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HomeMy WebLinkAbout05 SR-55 WIDENING PROJECT (I-405 TO I-5)MEETING DATE: TO: FROM: SUBJECT: SUMMARY: Hgenaa item Reviewed: AGENDA REPORT City Manager = f Finance Director J -44A - MEETING /n JANUARY 5, 2016 JEFFREY C. PARKER, CITY MANAGER COMMUNITY DEVELOPMENT DEPARTMENT TUSTIN RESPONSE TO DRAFT INITIAL STUDY / ENVIRONMENTAL ASSESSMENT FOR THE SR -55 WIDENING PROJECT (1-405 TO 1-5) Tustin City Council concurrence is requested for the City of Tustin's (the City) response to the Draft Initial Study / Environmental Assessment (IS/EA) for the State Route 55 (SR -55) Improvement Project between Interstate 405 (1-405) and Interstate 5 (1-5). The proposed project would widen a four (4) mile segment of SR -55 in both directions. The purpose of the proposed project is to provide congestion relief, improve traffic flow, and increase mobility on SR -55. RECOMMENDATION: That the City Council direct staff to forward the attached response letter to the California Department of Transportation (Caltrans). FISCAL IMPACT: There are no fiscal impacts associated with this action. CORRELATION TO THE STRATEGIC PLAN: Staff's review of the Draft IS/EA for the SR -55 Project falls under Goal D of the Strategic Plan pertaining to strong community and regional relationships. The City strives to work collaboratively with agencies both within and outside Tustin on issues of mutual interest and concern. BACKGROUND: The proposed project would widen SR -55 in both directions from just north of 1-405/SR-55 Interchange to just south of the 1-5/SR-55 Interchange. There are four (4) project alternatives under consideration, in addition to the "No Build Alternative": Alternative 1 includes additional auxiliary lanes and a southbound general purpose lane; Alternative 2 proposes new general purpose lanes in both directions; Alternative 3 includes new general City Council Meeting January 5, 2016 SR -55 1S/EA Page 2 purpose lanes and additional auxiliary lanes; and Alternative 4 proposes new high - occupancy vehicle (HOV) lanes and additional auxiliary lanes. The purchase of right-of- way will be required along the corridor for all of the four (4) "build" alternatives. Attachment A provides a summary of Alternatives and Impacts along with the four build alternatives. City staff has reviewed the subject Draft IS/EA. Based on general project concerns related to: Public outreach; temporary construction easements, detours, and staging; and specific concerns related to traffic and noise impacts, staff believes that it is in the City's interest to be on record regarding this matter and has prepared correspondence expressing the City's concerns regarding the Draft IS/EA. (Attachment). Staff requests that the Tustin City Council review and consider these comments and, if acceptable, concur with their formal transmittal to Caltrans. off Reekstin Principal Planner Attachment: A. Summary of Alternatives and Impacts B. Draft Comment Response Letter Elizabeth A. Binsack Community Development Director ATTACHMENT A Summary of Alternatives and Impacts Table 1.18 Summary of Alternatives and Impacts Evaluation Criteria No Build Alternative Build Alternative 1 Build Alternative 2 Build Alternative 3 Build Alternative 4 Project Features and Design Standards Number of Lanes 1 HOV, 4 general- 1 HOV, 4 general-purpose, 1 HOV, 5 general-purpose 1 HOV, 5 general-purpose, 2 HOV, 4 general-purpose purpose and auxiliary and auxiliary Travel Lanes consistent wth the Nonstandard general- Standard general-purpose Standard general-purpose Standard general-purpose Standard general-purpose Caltrans Highway Design Manual? purpose and HOV lanes and HOV lane lanes and HOV lane lanes and HOV lane and HOV lane lanes Shoulders consistent with the Non-standard HOV Standard HOV median Standard HOV median Non-standard HOV median, Non-standard HOV median, Caltrans Highway Design Manual? median shoulder, shoulder, standard outside shoulder, non-standard non-standard outside non-standard outside standard outside shoulder, non-standard outside shoulder, non- shoulder, non-standard shoulder, non-standard shoulder inside shoulders standard inside shoulders inside shoulders inside shoulders Horizontal clearances consistent Standard clearances Standard clearances are Standard clearances are Standard clearances are Standard clearances are with the Caltrans Highway Design are not provided for the provided except bridge provided except bridge provided except bridge provided except bridge Manual? inside median columns and median sign columns and median sign columns and median sign columns and median sign posts posts posts posts Vertical clearances consistent with Minimum vertical Minimum vertical clearance Minimum vertical clearance Minimum vertical clearance Minimum vertical clearance the Caltrans Highway Design clearances are over LOSSAN rail corridor over LOSSAN rail corridor over LOSSAN rail corridor over LOSSAN rail