HomeMy WebLinkAboutStaff Report 221-10City of Palo Alto
City Manager's Report
TO: HONORABLE CITY COUNCIL -10
FROM: CITY MANAGER DEPARTMENT: PLANNING
AND COMMUNITY ENVIRONMENT
DATE: APRIL 19, 2010 CMR: 221:10
REPORT TYPE: ACTION
SUBJECT: Approval of Comment Letter on the Revised Draft Program EIR for the Bay
Area to Central Valley High Speed Train Project and Review of Guiding Principles
RECOMMENDATION
Staff recommends that the City Council
1. Authorize the Mayor to sign the attached letter to the Califomia High Speed Rail Authority
(Authority) detailing Palo Alto's comments on the Revised Draft Program EIR for the Bay
Area to Central Valley High Speed Train Proj ect.
2. Review the Guiding Principles and direct staff to retum with revisions for Council approval.
BACKGROUND
On March 4, 2010, the HSRA released a Revised Draft Program Environmental Impact Report.
A 45-day public comment period began on Mareh II, 2010, and will end on April 26, 2010. The
documeot includes the changes made in response to the court decision, focused on the Gilroy
San Jose alignment and alternatives to using the Union Pacific Railroad right-of-way.
On April 7, 2010 the Planning and Transportation Commission reviewed the DEIR and a draft of
the comments prepared by staff. The Council reviewed the draft and PTC comments on April
12, 2010, accepted public testimony and provided further direction to staff to finalize the
comment letter for Council approval on April 19.
In March 2009, the City council established the High Speed Rail Committee to represent the City
in public at meetings with community groups and stakeholders, when speaking to other public
agencies, when providing written correspondence or testimony in advocating for legislation
related to high speed rail; and to speak at public hearings on short notice when full City Council
discussion is hot feasible.
On May 18, 2009, the City Council adopted the Guiding Principles (Attachment B) as a means to
provide ongoing direction to the High Speed Rail Committee. On April 12, 2010, the Council
referred the HSR Guiding Principles to the HSR Committee for review and comment. The
Committee was scheduled to review the Guiding Principles on April 15.
DISCUSSION
This report transmits the revised draft comments on the Revised Draft Program EIR for the Bay
area to Central Valley HST Project (Attachment A).
CMR: 221:10 Page 1 of2
,Base,d on the input from the Planning and Transportation Commission, stakeholder groups and
J ''co~lci1 discussion on April 12, staff and the City's enviroumental planning consultant have'
\,revised and expanded and elaborated on the issues and concems included in the comment letter.
Staff requests that Council accept or modify the letter and authorize the Mayor to sign the
approved letter.
The HSR Committee had not yet met to discuss the Guiding Principles when this report was
prepared. It is expected that the Committee will propose changes to the Guiding Principles to
address issues and situations for which fUlther Council direction may be needed given the current
status of the High Speed Rail Project. A summary of comments and recommendations from the
meeting as well as a draft of the proposed revisions to the Guiding Principles will be provided to
the Council at-places on Apdl 19.
POLICY IMPLICATIONS
The recommendations in this repOit 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. Draft Comments Letter on Bay Area to Central Valley Draft Revised Program ElR
B. Guiding Princip les
The Revised Draft Program ElR for Central Valley to Bay Area High Speed Rail Project, March
2010 is available online at: htlp:llwww.cahighspeedrail.ca.gov/lib!lIly.asp?p=92}4
The 2008 Final Progrllln ElR for Central Valley to Bay Area High Speed Rail Project is available
online at: http://www.cahighspe(l~!J:ail.ca.govJlipJary.asp?n=9274
PREPARED BY:
GAYLE KENS
ent Spe' .
APPROVED BY:
CITY MANAGER APPROVAL:
CMR: 221:10 Page 2 of2
ATTACHMENT A
April 13, 2010
Califol11ia High Speed Rail Authority
Attn: Dan Leavitt, Deputy Director
925 L Street, Suite 1425
Sacra!llento, CA 95814
DRAFT
Subject: Bay A.·ea to Centrdl VaIley Revised Draft Program-Level EIR Material Comments
Dear Mr. Leavitt:
Thank you for the opportunity to comment on the California High Speed Rail Authority's
March 20 I 0 Bay Area to Central Valley lligh-Speed Train Revised Draft Program EIR
Material. The California HST project will have a long-lasting and far-reaching impact on
the City ofPato Alto. The City has thoroughly reviewed the Revised Draft Program EIR
and has the following comments:
A. General Comments and Process
A.I Public Meetings
CommentA.l·l -No scoping sessions or public meetings were held anywhere on the
Peninsula between San Jose and San Francisco for the Revised Draft Program EIR.
Peninsula cities were also not included in the Outreach before the Second Draft Program
EIRIEIS process. The failure of the California High-Speed Rail Authority (CHSRA) to
solicit comments from communities along the Peninsula during the seoping process, the
ElR/EIS public review process, or the Revised Draft Program EIR process violates the
public review requirements of the Califomia Enviromnental Quality Act (CEQA, and
renders the cunent Revised Draft EIR inadequate.
A.2 Significant New Information
Comment A.2-1 . Significant new information exists, under many environmental
parameters, that makes the earlier Program ElRJEIS invalid and requires a recirculation of
the Program ElRJEIS, as well as recirculation ofthe Revised Program EIR.
Comment A.2-2 -The ridership and revenue modeling used for the analysis and altematives
comparison is flawed, particularly given the new infonnation provided in the 2009 Business
Plan update and the major shifts in the economy since the forecasting was last completed.
The ridership models need to be revised to provide a more accurate forecast of ridership.
Mr. Dan Leavitt
. April 14, 2010
Page 2 of21
Comment A.2-3 -New infonnation on project impacts and altematives is being discovered
during the project-level enviromnentai review for the San Francisco to San Jose and San
Jose to Merced segments. TIlis new infonllatioll may indicate new or increased impacts,
and new feasible alternatives or mitigation measures. TIle new infol111ation needs to be
presented and analyzed in a revised and recirculated enviromnental document.
Comment A.2-4 -New infOlmation has been presented in the Revised Draft EIR regarding
the use of the Monterey Highway median for pOltions ofthe high-speed train (RST) right
of-way (ROW).·The document fails to address how the use ofthis median may result in
impacts associated with noise, land use, property, traffic, and construction impacts.
Conullent A.2-5 -The recently ruIDounced project to conduct a seismic retrofit of the State
Route 92 San Mateo bridge opens the possibility of placing a HST crossing in conjunction
with rebnilding the blidge. The environmental document needs to be revised alld
recirculated to incorporate the alignment altematives provided by this seismic retrofit
project.
