGEMENT LUVNING GAOUP Page 24 0 TRAFFIC CONGES77ON AND CAPACITY INCREASES times based on the relationship between the assigned volume and the capacity of the facilrty. reassign traffic, using the newly -calculated travel times to produce a new set of zone -to -zone paths. This step has the effect of moving much of the traffic from the heavenly -congested facilities of the first step, while loading traffic onto the under-utilized facilities of the first step. Some traffic will remain on the heavily -congested facilities, because the next possible path is so much poorer in travel time than even the con- gested time on the initial path. However, many paths will shift in the second step. This procedure is continued through several more iterations, because each of these produces a different assignment, always with a mix of overloaded and underloaded facilities. Most often, the procedure is continued through five iterations, and an average is taken of the last two iterations to produce the estimated most likely final assignment of traffic. No such procedure is available for the transit system, and a single assign- ment is often the only one made to transit. it is also a single -path, all -or - nothing assignment and may result in apparent overloads generated on some bus routes with close -by routes being left largely empty. as a result of the same features of the process described for the highway network. However, overloading in transit does not affect running times appreciably, so that there is no basis for iterating the assignment: Manual adjustments will usually be made to the resulting assignment to represent most prob- able realistic loads on bus routes and rail lines. Impacts of Capacity increases In this section, we review first what the MTCFCAST model system is cap- able of producing. Second, we review the different responses to capacity increases and assess what the models should be able to show. Third, we discuss how the system is used in practice. These are then used to draw conclusions about what MTCFCAST does in practice in providing estimates of traveler responses to capacity increases. u MGEMENr OGN4Pa Page 25• TRAFFIC CONGESTION AND CAPACny INCREASES MTCFCAST Model Capabilities When a transportation system experiences significant congestion, the MTCFCAST models can reflect the degradation of speeds on facilities through the capacity -restraint process used to load the highway network. The process does not, however, shift highway trips to transit, as a result of congestion, unless at least the mode -choice and assignment steps are recycled, with mode -choice using the travel speeds calculated from a loaded highway network. If the procedure is recycled back through trip distribution, with the es- timated peak and off-peak speeds used from the final network assignments instead of -the pre -coded ones, then changes will be reflected in both the destinations of trips and the allocations between highway and transit modes. Trip distribution will be affected, because it is a function of travel time. As speeds degrade, the distance that can be traveled in a given amount of time decreases, so that under congested conditions, nearer destinations will be selected by the model than under less -congested conditions. Similarly, as highway congestion increases, the relative levels of service of transit and highway, particularty where rail and busway fac- • Tiles exist (or buses on HOV lanes), will change so that transit becomes more favorable. Therefore, the model will shift trips from drive modes to transit modes. ft is important to note, however, that because of the restricted sensitivity of land use modeling and trip generation, congestion will have no effect in the models on the distribution of population and employment forecast nor will it affect the total forecast of trip -making by the population in the region. In other words, no matter how congested travel becomes, or how much capacity is added, speeding up travel, the MTCFCAST models cannot show any change in the amount of travel taking place in the Say Area. If recycling of the model system is performed, as described here, then the forecasts can be made sensitive to levels of congestion, within the limits that total amounts of trips and the distribution and total amount of popula- tion and employment will not change. APPtJED MANAGEMENT &LANNING GROUP Page 26 0 0 C TRAFFIC CONGESTION AND CAPACITY INCREASES it follows, therefore, that if a future scenario includes the addition of new capacity in areas where highways are currently congested, the IVITCFCAST models can respond, within certain limits, to this additional capacty. Additional highway capacity will show up initially in the network assignment process as increased speeds of the traffic on the facility. Through cap- acity -restraint steps, the network assignment procedure will then shift additional trips to the facility that has added capacity, indicating the route changes that take place when capacity is added. If the procedure is not recycled through trip distribution or mode choice, this will be the only effect that will be estimated by the model system. If the model system is recycled back through mode choice, with the newly - estimated travel speeds on the expanded facility, the mode -choice model can be expected to shift trips- out of transit and high -occupancy vehicles and into solo drive and shared ride, because levels of service for the latter two modes will have improved relative to the former modes. In the follow- ing network assignment, additional highway trips will be assigned to the expanded facility, and speeds may drop again from the initial estimates. Therefore, these steps may require several iterations in order to reach an equilibrium or stable result, in which the speeds on the new faaTity are successively adjusted and the amount of shifting between other highway routes and between atiemative travel modes stabilizes. If the models are recycled back through trip distribution and newly es- timated speeds on the expanded highway system are used, then the trip distribution model will adjust the origin -destination pattem of trips, reflecting the improved speeds obtained from the capacity addition, and lengthening trips that can take advantage of the new facility. This -will occur provided that the following conditions hold: 1) The initial peak and off-peak speed estimates were dose to actual loaded speeds at the end of the original assignment, or the entire modeling process was recycled originally to use loaded speeds from the highway network; and GEMEW &LANNUPG Page 27 TRAFFIC CONGESTION AND CAPACI7y INCREASES . 2) The new speeds after capacity addition improve travel times by at least one or two minutes for some trips that can use the expanded facility. A single pass through trip distribution, mode choice, and assignment, after a capacity addition will not be sufficient if the capacity increase has a significant impact on travel times. Rather, it will be necessary to perform several iterations of this process, in order to obtain reasonably stable estimates of the traffic impacts. There is no guarantee that this process will converge, but the same steps as in highway capacity restraint can be used in which results are averaged from two or more sucxessive Iterations. Travel -Forecasting Responses Some of the effects of capacity increases can be captured by the travel - forecasting models while others cannot In this section, we describe how each of the responses described earlier in this paper are related to the travel -forecasting process. Peak Spreading Peak spreading involves the proportion of trips that are made in a given time period. In the standard travel -forecasting procedure, Ahe only point where time of day enters the picture is when the trip purpose tables by mode after mode choice are prepared for assignment to the networks. This is a purely exogenous process, utilizing factors that are derived from data sources such as past origin -destination surveys. Therefore, the travel - forecasting process can reflect the peak -spreading phenomenon and reactions to it only through exogenous changes made to the factors by the analyst Given that peak spreading is not fully understood, and its relation- ship to travel times is not known specifically, any changes made by the analyst to the time -of -day factors would necessarily be judgmental. Hence, the MTCFCAST models cannot show the impacts of capacity changes on the duration of the peak periods. APPUED A"WG&W&Vr NG CJMP Page 28 n TRAFFIC CONGES77ON AND CAPACITY INCREASES • 41t V1. Travel -forecasting models base route selection strictly on travel time. 9 a capacity increase is provided in the highway network, speeds will increase over the capacity -increased segment of highway, and new minimum time paths are likely to shift trips onto the enlarged facility. Therefore, the travel -forecasting procedure is fully capable of reflecting route changes oorsequent upon capacity increases. Hence, the MTCFCAST models can show the effects of capacity changes on route choices. Foregone Trips We have noted previously that the amounts of trip -making estimated by the models are not sensitive to the supply of transportation, even though it is widely recognized by transportation professionals that they should be. As a result of this deficiency in the models, no estimates would be obtained from the models of trips foregone as a result of congestion, nor of trips added because of a decrease in congestion. To the extent that the mod- els in the travel -forecasting process were originally calibrated with data collected when a state of congestion already existed, the models may embody some level of foregone trips. However, this is not explicit and is not readily available for manipulation through the modeling process. Hence, the MTCFCAST models cannot reflect the impact of capacity changes on the numbers of trips made or not made. Chained Trips The travel forecasting process treats trips as being single purpose. Chain- ed trips are generally represented as a series of apparently independent events, not as a linked chain. As a result, the travel -forecasting process is unable to show changes in the linking of trips as a result of congestion or, conversely, the relief of congestion. The relative proportions of trips for MAMG MEEff &O MNNG Page 29 TRAFFIC CONGESTION AND CAPACITY INCREASES different purposes is a function of trip chaining in the calibration data, but the model system is not able to handle explicitly the trade-offs between chained trips and single -purpose trips. The MTCFCAST models are unable to show the effect of capacity changes on trip chaining behavior. Destination Changes The travel forecasting models are sensitive to levels of service as they relate to the choices of destinations. When travel speeds are low and traffic is congested, more trips will be given a destination in a short dis- tance from the origin than when travel speeds are higher and traffic is less congested. As noted in the preceding section, the ability of the model to show these effects is contingent on two conditions: first, that the initial distribution of trips was made using loaded (congested) travel times from the highway network; and second, that the models are recycled back to trip distribution to test the effects of new capacity, with appropriate ac- counting made of the extent to which speeds appear to have increased with congestion relief. However, as a general statement, the models are capable of providing a good estimate of this phenomenon under capacity increases. The MTCFCAST models are capable of showing the effects of capacity changes on destination choices. Mode Changes Choice of mode of travel is explicitly a function of comparative service levels among the available travel modes. Therefore, a change in travel time that results from a capacity increase on a highway is able to be included within the travel -forecasting procedure. As with destination changes, it will require that the service levels on the highway network are generated from a first pass of the forecasting procedure that results in a loaded highway network and capacity -restrained speeds. Given that highway travel times MJMGEMENr &P ONu" c Page 30 TRAFFIC CONGESTION AND CAPACITY 1NCRE4SES are derived from a loaded network, however, the mode-c hoice model will produce changes in the shares of each travel mode as a result of capacity increases on a highway segment. - The MTCFCAST models are capable of showing the effects of capacity changes on choice of travel modes. New Development As we have noted previously, the land -use modeling component of the travel -forecasting procedure is not transportation supply sensitive and the forecasts use a fixed, static forecast of land use. Therefore, the forecasting procedure is unable to provide estimates of the new development effects of capacity increases in the highway system. Further, because PODS is only an allocation model, it will not show how location decisions might affect the overall level of growth in the Say Area. The MTCFCAST models are not capable of estimating the effects of capacity changes on development within the region. Conclusions Based on the above assessments, the travel -forecasting procedure is able to provide explicit estimates of three of the seven potential travel behavior changes that result from capacity increases, namely: route changes, destination changes, and mode changes. While the other four potential travel behavior changes are not susceptible to estimation from the model- ing process, some judgmental adjustments to travel volumes could be n made, based on prior evidence of the magnitude of the changes. EE "WGMFNT NSPc Page 31 TRAFFIC CONGESTION AND CAPACITY INCRF4SES is M rCFCAST Models in Practical Application While the foregoing has described the procedure that the models are capable of providing, what is done in practice is far below the capabirities of the models. Each time that the entire model system is rerun, either from trip generation or trip distribution, a considerable amount of computer time is required and several days are required to perform all of the steps in the procedure. The- auto ownership and workers per household steps in the MTCFCAST model make the process even more time-consuming and expensive than standard models in use elsewhere in the country. The result of this is that, in practice, a number of shortcuts are used in the modeling process. First, the auto ownership and workers per .household steps of the process are run only once for a given horizon year. There- fore, although theoretically the models can show how capacity increases would affect auto ownership in the Say Area, this capability is not exer- cised. In fact, the models are run much more like conventional models, not utilizing the `upward pass" capability between mode choice and trip distribution, but running these models in the conventional sequence from trip distribution to mode choice. • Second, when MTC planners examine aitemative capacity additions to the transportation system, the models are not rerun, to estimate the impacts on destinations and mode shares. Performing several iterations of the models from trip distribution through assignment, and readjusting the speeds on the network after running each iteration, is considered too expensive and time-consuming and is not performed. In looking at the impacts of alterna- tive capacity additions, the models are only rerun to look at the assignment of trips to the network for different projects, with no rerunning of mode choice or trip distribution. Also, a procedure for changing travel times on the highway and transit networks rapidly is not available and poses some difficulties because of the need to average results from two successive assignments. This also means that a procedure would be required that could estimate the average volume on each link from two successive assignments and then compute the travel time on the link from that voi- �+ F � &PLANua G Page 32 GRO is TRAFRC CONGESTION AND CAPACITY INCREASES ume. Such a procedure would not be c0cult to create, but does not currently exist Summary of the MTCFCAST Travel g procedure Given that the MTCFCAST models contain not only the usual elements of the traveMorecasting procedure, but also contain some refinements that are not usually found in applications contexts, three conclusions can be drawn at this point. First, the MTCFCAST models offer some capabilities that other regions in the United States do not have. • Second, the models are certainly capable of providing estimates of three of the seven responses to congestion -relieving capacity increases described in the previous chapter, i.e., route changes, destination changes, and mode changes. Third, because of the way in which the models are applied, the capabilities of the models to estimate the impacts of rapacity increases are not utilized and only route changes are reflected in the results. Furthermore, the MTCFCAST models are capable of reflecting an additional change not included in the discussion of that chapter, namely a change in auto ownership. To the extent that increasing congestion degrades solo driving compared to carpooling and transit riding, the MTCFCAST models could show a decline in auto ownership. If the initial estimates from a capacity increase are, as expected, of improved solo driving times, then the MTCFCAST models contain the capability to show increasing auto ownership as a response, which in turn will reinforce the mode shift from carpooling and transit riding to solo- driving for work trips.. Also the in- creases in auto ownership will generate lower levels of shared -ride oc- cupancy for secondary worker work trips. However, this capability is not used in practice by the MTC planners. MAMGEM&ir & NO Page 33 t TRAFFIC CONGESTION AND CAPACITY INCREASES Additionally, the "upward pass" between mode choice and trip distribution contained in the work -tip estimation procedure for both. primary and secondary workers provides the capability to make a more accurate assessment of the impacts of a service4evel change on destination choices. This is because destination choice in the MTCFCAST models is a function of both highway and transit levels of service (compared to just highway levels of service in conventional models), and the model system contains the capability to adjust trip distribution as a result of both highway and transit service level changes. Again, this capability is not exercised by MTC planners. Impacts of Capacity Changes in Environmental Documents .. Introduction First, this chapter reviews procedures used by MTC and Caltrans to assess the environmental impacts of capacity increases, as shown in general methodology reports. Second, the chapter reviews a number of environ- mental documents to determine their consistency with the methodology and evidence of the impacts assessed for capacity increases. The MTC Forecasting Models Using the MTCFCAST Models to Predict Congestion and Response to Capacity Increases The normal procedure that is used by MTC to predict congestion and examine the impact of a range of congestion -relieving strategies is to apply the steps described in the preceding chapter as Phases One, Two and Three of the network construction and forecasting process. Prior to load- GEMENr &PI.MNING Page 34 GROUP El .1 TRAFFIC CONGESTION AND CAPACITY INCRF4SFS ing forecast trip tables on the 2010 network, the forecast trip tables are assigned to the base -year networks, providing an estimate of the amounts of congestion that could be expected under a `no -build' scenario. This procedure should reflect mode shifts, destination shifts, and route shifts caused by high congestion levels on primary highway routes and resulting from congestion on ail routes within a specific corridor. Assuming that there is substantial growth projected in the region over the twenty-year forecast period, and given congestion in the present system, much of the future highway system would be projected to be heavily congested. Re- flection of destination and mode changes will occur only to the extent that the MTC planners change congested and uncongested speeds on the transportation system description. The MTC analyst may also make an exogenous change by inserting revised factors for peak period duration, in order to decrease the peak levels of congestion. However, the application of this "no=build" estimation procedure generally has resulted in estimating levels of peak congestion that are so high that they will never actually occur. in the real transportation system, it is not unusual to find a ratio of volume to capacity of up to about 12 for short periods of time. (By definition, a long-term volume -to -capacity ratio in excess of 1.0 is impossible, if capacity is correctly assessed, because this would imply that one could accommodate some volume in excess of capacity on a long-term basis. However, volume -to -capacity ratios in excess of 1.0 can be obtained for short periods of time, and inevitably lead to a partial breakdown of the transportation system.) Applying the "no -build" procedure to future trip levels has produced vol- ume -to -capacity ratios in the range of 1.75 to 125 and even higher on the highway network In other words, attempting to assign the traffic estimated to be generated in the region with future growth and no increase in the capacity of the transportation system leads to gross overioading of all transportation facilities in certain corridors, to the extent that the models may attempt to assign over 12 times the amount of traffic to some facilities than they are actually capable of carrying. These volume -to -capacity ratios cannot be sustained even for short periods of time in reality and indicate simply that the forecast levels of trip making are inconsistent with the no - build transportation supply scenario. Either changes must occur in trans- A"W EMENr � Mxrp c Page 35 TRAFFIC CONGESTION AND CAPACITY INCREASES portation demand beyond those of which the models are capable of esti- mation, or the growth of the region will not occur to the level predicted by the land -use and demographics models. This no -build scenario is useful as a device to identify where the most severe shortages of capacity will be located and thereby to pinpoint where priority corridors lie for addition of capacity, but they do not represent a realistic description of any possible future. If the no -build scenario is to be used as a realistic assessment of a possible future, then it is imperative that volume -to -capacity ratios greater than about 1.5 be removed by estimating or assuming other changes to the region (lack of growth, peak - spreading, mode changes, trip chaining, etc.). If such modifications are not made to the no -build scenario, it is incorrect to use it for such pur- poses as estimating the travel delays that will occur under no -build versus some attemattve scenario that involves addition of capacity, or to estimate - the comparison of pollutant burdens from transportation sources. Following this, the Existing plus Funded and future networks are created and trips assigned as described previously. By comparing the results of the assignments of trips to these two networks to the original one, the impacts of capacity increases can be seen as reductions in the volume/ca- pacity ratios. A comparison of speeds derived from the original assign- ment of future trips to the unchanged network to the speeds derived from the new network provide the basis for statements of the speed increases that will resutt from implementing the capacity4ncreasing projects. As noted before, trip distribution is not rerun with the capacity increases in place, so that destination shifts resulting from the capacity increases are not included in the process. Documentation of the application of MTCFCAST indicates that the trip tables that are used for assignment to the network are generated once only, using data from the base year network. Thus, in common with most other urban areas in the state, and with the tacit approval of Caltrans, the abilities of the models to estimate more of the impact of capacity increases on network loading are ignored, and the only impacts that are included in the standard application are those of APPUEfl Page 36 MMIAGEMENT LIMNING GROUP • 9 7RAFFIC CONGESTION AND CAPACITY INCREASES route change and, to a very limited extent, mode shift. In many instances, Caltrans ignores the issue of mode ,shift, and uses one estimate of transit trips from each of the base and future year This is fairly common practice by Caftans staff, but is not discussed explicitly in methodology documenta- tion. Furthermore, once the future network has been loaded with future trips, subsequent changes in projects are analyzed without returning to the system modeling step. Procedures for Identifying Impacts of Capacity Increases The draft 1990-1994 Transportation Improvement Program [15] contains a chapter that explains the procedures for Air Quality Assessmem Several versions of this chapter have been reviewed. It is notable that the later versions are less dear in describing the assessment of air quality impacts of transportation projects than were the earlier versions. • in the final version of the Air Quality Assessment chapter, towards the end of the document on page 1i-10-26 [151 it becomes apparent that projects receive an automatic "beneficial" or "potentially beneficial" rating if they institute Transportation Control Measures (TCMs) in conjunction with increased capacity. Moreover, to be rated as beneficial, a project must either have no impacts, or provide mitigation of negative impacts. In contrast, a project must have both negative impacts and no transportation control measures in order to be rated as a "detrimental" project Because MTC works with project sponsors "...to ensure that all appropriate transpor- tation control measures are included in the project design and to ensure commitments to air quality mitigation measures are in place.. " 1151, pre- viously detrimental projects can be upgraded to beneficial simply by adding mitigation measures. Consequently, it can be concluded that the process is set up to assist projects to receive a beneficial rating, rather than requiring a stringent analysis of the air quality impacts of each project. Resolution No. 2107, "...establishing the criteria for review of the air quality impacts of highway projects, and the criteria for determining which pro- jects with significant adverse impacts on air quality will be considered for Mums FMF.NT f Wx4 Page 37 TRAFFIC CONGES77ON AND CAPAC17Y INCREASES ' fe delay...", adopted on October 30, 1989 and revised on December 20, 1989, has a very similar structure. Pages 5 and 6 of Attachment A of Resolution 2107 show an almost identical set of statements and criteria as the Air Quality Assessment Chapter cited above. Given this situation, whereby the inclusion of TCMs in a project will guaran- tee a beneficial or poterrtially beneficial rating, it is appropriate to examine what TCMs can be implemented as part of a project The TCMs required by the current state implementation plan are shown in Table 1. As can be seen from a brief review of Table 1, all but one of the TCMs involve transit or parking management However, Measure 4 indicates HOV lanes as a TCM, which is also the only TCM that can actually be included in a capac- ity increase project This generates a conflict. In the Air Quality Assess- ment chapter [151, HOV lanes are listed as being one of the types of capacity -addition projects that may have potential air quality impacts (page 11-10-23). Yet, provision of HOV lanes, in conjunction with other improve- ments that may have negative air quality impacts, will automatically provide a beneficial rating on the project. The issue dearly becomes one of the degree to which HOV lanes are beneficial to air quality. This is a complex issue, but there are several circumstances surrounding this that provide • some fairly dear indicators. First, in California, Caltrans established an internal policy, following the debacle of the diamond lanes on the Santa Monica Freeway in Los An- geles, that existing capacity cannot be removed in order to provide HOV lanes. Therefore, to comply with Cafirans policy, which is a requirement in order to receive any state or federal funding for a highway project, when- ever HOV lanes are provided, they must, necessarily, represent an overall increase in capacity. As has already been discussed in this document, capacity increases in a congested urban area are likely to result in in- creased trip -making and longer trips, both of which will increase Vehicle Miles of Travel (VMT). Brittle et al. [161 state '...to the extent that traffic mitigation programs lower the number of vehicle miles of travel, they will also have environmental benefits — reduced emissions and reduced (fuel) consumption...