HomeMy WebLinkAbout24th ST FEIR Vol 3
24th Street Improvement Project
Bakersfield, Kern County, California
SCH# 2008041070
Final Environmental Impact Report
VOLUME 3 of 3
Recirculated Final Environmental Impact Report
and Responses to Comments
Prepared by the
City of Bakersfield
The environmental review, consultation, and any other action required in accordance with applicable
federal laws for this proposed project is being, or has been, carried out by the California Department of
Transportation under its assumption of responsibility pursuant to 23 U.S. Code 327.
MAY 2016
General Information About This Document
This document is a Recirculated Final Environmental Impact Report (R-FEIR) for the 24th Street
Improvement Project, prepared by the City of Bakersfield (City), in accordance with CEQA
Guidelines Section 15088.5(a) and (c). The proposed project is located along the 24th Street
corridor (State Route 178) from just west of the State Route 99 interchange to just east of
M Street in the City of Bakersfield in Kern County.
The Draft Environmental Impact Report/Environmental Assessment (DEIR/EA) for this
proposed project was previously prepared and circulated for public review in mid-2012, and the
Final Environmental Impact Report/Environmental Assessment was completed in December
2013. The final environmental document was decertified by the City of Bakersfield City Council
in September 2015, and that document is now referred to as the 2015 Draft Environmental
Impact Report (2015 DEIR). The City prepared a Recirculated Draft EIR (R-DEIR) based on the
2015 DEIR to comply with an Order from the Superior Court for the State of California, County
of Kern, to include six additional cul-de-sacs in the proposed project description that were
separately approved, and to expand the explanations about alternatives that were considered, but
rejected. The R-DEIR analyzed the impacts of various environmental resources considered with
the proposed cul-de-sacs included in the proposed project, and also provides additional evidence
to support the reasons why the eight alternatives considered in the previously circulated
DEIR/EA for this proposed project were rejected. The R-DEIR consists of only the revised
portions of the 2015 DEIR, as they relate to the actions advised by the Court. The R-DEIR was
available for public and agency review from January 11, 2016 to February 25, 2016 (a 45-day
period).
In accordance with CEQA Guidelines Section 15088.5(f)(2), the City needs only to respond to
those comments that pertain to the revised and recirculated portions of the 2015 DEIR, as set
forth herein. This R-FEIR is a revision to the January 2016 R-DEIR, and reflects revisions that
resulted from comments on the R-DEIR (please see responses to comments on the R-DEIR in
Appendix C of this volume).
24th Street Improvement Project FEIR/EA Volume 3 i
Executive Summary
Project Background
The California Department of Transportation (Caltrans), as assigned by the Federal Highway
Administration, in cooperation with the City of Bakersfield (City), proposes improvements to the
24th Street corridor (State Route 178) from just west of State Route 99 to just east of M Street,
including widening 24th Street between Olive Street and D Street, widening the 23rd Street/24th
Street couplet, and making intersection improvements at Oak Street and 24th Street in the City of
Bakersfield in Kern County. Originally, two cul-de-sacs (Elm Street and B Street) would be
constructed on the south side of 24th Street in conjunction with the widening of 24th Street. In
addition to the proposed improvements along 24th Street, a northbound auxiliary lane for a
northbound off-ramp along State Route 99 south of 24th Street is planned.1 The improvements
would relieve existing traffic congestion and provide for anticipated future growth in traffic
volume through central Bakersfield.
A joint environmental document (Draft Environmental Impact Report/Environmental
Assessment) was prepared in 2012 (2012 DEIR/EA) for the proposed project in compliance with
the National Environmental Policy Act (NEPA) and the California Environmental Quality Act
(CEQA). The Final Environmental Impact Report/Environmental Assessment (FEIR/EA) was
completed in December 2013 and was approved by Caltrans as a NEPA Lead Agency and
certified by the City as a CEQA Lead Agency in February 2014.
Following certification of the 2013 FEIR/EA, a legal challenge to the adequacy and
completeness of the Final Environmental Impact Report (2013 FEIR) was filed in Kern County
Superior Court (Court). Citizens Against the 24th Street Widening Project filed a petition for a
Writ of Mandamus against the City and Caltrans, alleging defects in the 2013 FEIR under
CEQA. In its May 1, 2015, preliminary ruling in the Citizens Against the 24th Street Widening
Project v. City of Bakersfield proceeding [Case No. S-1500-CV-281556KCT], the Court ruled
that the 2013 FEIR certified by the City of Bakersfield in February 2014 was deficient in two
respects: (1) the project description and environmental analysis in the 2013 FEIR should have
included six additional cul-de-sacs requested by local residents (for a total of eight cul-de-sacs),
and (2) the 2013 FEIR did not adequately and completely consider and analyze the eight
potentially feasible alternatives discussed under Alternatives Considered but Eliminated from
Further Discussion.
On July 10, 2015, the Court finalized its ruling ordering the City to void the certification of the
2013 FEIR and the approval of the proposed project, and issued an injunction on the proposed
project. In response to the Court’s ruling, the Bakersfield City Council decertified the 2013 FEIR
in September 2015; with its decertification, the 2013 FEIR became the 2015 Draft
1A complete description of the proposed project is provided in Section 1.2.
Executive Summary
24th Street Improvement Project FEIR/EA Volume 3 ii
Environmental Impact Report (2015 DEIR). The City released the Recirculated Draft
Environmental Impact Report (R-DEIR) for public review and comment to comply with the
Court’s ruling on the cul-de-sacs and the alternative analysis, as described above.
The R-DEIR was intended to provide the public with a meaningful opportunity to comment on
the additional information and analysis included in the revised 2015 DEIR in response to the
Court’s ruling. The City responded only to comments on the new material included in the R-
DEIR. After comments on the R-DEIR were reviewed and responses prepared, the R-DEIR was
finalized as the 2016 FEIR and considered for certification by the City as having been prepared
in compliance with CEQA. If the City certifies the 2016 FEIR, the City will then consider
whether to approve the proposed project.
Key Issues Addressed in the R-DEIR
Inclusion of Cul-de-Sacs in Project Description
The construction of cul-de-sacs at Beech, Myrtle, Spruce, Pine, Cedar, and A Streets on the south
side of 24th Street was originally requested by local residents in response to the release of the
2012 DEIR/EA. The City considered and approved the cul-de-sacs as an individual project, with
a separate environmental document (Initial Study/Negative Declaration) prepared to comply with
CEQA. In its May 1, 2015, ruling, however, the Court held that these six cul-de-sacs should have
been a part of the proposed project description in the 2013 FEIR, along with two cul-de-sacs
(Elm Street and B Street) that were already included in the proposed project. The Court held that
the absence of these six cul-de-sacs in the 2013 FEIR rendered the document inadequate to meet
the requirements of CEQA. Specifically, the Court stated:
“… The additional resident-requested cul-de-sacs [were] improperly piecemealed from
the project and … the respondents have not proceeded in the manner required by CEQA
law.”
(Excerpts from Reporter’s Transcript of Proceeding page 32, Friday, May 1, 2015, Citizens Against the 24th Street
Widening Project, an unincorporated association vs. City of Bakersfield, a Municipal Corporation.)
In response, the City included in the R-DEIR cul-de-sacs at six additional locations on the south
side of 24th Street in the description of the proposed project, and re-evaluated the proposed
project’s environmental impacts with those additional cul-de-sacs taken into consideration. As
detailed in the errata sheet to Chapter 3 of the 2015 DEIR (see Appendix A of the R-DEIR), the
cul-de-sacs would have minor effects on traffic circulation, storm water runoff, and partial
property acquisitions in a historic district. The additional cul-de-sacs were found to have
negligible or minor effects on other environmental resources that did not alter the City’s overall
conclusions about the significant impacts of the proposed project as a whole.
Executive Summary
24th Street Improvement Project FEIR/EA Volume 3 iii
Consideration of Potentially Feasible Alternatives
With respect to alternatives, the Court ruled that the 2013 FEIR did not adequately and
completely consider or analyze eight potentially feasible alternatives that were briefly described
in that report and then eliminated, nor did the document clearly provide a rationale for their
selection. The Court further indicated that the discussion of those potential project alternatives
that had been considered and then eliminated did not provide sufficient detail or evidence about
why they had been eliminated to allow for a meaningful comparative analysis and understanding
by those who did not participate in the environmental document preparation.
Specifically, the Court stated:
“… the EIR did not adequately and completely consider and analyze the eight potentially
feasible alternatives that were briefly described in the EIR and then eliminated.”
“The eight alternatives were each described in the FEIR in a very brief and general
manner, without including sufficient analysis and evidence about each that would allow
meaningful analysis and comparison with the proposed project. The discussion of those
eight rejected alternatives includes only conclusions and opinions, with no substantial
evidence to support them. There is not sufficient detail included that would allow those
who did not participate in the EIR preparation to understand and consider the issues
raised by the proposed project, as required by CEQA.”
(Excerpts from Reporter’s Transcript of Proceeding pages 14-15, Friday, May 1, 2015, Citizens Against the 24th
Street Widening Project, an unincorporated association vs. City of Bakersfield, a Municipal Corporation.)
In response to the Court ruling, the City included in the R-FEIR an expanded analysis of the
potentially feasible alternatives to the proposed project, using the approach the Court identified
for determining suitable alternatives, and provided additional technical information about the
potential alternatives, together with corresponding figures. This additional analysis supports the
City’s determination that each of the eight eliminated alternatives fails to meet one or more of
the four threshold criteria for selecting alternatives that are cited in the CEQA Guidelines and, for
this reason, should not be selected for further detailed analysis in the R-FEIR.
Potential Impacts of Cul-de-Sacs on Historic District South of 24th Street
The Court noted the City’s acknowledgement that the six additional cul-de-sacs could adversely
affect adjacent historic districts, reading into the record the following:
“In addition, new cul-de-sacs where local streets cross 24th Street, other than Elm Street,
would potentially create additional new impacts to the historic districts north and south
of 24th Street. These impacts include the introduction of new hardscape features, cul-de-
sacs, that would introduce new visual features that indirectly affect the historic context
and setting. Also, if the cul-de-sac streets were built, the City-required design turning
radius of 84 feet would need additional property acquisitions from contributors, historic
Executive Summary
24th Street Improvement Project FEIR/EA Volume 3 iv
resources such as houses from either of the two historic districts north and south of 24th
Street. These impacts would potentially require additional evaluation through the Section
106 process requiring approvals from Caltrans and the state historic preservation officer
potentially creating additional impacts and mitigation measures not previously disclosed
in the draft environmental document.”
(Excerpts from Reporter’s Transcript of Proceeding page 32, Friday, May 1, 2015, Citizens Against the 24th Street
Widening Project, an unincorporated association vs. City of Bakersfield, a Municipal Corporation.)
In response to the Court ruling, the City included in the R-DEIR a discussion of the potential
impacts of the additional cul-de-sacs on visual and cultural resources. With respect to visual
resources, a new viewpoint along 24th Street that incorporated one of the additional cul-de-sacs
was added to the analysis. The conclusion was that the proposed project with the cul-de-sacs
included would have a moderate to moderately high impact on the aesthetic environment along
24th Street, which is the same level of impact that the proposed project would have had without
the additional cul-de-sacs. In other words, the widening of 24th Street between Elm Street and
B Street would change the visual character of that corridor, and the addition of six cul-de-sacs
along the south side of 24th Street would not substantially increase or decrease that change.
The impacts on cultural resources as a result of adding the six cul-de-sacs to the project
description are also addressed. Based on the results of the analysis (see revisions to Section 2.1.6
in Appendix A), the City determined that the six additional cul-de-sacs on the south side of 24th
Street would have no impact on the historic district to the north of 24th Street. On the south side
of 24th Street, the partial parcel acquisitions required to construct the additional cul-de-sacs
would not alter the conclusions reached in the 2013 FEIR about the proposed project’s effects on
the historic district south of 24th Street. The Section 106 process addresses a federal requirement
that has been met by the proposed project and that does not require additional evaluation.2 The
City of Bakersfield, as lead agency under CEQA, is responsible for historical resources impact
analysis, and there is no formal process of consultation with the State Historic Preservation
Office and thus no formal concurrence in determinations of impacts (or effects) as there is under
Section 106. The State Historic Preservation Office had an opportunity to comment on the R-
DEIR when it was distributed to State of California agencies by the State Clearinghouse.
2 Section 106 of the National Historic Preservation Act of 1966 requires federal agencies to consider the effects
ofprojects they carry out, approve, or fund on historic properties, defined as properties that are included in the
National Register of Historic Places or that meet the criteria of the National Register. The proposing agency
consults with the State Historic Preservation Officer during the Section 106 process. The Section 106 regulations
are published in the Code of Federal Regulations at 36 CFR Part 800, “Protection of Historic Properties,” and can
be found on the Advisory Council on Historic Preservation Web site at www.achp.gov.
