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HomeMy WebLinkAboutSS2 - CenterLine Revised Draft EIR��EWPpRT CITY OF NEWPORT BEACH C 9 PLANNING DEPARTMENT 35oo NEWPORT BOULEVARD wr SS NEWPORT BEACH, CA 92658 (949) 644-3 FAX (949) 644-3 Hearing Date: Agenda Item No.: Staff Person: STUDY SESSION REPORT TO THE MAYOR AND CITY COUNCIL SUBJECT: The CenterLine Revised Draft Environmental Impact Report February 13, 2001 SS2 Patrick J. Alford (949) 644 -3235 SUMMARY: Discussion on the Revised Draft Environmental Impact Report (RDEIR) for The CenterLine rail transit project. Background The CenterLine Rail Transit Project is a 28 -mile rail transit system proposed for Central Orange County. Bill Hodge from the Orange County Transportation Authority will be at the City Council meeting to make a presentation on the project. In September 1999, the United States Department of Transportation (DOT) and the Orange County Transportation Authority (OCTA) submitted a Draft Environmental Impact Statement/Draft Environmental Impact report for the The CenterLine Rail Transit Project. In December 2000, DOT and OCTA submitted at a Supplemental Draft Environmental Impact Statement/Revised Draft Environmental Impact Report for The CenterLine Rail Transit Project. Analysis The Supplemental Draft Environmental Impact Statement/Revised Draft Environmental Impact Report (SEIS/RDEIR) for The CenterLine rail transit project was prepared in to analyze revised build alternatives that were not evaluated in the September 1999 DEIR. The SEIS/RDEIR evaluates seven (7) build alternatives, which OCTA will use to select the locally preferred alternative. The build alternatives include four (4) candidate Minimum Operational Segment (MOS) alternatives. The MOS alternatives will be considered by the OCTA as an initial segment if one of the build alternatives is selected as the locally preferred alternative. MOS Central Minimum Operational Segment Central (MOS Central) is of the most interest to the City of Newport Beach vis -d -vis the intensification of John Wayne Airport and its environs. MOS Central is a 15.4 -mile segment running from the Anaheim Resort to the Irvine Business Complex. It is the only segment extending to the John Wayne Airport Area (JWA) that does not continue to the Irvine Transportation Center and adjacent MCAS El Toro. The basic concern is that the project could halt with the MOS Central segment, leading to the intensification of JWA and its environs. The SEIS/RDEIR identifies MOS Central as the most cost - effective of the MOS segments in terms of cost per new rider. However, the environmental analysis does not appear to favor MOS Central over any of the other segments. Growth - Inducing Impacts The SEIS/RDEIR contains a brief evaluation of potential growth- inducing impacts. However, the conclusion is that "the CenterLine build alternatives are not expected to cause overall growth within the region, but may redirect or focus a small portion of anticipated growth around station areas." The California Environmental Quality Act requires an environmental impact report include a discussion of the ways in which a proposed project could foster economic or population growth, directly or indirectly, in the surrounding environment. By defining the surrounding environment as "the region," the SEIS/RDEIR fails to examine the catalyst effect that a transportation project can have on the adjacent area. A closer examination of the growth - inducing impacts on the employment centers that the CenterLine project is intended to serve should be considered. Similarly, the growth - inducing impacts on facilities such as John Wayne Airport should also be considered, especially with respect to the potential selection of MOS Central as the locally preferred alternative. The public review period for the SEIS/RDEIR ends on February 14, 2001. The Environmental Quality Affairs Committee (EQAC) is expected to complete their review of the SEIS/RDEIR on February 12, 2001 and staff will present an oral report of their findings at the study session. Staff will forward EQAC's comments and those outlined in this report to OCTA, if so directed by the City Council. Submitted by: SHARON Z. WOOD Assistant City Manager Prepared by: PATRICK J. ALFORD Senior Planner ?Ze Attachment: Center SEIS/RDEIR Executive Summary. CenterLine RDEIR February 13,2001 Page 2 oraw County Cenn lLro Svpplerc tol DE1SIRry dDM- Exemri swr ry S.0 EXECUTIVE SUMMARY This section summarizes The Centerline Draft Environmental Impact Statement/ Environmental Impact Report (DEIS/DEIR) and the Supplemental DEIS/Revised DEIR: the project history and decision making process; the purpose and need for the project; the alternatives considered; related projects; the financial analysis; a compara- tive evaluation of alternatives based on cost effectiveness and environmental consider- ations; and transportation and environmental impacts with proposed mitigation mea- sures. This section also discusses issues to be resolved and potential subsequent phases of The Centerline project 11 PROIECTXISTORYAMIDECISlONM4MGPROCESS Project Hlstary Rail transit studies conducted since 1991 by Orange County Transportation Authority (OCTA) have resulted in three key local decisions: In 1991, the OCTA Board adopted a conceptual 87 mile Countywide Long - Range Transit System Plan. The plan identified an expansive 87 mile rail network that uses existing and potential rail corridors across Orange County and provides rail connections to neighboring counties. On April 11, 1994, the OCTA Board adopted a 28 mile priority corridor from the Fullerton Transportation Center to the Irvine Transportation Center, better known as "The Corridor." Approval of a Locally Preferred Strategy (referred to as the Elevated Alterna- tive), at the culmination of the Corridor Major Investment Study (Corridor MIS) in June, 1997. This strategy included further study and refinement of a 28 mile initial CenterLine segment in central Orange County between the Fullerton Transportation Center and the Irvine Transportation Center. The further study and refinement of a 28 mile rail transit system in central Orange County is being carried out as The CenterLine project conceptual engineering and environmental studies. included within the 28 mile CenterLine project is a 15 mile segment that has been included in the adopted Regional Transportation Plan for South- ern California (SCAG, 1998). The previous CenterLine DEIS/DE1R (September, 1999) included the following four alternatives: A "No Build" Alternative (no CenterLine project); The Elevated Alternative as identified in the Corridor NOS (with minor refine- ments reflecting recent land use changes); 12aW(P.VHI830kEA2vup acct S -0rcv.wp&> S-1 &wv Cowry Cenmrbm Supp&mewat DEIVRevixd DEIR - Eaauave Summary The Street Level Alternative 1 (SLA 1); and The Street Level Alternative 2 (SLA 2). The DEIS/DEIR for the alternatives described above was released for public comment on September 3, 1999. The OCTA Board held a public hearing on the DEIS/DEIR on September 27, 1999, which was supplemented with six field hearings to maximize the opportunity for public input. At the time the public comment period closed on October 25, 1999, OCTA had received over 2,000 comments from the public, affected cities, and public agencies. As the first step in the process to adopt a Locally Preferred Alternative (LPA), OCTA staff developed a Staff Recommended Alignment (SRA). In developing the SRA, OCTA was guided by input from the public, discussions with City staff, and extensive meetings with impacted communities_ As a result of this input, the SRA is a hybrid alignment it includes segments of the three previously studied alternatives, but also incorporates new segments and features in response to public comments on the DEISIDEIR. In order to assess the environmental impacts of the SI A at a level of detail equal to the other three build alternatives, OCTA initiated the preparation of this Supplemental DEIS/Revised DEIR. In addition to the SRA, two additional revised build alternatives are being considered and evaluated in this Supplemental DEIS/Revised DEIR: the Irvine Alignment Alter- native (IAA), and the Elevated Alternative 2 (EA 2). Both the IAA and the EA 2 are alignments that include segments ofthethree previously studied build alternatives, and also incorporate new segments and features. The new segments and features of the IAA respond to City of Irvine comments and concerns, while EA 2 focuses on the cities of Santa Ana and Orange. This Supplemental DEIS/Revised DEIR also evaluates four candidate Minimum Operable Segment (MOS) alternatives: the MOS for the SRA (MOS -South A), the MOS for the IAA (MOS -South B), and the two MOS for the EA 2 (MOS- Central and MOS- North). These MOS alternatives will be considered by OCTA as an initial segment if a build ahernative is selected for the LPA. This Supplemental Draft EIS/Revised Draft EIR is being circulated for public review to disclose potential environmental impacts associated with alternatives that have been revised from the previous alternatives considered in the previous Draft EIS/EIR (Sep- tember 1999). The revised alternatives are the direct result of public input and com- ments from the previous Draft EIS/EIR (September 1999) and ongoing outreach with interested public agencies and the public. The comments received during the public review period for this Supplemental Draft EIS/Revised Draft EIR for The CenterLine project should focus on the revised altema- tives described and evaluated in this document. The public comments received on the alternatives evaluated in the prnimm Draft EISIEIR (September 1999) and their respective responses are part of the administrative record and will be considered by the OCTA Board prior to the adoption of an LPA and the certification of a Final EIR. In 12tYQ0UP At818101EA2\M test S- 0mvmVidl3 S -2 Orange Comuy CenrerLkae Suppkmeelar DFJS/Rnwd DER - &ecudw Summary addition, the FTA will consider all comments and responses in the preparation of a Final EIS and adoption of a Record of Decision (ROD). Additional environmental analysis will be conducted after the selection of an LPA and a MOS for The CenterLine project. This additional environmental analysis will focus on more specific project characteristics related to the MOS that will be defined during preliminary engineering such as specific power substation location and park- and -ride lots. As part of this analysis, the OCTA will be able to include more recent available data and will define more specific mitigation measures that will be adopted as part of a Final EIR/EIS. Decision Making Process Public agencies in Orange County have considered building a rail transit system for many years. Since the mid- 1970s, a number of studies have addressed different align- ments for an initial segment of a rail transit system, as well as a complete countywide rail network. In 1990, as part of Measure M, voters mandated that $340 million be set aside for the development of a high technology rail transit system. In 1991, the OCTA Board of Directors adopted a Long -Range Transit System Plan. The plan identified an 87 mile rail network that uses existing and potential rail corri- dors across Orange County and provides rail connections to neighboring counties. When the Intermodal Surface Transportation Efficiency Act (ISTEA) was signed into law in 1991, federal guidelines changed for transportation planning projects. Under ISTEA, transportation projects are planned using a multi-modal approach. To comply with federal requirements, planning efforts for an Orange County rail transit system were incorporated into a multimodal Major Investment Study (MIS) for the Corridor that was initiated in 1994. On June 9, 1997, the OCTA Board of Directors adopted a Locally Preferred Strategy that includes an additional 1,000 daily seats for existing Metrolink service and a 49 percent increase in weekday bus service, in addition to swilying'Ibe CenterLine project within the Corridor. The Corridor MIS results have been reviewed by the Federal Transit Administration (FTA), which granted OCTA authority to enter into Preliminary Engineering to refine the alignment, profile, impacts, and costs of the proposed rail transit system. The LPA to be adopted by the OCTA in December, 2000 will be based on the analysis and findings from this environmental document, the previous DEIS/DEIR (which evalu- ated three build alternatives [Elevated Street Level Alternative 1, Street Level Aherna - tive 2, and the No Build Alternative]), and the conceptual engineering studies. These alternatives, which are described in further detail in Section 2.0, were developed through a joint process involving the OCTA and the Corridor cities, as well as substan- tial public outreach. The LPA may be any one of the six, full - length build alternatives or a combination of elements from each. If a build alternative is selected as the LPA, a Final EIS/EIR (FEISIFEIR) would be prepated for one of the MOS alternatives as an initial project phase. The FEIS/FEIR would be reviewed, considered, and certified by OCTA and the FTA prior to project approval. 12f3=0 P.Xrat93eTA2WV sea S4irtv.wpa» S-3 Orange Caunty Centerline Svppkmexmf DFJS1Rev4ed DFJR - Executive Amnnry S.2 PURPOSEAMJNEED Need for Transportation Improvements An effective multi -modal transportation network within the Corridor is necessary to meet the future mobility needs of businesses and residents by providing vital intra- corridor and inter - corridor linkages and services. Despite current and planned trans- portation system improvements, the magnitude and nature of the County's population and employment growth trends are projected to result in continuing transportation challenges in the Corridor, as evidenced by the following; • Increasing travel • Growing transit reliant population • Continuing freeway congestion • Increasing arterial congestion • Limited modal options In defining the purpose and need for The Centerline project; it is importantto identify objectives against which the project will be evaluated. The objectives must reflect a full range of public input, be sensitive to environmental and neighborhood impacts, address public policy guidance, and meet community and regional goals and objec- tives. In summary, viable alternatives must: • Increase transportation system modal options and capacity without increasing mobile source emissions; • Result in minimal neighborhood and environmental impacts; • Have public support; and • Support public policy direction. OCTA Adopted Policies and Goals The OCTA Long -Range Transportation Plan - FastForward, adopted July 27, 1998, was developed through extensive outreach to the general public, the business commu- nity, and local cities and agencies. Input was also received from neighboring counties to ensure regional coordination of programs and services. As part of theFastForward plan, OCTA adopted eight transportation goals, supported by numerous long-term strategies. Listed below, these goals and strategies complement federal, State, and regional planning goals. Create a balanced and integrated transportation system that enhances mobility for a growing population and employment base. Develop and maintain an effective street and freeway network to support the efficient movement of people and goods. 