Final Supplemental

Environmental Impact

Statement and Subsequent

Environmental Impact

Report Volume 3, Part 1

State Clearinghouse No. 2010051001

U.S. Department of

Transportation

Federal Transit Administration

and the

San Diego Association of

Governments

September 2014

Final SEIS/SEIR Volume 3 Comments and Responses

September 2014

Prepared by

The San Diego Association of Governments (SANDAG)
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INTRODUCTION

This Mid-Coast Corridor Transit Project Final Supplemental Environmental Impact Statement/

Subsequent Environmental Impact Report (SEIS/SEIR) incorporates the comments received on

the Mid-Coast Corridor Transit Project Draft SEIS/SEIR during the 60-day review and comment

period that began on May 17, 2013, and concluded on July 17, 2013. It also incorporates

comments received on the Mid-Coast Corridor Transit Project Supplemental Environmental

Impact Statement/Supplement to the Subsequent Environmental Impact Report (Supplement)

regarding the federally endangered San Diego fairy shrimp during the 45-day review and

comment period that began on July 18, 2014, and concluded on September 2, 2014.

During the Draft SEIS/SEIR review and comment period, the Draft SEIS/SEIR and technical

reports were made available to all interested and concerned parties for review, including public

agencies, elected officials, community groups and organizations, businesses, and individuals.

Four public meetings and one public hearing also were held during the 60-day review and

comment period. Comments on the Draft SEIS/SEIR were submitted via mail, e-mail, voice

mail, fax, and at each meeting via comment cards or by speaking to a court reporter. Oral

comments also were received during the public hearing held before the San Diego Association

of Governments (SANDAG) Transportation Committee on June 21, 2013.

During the Supplement review and comment period, the Supplement was made available to all

interested and concerned parties for review, including public agencies, elected officials, community

groups and organizations, businesses, individuals, and those who commented on the Draft

SEIS/SEIR. Comments on the Supplement were accepted via mail, e-mail, voice mail, and fax.

Chapter 8.0 of this Final SEIS/SEIR describes in more detail the review and comment

processes for the Draft SEIS/SEIR and Supplement.

Regulatory Requirements

The Code of Federal Regulations (40 Code of Federal Regulations 1503.4) requires that an

agency preparing a final environmental impact statement under the National Environmental

Policy Act assess and consider comments both individually and collectively, and respond by one

or more of the means listed below, stating its response in the final environmental impact

statement. Possible responses are to:

· Modify alternatives, including the proposed action

· Develop and evaluate alternatives not previously given serious consideration by the agency

· Supplement, improve, or modify its analyses

· Make factual corrections

· Explain why the comments do not warrant further agency response, citing the sources,

authorities, or reasons that support the agency's position and, if appropriate, indicate those

circumstances that would trigger agency reappraisal or further response
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Section 15088(c) of the California Environmental Quality Act Guidelines describes the

evaluation that is required in the response to comments:

The written response shall describe the disposition of significant environmental issues

raised (e.g., revisions to the proposed project to mitigate anticipated impacts or objections).

In particular, the major environmental issues raised when the lead agency’s position is at

variance with recommendations and objections raised in the comments must be addressed

in detail giving reasons why specific comments and suggestions were not accepted. There

must be a good faith, reasoned analysis in response. Conclusory statements unsupported

by factual information will not suffice.

In order to comply with 40 CFR 1503.4 and Section 15088(c) of California Environmental

Quality Act, factual responses have been provided to all substantive comments received during

the comment periods, with a particular emphasis on significant environmental issues.

Generally, the responses to comments provide explanation, clarification, or amplification of

information contained in the Draft SEIS/SEIR and Supplement. All comments and responses to

comments are included in the Final SEIS/SEIR and will be considered by the SANDAG Board of

Directors prior to certification of the Final SEIR and approval of the project.

Document Organization

This volume of the Final SEIS/SEIR contains copies of all comment submissions received

during the comment periods on the Draft SEIS/SEIR and Supplement, a copy of the Draft

SEIS/SEIR public hearing transcript, and SANDAG’s responses to the comments. In order to

facilitate review of the responses to comments, the Final SEIS/SEIR includes Master

Responses that respond to issues and questions raised by a number of the comments.

This volume is organized as follows:

· Introduction

· Master Responses

· Section V3-1: Draft SEIS/SEIR Comments and Responses

– Agencies

– Tribes

– Elected Officials

– Groups/Organizations

– Businesses

– Individuals

– Public Hearing Transcript

· Section V3-2: Supplement Comments and Responses

– Agencies

– Groups/Organizations

– Individuals

· Section V3-3: Other Correspondence Related to the Environmental Document
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To locate a submission and review the response(s) to the comment(s), identify the commenter’s

name in the Index of Comment Submissions at the beginning of Sections V3-1 and V3-2. The

index is organized by affiliation, and each comment submission has been assigned a

submission number. The page number for the corresponding comment submission is identified

in this index. Each comment in a submission is bracketed and labeled with a comment number

(e.g., the first comment is comment number 1). The responses to the comments appear on the

pages immediately following the entire submission. Each response is bracketed and has a

number that corresponds to the comment number shown on the submission. The submissions

in Section V3-3 are also organized by affiliation but have not been bracketed or provided a

submission number. An index is provided at the beginning of this section.

Overview of Comments and Responses

The responses to comments contained in this volume of the Final SEIS/SEIR respond to

comments received from agencies, elected officials, businesses, groups/organizations, and

individuals during the comment periods for the Draft SEIS/SEIR and Supplement. Comments

received after the close of the Draft SEIS/SEIR comment period were considered as being

received during the comment period to the extent time permitted, and responses were prepared

for the three comment submissions in this category. All substantive environmental issues raised

during ongoing coordination with stakeholders and in comments received after the comment

period are addressed in the written responses to comments and in the Master Responses. All

other comments have been thoroughly considered to ensure all substantive environmental

issues raised were addressed in the Final SEIS/SEIR. It was determined that all issues were

addressed in the Final SEIS/SEIR, and accordingly the comments are included in Section V3-3

of this volume and are noted, but no further responses were prepared.

Since the release of the Draft SEIS/EIR, updates to the project description and mitigation

measures presented in the Draft SEIS/SEIR have been made as a part of SANDAG’s ongoing

coordination with agencies with jurisdiction over the project and public outreach. The responses

to comments contained within this volume also describe changes made to the SEIS/SEIR and

any updated or new technical studies (such as the Mid-Coast Corridor Transit Project Balboa

Avenue Station Relocation Study Technical Memorandum and the Mid-Coast Corridor Transit

Project Noise and Vibration Impacts Technical Report) either in response to comments received

or as a result of consultation with agencies with jurisdiction over the project. These changes are

intended to clarify and refine the description of the proposed project, refine measures to

minimize environmental impacts, and to ensure that the project is carried out in a manner

consistent with the laws and policies governing the project area and its resources. These

modifications do not change the conclusions of the analysis presented in the Draft SEIS/SEIR

and do not introduce significant new information on the project, project impacts, or mitigation

that is substantially different from what was presented and analyzed in the Draft SEIS/SEIR.

In some instances, a comment created a need to make a change to the Draft SEIS/SEIR.

Where a change was made, the appropriate section in which the change was made is

referenced in the response. Responses referenced the Draft SEIS/SEIR or Supplement when

the information needed to respond to the comment was available in the Draft SEIS/SEIR or

Supplement and remained unchanged. References to the Final SEIS/SEIR were used if

information changed since circulation of the Draft SEIS/SEIR or Supplement (e.g., capital cost

of the project).
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Section V3-1 includes comments received during the public review period for the Draft

SEIS/SEIR (May 17, 2013 to July 17, 2013), as well as three comment submissions received

after the close of the comment period. Section V3-2 includes comments received during the

public review period for the Supplement (July 18, 2014 to September 2, 2014). Section V3-3

includes information or comments provided by commenters after the close of the comment

periods to supplement their original comments on the Draft SEIS/SEIR. This section also

includes other correspondence provided to SANDAG after the close of all pubic comment

periods. A summary of the themes of comments on the Draft SEIS/SEIR, the Supplement, and

within the other correspondence is presented below.

Comments on the Draft SEIS/SEIR

In total, 309 comment submissions (e.g., comment cards, e-mails, and letters) were received on

the Draft SEIS/SEIR containing 1,416 individual comments. Table 1 lists the number of

submissions and comments received by affiliation.

Table 1. Number of Submissions and Comments by Affiliation for the Draft SEIS/SEIR

Affiliation Submissions Comments

Federal Agency 6 17

State Agency 10 113

Local Agency 3 41

Tribal Agency 1 4

Elected Official 2 23

Groups/Organizations 30 402

Businesses 21 173

Individuals 236 643

TOTAL 309 1,416

Source: SANDAG, 2013

Note: The term “submission” refers to a comment card, e-mail, or letter containing

comments. The term “comments” refers to individual comments within a

submission.

The comments received on the Draft SEIS/SEIR addressed a variety of topics. Some included

general statements of support or opposition to the project, or the options evaluated in the Draft

SEIS/SEIR. Other comments offered suggestions on how to improve the project through

refinements, as well as requests for changes, clarification, and new or additional analysis and

mitigation. Additionally, other comments expressed concern over environmental impacts and

funding/cost-effectiveness issues in regard to the project. The dominant themes of comments

received related to the following:

· Project alternatives or features (e.g., alignment, stations, traction power substations

[TPSSs], construction staging areas)

· Impacts related to biological resources, noise, and visual changes

· Impacts related to construction

· Station area circulation
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· Pedestrian and bicycle access to stations

· Parking

Comments on the Supplement

In total, nine comment submissions (e.g., e-mails, voicemails, and letters) were received on the

Supplement containing ten individual comments. Table 2 lists the number of submissions and

comments received by affiliation.

Table 2. Number of Submissions and Comments by Affiliation for the Supplement

Affiliation Submissions Comments

Federal Agency 1 2

State Agency 2 2

Groups/Organizations 2 2

Individuals 4 4

TOTAL 9 10

Source: SANDAG, 2014

Note: The term “submission” refers to an e-mail, voicemail, or letter containing

comments. The term “comments” refers to individual comments within a

submission.

The dominant themes of comments received during the comment period for the Supplement

related to the following:

· Support for the project despite impacts to the San Diego fairy shrimp

· Emergency access during construction in south University City

· Mitigation for the San Diego fairy shrimp

Other Correspondence Related to the Environmental Document

As noted earlier, SANDAG received additional correspondence from a variety of parties and

also continued coordination with stakeholders outside of the comment periods for the Draft

SEIS/SEIR and the Supplement. Some of the correspondence related to the environmental

impacts of the project or the environmental document, and consisted of the following categories:

· Comments related to the SANDAG Board of Directors meetings on the approval of the

Refined Build Alternative—These comments are included in the Mid-Coast Corridor Transit

Project Final Refined Build Alternative Report.

· Supplemental information or additional comments—In some instances, a stakeholder who

submitted a comment during the comment period also provided supplemental information or

additional comments after the close of public comment period. In these instances, the

supplemental information and additional comments are included in Section V3-3 of this

volume. Where applicable, the submission with the supplemental information and/or

comment(s) is followed by correspondence from SANDAG regarding this supplemental

information or comment(s).. Responses to initial comment submissions, master responses,
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and/or supporting technical reports and memoranda were revised in consideration of the

supplemental information and additional comments as needed.

· Other correspondence—Includes correspondence related to the content of the Draft

SEIS/SEIR or Refined Build Alternative received from individuals who did not comment on

the Draft SEIS/SEIR or Supplement. These comments were thoroughly considered to

ensure all substantive environmental issues raised were addressed in the Final SEIS/SEIR.

It was determined that all issues were addressed in the Final SEIS/SEIR, and accordingly

the comments are included in Section V3-3 of this volume and are noted, but no further

responses were prepared.

Approximately 26 submissions representing supplemental information/additional comments or

other correspondence were received outside the comment period. Table 3 provides a summary

of the correspondence included in Section V3-3.

Table 3. Other Correspondence Related to the Environmental Document

Commenter Submissions Topic

Friends of La Jolla Village

Square (Change.org petition)

1* Nobel Drive Station and parking structure

Steve Arndt 7 Nobel Drive Station and parking structure

Cape La Jolla Gardens

(Michael Krupp)

1 Shift in I-5 crossing proposed in November

15, 2013 Refined Build Alternative**

Annette Groves 1 Shift in I-5 crossing proposed in November

15, 2013 Refined Build Alternative**

La Jolla Village Square

(correspondence between

SANDAG and Samuel Blick)

2 Supplement to comments on Draft

SEIS/SEIR regarding Nobel Drive Station

parking structure design, parking demand,

and traffic impacts

Sheraton Hotels

(correspondence between

SANDAG and James Dawe,

Arup, and Richard Bartell)

10 Supplement to comments on Draft

SEIS/SEIR regarding noise, vibration, and

lighting impacts

TRU 2005 RE I, LLC (Toys R

Us) (Koons Real Estate Law)

1 Supplement to comments on Draft

SEIS/SEIR regarding store reorientation

Phillip Enright 1 Supplement to comments on Draft

SEIS/SEIR regarding Balboa Avenue

Station location and impacts

San Diego Gas & Electric

(Richard Quaserano)

1 CPUC and permitting requirements for

relocation of SDG&E facilities

W. J. Groth (wjgroth@att.net) 1 Sound wall along Morena Boulevard

Source: SANDAG, 2014

Note: * Change.org petition reflected 450 signatures as of September 16, 2014

** In May 2014, the crossing was returned to the location designated in the Draft SEIS/SEIR;

therefore, those comments no longer apply to the project as it is presented in the Final

SEIS/SEIR
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MASTER RESPONSES

Common themes emerged from the comments received on the Draft SEIS/SEIR. As such,

master responses were developed for these frequently asked questions and comments to

address broad issue areas where there was extensive public comment and to respond to the

various comments in a comprehensive fashion. The text for each master response is provided

here for ease of reference instead of repeating text for each individual comment received. Each

master response has been identified by a corresponding number, as shown in the list below,

which is cited in the applicable comment responses (e.g., “Please refer to Master Response

1”). Specifically, master responses are provided to address the following issues:

Master Response ID and Topic

1. Bicycle and Pedestrian Connections and Station Amenities .................................1

2. Stations in Residential Areas ...............................................................................2

3. Tecolote Road Station..........................................................................................3

4. Clairemont Drive Station and Future Development ..............................................5

5. Balboa Avenue Station—Consideration of Other Sites and Elimination of the

Station .................................................................................................................6

6. Balboa Avenue Station—Spillover Parking.........................................................13

7. Balboa Avenue Station and Morena Boulevard Area Noise ...............................16

8. Balboa Avenue Station—Traffic Conditions........................................................17

9. Overview of Noise Impact Assessment and Mitigation .......................................20

10. Property Values .................................................................................................21

11. Potential for Crime Rates to Change within the Mid-Coast Corridor ...................22

12. Graffiti ................................................................................................................23

13. Project Lighting Impacts .....................................................................................23

14. Rose Canyon Open Space Park—Noise ............................................................24

15. Rose Canyon Open Space Park—Visual ...........................................................26

16. Rose Canyon Open Space—Habitat Mitigation ..................................................27

17. Requests for a Berm ..........................................................................................28

1. Bicycle and Pedestrian Connections and Station Amenities

This master response was prepared to address comments received on the Draft SEIS/SEIR

suggesting new or improved bicycle and pedestrian connections to stations from surrounding

communities and/or inquiring about station design and amenities, including the provision of

restrooms.

SANDAG is committed to working with land use authorities (e.g., the City of San Diego, UCSD,

and the U.S. Department of Veterans Affairs) to promote safe and effective environments for

pedestrians and bicyclists at project stations. All new station facilities will be designed to

provide adequate access for pedestrians and bicyclists, and pedestrian facilities directly

adjacent to new stations will be upgraded where they are missing or do not provide adequate

access. The locations of new or improved pedestrian facilities are shown in Chapter 2.0,

Section 2.4.2 of the Final SEIS/SEIR (Volume 1) and in the figures within Chapter 2.0. Beyond

the station site, the provision of additional community-serving pedestrian and bicycle facilities is

outside the scope of this transit project.
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As indicated in Chapter 4.0, Section 4.2.3.2, “stations would be designed to be consistent with

the existing character of the surrounding communities and neighborhoods, and would support

existing development.” Stations will be designed to be accessible, and appropriate safety

features (e.g., signage and security personnel) will be incorporated. Refer to the Final

SEIS/SEIR Plan Set (Volume 2) for general station designs.

All new stations will be side-platform stations with 360-foot-long platforms designed to

accommodate up to four-car trains. All platforms will be fully accessible and comply with the

Americans with Disabilities Act.

Canopies will be provided at each station and will cover portions of the platforms and fare

collection areas. Fare collection equipment, consisting of ticket/smart card vending machines

and Compass Card validators, will be provided at each station. These amenities will be placed

as appropriate on the platform where boarding occurs or at station entrances. Other station

amenities will include benches, information kiosks, and security features. Bicycle lockers will be

available at all stations. At the UTC Transit Center, bicycle lockers will be located within the bus

transit center adjacent to the Trolley station. While there are currently no plans to incorporate

the City of San Diego's bicycle share program as part of the project stations, station design will

not preclude future incorporation of this program. Consistent with current MTS practice, no

public restrooms will be provided at any of the stations.

2. Stations in Residential Areas

This master response was prepared to address comments expressing concern with the location

of Trolley stations within predominantly residential areas. Commenters were primarily

concerned with the location of the Balboa Avenue Station and the corresponding bus transfer

point presented in the Draft SEIS/SEIR, stating that it would be better suited in a more

commercial location. Additional information regarding concerns related to the Balboa Avenue

Station is provided in Master Responses 5 through 8.

Transit stations are considered to be compatible uses within residential areas, and are a vital

component for smart growth and transit-oriented development. As documented in the MidCoast Corridor Transit Project Land Use Technical Report, the community plans in the land use

study area have identified the Mid-Coast Corridor Transit Project, and the communities have

anticipated its implementation since the mid-1980s. The City of San Diego General Plan

incorporates the Strategic Framework Element “City of Villages” smart growth strategy to focus

growth into mixed-use villages, which include residential land uses, that are pedestrian-friendly

districts of different scales and that connect to regional transit systems. Implementation of the

city’s smart growth strategy depends on closely coordinating land use and transportation

planning. The locations of the proposed transit stations will support adopted plans and policies

to encourage transit-oriented development, particularly regional plans for smart growth at major

activity centers and residential neighborhoods. Within the corridor and station areas, the project

will be compatible and consistent with applicable regional and local land use goals, objectives,

policies, and plan recommendations.

The locations of the stations for the Mid-Coast Corridor Transit Project were selected to

maximize ridership. The station locations include “trip origins” such as residential areas, hotels,

and student housing, along with major “trip destinations” such as centers of employment,

universities, and entertainment venues. The project will serve transit patrons living, working, or
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visiting the corridor by providing Trolley access to other uses within the corridor, as well as

providing access to the regional transit system. Locating stations within residential

neighborhoods allows residents in the corridor greater regional access as well as allowing those

outside the corridor to travel to and from locations within the corridor.

3. Tecolote Road Station

This master response was prepared to address comments from employees of Armstrong

Garden Center and members of the general public who opposed the acquisition and

displacement of Armstrong Garden Center by the Tecolote Road Station and park-and-ride

facility. Additionally, comments received from Toys “R” Us expressed concern with impacts to

the store from the loss of parking associated with the park-and-ride facility. This master

response summarizes the additional analysis that was conducted to determine if impacts to

businesses could be reduced by eliminating the Tecolote Road Station or reconfiguring the

station footprint.

Based on comments received on the Draft SEIS/SEIR, elimination and reconfiguration of the

Tecolote Road Station were considered. The analysis is documented in the Mid-Coast Corridor

Transit Project Tecolote Road Station Layout Options Technical Memorandum. However,

SANDAG has determined that the provision of a station at Tecolote Road is a necessary

component of the Mid-Coast Corridor Transit Project. In addition, as described below, the

station site plan cannot be reconfigured to avoid acquisition of Armstrong Garden Center and

still provide adequate parking without shifting adverse impacts to surrounding businesses.

Elimination of Station. Elimination of the station would reduce ridership and the effectiveness of

the project. In addition, it would be less effective in achieving the equity goal for the project as it

would not improve transit accessibility to low-income and minority populations. Elimination of

the Tecolote Road Station would also adversely affect parking at adjacent stations and would

not support future growth as planned for the area.

· Ridership. Using the SANDAG Series 11 Travel Demand Forecasting Model, SANDAG

determined that elimination of the station would reduce the project’s transit ridership by

1,190 daily boardings on the portion of the project north of the OTTC. Ridership and cost

are primary factors for determining the competitiveness of the project for FTA New Starts

funding. Although the Tecolote Road Station is at the lower range of projected ridership for

the proposed extension, it provides about 6 percent of the overall ridership along the

extension north of the OTTC, while contributing less than 1 percent to the cost of the project.

Therefore, the inclusion of the Tecolote Road Station increases the effectiveness of the

project.

· Transit Equity. The Tecolote Road Station will improve transit access to members of the

Linda Vista community. This community has substantial concentrations of minority and lowincome populations. As described in Chapter 1.0, Section 1.6.3 of the Final SEIS/SEIR

(Volume 1), one of the goals of the project is to provide transit service equity to Mid-Coast

Corridor communities. This consideration of equity is required as part of Title VI of the Civil

Rights Act and FTA Environmental Justice regulations and guidelines. If the station is

eliminated, Linda Vista (an area identified as having low-income and minority populations

(see Chapter 4.0, Table 4-36 of the Final SEIS/SEIR [Volume 1]) would not receive the

benefits of improved access to transit from the project. Therefore, removing the Tecolote
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Road Station would be less effective in achieving the equity goal compared to the Refined

Build Alternative.

· Parking. Elimination of the Tecolote Road Station would increase parking demand at other

adjacent stations, such as the OTTC and Clairemont Drive Station. Specifically, parking

demand at the OTTC would increase from 624 spaces under the Refined Build Alternative

with the Tecolote Road Station to 728 spaces without the station, while parking demand at

the Clairemont Drive Station would increase from 150 spaces to 395 spaces. The increased

demand at both stations would exceed the planned parking supply. Accommodating the

additional parking at the OTTC would be especially challenging because the existing site

has insufficient space to increase surface parking. Retention of the Tecolote Road Station,

on the other hand, would relieve some of the parking demand at the OTTC, in addition to

providing public transportation access to the Linda Vista community.

· Future Growth. The station area is identified by the City of San Diego and SANDAG as a

planned Smart Growth Area. Land uses within one-quarter mile of the station are

anticipated to be redeveloped as a Town Center with office and commercial development of

low- to mid-rise buildings served by regional rail transit. The Linda Vista Community Plan

also has identified the Tecolote Road Station to support the redevelopment of this location

into a mixed-use center and employment hub. The Tecolote Road Station is an important

component of the Smart Growth Area, providing convenient transit access. The full potential

of the site as a planned Smart Growth Area might not be realized if riders have to access

the area from the OTTC or Clairemont Drive Station.

Alternate Station Locations. Alternative sites for the Tecolote Road Station were considered based

on comments received on the 1995 Mid-Coast Corridor Alternatives Analysis/ Draft

Environmental Impact Statement/Environmental Impact Report. Public meetings were held after

circulation of the Mid-Coast Corridor Alternatives Analysis/ Draft Environmental Impact

Statement/Environmental Impact Report to receive public input on the Locally Preferred

Alternative, including on station sites. On October 26, 1995 the SANDAG Board of Directors

adopted the Locally Preferred Alternative with the station site proposed in the Mid-Coast

Corridor Alternatives Analysis/ Draft Environmental Impact Statement/Environmental Impact

Report, selecting that site to be carried forward. This decision is documented in the Mid-Coast

Corridor Locally Preferred Alternative Report and the 1995 Final Environmental Impact Report

for the Mid-Coast Corridor. Prior to the preparation of the Mid-Coast Corridor Draft SEIS/SEIR,

an analysis of changed conditions was conducted that found no changed condition that required

reconsideration of the SANDAG Board of Directors’ decision on the Tecolote Road Station

location. The analysis of changed conditions is presented in the Mid-Coast Corridor Transit

Project Comparative Evaluation of Alternatives Report.

Site Designs Variations. SANDAG studied whether there are alternate layout options for the

Tecolote Road Station that could accommodate forecasted parking demand, avoid

displacement of the Armstrong Garden Center, minimize parking impacts to Toys “R” Us, and/or

avoid or minimize impacts to other adjacent businesses. In all, five surface parking design

variations and three parking structure options were evaluated. After careful analysis and

consideration of the design variations, it was determined that none of these site design

variations would be able to accommodate projected parking demand without shifting additional

impacts to multiple adjacent businesses. As discussed above, site designs that do not provide

sufficient parking to meet demand would result in parking spillover in adjacent areas and
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increase parking demand at nearby stations, thereby increasing impacts to other businesses

and residential communities. Designs that do not utilize the City of San Diego-owned parcel

extending north from the station would result in the need for additional right-of-way acquisition

from private owners and an associated increase in project costs.

Three possible locations were considered for a potential parking structure. It was determined

that the replacement of surface parking with a parking structure would still require full acquisition

of either the nursery or adjacent businesses and would increase the cost of the project, as

documented in the Tecolote Road Station Layout Options Technical Memorandum. As such,

the station location presented in the Draft SEIS/SEIR was retained as part of the Refined Build

Alternative with only minor modifications to the site layout (the minor modification resulted in a

0.11-acre reduction in permanent right-of-way requirements). As stated in Chapter 4.0, Section

4.2.3.2 of the Final SEIS/SEIR (Volume 1), there is another nursery within 1.85 miles that will

continue to serve the community.

4. Clairemont Drive Station and Future Development

This master response was prepared to address comments received on the Draft SEIS/SEIR that

expressed concern that the surface park-and-ride facility for the Clairemont Drive Station would

prevent future mixed-use development on that parcel. The Refined Build Alternative includes a

150-space park-and-ride facility for the Clairemont Drive Station located east of Morena

Boulevard on a former retail commercial site, as shown in Chapter 2.0, Figure 2-14 in the Final

SEIS/SEIR (Volume 1). The SANDAG Series 11 Travel Demand Forecasting Model identified

the demand for a 150-space park-and-ride facility at the Clairemont Drive Station. If parking

demand exceeds available parking supply, spillover parking into the adjacent community is

likely.

This site will be acquired and improved by SANDAG as part of the project. This surface parking

facility and TPSS units will not preclude the opportunity for mixed-use development or a jointuse development on the former retail commercial site. The two TPSS units that will be

constructed adjacent to the park-and-ride lot at the Clairemont Drive Station will be screened

from view with walls and/or vegetation per the design measures noted in Chapter 4.0, Section

4.4.3.2 of the Final SEIS/SEIR (Volume 1) under the heading “Project Measures to Avoid or

Minimize Impacts.” With these design measures, the TPSSs will not degrade the visual

character of the station area and thus would not preclude mixed-use or joint-use development

on the site.

Mixed-use projects that include transit parking have been developed elsewhere along the

Trolley system, such as at the Grossmont Transit Center on the Trolley Green and Trolley

Orange Lines, which provides 220 parking spaces within an intensive development. The MidCoast Corridor Transit Project provides for the extension of the Trolley Blue Line from Santa Fe

Depot to the UTC Transit Center. It does not include joint development as a component of the

project. Therefore, any future development on this site would undergo a separate

environmental review process. Additionally, future mixed-use development opportunities in the

project corridor are the subject of the Station Area Planning Studies for the Tecolote Road and

Clairemont Drive Station areas that are being undertaken by the City of San Diego as part of the

community plan update process.
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5. Balboa Avenue Station—Consideration of Other Sites and Elimination of the Station

This master response was prepared to address comments from residents in the neighborhood

adjacent to the Balboa Avenue Station primarily related to the location or elimination of this

station. Specifically, the comments received requested relocation of the station to the area

north of Balboa Avenue at the City Maintenance Yard/Rose Canyon Municipal Operations Lot

(City Yard). Other commenters suggested eliminating the station altogether. Refer also to

Master Response 6 for details on the spillover parking analysis, Master Response 7 for details

on the noise analysis, and Master Response 8 for details on traffic conditions within the Balboa

Avenue Station area.

In response to the comments, SANDAG studied the relocation of the Balboa Avenue Station

from south of Balboa Avenue to the City Yard. The analysis is documented in the Mid-Coast

Corridor Transit Project Balboa Avenue Station Relocation Study Technical Memorandum and

is summarized in this response. The additional analysis confirmed that the City Yard could

accommodate the station and provide sufficient space to meet the forecasted station parking

demand, but that locating the station at the City Yard site would:

• Not eliminate or reduce any adverse or significant project impacts that were identified for the

Draft SEIS/SEIR, site

· Increase capital and operating and maintenance (O&M) costs

Elimination of the station was also considered; however, the Balboa Avenue Station is a critical

component of the project. This station will have a 220-space park-and-ride facility and will be

served by four bus routes. As shown in Chapter 3.0, Table 3-18 of the Final SEIS/SEIR

(Volume 1), the Balboa Avenue Station will have the second-highest daily ridership among the

new stations constructed as part of the project, with more than 3,000 boardings daily (only the

UCSD West Station will have greater ridership). Therefore, this station was not eliminated from

the Refined Build Alternative.

Site Options Considered. Two City Yard site options were evaluated: one on the northern part of

the site and a second on the southern part of the site (Figure 1). The station layouts for these

sites are presented in more detail in the Balboa Avenue Station Relocation Study Technical

Memorandum. The site concept plans for the City Yard stations allow sufficient area for a

consolidated operations center on the unused portion of the parcel, should that be acceptable to

the City of San Diego. Otherwise, relocation of the City Yard facilities to an alternative site

would be required.

Transportation Considerations

The evaluation of transportation issues included consideration of bus access, auto access,

parking demand, bike/walk connectivity, transit ridership, and future LRT connections.
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Figure 1. City Yard Station Site Options for Balboa Avenue Station

Source: SANDAG, 2013
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Bus Access. As shown in Chapter 3.0, Table 3-19 in the Final SEIS/SEIR (Volume 1),

approximately 70 percent of transit patrons accessing the Balboa Avenue Station will arrive via

bus; therefore, providing convenient and efficient bus access to the station is necessary in

attracting transit riders. All four bus routes that will serve the Balboa Avenue Station operate

along Balboa Avenue. As proposed in the Draft SEIS/SEIR, the reconfigured Morena

Boulevard/Balboa Avenue ramps will provide bus access from Balboa Avenue to the station site

without the need for substantial out-of-direction travel.

Relocation of the station to either City Yard site would increase travel time for buses. The travel

distance for the Option 1 and Option 2 station sites would increase by 3,400 to 4,800 feet (0.6 to

0.9 miles) for eastbound buses compared to the Draft SEIS/SEIR station site. The change in

distance for westbound buses between Option 2 and the Draft SEIS/SEIR site would remain

essentially unchanged while Option 1 would increase travel distance by 1,300 feet (0.25 mile).

The Balboa Avenue Station Relocation Study Technical Memorandum presents bus routing maps

depicting the eastbound and westbound bus routes for each station option. The additional

distance for eastbound buses compared to the Draft SEIS/SEIR site is a result of the longer

travel distance required on Morena Boulevard as well as within the station site. In particular, the

City Yard parcel is wider at the location where Option 2 would be sited, which would increase

the distance and time a bus circulates within the station site compared to Option 1 and the Draft

SEIS/SEIR sites. Because of the additional travel distance, bus travel time for the City Yard

sites would increase by approximately 1 to 6 minutes per route per roundtrip compared to the

Draft SEIS/SEIR station site (Route 27 serves the Balboa Avenue Station twice during each trip

and thus would have a greater increase in travel time than the other three routes that serve the

station).

This increase in travel time could require an additional bus on two to four of the routes serving

the City Yard sites in order to maintain planned service headways. The number of routes

requiring an additional bus would depend on the layover time included in the bus schedule and

would be determined by the transit operator—the Metropolitan Transit System. Additional

buses would result in higher O&M costs. Specifically, annual O&M costs would increase by

approximately $497,000 if one additional bus is needed on two routes (two new buses total) to

$1,105,000 if an additional bus is needed on each of the four routes (four new buses total)

(costs are in 2013 dollars). Thus, it is anticipated that relocating the Balboa Avenue Station

under Option 1 or Option 2 would increase O&M costs.

Due to the additional travel time resulting from the additional stops, turns, and/or out-of-direction

travel, mode of access (i.e., mode refers to means of access or travel to or from the station) via

bus transfer would decrease by 220, or from a 70 percent mode share under the Draft

SEIS/SEIR station site to 63 percent under Option 1. This would affect daily boardings at the

station. As stated in Chapter 1.0, Section 1.5 of the Final SEIS/SEIR (Volume 1), one purpose

of the project is to “make transfers more convenient where they do occur” and the increased

travel time and out-of-direction travel required for buses accessing the City Yard site would not

support that goal.

Auto Access. As discussed previously in the Bus Access section, the Morena Boulevard/Balboa

Avenue ramps would be reconfigured to provide direct access into the Draft SEIS/SEIR station

site. This station site and the reconfigured ramps would reduce travel distance and improve

accessibility for transit patrons traveling via automobile from the south and west when compared
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to Options 1 and 2. Travel distances from the north would be longer for the Draft SEIS/SEIR

site compared to Options 1 and 2; travel distance from the east would be comparable with

Option 2 but shorter than Option 1. For patrons traveling from the south and west, Option 1 would

add 2,500 feet (0.5 mile) while Option 2 would add 1,500 feet (0.3 mile) of travel compared to the

Draft SEIS/SEIR site. Travel distances from the north would be 2,500 to 1,500 feet (0.5 to 0.3

miles) shorter for Options 1 and 2, respectively, compared to the Draft SEIS/SEIR site. Travel

distances from the east would be longer for Option 1 but comparable between Option 2 and Draft

SEIS/SEIR site.

Traffic Impacts

Two adverse and unmitigable traffic impacts were identified near the Balboa Avenue Station in

the Draft SEIS/SEIR: at Mission Bay Drive and Garnet Avenue during the p.m. peak hour and

daily on Balboa Avenue from the I-5 southbound on-ramp to the I-5 northbound off-ramp.

These traffic impacts would occur because the increase in traffic accessing the Balboa Avenue

Station and park-and-ride facility would have a negative impact on the operation of the

intersection at Mission Bay Drive and Garnet Avenue and on the Balboa Avenue roadway

segment, based on City of San Diego criteria for level of service and delay. Relocating the

Trolley station and park-and-ride facility to the City Yard site would not minimize these traffic

impacts. This is because transit passengers traveling from areas west of I-5 would continue to

use Balboa Avenue to access the station. Further, a greater number of parking spaces (300)

could be accommodated under Options 1 or 2 compared to the Draft SEIS/SEIR parking supply

(220 spaces), resulting in additional vehicular trips on roadways near the station by transit

passengers that wish to park at the station. Therefore, the unmitigated traffic impacts at Mission

Bay Drive and Garnet Avenue and on Balboa Avenue identified in the Draft SEIS/SEIR would

not be eliminated or reduced under these options.

Parking Demand. Park-and-ride demand for the Balboa Avenue Station was forecast based on the

SANDAG Series 11 Travel Demand Forecasting Model. The park-and-ride facility for the Draft

SEIS/SEIR station site was forecast to have a demand for 382 parking spaces in 2030.

However, due to the site constraints, including an active earthquake fault that prohibits a parking

structure, only 220 spaces could be accommodated with a surface parking facility on the site.

This resulted in an unmet need for an additional 162 parking spaces in 2030. However, no

adverse spillover parking impacts were identified in the Draft SEIS/SEIR. Parking on local

streets is not anticipated because it is not convenient or visible from the main roadways that

provide access to the station (i.e., Morena Boulevard and Balboa Avenue), and to the extent

patrons do park on local streets, there are available parking spaces without substantially

displacing parking for existing residents (refer to Master Response 6 for additional information

on parking at the Balboa Avenue Station).

Park-and-ride demand for Options 1 and 2 forecast a need for 296 spaces in 2030, which is less

than the demand forecasted for the Draft SEIS/SEIR site. Parking demand is forecast to be less

because travel distances for transit patrons driving from certain locations in the corridor would

be longer under Options 1 and 2 compared to the travel distances to the Draft SEIS/SEIR site.

The conceptual design of parking for Options 1 and 2 determined that both station sites could

accommodate the forecast parking demand. Thus, relocating the Balboa Avenue Station under

Option 1 or Option 2 would reduce parking demand and provide sufficient parking to

accommodate the total demand. However, since no adverse or significant parking impact was
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identified for the Draft SEIS/SEIR site, the additional parking would not reduce any adverse or

significant parking-related impacts.

Bike/Walk Connectivity. For the Draft SEIS/SEIR station site, pedestrian access would require new

sidewalks on Balboa Avenue. Further, ramps and stairs would be required for vertical

circulation because of the elevation difference between the station and Balboa Avenue. Morena

Boulevard and Balboa Avenue are designated as Class 2 bicycle facilities within the station

area.

Option 1 and Option 2 provide more convenient bicycle and pedestrian connections to the

surrounding community and nearby employment destinations just north on Morena Boulevard.

While Option 1 would provide better pedestrian and bicycle connections to areas north of the

station, the share of trips arriving by walking or biking would only increase slightly (by 110, or

from 8 percent for the Draft SEIS/SEIR station site to 12 percent for Option 1).

The station platform for Option 2 would be farther from the high-density residential units and the

employment destinations than Option 1. Relocating the Balboa Avenue Station under Option 1

or Option 2 would provide better pedestrian and bicycle connections but would not significantly

increase pedestrian and bicycle access to the station or significantly increase transit ridership.

Transit Ridership. Under Options 1 and 2, there would be a negligible decrease in daily transit

boardings, as identified in Table 4. The ridership for the Draft SEIS/SEIR station site assumes

220 parking spaces (lower than the forecasted demand of 382 parking spaces, due to site

constraints), whereas ridership under Option 1 assumes 300 parking spaces (based on

forecasted demand of 300 spaces).

Table 4. Daily Boardings in 2030

Option Balboa Avenue Station Trolley Blue Line Transit System

Draft SEIS/SEIR site1, 3 3,180 111,990 636,480

Option 11, 2, 4 3,130 111,750 634,990

Change from Draft SEIS/SEIR site -50 (-1.6%) -240 (-0.2%) -1,490 (-0.2%)

Source: SANDAG Series 11 Model

Notes: Numbers rounded to nearest 10.

1

 Model run included the VA Medical Center Station Option.

2

 Modeling was conducted for Option 1 to determine changes in mode of access, parking demand, and

transit ridership compared to the Draft SEIS/SEIR station site. However, the model is not sensitive

enough to differentiate between Options 1 and 2 and, therefore, a separate model run was not conducted

for Option 2. The model results for Option 1 would generally be applicable to Option 2.

3

 Assumes 220 parking spaces.

4 Assumes 300 parking spaces.

Environmental Considerations

The evaluation of environmental issues included consideration of land use, hazardous

materials, geotechnical/seismic issues, and potential transit-oriented development (TOD)

opportunities. With the exception of these considerations, no other environmental

considerations were identified that would differ among the three sites to the extent that it would

affect the decision to relocate the Balboa Avenue Station on the City Yard site.
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Some residents suggested relocating the station as a means to minimize environmental impacts

(e.g., noise, visual). As documented in Chapter 4.0 of the Draft SEIS/SEIR, the Balboa Avenue

Station would not result in adverse or significant environmental impacts. As such, relocating the

station would not minimize or avoid any unmitigated adverse or significant environmental

impacts. As noted above under the Auto Access section, locating the station at one of the

alternative sites would not minimize or avoid the unavoidable traffic impacts.

Hazardous Materials. The Draft SEIS/SEIR identified the City Yard site as a hazardous materials

site of concern, based on several reports of unauthorized releases (including waste oil,

gasoline, and diesel fuel) and violations issued (refer to the Mid-Coast Corridor Transit Project

Hazardous Materials Technical Report for additional information). There were no hazardous

materials sites of concern identified on the Draft SEIS/SEIR station site. Any development at

the City Yard site, whether for the station or to consolidate the city maintenance facilities, would

require remediation if hazardous materials are found. This is a cost consideration; the cost of

remediating for any hazardous material contamination would depend on the material found and

the special handling required for disposal. Current research indicates that contamination is

likely in the southern portion of the site; however, further field work would be required to

establish the types and boundaries of contaminants, if present.

Geotechnical Considerations. A potential earthquake fault was identified on the Draft SEIS/SEIR

station site. Since circulation of the Draft SEIS/SEIR, an active earthquake fault was identified.

The existence of this fault precludes construction of a park-and-ride structure on the station site.

Current fault records indicate that there are no known faults on the City Yard site where Options

1 and 2 are located.

Potential TOD Opportunities. The Draft SEIS/SEIR station site is not large enough to accommodate

TOD on the site. Further, future development of the site as something other than a transit

station would be limited due to the earthquake fault, which would preclude construction of

structures such as houses or parking structures. However, locating the Trolley station on the

Draft SEIS/SEIR site could allow for future TOD on the entire City Yard site if the existing city

operations are relocated. The pedestrian bridge built as part of the project would connect any

future TOD on the City Yard site to the Draft SEIS/SEIR station site. The City Yard site is

approximately 21 acres; as a consolidated parcel, it provides a significant area for future

development opportunities.

The station concepts for either Option 1 or Option 2 use approximately one-third of the City Yard

site, leaving less of the property available for a future TOD opportunity if the existing city

operations relocate. The Trolley platform under either option would be located close to any

future TOD on the remaining portion of the City Yard site.

Engineering Considerations

The Draft SEIS/SEIR station site requires the redesign of the Balboa Avenue ramps to improve

access to the station site, installation of ramps from Balboa Avenue to the station site,

installation of traffic signals at the main entrance and at the bus-only exit, construction of

perimeter retaining walls, and construction of the LRT bridge over Balboa Avenue to allow for

pedestrian access from the north side of Balboa Avenue to the south side where the station

would be located. Because of the active earthquake fault at this site, the improvements at the

site are limited to an at-grade parking lot, precluding the use of a parking structure.
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The Option 1 station site is approximately 5 to 15 feet below Morena Boulevard (the City Yard

site is not level in this location) and approximately 30 to 40 feet above the LRT tracks and

platform. It is not feasible to raise the LRT tracks by this amount as it would require a retaining

wall of the same height between the LRT tracks and the LOSSAN tracks. Therefore, a retaining

wall would have to be constructed between the northbound Trolley platform and the station

parking lot and bus bays; elevators and stairs would be required between the parking lot and

platform. Such features would add to the capital and O&M costs of the project and are included

in the capital cost estimates presented in the Cost Considerations section below.

The Option 2 station site is approximately 35 feet above Balboa Avenue and approximately 30

feet below Morena Boulevard, which would make it more challenging to provide pedestrian

access to the station. Because of these grade differentials, pedestrian ramps would not be

feasible, and stairs and elevators would be required to provide access from Morena Boulevard

and Balboa Avenue to the station site, increasing capital and O&M costs. Additionally, the

station site would be approximately 10 feet above the LRT tracks and platform. With 10 feet of

grade separation, stairs and ramps would be provided from the northbound Trolley platform to

the parking lot and bus bays. These features are included in the capital cost estimates

presented in the Cost Considerations section below.

Right-of-Way Considerations

The Draft SEIS/SEIR station site is located on excess City of San Diego right-of-way and,

therefore, it is reserved for transportation use; there is no cost associated with acquiring this

parcel. Because of the difficult access and the active fault that runs through this site, it would be

difficult for the city to change the use of this site (as stated previously, structures are prohibited

on active faults).

In comparison, the City Yard site, while also owned by the City of San Diego, is an active

facilities yard with buildings and other infrastructure on the site. Locating the Balboa Avenue

Station on the City Yard site would require acquisition of the portion of the parcel needed for the

station facilities from the City of San Diego and consolidation of the City Yard facilities on the

remaining portion of the parcel, assuming the city agreed to the use of the City Yard site. (It

may be determined through coordination with the city that relocating the maintenance facilities

to a new site would be required; however, for the purposes of this memorandum it is assumed

that the facilities can be consolidated on the City Yard site.) The City Yard site is a larger parcel

than the Draft SEIS/SEIR site and, therefore, a cost is assumed for acquiring the portion of the

parcel needed for the station.

Cost Considerations

Capital costs were calculated for the three station sites and considered site work, roadway

improvements, retaining walls, and station features such as elevators and ramps as needed.

The capital cost estimates for the City Yard site also included hazardous materials remediation,

right-of-way, and consolidation of the City Yard maintenance facilities.

The Draft SEIS/SEIR site is estimated to have a capital cost of approximately $18.9 million in

year of expenditure (YOE) dollars (Table 5). As stated previously, this cost does not include

right-of-way.
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Table 5. Comparison of Capital Cost

Option YOE Dollars

Difference from Draft

SEIS/SEIR site

Draft SEIS/SEIR site $18,866,000

Option 1 $31,381,000 $12,515,000

Option 2 $36,529,000 $17,663,000

Source: SANDAG Series 11 Model

Notes: YOE = year of expenditure

Capital costs would increase under both Options 1 and 2 compared to the Draft SEIS/SEIR site.

Specifically, Options 1 and 2 would increase capital costs by approximately $12.5 and $17.7

million, respectively, over the Draft SEIS/SEIR site in YOE dollars (Table 5). The increase in

cost is due to the consolidation of City Yard maintenance facilities, right-of-way costs to acquire

the portion of the parcel needed for the station site, and hazardous materials remediation.

Further, the station site plans for Options 1 and 2 require additional site work (including grading

and retaining walls) than what would be required for the Draft SEIS/SEIR site. As explained

under the Engineering Considerations section, Options 1 and 2 also require ramps and

elevators or stairs to provide access from the street to the station site and from the station site

to the Trolley platform; these facilities are not required for the Draft SEIS/SEIR site. Such

features further increase the cost associated with each site. As such, relocating the Balboa

Avenue Station to the City Yard site under Options 1 or 2 would increase capital costs.

Conclusion

Although the City Yard site could accommodate the station and provide sufficient space to meet

the forecasted station parking demand, locating the station at the City Yard would not eliminate

or reduce any adverse or significant project impacts that were identified for the Draft SEIS/SEIR.

Further, the City Yard sites would increase capital and O&M costs.

6. Balboa Avenue Station—Spillover Parking

This master response was prepared to address comments from local residents that spillover

parking from station patrons could result in impacts to the surrounding neighborhoods.

The park-and-ride facility for the Draft SEIS/SEIR station site is forecast to have a demand for

382 parking spaces in 2030. However, parking supply is constrained due to the size of the

station site and the location of an active earthquake fault that prohibits a parking structure;

therefore, only 220 spaces can be accommodated with a surface parking facility. This resulted

in an unmet need for an additional 162 parking spaces.

Spillover parking into residential neighborhoods is not anticipated due to distance and

topography, particularly the grade differential between the Balboa Avenue Station and the

residential streets with on-street parking to the east of Morena Boulevard. For example, parking

at existing on-street facilities would require crossing busy streets, such as Morena Boulevard, or

walking along Balboa Avenue and crossing under the I-5 overcrossing to reach the station

platform. Such a walk likely would be a deterrent for those wishing to park near this station if

parking spaces were not available in the station park-and-ride lot. Additionally, the majority of

available on-street parking is located on residential side streets and is not visible from the main
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roadways that provide access to the station (i.e., Morena Boulevard and Balboa Avenue).

Further, pedestrian access from parking on these side streets to the station is not convenient.

As a result of comments received during the Draft SEIS/SEIR comment period, a spillover

parking analysis was conducted for a one-half-mile area around the Balboa Avenue Station to

determine if unmet parking demand (ranging up to approximately 160 spaces throughout the

day in 2030) could adversely affect on-street parking in surrounding areas. The analysis

identified 100 available spaces within a one-quarter-mile walk of the station and approximately

800 additional available spaces within a one-half-mile walk of the station during the midday

period, when parking at the Balboa Avenue Station could likely be full (refer to Figure 2 showing

parking availability in the vicinity of the Balboa Avenue Station).

The spillover parking analysis indicates there is adequate on-street parking to accommodate

unmet demand in the unlikely event of spillover parking; however, the parking spaces that are

closer to the station will be more desirable (e.g., along Morena Boulevard, a non-residential

area). Distance and topography could discourage transit patrons from parking on residential

streets farther from the station. Therefore, in the unlikely situation that transit patrons do park

on-street, they are anticipated to find on-street spaces within one-half mile of the station

(approximately a 10-minute walk) without substantially displacing parking for existing residents.

Consequently, it is not expected that spillover parking would result in an adverse impact on the

existing on-street parking supply in this area and mitigation would not be required.
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Figure 2. On-Street Parking Availability near the Balboa Avenue Station

Source: SANDAG, 2014
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7. Balboa Avenue Station and Morena Boulevard Area Noise

This master response was prepared to address comments from residents in the neighborhoods

adjacent to Morena Boulevard and the Balboa Avenue Station who expressed concern about

the noise level associated with the Trolley operation. In particular, these residents expressed

concern that the Trolley would increase the ambient noise level when combined with the

existing COASTER and Amtrak noise levels through this area. Commenters also expressed

concern that Trolley vehicles operating through this area would use a horn or other warning

device, further adding to the noise level in the area.

The noise impact assessment conducted in support of the project is presented in the Mid-Coast

Corridor Transit Project Noise and Vibration Impacts Technical Report and summarized in

Chapter 4.0, Section 4.7 of the Final SEIS/SEIR (Volume 1). Figures 4-18 and 4-19 show the

locations where noise analysis was completed along Morena Boulevard to determine whether

project-related noise would constitute an impact that would require mitigation. The evaluation

concluded that noise levels along Morena Boulevard between Sea World Drive and Balboa

Avenue caused by operation of the project will be less than the FTA moderate noise impact

criteria in all locations. Mitigation is provided only if project-generated noise would exceed the

FTA moderate noise impact criteria by more than 1 dBA. Therefore, no mitigation is necessary

and operation of the project will not result in a moderate or severe impact per FTA criteria or a

significant impact under CEQA.

The Trolley vehicles are powered by electricity and produce substantially less noise than the

diesel-powered COASTER and Amtrak trains currently in use on the existing heavy-rail tracks.

The maximum noise level (Lmax) generated when a diesel locomotive passes by at 50 miles per

hour is approximately 88 dBA at 50 feet from the tracks. A Trolley pass-by would generate an

Lmax that is 8 to 10 dBA quieter than that of a COASTER or Amtrak train.

Trolley vehicle electronic horns have two loudness settings. The low (quacker) setting is 75

dBA at 100 feet, and the high setting is 85 dBA at 100 feet when measured directly in front of

the train. The California Public Utilities Commission requires use of the high setting when trains

are approaching roadway grade crossings and when a safety concern is identified by the

operator (e.g., a pedestrian on the tracks). The California Public Utilities Commission requires

that MTS use horns to warn patrons before Trolley vehicles depart from a station. MTS uses

the quieter “quacker” horns when exiting stations. Off-site noise is reduced by mounting the

horns at track level on the trains rather than on the roof, and focusing the sound forward of the

vehicle. Noise experienced at greater than a 30-degree angle from the front of the train is

reduced by 5 dBA or more as the angle continues to increase.

The Trolley system will be fully grade separated in the Bay Park area, with no gated crossings;

therefore, no crossing bells or loud Trolley electronic horns will be required along Morena

Boulevard unless a safety concern is identified by the operator. The existing noise environment

in this area is affected by traffic along I-5, existing Amtrak and COASTER trains, freight trains,

and local roadways. Horns on the Amtrak and COASTER trains that currently operate through

the corridor produce an Lmax of between 96 and 110 dBA measured 100 feet in front of the train,

which is substantially louder than the quacker horns on light-rail trains. For reference, to a

person with average hearing, a 20-decibel increase is generally perceived as four times the

loudness of the original sound level.
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The anticipated noise levels for the Refined Build Alternative are provided in Chapter 5.0, Table

5-4 of the Mid-Coast Corridor Transit Project Noise and Vibration Impacts Technical Report. In

this area, the project will generate noise levels between 56 and 65 dBA Ldn. Noise levels from

the Trolley will be lower than the existing ambient noise levels in the area (65 to 77 dBA Ldn).

The addition of noise from the Trolley to existing ambient noise levels will have a minimal effect

on the total noise levels (up to a 1 dBA increase), an effect that is not normally perceptible to the

human ear.

8. Balboa Avenue Station—Traffic Conditions

This master response was prepared to address comments from residents in the neighborhood

adjacent to the Balboa Avenue Station who expressed concerns that traffic accessing the

station and park-and-ride facility could result in impacts on roadways and intersections in the

area. Residents expressed concern that the roadway modifications proposed as part of the

project could also worsen traffic conditions. Additionally, the Draft SEIS/SEIR identified two

adverse and unmitigated traffic impacts as a result of traffic accessing the station; residents

commented on these impacts and the potential measures that could mitigate these impacts.

As part of the station plan for the Balboa Avenue Station, there will be a reconfiguration of the

Morena Boulevard/Balboa Avenue ramps in the station vicinity (refer to Figure 3 showing the

proposed reconfiguration of ramps and proposed access to the station). As discussed further

below, these changes will not adversely affect traffic flow along Balboa Avenue or Morena

Boulevard at this location. Specifically, the following access changes will be made:

· The ramp from eastbound Balboa Avenue to southbound Morena Boulevard will be

eliminated to accommodate the Balboa Avenue Station. This will allow for a longer merge

distance (approximately an additional 300 feet) between the northbound I-5 off-ramp to the

eastbound Balboa Avenue and Morena Boulevard connector ramp from eastbound Balboa

Avenue. A longer merge distance allows cars more time and longer distance for weaving

and merging, which will benefit traffic on Balboa Avenue between the I-5 northbound offramp and the Balboa Avenue and Morena Boulevard ramp. A four-way intersection will be

provided at the entrance to the station.

· To provide access from eastbound Balboa Avenue to southbound Morena Boulevard with

the elimination of the ramp, the intersection of the Balboa Avenue loop ramp/Balboa Avenue

Station park-and-ride entrance/Morena Boulevard intersection will be reconfigured (refer to

Figure 3 showing the proposed reconfiguration of ramps and the proposed access to the

station, and Sheet 185 of the Final SEIS/SEIR Plan Set [Volume 2]). A traffic signal will be

installed at this intersection (Morena Boulevard and the ramp from Balboa). Under this new

configuration, traffic from eastbound Balboa Avenue heading to southbound Morena

Boulevard will make a right turn onto the reconfigured Balboa Avenue-to-Morena Boulevard

loop ramp and make a left turn from the loop ramp onto southbound Morena Boulevard at

the new signalized intersection. No new traffic control or traffic movement will be introduced

on Balboa Avenue, and the new configuration will not affect traffic flow on eastbound or

westbound Balboa Avenue.
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Figure 3. Reconfiguration of the Balboa Avenue/Morena Boulevard Ramps

Source: SANDAG, 2014
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· In addition to the traffic signal installed at the park-and-ride entrance, a second traffic light

will be installed at the bus-only exit driveway (refer to Sheet 185 of the Final SEIS/SEIR

Plan Set [Volume 2], for the locations of the intersections). Morena Boulevard typically will

have longer green time than the entrance and exits to the park-and-ride because of the

greater traffic volumes. In addition, the two new traffic signals will provide a green light to

the side street (i.e., the park-and-ride entrance and the bus exit driveway) only when it is

actuated or triggered by a vehicle or pedestrian. This will maximize the green time on

Morena Boulevard. Further, the timing of the two new traffic signals will also be coordinated

for traffic on Morena Boulevard, thus providing traffic progression on Morena Boulevard

through the two intersections.

Traffic Conditions from the Modifications. Modifications to the ramps from Balboa Avenue to

Morena Boulevard and the addition of signalized intersections on Morena Boulevard will change

existing traffic conditions, but the overall impact will not be adverse. A future (2030) and nearterm (2010) traffic analysis was conducted for the reconfigured ramps. As documented in

Chapter 3.0, Section 3.4.2.2 under the heading “Refined Build Alternative Freeway and

Roadway System Performance and Impacts” of the Final SEIS/SEIR (Volume 1), potential

impacts to two roadway segments on Balboa Avenue between the I-5 northbound off-ramp and

Moraga Avenue (the segments that include the Balboa Avenue and Morena Boulevard ramps)

and the new signalized intersection at Morena Boulevard and the Balboa Avenue loop ramp

were analyzed (refer to Chapter 3.0, Inset 3 in Figure 3-2 of the Final SEIS/SEIR (Volume 1) for

the locations analyzed).

The roadway segment and intersection analysis in the near and long term is presented in the

Mid-Coast Corridor Transit Project Transportation Impacts and Mitigation Report in Chapters 4.0

and 7.0. Specifically, refer to Table 4-57 for roadway-segment impacts in 2030, Table 4-62 for

intersection impacts in 2030, and Tables 7-4 and 7-9 for near-term impacts at these locations.

As shown in Table 4-57, the project will not have an adverse impact on the two segments

between the I-5 northbound off-ramp and Moraga Avenue. In addition, the Refined Build

Alternative will not have an adverse impact at the Balboa Avenue eastbound ramps, park-andride entrance, or the Morena Boulevard intersection (Table 4-62). The results of the near-term

analysis also concluded that there will be no adverse impacts at these locations if the project

were implemented immediately (Tables 7-4 and 7-9).

Traffic Conditions from Station Area Traffic. The project will have significant and adverse traffic

impacts at one roadway segment (Balboa Avenue from the I-5 southbound on-ramp to the I-5

northbound off-ramp where daily traffic will increase by less than 1 percent compared to the NoBuild Alternative) and one intersection (Mission Bay Drive and Garnet Avenue, where an

increased delay of 1 to 4 seconds over the No-Build Alternative will occur). Mitigation measures

were considered for the segment of Balboa Avenue and the intersection of Mission Bay Drive

and Garnet Avenue, but were deemed infeasible as described below.

The increased traffic volume on the Balboa Avenue segment could be mitigated by the addition

of lanes, if sufficient land were available. However, widening this segment of Balboa Avenue

would require reconstruction of the I-5 overpass and railroad overpass, utility relocations, and

full and partial property acquisitions. The significant cost and additional impacts render

mitigation of these impacts infeasible.
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The impact at the intersection of Mission Bay Drive and Garnet Avenue could be mitigated by

the addition of either a second southbound through lane or a dual westbound left-turn lane, both

of which would require additional right-of-way and utility relocations. Further, even with

implementation of either mitigation measure, the level of service would remain E, as it does

under existing conditions, but with slightly less delay than with the No-Build Alternative. While

the project does increase delay above city guidelines, its contribution is relatively minor when

compared to existing and future conditions without the project. The benefits of incrementally

reducing the impact at this intersection would not outweigh the secondary impacts of this

mitigation, and the impact at this location would still remain adverse and significant.

9. Overview of Noise Impact Assessment and Mitigation

This master response was prepared to summarize the methodology of conducting the noise

analysis and identifying mitigation for the project. Comments received on the Draft SEIS/SEIR

regarding noise mitigation primarily related to the following: (1) asking whether noise mitigation

for noise levels from the project would be provided along certain portions of the alignment, (2)

requesting the provision of noise mitigation measures at a specific location along the alignment,

or (3) questioning why noise mitigation was being provided in one location but not in another.

The noise and vibration analysis was conducted in compliance with federal, state, and local

regulations. FTA guidelines and criteria for assessing noise impacts related to transit projects

are outlined in the Transit Noise and Vibration Impact Assessment Guidance Manual. Caltrans

guidance included in the Traffic Noise Analysis Protocol for New Highway Construction,

Reconstruction, and Retrofit Barrier Projects applies to locations where the project could affect

traffic noise. City of San Diego noise abatement and control requirements included in Article 9.5

of the San Diego Municipal Code also were applied were appropriate.

The FTA Noise Impact Criteria depend on the noise sensitivity of the land use and the existing

noise environment. For properties such as schools and libraries that are only sensitive to the

daytime noise level, the impact criteria apply to the hourly Leq, which is a measure of total noise

averaged over a one-hour period. For locations where people sleep, including residences,

hotels, and hospitals, the applicable impact criteria consider the day/night noise level (Ldn), a

descriptor of the daily (24-hour) Leq that incorporates a 10-dBA penalty for all sound occurring

during the nighttime hours of 10:00 p.m. to 7:00 a.m.

The FTA defines two levels of noise impact: moderate and severe. The specific noise impact

criteria associated with each land use category, existing noise environment, and level of impact

are shown in Chapter 4.0, Figure 4-16 of the Final SEIS/SEIR (Volume 1). Severe noise

impacts are significant within the context of NEPA or CEQA. Mitigation measures must be

considered and incorporated into the project to avoid severe impacts unless there are

extenuating circumstances that prevent it. Moderate noise impacts are not necessarily

significant within the context of NEPA and CEQA, but they do require consideration and

adoption of mitigation measures when it is reasonable. One consideration is the extent to which

the predicted noise level exceeds the moderate impact threshold. Mitigation measures are not

proposed and the impact is less than significant within the context of NEPA and CEQA when

predicted noise levels equal, but do not exceed, the FTA moderate impact threshold.

No severe noise impacts have been predicted for transit operations. As shown in Chapter 4.0,

Figures 4-18 and 4-19 of the Final SEIS/SEIR (Volume 1), moderate impacts will occur at seven
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locations in the corridor. The project noise exposure (the noise generated by the project) will

exceed the moderate threshold by 1 or more dBA at five of the seven locations; mitigation

measures were evaluated for these five locations according to the FTA criteria, as summarized

in Chapter 4.0, Table 4-14 of the Final SEIS/SEIR (Volume 1). Mitigation was not considered

for the other two locations because the project noise exposure did not exceed the FTA

moderate noise threshold by 1 dBA or more.

Mitigation of noise impacts from transit projects may involve treatment at the three fundamental

components of the noise problem: (1) at the noise source, (2) along the path that the noise

travels, or (3) at the receiver. Measures to reduce noise at the source and in the path of travel

reduce the noise level experienced by all nearby land uses, both outdoors and inside of

buildings, and provide a benefit for indoor locations when windows are open. Noise insulation,

including window and door replacements, are generally a measure of last resort when other

measures are not feasible, because they provide no benefit to outdoor users, require

modification of private property, and rely on the property owner to maintain the modifications for

them to continue to provide a benefit.

For the Mid-Coast Corridor Transit Project, mitigation of either the noise source or path of travel

will be implemented to reduce project noise exposure levels to below the moderate impact

criteria at five locations evaluated. At one location (Cluster 9 Camden Tuscany Apartments),

the sound level of grade-crossing bells will be lowered to the minimum allowed for safe

operation. At the other four locations (Clusters 57 and 59 La Paz Condominiums, Cluster 71

Lost Apartments at the Shops at La Jolla Village shopping center, and Cluster 72 Sheraton La

Jolla Hotel), sound walls will be provided adjacent to the tracks, blocking the noise path

between the tracks and nearby noise-sensitive land uses.

10. Property Values

This master response was prepared to address comments stating concerns that the introduction

of the project would decrease property values. Additionally, it addresses comments that

requested an economic analysis to determine the impacts to residential properties resulting from

the project. These comments were received from residents who live along the alignment or

near proposed stations.

As stated in the Final SEIS/SEIR (Volume 1), there could be increases in property values for

both residential and commercial properties near the new stations constructed for the Mid-Coast

Corridor Transit Project (refer to Chapter 4.0, Section 4.3.3.2) as a result of higher density

development around stations and the effects of improved mobility and accessibility. This

conclusion is supported by local and national research on the relationship of transit to urban

land use development.

Local Level. Several studies have been completed with respect to property values within San

Diego. A 2002 Urban Land Institute study titled Land Value Impacts of Rail Transit Services in

San Diego County found that rail transit services in the San Diego region have resulted in

significant benefits to land values for residential and commercial properties, although

relationships vary considerably by type of land use and corridor. A 1992 study completed by

MTDB found that single-family residential values increased by 2 percent; multifamily residential

values increased by 4 to 18 percent; and commercial values increased by 167 percent within

200 feet of station areas in the Trolley system. Similarly, a 1990 analysis of land-value impacts
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on single-family homes in San Diego was completed by Landis, Guhathakrurta, and Zhang.

Based on data for 134 home sales in the City of San Diego, the study found appreciable landvalue benefits accrued to single-family residences near Trolley stations.

National Level. National research studies show that, in general, the more accessible a location is

in terms of transportation access, the higher its property values. A 2013 analysis commissioned

by the American Public Transportation Association titled The New Real Estate Mantra–Location

near Public Transportation, demonstrated that residential properties located in proximity to

fixed-guideway transit have maintained value as compared to residential properties without

transit access in five regions across the United States. This study found that property values

within transit station areas outperformed the region as a whole by 41.6 percent. Two areas

studied contained light-rail transit systems: Minneapolis-St. Paul and Phoenix. Property values

within these two areas with light-rail transit systems outperformed local areas without light-rail

transit systems between 37 and 48 percent.

11. Potential for Crime Rates to Change within the Mid-Coast Corridor

This master response was prepared to address comments stating concerns that the introduction

of the project would increase crime, including vandalism, theft, or other illegal activities, within

the community. Additionally, commenters expressed concern that crime could occur at the new

Trolley stations and/or park-and-ride facilities. Some commenters requested an analysis of

changes in crime when a new transit system is implemented, particularly within residential

areas.

The 2006 Mission Valley Corridor Crime Study (2006 Study) evaluated the impacts of the

recently implemented Green Line Trolley extension on crime and perception of crime in the

eastern part of the Mission Valley Corridor.

The 2006 Study was designed to obtain a complete picture of the Trolley Green Line

extension’s perceived and actual impact on crime. It included three main components: 1) a

survey of residents (zip codes containing Trolley stations and surveys of residents within one

mile of a Trolley station) and business owners/managers (within one-half mile of stations) to

learn about current and changing crime perceptions as a result of the Trolley Green Line

extension, 2) an analysis of the 2006 Green Line Trolley Survey to gather Trolley riders’

opinions about safety and to determine who and why people are riding it, and 3) an analysis of

crime data for census tracts containing Trolley stations in the eastern portion of the Mission

Valley Corridor compared to total crime rates for all census tracts in the City of San Diego and

the County of San Diego.

The results of the 2006 Study were used to assess potential impacts of the Trolley Blue Line

extension into the Mid-Coast Corridor. The use of data from the Trolley Green Line extension to

evaluate potential impacts of the Trolley Blue Line extension is appropriate because of the

similar land use and demographic characteristics of the communities along the two corridors

(age distributions almost identical, both have similar housing characteristics, a major university,

similar racial and ethnic demographics, and a median income above the City of San Diego

median household income).
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The results of the 2006 Study indicate that the Trolley Green Line extension has not negatively

impacted crime rates in the Mission Valley Corridor, and it concluded that it is unlikely that the

Trolley Blue Line extension will significantly impact crime rates in the Mid-Coast Corridor.

To enhance crime prevention at stations, the Mid-Coast Corridor Trolley stations will incorporate

lighting, security cameras, and the principles of Crime Prevention through Environmental

Design, a safety policy adopted by the San Diego Police Department in 2001. These principles

include open visible platforms with lighting. Additionally, signs with phone numbers are posted

at stations if transit patrons or the general public observe suspicious activity within the station

area. MTS employs roving code enforcement inspectors and a transit security force, both of

which will be expanded as required to serve the new Trolley stations within the Mid-Coast

Corridor. Consistent with current MTS policy, anyone observed by the roving code enforcement

inspectors in a fare paid area without proof of a paid fare will be asked to leave the premises. It

is anticipated that the project will incorporate design features, such as benches, that do not

allow people to lie down comfortably, consistent with current MTS practice. The safety features

and practices, and the design features described above, will deter individuals from loitering in

station areas, including during evening and early morning hours.

12. Graffiti

This master response was prepared to address comments stating concern that elements of the

project, particularly retaining and sound walls, could be covered with graffiti. Additionally, some

commenters inquired about, or suggested, treatments for walls, such as textures, to minimize

the likelihood of graffiti.

SANDAG is aware that structures, walls, and fences associated with a light-rail system may be

targets for graffiti “taggers.” Chapter 6.0, Table 6-2 of the Mid-Coast Corridor Transit Project

Visual Impacts Technical Report provides for the planting of vines on walls to soften the

appearance of walls and help with graffiti control. Once the project is implemented, MTS will be

responsible for maintenance of stations and the right-of-way. MTS is part of the Graffiti Tracker

Program, which is a database that tracks graffiti incidents throughout the San Diego region to

aid in enforcement. Reports of graffiti are analyzed within 24 hours, and cleanup is undertaken

by the jurisdiction within which the graffiti has occurred (Caltrans, City of San Diego Streets

Division, or MTS). Information is shared by law enforcement agencies to prosecute vandals,

resulting in increased penalties and large restitutions. In addition, MTS employs undercover

security to patrol and investigate graffiti and has recently implemented an in-station closedcircuit television system with on-board cameras on Trolleys to help fight graffiti.

13. Project Lighting Impacts

This master response was prepared to address comments stating a concern about lighting

impacts from the project. In particular, comments focused on specific areas near the alignment

(e.g., near Rose Canyon Open Space Park), at stations, along the tracks, or from Trolley

vehicles.

Evening or nighttime views will not be altered or substantially changed by project lighting. At

project stations and station areas, exterior lighting will include light fixtures for pedestrian safety,

security, and signage. This lighting will be directed downward and will minimize light trespass or

spill-over into sensitive areas, such as residential neighborhoods. There is no track or aerial
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guideway lighting. The only location that could have lighting along the guideway is through the

undercrossing of La Jolla Colony Drive (where any lighting would be shielded). Project

measures identified in Chapter 4.0, Section 4.4.3.2 of the Final SEIS/SEIR (Volume 1) under the

heading “Project Measures to Avoid or Minimize Impacts” note that lighting levels will not

exceed 2 foot-candles from the project area into the adjacent residential uses or other sensitive

receptors. Although project lighting will be designed to illuminate specific areas of the project

site and station platforms, the lighting will be visible from off-site locations and will blend with the

ambient illumination typical to an urban environment.

Any light fixtures adjacent to natural areas will be minimal, and any lights will be shielded to

direct the light source directly down and away from natural areas to reduce any indirect lighting

or spillover lighting. The headlights on the front of the Trolley vehicles are directed straight

toward the tracks. Currently, all Trolley cars have tinted windows to screen interior lighting, and

it is anticipated future vehicles will have similar design features.

14. Rose Canyon Open Space Park—Noise

This master response was prepared to address comments received on the Draft SEIS/SEIR

requesting analysis of operation or construction noise impacts in Rose Canyon Open Space

Park on recreational users and/or special-status wildlife. Comments also requested

consideration of noise mitigation, including construction of an earthen berm, adjacent to Rose

Canyon Open Space Park. The request to construct an earthen berm is addressed in Master

Response 17.

The noise impact assessment conducted for the Mid-Coast Corridor Transit Project uses FTA

guidance to identify potential impacts. The FTA Noise Impact Criteria state that “Certain

historical sites and parks are also included” in the definition of noise-sensitive Category 3 Land

Uses. Areas within Marian Bear Memorial Park and the multi-use path in Rose Canyon Open

Space Park are considered to be noise-sensitive Noise Category 3 receivers. For noisesensitive parklands, Leq(h)—a measure of the hourly average noise level—is the appropriate

noise metric. As described below, the analysis conducted for the project determined that noise

levels associated with the project will not exceed the FTA’s thresholds for a moderate or severe

noise impact.

Rose Canyon Open Space Park is an open-space park that is located near two freeways and an

active railroad corridor. The existing daytime park noise levels are in the 59 dBA to 64 dBA

Leq(h) range. The project will introduce project-generated noise levels of between 45 dBA Leq(h)

and 50 dBA Leq(h) within Rose Canyon Open Space Park (Receiver Clusters 56c through 56g in

Chapter 5.0, Table 5-5 of the Mid-Coast Corridor Transit Project Noise and Vibration Impacts

Technical Report). The additional noise generated by the project will increase the total noise

level by less than 0.5 dBA at the modeled receiver sites, an effect that is not normally

perceptible to the human ear. The project will not substantially change the existing noise

environment or alter the existing compatibility of the park.

In response to comments on the Draft SEIS/SEIR, SANDAG completed additional noise

analysis within Rose Canyon Open Space Park with consideration of both noise-sensitive

human uses and noise effects on wildlife. The analysis is summarized in Chapter 4.0, Section

4.7.3.2 of the Final SEIS/SEIR (Volume 1) regarding human use and Chapter 5.0, Section 5.1.2
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of the Mid-Coast Corridor Transit Project Biological Resources Technical Report regarding

effects on wildlife habitat. The project noise levels (see Chapter 5.0, Table 5-5 and Chapter 7.0,

Table 7-1 of the Noise and Vibration Impacts Technical Report) will be between 45 dBA Leq(h)

and 50 dBA Leq(h) within Rose Canyon Open Space Park (Receiver Clusters 56c through 56g).

These levels are less than the 60-dBA Leq threshold used by the City of San Diego to analyze

potential noise impacts to coastal California gnatcatcher, which is often used to evaluate

impacts to other bird species.

The additional noise analysis within Rose Canyon concludes that the hourly average noise

levels associated with project operation will not exceed the City of San Diego’s General Plan

noise level compatibility standards or the FTA’s moderate or severe noise impact criteria for

noise Category 3 Land Use.

Mitigation measures to reduce long-term, operational noise levels within Rose Canyon Open

Space Park are not required, as operational noise will not exceed FTA thresholds for moderate

or severe impacts and the project will not interfere with wildlife utilization of the Multi-Habitat

Planning Area (MHPA) or use of the park for recreation. The alignment is located within the

existing MTS right-of-way. The two existing LOSSAN tracks within the MTS right-of-way

currently support freight, COASTER, and Amtrak service, and the project alignment is separated

from Rose Canyon Open Space Park by these two tracks. The project will not introduce a new

land use or affect areas of the park that are not already subject to disruption from existing rail

operations. The analysis for the project concluded that the project will not result in or contribute

to cumulative adverse noise impacts to recreational users or biological resources, including

impacts within the MHPA.

Construction noise impacts on breeding areas are addressed in Chapter 4.0, Section 4.17.3.2

under the heading “Special-Status Wildlife” of the Draft SEIS/SEIR, which states that

“Construction would result in short-term noise impacts in adjacent habitat areas which can

disrupt foraging, nesting, and reproduction activities in breeding birds.” However, existing

ambient noise levels associated with freeway traffic and other nearby sources at these locations

are relatively high. Potentially suitable habitat for coastal California gnatcatcher, least Bell’s

vireo, southwestern willow flycatcher, and light-footed clapper rail was identified within the

project area. Mitigation Measures CON12, CON13, and CON14 include the implementation of

breeding season avoidance, noise minimization, and/or noise attenuation measures. With the

implementation of these mitigation measures, potential short-term indirect impacts to coastal

California gnatcatcher, least Bell’s vireo, southwestern willow flycatcher, and light-footed clapper

rail from construction noise will not be adverse for the Refined Build Alternative. Additionally,

with mitigation, construction-related noise levels in the adjacent habitat areas would not

substantially increase ambient noise levels during the breeding season; therefore, potential

indirect impacts to most special-status wildlife species from noise during construction will not be

adverse.

The Draft SEIS/SEIR identified a moderate noise impact to Marian Bear Memorial Park, which is

near Rose Canyon Open Space Park, that would have been caused by the location of a track

crossover. The Refined Build Alternative eliminated the track crossover, which avoided the

moderate noise impact at Marian Bear Memorial Park.
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15. Rose Canyon Open Space Park—Visual

This master response was prepared to address comments received on the Draft SEIS/SEIR

expressing concern with visual impacts on Rose Canyon Open Space Park. In particular,

comments discussed visual impacts on recreational users from within the park and requested

additional analysis. Commenters also suggested an earthen berm to minimize visual impacts.

The potential to construct such a berm is addressed in Master Response 17.

The project has been designed to minimize impacts to Rose Canyon Open Space Park and will

be located within the existing MTS right-of-way. The MTS right-of-way currently includes

overhead utility lines and other man-made features (some of these features, such as overhead

utility lines, are also located in the park), as well as two LOSSAN tracks that currently support

freight, COASTER, and Amtrak services. The project will be separated from Rose Canyon

Open Space Park by these two tracks. Although the project will add Trolley service, which will

be more frequent than current rail services, the duration of any view affected by the project (i.e.,

a four-car consist traveling at 50 mph) will be minimal, representing only a few seconds for each

train.

The project will be located within the MTS right-of-way and no project features will be located

within Rose Canyon Open Space Park. In this area of the corridor, the project and the park are

located in the Rose Canyon North landscape unit, as defined in the Mid-Coast Corridor Transit

Project Visual Impacts Technical Report. As described in Chapter 4.0, Section 4.4.3.2 of the

Final SEIS/SEIR (Volume 1), “Within Rose Canyon West and Rose Canyon North, project

features would include tracks and catenaries. Project construction would entail limited grading,

tree removal, and retaining walls. It would be built primarily within the existing MTS right-of-way

where railroad tracks and other equipment already exist. The additional project features would

not be visually prominent for recreation users because they would be adjacent to existing tracks,

buildings, freeways, and above ground utilities, and mitigation measures would reduce the

visual impact of retaining walls and tree and vegetation removal. Thus, with implementation of

mitigation measures, the new project features would not contrast with the existing visual

character or quality, and no adverse impacts would occur.” Mitigation measures for landscape

design and vegetation replacement are outlined in Chapter 4.0, Section 4.4.4 of the Draft

SEIS/SEIR (i.e., VR4, VR6, and VR7).

The selection of key views is described in Chapter 3.0, Section 3.3.3 of the Mid-Coast Corridor

Transit Project Visual Impacts Technical Report, starting with potential key views, which were

narrowed down to candidate key views and then final key views. The evaluation of potential key

views within Rose Canyon for recreational users, including hikers and cyclists, is provided in

Appendix A of the Mid-Coast Corridor Transit Project Visual Impacts Technical Report (i.e.,

Potential Key Views 13-19). The key views were reviewed to identify areas where the project

could result in adverse impacts. Simulations were prepared for final key views, identified as

areas where the project could have an adverse impact on the visual setting. The evaluation in

support of the Draft SEIS/SEIR determined that the project will not have adverse impacts in the

Rose Canyon area and, therefore, simulations were not prepared.

Based on comments received during the Draft SEIS/SEIR comment period, additional analysis

was completed to confirm the accuracy of the conclusion that, with mitigation, there will be no

adverse or significant visual impacts on Rose Canyon Open Space Park. Specifically, seven
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additional potential key views from hiking trails within Rose Canyon Open Space Park were

evaluated in support of the Final SEIS/SEIR, as presented in Appendix D of the Visual Impacts

Technical Report (i.e., Potential Key Views C through I). As documented in Appendix D, based

on this analysis of additional potential key views, the project will not change or modify the

existing visual character or quality from these locations and will have a low level of contrast with

the existing visual environment. There will be no adverse visual impact to this area, and no

additional mitigation is required.

Additionally, in response to comments received on the Draft SEIS/SEIR, SANDAG prepared

visual simulations for Potential Key Views I and G, illustrating the location and scale of the

project. These simulations, as provided and analyzed in Appendix D of the Mid-Coast Corridor

Transit Project Visual Impacts Technical Report, were not required based on the methodology

used for visual simulations but further demonstrate that the project will not contrast with the

existing visual character or quality.

The additional analysis and potential key views presented in Appendix D of the Mid-Coast

Corridor Transit Project Visual Impacts Technical Report confirms the findings presented in the

Draft SEIS/SEIR regarding no adverse or significant visual impacts to Rose Canyon Open

Space Park.

16. Rose Canyon Open Space—Habitat Mitigation

This master response was prepared to address comments received on the Draft SEIS/SEIR

expressing concern regarding the loss of wetlands and riparian habitat, particularly along Rose

Creek. In addition, comments were received requesting that impacts to sensitive upland habitat

be mitigated within the Rose Canyon watershed rather than at the identified off-site mitigation

location, Sage Hill. Finally, concerns were raised regarding the potential of the project to

introduce or expand the presence of invasive nonnative species during construction and

implementation of mitigation.

Long-term impacts to wetlands will be mitigated at a minimum ratio of 3:1, including a 1:1 ratio

of wetlands creation to ensure no net loss. As stated in Chapter 4.0, Section 4.8.4 of the Final

SEIS/SEIR (Volume 1), for impacts to wetland “vegetation communities in the Rose Creek

watershed, proposed mitigation includes implementing a portion of the restoration and creation

opportunities identified in the Rose Creek Watershed Wetland, Riparian and Water Quality

Restoration Opportunities Analysis.” SANDAG will select mitigation sites, choosing from the

specific options presented in that document.

As indicated in Chapter 4.0, Section 4.8.4 of the Final SEIS/SEIR (Volume 1), “Agency

consultation regarding mitigation, including the identification of off-site mitigation areas, will

continue throughout the permitting process. Additional on- and off-site options may be identified

to satisfy mitigation requirements.”

The proposed mitigation for impacts to upland habitat that supports coastal California

gnatcatcher is subject to review by the USFWS as a part of ongoing Section 7 consultation.

The TransNet Environmental Mitigation Program encourages early coordination with wildlife

agencies (CDFW, USFWS) to identify mitigation sites with high value for species that are

anticipated to be affected by current and future projects identified in the RTP. This allows for

mitigation that benefits the species on a regional level. The Sage Hill site was previously
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approved by the wildlife agencies as an acceptable mitigation location for upland impacts from

the project. Impacts to upland habitat within Rose Canyon will be limited to relatively narrow

linear areas within or immediately adjacent to the existing MTS right-of-way. While mitigation

opportunities may exist in the area, it is not known if the wildlife agencies would concur that

such areas would provide an equivalent level of benefit to the species as would mitigation at the

Sage Hill site. SANDAG has consulted with the Rose Creek Watershed Alliance regarding

wetland and upland mitigation opportunities in Rose Canyon, and has preliminarily identified

sites both for wetland mitigation and upland mitigation to supplement the mitigation at the Sage

Hill site.

As indicated in Chapter 4.0, Section 4.8.5.1 of the Final SEIS/SEIR (Volume 1), “Implementation

of the project is not expected to introduce invasive plants into natural open space areas.

Although landscaping likely would be incorporated at stations and related facilities, these

locations are not near or adjacent to natural open space areas that would be susceptible to the

introduction of invasive plant species. During construction, invasive plant species could be

introduced into adjacent natural open space areas via the transport of seeds or other plant

propagules on construction vehicles and equipment. However, construction vehicles and

equipment will be washed prior to working in areas where sensitive vegetation communities are

present adjacent to the project. Therefore, implementation of the project would not introduce

invasive plant species into natural open space areas and a less than significant impact would

occur.” Mitigation for temporary impacts (e.g., restoration of temporarily disturbed areas) will

occur on site and will restore disturbed areas to pre-project conditions using only appropriate

native plant species.

17. Requests for a Berm

This master response was prepared to address several comments on the Draft SEIS/SEIR that

expressed interest in the potential to construct one or more earthen berms along the alignment

between the MTS right-of-way and the Rose Canyon Open Space Park/Marian Bear Memorial

Park area. Comments suggested that such berms could provide sound attenuation, visual

screening, and light shielding; that they could limit the spread of invasive species; and that they

could reduce the potential for wildlife to cross the train tracks.

As documented in the Mid-Coast Corridor Transit Project Noise and Vibrations Impacts

Technical Report and Chapter 4.0, Section 4.7.3.2 of the Final SEIS/SEIR (Volume 1), the

project will not result in significant noise impacts within Rose Canyon Open Space Park or

Marian Bear Memorial Park; therefore, mitigation is not required. While the project could still be

audible to trail users at some locations within Rose Canyon Open Space Park, depending on

the topography and distance of the trail user from the project, noise impacts will not be

significant. Refer to Master Response 14 for additional information regarding the noise analysis

for Rose Canyon Open Space Park.

As noted in Chapter 4.0, Section 4.4.3.2 of the Final SEIS/SEIR, “The additional project features

would not be visually prominent for recreational users because they would be adjacent to

existing tracks, buildings, freeways, and above ground utilities, and mitigation measures would

reduce the visual impact of retaining walls and tree and vegetation removal. Thus, with

implementation of mitigation measures, the new project features would not contrast with the

existing visual character or quality, and no adverse impacts would occur.” Refer to Master
Volume 3 – Comments and Responses

Master Responses

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 MR-29

Response 15 for additional information regarding the visual analysis for Rose Canyon Open

Space Park. As a result, a berm is not needed as additional mitigation for noise or visual

impacts.

Impact avoidance, minimization, and mitigation measures are described in Sections 4.4 and

4.17.3.2 of the Final SEIS/SEIR, and include screening TPSS locations with walls and/or

vegetation; designing retaining walls to be compatible with the visual character and quality of

the surrounding area; replacing trees that are removed to accommodate the project; and

restoring habitat that is temporarily affected by construction through the implementation of a

habitat mitigation and monitoring plan with a multi-year maintenance and monitoring period.

Thus, new elements associated with the project (e.g., retaining walls) will be visually compatible

with the surrounding open space areas, and areas that are temporarily affected during

construction will be restored with native vegetation communities.

As described further, the impacts to natural resources associated with constructing berms

adjacent to the railroad corridor outweigh the potential benefits, particularly as no significant

noise or visual impacts have been identified in this area. To provide any additional sound

attenuation, a berm would need to be approximately 6 feet high. Construction of a 6-foot-tall

earthen berm with a 2:1 slope would require a minimum width of 24 feet on level ground. In the

specific case of Rose Creek, the construction of a berm of this height adjacent to the project

alignment would not only require use of land outside the designated railway corridor (MTS rightof-way), it would also physically extend into Rose Creek and would also encroach onto

dedicated parkland.

Construction of earthen berms to serve as light shielding or to reduce noise or visual impacts

would result in substantial temporary impacts to habitat and permanent impacts to aquatic

resources within Rose Creek. A berm would provide minimal value for noise attenuation, and

the limited light associated with Trolley vehicles does not warrant additional shielding. Refer to

Master Response 13 for a discussion of lighting impacts. The project will not include any

permanent light elements or fixtures in Rose Canyon Open Space Park.

Wildlife is not expected to routinely cross over the train tracks because the majority of highquality habitat is located east of the right-of-way; therefore, injury or mortality due to collisions

with trains is not expected to result in adverse impacts (see Chapter 5.0, Section 5.1.2.1 of the

Mid-Coast Corridor Transit Project Biological Resources Technical Report). Furthermore, given

the existing hilly terrain in the area, a vegetated berm is not expected to serve as an effective

barrier to protect wildlife unless fencing is also incorporated, which would result in visual

impacts to trail users.