24th Street Improvement Project FEIR/EA Volume 3 v
Table of Contents
CHAPTER 1 INTRODUCTION ........................................................................................ 1
1.1 Project Overview .................................................................................................. 1
1.2 Project Description ............................................................................................... 4
1.3 Policy History of South of 24th Street Cul-de-Sacs ............................................ 11
1.4 Key Issues Addressed in the R-FEIR ................................................................. 13
1.4.1 Inclusion of Cul-de-Sacs in Project Description ................................... 13
1.4.2 Consideration of Potentially Feasible Alternatives ............................... 13
1.4.3 Potential Impacts of Cul-de-Sacs on Historic District South of 24th
Street ..................................................................................................... 14
1.5 Overview of Environmental Document Processing for this Proposed Project .. 15
1.5.1 Environmental Document Processed to Date ........................................ 15
1.5.2 Public Review of R-DEIR ..................................................................... 16
1.5.3 Final Environmental Impact Report Preparation and Certification ...... 16
1.6 Organization of the R-DEIR .............................................................................. 16
CHAPTER 2 SUMMARY OF CHANGES INCLUDED IN THE R-DEIR .................. 19
CHAPTER 3 ADDITIONAL INFORMATION ON ALTERNATIVES
CONSIDERED BUT ELIMINATED FROM FURTHER
DISCUSSION .............................................................................................. 23
CHAPTER 4 DOCUMENT PREPARERS ...................................................................... 75
CHAPTER 5 DISTRIBUTION LIST ............................................................................... 77
CHAPTER 6 REFERENCES ............................................................................................ 81
APPENDIX A ERRATA SHEET TO THE 2015 DRAFT ENVIRONMENTAL
IMPACT REPORT ..................................................................................... 83
APPENDIX B ALTERNATIVES COST ESCALATION .............................................. 123
APPENDIX C RESPONSES TO COMMENTS ON R-DEIR ....................................... 125
Table of Contents
24th Street Improvement Project FEIR/EA Volume 3 vi
List of Figures
Figure 1-1. Project Vicinity .......................................................................................................................... 2
Figure 1-2. Project Location ......................................................................................................................... 3
Figure 1-3. Proposed Project (Widen to the North with Cul-de-Sacs on the South) .................................. 10
Figure 1-13. Alternatives Screening Process .............................................................................................. 26
Figure 1-14. Alternative A - Northeast/Northwest Loop Ramps Interchange ............................................ 31
Figure 1-15. Alternative B - Single Point Interchange ............................................................................... 34
Figure 1-16. Alternative C - Kern River Crossing ...................................................................................... 38
Figure 1-17. Alternative D – Interchange ................................................................................................... 41
Figure 1-18. Alternative E - Jug Handle ..................................................................................................... 44
Figure 1-19. Alternative F1 - Depressed Arterial with Retaining Walls .................................................... 47
Figure 1-20. Alternative F2 - Depressed Arterial without Retaining Walls ............................................... 48
Figure 1-21. Alternative G1 - Widening on 24th Street on South Side with Frontage Road on North
Side ........................................................................................................................................ 52
Figure 1-22. Alternative G2 - Widening on North Side with Frontage Road on North Side ...................... 53
Figure 1-23. Alternative G3 - Widening Both North and South Side with Frontage Road on North Side . 54
Figure 1-24. Alternative G4 - Widening on South Side with Frontage Road off of Northerly Curb ......... 55
Figure 1-25. Alternative H - Widening Both Sides of 24th Street ............................................................... 59
Figure 1-26. Alternative I – Restriping 24th Street ...................................................................................... 62
Figure 1-27. Cross-Section for Alternative I Compared to Arterial Standard ............................................ 64
Figure 1-28. Alternative J - Hageman Flyover in Regional Context .......................................................... 68
Figure 1-7. Alternative 1, Widen to the North – West of Oak Street to Cedar Street ................................. 95
Figure 1-8. Alternative 1, Widen to the North – Cedar Street to Eye Street ............................................... 96
Figure 2-6. Potential Acquisitions/Relocations – Alternative 1 – Widen to the North (Sheet 3 of 5) ...... 105
Figure 2-6. Potential Acquisitions/Relocations – Alternative 1 – Widen to the North (Sheet 4 of 5) ...... 106
Figure 2-11. Key View Locations ............................................................................................................. 109
Figure 2-18A. Key View 8 Existing and Proposed Conditions ................................................................ 110
Figure 2-19. Impacts to Properties within the Historic Districts North and South of 24th Street –
Alternative 1 ......................................................................................................................... 113
Figure 2-24. Modeled Sound Barriers and Receiver Locations – Alternative 1 (Sheet 3 of 5) ................ 118
Figure 2-24. Modeled Sound Barriers and Receiver Locations – Alternative 1 (Sheet 4 of 5) ................ 119
List of Tables
Table 2.1. Summary of Revisions to the 2013 Final Environmental Impact Report /2015 Draft
Environmental Impact Report ................................................................................................ 19
Table 2.2. Sections of the 2013 Final Environmental Impact Report/2015 Draft Environmental Impact
Report that Require No Changes ............................................................................................ 21
Table 1.4. Twelve Busiest Arterial Roads in Bakersfield ........................................................................... 27
Table 1.5. Evaluation of Potentially Feasible Alternatives Against CEQA Threshold Criteria ................. 73
Table S.1. Summary of Potential Impacts from Alternatives ..................................................................... 87
Table 1.3. Comparison of Project Alternatives ........................................................................................... 98
Table 2.7. Summary of Property Acquisitions for the Build Alternatives ................................................ 104
Table 2.13. Permanent Uses and Temporary Occupancies at the Historic Properties .............................. 112
Table 2.28. Cumulative City of Bakersfield Projects within the Study Area ........................................... 121
Table 3. Individual Comments Received on the 24th Street Improvement R-DEIR ................................. 163
Table 4. Oral Testimony Received on the 24th Street Improvement R-DEIR .......................................... 449
Table 5. Petitions on the 24th Street Improvement R-DEIR ..................................................................... 493
24th Street Improvement Project FEIR/EA Volume 3 vii
List of Acronyms and Abbreviations
AADT Annual Average Daily Traffic
ac acre
APE Area of Potential Effects
Caltrans California Department of Transportation
CEQA California Environmental Quality Act
City City of Bakersfield
Court Kern County Superior Court
dBA A-weighted decibels
DEIR Draft Environmental Impact Report
EA Environmental Assessment
EIR Environmental Impact Report
FEIR Final Environmental Impact Report
FONSI Finding of No Significant Impacts
N North
NEPA National Environmental Policy Act
NOA Notice of Availability
PM Post Mile
P.E. Professional Engineer
PSR Project Study Report
R-DEIR Recirculated Draft Environmental Impact Report
R-FEIR Recirculated Final Environmental Impact Report
RTP Regional Transportation Plan
R/W right of way
SCH State Clearinghouse
SR State Route
ST Street
TCE Temporary Construction Easement
TRIP Thomas Roads Improvement Program
U.S. United States
24th Street Improvement Project FEIR/EA Volume 3 1
Chapter 1 Introduction
The California Department of Transportation (Caltrans), as assigned by the Federal Highway
Administration, in cooperation with the City of Bakersfield (City), proposes improvements to the
24th Street corridor from just west of State Route 99 to just east of M Street, including widening
24th Street (State Route 178) between Olive Street and D Street, widening the 23rd Street/24th
Street couplet, and making intersection improvements at Oak Street and 24th Street in the City of
Bakersfield in Kern County. Eight cul-de-sacs would be constructed on the south side of 24th
Street by the City in conjunction with the widening of 24th Street. In addition to the proposed
improvements along 24th Street, a northbound auxiliary lane for the northbound off-ramp along
State Route 99 south of 24th Street is planned. The project vicinity and project location are shown
in Figure 1-1 and Figure 1-2, respectively.3
The 24th Street Improvement Project will require reviews and approvals by the City and Caltrans.
The City is the lead agency for compliance with the California Environmental Quality Act
(CEQA), and Caltrans is the lead agency for compliance with the National Environmental Policy
Act (NEPA). The 24th Street Improvement Project is a joint state and federal project included in
the Thomas Roads Improvement Program (TRIP). Compliance with NEPA for the proposed
project has been completed with Caltrans’ approval of a Final Environmental Assessment and
issuance of a Finding of No Significant Impacts. This 2016 Final Environmental Impact Report
(2016 FEIR) will be considered by the City for certification under CEQA. If the City certifies the
2016 FEIR, the City will then consider whether to approve the proposed project.
1.1 Project Overview
The 24th Street Improvement Project initially consisted of two separate projects, the Oak
Street/24th Street Interchange Project (Interchange Project) and the 24th Street Widening Project
(Widening Project). Transportation studies of the 24th Street area prepared from 1986 to the early
2000s indicated a need to relieve traffic congestion at the Oak Street/24th Street intersection, and
to provide more capacity along 24th Street to the east of that intersection into the downtown
Bakersfield area. Project Study Reports for the Interchange Project (URS Corporation 2005a)
and the Widening Project (URS Corporation 2005b) were finalized in 2005. These reports
provided a foundation for the Interchange Project and Widening Project environmental studies in
2007.
3See Section 1.2 for a detailed description of the proposed project.
Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 2
Figure 1-1. Project Vicinity
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Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 4
Continuing traffic and environmental studies of the conditions on 24th Street indicated a need to
update the Project Study Reports for the Interchange Project (URS Corporation 2005a) and the
Widening Project (URS Corporation 2005b). The results of traffic modeling indicated a systems
approach should be used because the two separate projects would not eliminate current and
future traffic congestion independently. In addition, the proposed improvements at the Oak
Street/24th Street intersection would affect traffic conditions west of the intersection. Therefore
the Supplemental Project Study Reports for the Interchange Project and the Widening Project
were prepared (RBF Consulting 2011a and 2011b) to account for the linkages between the two
projects and incorporate the necessary elements of a systems approach.
The major changes in the Interchange Project from its 2005 Project Study Report to its 2011
Supplemental Project Study Report were that the Oak Street/24th Street intersection would
require some improvements, but not a full interchange, and that improvements to State Route 99
would also be needed. The major changes in the Widening Project from its 2005 Project Study
Report to its 2011 Supplemental Project Study Report were that the limits of the proposed
project needed to extend to the east of M Street and needed to include widening the 23rd
Street/24th Street couplet. Together, these two projects with the additional elements included in
the two Supplemental Project Study Reports provided a comprehensive solution to the demand
for roadway capacity on 24th Street from State Route 99 to the downtown area (M Street).
The 2011 Supplemental Project Study Report for the Widening Project identified two feasible
approaches to achieving the project’s goals – widening 24th Street on the north side and widening
it on the south side. The two build alternatives of the proposed project evaluated in the 2015
DEIR, Alternative 1 – Widening to the North and Alternative 2 – Widening to the South,
represent these two feasible approaches. The Oak Street/24th Street intersection modifications
outlined in the 2011 Supplemental Project Study Reports are the same under both build
alternatives.
The rationale for selecting Alternatives 1 and 2 for further evaluation in the 2015 DEIR was
based on engineering, environmental protection, and cost. Adding capacity to an existing road to
relieve traffic congestion involves some combination of widening to one or both sides of the
road. Alternatives 1 and 2 were developed to minimize environmental impact. After the
circulation of the draft environmental document in May 2012 and consideration of the public
comments on that document, Alternative 1 (Widen to the North) was selected as the Preferred
Alternative. For the purposes of complying with CEQA, Alternative 1 is addressed in this R-
FEIR as the proposed project.
1.2 Project Description
The 24th Street Improvement Project evaluated in the R-FEIR addresses traffic congestion along
the 24th Street corridor (State Route 178) which, for purposes of environmental review, begins
just west of the State Route 99 interchange with State Route 58 and ends just east of M Street.
The proposed project is an integration and enhancement of various improvements that were all
Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 5
found to be necessary to relieve traffic congestion along 24th Street and provide for future growth
in traffic volumes in central Bakersfield. Together, these improvements achieve acceptable levels
of service along the 24th Street corridor during morning and evening peak traffic periods. The
“proposed project” referred to in the R-FEIR is the project described in this section.
The proposed project consists of improvements along 24th Street from west of State Route 99 to
0.2 mile east of M Street, a distance of about 2.1 miles, and improvements on State Route 99 for
a northbound auxiliary lane from 1,500 feet south of and to the Kern River Bridge. The main
features of the proposed project are improvements at the Oak Street/24th Street intersection, just
east of the Kern River Bridge, and the widening of 24th Street between Olive Street and D Street.
Other proposed actions include widening the 23rd Street/24th Street couplet between D Street and
M Street, and improvements at State Route 178. The proposed project is divided into the
following four segments (see Figure 1-2):
Segment 1: State Route 99/Rosedale Highway (State Route 58)/24th Street (State
Route 178) interchange improvements, including Northbound State Route 99 Auxiliary
Lane and southbound State Route 99 ramp improvements to the west end of the Kern
River Bridge;
Segment 2: 24th Street/Oak Street intersection and 24th Street improvements from the
west end of the Kern River Bridge to Olive Street;
Segment 3: 24th Street widening from Olive Street to D Street, with a reverse curve (S-
curve); and
Segment 4: 23rd Street/24th Street couplet improvements from D Street to 0.2 mile east of
M Street.
Each of these segments is described in detail below.
Segment 1—State Route 99/State Route 58/24th Street (State Route 178)
Interchange Improvements and Northbound State Route 99 Auxiliary Lane
Segment 1 project features would consist of improvements to the State Route 99 ramps,
including the following changes at the interchange with 24th Street (State Route 178) and
Rosedale Highway (State Route 58):
Improve the westbound loop on-ramp from Rosedale Highway (State Route 58) to
southbound State Route 99 from one lane to two lanes within the existing pavement
width.
Improve northbound State Route 99 to include a 1,500-foot auxiliary lane (an extra lane
to help traffic enter and exit the freeway smoothly) before the State Route 99 northbound
off-ramp at 24th Street (State Route 178). With the auxiliary lane option, the northbound
off-ramp would be expanded from a one-lane off-ramp to a two-lane off-ramp. A
retaining wall up to 11 feet high (exposed height) with a concrete barrier on top would be
Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 6
built at the edge of the shoulder from the beginning of the improvements to the existing
Kern River Bridge. No structural improvements would be made to the Kern River Bridge,
but the existing roadway would be restriped to create the auxiliary lane and a two-lane
departure.
Improve the westbound 24th Street (State Route 178) approach to Buck Owens Boulevard
from three through lanes and one right-turn lane to three through lanes and two lanes
aligning with the southbound State Route 99 loop on-ramp — one on-ramp lane and one
shared through/right-turn lane. The section would include a bike lane, a 12-foot-wide
lane, a 5-foot-wide shoulder, a 5-foot-wide sidewalk, a 10- to 12-foot-high (exposed
height) retaining wall, and a 3-foot-high concrete barrier. The three westbound lanes,
which would go under the State Route 99 superstructure, would be separated from the on-
ramp lanes by a raised median. The bike lane would begin at the beginning of the right
turn pocket, approximately 200 feet west of the Kern River Bridge, and extend to Buck
Owens Boulevard. The bike lane would align with the 8-foot-wide right shoulder of the
westbound through lanes along 24th Street (State Route 178) under State Route 99. The
three westbound through lanes would continue westerly on 24th Street. A retaining wall
would be required under State Route 99 to support the north abutment slope. The lanes
would be 12 feet wide with an 8-foot-wide shoulder, an 8-foot-wide sidewalk, and a 4- to
8-foot-high (exposed height) retaining wall.
Improve the southbound Buck Owens Boulevard approach to 24th Street from two left-
turn lanes and one right-turn lane to two left-turn lanes and two right-turn lanes. All lanes
of the approach would be 12 feet wide.
Improve the northbound State Route 99 off-ramp from two left-turn lanes and one free
right-turn lane to three left-turn lanes and one free right-turn lane. The additional left-turn
lane would be 12 feet wide with a 4-foot-wide left shoulder. Eastbound 24th Street would
remain as-is, with three through lanes and an additional lane at the northbound State
Route 99 off-ramp free right turn.
Segment 2—24th Street/Oak Street Intersection and 24th Street Improvements
from the West End of the Kern River Bridge to Olive Street
Segment 2 improvements would include the following:
Improve the existing 24th Street Bridge over the Kern River, between Oak Street and
Buck Owens Boulevard within the limits of the existing bridge to remove the existing
raised median and build a 3-foot 3-inch wide (39-inch wide) raised median near the
middle of the bridge to accommodate four 12-foot-wide lanes, a 6-foot-wide right
shoulder, and a 1-foot-wide left shoulder in each direction. The existing curb and 5-foot-
wide sidewalks in the westbound direction and the existing concrete barrier in the
eastbound direction would remain.
Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 7
Improve the northbound Oak Street approach to 24th Street from one left-turn lane, one
shared left-turn/through lane, and one right-turn lane to two left-turn lanes, one shared
left-turn/through lane, and two right-turn lanes. A raised/striped median or an island
would be installed for right-turn movements onto eastbound 24th Street. The section
would consist of three through lanes, shoulders, a bike lane, and an 8-foot-wide parkway
(the area between the travel lanes and sidewalks, ordinarily used as a planting area).
