9.2_-_Initial_Study_Comments_&_Responses_FINAL_1-10-08.pdf

MURRAY STREET BRIDGE SEISMIC RETROFIT PROJECT

INITIAL STUDY / MITIGATED NEGATIVE DECLARATION

SCH#: 2007112037

RESPONSE TO COMMENTS & CHANGES

January 10, 2008

R E S P O N S E T O C O M M E N T S

Written comments on the Initial Study/Mitigated Negative Declaration were received from the California Coastal Commission, University of California Santa Cruz, Monterey Bay Unified Air Pollution Control District, Santa Cruz County Board of Supervisors’ Supervisor Neal Coonerty, Santa Cruz County Regional Transportation Commission, Union Pacific Railroad and Tom Burns. CEQA does not require preparation of written responses to comments on a Mitigated Negative Declaration, but the City has chosen to provide the following responses. The comment letters are attached.

California Coastal Commission

1-1 Project Support. The letter expresses support of the public benefits of the project, and staff may have additional comments as plans are completed.

1-2 Pile Installation. Commission staff recommends use of a hydraulically-powered pile driver, if feasible. Hydraulically-powered vibratory drivers reduce potential noise impacts.

The vibratory hammer would be better for starting each pile, but may not have enough "power" to penetrate the rock-like material in which case a hydraulic impact hammer (or there now is a "clean burn" diesel hammer) would be needed to finish the pile driving.

Driving 80% with a vibratory and then putting an impact hammer on the shell will reduce the overall noise.

1-3 Pedestrian Connection to Lake Avenue. Commission staff recommends that the sidewalk component of the project provide an adequate connection to the right-of-way that extends onto the Harbor side of Lake Avenue. A sidewalk on Murray connecting to the Harbor currently exists and will not be removed with the project.

1-4 Regulatory Process. The letter notes that the project is located within the Coastal

Commission’s original jurisdiction, and thus, the CCC is responsible for issuance of the Coastal Development Permit. Comment is noted, and is reflected in the Initial Study.

University of California Santa Cruz (UCSC)

2-1 No Substantive Issues. The letter states that the project description has an improved level of detail relative to other recent Initial Studies, no substantive issues of relevance to University concerns are raised.

Monterey Bay Unified Air Pollution Control District (MBUAPCD)

3-1 Demolition. MBUAPCD staff should be contacted regarding requirements for demolition of pilings, gangway, railings and docks as referenced on page 2-3 of the Initial Study.

Comment is referred to City staff and project engineer to incorporate into the plans and regulatory permit process.

3-2 Construction Activities. Comment indicates that the emissions program, URBEMIS 2007, should be used to calculate the emissions of criteria pollutants. The comment notes a 24-month construction schedule, but the Initial Study indicates that construction may take up to 18 months. Air quality impacts are addressed on pages 5-1 to 5-4 of the Initial Study. The MBUAPCD’s CEQA Guidelines (June 2004) indicate that construction projects using typical construction equipment which temporarily emit precursors of ozone are accommodated in the emission inventories of State and federally required air plans and would not have a significant impact on the attainment and maintenance of air quality standards. Although the project includes pile driving, the occurrence and duration are short-term. As indicated in the Initial Study, ground disturbance would be minimal and would not exceed nor even approach the acreage threshold for PM10 emissions (8.1 acres per day with minimal earthmoving) as set forth in the MBUAPCD’s CEQA Guidelines. The Guidelines indicate that construction projects below the screening level thresholds are assumed to be below the 82 lb/day threshold of significance. Thus, further calculation of emissions is not warranted.

3-3 Impacts of Diesel Equipment. MBUAPCD staff should be contacted regarding a diesel risk analysis. Comment is noted. However, as indicated on page 5-3 of the Initial Study, project construction would involve very limited, if any, use of diesel trucks and equipment due to limited construction and grading activities that would use this kind of equipment.

