HomeMy WebLinkAboutStaff Report 7037City of Palo Alto (ID # 7037)
City Council Staff Report
City of Palo Alto Page 1
Report Type: Consent Calendar Meeting Date: 6/6/2016
Summary Title: Authorization for the Mayor to Sign a Letter Responding to
the CHRSA
Title: Approval and Authorization for the Mayor to Sign a Letter Responding
to the California High Speed Rail Authority's Notice of Intent/Notice of
Preparation
From: City Manager
Lead Department: Planning and Community Environment
Recommendation:
Staff recommends that the City Council approve and authorize the Mayor to sign the City’s
response to the California High Speed Rail Authority’s (CAHSRA’s) Notice of Intent/Notice of
Preparation (NOI/NOP) of an Environmental Impact Statement/Environmental Impact Report
(EIS/EIR) for the San Francisco to San Jose segment of their blended system project. The draft
letter has been reviewed and recommended by the Council’s Rail Committee.
Executive Summary:
The CAHSRA is proceeding with environmental review of the segment of the high speed rail
project proposed from San Francisco to San Jose and is seeking input on the scope of the
environmental document. (A copy of the CAHSRA’s NOI and NOP are included as Attachments
A & B.)
A draft comment letter was reviewed by the Rail Committee on May 31, 2016 and the proposed
response in Attachment C reflects their direction. The City’s written response is due June 10,
2016.
Attachments:
Attachment A: HSR NOP May 2016 (PDF)
Attachment B: Notice of Intent HSR May 2016 (PDF)
Attachment C: Response to HSR NOI-NOP June 2016_with RC Comments_Clean (DOCX)
#13
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The Federal Register
The Daily Journal of the United States Government
Notice
Environmental Impact Statement for the California
High Speed Rail System San Francisco to San Jose
Section, CA
A Notice by the Federal Railroad Administration on 05/09/2016
This document has a comment period that ends in 12 days (06/08/2016) Submit a formal
comment
Read the 22 submitted public comments
Action
Notice Of Intent (Noi) To Prepare An Environmental Impact Statement (Eis).
Summary
Through this NOI, FRA announces its intent to jointly prepare an Environmental Impact Report
(EIR) and Environmental Impact Statement (EIS) with the California High-Speed Rail Authority
(Authority) for the San Francisco to San Jose Section of the California High-Speed Rail (HSR)
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System, Blended System Project (Blended System Project or Project). FRA invites the public and all
interested parties to provide comments on the scope of the EIR/EIS, including the proposed
purpose and need, the alternatives to consider, potential environmental impacts of concern, and
methodologies for analysis of impacts. Through this NOI, FRA also rescinds its December 2008
NOI for the San Francisco to San Jose Section.
FRA and the Authority will develop the EIR/EIS in compliance with the California Environmental
Quality Act (CEQA) and the National Environmental Policy Act of 1969 (NEPA). FRA and the
Authority will hold scoping meetings and outreach activities as part of the NEPA/CEQA process.
Federal cooperating agencies for the EIR/EIS are the Surface Transportation Board (STB) and the
U.S. Army Corps of Engineers (USACE).
Table of Contents
•DATES:
•ADDRESSES:
•FOR FURTHER INFORMATION CONTACT:
•SUPPLEMENTARY INFORMATION:
•Purpose and Need
•Alternatives
•No Action Alternative
•HSR Blended System Alternative(s)
•Probable Effects
•Scoping and Comments
DATES:
Written comments on the scope of the San Francisco to San Jose Section EIR/EIS must be
provided to the Authority by June 8, 2016.
Public scoping meetings are scheduled in May 2016: FRA and the Authority will hold the scoping
meetings between 5:00 p.m. and 8:00 p.m. at the following dates:
•San Francisco:Monday, May 23, 2016.
•San Mateo:Tuesday, May 24, 2016.
•Mountain View:Wednesday, May 25, 2016.
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The Authority will make scoping materials and information concerning the scoping meetings
available on the Authority's Web site:
http://hsr.ca.gov/Programs/Statewide_Rail_Modernization/project_sections/sanfrancisco_sanjose.html.