Build a new 6-foot-wide sidewalk next to the existing curb on the west side of Oak Street
from the 24th Street intersection toward 22nd Street. A curb, gutter, and sidewalk would be
built on the east side of Oak Street from the 24th Street intersection toward 22nd Street.
Restripe the southbound Oak Street lane approach to 24th Street from one shared left-
turn/through lane and one right-turn lane to one left-turn lane and one shared
through/right-turn lane.
Improve the eastbound 24th Street approach to Oak Street from two through lanes to four
through lanes, leaving the existing one left-turn lane and one right-turn lane. A 9-foot-
high (exposed height) retaining wall with a 3-foot-high barrier at Beach Park in the
southwest quadrant of the intersection would be built.
Improve the westbound 24th Street approach to Oak Street from one through lane to three
through lanes.
Build bus stop turnouts on eastbound and westbound 24th Street near Oak Street.
Enhance landscaping in the median and parkway areas (the area outside the shoulder of
the roadway) on both the north and south sides of 24th Street. The parkway (the area
between the travel lanes and sidewalks, ordinarily used as a planting area) on the north
side, between Olive Street and Carrier Canal, would vary in width from 10 feet to 15 feet
to accommodate drivers’ sight distance (the distance drivers can see ahead) at Olive
Street.
The proposed project would include reconstructing Carrier Canal on the north and south sides of
24th Street to accommodate the widening of 24th Street. On the north side of 24th Street, Carrier
Canal would require about 10 feet of culvert extension, in addition to reconstructing about
30 feet of transition area. On the south side of 24th Street, Carrier Canal would require about
100 feet of culvert extension, in addition to reconstructing about 30 feet of transition.
Segment 3—24th Street Widening (from Olive Street to D Street), with a Reverse
Curve (S-curve)
The proposed project would widen 24th Street between Olive Street and D Street to the north,
adding two travel lanes — one in each direction. The proposed roadway alignment would be
shifted about 17 feet to the north of the existing alignment to minimize the acquisition of rights-
of-way on the south side of 24th Street. Eleven driveways on the north side of 24th Street would
be eliminated. Segment 3 improvements would include the following:
Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 8
Build raised medians along 24th Street, restricting cross-street access to right-in/right-out-
only vehicular movements, with left turns off of 24th Street allowed at two eastbound
intersections (Beech Street and C Street), but not at any westbound intersections.
Add a two-way frontage road on the north side of 24th Street between Elm Street and
Beech Street. A frontage road connecting Elm Street and Beech Street would provide
additional access to Elm Street.
Construct cul-de-sacs on the south side of 24th Street at Elm, Beech, Myrtle, Spruce, Pine,
Cedar, A, and B Streets. Residents may construct decorative walls on their properties
behind the cul-de-sacs, subject to City approval.
Enhance the landscaping in the median and parkway areas (the area outside the shoulder
of the roadway) on the north and south sides of 24th Street from Olive Street to C Street.
This segment of the 24th Street widening includes a reverse curve (the street curves from one
direction to the other in the shape of an “S”) that begins along 24th Street near A Street and ends
along 23rd Street near D Street. The reverse curve would include the following features:
Close D Street’s north leg at the 23rd Street intersection due to sight distance limitations.
A turn-around design pursuant to City standards would be built on D Street at this
location. A permanent easement would be required within the existing parking area north
of the alley on the west side of D Street to provide a turnaround for emergency fire
trucks.
Add a lane on 23rd Street at B Street.
Open the southbound approach of C Street onto 23rd Street to allow left-in, left-out access
and to help circulation to and from existing buildings.
Segment 4—23rd Street/24th Street Couplet (from D Street to 0.2 mile east of M
Street)
Segment 4 improvements would include the following:
Improvements to be made to the 23rd Street/24th Street couplet (a pair of one-way streets) would
include removing existing on-street parking along both sides of 23rd and 24th Streets,
rehabilitating the roadway, and restriping to allow an additional travel lane in each direction. The
roadway rehabilitation would include rebuilding the pavement, improving curb and drainage
facilities, providing Americans with Disabilities Act-compliant pedestrian curb ramps, changing
traffic signals, and adding bus turnouts.
The limits of the couplet area extend from D Street to 0.2 mile east of M Street, consisting of
four through lanes in each direction (24th and 23rd Streets) and shoulders on each side. The
existing sidewalk and parkway would remain. The design of the couplet area would include the
following:
Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 9
The intersection of 24th Street and K Street would be modified to prevent a right turn
from southbound K Street onto westbound 24th Street. A raised curb and sidewalk would
extend halfway into K Street to prevent right turns. A permanent easement within the
existing parking area would be required on the west side of K Street, just north of the
intersection, to provide a hammerhead cul-de-sac design for fire truck movements.
Along westbound 24th Street, the proposed project would end at the State Route 178
undercrossing, about 0.2 mile east of M Street. The existing undercrossing consists of
three through lanes. A fourth lane would be added just west of the undercrossing. No
construction on the undercrossing is expected. The 24th Street Frontage Road would join
24th Street just east of M Street as it is under existing conditions, and a fifth through lane
of traffic would be added at the M Street intersection. The right-most lane would be
dropped between M Street and K Street.
Along eastbound 23rd Street, the proposed project would end at the Union Avenue off-
ramp, about 0.2 mile east of M Street. Four eastbound through lanes would be built
through the M Street intersection. The fourth through lane would become the off-ramp,
and the three existing through lanes would continue to the undercrossing. No construction
on the undercrossing is planned.
A mid-block bus turnout would be constructed on westbound 24th Street between E Street
and F Street.
D Street would be closed on the north side of 23rd Street.
Construction Costs
The proposed project would cost an estimated $46 million.4 For purposes of comparing the
proposed project with alternatives, this cost has been broken down by project segment, as shown
in Figure 1-3. (Note that this estimate does not include engineering or construction support
costs.)
4Project costs presented here include right-of-way acquisition and construction costs.
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Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 11
1.3 Policy History of South of 24th Street Cul-de-Sacs
Since the late 1990s, residents and homeowners in the City’s Downtown neighborhood
expressed concerns that traffic on 24th Street (State Route 178) was causing safety issues on local
residential streets running south of and perpendicular to 24th Street. With high traffic volumes
and congestion, drivers stuck in traffic on 24th Street often cut through these residential streets
(Elm, Beech, Myrtle, Spruce, Pine, Cedar, A, and B Streets) and travel at excessive speeds.
In 2005, property owners on Elm Street petitioned the City to approve and implement a plan to
close Elm Street at the 24th Street intersection. The Bakersfield City Council passed Resolution
247-06 in September 2006, allowing the closure of Elm Street at 24th Street. At the time,
improvements were being considered but the specific design parameters for the Oak Street/24th
Street intersection and for widening 24th Street had not yet been developed. The projects had not
yet undergone federal (NEPA) or State of California (CEQA) environmental review. The City
deferred construction of the cul-de-sac and barricaded Elm Street with temporary concrete
barrier rail with the intent of including the cul-de-sac construction in the 24th Street
improvements, should that project be approved.
While system improvements to 24th Street (State Route 178) were undergoing engineering and
environmental studies by Caltrans and the City, other neighborhood property owners expressed a
need to close their particular streets by constructing cul-de-sacs on the south side of 24th Street.
Residents reported that there had been numerous accidents and near misses in the neighborhood
as a result of cut-through traffic, and requested the cul-de-sacs be constructed as soon as possible
for the safety of area residents.
City staff and City Council members declared a neutral stand on the proposed closures, but
agreed to resident’s requests to facilitate the process. The City’s Planning Department certified
that a project that allowed construction of cul-de-sacs on eight streets south of 24th Street would
implement the goals and polices of the Circulation Element of the Metropolitan Bakersfield
General Plan. In compliance with CEQA, the City prepared an Initial Study that evaluated the
potential impacts of the six cul-de-sacs not already studied in the 2012 Draft Environmental
Impact Report/Environmental Assessment (2012 DEIR/EA) and circulated it for public review.
A proposed Negative Declaration (including the Initial Study) was circulated for public review
and comment during October 2012, followed by a public hearing held on November 1, 2012.
During the Negative Declaration circulation period, the City distributed a fact sheet to property
owners on the affected streets, between 24th and 22nd Streets, clarifying the City’s role in the
resident-requested cul-de-sac project. This included the proposed requirement that all property
owners on a given street would have to agree to the cul-de-sac, that end-of-street property
owners (adjacent to 24th Street) would have to agree to donate sufficient property to construct the
cul-de-sacs to City standards, and that the City would provide no improvements beyond curbs
and gutters. End properties adjacent to 24th Street were also staked to demonstrate the amount of
property required to construct each cul-de-sac to City standards.
Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 12
On November 14, 2012, the City Council adopted the Negative Declaration, and passed
Resolution No. 128-12 which allowed for the closure and construction of cul-de-sacs on Beech,
Myrtle, Spruce, Pine, Cedar, A, B, and C Streets, south of 24th Street, provided that (1) all
property owners between 24th and 22nd Streets on the street requesting the cul-de-sac agree to the
closure by signing a petition; and (2) the owners of properties adjacent to 24th Street on each
street requesting the cul-de-sac agree to donate sufficient property for its construction built to
City standards.
At its January 8, 2014, meeting, the City Council approved Amendment No. 1 to Resolution
No. 128-12, to clarify the timing of construction on those streets requesting a cul-de-sac. At that
Council meeting, and at subsequent Council meetings on January 22, February 12, and
March 19, 2014, several area residents appeared before the City Council to discuss the desire and
urgent need to build cul-de-sacs on their streets to reduce traffic and make their streets safer,
particularly for children.
Many of the residents appearing before the City Council had expressed frustration over the
requirement for 100 percent signature approval from all property owners on those streets desiring
cul-de-sacs, as was City policy, per the original resolution. In one case, neighbors reported
having 19 of 20 property owners in support, but that a single non-resident property owner had
thwarted efforts by opposing the petition for a cul-de-sac. After further consideration and in
response to the community, at its January 22 meeting, the City Council passed a second
amendment to City policy by revising qualification requirements which would allow a petition in
which 75 percent of property owners on any street identified in Resolution No. 128-12 could
request a cul-de-sac. The Council noted that the 75 percent threshold is well above the two-thirds
approval rate considered by definition to be a “super majority” in citizen-voted issues.
City staff would then provide the City Council with a recommendation for those requests, and
the City Council would vote to approve or deny the request. Streets with 100 percent property
owner-signed petitions and the associated land dedications, as required, would continue to be
automatically approved. Subsequently, homeowners petitioned the City under this amendment
and the Bakersfield City Council granted their requests for cul-de-sacs.
Following approval of the homeowners’ petitions and the proposed Negative Declaration, the
City began to install temporary cul-de-sacs on Beech, Myrtle, Spruce, Pine, Cedar, and A Streets
with barrier rail, curb, and gutter in March 2014. Elm Street remained closed with temporary
barrier rail. Permanent construction of the cul-de-sacs is subject to final design and approval of
the proposed project, which would include sidewalks and landscaping improvements to 24th
Street. Project improvements would be coordinated with the homeowners’ installation of
decorative features behind the cul-de-sacs, as approved by the City.
Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 13
1.4 Key Issues Addressed in the R-FEIR
1.4.1 Inclusion of Cul-de-Sacs in Project Description
The construction of cul-de-sacs at Beech, Myrtle, Spruce, Pine, Cedar, and A Streets on the south
side of 24th Street was originally requested by local residents in response to the release of the
2012 DEIR/EA. The City considered and approved the cul-de-sacs as an individual project, with
a separate environmental document (Initial Study/Negative Declaration) prepared to comply with
CEQA. In its May 1, 2015 ruling, however, the Court held that these six cul-de-sacs should have
been a part of the proposed project description in the Final Environmental Impact Report
released in December 2013 (2013 FEIR), along with two cul-de-sacs (Elm Street and B Street)
that were already included in the proposed project. The Court held that the absence of these six
cul-de-sacs in the 2013 FEIR rendered the document inadequate to meet the requirements of
CEQA. Specifically, the Court stated:
“… The additional resident-requested cul-de-sacs [were] improperly piecemealed from
the project and … the Respondents have not proceeded in the manner required by CEQA
law.”
(Excerpts from Reporter’s Transcript of Proceeding page 32, Friday, May 1, 2015, Citizens Against the 24th Street
Widening Project, an unincorporated association vs. City of Bakersfield, a Municipal Corporation.)
In response, the City has included in the R-FEIR cul-de-sacs at six additional locations on the
south side of 24th Street in the description of the proposed project, and has re-evaluated the
proposed project’s environmental impacts with those additional cul-de-sacs taken into
consideration. As detailed in the errata sheet to Chapter 3 of the 2015 DEIR (see Appendix A of
the R-FEIR), the cul-de-sacs would have minor effects on traffic circulation, storm water runoff,
and partial property acquisitions in a historic district. The additional cul-de-sacs were found to
have negligible or minor effects on other environmental resources and those negligible or minor
impacts did not alter the City’s overall conclusions about the significant impacts of the proposed
project as a whole.
1.4.2 Consideration of Potentially Feasible Alternatives
The Court ruled that the 2013 FEIR did not adequately and completely consider or analyze eight
potentially feasible alternatives that were briefly described in that report and then eliminated, nor
did the document clearly provide a rationale for their selection. The Court further indicated that
the discussion of those potential project alternatives that had been considered and then
eliminated did not provide sufficient detail or evidence about why they had been eliminated to
allow for a meaningful comparative analysis and understanding by those who did not participate
in the environmental document preparation.
Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 14
Specifically, the Court stated:
“… the EIR did not adequately and completely consider and analyze the eight potentially
feasible alternatives that were briefly described in the EIR and then eliminated.”
“The eight alternatives were each described in the FEIR in a very brief and general
manner, without including sufficient analysis and evidence about each that would allow
meaningful analysis and comparison with the proposed project. The discussion of those
eight rejected alternatives includes only conclusions and opinions, with no substantial
evidence to support them. There is not sufficient detail included that would allow those
who did not participate in the EIR preparation to understand and consider the issues
raised by the proposed project, as required by CEQA.”
(Excerpts from Reporter’s Transcript of Proceeding page 14-15, Friday, May 1, 2015, Citizens Against the 24th
Street Widening Project, an unincorporated association vs. City of Bakersfield, a Municipal Corporation.)
In response to the Court ruling, the City has included in an expanded analysis of the potentially
feasible alternatives to the proposed project, using the approach the Court identified for
determining suitable alternatives, and provided additional technical information about the
potential alternatives, together with corresponding figures. This additional analysis supports the
City’s determination that each of the eight eliminated alternatives fails to meet one or more of
the four threshold criteria for selecting alternatives that are cited in the CEQA Guidelines and, for
this reason, should not be selected for further detailed analysis in the R-FEIR.