corridor Manual?provided is not provided is not provided is not provided is not provided AM/PM peak -hour mainline LOS in E/F E/F D/F DIF DIF 2040 Temporary construction easements None 24 47 59 49 Project Cost None $127,107,000 $198,030,000 $250,760,000 $216,519,000 Construction Duration None 30 months 30 months 36 months 36 months Potential Environmental Impacts Land Use Not consistent with Consistent with local, Consistent with local, Consistent with local, Consistent with local, applicable regional, and State plans regional, and State plans regional, and State plans regional, and State plans transportation and land use plans Permanent loss of 8 parking Permanent loss of 8 parking Permanent loss of 20 Permanent loss of 20 stalls stalls parking stalls arkin stalls Growth No impact Would not result in Would not result in Would not result in Would not result in unplanned growth unplanned growth unplanned growth un tanned row[h Farmlands and Timberlands No impact No impact No impact No impact No impact Community Community Character No impact Temporary impacts during Temporary impacts during Temporary impacts during Temporary impacts during Impacts and Cohesion construction, including 12 construction, including 19 construction, including 20 construction, including 19 overnight ramp closures overnight ramp closures overnight ramp closures overnight ramp closures No Ion -tern impacts I No Ion -tern impacts I No Ion -tern im acts I No Ion -term impacts Relocation No impact Construction would require Construction would require Construction would require Construction would require TCEs on 21 residential, TCEs on 41 residential, TCEs on 53 residential, TCEs on 43 residential, commercial, and industrial commercial, and industrial commercial, and industrial commercial, and industrial parcels; 2 flood control parcels; 3 flood control parcels; 3 flood control parcels, 3 flood control parcels, and 1 railroad parcels; 2 railroad parcels; parcels; 2 railroad parcels; parcels; 2 railroad parcels, parcel. and 1 public parcel. and 1 vacant parcel. and 1 vacant parcel. SR -55 Improvement Project Initial Study/Environmental Assessment 1-57 Table 1.18 Summary of Alternatives and Impacts Evaluation Criteria No Build Alternative Build Alternative 1 Build Alternative 2 Build Alternative 3 Build Alternative 4 Full acquisition of 4 vacant Full acquisition of 4 vacant Full acquisition of 8 non- Full acquisitions of 8 non - parcels and partial parcels and partial residential parcels residential parcels acquisition of 7 non- acquisition of 16 non- (including 2 business (including 2 business residential parcels, residential parcels, relocations) and partial relocations) and partial including the demolition of including the demolition of acquisitions 30 non- acquisitions of 21 non - one occupied building, one occupied building, residential properties residential properties resulting in the resulting in the (including the demolition of (including the demolition of displacement of one displacement of one one occupied building), one occupied building), business (Rockin' Jump). business (Rockin' Jump). resulting in the resulting in the displacement of one displacement of one business Rockin' Jum . business Rockin' Jum Environmental Justice No impact No disproportionate impact No disproportionate impact No disproportionate impact No disproportionate impact Utilities and Emergency Services No impact 30 utility relocations and 37 utility relocations and 38 utility relocations and 30 utility relocations and temporary emergency temporary emergency temporary emergency temporary emergency services delay during services delay during services delay during services delay during construction construction construction construction No long-term impacts No long-term impacts No Ion -lens impacts No Ion -tern impacts Traffic and Transportation Long-term negative Temporary impacts during Temporary impacts during Temporary impacts during Temporary impacts during impact construction construction construction construction Improved traffic operations Improved traffic operations Improved traffic operations Improved traffic operations and reduced congestion in and reduced congestion in and reduced congestion in and reduced congestion in the long tens the long tens the long term the long term Visual and Aesthetics No impact Temporary impacts during Temporary impacts during Temporary impacts during Temporary impacts during construction construction construction construction Permanent wall and Permanent wall and Permanent wall and Permanent wall and landscaping enhancements landscaping enhancements landscaping enhancements landscaping enhancements Cultural Resources No impact Potential to encounter Potential to encounter Potential to encounter Potential to encounter unknown cultural resources unknown cultural resources unknown cultural resources unknown cultural resources during construction during construction during construction during