` Therefore, because adding capacity through adding HOV lanes over and above existing lanes on a facility means that VMT in- creases, such projects are, by definition, a negative impact on both emis- APPLIED �Q �. _ "AMOEMENT LANNiNG GROUP Page 38 11 02 TRAFFIC CONGESTION AND CAPACITY INCRE4SFS Table 1 List of Transportation Control Measarrs from the State Implementation Plan sions and fuel consumption. • PUED cur rjEMEMr V L4WNING Page 39 GROUP TRAFFIC CONGESTION AND CAPAC1Ty INCREASES Second, if new HOV lanes are provided in addition to a capacity increase for low occupancy vehicles (LOVs), the project has a doubled capacity and VMT4ncreasing impact Furthermore, because use of the HOV lane is dependent on the degree to which the HOV traffic moves at a faster speed than mixed -flow traffic, the addition of more LOV lanes can actually reduce the number of vehicles using HOV lanes. For the period of time that speeds on the LOV lanes are improved because of the additional capacity, the competitive position of new HOV lanes is degraded, and use of the lanes is likely to be relatively low. As a mechanism for removing some cars from the road, then, new HOV lanes will be ineffective in the short run. In the longer run, as additional trips are made on the LOV lanes and congestion reattains pre -project levels, there will be an increase in use of the HOV lanes, but for each vehicle that is removed from the LOV lanes by an occupant of a HOV, a new LOV is likely to be added to the facility. Again, VMT will continue to increase, until a new equilibrium between supply and demand is reached. This phenomenon will lead to re-creation of current congestion but affecting now a larger number of vehicles than before, because more LOV lanes are involved. This type of situation is shown up dearly by the forecasting procedures in use by MTC and others, and has been encountered recently in work in Southern California on • planning transitways. The simultaneous addition of LOV and HOV lanes was found to improve LOV speeds sufficiently in the short run that use of the HOV lanes, even with an added lane, decreased to levels below the pre -project levels, because LOVs were traveling as fast as the HOVs. There appear to be no arguments that can be offered to suggest that new HOV lanes can reduce VMT except where the demand for travel prior to providing the new HOV lane was fully satisfied. In such a case, each LOV removed from the `mixed flow" lanes by a HOV occupant represents a net decrease in vehicles in the system Cd average occupancy in the.LOV lanes is 12 persons per vehicle and average occupancy in the HOV lanes is 24 persons per vehicle, then the same number of people traveling on the HOV lanes will travel in half the number of vehicles as traveling in the LOV lanes). It is highly unlikely that such a situation W11 occur, because, if demand were fully satisfied already, there would be no incentive to use a new HOV lane and the project would not be warranted. APPLIED Page 40 MANAGEMENT LWNlNG GROUP 0 7RAFFIC CONGES710N AND CAPACITY INCREASES Finally, the MTC Contingency Plan [171 states quite plainly that Congestion Relief Projects (HB42) can be subject to delay, because of negative air quality impacts. The addition of HOV lanes, when existing LOV lanes must not be reduced in capacity, represent congestion relief in most situations within the Bay Area. This further points up the circuity of reasoning in the Air Quality Assessment chapter and Resolution 2107: a project that in- creases capacity as a congestion relief project is subject to delay as a negative air quality impact project; however,- such a project can be miti- gated to beneficial N any TCMs are included, such as the addition of HOV lanes; however, HOV lanes themselves represent a congestion -reducing strategy and are therefore subject to delay. However, since HOV lanes are a TCM, the project will not be delayed regardless of its impacts on air quality. The implication of the above discussion is that a detailed air quality impact assessment is not considered necessary as part of the environmental documentation. Rather, a project can be classified, as to its air quality impacts, simply on the basis of the nature of the project and the inclusion or not of TCMs, one of which is itself a project that can actually have negative air quality impacts. Two other issues are appropriate to consider in this topic, relating to HOV lanes and capacity increases. First, Brittle et al. [161 also state on page 2: 7ratric midganon actions are designed to reduce the number of vehicle trips, shorten trip lengths, and change the timing of trips so that fewer people will travel during the most congested parts of the day." Given this definition, it is unclear how HOV lanes become classified as traffic mitigation actions, or TCMs. First, most HOV lanes are operative only during the peak hours and in the peak direction. Therefore, they encourage HOV users to travel during the most congested parts of the day. Second, HOV lanes are often designed to have relatively few entry and exit points, compared to the mixed -flow lanes on the same freeways (except where they are created simply by restriping an existing facility). ",Mc MF °r O L�P c Page 41 TRAFFIC CONGEMN AND CAPACITY INCREASES 0 When the lanes are added other than by rest iping, there may be three to five miles between segments where transition between mixed -flow and HOV lanes can occur. Therefore, HOV lanes may often encourage long trips as opposed to short trips. Third, HOV lanes reduce vehicle miles of travel only when there is no pool of unsatisfied demand for travel, so that person trip volumes before and after addition of the HOV lane are exactly the same; or when the HOV lanes replace existing LOV lanes and the HOV lanes run below capacity', so that fewer vehicles are in operation than before creating the HOV lane. In general, the addition of HOV lanes will increase vehicle miles of travel, particularly when the system is congested, and when the HOV lane is added without taking away any mixed -flow lanes. Hence, HOV lanes appear to violate all of the conditions considered neces- sary by Brittle et al. to be classified as TCMs. Second, Caltrans indicates in its System Management Plan [18] that: "...the extent of [adding capacity] will not be adequate to prevent a deterioration in the overall levels of. seMce on Bay Area freeways and will only marginally relieve the negative impacts caused by incident and recurring congestion." (page 67) The capaclty of a mixed -flow freeway lane Is estimated to be 2,000 vehicles per lane per hour. The capacity of a HOV lane Is estimated to be about 1,600 vehicles per lane per hour. If average occupancy of the mixed -flow lane Is 1.2, then the carrying capacity of such a lane Is Z400 persons per lane per hour. _ if average occupancy of the HOV lane Is 2.5 persons per vehicle, then It an carry 4,000 persons per lane per hour. At volumes above 960 vehicles per hour, the HOV lane carries more people than the maximum capacity of the mixed -flow lane. ,wPUED "4NACEMWT G uI a Page 42 TRAFFIC CONGEST70N AND CAPACITY INCREASES They also add: "Experience has shown the effects of adding capacity alone may only temporarily relieve congestion which recurs as demand continues to build." (page 225) This leads to a question as to why Caltrans then supports capacity expan- sion as a congestion -relieving strategy. This is not addressed dearly in the Systems Management Plan. However, a further issue of importance is raised by statements in the System Management Plan concerning HOV lanes and ramp metering [181. A heavily stressed note is printed on page 91 that states: "Once the freeway system is managed using ramp meters and HOV bypass lanes, there may not be the need for HOV lanes on all sections of freeways. Sec- tions identified for HOV lanes, which- already have been metered at on -ramps, may attain LOS D (speeds in excess of 40 mph). Under these conditions, the incen- bve for rfdesharfng along tree entire route would be increased. This situation will be evaluated carefully. If HOV lanes are not needed on freeway sections, HOV lanes on freeways could be converted to mixed -flow lanes." (page 97) Thus, it appears that Caltrans would encourage the provision of HOV lanes as a TCM for a freeway project, thus permitting a D* project to be recias- sified to a B project. Subsequently, Caltrans would encourage conversion of the HOV lane, under circumstances that are not explicitly described, to a mixed -flow lane. This appears to be a loophole in the process that would permit MTC, among other agencies, to add mixed -flow lanes to freeways in the Bay Area without considering the air quality impacts of those lanes, simply by adding HOV lanes at the same time; and subsequently convert- ing the HOV lanes to mixed -flow, thereby creating even graver consequen- ces for regional air quality. • MMUGEMf.NE°r &PWYNING Page 43 GAGUP TRAFFIC CONGESTION AND CAPAC1Ty INCREASES • In summary, the entire prescribed process for assessing the air quality impacts of capacity additions to the freeway system in the Bay Area ap- pears to be riddled with loopholes that permit projects to avoid air quality impact assessment and that also open the potential for substantial degrad- ation of air quality through subsequent conversion of HOV lanes to mixed flow. All of this is done against a background in which Caltrans itself seems to admit that adding capacity is not a procedure for solving con- gestion problems. Review of Environmental Documents A number of environmental documents have been reviewed from the Bay Area. These documents represent as many of the 48 projects whose D* (potentially detrimental) rating was changed to B (beneficial) as we were able to locate. These are the documents that were identified by MTC as the basis for redesignation. In the following discussion, we have drawn conclusions about the entire group of projects, bolstered by specific ex- amples drawn from those documents that were obtained for review. The basis for review, as outlined in the previous section of this chapter, is: 1. To determine if the project is a congestion -relief project; 2 If it is a congestion -relief project, to determine how air quality assessment was performed on the project; 3. If it is a congestion -relief project, to determine what TCMs are included, if any, and whether the inclusion of TCMs was the basis for a beneficial or potentially beneficial rating; and 4. if TCMs are included as the mitigation measures that provide the basis for a beneficial rating, in how many instances are the TCMs HOV lane additions? Before looking in detail at the specific projects, there is one additional point that should be made. As indicated much earlier in this chapter, there is M� EMEn° &L4NNING Page 44 caowP TRAFFIC CONGESTION AND CAPACITY INCREASES usually -a single travel forecast made with a highway and transit network that includes all programmed projects. This forecast effectively examines the combined impacts of ail projects as part of the entire transportation system. It is deficient only insofar as the planners do not redistribute trips prior to estimating mode choice and network assignment This procedure provides one set of estimates of traffic conditions, namely those that would occur if all projects were implemented by the horizon year. Following this one forecast -of all projects, each individual project that is defined for an - environmental impact assessment may be examined in isolation. In this case, it is customary to simply reassign the trips in the no -build or Existing -plus -Funded (see page 15) assignment with the one project in place. A repeated criticism of the MTC Transportation Improve- ment Program is that it frequently provides an assessment of impacts for the isolated project, even though the project in question may be part of a series of projects affecting one facility. For example, comment 4 on Air Quality Assessment [151 (page 8) states: it "Projects should be grouped together in logical seg- ments for air quality analysis purposes; segmentation masks the full air quality impacts of a project" While MTC responds that they agree, there is no evidence that they have changed the methodology to do so. Furthermore, since the air quality assessment is generally performed superficially, by using the guidelines outlined in the preceding section for rating the impact and the results of a local assignment to estimate actual reductions in pollutants, there is in fact no real analytical air quality assessment performed. It would have been more appropriate to respond by pointing out that a full analysis of air quality impacts is not performed, so that the comment is somewhat ir- relevant to the actual methodology. In general, reviews of the documents show the following conditions to exist: 1. Some documents_ provide no evidence of any traffic modeling; 0 GM M,wAG .M Nr UP a Page 45 TRAFFIC CONGESTION AND CAPACITY INCREASES 2. The "build" and "no -build" analyses do not consider the effect of capacity (or its lack) on demand, 3. There is no evidence that volume/capacity ratios have been checked and unreasonable or impossible values removed prior to developing the findings for the analysis; and 4. There is no modeling of the effects of any TCMs to verify their effect as being sufficient to mitigate adverse impacts of capacity additions. Table 2 shows the projects for which documentation was obtained from MTC and other agencies. It represents only a small proportion of all 48 projects, but apparently also includes all of those for which documentation can be located. The table shows a total of 14 projects for which doc- umentation was obtained. Most of the documents reviewed rely on MTC forecasts or on forecasts generated by Caftrans District 4 Office. In both cases, these forecasts appear to follow the standard approach of MTC and use a Ono -build" projection to 2000, 2005, or 2010, and a 'build" projection that includes other projects, besides the one that is the subject of the environmental document. The no -build forecast frequently shows levels of travel demand that could not be sustained by the facility in question. For example, the environmental document for the 1-680 widening from I- 580 to Rudgear Road shows am. peak volumes for one direction that are on the order of 16,900 vehicles in 2010 (see Exhibit 1, attached). The a.m. peak period is normally considered to be two hours long, the facility is three lanes in each direction, and the maximum capacity of a freeway lane is 2,000 vehicles per hour per lane. The facility therefore has a capacity for the a.m. peak of 12,000 vehicles. The 2010 projected volume is clearly far in excess of capacity. From a review of the document, it appears that this volume of traffic was used in air quality modeling to estimate the pollutant burden if the project were not built. It is also the basis of deter- mining travel times on the facility, under no -build conditions, and these travel times are also used in the air quality analysis. 91 APPEND Page 46 MMIAGEMENT LtNN/NG GAOUP is i TRAFFIC CONGES77ON AND CAPAC17Y INCRFASFS Table 2 List of Eaviranmental Docments Reviewed ected`:ighway{s)':::;:.':::Prajert; ;I=680-and'.I=S&0:.::: °:°':'I=680 from I=580 to.5foncm ge.:DavrAad :... .:::.:.::I M:fibm. Santa.Rita- Road:. to:.I w :. ... to Rud ea ".Roa : :6k and' SR 24`: -:*. ''J48Q:from- Rudgear- Road. to -WiIIow:.Pass Road and Willow. Pass : Road'ta Mi=ina::VistBoulemid::";:;=:::''' ......:...:.:::....::.:::.::.::.::::::...:.:.::.:... US:IOI"::::: ::::::'::.:':>:I=280/680/'IOI: IC`to. the:De.'.la :Csui°: Blvdr!ziatble. ......... -...::.:.......:.::...... ........... . °'::'.; ` ..us. Betitai::Road�: to:::San Mateo:;;Coun :. Luie: 80 ::::;:_`.::` _ :::`:::`::::Alvarado -Niles Road. to..Davis. ::-:::: :Mission--Boulevard -to Montague. Expressway Blossom. Hill Road to Curtner Avenue, San Jose: and:=Scott°Boulevard U5=1..:and I=280 0I•...:::.<.:::::::::.::;::.:':::.:.:.._::.. ::. ' :::: ; :.. Drive to Sage Street,.. Vallejo71, :I so : ` IGdweU.Road'Interchanize APPUEC • MAMGEMENT &LANKI G Page 47 TRAFFIC CONGESTION AND CAPACITY INCRF4SES 9 Because no account is taken of the extent to which travel demand would be suppressed by the lack of capacity in the peak period, the no -build volume is too high and speeds of travel too low. Further, the project analysis concludes there will be no change in travel volumes on the facility, if the facility is widened. Rather, because the addition of a lane in each direction will increase the capacity in the peak period to 16,000 vehicles, which is just slightly below the demand level of 16,900. traffic is assumed to move faster under the "build" option, and the pollutant burden is as- sumed significantly less. Not surprisingly, the conclusion is then drawn that this project has no adverse effect on air quality, but rather will improve it. To show that the level of demand for travel is 16,900 vehicles in the peak link, peak direction for the a.m. peak is relevant for identifying the potential need for the project. However, the use of that volume for computing air quality impacts under the no -build scenario is dearly incorrect, because such a volume would not occur, nor would congested speeds be as low as projected with that volume on the existing facility. In several other of the documents listed in Table 2, the exact same proced- ure appears to have been used. Traffic volumes are not always reported in the document, so that the reasonableness or not of the no -build fore- casts cannot always be determined. However, its use in the air quality analysis seems quite clear. This can be seen, for example, in the docu- ments for Route 880 widening from Alvarado -Niles Road to Davis Street, and for US 101 widening from 280/680/101 to the De La Cruz Boule- vard/Tdmble Road Interchange. In almost every case, ramp metering and HOV lanes are considered as possible TCMs. However, because most of the documents conclude that there will be no negative air quality impacts from the capacity addition. TCMs are not required in order to obtain a B or N rating, and the recom- mendation is made consistently that these operational options should be examined after the public hearings and environmental clearances are completed. There is a minimal analysis performed of the potential impacts of HOV lanes. It is minimal in that no effort is made to model the changes to travel demand patterns resulting from addition of a HOV lane. Rather, a APPLIED Page 48 MANAGEMENT WYN/NG GAOUP TRAFFIC CONGESTION AND CAPACITY INCREASES volume of use on the HOV lane is assumed and subtracted from the LOV lanes. An estimate is made of the reduction in *vehicles that would result from the increase in vehicle occupancy, and this is used to estimate (generally negligible) changes in emissions. Each project also references the TIP in summarizing the air quality impacts. Generally, this reference indicates that, because the project is part of the TIP, and because the 71P includes TCMs, the project conforms and there are no relevant air quality impacts. Despite this statement, several docu- ments still undertake a microscale analysis for Carbon Monoxide, although this analysis is.flawed by comparing the no -build and build options with no accounting for unrealistic volume/capacity ratios and travel speeds. Conclusions The primary conclusion to be drawn from this review of the environmental documents is that almost any project that adds capacity to an existing con- gested facility will be assessed as having no negative impacts on air quality and may be considered beneficial. This situation arises because com- parison is made between an unrealistic "no -build" option and the `build" option, in which the traffic volumes and speeds in the no -build would not in fact occur, and the volumes remain generally unchanged for the build option. In addition, the only TCM whose effect is even superficially estimated is that of HOV lanes, where an oversimplified 'analysis leads to the conclusion that a slight reduction in emissions would occur if HOV lanes were used for the capacity addition, but that the effects within the accuracy of the models are undetectable. A"MGE ENT & L4WN/NG Page 49 GROUP TRAFFIC CONGESTION AND CAPACITY INCREASES References I. Lowry, I.S., 'Planning for Urban Sprawl,' Transportation Research Board Special Report No. 220, Washington, D.C., 1988, p.302. 2. AASHTO, A Manual on User Benefit Analysis of Highway and Bus - Transit Improvements — 1977, American Association of State Highway and Transportation Officials, Washington, D.C. 1978. 3. Zahavi, Y., 'The. Effects of Transportation Systems on Spatial Distribution of Population and Jobs,' presented at the Joint Nation- al Meeting of the Operations Research Society and Institute of Management Sciences, Miami, Florida, November, 1976. 4. Zahavi, Y. Travel Characteristics In Cities of Developed and Develop- ing Countries, Staff Working Paper #230, World Bank, Washington, D.C., March 1976. S. Reno, A.T., 'Personal Mobility in the United States,' Transportation Research Board Special Report No. 220, Washington, D.C.,1968, p.374. 6. Remak, R. and S. Rosenbloom, Peak Period Traffic Congestion, Transportation Research Board Special Report 169, 1976, p.62. 7. Metropolitan Transportation Commission, BART in the San Francisco Bay Area. The Final Report of the BART Impact Program, U.S. Depart- ment of Transportation, Washington, D.C., September 1979. 8. Sherret, A., 'BARrs First Five Years: Transportation and Travel Impacts. Interpretive Summary of the Final Report, U.S. Department of Transportation, Washington, D.C., September 1979. ,�PauED MMIAGEMEKTONIN G Page 50 • C TRAFFIC CONGESTION AND CAPACITY INCREASES 9. Orski, C.K, 'A Realistic Appraisal of Traffic Congestion,' Urban Land, Volume 48, No. 10, October 1989, page 34. 10. Cambridge Systematics, Inc., Travel Model Development Project Phase 2 Final Report: Volume 2: Detailed Model Descriptions, Report to Metropolitan Transportation Commission, Berkeley, CA, June 1980. 11. Cambridge Systematics, Inc., Travel Model Development Project Phase 2 Final Report Volume 1: Summary Report, Report to Metro- politan Transportation Commission, Berkeley, CA, June 1980. 12.Cambridge Systematics, Inc., Travel Model Development Project Phase 2 Final Report Volume 3: MTCFCAST Users Guide, Report to Metropolitan Transportation Commission, Berkeley, CA, June 1980. 13. Metropolitan Transportation Commission, 'A Disaggregate Work -Trip Mode Choice Model forAggregate Forecasting (Model7io', Technical Summary, Travel Model Update with 1980/81 Data Base, MTC, Oakland, April 1988. 14. Kollo, H.P.H. and C.L Purvis, 'Regional Travel Forecasting Model System for the San Francisco. Bay Area•, Metropolitan Transportation Commission, Oakland, CA, July 1988. 1 S. Metropolitan Transportation Commission, 1990-94 Transportation Improvement Program for the Nine -County San Francisco Bay Area: Volume 11: Highway and Other Elements, MTC, Oakland, CA (Draft, undated). 16. Brittle, C. et al. Traffic Mitigation Reference Guide, Metropolitan Transportation Commission, Oakland, CA, December 1984, page 2. 17.Association of Bay Area Governments, 1982 Bay Area Air Quality Plan, Bay Area Air Quality Management District, Metropolitan Transportation Commission, December 1983, page II-2. IIPPUED AUNAg GEMENT WVNlNG Page 51 GROUP TRAFFIC CONGESTION AND CAPACny INCREASES 0 18. Callfomia Department of Transportation, State Highway System Management Plan District 4, Prepared by DWtict 4 Transportation Planning Branch, System Planning, December 1988. APPUED "cE"« �" c Page 52 ;t I A A A O O O • O O O 7 .`. 1 w • w • w 1 1 a N O ; r ! ! 10 100 10 1•e r r 1e0 b A i 1 ;;otiaaao3aaa�a N I w w III w N 0 f+• A O A left 1 w w w • T P ? A w • w a w • w w O 1 ft l O G O O O O Q s I o 40 P4 N w r a $ u •� t o a a A o o e r N n� /ww i 0 O O • O O O • A A A • 1 1 t 0 O O �+ I N • O A. 1•O I • le • • • •• d Y ! ! ! A r r r w r- w r- n a r r r r r r r r r r r r r r r r- I t •t x N. 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W f0 • I I e O a w � lid• O Ipo W u .% O qQ .Wi 6 K W C O a w S = iC 4 :. :r •: �• _ u o o Iz 4 6 O 6i11 rl O W YJt YA1 J iL n 0 TC Rejects Latestflan ;To Widen 1=80 in East Bay is,v M=loW Ch?VOWe 8tgp"Wi wil Worried that new freeway con struction will jeopardize air quali- ty, a regional transportation pan. el yesterday rejected the state's latest plan to widen Interstate 90 in the East Bay. The panel urged the state De- J partment of Transportation to ex- pand the project's car. pool lanes and encourage commuters along the Bay's eastern shore to take BART and buses to meet air pollu. tion standards. The region is under court order to reduce automobile emissions. "Tidy worry is that if they pur- sue this project, there will be no project at all," said William Hein, executive director of the Metropol• itan Transportation Commission, which includes representatives from each of the Bay Area's nine counties. The $282 million Caltrans plan calls for adding new lanes and re- constructing several exits and in- terchanges along the heavily con- gested route between the Bay Bridge and the Carquinez Bridge. The 20-mile route is frequently the site of lengthy traffic jams. But the panel is concerned that Caltrans has not done enough to encourage car pooling and transit use along the busy corridor. They called for a continuous car pool lane — in which only vehi- cles with three or more occupants would be allowed — between the Bay Bridge and Rodeo. In addition, they called on the state to provide "park and ride" lots along the route and easier access for buses. 7�: The panel warned that without ,be revisions, it would lobby .against the project before the Cali- --,. fornia Transportation Commis- sion, which finances all state trans. portation projects. Caltrans representatives were not available for comment. A 4 Sian ,$randsco (l;tlronicle * * * * * SATURDAY, NOVEMUR 10, I M EXHIBIT 3 DENNIS L. KELLY 4/20/90 :OASTAL DOLPHIN SURVEY PROJECT c Orange Coast College e • 2701 Fairview Road Costa Mesa, CA 9262 / HISTORY OF THE COASTAL DOLPHIN SURVEY PROJECT The Coastal Dolphin Survey Project (CDSP) was organized and initiated at Orange Coast College, Costa Mesa, California in 1978. It was the official research project of the Marine Science Department and the Director was (and is) Dennis L. Kelly, Professor of Marine Biology. The goals and objectives of CDSP were patterened after those of the American Cetacean Society/National Organization. Specifically these included research, education, and conser-' vation. Unlike the American Cetacean Society, CDSP focused these objectives soley in regards to the population dynamics, biology, ecology, and concerva- tion of the Pacific coastal bottlenose dolphin (Tursiops truncatus). To ob- tain information and'data about this unique species of dolphin and determine whether this population was resident to the coast of Orange County and/or Southern California, many methods have been employed over the years. The project has conducted coastal boat surveys on a monthly basis sfnee a federal permit was obtained from the'National Marine Fisheries Service. Along with sighting data (location, number of dolphins, direction of movement, behavior, number of calves present, time, and date) photographs were taken of the dorsal fins of the dolphins. This led to the development of a catalogue of identif- able dorsal fins and, ultimately, estimations of the population size and • determination of the resident status of the dolphins. This work occured since the projects inception and continues today. Beginning in 1982, the project intitiated an effort to assist the Nat- ional Marine Fisheries Service with the southern California Marine Mammal Stranding Network. To accomplish this the director 'was "authorized" to inspect stranded dolphins, sea lions, whales, and other marine mammals at the stranding scene, fill out and submit a stranding report, and determine if the unfortunate animal was to be removed from the beach to a lab or other location for further analysis and/or necropsy (a dissection to determine the cause of death). The project director also was able to arrange, periodically, to have tissues from -the deceased animal analysed for contaminants and prepared for histological analysis (slides made of the tissues of various organs prepared for microscopic analysis). Over the years since this effort was begun, dozens of sea lions, seals, dolphins, whales, and even a -couple of sea otters have been processed. All of this data is now part of the federal record for this coast and the marine mammal populations that inhabit or use it. In 1987 the project developed a new direction when Educational Outreach was created. Trained Orange Coast College students were organized to deliever free lectures about the coastal dolphin population to schools, adult social groups and clubs, boating organizations, and other interested parties. Led by Mrs. Donna Wirfs, Educational Outreach has, since inception, reached and informed -tens of thousands of Orange County residents with the message about the dolphins. In 1988 the CDSP"began publishing a quarterly newsletter with articles • and information about the project and the dolphin population, that is distri-buted to citizens who subscribe to the newsletter service. This beautiful five to ten page, glossy, newsletter has been a terrific conduit of information to EXHIBIT 4 (2) the citizens of Orange County and elsewhere, with regards to the dolphins biology and ecology. During that same year the project undertook another new direction with the • creation of Dolphin Mass Sighting Day (now referred to as "Day of the Dolphin" and co -sponsored by the American Cetacean Society/Orange County Chapter). This led to citizen -involved research when citizens gathered for an informal introduction to the CDSP, a lecture on methods for sighting and recording dulphin observations, assignment to a predetermined sighting station (pier, jetty, beach, or cliff), and, ultimately, direct observation of the dolphins. On saturday mornings four times each year the citizen sighters observe and record at their stations between the hours of 10:00 and 12:00. Afterwards they meet at a specific location and turn in their sightings forms. Reports on the results of these mass sighting efforts are subsequently prepared and distributed. Since inception this study has involved thousands of citizens in Calif- ornia and has resulted in increased awareness of the dolphins presence coastally. The CDSP is currently working on the creation of a Coastal Dolphin Museum Exhibit with the Natural History Foundation of Orange County. Eventually, thousands of people each year will enjoy a hands-on, interactive exhibit about the coastal dolphins with an exciting center piece. The exhibit will be built around a full-sized,.computerized,- interactive dolphin model which will look and act like a living dolphin. But this special dolphin will lead people into a fascinating educational display that will stimulate their minds and motivate them to learn more about the resident dolphins that share the coastal habitat. At Orange Coast College, in 1985, a student club was formed. The Marine Mammal Research Group is composed of students who have taken one or many of the marine science classes at the college and wish to dive deeper into the informational world of marine mammelogy. The students in this campus club assist the director of CDSP in both the research and educational, as well as conservational efforts of the project and have several independent research projects of their own. Besides taking classes and assisting • with the research, students in the club visit and tour Sea World and at times study there: CDSP collaborates and cooperates with other scientific investigators, research projects, local, state, and federal agencies, as well as other marine related conservation groups. Since 1983 CDSP, for instance, has worked closely with Dr. R.H.DeFran of San Diego State University and his Cetacean Behavior Laboratory teams. The director of CDSP has published and co-authored many public magazine articles about the coastal dolphins, authored and co-authored several scientific papers, addressed scientific societies, and advised and consulted with the print and broadcast media on many occasions. The project currently has no paid employees, but depends on volunter help for all of its functions. To raise money to offset the costs of supplies, boat time, fuel, film, film development, equipment, printing, travel, and miscellaneous -expenses the project offers identified dolphins, from the catalogue, for adoption by citizens for $25, sells a beautiful Museum Proof artists print,"Free Spirit",(depicting in color a female dolphin and her calf swimming underwater) by the famous Laguna Beach artist Peter Paul Ott for $100, and accepts donations of cash, equipment, and property from local citizens. The yearly budget for the project has averaged between $3000 and $7000 since.1987. Currently the project is designated as tax exempt and has an IRS number of,identification through its affiliation with the Orange Coast College Foundation. In 1990 CDSP organized and met with a Citizens Advisory Committee composed of twently-five members of the local business, government, artistic, scientific, educational, and conservation community. Through the Citizens Advisory Committee the project receives valuable advise and evaluation, as well as good ideas and constructive criticism, of current projects and future plans. The Citizens Advisory Committee meets on a 0 7 (3) quarterly basis and has been a remarkable asset to CDSP. In 1985 CDSP helped fund and produce a 23 minute documentary video about the project which was titled; "Dolphins of the Orange Coast The video won awards both locally and nationally and was aired on network and cable television. The video is sold by the project, to interested parties, to raise additional funds to offset the research costs. Citizens and students interested in discovering more about marine mammals or CDSP are encouragedto write the director at the address listed below or call either of the two telephone numbers indicated. Students wishing to enroll at Orange Coast College will be sent brochures about the Marine Science Department and the classes offered at O.C.C.. Scientists and other investigators interested in the discoveries and publications of CDSP are invited to request a list of publications and may purchase copies of those publications for a nominal fee. In the future CDSP will be investigating new and exciting research possibilities for increasing our knowledge of the coastal dolphin popuaition as well as other marine mammals and sea life that inhabit the waters of Orange County. The project and the director will make every effort to represent the dolphin populations' needs, ecology, and problems whenever and where -ever decisions are being made that may affect this population. In all cases and at all times the project operates under the philosophy that the best research and investigation results from efforts that are as non -intrusive into the dolphins lives as possible and reasonable under the existing conditions. If you can support this unique exploration into the world of the dolphin, please do so. These are the last large mammals left in Orange County that are easily accessable by humans on a daily basis. They live along our coast, they swim in the same waters we swim in, they eat the same fish that we eat. They are intelligent beings and they, at times, have rescued people who were in danger of drowning. They carry very high levels of several pollutants in their bodies, that have biologically magnified up their ocean food chain as a result of past dumping of toxic pollutants in sewage effluent and from runoff via streams and rivers. They are worthy of our consideration, respect, concern, love, and attention. They are beautiful to watch as they surf the curling waves just off the sandy beaches that grace the coastline of southern California. They are long-lived and excellent sentinels of the quality of the nearshore marine environment. When they die we should be treating those deaths exactly the way we react (scientifically) when humans die along our coast. What will you do to assure them a future with us? For more information write: Dennis L. Kelly, Professor Marine Science Department and Director - Coastal Dolphin Orange Coast College 2701 Fairview Rd. Costa Mesa, CA. 92628 of Marine Biology - Survey Project Or Telephone (714) 432 -5564 or 432-5546 (4) DISCOVERIES CONCERNING THE BIOLOGY AND ECOLOGY OF COASTAL BOTTLENOSE DOLPHIN (TURSIOPS TRUNCATUS) IN SOUTHERN CALIFORNIA AND ALONG THE COAST OF ORANGE COUNTY, CALIFORNIA. ANIMAL INFORMATION: Length - up to 13 feet long (3 meters) Weight - up to 800 lbs (385 kg; C 1 1' h 0 or - I t gray to dark blackish gray Longevity - 44 + 5 years Dispositon - curious, intelligent, social, friendly, playful Size at birth - 2.5 feet (1 meter) Gestation - 10 months Pod (group) size - 1 to 40, averages 20, usually composed of older females, juvenile males and females, calves. Adult males often travel singly or in small groups. Distribution - entire coast of southern California from Mexican border to Monterey Bay, Central California. Most of population occurs from Mexican Border to Palos Verdes Peninsula. Many dolphins travel south of border along northwest coast of Baja California several hundred miles south. Population size - overall southern California : more than 500, Orange County : 40 to over 100 on any day. Pod membership is very fluid and individual dolphins appear to move throughout the range of the entire population. is Food: many species of coastal fishes and invertebrates including: White Croaker, Queenfish, bass, midshipman, turbot, sole, and small halibut, anchovy, and topsmelt. Octopus, clams, small shrimp, and many others. Dolphins have a wide range of dietary preferences. Behavior - migrate up and down the coast from -"core" feeding areas (usually sandy bottom areas) to other core deeding areas. Do not spend a lot of time in and around kelpbeds, rocky bottom areas, or within harbors or bays with lots of boat ;, a• traffic. Surf when waves are sufficient: Mill, play with each other, lots of sexual behavior and dominance ' interactions, occasionally approach human.swimmers or surfers. Love to ride the bow wake of nearby boats Pollutants and Problems: Contaminants - DDT (insecticide) and PCB (industrial toxic chemical) are both found in high concentrations in these dolphins tissues. Blubber levels have been recorded at nearly 3000 parts per million (it is illegal to sell ediole tisn to people with more than 5 parts per million). Habitat Loss due to coastal development. Entanglement in gill nets and fish;rg gear. Preyed upon by sharks and killer whales. Collison with boats and debri. ingestion of plastic trash. MEMOIRS OF THE NATURAL HISTORY FOUNDATION �0, OF ORANGE COUNTY; VOLUME 3 0` •1w ENDANGERED- WILDLIFE AND HABITATS IN SOUTHERN CALIFORNIA Edited by Peter J. Bryant and Janet Remington Published by the Natural History Foundation of Orange County 0 zff� ,& THE POPULATION BIOLOGY OF THE BOTTLENOSE DOLPHIN ALONG THE COAST OF ORANGE COUNTY, SOUTHERN CALIFORNIA by Dennis L. Kelly Professor of Marine Biology Orange Coast College Costa Mesa, California ABSTRACT A two-part study was conducted between 1982 and 1986 on the population biology of the bot- tlenose dolphin (Tursiops truncates) along the coast of Orange County, Southern California (1) Thirty five photographic surveys covered a coastal strip from Anaheim Bay in the north to San Onofre State Beach in the south. From 581 sight- ings of individuals, 89 dolphins were photographi- cally identified. We estimate those 89 to be approximately 65% of the total population, put- ting the estimated total at 137. This is a far larger population of bottlenose dolphins using the Orange County coast than has been previously documented or assumed. Of this population, 6.9% were calves. There was no indication of a home range within the dolphin community nor of fidelity of any individual to any specific part of the study area. The greatest numbers of sightings, however, were clustered at the north and far south ends of the study area, and we believe they represent sig- nificant habitat to the coastal dolphins. (2) Six dead bottlenose dolphins stranded on local beaches were necropsied and found to have suf- fered multiple pathologies, and DDT and PCB levels in all tissues analyzed (five dolphins) were very high compared to those in previous studies of offshore dolphin species. INTRODUCTION The literature contains numerous descriptions of the biology and ecology of the Pacific bot- 65 tlenose dolphin (Tursiops duncatus) from the coast of Southern California and northern Baja California, Mexico (Scammon,1874; Norris and Prescott, 1961; Dohl et al., 1978; Orr, 1963 and 1976; O'Shea et al., 1980; Walker, 1981; Kelly, 1983; Hansen,1990; Defran,1995; and Shane et al.,1986). There is documentation of extended travel by coastal bottlenose dolphins. Wells et al. (1990) reported that five individuals from Hansen's 1990 sample along the Sad Diego- coast were sighted 750 km to the north in the coastal waters near Monterey. Dolphins seen in Orange County have been identified as far south as Ensenada, Baja California Norte, Mexico (Defran et al, in press). From boat surveys and photo -identification, Kelly (1983) identified 60 dolphins off the Orange County coast. Along the northern coast of San Diego County, Hansen (1983) estimated a popula- tion of 175 to 250 dolphins, based on a count of 118 identified individuals. Defran et aL (1995) suggested that coastal movement rather than local residency is characteristic of this open coastline population. Information on the long-term effed that con- taminants have had and will have on the coastal bottlenose dolphin population is important to any attempt to understand the population biology and ecology of this species. Shafer et aL wrote is 1%5: "Since these animals are long-lived and many feed high in the food web, they are most likely to show chronic effects from the accumulation of organic contaminants... and are therefore the most likely candidates for study in our effort to understand the long-term effects of exposure to contaminants in the natural environment." The current research was conducted in col- laboration with Dr. R.H. Defran and personnel of the Cetacean Behavior Laboratory at San Diego State University. It involved extensive observa- tions north of Hansen's study area and made use of a new technology developed by Dr. Defray for identifying animals. The goals of this research were to determine 1) population parameters: group size, composi- tion (calf proportion), and coastal density 2) uses of the habitat, and 3) the organochlorine content of organs and tissues collected from dead, beach -stranded in- dividuals. METHODS Study Area The term "study area" refers to the coast of Orange County from Anaheim Bay, in the north (330 44' 00" north), to San Onofre State Beach, in the south (32' 20' 00" north), and offshore to a distance of 2 nautical miles from the beach (Figure 1). Survey Procedure All surveys were done from shipboard, usually one of two 23-foot Seacraft (inboards). 