1.4.3 Potential Impacts of Cul-de-Sacs on Historic District South of 24th Street
The Court noted the City’s acknowledgement that the six additional cul-de-sacs could adversely
affect adjacent historic districts, reading into the record the following:
“In addition, new cul-de-sacs where local streets cross 24th Street, other than Elm Street,
would potentially create additional new impacts to the historic districts north and south
of 24th Street. These impacts include the introduction of new hardscape features, cul-de-
sacs, that would introduce new visual features that indirectly affect the historic context
and setting. Also, if the cul-de-sac streets were built, the City-required design turning
radius of 84 feet would need additional property acquisitions from contributors, historic
resources such as houses from either of the two historic districts north and south of 24th
Street. These impacts would potentially require additional evaluation through the Section
106 process requiring approvals from Caltrans and the state historic preservation officer
potentially creating additional impacts and mitigation measures not previously disclosed
in the draft environmental document.”
(Excerpts from Reporter’s Transcript of Proceeding page 32, Friday, May 1, 2015, Citizens Against the 24th Street
Widening Project, an unincorporated association vs. City of Bakersfield, a Municipal Corporation.)
In response to the Court ruling, the City has included in the R-FEIR a discussion of the potential
impacts of the additional cul-de-sacs on visual and cultural resources. With respect to visual
Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 15
resources, a new viewpoint along 24th Street that incorporated one of the additional cul-de-sacs
was added to the analysis. The conclusion was that the proposed project with the cul-de-sacs
included would have a moderate to moderately high impact on the aesthetic environment along
24th Street, which is the same level of impact that the proposed project would have had without
the additional cul-de-sacs. In other words, the widening of 24th Street between Elm Street and
B Street would change the visual character of that corridor, and the addition of six cul-de-sacs
along the south side of 24th Street would not substantially increase or decrease that change.
The impacts on cultural resources as a result of adding the six cul-de-sacs to the project
description are also addressed. Based on the results of the analysis (see revisions to Section 2.1.6
in Appendix A), the City determined that the six additional cul-de-sacs on the south side of 24th
Street would have no impact on the historic district to the north of 24th Street. On the south side
of 24th Street, the partial parcel acquisitions required to construct the additional cul-de-sacs
would not alter the conclusions reached in the 2013 FEIR about the proposed project’s effects on
the historic district south of 24th Street. The Section 106 process addresses a federal requirement
that has been met by the proposed project and that does not require additional evaluation.5
However, the State Historic Preservation Office had an opportunity to comment on the R-DEIR
when it was distributed to State of California agencies by the State Clearinghouse.
1.5 Overview of Environmental Document Processing for this
Proposed Project
1.5.1 Environmental Document Processed to Date
A Notice of Preparation for the Draft Environmental Impact Report/Environmental Assessment
(DEIR/EA) for the 24th Street Improvement Project was published on April 11, 2008. The
DEIR/EA and a Section 4(f) Evaluation for this proposed project were released in May 2012.
Public hearings were held in June and July 2012. All comments received during the public
review period were considered and addressed in the Final Environmental Impact
Report/Environmental Assessment (FEIR/EA) and Section 4(f) Evaluation that were completed
in December 2013. The 2013 FEIR/EA was certified by the City and Caltrans, and the proposed
project was approved on February 12, 2014. For purposes of analysis under CEQA, this
FEIR/EA is referred to as the 2013 FEIR.
Following certification of the 2013 FEIR/EA, a legal challenge to the adequacy and
completeness of the 2013 FEIR was filed in Kern County Superior Court (Court). Citizens
Against the 24th Street Widening Project filed a petition for a Writ of Mandamus against the City
and Caltrans, alleging defects in the 2013 FEIR under CEQA. In its May 1, 2015, preliminary
5 Section 106 of the National Historic Preservation Act of 1966 requires federal agencies to consider the effects of
projects they carry out, approve, or fund on historic properties, defined as properties that are included in the
National Register of Historic Places or that meet the criteria of the National Register. The proposing agency
consults with the State Historic Preservation Officer during the Section 106 process. The Section 106 regulations
are published in the Code of Federal Regulations at 36 CFR Part 800, “Protection of Historic Properties,” and can
be found on the Advisory Council on Historic Preservation Web site at www.achp.gov.
Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 16
ruling in the Citizens Against the 24th Street Widening Project v. City of Bakersfield proceeding
[Case No. S-1500-CV-281556KCT], the Court ruled that the 2013 FEIR certified by the City of
Bakersfield in February 2014 was deficient in two respects: (1) the project description and
environmental analysis in the 2013 FEIR should have included six additional cul-de-sacs
requested by local residents (for a total of eight cul-de-sacs), and (2) the 2013 FEIR did not
adequately and completely consider and analyze the eight potentially feasible alternatives
discussed under Alternatives Considered but Eliminated from Further Discussion. On July 10,
2015, the Court finalized its ruling ordering the City to void the certification of the 2013 FEIR
and the approval of the proposed project, and issued an injunction on the proposed project. The
Court’s ruling did not affect the Final Environmental Assessment or the Finding of No
Significant Impacts.
On September 2, 2015, in response to a ruling by the Court, the City of Bakersfield decertified
the 2013 FEIR and voided its approval of the proposed project. Because it was decertified by the
City, the 2013 FEIR is now referred to as the 2015 DEIR.
To comply with the Court’s Order, the City prepared the R-DEIR by revising the 2015 DEIR. As
provided for in CEQA Guidelines Section 15088.5(c):
“If the revision is limited to a few chapters or portions of the EIR, the lead agency need
only recirculate the chapters or portions that have been modified.”
The R-DEIR, therefore, consisted of additions to, deletions from, and revisions of the 2013
FEIR/2015 DEIR text, tables, and figures, along with explanatory information necessary to place
it in an appropriate context.
1.5.2 Public Review of R-DEIR
The R-DEIR was made available for public review from January 11, 2016, to February 25, 2016
(a 45-day period). A public hearing before the Planning Commission occurred on January 21,
2016.
1.5.3 Final Environmental Impact Report Preparation and Certification
Following the close of the public review period, the City responded to comments received on
those portions of the 2013 FEIR/2015 DEIR presented in the R-DEIR. Once comments were
reviewed, the City revised the environmental document as needed to produce the 2016 FEIR.
The City’s responses to comments on the R-DEIR are included in the 2016 FEIR. A Notice of
Availability of the 2016 FEIR will be filed. The City of Bakersfield will consider the 2016 FEIR
and, if appropriate, certify it and approve the proposed project.
1.6 Organization of the R-FEIR
This R-FEIR contains only the text, table, and figure changes and supporting information needed
to revise the 2013 FEIR/2015 DEIR to supplement the discussion of those potentially feasible
Chapter 1 Introduction
24th Street Improvement Project FEIR/EA Volume 3 17
alternatives that were considered but eliminated prior to detailed analysis and to add six new cul-
de-sacs (for a total of eight) to the project description. The document is organized as follows:
Executive Summary provides a brief project overview, reasons for the preparation of the
R-FEIR, and the results of the additional impact analysis.
Chapter 1 provides background information about the proposed project, the proposed
project description, and the overview of environmental document processing for this
proposed project.
Chapter 2 summarizes the revisions to the 2013 FEIR/2015 DEIR.
Chapter 3 provides the new text of Section 1.3.6 of the 2013 FEIR/2015 DEIR,
Alternatives Considered but Eliminated from Further Discussion.
Chapter 4 lists the preparers of this document.
Chapter 5 provides the distribution list for this document.
Chapter 6 lists the references cited in this document.
Appendix A provides the actual changes to the 2013 FEIR/2015 DEIR, other than to
Section 1.3.6, in the form of an errata sheet.
Appendix B provides information on how the costs of the alternatives were derived.
24th Street Improvement Project FEIR/EA Volume 3 19
Chapter 2 Summary of Changes Included in
the R-FEIR
This section presents a summary of changes to the 2015 Draft Environmental Impact Report
(2015 DEIR) (i.e., December 2013 Final Environmental Impact Report [2013 FEIR], which was
decertified in September 2015) to address two deficient areas identified by the Court, including
the proposed cul-de-sac construction and the analysis of alternatives considered but rejected, as
outlined in Chapter 1. The revisions are summarized in Table 2.1 and the actual revision in the
form of an errata sheet is located in Chapter 3 and Appendix A.
Table 2.1. Summary of Revisions to the 2013 Final Environmental Impact
Report /2015 Draft Environmental Impact Report
2015 Draft Environmental Impact Report
Summary of Revision Section Subheading
Summary Overview, Purpose and
Need, and Proposed
Action
Revised text in these three subsections and added
text to describe the six added cul-de-sacs (see
Section 2.2.3 herein) to add CEQA objectives, and to
remove references to the 2013 FEIR, its certification,
and project approval. Revised text to include a total of
eight cul-de-sacs.
Table S.1 Revised table for updated partial property acquisitions
and temporary construction easements (TCEs) due to
additional cul-de-sacs; and effects on historic district
south of 24th Street.
Chapter 1 – Proposed
Project
Alternatives Added text regarding alternatives considered but
eliminated during the planning process. Deleted
discussion regarding the proposed project initially
being comprised of two separate projects. Added
discussion for CEQA objectives and CEQA
alternatives selection criteria. Deleted references to
the 2013 FEIR.
Build Alternatives Revised text for the centerline of the roadway
alignment and to add six cul-de-sacs (for a total of
eight) to the project description.
Figures 1-7 and 1-8 Revised figures for Alternative 1 to include cul-de-
sacs.
Comparison of
Alternatives
Revised number of partial property acquisitions and
TCEs for Alternative 1 to include those needed for cul-
de-sacs. Revised number of partial property
acquisitions and TCEs for Alternative 1 related to
historic districts.
Table 1.3 Revised numbers of parcel acquisitions and TCEs for
Alternative 1 and effects on the historic district south
of 24th Street..
Locally Preferred
Alternative
Added text describing additional project objectives
(planning objectives, safety, historic resources, etc)
and how the alternatives would accomplish objectives.
Updated project costs and number of partial property
acquisitions and TCEs for Alternative 1.
Alternatives Considered
but Eliminated
Replaced Section 1.3 to expand the descriptions of
alternatives, add figures, add information on costs and
Chapter 2 Summary of Changes Included in the R-FEIR
24th Street Improvement Project FEIR/EA Volume 3 20
Table 2.1. Summary of Revisions to the 2013 Final Environmental Impact
Report /2015 Draft Environmental Impact Report
2015 Draft Environmental Impact Report
Summary of Revision Section Subheading
number of parcel acquisitions, and add evaluations of
alternatives against the CEQA selection criteria.
Chapter 2 - Affected
Environment,
Environmental
Consequences, and
Avoidance, Minimization,
and/or Mitigation
Measures
Introduction Deleted 2013 FEIR language and revised introductory
text.
Section 2.1.1 Land Use
(Subsection 2.1.1.1)
Environmental
Consequences
Deleted text describing City approval of cul-de-sacs.
Under Build Alternatives, revised the number of TCEs
for Alternatives 1 and 2.
Section 2.1.1.2 –
Consistency with State,
Federal, Regional, and
Local Plans and
Programs
Build Alternatives Added discussion of cul-de-sacs, their effects on local
land use, and their consistency with land use plans
and zoning.
Section 2.1.2.1 -
Community Character
and Cohesion
Community Character
and Cohesion
Under Environmental Consequences, added a
discussion of cul-de-sacs’ effects on community
cohesion.
Section 2.1.2.2 -
Relocations and Real
Property Acquisitions
Environmental
Consequences
Under Temporary Impacts - Build Alternatives, revised
the number of parcels and acreage of TCEs for
Alternative 1.
Table 2.7 Revised the number of partial parcel acquisitions and
TCEs for Alternative 1.
Figure 2-6 Revised figure to include cul-de-sacs and additional
property acquisitions.
Section 2.1.3 Utility and
Emergency Services
Environmental
Consequences
Added discussion of effects of cul-de-sacs on fire
protection, law enforcement and emergency services.
Section 2.1.4 Traffic and
Transportation/Pedestrian
and Bicycle Facilities
Environmental
Consequences
Under Permanent Impacts, revised the text describing
installation of cul-de-sacs. Deleted reference to City
Resolution 128-12 and City approval.
Section 2.1.5
Visual/Aesthetics
Affected Environment Under Key Views, a paragraph describing the new
Key View #8 was added. A new Figure 2-18A was
added.
Environmental
Consequences
New cul-de-sacs are included in introductory
paragraph.
Under Permanent Impacts – Key Views, a discussion
of Key View #8 was added.
Section 2.1.6 Cultural
Resources
Table 2.13 Revised to include additional partial parcel
acquisitions and TCEs for cul-de-sacs for Alternative
1.
Environmental
Consequences
Figure 2-19 (Impacts to Properties within the Historic
Districts North and South of 24th Street – Alternative 1)
was revised. Text addressing effects of cul-de-sacs on
the historic district south of 24th Street was added.
Section 2.2.1 Water
Quality and Storm Water
Runoff
Environmental
Consequences
Minor revisions to indicate that the proposed cul-de-
sacs would not change any sources of pollutants from
construction or drainage patterns. The amount of
impervious surface areas would be slightly reduced.
Chapter 2 Summary of Changes Included in the R-FEIR
24th Street Improvement Project FEIR/EA Volume 3 21
Table 2.1. Summary of Revisions to the 2013 Final Environmental Impact
Report /2015 Draft Environmental Impact Report
2015 Draft Environmental Impact Report
Summary of Revision Section Subheading
Section 2.2.2
Paleontology
Environmental
Consequences
Minor revisions to indicate that the proposed cul-de-
sacs would not affect paleontological resources.
Section 2.2.3 Hazardous
Waste or Materials
Environmental
Consequences
New cul-de-sacs added to text regarding the number
of nonresidential partial parcel acquisitions;
Section 2.2.4 Air Quality Environmental
Consequences
New cul-de-sacs added to Alternative 1 impact
discussion would not change the estimated amounts
of air pollutant emissions.
Section 2.2.5 Noise and
Vibration
Environmental
Consequences
New cul-de-sacs added to discussion of short-term
construction impacts.
Figure 2-24 Sheets 3 and 5 of Figure 2-24 (Modeled Sound
Barriers and Receiver Locations) were revised to
show cul-de-sacs.
Section 2.2.6 Energy Environmental
Consequences
New cul-de-sacs added to impact discussion No
change in the amounts of energy consumed for
construction.
Section 2.3 Biological
Resources - Subsection
2.3.1 Natural
Communities
Affected Environment Minor revisions to indicate that cul-de-sacs would be
located entirely within developed areas; natural and
wildlife communities would not be affected.
Section 2.4 Cumulative
Impacts
Affected Environment Deleted text referring to City Resolution 128-12
pertaining to cul-de-sacs.
Table 2.28 Deleted cul-de-sacs as a separate project.
Section 3.2.2 Significant
Environmental Effects of
the Proposed Project
Noise Under the
California
Environmental Quality
Act
Minor revisions to include a total of eight cul-de-sacs
as part of Alternative 1.
Section 3.2.4 Significant
Irreversible
Environmental Changes
Revised numbers of partial acquisitions for Alternative
1 to include those for additional cul-de-sacs.
