Sierra Club Marin Group

Melanie Brent, Office Chief

Division of Environmental Planning & Engineering

California Department of Transportation

111 G= rand Avenue, Mail Station 8B

Oakland, CA 94612

November 15, 2007

RE: DEIR/DEIS Comments regarding Marin-Sonoma Narrows = HOV Widening Project

Dear Ms. Brent,

The Sierra Club Marin Group is pleased to have the opportunity to submit comments and request answers to outstanding issues and concerns regarding the DEIR/DEIS for the Marin Sonoma Narrows (MSN) HOV Widening Project. The National Sierra Club transportation policy regarding = new freeway expansion is:

“Highway Expansion: No limited access highways ("freeways") should be built or widened, especially in urban-subu= rban areas or near threatened natural areas. High occupancy vehicle (HOV) and hi= gh occupancy vehicle/toll (HOT) lanes should come from converting existing hig= hway lanes rather than constructing new lanes. This avoids constructing new lanes which are mixed-flow much of the day, or are converted to full-time mixed-f= low after construction.”

In accordance with this policy, the Marin Group will be supporting the No Project alternative, and trusts that such an option will = be seriously considered. The Mar= in Group, however, in recognition of the fact that the MSN Widening HOV Project appears to be moving forward since funding has already been designated for a portion of the project, nonetheless wishes to comment on the selection proc= ess. It appears from our analysis = of the four (4) Segment B Alternatives, Fixed Lane, Access Alternative 12b would be the least objectionable. It’s the= only option which does not add an additional urban size diamond interchange to Segment B.

Page 3.1-105 states a San Antonio Creek “interch= ange would have strong visual contrast and dominance against the existing natural/pastoral setting, with a strong resulting decline in visual quality= due to major grading, engineered fill embankments, a new over-crossing bridge, = and associated ramps, access roads, signs and lighting.” “…th= is would represent a substantial averse effect.” “Access Option 12b, which wo= uld not introduce a new San Antonio Road Interchange, would be considered preferable to the other options from a visual perspective.”

The Sierra Club Marin Group is very concerned with the growth inducement and visual impacts of the MSN project which will significantly alter the Narrows current = rural setting and agricultural uses with the addition of an additional interchang= e at San Antonio Road. The Evaluation Criteria Matrix, in Appendix A, used to weight the importance of visual aesthetics was only weighted at 8% and potential growth inducement at 10%. We believe these two criteria used= to determine the purpose and need of the project underestimated the importance= of these two issues and should have been weighted more heavily. A higher weighting would have been= in keeping with the General Plan policies of both Marin and Sonoma Counties an= d the cities of Petaluma and Novato. Page 3.1-101 states: “T= he increased dominance of the roadway would cause a pronounced qualitative change in the overall character of landscape to a more urban, highway-dominated setting, = with a noticeable decline in visual intactness and vividness……these impacts would potentially be substantially adverse.”

In addition to our opening statement we ask for consid= eration and response to the following comments and questions of the MSN DEIR/DEIS.<= /p>

1. Page 3.1-118: Adequate explanation, comprehensive discussion and diagrams of mainline freeway realignment of cut slopes and changes to natural contour of the land is noticeably lacking in = the entire DEIR/S. Absent in the = DEIR/S is any meaningful or substantial information regarding the amount of cut and fill or changes of contour or changes in elevations of the natural land formations which are required for the construction this project. Only one number is mentioned, a 43= foot cut between San Antonio Ro= ad and Gambini Road in the vicinity of Cloud L= ane. On page 3.1-118 and 3.1-119 it sta= tes, “Mainline realignment and profile changes, as well as the constructio= n of access roads and new interchanges, could involve major grading and alteration of existing landforms.” “Cut slopes and fill embankm= ents in various locations may result in prominent unnatural landforms that contr= ast with the existing topography.” Etc. How much earth movement will be required by this project? Will there be balanced cut and fill? How many truck loads of earth will be moved?&n= bsp; Will earth be required to be removed off site or brought on site? From what locations will the earth= be taken or come from? What are = the off site impacts of this earth movement?&n= bsp; Please produce and share renderings of contour and change of elevati= on maps of Segment B and describe in the DEIR/S so the public and decision makers c= an understand the magnitude of the impacts from the massive cut and fill of th= is project. What are the biological, hydrological, visual, etc impacts related= to the change in contours of the land and mainline realignment and access road= s?

While attending the Caltran= s Workshop for the MSN Widening project in Petaluma on November 6^th, Robert Nixon, an engineer for Caltrans, briefly described when asked about the earth movement, that one million cubic meter= s of fill would be moved during Segment B of the project. He also stated the project would n= ot have a balance of cut and fill and 2 or 3% of other soil would be required = to be brought in, which could amount to 20,000 to 30,000 cubic meters or 1,200 truck loads of soil. Also, mentioned at this meeting by John Martin, Branch= Chief of Design for Caltrans, was the mainline road would be raised or lowered in some locations as much as 25 to 28 feet. This was necessary due to the roll= ing terrain in sections of Segment B, which Caltrans plans to even out. The DEIR/S should confirm and expl= ain this information and discuss its impacts to the environment. Not doing so in detail, leaves the DEIR/S inadequate.