1) Complete Surveys. For complete surveys we traveled, first, 50 to 100 m beyond the surf -line at Newport Harbor, and then north until the team spotted a group of dolphins. At 100 to 200 m from the pod, the boat was stopped for 5 to 10 minutes. The team recorded the time and location, scanned the coast above and below the pod to determine if other dolphins were near, and began the count. At the same time the principal investigator noted behavior within the pod -- feeding, playing, mill- ing, traveling, mating -- and made a judgment as to whether closer contact would harass the dol- phins severely, moderately, or not at all. The boat was maneuvered to pass on the ocean side of the dolphins at slow, continual speed and at a distance of 10 to 20 m. During this initial pass, part of the shipboard team attempted to take close-up photographs of each dolphin's dorsal fin, while other team members counted admits and calves. (A calf was defined as an animal estimated to be one half the length or less of an adult, that swam next to an adult so as to be touching it at most times, and that was always accompanied by an adult during the course of the observation.) Contact with the animals was maintained until photographic and other census work was com- pleted. Then we left the pod and resumed the search, continuing up the coast as far north as Anaheim Bay, then south to San Onofre. 2) Partial Surveys. Partial surveys covered either the northern portion of the study area (Newport Bay to Anaheim Bay) or the southern portion (Newport to south San Onofre State Beach). 86 Animal Identification and Census by Donal Fin Analysis The majority of our photographs were taken with a Nikkromat 35 mm SLR camera with a Vnitar 80-280 mm zoom lens of F 23. We took most with a Kodaehrome 64-slide film. Since Dr. Defran prefers to work directly with developed negatives, we switched to Tri-X black -and -white print film in the last year of the research. All dolphin photographs (black -and -white nega- tives and color slides) were sent to Dr. De&an's laboratory, where, by analysis of the natural varia- tions (notches) that develop with time in the dol- phin dorsal fin, coded identifications could be established for all dolphins with two or more 6n notches. According to Dr. Defran, ibis technique is simple and easily learned by laboratory person- nel; it reliably identifies dolphins as resights or new additions to the catalog, in many cases even after new notches appear (Defran, 1988); and it permits laboratories to exchange data on dorsal fins inexpensively. A slide of each dorsal fin photographed is projected and enlarged to fill a 10 x 17 cm frame drawn on white paper, and the contours of the fin are traced. As shown in Figure 2, the top point of 0 • '040 N Seal Beach .Anaheim Boy 33030'N 'turfside Beach Chico Beach Huntington Beach Newpp.t Beach .5 Km Crystal Cove Beach Pacific Ocean Laguna Beach ... 4. .Aliso Beach 1800,w Orange County California /117050'W•Dona Point oheny Beach Capistrano Beach N Son Clemente Son Onof re Beach FIGURE 1. The study area. 4 87 1 the two largest notches are labeled A (top) and B (bottom). The identification code for each dol- phin, then, is the ratio of the distance between A and B to the distance from B to the top of the fin. Because it is a relative measure, this dorsal ratio is unaffected by the size of the fin in photographs or enlargements, or even by severe cases of paral- lax. Census Data The cetacean behavior tab recorded and filed the fin identification for each dolphin and counted 1) the total number of dolphins photographed 2) the total number of resightings, and 3) the total number of dolphins new to the exist- ing catalog. 10 Carcass Studies With the aid of lifeguards and citizens, we estab- lished a network for locating dead, beach - stranded marine mammals and set up a necropsy laboratory at Orange Coast College. Carcasses were weighed, measured and necropsied. Also, blubber, liver, muscle, brain and kidney tissues were analyzed for DDT and PCB levels. RESULTS We planned and attempted 45 boat surveys (Table 1). Ten were cancelled due to bad weather or engine probiems, and 35 were actuaby cm - ducted. Of the 35, 19 were surveys of the entire area,13 covered only the northern portions of the study area, and three covered the southern por- tion. We spotted no dolphins in eight of the 35 surveys. One was of the entire study area, and TOP 19MM Ao%n 44mm Dorsal A to B Ratio ea` B to Top FIGURE 2. Measurement of the dorsal ratio. 6s • 19 '1 TABLE 1. Boat Surveys 1982 -1985 Survey No. Date of Dolphins No. No. Dolphins: Adults Calves Behaviors 1 12/21/82 Huntington City Beach- 20-25 2 M lin& feeding, foraging Bolsa Chica State Beach - 2 3 12/29/82 5/12/83 San Onofre State Beach Bolsa Chica State Beach 25-30 q milling, feeding, foraging 4• 7/18/83 Bolsa Chica State Beach 6-7 6 1 traveling 4' 7/18l83 Newport Beach 25-30 traveling traveling 5 6 7/24/83 Huntington State Beach 20-25 traveling 7 7/29/83 1/31/83 Newport Beach San Onofre State Beach 40-45 traveling . 8 9 8/3/83 V183 Bolsa Chica State Beach 30-35 25-30 4 foraging, feeding �& foraging, feeding 10 11/14/83 Bolsa Chica State Beach none 25.30 milling, foraging, feeding 11 11/21/83 seen none seen 0 - 12 13 11/30/83 12/04/83 Huntington City Beach San Clemente State Beach 20-25 4 -- milling, foraging, feeding 14 15 2Z/13/83 3/12/84 Newport t gtonn State Beach Huntington 5 25.30 traveling foraging,feeding 16 4/09/84 none seen 6 0 1 milling 17 18 4/1&S4 4/2 A4 Huntington State Beach Huntington State Beach 25.30 2 for f �' Ong 19 5/14/84 none seen 35-40 0 play, foraging, feeding 20 21 6/26/84 7/03/84 Bolsa Cbica State Beach 25-30 5 - milling+ Play 22 7/17/84 none seen Irvine Coast 0 8 23 9/29/84 Bolsa Chica State Beach 1 5 traveling traveling 24 10/28/84 Huntington State Beach 5� feeding 25 11/11/84 none seen 0 26 27 11/18/84 San Onofre State Beach 2 traveling 28 11/19/84 2/C12/ 184 Bolsa Chica State Beach 15-0 2 ply, milting 29 2/23/85 San Onofre State Beach San Onofre State Beach 5 8-20 milling 30 3✓16/85 none seen 0 2 foraging' feeding 31 32 8/13/85 9AMM San Onofre State Beach Bolo Chica State 5each 25-30 � play, ln& feeding 33 9/15/85 none en se 0 30 2 play, feeding 34 35 10/ti6/85 lVlSI85 Newport -Point Loma Beaches Doheney State Beach 32.39 Play, traveling 7 traveling $separate pods sighted the same day fti . . seven were of either _the northern or southern portions. There were seven spring surveys (March, April May),10 in summer (June, July, August),11 in fall (September, October and November) and seven in winter (December, January, February). Number of Pods and Distribution We observed 28 separate pods between 1982 and 1985. Eighteen pod sightings occurred at the northern end of the study area: off Bolsa Chica State Beach, south Huntington State Beach, and north Newport State Beach. Seven took place at the far south end of the study area, off San Onofre State Beach. The three remaining sightings oc- curred between Newport and San Onofre State Beach. On only one survey trip did we sight more than one pod; on our fourth trip we spotted two. Pod Sizes Pod sizes ranged from six to 42 dolphins, with a median of 21. There were 22 or more animals in 14 of the groups. We saw only one significantly larger pod, of 42 dolphins. The most common size was between 20 and 30 animals. Pods of six to eight were so rare that we usually followed for some time to see if they regrouped with other dolphins. Individuals Sighted and Identified We sighted a total of 581 individual dolphins, and from all photos, 89 dolphins were identified. ResIghtings Animals photographed more than once were sighted an average of fewer than three times. Of the 89 identified animals, 59 (66%) were photographed once, 21 twice, and 5 three or more times. The record was of a dolphin photographed five times (Table 2). Ell Calves The proportion of calves to the whole group, summarized by month and across years, was 6.90/c. We generally observed and recorded two to four calves in each pod. On two occasions we observed what appeared to be dolphin births. Beach -stranding recoveries, necropsies, and tissue analysis Between 1983 and 1986, ten bottlenose dolphins were examined after stranding on Orange County beaches (Table 3). These included one adult female, six juvenile to adult males, one neonate female, one neonate of undetermined sex, and one dolphin whose sex and age could not be deter- mined because of advanced decomposition. We performed necropsies on six of the stranded dolphins and removed tissue for chemical analysis. Some bore injuries and all bore multiple pathologies that included stomach ulcers, parasitic infestations, enlarged lymph nodes, ver- miniferous pneumonia, infected organs, infected wounds, cysts, and tumors. One, a male juvenile, showed signs of having been entangled and sub- sequently drowned in a gill net: his epidermis bore net cuts, his tail had been sliced off at the peduncle, and his trachea contained frothy foam. All tissue samples (including blubber, muscle, Byer, kidney, and brain tissue) revealed high levels of the pesticide DDT (range 150 to 1,922 ppm; average for blubber 854 ppm) and of the industrial chemical PCB (range 3.1 to 265 ppm; average for blubber 105 ppm). DISCUSSION Distribution Dolphin pods were observed throughout the study area, but never more than 1 km offshore. On most occasions, the dolphins of a pod were spread out over SW to 1,000 m of coastline in several subgroups that frequently coalesced and then broke apart in a fluid and unpredictable manner. It was not uncommon for one subgroup to swim • r :• TABLE 2. Dolphins resighted off the Orange County coast, and the intervais between Orange County sightings. Additional sightings of these dolphins off the San Diego coast are listed in parenthesis and italics, Date 1D Sighted Location Interval Date ID Sighted Location Iotmal 003 5/21/83 11/14/83 Bolsa Chica Newport Beach 6 mo 055 (7/20/82 San Dk8o coast) (4110185 San Diego coast) 11/30/83 Huntington Beach 4/22/84 Huntington Beach 4.7 mo 004 (10123181 San Diego coast) (6123185 -San Diego coast) 8/7/85 10/6/85 Bolsa Chica Newport Beach 2 057 (812182 San Diego coast) 12/15/85 Doheney Beach mo 2.3 mo 8/3/83 10/6/85 Bolsa Chica Newport Beach 2 yr 2 mo 017 (7127182 Son Diego Coast) (4-25-86 San Diego coast) 7/31/83 8/3/83 San Onofre Bolsa Chica 3 days 065 (7127182 7/29/83 San Diego coast) (3117184 Son Diego coast) &WM Newport Beach Bolsa Chica 5 days (813184 (5/1/85 San Diego coast) San Diego coast) (11116185 San Dia8o coast) (419188 San Diego coast) 021 (812182 7/18/83 San Diego coast) Newport Beach 079 (10123181 'San Diego coast) 7/31/83 San Onofre 13 days MM (11116183 Bolsa Chica San Diego coact) 8/.I/83 (6110184 Bolsa Chica San Diego coast) 3 days 2rAW San Onofre 1A yr (7113184 San Diego coast) (6123185 (6126185 San DsW coast) San DkV coast) (2123186 San Diego coast) (4/9/86 San Diego coast) 090 (3124184 San Diep coast) 040 (3124184 San Diego coast) 4/2W (218185 Huntington Beach San Diego coast) 4/2?184 Huntington Beach 1016185 Newport Beach LS yr 12/W (513186 San Onofre San Diego coast) 73 mo (12119185 co=) (617186 San Diego coast) (4111186 San Diego coast) 047 (6/18/82 San Diego coast) 095 (8130182 4j30/83 Son Diego coast) Huntington Beach 12/29/82 San Onofre W7/83 Bolsa Chico 3 mo 7/18/83 Newport Beach 6A mo 4/1W San Onofre 7.4 mo 048 (1114182 Son Diego coast) (7113184 (6123185 San Diego coact) San Diego coast) (8124184 San Diego coast) 1Z2M San Onofre 2/73/85 San Onofre 2.7 mo (7131185 San Diego coast) (1116185 San Diego coast) (4125186 San Diego coast) (continued) ii1 TABLE 2 (continued). Date Date ID Sighted Location Interval ID Sighted Location Interval 100 (11120181 San Diego coast) 187 1 V30183 Huntington Beach 12/13/83 Newport Beach (1112184 San Diego coast) (3117184 San Diego coast) 10/6/85 Newport Beach 1 yr 10 mo (3124184 San Diego coast) 4/18/84 Huntington Beach 4 mo 209 (319184 San Diego coast) 4/22/84 Huntington Beach 4 days 4/18/84 Huntington Beach 10/28/84 Huntington Beach 6 mo 4/22194 Huntington Beach 4 days 1212/84 San Onofre 1 mo (3116185 San Diego coast) (2127185 San Diego coast) (7124185 San Diego coast) 216 (2115185 San Diego coast) (7131185 San Diego coast) 2/23/85 San Onofre 106 (11/4/82 San Diego coast) 10/6/85 Newport Beach 7.5 mo 7/3LW San Onofre 217 7/M Newport Beach 8/3/83 Bolsa Chica 3 days 8/3/83 Bolsa Chica 1 mo (3116184 San Diego coast) 9/6/83 Bolsa Chica 1 mo (518185 San Diego coast) (2115185 San Diego coast) (1116185 San Diego coast) (5/26/86 San Diego coast) 282 7/3LW San Onofre 8I7/83 Bolsa Chica 1 wk 108 (1/4/83 San Diego coast) 7/3LW San Onofre 295 g/3/g3 god Chica (6118184 San Diego toast) 10/60 Newport Beach 2 yr 2 mo 12115/85 Bolsa Chica 2 yr 5 mo 297 817/83 Bolsa Chica 116 (10123181 San Diego coast) 10/28184 Huntington Beach 1 yr 2 mo 12/13/83 Newport Beach 12/15/85 Doheney Beach 2 yr 291 4/18/84 Huntington Beach 121 (9/28/81 San Diego coast) 9/8/85 Bolsa Chica i yr 4 mo 4/22/84 Huntington Beach 299 1Qt6/85 Newport Beach 22385 San Onofre 10 mo IV15185 Doheney Beach 23 mo 127 8aW Boba Chica W7183 Bolsa Chica 4 days far away from the majority of dolphins, disappear for 30 to 40 minutes, and subsequently rejoin the larger group. Distribution of the dolphins in the study area did not appear random; the dolphins showed a definite bias for specific locations. Dolphin pods were found more frequently in the northern part 17 of the study area than in any other place; 64% of the sightings were between north Newport Beach and Bolsa Chica State Beach. Most of the remain - ins sightings, 25% of the total, occurred at the southern extreme in an area, significantly, with similar topography: shallow, sandy -bottomed, low relief beach with few or no rocky headlands, off- shore rocky reefs, or offshore submarine canyons. TABLE 3. Tursiops truncatus Strandina Data 1983 - 86, ID No., Sex, Date, Location, Necropsy Tbsue Analysis (ppm) Length, Weight Decomposition Results DDT PCB DK8318 5/5/83 stomach ulcer, blubber: 1,933 128 male Surfside Beach parasites, emaciated) muscle2: 20 0.8 266 cm, wt. na decomp. slight DK8323 8/1 V83 na na na sex undeterm. Newport Beach 89 cm, wt. na decomp. slight DK8324 9/15/83 na na na sex undeterm. Newport Beach 240 cm, wt. na decomp. slight DK8325 9/29/83 stomach parasite, muscle: 17.5 02 male Newport Beach emaciated3 liver: 121 23 289 cm, wt. na decomp. moderate DK8329 12I27/83 na as na female Crystal Cove 259 cm, wt. na decomp. advanced DK8411 10/25/85 chronic enteritis, blubber. 400 27 male Doheney Beach emaciated liver: 68 7 295 cm, 222kg decomp. slight DK8503 3/12/85 verminiferous blubber: 150 11 female Crystal Cove pneumonias liver : 144 is 128 cm,172 kg decomp. slight DK8519 1015185 large forestomach as na male Bolsa Chica ulcer, pneumom&6 218 cm, 227 kg decomp. slight DK8603 3/30/86 ulcer, �astritis, blubber. 910 265 male Newport Beach aboess kidaey2 : 117 38 312 cm, 590 kg decomp. slight DK8609 5/31M na na na male Huntington Beach 244 cm, wt. na decomp. advanced 1LJL County Museum of Natural History 2So- Calif. Coastal Water Research Project 'Dr. Dawson, Dept. of Psychobiology, UC Irvine 6D. Kelly, Orange 3Dr. Haight, Orange County Animal Shelter Coast CoUege 7Dr. Britt, L.A. County Veterinary Service 4Oaange County Sanitation District na - information not available �a This general topography in both areas extends Population Statistics I along the coast and offshore for several miles. Within these areas dolphins often exhibited hunting behavior (swimming in echelon formation perpendicular to shore)i or were actually ob- served chasing, catching and eating fish. Addi- tionally, pods sighted between those locations were constantly moving either northerly or southerly towards the high -density areas. It is hypothesized that both the northern and far southern areas represent significant forage loca- tions for dolphins. The two possible dolphin births observed were within the middle area (south Newport Beach to San Clemente Beach), where, as indicated above, pods were infrequently observed. Also, both were in sheltered bays (Scotsman's Cove and Niguel Beach), not heavily used by humans and without high -density residences on the cliffs above. Such areas, uncommon now along the Orange County Coast, may also represent significant habitat to this species. Sits Fidelity No evidence was found that identified any in- dividual as a year-round or even seasonal resident of the study area. Call Percentages Our finding of 6.9% calves is high compared to the percentages reported in most studies. How- ever, only a fraction of calf percentages in the literature are based on year-round observations (Gruber, 1981; Leatherwood and Reeves, 1980). Data based on long-term observation have been reported by Wells and his colleagues in the Sarasota study area (Wells, Irvine and Scott, 1980); by Shane (1977, 1980); by Gruber (MI), along the Gulf Coast of Texas; and by Hansen (1983). Most of these researchers report calf proportions of approximately 7%.The low proportion reported in the Sarasota study (4%) probably reflects the maximum reproductive rate that can be maintained in that relatively isolated environment. 94 The validity of our population figures rests on the following assumptions: 1; Identified and unidentified animals are ran- domly mixed 2) Animals once idend'fed are always correctly identifiable thereafter. (We restricted ourselved to clear slides of distinctively notched dorsal fins. Further, we were often able to document altera- tions in the notch pattern of previously photographed animals.) 3) All identifiable (distinctively notched) in- dividuals in a school are photographed. (The proportion of identifiable animals photographed probably approached 100% when the school size was small, and declined when it was large. The net effect of missing any animals would be to err on the conservative side in our estimates.) 4) Our correction factor is accurate. Estimating the number of animals in a study area begins with a consideration of the proportion of photographically identifiable animals in samples. Hansen (1983) identified 118 individuals in his studies along the coast of north San Diego County, and estimated a population numbering between 173 and 240. The number of individuals we iden- tified photographically can be used to mate a similar estimate of the minimal number of in- dividuals using the Orange County coast. Since our population estimate from photo -iden- tification refers only to those animals in the population with distinct dorsal fins, it must be corrected to account for the non -distinct fraction. Our estimates of the proportion of animaht with distinct dorsal fins (Le., possessing two or more notches) ranged from 60 to 70%, averaging 65%. Calves always had smooth fins, and the alightiy larger animals, judged to be sub -adults, aiso had characteristically smooth or single -notched fins. Sizelage distribution data presented by Wells (1978) from capture operations on 100 bottlenose dolphins in the Gulf of Mexico showed that 48% of their animals were either calves or sub -adults. i Even allowing for selection bias in the capture Process, their data tend to support our estimate of the fraction of calves and subadults, or perhaps suggest that it may be conservative. Assur&ng that the fraction of indistinct animals was 35%, we obtain an adjusted estimate of 137 as the number of individuals seen in the Orange County study area between 1983 and 1985. The role of contaminants. All tissue samples (including blubber, muscle, Ever, kidney, andbrain tissue) revealed high levels of the pesticide DDT (range 150 to 1,922 ppm; average for blubber 854 ppm) and of the industrial chemical PCB (range 3.1 to 265 ppm; average for blubber 105 ppm) (Table 2). These are extremely high levels of DDT and PCBs in all tissues ex- amined compared to California Sea lions pre- viously examined (Britt and Howard, 1983), but not quite as high as some levels reported pre- viously in bottlenose dolphins for the same area (O'Shea et a1.,1980). De Long et al. (1973) reported a significant cor- relation between premature sea lion births and DDT concentrations, but pointed out that the correlation did not indicate a cause -effect relationship and that other causes were possible. Halle et al. (1976) correlated FCB concentrations with increased uterine lesions and reduced reproductive success in ringed seals fom the Baltic Sea, but the PCB concentrations were higher than those found in California animals. Several inves- tigators (Gaskin, 1982; Britt and Howard, 1983) have speculated that high organochlorine levels may impair the immune system of the marine mammals and therefore increase their suscep- tibility to infection and disease. In studies of dead, beach -stranded bottlenose dolphins reported by O'Shea et al. (1985) from Southern California, tissue sampling revealed ex- traordinarily high body burdens of DDT and PCBs in act tissues examined. Similar findings were reported after a disaster to the East Coast population of coastal bottlenose dolphins between the summer of 1987andJanuary 95 1988. Unprecedented numbers washed ashore at that time along the Atlantic toast from New Jer- sey to Florida, with 740 bodies recovered and mortality estimated at up to 2,500 dolphins. Deaths exceeded 50% of the East toast migratory stock. A comprehensive investigation of proximate and contributing factors unparalleled in c etologiW history (Geraci, 1989) revealed levels of contaminants (organochlorines) in the dolphins' blubber among the highest ever recorded for a eetacean; in addition, a host of bacterial and viral pathogens produced an array of clinical signs. The dolphins were apparently poisoucd by brevitoxin, a neurotoxin produced by the dinoflagellate hychodiscus bm s, Florida's red tide organism. But in his final report, Geraci (1989) stressed the urgency of learning what role contaminants play in dolphin mortality. The results from the beach -cast specimens ob- vioudy reflect the levels of Conuminants in the nearshore environment, where the dolphins ac- cumulate these substances... Free -ranging animals facing intermittent food supply, or mobilizing fat during lactation, migration or times of illness, release compounds from this depot (body fat) into vital, perhaps more critical organs such as the liver. Geraci concluded; The overwhelming nature of some of the infec- tions, which probably arose in the hung may have been related to immunoincompetence, the cause of which cannot be established. The depletion of lymphoid follicles in spleen, lymph nodes, and the intestine supports this suggestion. 'Equally important is the need to resolve the growing question of whether contaminants at levels found in the dolphins might have affected their resistance and rendered them more suscep- tible either to the toxin or to the mieroortanisms that eventually brought them to their demise! The present study cannot add evidence to mtp- port or disprove the hypothesis that contaminants render dolphins more susceptible to other toxins and microorganisms. CONCWSIONS A much larger population of buttlenose dolphins (89 to 137) appears to use and visit the coast of Orange County than has been previously reported (Kelly,1983). The dolphins seem very flexible and fluid in their use of the entire coast of Southern California. Pods of dolphins exhibit a preference for areas at the northern end of the coast (north Newport Beach, Huntington Beach, and Bolsa Chica State Beach) and the far southern end (San Onofre State Beach), areas we believe are sig- nificant for foraging. Furthermore, it is hypothesized that certain coves within the middle portion of the coastline (Irvine Coast to Scotsman's Cove and south LAgunas Beach to Niguel Beach) represent im- portant habitat for dolphins giving birth. The cause of this may be the area's relatively low human density -- the lowest on the Orange County coast. The population contains individuals from neonates to adults who carry burdens of DDT and PCBs among the highest recorded for any mam- mal worldwide. This does not bode well for the future health of the Orange County coastal bot- tlenose dolphin population, and indicates the im- portance of further and more comprehensive study if we wish to know what the future holds for these important members of our coastal marine community. ACKNOWLEDGEMENTS This work, carried out at Orange Coast College by the Dolphin Survey Project, was funded and supported by the Associated Students of Orange Coast College, the Marine Research Group (an OCC student club), and both the Marine Science Department and the Math and Science Division of the college. Many individuals contributed their time and help over the years to keep the project afloat. Generous financi&l support came from the Orange County Chapter of the American Cetacean Society and from individuals. The author is most grateful for all their help. Mike Couffer, Patty L.eiberg, Larry Kepko, Lisa Flourney, Don Johnston, Marty Morales, Ted Bennett, Ron Jones, Dave Beeninga, and Robert (Rip) Profeta are only a few of the important contributors to this research effort. The author would also like to thank R.H. Defran, Cetaoean Behavior Laboratory, San Diego State University, for his encouragement and support through the many trials and tribulations of the last three years. Special appreciation is also extended to Henry Schafer and his fellow scientists at the Southern California Coastal Water Research Project, in Long Beach; Dr. Robert Haight and Dr. Nyla Kelly, of the Orange County Animal Shelter, Dana Seagars, Larry Hansen, Jim Lecky, and Sheridan Stone, of the National Marine Fisheries Service; and Dr. John Heyning and Dr. Dan Patten, of the Los Angeles County Museum of Natural History. To all of those additional good spirits who lent a hand and helped make this happen: many thanks. SPECIAL NOTE An award -winning documentary film about these dolphins, entitled Dolphins of the Onmge Coast, was written, photographed, produced and edited by George Gumbre&t, telemedia director for Orange Coast College. It is available for view- ing, rental or purchase from Orange Coast Col- lege, 2701 Fairview Road, Costa Mesa, California 92626. REFERENCES Britt, J.O. and E.B. Howard. 1983. Tissue residues of selected environmental contaminants in marine mammals. In Pathobiology of Marine Mammal Diseases, E.B. Howard (wL). CRC Press, Boca Raton, Florida. Defran, R.H. and G.M. Schultz,198g. A tech- nique for the photographic identification and • 0. CJ 0 cataloging of dorsal fins of the bottlenose dolphin (Tursiops duncafus). International Whaling Com. mission Symposium on the use of non -lethal tech- niques, especially photo -identification techniques in the assessment of cetacean population parameters. la Jolla, California. Defran, R.H., GA. Shultz, MA. Espinoza, and A.C. Weaver. 1985. The population biology of along the Southern California and northern Baja coastline: Sixth Biennial Conference on the Biol- ogy of Marine Mammals, Nov. 22-26, Vancouver, British Columbia, Canada. Defran, R.H., D.L. Kelly, G.M. Shultz, A.C. Weaver, and MA. Espinoza.1989. The occurence and movements of the bottlenose dolphin in the Southern California bight. Manuscript accepted by Marine Mammal Science, J. Soc. for Marine MammoIogy. DeLong, R.L., W.G. Gilmartin, and J.G. Simpson.1973. Premature births in California sea Bons: association with organochlorine pollutant residue levels. Science 181:1168-1170. Dohl, T.P., K.S. Norris, R.C. Gueas, J.D. Bryant, and M.W. Honig.1978. Pinnipedia, Cetacea, and parasitology of the Southern California bight area. VoL III., No. PB-295-932. National Technical In- formation Service, Springfield, Virginia. 473pp. Gaskin, D.C.1982. The Ecology of Whales and - Dolphins. Heineman, Exeter, New Hampshire. Gerad, J.R. 1989. Clinical Investigation of the 1987-88 Mass Mortality of Bottlenose Dolphin Along the U.S. Central and South Atlantic Coast. National Marine Fisheries Service, U.S.Navy, Of- fice of Naval Research, A Marine Mammal Com. mission. April 1988. Gruber, JA.1981. Ecology of the Atlantic bot- tlenose dolphin in the Pass Cavallo area of Madagorda Bay, Texas. MSc. thesis. Texas A 6c M Univ, College Station, Texas. Hansen, L.J. 1983. Population biology of the coastal bottlenose dolphin of Southern California. 97 MA. thesis, Sacramento State Univ, Sacramento, California.104 pages. HeUe, E., M. Olsson, and S. Jensen.1976. PCB -levels correlated with pathological changes in seal uteri. Ambio 5:261. Kelly, D.L., 1983. Photo -identification of bot- tlenose dolphins in Southern California. Whalewatcher. J. Am. Cet. So.17(2)..-&8. Leatherwood, J.S. and R.R. Reeves.1982. Bot- tlenose dolphin and other toothed cetaceans. Pp. 369-414 in JA. Chapman and G.A. Feldhamer (eds.). The John Hopkins University Prow, Bal- timore, Maryland.1147 pp. Norris, KS. and J.H. Prescott.1961. Observa- tions on Pacific cetaceans of California and Mexican waters. Univ. Ca. Publ. Zool. 63:291- 402. Orr. R.T.1963. A northern record for the Pacific Bottlenose dolphin. J. Mamm. 44(3):424. Orr, J.M.1976. A survey of 7knd*a populations in the coastal United States, Hawaii, and ter- ritorial waters. Contract No. MM7AD-028. Marine Mammal Commission. Washington D.C. 13pp. O'Shea, TJ, R.I. Brownell, D.R. Dark, WA. Walker, M.L Gay, and T.G: Lamont. 1990. Or- ganochlorine pollutants in small cetaceans from the Pacific and South Atlantic Oceans. November 1966-June 1976. Pesticides Monitoring J. 14(2):35-36. Sargent, D.E., D.K. Caldwell and M.C. 'Caldwell.1973. Age, growth, and maw* of bot- tlenose dolphin from northeast Florida. J. Fisheries Res. Board Canada 30:1009-1011. Scammon, C.M.1874. The Marine Mammals of the Northwestern Coast of North America, described and illustrated, together with an ac- count of the American whale -fishery. John H. Carmany and Co. San Francisco, California. 