The assertion that a berm would reduce the potential for the seeds of non-native plants to

spread in Rose Canyon Open Space Park is unsupported, as the berm would not prevent the

establishment of non-native species. Construction of a berm also would not eliminate the need

for ongoing weed abatement or maintenance.
Volume 3 – Comments and Responses

Master Responses

MID-COAST CORRIDOR TRANSIT PROJECT

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 Comments and Responses
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V3-1 COMMENTS RECEIVED ON THE DRAFT

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Volume 3 – Comments and Responses

Index of Comment Submissions

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 i

INDEX OF COMMENT SUBMISSIONS

PAGE

FEDERAL AGENCIES ...............................................................................................................1

Department of Homeland Security - Federal Emergency Management Agency -

Blackburn, Gregor, Branch Chief – ID002 ........................................................................1

Department of Interior - Port, Patricia S., Regional Environmental Officer - ID326 ...........4

Department of Veteran Affairs - VA San Diego Healthcare System - Gering,

Jeffrey T., Director – ID033 ..............................................................................................7

Environmental Protection Agency - Dunning, Connell, Transportation Team

Supervisor - ID229...........................................................................................................9

Marine Corps Air Station Miramar - Thornton, C.L., Community Plans and Liaison

Officer – ID068 ..............................................................................................................14

STATE AGENCIES...................................................................................................................19

California Coastal Commission - Buhr, Gabriel, Coastal Program Analyst III -

ID260.............................................................................................................................19

California Department of Fish and Wildlife - Sevrens, Gail, Environmental

Program Manager - ID268 .............................................................................................26

California Department of Parks and Recreation San Diego District - Phillips,

Clayton, District Supervisor - ID267 ...............................................................................40

California High Speed Rail Authority - McLoughlin, Mark A., Director - ID194 ................45

California Public Utilities Commission - Gilbert, Daren, Manager - ID228 ......................50

California Transportation Commission - Boutros, Andre – ID069 ...................................62

Caltrans - Johansson, Ken, Route Manager – ID001 .....................................................66

Caltrans - Kosup, Allan, Director I-5 and SR 76 - ID300 ................................................74

Native American Heritage Commission - Singleton, Dave, Program Analyst -

ID344.............................................................................................................................80

University of California, San Diego - Werdick, Brad, Director of Physical and

Community Planning - ID234 .........................................................................................91

LOCAL AGENCIES ................................................................................................................ 103

City of San Diego - Kicklighter, Holly, Planner – ID092 ................................................ 103

City of San Diego - Mahzari, Farah – ID074 ................................................................ 105

City of San Diego - Winterrowd, Cathy, Assistant Deputy Director - ID227 .................. 107

TRIBES................................................................................................................................... 135

Ewiiaapaayp Band of Kumeyaay Indians - Pinto, Robert, Tribal Chairman - ID343...... 135

ELECTED OFFICIALS ........................................................................................................... 141

Lightner, Sherri S. - City Council President Pro Tem - ID295 ....................................... 141
Volume 3 – Comments and Responses

Index of Comment Submissions

MID-COAST CORRIDOR TRANSIT PROJECT

ii September 2014

PAGE

GROUPS / ORGANIZATIONS ................................................................................................ 153

Bay Park Community - Hyytinen, Neil S., Attorney - ID273 .......................................... 153

Clairemont Community Planning Group - Barfield, Jeff, Chair - ID274 ......................... 162

Colony La Paz Condo Association - Kane, Audrey, Association Manager – ID021 ...... 169

Cosoy - Mogilner, Geoffrey, Founder - ID099 .............................................................. 171

Friends of Rose Canyon - DeLano, Everett, Attorney - ID270 ...................................... 182

Friends of Rose Canyon - Knight, Debbie, President – ID071...................................... 257

Friends of Rose Canyon - Knight, Deborah, President - ID085 .................................... 259

Friends of Rose Canyon - Knight, Deborah, President - ID269 .................................... 261

Friends of Rose Canyon - Knight, Deborah, President - ID342 .................................... 287

Friends of Rose Creek - Zirk, Karin, Founder and Executive Director - ID230 ............. 297

Good Samaritan Episcopal Church - Chase, Christopher, Senior Pastor and

Forte, John P., Director - ID340 ................................................................................... 334

La Jolla Colony Community Association - DeFreitas, Sean, Community

Association Manager - ID339 ...................................................................................... 343

Laborers International Union of North America, Local Union 89 - Drury, Richard,

Attorney - ID264 .......................................................................................................... 348

Marian Bear Natural Park Recreation Council - Bear, Deron, Chairman - ID341 ......... 368

Moderate Majority - Kim, Brian, CEO - ID182 .............................................................. 371

Move San Diego - Lowe, Elyse, Executive Director - ID258 ......................................... 373

North County Live Well Leadership - Hamilton, Andy, Air Quality Specialist -

ID272........................................................................................................................... 381

Old Town San Diego Community Planning Group - Coe, Thurston, Chairperson -

ID117........................................................................................................................... 389

One VA - Arends, Stephen, One VA Community Advisory Board - ID179 .................... 414

San Diego County Bicycle Coalition - Hanshaw, Andy - ID257 .................................... 416

San Diego County Building and Construction Trades Council - Purchia, Robyn,

Attorney - ID266 .......................................................................................................... 421

San Diego Public Library - Klockenga, Gary, Govt Publications Librarian - ID189 ....... 446

San Diego River Park Foundation - Hutsel, Rob, Executive Director - ID271 ............... 448

University Community Planning Group - Kruger, Janay, Chairperson - ID265 ............. 464

BUSINESSES ......................................................................................................................... 489

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - Heidelberg, Evelyn -

ID223........................................................................................................................... 489

Armstrong Garden Centers - Asakawa, Eric, South and Bay Area Regional Mgr –

ID004........................................................................................................................... 499
Volume 3 – Comments and Responses

Index of Comment Submissions

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 iii

PAGE

Armstrong Garden Centers - Asakawa Eric, South and Bay Area Regional Mgr -

ID136........................................................................................................................... 501

Armstrong Garden Centers - Butkus, Stephanie – ID034............................................. 505

Armstrong Garden Centers - Jones, Gary, Vice President of Marketing - ID038 .......... 507

Bartell Hotels (Sheraton Hotel) - Dawe, Jim, Attorney - ID232 ..................................... 509

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, Gardens LLC (La

Jolla Canyon) - Schulman, Richard - ID231 ................................................................. 547

Gary Kent Team - Christy, Kyley, Realtor, Broker Associate; Certified Distressed

Property Expert - ID185 ............................................................................................... 679

Harbor Investments Co., LLC - Baker, Cynthia Polak - ID309 ...................................... 681

Harbor Investments Co., LLC - Baker, Cynthia Polak - ID336 ...................................... 684

La Jolla Square Village Square - Blick, C. Samuel, Esquire - ID225 ............................ 688

Morena Business Association - Weber, Kimberly - ID174 ............................................ 706

Regency Centers Costa Verde Center - Chine, Jeffrey, Attorney - ID226 .................... 709

Scripps Health (Scripps Memorial Hospital La Jolla) - Madaffer, Robin, Attorney -

ID261........................................................................................................................... 733

TRU 2005 RE I, LLC (Toys R Us) - Zentmeyer, Don, Attorney - ID233 ........................ 745

UTC Venture, LLC (Westfield) - Maguire, Neal, Attorney - ID224 ................................ 753

INDIVIDUALS ......................................................................................................................... 767

Aguilar, A. - ID003 ....................................................................................................... 767

Allen, Dan - ID337 ....................................................................................................... 770

Anderson-Brustkern, Jason and Traci - ID299 ............................................................. 779

Anonymous - ID025 ..................................................................................................... 783

Anonymous - ID024 ..................................................................................................... 785

Anonymous - ID054 ..................................................................................................... 787

Anonymous - ID151 ..................................................................................................... 789

Anonymous - ID157 ..................................................................................................... 791

Anonymous - ID172 ..................................................................................................... 795

Anonymous - ID173 ..................................................................................................... 797

Anonymous - ID175 ..................................................................................................... 799

Anonymous - ID176 ..................................................................................................... 801

Anonymous - ID202 ..................................................................................................... 805

Anonymous - ID212 ..................................................................................................... 807

Ashby, George - ID245 ................................................................................................ 809

Atz, David - ID165 ....................................................................................................... 811
Volume 3 – Comments and Responses

Index of Comment Submissions

MID-COAST CORRIDOR TRANSIT PROJECT

iv September 2014

PAGE

Bacon, Ronald - ID177 ................................................................................................ 815

Bala, Erin - ID335 ........................................................................................................ 821

Ball, Ian J. - ID259 ....................................................................................................... 830

Baxter, Rilla and Alan - ID305 ..................................................................................... 838

Beeman, Daniel - ID060 .............................................................................................. 840

Beth - ID043 ................................................................................................................ 844

Biendara, Butch - ID108 .............................................................................................. 846

Bordieri, Paul - ID169 .................................................................................................. 849

Brewer, Walt - ID301 ................................................................................................... 866

Brezic, David - ID065 ................................................................................................... 868

Brown, Karen - ID222 .................................................................................................. 870

Brown, Steve - ID306 .................................................................................................. 872

Browne, Dave - ID155 ................................................................................................. 875

Browne, Terri - ID154 .................................................................................................. 877

Buck, Alice - ID044 ...................................................................................................... 879

Burgess, Nicole - ID109 ............................................................................................... 881

Burrascano, Cindy - ID312 .......................................................................................... 883

Calandro, JD - ID005 ................................................................................................... 885

Caldwell, Linda - ID035 ............................................................................................... 887

Caldwell, Linda - ID153 ............................................................................................... 889

Callon, Brandy - ID239 ................................................................................................ 894

Cao, Tan - ID110 ......................................................................................................... 896

Carlin, Christine - ID213 .............................................................................................. 898

Carlin, Christine - ID220 .............................................................................................. 900

Carlin, Stephen - ID313 ............................................................................................... 903

Ceveray, Brian - ID199 ................................................................................................ 907

Chernowsky, Shirley - ID006 ....................................................................................... 909

Christensen, Jon - ID338 ............................................................................................. 911

Clark, Jay A. - ID023 ................................................................................................... 925

Clark, Robert F. - ID056............................................................................................... 927

Cleveland, Mike - ID215 .............................................................................................. 929

Conklin, James and Sylvia - ID256 .............................................................................. 931

Cooke, R. - ID314 ........................................................................................................ 934

Corbin, Sylvia - ID111 .................................................................................................. 937

Corbin, Sylvia - ID112 .................................................................................................. 940
Volume 3 – Comments and Responses

Index of Comment Submissions

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 v

PAGE

Corbin, Sylvia - ID262 .................................................................................................. 942

Cromer, Bruce - ID113 ................................................................................................ 947

Croshier, Mark and Rose - ID334 ................................................................................ 949

Cummings, Kelly - ID158 ............................................................................................. 954

Cummings, Kelly - ID164 ............................................................................................. 960

DeLira, Simone - ID243 ............................................................................................... 964

Deroche, Christina - ID209 .......................................................................................... 966

Dickerson, Dale - ID028............................................................................................... 968

Drummy, Pat - ID095 ................................................................................................... 970

Dube, Pat - ID026 ........................................................................................................ 972

Duffey, Marilyn - ID217 ................................................................................................ 974

Duke, Sara - ID237 ...................................................................................................... 984

Emery, Linda - ID163 ................................................................................................... 986

Enright, Phillip - ID178 ................................................................................................. 990

Enright, Phillip N. - ID235 .......................................................................................... 1008

Falletta, Joe - ID122 .................................................................................................. 1015

Farnsworth, Tiffany - ID221 ....................................................................................... 1017

Ferrero, G. - ID114 .................................................................................................... 1019

Finely, Greg - ID097 .................................................................................................. 1021

Ford, Tom - ID115 ..................................................................................................... 1023

Forster, Stewart - ID142 ............................................................................................ 1025

Fralic, Lynn - ID210 ................................................................................................... 1027

Frodente, Josephine P. - ID244 ................................................................................. 1029

Gallego, Victor - ID252 .............................................................................................. 1034

Garcia, Kristina - ID116 ............................................................................................. 1037

Garcia-Herbst, Arleen - ID007 ................................................................................... 1039

Gates, Kathleen - ID191 ............................................................................................ 1041

Gendelmen, Javi - ID200 ........................................................................................... 1043

Geral, Debbie - ID211 ................................................................................................ 1045

Gerber, Michael - ID166 ............................................................................................ 1047

Gibson, Linda - ID315 ................................................................................................ 1051

Giffen, Connie and Allen – ID045 .............................................................................. 1053

Gille, Sarah - ID036 ................................................................................................... 1055

Glynn, Marysue - ID162 ............................................................................................. 1057

Godwin-Austen, Bill - ID032 ....................................................................................... 1059
Volume 3 – Comments and Responses

Index of Comment Submissions

MID-COAST CORRIDOR TRANSIT PROJECT

vi September 2014

PAGE

Goings, Peggy - ID008 .............................................................................................. 1061

Goodwill, Ken - ID058 ................................................................................................ 1063

Gould, Benjamin - ID037 ........................................................................................... 1065

Greg - ID198.............................................................................................................. 1068

Griggs, Karlyn - ID053 ............................................................................................... 1070

Groth, Walter - ID102 ................................................................................................ 1072

Hall, Lucia KB - ID039 ............................................................................................... 1074

Hall, Miranda K. - ID041 ............................................................................................ 1076

Hamilton, Andy - ID022 ............................................................................................. 1078

Hansen, Chris - ID207 ............................................................................................... 1080

Hartman, Beth - ID107 ............................................................................................... 1082

Hartz, Keith - ID063 ................................................................................................... 1084

Healy, Charlotte - ID240 ............................................................................................ 1086

Hemmerly, Larry and Lynne - ID255 .......................................................................... 1089

Heppell, Janis - ID316 ............................................................................................... 1091

Higgins, Jacqueline - ID009 ....................................................................................... 1093

Hill, F. - ID126 ........................................................................................................... 1095

Hoffhine, Donald - ID127 ........................................................................................... 1097

Hoffman, Gary - ID055 .............................................................................................. 1099

Howard, Erin - ID236 ................................................................................................. 1101

Howell, Patrick - ID152 .............................................................................................. 1103

Hull, Tim - ID018 ....................................................................................................... 1105

Hull, Tim - ID103 ....................................................................................................... 1107

Hurst, David - ID096 .................................................................................................. 1110

Hutton, Pamela - ID046 ............................................................................................. 1114

Innocente, Michael - ID180 ........................................................................................ 1116

Iturzaeta, Lisa - ID121 ............................................................................................... 1118

Iturzaeta, Mark - ID147 .............................................................................................. 1120

Jamason, Paul - ID128 .............................................................................................. 1123

Jan - ID010 ................................................................................................................ 1125

Jenson-Elliott, Cynthia - ID310 .................................................................................. 1127

Johnston, Eamon - ID138 .......................................................................................... 1129

Jones, Scott - ID311 .................................................................................................. 1133

Kanters, Robert - ID186 ............................................................................................. 1136

Kearney, Susan - ID106 ............................................................................................ 1138
Volume 3 – Comments and Responses

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MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 vii

PAGE

Kearney, Susan - ID181 ............................................................................................ 1140

Keenan, David - ID216 .............................................................................................. 1142

Keetley, Reginald G. - ID192 ..................................................................................... 1144

Keeven, Karen - ID029 .............................................................................................. 1146

Kellough, Lenora - ID083 ........................................................................................... 1148

Kellough, Lenora - ID302 ........................................................................................... 1150

Kirkland, Kelly - ID263 ............................................................................................... 1153

Klima, Rob - ID317 .................................................................................................... 1155

Kruger, Janay - ID047 ............................................................................................... 1157

Kruger, Janay - ID254 ............................................................................................... 1160

Kucharski, Jeff - ID139 .............................................................................................. 1163

L - ID061 ................................................................................................................... 1165

Leary, Alex - ID204 .................................................................................................... 1169

Lebowitz, David - ID040 ............................................................................................ 1171

LeCates, Corrine - ID129 ........................................................................................... 1173

Lin, Jonathan - ID027 ................................................................................................ 1175

Link, Jenny - ID205.................................................................................................... 1179

Lockwood, Wallace - ID059 ....................................................................................... 1181

Lopez, Inge - ID011 ................................................................................................... 1183

Loveless, Rebecca - ID143 ........................................................................................ 1185

Loveless, Rebecca - ID156 ........................................................................................ 1187

Lyntock, Brian - ID208 ............................................................................................... 1189

Malone, Barbara - ID318 ........................................................................................... 1191

Manalo, Markov - ID104 ............................................................................................ 1193

Mansell, Paul - ID161 ................................................................................................ 1195

Mathy, Sarah - ID094 ................................................................................................ 1198

McGehee, Jason - ID019 ........................................................................................... 1200

McIlwain, Craig - ID321 ............................................................................................. 1202

McIlwain, Mary - ID328 .............................................................................................. 1204

McIlwain, Virginia - ID327 .......................................................................................... 1206

McLaughlin, Nancy - ID140 ....................................................................................... 1208

McLaughlin, Nancy - ID144 ....................................................................................... 1211

Mertz, June - ID012 ................................................................................................... 1214

Miller, Sally - ID137 ................................................................................................... 1216

Mills, Rodney W. - ID130 ........................................................................................... 1218
Volume 3 – Comments and Responses

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viii September 2014

PAGE

Mogilner, Geoffrey - ID086 ........................................................................................ 1220

Muczynski, Sharon - ID322 ........................................................................................ 1222

Naschak, Bruce - ID048............................................................................................. 1225

Naschak, Bruce - ID253............................................................................................. 1228

Nelson, Sharon - ID201 ............................................................................................. 1231

Nickel, Melanie - ID131 ............................................................................................. 1233

Pallazola, Carol - ID167 ............................................................................................. 1235

Parchia, Robin - ID329 .............................................................................................. 1238

Parrish, Lynn - ID020 ................................................................................................. 1240

Patel, Shila - ID064.................................................................................................... 1242

Patula, Nancy - ID149 ............................................................................................... 1244

Pedusseau, Nadine - ID013 ....................................................................................... 1246

Pho, Nisa - ID125 ...................................................................................................... 1248

Piarulli, Josephine - ID160 ......................................................................................... 1250

Pique, Michael - ID319 .............................................................................................. 1252

Pitzel, Diane - ID132 .................................................................................................. 1254

Post, Nick - ID241...................................................................................................... 1256

Post, Trey - ID242 ..................................................................................................... 1258

Quesenberry, John - ID159 ....................................................................................... 1260

Reers, Elizabeth - ID123............................................................................................ 1262

Reid, Tom and Carol - ID031 ..................................................................................... 1264

Robbins, Lou Ellen - ID049 ........................................................................................ 1266

Roberts, Dave - ID150 ............................................................................................... 1268

Rodriguez, Eric W. - ID298 ........................................................................................ 1270

Rosado, Carolyn - ID141 ........................................................................................... 1272

Roth, Brenda - ID246 ................................................................................................. 1274

Roth, Ed - ID247 ........................................................................................................ 1276

Russakoff, Sharon - ID050 ........................................................................................ 1278

Russel, Michael - ID183............................................................................................. 1280

Rustin, Russell and Lisa - ID333................................................................................ 1282

Sammarco, Gavin - ID323 ......................................................................................... 1288

Sauder, Ellen - ID324 ................................................................................................ 1290

Schindler, Kristine - ID133 ......................................................................................... 1292

Schmidt, Margaret - ID014 ......................................................................................... 1294

Schwartz, Matt - ID331 .............................................................................................. 1296
Volume 3 – Comments and Responses

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MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 ix

PAGE

Shulds, Andrea - ID190 ............................................................................................. 1309

Sinclair, Ken - ID134 .................................................................................................. 1311

Sinclair, Ken - ID148 .................................................................................................. 1313

Sopher, Jan - ID146 .................................................................................................. 1315

Sopher, Jan - ID251 .................................................................................................. 1317

Sopher, Joseph - ID248 ............................................................................................. 1319

Spagarino, Lea - ID105 ............................................................................................. 1321

Spagarino, Lea - ID145 ............................................................................................. 1323

St Gillian, Billy - ID297 ............................................................................................... 1326

Steinbach, Joseph - ID303 ........................................................................................ 1328

Stender, Leah - ID135 ............................................................................................... 1330

Stewart, Kay - ID296 ................................................................................................. 1332

Sullivan, Michael - ID170 ........................................................................................... 1334

Sullivan, Michael - ID304 ........................................................................................... 1338

Syverson, Kort - ID066 .............................................................................................. 1340

Taylor, Sharon - ID307 .............................................................................................. 1342

Terwilliger, Troy and Jeannie - ID118 ........................................................................ 1344

Thomason, Stephen - ID188 ...................................................................................... 1346

Toledo, Alex - ID206 .................................................................................................. 1348

Triglia, Cory - ID168 .................................................................................................. 1350

Varonfakis, Joyce - ID249.......................................................................................... 1353

Varonfakis, James - ID250 ........................................................................................ 1355

Vasquez, Tim - ID193 ................................................................................................ 1357

Voss, Dave - ID051 ................................................................................................... 1359

W., Mark - ID171 ....................................................................................................... 1361

Wainscott, Joanne - ID332 ........................................................................................ 1364

Wasserman, Larry - ID015 ......................................................................................... 1367

Wasserman, Larry - ID084 ......................................................................................... 1369

Watson, Elizabeth - ID042 ......................................................................................... 1371

Watters, Eric - ID308 ................................................................................................. 1373

Wellhouse, Ann - ID325 ............................................................................................. 1377

Wiese, Andy - ID052 .................................................................................................. 1379

Will, Amber - ID238 ................................................................................................... 1382

Wilson, Patricia A. - ID330 ......................................................................................... 1384

Wiszowaty, Walter - ID057 ........................................................................................ 1392
Volume 3 – Comments and Responses

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x September 2014

PAGE

Yates, Susan - ID320 ................................................................................................ 1394

Zakeri, Vahid - ID016 ................................................................................................. 1397

Ziegler, Carole - ID067 .............................................................................................. 1401

PUBLIC HEARING – JUNE 21, 2013 ................................................................................... 1403

La Jolla Square Village Square - Blick, C. Samual, Esquire - ID275 .......................... 1403

United Veterans Council of San Diego County - Harkins, Jack, Chairman - ID276 .... 1406

Friends of Rose Canyon - Knight, Debbie, President - ID277 .................................... 1410

Friends of Rose Canyon - DeLano, Everett, Attorney - ID278 .................................... 1417

Clairemont Community Planning Group - Barfield, Jeff, Chair - ID279 ....................... 1422

Howell, Debra - ID280 ............................................................................................... 1428

Armstrong Garden Centers - Hydoski, Ian - ID281..................................................... 1432

Lightner, Sherri S. City Council President Pro Tem - ID282 ...................................... 1436

Christensen, Jon - ID283 ........................................................................................... 1443

Armstrong Garden Centers - Jones, Gary, Vice President of Marketing - ID284 ........ 1449

Armstrong Garden Centers - Asakawa Eric, South and Bay Area Regional Mgr -

ID285......................................................................................................................... 1453

Armstrong Garden Centers - Bollard, Will, Attorney - ID286 ...................................... 1458

Department of Veteran Affairs - VA San Diego Healthcare System - Butler, Cindy

- ID287 ...................................................................................................................... 1460

Bike San Diego - Cummings, Kelly - ID288................................................................ 1463

Paul, Billy - ID289 ...................................................................................................... 1466

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - Heidelberg, Evelyn -

ID290......................................................................................................................... 1471

Heisman, Charles - ID291 ......................................................................................... 1477

Thompson, Richard - ID292 ....................................................................................... 1479

Enright, Phillip - ID293 ............................................................................................... 1481

Allen, Dan - ID294 ..................................................................................................... 1487
MID-COAST CORRIDOR TRANSIT PROJECT

September 2014

Federal Agencies
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September 2014

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Volume 3 – Comments and Responses

Federal Agencies

Department of Homeland Security - Federal Emergency Management Agency -

Blackburn, Gregor, Branch Chief – ID002

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 1

FEDERAL AGENCIES

Department of Homeland Security - Federal Emergency Management

Agency -

Blackburn, Gregor, Branch Chief – ID002
Volume 3 – Comments and Responses

Federal Agencies

Department of Homeland Security - Federal Emergency Management Agency -

Blackburn, Gregor, Branch Chief – ID002

MID-COAST CORRIDOR TRANSIT PROJECT

2 September 2014
Volume 3 – Comments and Responses

Federal Agencies

Department of Homeland Security - Federal Emergency Management Agency -

Blackburn, Gregor, Branch Chief – ID002

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 3

Submission ID002 US Dept of Homeland Security - Federal Emergency Management

Agency Blackburn Gregor

Com ID Response

1 Chapter 4.0 of the Draft SEIS/SEIR addressed flood-related issues and, as shown in

Table 4-25 in that chapter titled “FEMA Flood Zones and Associated Waters within the

Study Area,” the May 16, 2012 FIRMs were used for the analysis of the water bodies

affected by the project (FIRMs with a May 16, 2013 date could not be located; it is

assumed that the May 16, 2012 FIRMs are being referenced in the comment).

The project will comply with all applicable National Flood Insurance Program

requirements described in Vol. 44 CFR Sections 59-65, as summarized in the

comment, and is within FEMA acceptable standards. This includes preparation and

submittal of a Conditional Letter of Map Revision (CLOMR) for the San Diego River,

Tecolote Creek, and Rose Creek to the City of San Diego for review and processing

through FEMA. The CLOMR will include revised local base flood elevations.

Technical data provided in the Draft Preliminary Location Hydraulic and Floodplain

Studies for the anticipated water surface elevations from bridge crossings are

summarized in Chapter 5.0, Table 5-3 of the Mid-Coast Corridor Transit Project Water

Impact Analysis Technical Report. Upon approval of the CLOMR, the design will

reflect its provisions.

The analysis in the Draft SEIS/SEIR indicated that through compliance with existing

regulations and requirements, the project will not result in any adverse flood-related

impacts.

2 Regulations that provided guidance for the flood-related analysis, including the local

floodplain management requirements, are discussed in Chapter 4.0, Section 4.9.1 of

the Draft SEIS/SEIR and Chapter 2.0 of the Water Impact Analysis Technical Report.

As discussed in Chapter 8.0, Section 8.4.2 of the Draft SEIS/SEIR, coordination with

the City of San Diego Floodplain Manager was initiated in December 2012 and is

ongoing.
Volume 3 – Comments and Responses

Federal Agencies

Department of Interior -

Port, Patricia S., Regional Environmental Officer - ID326

MID-COAST CORRIDOR TRANSIT PROJECT

4 September 2014

Department of Interior -

Port, Patricia S., Regional Environmental Officer - ID326
Volume 3 – Comments and Responses

Federal Agencies

Department of Interior -

Port, Patricia S., Regional Environmental Officer - ID326

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 5
Volume 3 – Comments and Responses

Federal Agencies

Department of Interior -

Port, Patricia S., Regional Environmental Officer - ID326

MID-COAST CORRIDOR TRANSIT PROJECT

6 September 2014

Submission ID326 US Department of Interior, Port, Patricia S.

Com ID Response

1 The Department of Interior's letter with no comments has been noted and will be part of

the record of proceedings for the Draft SEIS/SEIR.
Volume 3 – Comments and Responses

Federal Agencies

Department of Veteran Affairs - VA San Diego Healthcare System -

Gering, Jeffrey T., Director – ID033

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 7

Department of Veteran Affairs - VA San Diego Healthcare System -

Gering, Jeffrey T., Director – ID033
Volume 3 – Comments and Responses

Federal Agencies

Department of Veteran Affairs - VA San Diego Healthcare System -

Gering, Jeffrey T., Director – ID033

MID-COAST CORRIDOR TRANSIT PROJECT

8 September 2014

Submission ID033 US Dept. of Veteran Affairs -

VA San Diego Healthcare System Gering Jeffrey T.

Com ID Response

1 Your comment expressing support for the VA Medical Center Station will be part of the

record of proceedings for the Draft SEIS/SEIR. On November 15, 2013, the SANDAG

Board of Directors approved the Refined Build Alternative, which included the VA

Medical Center Station as part of the project to be evaluated in the Final SEIS/SEIR.

SANDAG will continue to coordinate with representatives of the VA Medical Center as

design progresses and during the construction period.
Volume 3 – Comments and Responses

Federal Agencies

Environmental Protection Agency -

Dunning, Connell, Transportation Team Supervisor - ID229

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 9

Environmental Protection Agency -

Dunning, Connell, Transportation Team Supervisor - ID229
Volume 3 – Comments and Responses

Federal Agencies

Environmental Protection Agency -

Dunning, Connell, Transportation Team Supervisor - ID229

MID-COAST CORRIDOR TRANSIT PROJECT

10 September 2014
Volume 3 – Comments and Responses

Federal Agencies

Environmental Protection Agency -

Dunning, Connell, Transportation Team Supervisor - ID229

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 11
Volume 3 – Comments and Responses

Federal Agencies

Environmental Protection Agency -

Dunning, Connell, Transportation Team Supervisor - ID229

MID-COAST CORRIDOR TRANSIT PROJECT

12 September 2014

Submission ID229 US Environmental Protection Agency Dunning Connell

Com ID Response

1 The comments relating to the project benefits and the resolution of previously

expressed concerns are noted. As stated in Chapter 2.0, Section 2.4.6 of the Final

SEIS/SEIR, construction is anticipated to begin in 2015 with project completion in

spring 2019.

Changes in the project since the initial NEPA and CEQA documents were prepared

are summarized in the Draft SEIS/SEIR (Chapter 2.0, Section 2.1; Chapter 3.0,

Section 3.0; and at the beginning of each section in Chapter 4.0). As noted in the

document, the alternatives analysis considered a variety of modes, as well as

changed conditions in the corridor and input from local agencies regarding the

alignment, station locations, and phasing.

2 The U.S. Environmental Protection Agency's rating of LO, Lack of Objections, has

been noted.

3 SANDAG will continue to coordinate with resource agencies as design and

construction of the project progresses.

4 SANDAG has continued to coordinate with resource agencies and stakeholders after

the close of the Draft SEIS/SEIR comment period. This coordination is documented

in Chapter 8.0, Section 8.8 of the Final SEIS/SEIR.

5 The comment supporting the inclusion of specific BMPs to reduce contaminants and

surface runoff as part of the project design has been noted. These measures are

presented in Chapter 5.0, Section 5.1.2.1 of the Mid-Coast Corridor Transit Project

Water Impacts Technical Report, and they are also summarized in Chapter 4.0,

Section 4.9.3.2 of the Final SEIS/SEIR.

6 Where feasible, SANDAG has minimized surface parking at project stations under the

Refined Build Alternative in the Final SEIS/SEIR. Parking for transit patrons is limited

to five of the nine stations: Tecolote Road, Clairemont Drive, Balboa Avenue, Nobel

Drive, and the UTC Transit Center. Additionally, all but two of the stations with

surface parking (Balboa Avenue Station and portions of the Tecolote Road Station)

will be located on sites with existing paved parking, which minimizes the amount of

new parking that will need to be constructed. The park-and-ride lot at the Balboa

Avenue Station will add approximately 4 acres of impervious surface within already

urbanized right-of-way. The northern portion of the Tecolote Road Station park-andride lot will add approximately 1 acre of impervious surface within already urbanized

right-of-way. The other lots are already paved surfaces.

BMPs listed in Chapter 4.0, Table 4-26 of the Draft SEIR/SEIR will treat any runoff

from impervious surfaces to avoid any adverse impacts to water quality.
Volume 3 – Comments and Responses

Federal Agencies

Environmental Protection Agency -

Dunning, Connell, Transportation Team Supervisor - ID229

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 13

Com ID Response

7 As discussed in Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR under the

heading “Air Quality Impacts”, the project will be required to comply with regional and

state rules and regulations regarding the registration and operation of equipment, as

well as the removal and disposal of asbestos (see SDAPCD Rules 12, 54, and

361.145, as well as CARB’s Off-Road Diesel Vehicle Registration). The project also

will include the following BMPs: minimize idle times of construction equipment;

maintain equipment in good condition; and control construction dust through watering

of earthwork during grading activities (as shown under the heading “Project Measures

to Avoid or Minimize Impacts” within this section). SANDAG will consult with

SDAPCD regarding measures to minimize air pollutant emissions from construction.

8 SANDAG’s commitment to mitigation measures is documented in the Record of

Decision per NEPA (issued as part of this Final SEIS/SEIR) and the agency will adopt

a mitigation monitoring and reporting program when the findings under CEQA are

made.

9 The comment regarding bicycle and pedestrian facilities around station areas has

been noted. Providing facilities to accommodate bicycle and pedestrian access is

important because the number of transit patrons bicycling or walking to and from the

stations is forecast to equal the number of patrons driving to and from the stations.

Where feasible, SANDAG has minimized surface parking at project stations under the

Refined Build Alternative in the Final SEIS/SEIR. Refer to the response to Comment

6 for a description of measures that minimize surface parking at project stations.

SANDAG is committed to working with local and regional agencies (e.g., the City of

San Diego, UCSD, and the U.S. Department of Veterans Affairs) to promote safe and

effective environments for pedestrians and bicyclists at project stations. Master

Response 1 provides additional information regarding pedestrian and bicycle

connections at stations.

10 A CD copy of Volumes 1, 2, and 3 of the Final SEIS/SEIR was sent to the U.S.

Environmental Protection Agency as requested. Additionally, a CD copy of the

Supplemental Environmental Impact Statement/Supplement to the Subsequent

Environmental Impact Report regarding the San Diego fairy shrimp was provided to

the U.S. Environmental Protection Agency as part of the distribution of that

document.
Volume 3 – Comments and Responses

Federal Agencies

Marine Corps Air Station Miramar -

Thornton, C.L., Community Plans and Liaison Officer – ID068

MID-COAST CORRIDOR TRANSIT PROJECT

14 September 2014

Marine Corps Air Station Miramar -

Thornton, C.L., Community Plans and Liaison Officer – ID068
Volume 3 – Comments and Responses

Federal Agencies

Marine Corps Air Station Miramar -

Thornton, C.L., Community Plans and Liaison Officer – ID068

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 15
Volume 3 – Comments and Responses

Federal Agencies

Marine Corps Air Station Miramar -

Thornton, C.L., Community Plans and Liaison Officer – ID068

MID-COAST CORRIDOR TRANSIT PROJECT

16 September 2014
Volume 3 – Comments and Responses

Federal Agencies

Marine Corps Air Station Miramar -

Thornton, C.L., Community Plans and Liaison Officer – ID068

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 17

Submission ID068 Marine Corps Air Station Miramar Thornton C.L.

Com ID Response

1 The name of the military installation has been revised in Chapter 4.0, Section 4.7.2.1

of the Final SEIS/SEIR to "Marine Corps Air Station (MCAS) Miramar."

2 If unexploded ordnance is encountered on the former Camp Matthews Naval Reserve

in the vicinity of the UCSD campus, the field supervisor will contact the Miramar Public

Affairs Office at (858) 577-6000 or Explosive Ordnance Disposal at (858) 577-7699.

Currently there is no formal agreement in place with the Department of Defense and

the project regarding the appropriate disposal of unexploded ordnance. As stated in

Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR, under the heading “Hazardous

Materials,” a site-specific Health and Safety Plan will be prepared to address potential

environmental hazards that may be encountered during construction activity. Once

the contractor is selected, part of the preconstruction activities for the contractor and

SANDAG will be the identification of appropriate procedures in the event of a public

safety emergency, including the discovery of unexploded ordnance.
Volume 3 – Comments and Responses

Federal Agencies

MID-COAST CORRIDOR TRANSIT PROJECT

18 September 2014

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September 2014

 State Agencies
MID-COAST CORRIDOR TRANSIT PROJECT

September 2014

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Volume 3 – Comments and Responses

State Agencies

California Coastal Commission -

Buhr, Gabriel, Coastal Program Analyst III - ID260

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 19

STATE AGENCIES

California Coastal Commission -

Buhr, Gabriel, Coastal Program Analyst III - ID260
Volume 3 – Comments and Responses

State Agencies

California Coastal Commission -

Buhr, Gabriel, Coastal Program Analyst III - ID260

MID-COAST CORRIDOR TRANSIT PROJECT

20 September 2014
Volume 3 – Comments and Responses

State Agencies

California Coastal Commission -

Buhr, Gabriel, Coastal Program Analyst III - ID260

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 21
Volume 3 – Comments and Responses

State Agencies

California Coastal Commission -

Buhr, Gabriel, Coastal Program Analyst III - ID260

MID-COAST CORRIDOR TRANSIT PROJECT

22 September 2014

Submission ID260 California Coastal Commission Buhr Gabriel

Com ID Response

1 The Draft SEIS/SEIR acknowledges the need for a Coastal Development Permit.

SANDAG anticipates subsequent detailed project review by California Coastal

Commission staff as part of the permitting process.

2 The Coastal Zone boundary shown in the Draft SEIS/SEIR is consistent with

information provided by the California Coastal Commission staff in 2006. The

Coastal Zone boundary shown in Chapter 4.0, Figure 4-4 (Maps 1 through 4) and

Figure 4-6 (Maps 1 through 3) of the Mid-Coast Corridor Transit Project Biological

Resources Technical Report has been revised as requested, based on the Coastal

Zone boundary determination provided by California Coastal Commission staff on

May 30, 2014. Additional text revisions have been made in the Final SEIS/SEIR, the

Biological Resources Technical Report, and the Mid-Coast Corridor Transit Project

Land Use Impacts Technical Report where appropriate, to indicate which portions of

the project are within the Coastal Zone and require a Coastal Development Permit

from the California Coastal Commission.

3 The comment that the project will support public coastal access will be part of the

record of proceedings for the Draft SEIS/SEIR.

4 The comment encouraging a summer shuttle service is noted and will be part of the

record of proceedings for the Draft SEIS/SEIR. As shown in Chapter 3.0, Table 3-3

of the Draft SEIS/SEIR, Routes 8, 9, and 27 serve Pacific Beach and Mission Bay.

Additionally, as shown in Chapter 2.0, Table 2-6 of the Draft SEIS/SEIR, these

routes will also serve the Balboa Avenue Station, operating with 15-minute peak

(6:00 to 9:00 a.m. and 3:00 to 6:00 p.m.) and off-peak (9:00 a.m. to 3:00 p.m.) period

headways in 2030 under the Build Alternative. Public access to beach destinations

will be served by planned transit connections to the Balboa Avenue Station. The

provision of additional routes would be under the jurisdiction of MTS, independent of

this project.

5 Although the project will expand the capacity of the transit system by extending the

Trolley Blue Line north to the UTC Transit Center, it has been designed to avoid or

minimize impacts to sensitive coastal resources to the greatest extent feasible. No

impacts to California Coastal Commission defined wetlands were identified in the

Draft SEIS/SEIR. However, the Draft SEIS/SEIR identified impacts to wetlands

between the San Diego River and Balboa Avenue, which, based on the Coastal

Zone boundary determination, would be considered coastal wetlands. The project

impacts to wetlands within the Coastal Zone have been minimized to the extent

feasible, limited to the Tecolote Creek and San Diego River Bridge crossings and 17

ephemeral basins within the existing right-of-way between the San Diego River and

Balboa Avenue that may potentially be coastal wetlands, subject to confirmation by

the California Coastal Commission. Long-term direct impacts from the bridge
Volume 3 – Comments and Responses

State Agencies

California Coastal Commission -

Buhr, Gabriel, Coastal Program Analyst III - ID260

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 23

Com ID Response

columns (San Diego River and Tecolote Creek combined) will result in 0.04 acre of

impacts to wetlands. The structures have been designed to minimize the number of

columns, and within the San Diego River, columns have been placed outside of the

active channel. In both cases, the new bridges will be adjacent to existing bridges

within an existing transportation right-of-way, minimizing the encroachment into

undisturbed areas. Long-term direct impacts from at-grade improvements within the

right-of-way will result in 0.19 acre of impacts to ephemeral basins that may be

coastal wetlands. At-grade improvements have been limited to otherwise disturbed

areas within the existing right-of-way, adjacent to the existing tracks and the I-5

transportation corridor. Short-term construction impacts to wetlands within the rightof-way between the San Diego River and Balboa Avenue total 0.67 acre (see

Chapter 5.0, Table 5-4 of the Mid-Coast Corridor Transit Project Biological

Resources Technical Report). Shading impacts will occur entirely within areas

temporarily impacted during construction and will be mitigated in conjunction with

mitigation for temporary construction impacts (e.g., restoration of temporarily

disturbed areas). This restoration will occur on site and will restore temporarily

disturbed areas to pre-project conditions or better, using appropriate native species

to be identified in a site-specific habitat restoration plan. Restored areas will be

subject to a minimum five-year monitoring requirement to ensure they meet sitespecific success criteria. With the incorporation of mitigation measures described in

Chapter 4.0, Section 4.8.4 and Chapter 4.0, Section 4.17.3.2 under the heading

“Biological Resources Impacts” of the Final SEIS/SEIR, the project will not have any

long- or short-term direct or indirect adverse impacts to sensitive coastal resources.

6 It is anticipated that the new bridge over the San Diego River will be similar to the

existing Trolley Green Line bridge over the San Diego River. Chapter 6.0, Section

6.1.1 of the Biological Resources Technical Report and Chapter 4.0, Section 4.8.3.2

of the Final SEIS/SEIR under the heading “Project Measures to Avoid or Minimize

Impacts” has been revised to include the following measure: Features will be added

to the San Diego River Bridge to make it more “bat friendly.” Several methods may

be used to make the bridge more conducive to bat use as roosting and maternity

colony sites. Potential add-on structures could include add-on panels, add-on

collars, capped-edge drains, wooden-backed signs, and bat houses. The

appropriate add-on structures will be selected based on consultations between a

qualified bat biologist and bridge structural engineers with consideration given to

site-specific conditions, maintenance and inspection accessibility, and safety. A

qualified bat biologist will monitor the add-on structures annually for three years postconstruction to ensure the add-on structures remain intact and to determine if the

add-on structures are being used as bat roosts.
Volume 3 – Comments and Responses

State Agencies

California Coastal Commission -

Buhr, Gabriel, Coastal Program Analyst III - ID260

MID-COAST CORRIDOR TRANSIT PROJECT

24 September 2014

Com ID Response

7 The mitigation measures in the Draft SEIS/SEIR that address impacts to wetlands

include specific sites, such as Mast Park and Rose Canyon, as well as language that

allows flexibility to identify additional mitigation areas in consultation with the resource

agencies during the permitting process. Following the review and comment period for

the Draft SEIS/SEIR, the mitigation available at Mast Park has been applied to other

projects. As stated in Chapter 4.0, Section 4.8.4 of the Draft SEIS/SEIR, "Agency

consultation regarding mitigation, including the identification of off-site mitigation areas,

will continue throughout the permitting process. Additional on- and off-site options may

be identified to satisfy mitigation requirements." Any additional mitigation locations are

subject to review by the USFWS as a part of the Section 7 consultation process and in

accordance with the Biological Opinion; however, SANDAG will continue to investigate

mitigation opportunities in the Rose Canyon area. For those wetland impacts within the

Coastal Zone, SANDAG will continue to work with the California Coastal Commission

staff to identify suitable mitigation sites and appropriate mitigation ratios.

8 As stated in Chapter 4.0, Section 4.8.3.2 of the Draft SEIS/SEIR, landscaping likely

would be incorporated at stations and related facilities that are not near or adjacent

to natural open space areas that would be susceptible to the introduction of invasive

plant species. In addition, as stated in Chapter 4.0, Section 4.4.4 of the Final

SEIS/SEIR, Mitigation Measure VR7 states: “All new plantings, regardless of

location, would not include invasive plants or noxious weeds, but would include

native and/or drought-resistant plants wherever appropriate.” Mitigation for

temporary impacts (e.g., restoration of temporarily disturbed areas) will occur on site

and will restore disturbed areas to pre-project conditions. Mitigation measures for

impacts on biological resources are described in further detail in Chapter 4.0,

Section 4.8.4 of the Final SEIS/SEIR, and require that only native species are used

for restoration of temporary impacts to habitat.

9 Direct and indirect short-term construction impacts (i.e., temporary impacts) are

discussed in Chapter 3.0, Section 3.3.2 of the Biological Resources Technical

Report and Chapter 4.0, Section 4.17.3.2 under the heading “Biological Resources

Impacts” of the Final SEIS/SEIR. As stated in the Biological Resources Technical

Report, “short-term construction activities would impact biological resources until

construction activities have ceased or, in some instances, until vegetation

communities or other affected resources are reestablished or restored.” Within the

context of the Draft and Final SEIS/SEIR, impacts are considered temporary if they

occur within the limits of work at locations where no permanent structures or other

permanent disturbances occur that would preclude restoration.

Mitigation for temporary impacts (e.g., restoration of temporarily disturbed areas) will

occur on site and will restore areas disturbed during construction to pre-project

conditions. According to Mitigation Measure BIO1: “Revegetated areas would be

maintained and monitored for approximately five years to ensure successful

reestablishment of vegetation communities.” In addition, revegetated areas will be
Volume 3 – Comments and Responses

State Agencies

California Coastal Commission -

Buhr, Gabriel, Coastal Program Analyst III - ID260

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 25

Com ID Response

subject to success criteria established as part of the required permits to be issued by the

resource agencies. As part of the Coastal Development Permit, SANDAG

acknowledges that due to the duration of temporary impacts, the California Coastal

Commission may require mitigating temporary impacts within the Coastal Zone at the

same ratio as permanent impacts.

10 Chapter 5.0, Section 5.1.6 of the Mid-Coast Corridor Transit Project Construction

Impacts Technical Report describes general construction methods and equipment

required to complete the five bridges required for the project. A more detailed

description of the San Diego River Bridge and specific construction methods are

discussed in Chapter 5.0, Section 5.1.6.1 of this technical report. Impacts to

biological resources stemming from construction of the bridge are described in

Chapter 5.0, Section 5.7, and avoidance and minimization measures are described

in Chapter 6.0, Section 6.6 of this technical report. Impacts and mitigation are also

described in Chapter 4.0, Section 4.17.3.2 under the heading “Biological Resources

Impacts” of the Final SEIS/SEIR. Impact minimization measures include reducing

impacts to the maximum extent feasible during the final design of the bridge, clearly

delineating the limits of construction, and installation of BMPs. SANDAG will

continue to coordinate with the resource agencies, including the California Coastal

Commission, as project design progresses and the specific construction methods

and approach are further developed.
Volume 3 – Comments and Responses

State Agencies

California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268

MID-COAST CORRIDOR TRANSIT PROJECT

26 September 2014

California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268
Volume 3 – Comments and Responses

State Agencies

California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 27
Volume 3 – Comments and Responses

State Agencies

California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268

MID-COAST CORRIDOR TRANSIT PROJECT

28 September 2014
Volume 3 – Comments and Responses

State Agencies

California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 29
Volume 3 – Comments and Responses

State Agencies

California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268

MID-COAST CORRIDOR TRANSIT PROJECT

30 September 2014
Volume 3 – Comments and Responses

State Agencies

California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 31
Volume 3 – Comments and Responses

State Agencies

California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268

MID-COAST CORRIDOR TRANSIT PROJECT

32 September 2014
Volume 3 – Comments and Responses

State Agencies

California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 33

Submission ID268 California Department of Fish and Wildlife Sevrens Gail

Com ID Response

1 The comment has been noted and will be part of the record of proceedings for the

Draft SEIS/SEIR. SANDAG has been coordinating with the California Department of

Fish and Wildlife, as documented in Chapter 2.0, Section 2.6.5 of the Mid-Coast

Corridor Transit Project Biological Resources Technical Report; coordination will

continue. Chapter 4.0, Section 4.8.1.1 of the Draft SEIS/SEIR described the state

regulations that apply to the proposed project. This section of the SEIS/SEIR has

been revised to include a description of the California Endangered Species Act.

2 The comment notes that the project will use existing bridges to cross the San Diego

River, Tecolote Creek, and Rose Creek. However, as described in Chapter 2.0,

Section 2.2.2.1 of the Draft SEIS/SEIR, the project includes construction of new

bridges across the San Diego River, Tecolote Creek, and Rose Creek.

3 The detailed comments and recommendations referenced in this comment are

addressed in the subsequent responses.

4 As stated in Chapter 4.0, Section 4.8.3.2 of the Draft SEIS/SEIR, the project would

not conflict with the MSCP Plan and would be consistent with the regional

conservation objectives of the MSCP Plan. The project incorporates design

features, management policies, and mitigation measures that are consistent with the

goals and objectives of the applicable subarea plan. However, pursuant to

applicable law governing independent agencies and the Cooperative Agreement for

Project Review Procedures between SANDAG and the City of San Diego (SANDAG

Document #5001195, City Document C-15015, August 17, 2009), the project is not

subject to the discretionary authority of the city and, as such, is not subject to the

MSCP process. Further, to the extent any portion of the project extends into an

MHPA area, the project is a regional public facility anticipated in the MSCP and is a

compatible land use within the subarea plan.

5 The MHPA lands impacted by the project are designated in the Subarea Plan as

occurring within the “Urban Habitat Subarea” within Rose Canyon Open Space Park

and Marian Bear Memorial Park (City of San Diego, 1997). Of the 0.26 acre of longterm impacts to the MHPA, approximately 0.01 acre will occur in areas identified as

HabiTrak gain. These impacts are located at various locations along the right-ofway and are not concentrated in one particular location. As stated in response to

Comment 4, the project is not subject to the MSCP process. SANDAG will provide

suitable data regarding project impacts to the city to allow appropriate

documentation. Please refer to Master Response 16 for a discussion of mitigation

for impacts to habitat within Rose Canyon Open Space Park.

The de minimis determination relates only to the findings under Section 4(f) of the

U.S. Department of Transportation Act of 1966, as amended, which applies to
Volume 3 – Comments and Responses

State Agencies

California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268

MID-COAST CORRIDOR TRANSIT PROJECT

34 September 2014

Com ID Response

transportation projects where federal approval is required prior to the start of

construction (such as the Mid-Coast Corridor Transit Project). Section 4(f) protects

public parklands and recreational lands, wildlife refuges, and historic sites of

national, state, or local significance. The Section 4(f) findings are included in

Chapter 5.0 of the Draft and Final SEIS/SEIR. As stated in Section 5.2 of the Draft

SEIS/SEIR, “for parks, recreation areas, and wildlife and waterfowl refuges, a de

minimis impact occurs when the transportation use of the Section 4(f) resource,

together with any impact avoidance, minimization, and mitigation or enhancement

measures incorporated into the project, does not adversely affect the activities,

features, and attributes that qualify the resource for protection under Section 4(f).”

The de minimis finding is not directly related to impacts to the MHPA, although areas

within the MHPA were considered to serve as wildlife refuges for the purpose of the

Section 4(f) analysis.

Impacts to all resources, including biological resources, are evaluated as part of the

NEPA and CEQA environmental analysis and documentation. Mitigation for

permanent impacts is proposed at ratios consistent with city guidelines. Please refer

to Master Response 16 for a discussion of mitigation for impacts to habitat. As

stated in Chapter 4.0, Section 4.8.4 of the Draft SEIS/SEIR, additional mitigation

may be identified during the resource agency permitting process, which will include

obtaining a Lake or Streambed Alteration Agreement from the CDFW. SANDAG

recognizes that impacts to previous mitigation sites typically require a higher

mitigation ratio. No prior mitigation sites are anticipated to be affected by the

project.

As stated in response to Comment 4, the project is not subject to the MSCP

process.

6 The project is consistent with the UCSD University Center/Sixth College

Neighborhood Planning Study, which is a more detailed element of the UCSD

Master Plan and 2004 Long Range Development Plan. The current alignment and

the UCSD West and UCSD East Station locations are not within or part of the UCSD

conserved open space areas on the campus.

7 As described in Chapter 4.0, Section 4.7.5 of the Biological Resources Technical

Report, Rose Canyon within the study area provides an avenue for local wildlife

movement in a north-south direction between the portion of Rose Canyon to the east

of I-5 and San Clemente Canyon. The technical report shows the connection

provided by Rose Canyon and San Clemente Canyon to undeveloped lands on

MCAS Miramar in Chapter 4.0, Figure 4-7, and acknowledges their function as

regional wildlife corridors in the text. The undeveloped lands on MCAS Miramar

provide the primary connection between these two east-west canyons. The portion

of Rose Canyon within the study area does not connect areas to the east with areas

farther to the west or south. The impacts of the project are located at the western
Volume 3 – Comments and Responses

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MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 35

Com ID Response

limits of the Rose Canyon and San Clemente Canyon wildlife corridors, neither of

which extend across the existing tracks or I-5; therefore, the project will not affect

east-west wildlife movement.

As stated in the comment, the areas adjacent to the railroad corridor are constrained

in many locations as a result of topography and existing development. In addition,

along portions of the alignment adjacent to Rose Canyon Open Space Park, the

project will be within the existing MTS right-of-way and separated from the park by

the two existing LOSSAN tracks. The increased frequency of trains will reduce the

amount of time between trains, particularly during peak hours, which could disrupt

wildlife movement. However, wildlife movement within this location primarily occurs

in a north-south direction parallel to the tracks. Due to the proximity of existing

development along some portions of Rose Creek, and the current operation of

heavy rail trains, it is expected that wildlife have adapted to the existing level of

disturbance, including periodic noise events. Therefore, the increased frequency of

trains will not preclude wildlife movement adjacent to the alignment.

As described in Master Response 14, the additional noise analysis concluded that

the hourly average noise levels will not substantially increase the total hourly

average noise levels during daytime or nighttime hours and will be below 60 dBA

Leq. Although train traffic will increase, the noise associated with the new light rail

vehicles is substantially lower than the noise associated with the existing heavy rail

trains.

Lighting associated with Trolley vehicles will include headlights and indoor lighting.

Headlights on the front of the Trolley will be directed straight toward the tracks, and

all Trolley cars will have tinted windows to screen indoor lighting. Therefore, indirect

impacts from lighting are not expected to alter wildlife use of the area despite the

increase in train traffic.

A path along the east side of the open channel will remain and continue to allow for

wildlife movement along the east side channel below SR 52. Additionally, as stated

in Chapter 4.0, Section 4.8.3.2 of the Final SEIS/SEIR under the heading “Project

Measures to Avoid or Minimize Impacts” the concrete-lined channel below SR 52

and the upstream and downstream riprap areas have been designed to allow a

suitable substrate for terrestrial wildlife movement, as detailed further in response to

Comment 9. Special-status species identified within the vicinity of this portion of the

project include yellow warbler (Dendroica petechia), a CDFW Species of Special

Concern, and coastal California gnatcatcher (Polioptila californica californica),

neither of which rely substantially on movement adjacent to the tracks.
Volume 3 – Comments and Responses

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MID-COAST CORRIDOR TRANSIT PROJECT

36 September 2014

Com ID Response

8 Refer to the response to Comment 7 regarding indirect noise impacts and lighting

impacts. As recommended in the comment, lighting adjacent to natural areas has

been minimized.

Refer to Master Response 17 for the potential to construct an earthen berm. The

impacts to natural resources associated with constructing berms adjacent to the

railroad corridor outweigh the potential benefits.

9 As noted by the commenter, although Rose Creek, including the concrete-lined

channel under SR 52, represents disturbed habitat conditions, the concrete-lined

channel nonetheless allows for tenuous habitat linkage and wildlife movement as

there are no viable north-south connections elsewhere. Chapter 4.0, Sections

4.8.2.2 and 4.8.3.2 of the Final SEIS/SEIR, and Sections 4.7.5, 5.1.2, and 7.1.4 of

the Biological Resources Technical Report have been clarified to indicate such

linkage and wildlife movement.

Regarding the concrete-lined channel under SR 52 and the north-south wildlife

corridor connection, in response to comments, the following design features have

been incorporated into the project to continue to allow wildlife to move through the

area. The concrete-lined channel has been designed with a slight inclination toward

the center of the channel. During dry seasons when the flows will be limited to

irrigation runoff, the outer segments of the channel bottom will carry limited amounts

of runoff and will continue to facilitate wildlife movement. The majority of riprap

placed at the upstream and downstream ends of the proposed channel will not be

grouted, which will allow sediment to fill gaps, creating a more natural and even

surface for wildlife to cross. In addition, a path along the east side of the open

channel will remain and continue to allow for wildlife movement along the east side

channel.

10 Refer to the response to Comment 9 regarding channel design, riprap placement,

grouting, and the existing path. The path (i.e., flat area, as is stated in the comment)

along the east side of the open channel under SR 52 within Caltrans right-of-way will

be retained for maintenance access and will continue to be available for wildlife

movement along the channel. This path will provide the same wildlife movement

function as the bench proposed in the comment.

11 SANDAG will incorporate CDFW’s comments regarding the restoration plan during

the resource agency permitting process. During the permitting process, impacts to

all mature trees will be calculated and mitigated in accordance with CDFW’s

requirements.
Volume 3 – Comments and Responses

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California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 37

Com ID Response

12 SANDAG will coordinate with MTS, NCTD, and the City of San Diego to identify any

concerns or opportunities regarding weed control.

As described in Chapter 4.0, Section 4.8.3.2 of the Draft SEIS/SEIR,

“implementation of the project is not expected to introduce invasive plants into

natural open spaces.” Although station areas will include landscaping, these areas

are not near or adjacent to natural open space areas that are susceptible to the

introduction of invasive plant species. During construction, invasive plant species

could be introduced into adjacent natural open space areas via the transport of

seeds or other plant propagules on construction vehicles and equipment. However,

construction vehicles and equipment would be washed prior to working in areas

where sensitive vegetation communities are present adjacent to the project.

In addition, Chapter 4.0, Section 4.4.4 of the Final SEIS/SEIR (Mitigation Measure

VR7) states: “All new plantings, regardless of location, would not include invasive

plants or noxious weeds, but would include native and/or drought-resistant plants

wherever appropriate.”

13 In response to comments, the following text has been added to Chapter 4.0, Section

4.17.3.2 of the Final SEIS/SEIR and Chapter 6.0, Section 6.2.2 of the Biological

Resources Technical Report to clarify CON4 to CON11, and the mitigation

measures for direct construction impacts:

During construction, a biological monitor would be present to assist in the avoidance

of native vegetation, jurisdictional aquatic resources, special-status plants and

wildlife, and nesting birds. Activities and impacts would be recorded in a daily

monitoring log. Specific biological monitoring and/or mitigation measures for nesting

birds, bats, vegetation communities, and jurisdictional aquatic resources are

described below. In addition to the specific biological monitoring requirements and

mitigation measures outlined below, general biological monitoring would include:

verifying that the contractor has covered all steep-walled trenches or excavations

used during construction at all times except when being actively used. If trenches or

excavations cannot be covered, the monitor would verify that the contractor has

installed exclusionary fencing (e.g., silt fence) around the trenches or excavation

areas, if feasible, to prevent entrapment of wildlife (e.g., reptiles and small

mammals). Open trenches, or other excavations that could entrap wildlife, would be

inspected periodically by the biological monitor. If animals are encountered within

any trenches or excavated areas, they would be removed by the biological monitor,

if possible, or provided with a means of escape (e.g., a ramp or sloped surface) and

allowed to disperse. In addition, the biological monitor would provide training to

construction personnel to increase awareness of the possible presence of wildlife

beneath vehicles and equipment and use best judgment to avoid killing or injuring

wildlife. The biological monitor would be available to assist with moving wildlife, if

necessary.
Volume 3 – Comments and Responses

State Agencies

California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268

MID-COAST CORRIDOR TRANSIT PROJECT

38 September 2014

Com ID Response

14 In response to comments, Mitigation Measure CON8 in Chapter 4.0, Section

4.17.3.2 of the Final SEIS/SEIR and Chapter 6.0, Section 6.2.2 of the Biological

Resources Technical Report was revised as follows:

CON8: Temporary and humane exclusionary devices would be installed in the fall

(September or October) preceding construction at those locations where summer

surveys detected an active maternity roost for the western mastiff bat to avoid

potential direct impacts. Prior to any exclusion measures being implemented

preventing bats from using an existing roost habitat, a qualified bat biologist would

survey (e.g., visually and using an ultrasonic device to record bat calls in concert

with sonogram analysis software) and identify nearby alternative maternity colony

roost sites. If any supplemental measures must be implemented to ensure

successful exclusion of bats from an existing roost and/or the identification of

alternative roosting habitat, all related assessments and monitoring must be

conducted by a qualified bat biologist, with biological monitoring reports and findings

provided to the CDFW.

If construction activities must occur when bats are active and pre-construction surveys

have identified non-breeding bat hibernacula in portions of the Trolley Green Line

Bridge subject to disturbance from bridge modification activities, the individuals would

be safely evicted under the direction of a qualified bat biologist using appropriate means

acceptable to the resource agencies (e.g., installation of one-way doors, foam filling of

roosting locations when bats are not present, or plastic sheeting hung vertically). In

situations requiring one-way doors, a minimum of one week would pass after doors are

installed prior to concluding that the roost had been vacated. During this time,

temperatures should be sufficiently warm for bats to leave the roost because bats do not

typically leave their roost daily during winter months or on unseasonably cold nights in

southern coastal California. In situations where the use of one-way doors is not

necessary in the judgment of the qualified bat biologist, roosts that need to be removed

would first be disturbed at dusk by various means at the direction of the bat biologist to

allow the bats to escape during the darker hours, and access to the roost site would be

excluded the next day (i.e., there would be one night between initial disturbance and

exclusion of the roost site).

Additional project measures were identified that would reduce impacts to bats.

Specifically, features would be added to the San Diego River Bridge to make it more

“bat friendly.” Several methods may be used to make the bridge more conducive to

bat use as roosting and maternity colony sites. Potential add-on structures could

include add-on panels, add-on collars, capped-edge drains, wooden-backed signs,

and bat houses. The appropriate add-on structures would be selected based on

consultations between a qualified bat biologist and bridge structural engineers with

consideration given to site-specific conditions, maintenance and inspection

accessibility, and safety. A qualified bat biologist would monitor the add-on

structures annually for three years post-construction to ensure the add-on structures

remain intact and to determine if the add-on structures are being used as bat roosts.
Volume 3 – Comments and Responses

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California Department of Fish and Wildlife -

Sevrens, Gail, Environmental Program Manager - ID268

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 39

Com ID Response

15 In response to comments, Mitigation Measure CON4 in Chapter 4.0, Section

4.17.3.2 of the Final SEIS/SEIR and Chapter 6.0, Section 6.2.2 of the Biological

Resources Technical Report have been revised to reflect the raptor breeding season

as beginning as early as January 15.
Volume 3 – Comments and Responses

State Agencies

California Department of Parks and Recreation San Diego District -

Phillips, Clayton, District Supervisor - ID267

MID-COAST CORRIDOR TRANSIT PROJECT

40 September 2014

California Department of Parks and Recreation San Diego District -

Phillips, Clayton, District Supervisor - ID267
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California Department of Parks and Recreation San Diego District -

Phillips, Clayton, District Supervisor - ID267

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 41
Volume 3 – Comments and Responses

State Agencies

California Department of Parks and Recreation San Diego District -

Phillips, Clayton, District Supervisor - ID267

MID-COAST CORRIDOR TRANSIT PROJECT

42 September 2014
Volume 3 – Comments and Responses

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California Department of Parks and Recreation San Diego District -

Phillips, Clayton, District Supervisor - ID267

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 43

Submission ID267 California Department of Parks and Recreation San Diego District

Phillips Clayton

Com ID Response

1 The project will not significantly impact the Old Town San Diego Historic Park. The

significant unavoidable air quality, traffic, pedestrian, and parking impacts identified in

the technical analyses conducted for the Draft SEIS/SEIR were not located at or near

the OTTC. Refer to Chapter 3.0, Section 3.4 and Chapter 4.0, Section 4.5 of the

Draft SEIS/SEIR for the results of the impact analyses associated with these issue

areas. As shown in Chapter 3.0, Table 3-28 of the Draft SEIS/SEIR, the project will

reduce total parking demand and spillover at the OTTC compared to existing

conditions and the No-Build Alternative, as some of the parking demand at the OTTC

will be shifted to the nearby new Trolley stations.

Consistent with 36 CFR 800.16, as presented in Chapter 4.0, Section 4.15.1.2 of the

Draft SEIS/SEIR, a project's APE is "the geographic area or areas within which an

undertaking may cause changes in the character or use of historic properties, if any

such properties exist." The project will not physically alter any of the historic

properties or their use. As noted below, the project will use parcels outside of the

historic district. As there will be no physical improvements in the historic district and

the project will neither pass through nor be adjacent to the historic district, the Old

Town San Diego Historic District was not included in the APE. The listed buildings

are outside of the APE for the project.

The project APE is shown on maps provided in Appendix A of the Mid-Coast Corridor

Transit Project Historic Property Survey and Eligibility Determination Report. Sheet 4

of 14 shows the Old Town San Diego Historic District, a NRHP-listed resource, east

of Congress Street outside of the APE.

The project will not directly or indirectly affect any of the historic buildings identified

by the commenter. In the Old Town San Diego area, the project will operate on

existing Trolley tracks at the existing station west of Congress Street, which is

located on parcels outside of the historic district. The district is separated from the

Trolley tracks by a block of buildings and Congress Street. The analysis of potential

vibration impacts (see Chapter 4.0, Section 4.7.3.2 of the Draft SEIS/SEIR) included

consideration of impacts related to the increase in the frequency of Trolley service on

existing tracks, and concluded that no potentially significant vibration effects would

occur. Vibration levels caused by the project will be substantially lower in magnitude

than existing levels generated by heavy-rail operations through the OTTC. Damage

to sensitive structures is directly related to the maximum magnitude of vibration

events; therefore, additional Trolley operations will not increase the potential of

vibration damage to sensitive structures in the Old Town San Diego area.
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44 September 2014

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2 In a letter dated April 9, 2014, the California State Historic Preservation Officer

concurred with the FTA’s determination that the project will result in “no adverse

effect” on historic properties. In the future, should the project change resulting in

effects on the Old Town San Diego Historic District, including a Section 4(f) use of

the property, California State Parks will be included in consultation and coordination.

3 The Final SEIS/SEIR Plan Set, which is Volume 2 of the Final SEIS/SEIR, provides

street improvement plans in the vicinity of the OTTC. The street improvements also

are summarized in Chapter 3.0, Table 3-26 of the Draft SEIS/SEIR (refer to Mitigation

Measure TR8). The improvements include adding turning lanes, realigning a

sidewalk, and extending existing turning lanes at the Taylor Street/Rosecrans Street

and Pacific Highway intersection. The improvements will not require additional rightof-way from the Old Town San Diego State Historic Park or the former Caltrans

building.

California State Parks is included on the mailing list for project information, and

SANDAG is willing to meet with interested agencies regarding the project.

4 The project will reduce parking demand at the OTTC by providing alternative parking

opportunities to the north. While additional parking will not be provided at the OTTC,

the project includes the construction of five additional park-and-ride facilities totaling

1,170 spaces at other locations along the route, including three stations in the vicinity

of the OTTC: Tecolote Road (280 spaces), Clairemont Drive (150 spaces), and

Balboa Avenue (220 spaces). Providing additional parking close to the OTTC will

enable passengers who would have parked at the OTTC to park at the new Trolley

stations, thereby reducing parking demand at the OTTC. As shown in Chapter 3.0,

Table 3-28 of the Draft SEIS/SEIR, future parking demand at the OTTC is projected

to decrease from 753 spaces under the No-Build Alternative to 624 spaces under the

Build Alternative, which represents a 17-percent decrease in parking demand. The

project also will provide a new access option to Old Town San Diego that does not

require driving to the area, particularly for riders traveling from areas north of the

OTTC.
Volume 3 – Comments and Responses

State Agencies

California High Speed Rail Authority -

McLoughlin, Mark A., Director - ID194

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 45

California High Speed Rail Authority -

McLoughlin, Mark A., Director - ID194
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McLoughlin, Mark A., Director - ID194

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46 September 2014
Volume 3 – Comments and Responses

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California High Speed Rail Authority -

McLoughlin, Mark A., Director - ID194

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 47
Volume 3 – Comments and Responses

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McLoughlin, Mark A., Director - ID194

MID-COAST CORRIDOR TRANSIT PROJECT

48 September 2014

Submission ID194 California High Speed Rail Authority McLoughlin Mark A.

Com ID Response

1 SANDAG acknowledges the California High-Speed Rail Authority’s on-going planning

and coordination process, particularly for the future high-speed rail section from Los

Angeles to San Diego (LA–SD). It is SANDAG’s understanding that the LA–SD

section is in the planning stage and is designated as Phase 2 of the HSR program.

Because there is uncertainty regarding the LA–SD alignment, and because no route

has been selected, no detailed analysis of this project in conjunction with the MidCoast Corridor Transit Project is possible at this time. SANDAG is aware that current

planning studies for the HSR show two different alignment scenarios for the LA–SD

section south of Mira Mesa to the proposed terminal station at San Diego International

Airport. One alignment scenario, which travels through Carroll Canyon and under

University City, and then follows the I-5 corridor to the airport, would be located near

the Mid-Coast Corridor Transit Project alignment. The second alignment would travel

along the I-15 corridor to SR 163 and along I-8 and I-5 to the airport. Without an

established alignment for HSR, the plans for the Mid-Coast Corridor Transit Project do

not show an LA–SD section alignment. SANDAG will continue to coordinate with the

Authority as final decisions are reached regarding the Mid-Coast Corridor Transit

Project.

It is also SANDAG’s understanding that the LA–SD section is currently planned for

implementation beyond the year 2030, which is the horizon year for the Mid-Coast

Corridor Transit Project. In contrast, the Mid-Coast Corridor Transit Project is planned

to be completed and in operation by 2019. It is important to recognize that the

analysis in the Draft and Final SEIS/SEIRs is based on SANDAG’s 2030 Regional

Transportation Plan Revenue Constrained Scenario. The timing difference also

presents difficulties for detailed analysis, as the Revenue Constrained Scenario in the

2030 Regional Transportation Plan (which serves as the basis for the 2030 No-Build

and Build Alternative transportation networks for SANDAG) does not include the LA–

SD HSR section.

 2 SANDAG and FTA acknowledge the California High-Speed Rail Authority’s interest in

studying alignment alternatives in the vicinity of the Mid-Coast Corridor Transit

Project. The need for cooperation and coordination among all of the interested

agencies is recognized. As stated in response to Comment 1, plans for the Mid-Coast

Corridor Transit Project do not show a high-speed rail alignment because the highspeed rail alignment for this segment has not yet been determined, and also as the

project is not included in the Revenue Constrained Scenario of SANDAG’s 2030 RTP,

which serves as the background transportation network for the Draft and Final

SEIS/SEIRs.
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Com ID Response

3 As stated in response to Comment 1, the Revenue Constrained Scenario from the

2030 RTP served as the basis for the 2030 No-Build and Build Alternative

transportation networks used for the project's analyses and evaluations. As stated in

Section 2.2.1.1 in Chapter 2.0 of the Draft SEIS/SEIR, the Revenue Constrained

Scenario from the recently adopted 2050 RTP was also reviewed to determine if it

included any additional funded projects planned for implementation in the Mid-Coast

Corridor by 2030 that were not included in the 2030 RTP. This assessment found that

the LA–SD high-speed rail section is shown to be funded in the 2041 to 2050

timeframe, beyond the 2030 planning horizon used in both the Draft and Final

SEIS/SEIRs. As a result, the LA–SD HSR section was not included in the 2030

transportation network for the No-Build or Build Alternative.

4 SANDAG will continue to coordinate with the California High-Speed Rail Authority as

final decisions are reached regarding the Mid-Coast Corridor Transit Project.
Volume 3 – Comments and Responses

State Agencies

California Public Utilities Commission -

Gilbert, Daren, Manager - ID228

MID-COAST CORRIDOR TRANSIT PROJECT

50 September 2014

California Public Utilities Commission -

Gilbert, Daren, Manager - ID228
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California Public Utilities Commission -

Gilbert, Daren, Manager - ID228

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Volume 3 – Comments and Responses

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California Public Utilities Commission -

Gilbert, Daren, Manager - ID228

MID-COAST CORRIDOR TRANSIT PROJECT

52 September 2014
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State Agencies

California Public Utilities Commission -

Gilbert, Daren, Manager - ID228

MID-COAST CORRIDOR TRANSIT PROJECT

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State Agencies

California Public Utilities Commission -

Gilbert, Daren, Manager - ID228

MID-COAST CORRIDOR TRANSIT PROJECT

54 September 2014
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State Agencies

California Public Utilities Commission -

Gilbert, Daren, Manager - ID228

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 55
Volume 3 – Comments and Responses

State Agencies

California Public Utilities Commission -

Gilbert, Daren, Manager - ID228

MID-COAST CORRIDOR TRANSIT PROJECT

56 September 2014
Volume 3 – Comments and Responses

State Agencies

California Public Utilities Commission -

Gilbert, Daren, Manager - ID228

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 57

Submission ID228 California Public Utilities Commission Gilbert Daren

Com ID Response

1 The CPUC’s jurisdiction has been noted. The CPUC’s jurisdiction is identified in

Chapter 2.0, Section 2.2.2 of the Mid-Coast Corridor Transit Project Safety and

Security Impacts Technical Report.

2 SANDAG will develop a Safety and Security Certification Plan during design for

approval by the CPUC.

3 The eight existing grade crossings from Santa Fe Depot to the San Diego River

are not being reconstructed or altered at the crossing by the project and will not

require a CPUC General Order 88-B application. SANDAG will submit a CPUC

Form G “Report of Completed Changes at Rail Crossing” to report completion of

signaling control revisions at each of the eight existing crossings from Santa Fe

Depot to the San Diego River. A formal application will be submitted for new

grade-separated crossings at: Friars Road, Tecolote Road, Clairemont Drive,

Garnet Avenue, State Route 52 interchange ramps, La Jolla Colony Drive, I-5

south of Nobel Drive, Nobel Drive, La Jolla Village Drive and I-5 access ramps,

Gilman Drive east of the VA Medical Center, Artists Lane, Lyman Avenue, two

crossings of Voigt Drive, I-5 alongside Voigt Drive, Campus Point Drive, Genesee

Avenue, Eastgate Mall, Executive Drive, and La Jolla Village Drive. Formal

applications will be submitted for two pedestrian grade crossings: one at the

Executive Drive Station and one at the UTC Transit Center.

4 The project will comply with all applicable federal and state regulations, including

CPUC rules and regulations.

The San Diego Trolley, Inc. (SDTI) Roadway Worker Protection program will apply

to all right-of-way work occurring near the SDTI’s and San Diego subdivision’s

active mainline tracks. SDTI will update its System Safety Program Plan and

System Security Plan prior to revenue service on the project. A Preliminary

Hazards Analysis Report and Threat and Vulnerability Analysis will be performed

as required by CPUC General Order 164-D, as part of the Safety and Security

Certification Plan process during project design.

5 No new at-grade crossings are proposed as part of the project. Refer to the

response to Comment 3 regarding GO-88 at the existing grade crossings. Formal

applications will be submitted for the new grade-separated crossings north of the

Taylor Street grade crossing. As noted in the comment, the project does not

include at-grade crossings along Genesee Avenue.
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58 September 2014

Com ID Response

6 Refer to the response to Comment 3 regarding GO-88. Coordination with the

CPUC began prior to circulation of the Draft SEIS/SEIR. SANDAG will continue to

coordinate with the CPUC regarding the project and the applicable rules and

regulations. Diagnostic meetings with the CPUC will be arranged during project

design to discuss crossing safety issues. All new crossings will be grade

separated.

7 At-grade open ballast stations will have four patron crossings with two crossings,

one at each end of the platform, which will be ADA accessible. At stations with

direct fixation track, the trackway will be surfaced level with the top of rail and ADA

ramps will be located on each end of the platforms. The patron crossings within

stations on the Mid-Coast Corridor Transit Project are consistent with existing

station design on the operating MTS system and in accordance with station design

guidelines.

All approaches to stations will have a clear line of sight.

FTA requires a hazard analysis before the project can begin operation; the hazard

analysis is not required as part of the environmental review of the project.

SANDAG has reviewed the safety record for the existing SDTI stations (see

Chapter 4.0, Section 4.13.2 of the Draft SEIS/SEIR). The accident rate on the

existing Trolley system is approximately one-half of the national average for LRT

systems. For 2010, the National Transit Database shows the nationwide average

accident rate for LRT systems was 16.0 per million revenue service miles,

compared to 8.0 per million revenue service miles for the SDTI system. SDTI has

current operational practices in place at all stations that demonstrate consistent

safe operations through controls established by SDTI rules and procedures that

will be applied to operation of the Mid-Coast extension.

8 Refer to the response to Comment 7 regarding pedestrian crossings at platforms.

At the Executive Drive Station and the UTC Transit Center, automatic flashing

lights and audible warning devices will be provided because the general public will

use the platforms to cross over Genesee Avenue. The San Diego LRT design

standards do not require fencing between the tracks in stations; refer to the

response to Comment 10 for additional information regarding fencing at stations.

9 San Diego Trolley light rail vehicles have horns with sound levels that can be heard

by patrons and pedestrians above ambient station noise. Federal and state

requirements are currently met on the existing system, and the same requirements

will apply to stations along the project alignment. Sound screening as required will

be provided at stations near I-5 (the Nobel Drive and VA Medical Center Stations)

to reduce ambient noise if the levels are above a level that would reduce the

effectiveness of the train horns.
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Gilbert, Daren, Manager - ID228

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September 2014 59

Com ID Response

10 The project will comply with GO 143-B, Section 9.03 (Installation of Curbs, Fences,

and Barriers. Concrete curbs, Fences, or Barriers), which states that such

separation shall be installed along sections of separate right-of-way of an LRT

system when there is a likelihood that motor vehicles or pedestrians may leave the

traveled way of any nearby street or highway and encroach onto mainline track.

GO 143-B does not address fencing between LRT and railroad tracks. The project

is not proposing fencing between the tracks except at the three at-grade stations

adjacent to the LOSSAN commuter and freight railroad tracks (Tecolote Road,

Clairemont Drive, and Balboa Avenue Stations). At these stations, a solid wall will

be built between the LOSSAN tracks and the station platform and fencing will be

extended beyond the stations to deter pedestrians from entering the LOSSAN

railroad right of way.

11 SANDAG and MTS have worked with the City of San Diego to optimize traffic

signal operation at the existing grade crossings to ensure vehicular and pedestrian

safety is not negatively impacted. The changes have been modeled and the

results reviewed with the city for concurrence. The preemption times and phasing

assumed under the project are consistent with current preemption timings. The

traffic signal modifications will be implemented and tested during construction and

system testing. SANDAG will work with CPUC during design to ensure sufficient

track clearance time is provided.

12 SANDAG will work with CPUC during design to ensure that clear direction and

adequate signage are provided.

13 All horizontal and vertical clearances have been designed to comply with GO 26-D

and GO 118-A. Clearances will be further verified during design and again during

construction.

14 The combination of factors listed for existing conditions in this comment were

considered during the preliminary design of the project. The project’s final design

and construction will be in accordance with all applicable federal and state

regulations, including CPUC rules and regulations. As stated in response to

Comment 7, the SDTI operation is safe, with accident rates one-half the national

average. Improvements to grade crossing traffic signal pre-emption on the

segment between Santa Fe Depot and the San Diego River have been optimized

to further improve safety for vehicles and pedestrians, and these improvements will

be implemented with the project. No other modifications to the existing conditions

are proposed at this time.

15 Refer to the response to Comment 14.

16 The comment stating support of the traffic signal improvements and the

optimization of warning device activation times has been noted.
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Gilbert, Daren, Manager - ID228

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60 September 2014

Com ID Response

17 The comment regarding few safety concerns from OTTC to SR 52 has been noted.

18 The grade-separated crossings north of Old Town will follow the CPUC General

Order 88-B process.

19 Refer to the responses to Comments 7 through 9.

20 Coordination with CPUC will occur prior to the start of revenue service.

21 Refer to the response to Comment 10, which states that the project will comply

with GO 143-B, Section 9.03, which requires fencing of the exclusive portion of the

LRT right-of-way. In accordance with GO 143-B, Section 9.03 (Installation of

Curbs, Fences, and Barriers. Concrete curbs, Fences, or Barriers), fencing or

other barriers will separate the tracks from the roadways in this segment.

22 Walls, fences, or other substantial barriers will be provided to separate SDTI

stations from the adjacent LOSSAN railroad tracks on this segment. These

barriers are shown on the Final SEIS/SEIR Plan Set, Sheets 22, 25, 26, 58, 59, 65,

71, 301, 311, and 317.

23 As stated in response to Comment 10, fencing beyond the station platforms will be

provided.

24 LOSSAN projects planned along Segment 2 are being coordinated with the MidCoast Corridor Transit Project. In particular, significant coordination regarding

clearances and lines of sight has occurred and will continue during design.

Clearances will comply with applicable CPUC General Orders.

25 SANDAG will notify the CPUC upon removal of the railroad spur track.

26 The design of the project will meet or exceed the requirements of GO 26-D and will

comply with the application requirements for the crossing of railroad tracks. The

formal application will be developed and submitted to the CPUC during final design

when design clearances have been finalized.

27 Refer to the responses to Comments 7 through 9.

28 Refer to the response to Comment 8. The design at the Executive Drive Station

and the UTC Transit Center contemplates incorporating CPUC Standard No. 8

active warning devices, which would use the directional speaker warning devices

used in the City of Pasadena. Flashing lights would also be used. Pedestrian

counts will be developed during design, and the level of pedestrian treatment will

be coordinated with CPUC.
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Gilbert, Daren, Manager - ID228

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September 2014 61

Com ID Response

29 The formal application will be processed during final design.

30 SANDAG has continued to coordinate with the CPUC after the close of the Draft

SEIS/SEIR comment period and will continue this coordination through design and

construction of the project.
Volume 3 – Comments and Responses

State Agencies

California Transportation Commission -

Boutros, Andre – ID069

MID-COAST CORRIDOR TRANSIT PROJECT

62 September 2014

California Transportation Commission -

Boutros, Andre – ID069
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MID-COAST CORRIDOR TRANSIT PROJECT

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California Transportation Commission -

Boutros, Andre – ID069

MID-COAST CORRIDOR TRANSIT PROJECT

64 September 2014
Volume 3 – Comments and Responses

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California Transportation Commission -

Boutros, Andre – ID069

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 65

Submission ID069 California Transportation Commission Boutros Andre

Com ID Response

1 The statement that the California Transportation Commission has no comments on the

Draft SEIS/SEIR and alternatives has been noted.

2 Chapter 6.0 of the Draft SEIS/SEIR summarizes the project's Financial Plan. The

anticipated local and federal funds are presented in Chapter 6.0, Table 6-4 of the Draft

SEIS/SEIR. Local funds for capital and operating expenses are in place through the

existing, voter-approved half-cent TransNet sales tax. SANDAG intends to seek

commitment for federal funding through the FTA New Starts program once the NEPA

process has been completed.

3 Although SANDAG is not currently seeking state funds for project design, right-of-way,

or construction, SANDAG will notify the State Clearinghouse when the CEQA process

has been completed with issuance of the CEQA Notice of Determination.

4 SANDAG will comply with Commission requirements after completion of the CEQA

process. As identified in Chapter 1.0 of the Final SEIS/SEIR, the Mid-Coast Corridor

Transit Project is identified in SANDAG’s adopted 2050 Regional Transportation Plan:

Our Region, Our Future.
Volume 3 – Comments and Responses

State Agencies

Caltrans -

Johansson, Ken, Route Manager – ID001

MID-COAST CORRIDOR TRANSIT PROJECT

66 September 2014

Caltrans -

Johansson, Ken, Route Manager – ID001
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Caltrans -

Johansson, Ken, Route Manager – ID001

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 67
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Caltrans -

Johansson, Ken, Route Manager – ID001

MID-COAST CORRIDOR TRANSIT PROJECT

68 September 2014
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Caltrans -

Johansson, Ken, Route Manager – ID001

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 69
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State Agencies

Caltrans -

Johansson, Ken, Route Manager – ID001

MID-COAST CORRIDOR TRANSIT PROJECT

70 September 2014
Volume 3 – Comments and Responses

State Agencies

Caltrans -

Johansson, Ken, Route Manager – ID001

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 71

Submission ID001 Caltrans Johansson Ken

Com ID Response

1 Your comment regarding the need for a WQTR or equivalent SWDR document

relating to Caltrans right-of-way has been noted. SANDAG will continue to

coordinate all improvements and potential impacts to current and potential future

Caltrans facilities within the Caltrans right-of-way throughout the entire project

development and construction phases of the project.

A Draft Preliminary SWDR for the project was provided to Caltrans on May 16, 2013,

for review and comment. The SWDR will be updated during final design of the

project, consistent with the standard procedure for SWDR development and will

include updates to the DSA quantity, additional impervious area quantity, preliminary

treatment siting and constraints, and percent treatment versus net new impervious

area.

2 Construction and maintenance of treatment BMPs for the project will occur outside

of the Caltrans right-of-way. Proposed treatment BMPs will not preclude future

treatment opportunities by Caltrans. SANDAG will continue to closely coordinate all

improvements and impacts to current and potential future Caltrans facilities within

the Caltrans right-of-way throughout the entire project development and construction

phases of the project.

Refer to the response to Comment 1 regarding the SWDR.

3 A Draft SWPPP (including temporary water pollution control plans) will be prepared

prior to the start of construction and will be provided to Caltrans prior to the

encroachment permit submittal. A Final SWPPP will be prepared by the contractor

after completion of final design. Plans will be processed through the Caltrans

NPDES unit for review and comment.

4 Your comment providing background information relative to environmental clearance

and permitting related to water quality has been noted and will be part of the record

of proceedings for the Draft SEIS/SEIR. Most of the suggested information can be

found in the technical reports supporting the Draft SEIS/SEIR. As described in

Chapter 2.0 of the Mid-Coast Corridor Transit Project Construction Impacts

Technical Report, the project will comply with the Statewide Storm Water Permit and

Waste Discharge Requirements for Caltrans (Order No. 99-06-DWQ, NPDES No.

CAS000003, as amended by 2012-0011-DWQ); the Construction General Permit

(CWA Section 402, Order No. 2009-009-DWQ, as amended by 2010-0014-DWQ

and by 2012-006-DWQ); and the CWA Section 303(d). Additionally, Chapter 2.0,

Section 2.2.5 of the Mid-Coast Corridor Transit Project Water Impact Analysis

Technical Report discusses project compliance with the State Antidegradation Policy

waste load allocations for TMDLs (40 CFR 130.7). Chapter 4.0, Section 4.17.3.2 of

the Final SEIS/SEIR under the heading "Water Resources Impacts" has been

revised to include the Statewide Storm Water Permit and a reference to Chapter 2.0
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MID-COAST CORRIDOR TRANSIT PROJECT

72 September 2014

Com ID Response

of the Construction Technical Report has been provided to capture all federal, state,

and regional water quality regulations and permits.

5 The amount of DSA and additional impervious areas, along with avoidance,

minimization, and mitigation measures, are disclosed in the Draft SEIS/SEIR in

Chapter 4.0. As described in Section 4.17.3.2 of this chapter under the heading

“Water Resources Impacts,” the total DSA during construction of the Build

Alternative with the VA Medical Center Station Option is estimated to be

approximately 151 acres. Temporary construction site BMPs are identified in

Chapter 4.0, Table 4-35 under the heading "Drainage and Water Quality," which

states that the estimated new net impervious area ranges from approximately 16 to

17 acres for the entire project and options (inclusive of the Caltrans right-of-way).

Proposed BMPs and treatment efficiencies are identified in Chapter 4.0, Table 4-26.

Refer to the response to Comment 1 regarding the SWDR.

6 Chapter 4.0, Section 4.9.3.2 under the heading "Drainage and Water Quality" of the

Draft SEIS/SEIR states that “the estimated new net impervious area ranges from

approximately 16 to 17 acres for the project and options.” Proposed treatment

BMPs are identified in Chapter 4.0, Table 4-26 of the Draft SEIS/SEIR. As stated in

the response to Comment 1, the SWDR will be updated during final design of the

project, and will include updates to the DSA quantity, additional impervious area

quantity, preliminary treatment siting, and constraints. As stated in the response to

Comment 2, construction and maintenance of treatment BMPs will occur outside of

Caltrans right-of-way.

7 The existing and potential beneficial uses for the water bodies within the study area,

including inland surface waters (the San Diego River, Tecolote Creek, Rose Creek,

and Soledad Canyon Creek), coastal waters (the mouth of the San Diego River,

Mission Bay, Los Peñasquitos Lagoon, and the Pacific Ocean), and ground waters

(Mission San Diego Hydraulic Sub-Area, Tecolote HA, Miramar HA, and Miramar

Reservoir HA), are listed in Chapter 4.0, Tables 4-3 through 4-5 of the Water Impact

Analysis Technical Report.

8 Section 303(d) Impaired Water Bodies’ existing constituents of concern and targeted

design constituents are identified in Chapter 4.0, Table 4-9 of the Water Impact

Analysis Technical Report. These were then compared against the anticipated

design constituents identified in Chapter 5.0, Section 5.1.2.1 under the heading

“Summary” of the technical report.
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Caltrans -

Johansson, Ken, Route Manager – ID001

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 73

Com ID Response

9 The project will comply with the active TMDLs listed in the Draft SEIS/SEIR, Chapter

4.0, Section 4.9.2.2. Additional data (including resolution numbers and dates of

adoption) are included in Chapter 4.0, Section 4.5.2 of the Water Impact Analysis

Technical Report.

10 The comment regarding the groundwater extraction and permitting process section

in the Draft SEIS/SEIR has been noted. Chapter 2.0, Section 2.3.1.2 of the

Construction Impacts Technical Report states that the project will comply with the

SDRWQCB General Waste Discharge Requirements for Discharges from

Groundwater Extraction and Similar Discharges to Surface Waters within the San

Diego Region Except for the San Diego Bay (Order No. R9-2008-0002, NPDES No.

CAG919002). Chapter 4.0, Section 4.17.3.2 of the Final SEIS/SEIR under the

heading "Water Resources Impacts" has been revised to include a reference to

Chapter 2.0 of the Construction Technical Report, which addresses all federal, state,

and regional water quality regulations and permits.

11 Chapter 4.0, Section 4.9.5.1 of the Final SEIS/SEIR and Chapter 7.0, Section 7.1.2

of the Water Impact Analysis Technical Report have been revised to state that

contaminants will be minimized to 303(d) listed water bodies (shown in Chapter 4.0,

Table 4-24 of the Draft SEIS/SEIR and Chapter 4.0, Table 4.9 of the technical

report).

12 The comment regarding the CEQA determination in the Draft SEIS/SEIR regarding

water quality has been noted. Chapter 4.0, Section 4.9.5.1 of the Final SEIS/SEIR

and Chapter 7.0, Section 7.1.2 of the Water Impact Analysis Technical Report have

been revised to state that project BMPs will treat and remove contaminants to the

maximum extent practicable.
Volume 3 – Comments and Responses

State Agencies

Caltrans -

Kosup, Allan, Director I-5 and SR 76 - ID300

MID-COAST CORRIDOR TRANSIT PROJECT

74 September 2014

Caltrans -

Kosup, Allan, Director I-5 and SR 76 - ID300
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Kosup, Allan, Director I-5 and SR 76 - ID300

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Caltrans -

Kosup, Allan, Director I-5 and SR 76 - ID300

MID-COAST CORRIDOR TRANSIT PROJECT

76 September 2014
Volume 3 – Comments and Responses

State Agencies

Caltrans -

Kosup, Allan, Director I-5 and SR 76 - ID300

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 77

Submission ID300 Caltrans Kosup Allan

Com ID Response

1 SANDAG will continue its coordination efforts with Caltrans, MTS, NCTD, and the

City of San Diego during design and construction of the project.

2 SANDAG will continue the collaborative effort on this project to help facilitate timely

approval of the JUMA and encroachment permit.

3 To the extent feasible, vegetation clearing will occur outside of the bird breeding

season (February 15 to August 31 for most species, January 15 to August 31 for

raptors). Work limits and the timing of any work within the Caltrans right-of-way will

be coordinated with Caltrans. Agency coordination is described in Chapter 2.0,

Section 2.6 of the Mid-Coast Corridor Transit Project Biological Resources

Technical Report. Areas within the Caltrans right-of-way that will be temporarily

impacted and that contain native habitat will be restored to pre-project conditions.

On-site mitigation is not proposed within the Caltrans right-of-way.

4 Archaeological resources P-37-013710 and CA-SDI-17689H were found to be ineligible

for the NRHP based on research and surveys undertaken by SANDAG working in

cooperation with the FTA (and as documented in the culturally sensitive archaeological

information detailed in the Mid-Coast Corridor Transit Project Archaeological

Resources Survey Report, which was provided to Caltrans archaeologists). SANDAG

has completed archaeological testing for archaeological resources CA-SDI-41, CA-SDI12453, CA-12558, and CA-SDI-12557, and has provided the report documenting the

results to Caltrans archaeologists. Based on the results of this testing, no

archaeological resources eligible for listing in the NRHP were identified or detected

within the project’s archaeological Area of Potential Effects. In a letter dated April 9,

2014, the California State Historic Preservation Officer concurred with the FTA’s

determination that the project will result in “no adverse effect” on historic properties.

5 As discussed in response to Comment 4, SANDAG has completed archaeological

testing and FTA has consulted with the SHPO. No archaeological resources

eligible for listing in the NRHP were identified or detected within the project’s

archaeological Area of Potential Effects during testing. Therefore, no

environmentally sensitive areas have been established as related to archaeological

resources. To account for the possibility of an unanticipated discovery of

archaeological resources or human remains during project-related ground

disturbance, the project includes mitigation that requires construction monitoring of

ground-disturbing activities in native soil by a qualified archaeologist and a Native

American monitor, construction worker training, and appropriate treatment of human

remains. These measures are specified as CON14, CON15, and CON16 in

Chapter 4.0, Section 4.17.3 of the Draft SEIS/SEIR and as CON15, CON16, and

CON17 in Chapter 4.0, Section 4.17.3 of the Final SEIS/SEIR under the heading

“Archaeological Resource Impacts.” In the event of an unanticipated discovery of
Volume 3 – Comments and Responses

State Agencies

Caltrans -

Kosup, Allan, Director I-5 and SR 76 - ID300

MID-COAST CORRIDOR TRANSIT PROJECT

78 September 2014

Com ID Response

buried archaeological resources in Caltrans right-of-way during construction,

environmentally sensitive areas within Caltrans right-of-way will be established in

consultation with the FTA, SHPO, Caltrans, and SANDAG, as appropriate, and will

be protected in accordance with Caltrans requirements.

6 Construction impacts to air quality, along with other construction-related impacts,

are documented in Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR.

Construction will be conducted in full compliance with all applicable regional and

state rules and regulations. In addition, the following best management practices,

as detailed in Chapter 4.0, Section 4.17.3.2 of the Final SEIS/SEIR, will be

implemented: minimize idle times of construction equipment; maintain equipment in

good condition; and control construction dust through watering of earthwork during

grading activities. Regarding storm water pollution control, see the response to

Comment 7.

7 A Draft Preliminary Storm Water Data Report has been prepared for the project and

was provided to Caltrans on May 16, 2013, for review and comment. The report will

be updated during final design of the project, consistent with the standard

procedure for SWDR development.

Additionally, a Draft Storm Water Pollution Prevention Plan will be prepared, as

outlined in Chapter 5.0, Section 5.12.1 of the Mid-Coast Corridor Transit Project

Construction Impacts Technical Report, prior to the start of construction activities.

This document will be provided to Caltrans for review prior to issuance of the

encroachment permit. A Final Storm Water Pollution Prevention Plan will be

prepared by the contractor after the completion of final design and will include

temporary Water Pollution Control Plans, which will be submitted to the Caltrans

NPDES unit for review and comment.

8 SANDAG will continue to coordinate with stakeholders, including Caltrans, as the

project design progresses. Chapter 4.0, Section 4.4.4 of the Final SEIS/SEIR

describes mitigation measures that are intended to reduce the project’s visual

impacts. Mitigation Measure VR1 now states: “The design of structures such as

bridge columns, retaining walls, and sound walls within or adjacent to the Caltrans

right-of-way would be compatible with Caltrans Design Guidelines, including those

prepared for the I-5 North Coast Corridor Project.” Additionally, Mitigation Measure

VR7 states: “All new plantings, regardless of location, would not include invasive

plants or noxious weeds, but would include native plants wherever appropriate.”

VR4 has been modified since the Draft SEIS/SEIR to apply to features adjacent to

the Caltrans right-of-way, and VR7 has been revised to include the use of droughttolerant plants.

Chapter 6.0, Section 6.1.2 and Tables 6-2 and 6-3 of the Mid-Coast Corridor Transit

Project Visual Impacts Technical Report identify vine plantings as a possible wall
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Caltrans -

Kosup, Allan, Director I-5 and SR 76 - ID300

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 79

Com ID Response

treatment for the mitigation of retaining walls; vines can also be used for the ongrade noise walls.

Mitigation Measure VR4 in Chapter 4.0, Section 4.4.4 of the Draft SEIS/SEIR states

that provisions for a plant establishment period will be included in the construction

documents developed during final design of the project. The requirement for the

plant establishment period within Caltrans right-of-way will be specified in these

documents.

