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Planning & Design Meetings Environmental Impact Report Comments 4/23/2010 - Report.- __ -�_ Pa10,Qto Unified School District April 23, 2010 Dan Leavitt, Deputy Director California High Speed Rail Authority 925 L Street, Suite 1425 Sacramento, CA 95814 RE: Palo Alto Unified School District Comments for the California High Speed Rail Authority's Bay to Central Valley High Speed Train Revised Draft Program Environmental Impact Report Materials Dear Mr. Leavitt, Thank you for the opportunity to comment on the California High Speed Rail Authority's (Authority) March 2010 Bay Area to Central Valley High -Speed Train Revised Draft Program E/R Materials. The California HST would be located along 3.8 miles of the Caltrain right-of-way through Palo Alto along the Caltrain tracks, adjacent to the Palo Alto High School campus, and would have a long-lasting and far-reaching impact on campus. Palo Alto High School Palo Alto High School is located at 50 Embarcadero Road at EI Camino Real. The school site is bounded by EI Camino Real on the west, Embarcadero Road on the north, Churchill Avenue on the south, and Caltrain tracks and right-of-way on the east. Total 2008-09 school year enrollment is 1,755 students. Student enrollment on the campus is projected to increase to approximately 2,300 students by the year 2017. Approximately 180 full-time staff and employees occupy the campus. Two classroom buildings (Social Studies and World Languages) and a series of portable classrooms are located between 60 and 150 feet from the Caltrain right-of-way at the northeastern end of the campus. These buildings are buffered by paved areas used for vehicle parking, landscaping, and the paved bike path. The school district maintenance buildings and the high school football field are directly adjacent to the paved bike path in the southeastern portion of the site. A fence separates the school property from the bike path, and another fence separates the bike path from the Caltrain tracks. The right-of-way required for the HST alignment would require approximately three quarters of the campus to be affected. This would include all entrances and exits of the campus by automobile, pedestrian, and bicycle travel. A maintenance building will be directly affected and may required relocation. In addition, the visitors' bleachers, subsequently the stadium field, may require relocation. The Palo Alto High School Master Plan locates a new permanent two- story general classroom building on the northeast end of campus approximately 100 feet from the Caltrain right-of-way. Also included in the Master Plan is a new Media Arts complex, Career Tech Center, and 600 - seat Theater all within a few hundred feet of the Caltrain right-of-way. The Palo Alto Unified School District (PAUSD) has thoroughly reviewed the Revised Draft Program EIR and has the following comments: 25 Churchill Avenue, Building 'D' e Palo Alto, CA 94306 • Phone 650.329.3935 • Fax650.327.3588 • nwxv.pauW.org STRONG SCHOOLS BOND PaloAAto Unified School District A. GENERAL COMMENTS AND PROCESS A.2 SIGNIFICANT NEW INFORMATION Comment A.2.1. Significant new information exists, under many environmental parameters that makes the earlier Program EIR/EIS invalid and requires a recirculation of the Program EIR/EIS, as well as recirculation of the Revised Program EIR. Comment A.2-3. New information on project impacts and alteratives is being discovered during the project - level environmental review for the San Francisco to San Jose segment. This new information may indicate new or increased impacts, and new feasible alternatives or mitigation measures. The new information needs to be presented and analyzed in a revised and recirculated environmental document. Comment A.2-6. The need to evaluate impacts from Union Pacific Railroad's (UPRR) recent refusal to share its ROW opens up the possibility of considering new alternative alignments for not only the Pacheco Pass alignments but also the Altamont Pass alignments. This could affect other school properties depending on any new alignments selected. 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. Therefore, we feel it is imperative that the Authority consider comments on not only the Revised Materials but also on the Final EIR/EIS. B. INADEQUATE PROJECT DESCRIPTION AND BUSINESS PLAN B.1 PROJECT DESCRIPTION Comment B, 1-1. The project description is essentially limited to the alignment of the 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, turnouts, bridges and tunnels, advanced signaling and communication systems, electrification facilities, station automobile parking structures, and the public open spaces needed to support the pedestrian traffic generated by the hub stations. In addition, construction staging areas are not clearly specified. The Revised Program EIR 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 should be identified, the typical effects explained, and should be addressed in detail in the forthcoming project -level engineering and environmental 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, surface disturbance, noise, air quality, aesthetics, and PaloAlto Unified School District 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 disruption of local schools operations; these issues are not addressed in the EIR. 