The emissions are considered short-term and minimal. Furthermore, regulation of diesel equipment and emissions has been ongoing with the California Air Resources Board, which in July 2007, adopted regulations for off-road diesel equipment. The project can use hydraulically-powered pile drivers and/or specify that all diesel engines be certified to meet Tier 2 Emission Levels as set forth by the California Air Resources Board for off-road diesel engines.

3-4 Mitigation of Dust Impacts. As discussed in the Initial Study and Response to Comment

3-2 above, dust generation is expected to be limited due to limited grading activities.

However, the project would include dust control measures as standard construction specifications.

3-5 Use of Portable Equipment. MBUAPCD staff should be contacted to ensure that any portable equipment complies with applicable registration requirements. Comment is referred to City staff and project engineer to incorporate into the plans and regulatory permit process.

Santa Cruz County Board of Supervisors, Neal Coonerty, Third District Supervisor

4-1 Traffic Impacts During Construction. Support for the project is stated, and appreciation of the City’s proposal to establish a City-County oversight group to monitor and adjust if necessary, the project’s traffic control measures and to advise on the public information program in order to address temporary construction impacts.

Santa Cruz County Regional Transportation Commission (RTC)

5-1 Project Support. RTC staff express support for the project and improvements and indicates that the project will increase the reliability and safety of vehicular access with improved and enhanced bicycle and pedestrian access. It is also noted that the project is consistent with the 2005 Regional Transportation Plan goals and policies.

5-2 Minimize Adverse Impacts. RTC staff recommends that adverse impacts to all travelers during construction be minimized. Comments are noted. The Initial Study addresses impacts to motorists, pedestrians and bicyclists on pages 5-23 through 5-28. As discussed, the project will include traffic control plans, including detours, to minimize impacts during construction.

Union Pacific Railroad

6-1 Encroachment into RIght-of-Way. The extent of the project’s impact upon the railroad right-of-way is not clear in the Initial Study. The indication that the project will encroach upon right-of-way is of concern. The Initial Study does not take into consideration the safety implications of construction in close proximity to an active rail line. City staff and project engineers had been in contact with Patrick Kerr, Manager – Industry and Public Projects, Union Pacific Railroad. The Initial Study acknowledges that there may be encroachment into the right-of-way during construction, and that this will need to be approved by Union Pacific, and potentially the California Public Utilities Commission.

The City intends to work with the company to prevent any disruption to rail service or safety risks during construction.

Tom Burns

7-1 Temporary Traffic Impacts. The comment expresses concern regarding temporary traffic impacts during construction, including lane closures during commute hours. Comment indicates that the Negative Declaration is inadequate as it does not include traffic mitigation measures, and there is no formal plan to address these impacts. Temporary traffic impacts are fully addressed in the Initial Study, and included an analysis of different traffic control plans to minimize temporary impacts. The selected alternative— one lane closure with signal control—was found to result in the least traffic disruption and undesirable levels of service. Traffic disruption would be temporary and intermittent throughout the construction period, and would not result in permanent significant impacts that would require mitigation. The Recommended Construction Specifications require preparation and implementation of a Traffic Control Plan that will establish the details of the signal location, timing, etc. for traffic control during times when one lane on the bridge is closed. The recommendations also require that lane closures be restricted during peak hours. Details of the traffic control plan typically are provided as part of the encroachment permit process. See also Response to Comment 4-1 regarding City- County oversight and monitoring of these measures.

C H A N G E S T O I N I T I A L S T U D Y

Page 2-5 Indicate that new docks will be installed at the ends of docks N, O, P, and Q.

Figure 1 does identify this area as part of the area of potential impact, but the Q dock wording was inadvertently left out in the text. However, the full area of impact was assessed in the Initial Study. The same change should be made to Table 1.

Page 5-28 Add the following Recommendation to the Traffic section:

RECOMMENDATION: Establish a City-County oversight group to monitor and adjust, if necessary, the project’s traffic control measures and to advise on the public information program in order to address temporary construction impacts.