Comment A.2·6 -The need to evaluate impacts from Union Pacific Railroad's (UPRR)
recent refusal to share it, ROW opens up the possibility of considering neW alternative
alignments for not only the Pacheco Pass alignments but also the Altamont Pass aliguments,
including an Altamont Pass alignment that would run along State Route 84 through the East
Bay rather thall along the UPRR ROW.
A.3 Limiting Scope of Comments to the Revised Draft Program EIR
Inappropriately Limits the Analysis
Comment A.3-1 -Limiting the scope of comments to the Revised Materials is inappropriate
if the original analysis was flawed.
A.4 Inappropriate Listing of Supporters and Opponents
Conlment AA-l ~tt is inappropriate to list the agencies and organizations who SUPP~lIt, or
have expressed concem over, the selection of the Preferred Alternative (Sections 7.3.2 and
elsewhere) in the document. Their conunents and concems should certainly be .
acknowledged when deciding on the scope of analysis in the EIR, but their identification in
this document can have the effect of unnecessarily pitting one agency or organization
against another, rather than focusing attention on which environmental issues need to be
addressed in the document.
A.5 L<\ck of Tables Makes Analysis Difficult
Comment A.5c 1 -The presentation of data in the text is confusing and makes the analysis
difficult to follow. The infOimation would be more presentable alld understandable to the
lay reader ifpl'esented in tables. An example of where such a table would be appropriate is
Mr. Dan Leavitt
April 14, 2010
Page 3 of21
on page 7-17 in the Travel Times/Travel Conditions section of the document. Conversely,
the text on page 4-3 repeats the infol1llation already presented in Table 4-1. More careful
use of tables is warranted.
B. Inadequate Project Description and Business Plan
B.l Project Description
Comment B, 1-1 -The project description is essentially limited to the alignment ofthe track
corridors and possible stations, but does not mention the additional support facilities, other
than the maintenance facility, that would be needed. These additional support facilities
would include layover facilities, tumouts, bridges and tunnels, advanced signaling and
communication~ systems, electrification facilities, station automobile parking stmctures,
and the public open spaces needed to support the pedestrian traffic generated by the hub
stations. The Revised Program ErR is inadequate because they are not identified or
analyzed in the document. If the potential environmental impacts of these supporting
facilities are not going to be addressed in the Program EIR, they shoutd be identified, the
typieal effects explained, and should be addressed in detail in the forthcoming project-lcvel
engineering and environmcntal reviews.
Comment B.1-2 -Grade separations are not identified in the document. The document
should indicate which crossings are expected to be separated, and define whether each
intersection is to be separated by underpasses or overpasses (presumably the vehicular and
pedestrian traffic and not the HST). Grade separations cause substantially more
construction, snrface disturbance, noise, air quality, aesthetics, and transportation conflicts.
An elevated railway would be a significant change from the existing landscape, and could
have significant impacts on neighboring communities. Project construction could have
significant impacts, such as disruption of existing rail service and dismption of local
businesses; these issues are not addressed in the ElR. These impacts must be analyzed for
the CEQA document to be adequate.
Comment B.1-3 -The document fails to adequately describe the location of the project,
including the proposed right-of-way, station locations, and other infrastructure locations.
The cOITesponding impacts are not analyzed and no mitigation is proposed.
Comment B.1-4 -The document fails to adequately indicate the extent to which the project
would require acquisition of private propelty through eminent domain. This issue applies to
both use of existing corridors where such corridors need to be widened, and the possible
requirement for identifying a new corridor should UPRR block the shared use of its ROW.
The document also does not identify whether eminent domain would include the taking of
all or only a portion of any of the neighboring properties along the alignment.
Comment B.l-5 -The document fails to address the maintenance of the HST line, and does
not answer the questions of how often and when maintenance activities would occur, and
Mr. Dan Leavitt
April 14, 2010
Page 4 of21
what additional infrasll11cture would necd to be constmcted (rail spurs, repair shelters) to
allow the maintenance activities.
Comment B.1-6 -The statement that ... "The prefell'ed maintenance and storage facility
location to support the lIST fleet in the study region is the Merced area (Castle AFB)"
(page 7-28, Section D Maintenance Facilities) conh'adicts the statement in the Program
EIRJEIS on page 2-48, second paragraph, that states that ... "One fleet storage/service and
inspection/light maintenance facility would be needed for each major branch of the
statewide lIST system ... These facilities would need to be sited as near as possible to the
terminal stations (emphasis added)," Merced is about 120 miles from San Francisco. The
Revised DraftPmgram EIR fails to identify tlIe location ofthe maintenance facility in the
Peninsula segment of the HST system.
Comment B.I-7 -The Federal Rail Authority (FRA) does not allow heavy rail and light rail
to share the same corridor. The proposed project would require an exemption from FRA
regulations in order to move forward as proposed. The document does not address the
feasibility of obtaining this exemption from the FRA, nor does the document address what
alternatives are available if the FRA does not grant this exemption.
Comment B.I-8 -The document does not address how the land beneath an aerial viaduct
would be used and maintained. What would be the use of the land beneath the viaduct
parking, landscaping? Would the area be open or fenced off? Who would be responsible for
maintaining this area to reinove weeds, clean up trash, remove graffiti, etc.? Who would
pay for this maintenance?
Comment B.1-9 -The document does not define how eminent domain would be used to
widen an existing cOlTidor or to create a new con'idoL For example, would the CHSRA
only tl1ke the back yard of a residential property, or would CHSRA be forced to take the
entire property even if only a portion of the property is required for the COITidor?
Comment B.l-IO -Section 2704.09 of Assembly Bill (AB) 3034 sets design characteristics
and goals for an HST system. These goals include maximum limits on travel times, such as
a maximmn travel time from Oakland to Los Angeles of2 hours 40 minutes, and a
requirement that such travel be accommodated without the need to change trains at any
point along the journey. The project description and subsequent EIR analysis is flawed
because it does not address theserequirements. The City of Oakland is not cUlTentiyon the
proposed HST aligmnent, and therefore travel to or from Oakland would involve a transfer
onto another h'ain ortraI)Sit system, and would require mOl'e'lhan 2 hours and 40 minutes of
travel time. The project description and aitematives,need to be revised in order to add
Oakland to the syst<;)ITI, either by coming north through Pacheco Pass and San Jose, or west
tln'ough the Altanlont Pass.
Mr. Dan Leavitt
April 14,2010
Page 5 of2l
B.2 Flawed and Inadequate Business Plan
Comment B.2-1 ~ The Revised Draft Program EIR fails to provide an explanation of the
methodology used to calculate ridership figures.
Comment B.2-2 The document fails to include an explanation of what portions of
projected ridership would occur regardless of whether the project was approved or
regardless ofthe aligmnent altemative chosen. .
