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HomeMy WebLinkAboutStaff Report 173-10TO: HONORABLE CITY COUNCIL 8 FROM: CITY MANAGER DEPARTMENT: PLANNING AND COMMUNITY ENVIRONMENT DATE: MARCH 15,2010 CMR:173:10 REPORT TYPE: STUDY SESSION SUBJECT: Monthly Update on City Activities Related to the California High Speed Rail Project RECOMMENDATION This report is for infonnation only and no action is required. BACKGROUND Since passage of Proposition lA in November 2008, approving funds for the High Speed Rail connection from Los Angeles to San Francisco, the High Speed Rail Authority (HSRA) has initiated environmental and engineering studies for implementation of the train system statewide. The HSRA consulting team for the San Francisco to San Jose Project Level Environmental Impact Report (EIR) began work in early 2009. On May 18, 2009, the City Council adopted Guiding Principles to provide direction to the City's High Speed Rail Ad Hoc Committee. The Ad Hoc Committee has been working closely with the Peninsula Cities Consortium (PCC) to develop public outreach and education efforts, monitor, and evaluate HSR activities, and to explore urban design solutions that consider community values for the high speed rail project. On August 3, 2009, the Council approved a transfer of Council Contingency in the amount of $70,000 to fund the a HSR symposium (or Teach-in) in September, a two-day design workshop in October and retention of outside expertise to provide peer review and analysis of technical documents including the HSR project alternatives analysis. On January 25, 2010, the Council authorized a transfer of $88,000 from the Council Contingency account to fund the FY 2010 Resources Plan for the Ad Hoc Council HSR Subcommittee for: (1) additional engineering consultant services for the peer review of the Alternatives Analysis for the San Francisco to San Jose HSR project, (2) outside expertise for peer review ofHSR ridership, (3) a Sacramento legislative liaison consultant to represent the City'S interests to the State Legislature, and (4) a one-day symposium on financing of the HSR alternatives and potential HSR station in Palo Alto. CMR: Page 10f6 DISCUSSION This report provides an update regarding activities related to the High Speed Rail project that have been undertaken at the State and City levels since the last report in January 2010. Schedule and Council Reports The schedule established by High Speed Rail staff and its consultants is extremely unpredictable. The Council's High Speed Rail Subcommittee and staff monitor closely changes to announced meetings and other activities, however unanticipated changes frequently occur without much notice. In an effort to provide as much transparency as possible, staff has arranged to broadcast HSR Subcommittee meetings and to make recordings available via the City'S website. Regular broadcasts would supplement twice monthly Subcommittee meetings and monthly Council updates. San Francisco to San Jose HST Project Alternatives Analysis The Alternatives Analysis (AA) Report was scheduled to be completed and ready for circulation and presentation to the HSRA Board on March 4. However, HSRA delayed its released pending review of the AA by the Federal Railroad Administration (FRA) and now anticipates the report will be released on April 1, the next HSRA Board meeting date. However, based on recent experience with HSRA deadlines, this is a fluid situation, with some uncertainty about the actual release date. The AA is an important part of the EIRJEIS as it will incorporate conceptual engineering information, identify and compare the alternatives, and will explain why some alternatives will be retained while others will be dropped from further study in the EIRJEIS. The AA evaluation will be based on planning and engineering at a 2% to 4% level of engineering design. This level of detail may be enough to understand if an alternative can feasibly be constructed and if the alternative might encounter significant environmental, community, economic and construction­ related impacts. The AA will describe the alternatives based on alignment and vertical profile, that is, whether the alignment will be below ground, at-grade, or elevated. The City has retained the engineering firm Hatch Mott MacDonald to conduct an independent peer review of technical conclusions in the AA, such as tunneling feasibility and other below grade options, costs, and railroad operations. Hatch Mott is ready to begin their analysis as soon as the report is issued. The scope of work includes full technical review and participation in meetings with the Ad Hoc Committee, City Council and a community meeting. At the unanimous request of the Ad Hoc Committee, in a letter dated February 24, 2010 (Attachment A), the City has also formally requested that HSRA extend the 45 day comment period for the AA to a total of 90 days in order to provide adequate time for the Council and community to fully understand the complexities of the alternatives that are identified in this major milestone report. During this time, the peer review will be prepared and the City will schedule two community meetings prior to the City Council finalizing its comments on the report. The Ad Hoc Committee further directed staff to request that the HSRA and Peninsula Rail Program (PRP) post the most up-to-date, accurate right-of-way maps for the Caltrain corridor CMR: Page 2 of6 and the Caltrain Station Footprint study on their respective websites to infonn the public about the potential right-of-way implications for the Alternatives Analysis and a potential HSR stop in Palo Alto (Attachment B). Status of Bay Area to Central Valley Program EIR In August 2008, a group of petitioners filed a lawsuit in Sacramento County Superior Court claiming the Authority's Final Bay Area to Central Valley Program EIR (PEIR) violated the California Environmental Quality Act (CEQA) in numerous ways. (Town of Atherton, et aI., v. California High-Speed Rail Authority, et al). The City'S Amicus Curae Brief in support of the petitioners (Attachment C) details the City'S position on the deficiencies in the PEIR. In particular, the brief identifies significant environmental impacts on the Peninsula related to land use compatibility, noise impacts, vibration, and visual aesthetics that were not properly identified, analyzed, or mitigated in the PEIR In August 2009, the Court issued a ruling that the program ErR required reVlSlon and recirculation in the several areas to comply with CEQA related to the San Jose to Gilroy section and vibration impacts, etc. On December 3,2009, the Authority approved resolution rescinding the 2008 certification of the Program EIR and related approvals and directed Authority staff to prepare the necessary revisions to the EIR and circulate them in accordance with CEQA for public comment. The Authority will consider the revised PEIR and the entire record of material before making a new decision to certify the revised Final Program EIR. The Authority is scheduled to release the revise PEIR on March 11,2010 and initiate the 45 day comment period. Staff will work with the HSR Council Subcommittee and prepare comments for Council review and approval in early April. HSRA Business Plan The 2009-10 State Budget mandated that the HSRA submit an updated Business Plan to the Legislature by December 15, 2009. The report updated the cost of the project's Phase 1 into years of construction dollars (rather than current year dollars) and provided an updated financing plan that takes into account Proposition lA, ARRA stimulus funding, and other funding sources that were not known last year. The new Business Plan projects approximately 30% lower system ridership by 2035, higher construction costs, and higher passenger fares based on 83% of the cost of air travel rather than 50% cost. On January 12, 2010, the Legislative Analyst's Office (LAO) released its initial comments to the Assembly Transportation Commission on the 2009 Business Plan. The LAO found the report substantially lacking in detail and cited the lack of infornmtion on risk management, including the risk of incorrect ridership forecasts and the financial risks associated with a flawed funding plan. The LAO further found the timelines very general and potentially inconsistent and identified a potential violation of state law associated with the funding plan. On February 11, 2010, the Mayor sent a letter (Attachment D) to Senator Simitian, Assemblyman Ruskin, and six other local state legislators outlining the HSR Subcommittee's concerns about the Business Plan. The Subcommittee, in conjunction with the Peninsula Cities Consortium, identified a number of deficiencies and flaws in the Business Plan that need to be CMR: Page 3 of6 addressed and rectified before the project proceeds further. Those issues relate to the inadequate and fundamentally flawed ridership study, a questionable financing strategy that relies upon "hoped for" federal funding, and omits key cost elements in the San Francisco to San Jose segment, and a grossly deficient risk management· plan. These issues and concerns were presented by Palo Alto Mayor Burt at the Joint Hearing of the Senate Budget Subcommittee #2 on Resources, Environmental Protection and Energy and Transportation, and the Senate Transportation and Housing Committee on January 21 in Palo Alto. On March 2, 2010, the LAO released new comments on the HSRA budget for 2010-11 and recommended reducing or withholding funding for contract funding, capital land acquisition, and staffing levels requested by the HSRA until further supporting information is provided (Attachment E). Context Sensitive Solutions (CSS) The Peninsula Rail Program adopted Context Sensitive Solutions, a dynamic, two-way collaborative process, to support the active involvement of Peninsula communities in the planning and design of California High-Speed Rail and Caltrain 2025 projects. CSS is a collaborative and interdisciplinary approach that involves all stakeholders to develop a transportation project that fits its physical setting and preserves scenic, aesthetic, historic, and environmental resources while maintaining safety and mobility. CSS helps communities, stakeholders, and project sponsors collaborate to achieve feasible solutions that meet community and project goals. The process offers an opportunity for the community and the design team to define key values, priorities, measures of success, and context considerations. The PRP has prepared a CSS Toolkit which will guide the process, however the release of the toolkit has also been delayed by HSRA. When the toolkit becomes available, staff will be reviewing it and working with the CSS stakeholder representatives from Palo Alto to follow the process. Ad Hoc HSR Subcommittee Activities The Council Ad Hoc Committee continues to meet every two weeks and has focused much of its efforts on working with the other peninsula communities that are potentially impacted by high speed rail. Mayor Burt has appointed Council Members Klein, Price, and Shepherd to serve with him on the committee this year. The HSR project is a multi-year project that will require continuation of the Subcommittee for the foreseeable future. Since Ad Hoc Committees are defined as being of short duration, typically one year or less, it is appropriate to transition the Ad Hoc HSR Subcommittee to a new Standing Committee of the City Council. City Council's agenda tonight (3/15) contains a consent calendar item (#7) which converts the Subcommittee to a Standing Committee. Mayor Burt also represents Palo Alto on the Peninsula Cities Consortium (PCC). The PCC continues to engage various community groups organized around the potential impacts of high speed rail to coordinate local, statewide, and national legislation. The PCC cities are also considering jointly sharing costs for technical expertise, as well as considering entering into a Memorandum of Understanding with the Peninsula Rail Project. CMR: Page 4 of6 Sacramento Legislative Liaison Update The City has retained Ravi Mehta of Capitol Advocates to provide legislative liaison and advocacy services in Sacramento on High Speed Rail issues. Mr. Mehta is tracking all legislation that directly or indirectly impact the HSR project. Mr. Mehta has provided a legislative update (Attachment F) on the most recent legislation of concern. Of particular concern are a series of bills that have been introduced that would exempt projects selected by the Business, Transportation, and Housing Agency from judicial review pursuant to the California Environmental Quality Act (CEQA). Since CEQA legislation was enacted into law in 1970, and required state and local agencies to identify and disclose the significant environmental impacts of their actions and to avoid or mitigate those impacts, if feasible. CEQA statutes have assured full public scrutiny and input on the environmental impacts ofprojects and judicial recourse. At the direction of the HSR Subcommittee, staff is working with Capitol Advocates to oppose any legislation which would diminish or circumvent the current protections or in any way create exemptions from the California Environmental Quality Act (CEQA) and court review for major infrastructure projects each year, including but not limited to the California High Speed Rail Project. Staff will prepare letters to our local legislators recommending support, opposition or continued monitoring of each bill. Next StepslPlaJ:Jl1ed Activities The schedule for local PCC and City Council meetings is provided as Attachment G. The next milestones for the Project are: Issue of Bay Area to Central Valley Program EIR -March 11, 201 0 Issue of Alternatives Analysis Report -early April 2010 Draft EIRJEIS -First Quarter of2011 Final EIRIEIS End of2011 POLICY IMPLICATIONS The recommendations in this report are consistent with existing Council policy direction related to the California High Speed Rail Project. ENVIRONMENTAL REVIEW The recommendations in this report do not constitute a project requiring environmental review under the California Environmental Quality Act. ATTACHMENTS A. February 24,2010 letter to HRSA re Extension of Comment Period for the San Francisco to San Jose HST Project EIR B. March 2,2010 letter to HSRA/PRP re Caltrain Corridor Right-of-Way Maps and Station Footprint Study C. Amicus Curae Brief D. February 11,2010 letter to State Legislators re HSR Business Plan CMR: Page 5 of6 E. Excerpt from March 2,2010 Legislative Analyst's Office 2010-11 Transportation Budget Analysis F. Legislative Update Memorandum from Capitol Advocates G. Letter dated March 3,2010, to Mayor Pat Burt from Peninsula Rail Program PREPARED BY: ~a...