1213l001<P:Vm83MEAZ p sect S•Orev.wpd» S-4 oraw Coanry cm fftL Suppkm wl D©SLRevovd DEIR - fseralkr Summary • Improve access to Orange County destinations by providing convenient, effec- tive, safe alternative transportation modes for all travelers, including the transit reliant and visitors. • Provide funding needed to optimize and maintain the existing transportation system, as well as make new improvements. • Support biking, walking, telecommuting, and other non - motorized mobility strategies. • Be sensitive to the environmental impacts of transportation decisions. • Work with cities to integrate transportation and land use planning. • Seek diverse public participation in the development of transportation solu- tions. Southern California Association of Governmenis (SCAG) Adapted Policies SCAG, as the Metropolitan Planning Organization for Southern California, is required by State and federal law to develop and maintain a long -term Regional Transportation Plan (RTP). The RTP must be financially constrained and meet air quality mandates. Transportation strategies have been adopted in order to implement the RTP and con- form to the Air Quality Management Plan (AQMP). Adopted SCAG, RTP, and AQMP goals are to: • Sustain mobility, • Attain clean air mobile emission targets, • Foster economic development, • Enhance the environment, • Reduce energy consumption, and • Promote transportation friendly development patterns. Design of a 28 mile segment of the Orange County CenterLine system is included in the most recent RTP adopted by SCAG on April 16, 1998, and an initial 15 mile segment (from the John Wayne Airport area north to the Disney Resort area) is in- cluded for construction, transportation modeling, and air quality conformity analysis. The RTP has been determined to be in conformance with the AQMP and the federal Clean Arc Act Spectrie Transportation and Transit Problems and Needs in the Corridor This section highlights the needs within the Condor that will be addressed by the Orange County CenterLine project. Growth within the Corridor and the County is related to the mobility and accessibility of the population to the key activity centers 121310MCP:llare3MA2kup sea s-0n .wp& S-5 Oraage Comfy Cent"Un Suppiememal Df4W&v1md DEIR - &druii%r Summary identified; existing highway and transit access to these activity centers is poor due to roadway congestion. Enhancement of the County's existing transit system with The CenterLine project will give discretionary riders a choice for an alternative mode of transportation. In addition, The CenterLine project will improve transit service for transit reliant users. 1. Freeway and Arterial Congestion Exceeds Acceptable Levels and Will Continue Currently, the Orange County freeway system is highly congested, resulting in travel time delays for a significant portion of each day. Congestion is forecast to continue to increase in the future; therefore, a mobility problem or gap is projected for the Corri- dor in 2020. Based on the forecast 2020 traffic congestion within Orange County, the impacts related to congestion and trip delays are anticipated to increase for Corridor travelers over current conditions. Based on public input from the Corridor MIS pro- cess, traffic congestion is a concern among County residents, and has consistently been listed as one of the top concerns affecting the quality of life in Orange County. 2. Highway and Arterial Capacity Improvements are Feasible But Dicult m Implement Numerous freeway widening projects have been completed during the past ten years, or are being implemented, to relieve congestion within Orange County and the Corri- dor. With the exception of projects assumed to be completed by 2020, no additional freeway improvements (capacity expansion) are being planned by OCTA or Caltrans. Additional capacity improvements, while technically feasible, are difficult in built out areas because they would require the extensive purchase of additional and costly right - of -way, as well as the displacement of homes and businesses. 3. Existing Transit System is Impacted by fliglrway Congestion The existing bus system is near capacity within the Corridor during peak hours and the travel time for the bus system is delayed by traffic congestion on local streets and arterials. Although bus service throughout Orange County will be increased by 49 percent by 2015 in accordance with the LPS adopted by the OCTA Board, bus system travel times will continue to be delayed by the existing and forecast traffic congestion within Orange County and the Corridor. There is a lack of a dedicated transit system that would not be affected by existing and forecast traffic congestion within the Corri- dor. 12/3/W<PAHn93MA2'a* met S-0rev.,epO> S-6 OMW Counry CenrerUm SvppIa mntat DEJYfttvkwd DEM- Evm7in Summary• 4. Fslulag Transit Serves Compeang Demands Transit service in the Corridor is limited in frequency, and there is no significant through service traversing the entire Corridor. Existing bus lines are trying to serve the competing demands of short local trips and long distance travel, which results in excessive travel time for long distance travel. The absence of viable through Corridor transit service represents a transit deficiency. As documented in the FastForward plan, the inability to distribute and/or collect transit users at the existing Metrolink stations and excessive delays along major north/south transit routes are examples of transit deficiencies within Orange County and the Corridor. S. Population and Employment in eke Corridor and Adjacent Communitles Will Continue to Grow, Increasing Ike Demand for Alternative Means of Transportation Between 1995 and 2020, population and employment within the County are projected to increase by clearly 23 percent and 70 percent, respectively. The changing demo- graphics of the County's population also show a growing youth and senior population, which are typically more transit reliant because there are typically fewer cars per household for these population groups. These demographics and growth trends will increase the burden on already congested transportation facilities, resulting in demand for alternative means of transportation that are reliable, time competitive, and safe. Prrrposefor The CenterLfne in the Corridor Based on the Corridor land use, demographic, transportation, and growth patterns, The CenterLine would play a significant role in addressing travel demand issues, enhancing travel options, and providing service to an expanded work face. Specific goals and objectives for The CenterLine project are as follows: • Enhance mobility by serving high demand travel corridors and major activity centers with dependable and convenient service not affected by traffic congcs- tion. • Minimize costs by using proven implementation methods, technologies, and available public rights -of -way. • Allow for easy expansion (i.e., addition of trains, reduction of headways) to meet expanding needs. • Support economic and local land use objectives by providing access to major activity centers and areas to ensure the continued growth and economic devel- opment of the County, including redevelopment of older portions of the County. 12n/W(P:lm1630W.A21wp sect 5-Om .wp& S -7 orangr Cmxry CMWZiW Supplcmexial DEZW?ry d DEIR - Erecurm Summary Protect or enhance the natural, social, and physical environment by providing a pedestrian and transit friendly environment, increasing mobility options, and promoting more environmentally sustainable transportation modes. The specific purposes of The CenterLine project in the Corridor are summarized as follows: L Implement Transit Services That Provide for Priority Treatment and Separation from Automobiles and Congested Roadways The Corridor includes some of the most severely congested freeway and arterial sections within Orange County. Due to right -of -way constraints, the ability to imple- ment additional capacity improvements on Corridor freeways and arterials is limited. The CenterLine project can provide some separation and priority over the automobile in and through the Corridor, thus providing transit service that is not affected by freeway and arterial congestion. Z Provide a Yariety of Transit Services to Accommodate Competing Demands to the Corridor Bus lines serving this area are trying to serve competing demands of both shorter local trips and long distance travel. As a result (and in combination with the slower speed, arterial street network these routes traverse), neither type of trip is served well. The CenterLine project will create a rail backbone system with complementary feeder bus service that would connect nearby high capacity transit routes to the rail service. This rail system will serve the public needs of point to point travel through the Corridor. 3. Implement Adopted OCTA and SCAG Long Range Transportation and Air Quality Plans The CenterLine project would support regional transportation plans and the need to achieve mobility and air quality goals. In addition, The CenterLine project supports adopted FastForward mobility goals by contributing to improving the overall mode split of non - automobile travel. It further supports goals to: Create a balanced and integrated transportation system that enhances mobility for a growing population and employment base; Improve access to Orange County destinations by providing conve- nient, effective, and safe alternative transportation modes for all trav- elers, including the transit reliant and visitors; Integrate transportation and land use planning; and 12/3/0 ((MBJ&3ekFA2\sWnctSArcv.xpd)) S -8 Orange Ca ty Cemrlime Supplemenud DErB &Mud DER - Eremltw Summary Support biking, walking, and other non - motorized transportation strat- egies. A Close the Gap in Conneedvhy between Orange County Inferno" Transportation Centers and Activity Centers The Corridor contains major employment and activity centers within Orange County. Major intermodal transportation centers exist at the Fullerton Transportation Center, the Anaheim Resort area, and the Irvine Transportation Center, to distribute transit trips from line -haul Corridor services throughout the region. Closing the transit gap would provide improved connectivity between these intermodal transportation centers and Corridor activity centers, thus enhancing system productivity and patron access. As Metrolink commuter rail ridership grows, more people will rely on The CenterLine as a rail feeder service. S. Provide Transit Services to Meer the Transportation Demands of Growing Population and Employment in the Corridor and Adjacent Comnumities The land use, demographic characteristics, and growth trends of the Corridor will increase the burden on already over -taxed transportation facilities, resulting in demand for alternative means of transportation. As stated earlier, the changing demographics of the County's population shows a growing youth and senior population. In addition, an expanding work force will create a higher demand for transit ridership within the Corridor. Increased employment, coupled with a built out freeway and arterial net- work, increases the need for alternative means of transportation. Therefore, The CenterLine project would help meet these travel demands in the Corridor. 6. Provide Transit Services that are Integrated and Corrrpodhk with Land Uses in the Corridor Communities Future growth in the Corridor will increase freeway and arterial congestion, which mill increase the need for transit alternatives to the automobile and will offer opportunities to integrate transit oriented development into future projects. This is true particularly near the activity centers within the Corridor, where high density, mixed use redevelop - ment plans can benefit from ditoet access to transit services, including bus and Tice CenterLine project. These plans would comply with air quality mandates that require working toward sustainable communities, neighborhood revitalization and reducing roadway congestion. In cooperation with OCTA, cities within the Corridor are cur- rently evaluating transit oriented development strategies for this purpose, which would be adopted by the cities foliowing OCTA's adoption of an LPA. Well integrated transit services would provide an essential component to provide livable communities throughout the Corridor by providing enhanced mobility to residems of these areas. ivi ooccP.varno,F.uwro wt s- 0mv.wod» S -9 Orange C~JY Centerlbx Sapp1e ntal D6iS1&vkwd DFJR - Fvrcun Su ry 7. Provide Mobility Improvements that Balance Cost - Effectiveness and Environmental Constraints The Corridor MIS developed a comprehensive set of multi -modal transportation system improvements that were screened through a three step process to identify a Final Set of Alternatives. During detailed technical analysis, conceptual engineering was completed to identify mobility benefits, project costing, ridership projections, cost - effectiveness measurements, and environmental benefits and impacts for seven alternatives. The TSM and Fixed Guideway alternatives (as evaluated during the MIS process) constituted the Locally Preferred Strategy adopted by the OCTA Board, in consideration of the above criteria- 13 ALTERNATIVES CONSIDERED Three full - length build alternatives were analyzed in the previous DEIS/DEIR (Sep- tember, 1999): the Elevated Alternative (EA), Street Level Alternative (SLA 1), and Street Level Alternative 2 (SLA 2). The CenterLine alternatives considered and evaluated in this Supplemental DEIS/Revised DEIR are as follows: • The Staff Recommended Alternative (SRA) • The Irvine Alignment Alternative (IAA) • Elevated Alternative 2 (EA 2) • Minimum Operable Segment, South A (MOS -South A) • Minimum Operable Segment, South B (MOS -South B) • Minimum Operable Segment, Central (MOS- Central) • Minimum Operable Segment, North (MOS- North) The characteristics of these alternatives are summarized in Tables SA through S.F. Figures S.1, 5.2, and S.3 show the location of each alternative and proposed station locations. Detailed operating characteristics are described in Section 3.13 of this Supplemental DEIS/Revised DEIR and within Appendix 1 (CenterLine Operating Plan) to the Sup- plemental DEIS/Revised DEIR. Additional basic assumptions for all build alternatives include the following: • Train S ize: two or three cars • Station Platform Length: 270 feet (designed for potential three car trains) • Platform Width: 19 feet for center and 14 feet for side platform stations. • Parking: provide parking for forecasted demand at various high ridership locations along The CenterLine alternatives. • Design Standards: basic design standards are proposed and are described in detail in the Rail System Specifications technical report (Appendix M to the previous CenterLine DE1S/DEIR (September, 1999)). • Security: physical features and/or security personnel. 