9 As stated in Chapter 3.0, Section 3.4.7.3 of the Draft SEIS/SEIR, mitigation

measure TCON1 includes the construction of "a temporary bicycle path adjacent to

the construction site along the Rose Canyon Bicycle Path to maintain access and

connectivity. During any short-term, intermittent closures, such as may be required

for safety and at the time the temporary path is being constructed, provide

informational signs and a detour route along local streets and pathways."

Intermittent closure of the temporary bicycle detour may be required for safety

reasons. During these closures signage and a detour route along local streets and

pathways will be provided. Although there are no plans to provide a shuttle during

intermittent closures estimated to last no more than two weeks, a shuttle could be

provided by SANDAG if closures lasting one month or longer are required, as

stipulated in the Transportation Management Plan.

10 Coordination with Caltrans began prior to circulation of the Draft SEIS/SEIR and will

continue throughout the design and construction phases of the project, including the

scheduling of meetings to further discuss the comments raised in this letter.
Volume 3 – Comments and Responses

State Agencies

Native American Heritage Commission -

Singleton, Dave, Program Analyst - ID344

MID-COAST CORRIDOR TRANSIT PROJECT

80 September 2014

Native American Heritage Commission -

Singleton, Dave, Program Analyst - ID344
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Singleton, Dave, Program Analyst - ID344

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Native American Heritage Commission -

Singleton, Dave, Program Analyst - ID344

MID-COAST CORRIDOR TRANSIT PROJECT

82 September 2014
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Native American Heritage Commission -

Singleton, Dave, Program Analyst - ID344

MID-COAST CORRIDOR TRANSIT PROJECT

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Native American Heritage Commission -

Singleton, Dave, Program Analyst - ID344

MID-COAST CORRIDOR TRANSIT PROJECT

84 September 2014
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Native American Heritage Commission -

Singleton, Dave, Program Analyst - ID344

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 85
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Native American Heritage Commission -

Singleton, Dave, Program Analyst - ID344

MID-COAST CORRIDOR TRANSIT PROJECT

86 September 2014
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Native American Heritage Commission -

Singleton, Dave, Program Analyst - ID344

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 87
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Native American Heritage Commission -

Singleton, Dave, Program Analyst - ID344

MID-COAST CORRIDOR TRANSIT PROJECT

88 September 2014
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Native American Heritage Commission -

Singleton, Dave, Program Analyst - ID344

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 89

Submission ID344 Native American Heritage Commission Singleton Dave

Com ID Response

1 Your comment and the attached letters refer to the potential effects associated with

the Disposal of the Former Caltrans District 11 Building Project, which is a separate

undertaking independent of the Mid-Coast Corridor Transit Project. FTA has no

participation in the Disposal of the Former Caltrans District 11 Building Project.

Although the former Caltrans District 11 Building is located near the Mid-Coast

Corridor Transit Project, it is not located in the project's archaeological Area of

Potential Effects, which is shown in the Mid-Coast Corridor Transit Project

Archaeological Resources Survey Report. Additionally, any ground disturbance

associated with demolition of the former Caltrans complex is not related to activities

proposed for the Mid-Coast Corridor Transit Project.

The Mid-Coast Corridor Transit Project considers applicable laws and regulations, as

documented in the Archaeological Resources Survey Report, including those

specified in this comment.

The project has demonstrated extensive Native American outreach efforts

throughout the project development process, including consultation in compliance

with Section 106 of the National Historic Preservation Act. All tribes identified by the

Native American Heritage Commission were invited to comment on the project

during CEQA and NEPA scoping in April 2010 and August/September 2011,

respectively. As part of Section 106 consultation, the FTA contacted the tribe’s

Ewiiaapaayp Tribal Office Chairperson by letter in November 2011, and again by

telephone and e-mail in December 2011, inviting comment on the project as well as

information on cultural resources and sites of Native American importance in the

project vicinity. Additionally, the NOA, NOC, and Draft SEIS/SEIR were sent to

Native American groups, including the NAHC and Ewiiaapaayp Band of Kumeyaay

Indians in May 2013. Prior to your letter dated August 9, 2013, only the Ipay Nation

of Santa Ysabel had responded directly to FTA and SANDAG regarding the MidCoast Corridor Transit Project as a result of consultation efforts.

A copy of a comment letter dated August 15, 2013, from Robert Pinto, Sr., the Tribal

Chairman of the Ewiiaapaayp Band of Kumeyaay Indians, to the Governor’s office

regarding the Former Caltrans District 11 Building Project, was sent to SANDAG. As

a follow-up to the comment letter, which discusses impacts associated with the

Disposal of the Former Caltrans District 11 Building Project (a project that is

independent of the Mid-Coast Corridor Transit Project), the FTA and SANDAG sent

a letter to Chairman Pinto requesting consultation once more to verify the location of

a recorded Native American burial ground reported to the native American Heritage

Commission in 1990 and to confirm whether it is located within the archaeological

Area of Potential Effects for the Mid-Coast Corridor Transit Project. To date, FTA

and SANDAG have not received any replies from the Ewiiaapaayp Band of

Kumeyaay Indians.
Volume 3 – Comments and Responses

State Agencies

Native American Heritage Commission -

Singleton, Dave, Program Analyst - ID344

MID-COAST CORRIDOR TRANSIT PROJECT

90 September 2014

Com ID Response

Extended Phase I investigations within the project’s archaeological Area of Potential

Effects were conducted in 2013. The purpose of the investigations was to determine

whether archaeological deposits associated with previously documented or reported

archaeological sites are present within the project’s archaeological Area of Potential

Effects. The investigations, which included areas south of the San Diego River,

verified extensive ground disturbance and the absence of archaeological deposits in

the vicinity of the previously recorded archaeological sites within the project’s

archaeological Area of Potential Effects. Based on the results of the investigations,

no archaeological resources eligible for listing in the National Register of Historic

Places were identified or detected within the project’s archaeological Area of

Potential Effects. In a letter dated April 9, 2014, the California State Historic

Preservation Officer concurred with the FTA’s determination that the project will

result in “no adverse effect” on historic properties.

No archaeological resources eligible for listing in the National Register of Historic

Places were identified or detected within the project’s archaeological Area of

Potential Effects during Extended Phase I investigations; however, there exists a low

potential to encounter unknown cultural materials during construction (unanticipated

discoveries). To account for the possibility of an unanticipated discovery of

archaeological resources or human remains during project-related ground

disturbance, the project includes mitigation that requires construction monitoring of

ground-disturbing activities in native soil by a qualified archaeologist and a Native

American monitor, construction worker training, and appropriate treatment of human

remains. These measures are specified as CON14, CON15, and CON16 in Chapter

4.0, Section 4.17.3 of the Draft SEIS/SEIR and as CON15, CON16, and CON17 in

Chapter 4.0, Section 4.17.3 of the Final SEIS/SEIR under the heading

"Archaeological Resource Impacts." These measures are outlined in greater detail in

the Mid-Coast Corridor Transit Project Construction Monitoring Plan and the MidCoast Corridor Transit Project Cultural Resources Discovery Plan, which are

confidential reports.
Volume 3 – Comments and Responses

State Agencies

University of California, San Diego -

Werdick, Brad, Director of Physical and Community Planning - ID234

MID-COAST CORRIDOR TRANSIT PROJECT

September 2014 91

University of California, San Diego -

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Submission ID234 University of California, San Diego Werdick Brad

Com ID Response

1 The comment expressing support of regional transportation will be part of the record

of proceedings for the Draft SEIS/SEIR.

2 On November 15, 2013, the SANDAG Board of Directors approved the Refined Build

Alternative, which included the VA Medical Center Station as part of the project to be

evaluated in the Final SEIS/SEIR.

3 SANDAG’s intent is to coordinate the construction of both projects to minimize the

amount of disruption to the area. However, the I-5 North Coast Corridor Project is

separate from the Mid-Coast Corridor Transit Project, both of which are undergoing

separate environmental review. Both projects require environmental clearance and

funding prior to the start of construction. Actual implementation schedules for these

projects cannot be precisely determined at this time. The Mid-Coast Corridor Transit

Project is designed to accommodate the realigned Campus Point Drive and the

modifications to Voigt Drive. The Mid-Coast Corridor Transit Project Construction

Impacts Technical Report has been revised to include the I-5 North Coast Corridor

Project as part of the cumulative analysis. As stated in Chapter 2.0, Section 2.2.1.1

of the Draft SEIS/SEIR, the No-Build Alternative was evaluated in the context of

facilities and services identified in the Revenue Constrained Scenario of the 2030

RTP, including the implementation of direct access ramps at Voigt Drive, which is part

of the I-5 North Coast Corridor Project. These improvements were also included in

the Build Alternative and therefore were part of the long-term analysis conducted for

the applicable topical areas, including the traffic analysis.

4 Your comment regarding the cooperative working relationship between the campus

and SANDAG has been noted. SANDAG intends to continue coordination throughout

the design and construction of the project.

5 The design of both the UCSD West and UCSD East Stations is being coordinated

with UCSD. The Final SEIS/SEIR Plan Set (Volume 2 of the Final SEIS/SEIR)

includes conceptual designs for these stations; coordination with UCSD will continue

as station designs are finalized.

6 As stated in response to Comment 5, the design of the UCSD West Station is being

coordinated with UCSD. Additional analysis of the potential for impacts on future

development projects as requested by the commenter is not required as the

development plans at this time are speculative because no funding source for the

expansion has been identified to date. It is reasonable to presume future

development in the corridor will be designed in a manner that takes into consideration

public transit facilities, similar to what has occurred at other residential, institutional,

and commercial development near Trolley stations and facilities.
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Com ID Response

7 SANDAG is committed to continuing to work with UCSD and the UCSD Design

Review Board to integrate the station and its design into the campus environment.

8 The noise measurement conducted at Site LT-13, which was 66 dBA Ldn, is

representative of the noise environment experienced at student housing adjacent to

Pepper Canyon in areas where I-5 is the primary noise source. In response to this

comment, additional noise measurements were completed for Clusters 74 through 77.

The Ldn ranged between 51 and 58 dBA at locations farther removed from I-5.

Chapter 4.0, Section 4.7.3 of the Final SEIS/SEIR reflects this revised analysis.

Additional information is provided in Chapter 5.0 of the Mid-Coast Corridor Transit

Project Noise and Vibration Impacts Technical Report. At all four clusters, the project

noise level will not result in a significant impact that would require mitigation.

9 As discussed in response to Comment 8, additional noise analysis was completed to

support the Final SEIS/SEIR. Noise measurements were completed for sensitive

receivers closest to the project alignment. The nearest residential building is located

in Cluster 77, which will be approximately 65 feet from the alignment. The existing

measured Ldn at Cluster 77 is 58 dBA (refer to Chapter 5.0, Table 5-4 of the Noise

and Vibration Impacts Technical Report). This measurement results in an FTA noise

impact criterion of 57 dBA. The project will generate a noise level of 57 dBA Ldn that

will equal but not exceed the criterion for this location, resulting in a less-thansignificant impact. Noise levels at the residence halls on the west side of Pepper

Canyon will not be affected because the distance to the project alignment is greater

than the distance to Cluster 77.

10 Mitigation for the proposed addition to the SME Building is not provided because it is

not an existing or designed facility and no funding source has been identified, and as

such, specific impacts are speculative. In response to this comment, potential

vibration levels at the approximate location of the SME Building expansion were

assessed to assist UCSD with future planning and development. At the nearest

distance, the proposed future SME Building addition would be approximately 15 feet

from the guideway and 30 feet from the nearest guideway column. Future planning

and development of the proposed future addition to the SME Building will need to

consider proximity to the guideway in the building design and layout of uses for the

building. At the nearest corner of the proposed SME addition, peak vibration velocity

levels would be lower than the vibration criteria for instruction and office use (see also

the response to Comment 6).

The mitigation measures suggested in the comment (vibration isolators, structural

dampening, floating slab trackwork) are not appropriate for use on aerial guideway

and are not part of the project.
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11 In response to this comment, and based on the most recent UCSD survey data from

2001 and 2004 (UCSD, 2004 and Leonard, 2004), the Mid-Coast Corridor Transit Project

Biological Resources Technical Report and the Draft SEIS/SEIR have been revised for

the Final SEIS/SEIR to indicate that the canyon north of Warren Field on the UCSD

campus is occupied by the coastal California gnatcatcher. To determine noise impacts to

the coastal California gnatcatcher, additional noise measurements were taken at this

location and anticipated noise impacts were evaluated. Chapter 5.0, Section 5.1.2.2 of

the Biological Resources Technical Report was revised to include this new analysis and

to describe the potential impacts noise may have on the UCSD occupied habitat. In

addition, Chapter 4.0, Figure 4-4, Map 8 of 9 of the Biological Resources Technical

Report was revised to indicate that coastal sage scrub in the canyon is occupied by the

species. Revisions to Chapter 6.0, Section 6.2.3.1 of the Biological Resources Technical

Report now state that project construction in the vicinity of coastal California gnatcatcher

occupied habitat may have adverse indirect impacts on the coastal California gnatcatcher

due to noise if construction occurs during the breeding season (from February 15 through

August 31), and incorporates application of Mitigation Measure CON12 to reduce shortterm indirect impacts at this location.

12 The placement of permanent treatment BMPs and hydromodification facilities in wetland

and biologically sensitive areas will not be required. At the UCSD West Station, BMP

facilities can be located upstream and outside of wetland areas, and at the UCSD East

Station, BMP facilities can be placed within the plaza area of the station.

Chapter 2.0, Section 2.3.1.1 of the Mid-Coast Corridor Transit Project Water Impact

Analysis Technical Report acknowledges that the project will comply with the

applicable UCSD plans developed in compliance with the SDRWQCB Phase II MS4

Permit (Order No. 2003-005-DWQ). SANDAG will continue to coordinate with UCSD

throughout the design and construction phases of the project. The impact of

permanent facilities in wetlands and biologically sensitive areas was described in

Chapter 4.0, Section 4.8.3.2 of the Draft SEIS/SEIR. Construction impacts to

wetlands and biologically sensitive areas were described in Chapter 4.0, Section

4.17.3.2 of the Draft SEIS/SEIR.

13 SANDAG will continue to coordinate with UCSD throughout the design and

construction phases of the project. Storm-water issues are addressed in the detailed

responses to the comments below.

14 BMPs and flow-control devices will be implemented to limit the increase in stormwater flows to Pepper Canyon from new impervious surfaces associated with the

project in accordance with the requirements of the SDRWQCB MS4 Permit. Final

locations and types of BMPs will be determined during final design once geotechnical

data are known (e.g., soil properties, infiltration rates), consistent with the standard

procedure for the development of treatment BMPs. SANDAG will continue to

coordinate with UCSD throughout the design and construction phases of the project.
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15 The UCSD East Station was relocated farther east after the close of the Draft

SEIS/SEIR comment period. The UCSD East Station shown in the Final SEIS/SEIR

Plan Set (specifically Drawing Nos. TA048 and AA701) is located on the paved

parking lot, straddling the future realigned Campus Point Drive. Additionally, the

TPSS at the UCSD East Campus has been relocated to the paved parking lot west of

the ball field, eliminating impacts to the existing 18-inch storm drains (refer to Final

SEIS/SEIR Plan Set Drawing Nos. TA047 and TN013).

The UCSD East Station and TPSS will be located on already impervious surfaces,

thereby eliminating the contribution of additional flows to the existing drainage system

in this area. Water quality and hydromodification facilities will not be required in

wetlands or areas with sensitive habitats. Chapter 2.0, Section 2.3.1.1 of the Water

Impact Analysis Technical Report states that the project will comply with the

applicable UCSD plans developed in compliance with the SDRWQCB Phase II MS4

Permit (Order No. 2003-005-DWQ).

Project-level storm-water impacts and development of treatment BMPs are discussed

in response to Comments 13 and 14, respectively. Final design may include

additional impact areas due to other projects anticipated within the UCSD campus, if

such other projects have environmental clearance. SANDAG will continue to

coordinate with UCSD throughout the design and construction phases of the project

to avoid impacts from water quality and hydromodification facilities to UCSD’s ability

to develop planned future recreational facilities on East Campus.

16 After the close of the Draft SEIS/SEIR comment period, a Safety and Security

Committee was established, and UCSD is participating on this committee.

17 The edits suggested in the comment have been incorporated into Chapter 4.0,

Section 4.13.3.2 of the Final SEIS/SEIR.

18 After the close of the Draft SEIS/SEIR comment period, additional three-dimensional

modeling of Trolley operations was performed and coordination was conducted with

UCSD concerning potential EMF impacts on sensitive research equipment on the

UCSD campus, specifically the existing SME Building. The analysis determined that

with the proposed Trolley power supply mitigation, EMF generated by Trolley

operations will not affect the existing electron microscopes within the existing SME

Building. The mitigation is described in Chapter 4.0, Section 4.14.4 of the Final

SEIS/SEIR. The UCSD allowable threshold of no more than a 1 milligauss shift will

be achievable at distances of 166 feet or more from the closest LRT track with the

proposed mitigation. The location of the existing electron microscopes within the

SME Building is greater than this distance. As stated in response to Comment 10,

mitigation for the proposed addition to the SME Building is not provided because it is

not an existing or designed facility, and as such, specific impacts are speculative.
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19 Refer to the response to Comment 10.

20 Coordination will occur with UCSD and other agencies regarding other construction

projects to minimize overlapping impacts within UCSD. The impacts of other projects

were considered in the construction-related cumulative impact analysis documented

in Chapter 3.0, Section 3.4.7.7 of the Draft SEIS/SEIR for transportation-related

impacts and in Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR under the

heading "Construction Impacts" for environmental impacts. The requirement for

coordination with other projects will be documented in the Transportation

Management Plan for the project. Additionally, the TMP requires public notification

prior to construction activity. Chapter 5.0, Table 5-29 in the Construction Impacts

Technical Report includes a list of known projects with construction schedules that

overlap with the Mid-Coast Corridor Transit Project; the projects listed in the comment

have been added to that table and considered in the report.

21 Coordination with UCSD will occur to minimize the construction-related concerns

noted in the comment. Chapter 3.0, Section 3.4.7 and Chapter 4.0, Section 4.17.3.2

of the Draft SEIS/SEIR discuss construction-related project and mitigation measures.

UCSD will review the Traffic Control Plan for construction activities on the campus.

The project will follow UCSD construction practices where applicable.

22 Mitigation Measure CON1 requires that the contractor prepare and implement a

Construction Noise Control Plan, which demonstrates how the contractor would

reduce noise levels near sensitive noise receptors (see Chapter 4.0, Section 4.17.3.2

of the Final SEIS/SEIR). The Preuss School and the Sixth College student housing

are sensitive noise receptors and will be specifically addressed in the Noise Control

Plan prepared in accordance with Mitigation Measure CON1. This plan will be

provided to UCSD for review prior to the start of construction.

Mitigation Measure CON3 will apply to the SME Building and the Sixth College

housing.

23 FTA and SANDAG determined that the “park” is not a property protected by Section

4(f). Chapter 5.0, Table 5-5 of the Final SEIS/SEIR has been clarified to note that

although the university is publicly owned, it is not accessible by the general public.

The park was removed from Chapter 5.0, Table 5-4 of the Final SEIS/SEIR.
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Com ID Response

1 A digital copy of the Mid-Coast Corridor Transit Project Biological Resources

Technical Report can be found at: http://www.sandag.org/uploads/midcoast/tr02a.pdf. This link was provided via e-mail to the commenter on June 28, 2013, as

requested.
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Com ID Response

1 A digital copy of the Mid-Coast Corridor Transit Project Transportation Impacts and

Mitigation Report was provided to Farah Mahzari in June 2013.
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Submission ID227 City of San Diego Winterrowd Cathy

Com ID Response

1 The issues raised in the submission letter are addressed in the subsequent detailed

responses.

2 SANDAG has continued to coordinate with the city and other agencies since

circulation of the Draft SEIS/SEIR. This coordination is documented in Chapter 8.0,

Section 8.8.2 of the Final SEIS/SEIR and will continue through the final design and

construction phases of the project.

3 The commenter is correct that the project will impact Environmentally Sensitive

Lands, as defined by the City's Land Development Code (the city defines wetlands

more broadly than other jurisdictional agencies). Impacts to wetlands as defined by

the city’s Land Development Code are discussed in Chapter 5.0, Section 5.3.2.1 and

Chapter 7.0, Section 7.2.2 of the Mid-Coast Corridor Transit Project Biological

Resources Technical Report. However, a Site Development Permit is not required

because the Mid-Coast Corridor Transit Project is exempt from local permitting

requirements in accordance with state law and the Cooperative Agreement between

SANDAG and the City of San Diego dated August 17, 2009.

4 The purpose of the Draft SEIS/SEIR is set forth in the Executive Summary (Section

S.0). Each topic area of the Draft SEIS/SEIR includes an overview of the legal and

regulatory authority for the subject area. An Intended Use section has been added

to the Final SEIS/SEIR (Executive Summary, Section S.8) in response to this

comment.

5 As the lead agency under CEQA, SANDAG has independent authority to develop

thresholds of significance for the project. The CEQA thresholds and determinations

are presented in Chapters 3.0 and 4.0 of the SEIS/SEIR and in the technical reports

prepared in support of the SEIS/SEIR; these sections include a discussion of the

significance criteria and application. The adopted City of San Diego Significance

Thresholds and Appendix G played an important role in the development of

thresholds of significance for the project. In some instances, the city and project

thresholds are the same. In other cases, the thresholds have been modified to

better fit the unique attributes of a transit project, such as the Mid-Coast Corridor

Transit Project.

Refer to the response to Comment 3 regarding city permits for the project.
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6 The CEQA noise criteria adopted by SANDAG are detailed in Chapter 4.0, Section

4.7.5.1 of the Draft SEIS/SEIR. The criteria include evaluation of compatibility to the

city’s Noise Land Use Compatibility Chart. As explained in Chapter 4.0, Section

4.7.5.1, the project will have a less-than-significant impact relative to the city’s

criteria.

Table NE-3 in subsection A of the Noise Element of the city’s General Plan applies

to proposed development; subsection C applies to Trolley and train noise. Policies

of subsection C applicable to the Mid-Coast Corridor Transit Project include the

following:

· NE-C.1 Use planning to help minimize exposure of noise-sensitive use to rail

corridor and Trolley line noise

· NE-C.2 Work with SANDAG, Caltrans, MTS, California High-Speed Rail

Authority, and passenger and freight operators to install noise attenuation

features to minimize impacts to adjacent residential or other noise-sensitive

uses

The project is consistent with these policies. The use of sound walls, as shown in

Chapter 4.0, Table 4-14 of the Final SEIS/SEIR, will minimize impacts to residential

and other noise-sensitive users and supports both applicable policies.

7 As noted by the commenter, the 2011 City of San Diego CEQA Significance

Thresholds do not address GHG, and the interim City Guidelines were not formally

adopted when the Draft SEIS/SEIR was prepared. As a result, SANDAG used

Appendix G of the CEQA Guidelines to develop significance thresholds for GHG

impacts, and the guidance found in Section 15064.4 of the CEQA Guidelines to

determine their significance. The GHG analysis quantified the projected GHG

impacts of the project, including projected emissions from Trolley facilities and

reduced emissions resulting from a reduction in regional vehicle miles traveled.

Specifically, as shown in Chapter 5.0, Table 5-6 of the Mid-Coast Corridor Transit

Project Air Quality Impacts Technical Report, the project is predicted to reduce

regional GHG emissions in the year 2030 by approximately 88,700 metric tons, or

243 metric tons per day, compared to the No-Build Alternative. As the lead agency,

SANDAG has independent authority to develop GHG thresholds and determine the

appropriate methodology to determine significance (CEQA Guidelines, Section

15064.4).

8 The archaeological testing within the Area of Potential Effects (APE) for the project

has been completed by SANDAG working in cooperation with the FTA (documented

in the Mid-Coast Corridor Transit Project Archaeological Resources Extended Phase

I Investigation Report and Effects Assessment). No resources associated with the

previously recorded sites were found within the project APE. Based on the results of

this testing, FTA has determined that there are no NRHP-eligible archaeological
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resources detected within the APE, as documented in Chapter 4.0, Section 4.15.2.2

of the Final SEIS/SEIR.

9 It is estimated that the Tecolote Road Station (located east of I-5 and south of Sea

World Drive) is 1,200 feet from the landfill at its closest distance. Therefore, the

project is outside of the 1,000-foot zone mentioned in the comment, and no further

approval is required by the Solid Waste Local Enforcement Agency. The

approximate limits of the 120-acre Mission Bay landfill area, located within the

“South Shores” area of Mission Park, are SeaWorld’s east parking lot on the west,

the San Diego River on the south, I-5 on the east, and the boat launching ramp on

the north (City of San Diego Manager’s Report No. 03-123;

http://docs.sandiego.gov/reportstocouncil/2003/03-123.pdf). SANDAG will continue

to coordinate with the City of San Diego as site plans for the Tecolote Road Station

are developed and finalized.

10 As discussed in Chapter 8.0, Sections 8.4.2 and 8.8.2 of the Final SEIS/SEIR,

SANDAG has closely coordinated with city staff (including the City’s Floodplain

Manager, Development Services Department, Transportation and Storm Water

Department, Park and Recreation Department, and Real Estate Assets Department)

regarding all improvements and potential impacts to current and potential future City

of San Diego facilities within the city’s right-of-way. SANDAG will continue such

coordination throughout the entire development and construction phases of the

project. Review of site-specific preliminary design drawings for project structures

and features, as well as hydraulic and hydrology analysis documenting downstream

flows or obstruction of flows, is generally performed during final design of a project.

Because the project will comply with regulatory standards for water quality during

planning, design, and construction activities, as described in Chapter 4.0, Section

4.9.1.1 of the Draft SEIS/SEIR, and Chapter 2.0, Section 2.3.1.1 of the Mid-Coast

Corridor Transit Project Water Impact Analysis Technical Report, anticipated

increases in flows will not cause adverse impacts to downstream facilities. As noted

in Chapter 2.0, Sections 2.3.1.1 and 2.4 of the Water Impact Analysis Technical

Report, for areas within the City of San Diego right-of-way, the project will comply

with all applicable City of San Diego plans developed in compliance with the

SDRWQCB MS4 permit, including the City of San Diego’s Storm Water Standards

Manual (2011), San Diego River Watershed Urban Runoff Management Plan (2008),

Mission Bay and La Jolla Watershed Urban Runoff Management Plan (2008), Flood

Mitigation Plan (2007), General Plan (2008), and Municipal Codes.
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11 Additional language has been added to Chapter 4.0, Section 4.9.5.1 of the Final

SEIS/SEIR and Chapter 7.0, Section 7.1.2 of the Water Impact Analysis Technical

Report to expand dam failure and proactive preventative measures identified in the

San Diego County Multi-Jurisdictional Hazard Mitigation Plan (2010), as well as to

address all aspects of flooding.

As noted in Chapter 2.0, Section 2.3.1.1 of the Water Impact Analysis Technical

Report, the project will comply with all applicable City of San Diego plans developed

in compliance with the SDRWQCB MS4 permit. Chapter 2.0, Section 2.3.1.1 and

Chapter 8.0 of the Water Impact Analysis Technical Report have been updated to

include the adopted permit (SDRWQCB MS4 Permit—Order No. R9-2013-0001,

NPDES No. CAS0109266, adopted May 8, 2013 and effective June 27, 2013).

SANDAG will continue to coordinate with the City of San Diego and the resource

agencies as design and construction of the project progresses and will employ the

most current, applicable measures as they are put into place.

12 The project will include fencing, natural barriers, and/or signs to preclude

encroachments into the construction area. Any person or persons camped within the

construction area would be notified to vacate and, if needed, removed. Persons

requiring temporary shelter and/or social services would be directed to the City of

San Diego Homeless Administrator regarding the city’s Homeless Services program.

SANDAG will coordinate with the city prior to construction to advise them of the need

for temporary shelter and services for homeless individuals within the project

construction zone. Such services may be provided by the City of San Diego or an

affiliate agency.

13 The Draft SEIS/SEIR conducted an analysis of traffic based on conditions in 2010,

which did not assume the implementation of transportation network improvements

that could affect the level of service of city streets and intersections, and a long-term

2030 analysis, which did assume implementation of two transportation network

improvements consistent with adopted plans. The traffic, bicycle, and pedestrian

circulation analyses for years 2010 and 2030 identify impacts that are equivalent to,

or greater than, what will occur in the opening year of the project, which is assumed

to be 2019. Because the transportation network improvements on opening day are

not materially different than the 2030 conditions, additional analysis of traffic on

opening day is not necessary. Further, opening day traffic volumes will be equal to

or less than 2030 volumes, and fewer Trolleys will be running on opening day than

are projected for 2030. As such, the 2030 analysis represents worst-case conditions

and encompasses any opening day impacts.

Inclusion of the I-5 HOV and I-805 managed lanes in the 2030 analysis did not cause

traffic volumes to be underestimated. The 2030 analysis assumes implementation of

I-5 HOV lanes and I-805 managed lanes that are not scheduled to be in place by

2019. However, the general impact of these improvements would be to increase the
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volume of traffic on arterial streets, such as Nobel Drive, that will provide access to

the HOV and managed lanes, as more drivers use these arterial streets to access

the freeways. Thus, the 2030 analysis generally assumes traffic volumes on these

arterial streets that are greater than what would occur without the assumed I-5 HOV

lanes and I-805 managed lanes improvements.

The 2030 traffic analysis also assumed two roadway changes in the corridor that are

anticipated to be in place by opening day and will increase roadway capacity (and

therefore improve traffic conditions): 1) the addition of a dedicated right-turn lane on

the west leg of the Sassafras Street and Pacific Highway intersection, which,

according to the Airport Master Plan, will be implemented by 2015 and thus will be

included in an opening year (2019) analysis both with and without the project, and 2)

modifying Regents Road to a four-lane facility near Genesee Avenue, which, based

on the current construction schedule, will be four lanes by the time the Mid-Coast

Corridor Transit Project begins construction on Genesee Avenue and therefore will

also be incorporated in an opening year analysis with or without the project.

The methodology used for the bicycle and pedestrian impact analysis included an

assessment of existing conditions using data gathered during field observations and

review of geographic information system files for existing and planned bicycle

facilities. The bicycle and pedestrian network is not anticipated to be materially

different in 2019, and the future (2030) analysis considered impacts to all future

bicycle and pedestrian facilities. As such, an opening day analysis is not necessary.

14 All of the transportation mitigation measures shown in Chapter 3.0, Table 3-26 of the

Draft SEIS/SEIR will be in place prior to opening day of the project. The text in

Chapter 3.0, Section 3.4.2.3 of the Draft SEIS/SEIR has been revised to state that

these measures will be implemented prior to opening day (refer to Chapter 3.0,

Section 3.4.2.3 of the Final SEIS/SEIR).

15 The project has been designed to minimize construction impacts to the extent

feasible. The roadway and lane closures shown in Chapter 3.0, Table 3-33 of the

Final SEIS/SEIR provide a reasonable estimate of the durations required to construct

the project, as summarized below. The Final SEIS/SEIR Plan Set (contained in

Volume 2) provides additional detail regarding the project features located within

each roadway. SANDAG will continue to make minimization of traffic disruptions a

priority as project design proceeds and as the Transportation Management Plan

(TMP) is developed.

Since the close of the Draft SEIS/SEIR comment period, the locations of construction

staging areas were revised, which changed some haul routes identified in the Draft

SEIS/SEIR. La Jolla Colony Drive and Charmant Drive will no longer be required as

truck haul routes, eliminating this potential impact. Refer to Chapter 5.0, Figure 5-26

of the Mid-Coast Corridor Transit Project Construction Impacts Technical Report for
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the revised haul route map. Refer to Chapter 2.0, Section 2.3.6 of the Final

SEIS/SEIR for a summary of refinements to construction staging areas.

The Morena Boulevard and Balboa Avenue ramps will be reconstructed as part of

the project. Intermittent closure of the ramps at nights and on weekends will be

required during reconstruction over the course of approximately 12 months. Detour

routes will be provided during closure of the ramp that will minimize the use of

residential streets and out-of-direction travel to the extent feasible. The potential

detour routes are summarized in Chapter 5.0, Section 5.6.2.3 of the Construction

Impacts Technical Report; the final detour routes will be evaluated in consultation

with the city when the TMP is finalized. As stated in Chapter 3.0, Section 3.4.7.2 of

the Draft SEIS/SEIR, a TMP will include a public awareness campaign, which will

inform the public about road closures and detours.

As stated in Chapter 3.0, Section 3.4.7.2 of the Draft SEIS/SEIR, a TMP will be

prepared as a project measure to minimize construction-related impacts on traffic,

transit, bicycles, pedestrians, and parking. The TMP will also include information on

haul routes. The TMP will be developed prior to the start of construction of the

project and will be prepared in consultation with the City of San Diego and other

agencies.

16 The Draft SEIS/SEIR and the Mid-Coast Corridor Transit Project Transportation

Impacts and Mitigation Report detail the mitigation measures to reduce direct and

cumulative impacts that were considered and found to be infeasible for Balboa

Avenue between the I-5 southbound on-ramp and the I-5 northbound off-ramp,

Mission Bay Drive and Garnet Avenue, and Beech Street and Pacific Highway.

These measures are described in Chapter 6.0, Section 6.1.2.1 of the Transportation

Impacts and Mitigation Report and summarized in Chapter 3.0, Section 3.4.2.3 of the

Draft SEIS/SEIR. Master Response 8 also provides information for the unmitigated

traffic impacts at Balboa Avenue between the I-5 southbound on-ramp and the I-5

northbound off-ramp and Mission Bay Drive and Garnet Avenue.

17 SANDAG will continue to coordinate with the City of San Diego during design and

construction of the project. Traffic control plans will be developed and will be

reviewed by the city prior to the start of construction. Chapter 4.0, Table 4-37 of the

Draft SEIS/SEIR shows the applicable project-related permits and agreements with

which the project will comply, including the traffic control permit from the City of San

Diego referenced in this comment.
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18 Chapter 4.0, Section 4.1.1 of the Draft SEIS/SEIR included a bulleted list of state,

regional, and local plans and policies that were reviewed for the land use analysis.

The City of San Diego Multiple Species Conservation Program Subarea Plan is

shown toward the end of the bulleted list. A reference to the Mid-Coast Corridor

Transit Project Land Use Impacts Technical Report is provided, which includes

additional information on this plan. Therefore, a change to this section for the Final

SEIS/SEIR is not required.

19 Chapter 4.0, Table 4-37 of the Final SEIS/SEIR shows the applicable project-related

permits and agreements with which the project will comply. Pursuant to applicable

state law governing independent agencies and the Cooperative Agreement for

Project Review Procedures between SANDAG and the City of San Diego (SANDAG

Document #5001195, City Document C-15015, August 17, 2009), the project is not

subject to the discretionary authority of the city and, as such, is not subject to the

permits and boundary line adjustments referenced in the comment. SANDAG will

provide relevant data to the City of San Diego regarding the areas of impact suitable

for use in tracking the conservation status of MHPA lands.

20 In response to this comment, the terms "likely" and "may" have been revised, where

appropriate, when discussing wildlife corridors in the Biological Resources Technical

Report and the Final SEIS/SEIR. These terms were used to indicate that the project

is located within a wildlife corridor that is constrained by surrounding development

and land uses.

21 The project incorporates design features, management policies, and mitigation

measures that are consistent with the goals and objectives of the City of San Diego

MSCP subarea plan, as implemented in the city’s Biology Guidelines. However,

pursuant to applicable law governing independent agencies and the Cooperative

Agreement for Project Review Procedures between SANDAG and the City of San

Diego (SANDAG Document #5001195, City Document C-15015, August 17, 2009),

the project is not subject to the discretionary authority of the city. As such, the

project is not subject to the MSCP process and a Site Development Permit and

MHPA Boundary Line Adjustment are not required. Further, to the extent any portion

of the project extends into an MHPA area, the project is a regional public facility

anticipated in the MSCP and is a compatible land use within the subarea plan.

CITY OF SAN DIEGO BIOLOGY GUIDELINES COMPLIANCE

The biological analysis in the Biological Resources Technical Report relied on the

guidance of the city’s Biology Guidelines. Biological surveys for the project were

initiated in April 2009 and relied on the guidance of the City of San Diego 2004

Biology Guidelines, the most current version of the guidelines available at the time.

The city’s 2012 Biology Guidelines have since been reviewed, however, and the

biological analysis in the Draft SEIS/SEIR and Biological Resources Technical

Report was found to be consistent with the city’s updated guidelines. References in
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the Final SEIS/SEIR and Biological Resources Technical Report have been updated

to cite the 2012 Biology Guidelines.

The vegetation classification system referenced by the commenter as modified

Holland/Oberbauer is in fact the same reference cited in the Biological Resources

Technical Report and Draft SEIS/SEIR. Although the format of the short citation

used in the city’s Biology Guidelines and the Draft SEIS/SEIR and Biological

Resources Technical Report differ, the Draft SEIS/SEIR and Biological Resources

Technical Report used the modified Holland/Oberbauer vegetation classification

system. The full citation for the reference used in the Biological Resources

Technical Report and Draft SEIS/SEIR is:

Oberbauer, T., M. Kelly, and J. Buegge. 2008. Draft Vegetation

Communities of San Diego County. Based on “Preliminary Descriptions of

the Terrestrial Natural Communities of California.” Robert F. Holland, Ph.D.

(October 1986). March 2008.

The Biological Resources Technical Report and the Final SEIS/SEIR have been

revised throughout to remove wetlands from the Tier I category and to change

terminology in the text and tables accordingly.

Mitigation ratios proposed for the project are based on SANDAG standards and are

subject to final approval with the resource agencies during the permitting process.

Disturbed habitat is the classification used in Oberbauer et al. 2008 and, therefore, is

the term used to describe the mapped vegetation communities.

Direct and indirect impacts are clearly defined. Chapter 3.0, Section 3.3 of the Biological

Resources Technical Report and Chapter 4.0, Sections 4.8.3.2 and 4.17.3.2 of the Final

SEIS/SEIR, provide a clear definition of both long- and short-term direct impacts, as well

as long- and short-term indirect impacts. Long-term direct impacts are considered

permanent impacts and are mitigated in accordance with the mitigation ratios presented

in Chapter 6.0, Tables 6-1 through 6-3 and as described in Section 6.1 of the Biological

Resources Technical Report. Mitigation is also discussed in Chapter 4.0, Section 4.8.4

(Tables 4-19 through 4-21) of the Final SEIS/SEIR. Mitigation for long-term indirect

impacts from shading and short-term direct impacts are also captured in Chapter 6.0,

Tables 6-1 through 6-3 and Sections 6.1 and 6.2 of the Biological Resources Technical

Report and Chapter 4.0, Tables 4-16 through 4-18, and Section 4.8.3.2 of the Final

SEIS/SEIR. Mitigation for short-term indirect impacts is discussed in Chapter 6.0,

Section 6.2.3 of the Biological Resources Technical Report and Chapter 4.0, Section

4.17.3.2 of the Final SEIS/SEIR.

Revegetation of wetlands and Tier II and III habitats is proposed as mitigation for

short-term direct impacts (e.g., areas graded during construction or temporarily
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affected by construction access), and will include a minimum 5-year

mitigation/monitoring period subject to resource agency approval during the

permitting process (Mitigation Measure BIO1).

The mitigation for wetland impacts will ensure that wetland functions and values are

retained. The Mid-Coast Corridor Transit Project is not specifically listed as an

Essential Public Project but meets the definition because the project is a linear

infrastructure project identified in adopted land use plans, impacts have been

minimized, and no feasible alternative exists that would avoid wetland impacts due to

the location and need of the project. Thus, the project would qualify for a deviation

from city regulations. However, as described above, the project is not subject to the

discretionary authority of the city and, as such, is not subject to city regulations

regarding deviations and wetland buffers.

All special-status species, including MSCP covered and/or state or federal

endangered/threatened species present or with the potential to occur in the study

area, are listed in Tables C-1 and C-2 of Appendix C of the Biological Resources

Technical Report.

Habitats where special-status species were identified are listed in Tables C-1 and

C-2 of Appendix C and described in Section 4.7 of the Biological Resources

Technical Report, as well as Chapter 4.0, Section 4.8.2 of the Final SEIS/SEIR.

MSCP SUBAREA PLAN COMPLIANCE:

As described above, although the project is not subject to the MSCP process, the

project incorporates design features and mitigation measures consistent with the

design and mitigation criteria of the city’s subarea plan, including the Management

Policies and Directives for Urban Habitat Lands and the Land Use Adjacency

Guidelines.

Coastal California gnatcatcher is an MSCP-covered species observed within the

project area. Direct and indirect effects and mitigation for this species are described

in Chapter 5.0, Sections 5.1.2.1 and 5.1.2.2 and Chapter 6.0 of the Biological

Resources Technical Report and Chapter 4.0, Sections 4.8.2.1, 4.8.4, and 4.17.3.2

of the Final SEIS/SEIR. As discussed in Chapter 4.0, Section 4.8.3.2 of the Draft

SEIS/SEIR, informal consultation for coastal California gnatcatcher, as well as San

Diego fairy shrimp, least Bell’s vireo, southwestern willow flycatcher, and light-footed

clapper rail, was being conducted through the Section 7 process between FTA and

USFWS in accordance with the federal Endangered Species Act. However, in

March 2014 (which was after the close of the Draft SEIS/SEIR comment period), the

federally endangered San Diego fairy shrimp was identified within the impact

footprint for the project. As a result, formal consultation under Section 7 was initiated

on June 12, 2014. Additionally, the Supplemental Environmental Impact

Statement/Supplement to the Subsequent Environmental Impact Report regarding
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the San Diego fairy shrimp was circulated for a 45-day public review and comment

period, from July 18 to September 2, 2014.

With respect to the consistency with the city’s Land Use Adjacency Guidelines,

potential indirect effects associated with drainage, toxics, lighting, noise, and

invasive plant species are analyzed in the relevant portions of the Water Impacts

Technical Report and Biological Resources Technical Report.

As discussed in Chapter 5.0, Section 5.1.2.1 of the Water Impact Analysis Technical

Report, the proposed storm drainage network has been designed to safely and

efficiently convey the anticipated runoff from the 100-year storm event through the

study area. BMPs (including, but not limited to, those identified in Table 5-2) will

reduce increases in surface runoff that could overwhelm existing downstream

facilities. Impacts of flooding that could result from the project would be further

alleviated through redesign of downstream storm drainage facilities when it is

determined that such actions are required. BMPs proposed for incorporation into the

project (including, but not limited to, those identified in Table 5-2), in compliance with

applicable water quality standards and waste discharge requirements identified in

Chapter 2.0 of the Water Impact Analysis Technical Report, will treat the increased

runoff caused by increased impervious surfaces and avoid substantial additional

sources of polluted runoff.

Discussion of direct and indirect effects and mitigation related to lighting, noise, and

invasive plant species is provided in Chapter 5.0, Sections 5.1.2.1 and 5.1.2.2 and

Chapter 6.0 of the Biological Resources Technical Report (Chapter 4.0, Sections

4.8.3.2 and 4.8.4 of the Final SEIS/SEIR). Measures intended to avoid and minimize

the potential indirect effects from lighting and invasive plant species adjacent to the

MHPA include project design features listed in Chapter 6.0, Section 6.2.1 of the

Biological Resources Technical Report (Chapter 4.0, Section 4.8.3.2 of the Final

SEIS/SEIR). Measures designed to mitigate for potential indirect impacts to specialstatus species due to noise in adjacent habitat areas, including the MHPA, are

described in Mitigation Measures CON12, CON13, and CON14 in Section 6.2.3.1 of

the Biological Resources Technical Report and Section 4.17.3.2 of the Final

SEIS/SEIR.

22 As described in response to Comment 19, the project is not subject to the MSCP

boundary line adjustment process.
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23 In order to clarify that existing biological resources are documented consistent with the

City of San Diego Biology Guidelines, Chapter 4.0, Section 4.4 of the Biological

Resources Technical Report has been revised to reference the City of San Diego

Biology Guidelines instead of the Final MSCP Plan. Discussions referencing the City of

San Diego Biology Guidelines have been updated from the 2004 version cited

previously, to the latest version dated June 2012. In addition, the classification of Tier I

through IV vegetation communities according to the City of San Diego Biology

Guidelines was corrected throughout the Biological Resources Technical Report.

Project-related impacts have been identified, and the impact analysis presented in the

Final SEIS/SEIR is consistent with the city’s guidelines. Long-term direct impacts are

discussed in Chapter 5.0, Section 5.1.2.1 of the Biological Resources Technical Report

under the heading “Regional Resource Planning.” In response to comments received,

supplemental noise and lighting analysis has been conducted (see Master Responses

13 and 14). A project design feature—washing of construction vehicles and equipment

prior to entering work areas adjacent to sensitive vegetation—has been included to

reduce potential impacts from invasive plant species, another indirect impact identified in

the city’s guidelines. Unavoidable impacts to vegetation communities inside the MHPA

will be mitigated as described in Chapter 6.0 of the Biological Resources Technical

Report. Long-term impacts to wetlands will be mitigated at a minimum ratio of 3:1,

including a 1:1 ratio of wetlands creation, to ensure no net loss. Impacts to sensitive

upland habitat, both inside and outside of the MHPA, will be mitigated in accordance

with the mitigation ratios outlined in the city’s guidelines. As a result, the project will not

preclude implementation of the city’s Subarea Plan and management of designated

open space areas.

24 Chapter 4.0, Figure 4-4 (Maps 1-9) of the Biological Resources Technical Report were

revised to include street names. Figure 4-4 Map 2 has also been updated to reflect the

results of the 2013-2014 wet season survey and the identification of one additional

location where San Diego fairy shrimp were found in the study area (referred to as Basin

II). The federally listed endangered Riverside fairy shrimp (Streptocephalus woottoni)

was not observed during focused surveys. Versatile fairy shrimp (Branchinecta lynchi),

although observed during focused surveys, are not a special-status species (refer to

Appendix D, Table 2, and Chapter 4.0, Section 4.7.2.3 of the technical report) and thus

are not depicted on Figure 4-4. However, locations of versatile fairy shrimp observed

during focused surveys are depicted on maps provided in the survey reports in Appendix

D of the Biological Resources Technical Report.

25 The 2012 focused survey report was inadvertently excluded from the appendices of

the Biological Resources Technical Report. The survey report has been added to

Appendix D of the technical report. Figure 3H of the survey report shows the basin

where San Diego fairy shrimp (Branchinecta sandiegonensis) were recorded and the

proposed limits of impact for the Build Alternative.
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26 Chapter 4.0, Table 4-16 of the Draft SEIS/SEIR has been revised to include the

designation of City of San Diego wetlands. Figure 3H of the 2012 focused survey

report shows the basin where San Diego fairy shrimp were recorded and the

proposed limits of impact for the Build Alternative.

27 The water demands of the project will include water for construction (e.g., dust

reduction), irrigation (e.g., landscaping), and maintenance (e.g., platform and vehicle

cleaning). Where feasible, reclaimed water will be used for construction and

irrigation activities. The project’s water demand and supply will be coordinated with

the City of San Diego.

28 Permanent impacts resulting from construction of the project will be mitigated

through SANDAG’s TransNet Environmental Mitigation Program, as described in

Chapter 4.0, Section 4.8.1.1 of the Draft SEIS/SEIR. The mitigation measures for

the project allow sufficient flexibility to incorporate mitigation at additional locations,

subject to resource agency (e.g., U.S. Army Corps of Engineers, U.S. Fish and

Wildlife Service, and California Department of Fish and Wildlife) approval.

29 As stated in response to Comment 28, impacts will be mitigated through SANDAG’s

TransNet Environmental Mitigation Program, as described in Chapter 4.0, Section

4.8.1.1 of the Draft SEIS/SEIR. The mitigation measures for the project allow

sufficient flexibility to incorporate mitigation at additional locations, subject to

resource agency approval. Therefore, the requested edit to Mitigation Measure

BIO3 was not required to allow consideration of the City of San Diego’s Marron

Valley Cornerstone Lands Mitigation Bank.

30 Chapter 4.0, Table 4-35 of the Draft SEIS/SEIR presented the Temporary

Construction Site BMPs proposed to avoid or minimize impacts during construction,

including those near water and sewer lines. Additionally, as stated in Chapter 4.0,

Section 4.17.3 of the Draft SEIS/SEIR under the heading “Water Resources,” a

Storm Water Prevention Pollution Control Plan will be completed during final design.

This plan will provide detailed information on the types and locations of temporary

construction BMPs based on the list shown in Chapter 4.0, Table 4-35 of the Draft

SEIS/SEIR. Utility conflicts and relocations are being coordinated with the affected

utility owners, including the City of San Diego, as part of the Utilities Relocation Plan

under development for the project, as stated in Chapter 4.0, Section 4.17.3.2 of the

Final SEIS/SEIR. The contractor will be directed to protect-in-place existing utilities

that are not affected by the project.
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31 The comments contained within the submission letter have been addressed (see the

comment responses above and below). CD copies of the Final SEIS/SEIR were

provided to the City of San Diego departments as part of the distribution of the Final

SEIS/SEIR. Additionally, CD copies of the Supplemental Environmental Impact

Statement/Supplement to the Subsequent Environmental Impact Report regarding

the San Diego fairy shrimp were provided to the City of San Diego departments as

part of the distribution of that document.

32 Additional larger-scale, detailed aerial maps of all evaluated sensitive receiver

clusters are included in Appendix G of the Mid-Coast Corridor Transit Project Noise

and Vibration Impacts Technical Report. Appendix B of the technical report provides

the precise location of long-term noise measurements, and Chapter 4.0, Section 4.1

of the technical report includes detailed descriptions of both short- and long-term

noise measurement locations. The maps included in Chapter 4.0, Figures 4-18 and

4-19 of the SEIS/SEIR are appropriate to identify the locations of noise impacts that

will be caused by the project. These maps may be used to locate the noise analysis

sites within community plan areas. The project will not introduce any new at-grade

crossings. Noise impacts associated with changes in operation at existing at-grade

crossings are included in Chapter 4.0, Section 4.7.3.2 of the Draft SEIS/SEIR and in

Chapter 5.0, Section 5.1.3 and Table 5-2 of the Noise and Vibration Impacts

Technical Report.

33 The noise impact assessment prepared for the Draft SEIS/SEIR analyzed potential

effects of train noise at 94 receiver clusters throughout the corridor. Noise

measurements were taken for an additional 7 clusters in support of the Final SEIS/SEIR

for a total of 101 clusters. The assessment locations are shown on detailed maps

included in Appendix G of the Noise and Vibration Impacts Technical Report. Noise

levels for both the existing conditions and future conditions with the project at each

receiver cluster are included in Chapter 5.0, Section 5.1.3 of the Noise and Vibration

Impacts Technical Report. This information provides a description of the projectgenerated noise throughout the study corridor. The noise analysis conducted for the

project and presented in Chapter 5.0, Section 5.1.3 of the Noise and Vibration Impacts

Technical Report identified all potentially significant noise impacts from operation of the

project. Additional analysis of the potential for noise impacts on future development

projects as requested by the commenter is not required and would involve improper

speculation. The project is consistent with local land use plans, which anticipate and

encourage public transit as discussed in Chapter 4.0, Section 4.1.3 of the Draft

SEIS/SEIR. Accordingly, it is not anticipated that noise associated with the project will

impact future land uses in a manner that is inconsistent with applicable plans. It is also

reasonable to presume future development in the corridor will be designed in a manner

that considers public transit facilities, similar to what has occurred at other residential

and commercial development near trolley stations and facilities.
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34 The proposed upgrades to the existing transit system between and including Santa

Fe Depot and the OTTC are described in Chapter 2.0, Section 2.2.2 of the Draft

SEIS/SEIR: "The only improvements included in the project south of the OTTC are

upgrades to the existing systems, including the signaling system and traction power

system to accommodate the increase in Trolley service in this segment."

Modifications to the traction power system are summarized in Chapter 2.0, Section

2.4.4 of the Final SEIS/SEIR and the signalizing system modifications are described

in Chapter 2.0, Section 2.3.7.2 of the Transportation Impacts and Mitigation Report.

There will be no addition or removal of pedestrian or bicycle facilities within this area.

Additionally, there will be no change in the location or supply of parking at any of the

existing stations or any upgrades to the existing Trolley stations. As discussed in

Chapter 5.0, Section 5.1.2.3 of the Land Use Impacts Technical Report, proposed

changes will not adversely impact adjacent land uses. All of the stations along this

segment of the alignment are located at-grade within the existing MTS right-of-way

and have been supporting Trolley service since 1996.

Mitigation measures, consisting of changes in traffic signal timing and/or phasing and

geometric modifications, are required for certain intersections south of and adjacent

to the OTTC to mitigate the traffic impacts from the Build Alternative; these

measures are described in Chapter 3.0, Table 3-26 of the Draft SEIS/SEIR.

35 The Draft SEIS/SEIR and the Transportation Impacts and Mitigation Report analyzed

parking impacts. The analysis is based on modeling and includes all transit services that

will operate in the corridor in 2030. As shown in Chapter 3.0, Table 3-28 of the Draft

SEIS/SEIR, the analysis concludes that the demand for parking at the OTTC is

projected to decrease by approximately 130 spaces (or 17 percent) under the Build

Alternative in 2030 compared to the No-Build Alternative. The process used to

determine parking supply is described in Chapter 4.0, Section 4.5.1 of the

Transportation Impacts and Mitigation Report. One of the reasons for this conclusion

has to do with the fact that transit parking will be provided at five new stations north of

the OTTC, which will shift the demand for parking to these new locations.

As shown in Chapter 2.0, Figure 2-5 of the Draft SEIS/SEIR, the Trolley Green Line

would serve the existing Trolley stations between and including Santa Fe Depot and

the OTTC under the No-Build Alternative and not the Trolley Blue Line. Under the

Build Alternative, these stations will be served by both the Trolley Green and Trolley

Blue Lines (Chapter 2.0, Figure 2-23 of the Draft SEIS/SEIR). The 7,190 boardings

referenced in the comment represent boardings under the Build Alternative for the

Trolley Blue Line only (Chapter 4.0, Table 4-27 of the Transportation Impacts and

Mitigation Report). As shown in Chapter 4.0, Figure 4-14 of the Transportation

Impacts and Mitigation Report, there will be approximately 4,000 daily boardings at

the OTTC for the Trolley Green Line. This is compared to approximately 5,000 daily

boardings at the OTTC for the Trolley Green Line under the No-Build Alternative

(Chapter 4.0, Figure 4-8 of the Transportation Impacts and Mitigation Report).
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Therefore, some of the demand that previously occurred on the Trolley Green Line

will decrease, with riders potentially taking the Trolley Blue Line instead.

For transit passengers traveling from areas north of the OTTC to areas south, the

OTTC is the first Trolley station with a park-and-ride facility under the No-Build

Alternative; however, the Build Alternative will add five new park-and-ride facilities

north of the OTTC, including the Tecolote Road, Clairemont Drive, and Balboa

Avenue Stations, providing opportunities for transit patrons to park elsewhere, which

will reduce parking demand at the OTTC. The Build Alternative assumes all transit

services that will operate in the corridor in 2030. As shown in Chapter 3.0, Table

3-28 of the Draft SEIS/SEIR, the demand for parking at the OTTC will decrease by

approximately 130 spaces (or 17 percent) under the Build Alternative compared to

the No-Build Alternative.

36 Refer to Master Response 4 for more information about the Clairemont Drive Station.

As stated in that response, the use of the site for surface parking would not preclude

future commercial or mixed-use development on the site.

Locating a new, or expanding an existing, park-and-ride facility in another location

would not meet the demand for parking that was identified in the Clairemont Drive

Station area under the Build Alternative. The parking analysis conducted prior to the

Draft SEIS/SEIR identified a need for parking at the Clairemont Drive Station that

would not be served by providing parking elsewhere (refer to Chapter 4.0, Section

4.5.1 of the Transportation Impacts and Mitigation Report). As such, alternatives for

new parking at Washington Street and/or Palm Street or expanding parking at the

OTTC as an alternative to parking at the Clairemont Drive Station or to offset land

use impacts are not analyzed in the Final SEIS/SEIR.

37 The Draft SEIS/SEIR, the Transportation Impacts and Mitigation Report, and the

Mid-Coast Corridor Transit Project Safety and Security Impacts Technical Report

analyzed bicycle facility impacts. Chapter 4.0, Section 4.13 of the Draft SEIS/SEIR

(summarized from the Safety and Security Impacts Technical Report) examined

impacts to bicyclists near the eight grade crossings. As indicated in Chapter 4.0,

Section 4.13.3.2 under the heading "Pedestrian and Bicycle Safety," "the trafficcontrol devices at these grade crossings would continue to provide the level of

advanced warning and protection from an oncoming train required by the CPUC and

California MUTCD. Therefore, the Build Alternative would not adversely affect

pedestrian and bicycle safety at these crossings or at adjacent intersections."

As part of the project, gate down times will be optimized for Trolleys traveling

through all eight existing grade crossings and for northbound COASTER and Amtrak

trains traveling through the Taylor Street grade crossing (the gate optimization

measures are described in Chapter 2.0, Section 2.3 .7.2 of the Transportation

Impacts and Mitigation Report). Even though the gates will be down more frequently
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with the project, the improvements to gate operations will decrease the average and

maximum gate down times per train at all eight grade crossings compared to the

No-Build Alternative. The actual time a bicyclist will wait to cross the tracks will still

depend on the type and number of trains traveling through the crossing.

In addition, the Draft SEIS/SEIR and technical reports examined long-term and

temporary impacts to bicycle facilities. Bicycle lanes near the Taylor Street grade

crossing will not be permanently removed by the project. However, as stated in

Chapter 3.0, Section 3.4.7.3 of the Draft SEIS/SEIR, the Class II bicycle lane on

Pacific Highway between Taylor Street and the OTTC park-and-ride lot access

driveway will be closed for up to 6 months during construction of the mitigation

measures at this location (i.e., the roadway improvements along Pacific Highway).

The bicycle lane will be reopened once construction is complete. Signage will be

provided to identify alternate routes for bicyclists where feasible, otherwise bicyclists

will share the travel lanes with vehicles. There will not be long-term or temporary

impacts to bicycle facilities near the other grade crossings.

38 The Draft SEIS/SEIR, the Transportation Impacts and Mitigation Report, and the Safety

and Security Impacts Technical Report analyzed impacts to pedestrians traveling

through the eight grade crossings and the adjacent intersections. Specifically, as stated

in Chapter 3.0, Section 3.4.2.3 of the Draft SEIS/SEIR, developing appropriate mitigation

for impacts at intersections required consideration of pedestrian wait times. Thus,

analysis was conducted to ensure that mitigation measures for vehicular delay will not

negatively affect how long a pedestrian will need to wait to cross an intersection.

The traffic analysis and mitigation measures assessed for the project considered

pedestrian wait times at locations south of the San Diego River (refer to Chapter 6.0,

Section 6.1.2.2 of the Transportation Impacts and Mitigation Report). Specifically, it was

assumed that an excessive pedestrian wait time would occur if a pedestrian would wait,

on average, longer than two average traffic cycle lengths. If, with mitigation, it was

determined that pedestrians would have to wait on average longer than two average

traffic cycle lengths, additional operational mitigation measures, such as traffic signal

timing changes or the addition of a pedestrian phase to the traffic signal exit phase, were

analyzed to reduce pedestrian wait times. Mitigation for improving pedestrian wait times

was assumed to be needed, even if the overall intersection level of service would

operate at a LOS E or F (considered an unacceptable level of service) as a result.

As shown in Chapter 3.0, Table 3-26 of the Draft SEIS/SEIR, a pedestrian phase

was added at Ash Street and Pacific Highway (Mitigation Measure TR1), Cedar

Street and Pacific Highway (Mitigation Measure TR3), Washington Street at

Northbound Frontage Road and Hancock Street (Mitigation Measure TR7), and

Taylor Street/Rosecrans Street and Pacific Highway (Mitigation Measure TR8). Wait

times for pedestrians crossing the tracks will be similar to those for bicyclists; refer to

the response to Comment 37 regarding bicyclist movement at the grade crossings.
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Chapter 4.0, Section 4.13 of the Draft SEIS/SEIR also summarized impacts to

pedestrians near the eight grade crossings (summarized from the Safety and Security

Impacts Technical Report). As indicated in Chapter 4.0, Section 4.13.3.2 under the

heading "Pedestrian and Bicycle Safety," "the traffic-control devices at these grade

crossings would continue to provide the level of advanced warning and protection from

an oncoming train required by the CPUC and California MUTCD. Therefore, the Build

Alternative would not adversely affect pedestrian and bicycle safety at these crossings or

at adjacent intersections."

39 The mitigation measures proposed for the Taylor Street/Rosecrans Street and

Pacific Highway intersection, as summarized in Chapter 3.0, Table 3-26 of the Draft

SEIS/SEIR, were the only measures identified that will improve level of service and

delay at the intersection. As shown in Table 3-24, delay at the intersection will

improve by 2.0 and 2.3 seconds during the a.m. and p.m. peak hour, respectively,

when compared to the No-Build Alternative in 2030.

The mitigation measures proposed for this intersection were required to restore the stopcontrolled intersection of Rosecrans Street and Jefferson Street to an acceptable level of

service, per city criteria (defined as LOS D or better than the No-Build Alternative). The

mitigation measures were proposed at Taylor Street/Rosecrans Street and Pacific

Highway because traffic queues from this intersection would extend back to the stopcontrolled intersection and affect level of service. The mitigation measures will improve

delay at Taylor Street/Rosecrans Street and Pacific Highway by 3.1 and 12.6 seconds

during the a.m. and p.m. peak hours, respectively, compared to the No-Build Alternative

in 2030, with a LOS D during both peak hours. This is consistent with city criteria as the

intersection will have less delay than the No-Build Alternative and will operate at LOS D.

As such, reducing the delay to existing conditions is not required. However, it should be

noted that the delay for the Build Alternative with mitigation in 2030 is approximately 10

seconds longer than existing (2010) conditions, despite the increases in vehicular traffic

and additional train crossings that will occur in 2030 compared to 2010. The existing

conditions analysis, both with and without the project, is documented in Chapter 7.0,

Table 7-6 of the Transportation Impacts and Mitigation Report. As shown in this table,

level of service at Taylor Street/Rosecrans Street and Pacific Highway with the project

will remain at LOS D with a 3.3-second increase in delay during the a.m. peak hour and

a 0.9-second decrease in delay during the p.m. peak hour. Therefore, there will not be a

significant impact at this intersection under CEQA. The existing plus project analysis

does not include the intersection modifications or traffic signal timing changes that will

occur in the future as mitigation (as shown in Chapter 3.0, Table 3-26 of the Draft

SEIS/SEIR); a further decrease in delay is expected with those mitigation measures.
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Submission ID343 Ewiiaapaayp Band of Kumeyaay Indians Pinto Robert

Com ID Response

1 Your comment discusses effects associated with the Disposal of the Former Caltrans

District 11 Building Project, which is a separate undertaking from the Mid-Coast Corridor

Transit Project. Although the former Caltrans complex site is located near the MidCoast Corridor Transit Project, it is not located in the project's Archaeological Area of

Potential Effects, which is shown in the Mid-Coast Corridor Transit Project

Archaeological Resources Survey Report. Additionally, any ground disturbance

associated with demolition of the former Caltrans complex is not related to activities

proposed for the Mid-Coast Corridor Transit Project.

Extended Phase I investigations within the project’s archaeological Area of Potential

Effects were conducted in 2013. The purpose of the investigations was to determine

whether archaeological deposits associated with previously documented or reported

archaeological sites are present within the project’s archaeological Area of Potential

Effects. The investigations, which included areas south of the San Diego River, verified

extensive ground disturbance and the absence of archaeological deposits in the vicinity

of the previously recorded archaeological sites within the project’s archaeological Area

of Potential Effects. Based on the results of the investigations, no archaeological

resources eligible for listing in the National Register of Historic Places were identified or

detected within the project’s archaeological Area of Potential Effects. In a letter dated

April 9, 2014, the California State Historic Preservation Officer concurred with the FTA’s

determination that the project will result in “no adverse effect” on historic properties.

No archaeological resources eligible for listing in the National Register of Historic Places

were identified or detected within the project’s archaeological Area of Potential Effects

during Extended Phase I investigations; however, there exists a low potential to

encounter unknown cultural materials during construction (unanticipated discoveries).

To account for the possibility of an unanticipated discovery of archaeological resources

or human remains during project-related ground disturbance, the project includes

mitigation that requires construction monitoring of ground-disturbing activities in native

soil by a qualified archaeologist and a Native American monitor, construction worker

training, and appropriate treatment of human remains. These measures are specified

as CON14, CON15, and CON16 in Chapter 4.0, Section 4.17.3 of the Draft SEIS/SEIR

and as CON15, CON16, and CON17 in Chapter 4.0, Section 4.17.3 of the Final

SEIS/SEIR under the heading "Archaeological Resource Impacts." These measures

are outlined in greater detail in the Mid-Coast Corridor Transit Project Construction

Monitoring Plan and the Mid-Coast Corridor Transit Project Cultural Resources

Discovery Plan, which are confidential reports.

2 The FTA and SANDAG have invited participation from the Ewiiaapaayp Band of

Kumeyaay Indians on the Mid-Coast Corridor Transit Project throughout the project

development process, beginning in April 2010 with CEQA scoping. As part of Section

106 consultation, the FTA contacted the Ewiiaapaayp Tribal Office Chairperson by letter

on November 29, 2011, and again by telephone and e-mail on December 23, 2011,
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inviting comment on the project as well as information regarding cultural resources and

sites of Native American importance in the project vicinity. Additionally, the NOA, NOC,

and Draft SEIS/SEIR were sent to Native American groups, including the NAHC and

Ewiiaapaayp Band of Kumeyaay Indians in May 2013. Prior to this comment, received

on August 15, 2013, the FTA and SANDAG had not received any replies from the

Ewiiaapaayp Band of Kumeyaay Indians.

As a follow-up to this comment, which discusses impacts associated with the Disposal

of the Former Caltrans District 11 Building Project (a project that FTA has no

involvement with and that is independent of the Mid-Coast Corridor Transit Project), the

FTA and SANDAG sent a response letter to the Ewiiaapaayp Band of Kumeyaay

Indians requesting consultation once more to verify the location of the recorded Native

American burial ground reported to the NAHC in 1990 and to confirm whether it is

located within the Archaeological Area of Potential Effects for the Mid-Coast Corridor

Transit Project. The FTA and SANDAG also sent a response letter to the NAHC, who

similarly submitted a comment on the Disposal of the Former Caltrans District 11

Building Project. Both response letters were mailed on September 26, 2013. At the

time of issuance of the Final SEIS/SEIR, the FTA and SANDAG have not received a

response from the Ewiiaapaayp Band of Kumeyaay Indians.

3 The Mid-Coast Corridor Transit Project considers applicable laws and regulations, as

documented in the Mid-Coast Corridor Transit Project Archaeological Resources Survey

Report, including those specified in this comment.

The project has conducted extensive Native American outreach efforts throughout the

project development process, including consultation in compliance with Section 106 of

the National Historic Preservation Act. The Ewiiaapaayp Band of Kumeyaay Indians

was invited to comment on the project during CEQA and NEPA scoping in April 2010

and August/September 2011, respectively. As part of Section 106 consultation, the FTA

contacted the Ewiiaapaayp Tribal Office Chairperson by letter on November 29, 2011,

and again by telephone and e-mail on December 23, 2011, inviting comment on the

project as well as information on cultural resources and sites of Native American

importance in the project vicinity. Additionally, the NOA, NOC, and Draft SEIS/SEIR

were sent to Native American groups, including the NAHC and Ewiiaapaayp Band of

Kumeyaay Indians in May 2013. Prior to this comment, received on August 15, 2013,

the FTA and SANDAG had not received any replies from the Ewiiaapaayp Band of

Kumeyaay Indians.

4 Refer to the response to Comment 1 for a description of the evaluation of cultural

resources and mitigation measures proposed to minimize the impacts of the Mid-Coast

Corridor Transit Project. As a follow-up to this comment letter, which primarily refers to

impacts associated with the Disposal of the Former Caltrans District 11 Building Project

(a project that FTA has no involvement with and that is independent of the Mid-Coast

Corridor Transit Project), the FTA and SANDAG sent a response letter to the
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Ewiiaapaayp Band of Kumeyaay Indians requesting consultation to verify the location of

the recorded Native American burial ground referred to in this comment letter and to

confirm whether it is located within the Archaeological Area of Potential Effects for the

Mid-Coast Corridor Transit Project. Section 106 consultation with the Ewiiaapaayp

Band of Kumeyaay Indians was initiated in November 2011.
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Submission ID295 San Diego City Council, District 1 Lightner Sherri S.

Com ID Response

1 Your comments regarding the focus of the comment letter and the importance of

the project to the region will be part of the record of proceedings for the Draft

SEIS/SEIR.

2 Your comment regarding the satisfactory resolution of comments by the groups and

entities identified in your letter will be part of the record of proceedings for the Draft

SEIS/SEIR. Responses to all of the comments received on the Draft SEIS/SEIR,

including the groups and entities mentioned in your letter, are included in Volume 3

of the Final SEIS/SEIR. Volume 3 of the Final SEIS/SEIR provides an index of

commenters and responses, and the page number where each response is

located.

3 The Final SEIS/SEIR has been updated to include the evaluation of the Refined

Build Alternative approved by the SANDAG Board of Directors on November 15,

2013 and amended on May 9, 2014. In compliance with NEPA and CEQA, and

where appropriate, the most recent applicable documents have been utilized in the

evaluation. Responses to comments provided by the City of San Diego are

included in Volume 3 of the Final SEIS/SEIR, which contains an index of

commenters and responses as noted in the response to Comment 2 above. The

updated technical reports and Final SEIS/SEIR have been provided upon request

to City of San Diego staff members; these documents are also available for review

on the project website at www.sandag.org/midcoast and at the regional and public

libraries listed in the Abstract in Volume 1 of the Final SEIS/SEIR. Appendix A of

the Final SEIS/SEIR contains a list of the technical reports and memoranda

prepared in support of the SEIS/SEIR and indicates which documents have been

updated since circulation of the Draft SEIS/SEIR. Additionally, in July 2014, copies

of the Supplemental Environmental Impact Statement/Supplement to the

Subsequent Environmental Impact Report regarding the San Diego fairy shrimp

was also provided to the City of San Diego staff during the 45-day public comment

and review period.

4 Your comment regarding the importance of University City and need to avoid noise

and visual impacts to residents and businesses during construction and during

operation will be part of the record of proceedings for the Draft SEIS/SEIR. Responses

to specific issues of concern are set forth in the responses to the comments below.

5 Your comment offering assistance from the City of San Diego in facilitating

coordination between various construction projects in the northern end of the

project area will be part of the record of proceedings for the Draft SEIS/SEIR.

SANDAG initiated outreach prior to circulation of the Draft SEIS/SEIR to several

stakeholders to facilitate early coordination, including UCSD, Scripps Memorial

Hospital La Jolla, and Westfield UTC shopping center, as described in Chapter 8.0,

Section 8.4 of the Final SEIS/SEIR. Coordination that occurred during the Draft
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SEIS/SEIR comment period is summarized in Chapter 8.0, Section 8.5.2, and

coordination that occurred after close of the Draft SEIS/SEIR comment period is

summarized in Chapter 8.0, Section 8.8 of the Final SEIS/SEIR. As specified in

Chapter 3.0, Section 3.4.7.7 of the Final SEIS/SEIR, coordination will occur with

other construction projects to minimize construction delays as well as overlapping

impacts, particularly within University City. The impacts of other projects were

considered in the construction-related cumulative impact analysis documented in

Chapter 3.0, Section 3.4.7.7 of the Final SEIS/SEIR for transportation-related

impacts, and in Chapter 4.0, Section 4.19.3.2 of the Final SEIS/SEIR under the

heading "Construction Impacts" for environmental impacts. The requirement for

coordination with other projects will be included in the Transportation Management

Plan (TMP) for the project.

6 The project has been designed to minimize the impact to the open space areas

associated with Rose Canyon Open Space Park, Marian Bear Memorial Park, and

other areas along the alignment. As shown in Chapter 5.0, Table 5-4 in the Final

SEIS/SEIR, the project has been designed such that there will be no direct impacts

to Rose Canyon Open Space Park. The project is located within existing MTS

right-of-way, and two existing LOSSAN tracks separate the project from Rose

Canyon Open Space Park. Mitigation for impacts to biological resources in Rose

Canyon is described in Master Response 16. Additional information regarding the

visual analysis for Rose Canyon Open Space Park is provided in Master Response

15.

7 SANDAG conducted an analysis for power requirements to fine tune the location of

TPSSs. As a result of this analysis, and in consideration of comments received on

the Draft SEIS/SEIR, the locations of several TPSSs have been modified, and two

TPSSs have been eliminated. Refer to Chapter 2.0, Section 2.3.5 for a summary of

the changes made to TPSS locations since the Draft SEIS/SEIR.

TPSS 17 (referred to as TPSS 15 in the Final SEIS/SEIR) was relocated from the

intersection of La Jolla Village Drive and Genesee Avenue to a less prominent

location on SDG&E property at the terminus of Fez Street, as shown in Chapter

2.0, Table 2-4 of the Final SEIS/SEIR.

TPSS 18 (referred to as TPSS 16 in the Final SEIS/SEIR) will remain in the location

presented in the Draft SEIS/SEIR on Westfield UTC property north of Nobel Drive.

This TPSS will be screened from public view with walls and/or vegetation to ensure

visual compatibility with surrounding uses. SANDAG is working with the Westfield

UTC shopping center to identify the best placement of the TPSS based on the

layout of the property and proposed expansion. An additional project measure that

requires screening and plantings to avoid or minimize the visual impacts of TPSS

sites has been incorporated into the Final SEIS/SEIR. For more information on this

project measure, see Chapter 4.0, Section 4.4.3.2 of the Final SEIS/SEIR under the

heading “Project Measures to Avoid or Minimize Impacts.”
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Your comment requesting placement of TPSS sites underground has been noted;

however, placing any of the TPSSs underground is cost prohibitive. Placing a TPSS

underground would introduce additional requirements, such as ventilation and

drainage/water pumps to avoid water damage to electrical equipment. Further,

maintenance would be more difficult for an underground TPSS because special

equipment would be needed. The site requirements also would be larger than for an

above ground unit in order to provide sufficient space for the TPSS and maintenance

access. Coordination with SDG&E, MTS, and the City of San Diego Fire Department

would be required in order to place a TPSS underground as all entities would need

access for maintenance or in case of emergency. Based on these additional

requirements, the cost would be considerably higher than that for an above ground

TPSS. Currently, none of the TPSSs on the existing MTS system are underground.

8 The load flow analysis conducted for the alignment indicates a TPSS is required

south of La Jolla Colony Drive. Therefore, TPSS 13 (referred to as TPSS 11 in the

Final SEIS/SEIR) has been retained at the site presented in the Draft SEIS/SEIR.

However, the project measures described in Chapter 4.0, Section 4.4.3.3 of the

Final SEIS/SEIR provide for appropriate landscape screening to ensure that the

facility will be visually screened from trails within Rose Canyon Open Space Park.

9 On November 15, 2013, the SANDAG Board of Directors approved the Refined

Build Alternative, which includes center columns supporting the aerial LRT

alignment on Genesee Avenue, for evaluation in the Final SEIS/SEIR. The

Genesee Avenue Design Option (i.e., straddle bents on Genesee Avenue) was

eliminated and is not considered in the Final SEIS/SEIR.

10 As stated in response to Comment 9, the Genesee Avenue Design Option was

eliminated on November 15, 2013. As reflected in the Final SEIS/SEIR Plan Set,

the aerial structure design has been modified to eliminate all but two straddle bents

along the alignment. One straddle bent is required to support the Executive Drive

Station, and one is required at Regents Road to support the structure as it

transitions to the median of Genesee Avenue. SANDAG will further investigate the

potential to eliminate these straddle bents during Final Design.

11 The unmitigated adverse and significant impacts identified in Chapter 4.0, Table

4-5 of the Draft SEIS/SEIR would only occur under the Genesee Avenue Design

Option. As stated in response to Comment 9, this design option was eliminated;

the remaining impacts can be mitigated to a level below significance.

The visual impacts of the project will be mitigated through both landscape and design

mitigation measures, which will be implemented along the project alignment wherever

appropriate. In response to comments, the Final SEIS/SEIR incorporates additional

project measures to avoid and minimize visual impacts associated with TPSS sites, as
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reflected in Chapter 4.0, Section 4.4.3.2 under the heading “Project Measures to Avoid

or Minimize Impacts.” The landscape and design mitigation measures are described in

Chapter 4.0, Section 4.4.4 of the Draft and Final SEIS/SEIR. As the impacts after

mitigation will not be adverse or significant, additional mitigation beyond that identified

in the Final SEIS/SEIR and the Mid-Coast Corridor Transit Project Visual Impacts

Technical Report has not been included.

12 The sound walls incorporated as noise mitigation (see response to Comment 13) in

the Draft SEIS/SEIR are sufficient to reduce project-related noise to a level below

the FTA impact criteria; therefore, additional noise mitigation is not required.

Providing sound walls to reduce exterior noise levels is generally preferable to

sound insulation because sound walls will also benefit residents when residents are

outside or have their windows open.

13 A continuous sound wall encompassing both sound walls N2 and N3 has been

incorporated into the project based on aesthetics (refer to sheets TA036 and TA037

in the Final SEIS/SEIR Plan Set). The two sound walls (N2 and N3) (as described

in Chapter 4.0, Table 4-14 of the Final SEIS/SEIR) would reduce noise impacts to a

level below the FTA noise impact criteria and the City of San Diego significance

criteria; the continuous sound wall is not necessary to reduce noise impacts.

14 The project noise impacts described in the Draft SEIS/SEIR at the La Jolla Vista

townhomes has been eliminated by relocating the track cross-over away from

residential uses. With this project design refinement, noise levels will be at a level

below significance; therefore, no mitigation measures are proposed. As stated in

response to Comment 12, reducing exterior noise levels caused by the project is

generally preferable to sound insulation because it will continue to benefit residents

when they are outside or have their windows open.

15 Refer to Master Response 14 for a discussion of noise impacts within Rose Canyon

Open Space, including the results of supplemental analysis conducted by

SANDAG. In addition, Master Response 15 provides a discussion of visual impacts

within Rose Canyon Open Space. As described in these responses, the project will

not result in adverse noise or visual impacts in this area.

The project will not include light elements or fixtures in Rose Canyon. Lighting

associated with Trolley vehicles will include headlights and indoor lighting. The

headlights on the front of the Trolley will be directed straight toward the tracks, and

all Trolley cars will have tinted windows to screen indoor lighting. The project is not

anticipated to result in light pollution within the park. Refer to Master Response 13

for further information regarding lighting impacts.

Your letter recommends that noise and visual impacts to Rose Canyon Open Space

Park be mitigated through construction of a vegetated earthen berm from La Jolla
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Colony to SR 52. Refer to Master Response 17 for the potential to construct an

earthen berm.

16 Impacts to wetlands will be mitigated in the same watershed in which they occur

(e.g., impacts to wetlands in Rose Creek will be mitigated in the Rose Creek

watershed) or as approved by the resource agency during the permitting process.

Consistent with this approach, all impacts to wetlands within the Rose Creek

watershed will also be mitigated within the Rose Creek watershed. Master

Response 16 provides additional information regarding proposed mitigation in the

Rose Canyon area. As noted therein, proposed mitigation includes implementing a

portion of the restoration and creation opportunities identified in the Rose Creek

Watershed Wetland, Riparian and Water Quality Restoration Opportunities Analysis

(San Diego Earthworks, 2012).

17 Refer to Master Response 16 for information regarding mitigation for impacts in the

Rose Canyon area.

18 The impact assessments conducted for the Draft SEIS/SEIR identified several

impacts that will occur during construction, including construction noise and

temporary visual impacts. As a result, SANDAG is committing to a range of

measures to avoid, minimize, and mitigate construction-related impacts. These are

presented in Chapter 3.0, Section 3.4.7 and Chapter 4.0, Section 4.17.3.2 of the

Final SEIS/SEIR and include a comprehensive TMP; a Noise Control Plan;

temporary sound walls; temporary voluntary relocation of residents on Charmant

Drive, in the Cape La Jolla Gardens housing complex, and along Genesee Avenue

during nighttime work; and screening of construction areas and avoiding light

spillover near residential areas.

The project and mitigation measures identified in the Final SEIS/SEIR will minimize

noise and visual impacts to the extent practicable; however, as detailed in Chapter

4.0, Section 4.17.3.2 of the Draft SEIS/SEIR under the heading "Noise and

Vibration Impacts," the project will have significant and unavoidable temporary

noise impacts during construction. In locations along Charmant Drive, at the Cape

La Jolla Gardens housing complex, and Genesee Avenue the contractor will

provide noise-reducing curtains or noise-masking machines where appropriate and

approved by the occupant. Additionally, when nighttime construction noise levels

exceed the ambient noise levels for that area by 5 dBA after implementation of

these measures, residents will be offered temporary relocation to a SANDAGapproved hotel (Mitigation Measure CON2). SANDAG, as part of final design of

this project, will prepare contract specifications that define the noise-control

measures to be implemented during construction in accordance with the Noise

Control Plan and city construction noise permit to minimize noise to the extent

practicable. Included in the specifications will be site-specific requirements for

implementation of the project measures to avoid or minimize noise impacts to the
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extent practicable during construction, as presented in Section 4.17.3.2.

Construction activities will result in short-term visual impacts along the project

alignment. Visual impacts will be localized to the areas of active construction and

staging. As stated in Section 4.17.3.2, “Project specifications would require

screening of construction zones and staging areas adjacent to residential

neighborhoods; shielding light at construction zones and staging areas to minimize

light and glare that might illuminate adjacent communities and neighborhoods,

particularly residential areas; and minimizing light and glare into the night sky

above the construction zone or staging area.”

As stated in Chapter 4.0, Sections 4.4.3.2 and 4.7.3.2 of the Final SEIS/SEIR, the

project will result in long-term noise and visual impacts during operation (see

Chapter 4.0, Table 4-4 for the location of visual impacts and Figure 4-19 for the

location of noise impacts). Mitigation measures have been identified, as

documented in Chapter 4.0, Sections 4.4.4 and 4.7.4 of the Final SEIS/SEIR,

including sound walls as well as design and landscaping measures that will reduce

impacts below a level of significance. Therefore, with mitigation, there will not be

adverse or significant long-term visual and noise impacts in University City.

SANDAG will minimize nighttime construction to the extent practicable; however, it

will be necessary in some cases (e.g., in areas where daytime construction will

result in traffic disruptions). In addition, in accordance with the TMP and the Noise

Control Plan, SANDAG will require contractors to provide community outreach and

notification regarding periods of nighttime construction. Through the noise

permitting process, SANDAG will work with the City of San Diego to determine

specific mitigation requirements, including options to replace typical backup alarms

with less intrusive options, such as ambient sensing and/or broad spectrum alarms.

19 The Rose Canyon Bicycle Path will continue to provide north–south connectivity for

pedestrians and bicyclists. A maintenance path along the east side of the open

channel under SR 52 will remain and continue to allow for north–south wildlife

movement adjacent to the east side of the open channel. Additionally, in response

to comments by the California Department of Fish and Wildlife and others, design

features have been incorporated into the project to continue to allow wildlife to

move through the area using the concrete-lined open channel below SR 52. For

example, as stated in Chapter 4.0, Section 4.8.3.2 of the Final SEIS/SEIR under

the heading “Project Measures to Minimize or Avoid Impacts,” the concrete-lined

channel has been designed with a slight inclination toward the center of the

channel. During dry seasons when the flows will be limited to irrigation runoff, the

outer segments of the channel bottom will carry limited amounts of runoff and will

continue to facilitate wildlife movement. Further, the majority of riprap placed at the

upstream and downstream ends of the proposed channel will not be grouted, which

will allow sediment to fill gaps, creating a more natural and even surface for wildlife

to cross. The project will not introduce any new barriers to park users.
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20 SANDAG will require its construction contractor to obtain a number of constructionrelated permits from the city, although pursuant to applicable law governing

independent agencies and the Cooperative Agreement for Project Review

Procedures between SANDAG and the City of San Diego (SANDAG Document

#5001195, City Document C-15015, August 17, 2009), the project is not subject to

the discretionary authority of the city. The city permits shown in Chapter 4.0, Table

4-37 of the Final SEIS/SEIR will be obtained prior to the start of construction. The

TMP will be developed after circulation of the Final SEIS/SEIR. The TMP is being

developed in consultation with the City of San Diego, Caltrans, and other

stakeholders (e.g., UCSD, Scripps, Jewish Community Center, La Jolla Country

Day School, and Westfield UTC). Outreach to community groups is included as

part of the outreach program for the TMP.
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Com ID Response

1 The traffic, parking, and noise impacts referenced in this comment are addressed in 

detail in the responses to subsequent comments.

2 The potential relocation of the Balboa Avenue Station to the City Yard site north of 

Balboa Avenue is discussed in Master Response 5. The location of the Balboa 

Avenue Station that was presented in the Draft SEIS/SEIR remains unchanged in 

the Final SEIS/SEIR.

3 The roadway segments and intersections referenced in the comment did operate at 

LOS E or F in 2010, the year used for the existing condition analysis. Adverse 

impacts under the Build Alternative will occur at one roadway segment (Balboa 

Avenue from the I-5 southbound on-ramp to the I-5 northbound off-ramp, where 

daily traffic will increase by less than 1 percent compared to the No-Build 

Alternative) and one intersection (Mission Bay Drive and Garnet Avenue, where an 

increased delay of 1 to 4 seconds over the No-Build Alternative will occur). 

Significant impacts were also identified for the near-term analysis at these locations 

(see Chapter 7.0, Table 7-4 of the Mid-Coast Corridor Transit Project Transportation 

Impacts and Mitigation Report for the roadway analysis and Table 7-9 for the 

intersection analysis). Although the volume of vehicles on other roadway segments 

will increase, the project will not cause the level of service to exceed the thresholds 

of significance established by the City of San Diego. Thus, the impacts on those 

other roadways are not considered adverse or significant, and no mitigation is 

required. Refer to Master Response 8 for additional information on the traffic 

analysis near the Balboa Avenue Station.

4 The traffic studies conducted for the project analyzed the intersections along the 

reconfigured Balboa Avenue/Morena Boulevard ramps. Refer to Master Response 

8 for additional detail regarding traffic impacts associated with the reconfigured 

ramps. In addition to the intersection analysis, the performance of individual 

roadway segments was analyzed and the results are documented in Chapter 3.0, 

Table 3-22 of the Draft SEIS/SEIR and Chapter 4.0, Table 4-57 of the 

Transportation Impacts and Mitigation Report. As shown in this table, the traffic 

analysis included an analysis of Morena Boulevard at the Balboa Avenue overpass 

and between the Balboa Avenue westbound ramps to Avati Drive. Under the Build 

Alternative, these roadway segments will operate at acceptable levels of service 

according to the City of San Diego significance thresholds. Therefore, 

reconfiguration of the ramps and the addition of traffic signals will not result in an 

adverse impact or traffic bottlenecks on Morena Boulevard.
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5 Refer to Master Response 5 regarding the potential relocation of the Balboa Avenue 

Station. 

As stated in response to Comment 4, the location of the Balboa Avenue Station 

south of Balboa Avenue and the reconfiguration of the Balboa Avenue/Morena 

Boulevard ramps will not result in adverse traffic impacts on Morena Boulevard. 

Therefore, there are no adverse traffic impacts that would be reduced by relocating 

the station. Refer to Master Response 8 for additional information on the traffic 

analysis near the Balboa Avenue Station. 

As stated in Master Response 5, if the station were moved to the City Yard/Rose 

Canyon site, vehicular traffic would continue to use Balboa Avenue and the 

intersection of Mission Bay Drive and Garnet Avenue to access the station and 

park-and-ride facility. Thus, relocating the station would not minimize the traffic 

impacts that were identified for the Draft SEIS/SEIR station site.

6 Refer to Master Response 6 for a discussion of the potential for spillover parking 

near the Balboa Avenue Station.

7 The prior environmental review proposed a noise barrier at Balboa Avenue and 

Morena Drive to reduce noise from the change in traffic circulation; however, based 

on the current, detailed analysis of the roadway and station design, no noise impact 

was identified at that location in the SEIS/SEIR. Chapter 4.0, Section 4.7.3 of the 

Draft SEIS/SEIR provided an updated evaluation of operational and traffic noise 

impacts that will result from the project near the Balboa Avenue Station. Refer to 

Master Response 7 with respect to noise impacts in the Morena Boulevard/Balboa 

Avenue area. The analysis indicates that no significant noise impacts are projected 

to occur at the Balboa Avenue Station, and thus no mitigation is required. Master 

Response 9 provides additional information regarding noise analysis and mitigation.

8 Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR includes an evaluation of 

construction noise impacts, project measures, and mitigation measures for the 

project. As identified in this section, the project will result in significant adverse 

construction noise impacts without mitigation. Mitigation Measure CON1 requires 

development and implementation of a Noise Control Plan, which will include 

analysis of existing noise levels, anticipated equipment to be used, noise levels at 

sensitive receivers, and “noise attenuation features as necessary, such as 

temporary sound walls, mufflers, and locating noisy equipment away from sensitive 

uses.” Contractors will be required to “take all feasible and reasonable efforts to 

reduce construction noise during nighttime hours.” 

The additional requirement that the contractor obtain a construction noise permit 

from the City of San Diego is an appropriate measure that includes a process to 

develop project-specific measures to minimize construction noise, and of 
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importance to residential uses, and absolute limit on construction noise that extends 

into property zoned residential during the 12-hour period from 7:00 a.m. to 7:00 p.m. 

(San Diego Municipal Code Section 59.5.0404(c)). The provisions that give the 

Administrator discretion to consider any number of factors when developing noise 

permit conditions do not render the process ineffective. They simply allow the 

Administrator reasonable flexibility to develop noise-reduction measure suited to a 

particular set of circumstances, including measures that are responsive to the 

character and nature of the neighborhood impacted. The city noise permit process, 

combined with the additional measures described above, provide adequate 

mitigation standards as required by CEQA. 

9 Refer to Master Response 5 regarding the potential relocation of the Balboa Avenue 

Station. 

Refer to the responses to Comments 7 and 8 regarding the noise analysis.

10 Refer to Master Response 5 for a discussion of the potential relocation of the 

Balboa Avenue Station. 

As stated in response to previous comments, changing the location of the station 

would not reduce the adverse or significant traffic impacts that were documented in 

the Draft SEIS/SEIR. Further, there are no significant noise impacts associated 

with the Draft SEIS/SEIR station site that would necessitate consideration of 

changing the station location. 

Refer to Master Response 6 regarding the potential for spillover parking near the 

Balboa Avenue Station.

11 Refer to the response to Comment 4 and Master Response 8 regarding traffic 

conditions under the Build Alternative, which include the reconfigured Balboa 

Avenue/Morena Boulevard ramps and introduction of traffic signals. As discussed 

in responses to Comments 4 and 5, there are no adverse or significant traffic 

impacts that would be minimized or eliminated by relocating the station.

12 As described in Master Response 5, convenient and efficient bus and auto access 

to the Trolley station is necessary to maximize ridership, and the City Yard site 

would increase travel time for bus routes and most autos. As stated in response to 

Comment 11, there are no adverse or significant traffic impacts that would be 

minimized or eliminated by locating the station at the City Yard site.

13 Chapter 4.0, Section 4.7.3 of the Draft SEIS/SEIR fully describes all operational 

noise impacts that will result from the project. Chapter 4.0, Figure 4-19 of the Final 

SEIS/SEIR identifies no significant impacts in the vicinity of the Balboa Avenue 

Station. Refer to the response to Comment 8 for a discussion of construction noise. 
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Refer to Master Response 7 for a discussion of noise impacts near the Balboa 

Avenue Station. Because no significant impacts will occur in this location during 

operation of the project, relocation of the station would not eliminate or reduce a 

significant impact.

