Paul Perkovic
Post Office Box 371149
Montara, CA 94037-1149
+1 (650) 728-9500

28 March 1995

Caltrans District 4
Office of Environmental Planning -- South
Post Office Box 23660
Oakland, CA 94623-0660

re: Draft SEIS/SEIR on the Noise Impact of the Devil's Slide Project

Ladies and Gentlemen:

In my opinion the Draft Supplemental Environmental Impact Statement / Supplemental Environmental Impact Report on the Noise Impact of the Devil's Slide (Route 1) Bypass Project in San Mateo County is fundamentally flawed. The draft report makes faulty assumptions about traffic behavior that call into question the projected noise levels of the project. The draft report fails to draw comparisons to the noise impacts of alternative alignments, which may make one of those alternatives a clearly preferable choice based on noise impacts. And, finally, the draft report completely ignores four major sources of environmental noise. Each of these concerns is considered in order below.

Faulty Assumptions About Traffic Behavior Affecting Projected Noise Levels

Section 4.2, "Future Traffic Volume Assumptions," on page 24 of the Appendix states: "A peak hour traffic volume of 1800 vehicles per hour per lane traveling at 55 mph was assumed. This traffic volume assumption is used by Caltrans to represent the maximum noise generating capacity of a roadway for a project of this type and location." It is obvious that whoever wrote this sentence has never driven on a California freeway, where, despite posted speed limits of 55 mph, traffic generally averages 65 to 70 mph. These much higher speeds are typical of traffic through Pacifica where there are two lanes in the same direction (as there would be for all uphill portions of the inland bypass route), and are also typical of traffic on the two-lane portions of State Route 1 south of Half Moon Bay. An honest evaluation based on actual driving speeds would produce higher average noise levels at all points evaluated.

A second faulty assumption is less clear from the document, but it appears that projected noise estimates are based on standard noise measurements of surface traffic. At the southern end of the proposed inland bypass, plans call for a long bridge over Martini Creek. Noise radiated from an elevated structure may echo from the surrounding hills and be focused on formerly quiet residental areas in Montara, or on areas in McNee Ranch State Park. This effect would be similar to the impact of the Shoreline Amphitheatre on Palo Alto residents many miles away. The draft report takes no account of increased distant noise.

Failure to Compare Impacts of Alternative Alignments

The 1986 Final Environmental Impact Statement considered three alternative alignments to provide a safe and dependable highway between Pacifica and Half Moon Bay. The purpose of an EIS is to investigate alternatives so that an informed choice can be made that optimizes necessary trade-offs between cost and environmental impact, as well as to identify areas where mitigation may be appropriate to reduce undesirable effects of a proposed project. The decision to select the inland bypass route was based on a flawed, incomplete EIS, which is why U.S. District Court judge Robert Peckham ordered Caltrans to prepare the present Draft SEIS / SEIR. It is the totality of findings in a correct and complete EIS, as updated and supplemented, that should form the basis for an honest and informed choice of alternatives.

All parties acknowledge that the 1986 FEIS is stale and must be re-examined. That re-examination may show that one of the alternative alignments, probably the tunnel bypass option, is superior in terms of cost, safety, environmental noise, maintainability, and ecological devastation. It would be prudent and forward looking for Caltrans to anticipate the need to compare noise impacts of the inland bypass with the tunnel option, and to perform that analysis now.

By totally disregarding the noise impacts of the other two alternatives contained in the original EIS, this Draft SEIS / SEIR fails to provide a complete picture of the alternative alignments. It is thus a dishonest report. The amended FEIS, as supplemented by the present study, must include the noise impacts of the alternatives. Only with the complete presentation of these noise effects, and the comparative costs of mitigation to bring the noise levels to acceptable levels for each of the alternatives, can a fair and honest choice be made.

First Ignored Source of Noise -- Construction

The first major source of environmental noise completely overlooked by the draft report is noise produced during construction -- a period expected to last several years. Public and private schools, businesses, and residences are all located near both the Pacifica and Montara ends of the proposed project. Caltrans' own estimates indicate that 5.9 million cubic yards of material must be moved from cuts through Montara and San Pedro mountains and compacted as fill. This is not Kansas, where graders can easily move topsoil to build a roadbed. It is likely that blasting will be necessary to break through the solid rock standing in the way of the proposed inland bypass. No noise estimates are given for blasting, nor are the psychological and physiological effects of sudden explosive noise intrusions on peaceful communities, especially among children, considered at all. In addition to the peak noise levels generated by necessary blasting during construction, the final report must also address the continuing increase in background noise produced by other construction activities.