ADDRESSES:
You can send written comments on the scope to Mr. Mark McLoughlin, Director of Environmental
Services, Attention: San Francisco to San Jose Section EIR/EIS, California High-Speed Rail
Authority, 770 L Street, Suite 1160, Sacramento, CA 95814, or via email with subject line “San
Francisco to San Jose Section EIR/EIS” to: comments@hsr.ca.gov.
You may provide comments orally or in writing at scoping meetings. FRA and the Authority will
hold the scoping meetings between 5:00 p.m. and 8:00 p.m. at the following locations:
•San Francisco:University of California, San Francisco Mission Bay, 11500 Owens Street, San
Francisco, CA 94158.
•San Mateo:San Mateo Marriott, 1770 South Amphlett Boulevard, San Mateo, CA 94402.
•Mountain View:SFV Lodge, 361 Villa Street, Mountain View, CA 94041.
FOR FURTHER INFORMATION CONTACT:
Ms. Stephanie Perez, Environmental Protection Specialist, Office of Program Delivery, Federal
Railroad Administration, 1200 New Jersey Avenue SE., (Mail Stop 20), Washington, DC 20590;
Telephone: (202) 493-0388, email: stephanie.perez@dot.gov,or Mr. Guy Preston, Regional Delivery
Manager, California High Speed Rail Authority, 100 Paseo de San Antonio, San Jose, CA 95113,
Telephone: (408) 277-1091 or sanfrancisco_sanjose@hsr.ca.gov.
SUPPLEMENTARY INFORMATION:
FRA is an operating administration of the U.S. Department of Transportation and is responsible for
overseeing the safety of railroad operations, including the safety of any proposed high-speed ground
transportation system. FRA is also authorized to provide, subject to appropriations, funding for high
-speed and intercity passenger rail projects and is also authorized to provide loans and other
financial support for railroad investments. FRA is conducting this review under NEPA because it
may provide funding or financing for this project in the future. STB and USACE are Federal
cooperating agencies on the EIS. STB has approval authority under 49 U.S.C. 10901 over the
construction and operation of the proposed California HSR System. USACE has jurisdiction under
Section 404 of the Clean Water Act.
The Authority was established in 1996 and is authorized and directed by statute to undertake the
planning and development of a proposed statewide HSR network fully coordinated with other public
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transportation services. In 2005, the Authority and FRA completed a Final Program EIR/EIS for
the Proposed California HSR System (Statewide Program EIR/EIS), as the first phase of a tiered
environmental review process. The Statewide Program EIR/EIS analyzed a No Project/No Action
Alternative; a Modal Alternative involving expanding freeways, airports, and conventional rail
systems; and a HSR alternative using electric propulsion and steel-wheel-on-steel-rail vehicles capable
of operating speeds of 220 mph on fully grade separated rail alignments with state-of-the-art safety,
signaling, and communication systems. The Authority certified the Statewide Program EIR under
CEQA and approved the proposed HSR System, and FRA issued a Record of Decision under
NEPA on the Statewide Program EIS.
In approving the Statewide Program EIR/EIS, FRA and the Authority selected the HSR Alternative
for intercity travel in California between the major metropolitan centers of Sacramento and the San
Francisco Bay Area in the north, through the Central Valley, to Los Angeles and San Diego in the
south. The Authority and FRA also selected certain corridors/general alignments and general station
locations for further study; committed to mitigation strategies and design practices; and specified
further measures to guide the development of the HSR system at the site-specific project level of
environmental review to avoid and minimize potential adverse environmental impacts. FRA and the
Authority did not select corridors or station locations between the Central Valley and the Bay Area
in 2005. Rather, they decided to prepare a second program EIR/EIS for that area.
In 2008, the Authority and FRA further evaluated alignments and station locations within the broad
corridor between and including the Altamont Pass and the Pacheco Pass to connect the Bay Area
and Central Valley portions of the HSR system in the Bay Area to the Central Valley High-Speed
Train Program EIR/EIS. Based on that EIR/EIS, the Authority and FRA selected the Pacheco
Pass—San Francisco and San Jose termini network alternative, including corridor alignments and
station location options. The selected corridor alignment uses the Caltrain rail right-of-way, between
San Francisco and San Jose along the San Francisco Peninsula, and the Pacheco Pass via Henry
Miller Road, between San Jose and the Central Valley.
