November 13, 2014
Joseph E. Weiland, P.E.
OMNI-MEANS, Ltd.
943 Reserve Drive, Ste. 100
Roseville, CA 95678
SUBJECT:
Evaluation of the CEQA/NEPA Compliance Process for the SR 1/SR 41/Main Street Intersection
Project, Morro Bay, San Luis Obispo County, California
Dear Mr. Weiland:
Attached please find our preliminary analysis of the environmental compliance process that would be necessary
to evaluate the SR 1/SR 41/Main Street Intersection Project (project) in compliance with the requirements of the
California Environmental Quality Act (CEQA) and National Environmental Policy Act (NEPA).
Thank you for providing us with the opportunity to work with you. Should you have any questions regarding the
attached, please contact me at (805) 543-7095, extension 6814.
Sincerely,
Emily Creel, JD
Environmental Planner
Attachment: Evaluation of CEQA/NEPA Compliance Process
OMNI-MEANS, LTD.
SR 1/SR 41/MAIN STREET ROUNDABOUT FEASIBILITY
SR 1/SR 41/MAIN STREET INTERSECTION
ENVIRONMENTAL COMPLIANCE EVALUATION
SWCA Environmental Consultants (SWCA) has prepared this feasibility evaluation to outline the processes
that would be required to complete environmental review and clearance of the SR 1/SR 41/Main Street
Intersection Project (project) in compliance with the California Environmental Quality Act (CEQA), National
Environmental Policy Act (NEPA), and other applicable regional, state, and federal laws and regulations.
The City of Morro Bay would be responsible for implementing CEQA as the Lead Agency. For purposes of
the analysis, we have also assumed that the City would obtain federal funding for the project, thereby
triggering requirements for NEPA compliance and coordination with the California Department of
Transportation’s (Caltrans) Local Assistance Program.
The environmental compliance process outlined in this evaluation assumes that the project would
generally be limited to the areas shown in Figure 1, below. Substantial design changes or expansion of the
project footprint may implicate additional environmental issues (i.e., disturbance further south within the
channel or banks of Morro Creek would require additional regulatory permits and technical
documentation; disturbance within a public park or recreation facility will trigger additional Caltrans’
requirements in accordance with Section 4f of the U.S. Department of Transportation Act of 1966).
Our analysis of the project’s requirements under CEQA and NEPA are set out separately below.
Figure 1. Project Area
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ENVIRONMENTAL DOCUMENTATION AND COMPLIANCE
CEQA Compliance Overview
It is anticipated that the appropriate environmental clearance document under CEQA would be a
Mitigated Negative Declaration (MND). The City previously completed an MND for the project in 2002,
which could largely be utilized in drafting an updated MND for the current project. The updated MND
would be revised to account for changes in site conditions/resources and new regulatory and legal
requirements.
The first step in preparing an adequate MND will be to develop a thorough and detailed project
description. Based on preliminary discussions with Omni-Means, we understand that the City is
considering two design alternatives for the intersection: a signalized intersection and a roundabout. Both
alternatives can be considered in equal detail in the MND, so that the decision makers have the necessary
CEQA coverage in place should they ultimately decide to approve either alternative. Specific project
details that should be flushed out in the project description include, but are not limited to: maximum
disturbance footprint, maximum depth of grading, proposed construction methods, haul trips, anticipated
length of construction activities, traffic/bike/pedestrian detour plans and routes, and staging areas.
SWCA has reviewed the 2002 MND to determine what updates/revisions would be necessary to meet
current standards. We have also conducted a reconnaissance-level field survey of the project site and
noted significant changes in the existing environmental baseline that should be reflected in the updated
MND. Each issue area required to be addressed under CEQA (per the City’s Initial Study Checklist and
Appendix G of the CEQA Guidelines) is identified in the table below, and recommendations have been
made regarding what would be necessary to update the relevant information. Although the feasibilitylevel evaluation below concludes that some issue areas have been adequately examined in the 2002 MND
and do not need substantial revision or additional analysis, the information presented in these sections
should be closely examined during preparation of the updated MND, to ensure accuracy and consistency
with current planning documents and regulations.