14 Refer to Master Response 6 for a discussion of potential spillover parking near the 

Balboa Avenue Station.

15 As described in Master Response 5, constructing the Balboa Avenue Station south 

of Balboa Avenue as proposed in the Draft SEIS/SEIR will not preclude future 

development on the City Yard site. The pedestrian bridge that will be built as part of 

the Mid-Coast Corridor Transit Project will provide pedestrian access from the 

station to the City Yard site.

16 As described in Master Response 5, relocating the Balboa Station to the City 

Yard/Rose Canyon site was evaluated in response to comments received on the 

Draft SEIS/SEIR. Prior to the SANDAG Board of Directors’ action on November 15, 

2013, SANDAG staff presented the proposed Refined Build Alternative, with the 

recommendation to continue with the Balboa Avenue Station site from the Draft 

SEIS/SEIR. The SANDAG Board of Directors voted to approve the Refined Build 

Alternative as the project to be evaluated in the Mid-Coast Corridor Transit Project 

Final SEIS/SEIR, with the Balboa Avenue Station remaining south of Balboa 

Avenue on the Draft SEIS/SEIR site. 

 
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Barfield, Jeff, Chair - ID274 

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Barfield, Jeff, Chair - ID274 
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Barfield, Jeff, Chair - ID274 

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Barfield, Jeff, Chair - ID274 

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Barfield, Jeff, Chair - ID274 

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166 September 2014 

Submission ID274 Clairemont Community Planning Group Barfield Jeff

Com ID Response

1 The project description and design concerns referenced in this comment are 

addressed in detailed responses to the subsequent comments.

2 The proposed action was identified in the Abstract appearing at the front of the Draft 

SEIS/SEIR. Additionally, a summary description of the project and a map were 

provided in the Executive Summary, Section S.3.2 of the Draft SEIS/SEIR, and a 

more detailed description was provided in Chapter 2.0, Section 2.2.2 of the Draft 

SEIS/SEIR. The Refined Build Alternative, which is the proposed project, is 

described in Chapter 2.0, Section 2.4 of the Final SEIS/SEIR.

3 Although modifications to the pedestrian and bicycle facilities between Pacific Beach 

and the Balboa Avenue Station are beyond the scope of the project, three bus routes 

will provide a connection between the Balboa Avenue Station and Pacific Beach. As 

shown in Chapter 2.0, Table 2-6 of the Draft SEIS/SEIR, Routes 8, 9, and 27 will 

operate between the station and Pacific Beach, providing a means of access between 

the Balboa Avenue Station and Pacific Beach via bus. Consistent with current MTS 

practice, bicycles are allowed on Trolley vehicles and buses. Route 27 will be 

modified slightly along its route to connect to the Balboa Avenue Station. It will 

continue to serve Pacific Beach. 

As noted in the comment, no modifications are required for Routes 50 and 105 as 

they will already connect to Trolley stations. As shown in Chapter 2.0, Table 2-6 of 

the Draft SEIS/SEIR, Route 50 will provide service between the Clairemont Drive 

Station and the UTC Transit Center, while Route 105 will provide service to the OTTC 

and the Tecolote Road and UTC Transit Center Stations. The communities and 

destinations served by these routes are shown in Chapter 3.0, Table 3-3 of the Draft 

SEIS/SEIR. 

Four bus routes will provide connections between the Clairemont community and the 

new Trolley stations: Routes 27 and 44 will connect to the Balboa Avenue Station; 

Route 50 will connect to the Clairemont Drive Station; and Route 105 will connect to 

the Tecolote Road Station. 

As shown on Sheet 310 in the Final SEIS/SEIR Plan Set (Volume 2 of this Final 

SEIS/SEIR), an off-street bus bay will be provided on the eastern end of the 

Clairemont Drive Station park-and-ride facility. Access to the bus bay and park-andride will be via Clairemont Drive, as recommended in the comment. 

A bus stop midway between Denver Street and the I-5 bridge and a mid-block 

pedestrian crossing will not be provided as part of the project. The project will not 

preclude the future addition of this bus stop and crossing by the local agency that has 

jurisdiction over the street (the City of San Diego) and MTS if a need for such a stop 

is identified.
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4 Refer to Master Response 1 for a discussion of the pedestrian and bicycle 

connections included as part of the project. 

While there are currently no plans to incorporate the City of San Diego's bicycle share 

program as part of the project stations, station design will not preclude future 

incorporation of this program. Refer to Master Response 1 for a description of station 

amenities, including bicycle lockers. Consistent with current MTS policy, bicycles are 

permitted on Trolleys and buses. 

With respect to the comment regarding the inter-modal analysis of level of service for 

bus service within 1 mile of project stations, the transit analysis conducted for the 

project was based on service standards established by MTS and SANDAG. These 

standards, which correlate to the levels of service referenced in the comment, include 

service frequencies, hours of service, reliability, and crowding on vehicles, including 

buses and light rail vehicles. The results of this analysis are summarized in Chapter 

3.0, Section 3.4.1.2 of the Draft SEIS/SEIR and detailed in Chapter 4.0, Section 4.2 of 

the Mid-Coast Corridor Transit Project Transportation Impacts and Mitigation Report. 

Three bus routes (Routes 8, 9, and 27) will provide connections between the Balboa 

Avenue Station and Mission Bay. As shown in Chapter 3.0, Table 3-19 of the Draft 

SEIS/SEIR, transit performance will improve under the Build Alternative compared to 

conditions without the project. 

The pedestrian and bicycle analysis conducted for the project did not determine a 

level of service for biking or walking. However, the analysis considered whether the 

project would impact any existing or planned bicycle and pedestrian facilities, and 

identified whether the existing pedestrian facilities are adequate to support the 

increased pedestrian traffic from the project. Further, as shown in Chapter 4.0, Table 

4-69 of the Transportation Impacts and Mitigation Report, the analysis considered 

pedestrian connectivity near Trolley stations to determine if there were barriers to 

pedestrian access within one-quarter mile of each station area. Based on this 

analysis, as summarized in Chapter 3.0, Section 3.4.3 of the Draft SEIS/SEIR, the 

project will not result in adverse or significant impacts to bicycle or pedestrian 

facilities. 

As noted in Master Response 1, the project will add or enhance sidewalks or 

pedestrian connections where they are missing or inadequate in the immediate 

station area. At the Tecolote Road Station, this will include pedestrian ramps and 

stairs on the east side of West Morena Boulevard for access to the north and south 

sides of Tecolote Road and a new sidewalk on the east side of West Morena 

Boulevard to Knoxville Street (as shown in Chapter 2.0, Figure 2-12 of the Final 

SEIS/SEIR). At the Clairemont Drive Station, this includes new sidewalks on the west 

side of Morena Boulevard from the north side of the station platform to Gesner Street 

and on the east side of Morena Boulevard from Ingulf Street to north of Clairemont 

Drive (as shown in Chapter 2.0, Figure 2-13 of the Final SEIS/SEIR). 
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5 Refer to Master Response 4 regarding future development on the Clairemont Drive 

Station site. 

Two TPSS units will be constructed adjacent to the park-and-ride lot at the Clairemont 

Drive Station. Based on comments received on the Draft SEIS/SEIR, additional 

design measures have been incorporated to address screening of TPSS sites. The 

measures are described in Chapter 4.0, Section 4.4.3.2 of the Final SEIS/SEIR under 

the heading “Project Measures to Avoid or Minimize Impacts”. These design 

measures will apply to the TPSSs in the station area.

6 Refer to Master Response 6 regarding spillover parking at the Balboa Avenue Station.

No changes to the bus service described in the Draft SEIS/SEIR are proposed at this 

time. As stated in response to Comment 3, three bus routes will connect the Balboa 

Avenue Station to Pacific Beach and Mission Bay without the need for modifying 

routes. Additionally, two routes will connect this station to the Clairemont 

community—Route 27 and Route 44. The evaluation of the parking demand at the 

station factored in the bus connections to Pacific Beach and Clairemont.

7 In the Clairemont community, the project will have significant and adverse traffic 

impacts at one roadway segment (Balboa Avenue from the I-5 southbound on-ramp 

to the I-5 northbound off-ramp, where daily traffic will increase by less than 1 percent 

compared to the No-Build Alternative) and one intersection (Mission Bay Drive and 

Garnet Avenue, where an increased delay of 1 to 4 seconds over the No-Build 

Alternative will occur). Refer to Master Response 8 for a description of the mitigation 

measures considered for these locations. 

See the responses to Comments 3 and 6 regarding bus connections. The traffic 

analysis conducted for the project did not assume a diversion of trips from automobile 

to transit, and therefore the traffic analysis is conservative. As stated in response to 

Comment 6, two routes will connect the Clairemont Community to the Balboa Avenue 

Station. Additionally, Route 50 will connect this community to the Clairemont Drive 

Station, and Route 105 will connect the community to the Tecolote Road Station. No 

additional bus service is required to serve the community. 

Any modifications to the I-5 ramps near Balboa Avenue and Grand Avenue are 

outside the scope of this project because modifications are not required to 

accommodate the project. 

 
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Kane, Audrey, Association Manager – ID021 

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Colony La Paz Condo Association - 

Kane, Audrey, Association Manager – ID021 

 
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Kane, Audrey, Association Manager – ID021 

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170 September 2014 

Submission ID021 Colony La Paz Condo Association Kane Audrey 

Com ID Response

1 Your comment on the corrected address for the La Paz HOA has been noted. A copy 

of the Supplemental Environmental Impact Statement/Supplement to the Subsequent 

Environmental Impact Report regarding the San Diego fairy shrimp and the Final 

SEIS/SEIR was sent to the address provided in this comment. 

In the vicinity of the La Paz condominiums, the project alignment will be parallel to I-5, 

with portions located within Caltrans right-of-way. Some right-of-way acquisition 

(permanent and temporary construction easements) will be required within the open 

area on La Paz property adjacent to the Caltrans right-of-way.

 
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Mogilner, Geoffrey, Founder – ID099 

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Cosoy - 

Mogilner, Geoffrey, Founder – ID099 
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ID Response

1 The transportation analysis for the Mid-Coast Corridor Transit Project is based on 

the SANDAG Series 11 Model, as described in Chapter 2.0, Section 2.1 of the MidCoast Corridor Transit Project Transportation Impacts and Mitigation Report and not 

Destination Lindbergh. Destination Lindbergh is a separate endeavor, which was 

commissioned by the San Diego County Regional Airport Authority to consider the 

ultimate build-out of Lindbergh Field, and was accepted in 2009 by the Airport 

Authority Board for public distribution. 

2 It is assumed that the modifications referenced in the comment refer to the traffic 

mitigation measures for the Mid-Coast Corridor Transit Project proposed at Taylor 

Street/Rosecrans Street and Pacific Highway, as described in Chapter 3.0, Table 

3-26 of the Draft SEIS/SEIR (refer to Mitigation Measure TR8). Additional detail for 

this mitigation measure is shown in Chapter 6.0, Figures 6-8, 6-9, and 6-10 of the 

Transportation Impacts and Mitigation Report. The mitigation measure includes the 

following: 

 Add a second northbound right-turn lane (Pacific Highway) 

 Reconfigure eastbound approach to have a third through lane (Rosecrans 

Street) 

 Realign southern sidewalk east and west of intersection to preserve existing 

dedicated bus-only lane (Rosecrans Street, Taylor Street west of railroad tracks)

 Add exit phase to serve vehicles making an eastbound left turn, vehicles 

traveling eastbound and westbound through the intersection, and pedestrians 

crossing Pacific Highway 

 Lengthen northbound left-turn lane by 40 feet (Pacific Highway) 

 Modify southbound approach geometry to include a second left-turn lane for 

general purpose vehicles (Pacific Highway) 

 Change westbound left-turn phase from first movement served to be served later 

in the traffic cycle. 

Additionally, traffic signal phasing will be modified at Taylor Street and Congress 

Street (Mitigation Measure TR9 in Chapter 3.0, Table 3-26 of the Draft SEIS/SEIR), 

as follows: 

 Add exit phase to serve vehicles making an eastbound left turn, vehicles 

traveling eastbound and westbound through the intersection, and pedestrians 

crossing Pacific Highway 

The traffic analysis summarized in the Draft SEIS/SEIR identified the need for these 

mitigation measures, as shown in the Draft SEIS/SEIR, Chapter 3.0, Table 3-25. 

These mitigation measures are required to restore intersections near the Taylor 

Street grade crossing to an acceptable level of service (LOS), consistent with City of 
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ID Response

San Diego criteria. Based on City of San Diego criteria, mitigation measures are 

required when a project impacts the level of service and delay at an intersection, 

causing the intersection to operate at LOS E or LOS F with increased delay 

compared to the No-Build Alternative. With the additional Trolley crossings through 

the Taylor Street grade crossing under the Build Alternative, the delay at 

intersections near this crossing will increase compared to the No-Build Alternative 

and mitigation is required. Specifically, the mitigation measures proposed at this 

location are needed to mitigate impacts at the intersection of Jefferson Street and 

Rosecrans Street. 

The mitigation measures are required to offset impacts associated with the 

additional Trolley crossings. They are not designed to allow more regional traffic to 

use Taylor Street. The project will not increase the volume of traffic traveling 

through Old Town or the number of through lanes on Taylor Street beyond the 

intersection with Pacific Highway. The 2030 traffic volumes used to determine the 

project’s long-term impacts would occur with or without the Mid-Coast Corridor 

Transit Project. 

Further, the mitigation measures that improve operation at some intersections near 

the Taylor Street grade crossing will not alter the existing character of the historic 

community. Taylor Street, in its current condition, is already a busy four-lane street 

and is designated as a “major through street” by the Auto Circulation/Parking 

Concept graphic on page 79 of the Old Town San Diego Community Plan. The 

development standards and community plan objectives identify the need for a 

circulation system to bring people into the area. Thus, the planning documents for 

Old Town anticipate Taylor Street to be a major ingress and egress point to the 

community. 

Within Old Town San Diego, the street improvements and signal timing included as 

traffic mitigation measures (described above) are limited to the intersections of 

Taylor Street/Rosecrans Street at Pacific Highway and Taylor Street at Congress 

Street; mitigation does not require street improvements within areas of Old Town 

that promote visitor-serving and pedestrian-oriented uses, or residential areas. The 

mitigation measures are largely limited to the existing roadway right-of-way and will 

not substantially alter the cohesion of the community or land uses in Old Town. 

They will maintain acceptable conditions at intersections serving the Old Town area. 

Further, the project will support the planned district by broadening and expanding 

regional and visitor access into the historic community and state park via the Trolley.

The project will not result in long-term adverse impacts to pedestrian or bicycle 

facilities near this grade crossing. The traffic analysis completed for intersections 

near the Taylor Street grade crossing considered the pedestrian wait times at 

intersections (refer to Chapter 6.0, Section 6.1.2.2 of the Mid-Coast Corridor Transit 

Project Transportation Impacts and Mitigation Report for a description of the 
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analysis). As shown in Chapter 3.0, Table 3-26 of the Draft SEIS/SEIR and 

described above, Mitigation Measure TR8 will add an exit phase to serve 

pedestrians crossing Pacific Highway. This means that once a train (Trolley, 

Amtrak, COASTER, or freight) clears the grade crossing and the gates return to an 

upright position, pedestrians crossing Pacific Highway will be given the green “walk” 

signal. 

The FTA has determined that the project will result in “no adverse effect” on historic 

properties. Historic properties are cultural resources eligible for or listed in the 

National Register of Historic Places. The California State Historic Preservation 

Officer (SHPO) has concurred with this determination of no adverse effect in a letter 

dated April 9, 2014. 

3 Access to attractions and businesses in Old Town will not be adversely impacted by 

the project. The mitigation measures at Taylor Street will ensure that pedestrian 

and vehicle wait times at this intersection are not adversely affected. Further, the 

project will improve the accessibility of the attractions and businesses via the 

Trolley, and is also anticipated to reduce parking demand at the Old Town Transit 

Center when compared to conditions without the project. 

4 The project would not affect the history-based character of Old Town San Diego. 

The project will use the existing tracks and Trolley station at the OTTC and will not 

include any site development in the Old Town area. The project is entirely outside 

of the Old Town Historic District, which is limited to the boundaries of the Old Town 

State Park as defined in the Old Town San Diego Community Plan, with effects 

limited to implementation of the traffic mitigation measures described in response to 

Comment 2. As shown in the Final SEIS/SEIR Plan Set (Sheet 369) (available at 

www.sandag.org/midcoast), the traffic mitigation measures at Taylor Street will 

require a permanent acquisition of approximately 530 square feet from a private 

property at the southwest corner of Taylor Street/Rosecrans Street and Pacific 

Highway and a temporary construction easement from the State of California in the 

southeast corner of the intersection; neither parcel has a historic property 

associated with it and neither are affiliated with the old Caltrans building. Further, 

the 1972 Old Town San Diego Architectural and Site Development Standards and 

Criteria for Street Design do not prohibit, or even address, the mitigation measures 

at issue, intersection improvements to a major arterial roadway. The community 

plan objectives and development standards identify the need for a circulation 

system to bring people into the area and also identify visual examples of Trolleys 

operating in the area in the 1880s and 1890s (source: Section H Interior Circulation 

Standards [page 129] of the standards, Old San Diego Planned District Review 

Board, Old Town Architectural and Site Development Standards and Criteria, 

September 1972.). 
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5 The term “general purpose vehicles” is used to convey that there are no restrictions 

to the types of vehicles that can use the additional southbound left-turn lane that will 

be added as mitigation (compared to the existing eastbound “bus only” lane). Refer 

to the response to Comment 2 regarding the purpose of these mitigation measures. 

The project will not increase traffic volumes or truck traffic on roadways in Old Town.

6 Refer to the response to Comment 2 regarding traffic volumes and mitigation measures. 

Traffic mitigation measures associated with the project are located outside of the key 

areas of Old Town that promote visitor-serving and pedestrian-oriented uses. 

The mitigation measures will not increase the volume of vehicle traffic traveling 

through Old Town or the number of vehicle through lanes on Taylor Street beyond 

the intersection with Pacific Highway and will not impact pedestrian-orientated land 

uses. The mitigation measures properly acknowledge projected traffic and 

pedestrian volumes for the area and are designed to ensure increased Trolley 

crossings will not cause unreasonable vehicular and pedestrian delays. 

The mitigation measures that improve some intersections near the Taylor Street 

grade crossing will not alter the existing character of the historic community. As 

stated in response to Comment 2, Taylor Street in its current condition is already a 

busy four-lane street and is designated as a “major through street” by the Auto 

Circulation/Parking Concept graphic on page 79 of the Old Town San Diego 

Community Plan. The development standards and community plan objectives 

identify the need for a circulation system to bring people into the area. Thus, the 

planning documents for Old Town anticipate Taylor Street to be a major ingress and 

egress point to the community. 

 

Further, the project will support one of the public transit objectives in the Old Town 

San Diego Community Plan (i.e., “All studies involving public transit should include 

the consideration of Old Town San Diego as a prime tourist attraction” page 82). 

Old Town State Historic Park is recognized as a “major park and visitor attraction” in 

the corridor, as shown in Chapter 1.0, Section 1.2.2 of the Draft SEIS/SEIR and in 

Chapter 1.0 of the technical reports. Further, the project will support the district by 

broadening and expanding regional and visitor access into the historic community 

and state park via the Trolley, which will allow more visitors to access the park 

without increasing traffic or parking demand. 
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7 The mitigation measures will not create a barrier or adversely impact low-income 

populations within the Old Town community. As stated in Chapter 4.0, Section 

4.2.3.2 of the Draft SEIS/SEIR, “Because the Trolley Blue Line and other trains 

currently operate through these neighborhoods, continued operation under the Build 

Alternative and options, although more frequent, would not divide a community and 

would not represent an adverse impact.” 

Design measures included in the project will reduce gate down times for Trolleys 

and for the northbound COASTER and Amtrak trains traveling through the Taylor 

Street grade crossing. Under the Build Alternative, maximum gate down times 

could be half the maximum gate down times experienced under the No-Build 

Alternative. Additionally, the traffic mitigation measures described in response to 

Comment 2 include modifications to traffic signal timing and phasing at intersections 

adjacent to this grade crossing. As a result, these modifications will ensure that 

there are no adverse effects to vehicular and pedestrian movements across the 

Trolley and LOSSAN tracks at Taylor Street. 

The increased connectivity and mobility provided by the project will benefit transitdependent community members, offering improved access to jobs, education, and 

other opportunities. No disproportionate adverse effects will occur to low income or 

minority populations within the Old Town Community. 

8 Refer to the response to Comment 7 regarding community impacts. The comment 

incorrectly assumes that the mitigation measures will result in increased traffic 

volumes on Taylor Street; as discussed in response to Comment 2, the project will 

not increase the volume of traffic traveling through Old Town or the number of 

through lanes on Taylor Street beyond the intersection with Pacific Highway. The 

traffic mitigation will largely occur in existing transportation rights-of-way (refer to the 

response to Comment 4 regarding right-of-way requirements), which will not remove 

acreage north of Taylor Street from the rest of Old Town and will not create new 

barriers within the Old Town community. 

9 The mitigation measures will not increase the volume of traffic traveling through Old 

Town or the number of through lanes on Taylor Street beyond the intersection with 

Pacific Highway. Appropriate safety measures will be maintained for all vehicle, 

pedestrian, and bicycle crossings. The traffic signal cycles will be timed to allow for 

the elderly and disabled to safely cross the intersections as described in Chapter 

4.0, Section 4.3 of the Mid-Coast Corridor Transit Project Safety and Security 

Impacts Technical Report. 
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10 The mitigation measures will not increase the volume of traffic traveling through Old 

Town or the number of through lanes on Taylor Street beyond the intersection with 

Pacific Highway. They are designed to avoid pedestrian delays at intersections 

near the Taylor Street grade crossing. Accordingly, the mitigation measures will not 

impact the Caltrans parking lot or impede access from this parking lot to the 

attractions and facilities in Old Town. 

11 The project does not include construction of a pedestrian overpass in the Old Town 

San Diego area. 

12 The technical reports and Draft and Final SEIS/SEIR evaluated impacts from the 

extension of the Trolley Blue Line and proposed mitigation measures (Chapter 3.0, 

Table 3-26 of the Draft SEIS/SEIR) as needed to mitigate or minimize impacts from 

the project. The traffic mitigation measures proposed near the Taylor Street grade 

crossing will mitigate impacts from the project, specifically from the increase in the 

number of Trolley crossings through the grade crossing. The Mid-Coast Corridor 

Transit Project does not include the construction of an overpass in the Old Town 

San Diego area or change access to I-8, and the traffic mitigation measures were 

not designed to accommodate the overpass or I-8 change referenced in the 

comment. 

13 The mitigation measures will not increase the volume of traffic traveling through Old 

Town or the number of through lanes on Taylor Street beyond the intersection with 

Pacific Highway. The project and the traffic mitigation measures (Chapter 3.0, 

Table 3-26 of the Draft SEIS/SEIR) will not increase project-related vehicular traffic 

that would create an increased demand on public services or facilities. The project 

will provide an additional mode of access for visitors from areas north of the OTTC 

that could potentially reduce roadway traffic in this area and is anticipated to reduce 

parking demand at the OTTC. 

 
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1 SANDAG has complied with all requirements under NEPA and CEQA. Comments on 

individual elements of the NEPA and CEQA analyses are addressed in subsequent 

detailed responses.

2 The Draft SEIS/SEIR provides a detailed description of the project in Chapter 2.0, 

Section 2.2.2. The description is supported by design plans included in the Draft 

SEIS/SEIR Plan Set, provided as Volume 2 of the Draft SEIS/SEIR. More specific 

responses are provided to the more specific comments below.

3 The Executive Summary, Section S.0, Chapter 1.0, Section 1.1, and Chapter 2.0, 

Section 2.1.1 of the Draft SEIS/SEIR present the project background, including a 

detailed description of the prior environmental documents being supplemented (the 

1995 AA/DEIS/DEIR, the 1995 FEIR, and the 2001 FEIS). 

Chapter 3.0, Sections 3.0 and 3.4.7 and each subsection in Chapter 4.0 of the Draft 

SEIS/SEIR include a description of findings from the prior AA/DEIS/DEIR, the FEIS, 

and the FEIR. These subsections then state how the findings of the Draft SEIS/SEIR 

differ from those of the prior environmental documents. 

The project analyzed in the Draft SEIS/SEIR is not one component of a larger project. 

The analyses presented in the Draft SEIS/SEIR evaluate the whole of the project. In 

addition, potential cumulative impacts of the project, together with other reasonably 

foreseeable projects, are addressed (refer to Chapter 3.0, Section 3.4.6 and Chapter 

4.0, Section 4.19 of the Draft SEIS/SEIR).

4 A detailed analysis of land use impacts was provided in the Mid-Coast Corridor Transit 

Project Land Use Impacts Technical Report and summarized in Chapter 4.0, Section 

4.1 of the Draft SEIS/SEIR. As concluded in this section, the project will not result in 

land use impacts and mitigation is not required. 

The project incorporates design features, management policies, and mitigation 

measures that are consistent with the goals and objectives of the City of San Diego 

MSCP Subarea Plan. However, pursuant to applicable law governing independent 

agencies and the Cooperative Agreement for Project Review Procedures between 

SANDAG and the City of San Diego (SANDAG Document #5001195, City Document 

C-15015, August 17, 2009), the project is not subject to the discretionary authority of 

the city and, as such, is not subject to the MSCP process. Further, to the extent any 

portion of the project extends into an MHPA area, the project is a regional public 

facility anticipated in the MSCP and is a compatible land use within the subarea plan. 

The project is a regional public facility anticipated in the MSCP and is a compatible 

land use within the subarea plan. There will be 0.26 acre of long-term impacts to 

biological resources (wetland and Tier II vegetation communities) within the MHPA. 
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These impacts will be confined primarily to the existing MTS right-of-way, are relatively 

small areas, and will not represent the expansion of existing, or the introduction of 

new, land uses within the MHPA. Therefore, although limited impacts will occur within 

the MHPA, the project will be consistent with the MSCP, and, with mitigation, impacts 

are not considered adverse or significant. The location of impacts to biological 

resources is shown in Chapter 5.0 of the Mid-Coast Corridor Transit Project Biological 

Resources Technical Report, specifically in Chapter 5.0, Figures 5-1 and 5-2. The 

Draft SEIS/SEIR appropriately cites this technical report and summarizes the analysis 

and conclusions that are provided in more detail therein.

5 The project has been designed to minimize the impact on Rose Canyon Open Space 

Park, Marian Bear Memorial Park, the MHPA, and the Rose Creek Watershed. 

Elimination of LRT Alternative 3 after Scoping avoided potentially significant noise and 

visual impacts to Rose Canyon Open Space Park. The project has been designed to 

minimize impacts to recreation within Rose Canyon Open Space Park, Marian Bear 

Memorial Park, and the Rose Creek Watershed, and is located within existing MTS 

right-of-way. The two existing LOSSAN tracks within the MTS right-of-way currently 

support freight, COASTER, and Amtrak service, and the project alignment is separated 

from Rose Canyon Open Space Park by these two tracks. The nearest park trail is 

approximately 90 feet east of the MTS right-of-way at its closest point (approximately 

325 feet south of La Jolla Colony Drive). 

As noted in Chapter 4.0, Section 4.4.3 of the Final SEIS/SEIR, “The additional project 

features would not be visually prominent for recreational users because they would be 

adjacent to existing tracks, buildings, freeways, and above ground utilities, and 

mitigation measures would reduce the visual impact of retaining walls and tree and 

vegetation removal. Thus, with implementation of mitigation measures, the new 

project features would not contrast with the existing visual character or quality, and no 

adverse impacts would occur.” 

A detailed analysis of visual impacts was provided in the Mid-Coast Corridor Transit 

Project Visual Impacts Technical Report and summarized in Chapter 4.0, Section 4.4 

of the Draft SEIS/SEIR. For purposes of assessing visual and aesthetic impacts, the 

guidelines in the Visual Impact Assessment for Highway Projects (FHWA, 1988) were 

used, which is applicable to many types of transportation projects. 

Furthermore, in response to comments on the Draft SEIS/SEIR, SANDAG conducted a 

more detailed assessment of visual resource impacts within Rose Canyon Open 

Space Park and Marian Bear Memorial Park, which verified the conclusions reached in 

the Draft SEIS/SEIR that, with mitigation, no adverse or significant impacts will occur 

within the parks. Refer to Master Response 15 for information regarding the additional 

visual analysis for Rose Canyon Open Space Park. 
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Refer to Chapter 4.0, Section 4.4 of the Final SEIS/SEIR, the Visual Impacts Technical 

Report, and Master Response 15 for information regarding the visual analysis for Rose 

Canyon Open Space Park.

6 Refer to response to Comment 5 and to Master Response 15 for information regarding 

the visual analysis for Rose Canyon Open Space Park. None of the elements 

described in the comment would be located within Rose Canyon Open Space Park. 

Additionally, no aerial structures, bridges, retaining walls, shade shelters, passenger 

platforms, parking lots, or parking structures will be located adjacent to Rose Canyon 

Open Space Park. The visual impacts of catenary wires, off-site retaining walls, 

grading changes, and tree and vegetation removal to Rose Canyon Open Space Park 

were considered in the visual analysis; however, these project features will not be 

visually prominent for recreational users because they will be adjacent to existing 

tracks, buildings, freeways, and above ground utilities, and mitigation measures will 

reduce the visual impact of retaining walls and tree and vegetation removal. Thus, 

with implementation of mitigation measures, the new project features will not contrast 

with the existing visual character or quality, and no adverse impacts will occur. 

7 The commenter is referencing the section of the SEIS/SEIR that assesses the CEQA 

significance determination using the following thresholds: “would the project strongly 

contrast with the surrounding development or natural topography through excessive 

height, bulk, signage, or architectural projections” and “would the project significantly 

alter the natural landform in a manner that substantially degrades the visual character 

of the surrounding area.” These questions are assessed in Chapter 4.0, Section 

4.4.5.1 of the SEIS/SEIR. 

For the first threshold, the SEIS/SEIR assessed significant visual impacts associated with 

project structures and walls (higher than 6 feet and longer than 50 feet), including the 

impact of such walls on cyclists and pedestrians in Rose Canyon Open Space Park. 

For the second threshold, the SEIS/SEIR found that the project will have a less-thansignificant impact on landform quality, as the project “would not disturb steep hillsides 

and would not result in major topographic changes.” 

Refer to the responses to Comments 5 and 6 for additional information regarding the 

visual analysis and conclusions, which is evidence that the Draft SEIS/SEIR does 

discuss the impacts on Rose Canyon and its environs. Refer to Chapter 7.0 of the 

Visual Impacts Technical Report for additional details regarding the specific location 

and nature of project impacts. As stated in Chapter 7.0, Section 7.3 of the technical 

report and Chapter 4.0, Section 4.4.5 of the SEIS/SEIR, with the incorporation of 

mitigation, no adverse or significant visual impacts will occur as a result of the Build 

Alternative. 

Refer to Master Response 15 for information regarding the visual analysis for Rose 

Canyon Open Space Park.
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8 Refer to the responses to Comments 5 through 7 and to Master Response 15 for 

information regarding the visual analysis for Rose Canyon Open Space Park.

9 The air quality analysis is detailed and its conclusions are supported by substantial 

factual and technical information. The long-term air emissions under the Build 

Alternative are discussed in Chapter 4.0, Section 4.5.3.2, and the construction-related 

impacts are discussed in Section 4.17.3.2 under the heading “Air Quality Impacts” of 

the Draft SEIS/SEIR. Additional information is provided in the Mid-Coast Corridor 

Transit Project Air Quality Impacts Technical Report and the Mid-Coast Corridor 

Transit Project Construction Impacts Technical Report. As explained in Chapter 4.0, 

Section 4.5.3.2 and depicted in Table 4-8 of the Draft SEIS/SEIR, emissions burdens 

in the study area for all pollutants will be equal or lower under the Build Alternative 

than under the No-Build Alternative. 

The decrease in VMT is the result of additional transit use on the extended Trolley line 

and is based on extensive modeling that incorporates anticipated Trolley ridership, 

specifically using the SANDAG Series 11 Travel Demand Forecasting Model, as 

described in Chapter 3.0, Section 3.1 of the Draft SEIS/SEIR. The Series 11 model 

forecasts roadway and transit network use based upon growth projections and a 

number of quality control features that includes, among other things, calibrating and 

verifying the model assumptions against observed use of transit in the region (refer to 

Chapter 2.0, Section 2.1.1.1 of the Mid-Coast Corridor Transit Project Transportation 

Impacts and Mitigation Report). Chapter 4.0, Table 4-49 of the Transportation Impacts 

and Mitigation Report presents automobile VMT by roadway classification for the NoBuild and Build Alternatives. The largest decrease will occur on freeways followed by 

collector roadways. 

10 Chapter 4.0, Table 4-10 of the Draft SEIS/SEIR describes the land use categories 

used for the noise analysis. No land uses classified as Category I for noise exist in the 

study area. Rose Canyon Open Space was evaluated as a noise Category 3 land use 

per FTA guidelines. Category 3 land uses include areas “where it is important to avoid 

interference with such activities as speech, meditation, and concentration on reading 

material. Places for meditation or study associated with...campgrounds, and 

recreational facilities can be considered to be in this category.” Certain historical sites 

and parks also are included. As a recreational use, Rose Canyon Open Space Park 

was classified as a Category 3 land use. Refer to Chapter 5.0 of the Mid-Coast 

Corridor Transit Project Noise and Vibration Impacts Technical Report and Master 

Response 14 for information regarding the noise analysis for Rose Canyon Open 

Space Park.

11 The comments in the appended report are addressed individually in the subsequent 

comments (specifically in the responses to Comments 31 through 44).
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12 Chapter 4.0, Section 4.8.2.2 of the Draft SEIS/SEIR summarizes the more detailed 

information provided in the technical reports. In-depth information regarding wildlife 

corridors and habitat linkages are discussed in Chapter 4.0, Section 4.7.5 of the 

Biological Resources Technical Report, which includes a map and a discussion of 

MSCP cores and linkages. As described in Chapter 4.0, Section 4.7.5 of the Biological 

Resources Technical Report, Rose Canyon within the study area provides an avenue 

for local wildlife movement in a north–south direction between the portion of Rose 

Canyon to the east of I-5 and San Clemente Canyon to undeveloped lands on MCAS 

Miramar (as shown in Chapter 4.0, Figure 4-7), and acknowledges their function as 

regional wildlife corridors in the text. The undeveloped lands on MCAS Miramar 

provide the primary connection between these two east–west canyons. The portion of 

Rose Canyon within the study area does not connect areas to the east with areas 

farther to the west or south. The impacts of the project are located at the western 

limits of the Rose Canyon and San Clemente Canyon wildlife corridors, neither of 

which extend across the existing tracks or I-5, and will not affect east–west wildlife 

movement. 

13 The cumulative impact methodology is described in Chapter 3.0, Section 3.4.6 and 

Chapter 4.0, Section 4.19 of the Draft SEIS/SEIR. The cumulative analysis contained 

in the Draft SEIS/SEIR includes an analysis of both of the following: (1) projects that 

are either approved, or being considered for approval, by SANDAG, the City of San 

Diego, USCD, and/or other agencies (or anticipated to be submitted for consideration, 

including projects in the design phase or under construction), and (2) growth 

projections set forth in regional plans, including regional modeling plans. 

Various related environmental documents and regional plans were reviewed and used in 

the cumulative analysis as identified in Section 4.19. Regional capacity-enhancing 

highway and transit projects included in the 2030 No-Build and Build Alternatives are 

identified in Chapter 2.0, Section 2.2.1.1 of the Draft SEIS/SEIR. The final EIRs for the 

RCP, 2030 RTP, and 2050 RTP were considered. As noted in Chapter 4.0, Section 

4.19.1, footnote 16 of the Draft SEIS/SEIR, the 2050 RTP EIR was consulted for 

informational purposes but the analysis was not relied upon to determine the significance 

of the Mid-Coast Corridor Transit Project’s cumulative impacts. To be conservative and 

ensure that all potentially significant cumulative impacts were analyzed, the SEIS/SEIR 

considered cumulative impacts identified as significant in the RCP, 2030 RTP, and 2050 

RTP EIRs. For each cumulatively significant impact identified in these documents, the 

SEIS/SEIR did its own analysis and independently considered whether the Mid-Coast 

Corridor Transit Project would contribute to the impact, and if so, whether the project’s 

contribution would be considered cumulatively considerable or adverse. The SEIS/SEIR 

went further and considered several additional impact areas that were not identified as 

cumulatively significant in the prior environmental documents, such as hazardous 

materials, geotechnical, energy, and safety and security impacts. 
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14 Significant water supply impacts are not anticipated because the water supply needs 

for the project are minimal compared to development of housing units or commercial 

and industrial land uses, and will be limited to irrigation (e.g., landscaping) and 

maintenance (e.g., platform and vehicle cleaning) activities and are anticipated to be 

minimal (approximately 0.01 percent of the total regional water usage [San Diego 

County Water Authority Water Use, 2012]). Where feasible, reclaimed water will be 

used for construction and irrigation activities. Water supply needs by the project will 

be coordinated with the City of San Diego. 

Additionally, the project is consistent with the assumptions of the City of San Diego 

2010 Draft Urban Water Management Plan (City of San Diego, 2011) and will be well 

within available water supply capabilities outlined in that plan as the project represents 

a negligible fraction of the City of San Diego's water demand. Chapter 4.0, Section 

4.16.3.2 of the SEIS/SEIR has been revised to include a discussion of water supply.

15 No catenary wires or other project features will be within Rose Canyon Open Space 

Park. The Trolley alignment will be in the MTS right-of-way and separated from the 

Rose Canyon Open Space by two existing LOSSAN tracks. Fire risk will be low 

because tree branches will not overhang the catenary wires. There will be a minimum 

of 28 feet from the edge of track to the edge of the public right-of-way.

16 The project will reduce overall energy consumption. The 62,200 mBtus identified in 

Chapter 4.0, Table 4-27 of the Draft SEIS/SEIR represent total energy (automobiles on 

the roadways as well as Trolley energy use) in the study area for 2010. The 74,500 

mBtus represent the total energy (automobiles on roadways and Trolley) in the study 

area under the Build Alternative in 2030. This increase in energy use (from 62,200 to 

74,500 mBtus) is not caused by the project but is instead the result of growth in the 

study area from 2010–2030 and the overall roadway vehicle and Trolley energy use. 

To understand the incremental reduction of energy resulting from the project one must 

compare future energy use with and without the project, the 74,500 mBtus of the Build 

Alternative in 2030 should be compared with the 74,700 mBtus of the No-Build 

Alternative in 2030. The third and fourth columns of Table 4-27 show that the project 

will reduce overall energy use in the study area by 0.2 to 0.3 percent in 2030 and in 

the region by 0.5 to 0.6 percent in 2030. This is because the overall energy savings 

from reduced VMT on the roadways will be greater than the energy needed for the 

expanded Trolley system. Therefore, the Build Alternative will result in a beneficial 

energy impact. 

As discussed in Chapter 4.0, Section 4.12.3.2 of the Draft SEIS/SEIR, LRT operations 

under the Build Alternative are expected to require approximately 54 megawatt hours 

(183 mBtus) of electrical energy above the No-Build Alternative. In 2010, the demand 

for electrical energy in San Diego County was about 19 million megawatt hours. 

Because the demand of the project for electrical energy is a small fraction of the 

regional energy use, the project will not cause an adverse impact to the supply of 

electrical power and will not require construction of new electrical substations. 
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Modifications to existing substations may be required to provide power at the required 

locations along the alignment; however, this is part of standard operating practice and 

does not represent an impact to the utility infrastructure. 

Refer to the response to Comment 13 regarding the cumulative impact analysis.

17 The cumulative impacts assessment is documented in Chapter 3.0, Section 3.4.6 and 

Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR. The documents and projects 

consulted as part of this analysis are presented in Section 4.19.1 and include the 

LOSSAN Final EIS/EIR, which analyzed double tracking through the Mid-Coast 

Corridor. As detailed in Chapter 2.0, Section 2.2.1.1 of the Draft SEIS/SEIR, the longterm (2030) impacts of the project were evaluated in conjunction with major 

improvements listed in the 2030 RTP. 

As discussed in Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR, “The Build 

Alternative and options would not result in cumulative biological impacts. The Build 

Alternative is primarily located within a transportation corridor, does not conflict with 

the approved habitat conservation plan, and does not result in significant and 

unavoidable biological impacts.” Further, elimination of LRT Alternative 3 after scoping 

avoided potentially significant noise and visual impacts to Rose Canyon Open Space 

Park and eliminated all direct impacts to the park. Remaining impacts will be limited to 

indirect visual impacts that, with mitigation, will not be adverse or significant. The Build 

Alternative’s impact on MHPA habitat and wetland resources will be minimal. For 

impacts that do exist, the Refined Build Alternative will include mitigation that is 

consistent with the MSCP Plan (County of San Diego, 1998) and therefore will require 

mitigation for impacts to special-status vegetation communities (wetlands and Tier II–

III). Mitigation for impacts to waters and wetlands within the Rose Creek Watershed 

will be located within that watershed. It is reasonable to presume other projects will 

also adhere to the MSCP Plan. Further, the specific projects listed in the comment are 

to the east and physically separated from the Mid-Coast Corridor Transit Project, 

which does not follow the existing rail right-of-way through Rose Canyon. Thus, the 

projects would not combine with the Mid-Coast Corridor Transit Project to create any 

cumulative noise, light, visual, or shadow impacts to biological resources. Therefore, 

the Mid-Coast Corridor Transit Project is not expected to combine with other 

foreseeable projects in the region and cause cumulatively significant impacts to the 

Rose Canyon Open Space Park, the MHPA, or the watershed. 

Refer to Master Response 14 for information regarding the noise analysis for Rose 

Canyon Open Space Park. 

18 The Draft SEIS/SEIR adequately considered growth inducing impacts of the project. 

The Draft SEIS/SEIR concluded that future development around transit stations will be 

consistent with adopted land use plans and existing zoning regulations of the City of 

San Diego General Plan (refer to the Series 11: 2030 Regional Growth Forecast 

Update: Process and Model Documentation and the Regional Comprehensive Plan [as 
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described in Chapter 4.0, Section 4.18.2.2 of the Draft SEIS/SEIR], both of which 

anticipate implementation of the Mid-Coast Corridor Transit Project). Land use 

designations and zoning permit a higher density of development overall than currently 

exists near the anticipated stations; therefore, while density may be expected to 

increase, such development is anticipated to be consistent with adopted plans and 

policies. As indicated in Chapter 4.0, Section 4.1.1 of the Draft SEIS/SEIR, SANDAG 

is the MPO for the region for transportation planning and regional Smart Growth 

policies that integrate land use and transportation planning. The project is a vital part 

of regional transportation and land use planning. SB 375 emphasizes the importance 

of planning land use and transportation in concert. This project responds to both 

regional and local land use plans and policies. SANDAG does not have land use 

regulatory authority, which is the responsibility of each of the local jurisdictions (cities 

and county) in the region. In this case, the local entity or jurisdiction is the City of San 

Diego (refer to Chapter 4.0, Section 4.1.1 of the Draft SEIS/SEIR).

19 The discussion of environmental impacts to Environmental Justice (EJ) populations is 

consistent with Executive Order 12898 and subsequent FTA guidance. CEQA does 

not require consideration of impacts to EJ populations. Chapter 4.0, Section 4.20.1 

summarizes the regulatory requirements prescribed in FTA Circular 4703.1(a). The 

key element of the EJ analysis is to identify disproportionately high and adverse 

human health or environmental effects of the project on EJ populations. The 

determination of whether effects are disproportionately high and adverse takes into 

account mitigation measures, enhancement measures, and offsetting benefits to the 

affected EJ populations. The detailed presentation of the facts and analysis can be 

found in the Mid-Coast Corridor Transit Project Environmental Justice Technical 

Report.

The project alignment contains both EJ and non-EJ populations. The EJ analysis 

determined that EJ populations would benefit from the project and that 

disproportionate effects would only occur with the Genesee Avenue Design Option. 

On November 15, 2013, the SANDAG Board of Directors eliminated the Genesee 

Avenue Design Option from further consideration and, thus, it is not part of the project 

analyzed in the Final SEIS/SEIR. Consequently, the project will not result in 

disproportionate effects to EJ populations.

20 As stated in the response to Comment 5, the project has been designed to minimize 

the impacts to recreation within Rose Canyon Open Space Park, Marian Bear 

Memorial Park, and the Rose Creek Watershed, and is located within the existing MTS 

right-of-way. 

Chapter 4.0, Sections 4.2.2.3 and 4.2.3.2 (Community, Park, and Recreational 

Facilities), 4.4 (Visual Resources and Aesthetics), and 4.7 (Noise and Vibration) of the 

Draft SEIS/SEIR, and their related technical reports prepared in support of the Draft 

SEIS/SEIR, provided the factual support and analysis that is summarized in Chapter 

5.0 and form the basis for the conclusions presented in Chapter 5.0 of the Draft 
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SEIS/SEIR. The Section 4(f) findings are subject to concurrence by the City of San 

Diego. Final concurrence was received in February 2013; documentation is provided 

in Appendix C of the Final SEIS/SEIR. Chapter 5.0 of the Final SEIS/SEIR includes 

the FTA’s final Section 4(f) evaluation. 

Refer to Master Response 14 for information regarding the noise analysis for Rose 

Canyon Open Space Park. 

Refer to Master Response 15 for information regarding the visual analysis for Rose 

Canyon Open Space Park.

21 Refer to Master Response 14 for information regarding the noise analysis for Rose 

Canyon Open Space Park. The project will not result in significant noise impacts 

within Rose Canyon Open Space Park. 

22 Refer to Responses 5 through 7 and Master Response 15 for information regarding 

the visual analysis for Rose Canyon Open Space Park. With mitigation, the project will 

not affect any visual resources within the park, nor will it result in adverse changes to 

scenic views or viewing corridors in or near the park. The project will not impair 

aesthetic features or attributes of the park.

23 The project is not expected to affect the movement of wildlife within the study area and 

will not significantly impact wildlife using Rose Canyon and its associated habitats. As 

indicated in Chapter 5.0, Section 5.4.2 of the Draft SEIS/SEIR, the project will not 

physically encroach into Rose Canyon Open Space Park, nor will it disrupt access, 

significantly increase noise, or introduce visual changes that will diminish the use and 

enjoyment of the park. Impacts to habitat within Rose Canyon are limited to relatively 

narrow linear areas within or immediately adjacent to the existing MTS right-of-way, 

and larger patches of habitat will not be impacted. The majority of vegetation within 

the project area will not be affected. The project will not diminish the value of wildlife 

habitat or interfere with wildlife and waterfowl access to a wildlife refuge or reduce the 

use of the wildlife and waterfowl refuge. Wildlife movement adjacent to the railroad 

corridor is constrained in many locations as a result of topography and existing 

development. The increased frequency of trains will reduce the amount of time 

between trains, particularly during peak hours, which has the potential to disrupt 

wildlife movement. However, wildlife movement within this location occurs in a north–

south direction parallel to the tracks. The proximity of existing development along 

some portions of Rose Creek and the current operation of heavy rail trains indicate 

that wildlife have adapted to the existing level of disturbance, including periodic noise 

events. Therefore, the increased frequency of trains would not preclude wildlife 

movement adjacent to the alignment. 

A path along the east side of the open channel will remain and continue to allow for 

wildlife movement along the east side channel below SR 52. Additionally, the following 
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design features have been incorporated into the project to facilitate wildlife movement 

through the concrete-lined channel under SR 52. The channel has been designed with

a slight inclination toward the center of the channel. During dry seasons when the 

flows will be limited to irrigation runoff, the outer segments of the channel bottom will 

carry limited amounts of runoff and will continue to facilitate wildlife movement. The 

majority of riprap placed at the upstream and downstream ends of the proposed 

channel will not be grouted, which will allow sediment to fill gaps, creating a more 

natural and even surface for wildlife to cross. 

As noted in the discussion of mitigation measures for biological resources impacts 

(Chapter 4.0, Section 4.8.4 of the Final SEIS/SEIR), mitigation for impacts to wetlands 

within the Rose Creek watershed is proposed to occur in Rose Canyon through 

implementation of the Rose Creek Watershed Wetland, Riparian & Water Quality 

Restoration Opportunities Analysis (San Diego Earthworks, 2012). Implementing 

portions of this plan is expected to enhance the natural open space within Rose 

Canyon. 

Please refer to Master Response 16 for a discussion of mitigation for impacts to 

habitat within Rose Canyon Open Space Park.

24 The project will not increase the noise level in Rose Canyon Open Space Park by 

more than 3 dBA. Refer to Master Response 14 for information regarding the noise 

analysis for Rose Canyon Open Space Park. The noise analysis was conducted in 

accordance with the FTA guidelines in the Transit Noise and Vibration Impact 

Assessment Guidance Manual (FTA, 2006), which is specifically suited to evaluate 

impacts associated with light rail service levels. As the Mid-Coast Corridor Transit 

Project is seeking federal funding, FTA has federal authority over the project and, 

therefore, the FTA guidelines must be applied to the noise analysis. Additionally, FTA 

noise-impact criteria are the appropriate noise criteria for evaluating transit noise 

impacts, including those to noise-sensitive recreational land uses such as Rose 

Canyon. 

As described in further detail in Chapter 3.0 of the Noise and Vibration Impacts 

Technical Report, the noise model was calibrated to accurately reflect the type of 

vehicles and track currently in operation on the Trolley system. 

The comment compares Leq noise measurements to Lmax passby levels. Leq is a longterm averaged noise measurement. Lmax is the highest noise level, experienced for 

less than a second, when a train passes by. The two values are on different time 

scales and cannot be compared.
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25 The SEIS/SEIR and the documents they update, as discussed in Chapter 2.0, Section 

2.1 of the SEIS/SEIR and highlighted below, include a comprehensive and reasonable 

range of alternatives. The 1995 AA/DEIS/DEIR, the 1995 FEIR, and the 2001 FEIS 

included the following alternatives: 

1. No Build 

2. Transportation System Management 

3. Transportation System Management/Commuter Rail 

4. Commuter Rail Tunnel 

5. High Occupancy Vehicle (HOV) Lanes 

6. LRT—Genesee Alternative 

7. LRT—I-5 Alternative 

The Transportation System Management and Transportation System Management/ 

Commuter Rail alternatives were rejected because they were least effective at meeting 

project objectives and cost. The Commuter Rail Tunnel alternative was deemed 

infeasible due to cost and the difficulty in venting diesel fumes. The High Occupancy 

Vehicle (HOV) Lanes alternative was adopted along with an LRT Alternative. The 

HOV alternative was then separated from the Mid-Coast Corridor Project, and this 

project element was constructed by Caltrans. Finally, the LRT Genesee Alternative 

was rejected for, among other reasons, its impact on Rose Canyon. These 

alternatives were analyzed in the EIR certified in 1995 and the EIS for which a Record 

of Decision was issued in 2001. The SEIS/SEIR adds to the alternative analysis 

described above by considering an updated version of the LRT I-5 Alignment (the 

current Refined Build Alternative) and an updated No-Build Alternative. In summary, 

the alternatives considered in the prior environmental review and SEIS/SEIR included 

a broad range of alternative mode and alignment options to serve the transit needs of 

the Mid-Coast Corridor and constitute a reasonable range of alternatives in compliance 

with NEPA and CEQA. 

In addition, after completion of the 1995 and 2001 environmental processes and prior 

to initiation of the Draft SEIS/SEIR, 13 additional alternatives were evaluated and 

considered: i) a new TSM alternative, ii) seven LRT alternatives, iii) four BRT 

alternatives and iv) a commuter rail alternative. Some alternatives were deemed 

infeasible prior to initiation of scoping for the Draft SEIS/SEIR, and others were carried 

through the scoping process and resulted in some further refinement of the Build 

Alternative. One LRT alternative considered at this stage (LRT Alternative 3) revisited 

the alignment that would have traveled within the existing MTS right-of-way through 

Rose Canyon. During the CEQA scoping process, objection to LRT Alternative 3 was 

overwhelmingly related to the alternative's proximity to Rose Canyon Open Space 

Park and potential effects on open space. In consideration of comments received 

during CEQA scoping, including objections related to potential impacts to Rose 

Canyon Open Space Park, the SANDAG Board of Directors reconfirmed the previously 

adopted LPA (LRT Alternative 1) that does not travel through Rose Canyon Open 

Space Park. 
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The evaluation of alternatives considered during this phase is presented in the MidCoast Corridor Transit Project Comparative Evaluation of Alternatives Report. Chapter 

3.0 and Chapter 4.0 of this report include information related to the identification and 

screening of initial alternatives and the conceptual alternatives considered; Chapter 

6.0 presents the recommendation of alternatives to carry forward into scoping. The 

information is summarized in Chapter 2.0, Section 2.1.1 and Table 2-1 of the Draft 

SEIS/SEIR.

26 Chapter 4.0, Section 4.8.4 of the Draft SEIS/SEIR identifies mitigation measures to 

reduce biological impacts to a level below significance (Mitigation Measures BIO1, 

BIO2, BIO3, and BIO4). There is no improper deferral of analysis for mitigation 

measures because project impacts are identified, and mitigation for those impacts 

includes specification of performance standards (including mitigation ratios and 

payment of in-lieu fees). While deferral of analysis and mitigation is not allowed, 

identification of a performance standard is not considered deferral of mitigation since it 

specifies what will occur to address a specified impact. As indicated in Chapter 4.0, 

Section 4.8.4 of the Draft SEIS/SEIR, “Often the mitigation ratios are higher than 1:1, 

which accounts for temporary losses and may increase net habitat area.” Section 4.8.4 

also describes specific mitigation for impacts to wetland vegetation communities in the 

Rose Creek watershed, indicating that “Proposed mitigation includes implementing a 

portion of the restoration and creation opportunities identified in the Rose Creek 

Watershed Wetland, Riparian, and Water Quality Restoration Opportunities Analysis

(San Diego Earthworks, 2012).” The Rose Creek watershed has been identified as one 

of three off-site mitigation locations. Mitigation will be provided through the TransNet

Environmental Mitigation Program using one or more of the mitigation approaches in 

Mitigation Measures BIO1, BIO2, and BIO3. Mitigation for impacts related to 

jurisdictional wetlands and waters will be fulfilled through Mitigation Measure BIO4. 

The references to Chapter 4.0, Section 4.4 (pages 4-48 and 4-53) refer to the 

presentation of visual impacts in the Draft SEIS/SEIR. However, page 4-46 of the 

Draft SEIS/SEIR clarifies that, within Rose Canyon West and Rose Canyon North, “the 

additional project features would not be visually prominent because they would be 

adjacent to existing tracks, buildings, freeways, and above ground utilities, and 

mitigation measures would reduce the visual impact of retaining walls.” Thus, with 

implementation of mitigation measures, the new project features will not contrast with 

the existing visual character or quality, and no adverse impacts will occur. The 

reference to mitigation measures is not vague, as the specific measures are set out in 

Section 4.4.4 and include replacement of trees that are removed to accommodate the 

project and restoration of natural vegetation in areas subject to temporary construction 

impacts, as well as implementation of architectural design elements to mitigate 

impacts of retaining walls. Additional detail regarding the mitigation is provided in the 

Visual Impacts Technical Report. 
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27 All impacts to biological resources will be mitigated to below significance, in 

compliance with the mandates of CEQA. Further, as noted in the discussion of 

mitigation measures for biological resources impacts (Chapter 4.0, Section 4.8.4 of the 

Final SEIS/SEIR), mitigation for impacts to wetlands within the Rose Creek watershed 

is proposed to occur in Rose Canyon through implementation of the Rose Creek 

Watershed Wetland, Riparian & Water Quality Restoration Opportunities Analysis (San 

Diego Earthworks, 2012). Implementing portions of this plan is expected to enhance, 

not degrade, the natural open space within Rose Canyon. 

Refer to the response to Comment 26 regarding the biology mitigation. Master 

Response 16 provides additional information on this topic, including a discussion of 

agency coordination and coordination with the Rose Creek Watershed Alliance. 

Chapter 8.0 also summarizes the agency coordination and consultation that has 

occurred throughout the environmental phase of this project. 

28 Chapter 7.0, Section 7.7 of the Draft SEIS/SEIR identifies the environmentally superior 

alternative. This section indicates, "the analysis in this Draft SEIS/SEIR has found the 

Build Alternative to be environmentally superior to the No-Build Alternative." This 

section has been revised in the Final SEIS/SEIR in response to comments received on 

the Draft SEIS/SEIR to reflect changes made to the project definition (refer to Chapter 

7.0, Section 7.7 of the Final SEIS/SEIR). The Refined Build Alternative remains 

environmentally superior to the No-Build Alternative.

29 The objectives included in the purpose and need for the Mid-Coast Corridor Transit 

Project allowed for consideration of a broad range of alternatives (including entirely 

different transit modes) in compliance with CEQA and NEPA standards. See response 

to Comment 25. 

30 The Draft and Final SEIS/SEIR for the project have been completed in conformance 

with the requirements of NEPA and CEQA. As summarized in Chapter 8.0 of the Final 

SEIS/SEIR, the public was provided the opportunity to review and comment on the 

content of the Draft SEIS/SEIR, and the Final SEIS/SEIR includes responses to all 

substantive comments received by SANDAG and FTA. The Final SEIS/SEIR does not 

include significant new information regarding a new or substantially more severe 

significant or adverse impact and therefore recirculation of the Draft SEIS/SEIR is not 

required (CEQA Guidelines 15088.5).

31 Project-related noise impacts to Rose Canyon Open Space Park were not 

disregarded. Refer to Master Response 14 for information regarding the noise 

analysis for Rose Canyon Open Space Park.

32 The impact of Trolley operations to park users and wildlife movement within the MHPA 

was evaluated in the Noise and Vibration Impacts Technical Report and the Biological 

Resources Technical Report. Additional analysis was conducted for specific locations 
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in Rose Canyon Open Space Park in response to comments received on the Draft 

SEIS/SEIR; the analysis is documented in Master Response 14 and provides 

additional validation for the conclusions reached in the Draft SEIS/SEIR. 

33 Rail operations in the corridor will increase, as indicated in the Draft SEIS/SEIR (refer 

to Chapter 2.0, Table 2-5 for the Trolley operating plan under the No-Build and Build 

Alternatives). The cumulative impact assessment that was conducted for the project 

considered the impacts that will result from the increased number of trains from the 

project combined with the increased number of trains along the LOSSAN corridor, as it 

includes projects in the 2030 RTP (refer to Chapter 4.0, Section 4.19.1 of the Draft 

SEIS/SEIR). The biological resources analysis considers the increase in train 

frequency as well, and discusses the potential effects to nearby wildlife. The analysis 

for the project concluded that the project will not result in or contribute to cumulative 

adverse noise impacts to trail users or biological resources, including impacts within 

the MHPA (refer to Chapter 3.0 of the Noise and Vibration Impacts Technical Report 

for specific methodology and assumptions). See also Master Response 14 for 

information regarding the noise analysis for Rose Canyon Open Space Park.

34 TPSSs contain electrical equipment to convert high-voltage electricity to the voltage 

required to power the system. They include air conditioning equipment to cool the 

equipment. The noise impacts of TPSSs were detailed in Chapter 5.0, Section 5.1.3.3 

of the Noise and Vibration Impacts Technical Report and summarized in Chapter 4.0, 

Section 4.7.3 of the Draft SEIS/SEIR under the heading "Stationary Source Noise 

Levels." A noise analysis was conducted for TPSSs located near sensitive noise 

clusters. The noise impacts of the TPPS sites were evaluated for noise-sensitive sites 

(refer to Chapter 5.0, Section 5.1.3.3 of the Noise and Vibration Impacts Technical 

Report). TPSS sites typically create a noise level of 45 dBA at 50 feet from the 

substation, which will be within city land use compatibility criteria for parks. TPSS 13 

(now referred to as TPSS 11 in the Final SEIS/SEIR) south of La Jolla Colony Drive 

will not be relocated from the site presented in the Draft SEIS/SEIR. The TPSS is 

required in this location based on the results of the load-flow analysis. This TPSS is 

approximately 150 feet from the nearest hiking trail (referred to as the San Clemente 

hiking trail in Google Maps).

35 As stated in the response to Comment 5, the project has been designed to minimize 

the impact on Rose Canyon Open Space Park. As noted by the commenter, the 

primary noise source in Rose Canyon is I-5, and the noise it generates is ongoing and 

continuous. Trolleys will not substantially alter the existing noise environment. Refer 

to the response to Comment 24 for a summary of the noise methodology used for the 

Mid-Coast Corridor Transit Project. 

The analysis for the project concluded that the project will not exceed FTA noise 

impact criteria for moderate or severe noise impacts or result in or contribute to 

cumulative adverse noise impacts to trail users or biological resources, including 
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impacts within the MHPA. The noise analysis accounts for the noise generated by 

Trolley passbys considering the speed and frequency of the operations. The 

additional noise generated by the project will increase the total noise level by less than 

0.5 dBA at the modeled receiver sites, which is less than significant. Changes in 

sound levels of less than 3 dBA are generally not noticeable to people with normal 

hearing sensitivity. 

Refer to Master Response 14 for information regarding the noise analysis for Rose 

Canyon Open Space Park.

36 Refer to Master Response 14 for information regarding the noise analysis for Rose 

Canyon Open Space Park for both recreational users and biological resources. The 

maximum passby level is not the noise level associated with noise impacts. Noise 

impacts are assessed for parklands using the 1 hour Leq. In addition, only the noise 

levels at the location of noise-sensitive frequent human use relate to impact 

determinations under FTA criteria. As stated in Master Response 14, the project will 

introduce project-generated noise levels of between 45 dBA Leq(h) and 50 dBA Leq(h)

within Rose Canyon Open Space Park (Receiver Clusters 56c through 56g in Chapter 

5.0, Table 5-5 of the Noise and Vibration Impacts Technical Report). These clusters 

range from 195 to 415 feet from the Trolley tracks. Refer also to the response to 

Comment 37 regarding the noise analysis for wildlife areas. 

MTS maintenance policy is applicable to the entire Trolley system. Trolley passbys 

will be no louder in this location than for other parts of the system. The sound level 

decreases with distance from the track. Trolley passbys will be quieter than existing 

LOSSAN operations. As stated in Chapter 3.0, Section 3.3.1.1 of the Noise and 

Vibration Impacts Technical Report, predictions of the light rail vehicle noise for the 

Mid-Coast Corridor Transit Project are based on measurements of the noise generated 

by LRT operations on the Trolley Orange Line where the vehicles are the same as, or 

similar to, vehicles that will be operating in the future. 

37 Based on comments received on the Draft SEIS/SEIR, supplemental noise 

measurements were performed within Rose Canyon Open Space Park in order to 

ensure that impacts within open space recreational areas and preserved wildlife 

habitat areas are appropriately characterized. The project is located within existing 

MTS right-of-way adjacent to the existing tracks and freeways where noise impacts are 

less intrusive to recreational users and wildlife resources. The ambient noise level on 

the trail near the project (approximately 90 feet east of the MTS right-of-way and 325 

feet south of La Jolla Colony Drive) was found to be 64 dBA Leq. Additional 

measurements in other nearby areas ranged from 59-62 dBA Leq. Project noise 

exposure levels will range between 45 and 50 dBA Leq at these locations (refer to the 

Noise and Vibration Impacts Technical Report for more detail regarding locations). 

Considering the ambient noise levels in this area of the park, the noise impacts will not 

result in or contribute to cumulative adverse noise impacts to trail users or biological 

resources, including impacts within the MHPA in Rose Canyon Open Space Park. 
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Refer to Master Response 14 for information regarding the noise analysis for Rose 

Canyon Open Space Park.

38 Refer to Response 37 and Master Response 14 for information regarding the noise 

analysis for Rose Canyon Open Space Park. The Draft SEIS/SEIR acknowledged that 

Rose Canyon is within the city’s MHPA and noise impacts to biological resources were 

assessed in the Biological Resources Technical Report rather than within the Noise 

and Vibration Impacts Technical Report. 

Project noise is predicted to be between 45 and 50 dBA Leq, well under the 60 dBA 

threshold referenced in the comment. Ambient noise levels were measured from 59 to 

64 dBA at various locations within Rose Canyon Open Space Park (refer to the Noise 

and Vibration Impacts Technical Report for details regarding these locations and 

measurements). 

Mitigation for impacts to habitat within Rose Canyon Open Space Park is described in 

Master Response 16. 

39 The project incorporates design features, management policies, and mitigation 

measures that are consistent with the goals and objectives of the City of San Diego 

MSCP subarea plan. However, pursuant to applicable law governing independent 

agencies and the Cooperative Agreement for Project Review Procedures between 

SANDAG and the City of San Diego (SANDAG Document #5001195, City Document 

C-15015, August 17, 2009), the project is not subject to the discretionary authority of 

the city and, as such, is not subject to the MSCP process. Further, to the extent any 

portion of the project extends into an MHPA area, the project is a regional public 

facility anticipated in the MSCP and is a compatible land use within the subarea plan. 

As stated in the responses to previous comments, the project will not result in 

moderate or severe noise impacts to Rose Canyon Open Space Park, and therefore a 

berm is not needed as mitigation for these impacts. Refer to Master Response 17 for 

information on the potential to construct a berm. 

Refer to Master Response 16 for a description of mitigation for impacts to habitat 

within Rose Canyon Open Space Park. 

40 Refer to Master Response 14 for information regarding the noise analysis for Rose 

Canyon Open Space Park. The noise measurements by Eiler and Associates that 

show high ambient noise levels are consistent with the analysis for the Mid-Coast 

Corridor Transit Project. For the purposes of the analysis, Rose Canyon Open Space 

Park is considered to be a noise Category 3 land use. The existing use of the park is 

not consistent with designation as a noise Category 1 land use. Using the ambient 

noise measurement of 66 dBA provided by the commenter, a moderate impact would 

occur if the project would increase the noise levels to 67 to 72 dBA Leq. Project noise 
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will be below these thresholds; therefore the reported measurements confirm the 

analysis in the Final SEIS/SEIR and supporting technical report.

41 Refer to Master Response 14 for information regarding the noise analysis for Rose 

Canyon Open Space Park. 

The mentioned Ldn calculator is not applicable to parklands, which are evaluated using 

an Leq(h) not an Ldn noise metric. The comment compares Leq noise measurements to 

Lmax passby levels. Leq is a long-term averaged noise measurement. Lmax is the 

highest noise level, experienced for less than a second, when a train passes by. The 

two values use different time scales and cannot be compared.

42 The project will not create a 69 dBA noise level at noise-sensitive locations within 

Rose Canyon Open Space Park. Refer to Master Response 14 for information 

regarding the noise analysis for Rose Canyon Open Space Park, which includes the 

project-generated noise levels within Rose Canyon Open Space Park.

43 Refer to Master Response 14 for information regarding the noise analysis for Rose 

Canyon Open Space Park and Master Response 17 regarding the construction of a 

berm. 

44 Refer to Response 37 and Master Response 14 for information regarding the noise 

analysis for Rose Canyon Open Space Park.

 
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1 One copy of the CD containing Volumes 1 and 2 of the Draft SEIS/SEIR was 

provided to Everett DeLano in June 2013 as requested.

 
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1 The copies of the CD containing Volumes 1 and 2 of the Draft SEIS/SEIR and DVDs 

containing the technical reports and memoranda were provided to Deborah Miller 

and Deborah Knight in June 2013 as requested.

 
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1 The comment expressing support of the project alignment is acknowledged. LRT 

Alternative 3 was eliminated from consideration in July 2010 after CEQA scoping as a 

result, in part, of concerns expressed by the public about potential impacts to Rose 

Canyon Open Space Park. 

2 The project has been designed to minimize the impact on Rose Canyon Open Space 

Park, Marian Bear Memorial Park, the MHPA, and the Rose Creek Watershed. 

Elimination of LRT Alternative 3 after Scoping avoided potentially significant noise and 

visual impacts to Rose Canyon Open Space Park. The project has been designed to 

minimize the impacts to recreation within Rose Canyon Open Space Park, Marian 

Bear Memorial Park, and the Rose Creek Watershed and is located within the existing 

MTS right-of-way. The two existing LOSSAN tracks within the MTS right-of-way 

currently support freight, COASTER, and Amtrak service, and the project alignment is 

separated from Rose Canyon Open Space Park by these two tracks. The nearest 

park trail is approximately 90 feet east of the MTS right-of-way at its closest point 

(approximately 325 feet south of La Jolla Colony Drive). 

As noted in Chapter 4.0, Section 4.4.3.2 of the Final SEIS/SEIR, “The additional 

project features would not be visually prominent for recreational users because they 

would be adjacent to existing tracks, buildings, freeways, and above ground utilities, 

and mitigation measures would reduce the visual impact of retaining walls and tree 

and vegetation removal. Thus, with implementation of mitigation measures, the new 

project features would not contrast with the existing visual character or quality, and no 

adverse impacts would occur.” Refer to the response to Comment 6 for additional 

information on views of the project from trails in Rose Canyon Open Space Park. 

The section of the project alignment near Rose Canyon will not include any lighting 

elements or fixtures. Refer to Master Response 13 and the response to Comment 9 

for a discussion of project lighting impacts. Refer to Master Reponses 14 through 16 

for information regarding the noise and visual analysis for Rose Canyon Open Space 

Park and the discussion of habitat mitigation for impacts within Rose Canyon Open 

Space Park. The noise analysis for the Draft SEIS/SEIR included an evaluation of the 

trails within Marian Bear Memorial Park (Cluster 56b), as documented in the MidCoast Corridor Transit Project Noise and Vibration Impacts Technical Report and in 

Chapter 4.0, Section 4.7.3.2 of the Draft SEIS/SEIR. The Draft SEIS/SEIR concluded 

that with implementation of Mitigation Measure N2, as described in Chapter 4.0, Table 

4-14 of the Draft SEIS/SEIR, there will be no moderate noise impacts to Marian Bear 

Memorial Park. Refinements made to the Build Alternative after circulation of the Draft 

SEIS/SEIR eliminated the moderate noise impacts to Marian Bear Memorial Park and 

mitigation is not required. Refer to Master Response 14 for additional information on 

the noise analysis for Rose Canyon Open Space Park. 
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Chapter 4.0, Section 4.8.3.2 of the Draft SEIS/SEIR describes the impacts on the 

wildlife corridor and habitat linkages, including the direct and indirect impacts to the 

MHPA (see also the Mid-Coast Corridor Transit Project Biological Resources 

Technical Report). Chapter 4.0, Section 4.8.4 of the Draft SEIS/SEIR describes the 

mitigation measures for impacts on biological resources. With implementation of the 

identified mitigation measures, impacts on biological resources will be reduced to a 

less-than-significant level, as described in Chapter 4.0, Section 4.8.5.2 of the Draft 

SEIS/SEIR. 

3 The comment regarding community enjoyment of the parks and the value of the parks to 

wildlife will be part of the record of proceedings for the Draft SEIS/SEIR. The value of the 

parks in providing recreational and wildlife benefits is acknowledged in the Section 4(f) 

Evaluation, which is documented in Chapter 5.0 of the Draft SEIS/SEIR. Section 4(f), as 

amended, of the U.S. Department of Transportation Act of 1966 (United States Code 

1983) protects public parklands and recreational lands, wildlife refuges, and historic sites 

of national, state, or local significance, commonly referred to as Section 4(f) properties or 

resources. As defined in Section 4(f), there will be no use of Rose Canyon Open Space 

Park but there will be a de minimis impact on Marian Bear Memorial Park. However, the 

de minimis finding reflects that the use of Marian Bear Memorial Park will not adversely 

affect the significant recreational activities, features, or attributes that qualify the park for 

protection under Section 4(f). Refer to Chapter 5.0 of the Draft SEIS/SEIR for information 

regarding the Section 4(f) use of Rose Canyon Open Space Park and Marian Bear 

Memorial Park. 

As discussed in the response to Comment 2, elimination of LRT Alternative 3 after 

Scoping avoided potentially significant noise and visual impacts to Rose Canyon Open 

Space Park. The project will not acquire any parkland from Rose Canyon Open Space 

Park nor will any project component be located within the park. The project incorporates 

design features, management policies, and mitigation measures that are consistent with 

the goals and objectives of the City of San Diego MSCP Subarea Plan. As noted in the 

discussion of mitigation measures for biological resource impacts (Chapter 4.0, Section 

4.8.4 of the Draft SEIS/SEIR), mitigation for impacts to wetlands within the Rose Creek 

watershed is proposed to occur in Rose Canyon through implementation of the Rose 

Creek Watershed Wetland, Riparian & Water Quality Restoration Opportunities Analysis

(San Diego Earthworks, 2012). Implementing portions of this plan is expected to 

enhance, not degrade, the natural open space within Rose Canyon. Finally, refinements 

made to the Build Alternative eliminated the moderate noise impacts to Marian Bear 

Memorial Park. 

4 The comment regarding the value and purpose of Rose Canyon Open Space Park will 

be part of the record of proceedings for the Draft SEIS/SEIR. The project will not 

conflict with the purpose of Rose Canyon Open Space Park. 
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5 Refer to Master Response 15 for information regarding the visual analysis for Rose 

Canyon Open Space Park, as well as responses to Comments 2 and 6 regarding 

visual impacts and mitigation. 

In response to comments on the Draft SEIS/SEIR, SANDAG conducted a more 

detailed assessment of visual resource impacts within Rose Canyon Open Space Park 

and Marian Bear Memorial Park, both of which are within the MHPA. The additional 

analysis verified the conclusions reached in the Draft SEIS/SEIR that, with mitigation, 

no adverse or significant impacts would occur within the parks. Refer to Master 

Response 15 for information regarding the additional visual analysis for Rose Canyon 

Open Space Park. 

6 As discussed in the response to Comment 2, the project has been designed to 

minimize the impacts to recreation within Rose Canyon Open Space Park and is 

located within the existing MTS right-of-way. Refer to Master Response 15 for 

information regarding the visual analysis for Rose Canyon Open Space Park. 

The simulations prepared by the commenter, as provided with the July 17, 2013 

submission, do not accurately represent the location and scale of the project. 

SANDAG prepared simulations from viewpoints along the trail at the same locations 

used by the commenter, to illustrate how the Trolley will appear to trail users in Rose 

Canyon Open Space Park (see Simulations 1 and 2 attached to this response, which 

show the same locations as Attachments 2 and 4 of the comment letter). 

The Trolley in the commenter’s simulations is incorrectly located on the LOSSAN 

tracks. In comparison, Key Views G, H, and I in Appendix D of the Mid-Coast Corridor 

Transit Project Visual Impacts Technical Report show an Amtrak train on the LOSSAN 

tracks as seen from the same trail location within Rose Canyon Open Space Park 

(Key View I is shown as the “before” for Simulation 1 at the end of this letter, while Key 

View G is shown as the “before” for Simulation 2). The Trolley shown in the 

commenter’s simulations appears to be vertically exaggerated and is significantly 

larger than the Amtrak trains shown in Key Views G and I. The Amtrak and 

COASTER trains traveling through the corridor are double-decker trains, while the 

Trolleys are a single-level cab. The Amtrak and COASTER trains currently operating 

in the Mid-Cost Corridor are taller than the Trolley vehicles. 

As viewed from the trail, the Trolley tracks will be located farther to the west on the 

other side of the LOSSAN tracks, toward the I-5 off-ramp. At the location shown in 

Simulation 1 and Attachment 2 of the comment letter, the Trolley tracks will be 

approximately 325 feet from trail users. As shown in Simulation 1, while the catenary 

poles and wires will be visible from the trail, the Trolley vehicle is barely visible above 

the vegetation. This is due to the change in topography, existing vegetation, and the 

project alignment beginning its decent into the tunnel under La Jolla Colony Drive. 

The catenary poles and wires are typical features in this area (as seen, there are 

already a number of utility lines and poles in this area). 
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At the location shown in Simulation 2 and Attachment 4 of the comment letter, the 

Trolley tracks will be approximately 300 feet from the viewer. An Amtrak train is 

shown in the new simulation prepared in response to this comment. As shown in 

Simulation 2, the Amtrak train will be larger than the Trolley vehicle. Further, existing 

vegetation will block portions of the Trolley vehicle. Similar to Simulation 1, existing 

utility lines are currently visible in this area. 

The simulations prepared by SANDAG support the conclusions presented in the Draft 

SEIS/SEIR that the project, with mitigation, will not adversely or significantly impact 

views of users in Rose Canyon Open Space Park. The project, if visible, will be a 

minor portion of the viewshed for trail users and will not result in significant visual 

impacts with the implementation of mitigation. 

7 Sheets 84 and 85 of the Final SEIS/SEIR Plan Set show the location of the LOSSAN 

tracks near Rose Canyon Open Space Park. Immediately north of SR 52, the 

LOSSAN tracks will be realigned about 10 feet to the east within the MTS right-of-way. 

At one location, the closest trail in Rose Canyon Open Space Park will be 

approximately 100 feet from the realigned LOSSAN tracks; however, there is a 

significant amount of existing vegetation between the MTS right-of-way and the trail 

screening the project corridor from trail users. At a minimum distance of 100 feet, the 

realignment of the LOSSAN tracks by 10 feet in this area will not result in a substantial 

visual change for trail users compared to existing conditions; therefore, no visual 

impacts will occur. 

Refer to Master Response 15 for information regarding the visual analysis for Rose 

Canyon Open Space Park and the responses to Comments 2, 5, and 6 regarding the 

visual analysis for park users. 

 

The Draft SEIS/SEIR incorporates a variety of measures to avoid and minimize 

impacts to Rose Canyon Open Space Park, as listed throughout Chapter 3.0 and 

Chapter 4.0. Visual mitigation measures will be applied where appropriate along the 

entire alignment (not just at key views), including measures related to landscaping and 

design (Mitigation Measures VR4 and VR5). Mitigation measures that will benefit park 

users include replacement of trees that are removed to accommodate the project 

(Mitigation Measure VR6), use of non-invasive plants (native plants) wherever 

appropriate (Mitigation Measure VR7), restoration of natural vegetation in areas 

subject to temporary construction impacts (Mitigation Measures CON9 and CON10), 

locating wetland mitigation sites in Rose Canyon, facilitating bicycle and pedestrian 

access during and after project construction (Mitigation Measure TCON1), and public 

outreach. In addition, SANDAG has incorporated project measures that provide for 

appropriate landscape screening to ensure that the TPSS will be visually screened 

from trails within Rose Canyon Open Space Park. These project measures are 

described in Chapter 4.0, Section 4.4.3.2 of the Final SEIS/SEIR under the heading 

“Project Measures to Avoid or Minimize Impacts.” 
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8 Refer to the response to Comment 7. As stated in Chapter 4.0, Section 4.8.3.2 of the 

Draft SEIS/SEIR, during final design, the project’s footprint will be further reviewed 

and, where possible, the footprint will be minimized to reduce impacts to vegetation. 

9 Refer to Master Response 13 for a discussion of project lighting impacts. 

The section of the project alignment near Rose Canyon will not include any lighting 

elements or fixtures. Any light fixtures adjacent to natural areas will be minimal, and 

any lights will be shielded to direct the light source directly down and away from 

natural areas to reduce any indirect lighting or spillover lighting. Stations are not 

proposed adjacent to the MHPA; therefore, potential sources of lighting from the 

project will be limited to train headlights moving along the alignment. Train headlights 

will be directed straight ahead, however, and will not substantially increase the extent 

of lighting in adjacent habitat areas in the MHPA. Currently, all Trolley cars have 

tinted windows to screen indoor lighting, and it is anticipated future vehicles will have 

similar design features. The existing levels of lighting within adjacent habitat areas 

are not expected to substantially increase from current levels. Therefore, indirect 

impacts on species listed or proposed as federally threatened or endangered, 

including coastal California gnatcatcher and other special-status wildlife species, 

caused by lighting will not be adverse. 

Some lighting will be required during construction. As stated in Chapter 4.0, Section 

4.17.3.2 of the Draft SEIS/SEIR, “The Rose Creek Bicycle Trail and adjacent disturbed 

upland areas would remain accessible during construction and would allow limited 

wildlife movement through the area. By minimizing nighttime construction activity 

whenever feasible and using shielded lights for nighttime security lighting in the area, 

the use of the area by nocturnal species is unlikely to be significantly affected.” 

10 As stated in the response to Comment 2, the project is located within existing MTS 

right-of-way and the project alignment is separated from the park by two LOSSAN 

tracks. Although noise impacts have been minimized, the project may still be audible 

to trail users at some locations within Rose Canyon Open Space Park, depending on 

the topography and distance of the trail user from the project. However, noise impacts 

will not be significant. Refer to Master Response 14 for additional information on the 

noise analysis within Rose Canyon Open Space Park. As stated in this master 

response, mitigation for noise impacts is not required because noise impacts will not 

be significant. 

The cumulative impact assessment that was conducted for the project considered the 

impacts that will result from the project combined with the increased number of trains 

along the LOSSAN corridor, as it includes projects in the 2030 RTP (refer to Chapter 

4.0, Section 4.19.1 of the Draft SEIS/SEIR). The biological resources analysis 

considers the increase in train frequency as well, and discusses the potential effects to 

nearby wildlife. 
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The impact of Trolley operations to park users and wildlife movement within the MHPA 

was evaluated in the Noise and Vibration Impacts Technical Report and the Biological 

Resources Technical Report. Additional analysis was conducted for specific locations 

in Rose Canyon Open Space in response to comments received on the Draft 

SEIS/SEIR; the analysis is documented in Master Response 14 and provides 

additional validation for the conclusions reached in the Draft SEIS/SEIR. 

Refer to the response to Comment 12 and Master Response 17 regarding construction 

of a berm. 

11 SANDAG will coordinate with MTS, NCTD, and the City of San Diego to identify any 

concerns or opportunities regarding weed control. 

As described in Chapter 4.0, Section 4.8.3.2 of the Draft SEIS/SEIR, “implementation 

of the project is not expected to introduce invasive plants into natural open spaces.” 

Although station areas will include landscaping, these areas are not near or adjacent 

to natural open space areas that are susceptible to the introduction of invasive plant 

species. During construction, invasive plant species could be introduced into adjacent 

natural open space areas via the transport of seeds or other plant propagules on 

construction vehicles and equipment. However, construction vehicles and equipment 

will be washed prior to working in areas where sensitive vegetation communities are 

present adjacent to the project. 

In addition, Chapter 4.0, Section 4.4.4 of the Final SEIS/SEIR (Mitigation Measure 

VR7) states: “All new plantings, regardless of location, would not include invasive 

plants or noxious weeds, but would include native and/or drought-resistant plants 

wherever appropriate.” 

12 As stated in the responses to previous comments, the project will not result in 

significant noise impacts, and with mitigation, will not result in adverse visual impacts 

on Rose Canyon Open Space Park. As a result, a berm is not needed as mitigation 

for these impacts. Refer to Master Response 17 for information regarding the 

potential to construct a berm. 

Refer to Master Response 13 for a discussion of lighting impacts. The project will not 

include any permanent light elements or fixtures in Rose Canyon Open Space Park. 
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13 In response to comments, additional design measures have been incorporated to 

address the appearance of TPSS sites. The design measures described in Chapter 

4.0, Section 4.4.3.2 of the Final SEIS/SEIR under the heading “Project Measures to 

Avoid or Minimize Impacts” will provide for appropriate landscape screening to ensure 

that the facility will be screened from trails within Rose Canyon Open Space Park. 

TPSS 13 (now referred to as TPSS 11 in the Final SEIS/SEIR) south of La Jolla 

Colony Drive is required in this location based on the results of the load flow analysis 

and cannot be relocated from the site presented in the Draft SEIS/SEIR. 

A noise analysis was conducted for TPSSs located near sensitive noise clusters. The 

noise impacts of the TPPS sites were evaluated for noise-sensitive sites (refer to 

Chapter 5.0, Section 5.1.3.3 of the Noise and Vibration Impacts Technical Report). 

TPSS sites typically create a noise level of 45 dBA at 50 feet from the substation, 

which will be within city land use compatibility criteria for parks. 

14 According to the City of San Diego, the area referred to in the comment was restored 

following wastewater maintenance activities and is not an active restoration or 

mitigation site. Since the restoration activity was for temporary impacts and not for 

providing compensatory mitigation to offset permanent impacts, the area is not 

considered to be a mitigation site. As the area is not a mitigation site and is not 

located within the MHPA, impacts to this area do not require special consideration. All 

impacts to vegetation communities are disclosed within Chapter 5.0, Table 5-2 of the

Biological Resources Technical Report, and mitigation for long-term impacts is 

outlined in Chapter 6.0, Section 6.1.2 of this technical report. As stated in response to 

Comment 3, mitigation for impacts to wetlands within the Rose Creek watershed will 

include implementing portions of the Rose Creek Watershed Wetland, Riparian & 

Water Quality Restoration Opportunities Analysis (San Diego Earthworks, 2012). 

15 As described in Chapter 4.0, Section 4.7.5 of the Biological Resources Technical 

Report, Rose Canyon within the study area provides an avenue for local wildlife 

movement in a north-south direction between the portion of Rose Canyon to the east 

of I-5 and San Clemente Canyon. The technical report shows the connection provided 

by Rose Canyon and San Clemente Canyon to undeveloped lands on MCAS Miramar 

in Chapter 4.0, Figure 4-7, and acknowledges they function as regional wildlife 

corridors in the text. The undeveloped lands on MCAS Miramar provide the primary 

connection between these two east–west canyons. 

The portion of Rose Canyon within the study area does not connect areas to the east 

with areas farther to the west or south. The impacts of the project are located at the 

western limits of the Rose Canyon and San Clemente Canyon wildlife corridors, 

neither of which extend across the existing tracks or I-5, and will not affect east–west 

wildlife movement. The data provided in the comment regarding wildlife movement 

recorded by the San Diego Tracking Team do not provide evidence of wildlife 

movement within the project study area, although they do provide evidence of wildlife 

movement farther to the east. 
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The analysis of direct and indirect impacts to biological resources presented in the 

Draft SEIS/SEIR and the Biological Resources Technical Report appropriately 

characterizes the anticipated project-related impacts to wildlife corridors. 

16 A path along the east side of the open channel will remain and continue to allow for 

wildlife movement along the east side channel below SR 52. Additionally, as stated in 

Chapter 4.0, Section 4.8.3.2 of the Final SEIS/SEIR under the heading “Project 

Measures to Minimize or Avoid Impacts” the following design features have been 

incorporated into the project to facilitate wildlife movement through the concrete-lined 

channel under SR 52. The channel has been designed with a slight inclination toward 

the center of the channel. During dry seasons when the flows will be limited to 

irrigation runoff, the outer segments of the channel bottom will carry limited amounts of 

runoff and will continue to facilitate wildlife movement. The majority of riprap placed at 

the upstream and downstream ends of the proposed channel will not be grouted, 

which will allow sediment to fill gaps, creating a more natural and even surface for 

wildlife to cross. 

The project will not introduce any new barriers to park users. 

The concrete-lined channel is designed to convey water flow within Rose Creek and is 

not intended for human use. 

17 Refer to the response to Comment 12 and Master Response 17 regarding construction 

of a berm. 

18 Refer to Master Response 16 for information regarding mitigation for impacts to 

biological resources in Rose Canyon. 

19 Refer to Master Response 16 for information regarding mitigation for impacts to 

biological resources in Rose Canyon. 

20 As discussed in Comment 2, the project has been designed to minimize impacts to 

Rose Canyon Open Space Park and is located within the existing MTS right-of-way. 

No project features will be located within the park. 

SANDAG has committed to mitigating all significant and adverse impacts to biological 

resources that will result from the project. As stated in response to Comment 3, 

mitigation for impacts to wetlands within the Rose Creek watershed will include 

implementing portions of the Rose Creek Watershed Wetland, Riparian & Water 

Quality Restoration Opportunities Analysis (San Diego Earthworks, 2012). SANDAG 

has taken specific actions to avoid and minimize impacts to biological resources, 

including selection of an alignment that avoids crossing Rose Canyon, early 

coordination with resource agencies, and retaining an open channel below SR 52 
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rather than replacing it with a box culvert. The TransNet Environmental Mitigation 

Program encourages early coordination with wildlife agencies (CDFW, USFWS) to 

identify mitigation sites with high value for species that are anticipated to be affected 

by current and future projects identified in the RTP. This allows for mitigation that 

benefits the species on a regional level. Additionally, it often allows SANDAG to 

secure mitigation sites in advance for impacts associated with anticipated future 

projects, reducing the impacts associated with temporal habitat loss by mitigating upfront. 

21 The evaluation of long-term noise and vibration impacts for the project considered the 

increased frequency of the Trolley Blue Line. The cumulative noise and vibration 

analysis is documented in Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR under 

the heading "Noise and Vibration." As indicated in this section, the cumulative impacts 

from the future expansion of I-5 and the LOSSAN double tracking were among the 

projects considered as part of the cumulative noise analysis. 

22 The cumulative impacts assessment is documented in Chapter 3.0, Section 3.4.6 and 

Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR. The documents and projects 

consulted as part of this analysis are presented in Section 4.19.1 and include the 

LOSSAN Final EIS/EIR, which analyzed double tracking through the Mid-Coast 

Corridor. As detailed in Chapter 2.0, Section 2.2.1.1 of the Draft SEIS/SEIR, the longterm (2030) impacts of the project were evaluated in conjunction with major 

improvements listed in the 2030 RTP. 

As discussed in Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR, “The Build 

Alternative and options would not result in cumulative biological impacts. The Build 

Alternative is primarily located within a transportation corridor, does not conflict with 

the approved habitat conservation plan, and does not result in significant and 

unavoidable biological impacts.” Further, as discussed in responses to Comment 2, 

elimination of LRT Alternative 3 after Scoping avoided potentially significant noise and 

visual impacts to Rose Canyon Open Space Park, and eliminated all direct impacts to 

the park. Remaining impacts are limited to indirect visual impacts that with mitigation 

are not adverse or significant. The Build Alternative’s impact on MHPA habitat and 

wetland resources is minimal. For impacts that do exist, the Build Alternative will 

include mitigation that is consistent with the MSCP Plan (County of San Diego, 1998) 

and therefore will require mitigation for impacts to special-status vegetation 

communities (wetlands and Tier II–III). Mitigation for impacts to waters and wetlands 

in the Rose Creek Watershed will be located within that watershed. It is reasonable to 

presume other projects will also adhere to the MSCP. Further, the specific projects 

listed in the comment are to the east and are physically separated from the Mid-Coast 

Corridor Transit Project, which does not follow the existing rail right-of-way east 

through Rose Canyon. Thus, the projects would not combine with the Mid-Coast 

Corridor Transit Project to create any cumulative noise, light, visual, or shadow 

impacts to biological resources. Therefore, the Mid-Coast Corridor Transit Project is 

not expected to combine with other foreseeable projects in the region and cause 
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cumulatively significant impacts to the Rose Canyon Open Space Park, the MHPA, or 

the watershed. 

Refer to the responses to Comments 10 and 21 regarding the cumulative noise 

analysis. 

23 The projects referenced in this comment are separate undertakings, independent of 

the Mid-Coast Corridor Transit Project. See response to Comment 22 regarding the 

cumulative impact of the Mid-Coast Corridor Transit Project. 

24 Refer to the response to Comment 2. As indicated in the responses to previous 

comments and in the Draft SEIS/SEIR, the project will not result in adverse or 

significant impacts to Rose Canyon Open Space Park or Marian Bear Memorial Park. 

As stated in response to Comment 3, mitigation for impacts to wetlands within the 

Rose Creek watershed will include implementing portions of the Rose Creek 

Watershed Wetland, Riparian & Water Quality Restoration Opportunities Analysis (San 

Diego Earthworks, 2012). This will enhance, not degrade, the natural open space 

within Rose Canyon. 

25 Refer to the response to Comment 2. The comment regarding smart growth and the 

value of urban open space parks and MHPA lands will be part of the record of 

proceedings for the Draft SEIS/SEIR. 

