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APPENDIX A NOTICE OF PREPARATION (NOP) Appendix A-1: 2050 RTP/SCS EIR NOP Appendix A-2: NOP Comment Letters Appendix A-3: Summary of NOP Comment Letters Appendix A-4: NOP Workshop Transcripts APPENDIX A-1 2050 RTP/SCS EIR NOP APPENDIX A-2 NOP COMMENT LETTERS STATE OF CALIFORNIA - THE NATURAL RESOURCES AGENCY ARNOLD SCHWARZENEGGER, Governor CALIFORNIA COASTAL COMMISSION SAN DIEGO AREA 7575 METROPOLITAN DRIVE, SUITE 103 SAN DIEGO, CA 92108-4421 (619) 767-2370 May 19,2010 Rob Rundle Principal Regional Planner SANDAG 401 B Street, Suite 800 San Diego, CA 92101 Re: Notice of Preparation for the 2050 RTP Dear Mr. Rundle, The above referenced Notice of Preparation (NOP) was received by this office on April 19, 2010. We appreciate the opportunity to comment on the environmental review process related to the 2050 RTP for the San Diego region. We offer these comments as general direction relative to the policies ofthe Coastal Act that should be incorporated into the environmental review ofany development slated within the RTP that would either directly or indirectly affect the resources of the California Coastal Zone. The presented goals ofthe 2050 RTP, to improve "Quality ofTravel and Livability, and Sustainability" create an opportunity to enhance San Diego's established transportation system in a manner that is supportive ofmany tenants ofthe Coastal Act. These stated goals, which are inclusive ofa Sustainable Communities Strategy pursuant to the requirements of SB 375, afford the possibility to address both local and regional efforts to address likely climate change scenarios. The development ofsmart growth solutions to future transportation and land use challenges is strongly supported through Coastal Act policies. Public Resources Code (PRC) 30250 requires that new development shall be located within or directly adjacent to existing developed areas having adequate public services able to accommodate the new development and that the new development will neither individually or cumulatively impact coastal resources. Public transit development that facilitates improved public coastal access is encouraged (PRC 30252), and further restrictions are placed on new development that require projects minimize energy consumption and vehicle miles travelled. These policies can be implemented through the concentration ofdevelopment densities along existing transportation corridors and employment centers, and improving the connectivity for various types oftransit linkages available within these areas. Additionally, concentrating development into existing areas can serve to preserve existing coastal agricultural resources (PRC 30241 and 30242) and reduce carbon emissions associated with the import ofthese locally produced goods. The reduction ofGHG emissions through adherence to the direction from SB 375 can further assist in achieving these stated goals, while maintaining compliance with Coastal Act policies. The transportation corridors located within the San Diego region bisect or are located directly adjacent to sensitive marine resources including coastal lagoon systems and the Pacific Ocean itself. Impacts to these resources are restricted by Coastal Act policies. Except for certain specific instances, fill of a wetland or other coastal waters is prohibited (PRC 30233), and the marine resources (PRC 30230), water quality (PRC 30231) and environmentally sensitive habitat 2050 RTP May 19,2010 Page 2 of2 areas (PRC 30240) often associated with the coastal environment are also protected. Many of these coastal systems have already significantly deteriorated due to historical transportation infrastructure development. Future transportation improvements planned for the Coastal Zone should seek to ameliorate and improve these constraints whenever feasible. The proximity ofseveral transportation corridors to the coastal environment also leave them highly susceptible to impacts associated with future sea level rise. This provides additional incentive to reduce GHG emissions, in order to not further exacerbate hazards associated with accelerated climate change. Future transportation improvements should be designed to account for predicted sea level rise extending to at least 2100, or beyond if the design life ofthe project extends into the next century. Additionally, it will be important to inventory existing transportation infrastructure in order to prepare for sea level rise and to develop appropriate adaptation strategies to address these potential impacts. As directed through AB 1396, the 2050 RTP should provide an opportunity to assess the California Coastal Trail (CCT) within the San Diego region in order to identify existing gaps and other related coastal access needs. The CCT provides valuable linkages between coastal areas for