--£<&u..aJ GAYLE IKENS APPROVED BY: CITY MANAGER APPROVAL: CMR: Page 6 of6 ATTACHMENT A February 24, 2010 Dominic Spaethling, Regional Manager California High Speed Rail Authority 925 L Street, Suite 1425 Sacramento, CA 95814 ~~J:x Q!_r~<?_M!Q Office of the City Manager FAX Transmittal 916-322-0827 Re: Request for Ninety Day Comment Period for San Francisco/San Jose HST Project Alternatives Analysis Dear Mr. Spaethling: The City wishes to thank you and your project team for meeting with the City Council High Speed Rail Subcommittee and community members on February 9, 2010 regarding the pending release of the Alternatives Analysis for the San Francisco to San Jose Project EIR/EIS on March 4, 2010. The Subcommittee looks forward to the opportunity to provide input to the California High Speed Rail Authority on the Alternatives Analysis. The Subcommittee finds, however, that the limited 45 day comment period is highly constraining for review and evaluation of such a major report. By unanimous action on February 16, the Subcommittee voted to request that HSRA extend the comment period by approximately forty­ five (45) days, for a total 90 day comment period. The extended period is necessary to 1) fully understand the complexities of the alternatives that are identified, and 2) better inform the Palo Alto community about the content and findings of the Alternatives Analysis, including holding 2 community meetings after the March 15 presentation by HSRA staff to the City Council. The City believes this outreach will best serve the community of Palo Alto and the HSRA by providing more cohesive and thoughtful comments on the Alternatives Analysis and its implications for Palo Alto. Thankyou for considering this request, and please let us know as soon as possible whether the deadline wiIl b~ extended. If you or others have questions, please feel free to contact me or City Manager James Keene. l:£:L STEVr;:~~~ Deputy City Manager cc: City Council Mehdi Morshed, HSRA Robert Doty, Peninsula Rail Project James Keene, City Manager Printed with soy-based iolt-=. no wor'J.., TPrvdpo nan¥f nrnrpssed without chlorine p.G. Box 10250 PaloAlto,CA 94303 650.329.2563 650.325.5025 fax ATTACHMENTB March 2, 20 I 0 Dominic Spaethling, Regional Manager and California High Speed Rail Authority 925 L Street, Suite 1425 Sacramento, CA 95814 Ci~ of Palo Alto Office of the City Manager FAX Transmittal 916-322-0827 . 650-508-6365 Robert Doty, Program Director Peninsula Rail Program 1250 San Carlos Avenue San Carlos, CA 94705 Re: Caltrain Corridor Right-of-Way Maps and Station Footprint Study Dear Mr. Spaeth ling and Mr. Doty: The City of Palo Alto wishes to thank you for directing us to the link on the Caltrain HSR Compatibility Blog (http://caltrain-hsr.blogspot.com/) containing the 2007 Caltrain corridor right-of-way maps. This link has also been posted on the CAARD website. However, in order to ensure that this information is accurate and valid, we request that the Peninsula Rail Program (PRP) verify the validity of these maps by posting them officially on the Caltrain PRP and the California High Speed Rail Project (HSRA) websites. Ifthese are no longer current, we request that the most up-to-date maps be posted on these websites. On a related matter, Palo Alto requests that the PRP post the documents related to the Caltrain Station Footprint Study on its website as well. This infonnation is not available online at the present time. Although this study only covered San Mateo County stations, it would be valuable for the City of Palo Alto to review in anticipation of the upcoming HSRA station study for a mid­ peninsula high speed train stop. Thank you for your attention to these requests and we look forward to a favorable response. Deputy City Manager cc: City Council James Keene, City Manager HSR Ad Hoc Committee l/rinted with soy-based inks on 100% recycled paper process~d without ch10rine P.O Box 10250 Palo Alto, CA 94303 6.'30.329.2563 650.325.5025 fax ATTACHMENT C I ARTHUR. F. COON (Bar No. 124206) ~cC!l,com . 2 ICRlSTlNA DANIEL LAWSON (Bar No. 221131) 3 ~.WRBGALIA Exempt from Filing Feu Pursuant to Government Code. § 6/03 A Professional Law Corporation 4 1331 N. California Blvd., Fifth FJoor Poat Omce Box 8177 S Walnut Creek, California 94596 . ToJ~e:92S93S 9400 6 FacsJl'oiJe: 925 935 9400 1 Attorneys for Amicus Curiae CITY OF PALO ALTO ~LED/E1tDORSED '-~~ MAY -1 2009 A J By: _---J.T_~C=AL:2AU~S~TR~t'IJ:.~'f/-- ~ ____ ~~=~I~o/=CIU='k~ _____ ~ 8 9 10 11 12 13 24 15 16 17 18 19 10 SUPBRIOR COURT OF THB STATE OF CALJPORNIA COUNTY OF SACRAMENTO TOWN OF ATHERTON, a Municipal Corporation, PLANNING AND CONSERVATION· LEAGUE, a California ftoupJOfit co~ration, CITY OF MBNLO . PARK, •• MuDicipal Co~ration, TRANSPORTATION SOLUTIONS DEPBNSB AND EDUCATION FUND, a California nonpofit corporation, CALIPORNIA RAIL POUNDATION, a California nonprofit corpofllioft. and SA YRAIL ALLIANCE, • Califomia nonprofit ~ation, and other similarly situated entitles, Petitioners and Plaintiffs, v. CALIFORNIA HIGH SPEED RAIL 21 AtmlORlTY, a public entity, and DOES 1-20, 22 23 24 25 26 27 28 CO'A'O'0717Uf14U Respondents and Defondant$. ~cNo.34-2008-80000022 AMICUS CUIUAE BRIEF OF THE CITY OF PALO ALTO IN SUPPORT OF PETITIONERS' VERIFIBD PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR1NJUNCTIVB AND DECLARATOR.Y B.BLIEF I BY FAX Dato Complaint Filed: August 8, 2008 Trial Date: May 29, 2009 AMICUS CURIAE BRIEF OP THE crrv OF PALO ALTO , TABLE OF CONTENTS IN'TRODUCTION .................................................................................. , ••••.•.•...•...................•.. 1 RELBV ANTPBNINSULA ... RELA TED FACTS AND BACKGROUND ......................... 2 .ARGUMENT ..... , ................... , ...................................................... ~ •••••........•. J> .......................... 4 . A. THB SECOND PBIR IS INADEQUATE. AS IT FAILS TO COMPLY WITH CBQA'S MANDATORY REQUIREMENTS FOR ElKS ......................... 4 1. Program BIRs Must Ct)ver The ·Same General Content as Project Bma .................... ~ ................................................................................... ~ ....•... 4 2. If An lDad~uate Program BIR Is Certified, Its Inadequacies Wi11 Infect AU PUIuIe Tiers or Bnviromnental Review ..................................... S B. THE SECOND PBIR's PROJECT DESCRIPTION IS INADEQUATE ............... S C. THE SBCOND PEIR. DOBS NOT ADEQUATELY IDBNTIFY. ANALYZB, OR MITIGATB THE PBNlNSULA-RBLATBD EN'V'mONMBmAL JMPACfS C;>P ~ HST .+ •• , ..................... t •••••••••••••••••• ~ ••••••• 6 I. The Project WiIIlWuIt In Sipificant Land Use Compatibility hnpacts Not Properly Identified, Analyzed. or Mitipted In the s.econd PBJR.. .......................................................................... t .. t ............................................. 8 2. . I The Project Willa_ul. In SipificlI1t Noise Impacts Not Properly . Identified, Analyzod, or Mitigated In The SecondPSIR ............................ 9 3. 4. The Project Will Result In Sipificant Vibration Impacts Not PIoperJy Identified, Analyzed, or Mitigated In the Second PEIR ............. I 1 The Project Win R.sult In Sipificant AestbotirJVisual Resources Impacts Not Properly Identified, Analyzed. or Mitigated In the Second. PBlR. ••••. ,. .............................................................. , ...••.••.•..••.•........• 11 CONCLUSION ..................... " ......................................... " ..••.••.• , ......................................... " ...... 12 .j. AMICUS CURIAE BlUm: OF nu~ CITY OF PALO ALTO 1 2 3 4 . TABLE OF AUTHORITIU PaeN> AI Larson Boal Shop, Inc. v. Bd. 0/ Commissionera 0/ the City o/Long Beach 5 (1993) 18Cal.App .4th 729 .. , ................................................................................................. , .............. 4 6 7 8 9 Berkeley Keep Jets Over the Bay Comm. v. Board 01 Port Comm 'n (2001) . 91 Cal.App.4t111344 ................................. * .................. ~ ................. I ••••••• '"' .......................... ~ •••• ~ •••••••• 10, 11 Co,?, C~~~;dCfft~~.~~~~~~ .. ~~~:.?~ .............................................................................. S. 6 In ,e BtI)",Delta Programmalic EnvironmenlalImpaet Report Coordintlled 10 Proceedings (2008) 43 Cal.4t111143 •.... ,., ............ , ........... , .. ,. ............................................................................................... , .. 7 11 12 13 14 15 16 K08~; &~;~:t fr..~~~!~~.~~~~~ ........................................................................................... S Laurel Heights Improvement Assn. v. Regents 0/ the University 0/ California (1988) . . 47 Cal. 3d 376 ................................................... "' ............................. " ........ , ••..•..••.. , .. " .. , ............................. 4, 7 Stanislaus Natural Heritage Project v. County of Stanislaus (1996) 48 Cal.App.4th 182 ......................................................................................... 1 ......................... 7 17 IIAIVIIS 18 PubUo Resources Code 19 Sections 21000 et seq ...... , .. , ....... , ...............................................•...•... t ................................................. 1 . Section 210113.9 ........................ "' .......•..•• , .................................................... ~ ... " ..••..••...•..••••••......• (:) 20'" "Sect jOn 21()9:2.4 ..... ; ••.. · ................................ ~ .••...•..•••.••.. t ............. , ............................................... " •••••• 6 Section 2J093_ subd.(a) ..................................... " ........ ~ ........................ t ••• "" •••••••••• ., •••••••• , .................. 4 21 Section 2100'4. suM (a) ......... : ........... , ................................................................. ., ............................ S 22 23 24 25 26 27 28 PDlIBaUTHORITIES 14 Califomia Code of Regulations Section IS064, subd,. (d)(I) ...... ~ ................. , ................................................. , ..... : ............................. 10 S~tion 15083, suM (b) .................................................................................................... : ........... 6 Section 15086 ............ , ................................................................................................................ , .••.•. 6 Sections 15120 -lS132 •••••..•••••..• , •.•......••••. , ....................................................................................... 4 Section 15125. subd. (d) ....................................................................................................... 8.9 Section 15126.4, subd. (a)(I)(O) ............................................................................................ l2 Section 15143 ......... "'._ .............................. " ..•.... , ................. " .......... , ............................... , ....... 'I> ............ ~ .. 10 Section 15144 ............................ ,. ..................................... , ....................................... _ .... , ......... : ........ " 9, 11 ·ii· . AMICUS CURIAE BlUEr OF THIl CITY OF PALO Al.TO 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 fO 21 22 23 24 25 26 27 28 TABLE ~F A!!jORlTIES contm ) hal') Section 15152, suttd. (b) ................•.•...••.....••.••••..••.••...•..•.•.•.•••.•.....•.•....•..•........•...•....•.•.••..••.••• 7 Section lS16S ................. ~ ............................................................................................................. I SCction 151·68_ 8UW. (a) •.. , ........................ " ........ " .••.•...•..••...••...•... ,. ............................... t ••••••••••• t1.4 Section ·15169, subc1.(b.)(4) ........ ".'# .... iI! .......................... t ••••••••••••••••••• .,.1> •••••••••••••••••••• , ••••••••••••••••••••••••••• 4 Sec:tion 15382 •..•.........••••........ : .......................................... , .......................................................... 10 Section 1.5384 .•.•.....• ~ .................................................... " .. " .......................... ~ ..... ,' ..... It •• 1t ••••••• , •••••••••••• S COPA\47107\7I1fiMfl -lIi- AMICUS CURlAB BRIEF OF THB CITY 0' PALO ALTO 1 I. INTRODUCTION 2 In 2004, Respondent CALIFORNIA HIGH SPEED RAIL AUIHORITY 3 ("CHSRA" or "Respondent'') first attempted to comply with the Califomia Bnvironmental 4 Ql.l8lity Act ("CEQA"; Pub. ResoW'Ce.a Code, f§ 21000 et seq.) through a Draft Systemwide 5 Prosram BlRIEIS (the "2004 PEm!,), which pwported to analyze the significant environmental 6 impacts of a proposed high-speed train system (the "JIST' or "Project"). When legal deficiencies 7 in the 2004 PBJR were identified, instead of correcting those deficiencies, CHSRA took the easy 8 . way out -it simply deleted. the non...compliant sections of the 2004 PBJR. and tabled its 9 consideration of the portion of the Project for which CEQA review was consequently incomplete • . 