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, in relation to Palo Alto High School and other PAUSD properties. The corresponding 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 school district properties 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 properties along the alignment. Comment B.I-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 what additional infrastructure, and where, would need to be constructed (rail spurs, repair shelters) to allow the maintenance activities. Comment B.1.8. 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 remove weeds, clean up trash, remove graffiti, etc.? Who would pay for this maintenance? C. ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES C.1 GENERAL COMMENTS Comment C.I.1. The Revised Program EIR identifies a Peninsula alignment and station locations, but fails to fully identify, analyze, and mitigate all Peninsula -related environmental impacts from 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.1.2. The document fails to disclose or adequately analyze the project's potential land use and transportation impacts associated with the use of the shared Caltrain/UPRR ROW between San Francisco and San Jose. Perhaps more importantly, the document fails to discuss the potential necessity of locating the project alignment away from either segment of this ROW. The potential need for a new project alignment in these areas necessitates a revised analysis of project impacts. Comment C.1-3. The impact discussion focuses on a corridor 50 feet to either side of the existing corridor or 50 feet to either side of the centerline of the new HST alignments. The analysis should focus on a wider corridor 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 3 rr� Palo Alto Unified School District appropriately sized impact corridors as appropriate for each specific impact, with no corridor narrower than 500 feet to either side of the proposed HST corridor. Comment C.1-4. The impact analysis fails to address and incorporate the significance criteria established by each local jurisdiction or special district (i.e., school districts) affected by the project, and uses flawed assumptions in determining impact significance. Comment C.1-5. The analysis in the Revised Draft EIR glosses over local impacts and does not provide the detailed analysis required by CEQA. C.2 AESTHETICS AND VISUAL IMPACTS Comment C.2-1. The document fails to address how the absence or removal of screening trees along the east side of Palo Alto High School would affect the impact significance of elevated structures, sound walls, substations, and new utility poles and wires. C.3 AIR QUALITY AND GREENHOUSE GASES Comment C.3.1. The document fails to fully disclose or adequately analyze the project's potential air quality impacts, including the impacts to sensitive receptors such as schools, the production of greenhouse gases (GHG) and contribution to global climate change. Comment C.3.2. The analysis focuses on emissions associated with operations. It does not consider construction impacts and their contribution to GHG emissions, or those impacts on the adjacent school site. Comment C.3.3. Construction activities will cause major traffic disruptions, resulting in indirect air quality and GHG emissions from idling vehicles. These potential emissions and their affect on nearby schools were not analyzed in the document. CA BIOLOGICAL RESOURCES Comment C.4-1. The document fails to address impacts to trimming or removal of mature or heritage trees along project alignment, including effects to the trees along the east side of the high school. These include oak, redwood, and pine. Mitigation should include compliance with the City's tree protection ordinance (City of Palo Alto Tree Technical Manual, Tree Value Replacement Standard). C.5 GEOLOGY AND SEISMICITY Comment C.5-1. The EIR/EIS does not explain how drainage will be affected if structural beams are constructed and/or extended along alignments located adjacent to Palo Alto High School. Erosion onto school property is a critical issue. C.6 HAZARDS AND HAZARDOUS MATERIALS Comment C.6-1. 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. go PaloAlto Unified School District The potential injuries or harm to students and school personnel or damage to properties adjacent to rail lines resulting from train derailments is not addressed. The document does not consider establishing hazard buffer zones to address derailment impacts Comment C.6.2. The document fails to discuss the potential for pedestrians to cross into the rail right-of- way, and measures (fencing, other barriers) that would eliminate potential conflicts. Comment C.6-3. The document fails to address hazards from construction, including from equipment and machinery, traffic to and from the site, and construction vibrations. Impacts should be assessed on the adjacent high school, as well as potential damage to surrounding streets. C.7 HYDROLOGY AND WATER QUALITY Comment C.7-1. As stated in Comment C.6-1, above, the EIR/EIS does not explain how drainage will be affected if structural berms are constructed and/or extended along alignments located adjacent to Palo Alto High School. Erosion and runoff onto school property is a critical issue that needs to be addressed. C.8 LAND USE AND PLANNING Comment C.8-1. The Revised Program EIR fails to address the displacement existing uses adjacent to the existing ROW, such as buildings at the PAUSD's corporation yard. Comment C.8-2. The EIR/EIS does not clearly identify the area of influence along the HST corridor. This is more than merely the project footprint, as it could affect future development on areas near the corridor, including development and improvements to Palo Alto High School, in accordance with its Master Plan. Comment C.8-3. The document fails to adequately address land use impacts resulting from the division of existing communities, either through the expansion and potential widening of the existing Caltrain/UPRR ROW and the elevation of structures within this ROW, or through the relocation of the proposed HST corridor away from the Caltrain/ UPRR ROW. Either of these two scenarios could result in the division of an existing community. Comment C.8.4. 