Notes: CEQA – California Environmental Quality Act. EIR – Environmental Impact Report. DEIR – Draft EIR. FEIR – Final
EIR. TCE – Temporary Construction Easement. See Chapter 3 for the replaced Section 1.3.6 and Appendix A for the actual
revisions to the text of the 2015 DEIR.
Sections of the 2013 FEIR/2015 DEIR that require no changes are listed in Table 2.2.
Table 2.2. Sections of the 2013 Final Environmental Impact Report/2015 Draft
Environmental Impact Report that Require No Changes
2015 Draft Environmental Impact Report Explanation Section Subheading
Section 2.3.2
Wetlands and Other
Waters
Environmental
Consequences
The proposed cul-de-sacs would not be located in wetlands or
near other waters. No changes were made to this section.
Section 2.3.3 Animal
Species
Environmental
Consequences
The proposed cul-de-sacs would not result in the loss of any
animal species. No changes were made to this section.
Section 2.3.4
Threatened and
Endangered Species
Environmental
Consequences
The proposed cul-de-sacs would not affect special-status plants
or animals. No changes were made to this section.
Chapter 2 Summary of Changes Included in the R-FEIR
24th Street Improvement Project FEIR/EA Volume 3 22
Table 2.2. Sections of the 2013 Final Environmental Impact Report/2015 Draft
Environmental Impact Report that Require No Changes
2015 Draft Environmental Impact Report Explanation Section Subheading
Section 2.3.5
Invasive Species
-- Cul-de-sacs would not cause or facilitate the introduction to the
project area of any invasive species. No changes were made to
this section.
Chapter 4
Comments and
Coordination
-- This chapter contains comments on the 2012 DEIR and
responses to those comments. Changes to this chapter of the
2015 DEIR for the R-DEIR would be inappropriate. The 2015
DEIR, the R-DEIR, and responses to comments on the R-DEIR
will constitute the Final Environmental Impact Report.
Appendices A
through L
-- There are no changes to the 12 appendices of the 2015 DEIR.
In particular, there are no changes to the Avoidance and
Minimization Measures summarized in Table G.1 (Appendix G).
List of Technical
Studies that are
Bound Separately
-- There are no changes to the list of technical studies that are
bound separately from the 2015 DEIR.
Notes: DEIR – Draft Environmental Impact Report. R-DEIR- Recirculated DEIR. Changes to the 2015 DEIR
are detailed in Appendix A.
The additional information on alternatives considered but eliminated from further discussion is
presented in Chapter 3 of this document. Other changes to the 2013 FEIR/2015 DEIR in the form
of an errata sheet are provided in Appendix A.
24th Street Improvement Project FEIR/EA Volume 3 23
Chapter 3 Additional Information on
Alternatives Considered but
Eliminated from Further Discussion
Section 1.3.6 on page 48 of the 2015 Draft Environmental Impact Report is replaced with
the following text.
(Note to the readers: All cost estimates presented in this chapter do not include engineering
or construction support costs)
1.3.6 Alternatives Considered but Eliminated from Further Discussion
Several transportation studies were prepared in the late 1980s to early 2000s to address, among
other objectives, the need to improve the 24th Street corridor. These studies included:
Route 178 Corridor Study (Barton-Aschman Associates 1986);
State Route 178 Alternatives Study (1994);
Metropolitan Bakersfield Major Transportation Investment Strategy (Barton-Aschman
Associates, Inc. 1997);
Bakersfield System Study (URS Corporation 2002); and
2011 Final Regional Transportation Plan (2011 RTP) (Kern Council of Governments
2010).
A series of alternatives to alleviate congestion in the project area have been studied in Regional
Transportation Plans (RTPs) over the years. As a legally required planning document that
identifies major transportation improvements, the RTP mandates a regional approach to
transportation planning. The widening of State Route 178 through central Bakersfield (24th
Street) was included in the 1998 Regional Transportation Plan for Kern County.
The Bakersfield System Study (2002) initially identified 20 possible regional alternatives for
relieving traffic congestion and, through a series of public workshops, reduced the number of
candidate alternatives to six. Alternative 15, which included improvements along the 24th Street
corridor to increase its traffic capacity, was ultimately selected as the preferred alternative. The
Oak Street / 24th Street Interchange and the widening of 24th Street both appear as transportation
improvement projects in the 2004 and 2007 RTPs.
As a result of the Bakersfield System Study, the City of Bakersfield (City) contracted with URS
Corporation to prepare Project Study Reports for the Oak Street/24th Street Interchange Project
(Interchange Project; URS Corporation 2005a) and 24th Street Widening Project (Widening
Project; URS Corporation 2005b), from Oak Street to D Street. These studies were finalized in
2005 and became the foundation for an Interchange Project environmental document and a
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 24
Widening Project environmental document. The City contracted with RBF Consulting in July
2007 to begin work on these environmental documents.
As RBF Consulting was collecting information and data and analyzing them, it became evident
that both the Interchange Project and the Widening Project should be revisited. It also became
apparent that, for the 24th Street corridor to function operationally, the two projects should be
combined, and the improvement limits should be extended both to the east and to the west, as
described in Section 1.2.
Supplemental Project Study Reports were prepared for the Widening Project (RBF Consulting
2011a) and Interchange Project (RBF Consulting 2011b). The major revisions to the Interchange
Project were that improvements, but not a full interchange, were required to the Oak Street/24th
Street intersection and improvements were required to State Route 99. The major revisions to the
Widening Project were that the limits of the project would need to be extended from D Street to
east of M Street, and would need to include widening the 23rd Street/24th Street couplet.
The 2011 RTP indicates that the two projects have been combined, and its description of the Oak
Street / 24th Street improvements did not include an interchange. The 2007 RTP included an
Environmental Impact Report that evaluated road improvements at a programmatic level. The
2007 RTP Environmental Impact Report process included consideration of alternatives, and
public involvement and commentary.6 Projects identified in the current RTP constrained
(funded) list of projects include:
Widening 24th Street through downtown and the Westchester neighborhood;
Upgrading and widening Golden State Highway (State Route 204) from four lanes to six
lanes, including an extension to Hageman Avenue (the Hageman Flyover);
Reconstructing the interchange of Golden State Highway (State Route 204) at State
Route 178; and
Constructing an interchange on Golden State Highway (State Route 204) at F Street.
This comprehensive and extensive project development process led to the refinement of a limited
set of alternatives that represented the most viable candidates for consideration in the Draft
Environmental Impact Report/Environmental Assessment (May 2012). Two of these alternatives
are addressed in detail in the environmental document as Build Alternatives 1 (Widening to the
North) and 2 (Widening to the South). The 2011 Supplemental Project Study Reports for the
Interchange Project and Widening Project also evaluated additional alternatives from the
Interchange Project Study Report (URS Corporation 2005a) and additional alternatives from the
Widening Project Study Report (URS Corporation 2005b).
6 The 2011 Regional Transportation Plan was evaluated in an Environmental Impact Report, which was not
challenged and is, therefore, presumed to be legally adequate. This is why off-site project alternatives do not have
to be revisited each time a new project consistent with the Plan is approved.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 25
These eight alternatives addressed segments of an overall project that encompassed both the Oak
Street/24th Street intersection and the widening of 24th Street from Olive Street to D Street, as
well as other elements. The alternative segments would not, by themselves, be viable. To
properly analyze these segments and to assure a complete and thorough cost and environmental
impact comparison, the eight alternatives need to be considered in the context of the overall
project. The following analysis provides a detailed explanation as to why these eight alternatives
were considered and withdrawn.
In addition to the eight rejected alternatives discussed above, two additional potential alternatives
were requested by the Citizens Against 24th Street (Petitioners). As stated in the Court’s
transcript:
“Petitioner further contends the City was presented with numerous alternatives that were
not meaningfully explored. And then the Petitioner presents a list of those alternatives in
their brief.”
(Excerpts from Reporter’s Transcript of Proceeding page 7, Friday, May 1, 2015, Citizens Against the 24th Street
Widening Project, an unincorporated association vs. City of Bakersfield, a Municipal Corporation).
Two alternative scenarios suggested by the Petitioner that expanded the range of alternatives
were added to this Recirculated Draft Environmental Impact Report for further analysis. One of
these alternatives is an off-site alternative and the other alternative addresses the segment of 24th
Street from Olive Street to D Street.
1.3.6.1 California Environmental Quality Act (CEQA) Alternatives Threshold
Selection Criteria
The potential alternatives to the proposed project were evaluated for compliance with the
threshold selection criteria, described in CEQA Guidelines Section 15126.6(c) and discussed
below, which are used to qualify viable alternatives to the proposed project. Specifically, the
Court stated:
“The Respondents must then adequately analyze and discuss whether or not each of the
potentially feasible alternatives satisfies the four threshold criteria under Guidelines
Section 15126.6. If any one of those four criteria is not satisfied, then that alternative
may be eliminated.”
(Excerpts from Reporter’s Transcript of Proceeding page 22, Friday, May 1, 2015, Citizens Against the 24th Street
Widening Project, an unincorporated association vs. City of Bakersfield, a Municipal Corporation).
To be qualified for detailed analysis in the environmental document, at the minimum, an
alternative should be feasible and reasonable, and should achieve most of the proposed project’s
objectives. Alternatives that avoid or reduce significant impacts should be identified, if possible.
The typical screening process is illustrated in Figure 1-13 below:
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 26
Figure 1-13. Alternatives Screening Process
Criterion #1 - Environmental:
Will the alternative avoid or substantially lessen the significant environmental impacts of
the project as proposed?
One California Environmental Quality Act (CEQA) criterion for identifying appropriate
alternatives is whether the alternative has the potential to “avoid or substantially lessen any of
the significant effects of the project” (CEQA Guidelines Section 16126.6(a)). An alternative that
clearly would not provide an overall environmental advantage compared to the proposed project
may be eliminated from further consideration. At the screening stage, it is not possible to
evaluate all of the impacts of the alternatives in comparison to the proposed project with
certainty, nor is it possible to quantify all impacts. However, it is possible to identify elements of
an alternative that are likely to be the sources of impacts and to determine the approximate level
of impact relative to the proposed project.
Criterion #2 - Project Objectives:
Will the alternative attain most or all of the basic project objectives?
The primary objective of the proposed project is to relieve existing traffic congestion on 24th
Street in the corridor from west of State Route 99 to east of M Street, while also providing the
roadway capacity necessary to handle the future traffic volumes anticipated by the growth in
population and employment through 2035. The objectives are to achieve a Level of Service of C
or better in the design year7 and to help maintain and improve the safety of motorists, public
transit riders, and pedestrians. The extent to which an alternative addresses the objectives of the
proposed project is the key criterion used to advance an alternative for more-detailed
consideration in the environmental document, but alternatives still must satisfy other criteria.
7Level of Service is a standard roadway scoring system similar to a report card with letter grades A through F, with
A representing the best conditions (free-flowing traffic) and F, the worst (severe congestion and delay).
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 27
Travel demands in the 24th Street corridor, particularly during peak demand periods, exceed the
design capacity of the existing transportation facility, which is estimated at approximately 1,600
vehicles per hour in each direction. An over-capacity roadway is unsafe, restricts commerce,
degrades air quality, contributes to noise pollution, and undermines the operability of a traffic
facility. As shown in Table 1.4, 24th Street is the second-busiest arterial road serving downtown
Bakersfield. The 24th Street corridor between Olive Street and D Street is operating very
inefficiently at Level of Service E, carrying traffic volumes higher than the facility can
adequately or safely accommodate. With only four travel lanes, the 24th Street corridor creates a
bottleneck because it has less traffic capacity than adjacent sections of 24th Street.
Table 1.4. Twelve Busiest Arterial Roads in Bakersfield
Arterial Location Lanes Volume (AADT) Year
1 Olive Drive East of Knudson
Drive
4 53,728 2015
2 23rd Street/24th
Street
West of F Street 4 53,651 2015
3 Truxtun Avenue Between Oak Street
and State Route 99
4 52,021 2014
4 Stockdale Highway West of California
Avenue
6 46,068 2015
5 Coffee Road South of Truxtun
Avenue
6 45,887 2014
6 Rosedale Highway West of Mohawk
Street
4 43,432 2015
7 California Avenue North of Stockdale
Highway
6 42,946 2015
8 Ming Avenue East of Stine Road 6 38,278 2015
9 Union Avenue South of California
Avenue
6 37,233 2015
10 Calloway Drive North of Stockdale
Highway
6 37,059 2015
11 White Lane West of Ashe Road 6 33,524 2015
12 Oak Street North of California
Avenue
6 33,201 2015
Source: Kern Council of Governments
With the completion of the Rosedale Highway improvement project to the west and
improvements to State Route 178 to the east of the 24th Street corridor, traffic volumes are
anticipated to increase in the future, exacerbating the existing congestion. In the absence of
improvements to the 24th Street corridor, increasing traffic volumes will eventually lower the
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 28
Level of Service and impede business and quality of life. Traffic modeling results indicate that
24th Street would operate at Level of Service F in 2035 if no improvements were made.
Safety is a serious concern on the 24th Street corridor. Accidents along the corridor exceed by
nearly three times the number of accidents on comparable roads due to the existing high traffic
volumes and congestion (City of Bakersfield 2014). The greater volume of vehicles projected to
use 24th Street in the future would create more delays and collisions than are already experienced
under the current conditions. Alternatively, implementation of the proposed project would
relieve traffic congestion along the 24th Street corridor through the 2035 design year. Relieving
traffic congestion would, in turn, make 24th Street safer, reduce energy consumption, and reduce
vehicle emissions of air pollutants.
Secondary project objectives include:
Maintaining or enhancing traffic safety in the community by adhering to established
federal, state, and local roadway design standards and policies;
Maintaining consistency with regional transportation planning objectives, including those
identified in the Regional Transportation Plan and the Circulation Element of the
Metropolitan Bakersfield General Plan;
Minimizing project effects on historic districts, including (in order of importance) loss of
historic buildings, removal of landscaping and other associated character-defining
features, direct parcel acquisitions, and loss of the general fabric, feeling and context of
historic properties;
Minimizing disruption of established residential districts due to loss of housing stock or
to increased traffic, noise, or air pollution, and
Providing cost-effective transportation improvements to the community that provide a
substantial public benefit, while minimizing construction, operating, and maintenance
costs.
For purposes of weighing project objectives, relieving existing traffic congestion and providing
for future estimated traffic volumes outweigh these secondary objectives, although traffic safety
concerns are of paramount importance, and are related to the primary objectives. Minor
differences in capacity or safety would not cause an alternative to be rejected. Maintaining
consistency with regional planning objectives and minimizing impacts on historic districts are
both important secondary objectives, while the remaining two objectives are considered tertiary
goals.
Criterion #3 - Feasibility:
Is the alternative potentially feasible?