In December 2008, the Authority and FRA respectively issued a notice of preparation and notice of
intent to prepare an EIR/EIS for the project-level San Francisco to San Jose Section of the
proposed California HSR System. In 2009, the Authority and FRA completed project scoping and
provided the public with alternatives screening documents. These alternatives screening documents
were for a rail corridor based on an entirely grade separated a four-track system between San
Francisco and San Jose where HSR would share tracks with Caltrain express commuter trains.
Communities along the Caltrain corridor expressed concerns with this proposal because of the
perceived magnitude of impacts to environmental and community resources. In response to these
concerns, the Authority suspended further work on the EIR/EIS in mid-2011 to consider blending
the HSR and Caltrain operations within a smaller project footprint. In November 2011, the
Authority proposed blended operations for the HSR section between San Francisco and San Jose,
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which would still provide HSR and Caltrain service between the two cities without requiring a four-
track system for the Project.
The San Francisco to San Jose Section EIR/EIS will describe the Blended System Project in detail,
identify site-specific environmental impacts from construction, operation, and maintenance of the
Blended System Project; identify specific mitigation measures to address those impacts; and
incorporate appropriate design practices to avoid and minimize potential adverse environmental
impacts. The EIR/EIS will describe the site characteristics, size, nature, and timing of the proposed
action as a basis for determining whether the impacts are potentially significant and whether impacts
can be avoided, minimized, or mitigated. The Authority will provide information and documents
regarding this EIR/EIS on the Authority's Web site: http://www.hsr.ca.gov.
The San Francisco to San Jose Section EIR/EIS will tier from, and build upon, the Statewide
Program EIR/EIS and the Bay Area to Central Valley HSR Program EIR/EIS consistent with
Council on Environmental Quality (CEQ) regulations, (40 CFR 1508.28) and State CEQA
Guidelines (14 California Code of Regulations 15168(b)).
In addition to the NEPA and CEQA process, the Authority is required by law to publish a Business
Plan, updated every two years, which includes a description of service type, chronology of statewide
construction, estimate of capital costs per segment, operating and maintenance costs, environmental
review schedule, and discussion of public and private funding availability. The Draft 2016 Business
Plan, which the Authority released in February, describes a phased implementation of the statewide
HSR system. The Draft 2016 Plan prioritizes construction between San Jose and the Central Valley,
but also emphasizes the importance of extending HSR service from San Francisco to San Jose as
soon as possible.
Purpose and Need
The purpose of the proposed HSR system is to provide a new mode of high-speed intercity travel
that would link major metropolitan areas of the state; interface with international airports, mass
transit, and highways; and provide added capacity to meet increases in intercity travel demand in
California in a manner sensitive to and protective of California's unique natural resources. The need
for a HSR system is directly related to the expected growth in population, and increases in intercity
travel demand in California over the next twenty years and beyond. With the growth in travel
demand, there will be an increase in travel delays arising from the growing congestion on California's
highways and at airports. In addition, there will be negative effects on the economy, quality of life,
and air quality in and around California's metropolitan areas from a transportation system that will
become less reliable as travel demand increases. The intercity highway system, commercial airports,
and conventional passenger rail serving the intercity travel market are currently operating at or near
capacity, and will require large public investments for maintenance and expansion to meet existing
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demand and future growth. The proposed HSR System is designed to address some of the social,
economic, and environmental problems associated with transportation congestion in California.
The San Francisco to San Jose Section meets this purpose and need by:
• Connecting the San Francisco Bay Area to the rest of the statewide HSR system, including the
Central Valley and Southern California;
• Incorporating HSR into the intermodal hubs at San Francisco, Millbrae and San Jose, thereby
providing interfaces with airports (San Francisco International Airport and Norman J. Mineta
San Jose International Airport), mass transit (BART, Caltrain, Capitol Corridor, Amtrak, and
light-rail and bus services), and highways, resulting in local and regional transportation hubs;
• Serving a large base of riders in the densely populated San Francisco and San Jose
metropolitan areas; and
• Reaching station locations with existing and planned transit oriented development potential.