As a resident of the area that will be disrupted for several years during construction, I want to know what the impact will be on my community. Even if formal environmental rules only require the continuing, long-term effects of a proposed project to be studied, I believe that local residents are entitled to be informed of the consequences of each alternative on our communities during the construction period. To the best of my knowledge, Caltrans has not made any information available to the community regarding construction impacts.

Second Ignored Source of Noise -- Emergency Vehicles

Appendix B1 of the Draft SEIS / SEIR, "Long-Term Noise Monitoring Results," records existing ambient and peak noise levels at seven observation locations along the proposed inland bypass route, performed over several months at dates selected by Caltrans. Along with sound levels, this appendix lists 158 observations of weather and wind conditions. Only 28% of these observations record clear weather. All of the rest -- 72% of the time -- conditions were either foggy, or foggy combined with drizzle, or foggy at times and clear at times, or just drizzle.

Appendix A of the Draft SEIS / SEIR, in Figure A1, gives the approximate noise level of an ambulance siren as 100 decibels.

Earlier in my comments we explored the actual driving speed of California motorists. Experience shows that higher speeds are most typical of commuters and other regular freeway users, who are familiar with every curve and hill and take every opportunity to pass the unfortunate out-of-state tourist who is plodding along at 45 mph, trying to read a map while coping with noisy children.

The obvious combination of a freeway designed to permit high-speed travel, along with fog or other adverse weather at least 72% of the time, is certain to lead to impatient commuters plowing into the rear end of an out-of-state Winnebago slowed to 30 mph because it is the first time the tourist has encountered fog. Perhaps we will be fortunate and not have 100-car pile-ups such as last week's massive wrecks on a bridge over Alabama's Mobile Bay; perhaps we will be fortunate and not have multi-fatality crashes in the fog, such as last year's disaster on Interstate 5. But every time we have a fog-related injury crash or fatality, we will have ambulances and police cars -- and sometimes fire engines and medical evacuation helicopters -- rushing through our quiet coastal communities. The noise impact of these almost-certain crashes resulting from the unfortunate siting of the inland bypass in a fog-shrouded mountain has not been addressed at all in the draft report.

In both of these cases, actual sound pressure levels of noise are not very important: What really affects people are what might be called psychological pressure levels. Explosive blasting sounds during construction may very well trigger flashback trauma in our veterans by reminding them of combat bombing.

Ambulance sirens produce vastly increased psychological stress, not linearly related to actual sound pressure levels, in persons who are awaiting the safe return of loved ones who are away from home and overdue; somehow, sirens summon uncontrollable visions of horrible crashes in the fog with one's children or husband or partner or wife screaming in pain, or dead, despite one's rational understanding that only a few persons per year are likely to be killed on the bypass under these frequently foggy conditions.

Third Ignored Source of Noise -- Slope and Bridge Failures

The proposed inland bypass route involves numerous cuts and fills, some of them 200 to 300 feet high. The mountain is made of the same rock that is slipping into the ocean at Devil's Slide, where Mother Nature has effectively produced a 300-foot "fill" on which the current roadbed gradually erodes. Similar rock will be shattered by blasting and moved to engineered fills of similar heights, where it will be subject to the same erosion processes as at Devil's Slide itself. United States Geological Survey maps showing landslide susceptibility indicate that the proposed area of construction is one of the most dangerous in San Mateo County. The history of Caltrans projects subjected to unusual weather conditions, such as this year's "100-Year" rains and flooding, is not good. Around the state at this very moment there are numerous roads closed because of landslides and slip outs -- all roads that were built by Caltrans, presumably using the same safety standards that would apply for the inland bypass route.

The eight-foot slip on Paradise Drive on the Tiburon Peninsula is greater than the actual slip this year on Devil's Slide. Highway 1 itself is closed north of Jenner. The Pacific Coast Highway section north of Santa Monica is also closed by landslides. The collapse of the Interstate 5 bridges over Arroyo Pasajero resulting in seven fatalities is an embarrassment to Caltrans. The inland bypass route has several bridges that are potential sources of collapse during unusually heavy rains or earthquakes.

The noise impact of rare events such as landslides in massive cuts, or collapse of compacted fill, or wash-out or collapse of bridges in major storms or an earthquake may be hard to evaluate, but these likely failures are certain to have a major impact on the nearby communities. The draft report fails to consider the noise produced by landslides and collapsing bridges, or the resulting 100-db noise of emergency vehicles necessary to attempt to rescue injured motorists.