construction No Ion -tern impacts No Ion -term impacts No Ion -tern impacts No long-term impacts Hydrology and Floodplains No impact Minimal change to Minimal change to Minimal change to Minimal change to floodplain elevations floodplain elevations floodplain elevations flood Iain elevations Water Quality and Storm Water No impact Construction activities Construction activities Construction activities Construction activities Runoff would disturb a total area of would disturb a total area of would disturb a total area of would disturb a total area of 38.9 ac, resulting in 70.3 ac, resulting in 77.2 ac, resulting in 64.9 ac, resulting in temporary impacts during temporary impacts during temporary impacts during temporary impacts during construction construction construction construction Permanent increase in Permanent increase in Permanent increase in Permanent increase in impervious surface area of impervious surface area of impervious surface area of impervious surface area of 7.3 ac, thereby increasing 11.3 ac, thereby increasing 15.4 ac, thereby increasing 15.0 ac, thereby increasing 1-58 SR-55ImprovementProject Initial Study/Environmental Assessment .......................................................................................................................................................................................................................................................................................Chapter 1 Proposed Project ........................................ Project Table 1.18 Summary of Alternatives and Impacts Evaluation Criteria No Build Alternative Build Alternative 1 Build Alternative 2 Build Alternative 3 Build Alternative 4 the volume of runoff and the volume of runoff and the volume of runoff and the volume of runoff and permanent improvement in permanent improvement in permanent improvement in permanent improvement in water quality with project water quality with project water quality with project water quality with project Treatment BMPs Treatment BMPs Treatment BMPs Treatment BMPs Geology, Soils, Seismic, and No impact Temporary impacts during Temporary impacts during Temporary impacts during Temporary impacts during Topography construction construction construction construction No substantial long-term No substantial long-term No substantial long-term No substantial long-term impacts impacts impacts im acts Paleontology No impact Potential to encounter Potential to encounter Potential to encounter Potential to encounter unknown paleontological unknown paleontological unknown paleontological unknown paleontological resources during resources during resources during resources during construction construction construction construction No long-term impacts No long-term impacts No long-term impacts No long-term impacts Hazardous Wastes and Materials No impact Soil contaminants and Soil contaminants and Soil contaminants and Soil contaminants and structural materials may be structural materials may be structural materials may be structural materials may be encountered during encountered during encountered during encountered during construction construction construction construction No long-term impacts No long-term impacts No long-term impacts No Ion -term im acts Air Quality No impact Temporary impacts during Temporary impacts during Temporary impacts during Temporary impacts during construction construction construction construction No substantial long-term No substantial long-term No substantial long-term No substantial long-term impacts impacts impacts impacts Noise No impact Temporary impacts during Temporary impacts during Temporary impacts during Temporary impacts during construction construction construction construction No perceptible increase in No perceptible increase in No perceptible increase in No perceptible increase in noise in the long-term noise in the long-term noise in the long-term noise in the long-term increase increase increase increase The following noise barriers The following noise barriers The following noise barriers The following noise barriers were determined to be were determined to be were determined to be were determined to be reasonable and feasible: reasonable and feasible: reasonable and feasible: reasonable and feasible: • NB No. 3 NB No. 3 NB No. 3 NB No 3 • Combined NB No 3 Combined NB No. 3 Combined NB No. 3 Combined NB No. 3 Reduced and NB No. 4 Reduced and NB No. 4 Reduced and NB No. 4 Reduced and NB No 4 ................................................................................................................................................................................................................................................................................................................................................... SR -55 Improvement Project Initial Study/Environmental Assessment 1-59 Table 1.18 Summary of Alternatives and Impacts Evaluation Criteria No Build Alternative Build Alternative 1 Build Alternative 2 Build Alternative 3 Build Alternative 4 Natural Communities No impact No impact No impact No impact No impact Wetlands and Other Waters No impact 1 01 ac of temporary 1.01 ac of temporary 1.01 ac of temporary 1.01 ac of temporary impacts to USACE and impacts to USACE and impacts to USACE and impacts to USACE and CDFG jurisdiction CDFG jurisdiction CDFG jurisdiction CDFG jurisdiction No permanent impacts to No permanent impacts to No permanent impacts to No permanent impacts to USACE jurisdiction. 