Alternatives
The San Francisco to San Jose Section EIR/EIS will consider a No Action or No Project
Alternative and one or more HSR Alternatives for the San Francisco to San Jose corridor. The San
Francisco to San Jose Section of the HSR system would connect to the San Jose to Merced Section
at Diridon Station, which would extend HSR service from the San Francisco Bay Area to the
Central Valley and Southern California.
No Action Alternative
The No Action Alternative (No Project or No Build) represents conditions in the San Francisco to
San Jose corridor as they exist in 2016, and as they would exist in future years based on projected
growth, programmed and funded improvements to the intercity transportation system, and other
reasonably foreseeable projects through the implementation of Phase 1 operations in 2029, and a
future year of operation in 2040. The No Action alternative takes into account the following sources
of information: State Transportation Improvement Program; Regional Transportation Plans for all
modes of travel; airport plans; intercity passenger rail plans; and city and county plans.
HSR Blended System Alternative(s)
The Blended System Project would follow the Caltrain right-of-way from San Francisco to San Jose.
It would utilize existing and in-progress infrastructure Caltrain developed for its electrification
project, but require construction in addition to electrification. The Blended System Project is
anticipated to include the following, subject to continued planning and engineering following the
scoping/outreach process:
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New and/or Upgraded Infrastructure
• Track improvements to support higher speeds, including upgrades of tracks, trackbeds, ties,
interlockings, and possible curve straightening;
• At least one passing track, with potential alternative locations for the passing track;
• One terminal storage maintenance facility, with potential alternative locations;
• Improvements to existing bridges necessary to accommodate mixed traffic;
• Potential grade separations necessary to support blended operations; and
• Installation of quad gates at remaining grade crossings.
Proposed Operations
• High-speed rail vehicles operating over mostly the same tracks between San Francisco and San
Jose;
• Speeds of up to 110 miles per hour; and
• Operations plan that would allow for up to 4 HSR vehicles per hour/per direction in the peak
period.
Upgrades to Existing Stations
• Raised and straightened platforms, platform screens (or other safety features) and passenger
facilities at 4th & King, Millbrae and Diridon stations.
Transbay Transit Center (TTC) and Downtown Extension DTX projects
• The Authority proposes its Blended System Project will reach the TTC in San Francisco via
the planned 1.3-mile extension of passenger rail track from the current terminus at the
Caltrain 4th and King station.
• The Transbay Joint Powers Authority is the state lead agency for both projects, which have
been the subject of separate environmental review.
• The TTC is currently under construction. The DTX is not yet under construction.
• Both projects will be addressed in the San Francisco to San Jose Section EIR/EIS.
During the Programmatic review phase, FRA and the Authority selected the Transbay Transit Center
as the station location in the city of San Francisco. However, the Authority anticipates that the 4th
and King Station would operate as an interim station until completion of the Transbay Transit
Center which the Transbay Joint Powers Authority is constructing and funding. Other HSR stations
would be located in the city of Millbrae at the existing Millbrae BART/Caltrain Station, and in the
city of San Jose at the existing Diridon Station. FRA and Authority selected these locations through
the Bay Area to Central Valley HSR Final Program EIR/EIS.
Probable Effects
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The EIR/EIS will evaluate and document the effects of the proposed project on the physical,
human, and natural environment. FRA and the Authority will continue the tiered evaluation of all
potentially significant environmental, social, and economic impacts of the construction and operation
of the HSR system. The San Francisco to San Jose EIR/EIS will address appropriate resource areas
including: Transportation, including impacts on existing passenger and freight rail tenants; safety and
security; land use and zoning; land acquisition, displacements, and relocations; cumulative and
secondary impacts; cultural resource impacts, including impacts on historical and archaeological
resources; parklands/recreation areas; neighborhood compatibility and environmental justice; geology
and paleontology impacts; natural resource impacts including air quality, wetlands, water resources,
noise and vibration, energy, wildlife and ecosystems, including endangered species, energy and
hazardous materials. The EIR/EIS will also identify and evaluate measures to avoid, minimize, and
mitigate adverse impacts.