319pp. Schafer, H.A., R.W. Gossett, C.F. Ward, and A.M. Westcott. 1985. Chlorinated hydrocarbons in marine mammals. In Southern California Coas- tal Water Research Project Biennial Report, 1983-1984, pp.109-114. Scott, G.P., D.M. Burn, and L.J. Hansen, 1988. The dolphin die -off: long-term effects and recovery of the population. Proceedings of the Oceans '88 Conference. Baltimore, Maryland, October 31- November 2,1988. Shane, S.H.1977. The population biology of the Atlantic bottlenose dolphin, in the Aransas Pas- sarea of Texas. M.Sc. thesis, Texas A &M Univer- sity, College Station, Texas. 239 pp. Shane, S.H. 1980. Occurrence, movements and distribution of bottlenose dolphins in southern Texas Fishery Bulletin (U.S.) 78:593-601. Shane, S.H., R.S. Wells, and B. Wursig. 1986. Ecology, behavior and social organization of the bottlenose dolphin: a review. 1-34-63. Walker, W.A. 1981 Geographical variation in morphology and biology of bottlenose dolphins in the eastern North Pacific. National Marine Fisheries Service/Southwest Fisheries Center Ad- ministrative Report No. LJ-81-03C. La Jolla, California. Wells, R.S. 1978. Home range characteristics and group composition of Atlantic bottlenose dol- phins on the west coast of Florida. MSc. thesis, Univ. of Florida. Well, R.S., A.B. Irvine and M.D. Scott. 1980. The social ecology of inshore odontocetes. Pp. 263-317 in L.M. Herman (ed.). Wells, R.S., T.P. Dohl, LJ. Hansen, A.B. Baldridge, and D.L. Kelly. 1990. Extraordinary movements of bottlenose dolphins (74rsiops sp.) along the coast of California. In The Bottlenose Dolphin, Academic Press. 98 0 0 Volume 6, Number 2 Summer 1990 • oast&ocean ,o�vWaterfront Age 3 From the Executive Office 4 Ebb and Flow 7 Conference Log 9 CrossCurrents 49 From Other Shores 53 Book Reviews 56 Letters Wildlife Corridors see page 10 0 2 Why We're Changing Our Name 10 Wildlife Corridors Carol Arnold Landscape linkages help counter the island effect that dooms species to extinction 22 Canine Access, or the One•Percent Syndrome Rasa Gustaitis Dog owners may be a dog's worst friend when it comes to walking on the beach 25 A Dog Owner's Guide to the California Coast A pull-out section reveals where your dog is welcome in coastal parks and beaches 13 A Greening on the Sundown Coast Wesley Mart Mission Impossible: Saving the Tall Trees Grove in Redwood National Park 19 Someone Special Avril Angevine Elizabeth Terwilliger turns thousands of children on to the joys of nature 42 The Fight for a Restored Wetland In Huntington Beach Gordon Smith Lesson number one: Don't relv on anvone else's emergency response plan 46 The Toll of a Routine Oil Spill Louann W. Murray The Huntington Beach oil spill was anything but routine for the shorebirds EXHIBIT 5 coast&-Ocan Cover: Woodcut by Ken Downing. Printed on recycled paper Dear Reader: With this issue, the magazine you have known as Califorlia Waterfrotit Age becomes California Coast & Ocean. It is still the State Coastal Conservancy's quarterly, published in association with Romberg Tiburon Centers of San Francisco State University. We took the new name because we outgrew the one with which we started. The magazine was launched in 1985 with the intent of focusing on urban waterfronts, which were being reclaimed statewide and nationwide as public assets. The Coastal Conservancy had valuable experience in water- front restoration and development and wanted to share it with a wider public. During the past five years, however, our coverage has expanded to a range of other coastal issues. We have considered wetland restoration and controversies about mitigation of development impacts; watershed restora- tion, the growth of the land trust movement, environmental education, waste water reclamation, the expected effects of global warming on the California coast, as well as other emerging themes. At the same time, of course, we have continued to inform the public of significant Conservancy activities. , The basic goal has remained the same: to contribute to the protection and enhancement of the qualitN and diversity of the California coast in keeping with the Coastal Act of 1976. lVe have drawn on the experience of the ,., Conservancv and those it works with, I-ut also on many other sources. More have found that local issues be viewed in a wider and more, we must context —within the watershed, the region, within national, and even global Moor• parameters. "From Other Shores," the department introduced in this issue, is in this direction. So is our new name. . a step The coast is not simply the territory that lies landward of the tidal zone. It 1985 extends out into the ocean. H.J. Walker, of Louisiana State Universitv's Coastal Studies Institute, has observed, "If there has been a noticeable trend in the change of man's view of the coast through time, it has been one of expansion." In 1961, he pointed out, a coastal geography panel sponsored by the National Academy of Sciences -National Research Council proposed that the coastal zone "may extend far from land, across shallow waters to -- the limits of major interactions between the land and water interface." `"' Recent vears have demonstrated with alarming evidence what our igno- ; ft ' ranee about the oceans is costing: oil and medical waste washing ashore, along with marine mammals dead of unknown causes; birds suffocating on 1981 waterborne plastic, vast host nets devastating calamitous numbers of p g g living creatures. At the same time, the great ocean commons has become ®—' subject to greater territorial claims. As deep sea explorers discover marvels Coast& -Ocean that we had never imagined, we are in danger of destroying not only them, but also life that sustains us. Turning with greater attention now toward the Pacific Ocean, this maga- zine will continue to do what we have attempted to do since the beginning: to publish material that might open new ways of thinking and otherwise serve our readers, who are all in one way or another involved with the California coast and ocean. 1990 Rasa Gustaitis Editor 2 CALIFORNIA COAST&OCEAN 0 0 • California Sketches by As Balbierius How lonely The Sierras Lietuva (Lithuania) the spirit of Erich Fromm Eternity's footsteps Freedom seed Above America's upon Earth's face in parched ancestral land automobile ocean waiting for rain the highway a Thousand years for the American an arrow, gives up his car above it only the setting sun. upon arrival in heaven or hell. Here my soul, Pacific Ocean Then he walks released, On its shores on his own leaps beside a dead bird along the path of out the car window misery leaves my soul another existence. a sudden breeze and only runs the ocean over the mountains. remains Rough and cracked is the bark of sequoia like the American Indian face �— Enclosed for centuries already in layers of a vanished time As Bolbierius is a poet, ornithologist, and member of the environmental movement in Lithuania. these impressions, written in May 1990, during his first visit to Americo, were translated 6om the Lithuanian. Arn Bolbierius SUMMER 1990 LB 1VEW CONCEPTS - z c ►j Kit fox Wildlife Corridors Landscape linkages may counter the "island effect" that can doom species isolated in preserves that are too small for them. by Carol Arnold 0 ne recent weekday afternoon, in the midst of stop -and -go traffic on In- terstate 80 along the shore of San Francisco Bay, motorists were startled to see a driver step out of his car into the roadway and wave his arms frantically at something close to the ground. At his feet was a duck followed by several duck- lings, heading straight into the eight lanes of traffic. Leaving the bay behind, the duck family had already waddled past the first rows of stopped cars in its hike, presumably toward the aquatic park on the other side of the freeway. The man managed to shoo them back to safety — this time. They would probably try again though, if not that day, then another. Four years ago, in southwestern Flor- ida, a 195-pound radio -collared black bear accomplished an amazing 11-week jour- ney through human habitat. He transected six counties, crossed eight major high- ways and a dozen other roads, swam a riverand numerouscanals, crossed fences and farm lands. Moving along abandoned railroad tracks, he passed suburban tracts, bee yards, turkey pens, and many road- side garbage containers. He was captured 200 miles from where he began. Earlier this vear in central California, a mountain lion was seen pacing in an agri- cultural field, looking confused and fright- ened. What had brought him to that ex- posed, dangerous place? Was he just "lost," as a news report suggested, or had genetic memory perhaps led him in search of some long -gone forest that his ancestors used to cross en route to feeding grounds on the coastal plain? What led these animals to venture into perilous human -dominated terrain cannot be known for certain. They were lucky. By a combination of chance and human good- will, thev were saved from becoming road kill statistics. An estimated 100 million wild animals are killed each year on the nation's roads. Animals move for many reasons, as do people —to feed, seek shel- 10 CALIFORNIA COAST&OCEAN ter, find mates, give birth. With humans claiming ever more of their habitat, their movements increasingly lead them into danger. Despite years of park and pre- serve acquisitions, protective regulations, and good intentions, we still know too little about the movement requirements of various species and have often failed to provide for them. Studies of wildlife movements have traditionally focused on long-distance travelers, such as migratory birds and caribou, species that move thousands of miles between summer and winter habi- tat. Recently we have become aware that resident animals also have movement needs. An otter's home range is about 1,000 acres, a single bobcat needs 5,000 acres, a blackbear must have at least 15,000 acres, and a Florida panther requires 150,000 acres. Many more acres are needed to maintain viable populations of these animals. These needs must be met if these and other species are to survive. The space left for them, however, has been steadilv shrinking. The Island Effect Biologists are accumulating evidence that we may have trapped our remaining wildlife populations within what amounts to a collection of islands, cut off from migration routes and historic home range by roads, fences, dams, buildings, agricul- tural fields, clear -cuts, and other manifes- tations of human occupation. The boundaries of our public lands are gener- ally arbitrary, laid out across a landscape that has been recognized as important to preserve, but is under competing claims. Parks and preserves are carved out of a human -dominated terrain, and their bor- ders usually have more to do with politi- cal and economic concerns than with the needs of plant and animal communities within them. "Prior to European settlement, Califor- • Even in open space areas, highways interrupt patterns of wildlife movement. Underpasses prevent road kills and expand range. • SUMMER 1990 11 LJ • "Prior to European settlement, California was a natural mosaic of habitats... We have overlaid an incredibly detailed grid of artificial boundaries, lines on the landscape that the natural world didn't evolve to deal with." Blunt -nosed leopard lizard nia was a natural mosaic of habitats," says Richard Spotts, California represen- tative of Defenders of Wildlife. "We had massive herds of tule elk and pronghorn antelope, as well as wolves, grizzly bear, and jaguar. We have overlaid an incredi- bly detailed grid of artificial boundaries, lines on the landscape that the natural world didn't evolve to deal with." If our parks and preserves are indeed functioning as islands, many species may be doomed. Plant and animal extinction rates on islands are higher than in almost any other habitat area. Although true islands contain Iess than 10 percent of all bird species, for example, more than 90 percent of all bird extinctions have been reported on islands. The state with the highest percentage of threatened and en- dangered species is Hawaii, our only is- land state. The theory that parks and preserves appear to replicate island conditions has been explored for some years but was defined more clearly in 1986 by ecologist William Newmark. In completing his doctoral dissertation on island biogeo- graphy at the University of Michigan, he produced compelling evidence that some mammalian extinctions in western North American parks are the consequence of the fact that the parks are too small to support many species that historically occupied a larger territorv. Gone from Brvice Canyon are the red fox, pronghorn antelope, northern flying squirrel, and the beaver. No river otter, ermine, mink, spotted skunk, and gray fox have been seen in Crater Lake Na- tional Park for many years; the black bear and badger have vanished from Zion National Park, and the wolverine and Ivnx from Mount Rainier National Park. The reasons for these extinctions were unclear until Newmark published his conclusion that "the loss of mammalian species [in the parks] is most probably attributable to the loss of habitat and the active elimination of fauna on adjacent ;lands." Cut off from their historic home range, isolated from other members of their kind and therefore unable to renew the gene pool, these animals were trapped within an area that was too small to main- tain them and was surrounded by incom- patible land uses, which prevented them from expanding their range "We cannot tuck species away in little reserves as if we were storing pieces in a museum, then come back a century later and expect to find them all still there," biologist Douglas H. Chadwick remarked recently in Defenders magazine. Habitat fragmentation has four major effects. First, it restricts and isolates large free -ranging animals. Second, it leads to the loss of genetic integrity and viability within the species. (The Florida panther's decline is attributed to inbreeding result- ing from range restrictions. Symptoms of inbreeding depression include loss of li- bido, high levels of infertility, high infant mortality, and eventual dwindling of the population. Research on adult Florida panther males found that 95 percent of of certain California mammals In ffroasends of square gores. -stark Bear 1 s,000 'Bobcat 0,000 Offer 1,000 those studied suffered from fertility prob- lems.) Third, habitat fragmentation leads to a loss of species dependent upon a par- ticular habitat. (Studies of breeding birds in hardwood forest fragments in north Florida showed that 47 percent of hard- wood -dependent species have disap- peared.) Fourth, habitat fragmentation opens the landscape to exotic, weedy plant species and to opportunistic wildlife spe- cies. (The cowbird is one of these species. It lays its eggs in other birds' nests, pushing out the eggs already there. The host bird hatches the cowbird's eggs and raises its young as its own. In the eastern United States, cowbirds are the likely cause of the extinction of one species of warbler and the decline of another.) Examples of habitat fragmentation and the island effect abound in California. In the eastern Sierra, a major deer migration corridor is blocked by the Mammoth Lakes Ski Resort. Near the shore of Morro Bay, the remaining population of Morro Bay 12 CALIFORNIA COAST&OCEAN kangaroo rat, the state's most endangered mammal, may be trapped in a privately owned habitat island of several hundred acres, separated from the remainder of its traditional habitat by residential develop- ment and other incompatible land use. The movements of black bear and moun- tain lions are increasingly restricted. The beaver, the otter, and other animals that move along watercourses are being in- creasingly restrained by dams, flood con- trol "improvements," the removal of ri- parian vegetation, and water diversions. The same can be said for many species of songbirds and fish. Salmon and steelhead are declining rapidly. The Least Bell's vireo, one of manv birds that depend on riparian habitat, is endangered. During the last century all but 5 percent of California's riparian habitat was depleted. According toThe Nature Conservancy's Sliding Tozcand Extinction report, "in Cali- fornia Nve have been rapidly eliminating ... natural habitats without fullv understanding... the consequences.... About 200 vertebrate animals, 600 species of plants and almost 200 different natural communities in California are considered ... to be threatened with severe reduction or... extinction." A New Strategy How to stop this sorry litanv of wildlife losses? Defenders of Wildlife and several other conservation organizations are promoting a strategy that, according to Chadwick, represents "a major shift in the way we go about practicing conservation... It involves a fundamen- tal change in values arising from a broader vision of how nature works." Central to that strategy are landscape linkages or wildlife corridors (in some cases referred to as greenbelts): planned connections between habitat "islands" to provide protected movement opportuni- ties and increased range for various ani- mals, thereby helping to maintain healthy populations and genetic diversity. These connections can be as inconspicuous as an underpass beneath a road or a hedgerow between two farmers' fields, or as impres- sive as a mile -wide riparian jungle bor- dering a major river, or 10,000 acres of forest lands connecting two national parks. The Ofay River Corridor The Otoy River Valley runs west from the San Ysidro mountain wilderness across the broad Otoy-Nestor mesa and into San Diego Bay. Finger canyons extend north and south. As in most river valleys of southern San Diego County, the riparian habitat areas of the Otay River Valley have been severely degraded over the past 50 years by agriculture, industrial development and rapid urbanization. Only vestiges remain of the woodlands, freshwater ponds and marshes in the river's upper reaches and the brackish and saline marshes near the estuary. Today, wildlife survives here mostly around man-made salt ponds that form a patchwork pattern in south San Diego Bay, and large freshwater ponds created by gravel extraction in the upper river valley. Wildlife use of the Otoy River Volley is extremely high. Many mammals, fish, and insect fauna depend on the riparian corridor for water, shade and cover while traveling across otherwise open areas. Small mammals and birds use this route to scatter when population pressures or food and water shortages drive them from their usual habitat. Many migratory and resident bird species —some of them rare and endangered —feed and nest in the Otoy River Valley and adjacent salt ponds. Among them are the Elegant tern, Black skimmer, Light-footed clapper rail, Califor- nia least tern, Snowy plover, Least Bell's vireo, and Belding's savannah sparrow. In 1989, an unprecedented cooperative effort began in the area to protect and restore wildlife corridors in the valley, while also providing new public recreational opportunities for the fast growing human population. The cities of San Diego and Chula Vista, the county of San Diego, the nonprofit Southwest Wetlands Interpret. Association, and others concerned about these issues formed a partnership designed to guide private development decisions while preserving, protecting, and, where possible, enhancing natural resources. The Coastal Conservancy has funded two enhancement plans that will recommend development strategies to minimize impacts to natural resources and identify the best areas for wetland and riparian habitat restoration and new access improvements. By Lisu Ames Whether the links are broad or narrow, many scientists are convinced that with- out them many of our native animals and plants are doomed. "The countdown for extinction starts when you establish isolated preserves," says Dennis Murphy, director of Stanford University's Center for Conservation Bi- ology. "There is a propensity to design isolated garrisons for particular target species. Yet it's clear that organisms exist as regional metapopulations that are highly interactive. As soon as you cut dispersal corridors out of the system, you've assured extinction." SUMMER 1990 13 0 Z Z z Florida has only one or two reserves big enough for a single Florida panther, according to Defenders of Wildlife, making these linkages crucial to the panthers' survival. Bighorn sheep A vivid case in point is the threatened Checkerspot butterfly, which population biologist Paul Ehrlich has studied at Stanford's 1,100-acre Jasper Ridge Pre- serve for 31 years. In 1973 there were three Checkerspot populations, totaling over 4,000 individuals, on Jasper Ridge. Ten years from now there may be none. One of the populations has already dis- appeared and others have diminished. "We haven't had 1,000 for the preceding decade," Murphy said. The process that has led to the decline began 150 years ago with the introduc- tion of European grasses. The Checker - spot lives only on native plants, laying its eggs on Common plantain and Owl's clover and taking nectar from daisy rela- tives. The plants it requires still grow in patches of serpentine soil, which have become de facto preserves because Euro- pean grasses have not yet invaded them. With suburbanization and the building of freeways, however, the open space between the patches has been disrupted, isolating the butterfly populations. "The lesson we take home from the Checkerspot butterflies is that 10 to 30 generations after isolation there is a good chance that a species will disappear," Murphy commented. 'The single most important feature of conservation plan- ning is the regional context into which preserves are designed." A Wider Vlew A new field of study, called landscape ecology, provides the required regional context and is the basis of the wildlife corridor strategy. The landscape ecologist seeks to understand the relation between adjoining "patches" of land such as agri- cultural fields, forests, grasslands, roads, river corridors, and towns. He tries to de- scribe how these individual patches affect processes that extend across an entire landscape, that is, a large expanse of con- tiguous land. For park and preserve man- agement purposes, the comprehensive approach of a landscape ecologist differs from the more traditional focus on indi- vidual park units or single species —a perspective that has inadvertently allowed habitat fragmentation to occur. "Landscape ecology is a new dimension to wildlife conservation, which says that we have to take a bigger look," says Rich- ard Spotts. "It might be naive, for example, to acquire a 50-acre area expecting it to remain static over time," he explains. "You have to consider whether the value for which the land is to be acquired can realis- tically be maintained once the area is re- moved from the landscape [by fencing or development of surrounding lands, for example]. Will the vegetative composition change? Will exotic weeds overwhelm the existing plants? The new scientific studies force us to raise such questions." In a pioneering study under way in the Idaho Cooperative Fish and Wildlife Re- search Unit at the Universitv of Idaho, J. Michael Scott and his colleagues have de- veloped a process to provide some an- swers to such vital questions. Scott calls it a "gap analysis." It involves the analysis of species composition and distribution rela- tive to the size and distribution of the preserved area and the opportunities for movement to other habitat areas. If this analysis shows that declines in species di- versity can be expected, the next step is to attempt to "fill in the gaps" by expanding existing parks, establishing connections with other habitat areas, or creating new areas managed for biological diversity. In his study, Scott used satellite data to pro- duce a vegetation map for Idaho. When it was overlaid with a map of preserve areas, it showed that 25 of ' 118 vegetation types were unprotected and 42 percent were in- adequately protected. Initial funding for the study came from the National Fish and Wildlife Foundation and the Idaho De- partment of Fish and Game. 14 CALIFORNIA COAST&OCEAN r: Gap Analysis: Protecting Biodiversity By Using Geographic Information Systems National and global biodiversity is disappearing, primarily because human beings have altered wildlands. Response to this loss has centered on rescuing species from the brink of extinction. The reactive strategy of recovering endan- gerea species is difficult, expensive, and inefficient. It is unrealistic to expect limited conserva- tion dollars to keep up with the growing number of listed and candidate endangered species. The best way to preserve biodiversity is to maintain common species in natural landscapes. Preliminary data indicate that the existing reserve system is inadequate for maintaining biodiversity and that additional reserve areas are needed. Presum- ing that only a small part of the and wildlife departments, university studies, game management records, etc In an ongoing gap analvsis of Idaho, U.S. Fish and Wildlife Service biologists at the Idaho Cooperative Fish and Wildlife Research Unit have developed a GIs database of the statewide distribution changes in land use. Managing these "hot spots" for their natural values should be the best wav to minimize loss of our natural heritage. Presently, gap analysis programs are in place in Oregon, Utah, and Idaho. The entire nation could be done in six vears for less than a pennv A yap analysis comparing the ranges ` of Hawaiian forest birds with 1 preserves revealed the need for more protected habitat and led to the KoN creation of Hakalou Forest National Wildlife Refuge. \� Hlc..o 1AA, A !. Endangered species Richness: J ^A LF- H O t Species (♦ 2- 4 sposles 71 Preserve$ land base will ever be devoted to preserving biodiver- sity, we need an objective way to identify and prioritize new conservation areas. Gap analysis uses a software package called Geographic Information Systems (GIs) that performs digital map overlay to identify species -rich areas and ecosystems that are inadequately protected by existing reserves. GIs can analyze multiple lavers of different maps, which could include satellite images of vegeta- tion, U.S. Geological Survey maps of land ownership and topography, and maps of animal species distribution from state fish and status of several components of biodiversity. Maps have been compiled at a scale of 1 inch to 230,000 inches of biodiversity indicators, including vegetation, terrestrial vertebrate species, and localities of threatened and endan- gered species. These are being overlaid with maps of ecoregions, existing reserves, and land ownership. Exotic species and species adapted to human - altered habitats are excluded from the analysis. The goal is to identify unpro- tected areas in each ecoragion that contain high species richness or vegetation types and that may be threatened by future an acre. Landscape linkages and corridors between wild lands, which may be critical in biotic responses to global change, could also be located. The database allows alternative patterns of future development to be analyzed with respect to fragmenta- tion and isolation of wildlife habitats. Potential conflicts could be avoided by relating maps of natural exploitable resources to areas of critical environmental concern. Because future land use changes will result in a net loss of wild lands, identifying those areas that will most efficiently maintain biodiversity may be the only way to resolve conflicts between conservation and development. By J. Michael Scott, U.S. Fish and Wildlife Service, and Blair Csuti, Idaho Cooperative Fish and Wildlife Research Unit, College of Forestry, University of Idaho. A Workshop on Protecting Biodiversity Using Geographic Information Systems will be held October 29-31 in Moscow, Idaho. For information, contact Kathy Merk, Cooperative Fish and Wildlife Research Unit, University of Idaho, Moscow, ID 83843, (208) 885-6336. SUMMER 1990 15 San Joaquin antelope ground squirrel The first statev.,ide attempt to conduct a comprehensive gap analysis in Califor- nia is about to start. Led by Frank Davis, professor of geography at the University of California, Santa Barbara, this two- year effort will produce a series of over- lays displaying habitat areas, political ju- risdictions, land ownership, and other information necessary for building a framework for comprehensive habitat conservation planning. It will include a network of wildlife corridors. Florida Fills Some Gaps Florida is considering doing a formal gap analysis and has already taken steps to enhance wildlife movement. Thirty- three underpasses are being built under a 130-mile extension of a major interstate route across the Everglades to allow Flor- ida panthers and other wide-ranging species to pass. The Osceola National Forest has been linked with Okefenokee National Wildlife Refuge by a $7 million federal acquisition of connecting lands, thus providing nearly a million acres of protected area. According to Defenders of Wildlife, this combined area is now large enough "to provide the potential for reintroduction of captive -bred Flor- ida panthers, whooping cranes, and red wolves as well as... to maintain viable populations of numerous other endan- gered species... " Opportunities for more landscape linkages abound in or near Florida. The 171,000-acre Conecuh National Forest and the contiguous 183,000-acre Black Water River State Forest lie five miles to the north of Eglin Air Force Base, which in- cludes open space with high habitat value. The connecting privately owned lands are rural and forested. If they were ac- quired and protected, an 817,000-acre preserve could be created —large enough for a viable population of the endangered Red cockaded woodpecker and other threatened wildlife. The Loxahatchee National Wildlife Refuge and the Corbett Wildlife Manage- ment Area could also be connected by protecting five square miles of private lands to assure viable populations of Florida panther and black bear. If these lands are not connected, these animals are probable doomed because of intense development pressures in this area. In some cases, small linkages can pro- vide enormous benefits. A 2 percent addi- tion to the total assemblage of lands al- ready acquired by various government agencies to protect the Wekiva River in northern Florida and adjacent areas would assure the protection of the entire river system. California Takes Steps In California, no comprehensive plan to connect habitat areas exists. The state's population of 30 million —already 10 per- cent of the nation's and relentlessly grow- ing —puts open space under ever greater development pressures. If we are to pre- serve what is left of our natural heritage, we must act right away or lose our oppor- tunity to do so. A gap analysis is a good start. "This is a more proactive approach," Davis said. "We have tended to focus our resources on the rare and endangered. Now we are seeing the need to protect species before they are rare and endangered." Another hopeful initiative is a bill intro- duced by Sen. Don McCorquodale of Dis- trict 12 (Stanislaus County and parts of Santa Clara County) to set up a task force of government and private sector represen- tatives to "identify existing and long-range opportunities to conserve and enhance the state's wildlife habitat... and recommend policies and actions to achieve the long- range goal of conserving biological diver- sity." Implied in this legislation is the need for comprehensive planning to establish wildlife corridors. The concept is beginning to find its way into the planning schemes of various re- source agencies and nonprofit organiza- tions. The Wildlife Conservation Board has purchased land for the purpose of provid- ing increased opportunities for deer to move from their summer to their winter range. Both the Wildlife Conservation Board and the State Coastal Conservancy have been active in acquiring and restor- ing wetlands that provide food and shelter for migratory birds along the Pacific Fly- way. The National Park Service, U.S. Forest Service, and California Department of Fish • • 16 CALIFORNIA COAST&OCEAN L] The San Dieguito Watershed The San Dieguito River watershed is long and narrow, extending 350 square miles from the Volcon Mountains to the Pacific Coast at Del Mar in San Diego County. Its major river, 43 miles long, is channeled under numerous roads and is dry much of the year, its flow held back behind two major dams. Nevertheless, the river corridor provides valuable wildlife habitat. It links inland wildlife areas and serves as a resting point on the Pacific Flyway. The stream that flows into the sea as the San Dieguito River begins at ironside Spring in the and mountains as Santa Ysabel Creek. It winds through Santo Ysobel Valley and past Witch - creek Mountain, is captured behind a dam in Lake Southerland, travels through Pomo and Posqual valleys, passes San Diego Wild Animal Park and is captured again at Lake Hodges. Released below the last dam on this man-made lake, it emerges renamed as the San Dieguito River and continues through on increasingly developed watershed to the coast. All along the way, canyons open into the river corridor; creating a network of travel routes for the small canyon and valley popula- tions of Least Bell's vireo, the San Diego horned lizard, Orange throated whiptail, and other animals. This habitat network is essential to the survival of threatened and endangered species, and to keeping other species off the list. If its strands are broken by development, as they have been in other watersheds, wildlife populations will weaken, and some populations of endangered species might vanish. Last year, hope for protecting the river rose when five cities and the county formed a joint powers authority to plan a river -long park, acquire properly, and maintain it to serve the recreational needs of the area's growing human population. if the canyons of tributary streams are protected as part of that park, wildlife will also be served. Animals will also continue to move between the river and the upstream Cleveland National Forest, across land that is now protected under city, county, and state ownership. The San Dieguito's estuary is on important link on the Pacific Flyway. A century ago the San Dieguito Lagoon was the largest coastal lagoon in the county, its channels and marshes encompassing perhaps 1,000 acres. More than half the lagoon and marsh complex has been destroyed since then by filling, transporta- tion and development projects. Since 1978, however, the State Coastal Conservancy has been working with the cities of Del Mar and San Diego and with other agencies and nonprofit organizations to restore tidal flow in the undeveloped portion of the lagoon ecosystem, including the channels, wetlands, and surround- ing uplands. In the early The San Dieguito Rh 1980s, the travel routes for three Wildlife Conservation Board acquired �� 1 about 100 acres, which have been enhanced by the Coastal Conservancy (. `�► �� L• and the Department of Fish and Game. With upstream, downstream, and canyon mouth linkages to the river corridor, species that otherwise might not survive may continue to play their part in maintaining the natural ecology. Coyotes, for instance, help to keep in check small animal predators, including domestic cats, that can decimate small mammal and bird populations, especially ground nesting birds such as the Least Bell's vireo and the California gnat catcher., Coyotes need to be able to travel, as do other large mammals, including mountain lions, mule deer, bobcats and ringtoils. Golden eagles can travel without corridors but they require large areas to forage and a degree of isolation from disturbances. Protecting the San Dieguito River watershed would benefit all these species and many more. If the joint powers authority succeeds in creating a park along the river and looks out for the needs of nonhuman species as it does so, bikers and joggers will be able to share a strip of territory with life forms they might otherwise only encounter during backpacking excursions to the remote wilderness. By Melanie Denninger throat or corrridor provides a web of and endangered species. d-A L-1 . SUMMER 1990 17 5i'4N 4lE�o �� a p,Q!