HomeMy WebLinkAboutStaff Report 6.C 9/8/2014(i)
DATE
TO
FROM:
Agenda Item #6.0
September 8, 2014
Honorable Mayor and Members of the City Council through City Manager
Heather Hines, Planning Manager
SUBJECT: Discussion and Direction on Rainier Cross -Town Connector Draft Environmental
Impact Report
RECOMMENDATION
It is recommended that the City Council:
o Receive public testimony on the Draft Environmental Impact Report;
® Provide continents on the Draft Environmental Impact Report; and
o Direct staff to move forward with preparation of the Final Environmental Impact Report
(FEIR).
The Rainier Connector was previously contemplated by the City of Petaluma (City) as part of the
larger interchange project evaluated for U.S. Highway 101 between East Washington Street to
the south and Corona Road to the north. The need for a Highway 101/Rainier Avenue
interchange was identified as early as 1965 by Caltrans and the City. Caltrans completed and
approved a Supplemental Project Authorization Report and a Project Study Report (PSR) for a
Rainier Avenue interchange in 1980 and 1988, respectively.
The interchange location and spacing requirements were reviewed again by Caltrans in 1992.
Because the proposed Rainier Avenue interchange was less than one mile from the existing East
Washington Street interchange, Caltrans required that auxiliary lanes be added in both directions
along Highway 101 between the proposed Rainier Avenue interchange and the existing East
Washington Street interchange. Subsequent to Caltrans' completion of an approved PSR for the
interchange, the City of Petaluma certified an E1R in 1994 for the project. The 1994 EIR studied
a modified diamond interchange with loop ramp alternative. The design and construction phases
for that interchange option, however, were abandoned.
In 2005 and 2006, City staff met with Caltrans to discuss revisiting the interchange project,
following Caltrans' Project Development Procedures, and begin preparation of a PSR for the
Agenda Review:
City Atlornev Finance Director
City Manager g1-
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Highway 101/Rainier Avenue Interchange project. During the review process Caltrans notified
the City that the new interchange would require approval of an exception to Caltrans' current
design standards that require a minimum interchange spacing of one mile along Highway 101
between the existing East Washington Street interchange and the new interchange at the Rainier
Connector.
In November 2004, the City Council decided to pursue the design, environmental studies,
funding, and construction of a Rainier Avenue interchange along Highway 101 and a cross-town
connector that included the extension of Rainier Avenue from North McDowell Boulevard to
Petaluma Boulevard North. The Rainier Avenue interchange is included in Sonoma County
Transportation Authority's (SCTA) 2004 Comprehensive Transportation Plan. The
Transportation 2035 Plan for the San Francisco Bay Area prepared by the Metropolitan
Transportation Commission (MTC) and adopted on April 22, 2009, includes construction of a
Petaluma cross-town connector/interchange under the Strategic Expansion category for Sonoma
County as Project Reference 921884.
In 2009, Caltrans requested that the City suspend the development of a PSR for the Highway
101/Rainier Avenue Interchange Project and proceed with a PSR for the Rainier Avenue Cross -
Town Connector Project, and assuming an undererossing structure at Highway 101 is installed
by the SCTA MSN C2 project, prepare an environmental document for the Rainier Avenue
Cross -Town Connector. (Since that time, Caltrans has determined that a PSR would not be the
appropriate document for the portion of the project within Caltrans right-of-way as its estimated
capital cost is under $1 million.) The City met with Caltrans and SCTA on November 3, 2009 to
discuss further including the undercrossing structure needed at Highway 101 for the Rainier
Avenue Cross -Town Connector Project as part of the SCTA MSN C2 project through Petaluma.
The MSN C2 project proposes to locally raise the profile of Highway 101 crossing the Sonoma
Marin Area Rail Transit (SMART) corridor to correct and make standard the existing non-
standard stopping sight distance for the crest curve on Highway 101 that does not meet Caltrans'
current design standards.
In January 2010, the Petaluma City Council separated the interchange and cross-town connector
into two independent but concurrent elements to allow coordination of the cross-town connector
with the Sonoma County Transportation Authority (SCTA) Marin Sonoma Narrows (MSN) C2
project that includes mainline and ramp improvements along Highway 101 from just south of
Caulfield Lane to just south of Old Redwood Highway.
The Rainier Connector project has been studied by the City and included in various planning
documents over the years including the General Plan 2025. Numerous traffic analyses concluded
that improvements to the Highway 101/East Washington Street interchange alone would not be
sufficient to address traffic congestion at the East Washington Street interchange. Constructing a
new interchange at Rainier Avenue was found to be the preferred alternative to address traffic
congestion at the adjacent interchanges.
The interchange is shown in Figure 5-1, Street Classifications, in the City of Petaluma: General
Plan 2025 (General Plan 2025). The Mobility Element of the General Plan 2025 includes a new
connection (interchange) on Highway 101 at Rainier Avenue, between Corona Road and the East
Washington Street Interchange (described as independent element 1). The General Plan 2025
also includes an extension of Rainier Avenue from North McDowell Boulevard that crosses
Highway 101 and connects to Petaluma Boulevard North (the east -west arterial referred to as the
Rainier Avenue Cross -Town Connector or independent element 2). Previously, these two
independent elements formed one project: the Rainier Avenue Interchange/Cross-Town
Connector and Highway 101 Undercrossing Project. The City of Petaluma Bicycle and
Pedestrian Plan, dated May 2008 (an appendix to the Petaluma General Plan 2025), identifies
proposed Class II bicycle facilities on the future extension of Rainier Avenue from the existing
intersection at North McDowell Boulevard (east of Highway 101) to a new intersection at
Petaluma Boulevard North (west of Highway 101).
The City has sought approval from the State over several years to develop a new interchange
onto Highway 101 at Rainier Avenue. However, the cross-town connector is a standalone project
without the need to construct the interchange, which means that the connector can attain the
project's objectives without any other transportation improvements. After much consideration,
the City decided to separate the two elements to allow the City to pursue the cross-town
connector in relation to the processing of the SCTA Marin Sonoma Narrows (MSN) C2 project
that proposes construction of an undercrossing structure along Highway 101 at the location of the
planned Rainier Avenue Cross -Town Connector.
The MSN C2 project has been designed and the Record of Decision was published on December
4, 2013. Consensus was reached on May 11, 2011 between the City, Caltrans, and SCTA to
include the undercrossing structure component of the Rainier Avenue Cross-Tovu Connector
element into the MSN C2 design. SCTA initiated a revalidation of the approved environmental
document for the SCTA MSN C2 project that included the undercrossing structure where the
extension of Rainier Avenue from North McDowell Boulevard to the west to Petaluma
Boulevard North would cross under Highway 101. As a conclusion of these steps and decisions,
construction of the Rainier Avenue Cross -Town Connector Project would require minor
modifications to the area under the Highway 101 mainline bridge abutment slopes. Specifically,
Abutment 1 and Abutment 3 would require minor embankment modifications and construction
of new slope paving in front of the undercrossing abutments.
The Rainier Avenue project is included as part of the General Plan 2025 to provide east -west
connectivity across Petaluma, traffic relief on the existing street networks, and access to parcels
designated for future development in the General Plan 2025. The project is needed to mitigate
traffic impacts that would occur under full buildout of the General Plan. The Rainier Crosstown
Connector does not create any of the significant overrides identified in the General Plan EIR;
rather the Cross -Town Connector is a project to mitigate impacts from the cumulative condition
at buildout of the General Plan.
Although funding for construction of the project is incomplete at this time, completion of the
EIR allows Caltrans to conduct the necessary undercarriage improvement (raising the
undercarriage at the Hwy 101 undercrossing); thereby permitting the project to move forward at
the time that funding is secured. If funding is not available and construction and operation dates
change from the analysis in this EIR, the environmental analysis will be updated and re -
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evaluated to determine if the EIR would require modification and recirculation in accordance
with CEQA Section 21166.
Project Description
The project would consist of a new 0.65 -mile long 4 -lane arterial roadway connecting North
McDowell Avenue on the eastern side of Highway 101 to Petaluma Boulevard North on the
western side of the City. The Rainier Connector would extend at grade from the signalized North
McDowell Avenue intersection, cross under Highway 101 at an elevated portion of the freeway
that will be constructed as part of the Marin -Sonoma Narrows HOV project, and cross over the
Petaluma River and Northwest Pacific Railroad corridor via a bridge. After crossing the rail
corridor, the Rainier Connector would continue at grade to Petaluma Boulevard North, where it
would terminate at a signalized T -intersection.