10 Then, in an interesting and novel twist on CBQA~s tieringprocess.1 CHSRA 11 directed its staff to prepare a second~ program-level onvironmonta1 impact report (the "Second 12 pBJRt,) to evaluate the previously deleted portions of the Project, and identify a preferred 13 alignment for tbe HST "within the broad corridor betWeen and including the Altamont Pass and 14 the Pacheco Pass ... connecting the San Francisco Bay Area to the Central ValJey and project level IS studies considering preferred alignment and station locations'" (AR 0OOO209i However, when 16 the draft Second PElR was 11"easOO, careful review of the document revealed that CHSRA had 17 . expanded its scope to include the portion of the HST that would traverse the San Francisco 18 Peninsula (the "Peninsula''). Like the 2004 PE~ the Second PBIR fails to comply with CEQA's 19 20 21 22 23 24 2S 26 27 28 mandatory enviromncntal review requirements. The question presented in, this case is whether CHSRA complied with its mandatory duty to scrupulously foHow CEQA. Without question. it did not. More detailed infonnation was available to CHSRA regarding the impacts of the Project on the Peninsula. and it , AlDicul PALO ALTO caa ODd no legal bub or au.borizatlon In CEQA or .... e CEQA GuideD ... for tile pnparatlo. of. lecoad, Pl'OJI'a.levei ElK rer tile ..... e project. Section 15168 of the CEQA Guidelines provides that: "A pl'OJl'8lll BIR is an EIR which may be prepared on a series of actions that can be characterized as one large project. •. " (14 Cal. Code Regs., § 15 168, subd. (8).) Here, instead of preparing a single program BIR for a series of actions that can be characteri2ed as _large project~ the CHSRA has spUt the Project into two separate parts, and has prepared a program BIR. for each separate part. This latctal environmental review frocess is unauthorized by CEQA. (See also 14 Cal. Code Regs., § lSI6S.) The Administrative Record prepared by Respondent is cited herein in the fonn "AR Xnnnnnn." X indicates the section, and nnnnnn indicates the page nwnber. COPA".,eo1\166S49.l .}. AMlCUS CURlAB BRIEf OP THE errv OF PALO ALTO 1 was possible for CHSRA to obtain it. This infonnation was absolutely necessary for CHSRA to 2 make a fully informed decision about the environmental consequences of its action. 3 Tile ~DseqlleDees of ano"iIll CHSRA to proceed with the Project based 00 a 4 delicleDt progfa. BfR .re substaatial. Because C.BQA autllorJzes f.ture ovir.melltal S review to Uer off of program level docllmeDtI, If tbls Court does Dot reqaire Secoad PEIR's 6 defideades to be corretted, those deRcleaeles wJlllDfeet all future levels of eDviroDmeatal 7 review for tbe Project. 8 II. RlLEV ANI PENINSULA-RELATED FACTS AND BACKGROUND .9 CHSRA prepared md circulated the 2004 PSIR to evaluate three transit system 10 alternatives: (1) a no project alternanve. (2) a highway andaitpOrt expansion alternative, and (3) 11 the HST. (AR B003869.) In response to comments resardinl the adequacy of the 2004 PSIR, " 12, CHSRA deleted an entire section &om the 2004 PBIR.. (petitioners' Openina Brief ("PBtl ), 6: 1 S- 13 18.) This deleted section had defectively evaluated only one route for the HST ,between the 14 CentraJ Valley and the San Francisco Bay Area: the PachecQ Pass alignment. (PB, 6: 6·22.) 15 Instead oftakins the extra time to study any alternative route. CHSRA simply deferred complete 16 enviromnental evaluation oltho Central Valley to San Francisco Bay Area alignment to a later 17 date. (AR 0000209.) J 8 NotwithstandinS that CBQA docs nQt contemplate the preparation of multiple 19 program*level ElRs for tile same "large project," in 2007 CHSRA prepared and circulated the 20 Second PEIR for the portion of the proposed Project previously deleted from the 2004 PBIR. 21 Consistent witb the direction CHSRA provided at the 'time the 2004 PBIR was 22 certified, and consistent with the Notice of Preparation, many interested parties believed that the 23 limited purpose of the Second PElIt was to evaluate environmental impacts associated with the 24 Pacheco and Altamont Pass aJignments. (AR. G000209.) This belief was confmned by reference 2.5 to the "Bay Area'to Central Valley Conidor" map included as Figure 1.1 ~ 1 in the final Second 26 PEIR. (AR B003870.) Th~ a hatched area between tbe Pacheco and Altamont Passcs was 27 described as the "Possible Alignment Area. tr (Ibid.) This batched area did not oxtend up the 28 Peninsula into the City and County of San Francisco. Notably, even the brief filed by CHSRA COPAIA'80'1\766849.2 AMICUS CURIAe DRlBF OF nlE CITY OF PALO ALTO 1 evidences a general understanding that the purpose of the Second PEIR was to evaluate 2 environmental impacts associated with the Pacheco and Altamont Pass alignments. (See 3 Respondent's Opposition Brief ("RB''), I! 12--13 ["The Authority used a fll'st~tier, program EIR to 4 focus on the br.~ad differences between the Altamont Pass and Pacheco Pass in order to choose S betWeen them. '1; RB, 4: 16-19 [" ... The Authority directed staff to prepare a new prognun EJR 6 focused on the northern mountain crossing. rr'; RD, 12: 11 .. 12 (pmpose of second program EIR. 7 was 'fto choose the northern mountain crossing to connect the HST between the Bay Area and the 8 Central Valley:'].) When the drift Second PEIR was released., CHSRA held eight public 9 hearinas -none ofwmcb were located in PALO ALTO or other Peninsula cities. (See RB, S: 13 .. 10 14, th. 1.) 11 Upon a close and detailed review of the text of the volwninous Second PEIR., it is 12 . clear its scope is much greater than believed. According to the 8eJf~deseribed "Alternatives" 13 section of the Second PEIR., the document analyzes the environmental impacts associated with 14 «[sJix Unear geograpbic belts or bands being considered for the HST system that connect different IS pw·ofthe study region." (AR B003898.) One of these "belts or bands·' extends up the 16 Peninsula from the City of San Jose into the City and County of San Francisco. (See AR 17· BOO3934.) Actual station locations on the Peninsula were identified on FiguJ'C 2.5-1, including a 18 potential station within the jurisdictional boundaries ofP ALO ALTO. (AR BOO3940.) The "San 19 Fnmcisco to San Jose'· alignment and station locatioDB options were described in detail as 20 21 22 23 24 25 26 27 28 "(oUows: COfA'of710T\166.4' 1 • Cal1rain AJipnent (Shgred .. Use Four .. Track); From San Francisco, this alipment alternative would follow south along the Caltrain rail alipment to Dumbarto~ and from there to San Jose. This alisnment assumes that the HST system would share tracks with Caltrain oommuter trains. The entire alipment would be gr.ade separated. Station location options would include a station in the lower level of the proposed new Transbay Transit Center in San Francisco or a station at 4th and King Streets, a station in Millbrae to serve SFO, and a station in either Redwood City or Palo Alto. The Caltrain shared-usc alianment would take advantage-of the existing rail inftastmQturc and would be mostly at grade. • I_sbU Ttansit Cm1eri The potential station location would serve ahe Caltrain sharedwuse alignment. a downtown terminal station. • 4th and Kins: This potential station location would serve the Caltrain shared-use four-track alignment as a downtown tennioal station. .3- AMICUS CURIAE BRIBF OF THB CITY Of PALO ALTO 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 • MUlbm: This potential station would SClVe as a connection with SFO. • Redwood City: 1bis potential station loCation would provide accC8sibility and serve the population between San Jose and San Francisco, • Palo AIm: This pOtential station location would provide accessibility and serve the population between San Jose and San Francisco. (AR BOO39S3·BOO39S4; see also AR BOO3958.) Despite receiving nUDlCfOUS letters pointing out that the Second PEIR failed to comply with many of CEQAts II'l&ndatory requirements, the final Second PEIR was certified by CHSRA on July 9, 2008. (AR AOOOOO2.) III. ABGUMENT A. THE SECOND PElR IS lI!APEOUATI, AS ITFAJLS TO COWLX WITH ClQA'S MANDATORY RlOYIREMENTS Ji'OR EIRS •. 1. '"&ram Elas MUlt C.ver 'he Sail!! Geller.1 Co.,,,, •• Despite w.bat CRSRA would have the Court believe, CEQA '. c •• teat requiremeDts for progrllm ElBa are DO dlffereDt diu CEQA'. eODteDt requtrements for pIVIJed EIRs. (See 14 Cal. Code Regs., §f 1 S 12() -1 S 132; AI Larson Boat Shop. Inc. v. Bd. of Commissioners of the City of Long Beach (1993) 18 CaI.App.4th 729, 741 ["All BIRs muSlcover . the same general content.,,].)3 A program EIR is simply a $pOCiaJ type ofBIR, "which may be prepared on a series of actions that can be characterized as one large project. n (14 Cal. Code Regs., § 15168, subd,(a).) Program .ElRs allow government agencies -such 88 the CHSRA -to "consider broad paUcy alternatives and program wide mitisation measures .. ,n (14 Cal .. Code Regs., § IS169, subd.(b)(4).} The purpose of the optional plV&f8II1 EIR process is to simplify later environmental review, (See Pub. ResoUJCos Code, § 21093, subd.(a); AI Larson Boot Shop. Inc. v. Bd. of Commissioners of the City of Long Bedch, supra. 18 Cal.App.4th at 741.) 3 While the courts have not detennined whether the Ouidelhiea are ni!gulatory mandates or only aids in interpretiDB CEQA, " .•. courts should afford great weight to the Guidelines except when a provision is olearly unauthorized or enoneous under CBQA." (Laurel Heiglltslmprovemetll Assn. v. Regents of the University ofCalifomkl (1988) 47 CaI.3d 376, 391, fit. 2; sec also nneyard ArflQ Citizens for Responsible G1'OW11t. Inc. v. City of Rancho Cordova. supra, 40 Cal.4th at 428t fn. 5.) COPAW7SOn7&5I".2 -4- AMICUS CURIAB BRJB.P OF me CITY Of PALO ALTO 1 2. HAD Inadequate 'rolEam ElK Is CertU1edt Its IDgdeqyasl!s .' 2 Wig lar". All Future Tiers Of EgyJroPDlFata. RevlllL 3 CEQA contemplates a If tiered" environmental r~view process, whereby agencies 4 can ~opt program EIRs focusia,s on the ''big picture" and can then use streamlined CEQA S review for future projects that are consistent with the already reviewed biS picture plans. (Koster 6 v. County of San Joaquin (996) 41 Cal.App.4th 29, 36.} Later prepared EIRs fer .p.cllle 7 preject. are exeused from repeating the analysis of the eDvitoamea.lllsDes aDalyzed. .. tb. S previous prOiram EIR. (Pub. Resources Code, § 21094, subd. <a); 14 Cal. Code Regs., § 9 15384.} By using CEQA's tiered environmental review process, CHSRA can limit fUture, site· IO specific environmental review by excluding cm:tain issues ftom analysis in later CEQA 11 documents. 12 The importance of a proper CBQA tiering process in this case is paramount. 13 Because future site-specific BIRs wi)) necessarily be more limited in focus than the Second PEIR, 14 and will rely upon the Second PEIR for analysis of certain issues, it is vital that the Second PEIR 1 S . be legally adequate and comply with all of CEQA '8 mandatory requirements. (Se6, e.g., Koster v. 16 County of San Joaquin (1996) 47 Cal.App.4th29, 41-42.) IfCHSRA is to adequately analyze 17 the site-specific environmental consequences of the Project in the future, it must remedy the 18 deficiencies and inadequacies of the Second. PElR, so thosc problems are not allowed to infect 19 future CEQA documents. 20' B. THE pCON» PEIR's Paon;cr DESCRIPTION IS 21 INAPEOVATE. , 22 "An &(leurate, stable, and finite project description is the sine qua non of an 23 infonnative and legally sufficient BIR.. t. (County olInyo \I, City of Los Angelea (1977) 71 24 Cal.App.3d 18S. 193.) Here, CHSRA (eferred to the Project conrrid.ered in the Second PBIR 25 differently in different parts of the Second PBJR. In fact, CHSRA also referred to th~ Project 26 differently in many of the documents prepared in comection with the Second PBIR. 27 Respondent's counsel also refers to the Project differently throughout its brief. As a result, the 28 Second PEIR's project description is unstable and inadequate. AMICUS CURIAE 8R1BF OF THE CITY OF PALO ALTO 1 Pursuant to Resolution No. OS-<> I of CHSRA, the Second PEIR was supposed to 2 . analyze: C' ••• 8 preferred alignment within the broad conidor between and including the Altamont 3 4 S 6 7 8 9 10 11 12 13 Pass and the Pacheco Pass for the HST SyStem segment connecting the San Francisco Bay Area .' to the Central Valley ... H (AR GOOO209.) The document that resulted -the Second PBIR ... does not focus exclusively on this iuue. Instead, the Second PBIR also identifies a specific alignment . for the HST on the Peninsula., and selects specific station locations on the Peninsula. The first time a reader of the Second PBIR becomes aware of the true scope of the project evaluated in the Second PBIR is upon review of the "Alternatives·' chaptor. In that section, the Peninsula alignment is revealed for the first time. (See AR B003898·AR B0039'77.) The repeated inconsistencies in describing the project evaluated in the Second PEIR. confused the pubJic and local agencies. thus vitiating the usefulness of CEQA' s environmental review process. (CountyofJnyov. CityoluaAngelestsup1'a, 71 Cal.App.3dat 197-198.) "- The seneral public was further coDfUaed by the fact that Dot ODe of the seopibl 14 . SessiObS was beld 18 aDy oftbe Pealasula dUes between San Jose ad Sao PraDcIKo. (AR 1S 8000002.) Additional misunderstanding resulted when Dot Obe of the plabDe hearlDII OD the l(i dnft SKond PEIB was beld OD tbe PeDta.ala. (AR BOOIOS3.) Santa Clara County and all .7 . Pea •• ul. cities were eODspicaously abseat from the Outr,.eh Before Drift Progn .. J 8 EIRIEIS process. CHSRA also did not consult· with local agencies located on the Peninsula 19 during the Icoping process. (AR Booms.) 20 2] 22 13 24 2S 26 27 28 c. THE PCQNO,PEIIDON NOT AQEOUATILXWEN1'llf. ANA!.'DI. OR MITIGATE THE PENINSULA-RELATED ENVIRONMENTAL IMPACTS OF THE HSI. Respondent flatly contends that it need not fully identify, analyze, or mitigate significant environmental impacts that the HST will cause on the Peninsula because the Second • Section 15083 of the CEQA Guidelines suggests that early consultation with local agencies is an effective way to resolve concerns of affected aaencies. (14 Cal. Code Regs •• § 15013, aubel. (b).) Further, section 15086 of thoCEQA Ouidelina requires a lead agency to consult with and request comments on a draft EDt tiom all localaJeBcles which have jurisdiction bylaw with respect to the project, or which exercise authority over resources which may be affected by the project, and any city within which the project is located. (14 Cal. Code Rep., § 15086.; see also Pub. Resourees Code, §f 21083.9, 21092.4/requiring consultation with toca1 agenoies in cormectioD wi1h taU projects and projects 0 reponal or statewide signi(acance).) COPA't4,"'I\1I6I49.2 . -6- AMICUS CURIAB BRIU OF THE CITY OF PALO ALTO ' 1 PEIR is a progr'ant EIR, Respondent indicates it was "nol ready to tackle [] site-specific issues," 2 (RB,36: 19) despite that it was ready to approve (and actually did approve) a specific well- 3 defined PeninsulaaIignment, jne1uding specific rail station locations. (See AR AOOOOOl- 4 AOOOOO4.) Contrary to RC8pondent~s unsupported contention that applicable case law permits S CHSRA to defer proper consideration of environmental impacts if the "level of detail" required to 6 be considered is "overwhelming/' (RB~ 36: 19-20) where speeUle sites bave bee. selected for 7 proposed develOpment. aud wlatre ially ... of eavlroDmeDtal.lmp8etll. bot .. practicable 8 .ad feasible, CEQA wlthout eseeptlcm requires sucla analysts to he cond"cud. (In re Bay- 9 Delta Programmatic, Environmental Impact Rtlpon Coordinattld Proceedings (2008) 43 Cat4th 10 1 t 43, It 73; see also Stanislaus Natural Htlr/lagtl Project v. COURty 0ISton/slous (1996) 48 1 t Cal.App.4tb 182, 199.) Because CHSRA actually selected a Peninsula alignment, and station 12 locations, it was required to fully identify. analyze. and mitigate all Peninsula-related ] 3 environmental impacts from that specific alignment and those specific stationa. 