Comment B.2-3 -The ridership forecasts in the analysis are flawed and grossly
overestimate the ridership that the project would generate, particularly since the ridership
. forecasts were created during a different economic cycle. Realistic ridership numbers need
to be usedjn the analysis to reflect both a robustand a poor economy.
Comment B.2-4 -The document fails to include a full tabulation and explanation ofproject
costs, including: methodologies for calculating costs, costs for each altemative and sub
altemative, costs for tunnels through developed urban areas, costs for maintenance
activities, and costs for developing ridership.
Comment B.2-S -The document does not include a tabulation of expected funding sources
for the project.
Comment B.2-6 The document does not adequately address construction costs, including
thc full economic costs of using eminent domain to either widen an existing cOlTidor or to
create a new corndor.
Comment B.2-7 -The document fails to address how nearby businesses would be affected
during project construction, if aecess would be limited, ifsmall businesses will survive, and
how citytax revenues may be affected as a result.
Comment B.2-8 -The document needs to include a realistic and defensible business plan in
order to answer the very basic question of whether the HST project is actually
enviromnentally advantageous for Califolllia.
Comment B.2-9 -Cost reporting should be in 2010 dollars, and not 2006 dollars (page 7-13,
second paragraph, last line and elsewhere in the document).
Comment B.2-l 0 -The daily ridership projections for the San Francisco station include
riders from Oakland and elsewhere in the East Bay, which is a flaw in the analysis. East
Bay ridership needs to be shown at an Oakland station location, as required by AB3034,
and not San Francisco. Once the East Bay ridership is removed from the San Franciscc
projections, the forecasted ridership at San Francisco should be dramatically reduced.
Mr. Dan Leavitt
April 14,2010
Page 6 of21
Comment B.l-Il -The December 2009 Business Plan's forecasted annual boardings for the
San Francisco to Anaheim corridor are less than half of the forecasted annual boardings
referred to in the ElR. The boarding numbers in the EIR need to reflect updated forecast
figures.
C. Environmental Impacts and Mitigation Measures
C.l General Comments
Comment C.l-1 -The Revised Program ElR identifies a Peninsula alignment and station
locations, but fails to fully identify, analyze, and mitigate all Peninsula-related
environmental impacts fi'om that specific alignment and those specific station locations. A
Program-level EIR that identifies specific project elements or project locations is required
to provide a full analysis of the impacts associated with these elements and locations.
Comment C.I-2 -The mitigation measures used in the document are often inadequate, and
in some cases so poorly described as to make it impossible to detennine the feasibility of
the mitigation measure.
Comment C.I-3 c The document fails to disclose or adequately analyze the project's
potential land use and transportation impacts associated with the use of tbe shared
CaltrainlUPRR ROW between San Francisco and San Jose, and the UPRR ROW from San
Jose to Gilroy. Perhaps more importantly, the document fails to discuss the potential
necessity of loc'!ting the project alignment away from either segment of this ROW,
particularly in. tlle San Jose to Gilroy segment where the UPRR owns and controls the
corridor. The potential need for a new project alignment in these areas necessitates a
revised analysis of project impacts.
Comment C.1-4 -The impact discussion focuses on a corridor 50 feet to either side ofthe
existing con'idor or 50 feet to either side ofthe centerline of tlle new HST alignments. The
analysis should focus on a wider cOlridor for impacts. Some impacts, such as noise, can
have. a 'significant effect several hundred or even several thousand feet away from the
project corridor. The impact discussion should be revised to use appropriately sized impact
corridors as appropriate for each specific impact, with no conidor nanower than 500 feet to
either side of the proposed HST cOlridor.
Comment C.1-5 -The impact analysis fails to address and incorporate tlle significance
criteria estahlished by each local jurisdiction affected by the project, and uses flawed
assumptions in detel1nining impact significance.
Comment C.l ~6 -The document f;Uls to indicate ho,,4 the HST project would affect Cal train
service, hoth during construction and operation. It is unclear whether Caltrain would be
able to c,ontinue providing express service once the HST system is in place. The lack of
Mr. Dan Leavitt
April 14, 2010
Page 7 of21
analysis of tilis potentially significant impact requires tilat the document be recirculated
with the complete analysis.
Comment C.1-7 -The analysis in the Revised Draft EIR glosses over local impacts and
does not provide the detailed analysis required by CEQA.
Comment C.1-8 ~ The document uses the tel1llS "exclusive guideway" and "shared
gnideway", but does not define these tenns. The document further concludes in a cursory
and conc1usory manner that "exclusive guideway" altematives should be rcjccted, and that
a "shared guideway" alternative should move forward for analysis. This conclusion is
inappropriate given thatUPRR has stated opposition to sharing their corridor.
C.2 Aesthetics and Visual Impacts
Comment C.2-1 -The Revised Program EIR fails to address a number of issues related to
aesthetics and visual impacts. Many of the proposed project elements (such as an elevated
railway, overhead wires, sound walls, and transmission lines) would likely have a
significant visual impact, and these impacts are neither fully addressed nor sufficiently
mitigated.
Comment C.2-2 -The document fails to address the visual impacts of elevated stroctul'CS
and the associated 45 miles of sound walls proposed as mitigation for noise effects. These
stroctures would represent a significant change to the visual character of the conido!'. The
document also fails to address the shade and shadow impacts of these proposed elevated
stroctures and sound walls. The sound walls as proposed are inadequate to mitigate the
projcct's noise impacts, and will likely need to be made cven taller, which would have a
cOlTesponding increase in impacts on aesthetics.
Comment C.2-3 -The visual impacts of the ncw utility infrastrocture, in pruiicular the
electrical substations, transmission lines, and overhead electrical rail lines, arc not fully
addressed in the Reviscd Program EIR. The document does not provide locations for the
proposed substations and transmission lines, so no analysis of aesthetic impacts can be
perfOlmed. The City of Palo Alto is in the process of placing all existing overhead wires
underground. The addition of new overhead wires in Palo Alto would not be in keeping
with City policies and goals. .
Comment C.2-4 -The document fails to address how the absence or removal of screening
trees along certain segments ofthe rail line would affect the impact significance of elevated
stroctures, sound walls, substations, and ncw utility pole~ and wires.
Comment C.2-5 -The document fails to address how any new vehicle or pedestrian
overpasses would affect the visual environment. Such structures would be significant new
elements in the visual landscape, and their visual impacts need to be addressed in the EIR.
Mr. Dan Leavitt
April 14, 2010
Page 8 of21
Comment C.2-6 -The document does not address whether the project would include
nighttime lighting, and what impacts such lighting would have on neighboring uses,
particularly on two-story residences across from an elevated railway .
