November 17, 2010

Caltrans District Office

4050 Taylor Street
San Diego, CA 92110

Email: I-5_NCC_EIR_EIS@dot.ca.gov

SUBJECT: COMMENTS ON DEIR FOR PROPOSED I-5 WIDENING PROJECT

This is a joint response, from the Buena Vista Audubon Society, the San Diego Audubon
Society, and Preserve Calavera, to the public review and comment period regarding the Draft
Environmental Impact Report (DEIR) for the I-5 Expansion Project. The proposed I-5
expansion involves construction of four or six new traffic lanes in addition to the existing
eight lanes, along with associated overpasses, access ramps, and retaining/noise walls. The
project would take place, on 27 miles of I-5 from La Jolla to Camp Pendleton, over a period
of 40 years, at a cost of $3-4.3 billion. The stated purpose is the relief of traffic congestion.
The following are our comments on the DEIR and the specific environmental impacts of the
project.

Traffic Circulation

Adding travel lanes will relieve traffic congestion in the short term but studies have shown
that similar problems will occur in the long term, and, therefore, it is not an efficient use of
the enormous sums of money involved. A freely running freeway creates “induced demand”,
as it attracts traffic from other routes and encourages individuals and businesses to make
greater use of the freeway. A permanent solution to traffic congestion on I-5 should involve
funding of a program that: 1) encourages and facilitates the use non-motorized alternative
means of transportation, where possible; 2) upgrading of public mass transit; and, 3)
implementation of various traffic management and demand strategies.

Due to the proposed project’s inability to address traffic congestion in the long term, and due
to the project environmental impacts, including the emission of greenhouse gases and
contribution to climate change, we recommend among the Alternatives evaluated in the
DEIR, the “No Build Alternative” and the “Traffic System Management and Traffic Demand
Management Alternative” which would help to reduce traffic volumes.

However, the DEIR is deficient in not also including a “Public Transit Alternative” which, if
funded appropriately and designed to better meet the transportation needs of the region, could
also greatly alleviate congestion problems on the freeway. Public mass transit could take the
form of improvements to the Coaster with connecting transportation, expansion of light rail,
and express and shuttle buses. Transportation System Management strategies include using
the existing facilities to maximize efficiency, such as promoting ridesharing and providing
rideshare services such as vanpools, parking, traffic system optimization, to improve traffic
flow and increase the number of vehicles trips the road can carry without increasing the
number of lanes. Transportation Demand Management strategies would reduce the number of
vehicle trips and miles traveled through the promotion of telecommuting, change of work
schedules to even out the pattern of vehicle use on the road, muting the effect of the morning
and afternoon rush hours. We urge that the EIR not be certified in its current form and that it
be recirculated with these alternatives analyzed, and compared with the more damaging
alternatives that are in the current draft for their mid and long term impacts.

Visual Impacts/Aesthetics/Community Character

The I-5 corridor in the project area is the northern gateway to the San Diego region and is
unique as a coastal freeway with ocean views. It traverses coastal communities with
expansive views of river valleys, coastal lagoons, beaches, scenic hillsides, and Torrey Pines
State Reserve, with low density development and open space near these natural features. The
I-5 passes through a number of cities which have designated the I-5 as a protected view
corridor because of the importance residents place on these scenic qualities. The trees and
median and slope vegetation along the freeway provide positive visual impacts, as well as
sequester pollutants. Large structures such as retaining walls and noise walls are currently
largely absent from the corridor. However, the road expansion project would introduce a
greater mass of roadway and an array of road infrastructure that would transform this scenic
corridor into an urbanized concrete-dominated arterial characteristic of the Los Angeles
region. The proposed concrete retaining walls, sound walls (up to 45 feet in height), and
direct access overpasses, would obscure ocean views and other scenic features from both I-5
travelers and the nearby and distant communities, and would have a significant impact on the
visual and community character of the area. The walls would create a tunnel effect that would
obscure the region’s unique visual identity and character. The sound walls will also tend to
obstruct bird flights from one side of the freeway to the other. The need for these sound walls
alone should preclude this approach. How will Caltrans address the above concerns on visual
impacts?