The project would acconunodate a dedicated right -turn lane and two future eastbound left -tum
lanes at the existing signalized Rainier Avenue and North McDowell Boulevard intersection. The
project would terminate as a "T" intersection at Petaluma Boulevard North with a westbound
right -turn lane and left -turn lane, and two eastbound receiving lanes separated by a median. The
new roadway would have on -street bicycle lanes and sidewalks with planter strips on both sides.
The median and planter area widths would vary depending on the roadway location. The project
would include landscaping in the median, where feasible, and planter areas. No planter areas are
proposed on the new bridge. The median ranges from 14 feet to 24 feet wide in order to allow for
future connections.
Best management practices (BMPs) for temporary and permanent erosion control and the
treatment of stoma water would be implemented. These BMPs would include temporary and
permanent fiber rolls, concrete washouts, street sweeping, drainage inlet protection, rock slope
protection at new outfalls, biofiltration swales, hydroseeding and/or erosion control blankets and
temporary covers.
Highway 101 Undercrossing
The project would cross under Highway 101 at an undercrossing structure to be constructed as
part of the SCTA MSN C2 project. Additional excavation would be needed under the
undercrossing structure along Highway 101 to construct project roadway and utilities. The
undercrossing roadway would be an adequate width to include a median, bicycle lanes, curbs,
gutters, sidewalks, lighting, and drainage facilities. These facilities would be modified in the
future when a Rainier Avenue/Highway 101 interchange is constructed. Storm water runoff from
the undercrossing portion of the roadway would be collected by an underground drainage system
consisting of pipes and drainage inlets. The roadway would meet applicable Caltrans Highway
Design Manual (HDM) design standards for that portion within State right-of-way (the cross-
town connector must meet vertical clearance requirements where it passes under Highway 101).
Petaluma River/SAMRT Corridor Bridge
The project would include construction of a bridge elevated above the Petathmia River and
Sonoma Marin Area Rail Transit (SMART) tracks. The bridge would include a 14 -foot wide
raised median, two travel lanes in each direction, 6 -foot wide bicycle lanes, 6 -foot sidewalks
with concrete barriers and chain link railings on both sides, and street lighting. The bridge would
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be approximately 88 feet wide, 508 feet in length, would meet the minimum vertical clearance
requirements over the SMART Corridor tracks, and would be designed per the American
Association of State Highway Transportation Officials (AASHTO) Load and Resistance Factor
Design (LFRD) Bridge Design and California Amendments.
In the preliminary design, the bridge would be constructed of 299 60 -foot long cast -in -steel shell
piles, hammer driven to approximately 50 feet in depth. Construction would include one bent
located west of the SMART corridor right-of-way and one bent between the river and the
SMART tracks, bridge abutments, and two retaining walls. The shell piles would be located out
of the river at normal high water levels; however, temporary enclosures (cofferdams) would be
used to divert the river during construction as needed. The cofferdams would be designed so that
water flows passively and would not require pumping. Temporary structures to support the
bridge during construction would be installed in the diverted portion of the Petaluma River. Pile
driving would be required for construction of the temporary structures, and these piles would be
the same size or smaller as those used for the bridge supports. The cofferdams would be removed
for the rainy season, but the temporary support structures may stay in place during the rainy
season. Storm water collected on the bridge would either be collected by the roadway drainage
system or bridge deck drains.
Project Phasing
The project is anticipated to begin construction in 2017. This date is based on the project's
dependence on implementation of the SCTA MSN C2 project, as construction of the
undercrossing structure would be contingent on the raising of the profile of Highway 101 as pari
of the MSN C2 project. The project would be constructed in a single phase and is estimated to
take 30 months to construct with a significant portion of the construction period needed for the
new bridge. Construction is expected to be completed in 2020.
The interchange and Shasta Avenue collector road are not a part of this Rainier Avenue Cross -
Town Connector project, but they are included as projects that are constructed in the future and
considered in the cumulative analysis scenario for the project. Construction of the Rainier
Avenue Extension and Interchange would not preclude construction of the Shasta Avenue
collector or other future projects.
Community Review
A scoping session for the DEIR was held on August 30, 2011 during the Notice of Preparation
(NOP) review period. Invitations were sent to all property owners and residents within 500 feet
of the project boundary, local and regional public agencies, organizations, and individuals that
requested notification. The scoping session was attended by 28 people. A total of 15 comment
letters regarding the NOP were received in addition to verbal comments provided at the scoping
session. The Notice of Preparation is in Appendix A of the DEIR and was circulated between
August 11, 2011 and September 26, 2011. All comment letters received on the NOP are
included in Appendix A to the DEIR.
The public has an opportunity to provide written comments at any time during the DEIR review
period through September 8, 2014. A Notice of Completion/Availability of the DEIR and Public
Hearing, was published in the Argas Cornier and notices were sent to residents and property
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owners within 500 feet of the subject property, as well as interested parties who requested
notification, and all individuals who commented on the NOP. Copies of the DEIR and
associated Appendices have been made available at the Petaluma Library, the Community
Center, City Hall, and on the City's website.
The public also had an opportunity to provide oral comment during the August 12, 2014 public
hearing on the DEIR before the Planning Commission. One member of the public provided
public comment at the Plamiing Commission hearing regarding overall concern for the project
and advising that a close review is warranted. The Planning Commissioners also provided verbal
comments on the adequacy of the DEIR. Commissioners comments are summarized below.
The public also has an opportunity to provide oral comments before the City Council during the
September 8, 2014 hearing on the DEIR. Additionally, written connnents on the DEIR may be
submitted at any time during the public review period through September 8, 2014.
Planning Commission Review —August 12, 2014
The Planning Commission held a public hearing to provide comments and receive public
testimony on the DEIR at its meeting on August 12, 2014. Comments from the Commissioners
included the following:
1. GHG Methodology. Clarify methodology for GHG analysis. Describe how operational
GHG would be reduced because of reduction in VMT created by the project.
Construction emissions should not be amortized over the life of the project.
2. Petaluma Transit Operations Facility. Concerns about conflict with transit vehicles
blocking the left turn lane on Rainier Ave near North McDowell.
I Construction truck trips/project phasing. Expand detail on construction related traffic,
lane closures and delays.
4. CEQA Baseline. Concern that a future baseline is being used to assess impacts. The
impact analysis uses existing baseline to forecast future year conditions. The No Project
scenario is shown for informational purposes.
5. Hydrology. Concern that new improvements within the floodplain will result in flooding.
6. Project Benefit. LOS analysis does not appear to improve congestion relative to existing
condition.
7. Impacts from Mitigation. Concern that indirect impact from mitigation measures has not
been fully analyzed.
8. Mitigation to offset fill to waters of the State should occur onsite.
DISCUSSION
Environmental Review
The California Environmental Quality Act (CEQA) is a system of checks and balances that
informs land use development and management decisions in California. All development permit
applications subject to public agency discretionary action require environmental review under
CEQA. An environmental impact report (EIR) is a detailed report prepared pursuant to CEQA
that analyzes the significant environmental effects of a proposed project, identifies alternatives,
and discusses ways to reduce or avoid possible significant environmental impacts.
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Pursuant to the City's Environmental Review Guidelines, all projects requiring an FIR shall be
referred to the City Council for certification of the adequacy of the EIR and a final
determination. The Planning Commission shall first consider the draft EIR and any comments
received and may make recommendations to the City Council on the adequacy of the EIR and
the appropriate findings. The Planning Commission may request additional information or
clarification prior to or concurrent with their recommendations. Prior to a decision on the project,
the City Council shall certify the adequacy of Final EIR by resolution.
The CEQA Guidelines state that public hearings may be held on the environmental documents,
either in separate proceedings or in conjunction ivith other proceedings of the public agency. The
practice of the City of Petaluma has been to schedule public hearings Alth both the Planning
Commission and City Council during the public review period for a DEIR. The Rainier DEIR
was released on July 24th, 2014 for a 45 -day public review period that will close on September
8, 2014. The item was heard before the Planning Commission on the August 12, 2014 meeting
and will come before the Council on September 8, 2014.