•
C.3 Agriculture
Comment C.3-1 -Direct impacts to agricultural resources would occur if the HST
alignment and associated infrastructure (substations, utility lines, etc.) needed to pass
tin'ough lands that are cunently in agricultural use. The document fails to adequately
address the loss of prime agricultural land, partiCUlarly if the proposed ROW must be
relocated away from the UPRR ROW within the San Jose to Gilroy corridor. This
relocation could be necessitated by UPRR's refusal to share a ROW with the HST system.
C.4 Air Quality and Greenhouse Gases
Comment C.4-1-The document fails to fully disclose or adequately analyze the project's
potential air quality impacts, including the production of greenhouse gases (GHG) and
contribution to global climate change.
Comment C.4-2 -The analysis focuses on emissions associated with operations. It does not
consider constlUction impacts and their contribution to GHG emissions.
Comment C.4-3 -Construction activities will cause major traffic disruptions, resulting in
indirect air quality and GHG emissions from idling vehicles. These potential emissions
were not analyzed in the document.
Comment C.4-4 -New electrical infrastructure (transmission and distribution lines and
substations) will be required. The construction impacts of these facilities are not included in
the analyses.
Comment C.4-5 -Greenhouse gas emissions should be recalculated and reconsidered based
on updated and realistic ridership figures. Sce. Comment A.2-2.
Comment C.4-6 -The comparison of rail travel GHG emissions to air travel GHG
emissions should be revised to account for the reductions in air travel since 2002 and the
improvements made in emissions from air travel. See Comment A.2-2.
Comment C.4-7 --The document fails to adequately compare air quality and GHG
emissions between the altemative options for the new railway elevated viaduct, elevated
benll, at grade, below grade, and underground. Construction activities and dUration vary
dramatically for different types of constlUction. Air quality and GHG emissions for longer
duration constlUction should be considered.
Mr. Dan Leavitt
April 14, 2010
Page 9 of21
Comment C.4-8 -The document uses flawed assumptions in the impact analysis. For
example, it is impossible to run on 100 percent clean, zero-carbon emissions electricity.
Zero-carbon emissions electricity does not exist. "Clean energy" cannot be separated fi'om
other electricity, and is itself not 100 percent clean.
Connnent CA-9 -Does the project actually reduce emissions, or only move them out
further into the future? This issue is not considered in the analysis.
Comment CA-l 0 -Construction emissions, especially GHG emissions, should be
anlOrtized and included in the analysis.
Comment CA-ll -Construction activities include rebuilding Caltrain, which will result in
a disruption in service and in tum result in commuters and travelers finding other
transportation options, likely increasing vehicular emissions.
Comment C.4-12 -In addition to direct air and GHG emissions associated with Caltrain
rebuilding, the project will also result in indirect traffic and air emissions. These emissions
have not beeninc1uded in the impact analysis.
Comment CA-13 -The required new electrical infrastructure will result in both
construction and operational particulate and GHG emissions (SF6 from substations). These
emiSSIons have not been included in the impact analysis.
C.S Biological Resources
Comment C.5.1 -Statements such as those on page 7-13 (second paragraph, lines 4-7) ...
"That the preferred altemative to San Francisco would have slightly less potential impacts
on wetlands (15.6 ac vs. 17A ac), waterbodles (3.8 ac vs: 4.5 ac), and streams (20,276
linear ft. vs. 21,788linear ft), but would have slightly more potential impacts on floodplains
(520.6 ac VS. 477.5 ac) and species (plant and wildlife) ... " are not very helpful without
knowing something about the cun'ent quality, trends, susceptibility, and other threats
(cumulative or otherwisc) to these resources. An attempt to look at these from a landscape
point of view should be considered. Just providing disturbed acreage estimates can be very
misleading, and could support or lead to incorrect conclusions about the comparative
. severity of impacts between altematives.
Comment C.5.2 -It is a mistake to equate only miles of disturbance with environmental
impacts: For example, on page 7-15, second paragraph, lines 5-8, the document states,
"However, this alternative has greater enviroumental impacts ... since it requires nearly 38
additional miles ofHST aligument to be constructed along the east bay" and repeats this
statement on page 7-15, third paragraph, lines 5-7. The severity of the environmental
impact depends on what biological resources are encountered in those 38 additional miles,
·and what is. encountered in the original alignment before the 38 miles are added on.
Similarly, the impacts depend on the nature/severity oflhe impacts encountered. One
Mr, Dan Leavitt
April 14, 2010
Page 10 of21
significant impact in a Sh011 stretch of alignment would have more weight than several, or
indeed many,less than significant impacts in a longer stretch of alignment.
Comment C.5,3 -The document perpetuates a common enor in only considering threatened
and endangered species (T&E species). EIRs and EISs are not environmental compliance
documents. They are envhomllental impact assessment documents. Yet there is no
. consideration of the potential for impacts to many non-T &E species, especially keystone
species, particularly in terms of habitat loss and fragnlentation.
Comment C.5-4 -The docnment does not address the wide-ranging effects of air and water
emissions (pollution) and noise on biological resources, particularly wildlife and their
critical habitat. The harmful effects of pollution have contributed to the listing of numerous
species under the Endangered Species Act, yet the document focuses on the direct impacts
associated with the loss of habitat. Habitat fragmentation and degradation are not addressed.
The indirect effeets of air, water, noise, and other emissions, even if they meet regulatory
andlor pe!mit thresholds, are ignored. Not all habitats are of equal imp011anee. Certain
habitats disprop01tionately conbibute to ecosystem functioning and are analogous to
keystone species. Even non-keystone habitats vary in quality with very different functional
value. These nuances are ignored cir overlooked, and should be the major focus of affected
environme!lt discussions.
Comment C.S-5 -The document fails to. adch'ess the potential loss of valuable wildlife
habitat, including wetlands, pal1icularly if the proposed right-of-way must bere10cated
away from the CaltrainiUPRR right-of-way anywhere along the San Franciscoto Gilroy
corridor. Such a relocation could be necessitated by Union Pacific's refusal to share a ROW
with the HST system.
Cemment C.5-6 The document fails to address impacts to trimming or renlOval of mature
or heritage trees along project alignment, including effects to El Palo Alto, the iconic
herit'lge redwood b'ee in Palo Alto.
C.6 Cultural Resources
Comment C.6-1 -The document fails to fully address impacts to histodc resources and
Native Ame!ican archaeological sites along the alignment, The do.cument do.es not ide!1tify
and name each type of historic resource, and only identifies the total number of such
resources located along eilCh aligument. It is therefore not possible to assess the
significance of the impacts. The document also fails to address the potential impacts to
cultural resourees from the UPRR's refusal to share its ROWand the potential need to
identify a new alignment.
Comment C.6-2 -Inadequate measures are provided in the documellt to mitigate the 110ise,
vibration, and visual impacts'ofthe proposed HST system on the historic resources located
near the proposed alignment.