 
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Simulation 1

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Simulation 2 

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1 The project has been designed to minimize the impact on Rose Canyon Open 

Space Park. Elimination of LRT Alternative 3 after Scoping avoided potentially 

significant noise and visual impacts to Rose Canyon Open Space Park. The 

project has been designed to minimize impacts to recreation within Rose Canyon 

Open Space Park, and is located within the existing MTS right-of-way. The two 

existing LOSSAN tracks within the MTS right-of-way currently support freight, 

COASTER, and Amtrak services, and the project alignment is separated from 

Rose Canyon Open Space Park by these two tracks. No project features will be 

located within the park. The nearest park trail is located approximately 90 feet 

east of the MTS right-of-way at its closest point (approximately 325 feet south of 

La Jolla Colony Drive). 

As noted in Chapter 4.0, Section 4.4.3.2 of the Final SEIS/SEIR, “The additional 

project features would not be visually prominent for recreational users because 

they would be adjacent to existing tracks, buildings, freeways, and above ground 

utilities, and mitigation measures would reduce the visual impact of retaining walls 

and tree and vegetation removal. Thus, with implementation of mitigation 

measures, the new project features would not contrast with the existing visual 

character or quality, and no adverse impacts would occur.” 

Refer to Master Response 14 for information regarding the noise analysis for 

Rose Canyon Open Space Park. 

Refer to Master Response 15 for information regarding the visual analysis for 

Rose Canyon Open Space Park and the response to Comment 2.

2 The simulations prepared by the commenter, as provided with the July 17, 2013 

submission, do not accurately represent the location and scale of the project. 

SANDAG prepared simulations from viewpoints along the trail, including from the 

same locations used by the commenter to illustrate how the Trolley will appear to trail 

users in Rose Canyon Open Space Park (see Simulations 1 and 2 attached to this 

response, which show the same locations as Attachments 2 and 4 of the comment 

letter). 

The Trolley in the commenter’s simulations is incorrectly located on the LOSSAN 

tracks. In comparison, Key Views G, H, and I in Appendix D of the Mid-Coast 

Corridor Transit Project Visual Impacts Technical Report show an Amtrak train on 

the LOSSAN tracks as seen from the same trail location within Rose Canyon 

Open Space Park (Key View I is shown as the “before” for Simulation 1 at the end 

of this letter while Key View G is shown as “before” for Simulation 2). The Trolley 

shown in the commenter’s simulations appears to be vertically exaggerated and is 

significantly larger than the Amtrak trains shown in Key Views G and I. The 
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Amtrak and COASTER trains traveling through the corridor are double-decker 

trains while the Trolleys are a single-level cab. The Amtrak and COASTER trains 

currently operating in the Mid-Cost Corridor are taller than the Trolley vehicles. 

As viewed from the trail, the Trolley tracks will be located farther to the west on the 

other side of the LOSSAN tracks, toward the I-5 off-ramp. At the location shown 

in Simulation 1and Attachment 2 of the comment letter, the Trolley tracks will be 

approximately 325 feet from trail users. As shown in Simulation 1, while the 

catenary poles and wires will be visible from the trail, the Trolley vehicle is barely 

visible above the vegetation. This is due to the change in topography, existing 

vegetation, and the project alignment beginning its decent into the tunnel under La 

Jolla Colony Drive. The catenary poles and wires are typical features in this area 

(as seen, there are already a number of utility lines and poles in this area). 

At the location shown in Simulation 2 and Attachment 4 of the comment letter, the 

Trolley tracks will be approximately 300 feet from the viewer. An Amtrak train is 

shown in the new simulation prepared in response to this comment. As shown in 

Simulation 2, the Amtrak train will be larger than the Trolley vehicle. Further, 

existing vegetation will block portions of the Trolley vehicle. Similar to Simulation 

1, existing utility lines are currently visible in this area. 

The simulations prepared by SANDAG support the conclusions presented in the 

Draft SEIS/SEIR that the project, with mitigation, will not adversely or significantly 

impact views of users in Rose Canyon Open Space Park. 

3 As stated in the responses to previous comments, the project will not result in 

significant noise impacts and, with mitigation, will not result in adverse visual 

impacts on Rose Canyon Open Space Park. As a result, a berm is not needed as 

mitigation for these impacts. Refer to Master Response 17 for additional 

information on the potential to construct an earthen berm. 

Refer to Master Response 13 for a discussion of lighting impacts. The project will 

not include any permanent light elements or fixtures in Rose Canyon Open Space 

Park. 
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4 In response to comments, additional design measures have been incorporated to 

address the appearance of TPSS sites. The design measures described in 

Chapter 4.0, Section 4.4.3.2 of the Final SEIS/SEIR under the heading “Project 

Measures to Avoid or Minimize Impacts” will provide for appropriate landscape 

screening to ensure that the facility will be screened from trails within Rose 

Canyon Open Space Park. TPSS 13 (now referred to as TPSS 11 in the Final 

SEIS/SEIR) south of La Jolla Colony Drive is required in this location based on the 

results of the load flow analysis and cannot be relocated from the site presented in 

the Draft SEIS/SEIR. 

5 Refer to Master Response 16 for information regarding mitigation in the Rose 

Creek watershed. 

6 The project will not impact the existing wooden trestle railroad bridge or the area 

directly under the existing wooden trestle railroad bridge. This bridge is located 

immediately south of La Jolla Colony Drive. It should be noted that this project is 

independent of the operation and maintenance on the LOSSAN tracks.

7 As discussed in Comment 1, the project has been designed to minimize impacts 

to Rose Canyon Open Space Park, and is located within the existing MTS right-ofway. With implementation of mitigation measures, the new project features would 

not contrast with the existing visual character or quality, and no adverse impacts 

would occur.” The project, if visible 1,500 feet eastward of the tunnel as asserted 

by the comment, will be a minor portion of the viewshed for trail users and will not 

result in significant visual impacts with the implementation of mitigation.. 

Refer to the response to Comment 2 and Master Response 15 for additional 

information regarding the visual analysis for Rose Canyon Open Space Park. 

The Draft SEIS/SEIR incorporates a variety of measures to avoid and minimize 

impacts to Rose Canyon Open Space Park, as listed throughout Chapter 3.0 and 

Chapter 4.0. Visual mitigation measures will be applied where appropriate along 

the entire alignment (not just at key views), including measures related to 

landscaping and design (Mitigation Measures VR4 and VR5). Mitigation 

measures that will benefit park users include replacement of trees that are 

removed to accommodate the project (Mitigation Measure VR6), use of noninvasive plants (native plants) wherever appropriate (Mitigation Measure VR7), 

restoration of natural vegetation in areas subject to temporary construction 

impacts (Mitigation Measures CON9 and CON10), locating wetland mitigation 

sites in Rose Canyon, facilitating bicycle and pedestrian access during and after 

project construction (Mitigation Measure TCON1), and public outreach. In 

addition, SANDAG has incorporated project measures that provide for appropriate 

landscape screening to ensure that the TPSS will be visually screened from trails 

within Rose Canyon Open Space Park. These project measures are described in 
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Chapter 4.0, Section 4.4.3.2 of the Final SEIS/SEIR under the heading “Project 

Measures to Avoid or Minimize Impacts.”

Refer to Chapter 4.0, Section 4.7.3.2 and Chapter 5.0 of the Mid-Coast Corridor 

Transit Project Noise and Vibration Impacts Technical Report for information 

regarding the noise analysis for Rose Canyon Open Space Park. 

Mitigation is proposed for noise impacts to the La Paz condominiums (see 

Mitigation Measures N3 and N4 in Chapter 4.0, Table 4-14 of the Draft 

SEIS/SEIR). The mitigation consists of sound walls adjacent to the LRT tracks 

north of the Gilman Drive/La Jolla Colony Drive intersection where the tracks 

come within 25 feet of residential units. Mitigation is required at these locations 

because project-related noise would exceed the FTA’s moderate impact threshold 

by more than 1 dB. The mitigation for noise impacts in this location would not 

impact or benefit recreational use in Rose Canyon Open Space Park.

8 The visual impacts of tree and vegetation removal were considered in the visual 

analysis and were found to be significant for recreational users within Rose 

Canyon Open Space Park. Visual impacts from tree and vegetation removal will 

be reduced through mitigation measures that will benefit park users, including 

replacement of trees that are removed to accommodate the project (Mitigation 

Measure VR6 in Chapter 4.0, Section 4.4.4 of the Draft SEIS/SEIR) and 

restoration of natural vegetation in areas subject to temporary construction 

impacts. The existing vegetation does not substantially reduce noise levels, and 

thus removal will not increase the severity of noise impacts. Removal of 

vegetation will not substantially affect the sound attenuation in this area; 

furthermore, areas that are temporarily affected during construction will be 

replanted with native species and monitored for at least five years. 

Refer to Master Response 15 for information regarding the visual analysis for 

Rose Canyon Open Space Park and the responses to Comments 2 and 7 

regarding the visual analysis. 

Refer to Master Response 14 for information regarding the noise analysis for 

Rose Canyon Open Space Park. 

 
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Simulation 1

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1 Your comment regarding the general community consensus about the need for the 

project will be part of the record of proceedings for the Draft SEIS/SEIR. The 

concerns regarding impacts and mitigation measures summarized in this comment are 

addressed in the responses to the more specific comments that follow. 

The Draft SEIS/SEIR and supporting technical studies analyze and disclose the 

anticipated impacts of the project in accordance with the requirements of NEPA and 

CEQA. Construction-related impacts are presented in Chapter 4.0, Section 4.17 of the 

Draft and Final SEIS/SEIRs, with additional detail provided in the Mid-Coast Corridor 

Transit Project Construction Impacts Technical Report. A description of transportation 

operations is provided in Chapter 1.0, Sections 1.3 and 1.4, and Chapter 3.0 of the 

Draft and Final SEIS/SEIRs, with additional information available in the Mid-Coast 

Corridor Transit Project Transportation Impacts and Mitigation Technical Report. 

Environmental agency approval and oversight requirements are described in Chapter 

4.0, Sections 4.8 and 4.20 of the Draft SEIS/SEIR, with additional information in 

Chapter 8.0, Section 8.7.2 regarding coordination with resource agencies conducted 

to date. Chapter 8.0, Sections 8.4, 8.5.2, and 8.8.2 of the Final SEIS/SEIR also 

provide information regarding stakeholder involvement. 

The level of detail of construction and operational impacts is sufficient to identify the 

mitigation measures with appropriate detail to ensure impacts are mitigated to a level 

below significance. In addition, a Mitigation Monitoring and Reporting Program 

(MMRP) will be adopted by the SANDAG Board of Directors in connection with the 

final approval action on the project. At a minimum, the MMRP will identify the timing of 

each measure, the agency responsible for monitoring each measure, and the agency 

responsible for enforcing each measure. As described in Chapter 8.0 of the Draft and 

Final SEIS/SEIRs, coordination with agencies and stakeholders has been initiated and 

will be ongoing as design and construction of the project progress. 

The cumulative impacts assessment is documented in Chapter 3.0, Section 3.4.6 and 

Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR. The documents and projects 

consulted as part of this analysis are presented in Section 4.19.1 and include the 

LOSSAN Final EIS/EIR, which analyzed double tracking through the Mid-Coast 

Corridor. As detailed in Chapter 2.0, Section 2.2.1.1 of the Draft SEIS/SEIR, the longterm (2030) impacts of the project were evaluated in conjunction with major 

improvements listed in the 2030 RTP, including the Coastal Rail Trail. 

With regard to the California High-Speed Rail Project, insufficient information is 

available to include the project in the cumulative analysis. As explained in the Final 

Program EIR/EIS for the proposed California High-speed Train System (California 

High-Speed Rail Authority, 2005), the document analyzes impacts at a more 

generalized level to provide decision makers with sufficient information to decide 

whether to pursue the project and which conceptual alignment corridors to consider 
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(Refer to Chapter 1, Section 1.1 of the Final Program EIR/EIS.) 

After completion of the Final Program EIR/EIS, the lead agency is expected to conduct 

preliminary engineering and project-level environmental review to provide further 

analysis of potential impacts and issues at an appropriate site-specific level of detail in 

order to implement the project (Chapter 1, Section 1.1 of the Final Program EIR/EIS). 

Based on this conceptual planning stage of analysis, the Final Program EIR/EIS 

generally found that the following resources could result in potentially significant or 

unavoidable impacts: traffic and circulation (Chapter 3, Section 3.1.6); visual quality 

(Chapter 3, Section 3.9.7); farmland and agriculture (Chapter 3, Section 3.8.6); 

biological resources and wetlands (Chapter 3, Section 3.15.6); hydrology and water 

resources (Chapter 3, Section 3.14.6); public parks and recreation (Chapter 3, Section 

3.16.8); and cultural resources (Chapter 3, Section 3.12.6). However, all findings were 

primarily based on a lack of site-specific information and not actual impacts. In each 

case, the Final Program EIR/EIS states that it is expected impacts will be mitigated to 

a less than significant level, but sufficient information is not available to conclude with 

certainty that the identified mitigation strategies will reduce impacts to a less-thansignificant level in all circumstances. 

Additionally, the High-Speed Rail Project alignment within the Los Angeles-to-San 

Diego project section is still uncertain. Project-level analysis within the Los Angelesto-San Diego project section remains in a preliminary planning stage. The Preliminary 

Alternatives Analysis Report Los Angeles to San Diego via the Inland Empire Section

(California High-Speed Rail Authority, 2011) has been prepared using preliminary 

planning, environmental, and conceptual information in order to identify feasible and 

practical alternatives to carry forward for environmental review, but no specific 

alignment has been selected (refer to Chapter 1, Section 1.4 of this report). 

As a result, there is insufficient information at this time regarding the actual impacts of 

the High-Speed Rail Project to include it in the cumulative analysis for the Mid-Coast 

Corridor Transit Project. However, once the project-level analysis begins within the 

Los Angeles-to-San Diego project section and an alignment has been determined, the 

High Speed Rail Authority will be required to identify measures to avoid, minimize, and 

mitigate potential impacts. Thus, specific impacts and mitigation measures will be 

addressed “only after the alignment is refined and the facilities are fully defined 

through project level analysis.” (Chapter 3, Section 3.0 of the Final Program EIR/EIS). 

2 There is no requirement for a project-specific Water Quality Management Plan, and 

such a plan is not required to analyze the project’s impacts to water quality. As stated 

in Chapter 2.0, Section 2.3.1.2 of the Mid-Coast Corridor Transit Project Water Impact 

Analysis Technical Report, the water quality management plan applicable to the 

project is the Water Quality Control Plan for the San Diego Basin, which sets the 

regulatory water quality standard for surface and ground waters within the region. 

Further, as stated in Chapter 2.0, Section 2.1.2.1 of the Water Impact Analysis 

Technical Report, it is the State Water Resources Control Board's responsibility for 
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adoption and implementation of water quality control plans (including approved Total 

Maximum Daily Loads of pollutants and associated implementation measures, 

issuance of waste discharge requirements, and performing other functions concerning 

water quality control within their respective regions). 

3 Biodegradable lubricants are used on tight radius curves to reduce wheel squeal. 

Alignment curves over Rose Creek will not include tight radius curves; thus, they will 

not require lubrication, and lubricants will not be directly deposited into Rose Creek. 

Additionally, the disc brake pads for all existing MTS vehicles are comprised of 

proprietary, non-asbestos compounds that are non-toxic and not electrically conductive. 

Further, braking is primarily accomplished via dynamic braking (as opposed to friction 

braking, which could result in brake dust). Dynamic braking uses the traction motors as 

generators during braking. Friction braking will only be used below 6 mph when it adds to 

the dynamic braking effort (or as a backup to provide a few vehicle stops in the rare 

instance that dynamic braking is not available). Since friction brakes are not often used, 

they do not get a lot of wear and tear and do not routinely generate brake dust. Friction 

brakes, when used, generate an immeasurably small amount of brake dust. Further, as 

noted above, the disc brake pads are comprised of non-toxic compounds. Refer to the 

response to Comment 6 regarding cumulative impacts. 

4 Construction of catch basins/treatment Best Management Practices (BMPs) will be 

within the public right-of-way limits and no additional right-of-way is anticipated to be 

required for catch basins/treatment BMPs. Catch basins/treatment BMPs will be 

designed during final design of the project, consistent with the standard procedure for 

project development. Project–specific constituents of concern are identified in Chapter 

5.0, Section 5.1.2.1 of the Water Impact Analysis Technical Report. Proposed 

treatment BMPs and treatment efficiencies are identified in Chapter 4.0, Table 4-26 of 

the Draft SEIS/SEIR. 

Refer also to response to Comment 3 regarding brake dust. 

5 As noted in the response to Comment 2, there is no requirement for a project-specific 

Water Quality Management Plan. Rose Creek is shown as an impaired waterway 

under Section 303(d) in Chapter 4.0, Table 4-24 of the Draft SEIS/SEIR, consistent 

with the State Water Resources Control Board 2010 Integrated Report (Clean Water 

Act [CWA] Section 303(d) List/305 (b) Report). 

6 As noted in response to Comment 4, project–specific constituents of concern are 

discussed in Chapter 5.0, Section 5.1.2.1 of the Water Impact Analysis Technical 

Report. The use of selenium is not anticipated in production of rail or wheel 

components. As described in response to Comment 3, Trolley vehicles typically use 

their dynamic brake system rather than the friction brake system. Therefore, the 

amount of heavy metals generated by operation of the Trolley will be immeasurably 
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small. Likewise, selenium is not used by Amtrak and COASTER trains; therefore, the 

cumulative impact of the Trolley, COASTER, and Amtrak trains with respect to 

selenium will not be adverse. As discussed in Chapter 4.0, Section 4.19 of the Draft 

SEIS/SEIR, Amtrak and COASTER projects would undergo their own environmental 

review and permitting processes, and BMPs and mitigation measures would be 

required for these projects to avoid and minimize adverse cumulative impacts 

(including those related to heavy metals). The Build Alternative will not contribute to 

long-term cumulative impacts with respect to heavy metals and will not be adverse. 

As discussed in Chapter 4.0, Section 4.5.2, of the Water Impact Analysis Technical 

Report, the project is required to comply with Indicator Bacteria TMDL requirements as 

specified in SDRWQCB Resolution No. R9-2010-0001 for the San Diego River, 

Tecolote Creek, and Rose Creek, and with Sediment TMDL requirements as specified 

in SDRWQCB Resolution No. R9-2012-0033 for the Los Peñasquitos Lagoon. As 

discussed in Chapter 2.0, Section 2.1.2.1 of the Water Impact Analysis Technical 

Report, Section 303(d) of the CWA requires states, territories, and authorized tribes to 

develop, authorize, and implement a process to establish TMDLs to meet water quality 

standards. Therefore, any needs for development of TMDLs for Rose Creek that are 

not currently identified within the Water Quality Control Plan for the San Diego Basin 

are the responsibility of the state and such regulations would be beyond the scope of 

the project. 

As discussed in Chapter 4.0, Section 4.19.3.2 under the heading, “Water Resources” 

of the Draft SEIS/SEIR, other projects are required to undergo similar environmental 

review and permitting processes, and BMPs and mitigation measures would be 

required for those projects to avoid and minimize adverse impacts. The LOSSAN 

Final EIR/EIS (September 2007) analyzed double-tracking through the Mid-Coast 

Corridor and concluded that there would be a less-than-significant impact to water 

quality within the Mid-Coast Corridor. The Mid-Coast Corridor Transit Project will not 

result in cumulative impacts to water resources because the project will implement 

appropriate BMPs identified in the SEIS/SEIR, in accordance with permit 

requirements, to avoid contributing to cumulative water quality impacts. 

As stated in response to Comment 1, the specific alignment for high-speed rail has not yet 

been established. Therefore, the cumulative impact assessment has not been revised to 

evaluate impacts from high-speed rail. However, as noted above, the high-speed rail 

project is expected to undergo environmental review and permitting processes, and 

resulting mitigation measures and BMPs would be required for project approval. 
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7 See Comment 6. The use of selenium is not anticipated in production of rail or wheel 

components. The operation of the Trolley will not generate or utilize diazinon. 

Further, the operation of the Trolley will not result in lead deposition into Rose Creek 

and will not impact the levels of lead along Rose Creek or in Mission Bay. 

Section 303(d) Impaired Water Bodies’ existing constituents of concern and targeted 

design constituents for Rose Creek are identified in Chapter 4.0, Table 4-9 of the 

Water Impact Analysis Technical Report. These have been compared against the 

anticipated design constituents (i.e., pollutants) identified in Chapter 5.0, Section 

5.1.2.1 of the Water Impact Analysis Technical Report under the heading “Summary.” 

As stated in Section 5.1.2.1 under the heading "Discharges of Contaminants to 303(d) 

Listed Water Bodies," "As part of the project design, appropriate Best Management 

Practices (BMPs) to address the contaminants to the 303(d) listed waters (Table 4-9) 

will be included as part of the project. The BMPs may include infiltration devices, 

detention devices, biofiltration devices, and/or media filters, as discussed above. 

Treatment efficiencies for each measure are shown in Table 5-2." Therefore, the 

discharge of contaminants associated with implementation of the project is not 

expected to be an adverse impact, as the BMPs proposed for incorporation into the 

project will treat the increased runoff. 

Refer to the response to Comment 6 regarding cumulative impacts. 

8 The City of San Diego North City Water Reclamation Plant will comply with the waste 

discharge requirements identified in the SDRWQCB Permit (Order No. 97-03 and 

Addendum No. 1 dated June 2003). As outlined in the permit and defined by state 

statutes and regulations pertaining to the use of recycled water in California (i.e., 

California Water Code, California Code of Regulations, and California Health and 

Safety Code), recycled water must be transported from the point of treatment or 

production to the point of use without an intervening discharge to waters of the state 

without SWRCB prior approval. 

While a study was initiated in 2008 (Wet Weather Storage Facility/North City 

Reclamation Plant – Wet Weather Intermittent Steam Discharge Feasibility Study – 

Phase II) and completed in 2012, the project was not implemented. There is no 

current approved SDRWQCB permit related to the study. As a result, no discharges 

from the City of San Diego North City Water Reclamation Plant would be discharged 

into Rose Creek (in compliance with Order No. 97-03 and state regulations). 

9 Draft Preliminary Location Hydraulic Studies (LHS) and Floodplain Studies have been 

developed for the project, and those results (i.e., anticipated water surface elevations 

from bridge crossings) are summarized in Chapter 5.0, Table 5-3 of the Water Impact 

Analysis Technical Report. These studies will be updated during final design of the 

project, consistent with the standard procedure for LHS/Floodplain Analysis 

development. Once finalized, these documents may be obtained through a request to 

SANDAG. 
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The impacts to natural and beneficial floodplain values and the measures to minimize 

floodplain impacts and restore or preserve floodplain values are discussed in Chapter 

4.0, Section 4.9.3.2 of the Draft SEIS/SEIR under the heading “Flood-Related.” The 

project does not adversely impact the floodplain values, and the existing natural 

watersheds will remain natural. 

10 Longitudinal encroachments are defined in Chapter 5.0, Section 5.1.2.2, under the 

heading “Changes to Floodplain from Longitudinal Encroachments,” and depicted in 

Figure 5-1 of the Water Impact Analysis Technical Report. Additional channel 

modifications (i.e., the Rose Creek Open Channel Structure at SR 52) are described in 

Chapter 5.0, Section 5.1.2.2, under the heading “Changes to Floodplain from Channel 

Modifications” of the Water Impact Analysis Technical Report. The longitudinal 

encroachments of the project are a result of retaining walls and their associated fill that 

are within the limits of the base floodplain parallel to the direction of flow. The impacts 

of the project are located at the western limits of the Rose Canyon and San Clemente 

Canyon wildlife corridors, neither of which extend across the existing tracks or I-5 and 

will not affect east–west wildlife movement. Because wildlife is predominantly present 

along the east side of the MTS right-of-way, access by wildlife to water will not be 

adversely impacted. 

As detailed in Chapter 4.0, Table 4-16 of the Draft SEIS/SEIR, long-term impacts to 

non-vegetated channel or floodways are limited to 0.45 acre. As stated in Chapter 

4.0, Section 4.8.3.2 of the Draft SEIS/SEIR under the heading “Jurisdictional Aquatic 

Resources,” the majority of long-term impacts to jurisdictional aquatic resources are 

associated with replacing an approximately 700-foot-long concrete-lined open channel 

portion of Rose Creek. The replaced open channel essentially will serve the same 

function as the existing open channel and will not limit long-term wildlife access to 

water. Additionally, the following design features have been incorporated into the 

project to facilitate wildlife movement through the concrete-lined channel under SR 52. 

The channel has been designed with a slight inclination toward the center of the 

channel. During dry seasons when the flows will be limited to irrigation runoff, the 

outer segments of the channel bottom will carry limited amounts of runoff and will 

continue to facilitate wildlife movement. The majority of riprap placed at the upstream 

and downstream ends of the proposed channel will not be grouted, which will allow 

sediment to fill gaps, creating a more natural and even surface for wildlife to cross. 

11 Refer to Master Response 1 for a discussion of pedestrian and bicycle connections to 

stations. Although pedestrian and bicycle facilities between Pacific Beach and the 

Balboa Avenue Station will not be modified or added as part of the project, three bus 

routes will provide a connection between the Balboa Avenue Station and Pacific 

Beach. As shown in Chapter 2.0, Table 2-6 of the Draft SEIS/SEIR, Routes 8, 9, and 

27 will operate at 15-minute headways between the station and Pacific Beach, thereby 

providing a means to access Pacific Beach via bus. Consistent with current MTS 

practice, bicycles are allowed on Trolley vehicles and buses. 
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Traffic impacts of the project are described in Chapter 3.0, Sections 3.4.2.2 and 

3.4.2.4 of the Draft SEIS/SEIR and include adverse and unmitigated impacts near 

Pacific Beach where delay will increase incrementally. These impacts will occur on 

Balboa Avenue from the I-5 southbound on-ramp to the I-5 northbound off-ramp and at 

Mission Bay Drive and Garnet Avenue. Refer to Master Response 8 for additional 

information on traffic impacts at these locations. 

12 Refer to Master Response 1 for information regarding bicycle and pedestrian 

connections to stations. 

13 The Rose Canyon Bicycle Path is located within the transportation right-of-way and 

classified as a local transportation use, which is not considered a noise-sensitive use 

under FTA or City of San Diego regulations (refer to Chapter 5.0, Section 5.3.2 of the 

Draft SEIS/SEIR). 

In terms of visual impacts, the Rose Canyon Bicycle Path is within Rose Canyon, 

within a highly urbanized area that includes the MTS right-of-way and nearby I-5. 

Appendix A of the Mid-Coast Corridor Transit Project Visual Impacts Technical Report 

presents the potential key views analyzed as part of the visual analysis for the project. 

Potential Key Views 16, 17, and 19 show views from the Rose Canyon Bicycle Path. 

Refer to Master Response 15 for information regarding the visual analysis for trail 

users within Rose Canyon Open Space Park. 

14 Passby noise from the diesel-powered Amtrak and COASTER trains will be substantially 

higher than from the electric-powered Trolleys. According to the FTA Noise and Vibration 

Guidance Manual, a diesel locomotive will typically generate a maximum noise level (Lmax) 

of 88 dBA at 50 feet from the tracks. The Lmax noise level represents the loudest noise 

level during a train passby. In the worst case, if a COASTER, Amtrak, and two Trolley 

trains are passing at the same location simultaneously, the noise level created by the 

Amtrak and COASTER trains combined would be 3 dBA higher than the noise level of a 

single train passby, resulting in an Lmax of 91 dBA for COASTER and Amtrak trains 

passing, which occurs in double-tracked sections today. Changes in sound levels of less 

than 3 dBA are generally not noticeable to people with normal hearing sensitivity. Adding 

the two Trolleys would add 1 dBA to the total noise, which would not be a perceptible 

increase compared to the passing Amtrak and COASTER trains. In this case, the total 

Lmax noise level would be 92 dBA for a COASTER, Amtrak, and two Trolley trains passing 

at the same instant. In a more likely case, the nearest train would block some of the noise 

from the trains on the farther track and the total noise level would be less. Note that these 

calculated levels are Lmax levels and do not directly relate to Leq levels (average noise 

levels), which are relevant to the identified FTA noise impact criteria (as documented in 

the Transit Noise and Vibration Impact Assessment Guidance Manual [FTA, 2006]) or to 

the City of San Diego noise impact criteria that are described in Section 4.7.1 of the Final 

SEIS/SEIR.
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15 To protect against car and bicycle crashes, the clear recovery zone adjacent to I-5 (the 

area required for an errant vehicle to recover control of the vehicle) that meets 

Caltrans' standards or protective barriers, such as guardrails or concrete barriers, will 

be provided. 

Because of the grade differential between the freeway and the bicycle path, nighttime 

blindness of bicyclists is not anticipated. In areas where existing vegetation is lost due 

to construction of the project, the vegetation will be replaced at the conclusion of the 

construction period. This vegetation will further reduce the potential for nighttime 

blindness. 

16 The Final SEIS/SEIR Plan Set shows the location of the relocated bike path through 

Rose Canyon. The relocation accommodates the future LOSSAN double tracking 

project. However, as stated in response to Comment 1, the location of the high-speed 

rail alignment has not been finalized and therefore cannot be included in the design. 

17 Refer to the response to Comment 11 regarding access to Pacific Beach from the 

Balboa Avenue Station. The project will provide pedestrian enhancements to provide 

for pedestrian access to the Balboa Avenue Station. Access from Morena Boulevard 

will be provided via new sidewalks on both sides of Morena Boulevard within the 

station area. Access from Balboa Avenue will be via ramps and stairs on both sides of 

the street. A pedestrian bridge will be provided across Balboa Avenue. Chapter 2.0, 

Figure 2-14 of the Final SEIS/SEIR presents these improvements. Therefore, with the 

project enhancements, pedestrian access will be provided to the station. 

Refer to Master Response 1 for information regarding bicycle and pedestrian 

connections to stations. 

The Balboa Avenue Station will be a major bus-to-Trolley transfer location along the 

project alignment, with approximately 70 percent of patrons accessing the station via 

bus, independent of pedestrian and bicycle facilities near stations. 

18 Refer to Master Response 1 for information regarding bicycle and pedestrian 

connections at stations. The provision of a pedestrian bridge to Mission Bay Park is 

beyond the scope of the project; however, three bus routes will provide service from 

the Balboa Avenue Station to Mission Bay Park. 

19 Refer to Master Response 8 for a summary of the mitigation considered for the 

adverse and significant traffic impact at Mission Bay Drive and Garnet Avenue. 

Refer to Master Response 1 for information regarding bicycle and pedestrian 

connections near stations. 
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20 Refer to Master Response 1 for information regarding bicycle and pedestrian 

connections near stations. No significant or adverse impact has been identified that 

would require mitigation through the provision of a pedestrian/bicycle connection from 

the Balboa Avenue Station to the Rose Creek Bicycle Path. 

21 Any potential modifications to the on-ramp/off-ramp from Morena Boulevard near 

Clairemont Drive are outside the scope of this project. The project will only modify 

roadways as needed to support the project alignment and stations or to mitigate 

adverse and significant traffic impacts. No significant or adverse impact has been 

identified that would require mitigation through the provision of the measures 

suggested by the commenter. 

22 The information presented in Chapter 4.0, Table 4-32 of the Transportation Impacts 

and Mitigation Report is from the SANDAG Series 11 Travel Demand Forecasting 

Model. The model used for the analysis does not have the capability of projecting 

bicycle, skateboarding, or rollerblading access to the station. 

The existing pedestrian and bicycle activity noted in Chapter 3.0, Section 3.4 of the 

Transportation Impacts and Mitigation Report was meant to provide an overview of 

bicycle activity around each existing and proposed station. Chapter 4.0, Section 4.4 of 

the Transportation Impacts and Mitigation Report presents an analysis of impacts to 

bicycle and pedestrian facilities under the Build Alternative. This analysis is based on 

impacts to existing or planned bicycle and pedestrian features (e.g., if column 

placement would require realigning a bicycle lane). Additionally, the analysis 

examined pedestrian connectivity to the stations, with the results presented in Chapter 

4.0, Table 4-69 of the Transportation Impacts and Mitigation Report. The analysis 

identified major pedestrian generators and barriers and reviewed existing facilities and 

those planned as part of the project. This analysis was based on site visits for the 

one-quarter-mile station areas and a review of maps to characterize existing land 

uses. For the Balboa Avenue Station area, the analysis concluded that the provision 

of new sidewalks under the Build Alternative will facilitate pedestrian access to the 

station and, therefore, there will be no adverse impact to pedestrian movements (refer 

to the response to Comment 17 for description of the pedestrian features that will be 

added in the immediate vicinity of the Balboa Avenue Station). Therefore, no 

additional studies were conducted. 

23 Refer to Master Response 1 for information regarding bicycle and pedestrian 

connections near stations. 
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24 SANDAG reviewed the Balboa Avenue Revitalization Action Program, adopted 

September 12, 2005. The program identifies design concepts and recommendations 

to transform Balboa Avenue into an activity hub in the approximate center of 

Clairemont. The Mid-Coast Corridor Transit Project will complement these design 

concepts and recommendations and will not preclude their implementation. However, 

information to assess the potential cumulative impacts of projects identified in the 

program is not available at this time because the design concepts and 

recommendations are conceptual in nature and no specific projects have been 

approved or have undergone environmental review. 

25 It is correct that Chapter 4.0, Table 4-60 of the Transportation Impacts and Mitigation 

Report states that an adverse impact will occur at the intersection of Mission Bay Drive 

and Garnet Avenue under the Build Alternative, and that the intersection currently 

operates at an unacceptable level of service. Delay will worsen from 73.2 seconds 

under the No-Build Alternative to 77.0 seconds under the Build Alternative during the 

p.m. peak hour, and from 67.0 seconds to 67.9 seconds during the a.m. peak hour 

(see Chapter 4.0, Table 4-62 of the Transportation Impacts and Mitigation Report). 

Refer to Master Response 8 for additional information. 

Transit passengers can access the station from the Pacific Beach community via bus 

as there are three bus routes that will operate between Pacific Beach and the Balboa 

Avenue Station at 15-minute peak-period frequencies. Bus transit will provide an 

alternative for those who do not want to drive to the station. The Series 11 model 

accounts for the travel time to access the station by each mode (pedestrian, bus, 

auto). 

26 Refer to Master Response 1 for information regarding bicycle and pedestrian facilities. 

The Draft SEIS/SEIR evaluates the impacts of the Mid-Coast Corridor Transit Project. 

The project will not create or worsen adverse pedestrian conditions at the intersection 

of Mission Bay Drive and Garnet Avenue, and pedestrian improvements to this 

intersection are beyond the scope of the project and SEIS/SEIR. Further, unlike other 

stations that will have heavy pedestrian access, such as Executive Drive, the primary 

modes of access to the Balboa Avenue Station will be via buses and automobiles. 

The Balboa Avenue Station will be a major bus-to-Trolley transfer location along the 

project alignment, with approximately 70 percent of patrons accessing the station via 

bus and only 9 percent of passengers walking to the station. 

27 Refer to the response to Comment 11 and Master Response 1. 

28 Refer to the response to Comment 1. Cumulative impacts are addressed in Chapter 

3.0, Section 3.4.6 and Chapter 4.0, Section 4.19 of the Draft SEIS/SEIR. The longterm impact analysis of project impacts also considers projects that are included in the 

adopted 2030 RTP, including the LOSSAN double tracking and Coastal Rail Trail. 
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29 As shown in Chapter 3.0, Table 3-32 of the Draft SEIS/SEIR, there will be intermittent 

off-peak lane closures and nighttime roadway closures. The nighttime closures will be 

intermittent as needed to erect and take down falsework and will occur between 9:00 

p.m. and the morning peak period. As these closures are intermittent and will not 

occur continuously or during peak periods, they are not anticipated to have significant 

or adverse impacts on businesses in, or access or egress to/from, Pacific Beach, 

regardless of the time of year. The construction schedule will be finalized once a 

contractor is selected; therefore, the time of year when these intermittent closures will 

occur is unknown. Your comment regarding scheduling roadway construction in this 

area to occur between October and April will be part of the record of proceedings for 

the Draft SEIS/SEIR. 

30 MTS regularly reviews on-time performance for bus routes. Should the on-time 

performance deteriorate for the routes that connect the Balboa Avenue Station and 

Pacific Beach, the service would be modified to improve reliability. Adjustments could 

consist of adding additional buses or altering the schedule. 

31 There will be no “take” of a floodplain. Because the existing right-of-way is located 

within the existing floodplain, there will be project impacts within the floodplain (i.e., 

temporary impacts associated with sewer relocation, temporary and permanent 

impacts from construction of a retaining wall, and raising of the Mid-Coast and 

LOSSAN tracks to avoid flooding), but the impacts will not be adverse. As discussed 

in Chapter 4.0, Section 4.9.3.2 of the Draft SEIS/SEIR under the heading "FloodRelated," "Proposed drainage management measures (e.g., channel stabilization, low 

impact development [LIDs], etc.) would avoid or accommodate any increase in peak 

runoff, and proposed structures, channel modifications, and longitudinal 

encroachments would not raise the 100-year water surface elevation (WSEL) more 

than 1 foot. The minimal floodway increase would not affect existing buildings, 

structures, or other beneficial uses. Additionally, the project would document any 

impacts through the FEMA Conditional Letter of Map Revision approval process, as 

well as meet the requirements of the SDRWQCB, as applicable." 

32 There is an existing LOSSAN track located within the existing Rose Creek floodplain. 

An additional LOSSAN track will be constructed south of SR 52 as part of the Build 

Alternative, approximately 2,150 feet in length by 20 feet in width. The project will 

eliminate the flooding of the existing LOSSAN track by raising the track above the 100-

year flood elevation; accordingly, the Build Alternative will not result in any adverse 

flood-related impacts. As discussed in response to Comment 31, the impacts within 

the floodplain will be minimal and not adverse. 

33 The cumulative impact methodology is described in Chapter 4.0, Section 4.19 of the 

Draft SEIS/SEIR. The cumulative analysis contained in the Draft SEIS/SEIR includes 

an analysis of: (1) projects that are either approved or being considered for approval 

by SANDAG, the City of San Diego, USCD, and other agencies (or anticipated to be 
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submitted for consideration, including projects in the design phase or under 

construction), and (2) growth projections set forth in regional plans, including regional 

modeling plans. Various related environmental documents and regional plans were 

reviewed and used in the cumulative analysis, as identified in Section 4.19. Refer to 

the response to Comment 32 regarding LOSSAN track impacts and the response to 

Comment 1 for additional information on the cumulative impact assessment. Refer to 

the response to Comment 1 regarding high-speed rail. 

As discussed in Chapter 4.0, Section 4.9.3.2 of the Draft SEIS/SEIR under the 

heading "Flood-Related," "Proposed drainage management measures (e.g., channel 

stabilization, low impact development [LIDs], etc.) would avoid or accommodate any 

increase in peak runoff, and proposed structures, channel modifications, and 

longitudinal encroachments would not raise the 100-year water surface elevation 

(WSEL) more than 1 foot. Additionally, the project would document any impacts 

through the FEMA Conditional Letter of Map Revision approval process, as well as 

meet the requirements of the SDRWQCB, as applicable." 

As stated in Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR, the Build Alternative 

will not result in cumulative impacts to water resources. Regulations have been adopted 

that fully mitigate cumulative impacts to water resources. The Build Alternative will 

implement appropriate BMPs and other projects also would undergo their own 

environmental review and permitting processes, and BMPs and mitigation measures 

would be required for these projects to avoid and minimize adverse cumulative impacts. 

Therefore, the Build Alternative will not cause an adverse or significant cumulative impact 

and will not result in a cumulatively considerable impact under CEQA. 

34 Refer to Master Response 16 regarding mitigation for impacts within the Rose Canyon 

watershed. 

35 Refer to Master Response 16 regarding mitigation for impacts within the Rose Canyon 

watershed. Restoration of vegetation communities, including those containing oaks, 

will be subject to maintenance and monitoring for approximately five years to ensure 

that the mitigation effort meets the established success criteria in accordance with an 

agency-approved habitat restoration plan. Success criteria typically address factors 

such as vegetative cover and survivorship, and plans typically include measures to 

avoid or reduce plant mortality as a result of herbivores such as gophers. The 

comments regarding mitigation opportunities for old growth oaks through treating 

existing oaks suffering from golden spotted oak borer infestation or planting new oak 

trees with gopher protection will be part of the record of proceedings for the Draft 

SEIS/SEIR. 
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36 The first sentence of this comment refers to a concrete-lined portion of Rose Creek 

located to the north of SR 52. However, the second part of the comment appears to 

refer to the existing concrete-lined portion of Rose Creek under the SR 52 and I-5 

interchange that will be replaced with a new channel design. Two responses are 

provided below. The first addresses temporary impacts associated with relocating an 

existing sewer line that crosses beneath the 1,000-foot-long concrete-lined channel 

located to the north of the SR 52/I-5 interchange. The second response addresses 

the proposal to replace the existing trapezoidal concrete-lined channel under the 

SR 52/I-5 interchange with a new lined channel with vertical walls. 

The proposed sewer relocation will occur using typical trench and backfill methods 

requiring the removal of accumulated sediment and associated vegetation from a 230-

foot segment of the channel. Accumulated sediment and associated vegetation within 

the remaining 770 feet of the existing lined channel will not be affected and will 

continue to provide habitat for and facilitate movement by native bird species. Upon 

completion of the sewer relocation, the disturbed portion of the channel will be 

restored to its original concrete-lined condition. Over time, it is expected that sediment 

will again accumulate within the restored portion of the channel allowing for the natural 

recruitment of vegetation that may be used by native bird species. 

Under the Build Alternative, the centerline of the concrete-lined portion of Rose Creek 

at the SR 52/I-5 interchange will be shifted slightly to the east and the existing 

trapezoidal channel will be replaced with a U-shaped channel with vertical walls. The 

existing lined channel is generally void of vegetation, although limited vegetation 

occurs in the channel where sediment deposited following storm events provides a 

substrate for limited plant establishment. Such “islands” of vegetation may be used by 

native bird species and facilitate movement along the channel, but are eventually 

scoured from the channel during subsequent storm events. Similar to the existing 

channel, the new channel will be concrete-lined and the opportunities for plant cover to 

become established will similarly be determined by the natural process of scouring 

and deposition that occurs during high flows associated with storm events. 

37 As described in Chapter 4.0, Section 4.7.5 of the Mid-Coast Corridor Transit Project 

Biological Resources Technical Report, Rose Canyon within the study area provides 

an avenue for local wildlife movement in a north–south direction between the eastwest portion of Rose Canyon to the east of I-5 and San Clemente Canyon. The 

technical report shows the connection provided by Rose Canyon and San Clemente 

Canyon to undeveloped lands on MCAS Miramar in Chapter 4.0, Figure 4-7, and 

acknowledges their function as regional wildlife corridors in the text. The undeveloped 

lands on MCAS Miramar provide the primary connection between these two east–west 

canyons. 

The portion of Rose Canyon within the study area does not connect areas to the east 

with areas farther to the west or south. The impacts of the project are located at the 

western limits of the Rose Canyon and San Clemente Canyon wildlife corridors, 
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neither of which extend across the existing tracks or I-5 and will not affect east–west 

wildlife movement. Wildlife is not expected to cross over the train tracks because the 

majority of high-quality habitat in Rose Canyon Open Space Park and Marian Bear 

Memorial Park is located to the east of the right-of-way. Areas to the west of the 

tracks are limited to disturbed or developed areas with little or no habitat value for 

wildlife and confined to a relatively narrow area between the right-of-way and I-5. 

A path along the east side of the open channel will remain and continue to allow for 

wildlife movement along the east side of the channel below SR 52. Additionally, the 

following design features have been incorporated into the project to facilitate wildlife 

movement through the concrete-lined channel under SR 52. The channel has been 

designed with a slight inclination toward the center of the channel. During dry seasons 

when the flows will be limited to irrigation runoff, the outer segments of the channel 

bottom will carry limited amounts of runoff and will continue to facilitate wildlife 

movement. The majority of riprap placed at the upstream and downstream ends of the 

proposed channel will not be grouted, which will allow sediment to fill gaps, creating a 

more natural and even surface for wildlife to cross. 

The project will not introduce any new barriers to park users. 

Construction of a pedestrian connection between the Rose Canyon Bicycle Path and 

the parks on the east side of the railroad right-of-way is not proposed as part of the 

Mid-Coast Corridor Transit Project. Such a connection is not proposed as mitigation 

because the project will not have any adverse or significant impacts to existing east–

west bicycle and pedestrian facilities in Rose Canyon. Mitigation and avoidance 

measures are proposed when adverse and significant impacts are identified. 

38 The portion of Rose Creek from the south end of Marian Bear Memorial Park to 

Mission Bay Park is not officially designated a park by the City of San Diego and 

therefore was not included or identified as a community, park, or recreational facility in 

the Draft SEIS/SEIR analysis. Impacts to the Rose Creek channel and adjacent 

riparian habitat inside and outside of designated parkland will be subject to regulation 

by several resource agencies, including the California Department of Fish and Wildlife, 

the U.S. Army Corps of Engineers (USACE), and the Regional Water Quality Control 

Board, all of which consider impacts to downstream resources during the permitting 

process. Typically, permit conditions include provisions for avoiding or minimizing 

impacts to downstream resources. Mitigation, including minimizing permanent 

impacts, restoring temporarily impacted areas, and providing compensatory mitigation, 

will be implemented for all impacts to biological resources regardless of the location 

along the project alignment and regardless of whether the areas are identified as 

recreational facilities. Impacts to and mitigation for Rose Creek are described in 

Chapter 4.0, Sections 4.8.3.2, 4.8.4, and 4.17.3.2 of the Final SEIS/SEIR. 
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39 The existing 700-foot-long concrete-lined trapezoidal channel portion of Rose Creek at 

the SR 52 and I-5 interchange will be replaced with a concrete-lined open channel that 

will essentially serve the same function as the existing channel. In addition, through 

coordination with the USACE, an open channel design at SR 52/Rose Creek was 

selected to replace the box culvert as the preferred design option of the Build 

Alternative. Retaining an open design allows for all wildlife, including birds, to use the 

channel to move between patches of native habitat located to the north and south of 

the concrete-lined channel. As noted in response to Comment 37, a path will be 

retained along the east side of the open channel and will continue to be available for 

wildlife movement. Only one federally listed bird species was identified within the 

project area, the coastal California gnatcatcher (Polioptila californica californica), and 

this species is not expected to frequently use the concrete-lined channel. 

40 As described in the Construction Impacts Technical Report, the project will be 

constructed in phases along the MTS right-of-way. Therefore, construction will not 

disrupt the entire project area at one time. Impacts to habitat within Rose Canyon will 

be limited to relatively narrow linear areas within or immediately adjacent to the 

existing MTS right-of-way (i.e., larger patches of habitat will not be impacted). The 

majority of vegetation within the project area will not be impacted. Therefore, it is 

anticipated that bird species will continue to use habitat adjacent to the construction 

sites to move within the corridor and it is not expected that construction will adversely 

affect the movement of birds within the study area. 

41 Mitigation for temporary impacts (e.g., restoration of temporarily disturbed areas) will 

occur on site and will restore disturbed areas to pre-project conditions at a minimum, 

using only appropriate native species. As noted in Chapter 4.0, Section 4.8.4 of the 

Draft SEIS/SEIR, Mitigation Measure BIO1 states that revegetated areas will be 

maintained and monitored for approximately five years to ensure successful 

reestablishment of vegetation communities. Restoration of vegetated areas will 

require the establishment of appropriate native vegetation communities, which in some 

cases will improve existing conditions. All mitigation will be subject to the approval of 

resource agencies with applicable jurisdiction. As described in response to Comment 

35, revegetated areas will be subject to success criteria established as part of the 

required permits to be obtained by the USACE, the RWQCB, and the CDFW. 

42 Refer to Master Response 16 regarding mitigation for impacts within the Rose Creek 

watershed. 

43 The Draft SEIS/SEIR identifies measures for avoiding impacts relating to off-site 

sedimentation or contamination during construction. Temporary construction site 

BMPs are listed in the discussion of water resources in Chapter 4.0, Table 4-35 of the 

Draft SEIS/SEIR, and Chapter 6.0, Section 6.11.1 of the Construction Impacts 

Technical Report. Project measures include temporary sediment control BMPs (e.g., 

fiber rolls, perimeter control, siltation fences, hay bales) in addition to the exclusionary 
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fencing proposed as a measure to avoid impacts to vegetation communities. 

As described in Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR, with the 

implementation of avoidance, noise minimization, and/or noise attenuation measures, 

short-term construction noise impacts to wildlife will be avoided or minimized, and no 

adverse impacts to special-status wildlife will occur. As further stated in Section 

4.17.3.2, “The Rose Creek Bicycle Trail and adjacent disturbed upland areas would 

remain accessible during construction and would allow limited wildlife movement 

through the area. By minimizing nighttime construction activity whenever feasible and 

using shielded lights for nighttime security lighting in the area, the use of the area by 

nocturnal species will not be significantly affected.” 

44 With respect to noise, Master Response 14 describes the additional noise analysis for 

Rose Canyon Open Space Park that was completed in response to comments on the 

Draft SEIS/SEIR. The noise analysis for locations within Marian Bear Memorial Park 

was described in the Draft SEIS/SEIR and the Noise and Vibration Technical Report. 

The increased frequency of trains will reduce the amount of time between trains, 

particularly during peak hours. As a result of the proximity of existing development 

along some portions of Rose Creek, and the current operation of heavy rail trains, 

wildlife in the vicinity have adapted to the existing level of disturbance, including 

periodic noise events. Implementation of the project is not expected to expand the 

area adjacent to the right-of-way that is subject to periodic noise disturbance from rail 

activity. 

The section of the project alignment through Rose Canyon will not include any lighting 

elements or fixtures in that area. Refer to Master Response 13 regarding the lighting 

impacts of the project. In addition, refer to Master Response 15 for additional 

information regarding the visual analysis for Rose Canyon Open Space Park. 

45 The frequency and the magnitude of noise events both contribute to the severity of the 

impacts. The FTA Transit Noise and Vibration Impact Assessment Guidance Manual

(FTA, 2006) accounts for both the magnitude and frequency of passby noise. Increased 

train frequency has the potential to result in noise and lighting impacts. However, as 

described in Master Response 13, lighting related to the project will not result in adverse 

impacts to adjacent habitat. As described in response to Comment 44, the project will not 

expand the area adjacent to the right-of-way that is subject to periodic disturbance from 

noise related to rail activity, and the noise levels associated with the project will be below 

the existing ambient levels. Therefore, the impacts associated with noise and lighting in 

the Rose Canyon/Rose Creek area will not be significant. 
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46 The evaluation of long-term noise and vibration impacts for the project considered the 

increased frequency of the Trolley Blue Line. The cumulative noise and vibration 

analysis is documented in Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR under 

the heading "Noise and Vibration." As indicated in this section, the cumulative impacts 

from the future expansion of I-5 and the LOSSAN double tracking were among the 

projects considered as part of the cumulative noise analysis. Refer to the response to 

Comment 49. As described in response to Comment 1, the impact of the high-speed 

rail project is not included in the analysis, as the alignment of this project has not yet 

been determined. The total time that train sets, including trains on the LOSSAN and 

Trolley tracks, will be passing one specific point during any given daylight hour will be 

less than 5 minutes (i.e., under 8.33 percent). 

47 The project has been designed to minimize the impact on Rose Canyon Open Space 

Park as well as impacts to MHPA lands. The project is located within existing railroad 

right-of-way at the edge of, rather than through, the open space and is adjacent to the 

existing I-5 transportation corridor. 

Chapter 4.0, Section 4.8.3.2 of the Draft SEIS/SEIR describes the impacts of the 

project to vegetation communities, the wildlife corridor, and habitat linkages, as well as 

the direct and indirect impacts to the MHPA (see also the Biological Resources 

Technical Report). Chapter 4.0, Section 4.8.4 of the Draft SEIS/SEIR describes the 

proposed mitigation measures. With implementation of the identified mitigation 

measures, both direct and indirect impacts related to biological resources will be 

reduced to a less-than-significant level, as described in Chapter 4.0, Section 4.8.5.2 of 

the Draft SEIS/SEIR. 

Refer to responses to Comments 2 through 7 regarding the potential for the project to 

contaminate wetlands and other habitat as a result of toxic materials. As stated in 

Chapter 4.0, Section 4.5 of the Draft SEIS/SEIR, “Mobile Source Air Toxics are not 

generated by LRT projects, such as the Mid-Coast Corridor Transit Project.” 

Additionally, as stated in Chapter 4.0, Section 4.10.3.2 of the Draft SEIS/SEIR, 

“operation and maintenance of the Build Alternative would not involve the regular use 

of hazardous materials.” 

As discussed in Chapter 5.0, Section 5.1.2.2 of the Biological Resources Technical 

Report, “Considering the urbanized setting of the study area and the edge effects 

already created by the existing LOSSAN tracks along Rose Creek and at the San 

Diego River, the project is not expected to substantially increase edge effects.” 

Therefore, indirect impacts, including lighting and noise, will not be adverse. 

Refer to Master Response 14 for information regarding the supplemental noise 

analysis that was prepared for Rose Canyon Open Space Park to confirm the 

conclusions that were presented in the Draft SEIS/SEIR. The section of the project 

alignment through Rose Canyon will not include any lighting elements or fixtures. 

Refer to Master Response 13 for a discussion of project lighting impacts. 
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As stated in the responses to previous comments, the project will not result in adverse 

noise or visual impacts on Rose Canyon Open Space Park, and therefore a berm is 

not needed as mitigation for these impacts. Refer to Master Response 17 for the 

potential to construct an earthen berm. 

48 Refer to the response to Comment 13. The trail is located within the transportation 

right-of-way. The noise analysis for the Draft SEIS/SEIR included an evaluation of the 

trails within Marian Bear Memorial Park (Cluster 56b), as documented in the MidCoast Corridor Transit Project Noise and Vibration Impacts Technical Report and in 

Chapter 4.0, Section 4.7.3.2 of the Draft SEIS/SEIR. With implementation of 

Mitigation Measure N2, as described in Chapter 4.0, Table 4-14 of the Draft 

SEIS/SEIR, there will be no moderate noise impacts to Marian Bear Memorial Park. 

Further, refinements made to the Build Alternative after circulation of the Draft 

SEIS/SEIR eliminated the moderate noise impacts to Marian Bear Memorial Park and 

mitigation is not required. In addition, as described in Master Response 14, noise 

impacts to recreational users of trails in Rose Canyon Open Space were also 

evaluated and will be less than significant. 

49 Refer to response to Comment 46, which states that the evaluation of cumulative 

noise impacts includes the effects of increased train frequency on the LOSSAN tracks. 

Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR addresses cumulative impacts of 

the project related to noise, including consideration of other transportation projects in 

the corridor. As stated in this section, the project’s contribution to cumulative noise 

impacts in the Mid-Coast Corridor is not cumulatively considerable, as the major 

source of future noise impacts is roadway vehicle noise, not LRT noise. As noted in 

the previous responses, the Rose Canyon Bicycle Path is classified as a 

transportation use and therefore is not a noise-sensitive use. Refer to Master 

Response 14 for information regarding the noise analysis for recreational trails in Rose 

Canyon Open Space Park, which were evaluated as noise-sensitive uses. 

Refer to the response to Master Response 13 regarding visual impacts of the project 

and Master Response 17 regarding the use of earthen berms for mitigation. 

50 Refer to the response to Comment 15. 

51 As discussed in Chapter 5.0, Section 5.3.2.2 of the Biological Resources Technical 

Report under the heading “Special-Status Wildlife,” the noise level threshold used to 

analyze potential noise impacts to the coastal California gnatcatcher and other 

federally listed bird species is 60 dBA Leq or ambient levels, whichever is higher. 

Noise measurements were taken within the vicinity of occupied coastal California 

gnatcatcher habitat to determine if the threshold is anticipated to be exceeded during 

construction and project implementation. In addition, potentially suitable habitat for 

coastal California gnatcatcher, least Bell’s vireo, southwestern willow flycatcher, and 
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light-footed clapper rail was identified within the project area. Mitigation Measures 

CON12, CON13, and CON14 include the implementation of breeding season 

avoidance, noise minimization, and/or noise attenuation measures. With the 

implementation of these mitigation measures, potential short-term indirect impacts to 

coastal California gnatcatcher, least Bell’s vireo, southwestern willow flycatcher, and 

light-footed clapper rail from construction noise will not be adverse. 

Refer to the response to Comment 44 regarding the indirect effects of increased rail 

frequency. 

52 The use of low-impact frogs increases system costs and long-term maintenance; 

therefore, they are not used in locations where noise impacts will not occur. Lowimpact frogs will be specified in locations where typical cross-overs would otherwise 

result in a noise impact to sensitive receivers. As a result of engineering studies, the 

crossover in the vicinity of Marian Bear Memorial Park has been removed in the 

Refined Build Alternative evaluated in the Final SEIS/SEIR; thus, no low-impact frog 

will be required at this location. Refer to the Noise and Vibration Impacts Technical 

Report and Chapter 4.0, Section 4.7.3.3 of the Final SEIS/SEIR, which have been 

updated to reflect the Refined Build Alternative, for additional information. 

53 As with the cumulative noise impact evaluation described in response to Comment 44, 

the analysis of cumulative vibration impacts accounted for the anticipated future 

increase in rail activity along the LOSSAN corridor. The results of this analysis 

concluded that there will be no adverse vibration impacts within Rose Canyon 

because Rose Canyon is not vibration sensitive per FTA criteria. 

The cumulative vibration analysis is documented in Chapter 4.0, Section 4.19.3.2 of 

the Draft SEIS/SEIR under the heading, "Noise and Vibration." As stated in this 

section, "Vibration impacts of the Build Alternative are localized and not likely to 

combine with vibration impacts of other projects. In addition, the vibration of project 

LRT vehicles would not increase or compound vibration from freight or passenger 

trains....Further, the vibration impacts of the Build Alternative would be fully mitigated 

to no impact under NEPA and less than significant under CEQA. Therefore, the Build 

Alternative and options would not cause an adverse or significant cumulative noise or 

vibration impact and would not result in cumulatively considerable impacts under 

CEQA." Refer to the Noise and Vibration Impacts Technical Report for additional 

information regarding the evaluation of vibration impacts. 

54 Refer to Master Response 15 for information regarding the visual analysis for Rose 

Canyon Open Space Park. The visual impact analysis for the project follows 

guidelines in the Visual Impact Assessment for Highway Projects (FHWA, 1988), 

which is applicable to many types of transportation projects. The analysis uses 

representative locations to evaluate the overall and worst-case visual impacts of the 

project. The analysis factors in elements such as the level of contrast with the existing 
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setting, removal of visual resources (such as vegetation), obstruction of scenic views 

or view corridors, viewer exposure, and anticipated viewer response. Refer to Chapter 

3.0 of the Visual Impacts Technical Report for a description of the methodology. Use 

of this methodology aims to evaluate visual impacts of representative locations of the 

landscape, which would meet the same goals as the recommended method in the 

comment. 

Refer to Appendix C of the Visual Impacts Technical Report for an analysis of 

candidate key views, including the consideration of a number of views near the Santa 

Fe RV Park Resort and business parks along Morena Boulevard. Candidate Key View 

2, located east of the Santa Fe RV Park Resort, which looks north from a business 

park at Morena Boulevard and Ariane Drive, also is evaluated in the technical report. 

As summarized in Table C-1 of the technical report, visual quality and resources 

impacts on Candidate Key View 2 were determined to be low; therefore, this key view 

was not selected for simulation. 

55 Refer to Master Response 15 for information regarding the visual analysis for Rose 

Canyon Open Space Park. 

For structure design and aesthetic finishes, Mitigation Measures VR2 and VR3, as 

described in Chapter 4.0, Section 4.4.4 of the Draft SEIS/SEIR, will be implemented to 

mitigate visual impacts. 

Mitigation Measure VR1, presented in Chapter 4.0, Section 4.4.4 of the Final 

SEIS/SEIR, describes the design of structures within and adjacent to the Caltrans 

right-of-way. Mitigation Measure VR1 notes compatibility with the I-5 North Coast 

Corridor Project-Design Guidelines, whose study area extends from La Jolla Village 

Drive in San Diego north to Harbor Drive in Oceanside. All design of the Mid-Coast 

Corridor Transit Project within or adjacent to the Caltrans right-of-way, including 

design themes specified in the I-5 North Coast Corridor Project-Design Guidelines, will 

be developed in coordination with Caltrans during final design. 

Additionally, concrete wall treatments, which will be applied as appropriate, including 

Codes G and H (vines and plant material on and at base of walls to soften the 

appearance of walls), are listed in Chapter 6.0, Table 6-2 of the Visual Impacts 

Technical Report and referenced in Chapter 4.0, Section 4.4.4 of the Final SEIS/SEIR.

In response to comments, additional design measures have been incorporated to 

address the appearance of TPSS sites. The design measures described in Chapter 

4.0, Section 4.4.3.2 of the Final SEIS/SEIR under the heading “Project Measures to 

Minimize or Avoid Impacts” will provide for appropriate landscape screening to ensure 

that the facility will be screened from trails within Rose Canyon Open Space Park. 
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56 Refer to Master Response 15 for information regarding the visual analysis for Rose 

Canyon Open Space Park. The Rose Canyon Bicycle Path is adjacent to, but not 

within, the park, and the railroad right-of-way is between the bicycle path and the open 

space park. As discussed in response to Comment 46, the total time in a given 

daylight hour when trains will be passing by a particular point is five minutes. While it 

will be more likely for bicyclists to see a Trolley or other train while using the Rose 

Canyon Bicycle Path, this is not anticipated to result in an adverse impact to the use of 

the path for nonmotorized transportation. 

Mitigation Measure VR1, in Chapter 4.0, Section 4.4.4 of the Final SEIS/SEIR, 

describes the design of structures within and adjacent to the Caltrans right-of-way. 

Mitigation Measure VR1 notes compatibility with the I-5 North Coast Corridor ProjectDesign Guidelines, whose study area extends from La Jolla Village Drive in San Diego 

north to Harbor Drive in Oceanside. All design within or adjacent to the Caltrans rightof-way, including design themes specified in the I-5 North Coast Corridor ProjectDesign Guidelines, will be developed in coordination with Caltrans during final design. 

57 Consistency with the Coastal Act would be subject to review by the California Coastal 

Commission (CCC) during the Coastal Development Permit process and is discussed 

in Chapter 4.0, Section 4.1.3.2 of the Final SEIS/SEIR. As stated in this section, the 

project is consistent with the Coastal Act. The project is consistent with the polices of 

the Coastal Act that provide for preservation and enhancement of visual resources, 

water quality, air quality, energy conservation, reductions in vehicle miles traveled, 

public access, and public transit. However, because a small portion of project 

development would involve fill of coastal wetlands and impacts to an ephemeral basin 

that could potentially be considered an environmentally sensitive habitat area (ESHA) 

due to the presence of the federally endangered San Diego fairy shrimp, the project 

creates a potential conflict with the allowable use tests of the Coastal Act’s wetland 

and ESHA policies. The Coastal Act requires CCC to resolve such conflicts in a 

manner that on balance is most protective of coastal resources. 

The project has been designed to minimize wetland impacts to the maximum extent 

practicable, and would include off-site restoration, creation, and enhancement 

activities that mitigate impacts and result in an overall increase in wetland habitat. 

Further, the impacts to San Diego fairy shrimp would be mitigated through off-site 

restoration, creation, and enhancement activities that would result in an increase in 

higher-quality habitat for the species affected. Additionally, implementation of the 

project would improve water and air quality, conserve energy, reduce vehicle miles 

traveled, and improve public access and public transit. These benefits of the project, 

combined with the minimization and mitigation measures, support a finding that 

proceeding with the project is more protective of coastal resources than the No-Build 

Alternative. As shown in Chapter 2.0, Figure 2-1 of the Mid-Coast Corridor Transit 

Project Land Use Impacts Technical Report, the portion of the alignment north of 

Balboa Avenue and south of Gilman Drive is outside of the Coastal Zone. 
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As noted in response to Comment 55, mitigation measures for structure design and 

aesthetic finishes have been proposed; these measures will apply to structures 

between Balboa Avenue and Gilman Drive where features of the project will result in 

adverse visual impacts. Refer to Mitigation Measures V1, V2, and V3 in Chapter 4.0, 

Section 4.4.4 of the Final SEIS/SEIR for a description of mitigation measures that will 

apply to structure design. Additionally, concrete wall treatments, which will be applied 

as appropriate, including Codes G and H (vines and plant material on and at base of 

walls to soften the appearance of walls), are listed in Chapter 6.0, Table 6-2 of the 

Visual Impacts Technical Report and referenced in Chapter 4.0, Section 4.4.4 of the 

Final SEIS/SEIR. 

In addition, Chapter 4.0, Section 4.4.4 of the Final SEIS/SEIR (Mitigation Measure 

VR7) states: “All new plantings, regardless of location, would not include invasive 

plants or noxious weeds, but would include native and/or drought-resistant plants 

wherever appropriate.” 

58 Mitigation for temporary impacts (e.g., restoration of temporarily disturbed areas) will 

occur on site. Mitigation Measure CON9 states that, “The location and configuration of 

wetland vegetation communities within restoration areas in the San Diego River and 

Rose Creek would be adjusted to ensure that restored areas beneath bridges are 

limited to wetland communities that can tolerate reduced sunlight availability. Based 

on the presence of wetland communities under existing bridges over the San Diego 

River and Rose Creek, similar communities, including cismontane alkali marsh, 

mulefat scrub, and in some cases southern willow scrub, would be planted under the 

proposed bridges. Restored areas adjacent to the proposed bridges and that are not 

subject to long-term shading would be revegetated primarily with southern willow 

scrub.” This will ensure that temporary impacts to native plants will be restored with 

vegetation known to flourish in areas where shading already occurs. As described in 

the response to Comment 35, revegetated areas will be subject to maintenance and 

monitoring for approximately five years in accordance with permit requirements to 

ensure successful establishment. 

59 As stated in Chapter 3.0, Section 3.3.1.2 of the Biological Resources Technical 

Report, “Where the alignment and stations are elevated, long-term indirect impacts 

includes shading from elevated structures (bridge crossings, elevated track sections, 

and stations) that could affect plants and vegetation communities by limiting growth 

and productivity, disrupting reproduction, and changing species composition or 

community type. However, impacts to plants and vegetation communities are likely 

dependent on several factors such as height, size, location, orientation, construction of 

overhead structures, and the tolerance of the affected resources themselves (i.e., 

plants and vegetation communities) to shading.” 

As stated in Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR, “The Build 

Alternative and options generally would include the same land use and transportation 

projects as the No-Build Alternative, except that Route 150 would be eliminated as 
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planned under the 2030 RTP, and the Mid-Coast Corridor Transit Project would be 

implemented, as described in Chapter 2.0.” Projects listed under the 2030 RTP are 

listed in Chapter 5.0, Section 5.2.1 and are shown in Chapter 2.0, Figure 2-3 of the 

Draft SEIS/SEIR. Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR further states, 

“The Build Alternative is primarily located within a transportation corridor, does not 

conflict with the approved habitat conservation plan, and does not result in significant 

and unavoidable impacts....Projects that are consistent with the MSCP mitigation 

ratios as specified by the Subarea Plan (City of San Diego, 1997) and implementing 

ordinances (City of San Diego, 2012) are not expected to result in a cumulatively 

considerable impact for those biological resources adequately covered by the 

MSCP....The Build Alternative would be consistent with the MSCP ratios. Other 

foreseeable projects also would undergo environmental review and permitting and are 

expected to be consistent with the MSCP.” 

Refer to response to Comment 58 regarding mitigation for impacts resulting from 

shading. 

60 Proposed improvements to the open channel are shown on the Draft and Final 

SEIS/SEIR Plan Sets. Typical sections and limits of improvements are shown as 

follows: 

The Draft SEIS/SEIR Plan Sheet No. 41 identifies the out-to-out width of the channel 

is approximately constant at 28 feet over the majority of its length, and the 

corresponding Final SEIS/SEIR Plan Sheet No. 42 identifies 26 feet out-to-out width of 

the channel. 

The Draft SEIS/SEIR Plan Sheet No. 79 and 80, and corresponding Final SEIS/SEIR 

Plan Sheet No. 84 and 85 identify the cast-in-place reinforced concrete open channel 

beginning approximately at “NB Track” Sta 508+30 and ending at approximately “NB 

Track” Sta 515+34 and loosely matches the alignment of the existing Rose Creek 

paved channel, with a total length of the channel measured at 677 feet 7.5 inches 

along its centerline. 

The existing 700-foot-long concrete-lined trapezoidal channel portion of Rose Creek at 

the SR 52 and I-5 interchange will be replaced with a concrete-lined open channel that 

will essentially serve the same function as the existing channel. The project will not 

alter the flow regime within the creek. As stated in response to Comment 37, the 

concrete-lined channel has been designed with a slight inclination toward the center of 

the channel. During dry seasons when the flows will be limited to irrigation runoff, the 

outer segments of the channel bottom will carry limited amounts of runoff and will 

continue to facilitate wildlife movement. The majority of riprap placed at the upstream 

and downstream ends of the proposed channel will not be grouted, which will allow 

sediment to fill gaps, creating a more natural and even surface for wildlife to cross. A 

path along the east side of the open channel will remain and continue to allow for 

wildlife movement along the east side channel below SR 52. As discussed in Chapter 
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4.0, Section 4.8.2.2 of the Draft SEIS/SEIR, the existing concrete channel provides 

minimal vegetative or habitat cover and the riparian corridor along Rose Creek within 

the project area does not function as a regional wildlife corridor or habitat linkage. 

Caltrans is responsible for maintenance of the channel. Because maintenance of the 

channel will be the same as it is currently, there will be no adverse impacts to native 

habitat as a result of maintenance operations. The existing access path will continue 

to be used for any necessary maintenance within the concrete-lined channel. See the 

response to Comment 36 regarding impacts to vegetation within concrete-lined 

channels. 

61 Refer to Master Response 16 regarding mitigation for impacts within the Rose Creek 

watershed. As described in response to Comment 41, restoration of vegetated areas 

will require the establishment of appropriate native vegetation communities, which in 

some cases will improve existing conditions. 

62 Refer to Master Response 15 for information regarding the visual analysis for Rose 

Canyon Open Space Park. 

As discussed in response to Comment 55, mitigation measures for retaining walls 

include Mitigation Measure VR3 and the wall treatments discussed in Chapter 6.0, 

Table 6-2 of the Visual Impacts Technical Report. 

While the I-5 North Coast Corridor Project does end at La Jolla Village Drive, 

Mitigation Measure VR1 in Chapter 4.0, Section 4.4.4 of the Draft SEIS/SEIR states 

that the design of structures from SR 52 to a location north of Voigt Drive will be 

compatible with the I-5 North Coast Corridor Project where these structures are within 

Caltrans right-of-way. This measure was revised for the Final SEIS/SEIR to also apply 

to structures adjacent to the Caltrans right-of-way in this area. 

In addition, as discussed in response to Comment 55, all design within or adjacent to 

the Caltrans right-of-way, including design themes specified in the I-5 North Coast 

Corridor Project-Design Guidelines, will be developed in coordination with Caltrans 

during final design. 

63 As described in the responses to detailed comments above, the level of detail of 

construction and operational impacts is sufficient to identify the mitigation measures 

with sufficient detail to ensure mitigation of impacts to a level below significance. In 

addition, a MMRP will be adopted by the SANDAG Board of Directors in connection 

with the final approval action on the project. At a minimum, the MMRP will identify the 

timing of each measure, the agency responsible for monitoring each measure, and the 

agency responsible for enforcing each measure. As described in Chapter 8.0 of the 

Draft and Final SEIS/SEIRs, coordination with agencies and stakeholders has been 

initiated and will be ongoing as design and construction of the project progress. 
Volume 3 – Comments and Responses 

Groups / Organizations 

Friends of Rose Creek - 

Zirk, Karin, Founder and Executive Director - ID230 

MID-COAST CORRIDOR TRANSIT PROJECT 

332 September 2014 

Com ID Response 

64 The project operator and project contractor are required to comply with regional and 

local regulations regarding the appropriate handling and disposal of waste generated, 

solid and otherwise, during construction. These regulations are in addition to the 

project measures specified in Chapter 4.0, Section 4.17.3.3 of the Draft SEIS/SEIR 

under the heading "Hazardous Materials" and Chapter 6.0, Section 6.8 of the 

Construction Impacts Technical Report. SANDAG commits to the project features 

through the adoption of the project’s MMRP. 

The following discussion addresses specific concerns named by the commenter. An 

Air Quality Monitoring Plan will be prepared by the construction contractor and 

approved by SANDAG to address potential exposure hazards pertaining to airborne 

dust in areas of contamination, and will be in compliance with all applicable federal, 

state, and local regulations. The plan will be adhered to during construction and site 

activities. Airborne dust is controlled by spraying water on the work area according to 

the regulations of the San Diego Air Pollution Control District, which is a requirement 

identified in Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR under the heading 

“Air Quality.” Additionally, Chapter 4.0, Table 4-35 of the Draft SEIS/SEIR lists 

temporary construction BMPs, including temporary soil stabilization and sediment 

control BMPs. 

The control and handling of sediment from the project is specified within the projectspecific Storm Water Pollution Prevention Plans mandated by the State Water 

Resources Control Board, as described in Chapter 4.0, Section 4.17.3.2 of the Draft 

SEIS/SEIR under the heading “Water Quality.” 

Areas of suspected asbestos will be sampled by a state and federally qualified person. 

The results of the tests will determine the content of the material, which will allow for 

determination of the appropriate disposal methods. As stated in Chapter 4.0, Section 

4.17.3.2 of the Final SEIS/SEIR under the heading “Hazardous Materials,” if asbestoscement pipes are encountered during construction, then appropriate actions will be 

taken by specialists to remove asbestos-cement pipes in accordance with local, state, 

and federal regulations. To ensure worker and public safety, removal and disposal of 

asbestos-cement pipes would follow the requirements of the Occupational Safety and 

Health Administration as stated in 29 CFR 1910.1001 and 29 CFR 1926.1101. 

Removal must also follow worker protection rules as stated in 40 CFR Part 763 

Subpart G, National Emission Standards for Hazardous Air Pollution, as specified 

under Rule 40, CFR 61, Subpart M, and the Clean Air Act as required under USC 

7401 et seq. 

Areas of suspected soil contamination, including toxic oils or grease, will be sampled 

prior to the start of construction in accordance with the project measures identified in 

Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR under the heading “Hazardous 

Materials.” If sampling in those areas identifies contamination in areas that will be 

impacted by construction, appropriate methods will be used to remove and dispose of 

the contaminated materials in accordance with applicable regulations (refer to Chapter 
Volume 3 – Comments and Responses

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Friends of Rose Creek - 

Zirk, Karin, Founder and Executive Director - ID230 

MID-COAST CORRIDOR TRANSIT PROJECT 

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2.0 the Mid-Coast Corridor Transit Project Hazards Materials Technical Report for a 

detailed description of applicable regulations). Fine dust particles will be controlled 

using water spray similar to the airborne dust control, described above. 

As acknowledged in Chapter 4.0, Section 4.17.3.2 of the Final SEIS/SEIR, 

construction activities will have temporary adverse air quality impacts related to 

construction emissions of NOX and CO2. To minimize potential impacts during 

construction, the project will be required to comply with regional and state rules and 

regulations regarding the registration and operation of equipment, as well as the 

removal and disposal of asbestos (see SDAPCD Rules 12, 54, and 361.145, as well 

as CARB’s Off-Road Diesel Vehicle Registration, in Section 4.17.3.2). The project will 

include the following BMPs: minimize idle times of construction equipment; maintain 

equipment in good condition; and control construction dust through watering of 

earthwork during grading activities. The statement referenced in the comment from 

Section 4.17 of the Draft SEIS/SEIR that construction impacts could be mitigated 

through a combination of measures included in project design, mitigation measures, 

compliance with regulations, and BMPs is a summary statement, intended to direct the 

reader to the appropriate sections that describe each of those measures. 

65 Refer to the response to Comments 2 and 7. 

66 The details requested by the commenter will be developed for the plans and programs 

cited as final design of the project progresses. Final work management plans and 

monitoring documents cannot be developed until final plans are available and a 

contractor is selected. However, at this stage of project development, the level of 

detail provided is sufficient to support informed decision-making and meaningful public 

comment regarding the project measures that will adequately address constructionrelated impacts. SANDAG is committed to implementing the described project 

measures to reduce or avoid construction-related impacts. 

67 Responses to specific comments are provided in the above responses. 

 
Volume 3 – Comments and Responses 

Groups / Organizations 

Good Samaritan Episcopal Church - 

Chase, Christopher, Senior Pastor and Forte, John P., Director - ID340 

MID-COAST CORRIDOR TRANSIT PROJECT 

334 September 2014 

Good Samaritan Episcopal Church - 

Chase, Christopher, Senior Pastor and Forte, John P., Director - 

ID340 
Volume 3 – Comments and Responses

Groups / Organizations 

Good Samaritan Episcopal Church - 

Chase, Christopher, Senior Pastor and Forte, John P., Director - ID340 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 335 
Volume 3 – Comments and Responses 

Groups / Organizations 

Good Samaritan Episcopal Church - 

Chase, Christopher, Senior Pastor and Forte, John P., Director - ID340 

MID-COAST CORRIDOR TRANSIT PROJECT 

336 September 2014 
Volume 3 – Comments and Responses

Groups / Organizations 

Good Samaritan Episcopal Church - 

Chase, Christopher, Senior Pastor and Forte, John P., Director - ID340 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 337 
Volume 3 – Comments and Responses 

Groups / Organizations 

Good Samaritan Episcopal Church - 

Chase, Christopher, Senior Pastor and Forte, John P., Director - ID340 

MID-COAST CORRIDOR TRANSIT PROJECT 

338 September 2014 
Volume 3 – Comments and Responses

Groups / Organizations 

Good Samaritan Episcopal Church - 

Chase, Christopher, Senior Pastor and Forte, John P., Director - ID340 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 339 
Volume 3 – Comments and Responses 

Groups / Organizations 

Good Samaritan Episcopal Church - 

Chase, Christopher, Senior Pastor and Forte, John P., Director - ID340 

MID-COAST CORRIDOR TRANSIT PROJECT 

340 September 2014 

Submission ID340 Good Samaritan Episcopal Church Chase Christopher

Com ID Response

1 Your comment expressing support for the Mid-Coast Corridor Transit Project will be 

part of the record of proceedings for the Draft SEIS/SEIR. The concerns referenced 

in this comment are addressed in the subsequent responses. 

2 Construction hours will be limited by the City of San Diego noise permit to be 

obtained by the Construction Manager/General Contractor. City regulations, in 

general, prohibit work on Sundays and on legal holidays; the City Noise Permit will 

specify work hours, and it is expected that permit conditions will require the 

contractor to limit work on Sundays and legal holidays whenever possible. Project 

construction activities will be conducted in accordance with a Construction 

Management Plan that will be developed by the Construction Manager/General 

Contractor and approved by SANDAG. Implementation of the Construction 

Management Plan and construction phasing will be coordinated with representatives 

from Good Samaritan Episcopal Church to minimize any temporary construction 

impacts. Measures to minimize impacts to businesses during construction are 

described in Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR under the heading 

“Socioeconomic and Fiscal Impacts.”

3 Construction phasing and scheduling will be conducted in a manner to minimize 

impacts to adjacent properties to the extent feasible. During construction of the 

aerial structure along Genesee Avenue, left turns on Genesee Avenue will be 

prohibited at the Genesee Avenue and Eastgate Mall intersection for approximately 

12 months (as described in Chapter 3.0, Table 3-33 of the Draft SEIS/SEIR), 

although SANDAG will continue to investigate options to reduce the duration of the 

impacts as construction phasing is developed. During this time, detour routes using 

the adjacent intersections and roadways will be provided. As described in the 

footnote to Table 3-33, “Closures and vehicular movement prohibitions at these 

intersections would be phased such that adjacent intersections would not be affected 

concurrently.”

4 As shown on the Final SEIS/SEIR Plan Set, the easterly edge of the sidewalk is 

anticipated to shift farther east between 8 and 15 feet. To limit grading on the 

property, a small retaining wall is included as part of the project. 

Compensation for property acquired from the Good Samaritan Episcopal Church will 

be in accordance with the Federal Uniform Relocation Assistance and Real Property 

Acquisition Policies Act of 1970, as amended, the California Relocation Assistance 

Act of 1970, as amended, and SANDAG's Board of Director's Policy No. 021. 

5 The condition of the stained glass windows will be documented by the project 

contractor prior to the start of construction activities, and appropriate steps will be 

taken to protect the windows from damage as a result of construction of the project. 

The appropriate steps for protecting the windows during construction will be 
Volume 3 – Comments and Responses

Groups / Organizations 

Good Samaritan Episcopal Church - 

Chase, Christopher, Senior Pastor and Forte, John P., Director - ID340 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 341 

Com ID Response

determined in consultation with representatives of the Good Samaritan Church and 

could include covering windows, monitoring, and incidence response. Additionally, 

the steps identified to protect the windows will be taken prior to the start of 

construction activities in this location. This requirement will be included in the project 

specification to which the contractor will have to adhere. Project measures cannot 

extend to protection of the windows from third-party vandalism. 

6 The Final SEIS/SEIR Plan Set shows a retaining wall to reduce grading and 

preserve existing landscaping on the church site. The retaining wall will block the 

existing pedestrian walkway to the Memorial Garden. However, a new walkway will 

be constructed as part of the project and will be designed in coordination with 

representatives from the church.

7 Mitigation Measure VR6 only applies where tree removal results in an adverse visual 

impact. Mitigation Measure VR5 will apply in this case, and states: where 

ornamental vegetation associated with maintained landscaped areas is affected, it 

would be replaced in-kind or with similar vegetation types and quantities contingent 

on the approval of the land owner. 

8 Irrigation and lighting impacted by the project will be replaced. Signage on the 

corner of the property will not be affected by construction of the project. Refer to the 

response to Comment 4 regarding compensation.

9 No response is required because the right to locate a cross on church property is 

independent of the project and the SEIS/SEIR.

10 On November 15, 2013, the SANDAG Board of Directors approved the Refined Build 

Alternative, which includes center columns along Genesee Avenue. The project has 

been designed to use center columns rather than straddle bents wherever possible; 

however, two straddle bents could not be eliminated. One is at the Executive Drive 

Station, and the other is at the intersection of Regents Road and Genesee Avenue. 

11 The effects of LRT noise were assessed at this location (Noise Receiver Cluster 90, 

as shown in Chapter 4.0, Figure 4-19 of the Draft SEIS/SEIR) using guidance from 

the FTA Transit Noise and Vibration Impact Assessment Guidance Manual (FTA, 

2006). The elevation of the alignment was considered in the noise analysis. No 

adverse or significant noise impacts were predicted from LRT operation. Decreasing 

the minimum distance to the edge of the roadway from approximately 70 feet to 

approximately 55 feet would not result in a significant change in traffic noise levels. 

The existing daytime noise level is 63 dBA Leq at Cluster 90, and the project will 

introduce a level of 58 dBA Leq, which is less than the moderate impact criteria of 65 

dBA Leq for this location. Therefore, the project will not result in a noise impact and 

mitigation is not required.
Volume 3 – Comments and Responses 

Groups / Organizations 

Good Samaritan Episcopal Church - 

Chase, Christopher, Senior Pastor and Forte, John P., Director - ID340 

MID-COAST CORRIDOR TRANSIT PROJECT 

342 September 2014 

Com ID Response

12 Sufficient transit parking will be provided at the UTC Transit Center and, therefore, 

spillover parking is not anticipated. Further, as stated in Chapter 3.0, Section 3.4.4.2 

of the Draft SEIS/SEIR, there is little available on-street parking around the 

Executive Drive Station and the station will be approximately 1,500 feet (0.3 mile) 

from the UTC Transit Center. Thus transit passengers wishing to park near the 

Executive Drive Station who are unable to find a place to park will likely drive to the 

UTC Transit Center instead, which was taken into account in the parking capacity of 

the UTC Transit Center. While spillover parking is not anticipated to occur near the 

Executive Drive Station, control of unauthorized parking within private parking 

facilities will be the responsibility of the property owner.

13 Your comment regarding an expanded security camera system for the church will be 

part of the record of proceedings for the Draft SEIS/SEIR. 

 
Volume 3 – Comments and Responses

Groups / Organizations 

La Jolla Colony Community Association - 

DeFreitas, Sean, Community Association Manager - ID339 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 343 

La Jolla Colony Community Association - 

DeFreitas, Sean, Community Association Manager - ID339 
Volume 3 – Comments and Responses 

Groups / Organizations 

La Jolla Colony Community Association - 

DeFreitas, Sean, Community Association Manager - ID339 

MID-COAST CORRIDOR TRANSIT PROJECT 

344 September 2014 
Volume 3 – Comments and Responses

Groups / Organizations 

La Jolla Colony Community Association - 

DeFreitas, Sean, Community Association Manager - ID339 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 345 

Submission ID339 La Jolla Colony Community Association DeFreitas Sean

Com ID Response

1 Your comment expressing appreciation for outreach efforts has been noted; 

SANDAG is committed to continue working with property owners and businesses to 

minimize impacts related to the project.

2 The Mid-Coast Corridor Transit Project has been designed to avoid and minimize 

impacts, and mitigation measures have been incorporated to address adverse and 

significant impacts. Responses to concerns referred to in the comment are 

addressed in the responses to the more specific comments that follow.

3 As described in Chapter 4.0, Section 4.7.3.2 and illustrated in Figure 4-19 of the 

Final SEIS/SEIR, noise impacts within the La Jolla Colony area will be limited to 23 

units within the La Paz condominiums, identified as Clusters 57, 59, and 61 in the 

Final SEIS/SEIR (a cluster is a grouping of noise-sensitive uses, such as houses, 

that would experience similar operational noise from the project and have a similar 

existing noise environment). Noise levels at Cluster 61 will equal, but not exceed, 

the moderate impact threshold. At that location, the impact will be less than 

significant and no mitigation will be provided. Refer to Master Response 9 for 

additional information on the noise analysis and mitigation. 

The Final SEIS/SEIR identified the need for sound walls at two locations to mitigate 

noise impacts at 11 units within the La Paz condominiums (referred to as Mitigation 

Measures N2 and N3 in Chapter 4.0, Table 4-14 of the Final SEIS/SEIR). The noise 

impact analysis conducted in support of the SEIS/SEIR determined that the project 

will not generate noise that would exceed FTA noise-impact criteria at other locations 

within the La Jolla Colony. 

Freeway noise at some residences in La Jolla Colony will be reduced as a result of 

shielding that will be created in the area when the grade is elevated to install the 

light-rail tracks between the residences and the freeway. There will be no significant 

noise impacts to other residences within the La Jolla Colony or Barcelona 

developments because they will be farther from, or shielded from, the project. 

Two sound walls (Mitigation Measures N3 and N4 in the Draft SEIS/SEIR—referred to 

as Mitigation Measures N2 and N3 in Chapter 4.0, Table 4-14 of the Final SEIS/SEIR) 

were identified in the Draft SEIS/SEIR as mitigation for the noise impacts to 11 units in 

the La Paz condominiums; however, a single continuous sound wall encompassing both 

walls has been incorporated into the Final SEIS/SEIR Plan Set based on aesthetics and 

will provide equivalent noise mitigation. 

SANDAG has proposed mitigation measures for sound walls, including architectural 

design elements, aesthetic finishes, and landscaping requirements, as described in 

Chapter 4.0, Section 4.4.4 of the Draft SEIS/SEIR (Mitigation Measure VR3). Further, as 

identified in Chapter 6.0, Table 6-2 of the Mid-Coast Corridor Transit Project Visual 
Volume 3 – Comments and Responses 

Groups / Organizations 

La Jolla Colony Community Association - 

DeFreitas, Sean, Community Association Manager - ID339 

MID-COAST CORRIDOR TRANSIT PROJECT 

346 September 2014 

Com ID Response

Impacts Technical Report, one option for treatment of sound walls is the use of vines to 

help soften the appearance of a wall, control graffiti, and change the scale (see Code G). 

Master Response 12 provides additional information related to graffiti. 

4 The noise analysis was conducted in accordance with criteria from the FTA Transit 

Noise and Vibration Impact Assessment Guidance Manual (FTA, 2006), and the 

disclosed impacts are based on typical wind and weather conditions. Noise 

measurements were taken over a 24-hour period during regionally-typical weather 

conditions to represent what is commonly experienced in the community. 

Wind and weather conditions can affect noise levels over long distances; in general, 

sound travels faster and for a longer distance when humidity is increased. The 

effects of wind and weather conditions are negligible at the distances that will be 

affected by project-related noise. Noise impacts related to the project will not extend 

beyond 350 feet when unobstructed, or beyond 175 feet with intervening buildings. 

Because the project will be adjacent to I-5 in the La Jolla Colony area, the area within 

500 feet of I-5 is the area where existing noise levels are relevant to the project noise 

analysis. Because noise travels a short distance from I-5 to this area, the area 

experiences relatively constant noise from I-5 compared to areas farther from I-5 

where weather conditions affect the level of noise. 

5 SANDAG is committed to working with property owners and businesses to minimize 

construction impacts. Regular community updates will be provided during the 

construction phase to notify neighbors about changing traffic and detour routes and 

other construction impacts. The Transportation Management Plan to be prepared for 

the project (see Chapter 3.0, Section 3.4.7.2 of the Draft SEIS/SEIR) includes a 

public awareness campaign to inform the public of construction activity and 

roadway/lane closures and detours, real-time traffic information, incident 

management to respond to incidents on roadways near construction areas, and 

identification of alternative routes and detours.

6 Mitigation measures for landscape replacement are outlined in Chapter 4.0, Section 

4.4.4 of the Draft SEIS/SEIR and include Mitigation Measures VR4, VR5, VR6, and 

VR7. Measures include the requirement to replace existing landscaping that is 

temporarily affected during construction, to replace small trees at a 1:1 ratio (less 

than 6 inches in diameter at chest height), and to replace large trees at a 2:1 ratio 

(greater than 6 inches in diameter at chest height). 

Mitigation is proposed for the project features depicted in Key Views 8 and 23, 

referenced in the comment. For these key views (see Chapter 4.0, Table 4-4 of the 

Draft SEIS/SEIR), there will be no adverse impacts with mitigation. Also see Chapter 

6.0, Table 6-1 of the Visual Impacts Technical Report for a further explanation of the 

effectiveness of the proposed mitigation.
Volume 3 – Comments and Responses

Groups / Organizations 

La Jolla Colony Community Association - 

DeFreitas, Sean, Community Association Manager - ID339 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 347 

Com ID Response

7 As design of the project progresses, the design of sound walls will include input from 

community outreach and public coordination. As stated in response to Comment 3, 

SANDAG has proposed mitigation measures for sound walls, including architectural 

design elements, aesthetic finishes, and landscaping requirements, as described in 

Chapter 4.0, Section 4.4.4 of the Draft SEIS/SEIR (Mitigation Measure VR3). Master 

Response 12 provides additional information related to graffiti.

8 Based on analysis of power requirements and in consideration of comments received 

on the Draft SEIS/SEIR, TPSS 14 (now referred to as TPSS 12 in the Final 

SEIS/SEIR) has been relocated from Charmant Drive to the west side of I-5. It will 

be located on Caltrans right-of-way adjacent to the La Jolla Village Square shopping 

center. The TPSS and associated enclosure will be screened to ensure that the 

facility is visually compatible with surrounding uses. Refer to Chapter 4.0, Section 

4.4.3.2 of the Final SEIS/SEIR under the heading “Project Measures to Avoid or 

Minimize Impacts” for a discussion of design and/or landscaping measures that will 

be applied to TPSSs. Refer to Chapter 2.0, Section 2.3.5 for a summary of the 

changes made to TPSS locations since the Draft SEIS/SEIR.