CEQA Guidelines Section 15364 defines feasible as, “capable of being accomplished in a
successful manner within a reasonable period of time, taking into account economic,
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 29
environmental, legal, social, and technological factors.” According to the CEQA Guidelines
(Section 15126.6(f)(1)), among the factors that may be taken into account when addressing the
potential feasibility of alternatives are site suitability, economic viability, availability of
infrastructure, general plan consistency, other regulatory limitations, jurisdictional boundaries,
and proponent’s control over alternative sites in determining the range of alternatives to be
evaluated in an Environmental Impact Report. For the screening analysis, the feasibility of
potential alternatives is assessed taking the following factors into consideration:
Economic Infeasibility. The alternative would be so costly that implementation would
be prohibitive, or the relative costs are such that implementation would be imprudent.
Note that local funding for transportation projects within the City comes from (a)
Transportation Development Fees, (b) utility surcharges, and (c) Gas Tax. These sources
of funding are already obligated to service future debt on the City’s $200 million
transportation improvement program over the next 30 years. Any increased costs for the
proposed project improvements would add to the amount of debt to be incurred by the
City, and would be outside of the range of anticipated budget parameters.
Environmental Infeasibility. Implementing the alternative would cause greater
environmental harm than the proposed project, either because a specific type of impact
could be more severe or because the alternative could result in a broader scope of
potentially significant impacts, thereby making the alternative clearly inferior from an
environmental standpoint.
Social Infeasibility. The alternative would cause significant damage to the
socioeconomic structure of the community, disrupt a planned or established community,
or be inconsistent with important community values and needs.
Technical Infeasibility. There are construction, operation, or maintenance constraints
that cannot be overcome.
Criterion #4 - Reasonableness:
Is the alternative reasonable and realistic?
An alternative whose implementation is remote or speculative is not reasonable or realistic. The
implementation of alternatives that are unlikely to be funded, or that require substantial changes
in agency policies or governmental regulations (e.g., changes in zoning or general plan
designations), would be remote. Alternatives that were contingent upon future events or that
relied upon unconventional approaches or technologies would be speculative. An alternative
would also be unreasonable if it provided the same public benefit as the project but cost more or
had more environmental effects. Finally, alternatives that included unnecessary elements or that
were detrimental to public safety would be considered unreasonable.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 30
1.3.6.2 Analysis of Eliminated Alternatives
Sections 1.3.6.3 to 1.3.6.5 below describe each of the eliminated alternatives, and evaluate each
of them against the alternative selection threshold criteria described in the CEQA Guidelines, as
explained in Section 1.3.6.1 above. Nine of the 10 alternatives presented in Sections 1.3.6.3,
1.3.6.4, and 1.3.6.5 consist of four segments, as described in Section 1.2 of the R-DEIR
(Alternative J, the Hageman Flyover, is an off-site alternative that does not have four segments).
In each alternative, improvements to Segment 1 (State Route 99 interchange) and Segment 4
(D Street to M Street) are the same as under the proposed project. In each alternative, the design
of a portion of either Segment 2 (Oak Street intersection) or Segment 3 (24th Street corridor from
Olive Street to D Street) differs from that of the proposed project.8 The alternatives are identified
by the major features of the segment that differ from the proposed project.
1.3.6.3 Segment 2 Alternatives
This section presents the alternatives to Segment 2 (Oak Street/24th Street intersection) of the
proposed project. Improvements to Segments 1, 3, and 4 would remain as described for the
proposed project.
Alternative A - Northeast/Northwest Loop Ramps Interchange
Improvements under this alternative would occur in Segment 2, as shown in the following
diagram.
Segment 1
Proposed Project
Segment 2
Alternative A
Segment 3
Proposed Project
Segment 4
Proposed Project
This alternative would include a grade-separated diamond interchange with two loop ramps at
the Oak Street/24th Street intersection. This interchange would have diamond ramps in the
southwest, southeast, and northeast quadrants and loop ramps in the northwest and northeast
quadrants (see Figure 1-14). A new crossing over the Kern River is included in the alternative.
An estimated 56 full parcels would need to be acquired for this alternative.9 This interchange
configuration was previously identified and studied in the Interchange Project Study Report
(URS Corporation 2005). The total estimated cost of this alternative is $84.7 million in 2014
dollars.10
8See Section 1.2 for a detailed description of the proposed project.
9Comparisons among alternatives are made on the basis of full parcel acquisitions because these are considered to be
a more appropriate basis for comparison than partial property acquisitions.
10Escalated at a rate of 3.5 percent per year from 2005 to 2014, based on costs reported in the Project Study Report
(URS Corporation 2005a).
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 31
Figure 1-14. Alternative A - Northeast/Northwest Loop Ramps Interchange
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 32
Screening Evaluation
Environmental - This alternative would have greater environmental effects than those of the
proposed project primarily because it would occupy a footprint about 85-90 percent larger, as a
result of new ramps and new bridge construction. As a consequence, this alternative would
require more construction materials and would cause more ground disturbance (45.4 acres) with
more potential to encounter subsurface cultural and paleontological resources. Utility conflict
and relocation costs would be higher. Up to 56 parcels of full property acquisitions would be
required, which is more than the number required for the proposed project. Construction noise
impacts and air pollutant emissions could be more substantial than for the proposed project
because of the larger construction footprint. The ramp configuration would create isolated
pockets of land with limited access, reducing or eliminating their potential for development.
Long-term visual impacts, consisting primarily of new ramps and a new bridge over the Kern
River, would be greater than those of the proposed project; views from Beach Park and from the
Kern River Parkway Trail would be most affected. This alternative would create larger areas of
impervious surfaces that would generate more storm water runoff than the proposed project.
Operational noise impacts would be more substantial than those of the proposed project because,
although the traffic volumes would be the same, the elevated interchange would raise the height
of the traffic noise relative to adjacent areas. The effects on biological resources along the Kern
River would be more adverse than for the proposed project because construction of a new bridge
over the river would eliminate or degrade river bank and bottom habitat.
The impacts in Segment 1, Segment 3, and Segment 4, would be as described for the proposed
project. In summary, this alternative would not avoid, reduce, or offset any of the potentially
significant impacts of the proposed project.
Project Objectives – Overall, this alternative would achieve the objectives of the proposed
project as described in Section 1.3.6.1. According to the Project Study Report prepared for the
Interchange Project (URS Corporation 2005b), the Oak Street/24th Street interchange ramps
would operate at Level of Service B to C during the morning and evening peak traffic hours. The
24th Street corridor between Olive Street and D Street would operate at Level of Service C to D
during both morning and evening peak traffic hours. This alternative would create a new travel
route over the Kern River from developed areas to the northwest. Along with other roadway
improvements proposed for Segments 1, 3, and 4, this alternative would achieve the objective of
relieving traffic congestion and providing for future traffic growth. It would also be consistent
with General Plan policies to increase traffic capacity in the project area.
This alternative would generally meet federal, state, and local design standards while reducing
traffic congestion, thus maintaining and enhancing traffic safety. Segment 3 of this alternative
would have the same effects on historic districts and established residential neighborhoods as
would the proposed project. Because this alternative would cost more than the proposed project
while providing a similar benefit, it is considered less cost-effective than the proposed project.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 33
Feasibility – Overall, this alternative would be socially and economically infeasible because it
would require more property acquisitions and would cost more than the proposed project.
This alternative would require full acquisition of 56 parcels compared with 23 parcels under the
proposed project, a difference of 143 percent. The additional 33 parcel acquisitions required for
this alternative would be considered socially infeasible because of the greater community
disruption. The acquisition of such a large number of parcels would alter the character of the
neighborhood surrounding the Oak Street/24th Street intersection. This alternative would not
allow for eastbound 24th Street access to the neighborhood north of 24th Street at Beech and Elm
Streets, and would thus require residents to travel easterly to C Street before being able to make a
U-turn.
Estimated construction costs for this alternative of $84.7 million compared to estimated costs of
$46 million11 for the proposed project, a difference of 85 percent, are considered to be imprudent
because the City would need to directly fund the additional $38.7 million. As explained in
Section 1.3.6.1, local funding for transportation projects within the City has already been
obligated to service future debt on the City’s $200 million transportation improvement program
over the next 30 years. Any increased costs for the proposed project improvements would add to
the amount of debt to be incurred by the City, and would be outside of the range of anticipated
budget parameters. Thus this alternative could not reasonably be implemented based on current
economic constraints.
Reasonableness – This alternative is unreasonable. Due to a reduction in the intensity of planned
land uses to the north of the project area, a new crossing on Oak Street over the Kern River is no
longer considered necessary. Constructing facilities that are not needed would not be reasonable.
Summary – This alternative was eliminated from further consideration because it fails three of
the four criteria: it does not avoid, reduce, or offset any of the potentially significant
environmental impacts of the proposed project; it is infeasible; and it is unreasonable.
Alternative B - Single Point Interchange
Improvements under this alternative would occur in Segment 2, as shown in the following
diagram.
Segment 1
Proposed Project
Segment 2
Alternative B
Segment 3
Proposed Project
Segment 4
Proposed Project
11The costs presented here are the total costs for all four project segments, with the cost of the alternative substituted
for the project’s cost for that segment (Segment 2 or Segment 3, depending upon the type of alternative).
Construction costs are escalated at a rate of 3.5% per year to 2014.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 34
Figure 1-15. Alternative B - Single Point Interchange
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 35
This alternative would include a grade-separated interchange at the Oak Street/24th Street
intersection in Segment 2 that focuses all ramps into one common intersection (Figure 1-15). A
new crossing over the Kern River is included in the alternative. An estimated 48 parcels would
need to be acquired for this alternative. This alternative was previously identified and studied in
the Interchange Project Study Report (URS Corporation 2005a). The estimated cost of this
alternative is $82.5 million in 2014 dollars.12
Screening Evaluation
Environmental – This alternative would have greater environmental effects than those of the
proposed project primarily because it would occupy a footprint about 60 percent larger as a result
of new ramps and new bridge construction. As a consequence, this alternative would require
more construction materials and would cause more ground disturbance (38 acres) with more
potential to encounter subsurface cultural and paleontological resources. Utility conflict and
relocation costs would be higher. Up to 48 parcels of full property acquisition would be required,
which is greater than those of the proposed project. Construction noise impacts could be more
substantial than for the proposed project because of the larger construction footprint. This is also
true for the air pollutant emissions during the construction. Land uses in the northeastern
quadrant of the new interchange, between the northern extension of Oak Street and the Carrier
Canal, would be severely impacted.
Long-term visual impacts, consisting primarily of elevated ramps and a new bridge over the
Kern River, would be greater than those of the proposed project; views from Beach Park and
from the Kern River Parkway Trail would be most affected. This alternative would create larger
areas of impervious surfaces that would generate more storm water runoff than the proposed
project. Operational noise impacts would be more substantial than those of the proposed project
because, although the traffic volumes would be the same, the elevated interchange would raise
the height of the traffic noise relative to adjacent areas. The effects on biological resources along
the Kern River would be more adverse than for the proposed project because construction of a
new bridge over the river would eliminate or degrade river bank and bottom habitat.
The impacts in Segments 1, 3, and 4 would be as described for the proposed project. In
summary, this alternative would not avoid, reduce, or offset any of the potentially significant
impacts of the proposed project.
Project Objectives – Overall, this alternative would achieve the project objectives described in
Section 1.3.6.1. According to a Project Study Report prepared for the Interchange Project (URS
Corporation 2005b), the Oak Street/24th Street intersection would operate at a Level of Service D
(morning peak traffic period) and a Level of Service C (evening peak traffic period in the future
(design year 2030). The 24th Street corridor would operate at Level of Service C to D during both
12Escalated at a rate of 3.5% per year from 2005 to 2014, based on costs reported in the Project Study Report (). The
costs presented here are the total costs for all four project segments, with the cost of the alternative substituted for
the project’s cost for that segment (Segment 2 or Segment 3, depending upon the type of alternative).
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 36
morning and evening peak traffic hours. This alternative would increase traffic from the
northwest by providing a new route over the Kern River. In conjunction with proposed
improvements in Segments 1 and 4, this alternative would achieve the primary objective of the
proposed project to relieve current traffic congestion and provide for future traffic growth along
the 24th Street corridor. It would also be consistent with General Plan policies to increase traffic
capacity in the project area.
This alternative would generally meet federal, state, and local design standards while reducing
traffic congestion, thus maintaining and enhancing traffic safety. Segment 3 of this alternative
would have the same effects on historic districts and established residential neighborhoods as
would the proposed project. Because this alternative would cost more than the proposed project,
however, it would not provide cost-effective transportation improvements.
Feasibility – Overall, this alternative would be socially and economically infeasible because it
would require more property acquisition and would cost more than the proposed project.
This alternative would require full acquisition of 48 parcels, compared with 23 parcels under the
proposed project, a difference of about 109 percent. The additional 25 parcel acquisitions
required for this alternative would be considered socially infeasible because of the greater
community disruption. The acquisition of such a large number of parcels would alter the
character of the neighborhood surrounding the Oak Street/24th Street intersection.
Estimated construction costs for this alternative of $82.5 million compared to estimated costs of
$46 million for the proposed project, a difference of 79 percent, are considered to be imprudent
because the City would need to directly fund the additional $36.5 million. As explained in
Section 1.3.6.1, the additional debt that the City would incur would be outside of the range of
anticipated budget parameters. This alternative is unreasonable to be implemented based on
current economic constraints.
Reasonableness - This alternative is considered unreasonable at the present time because a new
crossing of Oak Street over the Kern River is no longer necessary due to the reduction in the
intensity of planned land uses to the northwest of the project area. Constructing facilities that are
not needed would not be reasonable.
Summary – This alternative was eliminated from further consideration because it fails three of
the four criteria: it does not avoid, reduce, or offset any of the potentially significant
environmental impacts of the proposed project; it is infeasible; and it is unreasonable.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 37
Alternative C - Kern River Crossing Alternative
Improvements under this alternative would occur in Segment 2 as shown in the following
diagram.
Segment 1
Proposed Project
Segment 2
Alternative C
Segment 3
Proposed Project
Segment 4
Proposed Project
This alternative would include a new bridge over the Kern River to extend Oak Street to Sillect
Avenue (Figure 1-16). The Oak Street/24th Street intersection would be improved as described
under the proposed project. A Kern River Crossing Alternative was previously identified and
evaluated in a 2011 Supplemental Project Study Report (RBF Consulting) and in the Screening
Criteria Report (City of Bakersfield 2009). This alternative would cost an estimated $56.1
million in 2014 dollars,13 and would require acquisition of 26 parcels.
Screening Evaluation
Environmental – This alternative would have environmental effects greater than those of the
proposed project because it would occupy a larger footprint than that of the proposed project,
primarily because of the new bridge construction. As a consequence, this alternative would
require more construction materials and would cause more ground disturbance (29.1 acres) with
more potential to encounter previously unknown cultural or paleontological resources. Utility
conflict and relocation costs would be higher because this alternative would have a larger
footprint. Construction noise impacts could be more substantial than for the proposed project
because of the larger construction footprint, and noise would impact the Kern River Parkway
Trail and Kern River channel in areas that would not be affected by construction of the proposed
project. This is also true for the air pollutant emissions during the construction. Temporary
closure of the Kern River Parkway Trail would also likely be required for construction of the
bridge.