12!3Po09P,.UB1$301EA2WV Sect S- 0mv.wpd» 5-10 Uy z� cY�g� 00 x W O 'c a e U 0 O R 8 i 9 F N `a P e 3 v. 3 W Ell 6 -E 34 CO O?'p Y aii ��iQ s Cd '$ gg env a.5 °E3yt g.Ea �{ b }gym u C C tr 19 mii%e 'g� c8 g�� m C v3 0•� E °U •3a —$e'C �nQ og I a� ° � �sCC�U Y � •r3 pp5335r a9 � � � E + 4� C��2' � �p pq �. �p A 3' Y L N S a E 3 St 3 ,y O u¢3p � S N a Y a Ef i£ 8 Y y U t w, V u SSQY , ` Y 5yy' � -a 0,4 c Q E 1�'• C � C� ��k*� �NN pip � � 4 GG ~ Y ee Si 9 C i C E u •a E 96— N o - g $ 4 ° E Y�r e %9 o � C � u m 3° g� f E rd' : 8'& 0 0 G r V Z Y V z p ap, C z e O V e U Y z° t e V � m C u� v �a y u 3 3 O :4 O iJ .W E m Y •� cu u 4� cu V N Y > m $ o M3 � O C � C _o � � o o' L C C 3 •m � Y � Y N Q M dm L p� O P ro 2 �p 3 g C •� SSQY , ` Y C Y 6 6 M^ e C on4 � o` U ap, C z e O V e U Y z° t e V � m C u� v �a y u 3 3 O :4 O iJ .W E m Y •� cu u 4� cu V N Y > m $ o M3 � O C � C _o � � o o' L C C 3 •m � Y � Y N Q M dm L p� O P ro 2 �p 3 g C b E d" 2+ V v , 00 2 a 4 n g4 W N z a t .�i 71 i O m Z a V U G � L rz U 0 3 O a ° N 3 >Y P p 999 y3 v� C N � � �Op p � VJ C7 �• i'� �J'':J !i?�� 9 rJ• N P Y) M o p C 1 p m N Y m-4 O cO '� v tt •� T D L--° � L R 'L Q y p m �-% m y O Y A � E C C �3 m ra a;S 0 u is r 4 a m m Z Z Z k° e W S o C C a OD V c? c R' Y v Y s ° Y Y A F « c o v 5 GS U N 6 = m T h ; 1 O V q Y q O W v Q N 8 Y N b m 7 c. 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Z+ t v7 u' V E S E U g C G O Q> Ay I C G S S E E m o mow E E U N OCV of en L =O O O h NhY1 h m h C7 .•• M V N M Y1 M N N a F E e y P' 3k E ccT m OU > V n ��—°'o 3 TrnE @C.c O u E E O§ u m rnrndZm it O it Qri C Vl N V W- N N a w 0 00 rz 70 3 O O C .g m m ex a g of u e r y •� o w m o ^ r E � O g' w � 'O m E E 3 � O� h _ G. a }� J) !d ! k � 6 ) � % | v K $ a � ) k � a � d � ( � rA « 9 % 0 ■ ! g � $ ■ � E- 20 \ § � t | a saa &k �mG = aaa kk k&2 Ik §tk ion f ® \ \fk�22■ % # ® La «� � j� \� g\ /) � )k \4 §I %a �\ 3) )� �2f $ \\ \f» k \k k \\ A k E0 A ■) § i | k § Figure S.1 ORANGE COUNTY CENTERLINE PROJECT Alternatives Evaluated in the Draft EISAIR (September 1999) TN is i it 4azIZZ&;�, lbeCenterLine ii�& uan [Ft,- 1 4V Elevated Alternative 4V Street LevA A15ernative I (SA 1) ,OV Sirect Lovot Attornw-he 2 W,2) M At -Grade Seaion imi 91ovareis Semon *we Option 0 Station Y% Option ■ Regional Tramooraildn Center I AcvvtryAE ptoyrnem C=eIr -MM—MMMO=mMim� 0 1 2 5 Miles 7 S=21 Figure S.2 ORANGE COUNTY CENTERLINE PROJECT Alternatives Evaluated in the Supplemental DEIS/R6vised DIEIR' wq fA- M7 0 , �,m=33=&;;I VwCenterLlne � o I AP� Stall 4V. Ftavateci kematKa 2.t -A,2) At-Graw Section tttt tea Soc6cn Stmion 0 Rogionow Tramporation Cam . at AmMty/Empk��,t'Cem( . m 0 1 .2 5:xhes Per 'It J1 W-wo S722 Figure S.3 ORANGE COUNTY CENTERLINE PROJECT MOS Alternatives Evaluated in the Supplemental DEIS/Revised DEIR Syr :Y. �A r%�. T iY14M - T� 1� M� k" 11heCenterLine JV 08KNoorpi erstbng Sagowt OV MOS Cenval AOP MOS So= A wos south 8 A-,Gram Swicin 11111 E!cVDRx So-wor. 0 smon ■ Regional Trarmpcnavcn Caste, :D Advjty/Empfoyrrem Carta 2 5 MUC5 Hlv S-23 Orange County cenm/LbW Supplemenla! DEIS/R"n d DER - Ereminr Summ y Grade Crossing Treatments:' for street level alternatives, intersections are controlled by traffic signals. Some new signals may be introduced to provide places for vehicles to cross. No railroad grade crossing protection is assumed, except the following: Anaheim Boulevard at Santa Ana Street, where a Union Pacific rail spur runs down the middle of the latter street (currently controlled by traffic signal, and unlikely to change) Cerritos Avenue at the Union Pacific (UP) rail spur, affecting both the SRA and lAA (needs new signal or gates and bells) Memory Lane, west of the Santa Ana River Channel, crossed by EA 2 and MOS- Central (needs new gated crossing) Main Street at UP spur (south of Warner Avenue, on the SRA), proba- bly needs signal or gates and bells Arterial Highway Lanes and On- Street Parking: the street level alternatives may require removal of arterial highway lanes (one in each direction, except where being replaced by widening) and may eliminate on- street parking de- pending on the overall existing width of the arterial highway. Signal Preemption: the street level alternatives will preempt all local traffic signals (Le, CenterLine trains will get a green light as they approach traffic signals). Feeder Bus System: the County's bus transit system would be modified and optimized to serve as a feeder system to The CenterLine. For more detailed information regarding The CenterLine project alternatives, please refer to the Rail System Specifications technical report (Appendix M to the previous DEISIDEIR, September 1999). Please refer to Section 2.0 of the previous DEISIDEIR (September 1999), for a detailed description of the No Build Alternative, the Elevated Alternative, Street Level Alternative 1, and Street Level Alternative 2. CenterLine Facilhies Each CenterLine alternative would include a Maintenance and Storage Facility (MSF� as well as power substations in the vicinity of each station location. The proposed location for the MSF is in the City of Anaheim on the north side of Katella Avenue (north of the frontage parcels near Anaheim Boulevard and Cerritos Avenue). An alternate site for the MSF is located near the Irvine Transportation Center, located within the Marine Corps Air Station - El Toro (MCAS El Toro) property. This site is the assumed MSF for both MOS -South A and B. Light trail transit (LRT) vehicles would receive electrical power through a system that would include traction power substations and an overhead catenary power distribution. Substations (2 units, 1 megawatt each) would be located every 1.0 to 2.0 miles (1.6 to All potential grade crossing treatments will be designed in accordance with Public Utilities Commission requirements. 12/3M4(P,11918301EAZlmp sea s- orev.wpd)> 5-24 orange Calmly CenMdlne Suppl wmfal DEZ/Reriaed DUR • Ewmi m Sw wy 3.2 km) along the alignment. These substations would be prefabricated one -story containers, approximately 600 feet in size. CenterLine Technology In Orange County, The CenterLine project will serve a primary trunk role connecting with key activity centers and with feeder bus routes. Given this role and the require- ment for a medium capacity transit technology (based on ridership forecasts), the candidate technologies are LRT, monorail, and automated guideway transit (AGT). All three of these technologies are under consideration for the Elevated Alternative; however, for analysis purposes, LRT is assumed to be the technology used. For the seven new alternatives in this Supplemental DEIS/Revised DEIR, only LRT is feasi- ble, because each alternative runs at least partly at -grade within public streets. Mono- rail and AGT have been analyzed at a qualitative level of detail; please refer to the previous DEIS/DE1R (September, 1999) for a detailed description of other potential technologies for The CenterLine project The OCTA also wishes to maintain the flexibility of having an elevated system or a street level system where appropriate. OCTA is currently reviewing third rail power supply options on elevated LRT components, and exploring the possibility of eliminat- ing catenary wires at street level. Technological advances to LRT are being made that would allow for this possibility. S.4 FWANCTAL ANALYSTS The financial analysis includes identification of operating and capital sources and uses of funds; estimation of annual cash flow requirements; identification of potential funding sources, and evaluation of the fmancial'risk associated with implementing each of the alternatives. The analysis spans between 7 and 17 years of construction (depending on the alternative evaluated) and 20 years of operations following the opening of the MOS. The analysis evaluates two construction scenarios: building the full CenterLine system in two stages, and building only a Minimum Operable Seg- ment. Phasing options; including final definition of a Minimum Operable Segment, will be considered following selection of a locally preferred alternative. Funding sources currently available for The CenterLine project include FTA Section 5309 New Starts Funding, Congestion Management and Air Quality (CMAQ) Program funds, State Transportation Improvement Program (STEP) funds, Measure M local sales tax funds, and passenger fares. The main analytical tool of the fmancial analysis was the cash flow financial model. The cash flow model integrated general assumptions for all data, such as inflation rates and interest earnings rates, with the projected transit ridership data. Detailed funding/ revenue data were entered into the model, as well as operating and capital cost data developed for The CenterLine project. The cash flow summary consolidated the detailed data, and determined annual operating and capital surpluses/shortfalls and r213R10KP:1m1930EAZbvp ucr s- on:..wya» 5-25 Orange County Ceutrlont Supplemental DCMR"v d DER - Encwive Sununory cumulative ending balances for each CenterLine alternative. The results from the cash flow summary were the primary tool for evaluating the financial feasibility of The CenterLine alternatives. An alternative was considered to be financially feasible if there were no forecasted annual cumulative operating or capital negative ending balances. The results from the cash flow financial model indicate that all of the alternatives would be financially feasible given the assumptions listed above. An evaluation of the results from the cash flow financial model is presented below. Elevated Rail Alternative The establishment of the Rail Operating Fund signif icantly enhances OCTA's capabil- ity to build and operate an urban rail system. Accordingly, there are no cumulative negative capital or operating ending balances for the Elevated Rail Alternative. By 2016, the initial $250 million deposit of Measure M proceeds increases to $443.4 million. The grade separated operating characteristics of the Elevated Alternative result in the lowest operating cost and highest ridership of the three rail proposals, which extends the life of the endowment fund. As an expendable trust, the operating fund begins to reduce its principal balance in FY 2034. Conversely, capital construction costs are highest in the Elevated Rail Alternative (52.76 billion). The model projects no significant ending capital balances and uses all of the Measure M capital funds available. Street Level Alernative I (SLA 1) Each of the rail alternatives benefits from the fiscal stability provided by the Rail Operating Fund. There are no cumulative negative balances an either the operating or capital funding plans. SLA 1 begins to draw on the operating fund principal balance in FY 2032. The model also projects no significant ending capital balances; total con- struction cost is estimated at $1.95 billion. Street Level Alternative 2 (SLA 2) Similarly, SLA 2 has no cumulative negative operating or capital ending balances under the model assumptions. The operating costs for SLA 2 ate similar to the Ele- vated Rail Alternative, but as a much shorter alignment; the ridership projections and fare box recovery are the lowest. SLA 2 begins to use the operating fund principal in FY 2032. 12rY O (P.UB183 MEtLTWzp sea s- 0m-.wpd* S -26 O.arge Couary CemerLme Supphmemd DEIS /RgWmd DEIR - Emmlim Soma y Staff Recommended Alternarive (SRA) By FY 2009, the initial $250 million deposit of Measure M proceeds into the operating fund has increased to $295 million. The 12.6 mile minimum operating segment (SRA MOS -South A) is completed and revenue service begins. In the first year of operation. 4.6 million passengers ride the system; and the annual operating subsidy is $12.8 million. By FY 2017, the entire alignment is complete, and ridership grows to 20.4 million passengers at an annual operating subsidy of $35.5 million. At 20 years of operations (2028), 23.9 million passengers are riding, and the system operating sub- sidy is $52 million. As an expendable trust, the operating fund begins to draw down principal balance in FY 2024. The capital construction costs for the SRA are $1.790 billion (1999 dollars). The model projects no significant ending capital balances and uses all of the Measure M capital and Prop. 116 funds available. Irvine Alignment Alternative fL4A) By FY 2009, the 13.59 mile minimum operating segment (IAA MOS -South B) is completed and revenue service begins. In the first year of operation, 5.0 million passengers ride the system, and the annual operating subsidy is $14.9 million. By 2017, the entire alignment is complete, and ridership grows to 21.2 million passengers at an annual operating subsidy of $37.4 million. At 20 years of operations (2028), 29 million passengers are riding, and the system operating subsidy is $55 million. As an expendable trust, the operating fund begins to draw down principal balance in FY 2023. The model also projects no significant ending capital balances, with the total construc- tion cost estimated at $1.943 billion (1999 dollars). Elevated Alternative 2 (EA 1) EA 2 also had no cumulative negative operating or capital ending balances in the financial analysis. Two alternative minimum operating segments were evaluated, MOS- Central and MOS -North. Construction of either initial operating segment was completed in FY 2008, and revenue service began in FY 2009. MOS- Central had the highest ridership projections, at 12.7 million riders in 2009, at an estimated annual operating subsidy of $13.1 million, and was the longest of any of the initial operating pieces at 15.32 miles. Comparatively, the 8.95 mile MOS -North carried 7,6 million annual passengers in 2009, at an annual operating subsidy of $7.7 million. At build out, EA 2 is a 29.84 mile system. Operations of the full system began in FY 2019 and carried 24.3 million annual passengers at an operating subsidy of $40.3 million. At 20 years of operations (2028), 28.3 million passengers are riding, and the system operating subsidy is $55 million. Contingent on which MOS is constructed first, the r:/3lo (MMBISME 2yuvsars- orev.