 
Volume 3 – Comments and Responses 

Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

348 September 2014 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 
Volume 3 – Comments and Responses

Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 349 
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Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

350 September 2014 
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Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 351 
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Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

352 September 2014 
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Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 353 
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Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

354 September 2014 
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Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 355 
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Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

356 September 2014 
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Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 357 
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Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

358 September 2014 
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Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 359 
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Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

360 September 2014 

 
Volume 3 – Comments and Responses

Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 361 

Submission ID264 Laborers International Union of North America Drury Richard 

Com ID Response 

1 The Mid-Coast Corridor Transit Project Draft SEIS/SEIR was prepared in 

accordance with NEPA and CEQA requirements. Responses to the specific issues 

raised by the commenter are set forth below. Refer to the response to Comment 14 

with regard to mitigation for hazardous materials. 

2 Refer to the response to Comment 16 with regard to mitigation for impacts to water 

resources. 

3 Refer to the response to Comment 17 with regard to payment of mitigation fees. 

4 Refer to the response to Comment 10 with regard to recirculation. 

5 The commenter has the opportunity to participate in future hearings and 

proceedings related to the Mid-Coast Corridor Transit Project in the same manner 

as other members of the public. However, under CEQA, written responses are 

limited to comments submitted during the public comment period for the Draft 

SEIS/SEIR. 

6 The comment characterizing LlUNA Local 89 has been noted and will be part of the 

record of proceedings for the Draft SEIS/SEIR. 

7 The comment expressing interest in worker and community impacts has been noted 

and will be part of the record of proceedings for the Draft SEIS/SEIR. 

8 The commenter’s summary of NEPA has been noted and will be part of the record 

of proceedings for the Draft SEIS/SEIR. 

9 The commenter’s summary of CEQA has been noted and will be part of the record 

of proceedings for the Draft SEIS/SEIR. 

10 In July 2014, SANDAG issued a Supplemental Environmental Impact 

Statement/Supplement to the Subsequent Environmental Impact Report for a new 

impact to the federally endangered San Diego fairy shrimp. This species was 

identified in within the impact footprint for the project during surveys conducted in 

March 2014. This document was circulated for a 45-day public comment and 

review period from July 18 to September 2, 2014. 

Recirculation pursuant to CEQA Guidelines § 15088.5 is not required for the other 

topics covered in the Draft SEIS/SEIR because significant new information requiring 

the need for recirculation has not been added to what was presented in the Draft 

SEIS/SEIR. Additional information in the form of minor modifications to the Draft 

SEIS/SEIR and information provided in response to comments has been included in 
Volume 3 – Comments and Responses 

Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

362 September 2014 

Com ID Response 

the Final SEIS/SEIR. For purposes of recirculation, new information is not 

considered significant unless it changes the Draft SEIS/SEIR in a way that deprives 

the public of a meaningful opportunity to comment upon a substantial adverse 

environmental effect of the project or a feasible way to mitigate or avoid such an 

effect that the project proponents have declined to implement. Recirculation is not 

required when new information clarifies, amplifies, or makes minor modifications to 

the document (CEQA Guidelines, § 15088.5(b)). The requirements for recirculation 

have not been met in this instance because the Final SEIS/SEIR includes 

information and minor modifications that do not alter the environmental conclusions 

and findings of the Draft SEIS/SEIR. In addition, the refinements of the Build 

Alternative lessened the environmental impacts evaluated in the Draft SEIS/SEIR 

without causing other significant environmental impacts that were not evaluated in 

the Draft SEIS/SEIR. Further, as discussed in the detailed responses to comments 

below, all environmental impact issues raised by the commenter were analyzed in 

the Draft SEIS/SEIR. 

11 The commenter’s summary of NEPA has been noted and will be part of the record 

of proceedings for the Draft SEIS/SEIR. 

12 The commenter’s summary of CEQA has been noted and will be part of the record 

of proceedings for the Draft SEIS/SEIR. 

13 The commenter’s summary of the Sundstrom case is noted and will be part of the 

record of proceedings for the Draft SEIS/SEIR. 

14 Measures to address the potential for encountering hazardous materials during 

construction were not deferred. The Draft SEIS/SEIR identifies the potential scope 

of hazardous materials that could be encountered during construction of the project 

and includes specific requirements and standards to ensure any hazardous 

materials are identified and managed properly. These measures include gathering 

and evaluating site-specific soil samples prior to commencement of grounddisturbing activities. Site-specific soil sampling will take into account the nature of 

each site, the location, the particular site-specific circumstances that create a 

potential for encountering hazardous materials, and the potential to impact worker 

safety. In areas identified as contaminated, the contaminated soil will be disposed 

of safely at an off-site disposal facility in accordance with all applicable laws and 

regulations. In addition, should contaminated soils be encountered during 

construction, the contaminated soil would be properly disposed of off-site at an 

appropriate disposal facility; proper agencies would be notified; and an Emergency 

Release Follow-up Notice Reporting Form would be submitted no more than 30 

days following the release (refer to Chapter 4.0, Section 4.17.3.2 of the Draft 

SEIS/SEIR under the heading “Hazardous Materials” for additional information). 
Volume 3 – Comments and Responses

Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 363 

Com ID Response 

Project measures are based upon compliance with all federal, state, and local 

regulations regarding the handling and disposal of hazardous materials, including, 

without limitation, the Hazardous Materials Transportation Act; the Resource 

Conservation and Recovery Act; the Toxic Substances Control Act; the 

Comprehensive Environmental Response, Compensation, and Liability Act; 

California Code of Regulations, Title 22 relating to Environmental Health Standards 

for the Management of Hazardous Waste; and California Code of Regulations, Title 

26 relating to Hazardous Materials, Hazardous Waste, and Toxics. As explained in 

Chapter 4.0, Section 4.10.1 of the Draft SEIS/SEIR, these laws and regulations 

govern the acquisition, cleanup, and use of potentially contaminated properties, 

construction protocols, and operation and maintenance practices that could affect 

the environment and worker and public health resulting from the presence or 

accidental release of hazardous materials. SANDAG and FTA are committed to 

compliance with these laws and regulations. 

The fact that measures require future site-specific soil sampling prior to the 

commencement of construction is not a deferral of mitigation. Soil sampling is the 

means by which the project contractor will ensure that areas with potential soil 

contamination are properly evaluated, identified, and disposed of properly. The 

Draft SEIS/SEIR includes sufficient analysis to identify potentially contaminated 

sites and has measures to ensure any hazardous materials actually encountered 

during construction will be properly managed. 

Incorporation of project measures to avoid or minimize impacts is not improper 

deferral of mitigation. To the contrary, such measures allow for more efficient 

incorporation of environmental protection requirements into the design and project 

planning process. As explained in the introduction to Chapter 4.0 of the Draft 

SEIS/SEIR, “project measures” are “design features, best management practices 

(BMPs), or other measures (e.g., formation of plans to deal with hazardous 

materials) that are required by law or are incorporated as part of the project.” 

These measures are listed in the Draft SEIS/SEIR and retained for the Final 

SEIS/SEIR where applicable, and are incorporated into the project design and 

construction standards, and the conclusions of the environmental document rely on 

implementation of these project measures. In contrast, “mitigation measures” are 

“additional actions designed to avoid, minimize, or compensate for adverse or 

significant impacts.” SANDAG’s commitment to project and mitigation measures is 

documented in the Record of Decision per NEPA (included as Appendix D of the 

Final SEIS/SEIR) and the agency will adopt a mitigation monitoring and reporting 

program when the findings under CEQA are made. 

15 The Draft SEIS/SEIR properly defers some details of the site-specific project 

measures to address the potential for encountering hazardous materials during 

construction. CEQA Guidelines section 15126.4(a)(1)(B) provides that “Formulation 

of mitigation measures should not be deferred until some future time. However, 

measures may specify performance standards which would mitigate the significant 
Volume 3 – Comments and Responses 

Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

364 September 2014 

Com ID Response 

effect of the project and which may be accomplished in more than one specified 

way.” Further, deferral of the of some mitigation or project measures is acceptable 

under CEQA where practical considerations prohibit devising such measures early 

in the planning process and the lead agency commits itself to devising mitigation 

measures at a later time that will satisfy performance standards articulated at the 

time of project approval. 

In this instance, SANDAG and FTA are committed to working with the construction 

contractor to develop work management plans and monitoring documents such as a 

Stormwater Pollution Prevention Plan (SWPPP), a site-specific Health and Safety 

Plan, an Air Quality Monitoring Plan, and a contingency plan to address hazardous 

materials encountered during construction, as described in more detail below. 

A SWPPP outlines the Best Management Practices (BMPs) utilized by the project to 

control stormwater within and adjacent to the construction area. The SWPPP also 

includes the identification of materials storage areas, fueling areas, and the types of 

containment that will be used to minimize the possibility of an inadvertent spill being 

released by project construction personnel. The SWPPP also identifies the 

personnel responsible for overseeing and maintaining site conditions and the 

training that qualifies those personnel for that position. The SWPPP document is 

expected to be a “living” document and be updated as the project construction 

progresses. 

A site-specific Health and Safety Plan will be prepared by the construction 

contractor and approved by SANDAG to address potential physical and 

environmental hazards that could be encountered during construction activities. 

The plan delineates the basic safety requirements for construction activities and is 

required to be prepared in compliance with applicable federal, state, and local 

regulations. 

An Air Quality Monitoring Plan will be prepared by the construction contractor and 

approved by SANDAG to address potential exposure hazards pertaining to airborne 

dust in areas of contamination, and will comply with applicable federal, state, and 

local regulations. The plan will be adhered to during construction and site activities.

A Soil Management Plan will be prepared by the construction contractor and 

approved by SANDAG to address contractor procedures in the event that 

undocumented areas of contamination are encountered during construction and site 

activities. 

A contingency plan will be prepared by the construction contractor and approved by 

SANDAG to address contractor procedures in the event that any unidentified 

underground storage tanks or undocumented areas of contamination are 

encountered during construction. 
Volume 3 – Comments and Responses

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Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 365 

Com ID Response 

If asbestos-cement pipes are encountered during construction, then to ensure 

worker and public safety, removal and disposal would follow applicable federal, 

state, and local regulations, including, without limitation, the requirements of the 

Occupational Safety and Health Administration as stated in 29 CFR 1910.1001 and 

29 CFR 1926.1101, and the worker protection rules as stated in 40 CFR Part 763 

Subpart G, National Emission Standards for Hazardous Air Pollution, as specified 

under Rule 40 CFR 61, Subpart M, and the Clean Air Act as required under USC 

7401 et seq. 

Final versions of the above-described plans cannot be developed until such time as 

final design plans are available and a contractor is selected. In addition to 

completion of the work management plans and monitoring documents described 

above, SANDAG and FTA are committed to compliance with federal, state, and 

local regulations regarding the handling and disposal of hazardous materials. As 

noted in response to Comment 14, these regulations govern the acquisition, 

cleanup, and use of potentially contaminated properties; construction protocols; and 

operation and maintenance practices that may affect the environment and worker 

and public health resulting from the presence or accidental release of hazardous 

materials. 

With regard to the request for site-specific mitigation measures, the environmental 

evaluation requires disclosure of potential environmental impacts resulting from the 

project. The Draft SEIS/SEIR discusses potential contaminants and potential 

impacts from construction, operation, or maintenance. 

16 SANDAG and FTA are committed to mitigating impacts to water resources through 

implementation of appropriate BMPs, Low Impact Development (LID) measures, 

and hydromodification measures, as well as compliance with applicable water 

quality standards, and regulations. SANDAG’s commitment to implementing the 

following BMPs, LID measures, and hydromodification measures, as well as 

compliance with the following water quality regulations and standards, does not 

constitute improper deferral of mitigation. Refer to the response to Comment 15 

with regard to the standards for deferral of mitigation. 

As explained in Chapter 4.0, Section 4.9.3.2 of the Draft SEIS/SEIR, SANDAG is 

committed to implementing general site BMPs and will incorporate control 

measures into the project design in order to conserve natural areas, protect slopes 

and channels, and minimize impervious areas. Appropriate BMPs include the use 

of vegetated swales and buffers, detention basins, infiltration basins, and 

biofiltration devices. In addition, the project will incorporate LID and 

hydromodification measures to maintain pre-development runoff rates and volumes. 

To maximize effectiveness, the BMPs, LID measures, and hydromodification 

measures located within a project study area will target project-specific constituents 

of concern. Chapter 4.0, Table 4-26 of the Draft SEIS/SEIR identifies the proposed 

treatment BMPs and efficiency ratings. 
Volume 3 – Comments and Responses 

Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

366 September 2014 

Com ID Response 

As explained in Chapter 4.0, Section 4.9.5.1 of the Draft SEIS/SEIR, SANDAG is 

also committed to complying with regulatory standards for water quality and waste 

discharge requirements during the project, including planning, design, construction, 

and operation activities. Applicable water quality standards include, without 

limitation, the Clean Water Act, the Rivers and Harbors Act, the Porter-Cologne 

Water Quality Control Act, Section 1600 et seq. of the California Fish and Game 

Code, the California Coastal Act, and waste discharge requirements adopted by the 

San Diego Regional Water Quality Control Board. 

SANDAG’s commitment to implementing the foregoing BMPs, LID measures, and 

hydromodification measures, as well as compliance with the foregoing water quality 

regulations and standards, is an acceptable assurance that impacts will be less 

than significant. An evaluation of the project’s impacts for each parcel within or 

adjacent to the alignment and station locations is not necessary to ensure that 

impacts will be adequately avoided, minimized, or mitigated, nor is it possible to 

accurately conduct such an analysis prior to final design. Section 15004(b) of the 

State CEQA Guidelines states that “... EIRs and negative declarations should be 

prepared as early as feasible in the planning process to enable environmental 

considerations to influence project program and design and yet late enough to 

provide meaningful information for environmental assessment.” The current level of 

design allows identification of the BMPs, LID measures, and hydromodification 

measures that will be sufficient to adequately mitigate project impacts, while still 

allowing consideration of water quality impacts to influence the final siting of these 

measures. 

Refer to the response to Comment 14 with regard to SANDAG’s commitment to 

implementing project measures and mitigation measures. Refer to the response to 

Comment 15 with regard to the requirement for analysis. 

17 Payment of mitigation fees is an appropriate method of mitigation for biological 

impacts. According to the U.S. Army Corps of Engineers, in-lieu fee programs, 

which are described in the Corps regulations (Compensatory Mitigation for Losses 

of Aquatic Resources, dated April 10, 2008 [Title 33 CFR Part 332]), are similar to 

mitigation banks in that they sell compensatory mitigation credits to permittees 

whose obligation to provide compensatory mitigation is then transferred to the inlieu fee program sponsor. In addition, in-lieu fee programs involve the restoration, 

establishment, enhancement, and/or preservation of aquatic resources through 

funds paid to a governmental or non-profit natural resources management entity to 

satisfy compensatory mitigation requirements for Department of the Army permits. 

If payment of in-lieu fees is selected as a component of the mitigation plan for the 

project, SANDAG will ensure that the program is approved by the U.S. Army Corps of 

Engineers as part of the Clean Water Act Section 404 authorization process. The Draft 

SEIS/SEIR includes the payment of in-lieu fees as one of several options, and provides 

performance standards to ensure that impacts are adequately mitigated. 
Volume 3 – Comments and Responses

Groups / Organizations 

Laborers International Union of North America, Local Union 89 - 

Drury, Richard, Attorney - ID264 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 367 

Com ID Response 

18 Refer to the response to Comments 10 through 13. The project is not considered 

approved or adopted until the SANDAG Board of Directors certifies the Final 

SEIS/SEIR and approves the project and files the Notice of Determination, thus 

completing the CEQA process. The comment letter has been included in Volume 3 

of the Final SEIS/SEIR and is therefore a part of the record of proceedings for the 

project. 

 
Volume 3 – Comments and Responses 

Groups / Organizations 

Marian Bear Natural Park Recreation Council - 

Bear, Deron, Chairman - ID341 

MID-COAST CORRIDOR TRANSIT PROJECT 

368 September 2014 

Marian Bear Natural Park Recreation Council - 

Bear, Deron, Chairman - ID341 

 
Volume 3 – Comments and Responses

Groups / Organizations 

Marian Bear Natural Park Recreation Council - 

Bear, Deron, Chairman - ID341 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 369 

Submission ID341 Marian Bear Natural Park Recreation Council Bear Deron

Com ID Response

1 The project alignment will be located within the existing MTS right-of-way and will 

not prevent access to Marian Bear Memorial Park or to trails leading south to 

Mission Bay or north to Rose Canyon. 

Regarding the concrete-lined channel under SR 52 and the north-south wildlife 

corridor connection, following construction, the concrete-lined channel will remain 

available for wildlife movement between Rose Canyon Open Space Park and 

Marian Bear Memorial Park. SANDAG has designed the concrete-lined channel 

under SR 52 so that the channel bottom has cross slope to concentrate low flows 

toward the center of the channel. However, because of the large catchment area 

tributary to Rose Creek, the channel bottom will be inundated even during small 

storms events. During the dry season when the flows will be limited to irrigation 

runoff, the outer portions of the channel will carry minimal flows and will continue to 

facilitate wildlife movement. In addition, a path along the east side of the open 

channel under SR 52 within the Caltrans right-of-way will be retained for 

maintenance access and will continue to be available for wildlife movement along 

the channel. The project will not introduce any new barriers to park users. 

Rose Canyon provides an avenue for local wildlife movement in a north-south 

direction between the portion of Rose Canyon to the east of I-5 and San Clemente 

Canyon. Although Rose Canyon and San Clemente Canyon connect to 

undeveloped lands on MCAS Miramar, they do not connect to larger patches of 

natural open space to the south (west of the alignment). Therefore, Rose Canyon 

functions more as a local wildlife corridor between the western ends of San 

Clemente Canyon and Rose Canyon, rather than a regional wildlife corridor 

connecting large areas of open space. In response to comments received, the 

terms "likely" and "may" have been revised, where appropriate, when discussing 

the function of wildlife corridors in the Mid-Coast Corridor Transit Project Biological 

Resources Technical Report and the Final SEIS/SEIR. Additional information is 

provided in Chapter 4.0, Section 4.7.5 of the Biological Resources Technical 

Report.

2 In response to comments on the Draft SEIS/SEIR, including from the California 

Department of Fish and Wildlife, SANDAG has designed the concrete-lined 

channel under SR 52 so that the channel bottom has cross slope to concentrate 

low flows toward the center of the channel. However, because of the large 

catchment area tributary to Rose Creek, the outer portions of the lined channel will 

be inundated even during small storm events. During the dry season when the 

flows will be limited to irrigation runoff, the outer portions of the channel will carry 

minimal flows and will continue to facilitate wildlife movement. In addition, a path 

along the east side of the open channel under SR 52 within the Caltrans right-ofway will be retained for maintenance access and will continue to be available for 

wildlife movement along the channel. The design is illustrated in Sheets 83 and 84 
Volume 3 – Comments and Responses 

Groups / Organizations 

Marian Bear Natural Park Recreation Council - 

Bear, Deron, Chairman - ID341 

MID-COAST CORRIDOR TRANSIT PROJECT 

370 September 2014 

Com ID Response

of the Final SEIS/SEIR Plan Set. As a result, wildlife movement will not be 

restricted as a result of standing water in the channel.

3 Current access to the manhole is through MTS right-of-way and requires 

encroachment permits and railroad flaggers. Future access may be provided 

through the same procedure. Final arrangement for access to the manhole will be 

determined through coordination as part of the utility relocation with the City of San 

Diego and other utility owners, as applicable, as design of the project progresses. 

4 The noise impact analysis prepared for the project considered outdoor spaces 

along the project alignment as possible noise-sensitive receivers, including Marian 

Bear Memorial Park. Specifically, areas of frequent human recreational use within 

Marian Bear Memorial Park are considered to be Category 3 noise-sensitive 

receivers, as defined by FTA in the Transit Noise and Vibration Impact Assessment 

Guidance Manual (FTA, 2006), in this analysis. The existing wildlife habitats in 

Rose Canyon Open Space Park are identified as sensitive to noise, and the effects 

analysis of the future noise from the project on these habitats is presented in the 

Biological Resources Technical Report. 

Master Response 9 provides general information regarding the noise impact 

analysis and identification of mitigation. In addition, as noted in Master Response 

7, while the project will introduce additional noise into the environment, each LRT 

passby will be substantially quieter than existing trains in the area. The FTA noise 

impact assessment procedures use the hourly average noise level (hourly Leq) to 

account for both the quantity and magnitude of noise-producing events. 

As a result of engineering studies, the location of the track crossover identified in 

the Draft SEIS/SEIR as being near Marian Bear Memorial Park has been moved, 

eliminating the moderate noise impact identified in the Draft SEIS/SEIR and the 

need for mitigation. The noise level in Marian Bear Memorial Park near the project 

will increase from 58 dBA to 61 dBA Leq. 

Changes in sound levels of less than 3 dBA are generally not noticeable to people 

with normal hearing sensitivity.. An increase of 10 dBA would result in a perceived 

doubling in the noise level. The project-generated noise will result in a less-thansignificant increase, as described in Chapter 4.0, Sections 4.7.3 and 4.7.5 of the 

Draft SEIS/SEIR. Although there will be an increase in the number of trains, the 

minimal change in ambient noise described above will not result in a significant 

impact to wildlife or park users.

 
Volume 3 – Comments and Responses

Groups / Organizations 

Moderate Majority - 

Kim, Brian, CEO - ID182 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 371 

Moderate Majority - 

Kim, Brian, CEO - ID182 

 
Volume 3 – Comments and Responses 

Groups / Organizations 

Moderate Majority - 

Kim, Brian, CEO - ID182 

MID-COAST CORRIDOR TRANSIT PROJECT 

372 September 2014 

Submission ID182 Moderate Majority Kim Brian 

Com ID Response 

1 Your comment expressing support for the VA Medical Center Station will be part of the 

record of proceedings for the Draft SEIS/SEIR. On November 15, 2013, the SANDAG 

Board of Directors approved the Refined Build Alternative, which included the VA 

Medical Center Station as part of the project to be evaluated in the Final SEIS/SEIR. 

 
Volume 3 – Comments and Responses

Groups / Organizations 

Move San Diego - 

Lowe, Elyse, Executive Director - ID258 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 373 

Move San Diego - 

Lowe, Elyse, Executive Director - ID258 
Volume 3 – Comments and Responses 

Groups / Organizations 

Move San Diego - 

Lowe, Elyse, Executive Director - ID258 

MID-COAST CORRIDOR TRANSIT PROJECT 

374 September 2014 
Volume 3 – Comments and Responses

Groups / Organizations 

Move San Diego - 

Lowe, Elyse, Executive Director - ID258 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 375 
Volume 3 – Comments and Responses 

Groups / Organizations 

Move San Diego - 

Lowe, Elyse, Executive Director - ID258 

MID-COAST CORRIDOR TRANSIT PROJECT 

376 September 2014 
Volume 3 – Comments and Responses

Groups / Organizations 

Move San Diego - 

Lowe, Elyse, Executive Director - ID258 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 377 

Submission ID258 Move San Diego Lowe Elyse

Com ID Response

1 Your comment expressing support for the project will be part of the record of 

proceedings for the Draft SEIS/SEIR.

2 Your comments summarizing the selection of the LPA in 2010 and describing the 

benefits of the selected alternative have been noted. After the close of the comment 

period for the Draft SEIS/SEIR, additional refinements have been made to the 

project. The refinements are generally consistent with the overall alignment of the 

LRT-Alternative 1 configuration approved in July 2010. The refinements to the Draft 

SEIS/SEIR Build Alternative include minor changes to the alignment and station 

configuration, as well as other minor changes; however, they are not anticipated to 

reduce the benefits described in this comment related to ridership, students, 

employees, or patients. The refinements are described in Chapter 2.0, Section 2.3 of 

the Final SEIS/SEIR. 

On November 15, 2013, the SANDAG Board of Directors approved the Refined Build 

Alternative for evaluation in the Final SEIS/SEIR. The Refined Build Alternative 

includes the VA Medical Center Station. The SANDAG Board of Directors excluded 

the Genesee Avenue Design Option from further consideration.

3 The Refined Build Alternative includes an aerial, grade-separated alignment along 

Genesee Avenue. 

4 Your comment encouraging consideration of potential future uses of the area near 

Jutland Drive for transit-oriented development will be part of the record of 

proceedings for the Draft SEIS/SEIR. The decision to exclude the Jutland Drive 

Station at this time considered potential future uses of the area near the station 

among other factors. The feasibility of a Jutland Drive Station was evaluated in 

response to comments received during CEQA scoping in 2010 and NEPA scoping in 

2011, and is documented in the Mid-Coast Corridor Transit Project Jutland Drive 

Station Feasibility Study Technical Memorandum. The evaluation considered various 

factors, and used the SANDAG Series 11 Travel Demand Forecasting Model to 

determine peak hour and daily boardings at a Jutland Drive Station and on the 

Trolley Blue Line based on conditions in 2030, assuming changes in land use and 

population consistent with the 2030 RTP. This captured the potential future 

development around the station, consistent with regional and City of San Diego 

plans.

5 On November 15, 2013, the SANDAG Board of Directors approved the Refined Build 

Alternative, which included the VA Medical Center Station as part of the project to be 

evaluated in the Final SEIS/SEIR.
Volume 3 – Comments and Responses 

Groups / Organizations 

Move San Diego - 

Lowe, Elyse, Executive Director - ID258 

MID-COAST CORRIDOR TRANSIT PROJECT 

378 September 2014 

Com ID Response

6 Master Response 1 provides additional detail regarding the pedestrian and bicycle 

connections that will be provided at the new Trolley stations. Bicycle lockers will be 

available at each of the new stations on the extension and will be permitted on board 

Trolley vehicles consistent with current MTS policy.

7 Chapter 1.0 of the Draft SEIS/SEIR described the overall travel patterns to, from, 

through, and within the Mid-Coast Corridor. The chapter also identified the existing 

system that serves these travel patterns and the need to improve the system’s 

performance in serving travel at the corridor level. This description provided the 

basis for defining the purpose and need for the project, which as stated in Chapter 

1.0, Section 1.5 of the Draft SEIS/SEIR, is to increase transit speed and reliability, 

reduce the number of transfers required to complete a trip made using transit, make 

transfers more convenient, and expand transit capacity to accommodate existing and 

future travel demand. Chapter 1.0 is not meant to provide an all-inclusive discussion 

of the performance of various modes of transportation but to characterize the overall 

purpose and need for the project. Although pedestrian and bicycle facilities provide 

an important means to access transit on a local level, improved bicycle and 

pedestrian facilities are not part of the larger scale purpose and need for the Trolley 

extension. Pedestrian and bicycle facilities are evaluated in Chapter 3.0 of the Draft 

SEIS/SEIR, with additional detail in the Mid-Coast Corridor Transit Project 

Transportation Impacts and Mitigation Report. 

The comments received from the San Diego County Bicycle Coalition are addressed 

in response to its submission letter and are provided in Volume 3 of the Final 

SEIS/SEIR. Walk San Diego did not provide comments on the Draft SEIS/SEIR.

8 Transit parking is not being provided to mitigate impacts under CEQA or to offset 

environmental effects. Rather, the number of parking spaces was increased to 

satisfy project objectives. Transit parking is required at five stations (Tecolote Road, 

Clairemont Drive, Balboa Avenue, Nobel Drive, and the UTC Transit Center) to 

provide adequate access to stations and support ridership. Parking included at each 

station is based on forecasts from the SANDAG Series 11 Travel Demand 

Forecasting Model, which shows the number of riders that would require parking to 

access the system. If parking supply is inadequate, then system ridership is 

expected to decrease. 

Further, the significance threshold addressed in the comment properly considered 

parking supply in the context of physical impacts that could result from loss of 

existing parking spaces and impacts that could result in spillover parking. 

Amendments to Appendix G do not prohibit use of the threshold. Appendix G is a 

sample form that does not limit an agency’s ability to fashion alternative thresholds to 

better address a particular project’s impacts.
Volume 3 – Comments and Responses

Groups / Organizations 

Move San Diego - 

Lowe, Elyse, Executive Director - ID258 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 379 

Com ID Response

9 The Draft SEIS/SEIR analyzed the effect of parking on the environment. For the five 

stations with transit parking, the traffic analysis documented in Chapter 3.0, Section 

3.4.2.2 of the Draft SEIS/SEIR considered the increase in traffic volumes on 

roadways and through intersections that will result from vehicles accessing the new 

transit parking. The intersections and roadways analyzed as part of the traffic 

analysis are shown in Chapter 3.0, Figures 3-1 and 3-2 of the Draft SEIS/SEIR; the 

results of the traffic analysis are shown in Table 3-22 (roadway segments) and Table 

3-24 (intersections). Impacts to pedestrian and bicycle facilities as a result of the 

project, including parking, are evaluated in Chapter 3.0, Section 3.3.3. 

Project parking will not displace transit-oriented development. The Draft SEIS/SEIR 

states in Chapter 4.0, Section 4.1.4 and Section 4.1.5.1, that the project conforms 

with, and is consistent with, existing land use plans and policies. The at-grade 

station park-and-ride facilities are surface parking lots and will not displace existing 

TOD projects or preclude implementation of future TOD projects. Changes in the 

underlying land uses and zoning could be initiated after the project as a joint-use 

project and could be processed through the City of San Diego’s development 

approval process. Master Response 4 discusses an example. 

Parking at the Nobel Drive Station and the UTC Transit Center will be located within 

existing commercial parking lots.

10 Chapter 4.0, Section 4.1 of the Draft SEIS/SEIR discussed land use plans and 

policies for the corridor, noting the potential for TOD around stations. Chapter 4.0, 

Section 4.1.2 of the Draft SEIS/SEIR indicated that most areas around project 

stations allow for high development intensity, consistent with TOD opportunities and 

in conformance with regional documents (SANDAG and the city’s general plan). 

More specific information can be found in the Mid-Coast Corridor Transit Project 

Land Use Impacts Technical Report and in the documents listed in Chapter 4.0, 

Section 4.1.1 of the Draft SEIS/SEIR. 

Further analysis of potential transit-oriented development in the corridor is beyond 

the scope of the Draft SEIS/SEIR. However, a more detailed analysis of mixed-use 

development opportunities in the project corridor is the subject of station area 

planning studies for the Tecolote Road and Clairemont Drive Station areas that are 

being undertaken by the City of San Diego as part of the community plan update 

process. 

11 SANDAG conducted CEQA scoping for the Draft SEIS/SEIR in 2010 and NEPA 

scoping in 2011. During these activities, the 2030 RTP was the adopted 

transportation plan for the San Diego region, which is why it was the basis of the 

Draft SEIS/SEIR. Chapter 2.0, Section 2.2.1.1 of the Draft SEIS/SEIR acknowledges 

that the 2050 RTP was adopted by the SANDAG Board of Directors in October 2011. 

The 2050 RTP was reviewed to determine if it includes any additional funded 

projects planned for implementation in the Mid-Coast Corridor by 2030 that were not 
Volume 3 – Comments and Responses 

Groups / Organizations 

Move San Diego - 

Lowe, Elyse, Executive Director - ID258 

MID-COAST CORRIDOR TRANSIT PROJECT 

380 September 2014 

Com ID Response

included in the 2030 RTP. The only major new project in the Mid-Coast Corridor is 

the extension of the Trolley Blue Line from the UTC Transit Center to Mira Mesa via 

the Sorrento Mesa/ Carroll Canyon area; this project will be subject to project-specific 

environmental review. 

Additionally, the 2050 RTP also was reviewed to determine if it includes any MidCoast Corridor projects that are assumed in the No-Build Alternative that are not in 

the 2030 phase of the 2050 RTP. The only major project not in the 2030 phase of 

the 2050 RTP is the addition of HOV lanes in the segment of I-5 from I-8 to La Jolla 

Village Drive. The 2050 RTP defers the implementation of the HOV lanes in this 

segment until the decade ending in 2050. Because the 2050 RTP only defers 

implementation of the HOV lanes, but still includes them, they are assumed in the 

design and analysis of the Mid-Coast Corridor Transit Project under the No-Build and 

Build Alternatives. Therefore, the 2030 RTP was retained as the basis for the NoBuild and Build Alternatives because no substantive differences exist between the 

two RTPs that would materially affect the environmental analysis.

12 Your comments expressing support of the project and regarding future extensions to 

Sorrento Mesa and Pacific Beach will be part of the record of proceedings for the 

Draft SEIS/SEIR. 

 
Volume 3 – Comments and Responses

Groups / Organizations 

North County Live Well Leadership - 

Hamilton, Andy, Air Quality Specialist - ID272 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 381 

North County Live Well Leadership - 

Hamilton, Andy, Air Quality Specialist - ID272 
Volume 3 – Comments and Responses 

Groups / Organizations 

North County Live Well Leadership - 

Hamilton, Andy, Air Quality Specialist - ID272 

MID-COAST CORRIDOR TRANSIT PROJECT 

382 September 2014 
Volume 3 – Comments and Responses

Groups / Organizations 

North County Live Well Leadership - 

Hamilton, Andy, Air Quality Specialist - ID272 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 383 
Volume 3 – Comments and Responses 

Groups / Organizations 

North County Live Well Leadership - 

Hamilton, Andy, Air Quality Specialist - ID272 

MID-COAST CORRIDOR TRANSIT PROJECT 

384 September 2014 
Volume 3 – Comments and Responses

Groups / Organizations 

North County Live Well Leadership - 

Hamilton, Andy, Air Quality Specialist - ID272 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 385 
Volume 3 – Comments and Responses 

Groups / Organizations 

North County Live Well Leadership - 

Hamilton, Andy, Air Quality Specialist - ID272 

MID-COAST CORRIDOR TRANSIT PROJECT 

386 September 2014 
Volume 3 – Comments and Responses

Groups / Organizations 

North County Live Well Leadership - 

Hamilton, Andy, Air Quality Specialist - ID272 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 387 

Submission ID272 North County Live Well Leadership Team Hamilton Andy

Com ID Response

1 The comment letter, which included an additional signature from the Linda Vista 

Planning Group, has been accepted for inclusion by SANDAG. 

2 Your comments expressing support for the project and describing the anticipated 

benefits will be part of the record of proceedings for the Draft SEIS/SEIR.

3 Your comment expressing appreciation for the inclusion of off-site access 

improvements at stations will be part of the record of proceedings for the Draft 

SEIS/SEIR. The suggestions referenced in this comment are addressed in 

responses to the subsequent comments.

4 Master Response 1 provides information about the pedestrian and bicycle 

connections that are included as part of the project. Your comments regarding the 

Morena Boulevard Station Area Planning Study will be part of the record of 

proceedings for the Draft SEIS/SEIR.

5 Master Response 1 provides information about the pedestrian and bicycle 

connections that are included as part of the project. Your comments regarding a 

mid-block crosswalk on West Morena Boulevard near Vega Street will be part of the 

record of proceedings for the Draft SEIS/SEIR. 

A mid-block crosswalk near Vega Street could be considered during Final 

Design. The installation of a signalized mid-block crosswalk would require a traffic 

study to determine impacts to traffic, approval from the City of San Diego, and meet 

city requirements for installation of a signal. 

6 The City of San Diego’s Morena Boulevard Station Area Planning Study is a 

separate effort from the Mid-Coast Corridor Transit Project. SANDAG will continue 

to coordinate with the city throughout the project development, including advancing 

the design of station layouts. 

7 The suggested improvements at the Ingulf and Gesner Street intersections and 

Clairemont Drive overpass are outside the immediate station area and beyond the 

scope of this project. See Master Response 1 for more detail regarding station 

design and pedestrian access at stations.

8 As stated in Master Response 1, any modifications to the pedestrian network 

beyond the immediate station area are beyond the scope of this project.
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9 As noted in the comment, the non-motorized trips presented in Chapter 4.0, Section 

4.1.1.3 of the Mid-Coast Corridor Transit Project Transportation Impacts and 

Mitigation Report are not associated with a transit trip. Non-motorized trips are 

projected to decrease by 0.1 percent region-wide under the Build Alternative, or by 

400 trips daily. 

Tables 4-23 and 4-30 in Chapter 4.0 of the Transportation Impacts and Mitigation 

Report present mode of access to Route 150 under the No-Build Alternative and to 

the Trolley Blue Line under the Build Alternative, respectively. As shown in these 

tables, the walk trips to stations will increase significantly under the Build Alternative 

compared to the No-Build Alternative. For instance, under the No-Build Alternative, 

150 people would walk to the Nobel Drive Station and 40 people would walk to the 

UTC Transit Center where there would be bus service only. In comparison, 780 and 

590 people will walk to these stations, respectively, under the Build Alternative with 

LRT operations. 

The non-motorized trips presented in the Transportation Impacts and Mitigation 

Report and summarized in the Draft SEIS/SEIR were determined by the SANDAG 

Series 11 Travel Demand Forecasting Model. This model is based on the 

community and general plans that were adopted when the model was developed, 

which was in June 2008. Therefore, it does not include the City of San Diego's 

Morena Boulevard Station Area Planning Study, which is currently being prepared. 

SANDAG will continue to coordinate with Caltrans and the City of San Diego 

throughout the project development and construction phases.

 
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Submission ID117 Old Town San Diego Community Planning Group Coe Thurston

Com ID Response

1 The Taylor Street/Rosecrans Street and Pacific Highway mitigation measures are 

required to offset the impacts associated with the Mid-Coast Corridor Transit 

Project that result from the additional Trolleys traveling through the grade crossing. 

The mitigation measures are not designed to allow more regional traffic. The 

project will not increase the volume of traffic traveling through Old Town. The 2030 

traffic volumes used to determine the project’s long-term impacts would occur with 

or without the Mid-Coast Corridor Transit Project. 

It is assumed that the modifications referenced in the comment refer to the traffic 

mitigation measures for the Mid-Coast Corridor Transit Project proposed at Taylor 

Street/Rosecrans Street and Pacific Highway, as described in Chapter 3.0, Table 

3-26 of the Draft SEIS/SEIR (refer to Mitigation Measure TR8). Additional detail for 

this mitigation measure is shown in Chapter 6.0, Figures 6-8, 6-9, and 6-10 of the 

Mid-Coast Corridor Transit Project Transportation Impacts and Mitigation Report. 

The mitigation measure includes the following: 

 Add a second northbound right-turn lane (Pacific Highway) 

 Reconfigure eastbound approach to have a third through lane (Rosecrans 

Street) 

 Realign southern sidewalk east and west of intersection to preserve existing 

dedicated bus-only lane (Rosecrans Street, Taylor Street west of railroad tracks) 

 Add exit phase to serve vehicles making an eastbound left turn, vehicles 

traveling eastbound and westbound through the intersection, and pedestrians 

crossing Pacific Highway 

 Lengthen northbound left-turn lane by 40 feet (Pacific Highway) 

 Modify southbound approach geometry to include a second left-turn lane for 

general purpose vehicles (Pacific Highway) 

 Change westbound left-turn phase from first movement served to be served 

later in the traffic cycle 

Additionally, traffic signal phasing will be modified at Taylor Street and Congress 

Street (Mitigation Measure TR9 in Chapter 3.0, Table 3-26 of the Draft SEIS/SEIR), 

as follows:. 

 Add exit phase to serve vehicles making an eastbound left turn, vehicles 

traveling eastbound and westbound through the intersection, and pedestrians 

crossing Pacific Highway 

The traffic analysis summarized in Chapter 3.0, Table 3-25 of the Draft SEIS/SEIR 

identified the need for these mitigation measures. These mitigation measures are 

required to restore intersections near the Taylor Street grade crossing to acceptable 

levels of service (LOS) consistent with City of San Diego criteria. Based on City of 

San Diego criteria, mitigation measures are required when a project impacts the 
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402 September 2014 

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level of service and delay at an intersection causing the intersection to operate at 

LOS E or LOS F with increased delay compared to the No-Build Alternative. With 

the additional Trolley crossings through the Taylor Street grade crossing under the 

Build Alternative, the delay at intersections near this crossing will increase 

compared to the No-Build Alternative and mitigation is required. Specifically, the 

mitigation measures proposed at this location are needed to mitigate impacts at the 

intersection of Jefferson Street and Rosecrans Street. 

2 The Draft SEIS/SEIR and the Mid-Coast Corridor Transit Project Land Use Technical 

Report adequately considered the Old Town San Diego Community Plan and the Old 

Town Planned District Ordinance (see Chapter 5.0, Table 5.1 of the Land Use 

Technical Report). The purpose and intent of the Old Town San Diego Planned 

District, as noted in Chapter 15 Article 16 of the San Diego Municipal Code, is to 

control the development of land and to retain and emphasize the character of the 

historic community and state park. The Mid-Coast Corridor Transit Project does not 

include development of land, and will not impact the community character of the historic 

community and state park. The project provides for the extension of the Trolley Blue 

Line from Santa Fe Depot to the UTC Transit Center. The project will not modify the 

OTTC, which is an existing Trolley station. The project will not increase the volume of 

traffic traveling through Old Town or the number of through lanes on Taylor Street 

beyond its intersection with Pacific Highway. 

Further, the mitigation measures that improve intersections near the Taylor Street 

crossing will not alter the existing community character of the historic district. 

Taylor Street, in its current condition, is already a busy four-lane street and is 

designated as a “major through street” by the Auto Circulation/Parking Concept 

graphic on page 79 of the Old Town San Diego Community Plan. The development 

standards and community plan objectives identify the need for a circulation system 

to bring people into the area. Thus, the planning documents for Old Town 

anticipate Taylor Street to be a major ingress and egress point to the community. 

Within Old Town, the street improvements and signal timing included as traffic 

mitigation measures, as described in response to Comment 1, are limited to the 

intersections of Taylor Street/Rosecrans Street at Pacific Highway and Taylor 

Street at Congress Street. Mitigation does not require street improvements within 

areas of Old Town that promote visitor-serving and pedestrian-oriented uses, or 

residential areas. The mitigation measures are largely limited to the existing 

roadway right-of-way and will not substantially alter the cohesion of the community 

or land uses in Old Town. They will maintain acceptable conditions at intersections 

serving the Old Town area. Further, the project will support the planned district by 

broadening and expanding regional and visitor access into the historic community 

and state park via the Trolley.
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September 2014 403 

Com ID Response

3 Neither the project nor traffic mitigation measures will cause adverse or significant 

long-term visual, noise, or air quality impacts at or near Old Town. As stated in 

response to Comment 1, the project will not increase the volume of traffic traveling 

through Old Town or the number of through lanes on Taylor Street beyond the 

intersection with Pacific Highway. 

With respect to visual resources, the visual changes associated with the project in 

the vicinity of Old Town are limited to changes in the lane configurations at the 

Taylor Street/Rosecrans Street and Pacific Highway intersection (predominantly 

changes to Pacific Highway), and minor adjustment to curb and sidewalk locations 

on the south side of Taylor Street/Rosecrans Street (west of the railroad crossing). 

All of these changes are at grade level and do not entail adding new visual 

elements or removing existing visual resources. Thus, the project will not affect the 

visual character of the Old Town area. 

As described in Chapter 4.0, Section 4.7.3.2 of the Draft SEIS/SEIR, the project will 

not substantially alter transit noise in the vicinity of Old Town and thus will not result 

in any moderate or severe noise impacts per FTA criteria or significant impacts 

under CEQA. 

With regard to air quality impacts, there will be no emissions from fuel combustion 

associated with operations of the system because the Trolley will be electrically 

powered. Furthermore, as explained in Chapter 4.0, Section 4.5.3.2 of the Draft 

SEIS/SEIR, under the Build Alternative emissions burdens in the study area for all 

pollutants will be equal to or lower than under the No-Build Alternative. 

The project will not impede access to the historic district, individual historic 

properties, cultural resources, or side-street businesses. Mitigation measures at 

Taylor Street will ensure that pedestrian and vehicle wait times at this intersection 

are not adversely affected. As noted above, the project will not increase traffic 

volumes on Taylor Street. Further, the project is anticipated to reduce parking 

demand at the OTTC when compared to conditions without the project. As stated 

in Chapter 3.0, Section 3.4.2.4 of the Draft SEIS/SEIR, the Build Alternative will 

provide improved transit service between University City and the OTTC, thus 

improving access to San Diego State Historic Park near the OTTC. 

As discussed in Chapter 4.0, Section 4.15.1.2 of the Draft SEIS/SEIR, the Area of 

Potential Effects (APE) identifies the geographic areas that could be affected by the 

project, either directly or indirectly. Presidio Park is not identified within the project 

APE and will not be affected by the project or its mitigation measures. Refer to the 

response to Comment 21 for additional information. 
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Coe, Thurston, Chairperson - ID117 

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404 September 2014 

Com ID Response

4 As discussed in response to Comment 1, the project will not increase the volume of 

traffic traveling through Old Town. The 2030 traffic volumes used to determine the 

project’s long-term impacts would occur with or without the Mid-Coast Corridor 

Transit Project. Further, traffic mitigation measures associated with the project will 

occur in ancillary areas of the core subarea, as stated in responses to Comments 1 

and 3. 

Additionally, it is important to note that Taylor Street in its current condition is 

already a busy four-lane street and is designated as a “major through street” by the 

Auto Circulation/Parking Concept graphic on page 79 of the Old Town San Diego 

Community Plan. The existing status of Taylor Street and its consistency with longterm planning goals for Old Town are independent of the Mid-Coast Corridor Transit 

Project or its mitigation measures. 

5 The comment regarding the previous challenges of the Planned District Ordinance 

will be part of the record of proceedings for the Draft SEIS/SEIR. 

6 Presidio Park was recognized in Chapter 4.0, Figure 4-5, and Chapter 5.0, Tables 

5-2 and 5-4 of the Draft SEIS/SEIR. This park is not within the APE, and will not be 

directly or indirectly affected by the project.

7 The intersection improvements being implemented to mitigate project impacts are 

not inconsistent with the 1972 Old Town San Diego Architectural and Site 

Development Standards and Criteria (source: Section H Interior Circulation 

Standards (page 129) of the standards, Old San Diego Planned District Review 

Board, Old Town Architectural and Site Development Standards and Criteria, 

September 1972.). The development standards identify the need to include a 

walkway system to link the core to commercial–recreation and public recreation 

areas; to prohibit on-street parking; to promote the use of bicycles, horses, and 

street cars; and to connect circulation routes with other major centers. As 

discussed above, the Old Town Community Plan anticipates Taylor Street to be a 

major ingress and egress point to the community. The project mitigation measures 

will not alter this existing status or affect the character of the Old Town Historic 

District. The project will use the existing tracks and Trolley station at the OTTC and 

will not include any site development in the Old Town area. The project is entirely 

outside of the historic district, with effects limited to implementation of the traffic 

mitigation measures described in response to Comment 1. As shown in the Final 

SEIS/SEIR Plan Set (Sheet 369, available at www.sandag.org/midcoast), the traffic 

mitigation measures at Taylor Street will require a permanent acquisition of 

approximately 530 square feet from a private property at the southwest corner of 

Taylor Street/Rosecrans Street and Pacific Highway and a temporary construction 

easement from the State of California in the southeast corner of the intersection; 

neither of these parcels has a historic property associated with it and neither are 

affiliated with the old Caltrans building. No historic properties will be affected by 
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Coe, Thurston, Chairperson - ID117 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 405 

Com ID Response

this acquisition. Additionally, it is important to note that Taylor Street in its current 

condition is already a busy four-lane street and is designated by the Auto 

Circulation/Parking Concept graphic on page 79 of the Old Town San Diego 

Community Plan as a “major through street.” The existing status of Taylor Street 

and its consistency with long-term planning goals for Old Town are independent of 

the Mid-Coast Corridor Transit Project or its mitigation measures. 

8 Project mitigation measures do not create a 6- or 8-lane prime aerial 

street/highway, and the traffic mitigation measures will not change the classification 

of or number of through lanes on any of the streets in Old Town but will add a 

through approach lane at the intersection of Taylor Street/Rosecrans Street and 

Pacific Highway. As described in response to Comment 1, Mitigation Measure TR8 

will modify the eastbound approach at this intersection to include a third through 

approach lane on Rosecrans Street (west of Pacific Highway) and a third through 

receiving lane on Taylor Street (east of Pacific Highway). With this mitigation 

measure, Rosecrans Street will have four through lanes (three in the eastbound 

and one in the westbound direction) and two turning lanes in the eastbound 

direction, whereas Taylor Street will continue to have four through lanes (three in 

the eastbound and one in the westbound direction) and three turning lanes in the 

westbound direction at the intersection with Pacific Highway. 

Temporary and permanent property acquisitions are disclosed in Chapter 4.0, 

Sections 4.3.3.3 and 4.17.3.2 of the Draft SEIS/SEIR, are depicted in the right-ofway plans in the Final SEIS/SEIR Plan Set (Sheet 369), and are discussed in 

response to Comment 7 above. The project will not temporarily or permanently 

remove land from the historic district.

9 The mitigation measures are improvements to existing street intersections and will 

not create a highway. Refer to the response to Comment 8 regarding the roadway 

classification. The project will not increase traffic volumes or the number of through 

lanes on Taylor Street beyond the intersection with Pacific Highway. 

As stated in response to Comment 7, the project does not include a development 

component that would be subject to urban design standards. 

The traffic mitigation measures also support street improvements listed in the Old 

Town San Diego Community Plan, specifically “improve [traffic] signal progression 

between Pacific Highway and Morena Boulevard” because signal phasing and 

operation will be improved as part of the traffic mitigation measures. Section H of 

the Architectural Standards and Design Criteria regarding the implementation of 

circulation improvements to satisfy community plan objectives include a walkway 

system to link the core to commercial–recreation and public recreation areas; to 

prohibit on-street parking; to promote the use of bicycles, horses, and street cars; 

and to connect circulation routes with other major centers. The proposed project 

will be consistent with these policies. 
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Coe, Thurston, Chairperson - ID117 

MID-COAST CORRIDOR TRANSIT PROJECT 

406 September 2014 

Com ID Response

10 Refer to the response to Comments 4 and 7.

11 The project is not proposing that Taylor Street become a highway. Refer to the 

response to Comments 4 and 7. Further, the 1972 Old Town San Diego 

Architectural and Site Development Standards and Criteria for Street Design do not 

prohibit or address intersection improvements to a major arterial roadway. 

However, the standards do identify the need for circulation routes to connect with 

other major centers. 

12 As stated in response to Comment 1, the traffic mitigation measures will not increase 

the number of through lanes on Taylor Street/Rosecrans Street beyond the intersection 

with Pacific Highway or the volume of traffic passing through the area. Additionally, it is 

important to note that Taylor Street in its current condition is already a busy four-to-fivelane street and is designated by the Auto Circulation/Parking Concept graphic on page 

79 of the Old Town San Diego Community Plan as a “major through street.” The 

existing status of Taylor Street and its consistency with long-term planning goals for 

Old Town are independent of the Mid-Coast Corridor Transit Project or its mitigation 

measures. Further, the project will provide an additional mode of access for visitors 

from areas north of the OTTC that could reduce traffic in the area and is anticipated to 

reduce parking demand at the OTTC. 

Refer to the response to Comment 18 regarding the pedestrian analysis that was 

conducted for the project.

13 As stated in response to previous comments, the project is not incompatible with 

the Old Town Planned District Ordinance, and the proposed mitigation measures 

for the project will not result in changes that would affect or contrast with the 

distinctive character of the Old Town Historic District. No project construction will 

occur within or adjacent to the Old Town San Diego National Register of Historic 

Places Historic District boundary or the larger Old Town State Historic Park 

boundary as defined by the City of San Diego. In a letter dated April 9, 2014, the 

California State Historic Preservation Officer concurred with the FTA’s 

determination that the project will result in “no adverse effect” on historic properties. 

14 Historic resources in Old Town San Diego will not be affected by the project, either 

directly or indirectly. This determination was based on the Mid-Coast Corridor 

Transit Project Historic Property Survey and Eligibility Determination Report and the 

Mid-Coast Corridor Transit Project Historic Property Effects Report, as summarized 

in Chapter 4.0, Section 4.15 of the Draft SEIS/SEIR. No project construction will 

occur within or adjacent to the Old Town San Diego National Register of Historic 

Places Historic District boundary or the larger Old Town State Historic Park 

boundary as defined by the City of San Diego. In a letter dated April 9, 2014, the 

California State Historic Preservation Officer concurred with the FTA’s 

determination that the project will result in “no adverse effect” on historic properties.
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Coe, Thurston, Chairperson - ID117 

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September 2014 407 

Com ID Response

Old Town was identified as an EJ community in the Mid-Coast Corridor Transit Project 

Environmental Justice Technical Report and Chapter 4.0, Section 4.20 of the Draft 

SEIS/SEIR. The increased connectivity and mobility provided by the project will benefit 

transit-dependent community members, offering improved access to jobs, education, 

and other opportunities. No disproportionate adverse effects will occur to low income 

or minority populations within the Old Town Community.

15 The comment incorrectly assumes that the project will turn Taylor Street into a 

highway. As discussed in response to Comments 1, 8, and 9, the project mitigation 

measures will not increase the volume of traffic traveling through Old Town or 

change the classification of Taylor Street to a highway. Current and future traffic 

volumes on Taylor Street are independent of the Mid-Coast Corridor Transit Project 

and its mitigation measures. The 2030 traffic volumes used to determine the 

project’s long-term impacts would occur with or without the Mid-Coast Corridor 

Transit Project. The project will not impact pedestrian-oriented businesses or jobs 

within Old Town. Additionally, as stated in response to Comment 3, with 

implementation of the traffic mitigation measures, pedestrian mobility will not be 

adversely affected.

16 The Draft SEIS/SEIR considered the community character in Old Town as 

established through actions of the City Council. The Old Town community has a 

Trolley system, which is a component of its existing community character and is 

supported in the city’s planning documents. The additional Trolley vehicles and 

minor street modifications that will result from the extension of this system and the 

resulting traffic mitigation measures will not substantially alter the character of the 

community or impact historic resources within the Old Town community. The 

project will not require the relocation of buildings or create new structures within the 

Old Town community. 

The project will support one of the public transit objectives in the Old Town San 

Diego Community Plan (i.e., “All studies involving public transit should include the 

consideration of Old Town San Diego as a prime tourist attraction” page 82). Old 

Town State Historic Park is recognized as a “major park and visitor attraction” in the 

corridor, as shown in Chapter 1.0, Section 1.2.2 of the Draft SEIS/SEIR and in 

Chapter 1.0 of the technical reports. Further, the project will support the district by 

broadening and expanding regional and visitor access into the historic community 

and state park via the Trolley, which will allow more visitors to access the park 

without increasing traffic or parking demand.

17 The project will not result in changes to Presidio Park. As stated in response to 

Comment 6, Presidio Park is not within the project APE and will not be affected by 

the project, either directly or indirectly.
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MID-COAST CORRIDOR TRANSIT PROJECT 

408 September 2014 

Com ID Response

18 The design of the project will not substantially alter existing public improvements or 

pedestrian facilities. The traffic analysis completed for intersections near the Taylor 

Street grade crossing considered the pedestrian wait times at intersections (refer to 

Chapter 6.0, Section 6.1.2.2 of the Transportation Impacts and Mitigation Report for 

a description of the analysis). Additional mitigation was identified if pedestrians 

would have an excessive wait time to cross the street (defined as longer than two 

traffic signal cycles). As shown in response to Comment 1, Mitigation Measure TR8 

will add an exit phase to serve pedestrians crossing Pacific Highway. This means 

that once a train (Trolley, Amtrak, COASTER, or freight) clears the grade crossing 

and the gates return to an upright position, pedestrians crossing Pacific Highway 

will be given the green “walk” signal. Additionally, the mitigation measures will 

ensure that mobility, including for pedestrians, is not adversely affected. The 

project will not result in long-term adverse impacts to pedestrian or bicycle facilities 

near this grade crossing.

19 Refer to the response to Comments 7 and 13. The project will not affect the Old 

Town Historic District, its architectural character, or its economic viability. In a letter 

dated April 9, 2014, the California State Historic Preservation Officer concurred with 

the FTA’s determination that the project will result in “no adverse effect” on historic 

properties. 

20 The project is not proposing that Taylor Street become a highway. Refer to the 

response to Comment 8, which states that the project will not change the roadway 

classification of Taylor Street/Rosecrans Street or increase the number of through 

lanes beyond the intersection with Pacific Highway. Additionally, the traffic mitigation 

measures will not impact the historic core subarea or park within this community. 

The project will not introduce a new physical barrier in the Old Town community, 

and no improvements are proposed within the historic district area east of the 

railroad tracks. Changes to the traffic signal system will ensure that pedestrian and 

vehicle wait times are not adversely affected.

21 The use of the term APE in the context of the comment appears to refer to a site 

boundary rather than the area of potential effects for the project. As discussed in 

Chapter 4.0, Section 4.15.1.2 of the Draft SEIS/SEIR, the APE for the Mid-Coast 

Corridor Transit Project encompasses the geographic areas within which historic 

properties could be affected by the project, either directly or indirectly. The project 

APE was delineated to distinguish areas where archaeological and architectural 

resources could be affected (i.e., the archaeological APE is limited to areas that 

could be affected by the maximum extent of project-related ground disturbance). 

Additional information on the methodology used to define the project-specific APE 

is provided in Chapter 4.0, Section 4.1 of the Mid-Coast Corridor Transit Project 

Historic Property Survey and Eligibility Determination Report. The project APE, 

shown in Appendix A of the Historic Property Survey and Eligibility Determination 
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Report, identifies listed or eligible NRHP, CRHR, or San Diego Register of 

Historical Resources architectural resources, but does not show the location of 

archaeological resources. (To protect archaeological resources, the Mid-Coast 

Corridor Transit Project Archaeological Resources Survey Report is not disclosed 

to the public and its access is limited to persons meeting the Secretary of the 

Interior's professional standards for archaeologists.) Impacts to archaeological 

resources are summarized in Chapter 4.0, Section 4.17.3.2, of the Draft 

SEIS/SEIR. In a letter dated April 9, 2014, the California State Historic 

Preservation Officer concurred with the FTA’s determination that the project will 

result in “no adverse effect” on historic properties. 

Site SDM-W-291A, referred by the comment as the Native American village of 

Kosa’aay (or Cosoy) is not located within the project's archaeological APE. 

Previously recorded site CA-SDI-41 was identified during the original records 

search and also has been described as the ethnohistoric village of Cosoy. Site CASDI-41, which is overlapped by SDM-W-291A outside of the Mid-Coast Corridor 

Transit Project APE, was initially considered as potentially extending within the 

APE; however, Extended Phase I archaeological testing conducted in the recorded 

resource location did not identify resources associated with the site in the project 

APE. 

As noted in the confidential Archaeological Resources Survey Report, a low 

potential for buried resources associated with this site exists even though recently 

implemented subsurface exploration did not identify cultural resources within the 

horizontal or vertical APE. As such, Mitigation Measure CON14, noted in Chapter 

4.0, Section 4.17.3.2 of the Draft SEIS/SEIR, requires full-time archaeological and 

Native American monitoring during ground-disturbing construction activities near 

areas where the landform and context indicate the potential for undiscovered 

cultural resources, including in the vicinity of the recorded location of CA-SDI-41, 

which is overlapped by SDM-W-291A outside of the Mid-Coast Corridor Transit 

Project APE. The archeological monitor would halt construction in the event of a 

find, and the resource would be assessed to determine appropriate action, in 

accordance with the confidential Construction Monitoring Plan and Discovery Plan 

that will be implemented during construction. The Plan will be reviewed for 

adequacy and concurred with by SHPO prior to the start of construction.

22 Refer to the response to Comment 21 regarding the APE. The San Diego Presidio 

National Historic Landmark is not located within the project APE, and it will not be 

affected by the project (i.e., no visual, noise/vibration, or air quality impacts on this 

historic resource will occur). In a letter dated April 9, 2014, the California State 

Historic Preservation Officer concurred with the FTA’s determination that the project 

will result in “no adverse effect” on historic properties. 
Volume 3 – Comments and Responses 

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Old Town San Diego Community Planning Group - 

Coe, Thurston, Chairperson - ID117 

MID-COAST CORRIDOR TRANSIT PROJECT 

410 September 2014 

Com ID Response

23 The project will not alter the existing footprint of the OTTC. A transit system within 

Old Town is consistent with the Old Town Community Plan. As stated in response 

to the previous comments, the project will not result in adverse or significant 

impacts on the Old Town community.

24 The project will not impact the core zone land uses east of the grade crossing. The 

Old Town San Diego Community Plan, adopted in 1987, identified that on Taylor 

Street/Rosecrans Street “peak hour congestion in the eastbound direction is evident 

due to poor signal progression and a narrow cross section.” The current travel 

pattern was established decades ago, prior to Trolley service in this area. 

Destination Lindbergh is a separate endeavor commissioned by the San Diego 

County Regional Airport Authority and is not a part of the Mid-Coast Corridor 

Transit Project. 

The response to Section 29 of this comment regarding general purpose vehicles is 

provided below in response to Comment 28.

25 The comment asserts that impacts would result from increased traffic volumes on 

Taylor Street; as discussed in response to Comment 1, the project will not increase 

the volume of traffic traveling through Old Town or the number of through lanes on 

Taylor Street beyond the intersection with Pacific Highway. As stated in response 

to Comment 8, the project will not conflict with the Old Town Community Plan’s 

circulation goals and requirements. Taylor Street/Rosecrans Street is identified as 

a major through street, and the mitigation measures will support this function. 

Further, the intersection improvements are limited to what is necessary to 

accommodate additional Trolleys traveling through the grade crossing.

26 The comment incorrectly assumes that the volume of traffic at the intersection of 

Pacific Highway and Taylor Street/Rosecrans Street is a project impact. As 

discussed in responses to Comments 1, 8, and 9, the project mitigation measures 

will not increase the volume of traffic traveling through the Old Town area. Current 

and future traffic volumes are independent of the Mid-Coast Corridor Transit Project 

and its mitigation measures. The 2030 traffic volumes used to determine the 

project’s long-term impacts would occur with or without the Mid-Coast Corridor 

Transit Project. As stated in response to Comment 1, the technical reports and 

Draft and Final SEIS/SEIRs evaluate impacts from the extension of the Trolley Blue 

Line and propose mitigation measures as needed to mitigate or minimize impacts 

from the project. Destination Lindbergh is a separate endeavor commissioned by 

the San Diego County Regional Airport Authority, and it is not included in the 2030 

RTP. The Destination Lindbergh Plan, and its traffic assumptions, are not a part of 

the analysis for the Mid-Coast Corridor Transit Project 

The traffic mitigation measures proposed near the Taylor Street grade crossing will 

mitigate the impacts from the Mid-Coast Corridor Transit Project to a level below 
Volume 3 – Comments and Responses

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Old Town San Diego Community Planning Group - 

Coe, Thurston, Chairperson - ID117 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 411 

Com ID Response

significance. The mitigation measures are feasible and effective, and do not result 

in ancillary adverse effects; therefore, there is no need for the identification of 

alternate mitigation measures. 

27 Destination Lindbergh is a separate endeavor commissioned by the San Diego 

County Regional Airport Authority and is not a part of the Mid-Coast Corridor 

Transit Project. 

28 The term “general purpose vehicles” is used to convey that there are no restrictions 

to the types of vehicles that can use the additional southbound left-turn lane that will 

be added as mitigation (compared to the existing eastbound “bus only” lane). The 

traffic mitigation is provided to offset increases in vehicular delay that would 

otherwise result from the additional Trolley crossings through the Taylor Street 

grade crossing with the project. 

29 Refer to the response to Comment 27.

30 Refer to the responses to Comment 1, 27, and 32.

31 No “piece-mealing” of mitigation for Destination Lindberg in violation of CEQA is 

occurring. The Mid-Coast Corridor Transit Project and associated traffic mitigation 

measures are not related to the Destination Lindbergh study. The traffic mitigation 

measures included in the project are provided to offset the additional Trolley 

crossings through the Taylor Street grade crossing.

32 The traffic analysis is required to evaluate the impacts of the project in the future 

(2030). The 2030 No-Build Alternative traffic analysis did assume an increase in 

traffic volumes compared to 2010 conditions to account for traffic from other 

approved projects that would be implemented by that time. These volumes were 

also used for the 2030 Build Alternative analysis. As shown in Chapter 3.0, Table 

3-24 of the Draft SEIS/SEIR, with implementation of the traffic mitigation measures 

the intersections near the Taylor Street grade crossing will operate at conditions 

better than the No-Build Alternative.

33 The Mid-Coast Corridor Transit Project is not mitigating for the Destination 

Lindbergh Plan. Project mitigation measures are required to prevent adverse 

impacts from additional Trolley crossings at Taylor Street. Refer to the responses 

to Comments 14 and 27.

34 No “piece-mealing” of mitigation for Destination Lindberg in violation of CEQA is 

occurring. Refer to the responses to Comments 1 and 27. Routing traffic between 

Pacific Highway and I-8 is not the purpose of the Mid-Coast Corridor Transit Project. 

The purpose and need for the Mid-Coast Corridor Transit Project is described in 

Chapter 1.0, Section 1.5 of the Draft SEIS/SEIR.
Volume 3 – Comments and Responses 

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Old Town San Diego Community Planning Group - 

Coe, Thurston, Chairperson - ID117 

MID-COAST CORRIDOR TRANSIT PROJECT 

412 September 2014 

Com ID Response

35 The Presidio or Presidio Park is not located within the project APE. As stated in the 

confidential Mid-Coast Corridor Transit Project Archaeological Resources 

Supplemental Research Report, and based on the recorded site information, the 

precise location of the village of Kosa’aay (also Cosoy) is not known. It has been 

previously described, as indicated in the comment, as Site SDM-W-291A and as 

Site CA-SDI-41, which has had multiple site boundaries, first defined in 1913 and 

subsequently updated in the 1970s, 1990s, and in 2011 as part of the current study. 

In the past, limited testing (subsurface exploration) at the site within the project APE 

did not yield evidence for the presence of CA-SDI-41. Recently performed 

subsurface exploration (Extended Phase I testing) within the previously recorded 

(but unverified) location of the site also did not observe evidence for cultural 

resources within the project APE. In a letter dated April 9, 2014, the California 

State Historic Preservation Officer concurred with the FTA’s determination that the 

project will result in “no adverse effect” on historic properties. 

Nevertheless, the potential exists (albeit low) for the village to be buried within the 

APE near the river. As such, Mitigation Measure CON14, noted in Chapter 4.0, 

Section 4.17.3.2 of the Draft SEIS/SEIR, requires full-time archaeological and 

Native American monitoring during ground-disturbing construction activities within 

the archaeological APE near the San Diego River. 

Additional information on the methodology used to define the project-specific APE 

is provided in Chapter 4.0, Section 4.1 of the Historic Property Survey and Eligibility 

Determination Report. 

Whether Cosoy qualifies for listing as a historic resource is beyond the scope of this 

environmental document. The recommendation of cultural resources for listing on 

the National Register of Historic Places, the California Register of Historical 

Resources, or the San Diego Register of Historical Resources is subject to review 

and approval processes including, for example and as appropriate, the City of San 

Diego Historical Resources Board, the State Historical Resources Commission, or 

the California State Historic Preservation Officer/Keeper of the National Register, 

and the resources must be eligible for listing under one or more of the eligibility 

criteria, at minimum. Additionally, California Historical Landmarks and National 

Historic Landmarks have distinct criteria/approvals for designation.

36 Refer to the response to Comment 14 regarding environmental justice.
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Old Town San Diego Community Planning Group - 

Coe, Thurston, Chairperson - ID117 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 413 

Com ID Response

37 As stated in response to previous comments, the project and associated traffic 

mitigation measures are not related to the Destination Lindbergh study. The 

mitigation measures are required to mitigate impacts from the project. Without the 

mitigation, adverse and significant traffic impacts would occur from project 

implementation, which would be inconsistent with city criteria. As these measures 

are required, consistent with City of San Diego criteria, and as they are feasible and 

do not result in ancillary adverse effects, they will not be removed from this project. 

As discussed in the responses to previous comments, the community character and 

environment in the Old Town community will not be adversely affected by this 

project. 

Refer to the response to Comment 35 regarding the investigation of archaeological 

resources.

 
Volume 3 – Comments and Responses 

Groups / Organizations 

One VA - 

Arends, Stephen, One VA Community Advisory Board - ID179 

MID-COAST CORRIDOR TRANSIT PROJECT 

414 September 2014 

One VA - 

Arends, Stephen, One VA Community Advisory Board - ID179 

 
Volume 3 – Comments and Responses

Groups / Organizations 

One VA - 

Arends, Stephen, One VA Community Advisory Board - ID179 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 415 

Submission ID179 One VA Arends Stephen 

Com ID Response 

1 Your comment expressing support for the VA Medical Center Station will be part of 

the record of proceedings for the Draft SEIS/SEIR. On November 15, 2013, the 

SANDAG Board of Directors approved the Refined Build Alternative, which included 

the VA Medical Center Station as part of the project to be evaluated in the Final 

SEIS/SEIR. 

 
Volume 3 – Comments and Responses 

Groups / Organizations 

San Diego County Bicycle Coalition - 

Hanshaw, Andy - ID257 

MID-COAST CORRIDOR TRANSIT PROJECT 

416 September 2014 

San Diego County Bicycle Coalition - 

Hanshaw, Andy - ID257 
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San Diego County Bicycle Coalition - 

Hanshaw, Andy - ID257 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 417 
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Groups / Organizations 

San Diego County Bicycle Coalition - 

Hanshaw, Andy - ID257 

MID-COAST CORRIDOR TRANSIT PROJECT 

418 September 2014 
Volume 3 – Comments and Responses

Groups / Organizations 

San Diego County Bicycle Coalition - 

Hanshaw, Andy - ID257 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 419 

Submission ID257 San Diego County Bicycle Coalition Hanshaw Andy

Com ID Response

1 Your comments stating the interest of the San Diego County Bicycle Coalition 

and stating appreciation of SANDAG’s proposed improvements to north/south 

bicycle and pedestrian movements will be part of the record of proceedings for 

the Draft SEIS/SEIR.

2 Chapter 4.0, Section 4.4 of the Mid-Coast Corridor Transit Project 

Transportation Impacts and Mitigation Report presents an analysis of impacts to 

bicycle and pedestrian facilities under the Build Alternative. This information is 

summarized in Chapter 3.0, Section 3.4.3 of the SEIS/SEIR. This analysis is 

based on impacts to existing or planned bicycle and pedestrian features (e.g., if 

column placement would require realigning a bicycle lane). Additionally, the 

analysis examined pedestrian connectivity to the stations, with the results 

presented in Chapter 4.0, Table 4-69 of the Transportation Impacts and 

Mitigation Report. The analysis identified major pedestrian generators and 

barriers and reviewed existing facilities and those planned as part of the project. 

This analysis was based on site visits for the 1⁄4 mile station areas and a review 

of maps to characterize existing land uses and concluded that there will be no 

adverse impact to pedestrian movements. 

The project will not restrict bicycle or pedestrian movement to Mission Bay from 

Clairemont or University City. The project alignment will be located within the 

existing MTS right-of-way from the OTTC to north of SR 52.

3 Refer to Master Response 1 regarding the pedestrian and bicycle connections 

included as part of the project. Your comment regarding the importance of a 

bicycle and pedestrian connection from east to west near SR 52 will be part of 

the record of proceedings for the Draft SEIS/SEIR. However, the suggested 

bridge is beyond the scope of the Mid-Coast Corridor Transit Project and not 

required to mitigate any significant impacts. To the extent the project eliminates 

or prevents illegal or unsafe practices, this result would not be considered an 

adverse or significant impact. 

While construction of a grade-separated bicycle/pedestrian bridge at this 

location could benefit the community, funding for the project is not available for 

SANDAG to construct it. In regard to the Mid-Coast Corridor Transit Project 

Draft SEIS/SEIR, such a bridge is not proposed as mitigation since the project 

would not have any adverse or significant impacts to existing east–west bicycle 

and pedestrian facilities in Rose Canyon. Mitigation and avoidance measures 

are proposed when adverse and significant impacts are identified. For 

example, where the Mid-Coast Corridor Transit Project will encroach upon the 

existing Rose Canyon Bicycle Path that runs between I-5 and the existing rail 

line, the bike path will be realigned as part of the project to avoid adverse or 

significant impacts. 
Volume 3 – Comments and Responses 

Groups / Organizations 

San Diego County Bicycle Coalition - 

Hanshaw, Andy - ID257 

MID-COAST CORRIDOR TRANSIT PROJECT 

420 September 2014 

Com ID Response

Although construction of the bridge referenced in the comment is beyond the 

scope of the Mid-Coast Corridor Transit Project, the project will not preclude the 

future addition of a bicycle/pedestrian bridge at this location. 

4 Refer to Master Response 1 and the response to Comment 3. Improvements to 

the Rose Canyon Bicycle Path incorporated into the Mid-Coast Corridor Transit 

Project are limited to areas affected by the project, as shown on the Final 

SEIS/SEIR Plan Set, Sheets 198-207 (available at www.sandag.org/midcoast). 

5 A Transportation Management Plan (TMP) will be prepared for the project. The 

plan will address construction-related impacts to bicycle and other nonmotorized transportation modes and will provide information on bicycle detours, 

including those for the Rose Canyon Bicycle Path. Because project design is 

preliminary, detour plans cannot be completed at this time. The TMP and 

detour routes will be finalized once a contractor has been selected. As stated in 

Chapter 3.0, Section 3.4.7.2 of the Draft SEIS/SEIR, the TMP will include a 

public awareness campaign. This will include effective means and channels to 

inform the public in advance about the project, roadway impacts, and 

construction activities, including closures of any facilities. 

 
Volume 3 – Comments and Responses

Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 421 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

422 September 2014 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 423 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

424 September 2014 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 425 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

426 September 2014 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 427 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

428 September 2014 
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San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 429 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

430 September 2014 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 431 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

432 September 2014 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 433 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

434 September 2014 
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San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 435 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

436 September 2014 
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San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 437 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

438 September 2014 
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San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 439 
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Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

440 September 2014 
Volume 3 – Comments and Responses

Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 441 

Submission ID266 San Diego County Building & Construction Trades Council Purchia 

Robyn, Attorney 

Com ID Response 

1 The Mid-Coast Corridor Transit Project Draft SEIS/SEIR was prepared in accordance 

with NEPA and CEQA requirements. Responses to the general issues raised in this 

comment are set forth in the individual responses to comments below. 

2 SANDAG and FTA are committed to complying with NEPA, CEQA, and federal, 

state, and local regulations regarding the handling and disposal of hazardous 

materials, including, without limitation, the Hazardous Materials Transportation Act, 

the Resource Conservation and Recovery Act, the Toxic Substances Control Act, the 

Comprehensive Environmental Response, Compensation, and Liability Act, California 

Code of Regulations, Title 22 relating to Environmental Health Standards for the 

Management of Hazardous Waste, and California Code of Regulations Title 26 

relating to Hazardous Materials, Hazardous Waste, and Toxics. In California, 

construction-related activities are identified within Title 8 of the California Code of 

Regulations (T8 CCR) and fall under the jurisdiction of the California Department of 

Industrial Relations—California Occupational Safety and Health Administration. For 

work areas located within known areas of soil contamination, the Federal Department 

of Occupational Safety and Health Administration have identified Permissible 

Exposure Levels (PELs). PELs are the threshold levels of exposure that require the 

implementation of specific control measures to protect worker health and safety. An 

example of a control measure is using water spray to reduce the dust generated at a 

site. 

The contractor is required to prepare a project-specific Health and Safety Plan to 

comply with Title 8 of the California Code of Regulations. Within that plan are the 

specific procedures for working around specific types of equipment, identified areas 

of known contamination, and the threshold levels in which the control measures will 

be implemented. 

3 Refer to response to Comments 2, 6, 8, 9, and 10 for detailed information regarding 

the analysis of potential health impacts to construction workers. 

4 The commenter’s summary of information provided in the Draft SEIS/SEIR has been 

noted and will be part of the record of proceedings for the Draft SEIS/SEIR. 

5 The commenter’s summary of some project measures and mitigation measures that 

will be incorporated by the project to protect worker safety has been noted and will be 

part of the record of proceedings for the Draft SEIS/SEIR. 
Volume 3 – Comments and Responses 

Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

442 September 2014 

Com ID Response 

6 The Draft SEIS/SEIR discloses the potential for impacts to construction workers due 

to hazardous materials and identifies extensive project measures that will ensure no 

adverse or significant impacts occur. 

Refer to response to Comment 8 with regard to the description of proposed project 

measures. 

Refer to response to Comments 2, 9, and 10 with regard to health impacts to 

construction workers. 

7 The Draft SEIS/SEIR discloses the potential for impacts to construction workers due 

to hazardous materials and identifies extensive project measures that will ensure no 

adverse or significant impacts occur. No further revision is required. 

Refer to response to Comment 8 with regard to the description of proposed project 

measures. 

Refer to response to Comments 2, 6, 9, and 10 with regard to health impacts to 

construction workers. 

8 As noted in response to Comment 2, project measures are based upon compliance 

with all federal, state, and local regulations regarding the handling and disposal of 

hazardous materials, including, without limitation, the Hazardous Materials 

Transportation Act; the Resource Conservation and Recovery Act; the Toxic 

Substances Control Act; the Comprehensive Environmental Response, 

Compensation, and Liability Act; California Code of Regulations, Title 22 relating to 

Environmental Health Standards for the Management of Hazardous Waste; and 

California Code of Regulations, Title 26 relating to Hazardous Materials, Hazardous 

Waste, and Toxics. As explained in Chapter 4.0, Section 4.10.1 of the Draft 

SEIS/SEIR, these laws and regulations govern the acquisition, cleanup, and use of 

potentially contaminated properties, construction protocols, and operation and 

maintenance practices that may affect the environment and worker and public health 

resulting from the presence or accidental release of hazardous materials. SANDAG 

and FTA are committed to compliance with these laws and regulations. 

Project measures to avoid or minimize impacts of hazardous materials due to 

construction are identified in Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR. 

As described therein, SANDAG and FTA, in association with the project contractor, 

are committed to developing work management plans and monitoring documents 

such as a Stormwater Pollution Prevention Plan (SWPPP), site-specific Health and 

Safety Plans, an Air Quality Monitoring Plan, and a contingency plan to address 

hazardous materials encountered during construction, as described in more detail 

below. 
Volume 3 – Comments and Responses

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San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 443 

Com ID Response 

A SWPPP, as required by the State Water Resources Control Board under the 

General Construction Permit, will be prepared for the overall project by the 

construction contractor. Within the SWPPP, construction zones and staging areas 

and the measures available to minimize potential spills of hazardous, toxic, or 

petroleum substances will be identified. The SWPPP is developed by the general 

contractor and applicable to activities within the projects construction boundaries. 

The SWPPP also identifies who is responsible for implementation, monitoring, and 

reporting of site conditions, material storage and the Best Management Practices 

implemented as the project progresses. 

A site-specific Health and Safety Plan will be prepared by the construction contractor 

and approved by SANDAG to address potential physical and environmental hazards 

that could be encountered during construction activities. The plan delineates the 

basic safety requirements for construction activities and is required to be prepared in 

compliance with all applicable federal, state, and local regulations. 

An Air Quality Monitoring Plan will be prepared by the construction contractor and 

approved by SANDAG to address potential exposure hazards pertaining to airborne 

dust in areas of contamination, and will comply with all applicable federal, state, and 

local regulations. The plan will be adhered to during construction and site activities. 

A Soil Management Plan will be prepared by the construction contractor and 

approved by SANDAG to address contractor procedures in the event that 

undocumented areas of contamination are encountered during construction and site 

activities. 

A contingency plan will be prepared by the construction contractor and approved by 

SANDAG to address contractor procedures in the event that any unidentified 

underground storage tanks or undocumented areas of contamination are 

encountered during construction and site activities. 

If asbestos-cement pipes are encountered during construction, then to ensure worker 

and public safety, removal and disposal will follow applicable federal, state, and local 

regulations, including, without limitation, the requirements of the Occupational Safety 

and Health Administration as stated in 29 CFR 1910.1001 and 29 CFR 1926.1101, 

and the worker protection rules as stated in 40 CFR Part 763 Subpart G, National 

Emission Standards for Hazardous Air Pollution, as specified under Rule 40 CFR 61, 

Subpart M, and the Clean Air Act as required under USC 7401 et seq. 

Final versions of the above-described plans cannot be developed until such time as 

final design plans are available and a contractor is selected. However, at this stage 

of project development, the level of detail provided is sufficient to support informed 

decision-making and meaningful public comment regarding the project measures that 

will adequately address the potential presence of hazardous materials/waste impacts 

due to construction activities. The Draft SEIS/SEIR clearly discloses the potential 
Volume 3 – Comments and Responses 

Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

444 September 2014 

Com ID Response 

presence of hazardous materials/waste due to construction, and SANDAG is 

committed to implementing the described project measures to reduce or avoid those 

impacts. The impacts and project measures are sufficiently described to allow 

informed decision-making and meaningful public comment. 

With regard to soil sampling, the Draft SEIS/SEIR identifies the potential scope of 

hazardous materials that could be encountered during construction of the project and 

includes specific requirements and standards to ensure any hazardous materials are 

identified and managed properly. These measures include gathering and evaluating 

site-specific soil samples prior to commencement of ground-disturbing activities. 

Site-specific soil sampling will take into account the nature of each site, the location, 

the particular site-specific circumstances that create a potential for encountering 

hazardous materials, and the potential to impact worker safety. In areas identified as 

contaminated, the contaminated soil will be disposed of safely at an off-site disposal 

facility in accordance with all applicable laws and regulations. In addition, should 

contaminated soils be encountered during construction, the contaminated soil would 

be properly disposed of off-site at an appropriate disposal facility; proper agencies 

would be notified; and an Emergency Release Follow-up Notice Reporting Form 

would be submitted no more than 30 days following the release (refer to Chapter 4.0, 

Section 4.17.3.2 of the Draft SEIS/SEIR under the heading “Hazardous Materials” for 

additional information). The Draft SEIS/SEIR includes sufficient analysis to identify 

potentially contaminated sites and has projects measures to ensure any hazardous 

materials actually encountered during construction will be properly managed. The 

impacts and project measures are sufficiently described to allow informed decisionmaking and meaningful public comment. 

9 The Draft SEIS/SEIR discloses the potential for impacts to construction workers due 

to hazardous materials and identifies extensive project measures that will ensure no 

adverse or significant impacts occur. 

The potential for impacts to construction worker health was identified in Chapter 5.0 

of the Hazardous Materials Technical Report, and measures to minimize health 

impacts to construction workers and the public were identified in Chapter 5.0, Section 

5.3.2 of this report. The project measures, including the implementation of 

appropriate health and safety procedures to protect worker health and safety, are 

also described in Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR. 

As noted in response to Comment 2, SANDAG and FTA will comply with NEPA, 

CEQA, and federal, state, and local regulations regarding the handling and 

disposal of hazardous materials, including, without limitation, the Hazardous 

Materials Transportation Act, the Resource Conservation and Recovery Act, the 

Toxic Substances Control Act, the Comprehensive Environmental Response, 

Compensation, and Liability Act, California Code of Regulations, Title 22 relating 

to Environmental Health Standards for the Management of Hazardous Waste, and 

California Code of Regulations Title 26 relating to Hazardous Materials, 
Volume 3 – Comments and Responses

Groups / Organizations 

San Diego County Building and Construction Trades Council - 

Purchia, Robyn, Attorney - ID266 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 445 

Com ID Response 

Hazardous Waste, and Toxics. In California, construction-related activities are 

identified within Title 8 of the California Code of Regulations (T8 CCR) and fall 

under the jurisdiction of the California Department of Industrial Relations – 

California Occupational Safety and Health Administration. As explained in 

Chapter 4.0, Section 4.10.1 of the Draft SEIS/SEIR, these regulations address 

worker and public safety; the acquisition, cleanup, and use of potentially 

contaminated properties; construction protocols; and operation and maintenance 

practices that may affect the environment resulting from the presence or 

accidental release of hazardous materials. 

Refer to responses to Comments 6 and 10 for more information regarding potential 

health impacts to construction workers. 

10 The Draft SEIS/SEIR identifies several project measures to address potential impacts 

to construction workers and includes extensive evidence to support a finding that 

they will ensure no adverse or significant impacts occur. 

Refer to response to Comment 8 with regard to the description of proposed project 

measures. 

Refer to responses to Comments 2, 6, 9, and 10 for more information regarding 

potential impacts and measures to prevent health impacts to construction workers. 

SANDAG’s commitment to project and mitigation measures is documented in the 

Record of Decision per NEPA (included as Appendix D of the Final SEIS/SEIR) and 

the agency will adopt a mitigation monitoring and reporting program when the 

findings under CEQA are made. 

11 The Mid-Coast Corridor Transit Project Draft SEIS/SEIR was prepared in accordance 

with NEPA and CEQA requirements. Comments on individual elements of the NEPA 

and CEQA analyses are addressed in the detailed responses to Comments 2, 6, 7, 8, 

9, and 10 above. The performance standards for the various plans mentioned in the 

comment are the PELs developed by the Federal Department of Occupational Safety 

and Health as discussed in response to Comment 2. 

 
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1 The change of address has been noted. A hard copy of the Supplemental 

Environmental Impact Statement/Supplement to the Subsequent Environmental 

Impact Report regarding the San Diego fairy shrimp and the Final SEIS/SEIR has 

been sent to the new address as requested in your comment. 

 
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1 The comment regarding the focus of the letter has been noted. The detailed 

comments regarding the San Diego River and adjoining areas are addressed in the 

subsequent responses. 

2 The comment is noted. 

3 The Draft SEIS/SEIR refers to the portion of the San Diego River Trail in the vicinity of 

the project as the Ocean Beach Bicycle Path. As discussed further, there will be no 

significant long-term impacts to the Ocean Beach Bicycle Path, and short-term 

impacts will not be significant. Construction-related impacts to this facility were 

identified in Chapter 3.0, Table 3-34 and described in Section 3.4.7.3 of the Draft 

SEIS/SEIR under the heading, “Construction-related Impacts on the Bicycle and 

Pedestrian System;” the impacts are also disclosed in the evaluation of the use of 

U.S. Department of Transportation Act Section 4(f) resources in Chapter 5.0, Section 

5.4.2.3 of the Draft SEIS/SEIR. As indicated in these sections, construction will 

require nighttime closure of the Ocean Beach Bicycle Path during erection and 

demolition of falsework. Because this closure will be limited to nighttime hours, 

impacts will be minimized on those that use the facility. During the time when 

falsework is in place, bicyclists may have to dismount and walk while crossing under 

falsework due to low vertical clearance. These limited and temporary impacts will not 

be adverse. 

In addition, project measures are included to ensure the safety of bicyclists using the 

facility. As stated in Chapter 3.0, Section 3.4.7.3 of the Final SEIS/SEIR under the 

heading “Project Measures to Avoid or Minimize Pedestrian and Bicycle Impacts,” in 

coordination with the City of San Diego, SANDAG will develop a Traffic Control Plan 

that will specify the use of advance warning signs. Pavement markings also will be 

provided on the Ocean Beach Bicycle Path to inform bicyclists of the reduced 

headroom clearance and direct them to dismount from their bicycle during 

construction of the San Diego River Bridge. Construction will not cause a significant 

impact to the bicycle path, and further mitigation, beyond the avoidance and 

minimization measures identified above, is not required. As the impacts to the Ocean 

Beach Bicycle Path are not significant, they were not included in Table S-2 in the 

Executive Summary if the Draft SEIS/SEIR, but the analysis is included in the 

environmental documents. 

4 As indicated in Chapter 5.0, Section 5.4.2.2 of the Draft SEIS/SEIR, within the San 

Diego River, the project will include a bridge across the river within the existing MTS 

right-of-way, which will require five support piers in the river. All piers will be within the 

MTS right-of-way, and no permanent structures will be located within the Mission 

Valley Preserve Open Space. Permanent impacts from the piers within the right-ofway will be limited to less than 0.01 acre. Temporary impacts to vegetation will be 

restored to pre-existing conditions or better following completion of construction, and 
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will be subject to a minimum five-year monitoring plan. Permanent impacts from these 

piers will be mitigated within the San Diego Watershed or within an adjacent 

watershed, such as Rose Creek, subject to the approval of the resource agencies. 

For purposes of assessing visual and aesthetic impacts, the guidelines in the Visual 

Impact Assessment for Highway Projects (FHWA, 1988) were used, which is 

applicable to many types of transportation projects. The visual impact assessment 

conducted for the project also considered CEQA thresholds of significance derived in 

part from the City of San Diego significance thresholds. Based on the small footprint 

of the bridge columns and the presence of several existing bridges in the immediate 

vicinity, the project is not anticipated to appreciably alter existing visual conditions at 

this location and no significant visual impacts were identified as a result of 

construction of the bridge over the San Diego River. The visual analysis methodology 

is documented in detail in the Mid-Coast Corridor Transit Project Visual Impacts 

Technical Report. 

Refer to Master Response 12 for information regarding graffiti. 

5 Noise and vibration impacts to the San Diego River associated with construction are 

detailed in Chapter 4.0, Section 4.17 and in Chapter 5.0, Sections 5.4.2.2 and 5.4.2.3 

of the Draft SEIS/SEIR and in the Mid-Coast Corridor Transit Project Biological 

Resources Technical Report. A brief summary is provided below.

In addition to typical noise and vibration associated with construction, substantial 

vibration associated with various methods of ground improvement will occur at the 

San Diego River. Indirect impacts to nesting birds from construction vibration could 

occur as a result of the Refined Build Alternative. Implementation of the project will 

result in construction noise in adjacent habitat areas, which can disrupt foraging, 

nesting, and reproductive activities in special-status breeding birds. Native habitat 

areas adjacent to the project alignment with the potential to support special-status 

breeding bird species are present in the San Diego River; however, existing ambient 

noise levels associated with freeway traffic and other nearby sources are relatively 

high. With mitigation, construction-related noise in adjacent areas is expected to be 

similar to ambient noise levels, and therefore potential indirect impacts to specialstatus wildlife species from noise during construction will not be adverse.

Ground improvements associated with bridge construction at the San Diego River and 

in Rose Creek will result in short-term construction vibration in adjacent native habitat 

areas. Although vibration can disrupt foraging, nesting, and reproductive activities in 

breeding birds, the extent and duration of vibration will be limited to the immediate 

vicinity of construction and will persist for only a short duration of time as groundimproving activities will occur only during the initial stages of bridge construction. As a 

result, potential indirect impacts to special-status wildlife species due to vibration 

during construction will not be adverse. 
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The project will not appreciably alter existing noise, vibration, or visual condition at this 

location, as the new bridge will be located adjacent to existing rail bridges. 

As the impacts to the San Diego River Trail or Mission Valley Preserve are not 

adverse or significant, they were not included in Table S-2 in the Executive Summary 

of the Draft SEIS/SEIR, but the analysis is included in the environmental documents. 

6 Refer to the response to Comment 5. The San Diego River is identified as a wildlife 

corridor in Chapter 5.0, Section 5.1.2.1 of the Biological Resources Technical Report 

under the heading, “Wildlife Corridors and Habitat Linkages.” Mitigation for temporary 

impacts (e.g., restoration of temporarily disturbed areas) is expected to occur on site. 

The Draft SEIS/SEIR identifies the Mast Park site in the City of Santee as a potential 

mitigation location for permanent impacts within the San Diego River Watershed. As 

stated in Chapter 4.0, Section 4.8.4 of the Draft SEIS/SEIR, "Agency consultation 

regarding mitigation, including the identification of off-site mitigation areas, will 

continue throughout the permitting process. Additional on- and off-site options may be 

identified to satisfy mitigation requirements." As noted in Section 4.8 of the Final 

SEIS/SEIR, following the review and comment period for the Draft SEIS/SEIR, the 

mitigation available at Mast Park has been applied to other projects. SANDAG will 

coordinate with the City of San Diego Park and Recreation Department regarding the 

final location of mitigation for impacts to the San Diego River. The location of 

mitigation also will be subject to resource agency approval. 