The San Francisco to San Jose Section EIR/EIS will be prepared consistent with FRA's Procedures
for Considering Environmental Impacts (64 FR 28545, May 26, 1999) and the CEQ's regulations
implementing NEPA at 40 CFR parts 1500-1508. The San Francisco to San Jose Section EIR/EIS
also will address, as necessary, other applicable statutes, regulations, and executive orders, including
the Clean Air Act, Section 106 of the National Historic Preservation Act (Section 106) of 1966,
Section 4(f) of the Department of Transportation Act, the Endangered Species Act, and Executive
Order 12898 on Environmental Justice.
FRA funding or approval of the San Francisco to San Jose Section would be a Federal undertaking
with the potential to affect historic properties. As such, it is subject to the requirements of Section
106. Consistent with the Advisory Council on Historic Preservation's (ACHP) regulations
implementing Section 106, FRA intends to coordinate compliance with Section 106 of this Act with
the preparation of the San Francisco to San Jose Section EIR/EIS, beginning with the identification
of consulting parties in a manner consistent with the standards set out in 36 CFR 800.8. Under the
Programmatic Agreement among FRA, ACHP, the California State Historic Preservation Officer,
and the Authority, FRA and the Authority will conduct a phased review of effects on historic
properties consistent with 36 CFR 800.4(b)(2). FRA invites the public and interested parties to
provide comments on the potential effects of the proposed alternatives on historic properties within
the San Francisco to San Jose Section. In response to this NOI, a member of the public or other
interested party may also request to participate in the Section 106 process as a consulting party
under 36 CFR part 800.
Scoping and Comments
FRA encourages broad participation in the EIS process during scoping and review of the resulting
environmental documents. FRA invites Native American Tribes, interested agencies, and the public
at large to participate in the scoping process to ensure the EIR/EIS addresses the full range of
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issues related to the proposed action and reasonable alternatives, and that all significant issues are
identified. FRA requests that any public agency having jurisdiction over an aspect of the Project
identify the applicable permit and environmental review requirements of the agency and the scope
and content of the environmental information germane to the agency's jurisdiction over the Project.
Public agencies are requested to advise FRA if they anticipate taking a major action in connection
with the proposed project and if they wish to participate as a cooperating agency for the San
Francisco to San Jose Section EIR/EIS.
FRA and the Authority have scheduled public scoping meetings which are an important component
of the scoping process for both the State and Federal environmental review. The Authority will
advertise the scoping meetings described in this NOI locally and be included with any additional
public notification.
Issued in Washington, DC, on May 4, 2016.
Jamie Rennert,
Director, Office of Program Delivery.
[FR Doc. 2016-10959 Filed 5-6-16; 8:45 am]
BILLING CODE 4910-06-P
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DRAFT
June 7, 2016
Mark A. McLoughlin Ms. Stephanie Perez
Director of Environmental Services Environmental Protection Specialist
ATTN: San Francisco to San Jose Secton EIR/EIS Office of Program Delivery
California High Speed Rail Authority Federal Rail Administration
100 Paseo de San Antonio 1200 New Jersey Avenue SE
San Jose, CA 95113 Washington, D.C. 20590
RE: San Francisco to San Jose Section EIR/EIS – Response to NOI/NOP
Dear Mr. McLoughlin & Ms. Perez:
Thank you for the opportunity to comment on the scope of the California High Speed Rail Authority’s
environmental analysis of the San Francisco to San Jose Section pursuant to the National Environmental
Policy Act (NEPA) and the California Environmental Quality Act (CEQA).
The City of Palo Alto has been an active participant in planning for the rail corridor that bisects this
community for many years, and would like to offer the comments included in this letter to the California High
Speed Rail Authority (CHSRA) and its partners at the Federal Railroad Administration (FRA). Please use these
comments to inform your environmental review process and consider the suggested modifications to your
overall planning process/schedule, particularly as it relates to community engagement.
The Planning Process
1. We would like to request that the comment period for responding to the Notice of Intent/Notice of
Preparation (NOI/NOP) be extended by 30 days to permit other agencies, organizations, and
members of our community ample time to provide their input.