No new technical studies were identified as being necessary to complete the MND; however, as described
in further detail below, the MND would benefit from implementation of the technical documentation that
would be required by Caltrans for NEPA compliance. If the project schedule can accommodate it, the
updated MND should incorporate the information and findings of these reports to provide as much
information to the public and the decision makers as possible.
The evaluation (including anticipated costs and schedule) set out below assumes that the MND will be
prepared using the City’s template, and that the Caltrans template would not be required. Because the
project is on the State highway system, however, Caltrans will likely review the MND prior to circulation.
Table 1. CEQA Issue Area Approach
Issue Area
Necessary Evaluation Approach
Aesthetics
No updates to this issue area would be necessary. No significant changes in the existing
visual setting have occurred and the potential impacts of the proposed intersection
modifications would be generally similar to those addressed in the previous MND. The
analysis in the 2002 MND is accurate and adequate under current standards.
Agricultural
Resources
No updates to this issue area would be necessary. The project area consists of a major
intersection and other transportation infrastructure in an entirely urbanized area. The
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closest agricultural uses to the project site are located approximately 0.2 miles to the
east, on the opposite side of Morro Creek. The analysis in the 2002 MND is adequate
under current standards.
Air Quality
Update to issue area would be necessary. The proposed project would generally
improve air quality by reducing traffic congestion and improving operations at the
intersection. However, short-term construction impacts would occur as a result of
earthmoving activities, operation of heavy construction equipment, and additional
construction-related traffic trips. Therefore, the CEQA analysis is expected to be largely
consistent with that provided in the 2002 MND. However, the information in this section
should be updated to reflect current guidance on the evaluation of air quality impacts
under CEQA, including the San Luis Obispo Air Pollution Control District’s CEQA
Handbook (updated April 2012). Identified mitigation should be revised to reflect current
standard dust reduction and emission control measures, as appropriate.
It is likely that a technical analysis of construction-related air quality impacts and GHG
emissions will be required by Caltrans, as discussed below; this analysis should be
incorporated into the MND.
Biological Resources
Update to issue area would be necessary. Based on an SWCA reconnaissance survey on
November 7, 2014, virtually all of the project site is disturbed. The NRCS maps
Psamments and Fluvents (flood plain/river bottom sediments) as the native soil type in
the area, but it appears that much of the area around the existing on- and off-ramps are
fill consisting of road base and some type of loam/loamy sand. There are no coastal
dune scrub associates in the area. Based on the lack of baywood fine sand, lack of
coastal dune scrub vegetation, the native sediments, and various fill soils in the area, we
do not believe there is any potential for Morro shoulderband snail (MSS) to occur at the
site. SWCA would recommend that the City prepare a MSS Habitat Assessment for the
project and seek concurrence from U.S. Fish and Wildlife Service (USFWS). This section of
the 2002 MND should be updated to reflect the likely absence of MSS at the site.
Avoidance measures recommended in the previous MND are not likely to be necessary.
Based on the field survey, it does not appear that any features indicative of water of the
U.S or state occur in the area. There are a couple of drainage inlets that likely flow to
Morro Creek, but it is unlikely they would qualify as jurisdictional waters. Therefore,
additional mitigation requirements are not anticipated in this area. The 2002 MND’s
analysis of potential impacts to nesting birds as a result of tree and vegetation removal
remains applicable to the current project. The analysis and appropriate mitigation
measures should be incorporated into the revised Biological Resources section of the
updated MND.
Cultural Resources
Update to issue area would be necessary. The project is located in an area of high
cultural sensitivity, with numerous documented occurrences of prehistoric archaeological
resources adjacent to the existing intersection and in surrounding areas. This section
should be updated to incorporate any additional information available since 2002
related to the extent of cultural resources in the area (i.e., cultural resources studies
prepared by Caltrans or private developers along Highway 41). The maximum depth of
grading in all portions of the project area and the minimum extent of artificial fill
material should be specifically detailed in the updated MND to clearly reflect any
potential disturbance to underlying native soils. If the MND is completed on or after July
1, 2015, this section will also need to implement the requirements of newly-enacted
Assembly Bill (AB) 52, which created a new category of cultural resources that must be
considered under CEQA and established new rules for consultation with California Native
American tribes. As discussed below, Caltrans will likely require technical documentation
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of this issue area (preparation of an Archaeological Study Report); this information
should be utilized in the MND to provide as much non-confidential information to the
public as possible regarding the project’s potential to disturb or otherwise affect cultural
resources.