` �?c tSG 'r'J rA Ti jvana Estuary The 2,531-acre Tijuana River Notional Estuarine Reserve protects the largest tidally flushed coastal wetland remaining in southern California. Although it is affected by many perplexing problems, the reserve provides diverse habitat for wildlife, including several endangered or threatened species. The future of the reserve, however, depends largely on what happens upstream. Three-quarters of the Tijuana River's 1,735-square-mile watershed is in Mexico; the rest is in San Diego County. The headwaters lie in the northernmost mountains of Baja California and remote southeastern regions of San Diego County. The river traverses densely populated eastern Tijuana in a concrete -lined T i J A NR flood control R i V EQ channel, entering WRTEQSH the United States just west of the v • 5. A • border crossing. -- — Within the �'M E x i LC United States, the watershed and the Pi river ore mostly in a natural but highly degraded state. The 5,000- acre Lower Tijuana River •__,, ; Valley contains a ragtag mix of rural agriculture, horse corrals, and sand and gravel operations. Illegal fill and dumping have severely restricted the flood plain corridor; urban housing tracts encroach from north and east. For nearly a decade the Coastal Conser- vancy has been working with other state and federal agencies and the city and county of San Diego to preserve and enhance the valley's natural values, focusing on the estuary and salt marshes. Shortly aher the reserve was formed in 198Z Conservancy and federal funds were allocated for land acquisition to expand the habitat and maintain the integrity of the estuarine ecosystem. Even as the Reserve boundaries were extended in the mid- 1980s, however. troubling changes became evident. The river mouth closed with increasing regularity, eliminating tidal action and threatening fragile estuarine ecology. Channels filled with sediment. Just upstream, riparian habitats were diminished. Escalating sewage contamination and damag- ing trespass showed a clear need for communi cation with Mexico. In 1986, the Conservancy undertook on intensively researched restoration plan and an accompanying environmental assessment. Once the environmental review is compieted later this year, work on on extensive restoration project is expected to begin. Meanwhile, significant links with upstream areas are evolving. The San Diego County Parks Department has begun to acquire additional lands in the valley. While the county's long-range goals include developed recreational uses, plans also include generous restoration and extension of the valley's riparian habitat corridor. Habitat development work in the valley could benefit numerous species, most notably the endangered Least Bell's vireo. The often spicy international dialogue concerning regional issues has begun to show progress. A recent U.S.-Mexican agreement will result in development of a sewage treatment plant to treat the chronic sewage flows now plaguing the valley. Cross border communica- tion between environmental interests in Califor- nia and Bojo California on a range of issues gives rise to new promise. The arduous work of restoring environmental quality to the Tijuana River Valley is underway, despite the formidable obstacles that impede the recovery of what has been lost. While full restoration is just a step beyond the nether land of dreams, the process has begun, the dream has been articulated in plans, and a large number of people in numerous organizations are working toward a common vision. Some say the notion of a viable and productive wildlife corridor linking the Mexican highlands with the sea is sheer lunacy, others say visions like this are just the thing that gets them through the next backup on the freeway, and beyond the monotony and disillusionment of our times. By Jim King 18 CALIFORNIA COAST&OCEAN and Game are Nvorking together to rees- tablish a population of Sierra -Nevada Bighorn sheep in national forest lands ad*acent to Yosemite Rational Park. As part of that project, the animals' move- ment patterns are being studied and used as guides to management to help avoid the consequences of an earlier effort in northeastern California: the Bighorns contracted a disease from nearbv domes- tic sheep and died within the first week. In projects to restore coastal wetlands, the Coastal Conservancv seeks to enhance movement opportunities for fish and wildlife through stream and riparian cor- ridors. This agency increasingly considers entire watersheds and their relationship to downstream resources, such as coastal estuaries and other wetlands. [See boxes pp. 13-18.1 In other projects, the Coastal Conservancv is working with others to connect coastal dune areas to preserve the diverse array of plant and animal species found in this type of habitat. (Wildlife corridors serve for plants as well as ani- mals. Fruiting plants depend on animal consumption and movement to disburse their seeds. Many plant species depend on insects and birds to disperse pollen and prevent inbreeding.) The Coastal Conservancy is also par- ticipating actively in efforts to link up agricultural, open space and habitat lands along the San Mateo County coast through its acquisition of interests in a total of more than 2,1 00acres of ranch lands. These efforts have been promoted by several private nonprofit organizations and pub- lic agencies to link up the coastal trails and beaches with coastal terrace and moun- tain parks and preserves. The Santa Monica Mountains Conser- vancv and the Tahoe Conservancv have acquired lands to enhance wildlife move- ment. The Nature Conservancv is at- tempting to link scattered habitats in the San Joaquin Valley with the 300-square- mile area it and the Bureau of Land Man- agement are buying in the Carrizo Plain to protect various species, including the en- dangered San Joaquin kit fox, the Ante- lope ground squirrel, the Blunt -nosed leopard lizard, and Giant kangaroo rat. The scattered habitats in and of them- selves are not especially valuable in the long term for these species, according to Top: San Diego County, near Clairemont. Canyon -mesa habitat that provided habitat for songbirds, coyotes, and other wildlife now isolated by development. Bottom: Diminished riparian corridor of Oso Flaco Creek, Santa Maria Valley, east of Nipomo Dunes. 0 SUMMER 1990 19 9 0 1 t T—: It a. Whose right of way? The Alaska Department of Fish and Game is studying the hng-term effects on the caribou population of roads, the Alaska pipeline, and other man-made barriers that caribou encounter in their annual migration. Pregnant caribou and calves are much more sensitive to these disturbances than bulls. This year Congress will consider two bilk that would permit oil extraction from the 19-million-ocre Arctic National Wildlife Refuge. About 80,000 caribou give birth there annually. The Nature Conservancy's Ken Wiley. Linked, however, they can function as corridors to the core habitat, the Carrizo Plain. Several government agencies and private groups have formed a consor- tium to advance this goal. The Nature Conservancy is also ex- panding its Consumnes River Preserve „ 01 nk important habitat areas. It hopes to encourage the creation of a "conserva- tion corridor" that connects the Sacra- mento /San Joaquin River Delta, of which the Consumnes River is a part, to the Sierra Nevada region, "insuring the pres- ervation of a complete representation of the original Delta, Central Valley and mountain landscapes," the organization's Summer 1990 newsletter reports. Wildlife corridors can also be incorpo- rated into timber practices. Larry Harris, author of Fragmented Forests and an expert in this field, recommends an "island ar- chipelago" approach for the harvest of Douglas fir: leaving a series of intercon- nected forest preserves, sufficient in size, distribution, and number to assure viable populations of wildlife. In the future, it will likely be increas- ingly difficult to justify construction of a road or other obstacle through prime habi- tat within parks and preserves without at least providing some animal crossings. 20 CALIFORNIA COAST&OCEAN A Funding Priority Wildlife corridors are also emerging as a funding priority. Proposition 70, the California Wildlife, Coastal and Parkland Conservation Act of 1988, designated $6 million to the Wildlife Conservation Board for acquisition, enhancement, restoration, and / or protection of critical habitat areas, specifically including "significant routes of migration for wildlife." Proposition 117, the so-called Mountain Lion Initiative ap- proved by voters last June, places a fund- ing priority on projects that will serve as "corridors linking otherwise separated habitat so that the genetic integrity of wildlife populations will be maintained." The Planning and Conservation League, which is responsible for promoting these funding initiatives, is preparing a report on what California's conservation priori- ties in the 21st century should be. The report will call attention to the need for wildlife corridors. Some would argue that it is too late for all this in light of human population growth and the increased demands it places on natural resources. The demands are real enough, but choices can still be made that will respond to them and, at the same time, preserve our flora and fauna. Human development can be designed to allow for wildlife movement. If consid- ered in the planning stage, these allow- ances can often be simple and inexpen- sive. A streamside forest could be left intact. A coastal canyon could remain un- disturbed. An under crossing could be built beneath a road. New or existing parks and preserves could be linked, sometimes by adding only a small amount of land. It is important to note that the design of preserves and connecting corridors must consider the needs of the particular spe- cies that would use them to avoid poten- tial problems. They should be sufficient in size and include a diversity of habitat types (such as a mix of upland and wet- land areas) to preserve viable populations. If we can view the needs of wildlife as not too dissimilar from our own, the deci- sions that lead to wildlife protection be- come easier to make. The human ability to move from place to place is guaranteed by a network of roads, walks, trails, bridges, tracks, waterways, and other conveyances. FOR FURTHER READING Adams, L.W., and LE. Dove. 1989. Wildlife reserves and corridors in the urban environment, a guide to ecological landscape planning and resource conservation. Columbia: National Institute for Urban Wildlife. Chadwick, D. 1990. The biodiversity challenge. Defenders (May/ June):19-30. Harris, L.1984. The fragmented forest: Island biogeography theory and the preservation of biotic diversity. Chicago: University of Chicago Press. Mackintosh, G., ed.1989. Preserving communities and corridors. Washington: Defenders of Wildlife. Newmark, W.D.1987. A land -bridge perspective on mammalian extinctions in western North American parks. Nature 325: 430-432. Quammen, D.1988. The Newmark warning. Outside (May): 31. Soule, M., D. Boulger, A. Alberts, R. Sauvajot, J. Wright, M. Sorice, and S. Hill.1988. Reconstructed dynamics of rapid extinctions of chap- • arral-requiring birds in urban habitat islands. Conservation Biol- ogy 2: 75-92. Suchy, W. and L. Harris.1988. "Landscape Linkages." A video pro- duced by Florida Films, Gainesville, Florida. Without these movement corridors we would find it difficult to get to work, go to the store, visit friends. Wildlife corridors serve the same function. Both allow living beings to move about, gather food, find shelter, intermix —to live. Carol Arnold is a project manager in the Coastal Conservancy's resource enhancement program. She oversees the Nipomo Dunes Enhancement project, a continuing Conser- vancy effort to link significant dune habitat. She also manages the Morro Bay Watershed Enhancement project to improve habitat in Morro Bay's watershed and wetlands. SUMMER 1990 21 0 do' runs along the shore, chasing a stick tossed into the surf, racing after shorebirds it can never catch. The sight of it makes many people smile, for it goes with the sense of freedom they feel on the edge of the ocean. Other people, however, look at the same dog and see a mess in the sand, disturbed wildlife, even a reason to be afraid. Where to permit dogs and under what conditions is a divisive and difficult question ror those charged with manag- ing parks, protecting natural areas, and providing public access to the coast. "It is not an issue that lends itself to being reasonable," said Ranger Jav Eickenhorst at Stinson Beach in the Golden Gate National Recreation Area. "You can polarize a community on how to deal with dogs more easily than on anything, including civil liberties and children." Almost everyone agrees that no pets or domestic animals should be allowed in wildlife sanctuaries and nature pre- serves. Beyond that, however, consensus breaks down. "I've been accosted, licked, almost knocked over, and completely soaked by dogs running loose on the beach. I hate it. Dogs on the coast are a pain," says a former dog owner. "On. the other hand, I have a friend who calls dogs over to him and plays with them." Some people contend that dogs have no place in any public beach or natural area, some would tolerate restricted access, and some would accept well- behaved dogs accompanied by respon- sible owners almost anywhere. Rules vary from county to county, park to park, and even from hour to hour in some cases. They range from complete canine exclusion to complete acceptance, with manv variations in between. No matter what the rules are, how- ever, many perfectly conventional and otherwise law-abiding citizens tend to turn into scofflaws when they arrive at a beach with their dogs. They simply cannot resist letting their animals run. C nineAccess and the One Pei -cent Syndrome by Rasa Gustaitis Dogs, that heel obediently on the side- walk get a gleam in their eves, start panting, put back their ears, lob out their tongues, and strain on leashes with all that open space around them. It seems cruel to defv nature, with the wild wind blowing in from the sea. In Imperial Beach, an elderly man who lives alone with an old dog last year stopped at a neighbor's to borrow a spray can of red paint. He returned it a half hour later. The next morning the neighbor saw that the sign listing beach prohibitions ("No motor vehicles, no fires, no nude bathing, no dogs") had been altered. "No dogs" was covered by a red streak of paint. In the face of such anarchistic atti- tudes, as well as other problems, the State Department of Parks and Recre- ation has adopted a severe policy. It prohibits dogs in almost all state parks except in campgrounds, picnic areas, and on some roads, and in these areas requires that they be leashed. The National Park Service is more flexible, excluding dogs from sensitive resource areas, allowing them under voice control in some other places, especially within the GGNRA, the nation's first urban national park. At the Marin Headlands, a dog trail map is available, and one ranger'even sets out a water bowl at the visitor center door. 22 CALIFORNIA COAST&OCEAN I mar indi ing is ei Rea! wilt pres mes peol and. dog rule. POP' are certz nonF E peol their their do, ( place tion Ir exch ers c to pe plasi with fires, The} effec in m A Bimonthly Ma£acine of the Worlduvich Institute WOaDW-,ATCH COVER STORY APARTHEID'S OTHER INJUSTICE BY ALAN B DURNING Islands of extreme land degradation mark South Africa's homelands Ssystem, v.-hich cro,.N•ds blacks onto j marginal lands. COVER ILLUSTRATION BY FORREST GREENE 2 EDITORIAL 3 IN THIS ISSUE 4 LETTERS 5 PROMISING INITIATIVES ROMANIA'S CONDOM AIRLIFT A flood of contracepti\ es -fills Romania's family planning gap. TORONTO CUTS IT'S CARBON City to trim emissions by 20 percent. WOMEN'S BILL OF RIGHTS Why hasn't the U.S. endorsed the U.N. treat• to end discrimination against women? A MODERN-DAY NOAH'S ARK Red wolves, Mallorcan midwife toads, and other species are being re- introduced to their former range. 6 VITAL SIGNS CITINGS MAY - JUNE 1990 VOL. 3. NO. 3 FILLING UP IN THE FUTURE BY NICHOLAS LENSSEN AND JOHN E. YOUNG 18 Methanol, ethanol, methane. Which Will succeed petroleum? That's the problem with the alternative fuels debate —the answer should be a com- bination of solar -derived hydrogen and electricity. 10 WRONG TURNS CANADA DERAILS Canada cuts its passenger rail senice by nearly 50 percent. 35 TRENDS HOT AIR ON GLOBAL WARMING There's a lot of talk of doing some- thing about global warning, but not much national action. LAND EQUITY IN ZIMBABWE? On its 1 Oth anniversary, can Zimbabwe fulfill its promise? 38 TECHNOLOGICAL ADVANCES WINDOWS GOOD AS WALLS State -of -the -an windows are 10 to 12 times more energy efficient than single - pane glass. 39 WORTH READING ORGANIC FARMING GETS SOME RESPECT The National Academy of Science's AlternativeAgriculture lends credibility to an old-fashioned concept. W-1 v EXHIBIT 6 er• YOU ARE WHAT YOU 'BREATHE BY HILARY F FRENCH M 27 The chemical soup ho\,ering over cities is causing health problems around the globe. The cure for polluted air, coincidentally enough, would also slow global warning. IN OUR NEXT ISSUE DEADLY EXPORTS MAKE THE ROUNDS AFTER EARTH DAY: NOW WHAT? TIMBER POLICIES THAT SAVE TREES ALSO: India's green movement Soil erosion slows In the U.S. Brazil fights malaria with DDT The verdict's In on ecotourism To burn or not to bum? An environmental seal of approval VII`N• EDITORIAL BREADLINES AND BILLIONAIRES very night I pedal home past a van from Martha's Table, a Edowntown Washington charity that hands out sandwiches to the homeless. For vears now the line on the street corner has been growing steadily. This winter, for the first time, I saw mothers and small children. The lengthening queue is a personal reminder of the forces that are splitting humanity into haves and have-nots. The statistics are cold and appalling: The world today has 157 billionaires, perhaps 2 million millionaires, and 100 million homeless. It has half a billion who eat too much, and an equal number «•ho eat scarcely enough to stay alive. At the global level, as in the United States, equity of income distribution is worse today than at any time since records have been kept. The richest billion people consume at least 20 times the goods and services that the poorest billion do. The reasons are imbedded in the structure of the international economy. For almost a decade, the global marketplace has been acting like Robin Hood in reverse: Each year poor nations are paring rich ones S50 billion more in debt payments than they receive in new funds. Worsening this regressive financial flow is the plummet in prices for Third World exports. U.S. import limits on sugar during much of the past decade, for example, have created a situation in which Americans pay several times the world market price to sweeten our coffee with beet sugar from Minnesota while cane cutters nearly starve for lack of work in the Philippines. Militarism, meanwhile, adds its own trillion dollar drain. We humans spend $200 a year for each man, woman and child on the means of warfare, but we cannot seem to find the S 1 it would cost each of us to save 14 million children who die each year from simple diseases like diarrhea. Ending poverty is an en vironmental priority, too, because those at the bottom of the world's economic ladder are driven by hunger into clearing forests, overgrazing rangeland, and exhausting soil. Saving the earth -will remain little more than a pipe dream unless a floor is put under the poorest. The necessary steps are straightforward: bold debt relief, demilitari- zation, reduction of import restrictions, and rebuilding social service sectors —both at home and abroad —caught between spiraling needs and shriveling means. In exchange for a few of our worldly comforts, we the fortunate can gain a planet that is more peaceful, more sustainable, and more humane. Alan Durning Senior Researcher WORD WAMH Editor Lester R. Brown Managing Editor James P. Gorman Assistant Editor Howard M. Youth Staff Writers Holly Brough Alan Durning Christopher Flavin Hilary F. French Jodi L. Jacobson Nicholas Lenssen Marcia D. Lowe Meri McCoy -Thompson Sandra L. Postel Michael G. Renner John C. Ryan Cynthia P. Shea Marnie Stetson John E. Young Director of Communications Stephen R Dujack Design and Production Pensarc Design Group, Ltd. Worldwatch InstiWte Board of Directors Or%ille L. Freeman (Chairman) Lester R. Brown Carlo M. Cipolla Edward S. Cornish Lyrme Gallagher Mahbub ul Haq Hazel Henderson Annc-Marie Holenstein Abd-El Rahman Khan Lam• Minear Andrew E. Rice World Watch (ISSN 0996.0615) is published six times per year by the World%itch In- stitute, 1776 Massachusetts Avenue, N.W., Washington, D.C. 20036. O Copyright 1990, R'orldwatch Institute. Foreign sub- scriptions: S30 air mail. POSTMASTER: send address changes, orders and cor- respondence to World Watch, 1776 Mas- sachusetts Avenue, N.W., Washington,� D.C. 20036. MAY • JUNE 1990 0 YOU ARE WHAT YOU BREATHE Air quality is so bad in many cities that "smoggy," "smoky,"and "hazy" are now actual weather conditions. As the air thickens, human health worsens. Polluted air doesn't have to be the price of progress, though. BY HILARY F. FRENCH sked to name the world's top killers, most people .vouldn't put air pollution high on their lists. A nuisance, at best, but not a terribly serious threat to health. The facts say otherwise. In greater Athens, for example, the number of deaths rises six- fold on heavily polluted days. In Hungary, the government attributes one in 17 deaths to air pollution. In Bombay, breathing the air is equivalent to smoking 10 cigarettes a day. And in Beijing, air pollution -related respiratory distress is so common that it has been dubbed the "Beijing Cough." Air pollution is truly a global public -health emergency. United Nations statistics show that more than one billion people —a fifth of humanity —live in areas where the air is not fit to breathe. Once a local phenomenon primarily affecting city dwellers and people living near factories, air pollution now reaches rural as well as urban dwellers. It's also crossing international borders. - In the United States alone, rougtily 150 million people live in areas whose air -is con- sidered unhealthy by the Environmental Protection Agency (EPA). According to the American Lung Association, this leads to as many as 120,000 deaths each year. A century ago, air pollution was caused primarily by the coal burned to fuel the industrial revolution. Since then, the prob- lem and its causes have become more com- plex and widespread. In some parts of the world, including much of Eastern Europe and China, coal continues to be the main source ofpollution. Elsewhere, automobiles and industries are now the primary cause. Adding to the miasma, industries are emitting pollutants of frightening toxicity. Millions of tons of carcinogens, mutagens, and poisons pour into the air each year, damaging health and habitat near Their sources and, via the winds, sometimes thou- sands of miles away. Many regions that have enjoyed partial success combating pollution are finding their efforts overwhelmed as populations and economies grow, bringing in more power plants, home furnaces, facto- ries, and motor vehicles. Meanwhile, global warming has arisen as the preeminent environmental concern, sometimes conveying the misleading impres- sion that` conventional air pollution is yesterday's problem. But air pollutants and greenhouse gases stem largely from fossil fuels burned in energy, transportation, and industrial systems. HaNring common roots, 27 WORLD • WATCH Table 1. Health Effects of Pollutants from Automobiles' Pollutant Health Effect Carbon Monoxide Interferes with blood's ability to absorb oxygen impairing perception and thinking, slows reflexes, causes drowsiness, and can cause unconsciousness and death; if inhaled by pregnant women, may threaten growth and mental development of fetus. Lead Affects circulatory, reproductive, nervous, and kidney systems; suspected of causing hyperactivity and lowered learning ability in children; hazardous even after exposure ends. Nitrogen Oxides Can increase susceptibility to viral infections such as influenza. Can also irritate the lungs, and cause bronchitis and pneumonia. Ozone Irritates mucous membranes of respiratory system; causes coughing, choking, and impaired lung function; reduces resistance to colds and pneumonia; can aggravate chronic heart disease, asthma, bronchitis, and emphysema. Toxic Emissions Suspected of causing cancer, reproductive problems, and birth defects. Benzene is a known carcinogen. 'Automobiles we a primary source but not the only source. of these pollutants Source National Clean Air Coalition ane the U.S Environmental Protection Agency the two problems can also have common solutions. Unfortunately; policvrr►akers per- sist in tackling them separately, which runs the risk of lessening one -while exacerbating the other. Air pollution has proven so intractable a phenomenon that a book could be Nwitten about the history of efforts to combat it. Law has followed law. As one problem has largely been solved, a new one has frequently emerged to take its place. Even some of the solutions have become part of the problem: The tall smokestacks built in the 1960s and 1970s to disperse emissions from huge coal - burning power plants became conduits to the upper atmosphere for the pollutants that form acid rain. Turning the corner on air pollution re- quires moving beyond patchwork, end -of - the -pipe approaches to confront pollution at its sources. This will mean reorienting en- ergy; transportation, and industrial struc- tures toward prevention. 0 Chemical Soup Although air pollution plagues countries on all continents and at all levels of develop- ment, it comes in mangy• different varieties. The burning of fossil fuels —predominantly coal —by power plants, industries, and home furnaces was the first pollution problem rec- ognized as a threat to human health. The sulfur dioxide and particulate emissions as- sociated with coal burning —either alone or in combination —can raise the incidence of respiratory diseases such as coughs and colds, asthma, bronchitis, and emphysema. Par- ticulate matter (a general term for a complex and varying mixture of pollutants in minute solid form) can carry toxic metals deep into the lungs. Pollution from automobiles forms a sec- ond front in the battle for clean air. One of the -worst auto -related pollutants is ozone, the principal ingredient in urban smog. Formed when sunlight causes hydrocarbons (a by-product of many industrial processes and engines) to react -with nitrogen oxides (produced by cars and power plants), ozonto can cause serious respiratory distress. Recent U.S. research suggests that ground -level ozone causes temporary breathing difficult% and long-term lung damage at lower con- centrations than previously believed. Other dangerous pollutants spewed b} automobiles include nitrogen dioxide, car- bon monoxide, lead, and such toxic hydro- carbons as benzene, toluene, xvlene, and ethylene dibromide (see Table 1). At elevated levels, nitrogen dioxide can cause lung irritation, bronchitis, pneumo- nia, and increased susceptibility to viral in- fections such as influenza. Carbon monox- ide can interfere with the blood's abilin• to absorb oxygen, impairing perception and thinking, +slowing reflexes, and causing drowsiness and —in extreme cases —uncon- sciousness and death. If inhaled by a preg- nant woman, carbon monoxide can threaten the fetus's physical and mental development. Lead affects the circulatory; reproductive, nervous, and kidney systems. It is suspected of causing hyperact:i%4v and lowered learn- ing ability in children. Because it accumu- lates in bone and tissue, it is hazardous long • after exposure ends. Concern is growing around the world MAY - JUNE 1990 28 M it about the health threat posed by less com- mon but extremely harmful airborne toxic chemicals such as benzene, vinvl chloride, and other volatile organic chemicals pro- duced by automobiles and industries. These chemicals can cause a variety of illnesses, such as cancer and genetic and birth defects, yet they have received far less regulatory attention around the world than have "con- ventional" pollutants. Where the Breathing Isn't Easy With the aid of pollution control equipment and improvements in energy efficiency; many Western industrialized countries have made significant strides in reducing emissions of sulfur dioxide and particulates. The United States, for example, cut sulfur oxides emis- sions by 28 percent between 1970 and 1987 and particulates by 62 percent (see Figure 1). In Japan, sulfur dioxide emissions fell by ILLUSTRATIONS BY LAUREN HURD 29 WORLD - WATCH 39 percent from 1973 to 1984. The same cannot be said for Eastern Eu- rope and the Soviet Union, inhere hasty industrialization after World War II, pow- ered by abundant high -sulfur brown coal, Figure 1: Emissions of Selected Pollutants in the United States, 1950.1987 Million Tons 30 25 20 c� 15 10�� 5 Sulfur oxides Nitrogen oxides culates 1950 1960 1970 1980 1990 2000 Sra,ce a-a•c^ ­st wee ease o, Sur^mrs and Mes10n has led to some of the worst air pollution ever experienced. Pollution control tech- nologies have been virtually non-existent. And, because of heavily subsidized fuel prices and the absence of market forces gov- erning production, these countries never made the impressive gains in energy effi- ciency registered in the West after the oil shocks of the 1970s. Many developing countries also confront appalling air pollution problems. The lack of adequate pollution control technologies and regulations, plus plans to expand energy and industrial production, translates into wors- ening air quality in many cities. Urbaniza- tion in much of the Third World means that increasing numbers of people are exposed to polluted city air. A recent report by the United Nations Environment Program (UNEP) and the World Health Organization (WHO) gives the best picture to date of the global spread of sulfur dioxide and particulate pollution (sec Table 2). Of the 54 cities with data avail- able on sulfur dioxide pollution for 1980-84, 27 were on the borderline or in violation of the WHO health standard. High on the list were Shenyang, Tehran, and Seoul, as well as Milan, Paris and Madrid, • indicating that sulfur dioxide problems have by no means been cured in industrial coun- tries. Though conditions arc gradually im- proving in most of the cities surveyed, sev- eral in the Third World reported a worsening trend. Suspended particulate matter poses an even more pervasive threat, especially in the developing world, where the appropriate control technologies have not been installed and conditions are frequently dusty. Fully 37 of the 41 cities monitored for particulates averaged either borderline or excessive lev- els. Annual average concentrations were as much as five times the WHO standard in both New Dclhi and Beijing. Ozone pollution, too, has become a seemingly intractable health problem in many parts of the world. In the United States, 1988 ushered in one of the hottest and sunniest years on record, and also one of the worst for ground -level ozone in more than a decade. According to the Natural Resources Defense Council, the air in New York City violated the federal health standard on 340 days —two to three times a week, all summer long. In Los Angeles, ozone levels surged above the federal standard on 172 days. At last count 382 counties, home to more than half of all Americans, were out of compliance with the EPA ozone standard. Ozone is becoming a problem elsewhere, too. In Mexico City, the relatively lenient government standard of a one -hour ozone peak of 0.11 parts per million not to be ex- ceeded more than once daily is topped more than 300 days a year —nearly mice as often as Los Angeles violates its much stricter standard. The other automobile -related pollutants also constitute a far-flung health threat. The recent WHO / UNEP report estimates that 15 to 20 percent of urban residents in North America and Europe are exposed to un- acceptably high levels of nitrogen dioxide, 50 percent to unhealthy carbon monoxide concentrations, and a third to excessive lead levels. In a study in Mexico City, lead levels in the blood of 7 out of 10 newborns were found to exceed WHO standards. "The im- plication for Mexican society, that an entirefAlk generation of children will be intellectual- ly stunted, is truly staggering," says Mexican MAY • JUNE 1990 30 NX 1- chemist and environmental activist Manuel Guerra. Airborne toxic chemical emissions present no less of danger. In the United States, the one country that has begun to tally total emissions, factories reported 1.3 million tons of hazardous emissions in 1987, including 118,000 tons of carcinogens. According to the EPA, these emissions cause about 2,000 cancer deaths a year. These deaths fall disproportionately on certain communities. For example, in West Virginia's Kanawha Valley —home to a quar- ter of a million people and 13 major chemical plants —state health department records show that, between 1968 and 1977, the incidence of respiratory cancer was more than 21 percent above the national average. According to EPA statistics, a lifetime of exposure to the airborne concentrations of butadiene, chloroform, and ethylene oxide in this valley could cause cancer in one resi- dent in 1,060. Unfortunately, data is not so extensive for other countries. Wherever uncontrolled polluting industries such as chemical plants, smelters, and paper mills exist, ho-wever, emission levels are undoubtedly high. Meas- urements of lead and cadmium in the soil of the upper Silesian towns of Olkosz and Sla\vkoxv in Poland, for instance, are among the highest recorded anlvhere in the world. The health damage inflicted by air pollu- tion comes at great human cost; it also carries an economic price tag. The American Lung Association estimates that air pollution costs the United States S40 billion annually in health care and lost productivity. Clearing the Air In the Western industrial world, the last 20 years has been a period of intense political and scientific activity aimed at restoring clean air. The approaches to date, however, have tended to be technological Band-Aids rather than efforts to address the roots of the problem. Scrubbers, nitrogen -oxides conteol tech- nologies, and new cleaner -burning coal tech- nologies can all reduce emissions dramati- cally, but they are not the ultimate solutions. For one, they can create environmental prob- lems of their own, such as the need to dispose of scrubber ash, a hazardous waste. Second, they do little if anything to reduce carbon dioxide emissions, so make no significant contribution to slowing global warming. For these reasons, technologies of this Table 2. Violations of Sulfur Dioxide and Suspended Particulate Matter Standards, Selected Cities' city Sulfur Dioxide ParticU;ates' (number of days above WHO standard) New Delhi 6 294 Xian 71 273 Beijing 68 272 Shenyang 146 219 Tehran 104 174 Bangkok 0 97 Madrid 35 60 Kuala Lampur 0 37 Zagreb 30 34 Sao Paulo 12 31 Paris 46 3 New York 8 0 Milan 66 n.a. Seoul 87 n.a. Averages of readings at a variety of monitoring snes from 1980 to 1984 = For Madrid. Sao Paulo and Pans, the reading Is of smoke rather than particulates - Source United Nations Environment Program and World Heafth Organization. Assessment of UrDen Air Quality (Nairobi: Global Environment Monitoring System. 