%VM) S -27 Orange County Cenu Dne Supplenwnral DUNRe -isd DEfR • Eacutm Sumauny operating fund begins to draw down principal balance in either FY 2025 (MOS -Cen- tral) or FY 2028 (MOS- North). The capital construction costs are highest in the EA 2 at $2.33 billion (1999 dollars). The model projects no significant ending capital balances and uses all of the Measure M capital and Prop. 116 funds available. S.S COMPARATIVE EVALUATIONOFALTER NATIVES Financial The following points highlight key financial differences and tradeoffs among the alternatives relative to costs, performance, mobility, and impacts: Boardings on the rail alternatives vary from 62,800 per weekday for Street Level Alternative 2 (SLA 2) to 82,500 per weekday for the Elevated Alterna- tive 2 (EA 2). SLA 2 has the lowest ridership primarily because it is a shorter system, while the EA 2 has the highest ridership because it offers the lowest travel times along with the most stations. Each rail alternative increases overall transit boardings, ranging from 76,400 boardings per day for SLA 2 to 113,200 boardings per day for EA 2. These increases are all slightly higher than the number of rail boardings because the number of bus boardings also increases with each rail alternative. This reflects the increased number of transit trips in Orange County, and an increased transfer rate because of passengers riding feeder buses and transferring to The CenterLine rail system. EA 2 has more overall transit boardings than the other alternatives because the higher number of stations makes it easier to optimize the bus feeder network. All build alternatives result in approximately the same, slight reduction in vehicle miles traveled within the Corridor compared to the No Build Alterna- tive. The incremental cost per new transit rider ranges from Sl 1.68 to $21.25 for the build alternatives; SLA I is the most cost - effective alternative at $11.68, followed by SLA 2 at $13.67 and the Elevated Altemative at $21.25. The grade separated operating characteristics of EA 2 result in the lowest operating cost and highest ridership of the six full - length build alternatives. Capital construction costs are highest for EA 2 ($2.33 billion in 1999 dollars). EA 2 has the highest annual operating costs of the six alternatives. 12a=(<P1 ts1e30TA2uup sect s-0m mpd)) S-28 Environmental Omngr CaenNCrnrrr41 r Suppkmrmal DE/W -L ed DEIR - Erecudw Swampy Compared to the No Build Alternative, all build alternatives would have more adverse impacts on the environment (without mitigation) for traffic circulation, displacements, public services, visual quality, cultural resources, noiselvibration, hazardous materials, water resources, natural resources, park /trails, and environmental justice. Mitigation measures are proposed to reduce these impacts. However, all build alternatives would provide a positive cumulative impact on regional transportation, improved transit access for special needs groups, economic growth, air quality, and energy. Key environmental trade -offs between alternatives are summarized below for each environmental topic. Proposed mitigation measures and any residual impacts follow- ing mitigation are also discussed. Roadway Network Table S.G summarizes the adversely impacted roadway segments and intersections for the full - length and the MOS alternatives. Table S.G - Adverse Impacts to the Roadway Network Elevated MOS. MOS. MOS- MOS- Ahernatire SI.A 1 SLA 2 SRA IAA EA 2 South A South il Central North Segments 0 15 Intersections 20 43 36 27 28 6 5 10 For impacts to roadway segments, full lane replacement is not considered feasible or reasonable in areas where right -of -way is limited and widening would result in build- ing displacements. Therefore, there is a potential for unmitigated adverse impacts in these locations. While many of the intersections will function adequately under the identified project alternatives, in each case where impacts are deemed significant, a menu of mitigation measures is proposed, including the following: TSMlsignal optimization (includes retiming, rephasing, signal optimization, and potentially a light rail transit signal priority system in lieu of signal pre- emption, where preemption impacts operations). Also may include turn prohi- bitions, use of one -way streets, and traffic diversion to alternative routes. Local spot widening that allows for geometric improvements without signifi- cant right -of -way, acquisitions. Major intersection improvements (full lane widening), which would require significant right -of -way acquisition. Intersection impacts in the EA and EA2 alternatives and in the elevated portions of the other alternatives can be mitigated with TSM measures and spot widening. For alter- I2n/M(P.VB183UZUA Sup sea S-0re•,%pd» S -29 Orange Cmnry CenferUu Supplemenlal DEMUvieed DE /R - Lrecalm Summary natives with street level sections (SLA 1, SLA 2, SRA, and IAA), approximately 20 percent of the impacted intersections would require full lane widening. Please refer to Section 3.2 of the SDEIS/RDEIR for more information on roadway network impacts. Parking SLA 1, SLA 2, the SRA, and the IAA will result in losses of both on- street and off - street parking; the Elevated Alternative, EA 2, MOS -South A, MOS -South B, MOS- Central, and MOS -North will impact off - street parking in some areas (particularly stations), but will have less of an impact to on -street parking than the street level alternatives or segments of alternatives that are within street rights -of -way. OCTA will mitigate all significant on -street and off -street parking impacts to the extent physi- cally, environmentally, and financially feasible. A mitigation plan for parking impacts will be identified during development of the LPA. In addition to parking for Center - Line passengers, an allowance has been made in the capital cost estimates to replace up to 720 on- street parking spots that could be removed from the street in order to make up lane space lost to The CenterLine tracks. The CenterLine will also generate demand for new park and ride spaces. For the full- length alternatives, new park and ride spaces needed would range from 5,700 spaces for SLA 2 up to 7,850 spaces for the IAA. For the MOS alternatives, new park and ride spaces needed would range from 1,750 spaces for MOS -South B up to 4,500 spaces for MOS -North. Following selection of the preferred route, OCTA will work collaboratively with The CenterLine corridor cities on a park and ride plan to refine the exact locations of the park and ride facilities and how each park and ride facility would function. The parking plan will account for the character of the station areas, the need to minimize local traffic impacts, and the opportunity to provide shared parking at existing or proposed transit oriented developments. Please refer to Section 3.3 of the SDEIS/RDEIR for more information on parking impacts. Land Use For all proposed alternatives, The CenterLine project goals and objectives are consis- tent with those of relevant land use plans and policies. It is supportive of major land use policies defined by the General Plans of affected cities. Tberefore, no mitigation measures related to consistency with land use plans and policies are required. The CenterLine would have a beneficial effect in areas where cities seek to implement transit oriented development policies. With regard to land use compatibility, all of the proposed alternatives will have some impact on sensitive land rues such as residences and institutional uses such as schools and hospitals. The EA, SRA, IAA, EA 2, MOS -South A, MOS -South B, MOS -Cen- 1Wft(CP11ta30\EAZ Mp sea s- O"mpdD S -30 Om ge Counry Cem"Llne Supplameatal DEIS/R"Iwd DEIR • Erec w Summary tral, and MOS -North alternatives will have greater land use compatibility impacts due to visual impacts than either SLA 1 or SLA 2 because of the elevated segments of these alternatives. Conversely, SLA 1, SLA 2, and the street level sections of the SRA and IAA alternatives will have greater land use compatibility impacts due to noise and access impacts than the elevated alternatives. In general, land use impacts are mitigated by project design and by local jurisdictions through land use processes and actions. Specific mitigation measures will be identified through consultation with affected individuals, neighborhoods, and local jurisdictions after a preferred route is selected. Following mitigation, the residual impact on land use compatibility is not expected to be significant. Please refer to Section 4.1 of the SDEIS/RDEIR for more information on land use impacts. Demographics and Neighborhoods Where displacements of residences occur due to right -of -way acquisition, all alterna- tives have the potential for some displacement of special needs populations (minority, low- income, and elderly). These impacts are greater with SLA 1, SLA 2, and the street level sections of the SRA and IAA alternatives than for the EA, EA 2, and elevated sections of the SRA and IAA alternatives. All CenterLine alternatives will have a beneficial effect for transit dependent individuals within these special needs populations. The displacement impacts noted above would be mitigated through relocation assistance programs. All build alternatives would result in the introduction of new visual features and noise sources on the edges of existing neighborhoods within the study area, resulting in potential adverse impacts to community cohesion. The following mitigations are proposed to reduce potential impacts to neighborhoods: OCTA will work actively with affected communities through the station area planning process to establish station area design guidelines that reflect com- munity image and values and to protect community cohesion. After a preferred route is identified, OCTA will work with the local commu- nity and jurisdiction to develop a program of urban design improvements, which could include streetscapes, pedestrian access links, and landscaping elements designed to enhance the impacted neighborhoods. Following mitigation, residual impacts on special needs populations and neighbor- hoods are not expected to be significant. Please refer to Section 4.2 of the SDEIS/RDE1R for more information on demographics and neighborhoods. Acquisitions acrd Displacements Table S.H summarizes the impacts related to full property acquisitions and displace- ments for the full - length and the MOS alternatives. 126100KP:1BIa301EAMup sea S- 0m.wpd» S-31 Dronv County Cenwdine Supplements! DEWA/ IW DEIR • E=x1tw Sww—y Table S.H - Potential Acquisitions and Displacements Elevated mos- MOs- MOs- MOs- Alternative SLA 1 SLA 2 SRA IAA EA 2 South A South B Central North Residential 6 0 9 11 11 Nonresidential 43 14 141 141 142 13 0 1 10 11 Mitigation for displacement of residents or businesses would occur through implemen- tation of the Uniform Relocation Assistance and Real Property Acquisitions Policies Act (Uniform Act) of 1970 (Public Law 91- 646, 84 Stat 1894). Following mitigation, residual impacts from acquisitions and displacements are not expected to be signifi- cant. Please refer to Section 4.3 of the SDEIS/RDEIR for more information on acqui- sitions and displacements. Economics and Fiscal Conditions All build alternatives will result in the following economic and fiscal effects: • Small percentage of property tax reduction due to residential and business displacements. • Minor sales tax reduction due to business displacements. • Increase in overall employment within The CenterLine study area. • Displacement of businesses serving and employing special needs populations. Residual adverse economic and fiscal impacts are not expected to be significant, since the project would attempt to relocate businesses within the same general area. Please refer to Section 4.4 of the SDEIS/RDEIR for more information on economics and fiscal effects. Public Services and l7 iLUms SLA I, SLA 2, and the street level sections of the other build alternatives will poten- tially impact emergency access at street level segments if emergency vehicles are delayed for a significant amount of time due to a passing light rail vehicle. These impacts can be mitigated by implementing emergency signals or controls to allow for emergency vehicles to take priority over The CenterLine system. 'Access to public facilities would not be impaired by any of the build alternatives. All build alternatives have potential conflicts with major existing utilities in the cities of Fullerton, Anaheim, Saari Ana, and Irvine. The SRA, IAA, and EA 2 alignments will require relocations of facilities such as water, sanitary sewer, storm drain, tele- phone duct banks, and high voltage circuits (overhead and underground). In Fullerton and Anaheim, existing aboveground multiple high voltage circuits will need to be relocated underground. The relocation of major lines of water, sanitary sewer, and storm drain will be required for Anaheim, Orange, Costa Mesa, and Irvine. These IM /M(P:11BIB301EA2Unp sat S-Omv wpd)) S•32 Omngr County C'N L!nr Jlpplemental OEIS/Re Wd OEIR • Emudw Summary impacts would be mitigated through typical construction utility location, relocation, and avoidance mitigation measures. Following mitigation, residual impacts to public services and utilities are not expected to be significant. Please refer to Section 4.5 of the SDEIS/RDEIR for more informa- tion on public services and utilities. Visual Quality and Aestkefict While all CenterLine build alternatives will introduce new visual features along their respective alignments, the elevated segments of the EA, SRA, IAA, EA 2, MOS -South A, MOS -South B, MOS- Central, and MOS -North alternatives will have greater visual quality and aesthetic impacts than either SLA I or SLA 2 due to their introduction of elevated structures into viewsheds for sensitive viewers such as residents. Mitigation for visual impacts will occur through implementation of landscape plans, aesthetic features in project design, and the incorporation of project design and development standards to integrate the project into the surrounding communities. Following mitiga- tion, residual impacts to visual quality and aesthetics are not expected to be significant. Please refer to Section 4.6 of the SDEIS/RDEIR for more information on visual quality and aesthetics. Safety and Security Because of the intersecting movements of CenterLine trains with vehicular and pedes- trian traffic, there would be an accident risk associated with street level segments in any of the build alternatives. A recent research study of light rail transit accident experience in ten cities across the United States provides a reference for examining accident potential. The data indicate that the primary reason for accidents is motorist or pedestrian behavior, sometimes influenced by a less favorable design. The vast majority of accidents have involved violations of traffic controls, ignoring warning signals, or reckless behavior. Based on the data, elevated alternatives (EA and EA2) will have a lower potential for accidents than street level alternatives. All build alternatives have the potential for criminal activity (primarily theft and auto theft) around stations. Increased policing or security, especially around stations and parking facilities, would substantially minimize criminal activity associated with The CenterLine build alternatives. Careful planning and design of stations