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 determining the thresholds of significance for all environmental impact criteria. Comment C.8-5. The Final Program EIR states on page 2-3 that the HST 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.9 NOISE AND VIBRATION Comment C.9.1. The document fails to adequately address the impact significance of noise and vibration during both construction and operation, and fails to adequately mitigate these impacts. 5 -Pad0 Alto Unified School District Comment C.9-2. The document states that noise impacts along San Francisco to San Jose corridor are rated low for those alignment alternatives that are either in a tunnel or passing through sparsely populated areas. The remaining alignment alternatives are rated medium because of the higher population density in proximity to the alignment and the existing parkland and two schools. Vibration impacts along alignment alternatives have the potential for medium to high vibration impacts because of the proximity of residential and institutional structures to the alignment. However, although the EIR/EIS explains that HST typically generates lower noise and vibration levels than do conventional train traffic, the EIR/EIS does not fully address the affect of noise and vibration on the school and what the mitigation would be such as restrictions on use of horns in specific areas. Comment C.9-3. The proposed HST right of way would be within 50 feet of the District's corporation yard buildings, and within 60 to 100 feet of several school buildings at the high school. The EIRIEIS needs to be more specific in the evaluation of the impacts to these uses from train noise, vibration, and wind. Comment C.9-4. Available research shows that noise distraction when learning or concentrating occurs at 40 dBA. This is a critical issue for schools located along the rail corridor. The EIR/EIS did not evaluate this. Comment C.9-5. Grade separation would introduce inclines. The document does not address how such inclines would affect noise and vibration impacts of HST, Caltrain, and freight train operations, particularly when climbing up an incline. Comment C.9-6. The document fails to address how wind and weather patterns would affect noise impacts. Comment C.9.7. The document fails to quantify the potential noise reduction provided by sound walls, particularly given the presence of school facilities and the possibility of an elevated railway. Without an idea of how much sound attenuation and reduction can be achieved through the use of sound walls along an elevated railway, there is no way to conclude that such walls have the potential to reduce noise impacts to a less than significant level. Comment C.9.8. 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 that could occur more than once a day and adjacent to a school facility (i.e., sensitive receptor). CA 0 TRAFFIC AND CIRCULATION Comment C.10-1. The document does not identify impacts to streets during construction, including identification of detours and road closures. These construction impacts could significantly affect traffic patterns and traffic flow around Palo Alto High School for extended periods of time. Comment C.10-2. The document does not address increased traffic and parking impacts in the vicinity of proposed stations. Pad0 Alto Unified School District Comment C.10.3. The document does not address impacts to pedestrian and bicycle paths that parallel and/or intersect the proposed alignment. Comment C.10.4. In the routes to school section of the EIR/EIS, the bicycle counts do not seem accurate. Please explain how the counts were determined. Comment C.10.5. In the event there are at -grade crossings for any of the transit modes (auto, bicycle and pedestrian), the EIR/EIS should address traffic impacts from trains during peak vehicle usage (i.e., during morning school arrivals and afternoon departures). The impacts at these at -grade crossings should be carefully studied, giving particular attention to the effects such traffic diversion might have on the safety, convenience, and comfort of designated school commute routes for PAUSD students. Comment C.10.6. If a Palo Alto station stop is selected, the document needs to analyze what routes passengers will take to reach the station and what affect these routes will have on the local traffic patterns and parking. C.11 CONSTRUCTION METHODS AND IMPACTS Comment C.11-1. The EIR/EIS does not specify where construction staging areas will occur, let alone evaluate any impacts associated with them. The document needs to show where these areas will be and if construction fencing and effects will be located near Palo Alto High School. The PAUSD appreciates the opportunity to provide these comments for the Revised Draft Program EIR Materials for the CAHSRA Bay Area to Central Valley HST. The District looks forward to working with Authority staff on an ongoing basis to review alternatives, impacts and mitigation measures for this important project. For more information on the above, please contact Robert Golton at (650) 329-3801. Sincerely, Kevin Skelly, Ph.D. Superintendent 7