The City of Tehachapi has let Caltrans know that it thinks more should be done to offset the impact of a plan that would increase train traffic through town by about 80 percent by 2020.
The $106.7 million Tehachapi Rail Improvement Project is the topic of a draft Environmental Impact Report prepared by Caltrans and discussed at a public meeting in Tehachapi in September.
The EIR is required by the California Environmental Quality Act (CEQA), and the city believes it is deficient.
Community Development Director David James describes the city's concerns about deficiencies in an extensive document sent to Caltrans.
Specifically, the city believes the draft EIR falls short of meeting CEQA requirements in the areas of Summary/Environmental Setting, Noise and Traffic/Public Safety.
The city's Oct. 11 response to the draft EIR noted that that Caltrans failed to identify the public safety issue raised by the city during an Oct. 13, 2009, meeting.
To be CEQA compliant, the city asserts that at least one grade separation is required to alleviate adverse impacts noted in the Transportation Impact Report dated August 2012.
A grade separation would take the train either above or below street level.
The response also notes that the DEIR also provides an inadequate description of the environmental setting to the fact that it excludes the geographic area within the city. Only mentioning the city briefly in the traffic and transportation impacts section.
It states "Within the project area, State Route 58 is a four-lane divided highway that serves the City of Tehachapi and community in south east Kern County." The draft EIR does not mention that the tracks go through the city with three street crossings.
Trains: noisy business
In regards to the noise abatement issue, the city's response goes into considerable depth on noise level issues, illustrating the measurements that were previously taken by the county, were limited to noise sensitive locations adjacent to four or five segments -- none closer than five miles to the city.
The project area also does not define the relative environment when a project's environmental effects will be felt outside the project area. The analysis was limited to impacts within four of the five small areas or segments where construction would actually take place, therefore never considering existing noise environment and the noise impacts to its residents, according to the city's report.
A motorist's nightmare
The city's document also pointed out that although the draft EIR provides a somewhat disconnected view of traffic and transportation issues relating to the project, it does not provide any analysis of the impacts of the project on the city.
The report fails to analyze the project's incremental impact on emergency access and response times, as well as its impact on other transportation issues, including its failure to describe the methodology used to determine the project's impact at the city's at-grade rail crossings, according to James.
There is also no plan to estimate gate down time or peak hourly average delay per vehicle, or does it account for trains passing in opposite directions -- all of which are serious concern for motorists.
The plan also ignores the impacts at intersections adjacent to the rail crossings, and in the technical report engages in pure speculation and unsupported assumptions to simply "wish away" the project's traffic impacts within the city's sphere of influence.
The draft EIR avoids any mention of a topic that the technical report forthrightly addresses: grade separation, James noted in the report.
The city has contended for some time that the traffic and associated public safety impact will be significant, and has proposed grade separation as an appropriate means of mitigating the impact.
The city's document states that the draft environmental impact report conducted by Caltrans is significantly deficient as an informational document, and asks that the deficiencies be addressed and incorporated into the draft EIR, so that it and the document can be re-circulated for public review in accordance with CEQA guidelines.
Comments received from the public and reviewing agencies, including the city, are to be considered by Caltrans before the final EIR is published.