Air Quality/Climate Change

Motor vehicle emissions contain a number of pollutants that adversely affect human health
and natural ecosystems. These emissions represent the most significant source of “ultrafine”
particles which have shown to be more toxic than the larger particles. Studies published in
the Journal of Air and Waste Management Association and in Atmospheric Environment
show that proximity to a major freeway dramatically increases exposure to ultrafine particles
which are linked to neurological changes, pulmonary inflammation, and cardiovascular
problems. USC researchers found that children living within 82 yards of a major road had 50
percent greater risk of exhibiting asthma symptoms than those living more than 328 yards
away. Asthma is a major cause of hospital admissions in children. Asthma that begins in
childhood by exposure to ultrafine particles usually becomes a medically costly, lifelong
condition. This condition limits physical activity which subsequently contributes to
childhood obesity – another preventable epidemic. Research by UCLA scientists published in
the journal Atmospheric Environment indicates that air pollutants from LA Interstate 10 in
Santa Monica extend more than 1.5 miles downwind, further than previously thought. The
increase in vehicle volume will significantly increase impacts on air quality. This in turn will

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result in adverse health effects which disproportionately imperil our most vulnerable
populations of children and the elderly.

The I-5 expansion project would ultimately result in increases in greenhouse gas emissions
from both the massive construction and increased freeway use. It is therefore not consistent
with national and state goals to reduce greenhouse gases from vehicle use. Everywhere in the
country, individuals and governments are looking for ways to reduce their carbon footprint.
They are doing this to address climate change and global warming, and its potential
devastating effects on human populations, as well as native wildlife. The DEIR states that
because stop-and-go traffic is reduced in the short term from the added lanes, greenhouse
gases will decline after project completion. However, the DEIR disregards studies that
indicate that in the long term the added lanes will encourage more vehicle use, more high
speed traffic and eventually more stop-and-go traffic and, therefore, more greenhouse gases
will be released into the air. How will Caltrans address the above concerns on air quality
impacts?

Biological Resources and Water Quality

The road widening would impinge upon and impact a number of sensitive natural areas that
contain habitat and wildlife that are both state and federally protected, and of regional
significance. The project would impact the major coastal wetlands in the North County
region as it crosses five lagoons, San Dieguito Lagoon, San Elijo Lagoon, Batiquitos Lagoon,
Aqua Hedionda Lagoon and Buena Vista Lagoon, and is situated adjacent to Los Penasquitos
Lagoon and Marsh Preserve. It also crosses rivers and creeks that terminate in the ocean and
provide wildlife corridors from inland San Diego County to the coastal region, including Los
Penasquitos Creek, Carmel Valley Creek, San Luis Rey River, Cottonwood Creek, Loma Alta
Creek and Encina Creek. Cottonwood Creek, that has steeply sloped banks and runs parallel
to I-5, will be severely impacted by fill and other earth moving activities involved in
construction. Because of the historical loss of wetlands in the Coastal region due to
development, the impacts to these wetlands are individually and collectively significant.

The coastal wetlands and adjoining uplands support a variety of sensitive habitats and the
wildlife that depend on them. The wetlands support a year-round resident bird population that
is attracted to these highly productive marshes and riverine systems. Because the coastal
wetlands are located on the Pacific flyway, they also provide feeding, resting, and breeding
grounds for migratory bird populations. The expansion of the additional lanes and supporting
infrastructure will result in a significant loss of wetland habitat and a degradation of that
habitat during the construction phase and upon completion due to ultimate increases in the
volume of traffic. These coastal wetlands will also be significantly affected by water
pollution from freeway runoff and from the aerial deposition of contaminants from vehicles,
including copper, tire particles, oil leakage, and litter, that will be deposited in the lagoons by
the increased vehicle traffic. Even if totally effective capture and cleansing of runoff water is
incorporated into the project, it will still have a significant unmitigated water quality impact
due to the airborne deposition of contaminants and litter that will result from the additional
traffic.

During construction, the excavation of soils and other earth moving activities adjacent to the
road will release residues of a variety of pollutants, including but not limited to, petroleum
hydrocarbon particulate matter and aerosols, and lead. These toxic substances have
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accumulated over the years in soils adjacent to freeways. When disturbed, they
will quickly find their way into the lagoon food chain and, during tidal flushing, could also
affect ocean organisms. These are harmful substances that persist and accumulate in the
environment due to incomplete degradation, and bio-concentration in the food chain, which is
aided by their solubility in lipids and fats. Many are known to be genotoxic and carcinogenic
to aquatic organisms. Also during construction, earth moving activities will result in silt
containing soil nutrient movement into the wetlands causing excessive sedimentation in the
lagoons and contributing to algal blooms in the lagoon and ocean. These water bodies,
already overloaded at current pollutant levels, are subject to anoxic conditions.

