Category: Environment

The following letter was submitted this morning by Dr. Stephen Wheeler and the Sierra Club Yolano Group as formal comments for the Yolo 80 Draft Environmental Impact Report (DEIR), addressed to Dr. Masum Patwary, Environmental Scientist C at the California Department of Transportation. A copy was also sent to the Davis City Council. The letter concludes by stating that the Yolo 80 DEIR should be revised and recirculated.

Dear Dr. Patwary:

This letter provides detailed comments on the Yolo 80 Draft Environmental Impact Report (DEIR) on behalf of the Yolano Group of the Motherlode Chapter of the Sierra Club.

I have prepared these comments as an unpaid Technical Advisor to the Yolano Group. In my professional life I am a Professor of Urban Planning and Design in the Department of Human Ecology at the University of California, Davis, and Chair of the UC Davis Community Development Graduate Group. I have studied urban and regional planning topics for more than 35 years, including interactions between transportation systems and regional land use patterns, and was formerly chair of the City of Berkeley Transportation Commission and cofounder of the Bay Area’s regional transportation-land use-housing advocacy organization Transform. I am the author of urban planning textbooks used in universities worldwide, including The Sustainable Urban Development Reader (Fourth Edition, 2023), Planning for Sustainability (Third Edition to be published in late 2024), and Reimagining Sustainable Cities (2021). My awards in this field include the Dale Prize for Excellence in Urban and Regional Planning.

Let me say first that it’s very unfortunate that the Yolo 80 project has proceeded this far without better alternatives being considered. As has been widely known for decades, widening freeways does not fix congestion problems; it just defers them for a few years while increasing overall motor vehicle use, greenhouse gas (GHG) emissions, local air pollution, suburban sprawl, and related problems. The climate crisis gives particular urgency to the need to stop increasing road capacity and vehicle use. Although California is making progress in many sectors towards reducing its GHG emissions, transportation is one area in which it is not. Transportation is also the single largest source of the state’s GHG emissions, accounting for 38 percent of the total.

In order to meet California’s GHG reduction goals, the state has adopted policies that discourage road expansion and its concomitant VMT increases. SB 743, passed in 2013, required agencies to use VMT as a metric for analyzing transportation impacts of new projects after July 1, 2020 instead of Level of Service (LOS). Put another way, this bill made reducing overall motor vehicle use the goal of state policy rather than short-term reductions in road congestion. The California State Transportation Agency (CalSTA)’s Climate Action Plan for Transportation Infrastructure (CAPTI), adopted in 2021, establishes policy that “projects should generally aim to reduce vehicle miles traveled” and counsels agencies that “when addressing congestion, consider alternatives to highway capacity expansion such as providing multimodal options in the corridor, employing pricing strategies, and using technology to optimize operations.” However, Caltrans appears to be disregarding the state’s new policy framework with multiple projects including Yolo 80.

A certain amount of congestion isn’t bad in that it puts realistic constraints on the public’s behavior. However, if congestion is deemed to be a problem beyond that point, the academic and professional literature shows that pricing, better land use planning, and other demand management solutions (e.g. working with large employers to promote vanpools and transit use) are the best strategies. But Caltrans never considered those alternatives in the Yolo 80 case. It clearly wanted to widen the freeway from the start, and indeed appears to have illegally begun widening I-80 east of the Mace intersection and west of the I-50 split in early Fall 2023 well before the current environmental review was completed. This action  shows a high level of disregard for CEQA/NEPA processes, and we ask Caltrans to suspend construction activities on Yolo 80 until environmental review is completed and the environmental document certified.

The Yolo 80 DEIR has a great many deficiencies which require revising and recirculating the document. These include the following:

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By Alan Hirsch, YoloTD

As you read this, the lengthy draft Environment Impact Report (EIR) for the widening of I-80 has been released for public review (see I-80 Widening draft EIR now available). It was first promised in early 2021.