Purpose
An EIR is a disclosure document. The purpose of CEQA is to ensure that the public and decision
makers are aware of the environmental consequences of an intended action. The jurisdiction is
required to mitigate significant impacts where feasible, but may still approve a project with
significant impacts if it finds specific overriding considerations supported by substantial
evidence in the record.
Once a DEIR is prepared, it must be routed through the State Clearinghouse to all responsible
and/or trustee agencies. The agencies have 45 calendar days in which to continent on the DEIR.
At the same time the DEIR is sent to the State Clearinghouse, the public must be notified that the
DEIR is available for review.
A notice of completion and availability for the Rainier Cross -To -,;n Connector DEIR was
published in the Argus Courier on July 24"', 2014 and sent to residents and property oNiners
within 500 feet of the project property, as well as interested parties, individuals who commented
in response to the NOP, the State Clearinghouse and the Sonoma County Clerk.
The purpose of the September 8, 2014 hearing is to receive input from the Council and the public
on the adequacy and completeness of the analysis presented in the DEIR. Once the City Council
public hearing on the Draft EIR has been formally closed, all written and oral comments received
on the DEIR will be compiled, and responses to those continents will be presented in the FEIR.
Per the City's Environmental Review Guidelines, the Planning Commission may request to
review the FEIR before making a recommendation to the City Council, but Planning
Commission review of the FEIR is not required by state law.
Review Process
Pursuant to the recommendation made by the Plamiing Commission on the adequacy of the
DEIR, the City Council will consider the adequacy of the DEIR in disclosing the potential
impacts of the project and identifying mitigation measures. and any changes, clarifications, or
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additional information needed in the FEIR. At the direction of Council, staff will initiate
preparation of the FEIR, which will incorporate the necessary revisions and responses to all
significant environmental points raised during the public review period.
The FEIR and project approvals will come before the Planning Commission and City Council
following close of the DEIR review period.
Format of the Draft EIR
The analysis of the DEIR is broken into the following primary sections: Introduction (Section 1);
Summary (Section 2); Project Description (Section 3); Setting, Impacts, and Mitigation
Measures (Section 4); Alternatives (Section 5); CEQA Required Conclusions (Section 6), and
Report Preparation (Section 7).
The analysis includes an overview of the existing conditions compared with incorporation of the
project and applies thresholds of significance based on CEQA guidelines and other regulatory
criteria to assess whether or not the project will have an impact and, if so, the significance of that
impact. The DEIR discusses levels of significance and feasible mitigation measures to ensure
that the impact is reduced to a less -than -significant level.
Impacts and Mitigation Measures
The DEIR identifies several areas where the proposed project would have a potential
environmental impact. All of the impacts identified as potentially significant can be reduced to a
less -than -significant level with the incorporation of mitigation measures. These mitigation
measures have been identified in the DEIR and would be incorporated into the project approval
and carried out through a Mitigation Monitoring and Reporting Program (MMRP).
Environmental impacts considered to be "less than significant with mitigation measures" were
identified in sit categories in the DEIR. The mitigation measures identified for the project are
summarized below, following the impacts discussion for each environmental category, and will
reduce all project impacts to a "less than significant level."
Categories of Potential Impact
Potential environmental impacts of the project were identified in the DEIR, as summarized
below. Please see the text of the DEIR for full discussion of project impacts and mitigation
measures.
Air Oualih' and Gree77house Gases
The project would result in less than significant emissions from construction activities including
grubbing, grading, site preparation, delivery of materials and vehicle/equipment use. Fugitive
dust generated by construction vehicles and equipment traveling over exposed surfaces would be
reduced to less than significant levels through Best Management Practices such as watering
exposed surfaces, covering haul trucks, use of street sweepers, and other standards as set forth in
Table 8-1 of the BAAQMD CEQA Guidance document.
In order to reduce exposure to pollutants generated during construction, mitigation measure AQ -
8 requires that all diesel fueled off-road construction equipment achieve an 8 percent reduction in
diesel particulate matter compared to Tier 2 engines. Implementation of exhaust reducing
measures such as the use of late model engines, low -emission diesel products, alternative fuels,
engine retrofit technology, after -treatment products, and add on devices, would effectively
reduce the exposure concentration to nearby sensitive receptors to levels below significance.
Biological Resources
The project's biological resources report considered potential impacts to approximately 31 acres
consisting of 0.10 acres of the Petaluma River, 24 acres of upland habitat, and 5 acres of
developed areas that includes North McDowell Boulevard, Petaluma Boulevard North, US 101,
and SMART corridor. Within the project area boundary two vegetation communities (California
Annual Grassland and Coast Live Oak Riparian Woodland) were identified. Six special status
species have the potential to occur within the project site, three of which are federally listed as
threatened (California Red -Legged Frog, Central California Coast Steelhead DPS and Southern
Green Sturgeon DPS) and the other three being California species of special concern (Western
Pond Turtle, Sacramento Splittail and White -Tailed Kite).
A majority of the project boundary (Grassland vegetation) is dominated by non-native grasses
and forbs, including land that is highly disturbed by active grazing and agricultural use. The
Riparian Woodland vegetation is generally within the floodplain adjacent to the river and is
characterized by oaks and eucalyptus. The understory is highly disturbed by grazing and human
activity (encampments) and supports poison oak and blackberry shrubs.
Waters of the United States
The Petaluma River is a jurisdictional water of the U.S. that is defined by the ordinary high water
mark. No jurisdictional wetlands were identified within the project boundary. However, aquatic
resources are contained within the bed and bank of the Petaluma River. Less than OS acres of
Water of the US are anticipated to be impacted due to rock slope protection for the abutment east
of the bridge. This would result in impacts to waters covered by section 404 of the Clean Water
Act. Mitigation measure BI0-3, requiring purchase of mitigation bank credits will reduce
impacts to levels below significance.
To mitigate for the impacts to waters of the US, credits shall be purchased from an approved
mitigation bank at a ratio of one acre for every one acre impacted, or as otherwise directed by the
regulatory agencies. Due to general low -quality of the existing habitat (e.g. presence of non-
native species, disturbed soils, etc.) within the project site, a mitigation ratio of one acre
mitigated for each acre impacted is recommended by the biologist.
Waters of the State
The project is also subject to the requirements of section 401 of the Clean Water Act and the
Porter -Cologne Water Quality Control Act, which are regulated by the Regional Water Quality
Control Board (RWQCB). Section 401 requires that discharges of dredge and fill material into
waters of the US do not violate effluent limitations or water quality standards.
Riparian Habitat
Within the project site, the bank of the Petaluma River contains riparian habitat. Construction
activities associated with the proposed bridge have the potential to impact 4.21 acres of riparian
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habitat due to installation of the bridge pier, bent and abutment. Construction of the bridge could
result in temporary and permanent impacts to riparian habitat including the Petaluma River.
Accordingly Mitigation Measures BIO -1 through BIO -3, as well as BIO 7 and BIO -8 are
required in order to reduce impacts to less than significant levels.
BIO -1 requires that construction activities avoid and minimize disturbance by limiting work
adjacent to the River to the dry season, dedicating staging areas, protecting topsoil, replanting
disturbed vegetation and monitoring for establishment success, and removing construction
material once activities are complete.
BIO -2 further requires that the discharge of sediment and pollutants into the River during
construction is minimized by installing and maintaining silt fencing and erosion control blankets,
diverting runoff around equipment vehicles and material storage areas, minimizing the amount of
construction materials stored onsite and storing, handling, and containing materials in a mariner
that prevents discharge. BIO -2 also requires trash abatement, equipment maintenance, personnel
training on spill prevention, and other related measures that are intended to preclude or minimize
sediment or pollutants from entering the River.
13I0-3 requires that mitigation bank credits be purchased at a ratio of 1:1 for all impacts to
riparian habitat. Copies of applicable permits and proof of banking credit shall be obtained by the
City prior to grading.
Snecial Status Snecies
The Project Site Boundary contains habitat that may support special status species including the
Californian Red Legged Frog, Western Pond Turtle, and sensitive fish species. The DER
identified potential impacts to these species and sets forth mitigation measures to reduce impacts
to less than significant levels. The following discussion provides a summary of each of the
special status species with potential to occur within the project site boundary:
Californian Red Leeued Froa (CRLF)
The tidally influenced portion of the Petaluma River present within the project site boundary
would not be considered suitable habitat for this species due to the inability of CRLF to tolerate
elevated salinity levels. The nearest observance of CRLF is located approximately 2 miles
southwest of the project site. CRI -Fs are not expected to occur onsite given that the dispersal area
is not hydrologically connected, dispersal area is marginal, and the site lacks suitable habitat.