7 Surveys were conducted according to USFWS protocols, which require a total of eight 

visits over the course of the breeding season for least Bell’s vireo, and five visits for 

southwestern willow flycatcher (as described in Appendix D of the Biological 

Resources Technical Report). The established protocol is intended to provide an 

acceptable level of certainty with respect to determining the presence or absence of a 

species on a site to support analysis of potential effects in accordance with the federal 

Endangered Species Act. Focused surveys frequently occur where there are any 

number of factors that may affect detectability, including noise from roads or water, 

and human activity. The methods employed (i.e., the established protocol) require 

numerous surveys, which accounts for variable field conditions. Where field 

conditions were affected by factors that would reduce detectability, biologists slowed 

down the survey effort to increase the chance of detection. For these reasons, the 

presence of homeless encampments is not expected to have impacted the overall 

detectability of least Bell’s vireo and/or southwestern willow flycatcher during the 

protocol surveys conducted in the San Diego River area. 

8 Outside of the implementation of the mitigation and monitoring necessary for 

revegetated areas, vegetation maintenance is not planned for areas under the bridge 

over the San Diego River. The mitigation and monitoring activities will be described in 

the conceptual wetlands mitigation and monitoring plan that will be developed during 

the permitting process. This conceptual plan will include a summary of existing site 

conditions at proposed on-site and off-site wetland mitigation locations, a summary of 
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proposed impacts, an outline of proposed mitigation/revegetation strategies, and a 

description of the proposed implementation, maintenance, and monitoring programs. 

The conceptual plan will be prepared in accordance with the requirements of the 

USACE, RWQCB, CDFW, and the USFWS, where applicable, and will be subject to 

resource agency approval. Any application of herbicide would be targeted to control 

non-native species during the establishment of native vegetation communities; the 

herbicide application protocol would be subject to the approval of the resource 

agencies. Herbicide use, if any, would be limited to the areas that were subjected to 

direct impacts from column placements, indirect impacts from shading, short-term 

direct impacts from construction (including vegetation clearing, limits of grading, and 

subsurface soil improvements surrounding the columns), and any identified mitigation 

areas where invasive species are of concern. 

9 Refer to the response to Comment 5. Chapter 4.0, Section 4.17.3.2 of the Draft 

SEIS/SEIR, Mitigation Measure CON11, addresses temporary construction impacts 

under bridges and shading. Restoration for temporary impacts under the San Diego 

River bridge will occur at a minimum 1:1 ratio. As noted in CON11, based on the 

wetland communities that are present under the existing bridges over the San Diego 

River (areas subject to permanent shading), similar vegetation communities (e.g., 

cismontane alkali marsh, mulefat scrub) will be planted under the proposed bridges. 

10 No adverse or significant impacts are anticipated to result from TPSS 5, which will be 

located south of the San Diego River and north of I-8 (in the City of San Diego right-ofway). The location of the TPSS is shown on the Final SEIS/SEIR Plan Set, Sheet No. 

55 (available at www.sandag.org/midcoast). The location is adjacent to the Camino 

del Rio off-ramp from I-8 and adjacent to the existing Trolley Green Line tracks; 

nearby noise sources include I-8, the existing Trolley tracks, and the heavy rail tracks. 

The existing land uses near TPSS 5, the San Diego River Trail, and the Ocean Beach 

Bicycle Path are not considered by FTA as noise sensitive. Chapter 3.0, Section 

3.3.1.2 of the Mid-Coast Corridor Transit Project Noise and Vibration Impacts 

Technical Report describes the noise characteristics of the TPSS units. As stated in 

Chapter 5.0, Section 5.1.3.3 of the report, impacts from TPSS units near noisesensitive uses will not be significant. 

As stated in Chapter 4.0, Section 4.4.3 of the Final SEIS/SEIR, all TPSS enclosures 

located in highly urbanized and/or heavily traveled (vehicular or pedestrian) areas will be 

screened from public view with walls and/or vegetation. If walls are used, the material 

and design would be consistent with the existing visual character of the surrounding 

neighborhood. For eastbound users of the Ocean Beach Bicycle Path, the TPSS will be 

obscured by existing vegetation and the topography. For westbound users, the TPSS will 

be partially obscured by the topography and placement of the TPSS on the site and will 

only be visible for a short duration. Additionally, the TPSS will not contrast with the 

surrounding visual character, which is dominated by the highway ramps, support columns, 

a maintained slope below the support columns, existing rail tracks, and utility lines. 

Therefore, the TPSS in this location will not be screened. 
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Refer to Master Response 12 for information relating to graffiti. 

11 As stated in response to Comment 3, construction-related impacts to the San Diego 

River Trail (referred to as the Ocean Beach Bicycle Path) are shown in Chapter 3.0, 

Table 3-34 and described in Section 3.4.7.3 of the Draft SEIS/SEIR under the 

heading, “Construction-related Impacts on the Bicycle and Pedestrian System.” There 

will be no long-term adverse or significant impacts to this facility and thus it is not 

included in Chapter 3.0, Sections 3.4.3.1 and 3.4.3.2 of the Draft SEIR/SEIR, which 

only document the facilities where the project will have long-term impacts. 

The project is grade separated from the San Diego River Trail and will provide 

overhead clearance that is comparable to the nearby bridges. At the location of the 

Ocean Beach Bicycle Path, the Trolley Blue Line bridge will adjoin the Trolley Green 

Line bridge and make the existing bridge wider. This additional width is not expected 

to alter the existing conditions regarding safety and security of the trail. Accordingly 

the project will not significantly impact the safety of trail users. 

12 Projects included in the 2030 RTP and analyzed in the cumulative analysis of impacts 

to biological resources are listed in Chapter 5.0, Section 5.2.1 of the Biological 

Resources Technical Report and summarized in Chapter 4.0, Section 4.19.3.2 of the 

Draft SEIS/SEIR, which indicates that, “The Build Alternative is primarily located within 

a transportation corridor, does not conflict with the approved habitat conservation 

plan, and does not result in significant and unavoidable impacts....Projects that are 

consistent with the MSCP mitigation ratios as specified by the Subarea Plan (City of 

San Diego, 1997) and implementing ordinances (City of San Diego, 2012) are not 

expected to result in a cumulatively considerable impact for those biological resources 

adequately covered by the MSCP....The Build Alternative would be consistent with the 

MSCP ratios. Other foreseeable projects also would undergo environmental review 

and permitting and are expected to be consistent with the MSCP.” 

As stated in Chapter 3.0, Section 3.3.1.2 of the Biological Resources Technical 

Report, “Where the alignment and stations are elevated, long-term indirect impacts 

include shading from elevated structures (bridge crossings, elevated track sections, 

and stations) that could affect plants and vegetation communities by limiting growth 

and productivity, disrupting reproduction, and changing species composition or 

community type. However, impacts to plants and vegetation communities are likely 

dependent on several factors such as height, size, location, orientation, construction 

of overhead structures, and the tolerance of the affected resources themselves (i.e., 

plants and vegetation communities) to shading.” 

Shading impacts will occur entirely within areas temporarily impacted during 

construction and will be mitigated in conjunction with mitigation for temporary 

construction impacts (e.g., restoration of temporarily disturbed areas). This 

restoration will occur on site and will restore disturbed areas to pre-project conditions. 
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Restoration of vegetation communities will be subject to maintenance and monitoring 

for approximately five years to ensure that the mitigation effort meets the established 

success criteria in accordance with an agency-approved habitat restoration plan. 

Success criteria typically address factors such as vegetative cover and survivorship, 

and plans typically include measures to avoid or reduce plant mortality. 

Mitigation Measure CON9 states that, “The location and configuration of wetland 

vegetation communities within restoration areas in the San Diego River and Rose 

Creek would be adjusted to ensure that restored areas beneath bridges are limited to 

wetland communities that can tolerate reduced sunlight availability. Based on the 

presence of wetland communities under existing bridges over the San Diego River 

and Rose Creek, similar communities, including cismontane alkali marsh, mulefat 

scrub, and in some cases southern willow scrub, would be planted under the 

proposed bridges. Restored areas adjacent to the proposed bridges and that are not 

subject to long-term shading would be revegetated primarily with southern willow 

scrub.” This will ensure that temporary impacts to native plants will be restored with 

vegetation known to flourish in areas where shading already occurs. 

13 Design information for the structure at the San Diego River, as shown on Sheet Nos. 

51 and 52 of the Draft SEIS/SEIR Plan Set, provides details of the bridge footprint and 

column and abutment locations. This information is adequate for environmental 

analysis. 

The project will place a single bridge across the San Diego River. The Trolley Green 

Line and LOSSAN bridges are existing facilities. Altogether, transit, commuter freight, 

and intercity services will have three bridges across the San Diego River. As part of a 

separate project, the existing LOSSAN bridge may be removed and replaced by a 

single double-track bridge. Therefore cumulatively, after replacement of the LOSSAN 

bridge, there could still be three bridges within the San Diego River floodplain. 

As discussed in Chapter 5.0, Section 5.1.2.1 of the Biological Resources Technical 

Report, long-term direct impacts from the project will be limited to the loss of not more 

than 0.01 acre of native riparian habitat associated with the installation of concrete 

piers for the proposed bridge crossing. Temporary impacts to vegetation will be 

mitigated as described in Mitigation Measure CON9. Refer to the response to 

Comment 12 with respect to cumulative impacts. 

As discussed in Chapter 5.0, Section 5.1.2.2 of the Mid-Coast Corridor Transit Project 

Water Impact Analysis Technical Report, the hydraulic analysis conducted for the 

project determined that although the project could increase the water surface 

elevation by 0.02 feet, the piers are not expected to alter flood characteristics of the 

San Diego River. As stated in Chapter 4.0, Section 4.9.3.2 under the heading "FloodRelated" of the Draft SEIS/SEIR, "proposed drainage management measures (e.g., 

channel stabilization, low impact development [LIDs], etc.) would avoid or 

accommodate any increase in peak runoff, and proposed structures, channel 
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modifications, and longitudinal encroachments would not raise the 100-year water 

surface elevation more than 1 foot.” The minimal floodway increase will not affect 

existing buildings, structures, or other beneficial uses. The project will document any 

impacts through the FEMA Conditional Letter of Map Revision approval process, as 

well as meet the requirements of the SDRWQCB, as applicable. Therefore, the 

project structure placed within the floodplain will not impede or redirect flood flows, 

and the impacts to flooding as a result of changes to the floodplain from structures will 

not be adverse. Chapter. 4.0, Section 4.19.3 under the heading “Water Resources” 

states that other projects also will undergo their own environmental review and 

permitting processes, and BMPs and mitigation measures will be required for these 

projects to avoid and minimize adverse cumulative impacts. The Build Alternative will 

not contribute to long-term cumulative impacts on water resources. 

Measures will be incorporated into the design to avoid the potential for standing water 

that could accumulate around the project piers. These measures will be designed 

during final design in accordance with standard design practices. 

The project is not anticipated to be subject to tidal influence at the San Diego River 

bridge location since it is approximately 3 miles away from coastal waters (i.e., Pacific 

Ocean). 

Potential impacts to least Bell’s vireo, southwestern willow flycatcher, and light-footed 

clapper rail are described in Chapter 5.0, Section 5.1.2.1 of the Biological Resources 

Technical Report. Although these species were not detected near the San Diego 

River during surveys, measures have been identified that would avoid or minimize 

impacts in the event that suitable habitat becomes occupied prior to construction. 

Consultation pursuant to Section 7 of the federal Endangered Species Act, including 

the Biological Opinion, is documented in Appendix C of Volume 1 of the Final 

SEIS/SEIR. 

14 The San Diego River Park Foundation will be added to the distribution list for 

information on construction scheduling, bicycle path closures, and detour routes (if 

applicable). 

15 The Mission Valley Preserve Open Space is discussed in Chapter 5.0, Table 5-3 of 

the Draft SEIS/SEIR as city-owned parkland. No text edits in Chapter 4.0, Section 

4.1.3.2 of the Draft SEIS/SEIR are needed. 

16 Construction will occur within the MTS right-of-way, not within city-owned parkland. 

The portion of the San Diego River Park that could be affected by the project is 

referred to in the Draft SEIS/SEIR more specifically as the Mission Valley Preserve 

Open Space. No permanent impacts will occur within this city-owned parkland. As 

discussed in Chapter 5.0, Section 5.4.2.2 of the Draft SEIS/SEIR, a temporary 

construction easement approximately 40 feet wide will be required immediately 
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adjacent to the eastern edge of the MTS right-of-way. The area will provide 

construction access and facilitate construction activities associated with the proposed 

bridge over the San Diego River. Once the bridge is completed, the area will be 

revegetated and returned to pre-construction conditions, in accordance with Mitigation 

Measure CON11. 

The Mission Valley Preserve Open Space is considered a U.S. Department of 

Transportation Act Section 4(f) resource. The approval of the city is required for the 

temporary use of this property. The correspondence included in the Final SEIS/SEIR, 

Appendix C, includes City of San Diego concurrence with impacts on Section 4(f) 

resources, including the Mission Valley Open Space Preserve and the Ocean Beach 

Bicycle Path. 

17 The bridge over the San Diego River is located within MTS right of way in the Urban 

Subarea of the Multiple Species Conservation Program—City of San Diego MSCP 

Subarea Plan (City of San Diego, 1997). To the extent any portion of the project 

extends into an MHPA area, the project is a regional public facility anticipated in the 

MSCP and is a compatible land use within the subarea plan. The Overall 

Management Policies and Directives for MHPA in the Urban Subarea require 

preparation of Natural Resource Management Plans (NRMP) for adoption by the City 

Council to govern management of those lands. As indicated in Chapter 5.0, Section 

5.1.2.1 of the Biological Resources Technical Report, “the Mid-Coast Corridor Transit 

Project is described in Section 6.1 of the Draft Final San Diego River NRMP as a 

known project proposed for development within the NRMP area, including a 

description of the anticipated San Diego River bridge (City of San Diego, 2006a).” As 

such, the NRMP supports the conclusion that the project is a compatible land use and 

is considered to be consistent with the MSCP subarea plan. 

As discussed in response to Comment 16, SANDAG is coordinating with the City of 

San Diego regarding project-related impacts in the San Diego River. 

18 The statement in support of the removal of billboards will be part of the record of 

proceedings for the Draft SEIS/SEIR. With the exception of one billboard located 

south of Friars Road and another located west of the San Diego River Bridge, 

billboard structures within the MTS right-of-way will be removed as part of the project. 

Removal of these two billboards is not required for project implementation. 

19 The request for inclusion of the San Diego River on signage along I-5 and on Trolley 

line and station maps will be part of the record of proceedings for the Draft SEIS/SEIR 

that is provided to the decision makers for consideration prior to taking action on the 

project. Signage within the I-5 right-of-way is regulated by Caltrans, and signage at 

Trolley stations and aboard Trolley vehicles will be developed by MTS. 
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20 Passengers on the Trolley Green Line, Amtrak, and COASTER currently have views 

of the San Diego River and the nearby existing bridges. The addition of the Trolley 

Blue Line Bridge will alter these views; however, it will not be inconsistent with the 

existing visual environment. Brief interruption of views will occur when trains and 

Trolley vehicles pass each other at the same time, but this disruption of passenger 

views is not considered significant because views of the San Diego River will be 

available to passengers during the majority of time trains and Trolley vehicles cross 

the river. With the exception of additional poles and associated catenary, the views of 

riders west of the San Diego River will remain similar to existing views. As 

documented in the visual analysis prepared for the project, visual impacts in this area 

will be less than significant. 

21 The calculations for the San Diego River presented in Chapter 4.0, Table 4-17 of the 

Draft SEIS/SEIR were checked and confirmed to be accurate. Chapter 3.0, Section 

3.3 of the Biological Resources Technical Report provides a thorough description for 

the three types of impacts listed in Table 4-17 (see also Chapter 5.0, Table 5-4 of the 

Biological Resources Technical Report). The impacts associated specifically with 

bridges are described in Chapter 3.0, Sections 3.3.1 and 3.3.2 of the Biological 

Resources Technical Report. Direct impacts at the San Diego River Bridge crossing 

include the footprint of associated piers and abutments. Long-term indirect impacts 

include shading from elevated structures that could affect plants and vegetation 

communities by limiting growth and productivity, disrupting reproduction, or changing 

species composition or community type. Short-term construction impacts can be 

either direct or indirect. Temporary construction impacts associated with construction 

of the San Diego River Bridge crossing will extend up to 40 feet from the east edge of 

the platform. Temporary construction impacts at the bridge crossing will be necessary 

to allow for falsework, subsurface ground improvements, and construction access. 

Ground improvements are required to stabilize areas surrounding bridge piers and 

abutments. These improvements will be installed in a manner to ensure that preexisting contours and vegetation can be restored following construction. 

The bridge over the San Diego River will have seven spans, requiring two abutments 

and six support columns, one of which will be north of the river. Column sizes are 

expected to be approximately 7 feet in diameter, and the locations can be seen on 

Sheet Nos. 51 and 52 of the Draft SEIS/SEIR Plan Set. 

22 At the time of publication of the Draft SEIS/SEIR, groundwater conditions were 

evaluated from boring data collected along and nearby the alignment and projectspecific borings had not been performed. As noted in Chapter 4.0, Section 4.8 of the 

Water Impact Analysis Technical Report, borings encountered ground water within the 

San Diego River drainage at depths of between 24 feet (at higher elevations outside 

of the river levee) to 5 feet below ground surface (within the flood channel), which 

corresponds to approximately mean sea level (Geocon, 1991). Borings began prior to 

circulation of the Final SEIS/SEIR; these investigations are not yet complete. Once 

complete, the data obtained during the investigations may be obtained through a 
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request to SANDAG. Chapter 4.0, Section 4.9.3.2 of the Draft SEIS/SEIR under the 

heading “Ground Water” states that extensive storm-drainage systems along the 

project alignment currently intercept rainfall and runoff, thus limiting the amount of 

ground-water recharge that occurs and do not currently allow for direct percolation 

within the underlying ground-water basins. Therefore, there will be no substantial 

reduction in ground-water recharge due to increased impervious surfaces. 

Additionally, the use or extraction of ground water for project operations is not 

expected. Accordingly, the Build Alternative will not result in any adverse groundwater impacts. 

Chapter 4.0, Section 4.9.3.2 of the Draft SEIS/SEIR under the heading "FloodRelated" states that under an extreme weather event (100-year design storm plus 

2100 Sea Level Rise extreme conditions), water-surface elevations at the San Diego 

River Bridge could increase by 0.01 feet; however, the bridge will have sufficient 

freeboard to accommodate the increase in water-surface elevation. Sea-level rise 

impacts to project structures, including 100-year storm events, are shown in Chapter 

5.0, Table 5-6 of the Water Impact Analysis Technical Report. 

23 The project alignment and associated structures will affect a small area of the San 

Diego River embankment. However, the area needed for construction will require 

approximately 800 linear feet across the San Diego River and extend 40 feet beyond 

the edge of the bridge. As a result, homeless encampments in this area may be 

affected during construction of the project. In addition, to ensure a safe rail operating 

environment, encampments will not be allowed within or directly adjacent to the 

project rights-of-way on a permanent basis. The project will include fencing, natural 

barriers, and/or signs to preclude encroachments into the construction area. Any 

person or persons camped within the construction area would be notified to vacate 

and, if needed, removed. Persons requiring temporary shelter and/or social services 

would be directed to the City of San Diego Homeless Administrator regarding the 

city’s Homeless Services Program. SANDAG will coordinate with the city prior to 

construction to advise them of the need for temporary shelter and services for 

homeless individuals within the project construction zone. Such services may be 

provided by the city or an affiliate agency. 

 
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Com ID Response

1 Your comment expressing support for the Mid-Coast Corridor Transit Project 

alignment has been noted and will be part of the record of proceedings for the Draft 

SEIS/SEIR. The concerns referenced in this comment are addressed in detailed 

responses to subsequent comments. 

2 Community impacts are described in Chapter 4.0, Section 4.2.3.2 of the Draft 

SEIS/SEIR and in the Mid-Coast Corridor Transit Project Social, Communities, and 

Neighborhood Impacts Technical Report. Specifically, the analysis examined the 

transportation and environmental effects of the project on the surrounding 

communities, including residences, businesses, educational and medical facilities, 

and parks and open space. The analysis concluded that under the Build Alternative, 

long-term impacts will be less than significant with the incorporation of project 

measures and mitigation measures. Noise, vibration, and visual impacts are 

addressed more fully in detailed responses to comments below. 

3 The comment stating that design and construction should be done with great care 

has been noted and will be part of the record of proceedings for the Draft SEIS/SEIR. 

4 The Draft SEIS/SEIR fully discloses impacts to the University City community. 

Specifically, the Draft SEIS/SEIR discloses that the project will have temporary 

adverse and significant impacts within the University City community during 

construction, even with mitigation (transportation: transit, traffic, and parking; air 

quality; noise and vibration). However, permanent impacts will be less than 

significant with incorporation of project measures and mitigation measures. The 

comment does not identify any specific impact that has been underestimated or 

dismissed, and as a result, no specific response is provided. Detailed responses are 

provided in response to subsequent detailed comments. 

5 SANDAG has complied with requirements under NEPA and CEQA and is committed 

to avoiding, minimizing, and mitigating the impacts of the project in the University City 

community. On November 15, 2013, the SANDAG Board of Directors approved the 

Refined Build Alternative, which included several project refinements that avoid or 

minimize impacts in the University City Community. Outreach, consultation, and 

coordination efforts are described in Chapter 8.0 of the Final SEIS/SEIR, and have 

included coordination with a variety of stakeholders in the University City community 

to address specific concerns through refinements to the design of the project and 

identification of mitigation. Chapters 3.0, 4.0, and 5.0 of the Final SEIS/SEIR present 

a comprehensive analysis of potential impacts and identify feasible mitigation 

measures as appropriate. 
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6 SANDAG agrees that the Draft SEIS/SEIR must comply with CEQA as well as FTA 

and NEPA requirements. The SANDAG Board of Directors in certifying the SEIR will 

affirm that the Final SEIR meets CEQA requirements. The FTA, in issuing its Record 

of Decision, will affirm that the Final SEIS meets FTA and NEPA requirements. 

7 Please refer to the Mid-Coast Corridor Transit Project Final Refined Build Alternative 

Report for a description of the refinements that have been made to the project since 

release of the Draft SEIS/SEIR. These refinements were made in response to 

comments, stakeholder coordination, and a result of ongoing engineering and 

environmental studies. The changes to the project and mitigation measures referenced 

in this comment are addressed in detailed responses to subsequent comments. 

8 Chapter 4.0, Section 4.7.3 of the Draft SEIS/SEIR includes an extensive noise and 

vibration analysis. The information is presented in more detail in the Mid-Coast 

Corridor Transit Project Noise and Vibration Impacts Technical Report, which has 

been modified to reflect the Refined Build Alternative. Noise impacts related to 

the project are evaluated using the FTA criteria, including screening distances of 

350 feet with unobstructed line-of-sight to the receivers and 175 feet with 

intervening buildings. At these distances, weather and wind conditions have a 

negligible effect on noise levels. MTS Trolleys are equipped with two horns, a 

loud warning horn used in emergency situations and a quieter one (quacker horn) 

used when leaving stations. The California Public Utilities Commission requires 

the quacker horns to be 75 decibels measured 100 feet in front of the vehicle; offsite noise is reduced by mounting the horns at the track level on the trains rather 

than on the roof, and focusing the sound forward. The use of quacker horns by 

the Trolleys when they leave stations has been included in the noise analysis. 

MTS does not currently announce train arrivals. MTS will be introducing 

announcements throughout the system to comply with ADA requirements. As 

stated in Chapter 5.0, Section 5.1.1 of the Noise and Vibration Impacts Technical 

Report, station public address systems will have automatic volume adjustment 

controls that are designed so the announcements are only a few decibels above 

ambient noise levels. As such, the noise from these systems will not generate 

any moderate or severe noise impacts in communities near stations. 

9 A continuous sound wall next to the La Paz community has been incorporated into 

the project. However, as described below, the change was done for aesthetic 

purposes and was not required to mitigate significant noise impacts. 

As described in Chapter 4.0, Section 4.7.3.2 and illustrated in Figure 4-19 of the Final 

SEIS/SEIR, noise impacts within the La Jolla Colony area will be limited to 23 units 

within the La Paz condominiums, identified as Clusters 57, 59, and 61 in the Final 

SEIS/SEIR (a cluster is a grouping of noise-sensitive uses, such as houses, that 

would experience operational noise from the project and have a similar existing noise 

environment). Noise levels at Cluster 61 will not exceed the moderate impact 
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threshold. At that location, the impact will be less than significant and no mitigation 

will be provided. Refer to Master Response 9 for additional information on the noise 

analysis and mitigation. 

Sound walls will be provided at two locations to mitigate noise impacts at 11 units 

within the La Paz condominiums (referred to as Mitigation Measures N2 and N3 in 

Chapter 4.0, Table 4-14 of the Final SEIS/SEIR). The noise impact analysis 

conducted in support of the SEIS/SEIR determined that the project will not generate 

noise that will exceed FTA noise-impact criteria at other locations within the La Jolla 

Colony. 

Freeway noise at some residences in La Jolla Colony will be reduced as a result of 

shielding that will be created in the area when the grade is elevated to install the lightrail tracks between the residences and the freeway. There will be no significant noise 

impacts to other residences within the La Jolla Colony or Barcelona developments 

because they will be farther from, or shielded from, the project. 

Two sound walls (Mitigation Measures N3 and N4 in the Draft SEIS/SEIR—referred 

to as Mitigation Measures N2 and N3 in Chapter 4.0, Table 4-14 of the Final 

SEIS/SEIR) were identified in the Draft SEIS/SEIR as mitigation for the noise impacts 

to the 11 units in the La Paz condominiums; however, a single continuous sound wall 

encompassing both walls has been incorporated into the Final SEIS/SEIR Plan Set 

based on aesthetics and will provide equivalent noise mitigation. Sound-absorptive 

finishes are not required to reduce noise impacts at this location as the wall will be 

effective at reducing noise to below the moderate impact level. 

In general, reducing exterior noise levels caused by the project is preferable to sound 

insulation because it will continue to benefit residents when they are outside or have 

their windows open. Because all moderate noise impacts will otherwise be mitigated, 

double-paned windows are not proposed for the La Paz residences. 

10 As described in Chapter 4.0, Section 4.7.3.2 and illustrated in Figure 4-19 of the Final 

SEIS/SEIR, noise impacts requiring mitigation will be limited to 11 units within the La 

Paz condominiums within the La Jolla Community. This impact will be mitigated at 

this location with Mitigation Measures N2 and N3, as indicated in Chapter 4.0, Table 

4-14 of the Final SEIS/SEIR. The noise analysis did not identify any other moderate 

or severe noise impacts in La Jolla Colony. 

As stated in the response to Comment 9, providing sound walls to reduce exterior 

noise levels is preferable to sound insulation. 

11 SANDAG specifically evaluated the aesthetic impact of sound walls and retaining 

walls associated with the project, and identified mitigation measures to reduce 

significant visual impacts to a level below significant. None of the proposed walls are 

anticipated to have an adverse impact to view corridors; however, some will contrast 
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with existing visual character. Walls identified as having significant visual impacts, 

described in Chapter 4.0, Section 4.4.5.1 of the Final SEIS/SEIR, will require design 

and landscaping mitigation to improve their aesthetic quality. Visual impacts related 

to sound walls were documented in Chapter 4.0, Section 4.4.3.2 of the Final 

SEIS/SEIR and Chapter 5.0 of the Mid-Coast Corridor Transit Project Visual Impacts 

Technical Report. With implementation of design treatments, significant visual 

impacts will be reduced to a less-than-significant level. Mitigation Measures VR1, 

VR3, and VR4, as described in Chapter 4.0, Section 4.4.4 of the Final SEIS/SEIR, will 

apply to sound wall design and aesthetic finishes. As indicated in Response 9, a 

continuous wall encompassing both sound walls N2 and N3 has been incorporated 

into the project to improve project aesthetics. 

Sound walls at the La Paz condominiums (Clusters 57 and 59) will be located in a 

heavily vegetated area with mature trees and shrubs on an existing slope. The area 

at the base of the existing slope (west of the condominiums) currently experiences 

heavy shade and shadows for most of the day, with moderate sunlight near mid-day 

because of the direct overhead angle of the sun; the sound walls will not cause or 

significantly modify existing shade or shadow patterns compared to existing 

conditions. 

A 4-foot sound wall on top of the aerial structure is proposed east of the Sheraton 

Hotel to mitigate impacts at the Loft Apartments at the Shops at La Jolla Village 

shopping center and Sheraton La Jolla Hotel (Clusters 71 and 72, respectively) 

referred to as Mitigation Measure N4 in Chapter 4.0, Table 4-14 of the Final 

SEIS/SEIR; however, it will not cast shadow on any portions of the existing hotel 

structure. There is sufficient distance between the aerial structure and the hotel 

buildings so that no shading will occur. Any shadows will fall onto the adjacent 

surface parking lot. 

12 On November 15, 2013, the SANDAG Board of Directors approved the Refined Build 

Alternative. The refinements resulted in minor modifications to the operational speed 

of the trains. A reduction in Trolley speed will not be required because the mitigation 

listed in Chapter 4.0, Table 4-14 of the Final SEIS/SEIR will eliminate all significant 

operational noise impacts for the project. 

13 SANDAG considered the noise generated by stationary sources, including TPSSs, in 

the analysis of the project. The noise analysis conducted for the Draft SEIS/SEIR 

concluded that no noise impacts will be caused by TPSS units under the Build 

Alternative or options. TPSSs will be enclosed and the loudest noise source at the 

fence line will be air conditioning equipment used to cool the units. There will be no 

noticeable “hum” from the TPSSs. The results of the noise analysis of the TPPS 

units was documented in Chapter 5.0, Section 5.1.3.3 of the Noise and Vibration 

Impacts Technical Report and summarized in Chapter 4.0, Section 4.7.3.2 of the 

Draft SEIS/SEIR under the heading "Stationary Source Noise Levels." 
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After the close of the Draft SEIS/SEIR comment period, several TPSSs were 

relocated or eliminated. Refer to Chapter 2.0, Section 2.3.5 of the Final SEIS/SEIR 

for an overview of changes to TPSS locations. The noise analysis was updated 

based on the new locations and is documented in Chapter 4.0, Section 4.7.3.2 of the 

Final SEIS/SEIR. The updated analysis again concluded that there will be no noise 

impacts from TPSSs and, therefore, noise from TPSSs will not impact wildlife. 

14 The Trolley will not travel at speeds fast enough to generate wind impacts on 

existing buildings, including the XiMed Building and the buildings in the La Paz 

community. The projected maximum operating speed of the LRT trains is 55 mph. 

The aerodynamic effects of a light rail train at this speed are minimal. After the 

close of the Draft SEIS/SEIR comment period, the project alignment along Voigt 

Drive in the vicinity of Scripps Memorial Hospital La Jolla (Scripps Hospital) was 

relocated. The alignment relocation was based on coordination with hospital 

representatives to identify the location of sensitive equipment at the XiMed 

building, as well as further engineering and environmental studies. Specifically, 

the alignment has been shifted to the south side of Voigt Drive away from the 

XiMed Building. The alignment under the Refined Build Alternative evaluated in 

the Final SEIS/SEIR is a minimum distance of 168 feet from the XiMed Building 

compared to 36 feet under the Build Alternative evaluated in the Draft SEIS/SEIR.

15 The noise analysis was conducted in accordance with the FTA Transit Noise and 

Vibration Impact Assessment Guidance Manual (FTA, 2006), and the disclosed 

impacts will not be influenced by variations in wind and weather. While wind and 

temperature gradients can modify noise at very large distances, weather conditions 

have negligible effect on noise levels within the 350-foot noise screening distance for 

light rail transit. Noise levels beyond 350 feet will not exceed significance thresholds, 

even if weather causes the noise to travel farther or faster. 

16 Vibration impacts to hospitals, research facilities, and schools were considered in the 

Draft SEIS/SEIR. Hospitals and research facilities with vibration-sensitive equipment 

were identified as vibration Category 1 land uses, subject to the most stringent 

vibration impact criteria (see Chapter 4.0, Table 4-12 of the Draft SEIS/SEIR). The 

vibration analysis showed that vibration reaching Category 1 land uses will not 

exceed the applicable criteria. The use of FTA methodology to evaluate vibration 

impacts provides sufficient information to determine the impacts of vibration on a 

variety of land uses. As described in the Noise and Vibration Impacts Technical 

Report, the vibration impact criteria are based on the maximum indoor vibration level 

as a light rail train passes. The application of the vibration criteria discussed in 

Chapter 4.0, Section 4.7.1.3 of the Draft SEIS/SEIR is described in greater detail in 

Chapter 3.0, Section 3.4.1.2 of the Noise and Vibration Impacts Technical Report. 

The results of the vibration analysis for the VA Medical Center Station, the UCSD 

Structural and Mechanical Engineering Building, and Scripps Hospital are described 

in Chapter 4.0, Section 4.7.3.2 of the Draft SEIS/SEIR. 
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17 The statement referenced in the comment in Chapter 4.0, Section 4.7.2 of the Draft 

SEIS/SEIR refers to noise and not vibration. The text has been revised to state that 

there are no noise Category 1 land uses. There are three vibration Category 1 land 

uses. Refer to the response to Comment 16 regarding vibration impacts. 

18 The lower-than-typical traffic volumes that may have occurred during the noise 

measurements conducted at UCSD may have resulted in the application of a lower 

noise impact criteria level. Noise impacts thresholds are lower when existing noise 

levels are lower; therefore, lower ambient noise measurements would not reduce the 

level of noise impacts disclosed for the project. To the contrary, project noise would 

more easily exceed significance thresholds. 

19 The noise impact assessment used for the NEPA analysis follows guidelines from the 

FTA Transit Noise and Vibration Impact Assessment Guidance Manual (FTA, 2006). 

The thresholds of impacts are defined by the criteria included in this manual. The 

future ambient noise level may increase as a result of other projects mentioned in the 

comment independent of the Mid-Coast Corridor Transit Project. The CEQA analysis 

evaluated whether the project would increase the ambient noise level by 3 dBA or 

more at locations along the alignment. Under the Refined Build Alternative, five 

noise-sensitive receiver clusters representing 19 residential units and 20 hotel rooms 

are predicted to experience moderate noise impacts at least 1 dBA greater than the 

impact threshold or an increase in the cumulative environmental noise level of more 

than 3 dBA. With mitigation, the impacts at these five locations will be less than 

significant. 

The cumulative effect of the project and other future projects is not used by FTA as 

the basis for identification of a noise impact that would require mitigation; rather, it is 

based on the level of noise generated by the project. A noise increase caused by 

other actions independent of the project would not be a direct impact of the project. 

Generally speaking, the louder the ambient noise level, the louder the project noise 

level must be to trigger a moderate or severe impact under FTA criteria (see Chapter 

4.0, Figure 4-16 in the Final SEIS/SEIR). 

The cumulative noise analysis is documented in Chapter 4.0, Section 4.19.3.2 of the 

Draft SEIS/SEIR under the heading "Noise and Vibration." As stated in this section, 

the cumulative impacts from the future expansion of I-5 and the LOSSAN double 

tracking were among the projects considered as part of the cumulative noise analysis. 

As stated in this section, because the major source of future noise impacts is 

roadway vehicle noise rather than LRT noise, "to the extent that any cumulatively 

significant impact would occur, the project's contribution would not be cumulatively 

considerable." With mitigation, noise impacts from the project will be less than 

significant. Noise and vibration impacts related to the UCSD and Scripps Hospital 

expansion would largely be associated with the construction phase of those projects, 

and the projects would not cause long-term cumulatively significant noise and 

vibration impacts. Other projects, including the future I-5 widening and LOSSAN 
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double tracking, would be required to undergo appropriate approval processes to 

minimize the potential for incompatible noise and vibration environments. Therefore, 

the project will not cause an adverse or significant cumulative noise impact and will 

not result in cumulatively considerable impacts under CEQA. 

It should be noted that the Refined Build Alternative reflected in the Final SEIS/SEIR 

further reduces noise and vibration impacts to Scripps Hospital and the Scripps 

XiMed Building, as discussed in response to Comment 14. 

20 The Draft SEIS/SEIR concluded that there will be no significant vibration impacts at to 

any building within Scripps Hospital, including the XiMed Building. In the case of the 

XiMed Building, the Draft SEIS/SEIR identified a moderate noise impact but no 

vibration impact. The reference to Scripps Hospital in Chapter 4.0, Section 4.7.3.2 of 

the Draft SEIS/SEIR under the heading “Light Rail Transit Vibration Levels” is 

identifying the entire hospital campus, including the XiMed Building, as a vibration 

Category 1 land use, and disclosing that there will be no vibration impacts. The 

detailed vibration analysis of the Build Alternative alignment on the Scripps Hospital 

campus is based on the location of the XiMed Building (Cluster 79), which is nearest 

to the alignment. Chapter 5.0, Section 5.1.4.2 of the Noise and Vibration Impacts 

Technical Report provides the detailed analysis, and the exact location of Cluster 79 

is shown in Appendix G of that technical report. The predicted train vibration at the 

XiMed Building will be below the vibration criteria for an operating theater or surgical 

facilities and will not exceed the criterion used for electron microscopes operating to 

the limit of their capacity. 

Additionally, shifting the LRT alignment for the Refined Build Alternative to the south 

side of Voigt Drive, as described in response to Comment 14, would further reduce 

vibration levels. 

21 Maintenance provisions for the XiMed Building are not required. As stated in 

response to Comment 14, the alignment near Scripps Hospital has been refined since 

the close of the Draft SEIS/SEIR comment period. The noise and vibration analyses 

were updated based on the new alignment. The updated analysis concluded that 

there will not be significant or adverse noise or vibration impacts to Scripps Hospital 

or the XiMed Building with the new alignment (Chapter 4.0, Section 4.7.3.2 of the 

Final SEIS/SEIR). 

22 Refer to the response to Comment 14 regarding wind energy impacts. 
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23 The sound wall identified in the Draft SEIS/SEIR for noise impacts at Cluster 79 was 

proposed on the aerial structure itself, and would have been a minimum of 4 feet 

higher than the level at which the wheels meet the tracks (“rail activity”). However, as 

stated in response to Comment 14, the alignment near Scripps Hospital has been 

refined since the close of the Draft SEIS/SEIR comment period. For the Refined 

Build Alternative, the alignment has been shifted to a minimum of 168 feet away from 

the XiMed Building. With this refinement, there will not be a noise impact to this 

facility and the sound wall that was identified in the Draft SEIS/SEIR will not be 

required (refer to Chapter 4.0, Section 4.7.3.2 of the Final SEIS/SEIR). 

24 Subsequent to issuance of the Draft SEIS/SEIR, SANDAG removed the proposed 

construction staging area on the Scripps Hospital La Jolla property. A smaller 

construction easement will still be required on Scripps Hospital property, as shown on 

the Final SEIS/SEIR Plan Set right-of-way plans Sheet 390; however, there will not 

be parking impacts at Scripps Hospital during construction, and no valet parking will 

be required at this location. 

25 As indicated in the response to Comment 14, the alignment has been refined since 

the close of the Draft SEIS/SEIR comment period to move it farther from the XiMed 

Building (168 feet under the Refined Build Alternative as compared to 36 feet under 

the Build Alternative). As described in Chapter 4.0, Section 4.17.3.2 of the Final 

SEIS/SEIR, construction activities will result in temporary adverse air quality impacts 

related to construction emissions of NOx and CO2. To mitigate potential impacts 

during construction to the intakes of HVAC systems serving affected facilities, the 

project will be required to comply with regional and state rules and regulations 

regarding the registration and operation of construction equipment and the removal 

and disposal of asbestos. Chapter 4.0, Section 4.17.3.2 of the Final SEIS/SEIR 

describes these regulations (SDAPCD Rules 12, 54, and 361.145; CARB’s Off-Road 

Diesel Vehicle Registration). Furthermore, the project will include the following 

BMPs: minimize idle times of construction equipment; maintain equipment in good 

condition; and control construction dust through watering of earthwork during grading 

activities. The impacts described in the Final SEIS/SEIR are generalized for the 

entire project; location-specific BMPs and mitigation measures will depend on the 

specific construction activities, equipment being used, and scheduling at each site. 

SANDAG will coordinate with facility operators prior to construction to ensure minimal 

possible impacts to HVAC intakes for sensitive facilities. Coordination could include 

provisions for additional or new filters at the HVAC intakes. 

26 As stated in response to Comment 14, the alignment near Scripps Hospital has been 

modified as reflected in the Refined Build Alternative, and the distance to construction 

will be greater than the distance considered in the Draft SEIS/SEIR (approximately 

150 feet under the Refined Build Alternative). Additionally, the construction staging 

area on Scripps Hospital property that was shown in the Draft SEIS/SEIR has been 

eliminated in the Final SEIS/SEIR. While the increased distance will reduce 
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temporary noise impacts during construction, as detailed in Chapter 4.0, Section 

4.17.3.2 of the Final SEIS/SEIR, the project will have significant unavoidable 

temporary noise impacts during construction. The project and mitigation measures 

included in the Final SEIS/SEIR will minimize those impacts to the extent practicable. 

SANDAG will prepare contract specifications that define the noise-control measures 

to be implemented during construction, and will develop a Noise Control Plan as 

specified in Mitigation Measure CON1. The contract specifications will require the 

contractor to meet the requirements of the City of San Diego Municipal Code noise 

limits of 75 decibels average sound level for construction noise measured at or 

beyond the property lines of any property zoned residential during the 7 a.m. to 7 

p.m. 12-hour period when construction is allowed. 

27 As stated in response to Comment 24, the construction staging area at Scripps 

Hospital is no longer required and is not included in the Final SEIS/SEIR. Therefore, 

there will not be impacts to parking at this location during construction. 

28 The visual analysis in the Draft SEIS/SEIR and the supporting technical report 

provides a comprehensive overview of project features and their visual impact (see 

Chapter 4.0, Section 4.4 of the Draft SEIS/SEIR, and the Visual Impacts Technical 

Report). For purposes of assessing visual and aesthetic impacts, the guidelines in 

the Visual Impact Assessment for Highway Projects (FHWA, 1988) were used, which 

is applicable to many types of transportation projects. The visual impact analysis 

uses a representative approach to evaluate the impacts of the project. By identifying 

key views that represent important resources, viewer groups, and significant project 

elements, the impacts at these key views can be used to characterize the overall 

impacts of the project and provide mitigation measures that can be applied based on 

site-specific conditions. Within the University Community, the guideway will be within 

the existing railroad, freeway, and street right-of-way, as well as portions of La Jolla 

Village Square shopping center, UCSD, and the Westfield UTC shopping center. The 

project will be compatible with the existing transportation, commercial, and 

institutional uses, with structural architectural design treatments (see Mitigation 

Measure VR3 in Chapter 4.0, Section 4.4.4 of the Draft SEIS/SEIR) implemented to 

reduce the visual impacts of structural elements (i.e., the aerial guideway). TPSSs in 

highly urbanized and/or heavily traveled areas will be screened from public view to 

reduce visual impacts (see Chapter 4.0, Section 4.4.3.2 of the Final SEIS/SEIR under 

the heading “Project Measures to Avoid or Minimize Impacts” for a description of 

TPSS screening). 

Refer to Master Response 1 for information regarding station design compatibility 

with surrounding communities. 

Refer to Master Response 13 for information regarding project lighting impacts. 

It should be noted that FTA guidelines do not require an analysis of “shade and 

shadow” as a significance criteria for the visual impact analysis. Although shade and 
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shadow patterns will be created by the aerial guideway, these patterns mostly will be 

contained within the street right-of-way, with the longest duration of shadows 

occurring from late morning to early afternoon. Along the project corridor (i.e., where 

the aerial guideway will be located along Genesee Avenue), adjacent buildings and 

mature trees typically create shade and shadow patterns. The shadows created by 

the buildings will supersede any shadows created by the aerial guideway. As such, 

the shadows created by the aerial guideway will be consistent with the existing visual 

environment. 

Mitigation Measures VR4, VR5, VR6, and VR7, as described in Chapter 4.0, Section 

4.4.4 of the Final SEIS/SEIR, will apply to landscape design and aesthetic finishes. 

VR4 requires that landscape design plans be developed by a qualified landscape 

architect and coordinated with local agencies and property owners. VR7 specifically 

requires the use of native and/or drought-resistant plants whenever appropriate. 

29 Refer to the response to Comment 11 regarding visual mitigation for sound and 

retaining walls. Refer to Master Response 12 regarding graffiti. 

30 In response to concerns raised about the visual impacts associated with TPSSs, 

additional measures have been added that require that TPSSs in highly urbanized or 

traveled areas be screened to reduce visual impacts (see Chapter 4.0, Section 

4.4.3.2 of the Final SEIS/SEIR under the heading “Project Measures to Avoid or 

Minimize Impacts” for a description of TPSS screening). 

In addition, as a result of analysis of power requirements and in response to input 

received on the Draft SEIS/SEIR, the locations of several TPSSs have been modified. 

Two TPSSs were eliminated. Refer to Chapter 2.0, Section 2.3.5 for a summary of 

the changes made to TPSS locations since the Draft SEIS/SEIR. 

TPSS 14 (now referred to as TPSS 12 in the Final SEIS/SEIR) has been relocated 

from Charmant Drive to the west side of I-5. It will be located on Caltrans right-of-way 

adjacent to the La Jolla Village Square shopping center. 

Placing any of the TPSSs underground is cost prohibitive. Placing a TPSS 

underground would introduce additional requirements, such as ventilation and 

drainage/water pumps (to avoid water damage to electrical equipment). Further, 

maintenance would be more difficult for an underground TPSS because special 

equipment is needed. The site requirements would also be larger than for an above 

ground unit in order to provide sufficient space for the TPSS and maintenance 

access. Coordination with SDG&E, MTS, and the City of San Diego Fire Department 

would be required in order to place a TPSS underground as all entities would need 

access for maintenance or in case of emergency. Based on these additional 

requirements, the cost would be considerably higher than that for an above ground 

TPSS. Currently, none of the TPSSs on the existing MTS system are underground. 
Volume 3 – Comments and Responses 

Groups / Organizations 

University Community Planning Group - 

Kruger, Janay, Chairperson - ID265 

MID-COAST CORRIDOR TRANSIT PROJECT 

484 September 2014 

Com ID Response

31 Refer to Master Response 13 for information regarding lighting at stations and along 

the Trolley tracks. 

32 Refer to Master Response 1 for information regarding station design. Chain link 

fencing will not be used at any of the stations. 

Mitigation measures that will reduce visual impacts are described in Chapter 4.0, 

Section 4.4.4 of the Draft SEIS/SEIR and include VR2 and VR3. 

33 Your comment expressing support for the inclusion of the VA Medical Center Station 

has been noted. On November 15, 2013, the SANDAG Board of Directors approved 

the inclusion of the VA Medical Center Station as part of the Refined Build Alternative 

analyzed in the Final SEIS/SEIR. 

The mode choice component of the SANDAG Series 11 Travel Demand Forecasting 

Model, which was used to predict ridership for the project, is sensitive to both travel 

time and walk time. This is described further in the Mid-Coast Corridor Transit 

Project Veterans Administration Medical Center Station Feasibility Study Technical 

Memorandum. As noted in the comment, the addition of the VA Medical Center 

Station will benefit those who travel to the VA Medical Center or the nearby UCSD 

medical facilities. The predicted decrease in demand on the Trolley Blue Line due to 

the increase in travel time resulting from the addition of the VA Medical Center 

Station is negligible (less than 1 percent of daily boardings). 

34 Your comment expressing opposition to the Genesee Avenue Design Option has 

been noted. On November 15, 2013, the SANDAG Board of Directors approved the 

Refined Build Alternative, which includes the use of center columns to support the 

structure along Genesee Avenue, to be analyzed in the Final SEIS/SEIR. With the 

Refined Build Alternative, all straddle bents except two have been eliminated from the 

project. 

35 Refer to the response to Comment 30 regarding the TPSS on Charmant Drive and 

the feasibility of placing TPSSs underground. Chapter 2.0, Figure 2-21 in the Final 

SEIS/SEIR presents a TPSS that was more recently installed along the Trolley 

system. 

TPSS 13 (now referred to as TPSS 11 in the Final SEIS/SEIR) south of La Jolla 

Colony Drive has been retained in the location presented in the Draft SEIS/SEIR 

based on the results of the load flow analysis. Additional project measures have 

been identified, as described in Chapter 4.0, Section 4.4.3.2 of the Final SEIS/SEIR 

under the heading “Project Measures to Avoid or Minimize Impacts,” and will provide 

for landscape screening to ensure that the facility will be screened from trails within 

Rose Canyon Open Space Park. 
Volume 3 – Comments and Responses

Groups / Organizations 

University Community Planning Group - 

Kruger, Janay, Chairperson - ID265 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 485 

Com ID Response

36 Refer to Master Response 14 for information regarding the noise analysis for Rose 

Canyon Open Space Park. 

37 Refer to Master Response 14 for information regarding the noise analysis for Rose 

Canyon Open Space Park and Marian Bear Memorial Park. 

The predicted noise level in Rose Canyon Open Space Park mentioned in the 

comment is incorrect. The predicted noise levels for the Trolley are detailed in 

Chapter 5.0, Tables 5-2 through 5-5 of the Noise and Vibration Impacts Technical 

Report. The predicted noise levels from Trolley operations range from 45 to 69 dBA 

along the entire length of the alignment as experienced at the nearest sensitive 

receivers. Noise levels within Rose Canyon Open Space Park and Marian Bear 

Memorial Park will range between 45 and 50 dBA. 

38 Refer to Master Response 15 for information regarding the visual analysis for Rose 

Canyon Open Space Park. 

39 The analysis conducted for the project determined that it will not result in adverse 

noise or visual impacts on Rose Canyon Open Space Park with mitigation. 

Further, construction of the suggested berm for light shielding or to reduce visual or 

noise impacts would result in impacts to natural resources. Refer to Master 

Response 17 for the potential to construct an earthen berm. 

The assertion that a berm would reduce the potential for the seeds of non-native 

plants to spread in Rose Canyon Open Space Park is unsupported. SANDAG will 

coordinate with MTS, NCTD, and the City of San Diego to identify any concerns or 

opportunities regarding weed control. Construction of a berm would not eliminate the 

need for the weed abatement/maintenance program. 

40 Refer to the responses to Comments 28 and 31 regarding lighting and Master 

Response 17 regarding a berm. 

The Mid-Coast Corridor Transit Project will not be inconsistent with the MSCP. The 

project will not include any permanent light elements or fixtures in Rose Canyon 

Open Space Park, although some lighting will be required during construction. 

Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR indicates that during 

construction, with the use of shielded lights for nighttime security lighting in the area, 

the occasional use of the area by wildlife is not expected to be substantially affected. 

Refer to Master Response 13 for further information regarding project lighting. 
Volume 3 – Comments and Responses 

Groups / Organizations 

University Community Planning Group - 

Kruger, Janay, Chairperson - ID265 

MID-COAST CORRIDOR TRANSIT PROJECT 

486 September 2014 

Com ID Response

41 The project will not result in significant adverse noise impacts to areas in or adjacent 

to the MHPA. Master Response 14 addresses noise impacts to special-status wildlife 

species within Rose Canyon Open Space Park, which is the portion of the MHPA 

within the study corridor. 

42 Chapter 4.0, Section 4.8.5.1 of the Draft SEIS/SEIR indicates that the project is not 

expected to introduce invasive plants into natural open space areas. Landscaping 

will be incorporated at stations and related facilities. Mitigation Measure VR7, 

described in Chapter 4.0, Section 4.4.4 of the Final SEIS/SEIR, explicitly prohibits the 

use of invasive plants or noxious weeds in any new plantings, regardless of location, 

and encourages the use of native and/or drought-resistant plants wherever 

appropriate. Mitigation for temporary impacts to native vegetation (e.g., restoration of 

temporarily disturbed areas) will occur on site and will restore the disturbed areas to 

pre-project conditions or better using only appropriate native plant species (see 

CON11 in Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR under the heading 

“Biological Resources Impacts”). 

43 Refer to the response to Comment 35 regarding the visual assessment of the TPPS 

in Rose Canyon Open Space Park. 

As stated in Chapter 3.0, Section 3.3.1.2 of the Noise and Vibration Impacts 

Technical Report, a TPSS will create a noise level of 45 dBA at 50 feet from the 

substation. The TPSS will not generate an adverse or significant noise impact to 

noise-sensitive uses within Rose Canyon Open Space Park because the noise 

generated will be below the impact criteria for noise-sensitive uses within the park. 

44 Refer to Master Response 16 for a discussion of proposed mitigation for impacts to 

biological resources in the Rose Canyon area. 

45 Refer to Master Response 16 for a discussion of proposed mitigation for impacts to 

biological resources in the Rose Canyon area. 

46 Following construction, the concrete-lined channel under SR 52 will remain available 

for wildlife movement between Rose Canyon Open Space Park and Marian Bear 

Memorial Park. The concrete-lined channel has been designed with a slight 

inclination toward the center of the channel. During dry seasons when the flows will 

be limited to irrigation runoff, the outer segments of the channel bottom will carry 

limited amounts of runoff and will continue to facilitate wildlife movement. The 

majority of riprap placed at the upstream and downstream ends of the proposed 

channel will not be grouted, which will allow sediment to fill gaps, creating a more 

natural and even surface for wildlife to cross. In addition, a path along the east side 

of the open channel under SR 52 within Caltrans right-of-way will be retained for 

maintenance access and will continue to be available for wildlife movement along the 

channel. The project will not introduce any new barriers to pedestrian movement. 
Volume 3 – Comments and Responses

Groups / Organizations 

University Community Planning Group - 

Kruger, Janay, Chairperson - ID265 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 487 

Com ID Response

47 Pullouts at the Executive Drive Station will accommodate private shuttle buses (refer 

to Chapter 2.0, Figure 2-19 of the Final SEIS/SEIR for the location of these pullouts). 

Additionally, Trolley passengers using the UCSD East Station can transfer to MTS 

and UCSD shuttles, while the UTC Transit Center will be a major hub for MTS bus 

service. 

48 The UCSD East Station will be connected to Thornton Hospital by existing sidewalks 

along Voigt Drive and Campus Point Drive. 

49 MTS regularly reviews bus demand and loadings. Should the demand on Route 992 

increase, the service is anticipated to be adjusted to accommodate the demand either 

by using larger buses or shortening the headway between buses. Such adjustments 

would be made as part of MTS operations and are not a part of the Mid-Coast 

Corridor Transit Project. 

 
Volume 3 – Comments and Responses 

Groups / Organizations 

University Community Planning Group - 

Kruger, Janay, Chairperson - ID265 

MID-COAST CORRIDOR TRANSIT PROJECT 

488 September 2014 

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Volume 3 – Comments and Responses

Businesses 

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - 

Heidelberg, Evelyn - ID223 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 489 

BUSINESSES 

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - 

Heidelberg, Evelyn - ID223 
Volume 3 – Comments and Responses 

Businesses 

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - 

Heidelberg, Evelyn - ID223 

MID-COAST CORRIDOR TRANSIT PROJECT 

490 September 2014 
Volume 3 – Comments and Responses

Businesses 

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - 

Heidelberg, Evelyn - ID223 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 491 
Volume 3 – Comments and Responses 

Businesses 

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - 

Heidelberg, Evelyn - ID223 

MID-COAST CORRIDOR TRANSIT PROJECT 

492 September 2014 
Volume 3 – Comments and Responses

Businesses 

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - 

Heidelberg, Evelyn - ID223 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 493 
Volume 3 – Comments and Responses 

Businesses 

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - 

Heidelberg, Evelyn - ID223 

MID-COAST CORRIDOR TRANSIT PROJECT 

494 September 2014 

Submission ID223 Alecta Real Estate USA, LLC (Shops at La Jolla Village) Heidelberg

Evelyn

Com ID Response

1 Responses to the comments regarding procedural and substantive concerns are 

provided below.

2 Public notification for the project fully satisfied the public and agency outreach and 

coordination requirements of NEPA and CEQA. As summarized in Chapter 8.0, 

Section 8.3 of the Draft SEIS/SEIR, in April and May 2010, scoping notices were 

published in local newspapers and, as the commenter has noted, postcards were 

sent to nearly 25,000 residents and businesses in the corridor to notify them about 

the project. The scoping notices provided summary information about the project 

and approval process, and described multiple ways to obtain additional 

information, including public scoping meetings and website links. Participation at 

either the scoping meetings or through the website provided the opportunity to join 

the project e-mail newsletter distribution list. The 2010 scoping process 

culminated in the SANDAG Board of Directors' reconfirmation of the LPA that had 

been first identified during the 1990s and was a matter of public record. 

As part of the publication of the Draft SEIS/SEIR, FTA and SANDAG placed 

notices in local newspapers and mailed notices to local residents and businesses, 

as well as provided notice through the Federal Register, the State Clearinghouse, 

and the San Diego County Clerk’s office. In addition, SANDAG has included 

groups and organizations, such as the University Community Planning Group and 

the San Diego Regional Chamber of Commerce, throughout the planning process 

as a secondary means to distribute information to their members. SANDAG has 

continued to make a good-faith effort to notify all affected parties about the project 

and opportunities for participation. The additional details suggested by the 

commenter were not required to be part of the notices given.

3 As discussed in response to Comment 2, throughout the duration of the project, 

SANDAG has conducted the required public notification and has provided ample 

opportunities for public participation. All SANDAG Board of Directors meetings 

related to project decisions, including decisions regarding the alignment, have 

published agendas and have been open to the public. Chapter 2.0, Section 2.1 of 

the Draft SEIS/SEIR describes the prior actions and studies relevant to the project. 

The Draft and Final SEIS/SEIRs are a continuation of work that began with 

issuance of the Notice of Intent in 1990. The project is not approved or adopted 

until the SANDAG Board of Directors certifies the Final SEIS/SEIR, approves the 

project, and files the Notice of Determination, thus completing the CEQA process. 

The Final SEIS/SEIR includes all comments received during the review and 

comment period and SANDAG’s responses to such comments. 
Volume 3 – Comments and Responses

Businesses 

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - 

Heidelberg, Evelyn - ID223 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 495 

Com ID Response

4 In 2008, right-of-way was transferred for the purpose of improving access to the 

Shops at La Jolla Village (at that time known as the La Jolla Village Center), an 

action unrelated to environmental review for the Mid-Coast Corridor Transit 

Project.

5 As discussed in response to Comment 2, SANDAG has provided the required 

public notification and opportunities for participation throughout the duration of the 

project. In addition to these public opportunities to participate, SANDAG met with 

the management team for the property in 2009, when the shopping center was 

represented by Madison Marquette, and again in 2013, when it was represented 

by StepStone Real Estate Services. Further, the commenter has received actual 

notice of the proposed project alignment and a full opportunity to comment on its 

potential environmental consequences, as evidenced by the detailed comment 

letter submitted by its legal counsel. 

6 As discussed in Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR, the project 

will require temporary construction easements on several properties during 

construction. The specific areas required are detailed in the Final SEIS/SEIR Plan 

Set (Volume 2 of the Final SEIS/SEIR), Sheet 387 (available at 

www.sandag.org/midcoast). 

SANDAG is committed to working with property owners and businesses to 

minimize the negative effects to access and operations during the construction 

period. The parking lot on the west side of the Alecta property will remain open to 

shopping center use and will not be used for staging of construction. A temporary 

construction easement will be required between the building and the I-5 freeway 

(as shown on Sheet 387 in the Final SEIS/SEIR Plan Set), but access to loading 

docks will be maintained during construction. Delivery of construction materials 

will be closely coordinated with operation of the tenants in the shopping center. 

Maneuvering of delivery trucks around construction areas (truck turning templates) 

will be used to demonstrate adequacy of the remainder of the access road for use 

by delivery trucks.

7 In response to the concerns raised in your comment, construction vehicle access 

from Nobel Drive has been eliminated, as shown in the right-of-way plans included 

in the Final SEIS/SEIR Plan Set (Volume 2 of the Final SEIS/SEIR).

8 In response to the concerns raised in your comment, construction vehicle access 

from Nobel Drive has been eliminated.

9 The parking imbalance is a short-term impact that is not considered significant. 

The near-term analysis for spillover parking stated that the demand for parking at 

the Nobel Drive Station will exceed supply by 18 spaces or 7 percent (refer to 

Chapter 3.0, Table 3-30 of the Draft SEIS/SEIR). The project will not permanently 
Volume 3 – Comments and Responses 

Businesses 

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - 

Heidelberg, Evelyn - ID223 

MID-COAST CORRIDOR TRANSIT PROJECT 

496 September 2014 

Com ID Response

reduce the number of parking spaces at the La Jolla Village Square shopping 

center. Chapter 3.0, Section 3.4.4.4 of the Draft SEIS/SEIR concluded that, 

"Parking around the Nobel Drive Station is regulated for the use of patrons of the 

shopping center; therefore, spillover parking would be unlikely to occur." In 

particular, signage at the Shops at La Jolla Village shopping center indicates that 

parking is for the use of shopping center patrons and is limited to 2 hours. In 

addition, the Nobel Drive Station will provide an alternative means of access for 

local shopping centers. Thus, the small, short-term parking imbalance is not 

anticipated to result in significant vehicular congestion or other physical impacts. 

The long-term (2030) analysis shows a demand for 258 spaces, which is within the 

capacity of the parking facility (refer to Chapter 3.0, Table 3-28 of the Draft 

SEIS/SEIR). Therefore, there will not be long-term adverse or significant spillover 

parking impacts from the Nobel Drive Station and park-and-ride facility. 

10 SANDAG recognizes that the temporary loss of 9 parking spaces will result in 

some inconvenience, but the temporary loss of approximately 1 percent of 

available parking is not anticipated to result in significant physical impacts. The 

Transportation Management Plan, as described in Chapter 3.0, Section 3.4.7.2 of 

the Final SEIS/SEIR, will include strategies to manage traffic and associated 

parking demand during construction. One such measure could be temporary 

incentives for employees to use transit, which would leave more parking spaces 

available for customers of the shopping center. 

11 The traffic analysis conducted in support of the Draft SEIS/SEIR evaluated 

potential impacts at the intersections of Nobel Drive and La Jolla Village Square 

and Nobel Drive and Villa La Jolla Drive. The analysis showed that 

implementation of the project will not result in adverse traffic impacts at either 

intersection under near-term conditions (as quantified in 2010) or future conditions 

in 2030. 

The results of the analysis were presented in Chapter 4.0, Table 4-62 of the MidCoast Corridor Transit Project Transportation Impacts and Mitigation Report. As 

shown in this table, at Nobel Drive and La Jolla Village Square, the increase in 

delay is below the City of San Diego’s threshold for an adverse impact. As the 

Draft SEIS/SEIR only included a discussion of adverse impacts or impacts 

requiring mitigation that were identified in the technical report, the results for this 

intersection were not presented in the Draft SEIS/SEIR. 

Additionally, since the time that the traffic analysis was conducted for the Draft 

SEIS/SEIR, exclusive right-turn lanes have been added at this intersection as part 

of a separate effort, and will improve intersection operations. 

The project will not result in an adverse impact at the Nobel Drive and Villa La Jolla 

Drive intersection, as described in Chapter 4.0, Table 4-62 of the Transportation 
Volume 3 – Comments and Responses

Businesses 

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - 

Heidelberg, Evelyn - ID223 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 497 

Com ID Response

Impacts and Mitigation Report. With the project, the level of service in the a.m. 

peak hour will remain LOS D, with LOS C conditions during the p.m. peak hour. 

The City of San Diego considers LOS A through LOS D to be acceptable. 

The addition of the project will not result in an adverse near-term impact near 

Nobel Drive. Traffic studies were conducted for near-term conditions, using 

conditions as they existed in 2010 (referred to as existing conditions). The 2010 

conditions were based on traffic counts collected in 2010. The results of the 

existing conditions analysis are documented in Chapter 7.0, Table 7-9 of the 

Transportation Impacts and Mitigation Report. As shown in this table, with the 

project, the Nobel Drive and La Jolla Village Square intersection will operate at 

LOS B during the a.m. peak hour and LOS D during the p.m. peak hour, while the 

Nobel Drive and Villa La Jolla Drive intersection will operate at LOS B during the 

a.m. peak hour and LOS C during the p.m. peak hour. 

12 The noise and vibration impact analysis conducted for the project included an 

evaluation of the residential uses at the Shops at La Jolla Village. The Mid-Coast 

Corridor Transit Project Noise and Vibration Impacts Technical Report designates 

this area as Cluster 71 (multifamily residential), which is depicted in Appendix G of 

this technical report. 

The noise impact assessment at Cluster 71 was revised based on design revisions 

for the Refined Build Alternative. The project-generated noise at Cluster 71 is 

predicted to be 63 dBA Ldn, an exceedance of the impact threshold of 58 dBA Ldn, 

which would be a moderate impact. The existing noise level in this area has also 

been revised based on updated measurements conducted at the Sheraton La Jolla 

Hotel in November 2013 to better reflect the noise levels currently experienced at 

Cluster 71. The existing noise is 59 dBA Ldn. Noise mitigation for the project is 

now required at this location. Noise Mitigation Measure N4, a sound wall on the 

aerial structure in front of the Sheraton La Jolla Hotel and Shops at La Jolla 

Village, will mitigate the impact at Cluster 71 (refer to Chapter 4.0, Table 4-14 of 

the Final SEIS/SEIR). The location of Cluster 71 is also shown in Chapter 4.0, 

Figure 4-19 of the Final SEIS/SEIR. With mitigation, the noise level will be 51 dBA 

Ldn, which is below the impact criterion of 58 dBA Ldn. 

Chapter 5.0, Section 5.1.4.2 of the Noise and Vibration Impacts Technical Report 

presents the results of the vibration impact analysis conducted for the areas north 

of the OTTC. As noted in Table 5-10, the project-related vibration levels for 

Cluster 71 (37 VdB) are well below the screening threshold that would warrant 

more detailed analysis (72 VdB), and no adverse impact will occur. Therefore, no 

vibration mitigation is required at this location. 
Volume 3 – Comments and Responses 

Businesses 

Alecta Real Estate USA, LLC (Shops at La Jolla Village) - 

Heidelberg, Evelyn - ID223 

MID-COAST CORRIDOR TRANSIT PROJECT 

498 September 2014 

Com ID Response

13 Your comments expressing concern with the alignment location and the structures 

associated with the aerial guideway have been noted and will be part of the record 

of proceedings for the Draft SEIS/SEIR. Alternative alignments were reviewed 

prior to the SANDAG Board of Directors' reconfirmation of the LPA in 2010. These 

alternative alignments, which included placing the alignment along the east side of 

I-5, were documented in the Mid-Coast Corridor Transit Project Comparative 

Evaluation of Alternatives Report. Chapter 3.0 and Chapter 4.0 of this report 

include information related to the identification and screening of initial alternatives 

and the conceptual alternatives considered; Chapter 6.0 presents the 

recommendation of alternatives to carry forward into scoping. 

The Build Alternative alignment evaluated in the Draft SEIS/SEIR and the Refined 

Build Alternative alignment evaluated in the Final SEIS/SEIR both follow the LPA 

that was reconfirmed by the SANDAG Board of Directors in 2010. The alignment 

is already located as far to the east as possible. Moving the alignment into the I-5 

right-of-way is not feasible because the right-of-way is needed for future expansion 

of the freeway. The project has been designed to avoid placement of columns 

within the shopping center parking lot. 

Coordination with the shopping center occurred after the close of the Draft 

SEIS/SEIR comment period. The shopping center signage will be relocated so it is 

visible from I-5. Relocation of the signage will be done in consultation with the 

shopping center. Views of the building-mounted signs facing east at the back of 

the stores may be partially obstructed by the aerial guideway at intermittent points 

along the freeway for motorists, but this is not considered a significant physical 

impact. 

Socioeconomic and fiscal impacts of the Mid-Coast Corridor Transit Project are 

addressed in Chapter 4.0, Section 4.3.3.2 of the Draft SEIS/SEIR, which provides 

that compensation for property acquisitions will be in accordance with the Federal 

Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, 

as amended, the California Relocation Assistance Act of 1970, as amended, and 

SANDAG Board of Directors’ Policy No. 021. To the extent the commenter 

asserts an additional right to recover damages, the comment goes beyond the 

scope of the Draft SEIS/SEIR.

 
Volume 3 – Comments and Responses

Businesses 

Armstrong Garden Centers - 

Asakawa, Eric, South and Bay Area Regional Mgr – ID004 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 499 

 

Armstrong Garden Centers - 

Asakawa, Eric, South and Bay Area Regional Mgr – ID004 

 
Volume 3 – Comments and Responses 

Businesses 

Armstrong Garden Centers - 

Asakawa, Eric, South and Bay Area Regional Mgr – ID004 

MID-COAST CORRIDOR TRANSIT PROJECT 

500 September 2014 

Submission ID004 Armstrong Garden Centers Asakawa Eric

Com ID Response

1 Your comment expressing concern with the acquisition of the Armstrong Garden 

Center has been noted and will be part of the record of proceedings for the Draft 

SEIS/SEIR. Site design variations and elimination of the Tecolote Road Station were 

evaluated to determine the feasibility of avoiding acquisition of the nursery without 

impacting station access and ridership. Master Response 3 provides a detailed 

discussion of the evaluation. Based on the evaluation completed, it was determined 

that acquisition of the nursery could not feasibly be avoided. 

To the extent applicable, relocation assistance and compensation will be provided by 

SANDAG as required by the Federal Uniform Relocation Assistance and Real 

Property Acquisition Policies Act of 1970, as amended (49 CFR 24); the California 

Relocation Assistance Act of 1970, as amended (California Government Code 

Section 7260 et seq.); and SANDAG Board of Director's Policy No. 021.

 
Volume 3 – Comments and Responses

Businesses 

Armstrong Garden Centers - 

Asakawa Eric, South and Bay Area Regional Mgr - ID136 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 501 

Armstrong Garden Centers - 

Asakawa Eric, South and Bay Area Regional Mgr - ID136 
Volume 3 – Comments and Responses 

Businesses 

Armstrong Garden Centers - 

Asakawa Eric, South and Bay Area Regional Mgr - ID136 

MID-COAST CORRIDOR TRANSIT PROJECT 

502 September 2014 
Volume 3 – Comments and Responses

Businesses 

Armstrong Garden Centers - 

Asakawa Eric, South and Bay Area Regional Mgr - ID136 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 503 
Volume 3 – Comments and Responses 

Businesses 

Armstrong Garden Centers - 

Asakawa Eric, South and Bay Area Regional Mgr - ID136 

MID-COAST CORRIDOR TRANSIT PROJECT 

504 September 2014 

Submission ID136 Armstrong Garden Centers Asakawa Eric

Com ID Response

1 Your comments have been noted and will be part of the record of proceedings for 

the Draft SEIS/SEIR. 

2 The information regarding the capital improvements made to the property and the 

number of visitors has been noted and will be part of the record of proceedings for 

the Draft SEIS/SEIR. Typically, these factors are considered in the process 

associated with any necessary property acquisition for the public project. To the 

extent applicable, relocation assistance and compensation will be provided by 

SANDAG as required by the Federal Uniform Relocation Assistance and Real 

Property Acquisition Policies Act of 1970, as amended (49 CFR 24); the California 

Relocation Assistance Act of 1970, as amended (California Government Code 

Section 7260 et seq.); and SANDAG Board of Director's Policy No. 021. 

3 Site design variations and elimination of the Tecolote Road Station were evaluated 

to determine the feasibility of avoiding acquisition of the nursery without impacting 

station access and ridership. Master Response 3 provides a detailed discussion of 

the evaluation. Based on the evaluation completed, it was determined that 

acquisition of the nursery could not feasibly be avoided.

4 Refer to Master Response 3 regarding the feasibility of eliminating the Tecolote 

Road Station. Relocation assistance and compensation will be provided by 

SANDAG as described in the response to Comment 2.

5 Refer to Master Response 3 regarding the site design variations of the Tecolote 

Road Station that were evaluated to determine the feasibility of avoiding acquisition 

of the nursery without impacting station access and ridership, the goal of transit 

equity, and minimizing project impacts to existing commercial and residential uses. 

SANDAG remains committed to ongoing public outreach and coordination.

 
Volume 3 – Comments and Responses

Businesses 

Armstrong Garden Centers - 

Butkus, Stephanie – ID034 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 505 

Armstrong Garden Centers - 

Butkus, Stephanie – ID034 

 
Volume 3 – Comments and Responses 

Businesses 

Armstrong Garden Centers - 

Butkus, Stephanie – ID034 

MID-COAST CORRIDOR TRANSIT PROJECT 

506 September 2014 

Submission ID034 Armstrong Garden Centers Butkus Stephanie

Com ID Response

1 Your comment requesting elimination or modification of the Tecolote Road Station 

location has been noted and will be part of the record of proceedings for the Draft 

SEIS/SEIR. Site design variations and elimination of the Tecolote Road Station 

were evaluated to determine the feasibility of avoiding acquisition of the nursery 

without impacting station access and ridership. Master Response 3 provides a 

detailed discussion of the evaluation. Based on the evaluation completed, it was 

determined that acquisition of the nursery could not feasibly be avoided. 

To the extent applicable, relocation assistance and compensation will be provided 

by SANDAG as required by the Federal Uniform Relocation Assistance and Real 

Property Acquisition Policies Act of 1970, as amended (49 CFR 24); the California 

Relocation Assistance Act of 1970, as amended (California Government Code 

Section 7260 et seq.); and SANDAG Board of Director's Policy No. 021.

 
Volume 3 – Comments and Responses

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Armstrong Garden Centers - 

Jones, Gary, Vice President of Marketing - ID038 

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September 2014 507 

Armstrong Garden Centers - 

Jones, Gary, Vice President of Marketing - ID038 

 
Volume 3 – Comments and Responses 

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Armstrong Garden Centers - 

Jones, Gary, Vice President of Marketing - ID038 

MID-COAST CORRIDOR TRANSIT PROJECT 

508 September 2014 

Submission ID038 Armstrong Garden Centers Jones Gary

Com ID Response

1 Your comment requesting the elimination of the Tecolote Road Station has been 

noted and will be part of the record of proceedings for the Draft SEIS/SEIR. Site 

design variations and elimination of the Tecolote Road Station were evaluated to 

determine the feasibility of avoiding acquisition of the nursery without impacting 

station access and ridership. Master Response 3 provides a detailed discussion 

of the evaluation. Based on the evaluation completed, it was determined that 

acquisition of the nursery could not feasibly be avoided. 

To the extent applicable, relocation assistance and compensation will be 

provided by SANDAG as required by the Federal Uniform Relocation Assistance 

and Real Property Acquisition Policies Act of 1970, as amended (49 CFR 24); 

the California Relocation Assistance Act of 1970, as amended (California 

Government Code Section 7260 et seq.); and SANDAG Board of Director's 

Policy No. 021.

 
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Bartell Hotels (Sheraton Hotel) - 

Dawe, Jim, Attorney - ID232 

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Bartell Hotels (Sheraton Hotel) - 

Dawe, Jim, Attorney - ID232 

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September 2014 517 

Submission ID232 Bartell Hotels (Sheraton Hotel) Dawe Jim

Com ID Response

1 Your comments expressing concern regarding the noise and visual impacts to the 

Sheraton Hotel have been noted and will be part of the record of proceedings for the 

Draft SEIS/SEIR. Responses to specific concerns are provided below. SANDAG has 

met with representatives of Bartell Hotels since the close of the Draft SEIS/SEIR 

comment period and supplemental noise and visual studies have been provided to 

these representatives during and after these meetings. This supplemental 

information is attached to the end of this response.

2 The analysis conducted in support of the Draft SEIS/SEIR, and additional analysis 

done in response to this comment, determined that relocating the elevated track 

alignment substantially to the east is not feasible. There is limited space to adjust the 

alignment on the west side of I-5, and placing the facility on the east side of I-5 would 

not allow the project to serve the Nobel Drive Station. The Refined Build Alternative 

reflects a small eastward shift in the alignment near the Sheraton Hotel, which 

eliminated the need for permanent acquisition of a portion of the property. The Draft 

SEIS/SEIR acknowledges that if no mitigation were provided, a significant noise 

impact would occur at the Sheraton Hotel during project operation (see Chapter 4.0, 

Section 4.7.3.2, Figure 4-19, and Table 4-14 of the Draft SEIS/SEIR). The Draft 

SEIS/SEIR identified inclusion of a sound wall adjacent to the Sheraton Hotel for 

mitigation of the impact (specifically Mitigation Measure N5). Additional detail is 

provided in Chapter 6.0, Figure 6-3 of the Mid-Coast Corridor Transit Project Noise 

and Vibration Impacts Technical Report, which shows the location of the sound wall. 

The sound wall is also shown in Figure 1, below. 

At the request of the commenter, supplemental noise studies were conducted during 

preparation of the Final SEIS/SEIR (the studies are attached to the end of this 

response). These studies confirmed that the location of the sound wall (referred to as 

Mitigation Measure N4 in the Final SEIS/SEIR) will mitigate the noise impacts to the 

hotel buildings with guest rooms where the project would result in a moderate noise 

impact. See Response to Comment 9 for additional information regarding the 

additional noise study. 

As stated in Master Response 13, there is no track or aerial guideway lighting, and 

the headlights on the front of the Trolley vehicles are directed straight toward the 

tracks. As illustrated in Figure 1, the alignment is roughly parallel to I-5 when it 

passes near the Sheraton Hotel, and there are no curves that would result in Trolley 

vehicle lights being directed toward the windows of the hotel rooms. Spillover light 

from the Trolley vehicle lights, similar to the headlights on automobiles, would not 

differ substantially from other sources in the surrounding area (e.g., automobiles, 

trucks, street lamps, and traffic signals).
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Bartell Hotels (Sheraton Hotel) - 

Dawe, Jim, Attorney - ID232 

MID-COAST CORRIDOR TRANSIT PROJECT 

518 September 2014 

Com ID Response

3 Figure 1. Location of Alignment near the Sheraton Hotel 

4 The Draft SEIS/SEIR analysis identifies the Sheraton Hotel as a sensitive land use, 

and the environmental analysis and mitigation measures reflect this status. The 

response to Comment 2 outlines mitigation to address operational noise, including 

installation of a sound wall. The response to Comment 10 details project and 

mitigation measures that will minimize noise, vibration, dust, and light impacts during 

construction.

5 In response to this comment, SANDAG provided additional information to Bartell 

Hotels regarding the sound wall to be located on the aerial guideway, such as the 

representative cross sections of the aerial structure shown in Figure 2, below (the 

locations of the cross sections are shown in Figure 1). The additional information 
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Bartell Hotels (Sheraton Hotel) - 

Dawe, Jim, Attorney - ID232 

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provided is still conceptual in nature because at the current level of design, only the 

size and location of the sound wall have been determined. However, the size and 

location of the sound wall are designed to meet the noise-reduction levels described 

in the Final SEIS/SEIR. Additional information on the design of the sound wall will be 

developed and shared with the commenter as it becomes available. 

Figure 2.Cross Section of Aerial Structure with Sound Wall at the Sheraton 

6 All comments and testimony submitted during the Draft SEIS/SEIR public comment 

period, along with responses, are included in Volume 3 of the Final SEIS/SEIR.
Volume 3 – Comments and Responses 

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Bartell Hotels (Sheraton Hotel) - 

Dawe, Jim, Attorney - ID232 

MID-COAST CORRIDOR TRANSIT PROJECT 

520 September 2014 

Com ID Response

7 The noise measurements conducted at the Sheraton Hotel are presented in Appendix 

B, Section B.12 and Table B-12 of the Noise and Vibration Impacts Technical Report. 

SANDAG met with Bartell Hotels and provided a copy of the monitoring data on July 

29, 2013. 

The noise measurements performed as part of the supplemental noise studies 

conducted at the request of Bartell Hotels also have been provided to representatives 

of Bartell Hotels.

8 Consistent with CEQA, SANDAG has completed an evaluation of noise impacts in the 

Mid-Coast Corridor and, where impacts are predicted, devised mitigation to reduce 

the impacts to less-than-significant levels. As described in response to Comment 2, a 

sound wall along the guideway will eliminate the moderate noise impact that 

otherwise would occur at the hotel. The train design speed at this location of the 

alignment is 44 mph, not 55 mph. 

9 The sound wall adjacent to the Sheraton Hotel will shield the primary source of the 

train noise that occurs at the wheel/rail interface. The Mitigation Monitoring and 

Reporting Program for this project includes collecting noise measurements after 

system opening to verify that the mitigation measures committed to by SANDAG are 

performing as presented in the Final SEIS/SEIR (The Mitigation Monitoring and 

Reporting Program is included with the Record of Decision in Appendix D of the Final 

SEIS/SEIR Volume 1). Additional measures, such as increasing the wall height, 

grinding to reduce rail roughness, or applying sound-absorptive materials on the 

structure, will be implemented if the project mitigation does not perform as required.

10 The Sheraton Hotel is typical of residential and hotel uses adjacent to the project 

alignment, and impacts have been assessed consistently with this type of use. The 

noise analysis was conducted in accordance with FTA guidelines as documented in 

the Transit Noise and Vibration Impact Assessment Guidance Manual (FTA, 2006) 

and addresses FTA and CEQA requirements. The analysis includes comparison of 

existing noise levels with the projected noise of the Trolley operations over a 24-hour 

period. This includes the addition of a 10-dBA penalty for Trolley operations that 

occur between 10:00 p.m. and 7:00 a.m. The effect of this penalty is that when 

calculating the average project noise, any event that occurs during nighttime is 

deemed to have occurred 10 times, increasing the projected level of noise resulting 

from nighttime events to ensure that the significance of the impacts is not 

understated. 

Further, in response to the concerns raised in this comment, SANDAG calculated Lmax

passby levels for the project at the Sheraton Hotel location. Measured existing Lmax

levels at the hotel ranged between 55 and 84 dBA over the course of a day at two 

locations on the property. With incorporation of the sound wall, Trolley passbys are 

projected to result in Lmax levels between 63 dBA at ground level and 68 dBA at the 
Volume 3 – Comments and Responses

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Bartell Hotels (Sheraton Hotel) - 

Dawe, Jim, Attorney - ID232 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 521 

Com ID Response

third floor of the hotel. These Lmax levels are well within the range of daytime and 

nighttime noise events, such as truck passbys on La Jolla Village Drive and I-5, that 

are currently experienced at the hotel. As such, single event noise from Trolley 

passbys is anticipated to be within the same range experienced in the existing sound 

environment and is not expected not to alter the current sleeping environment at the 

hotel. This supplemental information is attached to the end of this response.

11 The Draft SEIS/SEIR provides a general qualitative assessment of the expected 

noise and vibration effects that will occur throughout the corridor during construction 

based on experience with other transit projects. The exact methods of construction 

may vary at different sites, and an important part of the assessment of construction 

impacts is to identify the noise and vibration control measures that will be required by 

the contractor when appropriate. These project and mitigation measures are 

described in Chapter 4.0, Section 4.17.3.2 under the heading "Noise and Vibration 

Impacts" of the Final SEIS/SEIR and in Chapter 6.0, Section 6.17 of the Mid-Coast 

Corridor Transit Project Construction Impacts Technical Report. 

Nighttime construction is not planned adjacent to the Sheraton Hotel, and SANDAG 

will continue to use its best efforts to avoid nighttime work near the hotel. Nighttime 

construction is anticipated near the Sheraton Hotel for a limited number of nights for 

safety reasons to cross freeway ramps and at La Jolla Village Drive. 

Socioeconomic and fiscal impacts of the Mid-Coast Corridor Transit Project are 

addressed in Chapter 4.0, Section 4.3.3.2 of the Draft SEIS/SEIR, which provides that 

compensation for property acquisitions will be in accordance with the Federal Uniform 

Relocation Assistance and Real Property Acquisition Policies Act of 1970, as amended, 

the California Relocation Assistance Act of 1970, as amended, and SANDAG Board of 

Directors’ Policy No. 021. To the extent the commenter asserts an additional right to 

recover damages, the comment goes beyond the scope of the Draft SEIS/SEIR.

12 For purposes of assessing visual and aesthetic impacts, the guidelines in the Visual 

Impact Assessment for Highway Projects (FHWA, 1988) were used, which is 

applicable to many types of transportation projects. Impacts are described in Chapter 

4.0, Section 4.4 of the Draft SEIS/SEIR, with further detail provided in the Mid-Coast 

Corridor Transit Project Visual Impacts Technical Report. The assessment 

methodology included identifying impacts to scenic views, public view corridors, and 

scenic resources, and uses the approach of evaluating impacts at representative “key 

views” (refer to Chapter 3.0 in the technical report). Chapter 4.0, Section 4.4.3.2 of 

the Draft SEIS/SEIR identifies several visual impacts in the University community; 

however, as identified in Chapter 4.0, Section 4.4.5.2 of the Draft SEIS/SEIR, all 

impacts from the Build Alternative can be mitigated to a level below significance. 

Additional detail, including the assessment of key views, is included in the Visual 

Impacts Technical Report. The Sheraton Hotel is on the boundary of the La Jolla 

Village and Medical landscape units discussed in Chapter 4.0, Section 4.2.2 of the 

technical report. 
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Bartell Hotels (Sheraton Hotel) - 

Dawe, Jim, Attorney - ID232 

MID-COAST CORRIDOR TRANSIT PROJECT 

522 September 2014 

Com ID Response

In response to this comment, SANDAG provided additional information to Bartell 

Hotels regarding the sound wall to be located on the aerial guideway, such as the 

conceptual visual simulations of the aerial structure as seen from the Sheraton Hotel 

property shown in Figures 3 and 4, below (the locations of the views used for the 

simulations are shown in Figure 1). The simulations are still conceptual in nature 

because at the current level of design, only the size and location of the sound wall 

have been determined. However, the size and location of the sound wall are 

designed to meet the noise-reduction levels described in the Final SEIS/SEIR. 

Additional visual simulations provided to representatives of Bartell Hotels are 

provided at the end of this response. 

Figure 3. View 1 Existing Conditions and Visual Simulation

13 Figure 4. View 2 Existing Conditions and Visual Simulation 

EXISTING SIMULATION 

EXISTING SIMULATION 
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Bartell Hotels (Sheraton Hotel) - 

Dawe, Jim, Attorney - ID232 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 523 

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14 The project is fully consistent with the City of San Diego General Plan and University 

Community Plan, as both anticipate development of the Mid-Coast Corridor Transit 

Project in the City of San Diego. The Mid-Coast Corridor Transit Project Land Use 

Impacts Technical Report provides additional detail. The Urban Design Element of 

the University Community Plan (page 85 of the plan) discusses linkages (auto, 

pedestrian, bicycle, and transit). As stated on page 29 of the plan, "[urban design] 

policies will be used to guide the form of urban growth in the community by providing 

the basis for reviewing proposed projects," which is important because when the plan 

was approved in 1986 it is noted that "there is little vacant land located within the 

community boundaries." The plan goes on to state that "the objectives and 

recommendations included in this element will apply to all new developments, 

additions and amendments to previously approved special permits." Page 84 of the 

plan states, "the Urban Design Element is concerned with the character of 

development abutting the proposed LRT right-of-way as well as the functional and 

design components of transit stops." As the Sheraton Hotel was developed prior to 

implementation of the LRT project and will not link directly (have direct station access) 

to the LRT, the urban design objective in the community plan does not apply. 

Specifically, consistency with the objective applies to future commercial, residential, 

and educational land use development supporting transit linkages, where possible—

not to the completion of the LRT project itself. 

As noted on page 2 of the plan, "the [University Community] Plan is not an isolated 

document; rather, it represents a refinement of citywide goals contained in the City's 

Progress Guide and General Plan and earlier community plans." Additionally, it 

states, “with respect to community planning areas, the General Plan establishes a 

framework for the development of more specific community plans by identifying and 

locating those facilities that possess citywide or inter-community importance." The 

City of San Diego General Plan was updated to include the "Reasonably Expected" 

transit network in the 2030 RTP, which includes the 2003 LPA alignment for the 

project. An update to the University Community Plan, to include an updated project 

alignment, should follow after a notice of determination is filed on the project. The 

City of San Diego is responsible for updating the University Community Plan. 
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Businesses 

Bartell Hotels (Sheraton Hotel) - 

Dawe, Jim, Attorney - ID232 

MID-COAST CORRIDOR TRANSIT PROJECT 

524 September 2014 
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Bartell 

Da

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September 2014 
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Bartell Hotels (Sheraton Hotel) - 

Dawe, Jim, Attorney - ID232 

MID-COAST CORRIDOR TRANSIT PROJECT 

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Dawe, Jim, Attorney - ID232 

MID-COAST CORRIDOR TRANSIT PROJECT 

528 September 2014 
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Dawe, Jim, Attorney - ID232 

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536 September 2014 
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Bartell Hotels (Sheraton Hotel) - 

Dawe, Jim, Attorney - ID232 

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Bartell Hotels (Sheraton Hotel) - 

Dawe, Jim, Attorney - ID232 

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540 September 2014 
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Dawe, Jim, Attorney - ID232 

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Dawe, Jim, Attorney - ID232 

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542 September 2014 
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Dawe, Jim, Attorney - ID232 

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544 
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Dawe, Jim, Attorney - ID232 

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MID-COAST CORRIDOR TRANSIT PROJECT 

546 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 547 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

548 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 549 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

550 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 551 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

552 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 553 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

554 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 555 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

556 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 557 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

558 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 559 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

560 September 2014 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 561 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

562 September 2014 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 563 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

564 September 2014 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 565 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

566 September 2014 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 567 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

568 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 569 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

570 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 571 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

572 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 573 
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Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

574 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 575 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

576 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 577 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

578 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 579 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

580 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 581 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

582 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 583 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

584 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 585 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

586 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 587 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

588 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 589 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

590 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 591 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

592 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 593 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

594 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 595 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

596 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 597 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

598 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 599 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

600 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 601 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

602 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 603 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

604 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 605 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

606 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 607 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

608 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 609 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

610 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 611 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

612 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 613 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

614 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 615 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

616 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 617 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

618 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 619 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

620 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 621 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

622 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 623 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

624 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 625 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

626 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 627 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

628 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 629 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

630 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 631 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

632 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 633 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

634 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 635 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

636 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 637 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

638 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 639 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

640 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 641 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

642 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 643 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

644 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 645 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

646 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 647 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

648 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 649 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

650 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 651 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

652 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 653 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

654 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 655 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

656 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 657 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

658 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 659 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

660 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 661 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

662 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 663 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

664 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 665 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

666 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 667 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

668 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 669 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

670 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 671 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

672 September 2014 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 673 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

674 September 2014 

Submission ID231 Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon Gardens, 

LLC La Jolla Canyon) Schulman Richard

Com ID Response

1 Consideration of the Monte Verde site is included in the Draft SEIS/SEIR. 

Specifically, it is included in the land use assessment, long-term and cumulative 

traffic analyses, and cumulative construction analysis conducted for the project. The 

analyses included a review of City Community Plans and the General Plan, which 

included the Monte Verde Project. Since the close of the Draft SEIS/SEIR comment 

period, SANDAG has coordinated with representatives from Monte Verde based on 

comments received on the Draft SEIS/SEIR and has removed the previously 

proposed construction staging area from the Monte Verde development site. 

SANDAG will continue to coordinate with Monte Verde and the City of San Diego 

throughout the final design process concerning any potential development and/or 

entitlement constraints on the property, if any, associated with the Mid-Coast Corridor 

Transit Project.

2 Existing physical conditions at the time the Notice of Preparation was issued is only 

one of the environmental baselines considered. The SEIS/SEIR also includes 2030 

conditions in its cumulative analysis, which includes the Monte Verde Project. Refer 

to the response to Comment 1 regarding the inclusion of Monte Verde in the analyses 

for the Draft SEIS/SEIR.

3 The land use analysis considers the currently adopted version of the General Plan. 

The General Plan was comprehensively updated in 2008 and was finalized after the 

approval of the Monte Verde Project. The analysis also considers the University 

Community Plan, which was revised in 2011 and includes the Monte Verde Project. 