0.93 ac USACE jurisdiction. 0.93 ac USACE jurisdiction. 0.93 ac USACE jurisdiction. 0.93 ac of permanent impacts to of permanent impacts to of permanent impacts to of permanent impacts to CDFW 'unsdiction CDFW jurisdiction CDFW jurisdiction CDFW'urisdiction— Plant Species No impact No impact No impact No impact No impact Animal Species No impact Potential for temporary Potential for temporary Potential for temporary Potential for temporary impacts during construction impacts during construction impacts during construction impacts during construction to burrowing owls, migratory to burrowing owls, migratory to burrowing owls, migratory to burrowing owls, migratory birds, bats, and other birds, bats, and other birds, bats, and other birds, bats, and other bridge- and crevice -nesting bridge- and crevice -nesting bridge- and crevice -nesting bridge- and crevice -nesting special -status species special -status species special -status species special -status species No long-term impacts No long-term impacts No long-term impacts No Ion -term im acts Threatened and Endangered No impact No impact No impact No impact No impact Species Invasive Species No impact No impact No impact No impact No impact Cumulative Impacts No impact No impact No impact No impact No im act Climate Change No temporary impacts Temporary impacts during Temporary impacts during Temporary impacts during Temporary impacts during Increase in CO2 construction construction construction construction emissions of 60 Increase in CO2 emissions Increase in CO2 emissions Increase in CO2 emissions Increase in CO2 emissions tons/day in 2020 and of 10 tons/day in 2020 and of 10 tons/day in 2020 and of 20 tons/day in 2020 and of 10 tons/day in 2020 and 500 tons/day in 2040 20 tons/day in 2040 30 tons/day in 2040 50 tons/day in 2040 30 tons/day in 2040 compared to existing compared to the No Build compared to the No Build compared to the No Build compared to the No Build 2011 conditions I Alternative I Alternative I Alternative I Alternative Source: LSA Associates, Inc. (2015). Note: Long-term impacts are equivalent to permanent impacts. ac = acres BMPs = best management practices CDFW = California Department of Fish and Wildlife GHG = greenhouse gas HOV = high -occupancy vehicle LOS = levels of service LOSSAN = Los Angeles to San Diego TCE = temporary construction easement USACE = United States Army Corps of Engineers 1-60 SR -55 Improvement Project Initial Study/Environmental Assessment � e r lip �► - 1w wi JIM -1 , �� WalnutA ve �a �.. 5 / r*. It �,. 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NOT TO SCALE SOURCE: FEHR & PEERS (Jan. 2013) I:\HDR1102\G\IS_EMExisting SR-55.cdr (4/23/14) LEGEND General Purpose Lane NOV Lane _- • Buffer Separation between NOV and GP Lanes FIGURE 1-2 State Route 55 (SR -55) Improvement Project beAveen Interstate 405 (I--405) and Interstate 5 (I-5) Existing SR -55 12 -ORA -55 PM 6.4/10.3 EA No. OJ3400/EFIS 1200020328 P.p01- s0 ♦ qt� 1 ! \' ♦�� : qp �' `\ !'\� off( %�� \�� �-------- _ p�rW < a ------------�------- 1 `-------------- =--------------------- � --------------------- --------- �.-. -,,..._._,.._----------------------------------------------------- e -.. e e e • e o 0 ------------ ---------0 n c c i`0 o 0 G \ U U-----------�G� � m s e o e o e o 0 __________________________________________________________________________________________________ .. .. .. ..._-.. _. ___- �____---____�-----________________ --------------------------------------- ____________________________ - ____________ r r r -i r _ y y I 1 i Y ole ._ 7: aim \ $ _ o. o �I N I e ---'------- ------ '-----------e--------- " -------------------- -------------------------------- -----� - -------------------------------------------------- ------------------.