Nonetheless, use of the site by CRLF cannot be ruled out and there is a possibility that CRLF
could move through the site during construction. Accordingly, implementation of mitigation
measures BIO -1 through BIO -3 as described above as well as BIO -4 further described below will
ensure that potential impacts to this species are reduced to less than significant levels.
Western Pond Turtle (WPT)
There are no documented occurrences of the WPT within the project site boundary. The nearest
observance of WPT is over 1 mile from the project site. The biological resources assessment
determined that there is marginal habitat onsite to support this species given the absence of deep
escape pools, limited basking habitat, and lack of nesting habitat. Although WPT are not
expected to occur onsite, there is a potential that individuals could disperse through the site.
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Accordingly mitigation (BIO -1 through BI0-3) is required to reduce potential impacts to less
than significant levels.
Additionally, mitigation measure BIO -4 requires avoidance and minimization measures to
protect CRLF and WPT including limiting construction activities to the dry season (as
practicable), conducting preconstruction surveys, construction worker training, installation of
fencing to preclude intrusion into protected areas during construction, and trash abatement
techniques.
Sensitive Fish Snecies (Central California Coast Steelhead. Southern Green Sturgeon, and
Sacramento Snlittail)
A portion of the project site is located within the designated critical habitat area of the Central
California Coast Steelhead and is upstream of the designated Southern Green Sturgeon critical
habitat and the identified range of the Sacramento Splittail. A potential impact to these protected
fish species is identified in the DEIR due to construction activities within the River including
construction of the falsework, rock slope protection, and associated dewatering. Additionally,
these species could be impacted by any increase in sediment or pollutants as well as noise related
to pile driving for Bent 3, Abutment 4 and bridge falsework. Accordingly, mitigation measures
BIO -1 and BIO -2 that address sediment and pollutant runoff into the River will be implemented.
Additionally, mitigation measure BIO -5 requires that construction, pile driving and other
activities within the Petaluma River be limited to the dry season to avoid interfering with
spawning migration or the outmigration of smolts. BIO -5 further requires that a fish rescue effort
be undertaken by a qualified biologist during construction of the cofferdams and dewatering
phase of development. In addition, construction worker personnel shall undergo training by a
qualified biologist to identify protected salmonids and their habitat, general provision and
protection afforded by the Endangered Species Act, and other information intended to familiarize
workers with these aquatic species. Implementation of these measures will reduce potential
impacts to special status fish species to levels below significance.
Nesting Birds
Nesting bird species and migratory birds may be present onsite and have the potential to be
impacted during construction activities. hi order to ensure that the project is consistent with the
requirement of the Migratory Bird Treaty Act (MBTA) and the Fish and Game code, mitigation
measure BIO -6 would be implemented. BIO -6 requires that pre -construction surveys for nesting
birds be conducted for all trees within 150 feet for nesting raptors and within 500 feet for nesting
passerines. Surveys shall be conducted no more than 15 days prior to the start of ground
disturbing activities. BIO -6 also specifies buffer areas in the event that nesting birds are
identified. This measure would reduce potential impacts to nesting birds to less than significant
levels.
Protected Trees
Several trees within the project footprint area site boundary and along Petaluma River would
need to be removed to construct the project including, but not limited to, species such as box
elder, willow. Oregon ash, coast live oak, and valley oak trees. Approximately 64 protected trees
will require removal as part of the new bridge over the River and the new intersection at Rainier
Avenue and Petaluma Boulevard North. Replacement trees would be planted in the project
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vicinity in accordance with the City's Approved Street Tree list in a ratio consistent with the
City's tree replacement requirement as described in City Code Section 17.060(B) and pursuant to
mitigation measure BIO -7 and 13I0-8.
13I0-7 requires that a qualified arborist determine which trees need to be removed and for those
that are protected establish replacement ratios based on tree health.
BIO -8 requires that a tree replanting plan be prepared and implemented that identifies where,
how many, and what type of trees shall be planted. The replanting areas shall be monitored
yearly with an annual report sent to the CDFW and the USACE. At the end of the 5 -year period
replanting shall be considered successful if a least 75 percent of the tree planting survive.
Implementation of 13I0-7 and BIO -8 will reduce potential impacts associated with the removal
of protected trees to levels below significance.
Cultural Resources
Records search and review, as well as pedestrian surveys and subsurface testing was conducted
for the project site by URS May- July 2011. The results of the study indicate that the project site
contains an archaeological resource (SON -2254/H) that has an identified historical value in that
it may yield additional information about California prehistory. The project has the potential to
substantially change the significance of this resource by compromising the integrity of the site.
Accordingly, mitigation measure CULT -1 requires that the City implement an archeological data
recovery program (ADRP) prior to initiating project construction.
Given the identified cultural resources onsite, construction activities have the potential to result
in the impacts to expected prehistoric deposits. In order to avoid potential impacts to prehistoric
deposits, mitigation measure CULT -2 requires that a qualified archeologist be present during all
ground disturbing activities occurring within 200 feet of the top of bank of the Petaluma River.
Some areas of the City, especially in the vicinity of the Petaluma River, have a high potential for
the discovery of unknown archaeological or paleontological materials. Given the identified
cultural resources onsite, construction activities have the potential to result in the accidental
discovery of previously unidentified cultural resources including human remains. Mitigation
measure CULT -3 provides that in the event of accidental discovery of cultural resources such as
concentrations of bone, shell or historic artifacts, construction activities would be suspended
until a qualified archeologist can assess the significance of the find. Mitigation measure CULT -4
provides protection in the event that paleontological materials are discovered. Additionally,
procedures established by the California Public Resources Code and the California Health and
Safety Code shall be implemented in the event that human remains are discovered.
CULT -1 through CULT4 provides measures to ensure that any potential impacts to cultural
resources resulting from implementation of the subject project are reduced to a less than
significant level.
Geology and Soils
The potential geologic hazards identified at the project site include risk of loss, injury or death
involving strong seismic ground shaking and ground failure including liquefaction. The project
12
site is located within a seismically active region and is potentially susceptible to strong to violent
ground shaking that could result in serious infrastructure or road damage. Additionally, an
impact was identified as the project site would be located on a geological unit or soil that is
unstable or could become unstable as a result of the project and potentially result in on or offsite
lateral spreading, subsidence, collapse, expansion or otherwise affect stability.
Mitigation measure GEO-1 requires that a Geotechnical Investigation be performed prior to
completing the roadway deign. The Report shall be prepared in accordance with Section
17.31.180 of the City's Grading and Erosion Control Ordinance and shall provide
recommendations such as requirements for fill material, compaction design, over excavation, and
grading techniques. The roadway design and construction shall adhere to the California Building
Code specifications for Seismic Zone 4. Implementation of the recommendations set forth in the
Geotechnical Investigation will ensure that potential geotechnical constraints associated with
ground shaking and stability are minimized through the incorporation of design and ground
treatment techniques that provide enhanced stability and limit risk of loss. Thus, potential
impacts would be reduced to less than significant levels through measure GEO-1.
Hydrology and Aster Quality
The project site is currently undeveloped and construction of the roadway would introduce
structures and impervious surfaces within the floodway and within the 100 -year floodplain,
which has the potential to impede or redirect flows. The project has the potential to substantially
alter the existing drainage pattern that could result in erosion or siltation on or offsite. The
changes to the hydrological flow pattern and water quality degradation are identified as
potentially significant impacts. Preliminary analysis indicates that the project has the potential to
raise the base flood elevation by 0.03 feet in the floodplain and floodway immediately upstream
of the bridge and would result in no change downstream.
In order to mitigate potential impacts and in accordance with the City's no net fill policy, a
design level hydrological analysis utilizing specific bridge abutment design shall be conducted to
determine the bridge's potential to increase the base flood water surface elevation within the
regulatory floodway (Mitigation Measures HYD -1). The hydraulic analysis would include
measures such as benching or widening the channel near the bridge to maintain flood flow
conveyance. In the event that a base flood elevation would increase, the City is required to obtain
a CLOMR from FEMA and request a NFIP map revision. HYD -I would ensure that potential
impacts due to impediment of surface flows, alteration of drainage patterns and introduction of
sediment are reduced to less than significant levels.