2. Page 3.1-119: To understand the magnitude of this project, please explain how many truck loads of soil will= be removed for the 43 foot cut between San Antonio Road and Gambini Road in the vicinity of Cloud Lane?= Is there any Design Exception that can be used to reduce this degree of cut or movement of soil? How many tr= uck loads of soil does the DEIR/S estimate will be moved for Segment B, for the various four (4) Access Ro= ad Option Alternatives?

3. What is the comparison of cost of construction for San Antonio Road Interchange = for Alternative 4b, 14b and 14d verses the no interchange of Access Option 12b?= Would a new San Antonio Road interchange increa= se the surrounding property values?

4. Would extra fill be required to con= struct the San Antonio Road Interchange? How much of the surrounding plain would n= eed to be filled to accommodate the interchange? While attending the Petaluma Caltra= ns workshop for the HOV Widening Project on November 6, Robert Nixon, Caltrans project designer, said that 6= 0,000 cubic meters of fill, equaling 2,400 truck loads of soil would be required = to raise the land for the San Antonio Road Interchange by 16 ½ feet. He stated there also would be an additional 4 or 6 foot high concrete bridge required to span the freeway on= top of this fill making the San Antonio Road Interchange 22 to 23 feet high. Pl= ease verify this information and describe in detail, produce a diagram and expla= in the environmental impacts of such amounts of fill to the land and habitat in this area from constructing an interchange of this magnitude in the middle = of an unpopulated, rural, agricultural area.

5. Please explain the justification used for proposing the major interchange at San Antonio Road in Alternatives 4b, 14b, and 14d. Is this huge diamond interchange in this location an unreasonable size for the surrounding rural land use? P= age 3.1-8 of the DEIR/S says that “Land in the vicinity of San Antonio Road, at the boarder of= Marin and Sonoma Counties, is currently scarcely populated.” Would construction of the interchange in Access Options 4b, 14b and 14d place str= ong pressure on the farmland owners to sell or develop the areas surrounding the new interchange? If so, would= this not be growth inducing?

6. Page S-51 Summary: Under Biologica= l Environment, Natural communities; please reconcile the number listed under 4b regarding = the potential result in the removal of about 962 native and non-native trees. S= hould the correct number be 1,401 native and non-native trees? This number would then correspond<= span style=3D'mso-spacerun:yes'> with the numbers listed in Section= 3.3 Biological Environment, Table 3.3-1 on page 3.3-10, Trees Potentially Impac= ted by the MSN Project. This will make it consistent with a difference of 305 t= rees removed between Access Options 4b and 12b.

7. Page 3.3-11: Is there a different configuration or design which could be used at the Redwood Landfill Interch= ange for access to the western frontage road which continues north, for Option 1= 2b, that would involve the removal of fewer trees?&= nbsp; Have other design alternatives been considered for Access 12b Altern= ative which would not require as deep a cut into the hillside and lessen the impa= ct to the trees? Could Design Exceptions be used at the Redwood Landfill Interchange to reduce the deep c= ut and reduce the loss of trees? Whi= le attending the Caltrans workshop for the MSN HOV Widening project in Petalum= a on November 6, John Martin, Branch Chief for Design said that it would be poss= ible to design and construct the Redwood Landfill Interchange on the west side i= n a way which could reduce the loss of trees.&= nbsp; He explained the access to the frontage road would be more in the sh= ape of a “T” verses the existing “bulb” shape. He mentioned this type of intercha= nge has been constructed in other locations, possibly more urban, but it is ano= ther option/alternative that could be used at the Redwood Landfill to reduce the loss of trees. Please explain= and diagram this other interchange alternative and recalculate the impacts of Alternative 12b in regards to the other Access Alternatives in the DEIR/S.<= span style=3D'mso-spacerun:yes'> This revised design would signific= antly reduce impacts on the loss of trees.

8. Page 3.1-22: Please explain why “grazing lands”, which are vital for local dairy farming, are less worthy of protection than “prime farmland”. The DEIR/S states in the sec= ond paragraph “While the MSN Project area is agricultural in nature, ther= e is relatively little land in the corridor that is designated prime farmland, unique farmland or lands of statewide or local importance, according to the NRCS definitions. Much of the project corridor is classified as grazing.” Many of the dairy farm lands, used= for grazing cattle, are under Williamson Act contracts. Are dairy farms not considered an agricultural use? Please explain. Are these ‘gra= zing lands’ less valuable than ‘prime farmland’ and thus potentially more susceptible to being built upon for freeways or other future development? If so, does this make the land aro= und a proposed interchange at San Antonio Road in Alternatives 4b, 14b and 14d l= ess worthy of preservation and protection from growth inducement? We note that Alternative 12b, wher= e no interchange at San Antonio= Road is contemplated, would serve this area as stated in the DEIR/S in most case= s as excellent to good, with non-connecting frontage/access roads and bicycle/pedestrian paths.