and parking facilities, in association with local police departments, would also deter criminal activity. Mitigation for potential safety and security impacts would occur through project design in the form of code requirements; station and parking lot layout and lighting; fencing where required; and use of existing OCTA operating, emergency, and security proce- dures. Following mitigation, residual safety and security impacts are not expected to be significant. Please refer to Section 4.7 of the SDEIS/RDEIR for more information on safety and security. IW/OORP."Jm830TA2XsW seat S,Omv.wpm> S•33 Orange County CenlerLme Supplemental D£lSI&vInd Df.1R • £tteunsn Suu ,y Cultural Resources Table S.l summarizes the potential impacts to cultural resources for the full- length and the MOS alternatives. PotcatMy Migible for NR Historic Districts (NR) Previously Listed on NR/ Signifi®t ]asignificant Table S.I - Impacts to Cultural Resources Elevated MOs- MOS. MOS- MOS- Alternative SLA 1 SLA 2 SRA IAA EA 2 South A South il Central North 257 307 521 544 544 76 1 1 69 54 2 2 2 2 2 2 0 0 2 1 180 155 310 386 386 41 25 25 26 36 77 152 211 158 158 159 0 0 153 54 NR = National Register of Historic Places Mitigation of cultural resource issues is accomplished through a series of steps. For a federal undertaking, the first step is to assess the potential eligibility of the property for listing on the National Register. For archaeological and buried historic sites, this is often accomplished through test level excavation. If the site is determined to be poteru- tially eligible for listing on the National Register and if project plans cannot be altered to avoid impacting the site, then data recovery would be required to recover the values associated with the potential eligibility of the site. For standing historic buildings, structures, and objects, evaluation is achieved through documentation of the resource. If the property is determined to be potentially eligible for listing on the National Register and if project plans cannot be altered to avoid impacting the site, then Historic American Building Survey/Historic American Engi- nwring Record (HABS/HAER) Level II documentation of all structures, preparation of oral histories, and curation of recovered artifacts may serve as resource mitigation for impacts. Following mitigation, there is still a potential that residual impacts to cultural resources would be significant. Please refer to Section 4.8 of the SDEIS/RDEIR for more infor- mation on cultural resources. Air Quality For all build alternatives, long -term air emission impacts related to operation of The CenterLine project are beneficial to the region. The local carbon monoxide "hot spot' analysis resulted in no identified adverse impacts for any of the build alternatives. All of the build alternatives would also be in conformance with the South Coast Air Qual- ity Management Plan (AQMP) and the federal Clean Air Act. Since no adverse air quality impacts would result from The Cemc Line project, no mitigation would be 12fM((PAMl33afA2lsup sat s•aev.wad)) S-34 Oeange Cwno Cente?Lme Supplemental LiVYRe,lmd DEIR • &eeuriw Sutnnmry required. Please refer to Section 4.9 of the SDEIS/RDEIR for more information on air quality. Noise and Vibration Table S.J summarizes the potential noise impacts for the full - length and the MOS alternatives. Table U - Potential Noise Impacts Elevated MOs- MOS. BIOS MOS_ Alternative SW 1 SI.A 2 SRA IAA EA 2 South A South B Central North Residential 284 291 205 136 142 219 1 7 163 50 Rotellmotel 38 22 12 11 11 11 0 0 7 9 Institutional 7 3 2 0 1 2 0 1 1 0 For elevated sections of the build alternatives, all severe and moderate impacts can be mitigated through the use of trackside barrier walls that would be placed on the ele- vated structures. The location of the sound walls would be three feet above the top of rail (4.5 feet high). For street level sections ofthe build alternatives, all severe impacts can be mitigated using six-foot high trackside barrier walls; however, some receptors would still experience moderate impacts. Vibration impacts occur when vibration from a passing light rail train moves through the geologic strata into building foundations, causing the building to vibrate. The main concern is annoyance to building occupants. There would be no groundbome vibra- tion impacts for the elevated sections of any of the build alternatives. Build alterna- tives that are primarily at street level (SLA I, SLA 2, SRA, and IAA) will have a greater potential for vibration impacts. Vibration impacts can be mitigated through train speed reductions, adherence to light rail vehicle performance specifications, optimizing wheel and rail profiles, and installing ballast mats. Following mitigation, noise and vibration impacts are not expected to be significant. Please refer to Section 4.10 of the SDEIS/RDEIR for more information on noise and vibration. Geology and Seismicity All build alternatives have the potential for impacts related to seismic ground shaking, liquefaction, and soil corrosivity. Elevated sections of the build alternatives have a higher potential for seismic impacts due to the introduction of new structures into the environment. Street level sections of the build alternatives have a higher potential for liquefaction and soil corrosivity due to the greater areas of soil disturbance. All geo- logical and seismic impacts will be mitigated through the implementation of the Uni- form Building Code, the American Association of State Highway and Transportation 12t3=((P:V87830 \EA2Vup=1 S- arcv.AVm) S-35 orange Comfy Cennrrine Supplewnml DElS/Revlsad DEIR - Exemlwe Summ y Officials requirements, and local and State design standards. With mitigation, no residual geological and seismic impacts are expected. Please refer to Section 4.11 of the SDEIS/RDEIR for more information on geological and seismic impacts. Hazardous Materials/Waste Since the project area is a developed, urbanized corridor, all build alternatives have the potential for impacting properties that are hazardous waste generators or have contami- nation on site. Street level alternatives are considered to have a higher potential for hazardous materials impacts or spills than the elevated alternatives due to the addi- tional ground area disturbed during construction with the street level alternatives, as well as the greater potential for accidents involving vehicles transporting hazardous waste. With all build alternatives, there is the potential for release of hazardous mate- rials at part: and ride lots, power substations, stations, and maintenance facilities. Mitigation for hazardous waste impacts includes implementation of emergency re- sponse procedures and coordination with the appropriate regulatory agencies, as well as implementation of standard safety, storage, and hazardous materials handling procedures. With mitigation, no residual hazardous materials/wage impacts are ex- pected. Please refer to Section 4.12 of the SDE1S/RDEIR for more information on hazardous materials/waste impacts. Water Resources All build alternatives will result in an increase in impervious surfaces, thereby increas- ing stormwater runoff. The amount of impervious surfaces and additional runoff would be small compared to the region as a whole, and there is little difference be- tween street level and elevated alternatives. All runoff from the proposed project facilities would be controlled so as not to impact water quality, human health, or safety. Therefore, there would be no significant impacts to water quality associated with the build alternatives. All alternatives will also introduce new structures within or near surface water chan- nels. Storm Water Pollution Prevention Plans (SWPPPs) will be developed in coordi- nation with the Regional Water Quality Control Board to ensure that these new struc- tures do not adversely affect the surface water channels. Appropriate Best Manage- ment Practices (BMPs) will also be incorporated into project design and construction. With mitigation, no residual impacts to water resources are expected. Please refer to Section 4.13 of the SDEIS/RDEIR for more information on water resource impacts. Natural Resources Although The CenterLine corridor is primarily urbanized, the build alternatives do have the potential for impacts to vegetation, wildlife, sensitive species, and wetlands. 12rYM<r:4at830TA2lsup sea s-0rcv.wpdU S -36 Ormp County Centerl uv Suppkmem.l OEISIaevind OEIR- ErNulov Summary The alternatives with the greatest potential for these impacts are the ones that are located within or adjacent to San Joaquin Marsh near UCI (SLA 2, SRA, IAA, EA 2, MOS -South A, and MOS -South B). These potential impacts can be reduced through implementation of the appropriate consultation with resource agencies, obtaining required permits, and restoration or replacement of affected habitat. Whh mitigation, no residual impacts to natural resources are expected. Please refer to Section 4.14 of the SDEIS/RDEIR for more information on natural resource impacts. Energy All of the build alternatives are relatively equal in energy consumption. The build alternatives would result in slightly lower energy consumption than the No Build Alternative; therefore, no mitigation for energy impacts is required. Further improve- ments in the energy efficiency of the build alternatives would require an increase in transit ridership through measures such as expanded marketing programs; increased connectivity of the transit system serving the area; and improved patron access to station areas via expanded feeder service, pedestrian amenities, convenient parking, and facilities supporting other nonmotorized modes of station access. Please refer to Section 4.15 of the SDEIS/RDEIR for more information on energy impacts. Electromagnetic Fields (EMF) No significant health impacts related to electromagnetic field exposure are anticipated to result from operation of The CemerLine, and there would be no substantive differ- ence in health related impacts among the various CenterLine alternatives. No health related mitigation measures are required. Please refer to Section 4.16 of the SDEIS/RDEIR for more information on EMF impacts. Recreation/Section 4(7 Resources All of the build alternatives will result in potential impacts to three or four Section 4(f) resources. In addition to the parks and schools, other Section 4 (f) resources would be impacted as identified in the Cultural Resources Section of this document. Mitigation measures for these impacts include replacement of the resource where feasible, appro- priate design of the project to incorporate the resource, detours during construction, and implementation of safety features to reduce potential conflicts with users. Even with mitigation, there is a potential for significant residual impacts. Please refer to Section 4.17 of the SDEIS/RDEIR for more information on potential impacts to recre- ation/Section 4(f) resources. Environmental Jusriee SLA 2, SRA, IAA, EA 2, MOS- Central, and MOS -North will have a greater potential for disproportionate impacts to low income and minority populations due to the large I f!/00tiP:VB1830\EA2ltup ma S-0rev.wpol> S -37 Orange Comfy CeaterUw Supplewnral DEWRevised DE/R- Ereculnr S=ma y number of business displacements within central Anaheim and central Santa Ana. SLA I, MOS -South A, and MOS -South B have the lowest potential for disproportion- ate impacts to low income and minority populations, since they have fewer displace- ments than either SLA 2 or the Elevated Alternative. All of the build alternatives have a beneficial impact to low income and minority populations by improving accessibility via public transit service. Mitigation for these impacts will occur through implementa- tion of measures identified earlier for acquisitions and displacements. With mitigation, no residual environmental justice impacts are expected. Please refer to Section 4.18 of the SDEIS/RDEIR for more information on environmental justice impacts. S 6 ISSUES TO BE RESOLVED Several issues must be resolved before The CenterLine project can proceed further toward implementation. The following discussion focuses on selection of a Locally Preferred Alternative (LPA), subsequent funding decisions, completion of a mitigation plan, and coordination with resource /permitting agencies, and local jurisdictions. Sdedion of the Locally PrejerredAlternadve and Subsequent Funding Decisions The Locally Preferred Alternative (LPA) to be adopted by the Orange County Trans- portation Authority (OCTA) in the winter of 2001 will be based on the analysis and findings from this Supplemental DEISJRevised DEIR, the previous DEIS/DEIR, and the conceptual engineering studies. The LPA may be any one of the six full - length build alternatives or a combination of elements from each. If a build alternative is selected as the LPA, OCTA and FTA will address an initial MOS in detail in the FEIS/FEIR. Following completion of PE and the Final EIS/EK OCTA will request FTA funding authorization to proceed with final design for the initial MOS. Completion of the Proposed Mit(gat/on Plan Design, determination of impacts, and estimates of costs for any major project such as The CenterLine proceed from conceptual to preliminary to final engineering as the project advances to construction. At this draft environmental stage of the process, numerous impacts have been identified, and many mitigation measures such as noise attenuation have already been incorporated into the conceptual design and cost esti- mates or committed to by the project. Mitigation measures are described in this Sup- plemental DEIS/Revised DEIR and in the previous DEIS/DEIR in as much detail as possible based on the conceptual engineering. Where lack of engineering detail pre- cludes identification of specific mitigation measures, the performance standard to be achieved through mitigation is identified. Specific mitigation measures based on more detailed engineering will be included in the Final EIS/EIR. In addition, the OCTA has committed to further ways to mitigate or finalize the mitiga- tion of certain impacts. Examples of areas requiring further study and commitment include: final decisions regarding landscaping and architectural design treatment of 12/31000: IB1a3MEARsW sea s- arr..wp& S -38 Ormge comoy c4we' ine Supplewnwl DEISIRevaed DFJR • Exe dw Swa ry CenterLine project facilities; traffic capacity problems at intersections where there would be significant project impacts on traffic; final definitions (e.g., location, height, extent, type) of noise mitigation measures for selected alignment alternatives and design options; final Memorandum of Agreement negotiated between the OCTA and the State Historic Preservation Officer for mitigation of adverse impacts to National Register eligible resources; demonstration of compliance with Section 4 (f) require- ments concerning parklands and historic properties; and development of traffic man- agement plans for construction of The Centerline project. Coordination with ResourceTermirdag Agencies and Local Jurisdictions Several resource agencies (U.S. Fish and Wildlife Service, U.S. Army Corps of Engi- neers, California Department of Fish and Game) have regulatory jurisdiction over the nature, location, and magnitude of mitigation that will be necessary for habitat losses in various drainage areas affected by The Centerline project. These details will need to be resolved before the project can move forward, and it is likely that this resolution will not be achieved completely until final design activities are in progress. The concept and general parameters governing this effort, however, will be outlined in the Record of Decision and the Final Mitigation Monitoring Program certified by the FTA and the OCTA. Permits will also need to be obtained from the Regional Water Quality Control Board and from the Cities of Fullerton, Anaheim, Orange, Santa Ana, Costa Mesa, and Irvine, for construction activities to be undertaken within those jurisdic- tions. Information supporting these permits will be developed during final design of The CenterLine project. S.7 USES OF THE ENVIRONMENTAL DOCUMENT /OTHER FEDERAL ACTIONS REQUIRED Once a Final EISaR has been prepared, it will be used by federal, state, regional, and local agencies to make a number of discretionary decisions regarding The Centerline project. Depending on the alternatives selected, other agencies may use the Final EIS/EIR as part of the process of issuing permits or other approvals necessary to construct the project. Federal agencies may include the U.S. Army Corps of Engi- neers, the U.S. Environmental Protection Agency, and the U.S. Fish and Wildlife Service. State agencies may include the California Department of Fish and Game and the Department ofTransportation. In addition, several regional and local agencies may use the environmental document in reaching their permit and approval decisions. 