------------------__--------_-------------------------- ------------------------------='-------- ��� <. -��\�- --- ---- - ---------------------- V NOT TO SCALE SOURCE: Final Traffic Operations Report (2014) I:\HDR1102\G\IS-EA\BuildAltemativc I.edr(I1/13/2015) LEGEND - General Purpose Lane - HOVLane Proposed GwwM Purpose Lane Proposed Auxiliary Lane Proposed HOV Lara HOV Limited Access Santa Ana rsYOea FIGURE 1-4 State Rowe 55 (SR -55) Improvement Project between Interstate 405 (I--405) and Interstate 5 (I--5) Build Alternative 1 12 -ORA -55 PM 6.4/10.3 EA No. OJ3400/EFIS 1200020328 i ,COs c vo ,' cF ��o ; S�y'`,� � � " �< a / aD -----------------------------------------99--ihrm ------------------------------------------------------------------------------------------------------------------------ ----- ----------------- h "cF a/ O`� �1� C , OT 19 z3, `O L ----------------------------------- w*a 0, �A \y¢° qy i Qim i o! o U i tl O O ` --- ----- — —— — -----------------_------- ---- —_ —------------ --- - __—____---------------- 1 P a 1 I Ir ---------- - ----------------_----------------------- -- r------------------------------ -------------------------------------------------- -------------------------------�------------------------------------ --------------------------------- ---------- --------------------- ------------------------------ _���------- a -o- --- ---- - - � a i i. N a ---------- e e e o ----------------------------- T==------------------------ = ---_-_-_-_--_-_-_--_--------------_-----_-_---_--_-_---_--------- --------------------------- -- ---- y -------------------------------------------------- ---------- ------------- ----------- �J ----------_--------------------- A,� -------r--_- ---------- ----------� '2.7, F�,' C); NOT TO SCALE SOURCE: Fehr & Peers 1:\HDRI102\G\IS EA\BuiIdAlternative2.cdr(I1/13/2015) LEGEND General Purpose Lena HOV Lane Proposed General Purpose Lane Proposed HOV Lane HOV UmRed Access Tustin Santa Ana ■ i i no FIGURE 1-5 State Route 55 (SR -55) Improvement Project behvee17 Interstate 405 (I--405) and Interstate 5 (I--5) Build Alternative 2 12 -ORA -55 PM 6.4/10.3 EA No. OJ3400/EFIS 1200020328 1 1 �" f `♦♦♦♦ ticf ♦♦�\ �/ °� ��� ♦t\�r (T+ Cf [�Gj� ` r��\�' �r t5' �!"/ i u a � i C._---------------------------------- --------------------------- -------- r • ------------------------------- _ e o a ae 0:0 010 U),W _----------- Op ______=_- j� Q P � \�� � r ~ �a \• l`� _ewe CM j �� ♦ 1 t 4, . j� E� } , > � - i iCNQ:41 -------------------------------- --------------------------------------------------- ----------------------- 's b C 0 --------- _ _ _-_--_-_-_- _- _- _- ---------- ------ --------------------------- _____ -_-_-_ ------- --- ----------- ------------------------- y ----------- ------- ------ sCr ---------------------- CP LEGMNO General Purpose Lane e HOV Lane Prcposed General Purpose Lane Proposed Awdliary Lane Proposed HOV Lane Separator Improvements by Other Project Compbted in 2012 HOV Limited Moses J FIGURE 1-6 –0-00- State Route 55 (SR -55) Improvement Project bent een Interstate 405 (I--405) and Interstate 5 (I--5) Build Alternative 3 NOT TO SCALE 12 -ORA -55 PM 6.4/10.3 SOURCE: Final Traffic Operations Report (2014) EANo. OJ3400/EFIS 1200020328 I:\HDR1102\G\IS EA\BuildAltemative 3.cdr (11/13/2015) r a/ -s C�a `Cr --------------� -------------- —------------- ---- ------------ ---------------- - --- - — -------------------------------------- ------------------------------------------------------------------- -----------------o ---- ------ ---- _ ------------------------------------ ------ ------------ -- ---------------------------------------------------------------------------------------------------------- - --a-------------------- ------ ------ oy o ' °�' r4�OS o ; o V 15 �\ U) CD ________-_-_-_--------- ----'---------- o------------- -_-_- _ o --------- ----------- o -------------------- ------- - -------- -----------_------------- _______-_ _- 1--�_________o o __________ _._________ y .�- _______ _____ -. _� ------------- ----- _-___-____-_--__ �---------------------------------------------_____-__-_____--___-_____ _ �___ 2 i ~ a, \ J cr ewe On °cF g .-�-� a f� 9�� t LEGEND s 13 °P S sB � -- ---------=------------------------------------------------------------------------ f -, --------------------- - — o -------- ---------e--------- mm - i -----a-------- 0 ------------------------------ ---- ---------------------- ---- --------------------------- -- -7 -------------------------------------------------- ------------- ------ ----------------------------- _ \ ------ �h NOT TO SCALE SOURCE: Fehr & Peers I:\HDRI102\G\IS-EA\Build Alternative 4.cdr (I 1/13/2015) - General Purpose Lane - HOV Lena Proposed General Purpose Lane Proposed Aub6ary Lena Proposed HOV Lane Separator HOV Umfted Access Santa Ana Tustin �W O� no FIGURE 1-7 State Route 55 (SR -55) Improvement Project behveen Interstate 405 (I--405) and Interstate 5 (I--5) Build Alternative 4 12 -ORA -55 RM 6.4/10.3 EA No. OJ3400/EFIS 1200020328 ATTACHMENT B Draft Comment Response Letter Community Development Department January 6, 2016 Mr. Charles Baker Senior Environmental Planner Department of Transportation, District 12 Environmental Analysis —Specialist Branch 3347 Michelson Drive, Suite 100 Irvine, CA 92612-1692 TUSTIN BUILDING OUR FUTURE HONORING OUR PAST SUBJECT: REVIEW OF THE INITIAL STUDY/ENVIRONMENTAL ASSESSMENT FOR THE SR -55 (1-405 TO 1-5) IMPROVEMENT PROJECT Dear Mr. Baker: Thank you for the opportunity to provide comments on the Initial Study/Environmental Assessment (IS/EA) for the State Route 55 (SR -55) Improvement Project between Interstate 405 (1-405) and Interstate 5 (1-5). The proposed project would widen SR -55 in both directions from just north of 1-405/SR-55 Interchange to just south of the 1-5/511-55 Interchange. According to the ES/IA, there are four project alternatives under consideration, in addition to the "No Build" Alternative. Alternative 1 includes additional auxiliary lanes and a southbound general purpose lane. Alternative 2 proposes new general purpose lanes in both directions. Alternative 3 includes new general purpose lanes and additional auxiliary lanes. And Alternative 4 proposes new high -occupancy vehicle (HOV) lanes and additional auxiliary lanes. The purchase of right-of-way will be required along the corridor for all of the alternatives. The City of Tustin offers the following general comments about the project and specific comments about the IS/EA at this time: GENERAL COMMENTS Modification at McFadden Avenue/Newport Avenue Northbound On-ramp It was reported at the conclusion of the Value Analysis Study that there would be safety benefits associated with a potential modification of the northbound SR -55 ramps at McFadden Avenue/Newport Avenue. The modification recommended by the Value Analysis Team would prevent vehicles entering the highway at that on-ramp from traveling north on SR -55. All vehicles entering at that location would be required to exit at Interstate 5 in the southbound or northbound direction. In response to the City's concerns regarding significant impacts on local 300 Centennial Way, Tustin, CA 92780 0 P (714) 573-3100 • F. (714) 573-3113 0 www tustinca.org SR -55 Widening IS/EA January 6, 2016 Page 2 traffic due to the potential modification, the Traffic Operations Report was revised to include an analysis of local intersections. This analysis concluded that one ramp intersection, Newport Avenue at 1-5 Northbound On -Ramp, requires mitigation. The extension of Newport Avenue from its current terminus to Edinger Avenue would alleviate some of these impacts by providing a direct route to the Newport/Edinger Avenue on-ramp and access to SR -55. However, the funding for the extension project has not been secured. Should funding from the Orange County Transportation Authority and other sources be secured, the proposed extension of Newport Avenue would provide cumulative benefits to the improvements anticipated by the SR -55 widening project and the ultimate build -out of the Master Plan of Arterial Highways. In addition, the City would prefer that the McFadden interchange be removed entirely. With the addition of the Newport Avenue extension to Edinger Avenue, the SR -55 Northbound can be reached via the ramps at Newport Avenue and Del Amo Avenue intersection. Partial Right -of -Way Takes Two parcels north of Warner Avenue, occupied by Ricoh, will be significantly impacted by partial right-of-way takes associated with the widening project. Alternatives 3 and 4 would impact the parking lot at 1100 Valencia Avenue, requiring its reconfiguration and resulting in a net loss of approximately 12 parking spaces. We are concerned that the reduction in parking spaces may prevent future building expansions and/or conversions of space to other allowable uses. The City of Tustin requests that Caltrans conduct outreach to the property owner on this matter, if this outreach has not yet occurred. Temporary Construction Easements It is our understanding that Alternative 1 would potentially require temporary construction easements (TCEs) at eight (8) properties in Tustin, while Alternatives 2, 3, and 4, would each require TCEs at as many as thirteen (13) Tustin parcels. These temporary construction easements may cause significant impacts to the affected parcels, depending on the size, nature, and duration of the easement. The City of Tustin requests that Caltrans conduct outreach to the affected property owners, if this outreach has not yet occurred. Detours According to the IS/EA, ramp closures and their associated detours would be temporary and usually during nighttime hours only. One of the proposed detours for the northbound SR -55 on- ramp at Newport/Edinger Avenues would direct traffic eastward on Edinger Avenue, northward on Red Hill Avenue and then westward on Sycamore Avenue, which is a two-lane road in a residential neighborhood with three schools (Deane Thorman Elementary School, A.G.,Currie SR -55 Widening IS/EA January 6, 2016 Page 3 Middle School, and St. Cecilia School and Church) fronting it. Night time work in a residential neighborhood is not preferred per the city's noise ordinance. Daytime during the school year would exacerbate already significant school traffic demand. The preferred detour alternative route to using Sycamore Avenue is for motorists to remain on Red Hill Avenue and continue to their destinations via the 1-5. Traffic impacts of this detour to the Red Hill Avenue/1-5 interchange should be analyzed if