2. We would like to request that the NOI/NOP be re-issued for additional comments once basic
parameters of the alternatives and the possible locations of critical project features are better
known. For example, the NOI/NOP does not identify the locations of passing tracks or the planned
maintenance facility, and does not specify which grade crossings will be separated as part of the
project, and which will simply receive quad gates. These parameters should be worked out with
the affected local agencies in advance of issuing a supplemental NOI/NOP.
3. As indicated in correspondence earlier this year, the City believes that the CHSRA’s objective of
completing the environmental clearance work for the CHSRA’s SF to SJ project segment by the end of
2017 will result in a process that is unnecessarily rushed, and that does not allow adequate time for a
community engagement process regarding project design and implementation. Please see the City’s
letter of January 25, 2016, which is attached, and consider revising the planning process/schedule to
permit additional community engagement. We have not received a response to this letter.
June 7, 2016
Page 2
Also, recent events call into question the CHSRA’s stated rationale for proceeding with the San
Francisco to San Jose segment, which was to secure third party funding. We understand that third
party investors and cap and trade funding have failed to materialize as anticipated by CHSRA and
again question whether a more inclusive community engagement process and a more realistic
schedule should be adopted.
4. As we indicated in our earlier letter, the City believes that the Context Sensitive Solutions (CSS)
process or an equivalent stakeholder process should be undertaken immediately. This kind of
community engagement effort has been shown to result in a better suite of project alternatives, to
better recognize competing interests, and ultimately to result in better projects, that are less likely to
be subject to delays due to legal challenges.
5. We understand from a May 25, 2016 presentation by Mr. Tripousis to our City Council’s Rail
Committee that the CHSRA is considering establishment of “working groups” to help shape a
preferred alternative while the Draft EIS/EIR is being prepared. The membership and purview of
these working groups should be clearly specified so that the City may understand how it can
participate and provide input.
We recommend regional topics be addressed by all of the working groups, that web conferencing be
provided as an option for participants, and that the meetings be facilitated by a third party, with HSR
participating as stakeholders rather than facilitators. All local agencies and transit/transportation
agencies should be include as participants.
The CHSRA’s overall outreach and communication process should be structured to ensure that
operational assumptions integral to the system and the identification of CHSRA preferences are not
made without community awareness and input.
6. We question whether the CHSRA and the FRA should identify a Preferred Alternative before a Draft
EIS/EIR is circulated for agency and public review. We understand that a NEPA analysis requires all
alternatives to be considered at an equal level of detail, and we are concerned that stating a
“preference” in advance of the Draft EIS/EIR may give one alternative higher standing or more
emphasis than the others. Also, reserving a decision about which alternative is preferred until after
the comment period on the Draft EIS/EIR will allow comments on the draft to inform that decision.
7. We understand the desire to “tier” from the Statewide Program EIS/EIR and from the Bay Area to
Central Valley HR Program EIS/EIR, however the NOI/NOP is unclear what this means for the
upcoming analysis. We would appreciate clarification as to what information or analysis from the
earlier environmental documents will be relied upon.
8. We understand that the Metropolitan Transportation Commission (MTC) has been approached to
fund a high level study of all 42 grade crossings along the Caltrain corridor, identifying issues and
opportunities associated with grade separations and a framework for advancing them in advance of
HSR. We applaud the goal of regional collaboration based on a scope of work developed in
conjunction with the Local Policy Maker Group (LPMG), and initiation of a study that will proceed
with their oversight. The nine-party MOU signed in 2012 anticipated early investments in “selected”
grade separations and engaging local agencies in a strategy for funding and sequencing grade
separations at all 42 grade crossings is long overdue. The EIS/EIR should assess the cost and time
needed to complete these grade separations, as well as the resulting impacts and benefits.
June 7, 2016
Page 3
The Alternatives Description
9. The proposed project is not sufficiently defined to allow meaningful comments on the scope of
the environmental document. For example, the NOP does not identify the location of passing
tracks or the planned maintenance facility in the project alternatives. Local agencies are thus
prevented from commenting on site specific analyses that would be required if these facilities
were located within their borders.