1Z3 /00((P;U81830% AZ=p tta S.)rev.wpm) S -39 Sent By Hawkins Law Offices M E To From M 949 650 1181 Feb 13 01 12 18PM Page 2 "RECEI D AGENDA PRINTED" S `' a Ut-ilej, O R A N D U M Leslie Rugers Regional Admimstralor FTA Arthur L eahy Chief Executive Officer OCTA Environmental Quality Affairs Citizens Advisory Committee ( LQAC ) City of Newport Beach Subject U S Department of Transportation Federal Transit Administration s ( M 1 A ) and Orange County Transportation Authority s ( OCTA") Supplemental Draft Environmental Impact Statement/Revised Environmental Impact Report ( "SDEIS/RDEIR") for the Orange County CenterLme Project (the "Project ") Date February 13 2001 ` C3 Cc Mayor Gary Adams and Members of the City Counul - M City of Newport Beach E3 m 1 Z M I hank you for the opportunity to provide these comments on the Suppementgl! (haft Fnvironinental Impact Statement/Revised Environmental Impact Report ( SDEIS/RDIRR or the Document ) for the Protect prepared by FTA and OCTA the Project includes design construction and operation of alight rail line through the heart of Orange County Collectively we refer to FTA and OCTA as the Agencies These comments incorporate any and all comrneuts received by the Agencies in connection with the Project I A Brief Summary of Our Concerns We recommend that the Agencies reconsider the SDEIS/RDEK revise the document to address the Project s impacts in connection with the John Wayne Airport and flibht schedules natural resources in and around the City and other issues discussed below and recirculate the document for public comment We make these recommendations for several reasons (1) The iDFNIRDEIR fails to desenbe the Project fully and accurately thereby undercutting the public s ability to review the SDEIS/RDEIR determine impact-, of the Project and evaluate mitigation measures (2) The SDEIS /RDEIR fails to recognize the significant impacts to the John Waync Airport and to the City of any truncated alignment which does not carry passengers south to the Irvine Spectrum and the Irvine Transportation Center i Sent By Hankins Law Off ices Leslie Rogers FTA Ashur L"hy OC7 A Page 2 February 13 2001 949 650 1181 Feb 13 01 12 19PM Page 3 (3) The SDLIS/RDE1R fails to discuss identify analyze and mitigate the ProjeLt impacts of inLreased passenger loads to the John Wayne Airport (4) The SDE1S /RDE1R fails to recognize analyze and mitigate the Project s impaLLS on the jewel of Newport Beach -San Diego Creek and the Back Bay (5) The SDFIt /RDE1R contain other failings discussed below the Agenues should address these and other issues 11 InIm uctign, EIWEIS and I.eeal Staod@&% whlLh An EIR constitutes the heart of CFQA An FIR is the primary environmental document serves as a public disclosure document explaining the effects of the proposed project on the environment alternatives to the project, and ways to minimize adverse effLcts and to increase benefiLidl effeLES CEQA Guidelines section 15149(b) See California Public Resources Code section 21003(b) (requiring that the document must disclose impacts and mitigation so that the document will he meaningful and useful to the public and decisionmakers ) Further CEQA Guidelines section 15151 sets forth the adequacy standards for an EIR Au EIR should 6- prepared with a sufficient degree of analysis to proi, ide dLLision makers with information which enables them to make a decision WluLh takes account of the environmental consequences An evaluation of the environmental Lffects of a proposed project need not be exhaustive but sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible Disabreement among experts does not make an EIR inadequate but the EIR should summarize the main points of disagreement among the experts The courts have looked not for perfection but for adequacy completeness and d j,00d faith attempt at full disclosure Further `the FIR must contain facts and analysis not just the agency s bare conclusions or opinions Concerned Citizens of Costa Mcs& Inc v 32nd District Agricultural_ Association (1986) 42 Cal 3d 929 In addition an EIR must specifically address the environmental effects and mitigation of the Project But lt1he degree of specificity required in an EIR will correspond to the degree Of spcufi(Aty involved in the underlying activity whlLh is described in the FIR CEQA Guidelines section 15146 Some projects such as general plan adoption deal with general issues but CFQA also applies to small projects which require merely a conditional use pLrmit ThL ISent By Hankins Lan Offices 949 650 1181 Feb 13 01 12 20PM Page 4 I "lie Rogers FTA Arthur Leahy OCrA Page 3 February 13 2001 anal} sis ui an EIR must be specific cnough to further Informed deusion makinb and public partiupdtron 1 he EIR must produce sufficicnt information and analysis to understand the cnvironmental impacts of the proposed project and to permit a reasonable choice of alternatives so far as environmental aspects are concerned See Laurel Heights ImDrovcmcnt Association Regents of the University of Califomia (1988) 47 Cal 3d376 I mdlly in wont Ltion areas near airports a rcccnt amcndment to the CEQA Guidelmcs requires When d lead abeucy prepams an EIR for a project within the boundaries of a Lompreheiisive airport land use plan or if a comprehensive airport land ux. plan has not beery adopted for a project within two nautical miles of a public airport or public use airport the agency shall utilize the Airport Land Use Planning Handbook published by Caltrans Division of Aeronautics to assist in the preparation of the FIR relativc to potcntial airport related safety hazards and noisc problems CEQA Guidelmcs seuion 15154(4) The federal standards cstablished for evaluating an EIS may be more relaxed than the California standards for evaluating an EIR Nonetheless an EIS should be a self contained document which informs the decisionmakers and the public without the need for undue cross rcfcrence Baltimore Gas and Electric Co. v Natural Resources Defense Co ncil (1983) 462 US 87 99101 n 12 and 13 F wally CEQA (Juidelmes sea.tion 15160 discusses various types of EIRs 1 he variations set forth in section 15160 are not exhaustivc Lead agencies may use other variations consistent with the Guidelines to meet the needs of other circumstances Id However all E1Rs must fulfill the content requirements of Article 9 of the CEQA Guidelines 11 The types of EIRs in Article I 1 include a Subsequent EIR Supplcment to an EIR, and an Addendums to an FIR Article I 1 does not address a Revised EIR Further a review of the CEQA case law reveals no sui-h us(. 11 Procedural Issues The "Revised FUR and Document Availability I he Executive Summary attempts to explain the Project History and the Decision Making Process The Summary attempts to explain the need for the Supplemental Environmental ImpdLt Statemcnt and the Revised Fnvironmental Impact Rcport However this sei.tion falls to explain why the EIS is supplemental and the EIR is re,.ised Indeed without explanation this difference will lead to confusion and obscure the purposc and the standards applicable to an evaluation of the Document Thc Document should clearly explain the process and the rationale for the developmcnt of this new category of a Revised FIR lSent By Hawkins Law Offices Leslie Rogers FTA Arthur Leahy OCTA Pagc 4 Fcbruary 13 2001 949 650 1181 Feb 13 01 12 20PM Page 5 Further the A6enctes have attempted to make the Document and the earlier DEIS/DEIR for the Projcch gcnerally available to the public However this attempt has met with dhffhculthcs First and foremost the Documcnh is available on CD ROM and on the OCTA webstte Althou6h the Document is available in this electronic medium the formatting of die Document precludes the ability to copy portions of the Document for comment Sccond the Document s current format is difficult to read in the clectrontc medium the paper copies are superior Unfortunately the paper copies arc not gcncrally available We suggcct that to the future the Agencies make other such documents fully electronic and allow for ease of use- III Section I Statement of Purpose and Need As indicated above this Section purports to discuss the baLkground of the Project and the used for the Document However this Section fails to discuss and explain in a clear fashion the need for a Reused EIR mshcad of some Addendum or other document One of the reasons for the SDEIS /RDLIR is the discussion of the new Alternatives As discussed immediately below the Alternatives discussion is inadequate the Agencies should continue to revise and improve tic Document so that the AltLrnatives discussion fulfills its promise Further and more importantly the scope of the Document is truncated Section 1 2 purports to dISLUSS the rebtonal setting of tie Project However this section fails to consider the Project s IoLauon in relattutt to the City ofNcwport Beach and the Project s impacts on the Civy including impacts on the John Wayne Arrport San Diego Creek and the Upper Ncwport Bay Correlatively section 1 2 erroneously states that the Project Corridor conshstS of mixed uses of residential and commercial uses However this statement ignores the important airport use in the vicinity of the City The Agencies should revise supplement or otherwise correct the Documcnh to discuss specifically the Project s impacts on the City the Airport and the City s resources including San Dtcgo Creek and the Upper Newport Bay Seaton l 5 5 addresses future environmental processes This scchton states that projects such as the Proju t are iterative with continued release of envhrorimcnhal documents for chanf,es in the PTOjcct Howevcr as discussed below the Agencies must carefully proceed in this iterative process Each document must contain specifics details rather than general promet s Ati discussed below the Document fails to contain specifics as to the Project Alternatives and this failing undercuts the Document. The Agencies cannot rely on the iterative process to delay thcSL details Sent By Hankins Laii Offices Leslie Rogers f"I A Arthur Leahy O(TA Page 5 February 13 2001 949 6.O 1181 Feb 13 01 12 21PM Page 6 IV Section 2 The Project Descnptwn, Project Alternatrves and the Need for Specificity As indicated above the SDEIS/RDBIR sets forth additional alternatives including a di%Lus,sion of the thrcc original alignments a new discussion of three new alignments as well as a decision on the I ovally Preferred Alternative ( LPA ) and a Minimum Operable Sci ment ( MOS ) At the outSCt we note that all Alignment Altcrnalrves for the LPA identify a Imc to the south UILluding the Irvine Spectrum and the Irvine Transportation Center (LOIICcttvcly the Irvine Spectrum and the Irvine Transportation Center are referred to as the Southcm Destinations ) as optional Further the MOS Central stopls at the Irvine Business Complex and does not servncc southcm areas in Orange County Although the Document does not address the impacts of truncated alignment or MOS any such alternative would likely have significant environmental impactS on the City and the John Wayne Airport If the preferred alternative omits the Southern Destinations then the Project becomes one which merely transports passengers to and from the John Wayne Airport As discussed below any Such result would create significant environmental impacts on transportation noise air quality and other resources for the City and for the John Wayne Airport l he Agencies should revise the DOLunient to uicludc discussion of such impacts and should recommend an alternative which mcludes the, Southern Destinations as a mandatory not optional stop for the Project I IOWLVCr Alternatives discussion ui the SDE.IS /RDEIR fails for Scvcral reasons rirst the environmental analysis in the Document does not contain enough information and Spmifncs to compare the, potential impacts of the three new alignments and the three original aligiunents as well as the impacts of the various MOS Alternatives This problem is significant if Alternatives —both the alignments and the MOS —lack specifics neither the public nor the decsiortmakers can determine the extent of the impacts and the nature and extent of thL proposed mitigation Further not only is the impacts discussion at a general level but the proposed tnrtil ation floats at a similar abstract level ( FQA does not require floating mitigation but real mitigation However because of the impacts discussion remains at a general level the proposed mitigation suffers Indeed based upon this general discussion of impacts and mitigation ncithcr the public nor the decisionmakers can confirm with any degree of certainty that significant adverse impacts would be mitigated to below a level of significance CEQA requires more either the proposed mitigation must really reduce the identified significant impacts to less than significant impacts or the Agencies must make findings to support a statement of ovcmding considerations I lowevcr the