1988). kind are best viewed as a bridge to the day when energy -efficient societies are the norm and pollution -free sources such as solar, wind, and water power provide the bulk of the world's electricity: Improving energy efficiency is a clean air priority. Such measures as more -efficient refrigerators and lighting can markedly and cost effectively reduce electricity consump- tion, which will in turn reduce emissions. Equally important, the savings that result from not building power plants because demand has been cut by effciencv can more than offset the additional cost of installing scrubbers at existing plants. Using conservative assumptions, the Washington, D.C.-based American Council for an Energy Efficient Economy concluded that cutting sulfur dioxide emissions steeply with a scrubbers/conservation combination could actually save consumers in the Mid- west up to S8 billion. Similar rethinking can help reduce auto 31 WORLD • WATCH WV 0 emissions. To date, modifying car engines and installing catalytic converters have been the primary strategies employed to lower harmful emissions. These devices reduce hydrocarbon emissions by an average of 87 percent, carbon monoxide by an average of 85 percent, and nitrogen oxides by 62 percent over the life of a vehicle. Although catalytic converters are sorely needed in countries that don't require them, they alone are not sufficient. Expanding auto fleets are over,,A,hciming the good they do, even in countries that have mandated their use. Alternative fuels, such as methanol, etha- nol, natural gas, hydrogen and electricity; are being pushed by many governments as the remedy for the air pollution quagmire. Although these fuels may have some role to play eventually, they can by no means be viewed as a panacea [see "Filling Up in the Future," page 18]. Reducing air pollution in cities is likely to require a major shift away from automobiles as the cornerstone of urban transportation systems. As congestion slows traffic to a crawl in many cities, driving to work is be- coming unattractive anyway. Convenient public transportation, car pooling, and measures that facilitate bicycle commuting are the cheapest, most effective ways for metropolitan areas to proceed. Driving restrictions already exist in many of the world's cities. For example, Florence has turned its downtown into a pedestrian mall during daylight hours. Budapest bans motor traffic from all but two streets in the downtown area during particularly polluted spells. In Mexico City and Santiago, one - fifth of all vehicles are kept off the streets each weekday based on their license -plate numbers. As with power plant and auto emissions, efforts to control airborne toxic chemicals will be most successful if they focus on mini- mizing waste rather than simply on con- trolling emissions. Such a strategy also pre- vents waste being shifted from one form to another. For instance, control technologies such as scrubbers and filters produce hazardous solid wastes that must be disposed on land. The Congressional Office of Technology Assessment has concluded it is technically and economically feasible for U.S. industries to lower production of toxic wastes and pollutants by up to 50 percent within the next few years. Similar possibilities exist in other countries. Freedom of environmental information can also be a powerful regulatory tool. In the United States, "right -to -know" legislation requiring industries to release data on their toxic emissions has been instrumental in raising public awareness of the tlu eat, spur- ring more responsible industrial behavior. The Monsanto Company, a major chemical producer, was so embarrassed by the enormous pollution figures it was required to release in 1989 that it simultaneously announced its intention to cut back emis- sions 90 percent by 1992. Few European countries have released information about emissions from industrial plants, although that may change if the European Economic Community (EEC) issues a directive now in draft form on free- dom of information regarding environmental matters. Glasnost is gradually improving the environmental data flow in some Eastern European countries and in the Soviet Union, although much progress in this area remains ..,._ to be made. MAY . )UNE 1990 32 W-W • • Solution from Smog City In most parts of the world, air pollution is now squarely on the public policy agenda. This is a promising sign. Unfortunately; the public's desire for clean air has not vet been matched with the political leadership needed to provide it. Recent developments at the national and international levels, though constituting steps forward, remain inade- quate to the task. In the United States, for example, Con- gress is on the brink of adopting major amendments to the Clean Air Act of 1970 that will cut acid rain emissions in half, tighten emissions standards for automobiles significantly, and require much stricter con- trol of toxic air pollutants. Almost any legislation would be an im- provement. Tvvenry years after the act be- came law, 487 counties still are not in com- pliance. But the proposed legislation fails to address the problem at a fundamental level by not encouraging energy efficiency, waste reduction, and a revamping of transporta- tion systems and urban designs. Los Angeles —with the worst air quality in the United States —is one of the first regions in the world to really understand that lasting change will not come through mere tinkering. Under a bold new air - quality plan embracing the entire region, the city government will discourage auto- mobile use, boost public transportation, and control household and industrial activities that -contribute to smog. For example, paints and solvents will have to be reformulated to produce fewer ozone - forming fumes; gasoline -powered lawn mowers and lighter fluid will be banned; car- pooling will be mandated; and the number of cars per family limited. Even though the plan has been approved by all of the relevant state and federal agencies, implementing it at the local level will be a challenge. Most of Europe, though quicker than the United States to cut back sharply on the emissions that cause acid rain, has been slower to tackle urban air quality. Non -EEC coun- tries such as Austria, Nor,.vayl Sweden, and Switzerland have had strong auto emissions control legislation in place for several years, but until recently the EEC had been unable to agree on its own stringent standards. This finally changed in June 1989, when the EEC Council of Environmental Minis- ters ended a nearly four-year debate and approved new standards for small cars. These will be as tough as those now in effect in the United States. To meet them, small cars «ill have to be equipped with catalytic convert- ers. Although an important step forward, it's somewhat ironic that Europe sees its adoption ofU.S. standards as a major victory at the same time the United States realizes these regulations don't go far enough. In Eastern Europe and the Soviet Union, air pollution has only recently emerged as a pressing political issue as glasnost and the revolutions of 1989 opened up public debate. Air pollution in much of the region is taking a devastating toll on human health. Fledgling governments in Eastern Europe are under pressure to show some improvements. A Helpful Hand To make a dent in their pollution, Eastern Europe and the Soviet Union will need Western technologies and a dose of domes- tic economic and environmental reform. Given current economic conditions in these countries, money for purchasing pollution control, energy cfficiencv, renewable energy; and waste reduction technologies will have 33 WORLD ' WATCH �Xlvl to come in part in the form of environmental aid from the West. Aid of this kind can be classified as en- lightened philanthropy; since stemming pol- lution in Eastern Europe, where even rudi- mentary controls are still lacking, can vield a far greater return on the investment than taking further incremental steps at home. To illustrate this point, Sweden receives 89 per- cent of the sulfur that contributes to the acid rain poisoning its lakes and forests from other countries. Because much of this is of Eastern European origin, anything Swe- den does to combat emissions there helps at home. Air pollution is beginning to emerge on the political agenda in the Third World as well. In Cubatao, Brazil, a notoriously pol- luted industrial city known as "the Valley of Death," a five -year -old government cleanup campaign is starting to make a dent in the problem. Total emissions of particulates, for instance, were cut from 521,600 pounds a day in 1984 to 156,000 last year. Mexico City, too, is embarking on an ambitious cleanup. With the support of the World Bank, Japan, the United States, and West Germany, the municipal government is introducing a package of measures aimed at cutting automotive pollution dramatic- ally over the next two to three years. As part of the plan, driving will be restricted on certain days. Industrial countries are involved in a vari- ety of efforts to assist developing countries 0 with air pollution problems. The Interna- tional Environmental Bureau in Switzerland and the World Environment Center in New York City help facilitate transfer of pollution control information and technology to the Third World. The World Bank is exploring ways to step up its air pollution control activities. One proposed project involving the World Bank and the U:N. Development Program would help Asian governments confront urban air pollution, amor-g other environmental problems. Legislation recently passed by the U.S. Congress requires the Agency for Interna- tional Development to encourage energy efficiency and renewable energy through its programs in the interests of slowing global warming. This step will reduce air pollution at the same time. While the means are available to clear the air, it will be a difficult task. In the West, powerful businesses such as auto manufac- turers and electric utilities will strongly resist measures that appear costly. In Eastern Eu- rope, the Soviet Union, and the developing world, extreme economic problems coupled with shortages of hard currency mean that money for pollution prevention'and control is scarce. Overcoming these barriers will require fundamental modifications of economic stvs- tems. As long as air pollution's costs remain external to economic accounting systems, utilities, industries, and individuals will have little incentive to reduce the amount of pol- lution they generate. Taxes, regulations, and public awareness can all be harnessed to bring the hidden costs of air pollution out into the open. On the promising side, faced with mount- ing costs to human health and the environ- ment, people on every continent are begin- ning to look at pollution prevention through a different economic lens. Rather than a financial burden, they're seeing that it is a sound investment. The old notion that pol- lution is the price of progress seems finally to be becoming a relic of the past. • Hilary F. French is a senior researcher at the i Worldwatch Institute. She is the author of World - watch Paper 94, Clearing the Air: A Global Agenda. MAY • JUNE 1990 34 • • • WRONG TURN_ • Contd. from page 10 ofit. That figure was S79per passenger in 1989, says Transport 2000's presi- dent, Darrel Richards. Bouchard's analysis dismays other transport professionals, too, including Ross Capon, executive director of the Washington, D.C.-based National Association of Railroad Passengers. Capon cites the U.S. subsidy_ program designed to protect isolated commun- ities from losing air service, at a public cost of up to S515 per passenger. Whether or not people approve of that subsidy, he notes, they don't question the 6abihry of aviation as a means of transport. By shortchanging its rails, Canada is bucking a worldwide trend toward greater investment in high-speed rail, if not convenrional railway service. Canada's rail -busters dismiss successful train systems in Europe as inappropri- ate for Canada's long distances and small population. Yet, several discarded Via Rail lines serve areas with higher densities than those of France, Switzer- land, and Italy. Even harder to ignore is the experi- ence of Via's nearest neighbor, the U.S. passenger train service Amtrak. Created in 1971 by the federal govern- ment to replace the nation's failing passenger rail companies, Amtrak .vas at first heavily dependent on operating subsidies. But, by improving manage- ment and adding new revenue sources such as lucrative mail and express serv- ices, Amtrak boosted its cost recovery from 48 percent in 1981 to 72 percent in 1989. Overall, the railroad has cut its routes by only 4 percent since it began operation. Today, some routes are so popular that passengers have to book tickets weeks in advance. Amtrak president W. Graham Clay - tor jr. predicts that, with enough fed- eral help in buying new equipment to improve and expand the system, his railroad could cover all its operating costs by the year 2000—an achieve- ment no national passenger train serv- ice in the world can now claim. Whether or not Via Rail could ever make an Amtrak -style comeback, Canada is taking a giant step back- ward. Darrel Richards reassures Ca- \1-V I nadians it's not the end of the world — yet. Dearly a decade ago, successive transport department heads soon re- stored a good portion of services lost to government cuts. Richards urges rail passengers to keep protesting the cuts; otherwise, they may be in for a long haul. HOT AIR ON GLOBAL WARMING BY MICHAEL G. RENNER For unleashing the greatest num- ber of speeches, reports and con- ferences in the shortest amount oftime, the global %•arming issue is hard to beat. How, though, does one distin- guish real progress in doing something about this frightening phenomenon from mere political rhetoric? As with anything in the public policy arena, follow the money trail. A serious commitment to addres- sing global warming would be detect- able in increased government funding of research and development in energy efficiency and renewable energy sources. There arc no better methods for cutting back on the carbon dioxide emissions from fossil -fuel burning leading to climate change. Doubling the efficiency of energy usage cuts car- bon emissions in half, and such renew- able sources of energy as solar thermal power, photovoltaics, wind power, and geothermal energy don't produce any carbon dioxide in the first place. By that measure, all the talk about global warming has contributed noth- ;in more than hot air. k8cb spending on efficiency and renewables among members of the International Energy Agency (IEA), which is composed of 20 Western industrialized countries that consume about 45 percent of the world's fossil fuels, is wocfulhr inade- quate and has fallen precipitously since 1980. Expenditures to improve energy efficiency were off by one-third by 1988, while renewables declined b} two-thirds, wiping out gains made since the late 1970s. As ofyet, there is no in- dication that a turnaround of the mag- nitude and speed required will materi- alize [see figure]. True, global warming became a household word only in the scorching summer of 1988. Thus, one might be inclined to think that past spending patterns are of little relevance. But the notion of human -induced climate change was first put forward as early as IEA Government Spending on Renewables & Efficiency R&D, 1977.1988 N 1 aw Soo 200 soo Renewables Efficiency SW aoo 0 1977 1062 1087 Source Inlernationei Energy Agency 35 WORLD • WATCH TRE\? . - Cored. 1896 and atmospheric scientists have crafted complex computer models to verify it for more than 30 years now. Those in positions to make decisions did not need to wait until 1988. This is especialh. the case since an alternative energy polio• not only pre- sents a good hedge against the impon- derables of global warming, but also offers a cost-effective Nyay of addressing such Ion --standing concerns as urban air pollution, acid rain, and the inevi- table depletion of finite energy sources. Exceptions to this pattern are rare. Only Switzerland spent as much R&D money on renewables in 1988—S14 million —as it did during the peak years of the earl- 1980s. In the case of efficiency programs, the picture is only slightly more encouraging: The budg- ets of Italy, the Netherlands, and again Switzerland reached new heights in 1988. This was not enough to offset the calamitous decline for the IEA as a whole, though. It should come as no surprise that spending for renewables and energy conservation traces the ups and downs of crude oil prices. Following the oil crises of 1973-74 and 1979-80, West- ern governments were eager to pour resources into an• project that prom- ised energy independence. In fact, most governmental programs to boost en- ergy efficiency and to advance the de- velopment of reneNvables only came into existence in those years. BN'• 1986, when oil prices hit bottom, funding for renewables and efficiency was back to its meager pre -crisis level. It is understandable that efficiency programs ,were given short shrift when decision -makers wvere preoccupied -with trying to augment supplies. Today, however, supply is no longer the solu- tion; it is part of the problem. Yet, in only four IEA countries did renewables and energy efficiency R&D command the lion's share of *energy R&D budgets in 1988: Greece (76 percent), Austria (59), Sweden (49), and Portugal (47). Together, these countries account for less than 3 per- cent of IEA members' total energy consumption. Meanwhile, many governments con - W- tinue to believe in the gospel of nuclear power, despite that industr•'s shaky record and its un- resolved waste problem. Belgium, England. Ital; Japan, the United States, and West Germany spent more than 50 percent of their budgets on nuclear technologies. The United States spent more on nuclear fusion research alone than it did on efficiency and renewables together. And, even though it has hardly any coal reserves to speak of, Japan spent a larger share of its energy R&D budget (14 percent) on coal re- search than on efficiency and renew- ables (9 percent). It's worth taking a closer look at U.S. funding priorities because, as the world's largest consumer of fossil fuels, this nation's energy consumption pat- terns sway any effort to avoid climate change. Of all IEA countries, the United States devotes the largest abso- lute amount of money on energy effi- ciency and the second-largest amount, behind Japan, on renewables. How- ever, funding for both areas has been slashed much more drastically than in other nations, by over 60 percent for conservation (compared with 37 per- cent for all IEA members) and by close to 90 percent for renewables (IEA: 67 percent). Besides research and development, the U.S. federal government's energy conservation budget also encompasses grants to state and local authorities for weatherization and other conservation projects. These expenditures shot from 0 IOxt rls W Jnms exes at I Po o nzk tlur o, tsue d enue m tuo,pei a totr yni onen,s cc�se s• • ene nu .., u...s ere rune.. . It zero in 1975 up to nearly S 1 billion in 1979, but have since fallen to about S200 million. In its fiscal year 1991 budget, the Bush administration would slash these grants to a mere S30 mil- lion, something Congress will prob- ably resist. Sadly, the story of R&D spending in IEA member nations is one of missed opportunities. If outlays had been maintained at their earIN-11980s level, or even increased further, the world would now be a big step ahead in the struggle against climate change. It's likely these governments will steer more money to conservation and alternative energy programs, but the go-slow atti- tude on the greenhouse effect that now seems to predominate in Washingtoo and some other capitals is not an en- couraging sign for those who want to see a substantial increase in funding. MAY - JUNE 1990 36 OCIVI tSl'�MiG MROpOLITAN ME TRANSPO TATION COMMISSION TQ:Commission • Fr: Executive Director Rei Cal trans Pom,,.+ *, ;11-21-80 ; 4:48PM ; MEMORANDUM MTC-4 dt638701;# 2 JOSEPH p SORT METROCENTER OAKLA D, CA5TRIET 94607 41 d/464•7706• FAX 41 S/464.7848 Date; 11 /09/90 .I.: On October 25, Caltrans forwarded a proposed I-80 project to MTC for review and approval. As currently designed the project would provide a westbound HOV from nest of Route 4 in Contra Costa County .to the Bay Bridge. and an Eastbound HOV from north of Powell Steet to just west of Route 4. The r project would also totally reconstruct the I-80/1-580 (Knox) interchange. Attachment 1 is a map illustrating the project. As proposed, this project: • does not meet the objectives (Attachment 2) adopted by the Commission In February, 1990 • does not fully address. the standards established by Resolution No. 2107 • leaves unanswered several critical questions regarding when and how a satisfactorily designed facility can be built. We recommend that Caltrans resubmit the project in deficiencies and request Commission endorsement of insists on cooking the Commission aWNt'vv41 of proposed, we will propose that the Work Program Review and Allocation Committees recommend that project at next month's meeting. . ,, In 1983 MTC approved Project provided for reconstruction of the Administration (FHWA) flow widening through continuous HOV lanes. order to satisfy the above that position. If Caltrans the project as currently and Plan Revision and Grant the Commission reject the Caltrans' first proposal for the I-80 project. This some HOV lanes and some widening. It did not include I-80/Knox interchange. Berkeley and -the Federal Highway objected to the project, Berkeley because of the mixed Berkeley and FHWA because the project did not include Caltrans responded with a redesign. In June, 1989, MTC wrote Caltrans regarding design deficiencies. The project was over budget and lacked integration with transit improvements in the corridor, particularly at Del Norte BART Station. In October, MTC adopted Resolution No. 2107 which sets forth MTCs policy with regard to the air Quality review of projects like I-80 . . EXHIBIT 7 o � SENT BY:MTC ;11-21-80 4:49PM ; MTC- 95547014 Memo to Commission Page two • In an effort to help Caltrans develop a project that addresses Resolution No. 2107, and that could be implemented within budget, MTC convened a series Of meetings with representatives from Caltrans, Alameda and Contra Costa Counties, and Berkeley (the I-80 working development, and adoption by the Commision— in)Februare,1990,meetings led to the Objectives (Attachment 2) to guide the design of the I-80 project. f The smotion approved by the Commission was as follows: I. Adopt the objectives (Attachment 2). 2. Advise Caltrans that its project is subject to delay if it fails to adhere to Resolution No. 2107, and 3. Advise Judge Henderson that the I-60 project design review is representative of the Commission's commitment to achieving hi hwa design that will not be significantly adverse to air quality. g y Prro Costs One goal of the I-80 working group was to develop a "fundable" project, that 1s, a project that could be delivered within the amount programmed in the 1988 STIP ($219 million). The cost estimates for the I-80 design at that time were over 5100 million more than the funding contained in the STIP. Representatives of Alameda and concerned with the project budget beContra Costa Counties were particularly cause of the negative impact cost overruns would have on the programming of other high priority transit and highway pro ects 1n their counties. The 1990 STIP programs $269 million for this pro ect. The current estimated cost of the project is ;282.8 million, -achieved only by stripping the project Of several elements. Because this amount 1s greater than 120% of the 1988 STIP CTC advises that MTC AU both counties will be required to make a finding that the project is still "cost effective". On September 19th MTC received from Caltrans the Executive Summary of the Draft Environmental Reevaluation and the air quality analysis. We reviewed the analysis with Caltrans staff, and as a result, sent a draft letter on September 28 detailing our concerns with the analysis and stated that seeking approval from FHWA was premature. The air quality analysis, while still lncomplete, indicates that not all appropriate transportation control measures in the proact design have been incorporated. In our draft letter we outlined the mil gation measures which we believed to be appropriate. However, the centerpiece of the Caltrans redesign is the reconstruction of the 1-80/Knox interchange, and Caltrans has omitted a portion of the HOV and features that are needed to make the HOV lanes work effectively. We followed the draft letter with a meeting with the working group To advance the discussion, we prepared a list of design (Attachment 3). Theseave g priorities representatives, emphasizedithe tneed tohbuild hHOV lanes, of the county , provide for the HOV u -------------------------------------------------- SENT BY:MTC ;11-21-90 ; 4:50PM ; Memo to Commission Page three MTC-* 95536701;# 4 enforcement, and provide for transit use of the HOV lanes. (In earlier discussion, the transit operators in the corridor - BART, AC, WestCat and Vallejo - stated that they would � bo able to use the MOV lanes as previously designed because they could not safely exit through three lanes of congested traffic to access El Cerrito Del Norte BART station. This station is being developed as a M&JZ corridor transfer point between BART and all of the bus sarvices for West Contra Costa and Solano counties.) Attachment 4 is a map reflecting these priorities. Two days later we learned that the project was being forwarded to MTC for approval without regard to its deficiencies or suggested improvements. The September draft letter was formally sent to Caltrans October 29 (Attachment 5). Copies of this letter were distributed at the last Commission meeting. Alameda and Contra Costa Counties may be adversely affected if this project, as proposed, is delayed because the funding would slide into the next funding cycle (quinqueneum). This could undermine the counties position in bidding on other high priority projects. The counties representatives have said it may be necessary to forego the I-80 project 1f it threatens to have this adverse impact. In this summary we have limited our comments to the project design and budget and the need for further improvements consistent with previous Commission direction. Based on this review, we recommend Caltrans withdraw its request for project review approval by MTC at this time until the deficiencies noted above are addressed. 2-6--- -- Lawrence D. Dahms LDD:WFH:dg:O150¢2 SENT BY:MTC ;11-21-90 ; 4:51PM MTC-► 95ti36701�# 5 Attachment i • DESIGN CONCEPT: Ultimate design sntaLt oorrtinuoua HOV lane In Moth derrotbne, plus adding mbnd flow oapaoMy through MAOMy of oorrldor, and redesigning 14WKnox lrrterohangs (almost 1100 m011on). TOTAL COST is $600 • $800 m11110n, Fundable design, Ocrrstrained by available money (111121W WHOM, entails 40/Knox INVO1102e and most of HOV kne but deletes a poRbn of sastbound HOV Irv, direct HOV mom ramps, mbad flow lanes, and recommnxotlon of most Irdsrohanpes, sp A. .