Notice of Preparation for the State Route 25 Corridor Improvement Project

Dianna Beck, Senior Environmental Planner
California Department of Transportation (District 5)
50 Higuera Street
San Luis Obispo, California 93401
Diana.beck@dot.ca.gov

December 31, 2024

Re: Comments on the NOP for the State Route 25 Corridor Improvement Project

Dear Ms. Beck,

The Santa Clara Valley Bird Alliance (SCVBA, formerly Audubon Society) and the Sierra Club Loma Prieta Chapter work to protect natural resources and promote the enjoyment of nature in Santa Clara and San Benito Counties. We thank you for the opportunity to provide comments on the Notice of Preparation for the State Route 25 Corridor Improvement Project. To ensure a thorough and effective analysis, we recommend incorporating the following measures and considerations into the EIR.

Biological Resources and Habitat Conservation

The Notice of Preparation (NOP) identifies potential impacts to federally and state-listed species (e.g., California tiger salamander), nesting birds, wetlands, riparian habitats, and wildlife migration corridors. While the planned studies and consultations are commendable, the EIR must include the following:

1. Clear Criteria and Measures of Success for Mitigation:
   • Define measurable success criteria for mitigation efforts for species protection, such as habitat restoration goals, population trends, and reductions in barriers to wildlife movement.
   • Specify standards for wetlands mitigation, including replacement ratios, monitoring periods, and adaptive management actions for failures.
2. Fish Passage and Wildlife Migration Corridors:
   • Baseline conditions for fish and wildlife movement along Pajaro River and Carnadero Creek must be detailed.
   • Success metrics should include measurable improvements to connectivity and long-term monitoring plans to evaluate passage effectiveness.
3. Mitigation Monitoring and Reporting Program (MMRP):
   • Include a detailed MMRP in the EIR that links each mitigation measure to specific success criteria, monitoring timelines, and adaptive management triggers.
4. Agency Consultations:
   • Provide clear criteria and goals to guide consultations with the U.S. Fish and Wildlife Service, National Marine Fisheries Service, California Department of Fish and Wildlife, U.S. Army Corps of Engineers, and Regional Water Quality Control Board.
   • This transparency will ensure alignment among stakeholders and accountability in achieving mitigation goals.

Wildlife Connectivity and Lighting Impacts

1. Wildlife Crossings:
   • Identify key wildlife movement corridors and propose mitigation measures such as overpasses, underpasses, or culverts at strategic locations.
   • Install fencing along the highway to guide animals to safe crossing points and prevent wildlife-vehicle collisions.
2. Lighting Impacts:
   • Assess baseline light levels and identify species sensitive to light pollution.
   • Minimize light impacts by using downward-directed, fully shielded fixtures, and wildlife-friendly wavelengths (e.g., amber or red lighting). Specify the use of that are less disruptive to nocturnal species, such as amber or red lighting rather than white or blue light. The Correlated color temperature should not exceed 2700 Kelvin. In areas close to waterways, do not exceed 2400 Kelvin.
   • Incorporate motion-activated or dimmable lighting to reduce constant illumination during low-traffic periods.

Induced Traffic and Growth Impacts

Expanding roads often leads to induced demand, where increased capacity results in more vehicle miles traveled (VMT) rather than reduced congestion. This phenomenon, supported by studies such as Duranton and Turner (2011), also promotes sprawling development and contributes to environmental degradation.

1. Induced Demand Analysis:
   • Use tools like the California Air Resources Board (CARB) Induced Travel Calculator to estimate the increase in VMT and associated greenhouse gas emissions.
2. Growth-Inducing Impacts:
   • Evaluate how the project might encourage urban sprawl, leading to habitat loss and conversion of agricultural or natural lands.
   • Assess secondary impacts on infrastructure demands, such as water, energy, and local roads, stemming from potential growth.
3. Cumulative Impact Assessment:
   • Consider interactions with other transportation and development projects in the region to ensure a thorough evaluation of cumulative environmental impacts.

Conclusion

We urge Caltrans and its partners to incorporate these recommendations into the EIR to ensure a robust analysis of the project’s environmental impacts. Prioritizing wildlife connectivity, minimizing lighting impacts, clearly defining success criteria, and addressing induced demand will help mitigate potential negative effects and enhance the project’s environmental outcomes.

Thank you for considering these comments. We look forward to reviewing the Draft EIR and subsequent project updates.

Sincerely,

Shani Kleinhaus, Environmental Advocate
Santa Clara Valley Bird Alliance

Mike Ferriera, Chapter Chair
Sierra Club Loma Prieta Chapter