Document fails to reach this level the lack of specifics as to impacts and Mitigation make it impossible to determine which alignment Alternative and which MOS Alternative would be the environmentally supenor alternative The Agencies must address this (Sent By Hawkins Law Offices 949 650 1181 Feb 13 Oi 12 21PM Page 7 Leslie Rogers FTA Arthur Leahy OC I A Page 6 February 11 2001 issue in view of the stated purposed of the Document, it must discuss impacts and mitigation not on a general level but on a specific level so that the public can meaningfully comment and the decisionmakers can accurately decide on the supenor altemdtives We recommend that the description of the alternatives include the following information (1) The exact location of each of the stations for each Alternative Alignment (2) For each station the Document should identify the proposed access and demand for both pedestrians and vehicles (3) For each station the Document should identify the nature and extent of the facilities t icluding loading facilities and parkin6 for passenger vehicles (For example stations 27 through 30 may serve the residents of Newport Beach but it is unclear whether parking would be provided at these stations ) (4) For each Alternative the Document should identify and discussion the locations of all electrical substations and other facilities needed to serve the proposed routes This lack of specifics also causes problems for the Document s discussion of mmgauon mo.awres The Document does not identify spcuGc imtigiation measures and does not commit the AgenLies to a specific mtiigatroti program Thus falling uadcrcuts the viability of the Document nether the public nor de cisionmakers can assess with cersetinty that potentially sigmfit.ant adverse impacts of the Project or what mitigation itpeasures are necessary Further the Document fails to state what agency implements and enforces the trutigation measures and what agency has oversight to ensure that the promised mitigation is implemented Witbout more specific information, the Document does not provide the City and the public at large with assurance that the Document has identified all adverse unpacis and provided the necessary mitigation therefor If the Agencies select an LPA and MOS without further defimitoat of the Project, its impacts and its mitigation the Document is insufficient to support any discretionary action to proceed with the project V Section 3.0. Transportation Parking, Roadway Impacts and wort Impacts" Section 3 0 of the Document attempts to address Transportation Impacts impacts on transit service and ridership roadway network impacts and parking impacts However this section fails to address transportation unpacts to an important transportapon feature adjacent to the, City John Wavnc Airport The Project will transport many passengers to and from the Airport and this increase will affect the Airport and its flight scheduling Yet the Document contains no discussion at all of this impact or any proposed mitigation The Agencies must again revise the Document to include a detailed discussion of this transportation aid impact, and provide specific mitigation for any such ISent By Hawkins Lau Offices 949 650 1181 Feb 13 01 12 22PM Page 8/25 I eshe Rogers FTA Arthur Leahy OCTA Page 7 February 13 2001 impau Indeed any impact to the Airport Will affect the City Hence any airport mitigation must urcludL mitigation for the City I Further this section fails to explamand analyze specific uripacts and mitigation Indeed the. Document candidly concedes Additional environmental analysis will be conducted after the selection of an LPA and an MOS are selected (sic) fbr T ie CenterLine project This additional environmental analysis will focus oft more specifiti project characteristics related to the MOS that will be defined du nq preliminary eft meenng such as specific power substations and park and ride lots i SDEIS /RDEIR, page Although this pl)mise is enLoOraging it fails to satisfy CEQA requirements The Document dips in apd opt of specifics ¢rid soars in generality in order to satisfy its disclosure obligations and its mformatlonalirequnrements the Document must deal in specifics CLQA dots not sanction the promise of latyr specifics The Agencies should revise the Document to either include specifics or tread at a gerrerallprogramrnaticllevel For instance, the Document attempts to address aad mitij,atc the Project s parking Impacts However the Document provides only a ptbrmse OCTA will work collaborauvgly with the CentetLinc cities on a park and nde plan to refine the e.xau locations of t�hc and ndc fabilitics and how Lath pa and nde facility would function The par" p park and will aLcount for the character of the station areas the need to muumize local ti f'ic impacts slid the opportunity to provide shared parking at e.xisung or proposed transit onegted developments OCTA will nuuj,ate all signs t;arrt on street and off street parkmj, impacts to the extent physically environnient4llyiand financially feasible A mitigation plan for park-u% impacts will be identified 4unng the development of the LPA SDLIS/RDLIR, pa6es 3 51 through 3 52 1 I7te Ajeaic,ies pronuse and defbmal on the mitigation of the sigmficant parking impacts Earls to satisfy CEQA s royuirements By def4rrmg envuonnsental assessment to a future date the conditions run counter to that policy ofCE(�A which mgwrzs environmental review at the earliest feasible stage in the plammnb profess 5gndstrom v Codpty of Menclotano (1988) 202 Cal App 3d 296 308 See BBgz4n6 v Local Agency UJInation Com (1975) 13 Cal 3d 263 282 (holding that the pnnciple, that the environmental impact should be assessc4 as early as possible in government planning ) Mount Sutro Defense Co v , Regent ofU mv i f alit rm (1978) 77 Cal App 3d 20 34 (notm6 that environmental roblems sho d be considered at a point in the plamiu% process where genuine flexibility remarrs� CEQA regOnes more than a promise of mmtigation of ISent By Hawkins Law Offices 949 650 1181 Feb 13 01 12 23PM Page 9/25 Leshe Kogers FT Arthur Leahy OC1 A Page 8 February 13 2001 significant impacts mitigation measures must really mtmmtae the impact The only way to accomplish this and satisfy the disclosure and analytic requirements of the Document is to discuss In specifics the padung mmgation VI Section 4 1 Land Use Impacts add John Way* Airport In 1998 the Airport Land Use Commission for Orange County commented on the Prolec,t and requested that the FIR include a detailed analysis of the potential impacts thtt may be caused by or to the locating of rail line or station facilities within any Noise Impact Zones ACLident Potential or Clear Lones Height Restriction Zones for John Wayne Airport The Commission s Airport Environs Land Use 111an ( AFLUP) provides detailed information regarding these impact zones and the mitigation measures that may be, required for projects within tht,m Neither the DEIS/DEFR nor the Document addresses this issue Indeed, for the City the AELUP ind) present significant issues which affect the Project s impact on the City To the extent that the Document fails to address the Commissions request, the Document must be revised for the City the. Document must Identify an) such ALLUP impacts preseht nutigation and analyze such impacts and imtigation for the effects on the City VII Section 4 10 Noise and Vibrah m What abQW San Diems Creek. San Joaquin Marsh and the Upper No2grt Bay. Round 19 As discussed immediately below in section 4 13 which addresses Impacts on water resources the Document contains a truncated description of San Diego Creek anti San Joaquin Marsh OC I A must remember in the San Joagwn Toll Road E I; the noise Impacts to this st nsitive area required the construction of a sound mitigation wall The Document Qaitalns no discussion of noise impacts on the San Joaquin Marsh Although this nesotmce Is not loctited within the City of Newport Beach, It forms part of the Newport Bay t cosystem The Upper Ntwport Bay Ecological Reserve Is a regionally sigmfitant natural resource located within Neviiport Beach The Document should address any potential Impacts to the habitat in the San Joaquin mash and any indirect Impacts to Upper Newport Bay Following Identification of the Impacts to these sensitive resources the Document should propose mitigation Sent By Ha%ikrns La%i Offices i eshe Rogers Fi A Arthur Leahy OCTA i age 9 rebruery 13 2001 949 650 1181 Feb 13 01 12 23PM Page 10/25 VIII Section 4 13 Water Resources Intjpacts What 'b ut SD Creek, SJ Marsh. nd Upper Newport Bay, Round H The Document s vision of water resources in the vicinity of the Protest iti myopic i All di%LUSSron of existing water resources will be described wider the City of ( osta Mesa and the City of Irvine setting secuons' since those are the only jurisdicUons that are potentially affected " Iles conclusion falls far short of the level of an impact ariWysis required for an rIR In addition Figure. 4 13 1 attempts to delineate surface waters in the vicinity of the Project However thL Project overlays render the vicinity map imoossible to read Further the maps fail to apprLt.iate the locations of San Diego Creek, San JoaqumMarsh and the Upper Newport Bay I wo Alternatives direLtly affect San Diego Creekl the Irvine Alternative and the Elevated Alternative Yet the Document fail% to address Impacts tq this resource Portions of IAA MOS South B and EA 2 trdverte the natural watercourse of the San Diego Creek Channel Although time alternatives mostly travel along the bank of the creek they do Lions the Lhannel at certain points IThis is not LonsidLred a sibnificant impact that would alter surface water drainage patterns SDCIS/RDE1R pagL 4 13 5 This conclusion is not analysis presumably thL Lonstruction impacts alone would regwrL some recogution and mitigation Thle Document has no time for such analysis 1 urther Given the lack of specificity with respect to parking and access to the Project and its stations the Document cannot address the unpact of impervious surfaces on drama6e and groundwater Nonetheless without quanti ring the e" of such impervious surfaces the Document concludes that the amount of impervious surfaces related to the Project would not affect drauiage or groundwater recharbe Agaut, the Docurignt ha, an explanatory not diLtatonal purpose Fhe Agencies should address the impacts of the impervious surfaces and propose appropriate mitigation IX. Newport Bay, Round Ill, I The Upper Newport Bay Ecological Reserve is a6onally significant natural resourct IoLated within the City of Newport Beach. None of the Project Alteratives are located within thL City Although the Document attempts to anal i to natural resources upstream from the City the Document fails to consider the extent of such and fails to trace the downstream impacts for any such upstream impacts In particular Project has the potential to affect the San Joaquin Marsh and Newport Bay Sent By Ha1ikLns Lati Offices Leslie Rogers FTA Arthur Leahy OCTA Page 10 February 13 2001 949 650 1181 Feb 13 01 12 24PM Page 11/25 1 or instance Figure 4 14 5C does riot deli rate the biotic resources adjacem to the Project Aliemativc alignment along Campus Drive Further Figure 4 14 3 fails to identify biological resources in the San Joaquin Marsh alon6 the south side of Michelson Dnvc. Page 4 14-4 ret.ogmzes the present of a strip of coastal cage scrub (CSS) resources which thL Irvine Ranch Waier Districi has installed on the berm along Carlson Avenue and Michelson Dnve Presumably tht, Disinci s installation of such habitai is mitigation for one of the Distnci s prolet.i s impacts l lowcvcr the last paragraph states than focused gnahatcher surveys found no suitable habitai along any of the Proleci Alternatives Thus statemeni fails io recognize the IRWD minganon CSS is suitable habitat for the gnattatcher The Agencies should revise the Documcni to include a study for proiecied species including the gnatcatcher for all locations along the Alternatives Sutularly the Agencies should revise the Doctuneni to uiclude a study for the least Bell s vireo m the npanan habitai io be affected These studies should include habitai area% adlaceni io Campus and Michcluln Section 14 14 3 1 addresses the Staff Rmommended Altemdtive s impacts on naniral resources Among other improvements the alternative includes the widening of Michelson Dnvc This widening would affeu IRWD s CSS restoration area Fast, the Documeni should includt. a figure which identifies this IRWD s CSS restoration area As tht, Agencies know the stale and federal resources agencies consider CSS io be a sensitive habitai This resoun c should be listed oil pa6e 4 14-27 Further page 4 14-30 states than the NLLhelson widening inay rcquae 4criioval of Lodstal sage scrub diong the road ed6e The Document concludes The removal of landscaped coasla) sage scrub is non considered significani since the nanrvc vcgclation provides sparse cover with little to no understory and does non provide a funtanonal corridor for wildlife movement Pd&e 4 14 30 Huh? If the CSS in the IRWD restoration area does not have high value for biological resources thus section should explain the rationale for the valuation The above quotation fails io evaluaie the value of the IRWD restoration area The Agencies cannon merely draw a conclusion withoui analysis The Agencies should revise the Docurnern to discuss thus impdt i and discuss whai happens io the landscaped mitigation on the rmtigated IRWD proleci impacts Further the Agencies should revise the second paragraph on page 4 14-30 to include discussion of the value of this CSS area for wildlife and whether a Lonstnutes unportani CSS The Documcni states that construction impacts will affeci natural resources mLludm6 the npartan habitat along all Alternatives The Agencies should revise the Document to include a nutiganion measure to require surveys for sensitive plain species be conducted prior io start of Lonstruction Further page 4 14 37 discusses other wildlife which was non defined in the setting or impacts discussions the Agencies should revise this section io include mmgation for such impacts Sent By Hankins Law Offices Leslie Rogers FTA Arthur Leahy OCTA Page 11 February 13 2001 949 650 1181 Feb 13 01 12 24PM Page 12/25 Huially as uidicated above the Document fails to consider any of the Alternatives dowmstrcdm impacts of the City s sensitive resources including the Bay and San Diego Creek lice A6enues should revise the Document to include discussion and analysis of U3ese downstream impacts as well as propose adequate nutigation X Section 4 15 Fnerey Impacts and the 2000.01 Enerev Crews Section 4 15 stales California and Orange County have enjoyed sufficient energy supplies throu&h mue,h of the 1980s and 1990s Electricity within Orange County is providt.d pnmanly by Southern California Edison (SSE) and in the extreme southern areas of the County by San Diego Gas and Electric (S G &E) The 25 power plants