Additionally, the project is subject to the requirements of the City's Grading Ordinance, NPDES
Phase II Permit, Stormwater Management and Pollution Control Ordinance, and the County's
SUSMP. These plans require implementation of Best Management Practices including temporary
and permanent fiber rolls, concrete washout areas, street sweeping, drainage inlet protection,
rock and slope protection at new outfalls, biofiltration swales, hydroseeding and/or erosion
control blankets, temporary covers and cofferdams. With implementation of HYD -1 as well as
adherence to required plans including BMP, the project's impacts due to hydrology and water
quality would be reduced to less than significant levels.
13
Traffic and Circzdatio77/Ti•aiasportatim7
The proposed project would implement the General Plan circulation by providing the Rainier
Avenue Cross -Town Connector, which would provide enhanced east/west connectivity by
introducing a new travel route over the Railway, Petaluma River, and under Hwy 101. Traffic
conditions were measured at study area intersections under the existing condition, no project and
plus project scenarios for opening year (2020).
A potentially significant impact was identified due to the project's potential to introduce an
incompatible design feature or use that would increase hazards. Currently, the west leg of the
existing Rainier Ave/N. McDowell Blvd. intersection is stubbed out and provides access to the
Petaluma Transit Operations facility located at the northwest comer of said intersection. The
project would replace the stub out providing public through access, which could interfere with
access to the Transit Operations facility. In order to ensure that access to the facility is
maintained, the City shall provide a driveway into the site from Rainier Avenue pursuant to
mitigation measure TRANS -1, which specifies that the driveway be located as far west as
possible and that a break be provided in the Rainier Avenue median at the driveway location to
provide for left -turn in from eastbound Rainier. Signage shall be provided to the effect of No
Left Turn Except for Buses," to ensure that public access in not granted. This measure will
ensure that potential hazards are reduced to levels below significance.
A potentially significant impact was identified due to the temporary increase in construction -
related traffic, which could introduce 8,000 truck trips over the course of the 30 -month
construction period. Construction activities will add traffic trips to the existing street network
due to construction equipment, delivery and off -haul of material, as well as construction worker
commutes. Temporary partial lane closures along project area roadways may occur during
construction activities. Other impacts associated with construction traffic include blocking
bicycle or pedestrian facilities and introducing incompatibility due to the shared roadway of
vehicles and heavy-duty construction equipment. Construction truck traffic would be limited to
the designated truck routes in Petaluma including McDowell Boulevard, East Washington Street,
Lakeville Street, and Petaluma Boulevard North, north of Lakeville Street.
Mitigation measures TRANS -2 requires that the City prepare a construction management plan
that identifies truck routes and staging, develops traffic control measures such as scheduling of
major deliveries, use of detour signs (as necessary), lane and sidewalk closure procedures (if
required), evaluates the need for flaggers or strategic traffic control at key intersections, and
establishes notification procedures. Implementation of TRANS -2 would reduce the project's
temporary traffic construction impacts to levels below significance.
A potentially significant impact was identified due to the project's potential to interfere with the
congestion management program including intersection level of service standards (LOS). The
new project intersection at Petaluma Boulevard North/Rainier Avenue includes the following
lane geometries:
• Northbound Approach —Two through lanes and one right -turn lane
• Southbound Approach - Two through lanes and one left -turn lane
• Westbound Approach - One left -tum lane and one right turn lane
This intersection was forecasted to operate at unacceptable LOS P during the PM peak hour
14
under Opening Year conditions. Accordingly, this would be a significant impact since the level
of service standard for this intersection is D.
Implementation of Mitigation Measure TRANS -3 that requires an additional westbound left turn
lane and northbound right overlap phase at the intersection of Petaluma Boulevard North/Rainier
Avenue would improve the level of service during the PM peals hour to LOS D. However, this
improvement would increase the pedestrian crossing distance. As such a median refuge shall be
provided with a minimum width of 5 feet.
Implementation of measure TRANS -1 through TRANS -3 will ensure that potential impacts
associated with construction and operation of the proposed Rainier Connector are reduced to
levels below significance.
Cunnilatire Traffic Impacts
Under the cumulative condition, which assumes full buildout of the General Plan, the
intersection of Rainier Avenue and Petaluma Boulevard North would operate at unacceptable
levels of service. Accordingly, mitigation measures CUMULATIVE TRANS -1 would be
implemented, which requires improvements in the event that the Shasta Avenue extension is not
constructed. Should Shasta be constructed then the project could have cumulative impacts at the
intersection of Petaluma Blvd. North/Sycamore Lane, depending on the configuration. Restriping
the existing westbound approach at this intersection to provide an exclusive left turn lane and
shared left/through/right-turn lane plus an exclusive northbound right -turn lane would correct the
deficient LOS. However, this configuration would increase pedestrian cross walk distance and a
5 -foot median refuge would be required at the south leg of Petaluma Blvd.
Impacts that are Significant and Unavoidable
The DEIR did not identify any potentially significant impacts on the environment that cannot be
mitigated. As such there are no significant and unavoidable impacts associated with the proposed
Rainier Avenue Cross -Town Connector Project.
Findings and Overriding Considerations
CEQA Guidelines Section 15091 requires public agencies to make one or more written findings
for each of the significant environmental effects identified in an EIR in conjunction with project
approval. CEQA Guidelines Section 15093 requires a statement of overriding considerations for
significant and unavoidable impacts; none have been identified so there is no statement of
overriding consideration necessary for the Project.
Growth Inducing Impacts
The project would remove an impediment to growth by providing roadway infrastructure access
to currently undeveloped parcels. These parcels have been previously designated in the General
Plan for development. The proposed General Plan accommodates future projected growth and
development in the City of Petaluma and includes the subject Rainier Connector. While the
proposed project will accommodate future growth by providing a new travel corridor, it does not,
in and of itself, serve to induce future growth within the City of Petaluma beyond what has been
projected in the General Plan.
15
Analysis of Alternatives
The DEIR evaluates the following three alternatives:
A. The No Project/No Build Alternative: The project site would remain in its current
undeveloped state.
B. The 4 -Lane Roadway, No Future Connections: This alternative would preclude future
connections at the Sid Common driveway, Shasta Avenue, and the Petaluma Outlet Mall
Expansion by having a slightly longer bridge and elevated profile.
C. The 2 -Lane Roadway, Future Connections: This alternative would allow for future
connections at the Sid Common driveway, Shasta Avenue, and the Petaluma Outlet Mall
Expansion. As a 2 -lane roadway, the project footprint would be reduced.
The alternatives analysis is intended to substantially reduce or avoid significant environmental
impacts. The proposed project did not identify any impacts that would remain significant after
implementation of mitigation. As such, the alternatives do not eliminate a significant
environment impact. Rather, alternatives have been developed in compliance with CEQA to
further reduce or avoid a mitigable impact. The Alternatives discussion begins on page 5-1 of the
DEIR.
Under the "No Project" alternative, which is required by CEQA, the proposed project would not
be constructed and the site would remain in its existing undeveloped condition. While this
alternative would eliminate many of the significant impacts associated with the proposed project
including biology, cultural resource, and hydrology impacts, it would result in greater impacts on
air quality, hazards, land use, population and housing, public services and traffic.
Alternatives B and C would create impacts comparable to the project in the opening year.
However, Alternative C would require an additional mitigation measure under cumulative year
conditions for traffic LOS. Although Alternative B would not provide access to parcels
designated for development in the General Plan, which have been designated to accommodate
housing and development as outlined in the City's General Plan, it would have fewer impacts
under cumulative conditions. Therefore, Alternatives B and C are not the environmentally
superior alternatives.
The alternatives would have similar, fewer, and greater impacts as compared to the project.
Therefore, there are environmental advantages and disadvantages of each alternative in
comparison with the project. Because each alternative would reduce some impacts and increase
others, there is no clearly environmentally superior alternative to the project.
FINANCIAL IMPACTS
The Rainier Cross -Town Connector is included on the list of Capital Improvement Projects,
which are funded by traffic impact fees. Traffic impact fees are collected for all new
development and funds are allocated to traffic infrastructure improvements based on Council
16
priority. It is recognized that there is currently a finding shortfall for the Rainier Cross-ToNvn
Connector.