14 Respondents specifically contend that a properly prepared program EIR. contains 15 ''more limited analysis and mitigation·' than a project BIR. (RB,34: IS.) Such limited analysis is 1 ~ not authorized by CEQA or by the CBQA Guidelines. 'Tierml-does Dot .:leus. the lead aleney 17 from adequately aa81yllal reponable foreseeable slpIDeant envJroDme.t.1 effects of the 18 proJect ... •• (14 Cal. Code Regs., § 15152. subd. (b).) ··An BIR m1.lSt include detail SUfficient to 19 enable those who did not participate in its preparation to understand and to consider meaningfully 20 --the issues raised by the proposed project." (Laurel Heigbtslmprovement Ass 'n v. Regents of the 21 University of California, supra, 47 Cal.3d at 405.) 22 The Second PEm ~ identify the specific location of the proposed HST alons i3 the Peninsula, and actually identifies station locatiOD8. These are nol simply broad or seneral 24 ffpolicY·decisions, but actual pJans for a specific rail system. The decision made by CHSRA on 25 July 9,2008 was a material step in selectins the Project', Peninsula route and station locations. 26 (AR AOOOOOl.AOOO004.) Because specific sites have been selected for proposed development, 27 and because analysis oftbe environmental impacts associated with the identified sites and 28 . alignment is practicable at this time, CBQA requires Buch analysis to be conducted. (;OPA\l7101\7Ge •• u ·7· AMICUS CUlUA6 BIUBP OF TH8 CITY OF PALO ALTO • 1 1. The PEgl. Will Res,lt la SlgplfieJpt Laad Use «;2lDPatibJljty 2 (mpa. Not PrGperly IcJgtlfled, AIlaJrad, or MIJ'cattd Ip tlJe Semd rlIR. 3 Two Peninsula cities submitted lengthy comments regarding the sipifieant land • 4 use compatibility impacts that would result from the HST. (See. e.g., AR B006S30, BOO6S17.) S Notwithstanding these identified land use compatibility impacts, the Second PBIR concluded 6 there would be KJliJh"land use compatibility because the alignment was "[c]ompatible with 7 existina Caltrain corridor!' (AR B004184-B00418S.) Apparently, CHSRA determined that the 8 only issue with respect to land use compatibiHty is whether or not a train already exist. in the ·9 area. CBQAdemands much more. l() Section 15125(11) oithe CEQA Ouidelinesmandates that: "An Em. shan discuss 11 any inconsistencies between the proposed project and applicable general plans and regional 12 plans." (14 Cal. Code Regs., § 15125, subd.. (d).) Thepu!pose of this discussion is to enable a 13 lead agency to find wa)lS to modify a project to reduce inconsistencies. 14 Remarkably, although the Second PBIR says it includes a discussion of potential 15 inconsistencies with land use plans, no such discussion is actually CODtained in the Second PBIR. 16 (AR 8004164.) Review of the Second PElRreveals that CHSRA only considered the existing 17 land use designations of property within the Peninsula alignmeal and did not consider other 18 glaring incompatibility and inconsistency issues. (AR B004165.) In fact, the Second PEIR' s 19 woefully inadequate land use compatibility discussion for the entire Peninsula alignment is ZO. . Qantained in the followjpg thrc:e (3) selltences: .21 22 23 24 25 The San l7ranciaco to Dumbarton alignment altomative would be hishly compGtlble with existing land US" because it would be conSIrUcteci primarily within the malin, Caltrain conidor. Grade separatiODS along tho alisnm_ altomative would entail the conversion of residential and nonresidential property ... The land use compatibility for the Dumbadon to San lose aJipment alternative would be the same as the San Francisco to Dumbarton alipment alternative. 26 (AR B00419S. emph. added.) This quotation makes clear that CHSRA failed to sufficiently 27 evalUate the impact of applicable land use plans. CBQA does not mefely require an evaluation of 28 whether a project is consistent with existing land uses -CEQA also reCluires aD evaluatioD .f CO'A .... 71107\'I1I6 ... 9.2 -8- AMICIJS CURIAE 8R1BF OF 'mE CITY OF PALO ALTO 1 . whether a project Is consisteDt wltb a,pUcable "ad useplR",. (14 Cal Code Regs., § 15125, 2 subd.(d).} 3 For the Peninsula station locations, the Second PEIR's analysis is similarly 4 deficient. (ARB004195.) Again, the Second PBIR answers the question whether the HST is S consistent with existing land uses at the separate station sites, but faUs entirely to address the 6 additional question CBQA requires to be answered -whether the project is cOnBistent with 7 applicable land use plans. (14.) 8 CHSRA simply ignores that CBQA requires it to "use its best efforts to find out 9 and disclose an that it reasonably can" in its EIR. (14 Cal. Code Rep., § 15144.) Ataminimum, J 0 CHSRA was required to identify the general and regional plans applicable to the Project on the 11 Peninsula,' and to discuss m inconsistencies between those plana and the Project. CHSRA', 12 failure to include such a discussion in the Second PBIR renders the document useless for 13 infonnational purposes jn this regard, and inadequate under CBQA. 14 Perhaps even more alannjng for the public and Poninsula4 area officials, is the 1 S manner in which tho Second PBIR unlawfully proposes to limit analysis in future, ~ond-ticr, 16 project-specific environmental documents. As set forth on page 3.7 .. 42 of the Second PBIR: 17 "Pro;ect·level review wOIlJd consider consistency with existing and planned land usc, 18 neighborhood access needs, and multi-modal connectivity issues." (ARB004207.) In essenoe, 19 CHSRA reads section 1512S(d) right out oithe CEQA Guidelines. and proposes to limit future 20· -. discussion to onl}rthtee separate land use-relatc.;Hssues, to the -exclusion of all others. 21 22 23 24 25 26 27 28 2. TIle ProJest Wig Besult 1M Slren._. Noise 'Dapaets Not Properly IdepdftecL Analvzej(. or Mltlut.d In The!,tpoPd PEIR. The Second PEIR provides that the proposed Peninsula alignment will "pass throuSh densely populated areas where there is wgh potential for noise impacts!' (AR 8004 t 17.) The Second PBIR then leaps to the unsuPPorted conclusion that Peninsula noise impacts wiD be either "low-level", or "medium-level," (AR B004118.) S Not one of over 20 .,pUcabIe General ud/or "'08.1 plaDs Is ',"iDeally referenced In tbe Land Use and Planning, CommuDlties aad Nelghborboods, Property, aDd Environmental Justice section of the SeeoDd PEIR. (Aft B004164 -8004211.) COf>AW11O'7\766U9.2 .9. AMICUS CUIUAIi BlUEf OPTHE CITY OF PALO ALTO 1 2 3 .4 S 6 7 8 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 26 27 28 CEQA is not concemed with whe&her a particular environmental impact will bave an "impact rating,,6 ofHl~w". "medium" or "high." (AR B004101.) CEQA is concerned with whether a particular impact is significant. (See 14 Cal. Code Regs., § 15382 [defining "significant"].) Aa ElK Is required to provide a complete dlscussloD ad aaaly,ls of aay IdeDdfted slgnlOeaat eavironmental Impact, regardlell or wlledaer It Is ebaraeterlzed as a low-level, medium-Ie;vel or Idab-Ievellmpaet (See Berlceley Keep Jets Over the Bay Comm. v. Board of Port Comm Irs (2001) 91 Cal.App.4th t 344, 1370.) One of the most extreme impacts of the Project is its noise impact. (AR 8006530.) The Projcct proposes electrified steel-wheel-on-steel-raiJ train service. running through densely populated residential conununities, (AR BOO3869.) In some cases, the trains will run within yards of the bedrooms ot single-family residences, (AR 8006531.) As a direct e"vironmental" ' . impact ortbe Project, CEQA mandates that the noise impact be fully and properly evaluated and mitigated. (14 Cal. Code Regs .• § 15064. subd. (d)(l).) Section t 5143 of the CEQA Guidelines provides that Usignificant effects should be discussed with emphasis in proportion to their severity and probability of occurrence," (14 Cal. Code Regs. § 15143.) Despite the CHSRA-described "htgb.poteDtJaI for aolse Impacts," on the Peninsula (AR B004117) the Second PEIR failed to properly identify. analyze, or mitigate the Project's noise impacts. The Second PEIR identifies four noise-related thresholds of significance. (AR 800410S.) However. the Second PElR makes no attemptto quantify whether the project will exceed these identified thresholds of significance on the Peninsula. Instead, the Second PEIR merely estimates noise levels on a region-wide (the entire San Francisco Bay area) basis. and makes no attempt to quantify noise levels anticipated on the Peninsula alignment or at the identified station locations. (AR 8004116.) Like the deficient land use compatibility analysis, the noise impact analysis for the entire Peninsula alignment and station locations is contained in three short cooclusory sentences. (See AR B004118.) Again, CHSRA simply ignores that CEQA requires CHSRA to "use its best 6 "Impact ratin~' has no meaning under CBQA. COl'A\47801\766149.2 .11). AMICUS CUJUAE BRffif OF THE CITY OJ! PALO ALTO 1 2 3 4 5 6 7 8 9 10 11 12 13 14 IS 16 17 18 ,. 19 ·_····20-. 21 22 23 24 25 26 27 28 efforts to find out and disclose all that it reasonably can" in its BIR. {14 Cal. Code Regs .• § 15144.} At a minimum. CHSRA should have quantified specific noise impacts to Peninsula sensitive receptors. CHSRA's failure to include such infomtation in the Second PBIR renders the . document useless for infonnational purposes, ... d inadequate under CBQA. 3. Th, Protect wln.wIt III SlgUkgl.Vlbratloa Impaoas Not Properly IdeDdf1ecL Aaalyz", or Mltlnted I. the Second PEI& CHSRA used the exact same legally deficient approach to vibration impacts as it did for noise impacts. Again, CHSRA classifies potential vibration impacts according to "levels'" As explained above, CEQA is not concemed with whether a particular environmental impact will have an "impact rating" ofulow", "medium" or "high'" (AR B004101.) CEQA is concerned with whether a particular impact is 8ipifica"t. (Sec Berkeley Keep Jets Over the Bay Comm. V. Board 0/ Pori Comm ',s, supra, 91 Cal.App.4th at 1370.) Because the EIR identifies potential vibration impacts as "significant" it is required to provide a complete discussion and anal~i8 of the potential vibration impacts. Amicus PALO ALTO is unable to locate any discussion or analyais of the potential vibration impacts of the HST to the Peninsula cities in the Second PEIR beyond the conclusory statement , that there is f'tbe potential for medium to high vibration impacts because of the proximity of residential structures to the aJipmcnt;' and a diagrammatic reference to the same conelusion in Figure 3.4·7 oCthe EIR. (AR B004118, 8004132.) The Second PEIR. contains absolutely no reference to an appendix or other document that would provide supporting data for its eonclusory vibration detenninations. At a minimum, CHSRA should have attempted to quantifY specific vibration impacts to the Peninsula. CHSRA's failure to include such infonnation in the Second PElR renders the doc\UJlent useless for infonnational purposes, and inadequate under CEQA. 4. The. Protect Will ResUlt II Sipille.o! Aest1tedctyl.yal Besoyrses Impacts Not Properly IcIeDtffted. Alllm!d... or Mitigated 18 the Sec;OIId 'EIRe As a result of the Second PElR's deficient noise analysis, the Second PEIR proposes only a single measure to mitigate the CHSRA-described "htl. potential for Roise impacts", on the Peninsula. (AR 8004117,8004129.) Specifically, the Second PEIR. provides COP"W'180'M668f'" AMICUS CURIAe BRIEF OF THB CITY Of PALO ALTO 1 that U[p ]otential noise impacts can be reduced substantial1y by the instaUation of sound bamer 2' walls constructed to shield receivers ftom Irain noise,'· (AR B004129.) Reference to Table 3.4-7 3 in the Second PBIR. indicates that CHSRA expects to install over 45 miles oenoise baniers along 4 the PeninsUla. (AR B004130.) The Second PBIR fails to comply with CEQA because it includes S absolutely no identification, analysis, ormiti.ation of the poteatially significant impacts or the 6 installation of noise barriers aIon& the Peninsula. 7 As set forth in seotion 1 S 126.4(8)(1 )(D) of the CEQA Guidelines; &6 If a mitigation 8 measure would cause one or more sipiflC88t effects in addition to those that would be caused by 9 the project as proposed, tile effects of the mitigation measure shan be ducused but in less 10 detail than the sipificant effects of the project as proposed." (14 Cal. Code Rep., § 1 S 126.4, 11 subd. (a)(I)(D) [jntemal citations omitted, emph added.]) 12 At an absolute minimum, the potentially significant visual and aesthetic impacts 13 should have been identified in the Second PSIR. Because the Second PBIR fails to identify, 14 analyze. or mitipte th8 significant enviromnental effects oilbo noise mitigation measure, the 1 S document is useless for infonnationa1 purposes, and inadequate under CBQA. 16 IV. {(ONCLUSION 17 For the reasons set forth a~ve, the Second PEIR fails to comply with CEQA's L8 most basic requirement -full disclosure. The deeply fla.wed Second·PEIR fails to inform the 19 public and the decisionmakers of all of the significant environmental impacts of the Project. and 2() is therefore ioadequ~e. Amicus curiae PALO ALTO supports Petitioners' JeqQesl th.8t the Coun 21 grant the petition and i.ssue a writ of mandate ordering CHSRA to rescind its "rtitica1ion of the 22 Second PEIR. and itJ approval ofibe Project 23 Dated: May 1. 