This area of noise impact is particularly important to compare with the almost absolute safety of the inland tunnel alternative, impervious to rain and far less likely to be damaged by a severe earthquake.

Fourth Ignored Source of Noise -- Other Devastated Parts of California

The last source of noise I wish to address is political noise, important to consider for this project although perhaps out of scope for the SEIS / SEIR. Massive storms this winter have ravaged California, resulting in damages estimated at over $2 billion. Entire communities, such as those on the Monterey Peninsula, have been cut off as a result of flooding and road failures. Dozens of roads across the state are currently closed or significantly damaged.

At the same time, California is still trying to recover from the highways that failed during the Loma Prieta and Northridge earthquakes, and needs hundreds of millions of dollars for earthquake retrofitting. Just the first phase of the Golden Gate Bridge project has been estimated at $165,000,000.

The existing road over Devil's Slide will be repaired and reopened, as it was in 1983 and in earlier years. That road will again provide reliable service sufficient for the needs of our communities, at least until the next major storm. The obvious fact that California mountain roads are subject to periodic, recurring closure from landslides and slip-outs during severe weather confirms the observation that these are predictable events that should be budgeted out of a routine maintenance fund. Characterizing such events as "emergencies" and seeking special funding is, fundamentally, dishonest. Failure to factor in likely continuing maintenance and repair costs for roads built in landslide-prone areas artificially conceals the true costs of those roads. It is fundamentally fraudulent. Projects that are unjustifiable when all likely costs are considered, may nevertheless be built anyway by concealing those costs and raiding the taxpayer later.

According to Caltrans 1993 traffic volume studies near Devil's Slide obtained by telephone yesterday, the closest observations are north and south of the slide:

    Community   Location               Milepost  Daily Average  Peak Hour
Moss Beach San Pedro Road 40.75 18,000 2000 Linda Mar Vallemar / Etheldore 35.34 14,700 1600

Accurate commuter traffic counts and times of peak hour traffic are not given. Taking the larger traffic figures, assuming two-hour commute periods with the peak volume both hours, and distributing the remaining traffic volume over the entire day, we can surmise that the maximum credible number of commuters using the Devil's Slide route is 3000 twice a day (once in each direction), with an average background casual traffic volume (shoppers, tourists, visitors) of 250 vehicles per hour in each direction. [The suggested analysis produces 250 vehicles per hour per direction times two directions for 24 hours, or 12,000 trips, plus 1500 vehicles per hour for two hours, northbound in the morning and southbound in the evening, for 6,000 trips, totalling 18,000.]

As a gross check on this analysis, it predicts about one vehicle each direction every 15 seconds during non-commute hours, and about one vehicle every 2 seconds in the commute direction during commute hours. These predicted numbers seem reasonable in comparison with observed experience.

The existing coastal alignment is safe and typically traversed at about 45 mph, or approximately 5 minutes per trip. The proposed inland bypass route is unsafe in fog and may be posted at 55 mph, but in reality (as argued earlier) drivers are likely to average 65 mph, or approximately 4 minutes per trip, when they are not backed up by accidents, landslides, or other road closures. The time savings per commuter per day are thus about 2 minutes in travel, or about 8 hours over a 240-work-day year. Thus, over a 10-year period, taking the high assumption of 3000 commuters using the route and the maximum daily time savings from a realistic driver speed of 65 mph, the aggregate benefits from the project amount to a savings to commuters of 240,000 hours. If we actually trust that the bypass can be built for the projected $73,000,000, without exceeding estimates at all, over the same ten-year period the project, together with interest on the resulting Federal debt (using today's 30-year Treasury bond rate of 7.36%), the inland bypass will cost taxpayers over $148,000,000. A quick cost/benefit computation shows that the inland bypass will cost taxpayers over $600 per hour of commuter time saved. This is an unconscionable cost!

In a period of incredible emergency demand for funds and nearly non-existent sources, how can Caltrans morally justify going forward with a $73,000,000 project when a safer, less-expensive, more environmentally sensitive, far less noisy alternative -- estimated to cost $60 million -- is available, namely, the inland tunnel bypass? Extravagant waste of millions of dollars might have been acceptable when California was running a budget surplus, but in these trying times, it is more important than ever to find the most cost-effective solution.

Other communities are crying out for help. Can we ignore their cries and spend at least $13,000,000 needlessly? Political sensitivity demands sharing the available resources equitably in this time of need.

Sincerely yours,

/s/ Paul Perkovic