`�.,...._. CONTRA COSTA COUNTY: Ultimets design antalis continuous MOV lanes, sastbound mixed now and auxiilary lanes, moons ClIon Of moss Intsrohangss and direct HOV ramps at Willow and Atlas. I<Undable deeipn deletes mixed flow lanes, Interchangs reconstnratlon and direct MOV ramps. ALAMEDA COUNTY: Uttlmate dnlgn entails . adding MOV and mlxsd flow lanes In each direction, direct NOV ramp at Ashby, reconstruction of &II fiterchanges and mpor rsdnlQn at 4 x1luchanan r Interchange. fundable design includes entire westbound HOV lane and I.60rKnox Interchange but deletes direot aoase ramps, MOV enforcement , area, and eastbound MOV Mno from 71:11 Plus to I Powell Street, m 6wh o. N11140 c � SENT BY:MTC ;11-21-90 ; 4:52PM ; MTCy I-80 OPERATIONAL IMPROVEMENT (HOV) PROJECT REDESIGN I) MTRONMENT Fog PROIECT DESIGN PURPOSES 95638701;# 5 HzzaCnmenz c A) (10 Year Horizon) • o Hannigan' Rail (Auburn - San Jose), possibly via PCL bond o BART's enhancements (Daly City turnback, central computer, etc.) o Ferry Service; Vallejo, plus a subset of Richmond, Jack London Square/Alameda, or Berkeley o Express bus service to del Norte BART station (Vallejo, BART, AC) o Implement AC Transit Comprehensive Service Plan B) Traffig r, tewayshi (These constraints apply to the design of the I-60 project and are not intended to pre -judge other -projects). o No additional mixed flow lanes across Carquinez Bridge (3 mixed flow lanes in each direction) o No additional mixed flow lanes through Distribution Structure o No additional mixed flow lanes southbound on Knox Freeway (2 mixed flow lanes for at least 1,000 feet north of I-SO/Knox) o Route 4 (westbound) to I-80 (southbound) 2 mixed flow lanes; design considerations may further limit capacity . o HOV or transit priority lanes may be added at any of the gateways C) Other Key Constraints/Concider bons o Funding for an operable project limited to approximate level in 1988 STIP ($240 million) o I-80 is major inter -regional route for freight and recreation o MTC Resolution No. 2107 (air quality) and state/federal air quality standards o Long term growth management issues II) SUCTIVESICRITrRIA o Reconcile mobility and air quality o Reduce congestion and delay o Operationally balanced system o No increase in air pollutant emissions; a decrease is desired o Sustainable benefits via system management o Safe to operate Of o Establish commitments to multi -modal package of improvements o Affordable (North/South split and county minimums) JG/mmm 6529p/2 (1/24/90) Adopted by Commission February 28, 1990 SENT BY:MTC '11-21-90 ; 4:52PM MTC-+ b:04 UI ;9 7 Nttacnment s 1-80/Air Quality Working Group 10/23/90 Jiff Georgevich MTC adopted Resolution No. 2107 in October, 1989 and immediately formed the I-SO/Air Quality Working Group to explore how Resolution No. 2107 would apply to the I-80 Operational Improvement (HOV) Project. The attached design guidance was prepared by the Working Group and subssquentl-y adopted by the Commission in January 1990. The guidance has been used by the Working Group to evaluate the various designs for 1-80 produced by Caltrans, although a design that all members of the Working Group were satisfied with has not yet been put forward, It's our understanding that cost escalation has necessitated revising the scope of the "fundable" project. This memo sets forth a prioritized list of the various design components, and is intended to help focus the Working Group's discussion of the revised project scope. DESIGN PRIORITIES 1) Continuous HOV Lanes, Bay Bridge to northwest Contra Costa County * HOV lanes need to extend through the Distribution Structure * HOV lanes need to extend through Knox/i-80 interchange, but full reconstruction is not required * Northern terminus dependent on available funding 2) Shoulders/Enforcement Areas * Fundable project needs to provide adequate shoulders and enforcement areas * Enforcement area in Alameda County may require reconstruction of University Interchange 3) Air Quality Mitigation for CO Violation * TMP (fully -funded) needed for construction -period mitigation * direct transit access at del Norte (and University if it is reconstructed) must be provided to accommodate long-term transit usage of HOY lane * direct HOV access at Atlas and Willow * Permanent Park/Ride lots needed for transit and HOV incentive 4) Knox/1-80 interchange with all HOV movements SENT BY:MTC ;11-21-80 ; 4;53PM E 0 1 1 0► I YL" • " •,�a�nr�r►A�atAsr�'LM1 a • a Oat'iaror►Aasd Nsw�aucwn/RA�Madhtaofrrr htfardrrlf� ittaownwnt MTC-+ 85838701;# 8 Attachment 4 DISION CONOEP'P Pravfda HOV lsnsa from Toll Pius to Wirbw. Inoludlne direct NOV ramps at Wpbw, Atlas, del Norte BART and tpouibw Unfwratiy, median NOV anioraoarn*nt areas, Perichlda lot$ and corutWlon period TMP. Postpone MOrny of i-lOA(nox Mterohanp$ 10 00w avallbls funds to be %*wW on HOY system. CONTM VXTA COUNTY: Provide o0rr I"Us NOV loss, @Moroemant stet$, parWrlds lots at Wtibw and Atha, dlraot access ramps at WAbw and Atlas plea now and roM at del Nate BART, nee noonetruotbn. ALAMEDA OOUNTY: Provide contUxlous NOV lefts rwrth of TO 1S ►�''" Plut-roconstwon of Ur►Ivsrehy Interchange, Inoiudtrre NOV anforcamant area and poubiy a dir@ot we ramp Into NOV Ian$. NOV Ian@ throuph Knox httarohenpa would in built as rovereible, "met prowl" ran@ on NN I wand sw of westbound visduot. MTOOMOft.w11141 v � SENT BY:MTC ;11-21-90 ; 4:54PM ; MTC-► METROPOLITAN TRANSPORTATION COMMI ION 95536701;# 9 Attachment 5 October 29, 1990 AIAnv,In c:.unlr DAYID S. KARP EOWARD R. CAMIRELI C"111 V1513cnwnl, Mr. Preston Kelley, Director RO"AT I. scm,0011 Cal trans District 04 STM WHR P. 0. Box 7310 v;«chaft San Francisco, CA 94120 marls counly ROHAT e. SYOCJ(*1LL Dear 4rqelley: FRro N[C:RI Thank you for sending us the Executive Summary of the Draft CioyamecaKY Environmental Reevaluation for the I-80 Operational Improvement (HOV) Project, We have reviewed the air quality section of the Don w.KAHN reevaluation and met with your staff to discuss the analysis. HARRY c. sRITT Continuing concerns with the project relate to both the project son maw) cDsarly IANI SAKII design and air quality analysis, At your request, these concerns were described to you in a tLgit of this letter transmitted TOM NOLAN 3en1e eu'e on September 28, 1990. Counly km[I T. 81ALL, ►1. Underlying y the current analysis s are questions about whether the FREQ ROD DIRIooN simulation accurately reflects the capacity and speeds on the CNIiPe,bh freeway, considering geometrics and diversion of traffic onto San wan Cwty Pablo Avenue and other alternative routes. The analytical JAMB SPIRINC requirements for air quality stemming from MTC Resolution No. 2107, fpNpgIA CDJeIy WILL14M R. L�clw� adopted in October 1989 and discussed at length with your staff, entail operational y P tional analyses of future speeds and volumes on major AYOeiel-,of fey A•ee Ocyt- men" roadways within a corridor. We have worked with project sponsors and consultants to develop appropriate methodologies and analyses DIANNI MCxINNA for several major projects, including the Willow Pass grade project an CC-4, SCI-87, I-880/Tasman Drive, and replacement s' ""r`ewdoo "l end mmmlol of the Cypress Structure, Wed .on our experience with these and other projects, ANCuo J. SAACUM we have found that analyses that meet the requirements of MTC Resoi ution No. 2107 can be prepared in a timely manner. Veto Rusimei{, Trenevonedonand mavolns ARenCy We are pleased to see that the environmental analysis is now rR11ToN KILLIy addressing the fundable project. The 2005 air quality analysis for the "fundable" project indicates that the federal state and eight -hour standard for carbon monoxide (CO) would be violated along the freeway. The possibility of CO violations on nearby local roads that parallel I-80, or provide access to it, was not examined. MTC's guidance for air quality analyses states that analysis of `ee local routes is optional, but we believe that the analysis is necessary in this corridor. LAWRIwee D. DAMMs D t y1W%+ilVr1')iF" r WILLIAmF,HIIN Absent an agreement between our two agencies on the air quality analysis, the Environmental Re-evaluation should be viewed as a draft, and transmittal of this draft document to the Federa' Highway Administration for approval is premature. JOSEPH P. BORT METROCENTIR 0 101 EICHTM STREET 01 OAKLAND, CA 94607.4700 0 415/464.7700 • FAX 415/464.7848 o-.---------------------------- --------------------------- SENT BY:MTC ;11-21-80 ; 4:55PM ; MTC-i 85538701;#10 Mr. Preston Kelley October 29, 1990 Page Two Regarding design issues, several important elements have been deleted from the fundable project due to cost considerations. These include park/ride lcts an; direct access HOV ramps, Other design features that serve as feasible mitigation measures include ramp metering with HOV bypass ramps, a direct access HOV ramp for express buses near the EI Cerrito del Norte BART Statior, provision of a continuous HOV lane eastbound from the Bay Bridge through the Distribution Structure to Willow Avenue, and continuation of selected elements of the reconstruction period Traffic Mitigation Plan, Cue to the projected CO violation, additional mitigation is desirable, We suggest teat the mitigation measures listed above be re-examined for incorporation into the fundable project concurrent with cost -saving design changes in other parts of the project. We are available to meet with you nd your staff at your convenience to a discuss any questions you may have on our comments. Sincerely yours, eence D, Dahms Executive Director LDD:JG:jlr:7931p2-3 CC: Bruce Cannon, FHWA Tom Powers, Chair, I-80 Reconstruction Advisory Committee Commissioner Campbell Commissioner Karp Commissioner Schroder Commissioner Weir .0 btlVl tr:Mlu ;li—zI-yu ; 4;:t1`1M ; MiG-+ 85538701;;e11 Alameda Count) DAVID S. KAit► EDWARD R. CAMr11tt Conan Costa Ceun,y R0111T I. se"10011 STIVl will Vice-Cwt Mein C901, 40111T S. STOCCWitl Neal COYntY Faso ► ec1, Ilan ►ra-C ,e� City ant) count, Dolts w, KAM, KkAtt C. bury 1&n MA106 Cevrq JANI SAR(1 Tom N04AN font& C+Iv Cevr'. JAMIf T, S1Att, 1110 . Rea DuuooN Ch&Itieisw, fol&no Ceunty JAMu srlclko sohof i COun!y W11ttAM R. t6civ1 AsllKiiheP 01 toy Aces Cev,,nngnt, OIAMNI aMCKlhkA S I. sly Cense-vat,an Ied Dayelopmeni Cwrmsslon ANC11D {. SIAACUfA 51111 lustress TnMHOMfion Ina elovsfnl Aleney P2117oN Kltuy I■eevilve D.�neelo, LAWAINCI D. DAMMI oePutY hefwNe 0.1"to• 0 W1411AM F. M11N MTC METROPOLITAN TRANSPORTATION C0MMISSIC►N September 28, 1990 Preston Kelley Director, Caltrans, District 4 P.O. Box 7310 San Fra i 5 o, CA 94120 Dear elley; Attached is a copy of the letter we intend to send you-elative to I-80, You suggested at the CMI Ssion meeting we consider it still a draft until we can get together and discuss it. Therefore, I are sending it to you now withc::t signature, I will! be in Houston, Texas until next Thursday after,'oon, we need to jeet as soon thereafter as we can, I will not send the cc$ to anycr.-e until we have mot and the letter is signed. L0D;0g;0001Qi18 Sincerely, Z7Lawr nce D. Dahrs 41EXe utive Director )OSIPH P. BORT METROCINTIR 0 101 EICNT01 STREET a OAKLAND, CA 94607.4700 is 41S/464. • 0 C IIA GUIDE FOR ENVIRONMENTAL RESTORATION IN ORANGE COUNTY T here is a parable: If a frog leaps into a pot of scalding water, it will leap out. But if it leaps into tepid water which then heats slowly to a boil, the frog will remain... until it perishes. A peculiar quirk of nature, some thought... until we realized that we are like the frog." ANONYMOUS ORANGE COUNTY. CALIFORNIA 19S9 EXHIBIT 8 IIA GUIDE FOR ENVIRONMENTAL RESTORATION IN ORANGE COUNTY Herein are summaries of eleven major environmental issues. Each overview includes (1) key facts, (2) predicted outcomes of existing patterns, (3) a resolution for corrective policies, and (4) actions which each person can perform to help reverse environmental degradation in Orange County. TABLE OF CONTENTS 1. INTRODUCTION: Why we must act now ............. 1 2. EDUCATION: We must learn— and teach one another— why and ............. 3 how to care for our environment 3. AIR: The maintenance of human health, comfort and productivity ............. 5 mandates a prompt significant reduction in air pollution 4. WATER: Wastage and contamination of water must be curbed in ............. 9 order to meet increasing demands for this essential commodity S. TRANSPORTATION: Transportation systems must be radically ............ 13 altered while there is still time to make a free choice 6. NATURAL UNDEVELOPED LAND: Remaining fragments of ............ 15 our vanishing natural surroundings must be preserved and restored 7. NATIVE PLANTS AND WILDLIFE: Preservation of other life- ............ 17 forms is essential for our long-range vitality and survival 8. WASTE: Immediate steps in source reduction and recycling are ............ 21 required to head off a pending disaster in waste management 9. URBAN LANDSCAPE DESIGN AND MAINTENANCE: ............ 25 The urban habitat requires more appropriate selection, location and care of plant materials 10. ENERGY: Excessive energy consumption must be curbed, and energy ............ 29 sources better utilized to avert local and global disasters 11. NOISE: Physical and emotional health demand reduction in sound ............ 31 pollution 12. POPULATION: Voluntary curtailment of geometric population ............ 33 growth is key to long range survival and an acceptable quality of life 13. SUMMARY AND RESOLUTION ENDORSEMENT: The .......... 35 Orange County environmental restoration "Call to Action" • A GUIDE FOR ENVIRONMENTAL RESTORATION II IN ORANGE COUNTY Compiled by Tom Larson Tom Larson, a business executive and horticulturist, is a native of Orange County. The father of four children, Tom began assembling The Guide as a result of concerns for Orange County's environment, and a hopeful awareness that people, indeed, do care. Many helped along the way, therefore... Grateful acknowledgement is extended to the following individuals who helped design and develop this guide as one more of their expressions of concern and appreciation for the Earth and its life forms: Alden Kelly, Ph.D., Arborist; Director, Tree Society of Orange County Dave Bontrager, Field Biologist; Educator Peter Bloom, Research Biologist, National Audubon Society Elisabeth Brown, Ph.D., President, The Laguna Greenbelt, Inc. Victor Leipzig, Ph.D., Educator; Immediate Past President of the Amigos de Bolsa Chica Peter Bryant, Ph.D., Developmental Biologist, UCI Virginia Chester, President, Sea & Sage Chapter, National Audubon Society Lauri Aunan, Attorney; Chairwoman, Sierra Club SCOPE Committee Robert Ward, Former Mayor of the City of Fullerton; Coyote Hills Committee Fern Pirkle, President, Friends of Irvine Coast Peter DeSimone, National Audubon Society, Manager, Starr Ranch Sanctuary Marie Patterson, Vice President, South Coast Audubon Chapter Jean Watt, Vice President, Orange County Fund for Environmental Defense, Councilwoman, Newport Beach Diana Glass, President, Save the Oaks and Slopes Peter Bunge, Ph.D., San Clementeans for Managed Growth Sharen Heath, Writer, The Hummingbird Group • This document is printed on regvIed paper. PRINTING: THE PROMOTE ENVIRONMENTALISM COMPANY (714.645.3164) TYPESETTING: THE HUMMINGBIRD GROUP (714.494.6703) • A GUIDE FOR ENVIRONMENTAL RESTORATION II IN ORANGE COUNTY I HAVE -READ "A Guide for Environmental Restoration in Orange County" AND I SUPPORT THE RESOLUTION WHICH IT CONTAINS. Signed, SIGNATURE DATE PLEASE PRINT NAME PHONE STREET OR P.O. BOX CITY/STATE ZIP CODE IN ADDITION TO MY PERSONAL ENDORSEMENT; I represent the following organization or agency, and as of that group, I certify their acceptance and endorsement of this resolution. ORGANIZATION NAME PHONE ORGANIZATION MAILING ADDRESS Comments? Please sign and return this page only to TOM LARSON 26516 Avenida Veronica Mission Viejo, California 92691 IIA GUIDE FOR ENVIRONMENTAL RESTORATION IN ORANGE COUNTY has been endorsed by the following organizations: Orange County Sierra Club The National Audubon Society -- Sea and Sage Chapter The National Audubon Society -- South Coast Chapter Laguna Greenbelt, Inc. Amigos de Bolsa Chica Friends of Irvine Coast San Clementeans for Managed Growth Tree Society of Orange County Tri-County Conservation League Laguna Canyon Conservancy Symbion Society Interfaith Peacy Ministry of Orange County Alliance for Survival Gridlock SPON (Stop Polluting Our Newport) SOS (Save the Oaks and Slopes) Rural Canyon Residence Association Rural Canyon Conservation Fund Friends of San Mateo Creek California Native Plant Society, Orange County Chapter • Orange County Fund for Environmental Defense Friends of Tecate Cypress Permaculture Institute of Southern California • A GUIDE FOR ENVIRONMENTAL RESTORATION II IN ORANGE COUNTY AN OPEN LETTER TO THE PEOPLE OF ORANGE COUNTY, CALIFORNIA: This message is being sent to Orange County citizens, including leaders in government, business, academic and other professions. The accompanying "Guide for Environmental Restoration in Orange County" outlines actions and objectives which must be accomplished for the health and well being of all of us. The guide has been endorsed by many groups and individuals concerned with our deteriorating environment: additional support continues to be registered as more Orange County residents learn of the project. We seek your active involvement in this important movement. Your personal influence can be significant. An increasing number of people are seeking ways to correct the environmental problems that have developed: your participation is needed to help assure a wholesome, beneficial existence at the present time, and a legacy of quality life for following generations. We are at a turning point in- public attitude toward environmental stewardships. More and more individuals and groups accept, practice, and demand responsible behavior at all levels, in all areas of human activity. The groundswell of environmental concern is coming spontaneously from the people: it is not merely a momentary fad, or a catchy political promotion. Citizens are calling upon fellow citizens and leaders alike to respond appropriately to the need for wise, effective action to repair and stabilize our damaged environment. Leaders who mount constructive programs to protect and restore our surroundings will win the respect and support of their constituencies. We ask you to read the Guide carefully, and identify those areas which you can address within your own sphere of influence. You are invited to express your support by completing and returning the form on the last page of this document. If you want to multiply your individual effectiveness, you can join forces with one of the many organizations which support and promote the aims of this document. • You are also welcome to duplicate and distribute copies of The Guide. December 1989 • A GUIDE FOR ENVIRONMENTAL RESTORATION II IN ORANGE COUNTY INTRODUCTION EACH DAY BRINGS MORE HARD EVIDENCE of dangerous abuse of the global ecosystem 'through human activity. Orange County's burgeoning population is contributing to the environmental crisis. Competent, credible authorities predict natural and economic crises from continuing overpopulation, pollution, and loss of natural resources. The longer we delay in making necessary changes, the more severe problems will be. Delay will also make the demanding tasks of correction even more difficult and costly. • On the positive side, there is sufficient time to avert a worldwide debacle if we act now. Appropriate policy changes and individual actions can reverse the environmental deterioration, without excessive demands on individuals or society in general. We can make the choices and carry out the activities needed to assure a safe, wholesome, desirable existence— for ourselves, our children, and our grandchildren. Orange County can play a major role in establishing a more environmentally sensitive society. It is time for its to become pacesetters in restoring our. surroundings. Our children, and their children and grandchildren are entitled to a legacy of clean air and water, attractive surroundings, and the option of working for a good life. We have an inter -generational responsibility to the children of today, the adults of tomorrow. A measure of self-restraint and discipline is a small price to pay -for assuring a comfortable, secure and prosperous future. Orange County residents are already demonstrating their willingness and ability to do this as individuals: It is essential to require corresponding stewardship roles on the parts of the government and business interests. This guide outlines measures which can diminish or avert the impending disaster. 0 AN ORANGE COUNTY GUIDE - PAGE 3 EDUCATION A GREAT DEAL OF HUMAN MISUSE of the environment has arisen from ignorance. We need much more knowledge about the organisms with which we share this planet, and about our dependence upon them. Nature makes no allowance for ignorance: our well-being is absolutely dependent upon stable natural surroundings. Our welfare, indeed our very survival will hinge upon how well we manage our natural resources. It is imperative that we learn and apply sound environmental principles. Only through understanding the influence of our actions on the balance of nature, and the dependence of humans upon natural balance, can we see that ecologically beneficial activities are in our own best interests. We must learn, teach and practice the methods for protecting our habitat. EDUCATIONAL RESOLUTION A We hereby resolve to promote the following actions and objectives. 1. Work with all school districts to establish comprehensive, practically -oriented kindergarten through 12th grade programs in environmental education by 1992; 2. Recommend that by 1992 the State Superintendent of Schools and Curriculum Commission create, and mandate for kindergarten through 12th grade, environmental curricula emphasizing the protection and conservation of natural resources; 3. Strengthen and promote standards for environmental preservation/protection practices, and make educational materials available to residential, commercial, industrial and agricultural entities; 4. Support ecological research, especially in regard to endangered species. PAGE 4 • ENVIRONMENTAL RESTORATION PERSONAL ACTION FOR ENVIRONMENTAL EDUCATION 1. Learn what you can do about the Earth's fragile environment. 2. Teach, share and exchange with others through your words and actions. 3. Help children to understand natural systems and how our individual behavior can enhance or harm our surroundings. 4. Join and support organizations involved in environmental protection. 5. Work with the P.T.A. to encourage environmental education. 6. Encourage teachers and school principals to stress the environment in science • classes, and to promote environmental clubs for students. 7. Provide programs and activities for scouts and for other young people's groups from schools and churches. 0 AN ORANGE COUNTY GUIDE - PAGE 5 THE SOUTH COAST AIR BASIN has the unhealthiest air in the nation. This condition generates an economic loss estimated to be over $8 billion per year. The pollution level here is projected to increase 25% by the year 2010 and by 50% by the year 2020, if we continue our current practices. Industrial pollution, increased emission from engines which burn fossil fuels, unrestricted release of synthetic chemicals into the environment, and the elimination of oxygen -producing trees and other plants are all major contributors to our regional air toxification and to the global warming problems. Left uncontrolled, intensifying air pollution will further increase the frequency and severity of personal illness, and significant economic setbacks. The promotion of global warming and related climatic changes will adversely affect our quality of life. As a coastal community, Orange County should be especially concerned with the possible rise in sea level that could accompany global warming. AIR QUALITY RESOLUTION We hereby resolve to promote the following actions. 1. Uphold the 1989 South Coast Air Quality Management District Plan for achieving cleaner air; 2. Support these policies and goals: (a) Reduce carbon -based fuel emissions starting in 1990, to 30% of current level by the year 2000, and 50% of the current level by the year 2010; • b Construct clean, safe mass transportation systems instead of new freeways; PAGE 6 • ENVIRONMENTAL RESTORATION 0 (c) Reward drivers and companies for car-pooling and for using non -fossil fuel burning engines; (d) Introduce fuel taxes designated for implementing clean mass transportation systems, energy research, and restoration of environmental deterioration caused by automotive and truck emissions; (e) Ban, or sharply restrict, the use of chlorofluorocarbons (CFCs) by 1991; (f) Increase Orange County's urban forest by 80% by 2000, to conserve energy, clean the air, generate oxygen and limit global warming; • (g) Preserve Orange County's undeveloped natural land as our buffer for clean air and as protection against global warming; 3. Exert influence upon the Environmental Management Agency to coordinate with other governmental agencies in developing an annual county environmental status report to the public, commencing in 1990: the report should disclose the status of the air, water and soil pollution and of hazardous waste; the report should include a listing of resources lost to development, and the condition of remaining resources; annual reports after 1990 should include the net change from the previous period's analysis and trend -based projection. 0 AN ORANGE COUNTY GUIDE - PAGE 7 PERSONAL ACTION FOR CLEAN AIR 1. Limit gas and diesel vehicle operation, air conditioning, and fuel burning to essential needs, efficiently met. 2. Use public transportation, car-pooling, bicycles and feet for transportation whenever possible. 3. Plant appropriate kinds of trees and shrubs where they can grow to full size, shading roofs and paved areas. 4. Protect and maintain existing landscapes through high standards of care and efficient water management. 5. Restrict use of articles made with or containing chlorofluorocarbons. 6. Keep family and business vehicles maintained for maximal operating efficiency and minimal air pollution. • AN ORANGE COON Y GUIDE - PAGE 9 WATER ORANGE COUNTY, along with the entire South Coast Megalopolis, has a very limited local water supply. About three -fourths of our water is imported from sources several hundred miles away. Our ground water is limited and many wells are polluted. Orange County's population continues to increase at twice the national rate, but our local water supplies at best will remain at present levels. Imported water, our major source, will become more vulnerable to unexpected reductions: this could occur through decisions by governmental agencies, through droughts, or through seismic disruption of supply channels. Groundwater, the local source, is being depleted in some areas faster than the aquifers can be recharged. Inadequate treatment of sewage, and of commercial, .10 industrial, and agricultural effluents, is causing increasing contamination of groundwater and coastal. waters. Land development operations create additional demands for water, while generating increasingly hazardous pollution of surface water and coastal waters. If these trends are not corrected, water shortages will become a way of life for Orange County residents. Tap water quality will continue to deteriorate, requiring greater energy use and cost for its purification. Ocean water for recreation and food sources will become unacceptably polluted. More streams and natural waterways will become open drains, transporting waste from adjacent developments into coastal waters and underground aquifers. WATER QUALITY RESOLUTIONS We hereby resolve to promote the following actions and objectives. 1. Work with the Orange County Sanitation District and the Regional Water Quality Control Board to establish standards for treatment and management PAGE 10 • ENVIRONMENTAL RESTORATION • of municipal, industrial and agricultural wastewater to produce water of suitable quality for additional beneficial use; 2. Starting in 1992, reduce all ocean dumping of primary treated sewage by 10% each year; 3. Beginning in 1991, all new developments should be structured for reclaimed water use; 4. Establish stricter approval standards and enforcement of regulations in development and construction to require the following: (a) Verification of adequate water availability to meet projected needs of homes and businesses in proposed developments; (b) Installation of new and retro-fitted facilities to yield demonstrably clean surface drainage and runoff water flowing into surface streams; this should be a condition of approval for new developments, and the governing municipality should be held responsible for correcting stream -polluting surface drainage systems on all projects completed since 1984; (c) Establish standard optimum water -usage needs for residential, commercial, industrial and agricultural uses, and impose high rates for excessive water use; (d) Define user classes and levels of need to identify the order of water rationing during water shortages: new developments after 1991 should be the first to be subject to rationing; and that proviso should be clearly stated to prospective buyers; (e) Update agricultural irrigation standards to allow optimal use of water with minimal wastage through runoff, • AN ORANGE COUNTY GUIDE - PAGE 11 5. Support reform of statewide agricultural water allocations, to avoid subsidization of high -water -demand field crops; 6. Require all contaminated industrial and agricultural wastewater to be reclaimed so that no contaminants are introduced into groundwater, streams, lakes, bays or the ocean. PERSONAL ACTION FOR CLEAN WATER 1. Practice serious, effective water conservation: limit all personal, domestic and landscape water use to reasonable levels. Guidelines are available from the Metropolitan Water District of Southern California, and from the U.C. Cooperative Extension Service. 2. Report water loss or waste water (such as geysers from broken irrigation heads, or streetside streams which result from overwatering of landscapes). 3. Reduce unnecessary driving of fossil -fuel powered vehicles. (It takes eight to ten gallons of water to produce one gallon of gasoline.) 4. Don't put anything toxic or hazardous down water drains (sink, toilet, tub or storm drain). Call the Fire Department for directions on disposal. 0 AN ORANGE COUNTY GUIDE - PAGE 13 TRANSPORTATION THE NUMBER OF MOTOR VEHICLES in Orange County has increased by more than 14% over the past two years. There are now more than two million vehicles, generating approximately 65% of the air pollution in the county (including some 33,000 tons of CO2 per day). Excessive use of private motor vehicles (mostly carrying solitary individuals) is a major contributor to our unhealthful air, blighted views, increased health care costs, and loss of natural resources. The proposed new freeways will not relieve the congestion. If built, those roadways will provide access and motivation for further destruction of a major part of the remaining rural and natural areas in the county. The resulting influx of population will add to the freeway traffic load, nullifying any relief from congestion which might be achieved. through planned expansion of the existing freeway system. TRANSPORTATION RESOLUTION We hereby resolve to promote the following actions and objectives. 1. Provide clean,. safe mass transportation systems as the alternative to new freeways; 2. Establish incentives to businesses and individuals using and promoting car- pools, in -home work, flexible working hours, and use of bicycles or other vehicles which do not use fossil fuels; 3. Adopt and implement a regional bicycle trail master plan linking all work centers, cities and recreational areas, with high priority given to effectively protected, integrated bicycle trails in all future transportation systems;. PAGE 14 - ENVIRONMENTAL RESTORATION 4. Improve community planning to foster self-contained cities that offer places to work and live, rather than promoting the spread of suburbia, resulting in great commuting distances. PERSONAL ACTION FOR TRANSPORTATION 1. Limit driving time and distance through more efficient, minimum essential vehicle operation. 2. Use car-pools, ride sharing, park and ride, and other forms of mass transit when feasible. 3. Service vehicles regularly to maintain operational efficiency and to limit polluting emissions. . 4. Buy lower -power, smaller, fuel -efficient vehicles. 5. Ride a bicycle or walk when feasible. 6. Switch to non -fossil fuel powered vehicles as soon as possible. 7. Notify your legislative representatives that you want mass transportation. 0 AN ORANGE COUNTY GUIDE • PAGE 15 NATURAL UNDEVELOPED LAND IN ORANGE COUNTY the little remaining natural undeveloped land is limited to the Cleveland National Forest and a few other places on which old growth woodlands, riparian ecosystems, wetlands and grasslands have not been destroyed by clearing, overgrazing, and tilling. At the current rate of "leap frog sprawl", by the year 2020 the only remaining expanses of natural undeveloped land in Orange County will be the Cleveland National Forest and our regional parks, all of which will be threatened by overuse and adjacent developments. Construction of the proposed new freeways will destroy more than 1600 acres of natural undeveloped and agricultural land; this will result in the isolation, fragmentation and degradation of additional thousands of acres of land containing native flora and fauna. Diminished acreage and overuse by increasing human population can destroy the few remaining areas set aside as natural preserves. Many plant, animal and insect species will vanish from our area. Bio-diversity will be reduced to the point that future generations will be unable to benefit from intact natural ecosystems in Orange County. Local temperatures and Santa Ana windforce will increase, along with intensified soil, air and water pollution. Irreversible deterioration of natural elements will be inevitable, decreasing the quality of life and economic strength of Orange County. NATURAL UNDEVELOPED LAND RESOLUTION We hereby resolve to promote the following actions and objectives. 1. By 1991, institute and enforce policies and ordinances to preserve and protect 100% of all currently remaining wetlands, 100% of all currently • remaining riparian habitats, 90% of all currently remaining woodlands, 80% of all currently remaining brushlands, and 70% of all currently remaining grasslands; PAGE 16 • ENVIRONMENTAL RESTORATION 2. To foster acquisition and protection of natural undeveloped land; 3. Terminate plans for construction of any new freeways and replace with alternatives to provide efficient, clean mass transportation systems to avoid the destruction of foothills, grasslands and canyons; 4. By 1991, require effective wildlife passages, adequate for passage of large mammals, under all new roads constructed in rural areas; 5. Require annual inventories of all county natural resources: categorize resources as to their endangered status; require that no endangered plant, animal or insect species, or any geographical resource be encroached upon in any manner which will threaten its extinction or decimation; 6. Restore and rehabilitate endangered species ecosystems; 7. Concentrate resources on redevelopment within existing developments rather than on exploitation of undeveloped areas, to preserve our natural undeveloped land. PERSONAL ACTION FOR NATURAL UNDEVELOPED LAND 1. Visit and protect parks and open spaces and all natural resources through respectful non -damaging use. 2. Let your legislative representatives know you support protection of undeveloped land. r� L 0 • AN ORANGE COUNTY GUIDE - PAGE 17 NATIVE PLANTS AND WILDLIFE PLANT AND ANIMAL SPECIES worldwide are being extinguished by human activities at an average of one or more species per day. Natural ecosystems in Orange County are rapidly vanishing: many of our native plant materials and wildlife have either vanished or are close to becoming extinct. Much of our natural undeveloped land is becoming fragmented and isolated by poorly regulated land use. Shortsighted, piece -meal land planning has been the cause of irreplaceable loss of major natural resources. The absence of area -wide, long range policies to protect the integrity of natural systems now jeopardizes the survival of many of the remaining native life forms. The opportunity to experience contact with nature (a basic psychological need of humans) has already been critically limited by a lack of good environmental planning. Natural life forms are valid in their own right, and are essential to the mental, emotional and physical well-being of humans. Urban expansion and freeway extensions result in accelerated loss of native plants and wildlife, with accompanying degradation of our quality of life. Less vegetation means more air pollution and intensification of atmospheric warming. Thus the sacrifice of native life forms in order to further urban sprawl can eliminate a vital benefit, while making our deteriorating surroundings less and less tolerable for human existence. NATIVE PLANTS AND WILDLIFE RESOLUTIONS We hereby resolve to promote the following actions and objectives. 