2009 24 25 26 27 28 00''''''710''766849.2 Respectfully Submitted, Mll..LER STARR REGALIA BY:~~ STJNA DANmL LA Wi iN Attorneys for Amicus Curiae . CITY OF PALO ALTO -12· AMICUS CUJUAB BRlJiF OF THe CITY OF PAW ALTO l :2 3 4 5 6 7 8 9 10 11 12 13 14 lS 16 17 18 19 20 21 22 23 24 2S 26 27- 28 PROQFOF Sf-mE (Town of Atherton, et at v. California 19h-Speed Rail AUlhorily. ef al., -Sacramento Superior ~urt. Case No. 34-2008-80000022) I. Karen Wigylu$, declare: I am a resident of the State of California and over the age of eighteen years, and not a party to the within action; my business address is 1331 N. California Blvd., Fifth Floor, Post Office Box 8117. Walnut Creek, CA 94596. On May 1, 2009, 1 served the within documents: AMICUS CURIAE BRIEF OF THE CITY OF PALO ALTO IN SUPPORT OF PETITIONERS' VERIFIED PETITION FOR WRIT 01' MANDATE AND COMPLAINT FOR INJUNCDVE AND DECLARATORY RELIEF o o o COI'A\47B07\76736l.1 by transmitting via facsimile the document(s) listed above to the fax number(s) set forth below on this date before 5:00 p.m. by placing the document(s) listed above in a sealed envelope with posta&e thereon fully prepaid, in the United States mail at Walnut Creek, California addressed as set forth below. -- by pJacing the document(s) listed above in a sealed Federal Express envelope and affixing a pre·paid air bill. and causini the envelope to be delivered to a Federal Express agent for next business day delivery. by personally delivering the documcnt(s) listed above to the person(s) at the addressees) set forth below. Stuart M. Flashman Law Offices of Stuart M. Flashman 5626 Ocean View Drive Oakland, CA 94618·1533 Tel: S 1 0.6S2.S373 Fax: 5io.6S2.S373 e·maiI: stuflash@aoI.com Attorney for Plaintiffs and Petitioners TOWN OF ATHERTON. PLANNING AND CONSBRVATION LEAGUE. CITY OF MENLO PARK., TRANSPOR.TATION SOLUTIONS DEFENSE AND EDUCATION FUND, CALIFORNIA RAIL FOUNDATION and BA YRAlL ALLIANCE Edmund G. Brown. Jr. Attomcy Gcnora1 of C.Ufomia Daniel L. SiegeJ SupervJIiDs Deputy Attorney General Christine Sproul Georsc Spanos Danao 1. Aitchison Deputy Attomoys General 1300 I Street, Suite 125 P. O. Box 944255 Sacramento, CA 94244-2550 Tel: 916.322.5522 Fax: 916.327.2319 e-mail: christine.sprouJ@doj.ca.gov; danae.aitchison@doj.ca.gov Attorney$ for Defendant and Respondent CALIFORNIA HIGH· SPBBD RAIL AUTHORITY 1 I am readily familiar with the .finn's practice of collection and processing' . 2 correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fuJly ·prepaid in the ordinary courso of business. I am aware that on motion of the party served, service is presumed invalid if P.C?'taI cancellation 3 . date or postage meter date is more than one day ~er date of deposit for mailing in affi~avit. 4 S 6 7 8 9 10 11 12 13 14 IS 16 17 18 )9 20 21 22 23 24 2S 26 27 28 I deelare under .penalty of perjury under the Jaws of the State of California that the foregoing is true and comet. . Executed on May I, 2009, at Walnut Creek, California. c COPA\47l107I767)63 I ·2· ATTACHMENTD February 11,2010 Senator Joseph Simitian State Capitol Room 2080 Sacramento, CA 95814 Qty qf P~o~to Office of the Mayor and City Council RE: 2009 High Speed Rail Business Plan Dear Senator Simitian: The Palo Alto City Council Subcommittee for High Speed Rail has reviewed the 2009 Business Plan prepared by the High Speed Rail Authority (HSRA). The Subcommittee, in conjunction with the Peninsula Cities Consortium, has identified a number of deficiencies and flaws in the Business Plan that need to be addressed and rectified before the project proceeds f:Urther. Those issues relate to the inadequate and fundamentally flawed ridership study, a questionable financing strategy that relies upon "hoped for" federal funding. and omits key cost elements in the San Francisco to San Jose segment, and a grossly deficient risk management plan. These issues and concerns were presented by Palo Alto Mayor Burt at the Joint Hearing of the Senate Budget Subcommittee #2 on Resources, Environmental Protection and Energy and Transportation and the Senate Transportation and Housing Committee on January 21 in Palo Alto. As discussed in detail below, the Subcommittee, on behalf of the Palo Alto City Council is requesting that the Legislature take the following actions related to HSR financing, governance, and process: Financing: • Require HSRA to correct all of the deficiencies in the Business Plan indentified in the Legislative Analyst's Report. • Require the HSRA to prepare a sound Investment Grade Ridership Study before additional funding is released for project engineering • Require that the Business Plan be rewritten and approved before any further funding is released for the project engineering. • Address the deficiencies in the construction budget for the San Francisco to San Jose segment where key cost elements have been omitted and no funding is included to address Context Sensitive Solutions (CSS). Governance: Printed with soy-based Inks on 100% recycled paper proc_d without chlorine P.O. Box 10250 Palo Alto, CA 94303 650.329.2477 650.328.3631 fax • Mandate that a new HSRA Governing Board of top professionals with mega­ project expertise and full accountability be appointed to manage the High Speed Rail project. • Clarify the role of the Peer Review Committee and require quarterly"reports ofthe Independent Peer Review to the Legislature. Process/Timeline: • Mandate that HSRA adopt CSS statewide, • Work with the Governor to request the federal government to extend the stimulus funding deadlines to allow for an adequate and thorough CEQAlNEP A process and successful project planning. Palo Alto recognizes that the California HST project is crucial for the future of mass transit in California and will have a long-lasting and far-reaching impact on the State and City of Palo Alto. It is the most significant project in the history of the Peninsula and must be designed to minimize impacts and roouce community divisions or barriers. Colfaboration between the HSRA and local communities is the key to success for the project Thank: you for considering these requests and please let us know when you will be able to incorporate these items into your oversight of the HSR project. If you or others have questions, please feel free to contact me or Deputy City Manager Steve Emslie at 329- 2354 or steve.emslie@cityofpaloalto.org. Sincerely, OJf~-I PATBURT 1 Mayor Enclosure cc: Medhi Morshed, HSRA Robert Doty, Peninsula Rail Project City Council ATTACHMENT E THE 2010-11 BUDGET CONTENTS Executive Summary ................................................................................ 3 Background ........................................................................................... 5 Department of Transportation ........................................................... 10 Capital Outlay Support Should Be Based on Workload ............................... 10 Payments for Public-Private Partnerships Problematic ............................... 21 Proposition 1 B Implementation ........................................................... 23 High-Speed Rail Authority ................................................................... 25 Project Development Work Increasing .................................................. 25 Project to Receive Federal Stimulus Funds .............................................. 26 Revised Business Plan an Improvement, but Still Lacks Details .................. 27 Current-Year Progress Difficult to Determine ........................................... 28 2010-11 Budget Proposals .................................................................... 29 TR-2 LEGISLATIVE ANALYST'S OFFICE THE 2010-11 BUDGET EXECUTIVE SUMMARY The Governor's budget proposes $18 billion in expenditures (mostly from special funds) for transportation programs in 2010-11. This includes $14 billion for the California Department of Transportation (Caltrans), $2 billion for the California Highway Patrol, $958 million for the High­ Speed Rail Authority (HSRAt and $954 million for the Department of Motor Vehicles. Caltrans Capital Outlay Support (COS) Program Is Overstaffed. The budget requests about $2 billion in 2010-11 for COS-staff resources that perform activities to develop and manage the department's capital construction program. We reviewed Cal trans' COS budget for recent years and found that the program's budget lacks sufficient workload justification. In order to gauge the reasonableness of the department's COS requests for staffing and funding, we evalu­ ated the program using several different methods. The cumulative evidence from our review shows that the program is over-staffed and lacks strong management. We think major actions are needed to' correct the issues we identify. Specifically, we rec­ ommend that the Legislature: »-Require Caltrans to provide additional information to justify its annual COS budget request. »-Have Caltrans report on the steps it is taking to control its COS costs. »-Request an audit of the program's time charging practices. »-Reduce the program's staffing by about 1,500 (and $200 million a year) to align with actual workload if Caltrans does not provide workload justification for its COS budget request. Payments for Public-Private Partnerships Problematic. The Governor requests that $3.45 billion in future federal transportation funds be appropriated to Caltrans to pay private­ sector firms for costs related to an unspecified number of public-private partnership (P3) agree­ ments. Our review found that the Governor's proposal has several significant problems. Specifi­ cally, we found the following: »-The proposal does not appear to be permissible under current law, and the types of agreements contemplated in the Governor's proposal are not eligible to be funded en­ tirely with federal funds. Thus, the proposal is not workable. »-Details are not available regarding how the majority of the funds (about $2.5 billion) would be used. However, in the case of the $1 billion project that has been identified, using a P3 approach may not reduce state costs as Caltrans claims. LEGISLATIVE ANALYST'S OFFICE TR-3 TR-4 THE 2010-11 BUDGET ~ The budget requests a "blank check" authority for the Department of Finance to aug­ ment the proposed appropriation without legislative oversight or approval. We recommend the Legislature reject the request. We further recommend that in revis­ ing its budget requests this spring, the administration ensure that any request for P3 funding is workable and meets certain criteria. Proposition 1 B The budget requests the appropriation of $4.7 billion in Proposition 'I B bond funds to meet current program needs. Our review indicates, however, that the level of funding requested is higher than the amount needed based on project schedules. We recommend that the Legisla­ ture direct Caltrans to report on the projects that are planned for allocation through June 2011, and the associated level of bond funding that would be needed. The budget should be adjusted accordingly. High-Speed Rail Authority Proposition lA, passed by voters in November 2008, authorizes $9 billion for HSRA to develop and construct a high-speed train system in California. Recently, the authority received a $2.25 billion award of federal economic stimulus funds to complement the $9 billion in bond funds available from the state. The massive increase in available funding has increased the de­ velopment work performed by the authority and its contractors. We evaluated HSRA's ability to measure the project's progress, as well as the authority's budget request, and recommend new reporting requirements to increase accountability. LEGISLATIVE ANALYST'S OFFICE THE 2010-11 BUDGET Federal Stimulus Funds Advanced Several Proiects Chapter 21, Statutes of 2009 (ABX3 20, Bass), allowed Caltrans to use federal stimulus funds provided under the ARRA to provide $310 mil­ lion in cash loans to Proposition 1 B projects in 2008-09 and 2009-10. These loans allowed four state highway projects to proceed to construction that otherwise would have been delayed due to the state's difficulties selling bonds. Similarly, sev­ eral local agencies used a portion of their ARRA funds to advance Proposition 'I B projects Analyst's Recommendation. In the event that California receives more federal stimulus funds for transportation, we recommend the Legislature enact legislation to authorize additional cash loans to Proposition 1 B projects, In total, there are about $600 million in Proposition lB projects ready to start construction, but that are delayed due to insufficient bond funding. Of these proj­ ects, Caltrans estimates that $428 million are fed­ erally eligible and could therefore be advanced if additional federal stimulus funds are provided. To do so, however, would require the approval of new state legislation, since the existing author­ ity relates only to federal stimulus funds already received under ARRA. HIGH-SPEED RAil AUTHORITY The High-Speed Rail Authority (HSRA) was statutorily established to develop a high-speed rail system in California that links the state's major population centers, including Sacramento, the San Francisco Bay Area, the Central Valley, Los Angeles, the Inland Empire, Orange County, and San Diego. The latest cost estimate for completion of the first phase of the project, from San Francisco to Los Angeles and Anaheim via the Central Valley, is roughly $43 billion. (This cost estimate reflects the escalated cost of each portion of the project at the time it is to be built.) In November 2008, voters approved Proposi­ tion lA, which allows the state to sell $9 billion in general obligation bonds to partially fund the development and construction of the high-speed rail system. The remaining funding for the sys­ tem's construction and operation is anticipated to come from federal and local governments as well as the private sector, LEGISLATIVE ANALYST'S OFFICE PRO.IECT DEVELOPMENT WORK INCREASING Over the past few years, the development work for the high-speed rail project has been in­ creasing. As shown in Figure 11 (seenext page), the authority'S support expenditures have grown very quickly since 2006-07. This