Geology and Soils
Update to issue area would be necessary. Existing conditions related to the geologic
and soil characteristics of a site do not generally change over time absent the occurrence
of a significant natural event or development (i.e., a major earthquake, or substantial
grading/excavation/loss of topsoil). Therefore, the analysis in the 2002 MND generally
remains accurate. Minor updates should be made in the revised MND to reflect current
building codes and standards, including the most current version of the Uniform
Building Code and applicable highway design standards.
Greenhouse Gas
Emissions and
Climate Change
Update to issue area would be necessary. In addition to Air Quality, current legislation
and programs aimed at addressing climate change in California, including Assembly Bill
(AB) 32, Senate Bill (SB) 97, and SB 375, require that CEQA analyses consider greenhouse
gas (GHG) emissions and climate change. The MND would need to be updated to
include a section on GHGs and climate change. This section would likely include a
qualitative analysis of GHG emissions. It is anticipated that the build alternatives would
improve traffic congestions and reduce idling, and therefore result in less GHG emissions
than no-build conditions. It is likely that a technical analysis of construction-related air
quality impacts and GHG emissions will be required by Caltrans; this analysis should be
incorporated into the MND.
Hazards and
Hazardous Materials
Update to issue area would be necessary. The project area is immediately adjacent to
two gasoline service stations, including one with documented soil and groundwater
contamination due to a leaking underground storage tank. The project site also likely
contains various surface and soil contaminants associated with heavy vehicular use in the
area, including fuels, oils, heavy metals, and lubricants. This section should be revised to
account for the potential disturbance of hazardous materials and/or substances in the
project area. It is likely that Caltrans will require preparation of a Phase 1 Initial Site
Assessment (and based on the results of the Phase I ISA, potentially also a Phase 2
Preliminary Site Assessment) for the project. The findings of the Phase 1 ISA (and Phase
2 PSA, if necessary) would be beneficial disclosures to the public in the CEQA document,
and should be incorporated into this section.
Hydrology and
Water Quality
No updates to this issue area would be necessary. It is expected that the information
contained in this section is predominantly adequate for use in the updated MND. The
site is within the 100-year floodplain and existing drainage conditions have not
substantially changed since 2002. This section should be reviewed to ensure the project
conforms to current standards associated with drainage and stormwater flows. Standard
mitigation similar to what was identified in the 2002 MND should be included to avoid
potential impacts associated with erosion, sedimentation, siltation, and stormwater flows.
Land Use and
Planning
Update to issue area would be necessary. Although no changes in the findings made in
the Land Use and Planning section of the MND are anticipated, this section should be
updated to reflect current plans and policies applicable to the proposed project. Both
build alternatives should be analyzed for consistency with applicable policies related to
the need for improvements at the SR 1/SR 41/Main Street intersection.
Noise
Update to issue area would be necessary. Consistent with the analysis in the 2002 MND,
the project would not generate additional traffic or create any additional long-term
noise source. Therefore, the analysis in the 2002 Noise section would generally be
adequate for use in the updated MND. The information in this section should be
reviewed and updated, as necessary, to incorporate updated noise contour
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measurement information (if available) and standards. The number and location of
nearby sensitive receptors should also be confirmed and updated, as necessary. It is
likely that Caltrans will require technical documentation on this issue area; this projectspecific information should be incorporated into the updated MND.
Population and
Housing
No updates to this issue area would be necessary. The project would replace an existing
intersection with similar public transportation infrastructure within areas of existing right
of way. No effect on regional populations or housing would occur, and no changes to
the Population and Housing analysis would be necessary for the current project.
Public Services
No updates to this issue area would be necessary. No change in the evaluation of Public
Services would be necessary for the current project. The 2002 MND adequately states
that the project would replace existing intersection with similar infrastructure and would
not result in any substantial change in use that would impact fire or police protection
services or other public services. No revisions to this section would be necessary.