Mr. Dan Leavitt
Apri114,2010
Page II of21
C.7 Environmental Justice
Comment C.7-1 -The document uses ineolTect methodology for its analysis of
environmental justice impacts.
Comment C.7-2 -The possibility of enviromnental justice issues is not necessarily related
to distance from the HST line (page 2-5, third paragraph, and page 2-7, second paragraph,
lines II and 12), but rather thc geographical extent of impacts, such as noise, traffie
congestion, air quality degradation, etc. .
Comment C.7-3 -Limiting potential property impacts to land uses within 50 feet of either
side ofthe existing COlTidor, or within 50 feet of both sides of the centerline for new HST
alignments, is too restrictive and limiting to fully assess impaets. Potential enviromnental
impacts could extend well beyond 50 feet, and so too would the potential for
disproJ(ortionate impacts to minority and.low incomc populations.
Commcnt C. 7 -4 -The potential for environmental justice impacts exists whether the
minority orlow income population is I, 5, 10,20 percent or 50 percent of the total (page 2-
5, first bullet). The question is not what the minority or low income population is, but
whetherit is disproportionately impacted regardless of size. The potential for enviromnental
justice impacts is made on a detenrunation of whether or not there are disproportionate
impacts to minority or low income popUlations, not just whether minority of low-income
popUlations exist along the alignment. The wording ofthe enviromnental justice section in
Chapter 6 should use the tenn "potential for enviromnental justice impacts" rather than
whether the alignm~nt has a "low, medium, or high enviromnentaljustice impact rating".
c.s. Geology and Seismicity
Comment C.8-1 -Thc document fails to adequately address potential impaets and risks
associated with the rail'line crossing several active and potentially active fault zones.
Potentially high risks are associated with all rail altematives crossing active and potentially
faults. These risks, for both constlUction and operations, are not fully addressed. Crossing
the Calaveras Fault in a hmnel represents a particularly high risk. Altematives to a tunnel
crossing should be considered.
Comment C.8-2 -The document fails to adequately address impacts resulting from a major
ealthquake and associated strong ground motion.
Comment C.8-3 The southern alternative mus nOlih through areas with potential effects
from liquefaction. Fonndations and SUppOlts for this altemative will require more
engineering and robust constlUction, resulting in greater traffic dismptions and increased air
emissions. These factors are not addressed in the analysis.
Comment C.8-4 The height of elevated structure is not indicated in the analysis. The
lateral seismic loading on these structures needs to be addressed. Substalltially larger (and
Mr. Dan Leavitt
April 14,2010
Page 120f21
more frequent) supports may be needed, possibly resulting in greater visual impacts or evcn
the need for a wider ROW to accommodate the structural supports.
e.9. Hazards and Hazardous Materials
Comment C.9-1 .. -The document fails to address the public health and safety impacts due to
possible derailments on the Union Pacific, Caltrain, or HST lines and subsequent collisions
with high speed trains. The derailment hazards and damage to adjacent rail lines are not
addressed, and the potential damage to properties adjacent to rail lines reSUlting from train
derailments is not addressed. The document does not consider establishing hazard buffer
zones to addres~ derailment impacts.
Comment C.9-2 -The document fails to address other possible collisions with trains.
Multiple trains (HST, Caltrain, freight) l.\sing the same tracks pose increased risks of
collisions. In addition, it has not been demonstrated in the enviromnental document that
multiple HST trains operating concuTI"ently would be able to stop in time if problems from
other operations oceur.
Comment C.9-3 -The document fails to address confliets with existing underground toxic
plumes. The approach and methodology in the document is flawed as it only used databases
listed in evaluating possible underground contamination. Additional infOlmation on
underground contamination is available and needs to be incorporated into the analysis.
Comment C.9-4 -Contamination along existing railroad ROWs is common. The analysis
does not consider this typically occuTI"ing hazardous contamination, and the methods to
mitigate the disturbance and disposal of contaminated materials.
Comment C.9-5 -Acquiring new ROW increases potential for encountering more
hazardous materialS/Waste, including contaminated groundwater. This issue is not
addressed in the Revised Draft Program EIR.
e.10 Hydrology and Water Quality
Comment C.l 0-1 -The document fails to address impacts of trenching or tuuneling on
groundwater during construction. This impact applies in particular to portions of the
Altamont Route Altemati Yes.
Comment C.I 0-2 The document fails to address impacts on creek flow, creek stability,
and riparian habitat. The analysis is flawed in comparing "flood plain area" without
considering water flow direction relative to proposed structures. This comment also applies
to Comment C.I 0-4.
Comment C.l 0-3 The document fails to adequately address impacts of shallow
groundwater on operations and maintenance. For example, the document states that,
Mr. Dan Leavitt
April 14, 2010
Page 13 of21
"Infiltration of ground and surface waters into tunnels is undesirahle for operations and
maintenance reas01~S and increases the potential for adverse impacts to ground and surface
waters. All reasonable measures would be taken to avoid water inflltration," 111ese
"reasonable measures" should be identified and discussed, Potential secondary impacts
(e.g" groundwater pumping for dewatering) should also be evaluated.
Comment C.I 0-4 " In addition to operations and maintenance, potential adverse impact to
tunneling from groundwater are discounted and not fully analyzed.
Comment C.I 0-5 The document fails to adequately address the impacts on project
operations from potential flooding.
Comment G.I 0-6 -The document does not discuss the project's potential to impair or
redirect flood water flows, or displace flood water and increase flood water elevation, and
thus increase flooding risks to adjacent and upstreanl areas.
Comment C, 10-7 -lfOPRR does not allow shared use of the existing ROW, then greater
potential impacts to surface waters could result from a new ROW.
Comment Col Oc8 -The analysis does not indicate the extent of impervious surfaces that
,would be created by the project. hnpervious surfaces create increased surface discharges,
which could cause local flooding or erosion, If retention/detention basins are required to
address and offset the increase in impervious surfaces, then more land may be required in
order to accommQdate these added features.
Comment C.l 0-9·· The analysis considers the effects of 100-year floodplains, but does not
consider 500-year floodplains.
c.n Land Use and Planning
Comment C.II-I -The document fails to discuss the direct and indirect impacts of
potential "sprawl" development as a result of the project, particularly near the locations of
proposed stations such as the potential station in the City of Palo Alto. The document needs
to address the development-inducing impacts of the HST project (such as high-density
housing being constructed near stations).
Comment C.11-2 -The Revised Program EIR fails to address the displacement of residents
and businesses if the proposed ROW must be relocated away from the CaltrainlUPRR
ROW, as may be required as a result ofUPRR's refusal to share the ROW with tbeHST
system. An alternate corridor would likely involve the extensive use of eminent domain in
order to create a new aligmnent
Comment C.II-3 The document fails to adequately address land use impacts reSUlting
from the division of existing comtnunities, either through the expansion and potential
Mr. Dan Leavitt
April 14, 2010
Page 14 of21
widening of the existing CaltrainJUPRR ROWand the elevation of stl1letures within this
ROW, or through the relocation of the proposed HST cOiTidor away from the Caltrainl
UPRR ROW. Either of these two scenarios could result in the division of an existing
community.