9. Page 3.1.5 and page 3.1-20: Caltrans plans to deed the right-of-way/access roads to Olompali and to the counties. Who will pay for the long term maintenance, monitoring, patrolling and liability for the new access roads = and bike/ped paths once they are transferred to Olompali and to the counties? Have Olompali and the counties agr= eed to accept the transfer of ownership, maintenance, monitoring, patrolling and liability of these roads built by Caltrans? Is this deeding of the right-of-wa= ys such a major issue that it may influence the decision as to which alternati= ve is chosen?

10. Pa= ge 3.1-16: What is the percentage of commute trips by Marin residents to Sonoma and North?= Only the Southern commute percenta= ge is discussed in this section of the DEIR/S.&n= bsp; How will a growing Northern commute pattern affect growth patterns i= n Sonoma? What is the Marin to Sonoma commute projected for the future= with the projected large growth of residences and jobs in Santa Rosa? Page 3.29 says that “Employm= ent in Sonoma County and <= st1:place w:st=3D"on">Petaluma is expected to grow respective= ly 48 to 39%.”

11. Pa= ge 3.1-50: If utility lines are to be moved d= uring project construction, is there consideration to placing them underground at= the same time as the roadway improvements, to enhance the scenic and visual qua= lity of Segment B? If so, would these be placed in the mainline or access roads? What would be the scenic and visual benefits of placing the utilities underground?

12. Pa= ge 3.54 states the completion of the HOV lanes will “not interfere” with the proposed SMART operations. Please clarify what is meant by “not interfere”. Page 3.= 1-56 says, when referring to the HOV Widening project, “Not only would tra= nsit travel time be reduced, but transit schedule reliability would be improved. Carpools and vanpoo= ls also would have improved speeds and reduced travel times. The improved speeds and schedule reliability would work as incentives for commuters and other travelers to carpool and/or take advantage of local and express buses that would also use the HOV lanes”. SMART w= ill offer an alternative mode of transit in the corridor, but how will the comp= letion of the MSN HOV Widening Project affect the ridership numbers projected by SMART? Would people more likely use the HOV Lanes for travel verses SMART?<= span style=3D'mso-spacerun:yes'> Please explain your travel and rid= ership analysis in relation to SMART verses completion of the MSN HOV Widening Pro= ject.

13. Pa= ge 3.1-71 & 3.1-72: A new southbound bottleneck is projected to develop between Miller Creek and N= ave Drive by 2030 as a result of the completion of= the Fixed or Reversible HOV Lane Alternative improvements in the MSN. Does Calt= rans have any plans or recommendations as to how to mitigate this new queue/bottleneck as a result of the MSN HOV Project? If an impact is recognized prior t= o the beginning of a project, there should be some discussion as to how to mitiga= te the projected future impacts.

14. Pa= ge 3.1-138, Design Exceptions: The MSN HOV Widening Project will have unavoida= ble visual, land use (taking of lands), archeological loss, increase of impervi= ous surface and storm water run off, increase of pollutants, hillside cuts, loss of vegetation and trees, major= cuts and fill, etc. impacts. Design Exceptions could substantially reduce the expanse and cost of the project a= nd have previously been implemented by Caltrans in many instances. The DEIR/S = page 3.1-138 says that “Design Exceptions shall be implemented where feasi= ble to avoid removal of significant existing vegetation. Design Exceptions may include reducing the width of the standard grading catch line to minimize vegetation removal, steeping of cut and fill slopes…or other measures= as recommended in the VIA…” Caltrans has stated they are willing to work with the counties to re= duce the impacts of the project to the greatest extent possible. One method to reduce many of the a= bove impacts has not been entertained or discussed in the DEIR/S. This would be to apply for and use Design Exceptions. See the following for the Procedure Manual.

ht= tp://www.dot.ca.gov/hq/oppd/pdpm/apdx_htm/apdx_bb/apdx_bb.htm

&nb= sp;

On page S-13, Figure S-4 sho= ws Typical Cross Sections of the freeway mainline with 10 ft inside and outside shoulders, 12 foot lanes and 2 foot center barriers for the MSN HOV Widening Project. Page 2-21, Figure 2-5 shows Typical Cross Sections of two 12 foot =3D 24 foot wide lanes on Front= age Roads with Proposed Class 1 and Class 2 Bikeways (5 to 8 feet wide). In Berkeley, Contra Costa County, Santa Rosa, Novato, San Rafael and other locations in California, Calt= rans has allowed Design Exceptions for reduced outside shoulders to 8 feet and insid= e shoulders to 5 feet. In Novato on U.S. 101 sections of the shou= lders, inside and outside are less then what is proposed in the cross section for = the MSN HOV Widening project; 8 feet for outside and 5 feet for inside shoulder= s on U.S. 101. In fact some inside shoulder widths are as narrow as 2 feet in Novato.