1. State and federal laws (because of the vast geography they regulate) are failing to protect Orange County's native wildlife species; therefore Orange County itself must ensure the protection of indigenous plant and animal resources, with immediate emphasis given to endangered and threatened species within: Orange County. By 1991, formulate indigenous plant and animal PAGE 18 • ENVIRONMENTAL RESTORATION • protection and preservation standards which include strong legislative and enforcement actions, predicated upon the following: (a) Field surveys by qualified specialists in native plants and wildlife, to inventory the kinds and numbers of existing species, and to define their space and habitat requirements; (b) Specified limits on space reduction in natural areas to assure the integrity and continuity of existing ecosystems; (c) Preservation of all remaining riparian habitats (including watersheds and blueline tributaries as defined by the U.S. Geological Survey program) in an ecologically functional state; (d) Preservation of 100% of all currently remaining wetlands, 90% • of all currently remaining woodlands, 80% of all currently remaining brushlands and 70% of all currently remaining grasslands; (e) Mitigation in full of resources lost to new development, requiring replacement in kind at full appraised value- of plant, animal and geographical elements; (f) Relocation of significant wildlife prior to any authorized habitat destruction; (g) All habitats containing significant wildlife species to be undisturbed during periods of migration, nesting or rearing of young; (h) Conversion of any and all sites containing rare, t�---atened or endangered native plants, or animals, to wildlife • -serves of • AN ORANGE COUNTY GUIDE • PAGE 19 sufficient land area to assure effective survival of the species in question; 2. Work to develop and implement municipal and county programs to preserve, restore and enlarge native plant stands, including: (a) All new landscaping in public areas and development sites to contain 75% native plant species; (b) Development of urban wildlife programs to protect, preserve and increase desirable native plants and wildlife in municipal and county areas. PERSONAL ACTION FOR NATIVE PLANTS AND WILDLIFE 1. Use parks and open spaces in non -damaging ways to protect native plants and wildlife. 2. Plant appropriate shrubs and trees, using native species where possible, for the support and protection of urban wildlife. 3. Work to develop "pocket wildlife preserves" in your community. • • AN ORANGE COUNTY GUIDE • PAGE 21 WASTE ORANGE COUNTY SHARES THE NATIONAL CRISIS in waste disposal, with the following array of rapidly worsening conditions: * Saturation of solid waste landfill sites; * Increase in volume and numbers of hazardous wastes and disposal sites; * Loss of recyclable materials through indiscriminate disposal; * Increase in total wastes resulting from population growth, production of disposable articles, and profligate packaging methods; * Pollution of air, water, soil and seacoast through careless, improper waste disposal. If these conditions are not corrected, we can expect rapidly mounting costs (in the form of service fees and taxes). Such expenditures will be necessary for the acquisition of new sites, and the need to transport wastes over greater distances. The use of more land for disposal stations will eliminate natural habitats, and will further pollute and poison the human environment. PAGE 22 - ENVIRONMENTAL RESTORATION WASTE RESOLUTION We hereby resolve to promote the following actions and objectives: 1. By 1992, establishment of mandatory recycling/presorted-disposal systems (i.e., by use of separate curbside containers for glass, metal, paper, plastics, non - recyclable) or else contract for sorting by the collection service; 2. Encourage the use of recycled products. 3. Establish mandated -use compost sites in 1992, to receive each community's full yield of grass clippings, leaves, brush and tree trimmings, and other compostable organic materials. The operations should provide tax credits or compost purchase credits, based on weight and kind of materials delivered to the sites; i 4. By 1991, institute solid waste disposal fees based on weight of waste, with premium rates to be levied for disposal of recyclable materials; 5. Stop all ocean dumping of primary treated sewage by the year 2003. PERSONAL ACTION FOR WASTE MANAGEMENT 1. Sort disposable items into (a) paper, (b) aluminum, (c) other metal, (d) glass, (e) plastics, (f) compostable organics, and (g) non -recyclable wastes. Recycle the first six, leaving only the last category for public disposal. If any waste material is hazardous, consult your city Fire Department for proper disposal procedures. 2. Avoid purchases of non -essentials packaged in needlessly elaborate • containers. If purchased, mail such containers back to the manufacturers. 0 • 0 AN ORANGE COUNTY GUIDE • PAGE 23 3. Compost organic wastes (grass clippings, tree trimmings, coffee grounds, etc.) which can be used to enrich soil. 4. Request paper bags instead of plastic bags at stores, and re -use or recycle the paper. 5. Re -use glass, plastic and metal containers when feasible. 6. Establish neighborhood recycling centers until municipal centers are available. 7. Collaborate with other volunteers in "adoption" projects to clean up sections of streets, roads, beaches, parks, vacant lots, etc. 8. Dump no toxic or hazardous wastes into storm drains or sewers. 9. Minimize use of toxic or hazardous materials or materials which yield toxic or hazardous wastes: 0 AN ORANGE COUNTY GUIDE • PAGE 25 URBAN LANDSCAPE AND MAINTENANCE ORANGE COUNTY IS IN AN ARID, SEMI -DESERT, temperate to subtropical region. Here our comfort and productivity require effective cooling of homes and workplaces. Our comfort level, as well as our savings on the cost for summer cooling, can be greatly benefited by well -designed landscapes. The right kinds of plants in the right places can also help assure plant survival under low water regimens. Well situated shade trees can reduce summer cooling costs by one- fourth, and can prevent formation of summer heat islands in open areas. There is a near certainty of future water shortages: it is therefore in everyone's best interest to use Xeriscape-type designs. Energy efficient landscape design in Orange County is a practical necessity which yields economic benefits. It is cost effective to select the appropriate kinds of trees and shrubs, to place them in good landscape locations, and to give them proper care. Doing so increases property value well beyond the costs of the improvement, and significantly reduces summer cooling costs. An additional reward is that it greatly enhances the beauty and comfort of Orange County urban areas. Investing in quality landscaping yields high returns. Unfortunately, many existing landscapes include numerous plant species which have been improperly grouped as to water requirements. Worse, the lavish irrigation commonly applied goes far beyond the needs (and sometimes even the tolerance) of plants. Under such conditions, any future shortage could lead to the decline or death of many of our landscape plants. If poor standards of species selection and water management continue, we could well arrive at a time when major landscape areas , will turn from lush green to grim brown. Landscape trees throughout Orange County are mutilated and disfigured by substandard pruning. Improper pruning nullifies the value, attractiveness and environmental effectiveness of trees. Topping of trees and other common mispractices create liability hazards, and leave the trees vulnerable to diseases and harmful insects. PAGE 26 • ENVIRONMENTAL RESTORATION 0 URBAN LANDSCAPE DESIGN AND MAINTENANCE RESOLUTIONS We hereby resolve to promote the following actions and objectives: 1. By 1991, establish county and municipal landscape design standards which will assure: (1) installation of water -conserving irrigation systems, (2) location of trees for optimal shade effects, (3) design parameters which will avoid hardscape damage; and (4) appropriate plant grouping to assure water conservation; 2. By 2000 enlarge the urban forest by 80% through the planting of suitable trees in appropriate locations; 3. Establish and implement new landscape design and management standards on municipal or county land, through the following measures: • (a) Require stricter and more effective landscape water management; (b) Establish and enforce quality standards in the pruning of trees; (c) Define and promote specifications for suitable selection, proper installation and beneficial, cost effective management practices in the development and maintenance of public landscapes. PERSONAL ACTION FOR URBAN LANDSCAPE DESIGN AND MAINTENANCE 1. Protect your own landscape by specifying and requiring high standards of performance from appropriately qualified professionals. 2. In landscape design/redesign, specify low water use plant species al::: low volume irrigation systems. 0 AN ORANGE COUNTY GUIDE - PAGE 27 3. Learn and practice (or require from professionals) the principles of low maintenance landscape design (such as selection and placement of trees that will not outgrow the available space or damage hardscape; Xeriscape design, and avoidance of species with high susceptibility to insects, diseases, windstress or physiological problems). 4. Protect the trees on your property, or on the parkway in front of your property, from being damaged by the practice of topping (stub -cutting of branches, and removal of major branches to produce a "staghorn" or "hatrack" effect). • • • AN ORANGE COUNTY GUIDE • PAGE 29 ENERGY IN THE UNITED STATES, 25% of the world's energy supply is used by only 5% of the world's population. However, the percentage of our income spent on energy conservation research is the lowest among the top seven industrialized nations. We waste more energy, and do comparatively less to conserve it, than any other country. Orange County's consumption of fossil fuel and other energy sources is 120 times the global average. We are among the major contributors to planetary warming. The stability of the total environment depends upon prompt, radical reduction in use of carbon -based energy sources, and upon developing alternatives to fossil fuels and nuclear power to supply our energy. To avoid the catastrophe of full-scale global warming, it is imperative that we develop and use energy sources other than carbon -based fuels and nuclear fission as presently employed. This must be accomplished within the next 10-15 years to prevent devastation of the earth's biosphere. We place our future and the well-being (quite possibly the survival) of our children at high risk through our over -consumption of energy. We must act immediately to establish a viable energy use program, one which will not further disintegrate the fabric of our surroundings. Failure to do so could spell disaster, and at the very least will lead to destruction of natural resources,increasingly impaired productivity, and burgeoning costs for pollution abatement and health care. ENERGY RESOLUTION We hereby resolve to promote the following actions and objectives. 1. Work with state and federal agencies to increase investments in research and development for greater efficiency in energy use; and alternatives to fossil fuels and nuclear power as energy sources; PAGE 30 • ENVIRONMENTAL RESTORATION • 2. Change local building codes by 1992 to enforce super energy saving designs in all new construction and remodeling; 3. Provide incentives for companies in Orange County to specialize in pollution control and energy -saving technology; 4. Work with state officials to restrict the use of fossil fuel burning engines, by instituting user fees based on size and fuel consumption rate, and by rewarding users of vehicles powered by electricity or other non -carbon based fuels; 5. Abandon new freeway plans and replace with energy saving, non-polluting mass transportation systems that help preserve our natural resources; 6. Establish mandatory recycling programs by 1992; 7. Establish incentives and regulations to promote 'least cost" planning for electric utilities. In this process, investments in producing new energy supplies are required to compete on an equal footing with investments in developing energy efficiency; 8. A county -wide, coordinated energy initiative, involving research, education and policy formulation must become an immediate priority. PERSONAL ACTION FOR ENERGY CONSERVATION 1. Practice fuel conservation in transportation, heating, cooling and other domestic operations. Consider solar energy retro-fitting. 2. Use all utilities efficiently. Institute rewards for your family or company for reducing utilities usage by 10% or more. 3. Use more plant sources of protein in your diet (such as legumes -- peas, • beans, etc.) which require less energy for production, and less animal source protein, which requires more land area and more energy to produce. E AN ORANGE COUNTY GUIDE - PAGE 31 NOISE DEVELOPMENT AND INCREASED POPULATION DENSITY have resulted in a dramatic increase in background noise levels. Almost everyone living in Orange County is daily assaulted by a multitude of unwanted sounds. Recent studies show that school children near the Los Angeles International Airport exhibit learning problems, "learned helplessness", and physiological precursors to stress responses such as elevated blood pressure and faster heart rates. Noise has also been linked to heart disease, elevated blood cholesterol and cortisol levels (an indicator of stress), ulcers, disturbed sleep, and hearing loss. Steps must be taken to reduce or eliminate as much noise as possible. Much of the sound pollution that is taken for granted and tolerated needs to be critically assessed, and its environmental and social impact weighed against any perceived "need" for such disturbances. Whereas urban noises can cause stress and disease, the sounds of nature, such as birds singing, breezes, or flowing streams, promote relaxation and healing. Environments containing such elements need to be created within communities, as places to "unwind". NOISE RESOLUTION We hereby resolve to promote the following actions and objectives. 1. Planting of dense shrubbery and trees where appropriate to absorb and buffer noise; 2. Promote implementation of technologies and flight paths to reduce noise impact from air traffic in Orange County; 0 3. Develop quiet mass transit systems; PAGE 32 - ENVIRONMENTAL RESTORATION 4. Require all vehicles, including those for off -road recreation, to use mufflers and tires that keep their noise emissions to 64db or less if possible; 5. Promote research, development and implementation of noise -reducing technology such as "noise cancellation" electronics; 6. Require that new homes in noisy areas be insulated with soundproofing insulation; 7. Incorporate "quiet" areas within developments where natural sounds dominate; 8. Include effects of sound in environmental education programs. PERSONAL ACTION FOR NOISE POLLUTION 1. Become more conscious of how noise affects you and how the noise you create bothers others. Take actions that reduce the noise you generate. 2. Recommend that noise inspections be included with bi-annual smog inspections. 3. Enforce current Orange County and local municipality noise regulations. 4. Encourage and recommend comfortable and productive noise levels at ply.-: of work and public recreation. 0 6,1 0 AN ORANGE COUNTY GUIDE • PAGE 33 POPULATION ORANGE COUNTY'S CURRENT POPULATION is 2.2 million and is projected to increase to approximately 2.6 million by the year 2000, 2.8 million by 2010, and 3 million by the year 2020. World population has passed 5 billion, and is increasing at 1.7% annually. It is predicted to double to 10 billion in another 40 years. Locally, nationally and globally, the fundamental cause of the environmental crisis is human overpopulation. More people require more food and shelter, more fertile farmland is swallowed up in urban expansion, and more forests are destroyed to create more farmland. Virtually all of Orange County's prime farmland is being lost to urbanization to accommodate the burgeoning population. Most of the remaining non-federal woodlands are slated for elimination by county planners and developers. On a land • area basis, the rates of present and planned destruction of native trees and vegetation in Orange County far surpasses the rate in the tropics. At the current rate of deforestation, it will take another 60 years to eliminate the last of the tropical rain forests; however, Orange County residents can look forward to the loss of most of our remaining woodlands (due to countywide land build -out within the next 20 to 30 years. POPULATION RESOLUTION We hereby resolve to promote the following activities and objectives: 1. Establish educational programs in schools and workplaces to promote population control; 2. Encourage foster parenting and adoption; 3. Promote and finance family planning education and services; 4. Practice reproductive responsibility. PAGE 34 • ENVIRONMENTAL RESTORATION PERSONAL ACTION FOR POPULATION MANAGEMENT 1. Be sensitive to population issues and plan your offspring accordingly. 2. Support family planning education and services. 3. Join or start a local population stabilization group. • I] fi SUMMARY AN ORANGE COUNTY GUIDE • PAGE 35 While dangerous environmental abuse is a daily occurance, EACH DAY ALSO BRINGS more evidence of people actively pursuing environmental care. Just a few weeks before this guide was published, 7,500 of you, for example, made Orange County environmental history when you walked for environmental preservation. Together, we are heartened by this positive evidence, and hope that all who review this guide for environmental restoration will join a larger, increasingly strong network of active individuals and groups dedicated to the achievement of a healthy, robust, and beautiful Orange County environment. Toward that end, we ask that you consider the resolution on the following page, and return it to Tom Larson with your endorsement. 0 --- ------------------------------------------------------------------------------------------------- NOV 24 '90 09:13 714 546 5814 p,2 Orange County Transportation Commission - A Report on Transportation Legislation Regional Planning Issues Left Unresolved Regional transportation planning and land use concerns proved too tough for the legislators to resolve in the 1989-90 legislative session. Several bills including SB 1850 (Torres/Presley) and SB 1332 (Presley) proposed adding new layers of government to the transportation planning process. Neither measure resolved how new agencies would work within the existing regional structures and both failed to gain local agency support. Assembly Speaker Willie Brown in AB 4242 pushed to revamp all &lona] planning to include air and water quality, housing, transportation and 1, agency formation within the authority of a new super agency. The bill left out local agencies from the planning loop but provides a framework for legislation on regional "governance" that is likely to resurface next year. The issues confronting state legislators involve what to include within, the scope of a regional planning structure; grassroots versus a top -down planning approach; and whether modification or complete redesign of the current planning and funding process is needed. Registration Fees to Pay For Clean Air Programs Air quality districts may raise vehicle registration fees up to $4 to pay for clean air programs, according to Assemblyman Byron Sher's bill, AB 2766. The measure, effective January 1 allows air quality districts in regions not meeting state standards for air quality to increase annual registration fees by $2 each year in 1991 and 1992. The monies will be used to implement sidesharing, use of alternate fuels, and other smog reduction programs. By 1993, the fees are estimated to raise S40 million annually in the South Coast Air Basin. Orange County's share will be about S2.4 million outright with eligibility to compete for a regional pool of $12 million awarded on a merit basis to specific projects, Ithe legislation reflects a hard fought compromise on funding that allocates to the South Coast Air Quality Maniigement District; 40% to cities and counties in the region by population formula; and 30% to a discretionary (Condmued on Page 2) Fall 1990 Orange County Rail Funds Jeopardized Orange County could loose as much as S80 million for commuter rail projects because of new rail funding restrictions. Senate bill 2392, and new law, authored by Senator Quentin Kopp, tightens the allocation of Proposition 108 rail bond monies approved by the voters in June of this year. The new provisions limit Prop 108 pro• ceeds to 56% of the total project costs exclud- ing federal funds and money received from Proposition 116, the other rail bond measure approved in June. This means that Orattge County must match Prop 108 funds dollar for dollar but is unable to use federal or Prop 116 dollars to meet the requirement. Orange County is eligible to receive S15 Million directly for commuter rail trains and stations if it can provide a dollar for dollar local match. Regionally, an additional $330 million has been promised to the counties of Orange, Los Angeles, Riverside, San Betaar- dino and San Diego to purchase rail right-of- way and trackage rights if the counties match the state amount. Orange County's share is estimated at S43 million to S65 million. The added restrictions make it difficult for Orange County, the only urban county without a local transportation sales tax, to capture state money. Orange County's portion may be awarded to competing counties unless Meas- ure M, a half cent transportation sales tax, passes in November. EXHIBIT 9 ----------------------------------------------------------------------------------- Consolidation Bill Becomes a Reality Orange County will get a unified transpor- tation authority by the end of 1991 according to SB 838 (Bergeson) signed into law by Gov. ernor George Deukmejian, The consolidation bill brings together four transportation agencies including the Orange County Transportation Commission (OCTC), Orange County Transit District (OCTD), Con- solidated Transportation Services Agency, and Service Authority for Freeway Emergencies under one governing board. The measure cleared last minute opposition from the Orange County Board of Supervisors just days before state legislative deadlines. Supervisor Roger Stanton, with backing from Supervisors Thomas Riley and Don Roth, pulled their support until specific language on merging agency personnel and job functions was written into the bill. The final version of the bill requires that OCTC and OCTD develop a consolidation plan by the end of 1991 to create the Orange County Transportation Authority with a new board of directors, Earlier versions gave the new governing board the responsibility to functionally merge the agencies. OCTC and OCTD have targeted June 1991 to finish the work plan before the December 1991 deadline. Penalties for not completing the plan in time would result in state withhold- ing of the county's gas tax money. Registration Fees Okayed (Continued jtom Page 1) project -based program. The Orange County Division of the League of California Cities, Orange County Board of Supervisors and Orange County Transportation Commission were all active in fashioning the spending package. Governor Deukmejian vetoed a similar bill last year because local and regional agencies disagreed on how the money should be spent. P.3 Transportation Agency Merger is Under Way Page 20 Implementation of consolidation legislation SB 838 is moving ahead of schedule as the Orange County Transportation Commission (OCTC) and the Orange County Transit District (OCTD) work together to develop a Com- prehensive Transportation Consolidation Plan, OCTC and OCTD have set June 30, 1991 as a target date to complete the plan for the new Orange County Transportation Authority. Management consultants Deloitte and Touche have been hired to study how to functionally merge the two agencies. Government and com- munity relations functions are the first areas to be combined, as early as the end of the year, The two agencies already are developing a joint legisla- tive program. Also in the works is the creation of a Rail Program Office that would bring countywide rail planning into one central location. Brian Pearson, currently the Transit District's director of development, would head up the program and report to OCTC Executive Director Stan Ofteiie. Final approval of the Rail Office is anticipated at a Functional consolidation between the Orange County Transportation Commission (OCTC) and the Orange County Transit District (OCTD) is beginning with the preparation of a joint legislative program for the 1991.92 legislative session, Although both agencies have been active in Initiating and pursuing state and federal legislation, OCTC has traditionally sought more specific bills that directly affect Orange County. The transit district has relied more heavily on legislation sponsored and supponed by the transit industry to represent its interests. The two agencies already share the same federal lobbyist. By developing a joint program, OCTD will gain the Commission's state advocate to speak out for Orange County's transit needs in Sacramento. Governmental relations Is the first area targeted for consolidation by the two agencies. OCTC and OCTD also hope to combine public affairs and community relations functions by the end of the year. joint agency meeting on November 26. Both agencies agreed to a hiring freeze, excluding but operations, to be in effect until the work plan for a new organizational and functional structure is completed. The Consoli- dated Transportation Services Agency, which provides rides for the elderly and disabled, also will be brought into the consolidation process when transit operations becomes the planning focus. 0 1989,90 Legislative Session Ends The legislative session ended August 31 with a September 30 deadline for action by the Governor on bills sent to him for his signature. Below is a summary of key transportation and related bills, now chaptered into the law books, of those tracked by the Orange County Transportation Commission (OCTC) during the second half of the 1989.90 legislative session. Chaptered Bills Funding Callbox System Expansion Effective: 01/01/91 AB 2937 (Johnson), Chapter 282, Statutes of 1990 allows callbox revenue to be used to add callboxes on freeways and highways that are not within California Highway Patrol (CHP) jurisdiction, with CHP approval. Carbon Canyon Road in Brea will get callboxes in the new year as a result of this legislation. Retail Transactions and Use Taxes Effective: 01/01/91 AB 3322 (Filante), Chapter 318, Statutes of 1990 allows the rate `a local sales tax to be imposed in 1/4 percent increments with aximum rate of one percent. Local Transaction and Use Tax Effective: 09/30/90 AB 3670 (Farr), Chapter 1707, Statutes of 1990 authorizes county boards of supervisors or an authority created by the board to place a 1/2 cent sales tax increase on the ballot without a majority of cities approval, High Occupancy Vehicle Fine Revenue Effective: 01101/91 SB 2629 (Bergeson), Chapter 266, Statutes of 1990 clarifies the law on High Occupancy Vehicle (HOV) lane fine monies by designating county transportation commissions as the agencies to receive HOV lane violation funds. Proposition 111 Clean-up Effective: 09/10/90 SB 2829 (Kopp), Chapter 627, Statutes of 1990 makes adminis- trative, procedural and clarifying changes to Proposition 111 and makes the Consolidated Transportation Services Agency eligible to receive state transit assistance funds. Planning Project Study Reports Effective: 01/01/91 AB 2038 (Eastin), Chapter 715, Statutes of 1990 allows regional 4 sportation planning agencies to prepare a priority list of tre capacity -increasing state highway projects in order to initiate the preparation of project study reports. The measure enables local agencies to prepare a project study report if Caltrans is unable to do the report in a timely manner. P.4 Page 3 Toll Collection Systems Effective: 01/01/91 SB1523 (Kopp), Chapter 1080, Statutes of 1990 requires Caltrans, workins with agencies planning or operating toll facilities, to develop statewide standards and specifications for automatic vehicle identification systems to ensure their compati- bility as the technology is implemented in California. Corridor Lands Preservation Effective: 01/01/91 SB 1784 (Leonard). Chapter 781. Statutes of 1990 creates a State Transportation Corridor Conservancy to protect and conserve transportation rights -of -way and essential corridors. Earthquake Bridges Retrofit Effective: 01/01/01 SB 2104 (Kopp), Chapter 265, Statutes of 1990 requires Caltrans to inventory all state owned bridges required to be strengthened or replaced to meet seismic safety standards and prepare a multi -year plan and schedule to complete the work. Combined Road Program Effective: OV01/91 SB 2404 (Kopp), Chapter 647, Statutes of 1990 sets up a process for Caltrans to implement the Combined Road Plan (CRP) program by establishing and distributing guidelines for program- ming and managing CRP apportionments. Federal funds continue to be allocated by existing procedures, Airport Ground Access Effective: 01/01/91 SB 2487 (Killen), Chapter 879, Statutes of 1990 requires each regional transportation planning agency to conduct a study of ground transportation to and from each airport in its jurisdiction working with other regional and local transportation agencies. Transit Telecommuting Pilot Project Effective: 01/01/91 AB 3069 (Clute), Chapter 1651, Statutes of 1990 requires Caltrans to conduct a one year pilot project on telecommuting as a commute alternative between Riverside and Orange County for employees in private industry. A similar provision is included for commutes from San Bernardino to Los Angeles. Regional Transit Planning Effective: 06/25/90 SB 1402 (Presley), Chapter 114, Statutes of 1990 requires the counties of Los Angeles, Riverside, San Bernardino and Orange, Upon approval by resolution, to jointly develop an implementa- tion plan for regional transit services. Working with each county transportation commission is the Southern California Association of Governments, California Transportation Com- mission and South Coast Air Quality Management District. --C?C_1---------------- Oil Companies pay Penalties Fines Help Fund Local Traffic Relief Orange County will receive S1.1S million for traffic im- provement projects from oil company fines collected for price violations during the 1970s. Assembly Bill 1145 by Assemblyman Byron Sher allocates S7,5 million, part of Califomia's sham of the federal Petroleum Violation Escrow Account, to cities and counties statewide for traffic relief and energy saving projects. In Orange County, the monies will pay $750.000 towards improvements to Beach Boulevard, the county's first Super Street. between the San Diego Freeway and Lincoln Avenue, An additional S400,000 will go to the city of Anaheim for route message signs, traffic surveillance cameras and energy efficient pedestrian signals, California gets about 10% of the fine monies collected annually by the federal government, The legislation requires that the funds be spent on energy conservation programs to aid consumers hurt by the original overcharges, The Orange County Transportation Commission is a state man- dated transportation agency that works with state and local officials, community groups, busineu and Industry, and other transportation agencW to coordinate a unified effort to identify, desigN fund, and implement traffic solutions, Ali amities appearing in Legslaaive Quarterly may be used in other publications, ORANGE Ct)INTY TRANNSPORT.vnox commissim Comtnissionerss Dana Reed, Chairman Iry Pickler, Vice Chairman Clarice Blamer Dick Edgar Tom Riley Roger Stanton Harriett Wieder Russ Lightcap Stan Oftelie, Executive Director P.5 Page 4 Tollroad Loans May Ease Construction Costs Construction on the Foothill and Eastern Transportation Corridors may be helped by loans of toll revenues or grant monies from the San Joaquin Hills Transportation Corridor (STHTC), thanks to legislation permitting loans between tollway agencies. Senate bill 1436, now law, would enable the San Joaquin Hills Transportation Corridor. once it is built. to help pay for construction on the unfunded tollroads, Conditions of the loan would require that it provide some financial benefit to the SJHTC. The SJHTC is first in line to receive federal and state grant monies and has been promised S40 million towards construction costs. Help in covering the upfront construction costs on the Eastern/Foothill Corridors may be needed as both have a slim chance of capturing any new state or federal dollars. Other good news for the tollway agencies includes SB 1437 that extends the use of developer fees to cover financing costs; and SB 1435 that allows the corridor agencies to modify developer fees and revise policy Issues at one consolidated public hearing instead of multiple hearings of all the member agencies. '1 (1 K RATE I IS. POSTAGE 71AID ";rmit \u. US .tntu :11111. CA • •