Readers should be warned not to take its results as truth, but rather as a forecast that has not been peer reviewed. The goal of public review of an EIR is to correct the deficiencies before the final document is completed and a decision to approve the project is made. If done accurately, the conclusions should inform government decision makers if the $330 million project‘s benefits outweigh the impacts.

These background facts and past Davis Enterprise reporting might be useful as you read the draft EIR:

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(From press release) I-80 Yolo Widening project’s draft environmental documents, including the draft Environmental Impact Report (EIR), are now available for public comment. This project is to improve mobility in the I-80 corridor and this environmental study compares cost/benefits of alternatives, primarily focused on adding 16 miles of freeway lanes in each direction between Dixon and the 50-80 split.

The draft environmental documents are available for review through the State’s CEQA Clearinghouse here: https://ceqanet.opr.ca.gov/2021060117/4

The public is encouraged to comment on the scope, alternatives (were enough considered?), assumptions, and methods of the analysis as described in these draft study documents. For example, were traffic noise and localized air pollution addressed and mitigated? Were impacts appropriately described and effectively mitigated? These draft documents include the first Caltrans EIR in Northern California that must conform to new state law SB743 (Steinberg). This new law requires environmental impact studies to focus on the climate impact described as the GHG from the changes in vehicle miles traveled. Traffic congestion is no longer considered an important factor in the environmental analysis.

The draft documents will also be posted on the Caltrans “Yolo80 Improvements” webpage: https://dot.ca.gov/caltrans-near-me/district-3/d3-projects/d3-i80-corridor-improvements. Yolo Transportation District (YoloTD) will post a link as well: www.YoloTD.org.

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Jeanie Ward-Waller, former Caltrans deputy director of Planning and Mode Development until she noted likely environmental violation on I-80 project

By Alan Hirsch, YoloMobility

News of a high-level Caltrans whistleblower hit the national media in recent weeks with stories in the Sacramento Bee, LA Times and Politico. But when you meet former Caltrans Deputy Director of Planning and Modal programs Jeanie Ward-Waller, you learn that she was forced out of Caltrans and into a public whistleblowing role by just one action.

She spoke via Zoom at a meeting of the Environmental Council of Sacramento (ECOS) on Thursday 10/19. In her opening remarks she said:

• She misses her colleagues of six years who are doing good work to evolve Caltrans.
• “We need good people in government.”
• Caltrans has an important role in maintaining our existing highways.
• Achieving a well-functioning transportation system is her life’s work and she misses being engaged.

She said her demotion and effective firing were a total surprise. Her story of how it happened started when she noted that Caltrans District 3 seemed to have misappropriated extra funds from a pavement rehab project to rebuild shoulders in a wider and more expensive way so that they could be easily converted to extra lanes. Technically it would not count as widening until the stripes for these lanes are painted. Widening the freeway had not been approved by elected officials or undergone the required public and environmental review process.  One thing she didn’t mention: the amount of misappropriated funds in question is likely on the order of tens of millions dollars — part of the $240 million I-80 Yolo Causeway pavement rehab project, which is separate from the I-80 widening project.

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Study: Average speed difference trivial if toll lanes added; HOV lanes don’t work.

By Alan Hirsch, Yolo Mobility 

If you read deeply and critically into Caltrans documents, you will often find a number of things  acknowledged- inconvenient truth not always shared with elected officials.

 City and County elected officials rely on agency staff to give honest and complete presentation of objective findings.  However, the reality is elected official are very vulnerable if an agency’s staff is committed to pursue a pre-ordained solution. Staff can bending their analysis or make strategic omissions of information in their presentation. These are rarely caught by elected official who don’t have time to read, much less understand the reports.

Then it’s up a rare whistleblower and or nerdy gadflies to protect the public interest by catching this, and making public comments to elected who otherwise don’t have time to read everything.

But in the end, it up courageous electeds, who are willing to both listen to the outsiders, and are then open to changing their minds, if the agency solution is be questioned if its pre-ordained solution is in the public good.

This manipulation of data  does come from all Government agencies, or even most, but this Machiavellian approach to public policy can hard backed  into  the culture of some.

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