Recreation
Update to issue area would be necessary. The 2002 MND adequately evaluated longterm impacts on parks and recreational resources (bike and pedestrian crossings) in the
project area. No change in the evaluation of long-term impacts would be necessary for
the current project. However, revised project plans should be reviewed to confirm
adequate bike and pedestrian access through the intersection is provided at project
completion and short-term construction impacts on bike and pedestrian use of the
project area should be evaluated. If not provided for in the project description,
mitigation measures ensuring adequate access and safety for bike and pedestrian uses
during the period of construction should be incorporated.
Transportation and
Traffic
Update to issue area would be necessary. Similar to the 2002 project, the current project
would serve to improve traffic in the project area and surrounding roadways. This section
should be updated to incorporate any available traffic modeling completed for the
current project. The impact analysis should be revised in consideration of new legislation
regarding the evaluation of traffic effects, including, in particular, Senate Bill (SB) 743,
which focuses on the reduction of GHG emissions and the creation of multimodal
networks rather than the traditional Level of Service (LOS) metric. Potential short-term
construction-related impacts should be fully disclosed, including possible detour routes,
effects on the availability and ease of access to adjacent properties and businesses, and
impacts to adjacent parking.
Utilities and Service
Systems
Update to issue area would be necessary. The project would likely require the relocation
of existing utilities; however, project implementation is not expected to generate
significant additional demands on waste, wastewater, or water systems and
infrastructure. Nevertheless, this section should be expanded to include additional
evidence of adequate capacity at regional landfills to accommodate
construction/demolition waste and adequate public water supplies to meet construction
and irrigation needs.
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NEPA Compliance Overview
For purposes of examining what level of environmental review would be required for the project, we have
assumed that the City would obtain federal funding for the project, thereby triggering requirements for
NEPA compliance and coordination with Caltrans’ Local Assistance Program.
The first step in coordinating NEPA review with Caltrans is completion of the Preliminary Environmental
Study (PES) Form. The PES form is required for almost all federal-aid transportation projects and is
designed to provide the early coordination needed to determine the appropriate level of analysis,
required technical studies, and appropriate NEPA action/document.
It is anticipated that the appropriate NEPA document will be a Categorical Exclusion (CE) with required
technical studies. In our experience, Caltrans generally prepares its CEs in-house, and we anticipate this
will be the case with this project. The City and/or its consultants should be prepared to provide any
necessary assistance to Caltrans to support the CE and to inform Caltrans immediately if any unexpected
circumstances arise that would potentially take the project out of the CE and require a more involved
NEPA document.
SWCA has provided a brief description of the various technical studies anticipated to be required for the
project based on our experience with similar transportation projects, Caltrans Local Assistance
requirements, and the background information provided by the City. The list of technical studies
recognizes that the project would be considered “on system” due to its location on the State Highway
System and the involvement with SR 1 and SR 41. The project would also likely be considered a “Type 1”
project, which is a designation applied to projects that include a physical alteration of the vertical or
horizontal alignment of an existing highway. In this case, it is presumed that minor alterations to the
vertical and/or horizontal alignment of SR 41 and/or the SR 1 on- and off-ramps at the project
intersection would be necessary. The Type 1 designation will apply to a project even if the vertical or
horizontal alteration is minimal, thereby triggering additional requirements and documentation related to
potential noise impacts.
It is important to note that this list of technical studies is only preliminary; the scope of work for the
technical studies must ultimately be signed off on by Caltrans after review of the project and a field visit.
The following studies are expected to be required for the project in support of the CE, and are listed
below in the order shown on the PES form.
Table 2. NEPA Technical Documentation
Technical Document
Comments
Traffic Study
A Traffic Study is generally required when a project may impact a State
highway facility. Caltrans guidance generally recommends that existing
traffic studies be updated if two or more years have passed since the
time of preparation. Therefore, an updated study for the project should
be prepared.
Noise Study Report (NSR)
The project is likely to be considered a Type 1 project; therefore, an NSR
would be required. The NSR would evaluate construction-related and
projected future noise levels.
Noise Abatement Decision Report
This would be required if the NSR identifies existing or modeled future
noise levels at any proximate sensitive receptor that would exceed
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(NADR)
established land use-based Noise Abatement Criteria.
Air Quality / Climate Change
Memorandum
This memorandum would be prepared to identify and document
potential construction-related air quality impacts.
