Your Comments to Caltrans on the Draft EIR for replacing the Alameda Creek Bridge Are Needed

One of the key steps that must occur is for the public to send in comments to Caltrans on the Draft EIR. Whether you agree with replacing the bridge or not if Caltrans does not hear from the public they move forward using their own plan. Save Niles Canyon is offering some preliminary topic areas which can serve as the background for comments on the EIR. We will be continuing to post additional thoughts along these lines as we digest the EIR however it is a large document (331 pages) and the comments are currently due by 20 March. An extension of time has been requested but Caltrans may not grant it.

The following write up is designed to get people thinking and hopefully commenting.

If you have questions or additional suggested comment topics please post them to the Save Niles Canyon Yahoo page and members of Save Niles Canyon and/or other groups will do our best to answer or distribute them. Save Niles Canyon Yahoo Page

The Caltrans Draft EIR is too large to post on this page or the Niles Canyon Yahoo E mail page.
It can be easily accessed and downloaded at: http://www.dot.ca.gov/dist4/nilescanyon/
We have posted several useful background documents in a File titled Alameda Creek Bridge Replacement Project on the Niles Canyon Yahoo page.

Some preliminary EIR items for consideration as comments to Caltrans are:

1. Bridge replacement alternatives – Replacing the bridge is considered a good idea however Caltrans alternatives as illustrated in the draft EIR are all overbuilt in concept and more massive than needed. During the stakeholder meetings of 2014 Caltrans was asked numerous times to prepare and propose an alternative which has a speed limit of 35 mph and keeps traffic at a moderate speed. Caltrans did not do so and all options are designed for 45 mph. Caltrans says they cannot develop such an alternative and the groups which support a more modest approach believe they can. Of the four options presented in the Draft EIR the only difference between seems to be the mass of the project or the length of the approach roadway to the bridge proper. It was noted that they really are not options as much as the same proposal with longer or shorter approach ramps.

2. Piecemealing – The controlling legislation – CEQA – prohibits piecemealing of projects in a manner whereby their overall impact on the environment is “hidden” within a number of smaller projects. This was a concern expressed in the Caltrans original plan for a three part re-do of the entire Niles Canyon Road between Sunol and Fremont/Niles in 2010. According to Caltrans there are other major projects which will be proposed at a later time for the Canyon Road, e.g. Palomares Road Intersection re-do.

3. Why start something new when you have unfinished work? Status of the Tree replacement Mitigation stemming from the Dec 2011 Court Ordered Agreement between Caltrans & ACA. – Caltrans has yet to complete the tree planting mitigation steps they were ordered to perform at the time of the Dec 2011 court agreement which shut down their Niles Canyon Road Phase 1 project of 2010. At the 23 Feb 15 Public Meeting which Caltrans held on the current EIR they explained that they had not completed it because they did not know where the best places were to plant the trees. The canyon itself is well forested and a target area for planting trees had not been identified. Before Caltrans begins a new project they ought to be completing the unfinished work.

4. Tree cutting- At the 23 Feb public meeting Caltrans listed new information expanding the actual number of trees that will be cut (removed) across the 4 options being presented. That new information along with the type of trees needs to get out to the public to weigh in terms of the project’s impact. (Note: Caltrans has apparently posted the revised tree cutting information on the Rt. 84 WEB Page.) Your views on the environmental impact of each of the alternatives proposed would be useful

5. A reduced speed bridge option would be useful for several reasons – If Caltrans would return to the drawing board and develop a 35 MPH alternative with less environmental impact it would be some outlier along the Canyon Road. There are at least two other locations along of the Rt. 84 Canyon road which still require vehicles to reduce speed even after the bridge is replaced. Specifically Palomares Rd. intersection and at the Farwell underpass.

6. Long Term Vision – Caltrans does not mention this idea in the EIR but that does not prohibit commenters from bringing it up. People have suggested that what is needed is a long term vision for the Niles Canyon area. One concept that has been mentioned is to de certify Niles Canyon Road as a State highway thereby removing it from Caltrans control. That might also remove the possibility of it becoming a four lane commuter route which is what many people believed was Caltrans intention going back to the original defeated plan of 2005 and remains their intention today. However it would probably have to be Alameda County that takes it over and there is no indication the County is in a position to do so or that they are interested. However if the public raises the idea and lets public officials know their point of view perhaps the conversation could be started?

7. Safety Data – Does the bridge really represent a safety concern? In the statement of Purpose of the Draft EIR safety is a primary driving force behind the project. An excerpt from that section reads: The actual fatality and injury rate of 1.13 within the bridge limits is more than double the state average rate (0.56) for similar facilities. In addition, the total accident rate (2.06) is significantly higher than the state average rate (1.31) for similar highway facilities. FHWA’s Road Safety Analysis indicated that the number of accident rates at the Alameda Creek Bridge and eastern and western approaches are higher than they would be with a facility that meets current design standards. A re-review of the data upon which this claim is based would be useful to ensure it is accurate and has credibility. In a data review conducted by the Save Niles Canyon group of traffic fatalities in May 2011 it was concluded that : Caltrans portrayal of the vehicle related accident fatality data underpinning the Route 84 “safety” project lacks credibility and is misleading. Reviewing the safety data which is located in several documents is somewhat complex but offering your own point of view based on your experience driving the road might be useful. In addition the Fatality Data review performed in 2011 is apparently still being used by Caltrans. It has been posted to the Niles Canyon Yahoo page.

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