&n= bsp; In addition, is it necessary to have 12 foot wide lanes on the front= age/access roads in this very rural setting? The speed of traffic on the access roads = will be considerably lower than the freeway, particularly next to bike/ped paths= and have minimal traffic. In Escon= dido, there is a project where the frontage road lanes are 10 feet rather then 12 feet wide. John Martin, Branch Chief of Design, at the Caltrans Workshop for the Na= rrows in Petaluma on November 6^th said that Design Exceptions have been made in some cases for 11 foot wide lanes for frontage roads. Please discuss in the DEIR/S how 1= 0 or 11 foot wide lanes for access roads would reduce the foot print, cost and t= he environmental impacts and improve the visual/scenic quality surrounding the frontage/acce= ss roads.

15. Th= e DEIR/S should educate the public and decision makers as to how they can apply for = and receive Design Exceptions for the MSN HOV Widening Project. This would bene= fit the community and help the Counties and Cities adhere to their General Plan policies to retain the rural and important scenic visual qualities of the M= SN. It should relay how Design Exceptions would reduce the cost and footprint of the project and thus significantly reduce the impacts previously mentioned.=

16. Wo= uld obtaining Design Exceptions for the mainline shoulders and frontage road wi= dths minimize the amount of earth movement and cut slopes and cost of the projec= t? Please explain.

17. Pa= ge 3.1-118: If a Design Exceptio= n is granted by Caltrans for inside and outside shoulder widths, as well as widt= h of access/frontage roads, would the loss of trees in Access Option 12b be reduced? Would the overall cro= ss section of the proposed roadway be reduced along with the impacts? By how much? Please explain and show a revised diagram.

18. In= Access Option 12b, could the loss of trees be mitigated by the planting of replace= ment trees? Would this be at a 5 t= o 1 ratio? How long would Caltrans monitor and insure the survival of replaceme= nt trees? Long enough to insure = their survival of at least 5 years?

19. Pa= ge 3.1-121: Option 12b would hav= e no interchange at San Antonio Road and thus avoid light and glare impacts.&nb= sp; Would this be the same for other Access Options 4b, 14b or 14d? This was not mentioned in this sec= tion of the DEIR/S.

20. Th= e newly adopted Marin County General Plan has language in the plan to “consider” the Marin Sonoma Narrows as a scenic highway. Has scen= ic highway designation been taken into consideration? What would be the benefits and imp= acts to the MSN HOV Widening Project if designated as a scenic highway? Would the current project, as currently designed, qualify as a scenic highway? If not, what would need to be done= to accomplish this goal?

21. Page 3.2-15: The 100 year floodplains of San An= tonio Creek and the Petaluma River cover expansive areas. During 100 year floods, water from= the creek and river has been known to overflow U.S. Highway 101 and/or the fron= tage roads. California Gov. Arnold Schwarzenegger in October 2007 signed several bills that require, in the future, considering the impacts of 200 year floods. This is due to the re= alization of global warming and sea level rise. What will be the impacts of a 200 year flood on the MSN HOV Widening Project? Will the culverts, c= uts, frontage roads and main line, etc be equipped and designed to withstand 200 year floods? Please evaluate = and consider the impacts and mitigations needed to address this new future legislative requirement.

22. Du= ring the Caltrans MSN HOV Widening Project workshop in Petaluma on November 6^th, it= was mentioned Caltrans plans to rebuild a significant section of U.S. 101 around San Antonio Creek to avoid future flooding of the freeway. Please include in the DEIR/S explanation and diagrams of the proposed earth movement and other changes adjacent to the creek and their impacts to the biological resources= and water quality from run off and from the addition of additional soil surroun= ding the creek. How are the impacts to be mitigated?

23. Adequate funds are cu= rrently unavailable to build the entire Segment B project at one time. A phased pro= ject is under consideration. What = would be the best method or steps to take in phasing Segment B? What acquisitions, portions of the project should be accomplished first, second, third, etc, as money becomes available? Plea= se offer suggestions of how to most effectively, environmentally and efficient= ly phase Segment B. What would be the construction related impacts of a phased project in regard to water quality, air quality, congestion, bike/ped acces= s, resident’s access, safety, costs, etc?

Thank you for your consideration of our concerns and comments.

Doug Wilson, Chair

Sierra Club Marin Group