figure includes the authority'S administration costs as well as the costs of consulting contracts to plan and develop the system. These contracts include: >-Program management, which includes oversight of all engineering work. >-Project-level engineering and environ­ mental studies conducted along the cor­ ridors by various contractors. >-Financial consulting and public-private partnership development. >-Technical consulting such as ridership forecasts and visual simulations. TR-2S TR-26 THE 2010-11 BUDGET Through the current year, nearly all fund- ing for project development has come from the state. However, the authority anticipates using some federal stimulus funding available through the ARRA to supplement state funds beginning in 2010-11. Additionally, the current-year budget authorizes the state to replace state bond fund­ ing with federal funding if allowed by federal law. Thus, it is possible some of the federal stimulus funding would be used in the clJrrent year as well. PROJECT TO RECEIVE FEDERAL S'rlMULUS FUNDS The ARRA provides $8 billion nationwide to fund rail projects, including high-speed rail development programs. The authority applied for more than $4.7 billion of the available fund­ ing to be used in three specific corridors as well as for systemwide planning and environmental clearance. Though not Figure 11 the state's current intercity rail program.) The funding will be available for program develop­ ment and environmental clearance for the entire first phase of the project, as well as design-build contracts in four of the project's ten corridors, including: >-Los Angeles to Anaheim. >-Merced to Fresno to Bakersfield. >-San Francisco to San Jose. The other corridors were not included in the grant application because they are not far enough along in the development process to meet the ARRA deadlines. Funding Availability and Expenditure Time­ line. It is unknown at this time when the ARRA funding will be available or how it will be di­ vided among the various eligible segments of the required under ARRA, the state's application forfunds pledged to match any ARRA funds awarded to the high­ speed rail project with an equal amount of state monies. High-Speed Rail Planning Expenditures Growing Rapidly (In Millions) Project Awarded $2.25 Billion. On Janu­ ary 28,2010, the federal government awarded California $2.25 billion toward the development . of the high-speed rail system. (California also received $99 million to improve and upgrade LEGISLATIVE ANALYST'S OFFICE THE2010 11 BUDGET project. According to interim guidance released by the Federal Railroad Administration (FRA) in June 2009, the money must be obligated by September 2011 and fully expended by Septem­ ber 2017. According to FRA's interim guidance, these funds will be considered obligated when a grant or cooperative agreement between the federal agency and the state is complete. The grant agreement will describe project milestones and what steps must be taken for the state to access these federal funds. However, because it is unknown at this time when this agreement will be reached, there is no way of knowing when the federal funds will become available for expenditure. Bond Funds Will Match Federal Dollars. At the time of this analysis, it is also unclear how the authority plans to structure the pledge to match federal funds with state bond funds. For example, one way to provide this match would be to apply one state dollar for every federal dol­ lar spent, whether it is for the purchase of land or some other service. This would mean that federal dollars would provide one-half of the funding for a particular contract or section of right of way, and the state bond money would fund the other half of the same expenditure. Alternatively, the authority could simply apply an equivalent amount of bond dollars to a particular segment of the system, regardless of what the particular expenditure may be. In this case, state funding may pay for a consulting contract to complete the environmental work on a section of the system where an equivalent amount of federal funding has purchased the right of way. How the authority plans to use state bond funds to match ARRA dollars would determine when the state would have to issue Proposition 1 A bonds as well as the amount to issue in the budget year. LEGISLATIVE ANALYST'S OFFICE Analyst's Recommendation. Because of the deadlines attached to the ARRA award, it is imperative that HSRA act expeditiously to meet federal requirements. In addition, the state should consider how to most effectively spend the federal dollars while reducing the debt ser­ vice burden on the state in the near term. There­ fore, we recommend that the authority report at budget hearings on its plans to meet the ARRA deadlines. Specifically, the HSRA should discuss the following: »0-What restrictions are placed on the fed­ eral funds? »0-How much of the ARRA funds are avail­ able for each segment or task? »0-How will the authority structure the state's match of federal funds? »0-What steps must be taken in order to obligate the funds? »0-How will HSRA ensure that the project schedule meets the federal obligation deadline? REVISED BUSINESS PLAN AN IMPROVEMENT, BUT STILL LACKS DETAILS The 2009-10 Budget Act (as amended in July 2009) required the authority to submit to the Legislature a revised business plan with specific elements by December 15, 2009. The plan was submitted on time, and included at least some discussion of all the required elements. The new plan is much more informative than the previ­ ous business plan, and contains, among its other components, descriptions of potential opera­ tional plans and many system details, as well as a discussion of various funding possibilities avail­ able for the project. TR-27 TR-28 THE 2010-11 BUDGET Nonetheless, our review of the plan con­ cludes that the plan's discussion of particular elements is lacking some important details. Spe­ cifically, the plan lacks discussion of risk manage­ ment, including any detailed description of many key types of risk or mitigation processes. Also, there are few deliverables or milestones identi­ fied in the plan against which progress can be measured. Due to the multiyear nature of a proj­ ect of this size, without clearly defined deadlines and work to be accomplished, it will be difficult for the Legislature and the administration to track progress in any meaningful way. Analyst's Comments. Chapter 618, Statutes of 2009 (SB 783, Ashburn), requires the authority to prepare, publish, adopt, and submit to the Leg­ islature an updated business plan addressing spe­ cific elements no later than January 1, 2012, and every two years thereafter. We will be reviewing the submitted plan to ensure compliance with statutory requirements and identify any improve­ ments that are needed in these documents. CURRENT-YEAR PROGRESS DIFFICULT TO DETERMINE Authority Submitted Program Work Plan Through 2072-73. The Legislature approved $139 million to fund continued preliminary plan­ ning of the rail system during 2009-10, including project-level design and environmental review for all ten segments of the rail line, program management services, financial planning, and development of a new ridership model. In order to justify the current-year funding level, the au­ thority submitted a Program Summary Report to the Legislature in July 2009, which described the authority'S recent and ongoing activities as well as the expected work to be completed each year through 2012-13. This multiyear summary is in- tended to outline the management plan to move the project through the environmental processes to construction and revenue service. However, our analysis indicates there are questions about how progress on the project is being tracked. We explain these concerns below. Actual Progress Does Not Appear to Follow Work Plan. So that the authority's staff can track the project's status against the work plan laid out in the Program Summary Report, the HSRA's program management consultant provides monthly status reports on a list of specific tasks that each have their own due date. However, our review shows that some of the tasks contained in recent status reports are inconsistent with those listed in the work plan. For instance, the November 2009 status report only provided an update on one-half of the 160 uncompleted tasks identified in the work plan, with the remain- ing tasks deleted or missing. When asked about these discrepancies, the authority indicated that some of the tasks might have been combined or considered unnecessary, but could not defini­ tively explain these changes. Progress Report of Project-Level Work Plan Provides No Details. The monthly status reports submitted to the authority are problematic in an­ other way: they provide only summary informa­ tion on the progress of project-level work being accomplished by contractors. The work plan lays out the expected timelines for the particular tasks to be accomplished each year by each of these contractors. However, our review indicates that the monthly reports do not track each contrac­ tor's status against the work plan. Instead, the reports only summarize the cumulative amount of time spent on the project by the contractors collectively. Without more detailed information, it is hard for the Legislature to determine what LEGISLATIVE ANALYST'S OFFICE THE 2010-11 BUDGET work is being accomplished by each contractor in the current year and what work remains to be done in subsequent years. Analyst's Recommendation. Multiyear mega projects such as the high-speed rail project are susceptible to significant unexpected challenges in their planning, development, and construc­ tion as well as financing. For example, a 2004 report by the BSA regarding the replacement of the Oakland-San Francisco Bay Bridge, another mega project, found that a considerable financial crisis arose in part due to the project manage­ ment's failure to disclose huge cost overruns as soon as it was aware of them. Because the state has committed a significant amount of funding for the high-speed rail project, it is important that the Legislature be provided from the outset with regular updates on the project's progress to avoid unexpected challenges in the project's develop­ ment. Therefore, we recommend the Legislature adopt legislation to require the authority to submit an annual report that tracks the project's progress and identifies (1) the expected tasks and deliverables for the coming year, and (2) any potential challenges and issues the project encounters. This information would enable the Legislature to better assess the authority's budget request for the subsequent year. The report could be structured similar to those reqUired for the oversight of the Bay Bridge replacement project. Information should include, but not be limited to: ,... A baseline budget, by contract, for capi­ tal and support costs. ,... Expenditures to date, by contract, for capital and support costs. ,... A comparison of the current or projected LEGISLATIVE ANALYST'S OFFICE schedule and the baseline schedule that was assumed. ,... A summary of milestones achieved dur­ i ng the previous year. ,... Any issues identified, and actions taken to address those issues, in the previous year. This report should be submitted by Sep­ tember 1 of each year. This date would give the authority time to compile details of the past fiscal year, clearly identify current-year deliverables, and provide an outline of the expected work plan for the coming budget year. 2010-11 BUDGET PROPOSALS The Governor's budget requests $958 mil­ lion to fund the authority's activities in 2010-11, including $375 million in expected federal economic stimulus funds and $583 million in Proposition 1A bond funds. The total request will be used for three purposes. First, $750 mil­ lion is requested for right-of-way assessment and acquisition. Second, $203 million would go for consulting contracts to perform system devel­ opment work. Finally, the remaining $5 million would cover the authority's administrative costs. We comment on each of these budget proposals below. Right-o' .. Way Acquisition Total Capital Outlay Request Not Needed in Budget Year. The authority is requesting $750 million for right-of-way acquisition in the budget year. At the time the Governor's bud­ get was being prepared, the authority did not know how much ARRA funding the state would be awarded or when the federal dollars wou Id TR-29 TR-30 THE 2010-11 BUDGET become available. Therefore, the $750 million request, comprised of $375 million from the state and an equal amount of federal funds, was a placeholder amount based on the authority's best estimate at the time. However, HSRA has indicated in recent discussions that it would not need the total amount requested in 2010-11. The authority now believes it will need no more than $250 million to begin negotiations with large landholders. Analyst's Recommendation. Based on the authority's updated estimate of the funding needed for land acquisition, we recommend that the capital outlay funding level be reduced by $500 million to provide $250 million in 2010-11. Furthermore, we recommend the adoption of budget bill language, similar to the language in the 2009-10 budget, to authorize the HSRA to replace state bond funding with federal funding as it becomes available. Contract Proposals Little Justification Provided for Contract Amounts. In 2010-11, the authority is requesting $203 million for various contracts. Figure 12 lists the contracts the HSRA proposes to be funded in 2010-11, as well as the amounts expended on these contracts in the prior and current years. While the general types of proposed contract work appear reasonable, the authority's budget requests provide no justification for the specific amou nts requested for each contract. Also, as discussed earlier in this analysis, because the monthly status reports do not indicate whether the work planned for 2009-10 is actually being accomplished, the Legislature cannot determine whether the resources proposed for 2010-11 are appropriate and justified. The authority's fund­ ing requests for consult­ ing contracts contain little information on the work to