withui the Count) derive their power supply from a variety of sources including hydroelectric oil/gas and waste by products SDEIS/RDEIR page 4 15 1 The analysis is several years old and reflects the optimism which led to the current energy crisis Further the energy methodology WhILh appears to equate oil and gas supplies with clectnc supplies may require revision in view of the energy crisis Given that many Orange County customers have experienced the threat ofsigruficant fines for violation of their usage contracts the Document must dist.uss the hill impacts of the energy crises on the Project and the Alternatives I he Ikx utnt.nt LonLIudeb Illicit, givem the savings on oil and gas supplies which the, Proje.et would afh,ct all of the Alternatives would result in slightly lower energy consumption than the No Build Alternative therefore no mitigation for energy impacts is required SDEIS/RDEIR page 4 l!) 5 HO%LVer this projection fails to consider the energy crisis The Agenues should revise the Document to include a full discussion of the impacts of each Alternative in connection with the energy crisis the limited supphes and the unstable character of the, energy providers XI Section 4 16 Ue&romagnetic Fields ( "EMY L Hialomcal immpacts and John Wayne Airport, The Documcnt attempts to identify potentially affected equipment and facilities as well as sensitive land uses However Pages 4 16-3 through -4 falls to identify and discuss impacts on important land uses and resources in the vwuuty of the City Furst, although the Documnent rites that lrW may affect biological resources it recognizes that such impacts are 'uncertain The Document incorporates guidelines which have safety factors for such resources However the Document does not discuss or analyze the nature or extent of FMH ISent By Ila%ikins La%i Offices 949 650 1181 Feb 13 01 12 25PM Page 13/25 I eshe RogM FTA Arthur Leahy OCTA Page 1 T February 13 2001 impacts oil biologicdl resources or address mitigation for any such Impacts The Agencies should revise the Document to Include a discussion of such Impacts and If necessary mitigation Second the Document Identifies several facilities and equipment locations which may be potentially affected by the Project s EMF However the Document falls to consider the EMT Impacts In corniection with the Jolu1 Wayne Airport. Tile Agencies should revise to the Document to Include d discussion of such impacts and any proposed Mitigation XII Seaton 4 17 Recreation. Bike Trails Yand Sensitive Resnurces The City has Important recreational resources on which the Project and Its Altenrativc mdy have significant Impacts First, as noted above I the Document focuses solely on upstream Impacts and Ignores any mipacts downstream In the Newport Bay and beyond The Agencies should revise the Document to discuss these downstream impacts on recreation Including boating and other water related activities In the Newport Bay I I urther the Proju.t and its Alternatives may also affect the City s recreational resource of the bicycle trail located adjacent to San Diego Creek Thus trml provides Newport Beach residents with access to regional recreational opportunities Irable 4 17 A purports to summarize recreational impacts but the table addresses only long term impacts For example on page 4 17 10 the Doc"It attempts to discuss short term Impacts Ibis section wt(edes that the Project may close thenratl system along San Diego Creek and require re")MIMetion of tic crossing In order to re -opgn the system Further the Document fails to describe In a clear and understandable fashiop the potential Impacts on the San Joaquin Marsh The Document states that the proximity impacts on the San Joaquin Marsh will not to Impair this recreational resource Sec SDEIS /RDFIR, p4ge 4 17 10 However the Document contains no dlsenssion of this resource or Its recreation vllue Further the Document fails to consider or discuss the Project s noise levels and the distlince from the Project to the recreational resource Without this information the Document cannot serve to inform the public or enable detisionmakers to assess whether the coostrt4ction and operation of the project will result in significant impacts to this recreational resourtc Further to the extent that the Project Lind my of its Alternatives will bring passengers to coastline or the beaches the Document should address the Impacts of this Increased passenger load on the area transportation system and orl the recreational resource The Document proposes certain genefal mitigation measures for Impacts to recreational resources Again the Document soars to di t levels of generality CEQA requires more speetfiLlty who will unplement the mitigatr n measures? Who can enforce the mitigation measures Who will determine whether the initigation measures are being properly Implemented ISent By Hawkins Law Offices 949 650 1181 Feb 13 01 12 26PM Page 14/2., Leslie Rogers F1 A Arthur Leahy OCfA Page 13 February 13 2001 The Akendes should revise the Document to include additional information and analysts on potentially significant short term impacts ( i e air noise restricted access during Lonstrucuon) that could affect the City s and the region s recreational and natural resources including impacts on the bike trail system and the San Joaquin Marsh Further the Agencies should bring the Document back from the stratosphere of general impacts and mitigation and provide specific discussion of impacts address the agency responsible for implementing and enforcing mitigation measures and who if any agency is responsible for oversight X111. Section 4 19 Construction Impacts and Related Downstream Impacts The Document attempts to address construction impacts on each resource or activity As discussed above the Document fails to recognize that the Project may have impacts on John Wayne Airport and upon sensitive resources within the City 1 or instartce as to construction impacts on Transportation activities the Document attempts to address impacts on traffic operations However the Document falls to address any impacts on the operation or facilities which serve the Airport The Agencies should revise the Document to address construction impacts in connection with the Airport i Further the DOCUMLUI states that COUStrnUlon activities may adversely affect park and recreational facilities directly adjacent to The CenterLine build alternatives and moss ]Tits disturbance would consist of detours of public trails construction noise and dust Wiese impacts can be mitigated after the implementation of appropriate mitigation these construction activities are not expected to be significant SDEIS/RDE1R page 4 19 9 This unsupported conclusion regarding no significant impadti and available but uncommitted mitigation does not satisfy CEQA requirements CEQA regwres much more the Agencies should tdenufy and discuss the construction impacts for each Alternative dtld address impacts including downstream impacts which may affect water resources sensitive habitat and other resources within the City including noise impacts on sensitive areas including San Joaquin Marsh as well as dust impacts to San Diego Creek and the Bay NCIV Section 4 2 Demographics. NMliborhoods, and Visitors and Guests The Document attempts to address the Project s impacts on demoi,raphics and neighborhoods but its focus is too narrow For instance the Document states that Project and its Alternatives would attract new transit riders to the Project s stations and that all of these new users would be within walking distance Ot the stations The Document concludes that local area residents would not need to park at the stations ISent By Hankins Lau Offices 949 650 1181 Feb 13 01 12 26PM Page 15/25 Leslie Rogers Fl A Arthur I eahy OCTA 1 age 14 February 13 200 t This assumption is unsupported by the facts and the realities of life in Southern California Area residents may park near tions including stations 27 through 30 We do not h heeve that to the extent that residents of Nowport Beach will become new nders that these new riders will walk to the stations Moreover I seems unlikely that all new riders would live within walking distance Lonsidenng the configuration of adjacent residential areas in southLm Irvine and northern Ncwport Beach The Agencies should revise the Document to include an analysis of parking needs at each of these stations in fader to assess fully the potential Project related nmpdLts and to propose mitigation measures of necessary XV Section 4 20 Cumulative Impacts and Increased Air Travel f The Document attempts to analyze cuumulative impacts in Section 4 20 The Document states that transit mode share would be mereased and patronage would be increased Presumably this would affect travel to and from John Wayne Airport Although the Document Loncludes that the cumulative impact- are consider beneficial impacts we doubt that increased passenger demands at John Wayne Airport nls'a beneficial unpact The Agenues should revise the Document to include a discussion of thelcumulative impacts of the Project on air traffic demands including scheduling at John Wayne Airport Father the DoLumenl fails to evaluate and analyze the cumulative nmpaLts of the Project and its Altematives on housing and scrvrecsi For instance the cost of housing within thL Comdor is high The Project may result in b concentration of high density housing along thL nLw transportation corridor with attendant increased demand for services The Agencies should rwnsL thL Document to address the cumulative impacts of the Project and its Alternatives on housing and services and propose necessar} mitigation. In addition the DOLument addreasesleumulative impacts to water resource! ,ensiuvc habitat As to water resources the Document notes the possibility of sh construction rclatcd nmpaLts on surface water and concludes that Project related runoff would be add�d to existing or potential runoff from projects SDEIS/RDFK page 4 20 7 However this promise is not comforting this simply there will be cumulative impacts CEQA re4wres more analysis and mmbation of Lunulative impacts As to natural resources the Document suirpnsingly states that most areas of the habitat within the Comdor area have been prevnousli disturbed or developed ISent By Hawkins La%i Offices 949 6,,0 1181 Feb 13 01 12 27PM Page tfi /25 Leslie RoLers F 1 A Arthur leahy OC7 A Page 15 February 13 2001 SDEIS/RDFIR, page 4 20 8 Any degradation of thI area 1s not a reason to continue the problem further the Document fails to recognize theQdownstream Impacts of the Project ThL cumulative Impacts of the Project and other related +jects may create significant Impacts downstream within the City The Agencies should rd' ise the Document to address the cumulative downstream Impacts and provide the nec*sary mitigation XVI Section 4 21 Other Impact Conaidgrationg�aduding Housing and Enerev As indicated above the Project and Its Altern lives growth InduLing Impacts would generate increased moderate and lugh density housln along the Corridor and its stations As to the stations in the vicinity of City stations 27 throng 30 these impacts maybe significant Further the Document notes that Once operational 1 he CenterLme build alteLives would wnsume slightly more energy on a daily basis than the No Bwl Alternative for propulsion energy SDE15 /Rl)hlR pagL 4 21 -2 Although this section discussion of ener6Y impacts again we encourage tl the current reality Lnergy costs are soaring given t the Agencies should revise the Document to reflect mitigation XVII Section 4 5 Public Services ai on City Services and Utilities Tht% section attempts to address the Project As noted ahove the Project w111 affeLt the power u Agencies should revise the Document to Show this In addition the Document attempts to show Ignores the City sjoint service agreement with area and fire services The Agencies should revise the C such agreements and propose any mitigation which Section 4 G attempts to address Impacts on vi Indicated above the Document s discussion of all irl impacts Is very general and undercuts the public s a ability to deUdc on the correct alternative 1 a it n 9 at odds with the Document s Agencies to revise the Document to reflLLt Project s mLrcdsed energy wusumptwn energy shortage and propose neLeSSarj acts on Public Services and Utilities Southern California F,dlson The ;t and provide necessary mitigation �oject impacts on Public Services but ties and the County of Orange for police ;ument to address the Project s Impacts on necessary quality and aesthetic% First as s including visual quality and aesthetic to comment and the decisionmarers Sent By Hawkins Law Offices Leslie Rogers F1 A 4rthur Leahy OCI 4 Page 16 febTuary 13 2U01 949 650 1181 Feb 13 01 12 28PM Page 17/25 FuirthLr & Project threatens substantial adverse aesthetics impacts associated with stations large platforms overhead catenary power syttems parking and substations end noist. walls The Document contains no specifics for theseand other areas The Agencies should rwiew the DOLu ment to assess these impacts for the San Diego Creek regional trail and for the Sari Joaquin Marsh In addition Section 4 6 2 employs a rating system to determine a visual impact d visual impact score of 2 1 or more is considered a sigmficaryl impact which would require mitigation However the numerical rating is not appLed to the impacts discussion The Agencies should revise the Document to carry over the rating system tlltto the impacts discussion The text should clearly state whether an impact is significantly adverse For example the fourth paragraph on page 4 6 21 states that significant visual impacts would occur at the University Town C cnter/UC However the impacts discussion below {his statement sunder Viewpoint 21 (San Joaquin Marsh) states that the visual impact would bd low This seems mwnsistent because viewers in the San Joaquin marsh would also see the Ration and other infrastructure at the intersection of Campus and University A clear discisssion of rmpaLts and possible mitigation should be provided for this uinique location XIX Section 4 7. Safety and Secunty —No FindL*j r+eeardmE John Wayne Airport As indicted above Guidelines section 15154(a) requires that the Agencies must use the Caltrans Airport Land Use Planning Handbook published to assist in addressing potential airport related sdfLty hdiards and noise problems Despite the Airport Land Use Con=ssion for Orange County s 1998 comments neither the Docur-4ent nor the DE1S /DEIS considers this resource or address this issue the Agencies should revise the Document to Include a discussion of this resource and an analysis of the Project s impacts on airport safety _d W V I y ♦fir r • -r f~ J---t r ,f I y ♦fir r 1 cc1 IMi_�rL1J • 1 'Co CD CC COD Q `: _ " 5 1; L • -r J---t r ,f 1 cc1 IMi_�rL1J • 1 'Co CD CC COD Q `: _ " 5 1; L 0 y i ca 0 ea . a? cfD i :O y eya Co N o RON .:. 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