both pedestrian and bicycle transportation. Trail systems provide valuable alternate transportation linkages that serve to further enhance connectivity and create a more robust and functional transportation plan. We look forward to future collaboration on improvements to the transportation system ofthe San Diego region and are available to address any question or concerns you may have. Sincerely, ;/;,71-- Gabriel Buhr Coastal Program Analyst III San Diego District 05/17/2010 16:41 FAX 18584674288 DF6 R5 Southcoast Region ~001/016 California Natural Resources Agency ARNOLDSCHWABZENEGGER. Govern"r JOHNMCCAMMAN, Director • May 17, 2010 Mr. Rob Rundle San Diego Association of Governments 410B Street, Suite 800 San Diego, CA 92101 Subject: Comments on the Notice of Preparation of a Draft Programmatic Environmental Impact Report for the 2050 Regional Transportation Plan (SCH# 2010041061) Dear Mr. Rundle: The California Department of Fish and Game (Department) has reviewed the above-referenced Notice of Preparation (NOP) of a Draft Programmatic Environmental Impact Report (DPEIR) for the proposed 2050 Regional Transportation Plan, and offers thefollowing comments and recommendations. Thefollowing comments have been prepared pursuant to the Department's authority asTrustee Agency with jurisdiction overnatural resources affected bythe project (CEQA Guidelines Section 15386) and pursuant to our authority as a Responsible Agency under CEQA Guidelines Section 15361 over those aspects of the proposed project that come under the purview of the Califomia Endangered Species Act (Fish andGame Code Section 2050 et seq.) and Fish and Game Code Section 1600 et seq, The Department also administers the Natural Community Conservation Planning Program (NCCP), The NOP for the project identifies thatthe project is located within planning areas for a number of NCCP plans in San Diego County (County), including the Multiple Species Conservation Program and the Multiple Habitat Conservation Program. The 2050 Regional Transportation Plan (RTP) is an update of the 2030 RTP produced in 2007, The RTP addresses both the movement of goods andpeople within the San Diego region, and includes roads, bike paths, marine terminals, air cargo facilities, freight rail, andland ports of entry that link the San Diego region with Mexico, The RTP Is based upon other forecasts and plans, such as a newRegional Growth Forecast, Climate Action Strategy, Regional Energy Strategy, Regional Bicycle Plan, Urban Area Transit Strategy, Comprehensive Freight Gateway Forecast, airport multimodal planning, high speed rail planning, and corridor and sub-regional studies, A newelement to the 2050 RTP is the S\lstainable Communities Strategy (SCS) which will address goals for regional greenhouse gasemissions. This is a requirement established by State Senate 8111375. The2050 RTP will have two overarching themes: Quality of Travel & Livability, and Sustainability. Under the theme of Sustainability is included the topic of a Healthy Environment, whieh will address the issues of open space and sensitive biological resources, The Department offers the follOWing comments and recommendations to assist SANDAG in avoiding or minimiZing potential project impaets to biological resources. Specific Comments 1. TheSustainable Communities Strategy should include an analysis of howthe RTP is consistent With approved NCCP plans such asthe Multiple Species Conservation Plan (MSCP) and the Multiple Habitat Conservation Plan (MHCP), In addition, a number of Conserving Cafijornia's 'Wf.U£fife Since 1810 05/17/2010 16:41 FAX 18584674288 DFG R5 Southcoast Region I4J 002/016 Mr. Rob Rundle May 17, 2010 Page 20f7 NCCP plans in the County are far along in the planning process and will likely be approved and begin implementation within the next yearor two. Inthe SANDAG document "2050 Regional Transportation Plan: Work Program and SchedUle", page 2: Sustainable Communities Strategy (SC$), It indicates thatthe SCS element of the RTP must be consistent withCalifornia Air Resources Board greenhouse gasemission reduction targets, and the Regional Housing Needs Assessment. This section ofthe RTP should also specifically call out the need to be consistent with the regional NCCP habitat conservation plans as well. 2. The Department requests thatin anyanalyses of open space lands in the RTP that natural open space be considered as public infrastructure as necessary astransportation, water, and developable lands. These open space lands provide critical functions for the human population (e.g., water quality, recreation, aesthetics, land values, ete.) as well asthe plants and wildlife of the region. Open space lands should notbe considered expendable or of lesser value than transportation corridors. In addition,
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