be accomplished over the budget year, or about how that work fits into the total develop­ ment of the system. As a result, it is unknown how the amount for each contract was determined. This is the same concern raised in our analysis of the authority's similar 2009-10 budget requests. The authority appears no LEGISLATIVE ANALYST'S OFFICE THE 2010 11 BUDGET more equipped to justify the requested contract amounts than it was one year ago. In addition, our review of the budget re­ quests for each of the ten contracts for project­ level planning and environmental review indi­ cates that they are significantly different from the contract amounts projected for 2010-11 in the Program Summary Report. Eight of these contract requests varied by 25 percent or more from the funding levels projected less than a year ago. The revised contract amounts could be due to any number of reasons, such as current-year work being delayed or future efforts being brought for­ ward to expedite certain segments of the project. However, the authority has not been able to pro­ vide any explanation for the significant changes in contract amounts, nor how these amounts were determined. Analyst's Recommendation. In regard to the proposals for contract funding, there is no basis for the Legislature to determine the appropriate level of contract funding that should be provided to the authority for 201 0-11. Accordingly, we withhold recommendation on the $203 million request pending receipt of supplemental informa­ tion on the amount of work to be accomplished in the budget year, by contract, and information on how each contract fits into the overall devel­ opment of the system. SlaHing Proposals Staffing Request Should Tie to a Staffing Strategy. The authority is also requesting an increase of $3.5 million and 27 additional staff. This would bring the total authority staffing to 38.5 positions in 2010-11. It is clear that as the project progresses the authority will need to add positions to admin­ ister, monitor, and oversee the growing amount LEGISLATIVE ANALYST'S OFFICE of work conducted by contractors. However, at the time this analysis was prepared, the authority was unable to explain how the requested posi­ tions would provide the necessary skill sets to support the overall development of the project and why this amount of state staff is needed at this point in the process. Specifically, the au­ thority has not determined the mix of state and contracted staff it plans on using to develop the rail project over time. An independent consultant hired by the authority concluded (in November 2009) that the current state staff is insufficient for a project of this size, and recommended a state managerial structure based on the best practices of similar programs around the world. However, the budget request does not provide information on how the proposed positions fit into the con­ sultant's recommendations. Early identification of the role of state staff in the project, as well as a future staffing structure, would have significant advantages. For example, it would enable the organization to grow at the necessary speed to ensure staffing levels coincide with the workload required to deliver the project. Additional Exempt Positions Should Be Statutorily Defined. The requested staff posi­ tions include a chief financial officer, chief program manager, and three regional managers. The authority believes that it would not be able to attract qualified individuals under the state's current civil service restrictions. Therefore, under the budget proposal, these positions would be established administratively as positions ap­ pointed by the Governor and exempt from civil service requirements. Statute currently grants the HSRA the authority to appoint an executive director who is exempt from civil service. We see merit in the HSRA's proposal to establish additional exempt positions. The HSRA TR-31 TR-32 THE 2010-11 BUDGET would likely need numerous exempt positions over the next few years in order to bring on vari­ ous staff that have the requisite skills to manage and oversee the development of the rail project by specialized contractors. These high-level staff must have the skills to negotiate with the private sector to finance, construct, and operate the system. Defining these positions through statute, similar to statutesdescribing exempt positions for other agencies in state government, would give the Legislature sufficient control over the specific positions that would be established, the salary levels, and the assignment of responsibilities of each position. This would enable the Legislature Contact Information Dana Curry Director, Transportation, Business, and Housing Jessica Digiambattista Transportation Financing/Highways to retain some additional oversight of the project, while making it easier for the authority to hire the staff necessary to administer the program. Analyst's Recommendation. We withhold recommendation on the staffing request until the authority is able to support the request for ad­ ditional staffing with a strategy that outlines how to meet the short-and long-term staffing needs of the organization. The staffing strategy should include justification for the requested exempt positions. For the reasons discussed above, we further recommend that any exempt positions be defined statutorily. 319-8320 Dana.Curry@lao.ca.gov 319-8363 Jessica.Digiambattista@lao.ca.gov Eric Thronson Public Transportation/High-Speed Rail! 319*8364 Housing Eric.Thronson@lao.ca.gov Russia Chavis Transportation/Business 319*8338 Russia.Chavis@lao.ca.gov LAO Publications The Legislative Analyst's Office (LAO) is a nonpartisan office which provides fiscal and policy information and advice to the Legislature. To request publications call (916) 445-4656. This report and others, as well as an E-mail subscription service, are available on the LAO's Internet site at www.lao.ca.gov.TheLAOislocatedat925LStreet.Suite 1000, Sacramento, CA 95814. LEGISLATIVE ANALYST'S OFFICE To: From: Date: RE: ATTACHMENT F MEMORANDUM City of Palo Alto -High Speed Rail Committee Rayi Mehta March 8, 2010 Legislative Update: Pending legislation that directly or indirectly impacts the California High Speed Rail Project The 2010 legislative session is in full swing with over 3,000 new bills introduced. As anticipated, a significant number of bills affecting High Speed Rail ("HSR") have also been introduced. These bills range from carving out exemptions to CEQA t to restructuring the HSR AuthoritYt creating a Department of HSR, providing funding for HSR workforce training t reconstituting the HSR Board membership, authorizing the HSR Authority to acquire land for rights-of-waYt etc. Some bills affecting CEQA are spot bills, which merely amend a code section in such an innocuous way as to be totally non-substantive. Spot bills are introduced to assure that a germane vehicle will be available at a later date after the deadline has passed to introduce bills. At that future datet the bill can be amended with more substance included. These bills will also have to be monitored carefully to ensure that they do not affect HSR. A number of CEQA bills were heard in Committee about 10 days ago. These bills t marked SBX because they are deemed urgency bills as part of the Special Legislative Session t were held in the Senate Environment Quality Committee at the request of the Authors who did not believe they had the votes for passage. Unfortunately, bills with identical language were also introduced t and we should expect them to be amended to address some of the concerns raised by Senator Samitian and other Committee members. The foregoing are summaries and status of each bill (with the exception of budget bills) I believe affects HSR. The City should consider taking a formal position of Supportt Support jf Amended t Oppose t or Monitor for each bill. I can provide more detailed information as requested. A letter stating the City's position, other than Monitor, should be sent to the legislature to ensure that the City's offiCial position is formally recorded. Legislative Update March 8, 20 I 0 CEQA Legislation ABX8 37 (Calderon, Charles) Environment: CEQA Status: 02jllj2010-From printer. Summary: This Bill would enact the CEQA Litigation Protection Pilot Program of 2010 and would require the Business, Transportation and Housing Agency to select projects that meet specified requirements from specified regions for each calendar year between 2010 and 2014. The bill would exempt from judicial review, pursuant to CEQA, a lead agency's decision to certify the EIR of, or to adopt a mitigated negative declaration based on an initial study for, the selected projects, a lead agency's and responsible agency's approval of the selected project, and the Business, Transportation and Housing Agency' s selection of the projects. The bill would require the Business, Transportation and Housing Agency, by December 31 of each year, to submit an annual report to the Governor and to the Legislature summarizing the designation of projects, and the job creation and investment attributable to the deSignated projects. AB 1805 (Calderon, Charles) Environment: (CEQA) Status: 02j25j2010-Referred to Com. on NATURAL RESOURCES & JUDICIARY Summary: This bill would enact the CEQA Litigation Protection Pilot Program of 2010 and would require the BuSiness, Transportation and Housing Agency to select projects that meet specified requirements from specified regions for each calendar year between 2010 and 2014. The bill would exempt from judicial review, pursuant to CEQA, a lead agency's decision to certify the EIR of, or to adopt a mitigated negative declaration based on an initial study for, the selected projects, a lead agency's and responsible agency's approval of the selected project, and the Business, Transportation and Housing Agency' s selection of the projects. The bill would require the Business, Transportation and Housing Agency, by December 31 of each year, to submit an annual report to the Governor and to the Legislature summarizing the designation of projects, and the job creation and investment attributable to the deSignated projects. AB 2713 (Knight) Environment: CEQA (Spot Bill) Status: 02j22j2010-Read first time. Summary: The (CEQA) requires a lead agency, as defined, to prepare, or cause to be prepared, and certify the completion of, an environmental impact report (EIR) on a project that it proposes to carry out or approve that may have a significant effect on the environment or to adopt a negative declaration if it finds that the project will not have that effect. The CEQA also requires a lead agency to prepare a mitigated negative declaration for a project that may have a significant effect on the environment if revisions in the project would avoid or mitigate that effect and there is no substantial evidence that the project, as reVised, would have a significant effect on the environment. This bill would make technical, non-substantive changes to the CEQA. Legislative Update March 8.20] 0 2 SBX8 42 (Correa) Environment: CEQA Status: 02j24j2010-Set, first hearing. Held in committee without recommendation. Summary: Would enact the CEQA Litigation Protection Pilot Program of 2010 and would require the Business, Transportation and Housing Agency to select projects that meet specified requirements from specified regions for each calendar years between 2010 and 2014. The bill would exempt from judicial review, pursuant to CEQA, a lead agency's decision to certify the EIR of, or to adopt a mitigated negative declaration based on an initial study for, the selected projects, a lead agency's and responsible agency's approval of the selected project, and the Business, Transportation and Housing Agency's selection of the projects. The bill would require the Business, Transportation and Housing Agency, by December 31 of each year, to submit an annual report to the Governor and to the Legislature summarizing the designation of projects, and the job creation and investment attributable to the designated projects. SBX8 56 (Hollingsworth) Environmental Quality: CEQA: exemption: critical infrastructure projects Status: 02j24j2010-Hearing canceled at the request of author. Summary: This Bill would exempt from CEQA a critical infrastructure project, which would include, among other projects, projects funded under the Highway Safety, Traffic Reduction, Air Quality, and Port Security Bond Act of 2006 or the Disaster Preparedness and Flood Prevention Bond Act of 2006. The bill would provide that this exemption applies retroactively. Because a permitting agency, which includes a local agency, would be required to determine the applicability of, and to give notice of, that exemption, this bill would create a state-mandated local program. SB 1010 (Correa) Environment: CEQA Status: 02j18j2010-To Coms. on ENVIRONMENTAL QUAL. and JUDICIARY. Summary: This Bill would enact the CEQA Litigation Protection Pilot Program of 2010 and would require the Business, Transportation and Housing Agency to select projects that meet specified requirements from specified regions for each calendar year between 2010 and 2014. The bill would exempt from judicial review, pursuant to CEQA, a lead agency's decision to certify the EIR of, or to adopt a mitigated negative declaration based on an initial study for, the selected projects, a lead agency's and responsible agency's approval of the selected project, and the Business, Transportation and Housing Agency' s selection of the projects. The bill would require the Business, Transportation and Housing Agency, by December 31 of each year, to submit an annual report to the Governor and to the Legislature summarizing the designation of projects, and the job creation and investment attributable to the designated projects. Legislative Update March 8. 