A preliminary cost estimate for the Rainier Cross -Town Connector is provided below.
(CAPITAL OUTLAY COSTS
Cross Town Connection)
(Roadway Items
$13,566,6301
(Structure Items
$12,846,0001
(Rainier UC
$7,000,0001
SUBTOTAL CONSTRUCTION
COSTS
$33,412,630
1Total Right of Way Items
$18,755,0001
TOTAL PROJECT CAPITAL OUTLAY
COSTS
$52,167,630
ISUPPORT COSTS
1
IPA/ED Phase
$1,670,631.501
IFinal Design (PS&E)
$3,341,3631
IRight of way Engineering & Acquisition
$668,2531
(Construction Administration
$3.341,2631
TOTAL SUPPORT COSTS
$9,021,4101
TOTAL PROJECT COSTS
$61,189,0401
Estimated Developer Dedicated R/W
$13,689,2181
1Estimated Developer Roadway Items
$8,753,5681
1Successor Agency Funding
$8,476,7121
I TOTAL IMPACT FEE
$29,858,8441
(Source: Department of Public Works
I
ATTACHMENTS
DE1R and Appendices (hand delivered on .lune 24"i. 2-0 14)
Public Continents on DEIR
17
Jennifer Pierre Comments on Rainier Draft EIR, August 2014
Proiect Description
Section 3.3.3 assumes 30 months of construction, but the bio analysis assumes periods in which
construction could not occur to avoid in -water and nesting bird impacts. The construction schedule
needs to be better defined to assess the effects of the construction activities, including concentration of
truck traffic (and associated AQ and Noise effects) during periods of construction.
The project assumes that the Shasta Avenue extension would be in place, which is not the baseline and
should not be considered as such.
Section 3.4 should be updated.
Proiect Obiectives
The first objective listed is 'Relieve traffic congestion within the local street network,' but the analysis
does not show that the project actually does this. In fact, there are significant project effects
cumulatively and as currently analyzed, assumes mitigating projects in the baseline such that it is
currently unknown what the effects of the project are on traffic.
Required Permits and Approvals
Please add USFWS to Table 3.3.
Impact Analvsis
Aesthetics assessment: Thank you for providing visual simulations!
Air Quality: This assessment does not take into account the 8,000 truck trips that are expected to occur
during construction. Impact AQ/GHG-6 assumes that the construction effects would occur equally over
30 months, which cannot be true given timing restrictions due to biological impacts. Also. you cannot
amortize construction -related AQ impacts over a 30-vear operational period! These effects should be
amortized over 30 months or whatever the construction period ends up being. Why are we assuming a
drastic drop in GHG between now and 2020 (without project)? (From 53,363 to 46,291)
Impact BIO -2: This discussion needs to acknowledge that there would be restrictions to in -water work to
avoid fish effects.
Mitigation Measure BIO -3: Mitigation should be onsite and the ratio listed in the measure should be
'2:1' not '1:2' as listed on page 2-8.
Impact 610-4: it is not clear what the total permanent and temporary effects would be. These should be
described.
Mitigation Measure 13I0-1: The Corps standard is 5 years for site monitoring of new plantings.
Impact HYD -9: This impact discussion essentially postpones essential information in determining the
design of the project to avoid base flood elevation changes. The mitigation measure HYD -1 includes
potential additional environmental impacts related to changes in the Petaluma River channel or other
potentially sensitive habitats. CEQA requires that the mitigation measures themselves are mitigated if
there is a potential for a significant impact. The EIR does not currently disclose those potential impacts
and any associated required mitigation, which is required.
Traffic impacts use the incorrect CEQA baseline. The effects of the project should not be compared to
future conditions (Opening Year). They must be compared to today's condition. Even though the
methods section says that there are 'dual baselines; the existing condition is not what is actually used
for the significance findings. The Opening Year assumes several other projects that may or may not be
constructed or operated as currently planned. The project analysis should demonstrate what the effects
of the project would be if it were added to existing conditions. Additionally, the 'LOS' method is
currently proposed to be eliminated as the standard assessment method for traffic impacts. Given the
importance of this as a traffic relief project, the traffic analysis should be more detailed, written for lay
persons to understand, and should be explicit about when the analysis shows degradation of
intersections or other traffic patterns. The tradeoffs should be articulated.
Traffic impacts (and associated AQ and noise) assume that 8,000 truck trips would occur equally over
the construction period, which is untrue since there are restrictions on construction timing. This analysis
should be consistent with the in -water and other timing restrictions laid out in the biological resources
section.
Table 4.2-10: Intersections of Stony Point/Old Redwood Highway (AM); Petaluma Blvd/Corona (PM);
substantial increases in McDowell/Rainier; Petaluma Blvd/Shasta (PM); Petaluma Blvd/Magnolia;
Petaluma Blvd/Rainier (PM); Washington/McDowell (AM); East Washington/101 NB Ramps (PM); East
Washington/101 SB Ramps (AM); East Washington/Ellis (PM) all have increased delav times.
East Washington/101 NB Ramps goes from LOS B to LOS C in PM hours and East Washington/Ellis goes
from LOS A to LOS C in PM hours. This needs to be discussed in greater detail.
Impact TRANS -7: The effects on access to the existing Operations Facility are proposed to be mitigated
by including a driveway from EB Rainier to the facility, essentially creating and extra left turn lane on
Rainier. Have the traffic effects of this been evaluated? Essentially, turning buses have the potential to
hold up the entire left turn pocket. Was this mitigation included in the modeling? What is the timing of
bus ingress and egress?
Impact TRANS -9: Intersection of Rainier and Petaluma Blvd N would operate at LOS D in peak PM. This
impact assessment should compare only the project to the existing condition. The current analysis is
convoluted by the inclusion of the Opening Year baseline. The question is: Does the project improve or
not existing conditions? How is Mitigation Measure TRANS -3 mitigating the effect of conflicts with a
congestion management plan?
Impact CUMULATIVE TRANS -1: Essentially every major intersection in Petaluma would operate at an
unacceptable level. CEQA compels us to look for an alternative to this.
Section 5.5.2.8: How does Alternative B perform relative to traffic? What residential land uses are
prohibited if this network of streets are not constructed? This is the 100 -year floodplain.
Why wasn't an alternative including the expansion of Corona Road evaluated? It would be a much
cheaper alternative and would likely provide better relief on its connecting intersections, would not
(ct
interfere with the bus Operations Yard, would not induce floodplain development, and would likely have
fewer impacts to riparian habitats. CEQA requires that reasonable alternatives be evaluated that have
the potential to meet MOST of the project objectives. Corona Road meets all objectives except that last
one: 'Not preclude future connections from adjacent parcels along the roadway.' This is not an
acceptable CEQA objective for what is described as and meant to be an East-West Connector.
Where are growth -inducing effects evaluated? If this project allows growth, which is acknowledges it
does, then the impacts of that growth must also be evaluated. What are the effects of loos of homes in
the floodplain?
wig
MEMORANDUM
To: Heather Hines
cc: John Brown
From: Mike Healy
Date: August 24, 2014
Re.: Comments & Ouestions on Rainier Cross -Town Connector DEIR
Below please find my comments and questions on the Draft EIR. Overall I
thought the document was quite comprehensive and well done, so please do not take the
following as implying otherwise.
p. 2-1 Regarding the 118 foot width of the 101 undercrossing, what lane / sidewalk
configuration can that accommodate? Does it include turn lanes for a future interchange.
as at Steele Lane?
p.2-9 In the discussion of Impact BIO -3. the "two -to -one" trunk diameter basis would
more accurately be called a "one -to -two" ratio, based on the example. This sante issue
recurs on p. 2-22 and p. 4.3-28.
p. 4.2-1 The two references to Petaluma being located in the "Sonoma Valley' are
incorrect.
p. 43-19 & elsewhere. Defining the "dry season' as June 15 — October 15 seems
arbitrarily short, when Petaluma's historic average rainfall in June is 0. 17 inches. June l
would seem to be a more appropriate start date.
p. 43-22 Dewatering and falsework seem to be a result of a particular design choice.