Comment C.11-4 -The environmental document fails to address project impacts due to
potential incompatibility with local land use plans and policies, including existing or
planned uses, zoning and general plan designations and regulations, and existing or
proposed development plans. Local plans and policies need to be taken into consideration in
the land use impact analysis, and in detennining the thresholds of significance for all
environmental impact criteria.
Comment C.II-5 -The document fails to address potential impacts to local businesses,
particularly during construction. Road closures, reduced parking, and construction noise
could all make it difficult for businesses to stay in operation during construction activities.
If the HST con'idor must be relocated due to DPRR's refusal to share its ROW with the
HST system, then additional businesses would also be directly impacted by CHSRA's need
to use eminent domain to acquire properties for the new alignment.
Comment C.11-6 -The document fails to address impacts to the property valucs of
rcsidences and businesses due to aesthetics, noise, vibration, and circulation impacts from
long-tenn constl1lction activities and daily train operations.
Comment C.II-? -The document incorrectly states that the proposed project corridor
would have a "high" eompatibility rating in the selected corridor. A large portion of this
conidor passes through residential neighborhoods. The document states that single-family
residential homes have a "low" compatibility rating with HST systems, so the pOltions of
the cOlTidor that pass through residential neighborhoods should have a "low" rating as well.
Comment C.II-8 -The document fails to address that elevating the railway and erecting
45 miles of sound walls could create a physical barrier that divides a community. The
existing Caltrain/UPRR ROW does not divide commtmities to the same degree that an
elevated HST system would.
Comment C.II-9 -The Final Program EIR states on page 2-3 that the lIST has a "high"
compatibility with high schools and a "medium" compatibility with elementary schools.
The document fails to justify why high schools are more compatible with a HST system
than elementary schools.
C.12 . Minerals
Comment C.12-1 -No issues regarding minerals have been identified at this time.
C.13 Noise and Vibration
Mr. Dan Leavitt
April 14,2010
Page 15 of21
Comment C.B-I -The noise metric (page 3.4-3, second paragraph) should include
retirement homes, assisted living centers, nursing homes, and other long-tenn medieal care
facilities, museums, libraries, motels, hotels, auditoriums, churches, and cemeteries, in
addition to the number of hospitals and schools. Sensitive land uses also include mobile
homes, donllitories, parks, picnic areas, playgrounds, and active sports areas.
Comment C.l3-2 -The noise metric does not include parkland, yet Table 3.4-4 on pages
3.4-14 to 3.4-18 does include parkland in its' noise and vibration summary data used to
compare alignment alternatives. Illig inconsistency in the document needs to be corrected.
Comment C.l3-3 -The document fails to adequately address the impact significance of
noise and vibration during both constmction and operation, and fails to adequately mitigate
these impacts,
COlllment C.13-4 -The document categorizes noise and vibration impacts as "low-level",
"medium-level", and "high-level", and establishes four noise-related thresholds of
significance, but does not indicate whether the project impacts would exceed these
t11resholds and be considered significant impacts.
Comment C.B-5 -The document fails to adequately explain how the proposed mitigation
measures would address noise and vibration impaets and reduce these impacts to a less than
sigtiificant level.
Comment C.13-6 The dOClmlent addresses estimated noise levels on a region-wide basis,
and does notquantify anticipated noise levels on the proposed alignment or station
10ca.tkJl1s: .
Comment C.l3-7 -Grade separation would introduce inclines. The document does not
address how such inclines would affect noise and vibration impacts ofHST, Caltrain, and
freight train operations, particularly when climbing up an incline.
Cornment C.13-8 -The mnnber of trains per honr is proposed to increase substantially over
existing conditions, meaning that more peak noise events will occur every hour and that (he
to(al duration of peak noise events will increase. The document does not quantify the
increase in the duration of noise, nor does the document indicate whether this would be
considered a significant impact.
Comment C.l3-9 -The document fails to address the noise and vibration impacts of nightly
traek maintenanee.
Comment C.13-1 0 -The document fails to address how the different design options
(tunnel, below grade, at grade, elevated belT11, elevated viaduct) affect noise impacts.
Mr. Dan Leavitt
April 14, 2010
Page 16 of21
Comment C.B-1I -The document fails to address how wind and weather pattems would
affect noise impacts.
Comment C.13-12 -Noise impact ratings should be indicated as "high" along most of the
San Jose to San Francisco corridor due to dense residential development.
Comment C.13-13 The document addresses noise impacts from 186 mile per hour (mph)
operations, but does not address noise impacts for 220 mph speeds through Morgan Hill
and Gilroy. .
Comment C.13-14 -The document fails to quantify the potential noise reduetion provided
by sound walls, paliicularly given the presence of two-story residences and the possibility
ofan elevated railway. Without an idea of how much sound attenuation and reduction can
be achieved through the use of sound walls, there is no way to conclude that such walls
have the potential to reduce noise impacts to a less than significant level. .
Comment C.13-15 -The proposed sound wall height appears to be inadequate to address
noise impacts. The document should include an analysis oflhe effectiveness of different
heights or document why the specific height was chose.
Commenl C.13-16 -The document fails 10 address impacts of sound walls on traffic noise
for adjacent streets. Vehicle noise on streets adjacent to the lIST con'idor may bounce off
the sound wall and back out into the community.
Comment C.l3-1? -The document does not address the combined noise and vibration
impacts of two or more trains passing by a location at the same time. Identify the noise and
vibration impacts of multiple, simultaneous trains.
C;14 . Population and Housing
Comment C.14-1 -The environmental document fails to evaluate the project impacts on the
jobs/housing balance in the region.
C.1S Public Services
Comment C.IS-1 .. No issues regarding public services have been identified at this time.
C;16 Recreation
Comment C.16-1 The document fails to address access, noise, dust, vibration, and visual
impacts to parks and recreational facilities along the conidor.
Comment C.16-2 -The document does not accurately identifY and consider all ofthe parks
and recreational facilities along the proj ect route.