2010 3 SB 1012 (Runner) Environmental quality: CEQA (Spot Bill) Status: 02/18/2010-To Com. on RULES. Summary: CEQA requires a lead agency, as defined, to prepare, or cause to be prepared by contract, and certify the completion of, an environmental impact report on a project, as defined, that it proposes to carry out or approve that may have a significant effect on the environment, or to adopt a negative declaration if it finds that the project will not have that effect. This bill would make technical, non­ substantive changes to those provisions. SB 1195 (Wyland) Environment: CEQA (Spot Bill) Status: 03/04/2010-To Com. on RULES. Summary: CEQA requires a lead agency, as defined, to prepare, or cause to be prepared, and certify the completion of, an environmental impact report (EIR) on a project that it proposes to carry out or approve that may have a significant effect on the environment or to adopt a negative declaration if it finds that the project will not have that effect. CEQA also requires a lead agency to prepare a mitigated negative declaration for a project that may have a significant effect on the environment if revisions in the project would avoid or mitigate that effect and there is no substantial evidence that the project, as revised, would have a Significant effect on the environment. This bill would make technical, non-substantive changes to CEQA. SB 1261 (Ashburn) Environment: CEQA: expedited review (Spot Bill) Status: 03/04/2010-To Com. on RULES. Summary: This bill would state the intent of the Legislature to enact legislation establishing a fast track environmental review process that maintains current environmental protection while expediting the review of projects related to green or renewable industries that will create jobs in the state. High Speed Rail Legislation AB 153 (Ma) High-Speed Rail Authority Status: 07/02/2009-In committee: Set, first hearing. Hearing canceled at the request of author. Summary: This Bill would eliminate those contingencies to the exercise of the Authority's authority and would specify that the Authority constitutes a "governing body" for the purpose of adopting a resolution of necessity. The bill would authorize the Authority to employ its own legal staff or contract with other state agencies for legal services, or both. AB 289 (Galgiani) High-speed rail Status: 02/11/2010-Re-referred to Com. on TRANSPORTATION & HOUSING Summary: Would authorize the Governor to appoint up to 5 deputy directors exempt from civil service who would serve at the pleasure of the executive director. Legislative Update March 8, 20 I 0 4 AB 1375 (Galgiani) High-speed rail Status: 02j11j2010-Referred to Committees. on TRANSPORTATION & HOUSING and RULES. Summary: "rhis Bill would revise and recast these provisions by repealing and reenacting the California High-Speed Train Act. The bill would continue the High­ Speed Rail Authority in existence to make policy decisions relative to implementation of high-speed rail consistent with Proposition lA. The bill would create the Department of High-Speed Trains within the Business, Transportation and Housing Agency, which would implement those policies. "rhe bill would transfer certain of the existing powers and responsibilities of the authority to the department and would specify additional powers and duties of the authority and department relative to implementation of the high-speed rail project, including the annual submission of a 6-year high-speed train capital improvement program and progress report to the Legislature. The director of the department would be appointed by the Governor, who would serve at the pleasure of the authority, and the Governor would be authorized to appoint up to 10 executive employees of the department who would be exempt from civil service and serve at the pleasure of the director. The bill would provide for acquisition and disposition by the department of rights-of-way for the high-speed rail project. The bill would enact other related provisions. AB 1747 (Galgiani» High-Speed Rail Authority Status: 02j18j2010-Referred to Com. on TRANSPORTATION. Summary: Would authorize the authority to consider, to the extent permitted by federal and state law, the creation of jobs in California when awarding major contracts or purchasing high-speed trains, as specified. AB 2121 (Harkey) High-speed rail Status: 03j04j2010-Referred to Com. on TRANSPORTATION. Summary: This Bill would reduce the amount of general obligation debt authorized pursuant to the Safe, Reliable High-Speed Passenger Train Bond Act for the 21st Century to the amount contracted as of January 1, 2011. AB 2703 (John A. Perez) Transportation funding Status: 02j22j2010-Read first time. Summary: This Bill would state the intent of the Legislature to enact legislation to ensure that federal transportation funds received in 2010 are expeditiously awarded to maximize job retention in California and to ensure robust oversight of those funds. SBX8 36 (Lowenthal) Federal transportation economic stimulus funds: 2nd round Status: 02jl0j2010-Re-referred to Com. on TRANSPORTATION & HOUSING Summary: This Bill Would require the Department of Transportation to work with local transportation agencies to develop a list of potential projects that may be Legislative Update March 8, 2010 5 awarded within a 90-day period of the award to the state of 2nd round federal transportation economic stimulus funds, The bill would require the department to submit a monthly status report to the Legislature, as specified, with respect to certain milestones for expenditure of these funds. The bill would make related legislative findings and declarations. 58409 (Ducheny) Passenger rail programs: strategic planning Status: 02/11/2010-To Com. on TRANS. Summary: Would place the High-Speed Rail Authority within the Business, Transportation and Housing Agency. The bill would require the 5 members of the authority appointed by the Governor to be appOinted with the advice and consent of the Senate. The bill would require the authority to annually submit a funding plan to the California Transportation Commission for approval, identifying the need for investments during the fiscal year and the amount of bond sales necessary to accommodate those investments. 58 455 (Lowenthal) High-speed rail Status: 07/24/2009-Placed on inactive file on request of Assembly Member Torrico. Summary: Would provide that the members of the authority appOinted by the Governor are subject to appointment with the advice and consent of the Senate. The bill would require the members of the authority, at a scheduled board meeting, to cause to be prepared an overall project schedule with project delivery milestones on a quarterly baSiS, and to approve a quarterly contract status report, beginning at the first board meeting after March 1, 2010. The bill would also require the members of the authority to approve all contract amendments at a scheduled board meeting. 58 879 (Cox) Construction projects: alternative bidding procedures: design­ build. Status: 01/21/2010-To Com. on LOCAL GOVERNMENT Summary: Existing law authorizes counties to use alternative procedures, known as design-build, for bidding on construction projects in the county in excess of $2,500,000, in accordance with speCified procedures. Each county that elects to use the design-build method on a public works project is required to submit a report to the Legislative Analyst's Office before December 1, 2009, containing a description of each public works project procured through the design-build process and completed after November 1, 2004, and before November 1, 2009. Existing law also requires the Legislative Analyst, on or before January 1, 2010, to report to the Legislature on the use of the design-build method by counties. This bill would repeal those reporting provisions. S8 964 (Alquist) Workforce development program: high-speed rail Status: 02/18/2010-To Coms. on TRANSPORTATION & HOUSING and EDUCATION. Summary: Would require the authority to contract with the California Community Colleges Chancellor'S office to develop a labor market assessment of the workforce and identify the education and skills needed for high-speed rail, and to develop a Legislative Update March 8, 2010 6 comprehensive workforce training and certification program or programs to facilitate the availability of that workforce. The bill would require the authority and the chancellor's office to form a Jobs Advisory Task Force! as specified, to advise the authority and the chancellor's office on the establishment and operation of training and certification programs required to produce an adequate skilled workforce for this project. The bill would require the labor market assessment to be incorporated into the authority's biennial revised business plan. 58965 (DeSaulnier) High-speed rail Status: 02/18/2010-To Com. on TRANSPORTATION & HOUSING Summary: Would authorize the authority to receive and expend any federal funds awarded to the authority for the purposes of developing a project or projects along the high-speed rail network, thereby making an appropriation. The bill would require the authority to take various actions in that regard. The bill would also require the authority to submit to the Legislature an expenditure plan for the federal funds within 30 days of enactment of this act and to submit a progress report on expenditure of the funds to the Legislature within 180 days of the award of those funds and annually thereafter. The bitl would make legislative findings and declarations relative to the award of federal funds to the state under the federal American Recovery and Reinvestment Act (ARRA) for high-speed rail purposes. S8 1260 (Vee) High-speed rail Status: 03/04/2010-To Com. on RULES. Summary: Existing law, the California High-Speed Rail Act, creates the High-Speed Rail Authority to develop and implement a high-speed rail system in the state, with specified powers and duties. Existing law! pursuant to the Safe, Reliable High-Speed Passenger Train Bond Act for the 21st Century, approved by the voters as Proposition lA at the November 4, 2008, general election, provides for the issuance of $9.95 billion in general obligation bonds for high-speed rail and related purposes. This bill would state the intent of the Legislature to enact legislation to implement the bond act. S8 1371 (Lowenthal & Correa) Federal transportation economic stimulus funds: 2nd round. Status: 03/04/2010-To Com. on TRANSPORTATION & HOUSING Summary: Would require the Department of Transportation to work with local transportation agencies to develop a list of potential projects that may be awarded within a 90-day period of the award to the state of 2nd round federal transportation economic stimulus funds. The bill would require the department to submit a monthly status report to the Legislature! as specified, with respect to certain milestones for expenditure of these funds. The bill would make related legislative findings and declarations. Legislative Update March 8. 2010 7 I I I I I I I I I I I I March 3, 2010 Mayor Pat Burt City of Pa 10 Alto 250 Hamilton Avenue Palo Alto, CA 94301 ATTACHMENT G Ilk! lfl MAR -0 PM 12: 18 Subject: Request for Information from City of Palo Alto Dear Mayor Burt, PRP-1802-LTO-PAL-00l Please pardon the inordinate delay in responding to the City of Palo Alto's detailed request for information submitted to Dominic Spaeth ling bye-mail on January 15,2010. Please know we are in the process of responding to your request. The Business Plan, Methodology and General requests and questions have been forwarded to CHSRA Headquarters (Sacramento) and you will receive a response from them directly. Below are some answers to the questions which pertain specifically to Caltrain. We will respond to the other requests and questions related to Engineering and Operations by March 19,2010. Budget 11. What is the dollar value of using Caltrain right of way for High-Speed Rail? The dollar value for using the Caltrain right of way for high-speed train service has not yet been determined. 12. Are there plans for re-utilizing the railroad corridor to build developments to pay for the High-Speed Rail Project. There are currently no plans to reutilize the railroad corridor for development to pay for the High-Speed Train Project. 13. What are the estimated costs for property values impact, right of way purchase and other temporary construction easements needed during construction? The cost estimates have not been completed. This will be part of a future negotiation between the CHSRA and JPB. Operations 2. What are the latest operational plans for the 2020 or 2035 (whichever is related to the start of HSR service)? The assumptions for future Caltrain service will be provided under separate cover by March 19, 2010. 4. What is the cost/benefit of operations and costs related to not having compatible equipment in terms of platform height, width and train sets? No cost/benefit analysis has been done, but the primary issue of non-compatible equipment between Caltrain and high-speed trains is that they will not be able to share the same platform edge if level-boarding access is to be provided. 5. What is the cost/benefit of having freight and not having freight? Caltrain receives annual payment from the freight operator based on gross tonnage. This amount varies each year. PENINSULA RAIL PROGRAM 799 Seventh Street San Francisco, CA 94107 ~~~ " . ..' HIGH-SPEED RAIL "J AUTHORITY Request for Information from City of Palo Alto March 3, 2010 Page 2 6. What are the restrictions because of freight? There are clearance and gradient requirements that must be met to preserve utility for freight operations. 7. What are the assumptions related to Union Pacific's rights? Assumptions are based upon the existing Trackage Rights Agreement between the Union Pacific and JPB. 8. Provide copies of applicable train horn blowing policies for trains passing through stations. There is no written policy, however, train engineers may use horns at stations at their discretion based on safety conditions. 9. We want a copy of the final EIR for Caltrain which is missing from all websites. And it should be posted next to the draft EIR on the Caltrain website. We are working to get the Finol Electrification EIR posted to the website. Thank you for your understanding as we seek to continue to provide the highest standard of project management on this historic project. CC: Steve Emslie, City of Palo Alto Dominic Spaeth ling, CHSRA PMT Jeffrey Barker, CHSRA Michelle Bouchard, Caltrain Doc. Control PENINSULA RAIL PROGRAM 799 Seventh Street San Francisco. CA 94107