Such features are not part of the new 101 / Petaluma River bridge, for instance.
p. 4.4-7 The old railroad trestle was recently replaced.
p. 4.4-15 The DEIR does not identify the location of SON -2254/11, so the decision
makers cannot evaluate if there is an alternate alignment that avoids disturbing it.
p. 4.5-1 The highest elevation within the city limits is far lower than 2,295 feet.
p.4.12-38 The data for Intersection 11 (East Washington at McDowell) shows a delay of
">80" seconds with no project in 2020 in both the a.m. and p.m. peak, with a letter grade
of "F." Please provide the actual computer run calculations, rather than just ">80."
There is a big difference between 81 and 150, for instance. These are perhaps the two
most important pieces of data in the entire document.
There are statements on p. 4.8-16 ("the project would create roadway access to vacant
parcels designated for residential and commercial development in the City's General Plan
that do not currently have access.") & p. 4.10-3 ("The project was included ... to ... provide
access to parcels designated for future development in General Plan 2025.") which seem
to be partially undercut by a statement on p. 4.10-5 ("the project would potentially
provide access to vacant parcels.") Then at p. 4.13-23 a scenario is described "including
connections at the Shasta Avenue extension and Sid Commons driveway." Also at p. 5-9
( "unlike the project, the design of [Alternative B] would preclude future connections at
the Sid Commons driveway, Shasta Avenue extension and the Petaluma Outlet Mall
expansion....")
For clarity, please show specifically where future connections off of the proposed
connector could be located and confirm that these connections would be permissible
given relevant design constraints, elevations; minimum distances between intersections;
minimum distance from a future 101 interchange: and so forth; and also advise which if
any are anticipated to be signalized. Would the Sid Commons driveway be west of the
river? Is the Shasta Avenue extension also west of the river, and is it dependent on an
(milikely) at -grade crossing of the SMART tracks? Is there any future connection
potentially providing access to the portion of the Johnson property east of the river?
These issues are important for two reasons. First, the availability of these parcels
for development consistent -with the General Plan is important to provide a sufficient
inventory of land within the UGB, thus supporting the continued viability of the UGB.
Second, the City is assuming that the property owners will donate the needed right of way
at no cost to the City, but that assumption will not hold if there is no ability to access their
properties.
Ervin, Olivia
From:
Dennis Kelly <drkelly5@comcast.net>
Sent:
Monday, September 01, 2014 3:44 PM
To:
Ervin, Olivia
Subject:
Comments on DEIR Rainier Cross -Town Connector
Dear Ms. Ervin,
My comments to the DEIR Rainier cross-town connector follow:
Comment on the Public Notice for the DEIR:
1. I received a notice of public hearing on the DEIR for the Rainier Cross-town Connector 8-29-14. The
notice is postmarked 8-27-14 and it advises that the public continent period on the Draft Enviromnental
Impact Report for the cross-town connector is from July 24`h, to September 8`h. The notice was
postmarked over month after the comment period began and less than two weeks before it expires. I am
requesting that the public comment period be extended such that the start date is the date that public
notice was received (i.e. 8-29-14).
2. I ani also requesting that any future such notices provide the web address where the DEIR be
downloaded on-line in pdf. The notice I received only referred to locations -where hard copies were
available at designated locations in Petaluma despite the fact that document was available on-line.
Comment on Overall Scope of the DEIR: Add another Alternative for evaluation under a revised DEIR as follows:
4 -Lane Roadway and highway interchange at Corona Road: In lieu of the Rainier cross-town connector,
construct a 4 -Lane Roadway and highway interchange at Corona Road. Through highway signage divert traffic
heading through Petaluma and out to Bodega; to the Petaluma Outlet Malls; to the AutoMall and frontage road
business along North McDowell and Petaluma Boulevard North to the new Corona Road exit (rather than
Lakeville, Washington Street or Old Redwood Highway). Make any minimally necessary roadway
improvements to Skillman Lane to accommodate and improve traffic flow heading out to Bodega and to provide
for improved bicyclist and pedestrian circulation.
A significant percentage of traffic on Lakeville Highway, Washington Street and old Redwood Highway is
either through town traffic or out of town traffic accessing the Petaluma Outlet Malls; to the AutoMall and
frontage road business along North McDowell and Petaluma Boulevard North. The proposed Rainier cross-
town connector would do nothing to mitigate this traffic. A Corona interchange would allow through town
traffic and traffic to be directed to Skillman lane from Highway 101 and would meet all of the project objectives
to with the exception of "Provide a new cross town connection to serve both the east and west sides of the
City;` (the inappropriateness of this objective is discussed later in these comments). A 4 -Lane Roadway and
highway interchange at Corona Road would:
• relieve traffic congestion within the local street networks by diverting out of town traffic off of
Lakeville Highway, Washington Street and Redwood Highway,-
Provide
ighway;
Provide enhanced transit, bicyclist, and pedestrian circulation between the east and west side of
the City of Petaluma (Note that bicyclist, and pedestrian circulation between the east and west
side of the City of Petalurna already exists at the Rainier location via the Lynch creek trails and
bridges).
Relieve future traffic demands at the East Washington Street interchange for local traffic
crossing east -west across the Highway 101 corridor by moving through out of town through
town traffic from the Washington street corridor to Skillman Lane and moving out of town
traffic accessing the Petaluma Outlet Malls; the AutoMall and frontage road business along
North McDowell and Petaluma Boulevard North from Lakeville Highway, Washington Street
and Redwood Highway to the new Corona Interchange.
Relieve future traffic demands at the Old Redwood Highway interchange for local traffic
crossing east -west across the Highway 101 corridor by allowing traffic from north central
Petaluma to access Highway 101 at Corona Road rather than use surface streets to access
existing interchanges at Lakeville Highway, Washington Street and Redwood Highway; and
• Not preclude future connections from adjacent parcels along the roadway.
In addition to improving traffic within Petaluma this route saves through town travelers 2 1/2 miles of travel and
avoids multiple delays associated with traffic lights on existing cross town routes. Unlike the Rainier option,
this option does not require crossing the new Smart Rail tracks lowering costs and coordination complexities.
Please note that the request that this alternative be evaluated is not new. I submitted a similar request on a
previous DEIR; however, city staff responded by conducting a cursory evaluation of a full interchange at Corona
in conjunction with a cross-town connector at Rainier which was not what I requested (That analysis concluded,
in essence, that two bridges cost more than one and, therefore the alternative was rejected as not cost
effective). So just to be clear, I ani again requesting that a full interchange at Corona Road be evaluated in lieu
of the Rainier Cross-town Connector.
Comment on Pedestrian Access: North McDowell has become extremely busy roadway and the envisioned
project will only exasperate that. Please incorporate measures into the project to improve the safety of
pedestrians at the interchange of Rainier and North McDowell.
Comment on financial impact: Petaluma has recently constructed several major retail shopping centers all of
which would tend to increase sales tar revenues. Despite this, the City is pursuing an increase in the sales tax
rate due to funding shortfalls. It would appear that retail economic development results in a net burden to the
City's general fund; thus making the overall benefit of such growth questionable. Since this proposed cross town
connector will open up large areas to development consistent with the general plan, please include an analysis of
the financial impact to the City's general fund of the construction of this project. hnclude in the analysis the
proposed mechanisms for funding the project as well as the financial impact of the growth envisioned in the
General Plan on City operating budgets in a revised DEIR.
Section 3.1 and 3.5 These sections discuss the project background and project objectives respectively. Section
3.1 is a long and confusing discussion regarding the history of the Rainier project that seems to say that the plan
is to build both a cross-town connector and highway interchange as evidenced by the general plan, but then in the
middle of the discussion the text concludes that the cross-town connector is a standalone project without the need
to construct the interchange, which means that the connector can attain the project's objectives without any other
transportation improvements. In Section 3.5 the highway interchange is not one of the project's objectives and
so, the DER while acknowledging the that the true scope of the project includes the highway interchange, is
inappropriately limiting the scope of the analysis to just the cross town comnector.
Comment: Since the stated intent is pursue the 101 interchange in parallel with the cross town connector, given
that the Rainier interchange is already embraced by the general plan and given that an independent decision to
pursue the cross town connector would virtually lock in the Rainier location for the interchange without any
analysis, revise the DEIR to also address the impacts of the crosstown connector in association with the
highway 101 interchange such that project is fully evaluated.
