Additional points to make in your comments to Caltrans:
Don’t Piecemeal” the environmental analysis - Include all 101 Corridor Improvements in the EIR
- There are three intersection improvements that are required for the Project, but are being processed “parallel” with the 101 widening, including improvements to the railroad bridge at Cabrillo Blvd/Los Patos Rd, to allow bikes and pedestrians to travel safely in the area, and a roundabout at Olive Mill Rd. and improvements to San Ysidro Rd. to prevent traffic from backing up onto the 101.
- CEQA prohibits “piecemealing” of a large project into a series of smaller projects to show less impact
- The EIR must analyze the impacts of these “parallel projects” in the EIR to ensure that all adverse environmental impacts are analyzed and mitigated comprehensively.
- Caltrans’ piecemealing of the project and its analysis has allowed the EIR to overlook significant safety impacts to pedestrians and bicyclists, backup of stopped cars onto the 101 travel lanes, and resulted in local jurisdictions having to pay to mitigate project impacts that Caltrans should be responsible for.
Use Local CEQA Thresholds to fully disclose impacts from increased intersection delays
- Caltrans uses an arbitrary CEQA threshold (that triggers a significant impact which must be mitigated) that minimizes the significance of Project impacts from intersection delay. The EIR should evaluate impact significance using established thresholds, which show that the Project will cause significant impacts at many more intersections.
- Flaws in the EIR’s analysis of complex intersections mask severe impacts including interchanges and downstream intersections reaching gridlock and queuing back onto the freeway. The analysis must be corrected, significant impacts recognized, and additional mitigation measures and/or alternatives identified.
- The EIR ignores unacceptable safety impacts to pedestrians and bicyclists caused by increased intersection delays and proposed mitigations to reduce vehicle delays. The EIR must identify, analyze, and mitigate or avoid these significant public safety impacts.
- The EIR fails to address inconsistencies with local planning documents, including policies protecting safe pedestrian and bicycle routes and access to the coast. Policy conflicts are created at several impacted intersections that must be identified as significant impacts, analyzed, and mitigated. This is especially critical because local jurisdictions must apply their own policies when reviewing permits required to implement the Project, and will rely on the EIR during that permit review.
Adequately mitigate the Project’s impacts
- The EIR does not show that the proposed mitigation measures will effectively reduce impacts, or evaluate whether they may cause additional impacts. This analysis must occur in a revised EIR.
- Because the EIR does not identify significant impacts to pedestrian and bicycle safety, it also fails to mitigate these impacts. The EIR must be revised to recognize and fully mitigate significant pedestrian and bicycle safety impacts.
- Caltrans proposes to fund only a tiny fraction of the cost of the required improvements to local intersections. To ensure that required mitigation is in place before the Project is constructed, Caltrans must commit to funding a much higher levels of funding.
- The “mitigation strategy” is not fully identified in the EIR, but is improperly deferred to “further coordination with the local jurisdictions”. Specific information about infrastructure improvements must be circulated to the public to review in a revised EIR.
Accurately assess cumulative impacts
- Cumulative impacts of the Project were substantially understated, because the EIR assumed all required mitigations for Project-specific impacts would be in place, even though new evidence shows this is unlikely. The EIR assumed that all mitigation projects would be funded largely by local jurisdictions, and that the “parallel projects” including improvements at Cabrillo/Los Patos, Olive Mill, and San Ysidro, and four daily commuter rail trips will be in place.
- To avoid the likely scenario that these improvements are not in place by 2040 and intersection and mainline ensues, Caltrans must ensure that the required mitigation and parallel projects, including commuter rail, are all funded and implemented concurrently with the highway widening Project.
Recirculate another draft EIR for public comment
- Because of the substantial errors and omissions in the revised draft EIR, it does not fulfill its informational function.
- Unless a revised EIR is recirculated for an additional review period, the public and responsible agencies cannot meaningfully comment on the Project’s impacts and ways to feasibly mitigate or avoid those impacts.