10. The CHSRA should include grade separations as an essential part of the project description to be
evaluated pursuant to NEPA and CEQA. Failure to include grade separations as an element of the
project would not only result in more significant impacts to be mitigated by CHRSA and other
agencies, but would also effectively segment the cumulative effects of high speed rail operation and
subsequent localized construction projects necessary for the CHSRA project to safely and effectively
operate.
Within Palo Alto, the alternatives should include and the EIS/EIR should analyze grade
separations at all of the rail crossings in Palo Alto: Charleston, Meadow, Churchill and Palo Alto
Avenue/Alma. Please include the 2% trench option for Charleston and Meadow developed for
the City by Hatch Mott Macdonald (HMA). This approach is detailed in a HMA memo available at
http://www.cityofpaloalto.org/civicax/filebank/documents/44297. (Please contact City staff for
the accompanying concept drawings.) The EIR/EIS analysis should also consider any necessary
accommodations or changes by freight operators to permit the 2% grade option suggested by
HMA.
11. Please consider the impacts of freight on the corridor and consider alternatives with a modified or no
freight option. These options should be considered in conjunction with the grade separation options
described above.
12. Please assess and disclose the impact on Caltrain and HSR schedule quality, travel time, and
reliability with and without level boarding at all Caltrain stops (not only HSR stations). We are
concerned that lack of level boarding at Caltrain stations will cause delays at those stations that will
in turn affect both Caltrain and HSR service.
13. The City is not supportive of adding passing tracks within Palo Alto, and does not see how this could
occur without significant right of way (and cost) implications as well as impacts that would be
unacceptable to our community. Please disclose physical right of way, cost, and visual impacts of
passing track options.
14. Please also disclose the impacts of various passing track options on Caltrain service quality and
reliability. We are concerned that some passing track options will result in bunching of trains. The
service quality evaluation should include an assessment of the ability to offer “clockface” type
service at regular intervals.
15. The No Project alternative should assess the benefits of expanded Caltrain service that will be
possible in the corridor after electrification if HSR did not proceed. We expect that more vehicle
trips would be eliminated and transit ridership would increase if Caltrain was able to use the
additional capacity created by their system modernization, rather than sharing that capacity
with HRS.
June 7, 2016
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16. An alternatives analysis under CEQA should include consideration of an off-site alternative. The
CHSRA has clearly reconsidered the original sequencing of project segments, and in an off-site
alternative, it could similarly reconsider the decision to access San Francisco by using the Caltrain
alignment. A reasonable alternative could include using an East Bay alignment with a connection to
BART.
17. Please include the Downtown Extension to the Transbay Terminal as an alternative or in a detailed
cumulative impacts analysis. The HSR EIS/EIR should disclose the environmental outcomes of this
option with respect to ridership, VMT, and GHG, including displaced air travel. Impacts on Caltrain
ridership and capacity should also be disclosed, and mitigation should be provided.
18. Please include the approach to Diridon Station in this EIS/EIR, including the potential impacts of
alternatives on Caltrain service as well as other passenger services utilizing the segment (ACE,
Capital Corridor). Any impacts identified should be fully mitigated.
19. For safety improvements at grade crossings remaining after HSR implementation, please
consider automated intrusion detection technology to detect barriers on tracks and automated
enforcement to enforce vehicle code prohibition against stopping on tracks.
Environmental Impacts & Mitigation
20. Please see the May 16, 2016 correspondence from the City’s transportation staff to Mr.
Tripousis for a list of intersections we believe should be included in the CHSRA’s analysis. Please
also note that intersection and grade crossing evaluations should account for and fully consider
pedestrian and bicycle safety and convenience. The existing at-grade crossings function as
designated active transportation school commute corridors and principle linkages in the
Citywide bicycle transportation network.
21. The City of Palo Alto’s Comprehensive Plan (its general plan) is currently being updated and is
expected to include policies to ensure acceptable Levels of Service (LOS) at signalized
intersections throughout the City. The EIS/EIR should provide a quantitative analysis of
intersection LOS at affected intersections in Palo Alto, as well as an analysis of pedestrian and
bicycle impacts with and without grade separations.
22. The City’s ongoing Comprehensive Plan Update will also consider elimination of Program T-39,
which restricts the addition of traffic signals on Alma Street. Please do not consider the current
program a constraint when evaluating impacts and necessary mitigation.