Section 3.5: Comment: Delete the project objective to
A
• Provide a new cross town connection to serve both the east and west sides of the City;
This objective is too narrow in scope and limits the opportunity for evaluation of alternatives that would be more
effective in meeting the other project objectives at lower cost with less enviromnental impact.
Section 4.2 This section evaluates the expected emission of air pollutants and greenhouse gases (GHG)
generated during the construction and operation of the project. As background, I have lived at my current
location of 107 Lassen Pl. since 1980. In the ensuing 34 years I have seen traffic on McDowell increase
dramatically as the number of lanes was expanded and Highway 101 turned into a parking lot most days. Over
the last year we have also had to live with an upwind construction project as the Deer Creek Village went in. It
obvious that all this has resulted in an increase in umnonitored exposure to GHG and particulates. Our vehicles
and lawn furniture serve as daily indicators of the increased particulate deposition.
Comment: The DEIR analysis is entirely based on data from a BAAQMD air quality monitoring station located
in Santa Rosa at 5th Street Monitoring Station. This was selected because it is closest such station to the project
site; however it is 14 miles away. Using data from such a distance does not allow for consideration of localized
conditions. Reconunend conducting monitoring at the Rainier Prince Albert intersection and using that data in
lieu of the Santa Rosa data to support conclusions in a revised DEIR.
Comment: The conclusion that GHG impacts can be mitigated to less than Significant (LTS) is entirely based
on the modeling using data from Santa Rosa and contract provisions stipulating construction controls (which
may or may not be rigorously enforced). Recommend that air monitoring be required during the construction
phase and that contractors be required to prepare work plans kdth action levels established for addressing GHG
and particulates in excess of action levels.
Section 4.7.4.3 This section discusses significant hydrology and water quality impacts. The section concludes
that the project will have Less than significant impacts because of a mitigation measure to conduct a future
hydraulic design study at later stages of project design to determine the project's potential to alter the river's
flood flows at the bridge location and upstream and downstrearn of the bridge. It is inappropriate to conclude
that impacts will be less than significant based on a future study. What if the study demonstrates
otherwise? Recommend that study be conducted now and that the study take into account the development
envisioned in the general plan (in terms of runoff from paved surfaces) and that those results be factored into a
revised DEIR.
Section 4.9 This section describes the existing noise environment in the project vicinity and potential noise
impacts resulting from the proposed project and concludes that the impacts are LTS. As background, the noise
impacts I am interested in are the long tern impacts of traffic noise in my neighborhood resulting from the
increased traffic flow resulting from the proposed project. My comments on the noise analysis are as follows:
Comment: . Section 4.9.4.3. this section states that "The project is a transportation project and not a
noise sensitive use; therefore, this impact would be less than significant." Please cite the authority for
this statement. The statement seems to imply that any noise impact from a transportation project no
matter how loud is somehow excluded by regulation or otherwise from considerations.
Comment: As written the entire Section 4.9 is very confusing containing too much boilerplate text and
tables with conflicting information. The Modeling states that it is done in conformance with Table 4.9-6
(Office of Planning and Research Guidelines), but no comparison of results to City of Petaluma
Guidelines, Table 4.9-5, is provided. In addition, graphical results such as Figure 4.9-4 provide no
acceptance standards. Please revise the text to clearly refer to the acceptance standards that are being
used and eliminate text that is not relevant to this project sited. Include test that clearly states the results
of the analysis such as:
"Based on the modeling conducted, implementation of the proposed project would result in no
changes/changes in traffic noise levels, relative to noise levels without the project, ranging from a
decrease/increase of X dB to an increase/decrease of Y dB Ldn. Under existing and Existing plus
Approved Projects conditions the proposed project would result in significant increases/decreases in
traffic noise levels along North McDowell Boulevard and Rainier Avenue. Implementation of the
proposed project under cumulative 2025 City General Plan conditions would result in less than
significant/significant increases in traffic noise levels along North McDowell Boulevard and Rainier
Avenue. Thus, long -teen noise levels fiom project -generated vehicular traffic would result in a less than
substantial/substantial (X—Y dB or greater) permanent increase in ambient noise levels. As a result, this
impact would be significant/less than significant. Feasible mitigation measures are
.........................................................................
Comment: Please collect actual long temp noise monitoring data on McDowell and Rainier in the area of the
Park Place subdivision and re -perform modeling. The existing model has a number of deficiencies which need to
be conected as follows:
The Model uses calculated noise levels in the Park Place (R8 and R9) subdivision area based on Rainier
traffic only (ignores McDowell traffic) and uses as a source site LT -3 which is located several blocks
away and subject to screening by existing structures and landscaping.
Section 4.9.4.2 states "Since traffic volumes in the area surrounding the roadway corridor have remained
relatively stable for the last 10 years, it was assumed that noise levels for existing and Opening Year
(2020) conditions would be relatively stable as well." This continent is incorrect because the new Deer
Creek Village opened subsequent to the collection of the monitoring data upon which the analysis is
based, and, in addition, the opening of the project site connector with result in increased traffic flow on
both McDowell and Rainier.
Section 4.10.3.3 Discusses Less Than Significant Impacts:
This section states that "the project would potentially provide access to vacant parcels along the projects length
that are designated for development in the General Plan. The Rainier Avenue extension and associated
connections have been anticipated in the General Plan to allow access to parcels that are designated for higher
density housing development including Medium Density
Residential (8.1-18.0 hu/ac) and Mixed Use. Therefore, any reasonably foreseeable growth resulting from the
project has been anticipated and incorporated into analysis utilized in development of the General Plan." This
section ignores the fact that access the cross town connector is not needed to access the areas planned for
development on the western side of Highway 101 in the project area. Areas to the east of Highway 101 are
already developed. Areas to the west of Highway 101 simply require access roads be built by the development
interests that will benefit from public infrastructure improvements needed to access their parcels.
Dennis Kelly
107 Lassen Place
Petaluma, CA 94954
707-778-0915A
�(a
State of California — The Natural Resources Aeencv
DEPARTMENT OF FISH AND WILDLIFE
Bay Delta Region
_ - 7329 Silverado Trail
Napa, CA 94558
(707)944-5500
www.wildlife.ca.aov
August 27, 2014
Ms. Heather Hines
City of Petaluma
11 English Street
Petaluma, CA 94952
Dear Ms. Hines:
EDMUND G. BROWN JR.. Governor
CHARLTON H. BONHAM, Dirctor
Subject: Rainier Avenue Cross -Town Connector, Draft Environmental Impact Report,
SCH #2011082032, City of Petaluma, Sonoma County
The California Department of Fish and Wildlife (CDFW) has reviewed the documents provided
for the subject project, and we have the following comments.
Please be advised that a California Endangered Species Act (CESA) Permit must be obtained if
the project has the potential to result in take of species of plants or animals listed under CESA,
either during construction or over the life of the project. Issuance of a CESA Permit is subject to
the California Environmental Quality Act (CEQA) documentation; therefore, the CEQA
document must specify impacts, mitigation measures, and a mitigation monitoring and reporting
program. If the project will impact CESA listed species, early consultation is encouraged, as
significant modification to the project and mitigation measures may be required in order to
obtain a CESA Permit.
For any activity that will divert or obstruct the natural flow, or change the bed, channel, or bank
(which may include associated riparian resources) of a river or stream, or use material from a
streambed, CDFW may require a Lake and Streambed Alteration Agreement (LSAA), pursuant
to Section '1600 et seq. of the Fish and Game Code, with the applicant. Issuance of an LSAA is
subject to CEQA. CDFW, as a responsible agency under CEQA, will consider the CEQA
document for the project. The CEQA document should fully identify the potential impacts to the
stream or riparian resources and provide adequate avoidance, mitigation, monitoring and
reporting commitments for completion of the agreement. To obtain information about the LSAA
notification process, please access our website at htto://www.dfa.ca.aovlhabcon/1600/: or to
request a notification package, contact CDFW's Bay Delta Regional Office at (707) 944-5500.
If you have any questions, please contact Mr. Adam McKannay, Environmental Scientist, at
(707) 944-5534; or Ms. Karen Weiss, Senior Environmental Scientist (Supervisory), at
(707) 944-5525.
Sincerely,
Scott Wilson
Regional Manager
Bay Delta Region
cc: State Clearinghouse
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