occurring during the peak hour. The City requests that Caltrans inform the City of all traffic detour plans and traffic management plans that would affect traffic in the Tustin area west of SR -55, north and south of the 1-5, during project construction. Construction Staging It has been noted that a potential construction staging area is being considered for the City - owned parcel to the south of the Edinger Avenue on and off -ramps. This parcel is slated for future commercial development, and a construction staging area at this location may significantly hamper efforts to market the site to potential investors. Therefore, the City of Tustin may be unable to offer this site as a temporary construction staging area. The City of Tustin also requests to be notified of the proposed locations of the construction staging areas to determine the potential for any short-term traffic impacts on City of Tustin streets. Public Outreach Extensive public outreach is requested so that Tustin residents, business people, and visitors are aware of the project and may plan accordingly. Outreach with the Tustin Unified School District will be critical. COMMENTS REGARDING THE IS/EA General IS/EA page 2.14-5: It is noted that the land uses to the east of SR -55 between Warner Avenue and Edinger Avenue include "two hotels that are currently under construction." The IS/EA should be revised to reflect the completion of the two hotels. IS/EA page 2.19-5: Table 2.19.1 (Planned Projects List) is out of date. The Village at Tustin Legacy (98,292 sq. ft. retail and 150,000 sq. ft. medical plaza) was approved in November of 2015, and an 8,000 square foot office building at 721 W. First Street is under review. SR -55 Widening IS/EA January 6, 2016 Page 4 Noise As part of the proposed project, sound attenuation walls are proposed in Tustin adjacent to the existing multiple family residences south of the northbound SR -55 off -ramp for McFadden Avenue and Newport Avenue. However, sound walls are not proposed to the north of the McFadden Avenue/Newport Avenue off -ramp. According to the IS/EA, "a minimum noise reduction of 5 dBA must be achieved at impacted receptors for the proposed noise abatement measures (i.e., noise barriers) to be considered feasible." The IS/EA further states that "all the noise barriers that were considered feasible were analyzed to determine their reasonableness. The overall reasonableness of noise abatement is determined by considering the noise reduction goal combined with the construction cost of the barrier." Caltrans has determined that the noise reduction goal is 7 dBA and that the reasonable noise barrier construction cost allowance per benefitted residence is $71,000. Pursuant to the California Environmental Quality Act (CEQA) Guidelines, Section 15070, a public agency may prepare a mitigated negative declaration for a project subject to CEQA when "the initial study identified potentially significant effects, but: (1) Revisions in the project plans or proposals made by or agreed to by the applicant before a proposed mitigated negative declaration and initial study are released for public review would avoid the effects or mitigate the effects to a point where clearly no significant effects would occur, and (2) There is no substantial evidence, in light of the whole record before the agency, that the project as revised may have a significant effect on the environment." The infeasibility of mitigation measures or project alternatives based on economic or other factors can be considered when an Environmental Impact Report (EIR) has been prepared for a project, but may not be used as a justification for not implementing mitigation measures in conjunction with a mitigated negative declaration. Therefore, the IS/EA should be revised to include additional mitigation measures, such as additional noise barriers, that fully mitigate the potential noise impacts at all receptor locations, or an environmental impact report should be prepared for the project. Further, the IS/EA does not adequately address interior noise impacts, as it assumes an interior noise reduction of 20dB. This level of noise reduction may only be achieved when windows and doors meeting specified acoustic ratings are completely closed, and ventilation systems are provided. The noise evaluation in the IS/EA should be revised accordingly. SR -55 Widening IS/EA January 6, 2016 Page 5 In addition, the following mitigation measures should be incorporated into the mitigated negative declaration to mitigate any identified significant interior noise impacts: 1) Caltrans shall offer to provide forced air ventilation in all residences where significant interior noise impacts would occur with windows and doors open, if the affected residences are not equipped with forced air ventilation. 