As traffic volumes increase on I-5 over time to fill the added lanes, the adjacent wetlands will
receive greater quantities of pollutants released from vehicles. In addition, there will be
ongoing project impacts to wetland wildlife from elevated noise levels, greater amounts of
light pollution from freeway and vehicle lighting, and increases in litter and debris. Any one
of these impacts could interfere with the life cycles of wetland organisms, including feeding
patterns, breeding, and overall physiology. How will Caltrans address the above concerns on
biological and water quality impacts?

Piecemealing of CEQA Review

The widening of I-5 along Buena Vista Lagoon cannot occur without addressing the
interchange of I-5 and I-78. The combined impacts from these two projects will be much
greater than those of the widening itself. The full impacts of the two projects need to be
considered, so it is possible to determine that project alternatives are both feasible and reduce
the combined impacts. It is a violation of the CEQA process to artificially divide a project
into smaller components that appear to reduce the impacts, but that in fact could result in an
even more damaging project when the full project is considered. How will Caltrans address
these concerns?

Indirect Impacts to Agriculture

The DEIR has failed to adequately consider the cumulative impacts of this project on
Agricultural Resources. Carl Bell, Director of the San Diego Farm Bureau, identifies two
critical factors affecting the sustainability of agriculture in San Diego – water pricing and
competition with lower priced imported food. Part of the justification for this project is to
support freight and goods moving through the Mexican Border crossing, and these goods
include an increasing amount of food products. Agriculture in San Diego County is not just
important for our local economy, it affects land use, watershed function, and habitat.
Agricultural land provides important movement, foraging and migrating areas for local,
national and even international wildlife populations. Facilitating the movement of lower
priced food, from long distances away, will reduce the viability of local agriculture. It also
contributes to excess carbon dioxide leading to global warming and to increased levels of
nitrous oxides that form smog. None of these issues were adequately considered in the
DEIR. How will Caltrans address these concerns on impacts to agricultural resources?

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Inadequate Mitigation

Two coalitions of non-profit organizations in North San Diego County, the North County
Open Space Coalition (NCOSC) and Carlsbad Watershed Network (CWN), had a series of
meetings with Caltrans staff over this project in 2006. Attached is a copy of the three page
list of potential mitigation measures for the Buena Vista Watershed that they asked to be
considered for inclusion as this project moves forward. All of these measures are related to
watershed function and habitat conservation. We cannot find that any of these mitigation
measures have specifically been included in the DEIR. These are all feasible, reasonable
mitigation measures that would provide some offsetting benefits for the huge direct and
indirect impacts from this project. We again request that all of these mitigation measures be
considered for inclusion in the final project, and, if they are not included, that the final EIR
provide an explanation for their exclusion. Why weren’t biological mitigation measures in
the Buena Vista Watershed included in the DEIR?

Conclusion

In conclusion, the proposed expansion of I-5 will have significant, unmitigable, and
irreversible environmental impacts to biological resources, air quality, water quality, efforts to
avoid climate change, visual aesthetics and community character, agriculture, and human
health. In addition, the DEIR does not meet the requirements of CEQA because it does not
evaluate less impactive alternatives, such as the public transit alternative. Therefore, the
DEIR should not be certified by Caltrans as meeting the requirements of CEQA. It should be
revised to include transportation alternatives that will benefit, not degrade, our region and
then be reissued.

Respectfully,

/s/ Diane Nygaard

Joan M. Herskowitz James A. Peugh Diane Nygaard

Conservation Co-Chair
Buena Vista Audubon Society
2202 South Coast Highway
Oceanside, CA 92054
760-439-2473
jmherskowitz@yahoo.com
Conservation Chair
San Diego Audubon Society
4010 Morena Blvd, Ste. 100
San Diego, CA 92110
619-224-4591
peugh@sandiegoaudubon.org
President
Preserve Calavera
5020 Nighthawk Way
Oceanside, CA 92056
760-724-3887
dandd2@peoplepc.com

ATTACHMENT

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 ATTACHMENT

Buena Vista Lagoon/Watershed Revised 5/01/06

Potential Projects Related to I-5 Widening/Interchange

This list of potential projects is submitted on behalf of member organizations of the

North County Open Space Coalition (NCOSC) and Carlsbad Watershed
Network(CWN). The framework for this list is the Carlsbad Watershed Management
Plan, and the position of NCOSC in support of the salt water alternative for the
restoration of the Buena Vista Lagoon. Our key objective is to support improved
coordination of watershed and habitat conservation efforts.
Assessing the impacts for the two projects, the I-5 widening and the I-5/#78
interchange, and planning effective mitigation for the impacts should be done
concurrently.