Mr. Dan Leavitt
April 14, 2010
Page 17 of21
Comment C.16-3 -The Section 4(f) and 6(f) (Public Parks and Recreation) ROI is 500 feet
on either side of the HST alignment alternatives centerline in non-urban areas, 100 feet
from the centerline in urban areas, and 500 feet where stations or other HST facilities are
proposed(identical to the Cultural Resomees APE). Delineating the ROI or APE so
narrowly may lead to inappropriate conclusions. For example, a park just outside the ROI
would not be included in the alignment evaluation, but still would be affected by noise
impacts from the HST. For another example, peak hour construction noise levels could be
as high as Lmax 86 to 89 dBA at 100 feet, and sound exposure levels of 100 dBA would
occur at 60 feet from HST passby at 180 mph (Figure 3.4-1, p. 3.4-7), and potential
vibration impaets from HST operations extend to 200 feet (page 3.4-5, first full paragraph,.
line 5). Noise attenuates by 6 dBA for every doubling of distance, so a park 120 feet from
the eenterline in an urban area could nominally experience a 94 dBA sound level fi-om a
HST passby, and thus be impacted. The ROI for publie parks and recreation areas should be
defined by the spatial extent ofthe impact creating source, not an arbitrary number. Noise
attenuation is also affected by intervening buildings, vegetation, and topography, and thus
noise impact assessments are more appropriate for the forthcoming project-level
engineering envirorrmental review.
C.17 Transportation and Traffic
CommentC.l7-1 -Section 7.3.3 (Network Alternatives Evaluation) is extremely complex
and detailed. This seetion would benefit from a series oftables that summarize the
evaluation criteria and how they compare and rank. As it stands now, the text-only
explanation is dense and difficult to follow.
Comment C.l?-2 -Page 3.1-1, Section B, third paragraph states that the Traffic, Transit,
Circulation, and Parking sections use year 2005 data, whereas levels of service (LOS) for
station cordons is based on data for the year 2000, and parking data is from 2002 (page 3.1-
2, second and fifTh bullets). The reliance on 8-to lO-year-old data is misleading because the
economic conditions were different at that time.
Comment C.17-3 -It is conceivable that construction-related traffic impacts could extend
. beyond the I mile or 0.25 miles distance threshold from the suburban rail stations or
downtown station locations, respectively. Adherence to this threshold could understate
impacts.
C011l1nent C.17-4 -Table 6-1 on page 6-2 of the Revised Program EIR states that "The HST
Network Altemative would reduce the number of lJ:avellanes from six to four on Monterey
Highway between Umbarger Road and Metcalf Road (near Bailey Road) in the City of San
Jose." The EIR provides no information on the LOS impacts consistent with the
information provided for other rouies in Tables 3.1-2 and 3.1-3 in the Final Bay Area to
Central Valley HST Program EIRJEIS.
Mr. Dan Leavitt
April 14,2010
Page 18 of21
Comment C.17-5 -The document fails to address the transportation-related policies and
plans oflocal jurisdictions.
Comment C.17 -6 -The document docs not identify impacts to streets during construction,
including idcntification of detours and road closures. These construction impacts could
significantly affect traffic patterns and traffic flow for extended periods of time.
Comment C.17-7 The document does not ad\h'ess increased traffic and parking impacts in
the vicinity of proposed stations.
Comment C.17-8 -The Final EIR does not include any provisions for orimpacts of multi
day parking at either Caltrain or HST stations. The need for multi-day parking further
reduces Caltrain's use as a feeder to the HST system.
Comment Col 7-9 -The document does not address impacts to pedestrian and bicycle paths
that parallel andlor intersect the proposed alignment.
Comment C.l7-10 -The document claims that Monterey Highway is underutilized, the loss
of two of the six lanes will not significantly affect traffic in the area, and the loss of these
two lanes would result in a decrease in traffic demand. The document fails to support these
conclusions, particularly the counterintuitive conclusion regarding the decrease in traffic
demand resulting from the decrease in traffic lanes. .
Comment C.17 -II -The Final EIR fails to address likely Caltrain service reductions as a
result of the project, how these service reductions would affect Caltrain's function as a
"feeder route" to the HST, and the subsequent effects on HST ridership figures. The
analysis should include consideration not only of capital improvements to Caltrain, but also
operational subsidies to assure that Caltrain remains viable.
C.iS Utilities
Comment C.18-1 -The document fails to adequately address the energy needs for the
project, the quantity of elech'icity required, and what infrastructure (transmission lines and
substations) would be required to bring the necessary power to the corridor. The document
only states that the State produces enough elechicity to serve the project's needs, and not
how that energy would he delivered to the lIST system. The analysis should identifY the
capability of existing lines to supply adequate power to the corridor.
Comment C.18-2 -The document fails to address other potential utility needs for the
project, and whether the infrastructnre is present to accommodate the project's needs.
Comment C.18-3 The document fails to identify the impacts of the relocation of all
utilities cUlTently located within or crossing the ROW. The relocation ofthese utilities
Mr, Dan Leavitt
April 14, 2010
Page 19 of21
could result in service intenllptions of water, wastewater, gas, electricity, telephone, and
cable service, and would represent an additional project expense,
C.19 Cumulative Impacts
Comment C, 19-1-The document fails to adequately address the cumulative impacts of
proposed Caltrain improvements, such as the proposed eloctrifieation of the Caltrain
system,
Comment C, 19-2 -The document fails to identify and address the cumulative impacts of
proposed roadway improvements along the entire corridor from San Francisco to Gilroy,
D. Alternatives
Comment D-l -The document fails to include infOlmation on the environmentally superior
alternative, thereby depriving the public of an oPPoliunity to comment on the methodology
used to identify that alternative,
Comment D-2 -The second Program EIRIEIS fails to analyze all alternatives at an equal
level of analysis as required by NEP A
Comment D-3 -The alternatives analysis is inadequate, inaccurate, incomplete, and biased,
as demonstrated under the following topics:
• ,The analysis of Altamont Pass Alternatives inaccurately portrays the operational
characteristics in a way that results in significantly underestimating the potential
ridership of those alternatives,
• The documentimpropedy and inaccurately discounted and found infeasible the
potential for the Altamont Pass Alternative to rebuild the Dumbarton Rail Bridge
iii a way that could be used by both the Caltrain Dumbarton Rail Project and the
proposed high-speed train.
• The document overemphasizes the aquatic impacts of rebuilding the Dumbarton
Rail Bridge and inaccurately discounts the likelihood of being able to obtain
environmental clearam,'e, At the same time, the document underestimates the
aquatic, wetlands, and wildlife impacts of the Pacheco Pass Alternative's crossing
. of the Grasslands Ecological Area and discounts the difficulty of obtaining
environmental clearance for such a crossing.
• The document improperly and inaccurately overemphasizes the impacts of a
corridor through the cities of Pleasanton and Fremont, while underestimating the
impacts of a corridor along the San Francisco Peninsula.
• The document underemphasizes the impacts of running the corridor through
portions of San Jose south of San Jose's Diridon Station by not disclosing the
Mr. Dan Leavitt
April 14, 2010
Page 20 of21
absence of undeveloped land outside of the Union Pacific corridor south of that
station.