2) Where significant interior noise impacts would otherwise occur, Caltrans shall offer to provide acoustic -rated window/door assemblies in all second -story windows and/or sliding glass doors in habitable rooms of the residences along the proposed project that view the proposed alignment. These assemblies shall have a sound transmission class (STC) rating of no less than 35 and the STC shall be high enough to achieve an interior noise level of no more than 45 dBA CNEL. Non -sensitive uses (e.g., bathrooms) do not require such assemblies. 3) Where significant interior noise impacts would otherwise occur, Caltrans shall offer to provide all second -story exterior doors in habitable rooms of the residences along the proposed project that view the proposed alignment with solid -core assemblies that are well sealed with weather-stripping. Traffic The City of Tustin is aware of the agreement between OCTA and Caltrans that resulted in the revision of this study to include unfunded freeway projects in the background conditions thereby creating freeway capacity and easing impacts on city streets. However, we feel that the inclusion of unfunded projects in the 2040 background conditions places a significant burden on city streets until such time the cumulative projects are funded. This is not addressed in the study. While the emphasis of the project is to add capacity on the mainline, it should be equally as important to address the operational deficiencies at the on -ramps and the ramp intersections, particularly the SR -55 Northbound Ramps at Newport Avenue and Del Amo Avenue. The level of service (LOS) for 2020 and 2040 is reported as LOS F with a >80 second delay for the No -Build and all alternatives for this ramp intersection during the PM peak hour. The degree to which the average delay changes per alternative from the No -Build is not disclosed. Without this information, the project impacts cannot be determined. The queuing on the northbound on-ramp itself, as well as particular movements at the ramp intersection, are also deficient, but yet are not addressed in the IS/EA. The queuing deficiencies are presented below for 2020 and 2040. SR -55 WideninglS/EA January 6, 2016 Page 6 Storage No -Build Alt.1 Alt.2 Alt.3 Alt.4 2020 PM Peak Hour On -Ramp 480 520 520 625 520 550 South Right 600 1,055 1,160 1,335 1,340 1,325 2040 PM Peak Hour On -Ramp 480 655 600 680 640 630 South Right 600 1,335 1,335 1,335 1,335 1,325 The extension of Newport Avenue between Edinger Avenue and Sycamore Avenue should be explored to determine if the extension could be a viable improvement to alleviate the deficiencies experienced at the ramp and ramp intersection by allowing an alternate route for motorists to the 1-5 North and 1-5 South. The previous Traffic Operations Report (TOR) identified three intersections in the City of Tustin needing mitigation. This study reflects changes to the background conditions that now include unfunded projects i.e., OCTA freeway projects that add capacity to the freeway mainline. The additional capacity keeps motorists on the freeways and away from city streets which could be the reason that Newport Avenue at 1-5 Northbound On -Ramp is the only intersection needing mitigation for Alternatives 3 and 4. The other two ramp intersections, Newport Avenue at 1-5 Southbound Ramp/Nisson Road and Red Hill Avenue at 1-5 Southbound Ramps, no longer need mitigation according to the performance criteria set forth in the study. The term "minimization" has been coined for these ramp intersections as an acknowledgment that "a relatively larger amount of traffic is diverted to the two locations due to the McFadden design variation" which precludes traffic from McFadden Avenue to head northbound on the SR -55 in Alternatives 3 and 4 Due consideration must be given, in the form of absolute analysis, not some invented "coined" term, for real impacts at these ramp intersections (and also at Newport Avenue/Del Amo Avenue at SR -55 Northbound Ramps) and associated city streets. Underground Utilities Table 2.4.1 shows that overhead 66 kV transmission lines along the east side of Northbound SR - 55 bordering the Cities of Santa Ana and Irvine will be relocated underground. We ask for the same treatment of any line bordering Tustin i.e., as the overhead 66 kV transmission line that crosses the SR -55 from Ritchey Street on the west side to the east side into Tustin. The City of Tustin appreciates the opportunity to provide comments on this project. If you have any questions regarding the City's comments, please call Scott Reekstin, Principal Planner, at (714) 573-3016 or Krys Saldivar, Public Works Manager, at (714) 573-3172. SR -55 Widening IS/EA January 6, 2016 Page 7 Sincerely, Elizabeth A. Binsack Community Development Director cc: Jeff Parker, City Manager Douglas S. Stack, Public Works Director Ken Nishikawa, Deputy Director of Public Works/Engineering Justina Willkom, Assistant Director— Planning Krys Saldivar, Public Works Manager Scott Reekstin, Principal Planner SR:environmental etc\Caltrans SR -55 Widening IS and EA Comment Letter.doc