Phase 1 Initial Site Assessment
The ISA would evaluate the potential for soil or groundwater
contamination related to the possible current or past use, storage, or
handling of hazardous materials on or near the project area.
Phase 2 Preliminary Site
Assessment
If identified as necessary by the Phase 1 ISA, the Phase 2 PSA could
require sampling of soil, groundwater, building materials, or air to
determine the degree or extent of any contamination that may be
encountered at the project site.
Coastal Zone Consistency
Determination
Due to the project’s location within the Coastal Zone, a Coastal Zone
Consistency Determination would be required to address project
consistency with the California Coastal Act and the City’s Local Coastal
Program (LCP). The memorandum would be submitted to the City and
Caltrans to initiate consistency consultation with the Federal Consistency
Unit of the California Coastal Commission.
Location Hydraulic Study
Caltrans will require preparation of a Location Hydraulic Study due to
the project’s location within 100-year floodplain. This task is typically
completed by the engineering team.
Summary Floodplain
Encroachment Report
A Summary Floodplain Encroachment Report is expected to be
appropriate due to an anticipated finding of minimal encroachment into
100-year floodplain.
Natural Environment Study
(Minimal Impact) (NES[MI])
We do not anticipate that the project would result in significant effects
on biological resources and/or that anything more than simple
avoidance and/or minimization measures would be needed to avoid
impacts. It is also anticipated that no regulatory approvals or permits
would be required from the U.S. Fish and Wildlife Service or California
Department of Fish and Game. Therefore, we believe an NES (MI) would
be appropriate to document potential impacts on biological resources.
Because we do not anticipate potential impacts on listed species, we do
not believe preparation of a Biological Assessment will be required.
Similarly, based on a preliminary site evaluation, we do not believe the
site supports jurisdictional water features; therefore, we don’t believe a
Wetland Delineation and Assessment would be required.
Visual Impact Assessment (VIA)
Checklist
Completion of the VIA Checklist is the first step in evaluation potential
visual impacts of a project. The VIA Checklist will determine the level of
additional documentation that would be required for visual impacts.
Minor VIA
Because of the project’s location in a highly visible area, with a high
number of public views from SR 41 and SR 1, and its scenic importance
as a “gateway” to the City, it is possible that a Minor VIA will be required.
Visual simulations are not always required in a Minor VIA; however,
Caltrans may request that they be included due to the sensitive visual
nature of the site.
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Land Use and Community Impact
Memorandum / Assessment
SR 1/SR 41/MAIN STREET ROUNDABOUT FEASIBILITY
The roundabout alternative would likely require right-of-way
acquisitions at three adjacent private properties, including the existing
Chevron gas station south of SR 41 and the two parcels east of Main
Street and north of SR 41 (one vacant, one planned for a Sonic Burger).
No relocations would be necessary and the right-of-way acquisitions are
not expected to substantially interfere with the economic viability of
these parcels.
Construction activities could affect visibility and accessibility of
surrounding businesses, and could also require temporary closure of the
SR 1 on- and/or off-ramps. The project would also likely involve the
relocation of public utilities. Therefore, Caltrans may require preparation
of a Community Impacts Assessment or Land use and Community
Impacts Memorandum to address and document these potential
impacts.
Area of Potential Effects (APE) Map
To comply with the National Historic Preservation Act (NHPA) Section
106, the preparation of an APE map that includes a delineation of the
area of direct impact and area of indirect effects will be required. The
APE map will serve as the study area boundary for archaeological and
historic resources.
Archaeological Survey Report
(ASR)
Unless previous surveys that cover the entire APE can be utilized,
Caltrans will require an intensive-level archaeological survey of the area
of direct impacts and preparation of an ASR. The ASR will also include a
records search and Native American coordination.
Historic Properties Survey Report
(HPSR)
Upon completion of the ASR, a short-format Caltrans HPSR should be
prepared according to Caltrans’s current guidance. The HPSR is the
overarching document that summarizes the results of the cultural
resources investigation; it will include a project description, a description
of the APE, details of coordination with Native American
groups/individuals as well as local government and historic groups, a
summary of identification efforts, information regarding any properties
identified within the APE, a list of attached documentation, and the
findings of the study.
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