Similarly, the cumulative analysis of land use impacts is based on the General Plan, 

which includes Monte Verde. The cumulative impacts are discussed in Chapter 4.0, 

Section 4.19 of the Draft SEIS/SEIR. As described in this section, the Mid-Coast 

Corridor Transit Project will not cause or contribute to an adverse or significant 

cumulative land use impact and will not result in a cumulatively considerable land use 

impact under CEQA. Refer to the response to Comment 4 regarding the traffic 

analysis. 

As stated in Chapter 2.0, Section 2.1 of the Mid-Coast Corridor Transit Project Travel 

Forecasting Report, future forecasts (2010 and 2030) made by the SANDAG Series 11 

model are based on the community plans adopted at the time the model was developed. 

For the Series 11 model, the City of San Diego General Plan and the San Diego County 

General Plan were used for model development. The Monte Verde Project was included 

in the General Plan and thus the Series 11 model. As a result, the ridership forecasts for 

the project include the Monte Verde Project.
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 675 

Com ID Response

4 As noted in response to Comment 1, the long-term and cumulative traffic analyses 

included the Monte Verde Project. The methodology for the future (2030) traffic 

analysis is documented in Chapter 2.0, Section 2.3.2.1 of the Mid-Coast Corridor 

Transit Project Transportation Impacts and Mitigation Report. The traffic volumes 

used at Genesee Avenue and Esplanade Court/UTC Driveway for the p.m. peak hour 

(when traffic volumes are highest) are within 2 percent of the traffic volumes shown in 

the Revised Final Environmental Impact Report for the Proposed Monte Verde (City 

of San Diego, 2007). Further, the project will not alter ingress/egress of Monte Verde 

to Esplanade Court. 

The Series 11 Travel Demand Forecasting Model showed a demand for 260 transit 

parking spaces at the UTC Transit Center, considering the forecast future demand. 

As the demand for transit parking is being met at the station, no spillover parking to 

adjacent areas is anticipated. 

Chapter 4.0, Section 4.19.3.2 of the Draft SEIS/SEIR and Chapter 5.0, Section 5.2 of 

the Mid-Coast Corridor Transit Project Noise and Vibration Impacts Technical Report

address cumulative impacts of the Mid-Coast Transit Corridor Project related to 

noise, including consideration of other projects in the corridor. 

The cumulative construction analysis for the Mid-Coast Corridor Transit Project 

considered the Monte Verde Project. Chapter 5.0, Table 5-29 of the Mid-Coast 

Corridor Transit Project Construction Impacts Technical Report presents the major 

foreseeable projects that are anticipated to be under construction simultaneously with 

the Mid-Coast Corridor Transit Project. The Monte Verde Project (No. 3) is included 

on that list of private development projects. 

The visual simulations in Chapter 5.0, Figure 5-17 and Figure 5-20 of the Mid-Coast 

Corridor Transit Project Visual Impacts Technical Report illustrate the appearance of 

the aerial structure within the existing right-of-way on Genesee Avenue. Details of 

future surrounding development (such as the Westfield UTC shopping center 

expansion and the Monte Verde Project) were unavailable. Therefore the simulations 

focused on correctly showing the project, which is sufficient for purposes of the visual 

analysis. These views are representative of the visual impacts of the aerial structure 

in this area, particularly along Genesee Avenue. With mitigation, the project will not 

result in adverse or significant visual impacts on Genesee Avenue in the vicinity of 

Executive Drive and the Westfield UTC shopping center.

5 As noted in response to Comment 1, subsequent to the issuance of the Draft SEIS/SEIR, 

in coordination with representatives from Monte Verde, SANDAG removed the proposed 

construction staging area from the Monte Verde development site. Further, coordination 

will continue throughout the final design process and construction concerning any 

potential site development and/or entitlement constraints, if any, caused by the MidCoast Corridor Transit Project on the Monte Verde Project. 
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

676 September 2014 

Com ID Response

While no staging area will be placed on the Monte Verde development site, to the 

extent the project necessitates the acquisition of private property, compensation will 

be provided, as appropriate, consistent with the Federal Uniform Relocation 

Assistance and Real Property Acquisition Policies Act of 1970, as amended, the 

California Relocation Assistance Act of 1970, as amended, and SANDAG Board of 

Directors Policy No. 021. To the extent the commenter asserts an additional right to 

recover damages, the comment goes beyond the scope of the Draft SEIS/SEIR. 

6 CAD files showing the Draft SEIS/SEIR project alignment, along with projected 

temporary easements (including acreage), street improvements, and right-of-way 

were provided to Costa Verde Hotel’s engineer, John Leppert, on August 1, 2013. As 

project design is developed further, coordination will continue with representatives of 

Monte Verde.

7 The vesting tentative map enclosed with your letter will be part of the record of 

proceedings for the Draft SEIS/SEIR. SANDAG is coordinating with representatives 

of La Jolla Canyon Gardens regarding the future expansion of the La Jolla Canyon 

Apartments. 

8 The noise analysis was conducted in accordance with FTA guidelines as documented 

in the Transit Noise and Vibration Impact Assessment Guidance Manual (FTA, 2006) 

and addresses FTA and CEQA requirements. Applicable FTA criteria specify that 

noise impacts and mitigation be based on an analysis of a 24-hour weighted average 

for residential land uses including the proposed transit noise source to evaluate 

cumulative exposure rather than single event levels. The analysis includes 

comparison of existing noise levels with the projected noise of the Trolley operations 

over a 24-hour period. This includes the addition of a 10 dBA penalty for Trolley 

operations that occur between 10 p.m. and 7:00 a.m. The effect of this penalty is that 

when calculating the average project noise, any event that occurs during nighttime is 

deemed to have occurred 10 times, increasing the projected level of noise resulting 

from nighttime events to ensure that the significance of the impacts is not 

understated. 

The maximum noise level of Trolley passbys is comparable in sound level to existing 

passby noise of vehicles and trucks, associated with a six-lane arterial roadway such 

as Genesee Avenue. As such, the noise from Trolley passbys is not anticipated to be 

any higher than the existing sound environment, and is not expected to disrupt sleep.

9 As stated in Chapter 4.0, Section 4.17.3.2 of the Final SEIS/SEIR under the heading 

“Noise and Vibration Impacts,” there will be periods of nighttime construction work 

along Genesee Avenue during the multi-year construction effort. It is anticipated that 

nighttime construction would exceed the noise level limit of 45 dBA established by the 

City of San Diego during some periods of structural erection, thus requiring that a 

noise permit be acquired for that construction activity. The project and mitigation 
Volume 3 – Comments and Responses

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 677 

Com ID Response

measures included in the Final SEIS/SEIR will minimize those impacts to the extent 

feasible. Chapter 4.0, Section 4.17.3.2 of the Final SEIS/SEIR describes these 

measures under the heading “Noise and Vibration Impacts” and as Mitigation 

Measures CON1 and CON2. 

Mitigation Measure CON1 requires that the contractor develop and implement a 

Noise Control Plan, which would demonstrate how the contractor would reduce noise 

levels near sensitive noise receptors consistent with the city’s Noise Ordinance. 

Sensitive receivers include residences, hotels, schools, churches, temples, and 

similar facilities where either outdoor or indoor activities would be sensitive to noise 

levels. The Noise Control Plan would include noise attenuation features as 

necessary, such as installing temporary sound walls and mufflers, and locating noisy 

equipment away from sensitive land uses. It would also consider alternative 

construction methods when relevant. 

Mitigation Measure CON2 addresses nighttime noise impacts to sensitive receivers 

along Genesee Avenue, on Charmant Drive, and at the northeast corner of Cape La 

Jolla Gardens housing complex adjacent to I-5. This mitigation measure includes the 

use of noise-reducing curtains or noise-masking machines where appropriate and 

approved by the occupant, and provides for temporary lodging in an approved hotel 

for affected residents if, after implementation of noise-reducing measures, nighttime 

construction noise is predicted to exceed the ambient noise levels for that area by 5 

dBA. The impact determination and approach to mitigation are consistent with CEQA 

(as well as the City of San Diego noise permit process).

10 Chapter 4.0, Section 4.7.3.2 of the Draft SEIS/SEIR identified a vibration impact at 

the La Jolla Canyon Gardens Apartments (Cluster 88) that would occur with the 

Genesee Avenue Design Option; the Genesee Avenue Design Option has been 

eliminated from the Refined Build Alternative analyzed in the Final SEIS/SEIR, and 

vibration impacts at La Jolla Canyon Gardens are not anticipated. 

11 The Final SEIS/SEIR analyzes the project’s impacts, including potential property 

acquisitions, that may be necessitated by the project. As indicated in the Final 

SEIS/SEIR Plan Set, no displacement of existing residential development will occur 

with the project. Moreover, using the Construction Manager/General Contract 

contracting method, a Utilities Relocation Plan will be developed as part of project 

design that will identify all required utility relocations, temporary routing, and 

reconstruction. The plan will also include a construction approach to minimize 

disruption (refer to Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR under the 

heading “Utilities, Project Measures to Avoid or Minimize Impacts”). Coordination 

with representatives of La Jolla Canyon Gardens has occurred since the close of the 

Draft SEIS/SEIR comment period and will be ongoing through final design and 

construction in order to minimize construction impacts to the extent feasible.
Volume 3 – Comments and Responses 

Businesses 

Costa Verde Hotel, LLC (Monte Verde) and La Jolla Canyon, 

Gardens LLC (La Jolla Canyon) - 

Schulman, Richard - ID231 

MID-COAST CORRIDOR TRANSIT PROJECT 

678 September 2014 

Com ID Response

12 The SEIS/SEIR for the project meets the requirements of NEPA and CEQA. The 

comments on individual elements of the NEPA/CEQA analysis are addressed in 

response to each comment. As noted in response to Comment 5, to the extent the 

project necessitates the acquisition of private property, compensation will be 

provided, as appropriate, consistent with the Federal Uniform Relocation Assistance 

and Real Property Acquisition Policies Act of 1970, as amended, the California 

Relocation Assistance Act of 1970, as amended, and SANDAG Board of Directors 

Policy No. 021. To the extent the commenter asserts an additional right to recover 

damages, the comment goes beyond the scope of the Draft SEIS/SEIR.
Volume 3 – Comments and Responses

Businesses 

Gary Kent Team - 

Christy, Kyley, Realtor, Broker Associate; Certified Distressed Property Expert - ID185 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 679 

Gary Kent Team - 

Christy, Kyley, Realtor, Broker Associate; Certified Distressed 

Property Expert - ID185 

 
Volume 3 – Comments and Responses 

Businesses 

Gary Kent Team - 

Christy, Kyley, Realtor, Broker Associate; Certified Distressed Property Expert - ID185 

MID-COAST CORRIDOR TRANSIT PROJECT 

680 September 2014 

Submission ID185 Gary Kent Team Christy Kyley

Com ID Response

1 A response to the request for information regarding the Clairemont Drive Station was 

provided via e-mail on July 11, 2013. Refer to Master Response 4 for information 

regarding the Clairemont Drive Station. 

 
Volume 3 – Comments and Responses

Businesses 

Harbor Investments Co., LLC - 

Baker, Cynthia Polak - ID309 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 681 

Harbor Investments Co., LLC - 

Baker, Cynthia Polak - ID309 
Volume 3 – Comments and Responses 

Businesses 

Harbor Investments Co., LLC - 

Baker, Cynthia Polak - ID309 

MID-COAST CORRIDOR TRANSIT PROJECT 

682 September 2014 
Volume 3 – Comments and Responses

Businesses 

Harbor Investments Co., LLC - 

Baker, Cynthia Polak - ID309 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 683 

Submission ID309 Harbor Investments, LLC Baker Cynthia Polak

Com ID Response

1 The signalized intersection at Vega Street and West Morena Boulevard will remain. 

Access to the shopping center parking lot via this intersection will be available 

during construction and operation of the project. 

Access through the existing signalized intersection at Vega Street and West 

Morena Boulevard will not be modified by the project (refer to Sheet 146 in the Final 

SEIS/SEIR Plan Set). This intersection will continue to provide access to the center 

for the general public accessing the center by car in all directions. Access to the 

shopping center parking lot via this intersection will be available during construction 

of the project. Further, the project will not create unsafe access to the shopping 

center or Tecolote Road Station in any direction of travel. 

Travel patterns to the shopping center will not change as a result of the project. 

The traffic analysis was conducted for the project for intersections adjacent to the 

Tecolote Road Station, as documented in the Mid-Coast Corridor Transit Project 

Transportation Impacts and Mitigation Report. That analysis concluded that there 

will not be adverse or significant impacts resulting from the project. 

2 Transit parking will be clearly demarcated to separate it from the surrounding 

commercial parking. Signage will be provided, and the perimeter of the parking will 

be delineated by raised curbs, landscaping, fencing, or a combination thereof. 

Spillover parking from transit patrons is not anticipated, regardless of the time of the 

year. The parking supply is based on the forecasted 2030 demand for parking at 

this location. As the demand for parking at the station will be accommodated, 

spillover parking is not anticipated. Refer to Chapter 4.0, Section 4.5.1 of the 

Transportation Impacts and Mitigation Report for additional information on how 

parking capacities were determined.

3 The project includes extensive safety and security measures for transit stations, 

including closed-circuit security cameras, roving code enforcement, and a transit 

security force. Safety and security issues were addressed in the Mid-Coast 

Corridor Transit Project Safety and Security Impacts Technical Report and 

summarized in Chapter 4.0, Section 4.13 of the Draft SEIS/SEIR. The safety and 

security analysis concluded that there will be no adverse or significant safety or 

security impacts under the Build Alternative. Master Response 11 provides 

additional information with regard to security at stations and crime in the 

surrounding areas.

 
Volume 3 – Comments and Responses 

Businesses 

Harbor Investments Co., LLC - 

Baker, Cynthia Polak - ID336 

MID-COAST CORRIDOR TRANSIT PROJECT 

684 September 2014 

Harbor Investments Co., LLC - 

Baker, Cynthia Polak - ID336 
Volume 3 – Comments and Responses

Businesses 

Harbor Investments Co., LLC - 

Baker, Cynthia Polak - ID336 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 685 
Volume 3 – Comments and Responses 

Businesses 

Harbor Investments Co., LLC - 

Baker, Cynthia Polak - ID336 

MID-COAST CORRIDOR TRANSIT PROJECT 

686 September 2014 
Volume 3 – Comments and Responses

Businesses 

Harbor Investments Co., LLC - 

Baker, Cynthia Polak - ID336 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 687 

Submission ID336 Harbor Investments, LLC Baker Cynthia Polak

Com ID Response

1 The signalized intersection at Vega Street and West Morena Boulevard will remain. 

Access to the shopping center parking lot via Vega Street will be available during 

construction and operation of the project.

Access through the existing signalized intersection at Vega Street and West 

Morena Boulevard will not be modified by the project (refer to Sheet 146 in the Final 

SEIS/SEIR Plan Set). This intersection will continue to provide access to the 

shopping center for the general public accessing the shopping center by car in all 

directions. Access to the shopping center parking lot via this intersection will be 

available during construction of the project. Further, the project will not create 

unsafe access to the shopping center or the Tecolote Road Station in any direction 

of travel. 

Travel patterns to the shopping center will not change as a result of the project. 

The traffic analysis was conducted for the project for intersections adjacent to the 

Tecolote Road Station, as documented in the Mid-Coast Corridor Transit Project 

Transportation Impacts and Mitigation Report. That analysis concluded that there 

will not be adverse or significant impacts resulting from the project. 

2 Transit parking will be clearly demarcated to separate it from the surrounding 

commercial parking. Signage will be provided and the perimeter of the parking will 

be delineated by raised curbs, landscaping, fencing, or a combination thereof. 

Spillover parking from transit patrons is not anticipated, regardless of the time of the 

year. The parking supply is based on the forecasted 2030 demand for parking at 

this location. As the demand for parking at the station will be accommodated, 

spillover parking is not anticipated. Refer to Chapter 4.0, Section 4.5.1 of the 

Transportation Impacts and Mitigation Report for additional information on how 

parking capacities were determined.

3 The project includes extensive safety and security measures for transit stations, 

including closed-circuit security cameras, roving code enforcement, and a transit 

security force. Safety and security under the Build Alternative were documented in 

the Mid-Coast Corridor Transit Project Safety and Security Impacts Technical 

Report and summarized in Chapter 4.0, Section 4.13 of the Draft SEIS/SEIR. The 

safety and security analysis concluded that there will be no adverse or significant 

safety or security impacts under the Build Alternative. Master Response 11 

provides additional information with regard to security at stations and crime in the 

surrounding areas. 

Wetlands have not been identified in the vicinity of the Tecolote Road Station. 

Consequently, there will be no impacts to wetlands in this area. 

 
Volume 3 – Comments and Responses 

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

688 September 2014 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 
Volume 3 – Comments and Responses

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 689 
Volume 3 – Comments and Responses 

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

690 September 2014 
Volume 3 – Comments and Responses

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 691 
Volume 3 – Comments and Responses 

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

692 September 2014 
Volume 3 – Comments and Responses

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 693 

Submission ID225 La Jolla Village Square Blick C. Samuel

Com ID Response

1 This comment letter is included in the record of proceedings for the Draft SEIS/SEIR. 

Responses to the general issues raised in this comment are set forth in the individual 

responses to comments below. 

2 The commenter may participate in future hearings and proceedings related to the MidCoast Corridor Transit Project and provide comments in the same manner as other 

members of the public. For purposes of CEQA compliance, written responses are 

limited to comments submitted during the noticed public comment period for the Draft 

SEIS/SEIR. SANDAG will continue to coordinate and respond to the property owner 

throughout the project. 

3 The comment expressing concern with the capacity of the park-and-ride facility at the 

Nobel Drive Station has been noted and will be part of the record of proceedings for the 

Draft SEIS/SEIR. Parking demand at each station was calculated based on results from 

the SANDAG Series 11 Travel Demand Forecasting Model. The process for determining 

the park-and-ride capacities is presented in Chapter 4.0, Section 4.5.1 of the Mid-Coast 

Corridor Transit Project Transportation Impacts and Mitigation Report. The model results 

have been reviewed and approved by FTA for use for this project. As identified in 

Chapter 3.0, Table 3-28 of the Draft SEIS/SEIR, transit park-and-ride demand at the 

Nobel Drive Station is estimated at 258 spaces. The 260 parking spaces that will be 

provided for this station will be sufficient to meet the forecast demand in 2030, and no 

spillover parking impact to the shopping center is expected. Additional information on the 

park-and-ride capacities is provided at the end of this response. This information also 

was provided to representatives from the shopping center on March 21, 2014 and July 3, 

2014 as part of ongoing stakeholder coordination.

4 As shown in the Final SEIS/SEIR Plan Set (Sheets 322 through 329P), a parking 

structure will be provided at this location to provide for transit parking as well as 

replacement parking for spaces removed from the shopping center as a result of 

construction of the parking garage and other parking spaces affected as a result of 

project features.

5 As noted in response to Comment 4, SANDAG is providing parking spaces that have 

been determined to be necessary based on impacts from the project and to 

accommodate projected transit parking demand. Due to the fact this is a public 

project that involves public dollars, SANDAG cannot expend public funds to provide 

additional parking for any private entity beyond the transit parking required for the 

project and the replacement of spaces removed by the project, which are impacts 

directly related to the project. As noted in response to Comment 3, the number of 

necessary parking spaces for transit patrons has been calculated using the SANDAG 

Series 11 Travel Demand Forecasting Model, which has been reviewed and 

approved by FTA. 
Volume 3 – Comments and Responses 

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

694 September 2014 

Com ID Response

6 The project will increase the number of people accessing the shopping center. The 

additional patrons can be expected to use the shopping center in the same manner 

as existing users for which ongoing maintenance is required. The comment does not 

provide any evidence that the additional patrons will cause adverse or significant 

physical impacts. To the extent the comment asserts a right to indemnification or to 

otherwise expand the legal responsibilities of SANDAG or MTS with regard to 

maintenance, it goes beyond the scope of the Draft SEIS/SEIR. 

7 The project includes extensive safety and security measures for transit stations, 

including closed-circuit security cameras, roving code enforcement, and a transit 

security force (see Chapter 4.0, Section 4.13.3.2 of the Draft SEIS/SEIR). The 

comment does not provide any evidence that the security measures described will be 

inadequate. To the extent the comment asserts a right to indemnification or to 

otherwise expand the legal responsibilities of SANDAG or MTS with regard to 

security, it goes beyond the scope of the Draft SEIS/SEIR. 

8 The design of circulation within the shopping center property has been coordinated 

with representatives of La Jolla Village Square shopping center, and this coordination 

will continue to the extent feasible through the design and construction phases of the 

project. As described in the Final SEIS/SEIR, the project will maintain all access 

points and driveways to the shopping center during construction and operation of the 

project. 

Project construction activities within the shopping center will be conducted in 

accordance with a Construction Management Plan that will be developed by the 

Construction Manager/General Contractor and approved by SANDAG. 

Implementation of the Construction Management Plan and construction phasing will 

be coordinated with representatives from the shopping center to minimize temporary 

construction impacts to the shopping center. Measures to minimize the impacts to 

businesses during construction are described in Chapter 4.0, Section 4.17.3.2 of the 

Draft SEIS/SEIR under the heading “Socioeconomic and Fiscal Impacts.” Chapter 

3.0, Section 3.4.7.4 of the Final SEIS/SEIR states that after the parking structure at 

the Nobel Drive Station is constructed, parking spaces in the structure will be made 

available to shopping center patrons during later phases of construction, which will 

temporarily replace the parking spaces lost during the time when the shopping center 

parking area adjacent to the structure is being reconstructed. This measure is similar 

to the one provided in the Draft SEIS/SEIR. However, the Draft and Final 

SEIS/SEIRs acknowledge that temporary impacts to parking at La Jolla Village 

Square during construction would remain significant despite this project measure if 

temporary replacement parking is not available. Parking impacts during construction, 

and specific measures to avoid or minimize impacts, are described in Chapter 3.0, 

Section 3.4.7.4 of the Final SEIS/SEIR.
Volume 3 – Comments and Responses

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 695 

Com ID Response

9 The comment regarding the existence of Conditions, Covenants & Restrictions and 

terms and conditions of leases has been noted and will be part of the record of 

proceedings for the Draft SEIS/SEIR. The comment does not point out any specific 

conditions, covenant, or lease that would be violated by the project. To the extent the 

comment raises a concern regarding any necessary property acquisition associated 

with the project, socioeconomic and fiscal impacts are addressed in Chapter 4.0, 

Section 4.3.3.2 of the Draft SEIS/SEIR, which provides that compensation for 

property acquisitions shall be in accordance with the Federal Uniform Relocation 

Assistance and Real Property Acquisition Policies Act of 1970, as amended, the 

California Relocation Assistance Act of 1970, as amended, and SANDAG's Board of 

Director's Policy No. 021. To the extent the commenter asserts an additional right to 

recover damages, the comment goes beyond the scope of the Draft SEIS/SEIR. 

10 To the extent the comment raises a concern regarding any necessary property 

acquisition associated with the project, such impacts will be addressed as described 

in the response to Comment 9. Costs associated with property acquisition are 

included in the capital cost estimate for the project, as presented in Chapter 6.0, 

Section 6.2.1 of the Draft SEIS/SEIR and in the Final SEIS/SEIR. 

Alternative designs were considered in coordination with representatives of the 

shopping center based on comments received on the Draft SEIS/SEIR. The changes 

to the design of the station and park-and-ride structure presented for the Refined 

Build Alternative in the Final SEIS/SEIR are the result of this coordination. To the 

extent feasible, coordination will continue with the shopping center throughout the 

design and construction of the project.

11 This comment letter is included in the record of proceedings for the Draft SEIS/SEIR. 

The commenter may participate in future hearings and proceedings related to the 

Mid-Coast Corridor Transit Project and provide comments in the same manner as 

other members of the public. However, for CEQA purposes written responses are 

limited to comments submitted during the noticed public comment period for the Draft 

SEIS/SEIR. As noted in response to Comment 3, SANDAG has included additional 

information related to the capacity of the park-and-ride facility at the Nobel Drive 

Station at the end of this response. SANDAG will continue to coordinate and 

respond to the property owner throughout the project.

12 Refer to the responses to Comments 2 and 11.
Volume 3 – Comments and Responses 

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

696 September 2014 
Volume 3 – Comments and Responses

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 697 
Volume 3 – Comments and Responses 

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

698 September 2014 
Volume 3 – Comments and Responses

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 699 
Volume 3 – Comments and Responses 

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

700 September 2014 
Volume 3 – Comments and Responses

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 701 
Volume 3 – Comments and Responses 

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

702 September 2014 
Volume 3 – Comments and Responses

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 703 
Volume 3 – Comments and Responses 

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

704 September 2014 
Volume 3 – Comments and Responses

Businesses 

La Jolla Square Village Square - 

Blick, C. Samuel, Esquire - ID225 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 705 
Volume 3 – Comments and Responses 

Businesses 

Morena Business Association - 

Weber, Kimberly - ID174 

MID-COAST CORRIDOR TRANSIT PROJECT 

706 September 2014 

Morena Business Association - 

Weber, Kimberly - ID174 
Volume 3 – Comments and Responses

Businesses 

Morena Business Association - 

Weber, Kimberly - ID174 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 707 

 
Volume 3 – Comments and Responses 

Businesses 

Morena Business Association - 

Weber, Kimberly - ID174 

MID-COAST CORRIDOR TRANSIT PROJECT 

708 September 2014 

Submission ID174 Morena Business Association Weber Kimberly

Com ID Response

1 Your comment requesting that the Tecolote Road Station name be changed to 

Morena District has been noted and will be part of the record of proceedings for the 

Draft SEIS/SEIR. The station names used in the Draft SEIS/SEIR represent the 

street or geographic location of the station. To avoid confusion, the station names 

used in the Draft SEIS/SEIR were also used in the Final SEIS/SEIR. 

The names used do not necessarily reflect the station names that will be used when 

the project begins operation. These names will be determined by MTS prior to the 

start of operation.

2 Your comment expressing support of the project and the easy access to hospitals has 

been noted and will be part of the record of proceedings for the Draft SEIS/SEIR. 

 
Volume 3 – Comments and Responses

Businesses 

Regency Centers Costa Verde Center - 

Chine, Jeffrey, Attorney - ID226 

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Submission ID226 Regency Centers (Costa Verde Center) Chine Jeffrey

Com ID Response

1 Detailed responses to the issues summarized in this comment are provided below.

2 On November 15, 2013, the SANDAG Board of Directors adopted the Refined Build 

Alternative, which includes center columns on Genesee Avenue, and eliminated the 

Genesee Avenue Design Option (i.e., straddle bents on Genesee Avenue) from 

consideration in the Final SEIS/SEIR. Although nearly all straddle bents have been 

eliminated in the final design, one is required to support the Executive Drive Station, 

and one is required at the intersection of Regents Road and Genesee Avenue.

3 SANDAG has conducted extensive outreach during the development of the project 

and will continue to reach out to stakeholders, including Costa Verde Center, during 

the design and construction phases.

4 The Draft SEIS/SEIR included extensive detail about the project. Conceptual design 

plans were provided in the Draft SEIS/SEIR Plan Set (available at 

www.sandag.org/midcoast). These plans provided elevations and footprints for the 

entire project corridor, including detailed station plans and right-of-way impacts. Refer 

to Master Response 1 for information regarding station design. The level of design 

completed for the project is consistent with the requirements of NEPA and CEQA and 

is sufficient to determine the significance of impacts to the environment and suitable 

mitigation measures. 

The detailed responses below address the visual analysis and mitigation measure 

issues summarized in this comment.

5 The SEIS/SEIR and the documents they update, as discussed in Chapter 2.0, Section 

2.1 of the Final SEIS/SEIR and highlighted below, include a comprehensive and 

reasonable range of alternatives. The Mid-Coast Corridor Alternatives Analysis/Draft 

Environmental Impact Statement/Draft Environmental Impact Report (MTDB, 1995b), 

Final Environmental Impact Report for the Mid-Coast Corridor (MTDB, 1995b), and the 

Mid-Coast Corridor Project Balboa Extension and Nobel Drive Coaster Station Final 

Environmental Impact Statement (MTDB, 2001) included the following alternatives: 

1. No Build 

2. Transportation System Management 

3. Transportation System Management/Commuter Rail 

4. Commuter Rail Tunnel 

5. High Occupancy Vehicle (HOV) Lanes 

6. LRT—Genesee Alternative 

7. LRT—I-5 Alternative 

The Transportation System Management and Transportation System Management/ 

Commuter Rail Alternatives were rejected because they were least effective at 
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meeting project objectives and cost. The Commuter Rail Tunnel Alternative was 

deemed infeasible due to cost and the difficulty in venting diesel fumes. The HOV 

Lanes Alternative was adopted along with an LRT Alternative. The HOV Lanes 

Alternative was then separated from the Mid-Coast Corridor Transit Project, and this 

project element will be constructed by Caltrans. Finally, the LRT Genesee Alternative 

was rejected for, among other reasons, its impact on Rose Canyon. These 

alternatives were analyzed in the EIR certified in 1995 and the EIS for which a Record 

of Decision was issued in 2001. The SEIS/SEIR adds to the alternative analysis 

described above by considering an updated version of the LRT I-5 Alignment (the 

current Refined Build Alternative) and an updated No-Build Alternative. In summary, 

the alternatives considered in the prior environmental review and SEIS/SEIR included 

a broad range of alternative mode and alignment options to serve the transit needs of 

the Mid-Coast Corridor and constitute a reasonable range of alternatives in 

compliance with NEPA and CEQA. 

In addition, after completion of the 1995 and 2001 environmental process and prior to 

initiation of the Draft SEIS/SEIR, a total of 13 additional alternatives were evaluated 

and considered: i) a new TSM alternative, ii) seven LRT alternatives, iii) four BRT 

alternatives, and iv) a commuter rail alternative. Some alternatives were deemed 

infeasible prior to initiation of scoping for the Draft SEIS/SEIR, and others were carried 

through the scoping process and resulted in some further refinement of the Build 

Alternative. The evaluation of alternatives considered during this phase is presented 

in the Mid-Coast Corridor Transit Project Comparative Evaluation of Alternatives 

Report. Chapter 3.0 and Chapter 4.0 of this report include information related to the 

identification and screening of initial alternatives and the conceptual alternatives 

considered; Chapter 6.0 presents the recommendation of alternatives to carry forward 

into scoping. The information is summarized in Chapter 2.0, Section 2.1.1 and Table 

2-1 of the Draft SEIS/SEIR.

6 The Draft SEIS/SEIR is not a tiered CEQA document. It is a supplemental/subsequent 

document to the EIS and EIR previously prepared for the project. The Draft 

SEIS/SEIR updates the following documents: the Mid-Coast Corridor Alternatives 

Analysis/Draft Environmental Impact Statement/Draft Environmental Impact Report

(MTDB, 1995b), Final Environmental Impact Report for the Mid-Coast Corridor (MTDB,

1995b), and the Mid-Coast Corridor Project Balboa Extension and Nobel Drive 

Coaster Station Final Environmental Impact Statement (MTDB, 2001). Alternatives 

considered in the 1995 and 2001 documents are summarized in the prior response to 

Comment 5. Chapter 1.0, Section 1.1 and Chapter 2.0, Section 2.1.1 of the Draft 

SEIS/SEIR present the project background, including a description of the prior 

environmental documents (the 1995 AA/DEIS/DEIR, the 1995 FEIR, and the 2001 

FEIS) that it supplements. 

The 1995 and 2001 environmental documents and the Comparative Evaluation of 

Alternatives Report are posted on the project website.
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7 The Planned Development Permit issues identified by the commenter are addressed 

in responses to Comments 10 through 18.

8 Chapter 3.0, Table 3-29 of the Draft SEIS/SEIR presents the locations where the 

project will result in the permanent loss of parking spaces. It is not anticipated that the 

project will result in any permanent loss of parking from the Costa Verde Center or the 

adjacent Monte Verde development site. These results for the Costa Verde Center 

and Monte Verde development site remain unchanged in the Final SEIS/SEIR.

9 As described in more detail in response to Comment 10, the 260 transit parking 

spaces provided at the Westfield UTC shopping center will be sufficient to meet the 

forecasted demand for parking, both under existing and future (2030) conditions. 

Transit users are not likely to park in private business spaces because there will be 

sufficient transit parking spaces closer to the transit station. For these reasons, 

spillover parking to adjacent areas is not anticipated. Refer to the response to 

Comment 10 regarding forecasted parking demand.

10 Parking demand at each station is calculated based on results from the SANDAG 

Series 11 Travel Demand Forecasting Model. The model results for this project have 

been reviewed and approved by FTA. Chapter 4.0, Section 4.5.1 of the Mid-Coast 

Corridor Transit Project Transportation Impacts and Mitigation Report documents the 

process by which park-and-ride capacity was determined. These parking spaces will 

be reserved for transit use only.

11 SANDAG is coordinating directly with representatives from the Westfield UTC 

shopping center regarding the provision of transit parking. SANDAG anticipates 

securing the necessary dedicated transit parking prior to operation. Therefore, the 

supply of transit parking is not dependent on the shopping center's development plans. 

Refer to Chapter 3.0, Section 3.4.4.2 of the Final SEIS/SEIR for additional information.

12 Subsequent to the issuance of the Draft SEIS/SEIR, and in response to comments, 

SANDAG eliminated the proposed construction staging areas at the Monte Verde 

development site and at the Westfield UTC shopping center. As discussed in Chapter 

3.0, Section 3.4.7.4 of the Final SEIS/SEIR, it is anticipated that there will be some 

temporary impact to approximately 16 parking spaces at the Costa Verde Center for a 

temporary construction easement (Chapter 3.0, Table 3-36 of the Final SEIS/SEIR); 

this is a substantial reduction compared to parking losses shown in the Draft 

SEIS/SEIR (185 spaces, as referenced in the comment). Further, as stated in this 

section under the heading "Construction Worker Parking," because parking for 

construction workers is generally provided in designated areas where either an 

easement or right-of-use has been obtained, or through leases of parking areas 

negotiated with property owners, construction-worker parking is not expected to have 

a temporary adverse impact during construction.
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13 Refer to the response to Comment 12.

14 Eligibility for inclusion in the Transit Overlay Zone is an issue controlled by the City of 

San Diego.

15 The construction staging area previously proposed on the Monte Verde development 

site has been eliminated, as reflected in the Final SEIS/SEIR Plan Set. Refer to the 

response to Comment 12 for additional information on parking during construction.

16 In conjunction with affected property owners, SANDAG and its contractors will develop 

and implement a Transportation Management Plan. Construction phasing and 

scheduling will be conducted in a manner that minimizes, to the extent feasible, 

impacts to adjacent properties. Access to properties during construction will be 

determined in coordination with property owners. Contractors will be required to install 

temporary signage for businesses open during the construction period and signage to 

direct vehicles to parking and/or access to pedestrian access routes. Detours will be 

shown in the Transportation Management Plan developed for the project. During 

construction, detour routes using the adjacent intersections and roadways will be 

provided. As described in the footnote to Chapter 3.0, Table 3-33 of the Draft 

SEIS/SEIR, closures and vehicular movement prohibitions at these intersections will 

be phased such that adjacent major intersections will not be affected concurrently. 

SANDAG has selected a contractor using the Construction Manager/General 

Contractor construction delivery method, which allows SANDAG to work with the 

contractor during the pre-construction phase of the project to finalize such plans in 

coordination with property owners and businesses. 

As discussed in Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR, businesses 

affected by temporary encroachments would be compensated, as appropriate, 

consistent with the Federal Uniform Relocation Assistance and Real Property 

Acquisition Policies Act of 1970, as amended, the California Relocation Assistance Act 

of 1970, as amended, and SANDAG Board of Directors Policy No. 021. To the extent 

the commenter asserts an additional right to recover damages, the comment goes 

beyond the scope of the Draft SEIS/SEIR.

17 Trolley operating hours will be established by MTS prior to opening of the project and 

are anticipated to be similar to those of the existing Trolley Blue Line. The Mid-Coast 

Corridor Transit Project will operate as an extension of the existing Trolley Blue Line 

service. Currently, the Trolley Blue Line operates from approximately 4:00 a.m. 

through 2:00 a.m. the next day. Refer to Chapter 2.0, Section 2.2.2.5 of the Draft 

SEIS/SEIR for a description of the Trolley operating plan. 

There is no evidence that after-hours Trolley service results in increased crime. 

Further, transit stations will have security features to complement existing security at 
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local businesses. Refer to Master Response 11 for additional information regarding 

the potential for crime rates to change in the Mid-Coast Corridor, and anticipated 

security measures at transit stations. 

18 Volume 2 of the Draft SEIS/SEIR provided a plan set for the project, including the UTC 

Transit Center. These plans have been updated for the Final SEIS/SEIR and are 

included as Volume 2. The right-of-way plans show detailed right-of-way requirements 

that are projected to be needed for the project. It is not anticipated that property areas 

outside of those identified in the plan set will be necessary for the project.

19 The SEIS/SEIR identifies the anticipated physical acquisition requirements of the 

project and analyzes potential environmental impacts associated with the project. The 

impact of the project on a property’s conformity with local land use regulations or 

permits is a legal question that is within the purview of the permitting agencies and 

beyond the scope of the SEIS/SEIR. However, SANDAG will continue to coordinate 

with permitting agencies and landowners in an effort to avoid and minimize any 

potential impacts on a property’s conformity with local land use regulations or permits.

20 The Draft SEIS/SEIR is consistent in its discussion of future development, and 

concluded that future development around transit stations will be consistent with 

adopted land use plans and existing zoning regulations of the City of San Diego 

General Plan (refer to The Series 11: 2030 Regional Growth Forecast Update: 

Process and Model Documentation) and the Regional Comprehensive Plan (as 

described in Chapter 4.0, Section 4.18.2.2 of the Draft SEIS/SEIR), both of which 

anticipate implementation of the Mid-Coast Corridor Transit Project. Land use 

designations and zoning permit a higher density of development than currently exists 

near the anticipated stations; therefore, while density may be expected to increase, 

such development is anticipated to be consistent with adopted plans and policies.

21 As noted in response to Comment 2, the Genesee Avenue Design Option was 

eliminated from consideration in the Final SEIS/SEIR. The UTC Transit Center station 

will be elevated in the middle of the Genesee Avenue right-of-way, and the vertical 

features (stairs and elevators) are currently planned to be placed in locations that will 

not disrupt existing shopping center operations. As shown on the Final SEIS/SEIR 

Plan Set (Sheets RW024 and RW025), it is anticipated that the sidewalk along 

Genesee Avenue will be shifted westward to accommodate the project. This shift in 

the sidewalk is not anticipated to alter the existing use of the site or prevent its 

revitalization in the future. The ultimate location of facilities will be coordinated with 

the shopping center.
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22 The project will not result in a permanent loss of parking from the Costa Verde Center. 

Permanent parking impacts, by location, are shown in Chapter 3.0, Table 3-30 of the 

Final SEIS/SEIR, and are depicted in the right-of-way plan set in Volume 2. This 

information was also provided in Chapter 3.0, Table 3-29 of the Draft SEIS/SEIR, and 

was shown on the right-of-way plan set in Volume 2 of the Draft SEIS/SEIR. As 

discussed in Chapter 3.0, Section 3.4.7.4 of the Final SEIS/SEIR, it is anticipated that 

there will be some temporary impacts to approximately 16 parking spaces at the Costa 

Verde Center during construction; this is a substantial reduction compared to parking 

losses shown in the Draft SEIS/SEIR (185 spaces, as referenced in the comment) and 

thus avoids and lessens impacts of the project, as requested by the commenter.

23 The Real Estate Acquisition Management Plan, which is currently under development, 

is a project measure designed to ensure compliance with the Federal Uniform 

Relocation Assistance and Real Property Acquisition Policies Act of 1970, as 

amended (49 CFR 24), the California Relocation Assistance Act of 1970, as amended 

(California Government Code Section 7260 et seq.), and SANDAG Board of Directors 

Policy No. 021. There is no improper deferral of mitigation because these acts and 

policies set forth clear, enforceable standards for property acquisitions. Preparation of 

a Real Estate Acquisition Management Plan to ensure proper implementation of those 

standards is appropriate.

24 The SEIS/SEIR includes adequate information to assess the visual impacts of the UTC 

Transit Center LRT station. Conceptual site plans for the station are provided (see 

Chapter 2.0, Figure 2-20 of the Final SEIS/SEIR). Also included are visual depictions 

of project features and stations that provide a general understanding of scale and 

characteristics of stations and related facilities (see Sheets 363 through 366 in the 

Final SEIS/SEIR Plan Set). The photo simulations for Key Views 19 and 20 (shown in 

Chapter 5.0, Figure 5-20 and Figure 5-19, respectively, of the Mid-Coast Corridor 

Transit Project Visual Impacts Technical Report), illustrate the appearance of the 

aerial structure within the existing right-of-way on Genesee Avenue. Figures 5-18 and 

5-19 also depict the Executive Drive Station, which is comparable in design to the UTC 

Transit Center LRT station. Note that Figure 5-18 is for the Genesee Avenue Design 

Option, which has been eliminated, and therefore the guideway will appear differently 

than what is shown in the figure. These photo simulations and other information 

contained in the visual analysis for the SEIS/SEIR support a finding that this 

component of the project will result in a low-level change in view quality, which will not 

be an adverse impact. Photo simulations of all project elements are not required to 

adequately assess visual impacts. The methodology used to analyze and assess 

visual impacts is consistent with FHWA methodology, as document in the Visual 

Impact Assessment for Highway Projects (FHWA, 1988), and as described in detail in 

Section 3.0 of the Visual Impacts Technical Report and meets the requirements of 

CEQA and NEPA. 

Refer to Master Response 1 for information regarding station design.
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25 Project plans were included in the Draft SEIS/SEIR Plan Set. Part 2–Street Improvement 

Plans and right-of-way plans provide the elevations and footprints for the entire project 

corridor, including station site plans and the locations of the TPSSs. These plans have 

been updated for the Final SEIS/SEIR and are included as Volume 2. 

TPSS 18 (referred to as TPSS 16 in the Final SEIS/SEIR) will remain at the Westfield 

UTC shopping center. TPSS 18 is located in a highly urbanized, heavily traveled area 

and will be screened from public view with walls and/or vegetation to ensure visual 

compatibility with surrounding uses. For more information on the project measure that 

requires screening of TPSSs, see Chapter 4.0, Section 4.4.3.2 of the Final SEIS/SEIR 

under the heading “Project Measures to Avoid or Minimize Impacts”. 

For additional information in response to this comment, refer to the responses to 

Comment 4 and 24 regarding the potential visual impacts of the project along 

Genesee Avenue near the Costa Verde Center, as well as the adequacy of the visual 

analysis. As noted in response to Comment 2, the Genesee Avenue Design Option 

was eliminated from consideration in the Final SEIS/SEIR. Refer to Master Response 

1 for information regarding station design.

26 SANDAG is committed to coordinating with adjacent property owners as the level of detail 

increases in the design of stations and associated facilities. Mitigation Measure VR2, 

described in Chapter 4.0, Section 4.4.4 of the Draft SEIS/SEIR, will ensure that final 

design of the project, including stations, takes into account the visual character of the 

surrounding area to minimize adverse visual impacts to the extent possible. Requiring 

station elements to be compatible with the surrounding visual character provides sufficient 

specificity because the visual character of the project areas is well documented. Also, 

including flexibility to adopt various design methods is a practical approach that allows the 

design to be refined as it is finalized This requirement, along with outreach to affected 

property owners, will be carried forward into the contract specifications for the project. 

Volume 2 of the Draft SEIS/SEIR provided a Plan Set for the project, including station 

plans for the UTC Transit Center (Sheets ST901 through AE901). These plans have 

been updated in the Final SEIS/SEIR and are included as Volume 2 (Sheets ST901 

through AE901). As stated in response to Comment 4, the level of design is 

appropriate for the SEIS/SEIR stage of the project. 

27 As noted in response to Comment 2, SANDAG has eliminated the Genesee Avenue 

Design Option from further consideration. 

The extent of shading of the commenter’s property will be limited in duration and not 

adverse. At 9:00 a.m. during the winter solstice, December 21, when the shading will 

extend the greatest distance from the structure, a westward shadow will be cast 

approximately 60 feet from the elevated project structure. The limits of this shadow 

will fall approximately 20 feet beyond the limits of the existing west side sidewalk along 

Genesee Avenue. 
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28 Refer to the response to Comments 26 and 27.

29 Specific guidance to minimize lighting impacts and balance the need for security with 

aesthetic considerations will be incorporated during final design of the project. Refer 

to Master Response 11 for information regarding security features at stations and 

Master Response 13 for a discussion of project lighting impacts. Protective barriers 

will be placed along the platform at the UTC Transit Center LRT station. The material 

for the barriers will be decided during final design.

30 As noted in response to Comment 2, the Genesee Avenue Design Option was 

eliminated from consideration in the Final SEIS/SEIR. Refer to the response to 

Comment 24 regarding the design of the project and photosimulations. 

Refer to Master Response 13 for information regarding lighting at stations. 

Refer to the response to Comment 27 regarding shading impacts.

31 A Utilities Relocation Plan will be developed as part of project design and it will identify 

all required utility relocations, temporary routing, and reconstruction. The plan will also 

include a construction approach to minimize disruption (refer to Chapter 4.0, Section 

4.17.3.2 of the Draft SEIS/SEIR under the heading “Utilities, Project Measures to 

Avoid or Minimize Impacts”). When service must be temporarily disconnected, it will 

be scheduled for a time when the service is least likely to be required and property 

owners will be notified in advance of this temporary interruption. Additionally, impacts 

to utilities on private properties affected by construction activities will be coordinated 

with property owners during final design.

32 The project contract specifications will require the preparation and implementation of a 

Noise Control Plan by the contractor. This plan will be monitored by SANDAG for 

compliance. The measures that will be included in the Noise Control Plan are 

presented in Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR under the heading 

“Noise, Mitigation Measures.” As recommended in the comment, this section has 

been revised to state that the contractor will "develop and implement" a Noise Control 

Plan (refer to Chapter 4.0, Section 4.17.3.2, Mitigation Measure CON1 in the Final 

SEIS/SEIR). 

33 As discussed in Chapter 4.0, Section 4.6.3.2 of the Draft SEIS/SEIR, the project will 

have lower roadway GHG emissions because of projected decreases in VMT. 

Additional information is provided in the Mid-Coast Corridor Transit Project Air Quality 

Impacts Technical Report. The project was identified to result in increased GHG 

emissions from Trolley energy use in the study area and at the regional level when 

compared to the No-Build Alternative. This increase was determined to be offset by 

the reduction in roadway GHG emissions, with total GHG emissions decreasing 

overall. The Air Quality Impacts Technical Report provided the data used to calculate 
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GHG in Chapter 5.0, Table 5-6. Further information on electricity consumption was 

included in Appendix A to the Mid-Coast Corridor Transit Project Energy Impacts 

Technical Report. 

The GHG emission burdens described in Chapter 4.0, Table 4-9 of the Draft 

SEIS/SEIR are based upon VMT estimates from the SANDAG Series 11 Travel 

Demand Forecasting Model, as described in Chapter 3.0, Section 3.1 of the Draft 

SEIS/SEIR. Specifically, Chapter 4.0, Table 4-49 of the Mid-Coast Corridor Transit 

Project Transportation Impacts and Mitigation Report presents automobile VMT by 

roadway classification for the No-Build and Build Alternatives. The largest decrease 

will occur on freeways followed by collector roadways. 

As shown in footnote 1 to Table 4-9 in Chapter 4.0 of the Draft SEIS/SEIR, the 

roadway analysis includes bus transit in the study area and region. As discussed in 

Chapter 1.0, Section 1.3.2.5 of the Air Quality Impacts Technical Report, bus service 

on Route 150 operating between Downtown San Diego and University City will 

duplicate the new Trolley services and, therefore, will be eliminated. Furthermore, 

although some buses will be rerouted to connect to stations, service frequency of the 

buses serving the stations will not change (refer to Chapter 1.0, Table 1-5 of the Air 

Quality Impacts Technical Report). Therefore, air emissions from buses were included 

in the analysis, which identified project impacts that are similar to conditions under the 

No-Build Alternative. 

Chapter 3.0, Figure 3-8 of the Draft SEIS/SEIR indicates the routes that will serve 

each of the new Trolley stations. Most of these Trolley stations will be served by one 

or two bus routes and the bus stops will be near existing bus stops. MTS has a policy 

that requires bus drivers to shut off the bus if they are staying in one location for longer 

than three minutes, thereby limiting the localized particulate matter emissions. 

Additionally, approximately half of the existing bus fleet is comprised of natural gas 

buses that meet clean fuel requirements; these buses do not release diesel particulate 

matter. Consequently, there will not be a substantial change in localized diesel 

particulate matter. 

 

The air quality analysis examined pollutant emissions from changes in transit vehicle 

miles traveled under the Build Alternative compared to the No-Build Alternative and, as 

a result, any change in route lengths are accounted for in the analysis.

34 Chapter 4.0, Figures 4-18 and 4-19 of the Draft SEIS/SEIR present all of the locations 

of noise-sensitive uses and where noise measurements were taken, and depict the full 

project alignment as it was presented in the Draft SEIS/SEIR. Since the close of the 

comment period, and in response to comments, additional noise measurements were 

taken for select sensitive receivers. Noise-sensitive clusters were identified along 

most of the alignment. The maps in Appendix G of the Mid-Coast Corridor Transit 

Project Noise and Vibration Impacts Technical Report include all areas with noisesensitive uses. The area between Figure G-18 and Figure G-19 includes the Campus 
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Services Complex, parking, a sports complex, and an interstate freeway, which are not 

noise sensitive. 

35 The noise analysis completed at Cluster 92 is representative of other noise-sensitive 

land uses, including the La Jolla Marriott Hotel. No significant noise impacts will occur 

at Cluster 92, the Towers at Costa Verde Apartments, and at the La Jolla Marriott 

Hotel, which is set back farther from the alignment than Cluster 92. The Final 

SEIS/SEIR and the Noise and Vibration Technical Report have been revised to 

indicate that Cluster 92 is an apartment building. 

36 The locations of the noise measurements conducted for the project are shown at an 

appropriate level of detail in Appendix B of the Noise and Vibration Impacts Technical 

Report. Noise-monitoring equipment was placed at outdoor locations representative of 

nearby noise-sensitive uses. As discussed in Chapter 5.0, Section 5.1.3 of the Noise 

and Vibration Impacts Technical Report, impact criteria at each receiver were adjusted 

based on distance and sound path to nearby traffic. Impact criteria are on a sliding 

scale depending on the existing noise environment, as illustrated in Chapter 4.0, 

Figure 4-16 of the Draft SEIS/SEIR. This means that there are more stringent impact 

criteria when the existing ambient noise level is higher; thus, potential impacts have 

not been underestimated.

37 The Draft SEIS/SEIR is required to use the FTA noise impact criteria in evaluating 

FTA-funded transit projects, as documented in the Transit Noise and Vibration Impacts 

Assessment Guidance Manual (FTA, 2006). These criteria do not classify outdoor 

uses of commercial spaces as noise-sensitive (refer to Chapter 4.0, Table 4-10 of the 

Draft SEIS/SEIR). Sensitive receiver Clusters 91 (community center) and 92 

(multifamily residential) are in the vicinity of the Costa Verde Center, with Cluster 91 

extending nearly to the edge of Genesee Avenue. As identified in Chapter 5.0, Table 

5-4 and Table 5-5 in the Noise and Vibration Impacts Technical Report, projectgenerated noise at Clusters 91 and 92 will be well below the moderate impact 

threshold for those clusters. Therefore, project-related noise at the seating areas is 

expected to be similar to the project-generated noise at Clusters 91 and 92, which is 

below the moderate impact threshold for noise-sensitive receivers.

38 The SEIS/SEIR properly considers the project’s growth-inducing potential in the 

context of existing development and existing land use plans. The project provides for 

the extension of the Trolley Blue Line from Santa Fe Depot to the UTC Transit Center 

to serve existing and planned uses. Expanding the growth-inducing analysis to predict 

future changes to community plans would require improper speculation and is 

unnecessary. Existing community plans anticipate the Mid-Coast Corridor Transit 

Project and provide sufficient guidance to assess the project’s growth-inducing 

potential. Any updates to the community plans along the corridor would be the 

responsibility of the City of San Diego and are beyond the scope of the project and 

SEIS/SEIR. 
Volume 3 – Comments and Responses 

Businesses 

Regency Centers Costa Verde Center - 

Chine, Jeffrey, Attorney - ID226 

MID-COAST CORRIDOR TRANSIT PROJECT 

732 September 2014 

Com ID Response

39 Refer to the response to Comment 38. The approval or disapproval of additional 

growth by the land use authority would not affect the impacts associated with the 

Mid-Coast Corridor Transit Project. The project need is based on existing transit 

demand. While demand is forecast to increase as a result of future development, and 

while the project would facilitate increased development density near stations, the lack 

of future developments would not eliminate the need for the project or change the 

impact conclusions presented in the Draft SEIS/SEIR.

40 The comments on individual elements of the NEPA/CEQA analysis are addressed in 

detailed responses to the previous comments. The SEIS/SEIR for the Mid-Coast 

Corridor Transit Project meets all applicable requirements of NEPA and CEQA.

 
Volume 3 – Comments and Responses

Businesses 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 733 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 
Volume 3 – Comments and Responses 

Businesses 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 

MID-COAST CORRIDOR TRANSIT PROJECT 

734 September 2014 
Volume 3 – Comments and Responses

Businesses 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 735 
Volume 3 – Comments and Responses 

Businesses 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 

MID-COAST CORRIDOR TRANSIT PROJECT 

736 September 2014 
Volume 3 – Comments and Responses

Businesses 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 737 
Volume 3 – Comments and Responses 

Businesses 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 

MID-COAST CORRIDOR TRANSIT PROJECT 

738 September 2014 
Volume 3 – Comments and Responses

Businesses 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 739 

Submission ID261 Scripps Health (Scripps Memorial Hospital La Jolla) Madaffer Robin

Com ID Response

1 SANDAG recognizes the importance of fully addressing project impacts to land uses 

throughout the corridor, including Scripps Memorial Hospital La Jolla (Scripps Hospital).

2 The comment correctly notes that the project alignment in the Draft SEIS/SEIR 

circulated for public review was approximately 40 feet south of the Scripps XiMed 

Medical Center. However, in response to this comment letter and additional analysis, 

the alignment has been shifted to the south side of Voigt Drive to avoid potential 

impacts, and is now a minimum distance of 168 feet from the Scripps XiMed Building. 

The distance is measured from the corner of the building to the edge of the deck on 

the alignment aerial structure. The new alignment, which is referred to as the Refined 

Build Alternative, was approved by the SANDAG Board of Directors for inclusion in 

the Final SEIS/SEIR on November 15, 2013. For additional information, see Chapter 

2.0, Section 2.3 of the Final SEIS/SEIR. 

3 The concern raised regarding the sensitive nature of the Scripps XiMed Building was 

considered and factored into the decision to relocate the project alignment farther 

south. For additional detail, refer to Chapter 2.0, Section 2.3 of the Final SEIS/SEIR.

4 Your comment expressing concern regarding proximity-related impacts related to 

noise, vibration, wind-related vibration, visual, and air quality impacts has been noted. 

Specific responses to each concern are provided in the responses below. 

5 As stated in response to Comment 2, the alignment near Scripps Hospital was refined 

after the close of the Draft SEIS/SEIR comment period and is now located 168 feet from 

the Scripps XiMed Building. The noise and vibration analysis was updated to reflect the 

Refined Build Alternative, which incorporates the new alignment, as documented in the 

Mid-Coast Corridor Transit Project Noise and Vibration Impacts Technical Report

(prepared for the Final SEIS/SEIR) and Chapter 4.0, Section 4.7 of the Final SEIS/SEIR. 

The updated analysis determined that there will not be any noise or vibration impacts to 

Scripps Hospital or the Scripps XiMed Building with the new alignment. 

The noise analysis for the Mid-Coast Corridor Transit Project was conducted in 

accordance with guidelines in the FTA Transit Noise and Vibration Impact Assessment 

Guidance Manual (FTA, 2006). The thresholds of impacts are defined by the criteria 

included in this manual. The FTA methodology bases the identification of impacts on 

project-related noise, not on overall ambient noise levels with the project added in. The 

noise levels generated by the project remain the same regardless of measured ambient 

conditions. Therefore, the noise impacts would not be underestimated if the measured 

ambient noise measurements were lower than usual; rather, lower ambient noise would 

result in a lower noise impact threshold for project-related noise. Master Response 9 

provides a more detailed description on how impacts and mitigation are determined 

pursuant to the FTA methodology. 
Volume 3 – Comments and Responses 

Businesses 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 

MID-COAST CORRIDOR TRANSIT PROJECT 

740 September 2014 

Com ID Response

The detailed vibration analysis of the Build Alternative alignment presented in the 

Draft SEIS/SEIR specifically evaluated the Scripps XiMed Building, referred to as 

Cluster 79 in Chapter 5.0, Section 5.1.4.2 of the Noise and Vibration Impacts 

Technical Report that was prepared for the Draft SEIS/SEIR. The analysis for the 

Build Alternative alignment concluded that the predicted train vibration at the Scripps 

XiMed Building will be below the vibration criteria for an operating theater or surgical 

facilities and will not exceed the criterion used for electron microscopes operating to 

the limit of their capacity. By shifting the LRT alignment to the south side of Voigt 

Drive, as reflected under the Refined Build Alternative, vibration levels at the Scripps 

XiMed Building will be further reduced. 

6 As stated in the response to Comment 5, the noise impact assessment used for the 

NEPA analysis follows guidelines from the FTA Transit Noise and Vibration Impact 

Assessment Guidance Manual (FTA, 2006). The thresholds of impacts are defined by 

the criteria included in this manual. The future ambient noise level may increase as a 

result of other projects described in the comment independent of the Mid-Coast 

Corridor Transit Project. The CEQA analysis evaluated whether the project would 

increase the ambient noise level by 3 dBA or more at locations along the alignment. 

Under the Refined Build Alternative, five noise-sensitive receiver clusters representing 

19 residential units and 20 hotel rooms are predicted to experience moderate noise 

impacts at least 1 dBA greater than the impact threshold or an increase in the 

cumulative environmental noise level of more than 3 dBA. With mitigation, the 

impacts at these five locations will be less than significant. 

The cumulative effect of the project and other future projects is not used by FTA as 

the basis for identification of a noise impact that would require mitigation; rather, it is 

based on the level of noise generated by the project. A noise increase caused by 

other actions independent of the project would not be a direct impact of the project. 

Generally speaking, the louder the ambient noise level, the louder the project noise 

level must be to trigger a moderate or severe impact under FTA criteria (see Chapter 

4.0, Figure 4-16 in the Final SEIS/SEIR). 

The cumulative noise analysis is documented in Chapter 4.0, Section 4.19.3.2 of the Draft 

SEIS/SEIR under the heading "Noise and Vibration." As stated in this section, the 

cumulative impacts from the future expansion of I-5 and the LOSSAN double tracking 

were among the projects considered as part of the cumulative noise analysis. As stated 

in this section, because the major source of future noise impacts is roadway vehicle noise 

rather than LRT noise, "to the extent that any cumulatively significant impact would occur, 

the project's contribution would not be cumulatively considerable." With mitigation, noise 

impacts from the project will be less than significant. Noise and vibration impacts related 

to the UCSD and Scripps Hospital expansion would largely be associated with the 

construction phase of those projects, and the projects would not cause long-term 

cumulatively significant noise and vibration impacts. Other projects, including the future 

I-5 widening and LOSSAN double tracking, would be required to undergo appropriate 

approval processes to minimize the potential for incompatible noise and vibration 
Volume 3 – Comments and Responses

Businesses 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 741 

Com ID Response

environments. Therefore, the project will not cause an adverse or significant cumulative 

noise impact and will not result in cumulatively considerable impacts under CEQA. 

It should be noted that the Refined Build Alternative reflected in the Final SEIS/SEIR 

further reduces noise and vibration impacts to Scripps Hospital and the Scripps XiMed 

Building as discussed in response to Comment 5. 

7 The noise and vibration analysis properly considered the sensitive nature of Scripps 

Hospital. The statement referenced in the comment (found in Chapter 4.0, Section 

4.7.2 of the Draft SEIS/SEIR) was unclear that it referred to Category 1 land uses in 

reference to standards for the noise analysis only. Under FTA standards for noise 

analysis, hospitals are considered Category 2 land uses (refer to Chapter 4.0, Table 

4-1 of the Draft SEIS/SEIR). Under the standards used for the vibration analysis, 

hospitals are considered Category 1 land uses (refer to Chapter 4.0, Table 4-12 of the 

Draft SEIS/SEIR). Both categories consider Scripps Hospital to be a sensitive use, 

and impacts were analyzed accordingly. The text in Chapter 4.0, Section 4.7.2 of the 

Final SEIS/SEIR has been revised to state that “there are no noise Category 1 land 

uses.” 

8 Refer to the response to Comment 5 regarding project vibration levels at the Scripps 

XiMed Building. The analysis conducted for the Draft SEIS/SEIR found that vibration 

levels would be below the vibration impact criteria for the most demanding of 

vibration-sensitive equipment, including electron microscopes operating to the limit of 

their capability. The shift in the project alignment farther from the Scripps XiMed 

Building will further reduce vibration impacts.

9 No significant wind impacts to the Scripps XiMed Building are anticipated because of 

the low speed of LRT trains and the distance between the building and relocated 

project alignment. The projected maximum operating speed of the LRT trains is 55 

mph. The aerodynamic effects of a LRT train at this speed are minimal. As stated in 

response to Comment 3, the LRT alignment under the Refined Build Alternative will 

be located 168 feet from the XiMed Building, which is 132 feet farther from the 

building than the alignment shown in the Draft SEIS/SEIR. 

10 As stated in responses to Comments 5 and 9, the vibration associated with the project 

will not result in an impact to Scripps Hospital or the Scripps XiMed Building. 

11 The analyses were reviewed and updated as needed for the Final SEIS/SEIR and 

supporting technical reports to reflect the new location of the alignment under the 

Refined Build Alternative. The results of these analyses are summarized in Chapter 

4.0 of the Final SEIS/SEIR (noise and vibration in Section 4.7 and EMF in Section 

4.14). As described in these sections, there will be no significant noise, vibration, or 

EMF impacts to Scripps Hospital and the XiMed Building with the new alignment.
Volume 3 – Comments and Responses 

Businesses 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 

MID-COAST CORRIDOR TRANSIT PROJECT 

742 September 2014 

Com ID Response

12 Because the alignment has been shifted 168 feet away from the XiMed Building, there 

will not be a significant noise impact to this facility, and the sound wall that was 

identified in the Draft SEIS/SEIR will not be required.

13 Chapter 4.0, Section 4.14.3.2 of the Draft SEIS/SEIR described the evaluation of EMF 

impacts throughout the corridor, including consideration of Scripps Hospital. In 

accordance with the approach described in the Draft SEIS/SEIR, Chapter 4.0, Section 

4.14.4, information regarding equipment that is potentially sensitive to electromagnetic 

interference was obtained during the public review period for the Draft SEIS/SEIR to 

allow accurate modeling of electromagnetic field levels. The resulting identification of 

potential electromagnetic interference to sensitive equipment in the Scripps XiMed 

Building was a factor leading to relocation of the project alignment to the south. The 

relocation was the result of coordination with hospital representatives to identify the 

location of sensitive equipment at the Scripps XiMed Building, as well as further 

engineering and environmental studies. 

As stated in response to Comment 2, the LRT alignment under the Refined Build 

Alternative in the Final SEIS/SEIR is located 168 feet from the Scripps XiMed Building. At 

this distance, as documented in Chapter 4.0, Section 4.14.3.2 of the Final SEIS/SEIR and 

Chapter 5.0, Section 5.1.2 of the Electromagnetic Fields Impacts Technical Report 

(prepared for the Final SEIS/SEIR), sensitive medical equipment and procedures will not 

be adversely affected by electromagnetic interference from the project. 

14 The potential visual and shading impacts have been significantly reduced by the 

relocation of the project alignment to the south. Chapter 4.0, Section 4.4.3 of the 

Draft SEIS/SEIR evaluated visual impacts in the vicinity of Scripps Hospital. Key 

Views 14, 15, 16, and 28 identified in Chapter 4.0, Figure 4-12 and described in Table 

4-4 of the Draft SEIS/SEIR are representative of views in the vicinity of the hospital. 

The analysis concluded that impacts to these views with the prior alignment would be 

less than significant. As reflected in the Final SEIS/SEIR and as shown in the 

updated visual simulation for Key View 28 shown in the Mid-Coast Corridor Transit 

Project Visual Impacts Technical Report (prepared for the Final SEIS/SEIR), with the 

alignment further removed from Scripps Hospital, view impacts would continue to be 

less than significant. The other key views did not require updates because the 

simulations prepared for the Draft SEIS/SEIR adequately capture the visual impact of 

the proposed changes to the extent that the impact conclusions would not be affected 

by the changed design. 

The relocated alignment to 168 feet from the Scripps XiMed Building and elimination 

of the sound wall (see response to Comment 12) eliminates any potential for 

significant shading or light impacts in the area. 

Your comment requesting the incorporation of first-class design principles which fit 

within the character of the community has been noted and will be part of the record of 

proceedings for the Draft SEIS/SEIR. 
Volume 3 – Comments and Responses

Businesses 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 743 

Com ID Response

15 The Draft SEIS/SEIR provides a qualitative assessment of the expected noise and 

vibration effects that will occur throughout the corridor, including at Scripps Hospital 

and the Scripps XiMed Building, based on experience with other transit projects. 

Construction activity near these facilities will last approximately 4 years and will 

include utility relocation and construction of the station and aerial guideway. The 

exact methods of construction may vary at different sites, and an important part of the 

assessment of construction impacts is to identify the noise and vibration control 

measures that will be required by the contractor when appropriate. These project and 

mitigation measures are described in Chapter 4.0, Section 4.17.3.2 of the Final 

SEIS/SEIR under the heading "Noise and Vibration Impacts" and in Chapter 6.0, 

Section 6.17 of the Mid-Coast Corridor Transit Project Construction Impacts Technical 

Report (prepared for the Final SEIS/SEIR).

16 As stated in Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR, one of the project 

measures to minimize noise-related impacts requires the following: “Coordinate with 

the site administrators of nearby schools and other sensitive noise receptors to 

discuss construction activities that generate high noise levels. Coordination between 

the site administrators and the construction contractor would continue on an asneeded basis throughout the construction period to address potentially disruptive 

noise levels.” Scripps Hospital is a noise-sensitive receptor, and ongoing coordination 

is proposed. The contract specifications that will be prepared by SANDAG during final 

design will require the contractor to meet the requirements of the City of San Diego 

Municipal Code noise limits of 75 decibels average sound level during the 7 a.m. to 7 

p.m. 12-hour period when construction is allowed. As part of the Noise Control Plan 

required by Mitigation Measure CON1, the contractor will be required to conduct noise 

monitoring to verify that exceedance of this noise limit does not occur.

17 The contract specifications that will be prepared by SANDAG during final design will 

require vibration monitoring during construction at sensitive locations, including 

Scripps Hospital and the Scripps XiMed Building. As a result of the shift in the 

guideway alignment, the increased distance from the construction area to the Scripps 

XiMed Building will substantially reduce construction vibration levels. The noisecontrol measures that will be required by the contractor during construction are 

described in Chapter 4.0, Section 4.17.3.2 of the Final SEIS/SEIR under the heading 

"Noise and Vibration Impacts" and in Chapter 6.0, Section 6.17 of the Construction 

Impacts Technical Report prepared for the Final SEIS/SEIR. As stated in response to 

Comment 16, noise measures will include ongoing coordination with Scripps Hospital 

to help avoid and minimize disruption of activities at the facility.

18 SANDAG will coordinate with Scripps Hospital prior to construction to ensure minimal 

impacts to HVAC intakes and associated sensitive operations. Coordination may 

include provisions for additional or new filters at the HVAC intakes.
Volume 3 – Comments and Responses 

Businesses 

Scripps Health (Scripps Memorial Hospital La Jolla) - 

Madaffer, Robin, Attorney - ID261 

MID-COAST CORRIDOR TRANSIT PROJECT 

744 September 2014 

Com ID Response

19 The station names used in the Draft SEIS/SEIR represent the street or geographic 

location of the stations. This particular station has been referred to as the UCSD East 

Station because of its geographic location. To avoid confusion, the station names 

used in the Draft SEIS/SEIR were retained in the Final SEIS/SEIR. The names used 

do not necessarily reflect the station names that will be used when the project begins 

operation. These names will be determined by MTS prior to the start of operation. 

The “Voigt Drive Station at UCSD East” name was used during the Draft SEIS/SEIR 

public meetings and hearing and as part of the informational materials mailed to the 

public during the Draft SEIS/SEIR comment period. It was not used in the Draft or 

Final SEIS/SEIRs.

20 As stated in response to previous comments, the alignment near Scripps Hospital has 

been refined since the Draft SEIS/SEIR and is now located 168 feet from the Scripps 

XiMed Building, rather than approximately 40 feet. The impact analyses were 

updated based on the new alignment location as reflected under the Refined Build 

Alternative; the results are summarized in Chapter 4.0 of the Final SEIS/SEIR and the 

supporting technical reports.

21 The Draft SEIS/SEIR analyzed the noise, vibration, and air quality impacts that will 

occur as a result of construction and operation of the project. Scripps Hospital is 

identified as a sensitive land use throughout the Draft SEIS/SEIR, including the noise, 

vibration, electromagnetic interference, and construction impacts discussions. 

SANDAG will continue to work with Scripps Hospital to incorporate appropriate 

construction requirements for the contractor to minimize site-specific construction 

impacts.

22 As discussed in response to the prior comments, design options to avoid impacts to 

the Scripps facilities referenced in this letter have been considered, and as a result, 

the project alignment has been shifted to the south to avoid and reduce impacts. The 

environmental analyses were updated for the Final SEIS/SEIR based on the new 

alignment. As documented in Chapter 4.0 of the Final SEIS/SEIR and the supporting 

technical reports, operation of the project will not result in long-term adverse or 

significant impacts to Scripps Hospital or the Scripps XiMed Building. Mitigation 

monitoring is discussed in the Mid-Coast Corridor Transit Project Mitigation Monitoring 

and Reporting Program (attached as part of the Record of Decision in Appendix D of 

the Final SEIS/SEIR Volume 1) that will be adopted by the SANDAG Board of 

Directors when the findings under CEQA are made.

23 SANDAG will continue to work with Scripps Hospital during project development and 

construction.

 
Volume 3 – Comments and Responses

Businesses 

TRU 2005 RE I, LLC (Toys R Us) - 

Zentmeyer, Don, Attorney - ID233 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 745 

TRU 2005 RE I, LLC (Toys R Us) - 

Zentmeyer, Don, Attorney - ID233 
Volume 3 – Comments and Responses 

Businesses 

TRU 2005 RE I, LLC (Toys R Us) - 

Zentmeyer, Don, Attorney - ID233 

MID-COAST CORRIDOR TRANSIT PROJECT 

746 September 2014 
Volume 3 – Comments and Responses

Businesses 

TRU 2005 RE I, LLC (Toys R Us) - 

Zentmeyer, Don, Attorney - ID233 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 747 
Volume 3 – Comments and Responses 

Businesses 

TRU 2005 RE I, LLC (Toys R Us) - 

Zentmeyer, Don, Attorney - ID233 

MID-COAST CORRIDOR TRANSIT PROJECT 

748 September 2014 
Volume 3 – Comments and Responses

Businesses 

TRU 2005 RE I, LLC (Toys R Us) - 

Zentmeyer, Don, Attorney - ID233 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 749 
Volume 3 – Comments and Responses 

Businesses 

TRU 2005 RE I, LLC (Toys R Us) - 

Zentmeyer, Don, Attorney - ID233 

MID-COAST CORRIDOR TRANSIT PROJECT 

750 September 2014 

Submission ID233 TRU 2005 RE I, LLC (Toys R Us) Zentmeyer Don

Com ID Response

1 Your comment stating that the Toys R Us store on West Morena Boulevard would 

be directly impacted by the Tecolote Road Station has been noted and will be part 

of the record of proceedings for the Draft SEIS/SEIR. 

2 Comments regarding physical impacts of the Mid-Coast Corridor Transit Project are 

addressed in the responses below. With regard to comments that raise claims for 

compensation, socioeconomic and fiscal impacts of the project are addressed in 

Chapter 4.0, Section 4.3.3.2 of the Draft SEIS/SEIR, which states that 

compensation for property acquisitions will be in accordance with the Federal 

Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, 

as amended, the California Relocation Assistance Act of 1970, as amended, and 

SANDAG Board of Directors’ Policy No. 021. To the extent a comment asserts an 

additional right to recover damages, the comment goes beyond the scope of the 

Draft SEIS/SEIR.

3 Your comment asserting that reorientation of the building would be required has 

been noted and will be part of the record of proceedings for the Draft SEIS/SEIR. 

Adequate parking will be maintained for the Toys R Us building. It is anticipated 

that approximately 93 parking spaces in the northwest corner of Morena Plaza will 

be needed to accommodate the station and facilities. It is further anticipated that 

approximately 23 parking spaces will remain on the northwest side of the Toys R Us 

building, and an additional 127 spaces will remain available on the southeast side 

of the building, for a total of 150 parking spaces. The Toys R Us building is 

approximately 35,000 square feet, and the parking requirements for this type of 

land use in the CC-4.2 zone generally is 2.5 spaces per 1,000 square feet, which 

results in the need for 88 parking spaces. Therefore, the 150 parking spaces that 

are expected to remain available to Toys R Us will exceed zoning parking 

requirements. 

Vehicle access to the Toys R Us building will not change. The primary access point 

to the Tecolote Road Station will be at Vega Street, which is currently used by Toys 

R Us customers for access. Access to Toys R Us at Vega Street will be maintained 

to allow northbound traffic to make left turns to access Toys R Us, as well as truck 

deliveries. 

The circulation will direct cars west and around the southwest entrance to the 

building and to the parking area to the southeast of the building. A diagram of the 

station circulation is provided in the Station Plans in the Final SEIS/SEIR Plan Set 

(Volume 2 of the Final SEIS/SEIR) (Sheet 304) (available at 

www.sandag.org/midcoast). 
Volume 3 – Comments and Responses

Businesses 

TRU 2005 RE I, LLC (Toys R Us) - 

Zentmeyer, Don, Attorney - ID233 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 751 

Com ID Response

As stated above, it is expected that 150 parking spaces will remain available to 

Toys R Us, which is more than the number required to satisfy City of San Diego 

parking requirements. No waivers or zoning exemptions for parking are anticipated.

4 As stated in response to Comment 3, it is expected that approximately 150 parking 

spaces will remain available for the Toys R Us store, which is sufficient to meet 

parking requirements per city code. The project will provide fencing along portions 

of the Tecolote Road Station site. Raised curbs, landscaping, or fencing will be 

provided around the transit parking at this station to clearly separate transit parking 

from commercial parking. 

Your comment expressing concerns with parking restriction enforcement by 

SANDAG in the vicinity of the Toys R Us store has been noted and will be part of 

the record of proceedings for the Draft SEIS/SEIR.

5 Based on comments received on the Draft SEIS/SEIR, several alternative site 

configurations for the Tecolote Road Station were considered but found infeasible, 

as described in more detail in Master Response 3. 

The required parking supply for the Tecolote Road Station was determined based 

on forecasts derived from the SANDAG Series 11 Travel Demand Forecasting 

Model for parking demand. Parking demand is based on many factors beyond 

projected daily boardings, including the availability of other modes of access to the 

station that do not contribute to parking demand (walk/bike and other modes of 

transit). A reduction in parking at the Tecolote Road Station below the forecasted 

demand would result in a reduction in ridership, and likely also would result in 

spillover parking in the vicinity of the Tecolote Road Station or an increase in 

parking demand at the adjacent stations, and is therefore not feasible.

6 As discussed in more detail in Master Response 3, a parking structure at the 

Tecolote Road Station was considered. The replacement of surface parking with a 

parking structure would substantially increase the cost of the project and has not 

been determined to be necessary to mitigate any identified significant impacts, as 

none would occur at this location. Therefore, a parking structure at this location 

was not carried forward as part of the project. 

7 The comment regarding the terms of the property lease has been noted and will be 

part of the record of proceedings for the Draft SEIS/SEIR. 
Volume 3 – Comments and Responses 

Businesses 

TRU 2005 RE I, LLC (Toys R Us) - 

Zentmeyer, Don, Attorney - ID233 

MID-COAST CORRIDOR TRANSIT PROJECT 

752 September 2014 

Com ID Response

8 As stated in Master Response 3, alternative site designs were evaluated after the close 

of the Draft SEIS/SEIR comment period. The station layout presented in the Draft 

SEIS/SEIR remains the best option for the project. On November 15, 2013, the 

SANDAG Board of Directors considered comments on the Draft SEIS/SEIR and public 

testimony, as well as a presentation by staff regarding the station layout options that 

were evaluated in response to comments. The Board of Directors approved the 

recommended Refined Build Alternative, which maintains the station layout presented 

in the Draft SEIS/SEIR with only minor modifications (the minor modification resulted in 

a 0.11 acre reduction in permanent right-of-way requirements). 

Your comment regarding reconstruction costs and reimbursements has been noted 

and will be part of the record of proceedings for the Draft SEIS/SEIR. 

 
Volume 3 – Comments and Responses

Businesses 

UTC Venture, LLC (Westfield) - 

Maguire, Neal, Attorney - ID224 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 753 

UTC Venture, LLC (Westfield) - 

Maguire, Neal, Attorney - ID224 
Volume 3 – Comments and Responses 

Businesses 

UTC Venture, LLC (Westfield) - 

Maguire, Neal, Attorney - ID224 

MID-COAST CORRIDOR TRANSIT PROJECT 

754 September 2014 
Volume 3 – Comments and Responses

Businesses 

UTC Venture, LLC (Westfield) - 

Maguire, Neal, Attorney - ID224 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 755 
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Businesses 

UTC Venture, LLC (Westfield) - 

Maguire, Neal, Attorney - ID224 

MID-COAST CORRIDOR TRANSIT PROJECT 

756 September 2014 
Volume 3 – Comments and Responses

Businesses 

UTC Venture, LLC (Westfield) - 

Maguire, Neal, Attorney - ID224 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 757 
Volume 3 – Comments and Responses 

Businesses 

UTC Venture, LLC (Westfield) - 

Maguire, Neal, Attorney - ID224 

MID-COAST CORRIDOR TRANSIT PROJECT 

758 September 2014 
Volume 3 – Comments and Responses

Businesses 

UTC Venture, LLC (Westfield) - 

Maguire, Neal, Attorney - ID224 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 759 
Volume 3 – Comments and Responses 

Businesses 

UTC Venture, LLC (Westfield) - 

Maguire, Neal, Attorney - ID224 

MID-COAST CORRIDOR TRANSIT PROJECT 

760 September 2014 

 
Volume 3 – Comments and Responses

Businesses 

UTC Venture, LLC (Westfield) - 

Maguire, Neal, Attorney - ID224 

MID-COAST CORRIDOR TRANSIT PROJECT 

September 2014 761 

Submission ID224 UTC Venture, LLC (Westfield UTC) Maguire Neal

Com ID Response

1 The statement regarding the topic of Westfield UTC shopping center’s comments has 

been noted.

2 Your comment regarding support for alternative means of transport and greater 

mobility are noted, and will be part of the record of proceedings for the Draft 

SEIS/SEIR. Refer to subsequent responses for information on impacts and mitigation 

near the Westfield UTC shopping center. 

3 SANDAG has completed a comprehensive environmental analysis and has complied 

with all requirements under NEPA and CEQA. Comments on individual elements of 

the NEPA and CEQA analyses are addressed in detailed responses below. The 

statement regarding the community benefits provided by Westfield UTC shopping 

center has been noted and will be part of the record of proceedings for the Draft 

SEIS/SEIR.

4 On November 15, 2013, the SANDAG Board of Directors approved the Refined Build 

Alternative, which includes center columns supporting the aerial LRT alignment on 

Genesee Avenue, for consideration in the Final SEIS/SEIR. Although the pedestrian 

bridges along Genesee Avenue will be removed, pedestrians will be able to cross 

Genesee Avenue at the existing crosswalks at La Jolla Village Square and Esplanade 

Court/UTC Driveway where crosswalks are provided and at the station platform. 

As stated in Chapter 3.0, Section 3.4.7.3 of the Draft SEIS/SEIR, the pedestrian 

bridges along Genesee Avenue near Executive Square and the Westfield UTC 

shopping center will be removed during construction. Under existing conditions, 

crosswalks are not provided at all approaches at Genesee Avenue and La Jolla 

Village Drive, which is the intersection located between the two pedestrian bridges. 

During construction, temporary crosswalks and pedestrian signals will be added at 

this intersection. Following construction, pedestrians will be able to cross at the 

elevated station platform. Pedestrian connectivity will be maintained during 

construction and operation of the project.

5 The analysis conducted in support of the project, as documented in the Draft 

SEIS/SEIR and supporting technical reports, identifies and evaluates the impacts of 

the project in compliance with NEPA and CEQA, and provides mitigation measures 

where appropriate. Chapter 3.0, Section 3.4.2 of the Draft SEIS/SEIR provides 

details on traffic impacts of the project. Table 3-25 provides specific details about 

impacts, and Table 3-26 provides specific details regarding the mitigation measures 

addressing access to the Westfield UTC shopping center from Genesee Avenue. 

With mitigation, the project will not result in an adverse or significant traffic impact 

near the Westfield UTC shopping center. 

Visual impacts are discussed in Chapter 4.0, Section 4.4.3 of the Draft SEIS/SEIR. 
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Key Views 19 and 20 presented in Table 4-4 of the Draft SEIS/SEIR and in Chapter 

5.0, Figure 5-20 of the Mid-Coast Corridor Transit Project Visual Impacts Technical 

Report are in the vicinity of the Westfield UTC shopping center. 

Because the Trolley will be electrically powered, there will be no emissions from fuel 

combustion associated with operation of the system. Furthermore, as explained in 

Chapter 4.0, Section 4.5.3.2 of the Draft SEIS/SEIR, under the Build Alternative with 

the VA Medical Center Station Option, emissions burdens in the study area for all 

pollutants will be equal to or lower than the No-Build Alternative. No air quality 

impacts to UTC will result from the project. 

Land uses in UTC in the vicinity of the transit station are commercial and parking; the 

corresponding noise metrics are shown in Chapter 4.0, Table 4-10 of the Draft 

SEIS/SEIR. A noise analysis was completed for Cluster 92, which is an apartment 

building on the corner of La Jolla Village Drive and Genesee Avenue near the UTC 

Transit Center Station. As shown in Chapter 5.0, Table 5-4 of the Mid-Coast Corridor 

Transit Project Noise and Vibration Impacts Technical Report, the project will not 

result in a significant noise impact at Cluster 92. Cluster 92 is representative of the 

closest residential land uses to the alignment in the vicinity of the Westfield UTC 

shopping center. 

More specific information regarding the Draft SEIS/SEIR’s environmental analysis is 

provided in response to the more detailed comments below. 

6 As acknowledged in the comment, traffic mitigation at Esplanade Court/UTC 

Driveway is required per City of San Diego criteria. The traffic analysis considered 

the plans that were approved and environmentally cleared at the time of the analysis 

(2010). SANDAG also reviewed the updated plans dated August 2014. The parking 

controls referenced in the comment were not included on plans available when the 

Draft SEIS/SEIR was released to the public or the plans dated 2014. The mitigation 

(widening of Esplanade Court to add a left-turn lane) has been retained in the Final 

SEIS/SEIR; however, SANDAG will consider future plans and will coordinate the 

design of the mitigation measure with the property owner. Chapter 3.0, Section 

3.4.4.2 of the Final SEIS/SEIR summarizes the permanent loss of off-street parking at 

the Westfield UTC shopping center with additional information provided in Section 

3.4.4.4. Socioeconomic and fiscal impacts of the Mid-Coast Corridor Transit Project, 

including acquisition of right-of-way and parking spaces at the Westfield UTC 

shopping center to accommodate transit parking at the UTC Transit Center, are 

addressed in Chapter 3.0, Section 3.4.4.2 and Chapter 4.0, Section 4.3.3.2 of the 

Final SEIS/SEIR, which provides that compensation for property acquisitions will be in 

accordance with the Federal Uniform Relocation Assistance and Real Property 

Acquisition Policies Act of 1970, as amended, the California Relocation Assistance 

Act of 1970, as amended, and SANDAG Board of Directors’ Policy No. 021. To the 

extent the commenter asserts an additional right to recover damages, the comment 

goes beyond the scope of the Draft SEIS/SEIR.
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7 Refer to the response to Comment 6 regarding the traffic analysis and mitigation. On 

November 15, 2013, the SANDAG Board of Directors approved the Refined Build 

Alternative for evaluation in the Final SEIS/SEIR. The Refined Build Alternative 

requires the use of property in the Westfield UTC shopping center that is currently 

being used for parking, rather than construction of an additional level on the future 

Westfield UTC shopping center parking structure. SANDAG anticipates that the 

location and the design of the transit parking will be done in such a manner to 

minimize impacts on access and circulation. Chapter 3.0, Section 3.4.4.2 of the Final 

SEIS/SEIR summarizes the permanent loss of off-street parking at the Westfield UTC 

shopping center with additional information provided in Section 3.4.4.4. Damages, if 

any, due to the Refined Build Alternative’s impacts on parking are addressed in 

Comment 6.

8 The project will not impact the construction schedule for expansion of the Westfield 

UTC shopping center. As stated in response to Comment 7, the Refined Build 

Alternative requires the acquisition of existing parking spaces, rather than 

construction of an additional level of structured parking. By utilizing existing parking, 

the potential impacts associated with construction of Westfield UTC shopping center’s 

new parking structure prior to a commitment by SANDAG are eliminated. Damages, 

if any, due to the Refined Build Alternative’s impacts on parking are addressed in 

Comment 6.

9 Based on your comment, the Mid-Coast Corridor Transit Project Final Refined Build 

Alternative Report recommended that the referenced construction staging area be 

eliminated from the project. The SANDAG Board of Directors approved the Refined 

Build Alternative, without the construction staging area, on November 15, 2013. As a 

result, any potential impacts previously associated with this construction staging area 

have been eliminated. 

10 As discussed in response to Comment 9, the construction staging area on Westfield 

UTC shopping center property has been eliminated. Damages, if any, due to the 

Refined Build Alternative’s impacts on parking are addressed in Comment 6.

11 Refer to responses to Comments 9 and 10 regarding elimination of the construction 

staging area. No additional analysis will be required with respect to the impacts of 

this staging area.

12 Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR discusses the visual impacts 

from construction. Construction-related visual impacts are discussed in additional 

detail in the Mid-Coast Corridor Transit Project Construction Impacts Technical 

Report. The level of detail provided in the Draft SEIS/SEIR and supporting studies is 

sufficient to identify potentially significant impacts as well as avoidance, minimization, 

or mitigation measures. As stated in Chapter 5.0, Section 5.11 of the Construction 

Impacts Technical Report, “Viewer responses to the construction activities are 
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expected to differ from viewer responses to the completed structures. Construction 

activities are typically perceived as temporary, with the expectation that unsightly 

elements such as scaffolding and bulky equipment will be removed upon completion. 

Therefore, the temporary existence of equipment, structures and activities related to 

construction that may be unsightly, on its own, is not generally considered an adverse 

impact.” 

As discussed in response to Comment 9, the construction staging area on the Westfield 

UTC shopping center property has been eliminated, along with any associated visual 

impacts. Construction-related visual impacts will be related to construction of the aerial 

guideway and the UTC Transit Center Station along the periphery of the project. The 

avoidance measure requiring light shielding near residential areas has been modified to 

include commercial areas with evening or nighttime use. As a result, short-term 

construction impacts will be less than significant. 

13 As discussed in response to Comment 12, with the project measures incorporated 

into the project to reduce the visual effects of construction, temporary visual impacts 

will be less than significant under CEQA and will not require additional mitigation. 

Existing Westfield UTC shopping center signage will not require relocation during 

construction. Temporary or relocated signage, if required, will be provided in 

coordination with the Westfield UTC shopping center. 

SANDAG’s commitment to mitigation and project measures is documented in the 

Record of Decision per NEPA (issued as part of this Final SEIS/SEIR) and SANDAG 

will adopt a mitigation monitoring and reporting program when it certifies the Final 

SEIR, makes findings under CEQA, and approves the project. 

14 The Draft SEIS/SEIR provides a quantitative assessment of the expected air quality 

impacts that will occur throughout the corridor during construction based on experience 

with other transit projects. The exact methods of construction may vary at different sites, 

and an important part of the assessment of construction impacts is to identify the air 

quality impact control measures that will be required by the contractor when appropriate. 

These project measures are described in Chapter 4.0, Section 4.17.3.2 of the Draft 

SEIS/SEIR under the heading "Air Quality Impacts" and in Chapter 6.0, Section 6.18 of 

the Construction Impacts Technical Report. 

As described in Chapter 4.0, Section 4.17.3.2 of the Final SEIS/SEIR, construction 

activities will have temporary adverse air quality impacts related to construction 

emissions of NOx and CO2. These pollutants result in impacts on a regional, rather than 

a local, level. Particulate matter emissions are not estimated to exceed the applicable 

state and federal thresholds. Location-specific best management practices and 

mitigation are effective in reducing the air quality impacts of construction, but depend on 

the specific construction activities, equipment being used, and scheduling. SANDAG will 

coordinate with affected tenants and landowners to identify and minimize possible air 

quality impacts during construction.
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15 The Draft SEIS/SEIR provides a generalized quantitative assessment of the expected 

noise and vibration effects that will occur throughout the corridor during construction, 

including along Genesee Avenue near the Westfield UTC shopping center, based on 

experience with other transit projects. The exact methods of construction may vary at 

different sites, and an important part of the assessment of construction impacts is to 

identify the noise and vibration control measures that will be required of the contractor

when appropriate. Location-specific measures are effective in reducing the noise 

impacts from construction. These project and mitigation measures are presented in 

Chapter 4.0, Section 4.17.3.2 of the Draft SEIS/SEIR under the heading "Noise and 

Vibration Impacts" and in Chapter 6.0, Section 6.17 of the Construction Impacts 

Technical Report. Noise levels at businesses will be similar to those at residences; 

however, commercial uses are less sensitive to nighttime construction noise because 

of the hours of operation for businesses and the type of business activity that occurs. 

Because they are less sensitive, commercial uses are not classified by FTA as noise 

sensitive. 

As discussed in response to Comment 4, the Genesee Avenue Design Option has 

been eliminated form further consideration, and further analysis for this option is not 

required.

16 Refer to the response to Comment 15 regarding noise impacts and mitigation. 

Noise and vibration impacts at Westfield UTC shopping center will not be significant 

after mitigation. Project measures to avoid or minimize impacts and mitigation 

measures have been incorporated into the project to reduce the noise generated 

during construction. There are no existing residential land uses on the Westfield UTC 

property within 350 feet (the noise screening distance to the rail tracks) of the project. 

The nearest residential use is Cluster 92, the Towers at Costa Verde Apartments, 

which will not experience a significant noise impact from the project. Commercial 

uses are typically less sensitive to noise because of the hours of operation for 

businesses and the type of business activity that occurs; therefore, they are not 

classified by FTA as noise sensitive. As described in Chapter 4.0, Section 4.17.3.2 of 

the Final SEIS/SEIR under the heading “Noise and Vibration Impacts”, with the 

implementation of mitigation measure CON3, vibration generated during construction 

will not result in damage risk to any of the buildings in the corridor, including those at 

the Westfield UTC shopping center. 

17 The comment has been noted. 

18 The comment has been noted. 

 
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