23. Palo Alto’s current Comprehensive Plan contains policies that are not generally supportive of
road widening and if mitigation measures are needed to address delay/congestion at
intersections, please consider signal timing, signal location, and barrier design, and
improvements to multi-modal transportation to address the impacts before suggesting road
widening.
24. Please provide a robust analysis of potential noise increases associated with the project alternatives,
including noise associated with trains, train horns, quad gate operations, station announcements,
and increased traffic congestion at grade crossings. Establishment of quiet zones should be included
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as mitigation.
The City recognizes that the rail corridor is in active use today, but expects an analysis that clearly
demonstrates the additional volume and duration of noise generating activities within the corridor
with the advent of HSR. The analysis should assess compliance with the City’s noise compatibility
guidelines and related policies in addition to using the FTA’s methodology and thresholds. The City’s
guidelines and relevant policies can be found in the Natural Environment Element of the City’s
Comprehensive Plan (Policy N-39 through N-43).
25. Please provide specific information about all right of way requirements for construction and
operation of the proposed alternatives, including grade separations implemented as part of the
project or as part of subsequent projects necessitated to address safety and congestion impacts of
the project. The NEPA analysis should include an estimated value of right of way acquisitions and
estimate property tax impacts from direct and indirect property takings for the life of the project.
26. Please provide a cumulative impact analysis that considers Caltrain modernization, HSR options,
and grade separating all 42 crossings in this segment of the project. If grade separations happen
concurrent with Caltrain modernization and/or HSR, their construction will likely impact the
schedule for project delivery. However, if grade separations happen after Caltrain
modernization and/or HSR, their construction will impact planned rail service. Either way, the
cumulative construction impacts on affected communities should be fully evaluated.
27. Palo Alto is a community rich in historic and cultural resources and both the EIS/EIR and the
associated Section 4(f) analysis must identify those likely to be impacted by construction and
operation of the proposed alternatives. Please be sure to include impacts on residential properties
and districts (neighborhoods) adjacent to the rail corridor from changes in their setting associated
with the removal of vegetative screening and the addition of high speed trains. Also consider
potential impacts on station-area resources, the City’s urban tree canopy and individual heritage
trees, including but not limited to El Palo Alto, the City’s namesake Redwood Tree and California
Historical Landmark Number 2 (Portola Journey’s End).
28. The analysis of aesthetic impacts and biological resources should also consider impacts to the City’s
urban tree canopy, as well as the loss of other vegetation along the rail corridor. The potential loss
of visual screening, important landscape features, bird habitat, and sequestered carbon should be
fully assessed.
29. Please also assess potential growth inducing impacts of the project, including the potential for
distant housing and job growth as long commutes become easier. Please also assess the extent to
which there will be additional demand for parking, transit, and paratransit (including rideshare
services) at HSR stops throughout the system once the San Francisco to San Jose segment is
completed.
The City of Palo Alto has a long-standing relationship with Citizens for Responsible Rail Design and the
Friends of Caltrain. While the short timeframe for submitting comments to the NOI/NOP did not allow
for adequate coordination of the City's letter and incorporation of input from these community
organizations, we support their analytical and methodical identification of key issues. As such, we
incorporate by reference comments submitted by CARRD and Friends of CalTrain. We request that their
comments be considered a part of the City of Palo Alto's comments on the necessary scope of your
environmental analysis.
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Once again, thank you for the opportunity to provide these comments. The City is in the process of hiring a
rail program manager who will be the City’s primary point of contact for the EIS/EIR and this project.
Until that person/firm is retained, please use the following contact for all correspondence:
Hillary Gitelman, Director of Planning & Community Environment
City of Palo Alto
250 Hamilton Ave
Palo Alto, CA 94301
Hillary.gitelman@cityofpaloalto.org
If you have any questions or comments, please contact Palo Alto City Manager James Keene at (650) 329-
2563 or by email at james.keene@cityofpaloalto.org.
Sincerely,
Patrick Burt
Mayor, City of Palo Alto
cc: Palo Alto City Council
Palo Alto City Manager
Congresswoman Anna Eshoo
Senator Jerry Hill
Assemblymember Rich Gordon