A new bridge also would degrade the visual quality of the area, especially views from the Kern
River Parkway Trail. This alternative would create larger areas of impervious surfaces that
would generate more storm runoff than the proposed project. Operational noise impacts would be
more substantial than those of the proposed project because the new road connection over the
Kern River would create a new permanent source of traffic noise in that area. Impacts on
biological resources along the Kern River would be more adverse than that of the proposed
project, which does not include a new bridge. Any additional encroachment on the Kern River
channel would have an adverse effect on biological resources by incrementally reducing the
amount and quality of river bank and river bottom habitat.
13The costs presented here are the total costs for all four project segments, with the cost of the alternative substituted
for the project’s cost for that segment (Segment 2 or Segment 3, depending upon the type of alternative).
Construction costs are escalated at a rate of 3.5% per year to 2014.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 38
Figure 1-16. Alternative C - Kern River Crossing
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 39
The impacts in Segment 1, Segment 3, and Segment 4 would be as described for the proposed
project. Overall, this alternative would not avoid, reduce, or offset any of the potentially
significant impacts of the proposed project.
Project Objectives – Overall, this alternative would achieve the proposed project’s objectives
described in Section 1.3.6.1. This alternative would provide the same traffic improvements from
just west of State Route 99 to just east of M Street as would the proposed project, so it would
meet the proposed project’s primary objective of relieving traffic congestion through the 24th
Street corridor. This alternative would increase traffic from the northwest by providing a new
route over the Kern River. By providing increased east-west traffic capacity through central
Bakersfield, this alternative would be consistent with the Regional Transportation Plan and the
Metropolitan General Plan.
This alternative would generally meet federal, state, and local design standards while reducing
traffic congestion, thus maintaining and enhancing traffic safety. Segment 3 of this alternative
would have the same effects on historic districts and established residential neighborhoods as
would the proposed project. This alternative would not be cost-effective because it would include
a costly and unnecessary element, the Kern River Bridge.
Feasibility – Overall, this alternative would be socially feasible because it would require only
three more parcel acquisitions than the propose project, but would be considered economically
infeasible because it would cost more than the proposed project.
This alternative would require full acquisition of 26 parcels, compared with 23 parcels under the
proposed project, a difference of 13 percent. The additional 3 parcel acquisitions required for this
alternative would be considered socially feasible because the level of disruption of the
community would be similar.
Estimated construction costs for this alternative of $56.1 million, compared to estimated costs of
$46 million14 for the proposed project, a difference of 22 percent, are considered to be imprudent
because the City would need to directly fund the additional $10.1 million. As explained in
Section 1.3.6.1, the additional debt that the City would incur would be outside of the range of
anticipated budget parameters. This alternative could not reasonably be implemented based on
current economic constraints.
Reasonableness - This alternative is considered unreasonable at the present time because a new
crossing on Oak Street over the Kern River is no longer considered necessary due to the
reduction in the intensity of planned land uses to the north of the project area. Constructing
facilities that are not needed would not be reasonable.
14The costs presented here are the total costs for all four project segments, with the cost of the alternative substituted
for the project’s cost for that segment (Segment 2 or Segment 3, depending upon the type of alternative).
Construction costs are escalated at a rate of 3.5% per year to 2014.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 40
Summary – This alternative was eliminated from further consideration because it fails three of
the four criteria: it does not avoid, reduce, or offset any of the potentially significant
environmental impacts of the proposed project; it is infeasible; and it is unreasonable.
Alternative D - Interchange Alternative
Improvements under this alternative would occur in Segment 2 as shown in the following
diagram.
Segment 1
Proposed Project
Segment 2
Alternative D
Segment 3
Proposed Project
Segment 4
Proposed Project
This alternative was previously identified and considered in the 2011 Supplemental Project
Study Report (RBF Consulting 2011c), and in the Screening Criteria Report (City of Bakersfield
2009), which considered nine possible interchange configurations in addition to the interchange
configurations represented by Alternatives A and B. For purposes of analysis in this
environmental document, this alternative was assumed to be Screening Criteria Report
Alternative A6a (City of Bakersfield 2009). This interchange would have diamond ramps in the
northwest, southwest, and southeast quadrants and loop ramps in the northwest and southeast
quadrants, and 24th Street would be depressed at the Oak Street overcrossing (Figure 1-17). The
Carrier Canal culvert would be extended south of 24th Street. This alternative does not include a
new bridge over the Kern River. This alternative would cost an estimated $84.6 million in 2014
dollars, and require the acquisition of 36 parcels.15
Screening Evaluation
Environmental - This alternative would have greater environmental effects than those of the
proposed project because it would occupy a larger footprint as the result of construction of a
combination of diamond and loop ramps. As a result, it would require more construction
materials and would cause more ground disturbance (37.1 acres) with more potential to
encounter subsurface cultural and paleontological resources. Utility conflict and relocation costs
would be higher. Up to 36 parcels of full property acquisitions would be required, which is 57
percent greater than those of the proposed project. Construction noise impacts could be more
substantial than for the proposed project because the construction footprint would be larger. The
ramp configuration would create isolated pockets of land with limited access, reducing or
eliminating their potential for development.
15The costs presented here are the total costs for all four project segments, with the cost of the alternative substituted
for the project’s cost for that segment (Segment 2 or Segment 3, depending upon the type of alternative).
Construction costs are escalated at a rate of 3.5% per year to 2014.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 41
Figure 1-17. Alternative D – Interchange
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 42
Visual impacts, consisting primarily of the new ramps and the interchange, would be greater than
those of the proposed project, which does not include any elevated structural elements. This
alternative would create larger areas of impervious surfaces that would generate more storm
runoff than the proposed project. Operational noise impacts would also be greater than those of
the proposed project, primarily because the ramps and interchange would elevate traffic noise
above adjacent areas. The effects on biological resources along the Kern River would be similar
to those of the proposed project because this alternative does not include a new bridge.
The impacts in Segments 1, 3, and 4 would be as described for the proposed project. This
alternative would improve the flow of traffic through the intersection, reducing travel time and
local air pollutant emissions. In summary, this alternative would not avoid, reduce, or offset any
of the potentially significant impacts of the proposed project.
Project Objectives – Overall, this alternative would achieve the project objectives described in
Section 1.3.6.1. Assuming that this alternative would have an effect on traffic congestion similar
to that of Alternatives A or B, the Oak Street/24th Street interchange would operate at a Level of
Service D (morning peak traffic period) and Level of Service C (evening peak traffic period in
the future (design year 2030). The 24th Street corridor would operate at Level of Service C to D
during both morning and evening peak traffic hours. In conjunction with proposed improvements
in Segments 1 and 4, this alternative would achieve the primary objective of the proposed project
to relieve current traffic congestion and provide for future traffic growth along the 24th Street
corridor. It would also be consistent with General Plan policies to increase traffic capacity in the
project area.
This alternative would generally meet federal, state, and local design standards while reducing
traffic congestion, thus maintaining and enhancing traffic safety. Segment 3 of this alternative
would have the same effects on historic districts and established residential neighborhoods as
would the proposed project. Because this alternative would cost more than the proposed project,
however, it would not provide cost-effective transportation improvements.
Feasibility – Overall, this proposed project would be socially and economically infeasible
because it would require more property acquisition and would cost more than the proposed
project.
This alternative would require the full acquisition of 36 parcels compared with 23 for the
proposed project, a difference of 57 percent. The additional 10 parcel acquisitions required for
this alternative would be considered socially infeasible because of the greater community
disruption. This alternative would not allow for eastbound 24th Street access to the neighborhood
north of 24th Street at Beech and Elm Streets, and would thus require residents to travel easterly
to C Street before being able to make a U-turn.
Estimated construction costs for this alternative of $84.6 million, compared to estimated costs of
$46 million for the proposed project, a difference of 84 percent, are considered to be imprudent
because the City would need to directly fund the additional $38.6 million. As explained in
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 43
Section 1.3.6.1, the additional debt that the City would incur would be outside of the range of
anticipated budget parameters. This alternative could not reasonably be implemented based on
current economic constraints.
Reasonableness - This alternative would not include any unnecessary elements, and is neither
remote nor speculative, so it would be considered reasonable.
Summary – This alternative was eliminated from further consideration because it fails two of
the four criteria: it does not avoid, reduce, or offset any of the potentially significant
environmental impacts of the proposed project and it is infeasible.
Alternative E - Jug Handle Alternative
Improvements under this alternative would occur in Segment 2, as shown in the following
diagram.
Segment 1
Proposed Project
Segment 2
Alternative E
Segment 3
Proposed Project
Segment 4
Proposed Project
This alternative would change the northbound left turn on Oak Street in Segment 2 to a through
movement that loops to the west with a right turn onto 24th Street (Figure 1-18). This alternative
would also change the westbound left turn to a through movement that loops to the north with a
right turn onto southbound Oak Street. An estimated 27 full parcels would need to be acquired
for this alternative.16 This alternative was addressed in the 2011 Supplemental Project Study
Report Construct Interchange at Oak Street (RBF Consulting 2011b) and included in the
Screening Criteria Report (City of Bakersfield 2009) as Alternative A16 – Jug Handle in
Northwest Quadrant. The estimated cost of this alternative is $52.4 million in 2014 dollars.17
Screening Evaluation
Environmental – This alternative would have environmental effects greater than those of the
proposed project, primarily because it would occupy a footprint about 21 percent larger as a
result of the jug handle. It would require more construction materials, and would cause more
ground disturbance (28.9 acres) with more potential to encounter subsurface cultural and
paleontological resources. Utility conflict and relocation costs would be higher because this
alternative would have a larger footprint. Up to 27 parcels of full property acquisitions would be
required, which is four more (17 percent higher) than the number required for the proposed
project. Construction noise impacts could be greater than for the proposed project because of the
larger construction footprint. The jug handle would create an isolated pocket of land with limited
access, reducing or eliminating its potential for development.
16Comparisons among alternatives are made on the basis of full parcel acquisitions because these are considered to
be a more appropriate basis for comparison than partial property acquisitions.
17Escalated at a rate of 3.5% per year from 2005 to 2014, based on costs reported in Project Study Report (URS
Corporation 2005a).
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 44
Figure 1-18. Alternative E - Jug Handle
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 45
Long-term visual impacts, consisting primarily of wider roads and intersections, would be
greater than those of the proposed project; views from Beach Park and from the Kern River
Parkway Trail would be most affected. This alternative would create larger areas of impervious
surfaces that would generate more storm water runoff than the proposed project. Operational
noise impacts would be more substantial than those of the proposed project because, although the
traffic volumes would be the same, the jug handle would increase traffic noise levels in areas
northwest of the Oak Street/24th Street intersection, bringing traffic noise closer to the Kern
River Bikeway Trail. The effects on biological resources along the Kern River would be more
adverse than for the proposed project because widening of an existing bridge over the river
would have incremental effects on biological resources along the river.
The impacts in Segment 1, Segment 3, and Segment 4 would be as described for the proposed
project. In summary, this alternative would not avoid, reduce, or offset any of the potentially
significant impacts of the proposed project.
Project Objectives – Overall, this alternative would achieve the project objectives described in
Section 1.3.6.1. This alternative would have an effect on traffic congestion similar to that of
Alternatives A or B by improving the flow of traffic along 24th Street. The Oak Street/24th Street
intersection would operate at a Level of Service D (morning peak traffic period) and Level of
Service C (evening peak traffic period in the future (design year 2030). The 24th Street corridor
would operate at Level of Service C to D during both morning and evening peak traffic hours. In
conjunction with proposed improvements in Segments 1 and 4, this alternative would achieve the
primary objective of the proposed project to relieve current traffic congestion and provide for
future traffic growth along the 24th Street corridor. It would also be consistent with General Plan
policies to increase traffic capacity in the project area.
This alternative would generally meet federal, state, and local design standards while reducing
traffic congestion. However, this alternative would introduce design elements that could be
confusing for motorists, possibly encouraging unsafe turns and driver distraction, and requiring
more merging and weaving for cars to enter and exit the flow of traffic. Segment 3 of this
alternative would have the same effects on historic districts and established residential
neighborhoods as would the proposed project. Because this alternative would cost more than the
proposed project, however, it would not provide cost-effective transportation improvements.
Feasibility – This alternative is considered to be socially and economically feasible. This
alternative would require full acquisition of 27 parcels, compared with 23 for the proposed project,
a difference of 17 percent. The additional acquisitions of four parcels required for this alternative
would be considered socially feasible because of the similar level of community disruption.
Estimated construction costs for this alternative of $52.4 million compared to estimated costs of
$46 million for the proposed project, a difference of 13 percent, are considered to be prudent.
The City would need to directly fund the remaining $6.4 million. This alternative could
reasonably be implemented based on current economic constraints.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 46
Reasonableness – This alternative is unreasonable. This alternative has a substantial safety
concern for motorists unfamiliar with the jug-handle configuration of the intersection, which
could cause confusion. Drivers believing that they had missed their turn or that they were being
routed in the wrong direction might attempt illegal turns or unsafe lane changes. Drivers may slow
down or may be inattentive while they are attempting to understand the design of the interchange.
Road improvements that could compromise motorists’ safety are not considered to be reasonable.
Summary – This alternative was eliminated from further consideration because it fails two of
the four criteria: it does not avoid, reduce, or offset any of the potentially significant
environmental impacts of the proposed project and it would not be reasonable.
1.3.6.4 Segment 3 Alternatives
This section presents the alternatives to Segment 3 (from Olive Street to D) of the proposed
project. Segments 1, 2, and 4 would remain the same as the proposed improvements under the
proposed project.
Alternative F - Two Depressed Alternatives to Widen 24th Street to Six Lanes
Improvements under each of the depressed alternatives would occur in Segment 3, as shown in
the following diagram.
Segment 1
Proposed Project
Segment 2
Proposed Project
Segment 3
Alternatives F1 or F2
Segment 4
Proposed Project
Both of the proposed depressed alternatives (F1 and F2) would include the widening of 24th
Street between Olive Street and D Street in Segment 3 to a six-lane arterial roadway, which
would be at-grade with Oak Street and depressed within the residential neighborhood along 24th
Street between Olive Street and C Street. Construction of the depressed section of the roadway
would require excavation to a depth of 19 to 21 feet below the existing grade. Alternative F1
(Figure 1-19) would include the construction of retaining walls, while Alternative F2 (Figure 1-
20) would not include retaining walls. An additional 50 feet of right-of-way would be required if
the sides of the depressed section were sloped at a 4:1 ratio in lieu of a retaining wall, requiring
more full and partial property acquisitions. A frontage road would provide access to properties on
the north side of 24th Street. Construction of Alternative F1 (with retaining walls) or F2 (without
retaining walls) would require an acquisition of approximately 23 or 37 parcels, respectively.