Comment D-4 -The document does not indicate whether Caltrans has given any sort of
recognition or approval to the nan'owing for Monterey Highway for the installation of the
HST lines. Until tlus authorization is obtained, then the alternatives involving the use of the
Monterey Highway ROW are no more viable than the UPRR ROW.
Comment D-5 -The Henry Miller alignment altemitive (UPRR Comleetion), one of the
Uu-ee aligmnent altematives south of Gilroy, involves the lise of the UPRR ROW (pages 2-
16 and 2-17). This alternative should be rejected as UPRR has clearly stated that it will not
share its ROW with the HST project.
Comment D-6 -The Revised Program EIR dismisses the various Altamont alternatives
because. the identified routes required use of the UPRR ROW, which UPRR has stated that
it will not share with the HST project. No serious attempt was made to identify and evaluate
non-UPRR Altamont alternatives with the same level of detail as the San Jose to Gilroy
non-UPRR altematives.
Comment D-7 -The Program EIR dismisses aligmnents between San Francisco and San
Jose other than the Caltrain corridor with only a cursory analysis, and this dismissal
precludes a detailed analysis of potential viable aligmnent alternatives and excludes related
public comment at the Project ElR level. Most ifnot all of the other segments of the HST
system involve consideration of more than one aligmnent, and the segment from San
Francisco to San Jose deserves the same level of alternatives analysis. The following is a
partial list ofaltemative aligmnent routes that should be considered in the Program EIR at
the same level of detail as the preferred alternative:
• The doclUnent should analyze a Highway 101 alternative that involves an
AltamontIDlUnbarton crossing of the Bay, joining a Highway 101 ROW route near
Menlo Park and Redwood City, and following the Highway 101 ROW to a point
near the South San Francisco Callrain station. The route \vould then follow tile
Caltrain corridor to downtown San Francisco. This alternative would avoid most of
the Callrain corridor atul eliminate most of the devastation to the residential
. neighborhoods that would be caused by the current Caltrail1 alignment alternative.
This Highway 101 alternative would also reduce most of the impacts to schools,
parks, and historical sites along the Caltrain cOlTidor, and could be less costly than
the Caitrain cOITidor alternatives, particularly in regard to undergrounding the HST
rail lines.
". The document should address and analyze alternative alignments within or along the
Callrans ROWand Highway 280.
• The document should address and analyze all alternative where the HST aliglUuent
ends in San Jose, and then passengers transfer to Caltrain.
Mr. Dan Leavitt
April 14, 2010
Page 21 of21
Comment D-8 -TIle document does not address alternatives that would reduce the number
of tracks to less than four. The ridership forecasts are flawed and grossly optimistic.
Realistic ridership projections may conclude that only two or three tracks would be required
for the HST project, not the four tracks currently proposed. Once the forecasted ridership is
conected to (1) reflect CUiTent predictions rather than the outdated and inflated figures used
in the current ElR, and (2) remove the East Bay ridership from the San Francisco station
forecasts, then the reductions in projected traffic volume could result in the need for less
than the 4 sets of tracks proposed between San Francisco and San Jose, and it may even be
possible for the HST system and Caltrain to share only the 2 existing sets oftracks.
COlTImentD-9 -The document provides a "low" or "medium" impact rating for segments
that pass alongside residential development, wheu that rating should be higher. A proper
weighting of the relative impacts of the various alignment altematives would provide a
more accurate assessment of which alignments are environmentally superior.
Comment D-l 0 -The various con-idor segments passing through Palo Alto should be
analyzed and diseussed in an equal and equitable mamler in order to appropriately assess
which corridor alternative is truly the euviromnentally superior alternative.
E. Response to Comments
Comment E.I -The responses to comments are often perfullctory or conclusory, and not
supported by substantial evidence.
The City of Palo Alto appreciates the opportunity to provide these comments on the
Revised Draft Program EIR for the Bay Area to Central Valley HST Project.
Please contact James Keene, City Manager, at 650-329-2563 for fmther information and
coordination.
Sincerely,
PAT BURT
Mayor
cc: City Council
James Keene, City Manager
Dominic Spaeth ling, CAHSR
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ATTACHMENT B
City Council High Speed Rail Subcommittee
Guiding Principles
Adopted May 18, 2009
The City Council High Speed Rail Subcommittee, consisting of four members, is
designated by the City Council to represent the City in public in meetings with
community groups and stakeholders, when speaking to other public agencies, when
. providing wlitten c011'espondence in advocating for legislation related to high speed rail. . .
The Subcommittee will have the authority to speak on behalf of the City Council at
hearings on short notice when full City Council discussion at a regularly scheduled
Couneil meeting is not feasible. In such cases the Subconmlittee should be guided by
broad principles that are consistent with existing City Comprehensive Plan and adopted
City Council policies.
In order to ensure consistency with existing City Council positions and policies, the
Subcommittee will be guided by the following principles:
• The City is supportive of efforts to improve accountability and effective
govemance of high speed rail planning and operations.
• The City advocates advancing economic feasibility analysis and project financing
options by High Speed Rail Goveming Body to implement selected altematives.
• The Ad Hoc committee will work with peninsula cities coalition to draft
Memorandum of Understanding with Caltrain and HSRA and retum to full
Council for review and approval.
• The City understands the opportunity to apply for Federal stimulus funding but is
concemed that enough time is allowed for appropriate analysis, public process,
and decision making.
• The City recognizes that High Speed Rail, if done correclly, has the potential to
minimize adverse impacts and be beneficial to the community.
• While acknowledging that the cnrrellt direction for the San Jose to San Francisco
High Speed Train project is to use the Caltrain light,of-way as the for the high
speed rail corridor betweell San Jose and San Francisco, the City is open to and
could support altemative alignments.
• The Ad Hoc Committee will be guided by the City of Palo Alto Scoping
Comments for the Califomia High Speed Rail Authority's San Francisco to San
Jose High Speed Train (HS1) Environmental Impact Report/Environmental
Impact Statement (EIR/EIS).
• The City SUppOlts Caltrain electrification and improved commuter rail services
betwcen San Francisco and San Jose. The City SUppOlts evaluation of operating
conditions along the Caltrain right-of-way that would be conducive to a high speed
rail intercity Connection in San Jose, with improved Caltrain conmmter rail service
between San Jose and San Francisco.
• The City is supportive of exploring creative ui:ban design and use of context
sensitive design processes that consider community values in collaborative
community-sensitive planning and for the high speed rail project.
• The Subcommittee shall provide monthly reports fothe Council on the activities of
thc Peninsula cities Consortium ..
• The Subcommittee will meet regularly with community leaders and stakeholders
to inform and involve the larger Palo Alto community in the planning, review,
oversight and decision-making for the San Francisco to San Jose HST project.
'I.
..