Hydrology

- support lagoon restoration plan

We're quite far along now in the planning and EIR development phase, and a
decision on the approved restoration plan should be forthcoming within a reasonable
time frame. The timing of the two projects could neatly coincide. The cost of the
restoration will be in the $100 million range.

- expanding the width of the I-5 bridge

Assuming the selected lagoon restoration is restoring it to a natural salt water

condition, expanding the width of the I-5 bridge would probably be considered a
critical component. The design of the new bridge should best accommodate our
preferred alternative of an all-saltwater estuary.

- add gauging stations

There are currently no gauging stations on Buena Vista Creek so there is little
quantitative/historical data available on discharge rates, and variation in surface flow.
Adding such stations would support the lagoon restoration effort as well as
improved storm water management in the watershed.

Public Education/Access Programs

- Boardwalk Interpretative Trail

BVAS has the concept plans for this project already in hand. It involves a loop
boardwalk trail which begins and ends at the Nature Center, and incorporates raised
observation platforms and interpretative signage. The second, more problematic
project would be a pedestrian boardwalk running along the east side of Pacific Coast

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Hwy and linking the small picnic park and lagoon overlook in Carlsbad with the BVAS
Nature Center.

- north side lagoon trail

This proposed trail would go from the Nature Center east along the north side of the
lagoon. The trail would probably need to deadend at the freeway, but such a trail
would greatly expand the ability of BVAS to serve as a focal point for nature
education about the lagoon.

- Watershed/ monitoring component

This would be similar to the program the University of California has at the
headwaters of the Santa Margarita River - Reserve Station. The BV Nature center
would be provided with high speed access - wireless access as field stations for on-
going research, mitigation and protection of the local wildlife and watersheds. The
nature center would function as a working field station with mobile carts and wireless
laptops that go along with ancillary monitoring devices. These along with onsite and
upstream monitoring equipment needs to be in place for nearby high school and
university student for on-going conservation studies and research.

- expand educational component of annual creek clean-ups

There have been broad based community clean-up efforts along the creek and to the
coast. What these efforts haven't included is a strong public education component.
Hundreds of volunteers turn out for this event. Interactive exhibits at the event, hand-
out materials etc could be designed with age appropriate messages about watershed
protection.

Land Acquisition

- coordinate habitat conservation planning within the watershed

Sections of the watershed are included in separate subarea plans for the MSCP
North County(being finalized), city of Vista (draft not issued), city of Oceanside
(second draft under revision), and city of Carlsbad (plan adopted.) . There is an
opportunity to improve the functioning of the riparian corridor and wildlife movement
by coordinating habitat planning across these four plans.

- acquire key parcels along the lagoon or strategically located within the watershed.

The list of potential acquisition parcels should include the following for consideration:

- the Boardwalk parcel adjacent to the inner lagoon

This parcel was recommended for acquisition in the lagoon restoration plan.and is
the top priority for direct lagoon benefit. It is ideally located for wetlands restoration.

- lower basin area around tributary entrance

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This area of non-native grassland is between high quality riparian woodland and
disturbed wetlands. It is identified as a Biological Core and Linkage Area in the
MHCP.

- conservation easement of the Marron Adobe site

This is within the key connecting linkage between Oceanside and Carlsbad and
adjacent to the pending Sherman acquisition. Homesite has been continuously
occupied by the original land grant family descendents. And while current occupant
is committed to preservation, without such an easement there is no protection of this
site from future sale for development.

- Sherman parcel

A conservation acquisition is currently underway through the Trust for Public Land.
There is currently a small funding shortfall for financing the acquisition.

- segment of South Coast parcel that parallels Marron Rd extension and the creek

This area next to the reclamation plan site and the Sherman acquisition would result
in significant protection of this entire valley.

- Hughes parcel next to pump station in the outer basin.

Hard to believe this is actually potentially developable.

- undeveloped parcel east of College between the two senior facilities along Lake
Blvd

This acquisition could be combined with replacing the concrete channel through this
area- using the adjacent parcel to provide for improved natural vegetation and creek
biological function.

Habitat Restoration/Enhancement

- TET site along Mossey Nissan in Oceanside

This is one of the unmanaged TET mitigation sites. Several invasive plants need to
be removed and former homeless encampments and erosion areas require
replanting.

- Hosp grove restoration

This area has a planned restoration program that has been hampered by funding.
Eucalyptus need to be replaced with native species in this preserve area right across
the street from the outer basin of the Lagoon .

- continuation funding for CWN invasives removal project

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Initial focus was on Arundo donax and pampass grass. Mapping of key invasives has
been done. Funding is needed to complete the removal/restoration effort of other
target species.