These two alternatives appear as Alternatives B8 and B9 in the Screening Criteria Report (City of
Bakersfield 2009), and were first identified and evaluated in a 2005 Project Study Report (URS
Corporation 2005b). The estimated costs of Alternatives F1 and F2 are $69.4 and $71.6 million in
2014 dollars18, respectively.
18The costs presented here are the total costs for all four project segments, with the cost of the alternative substituted
for the project’s cost for that segment (Segment 2 or Segment 3, depending upon the type of alternative).
Construction costs are escalated at a rate of 3.5% per year to 2014.
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Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 49
Screening Evaluation
Environmental – Both Alternatives F1 and F2 would have greater environmental effects than
those of the proposed project, primarily because:
Alternative F1 (with retaining walls) would occupy a footprint approximately 11 percent
larger as a result of the wider right-of-way necessary for the depressed section, the
greater depth of construction, and the larger amount of material to be excavated and
removed from the site.
Alternative F2 (without retaining walls) would occupy a footprint approximately 42
percent larger as a result of the wider right-of-way necessary for the depressed section,
the greater depth of construction, and the larger amount of material to be excavated and
removed from the site.
As a consequence, Alternatives F1 and F2 would require more construction materials and would
cause more ground disturbance (26.4 or 33.8 acres) with more potential to encounter subsurface
cultural and paleontological resources. Utility conflict and relocation costs would be higher
because both alternatives would have larger footprints than the proposed project. Alternative F1
would require full property acquisitions of 23 parcels and Alternative F2 would require 37
parcels of full property acquisitions, which are both greater than for the proposed project. The
eastern approach to the depressed section could require acquisition of parcels with historic
structures (bungalows) on them. Construction noise impacts could be more substantial than for
the proposed project because of the larger construction footprint and the larger amount of soil to
be excavated and transported from the site by truck. Groundwater could be contaminated during
construction and drilling mud disposal would generate potentially hazardous wastes. The depth
of construction would require extensive relocation of utilities.
Long-term visual impacts, consisting primarily of a large depression between the north and south
sides of 24th Street between Olive Street and D Street, would be greater than those of the
proposed project. Views from properties on the northern and southern sides of 24th Street
between Olive Street and D Street would be most affected. Alternative F1 would create areas of
impervious surfaces similar to those for the proposed project while Alternative F2 would result
in larger areas of impervious surfaces than those for the proposed project, and pumping stations
would be needed to remove storm water and ground water from the depressed section of the
road. The depressed arterial alternative without retaining walls (F2) would have a greater impact
on historic districts than the proposed project, requiring the acquisition of an additional 14
parcels. Operational noise impacts from either of these alternatives would be less than those of
the proposed project because the roadway would be depressed relative to surrounding urban
development. The effects on biological resources of either alternative along 24th Street would be
more adverse than for the proposed project because a depressed arterial would be more of a
barrier to terrestrial wildlife than the proposed project, especially Alternative F1 which includes
retaining walls.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 50
The impacts in Segment 1, Segment 2, and Segment 4 would be as described for the proposed
project. Both Alternatives F1 and F2 would not reduce any potentially significant impacts of the
proposed project, other than operational noise impacts.
Project Objectives – Overall, Alternatives F1 and F2 would achieve the project’s objectives
described in Section 1.3.6.1. Traffic congestion relief between Olive Street and D Street under
both Alternatives F1 and F2 would be similar to that of the proposed project because both
alternatives would provide the same number of travel lanes. Therefore, the 24th Street corridor
would operate at Level of Service C to D during both morning and evening peak traffic hours.
The Oak Street/24th Street intersection would operate at a Level of Service D (morning peak
traffic period) and a Level of Service C (evening peak traffic period in the future (design year
2030)). In conjunction with proposed improvements in Segments 1 and 4, Both Alternatives F1
and F2 would achieve the primary objective of the proposed project to relieve current traffic
congestion and provide for future traffic growth along the 24th Street corridor. Both alternatives
would also be consistent with General Plan policies to increase traffic capacity in the project
area.
Both Alternatives F1 and F2 would generally meet federal, state, and local design standards
while reducing traffic congestion, thus maintaining and enhancing traffic safety. Construction of
either alternative would be more disruptive to the adjacent residential districts than the proposed
project because of the greater truck traffic to haul away excavated material, and more noise and
dust from the extensive excavation necessary to lower the roadbed during construction. Either
Alternatives F1 or F2 would result in more disruptive to the community because the depressed
section of road would be a greater barrier between the residential areas on the north and south
sides of 24th Street than the existing roadway. With only three bridges across the depressed
arterial (Beech, Pine, and B Streets), access to residential areas north of 24th Street would be
greatly restricted. While Alternative F1 (with retaining walls) would have effects on historic
districts similar to those of the proposed project, Alternative F2 (without retaining walls) would
have a greater impact on historic districts than the proposed project because it would require
acquisition of 14 additional properties in historic districts.
Because both Alternatives F1 and F2 would cost more than the proposed project, neither
alternative would provide cost-effective transportation improvements.
Feasibility – Overall, Alternative F1 (with retaining walls) would be socially feasible but
technically and economically infeasible, while Alternative F2 (without retaining walls) would be
infeasible for social, technical, and economical reasons.
Due to slope and set-back requirements, Alternative F1 (with retaining walls) would require the
same number (23) of full parcel acquisition as the proposed project while Alternative F2 (without
retaining walls) would require 37 parcels, a difference of 61 percent. Since no additional parcel
acquisitions would be required for Alternative F1, it would be considered socially feasible.
Alternative F2, however, would be considered socially infeasible because it would require
additional 14 parcel acquisitions, causing greater community disruption.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 51
Estimated construction costs of $69.4 million for Alternative F1 and $71.6 million for
Alternative F2 compared to estimated costs of $46 million19 for the proposed project, a
difference of 51 or 56 percent, are considered to be imprudent because the City would need to
directly fund the additional $23.4 or $25.6 million. As explained in Section 3.1.6.1, the
additional debt that the City would incur would be outside of the range of anticipated budget
parameters. Either of these alternatives could not reasonably be implemented based on current
economic constraints.
In terms of technical feasibility, the eastbound reverse curves required for both Alternatives F1
and F2 do not account for corner sight distance at D Street, rendering them unsafe. The
anticipated depth of the depressed section would require a steep grade on its western end to
accommodate the Carrier Canal, or else the canal would need to be re-routed. There is no direct
access to the north side neighborhood, so residents would need to travel though the south side
neighborhood to reach the north side neighborhood via bridges at Beech, Pine, or B Streets.
Finally, the transition from an at-grade roadway to a depressed roadway section on the eastern
end of the section, where it joins the 23rd Street/24th Street couplet, poses engineering challenges.
Reasonableness – Overall, both Alternatives F1 and F2 are considered unreasonable due to cost
and safety issues. Both Alternative F1 and F2 are deemed to be too costly ($69.4 or $71.6 million
in 2014 dollars) relative to other available alternatives. The eastbound reverse curves required for
both alternatives do not account for corner sight distance at D Street, rendering them unsafe.
Summary – Both Alternatives F1 and F2 were eliminated from further consideration because
they fail three of the four criteria: they do not avoid, reduce, or offset any of the potentially
significant environmental impacts of the proposed project; they are infeasible, and they are not
considered to be reasonable.
Alternative G – Frontage Road Alternative
Improvements under this alternative would occur in Segment 3, as shown in the following
diagram.
Segment 1
Proposed Project
Segment 2
Proposed Project
Segment 3
Alternatives G1, G2, G3, G4
Segment 4
Proposed Project
This alternative was addressed in the 2011 Supplemental Project Study Report 24th Street
Widening (RBF Consulting 2011a) and was included in the Screening Criteria Report (City of
Bakersfield 2009), which identified four possible frontage road configurations (Figures 1-21 to
1-24):
Alternative G1: Widening 24th Street on the south side with frontage road on the north
side;
19The costs presented here are the total costs for all four project segments, with the cost of the alternative substituted
for the project’s cost for that segment (Segment 2 or Segment 3, depending upon the type of alternative).
Construction costs are escalated at a rate of 3.5% per year to 2014.
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Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 56
Alternative G2: Widening 24th Street on the north side with frontage road on the north
side and a traffic signal at 24th Street/Myrtle Street;
Alternative G3: Widening both sides of 24th Street with frontage road on the north side;
and
Alternative G4: Widening 24th Street on the south side with frontage road off of northerly
curb, and a traffic signal at 24th Street/Myrtle Street.
The common elements of these configurations are that a frontage road would require a wider
right-of-way, would alter traffic circulation along 24th Street in Segment 3 (between Olive Street
and D Street), and would incrementally increase construction impacts. Depending upon its
configuration, a frontage road alternative would cost $51.6 to $56.7 million in 2014 dollars.20
Approximately 30 to 35 parcels would need to be acquired.
Screening Evaluation
Environmental – Alternatives G1-G4 would have greater environmental effects than those of
the proposed project, primarily because they would require a wider right-of-way. As a
consequence, these alternatives would require more construction materials and would cause more
ground disturbance (ranging from 31.1 to 32.4 acres, depending on the configurations) with more
potential to encounter subsurface cultural and paleontological resources. Utility conflict and
relocation costs would be higher. Up to 30 to 35 parcels of full property acquisitions, depending
on the configurations, would be required, which are greater than those of the proposed project.
Construction noise impacts could be more substantial than for the proposed project because of
the larger construction footprint. This is true for the air pollutant emissions during construction.
Alternatives G1-G4 would have an incrementally greater effect on visual and aesthetic resources
than the proposed project due to the wider road and additional traffic lanes. Alternatives G1-G4
would require more property acquisitions in historic districts than would the proposed project.
These alternatives would also create larger areas of impervious surfaces and generate more storm
water runoff than the proposed project. Operational traffic noise along the 24th Street corridor
between Olive Street and D Street would be about the same as under the proposed project with
any of these alternatives because the traffic volumes and distribution would be about the same.
With a larger footprint, Alternatives G1-G4 would present a greater barrier to terrestrial wildlife
than the proposed project.
The impacts in Segment 1, Segment 2, and Segment 4 would be as described for the proposed
project. Overall, Alternatives G1-G4 would not avoid or substantially lessen any of the
potentially significant impacts of the project as proposed.
20The costs presented here are the total costs for all four project segments, with the cost of the alternative substituted
for the project’s cost for that segment (Segment 2 or Segment 3, depending upon the type of alternative).
Construction costs are escalated at a rate of 3.5% per year to 2014.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 57
Project Objectives – Overall, Alternatives G1-G4 would achieve the objectives of the proposed
project as described in Section 1.3.6.1. Traffic congestion relief between Olive Street and
D Street under Alternatives G1-G4 would be similar to that of the proposed project because they
would provide the same number of travel lanes. Therefore, the 24th Street corridor would operate
at Level of Service C to D during both morning and evening peak traffic hours. The Oak
Street/24th Street intersection would operate at a Level of Service D (morning peak traffic
period) and Level of Service C (evening peak traffic period in the future [design year 2030]). In
conjunction with proposed improvements in Segments 1 and 4, Alternatives G1-G4 would be
able to relieve current traffic congestion and provide for future traffic growth along the 24th
Street corridor. They would also be consistent with General Plan policies to increase traffic
capacity in the project area.
Alternatives G1-G4 would generally meet federal, state, and local design standards while
reducing traffic congestion, thus maintaining and enhancing traffic safety. Any of the
Alternatives G1-G4 generally would result in more disruption of the two established residential
districts along the 24th Street corridor because they would require a wider right-of-way than the
proposed project and more properties would need to be acquired. For the same reason, they
would have a greater effect on historic districts. Because Alternatives G1-G4 would have higher
costs while providing the same benefit as the proposed project, construction of any of these
alternatives would be considered less cost-effective.
Feasibility – Alternatives G1-G4 would be socially and economically infeasible because either
of them would require more property acquisition and would cost more than the proposed project.
Alternatives G1-G4 would require full acquisition of 30 to 35 parcels (depending on the
alternative selected), compared with 23 parcels under the proposed project, a difference of 30 to
52 percent. The additional 7 to 12 parcel acquisitions required for any of these alternatives would
be considered socially infeasible because of the greater community disruption. Alternatives G1
and G3 would provide no eastbound access to the north side neighborhood, isolating this
neighborhood and affecting the social feasibility of these configurations.
Estimated construction costs for Alternatives G1-G4 ranging from $51.6 to $56.7 million
compared to estimated costs of $46 million for the proposed project, a difference of 12 to 23
percent, are considered to be imprudent because the City would need to directly fund the
additional $5.6 million to $10.7 million. As explained in Section 1.3.6.1, the additional debt that
the City would incur would be outside of the range of anticipated budget parameters.
Alternatives G1-G4 could not reasonably be implemented based on current economic constraints.
Reasonableness – Construction of Alternatives G1-G4 is considered unreasonable because the
wider right-of-way along 24th Street between Olive Street and D Street for this alternative
compared to that of the proposed project would outweigh the public benefit.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 58
Summary – Alternatives G1-G4 were eliminated from further consideration because all of them
fail three of the four criteria: they would not avoid, reduce, or offset any potentially significant
environmental effects of the proposed project, they are infeasible, and they are unreasonable.
Alternative H - Widening Both Sides of 24th Street
Improvements under this alternative would occur in Segment 3, as shown in the following
diagram.
Segment 1
Proposed Project
Segment 2
Proposed Project
Segment 3
Alternative H
Segment 4
Proposed Project
Widening both sides of 24th Street between Olive Street and D Street in Segment 3, with and
without a frontage road on the north side, was previously considered in both the Screening
Criteria Report (City of Bakersfield 2009) and in the 2011 Supplemental Project Study Report
24th Street Widening (RBF Consulting 2011a). This alternative would consist of widening both
sides of 24th Street without a frontage road (Figure 1-25). The cost for this alternative is
estimated to be $53.2 million in 2014 dollars; 32 parcels would need to be acquired.21
Screening Evaluation
Environmental – This alternative would have greater environmental effects than those of the
proposed project, primarily because it would impact properties in historic districts on both the
north and south sides of 24th Street between Olive Street and D Street. Up to 32 parcels of full
property acquisitions would be required, which is about 40 percent more than the number
required for the proposed project. The area of ground disturbance (24.3 acres) and potential
effects on cultural and paleontological resources would be similar to those of the proposed
project. Other impacts of construction activities, such as air pollutant emissions and noise, would
be the same as for the proposed project.
This alternative would have an effect on visual and aesthetic resources similar to that of the
proposed project because 24th Street would be about the same width, but property acquisitions on
both sides of the road would move the road closer to existing structures. This alternative would
require 9 more property acquisitions in historic districts than would the proposed project, thus
having a greater impact on historic resources. This alternative also would cause more community
disruption because it would affect more properties. This alternative would create similar areas of
impervious surfaces and generate similar amounts of storm water runoff as the proposed project.
Operational traffic noise along the 24th Street corridor between Olive Street and D Street would
be the same as under the proposed project because the traffic volumes and distribution would be
the same. This alternative would present a barrier to terrestrial wildlife similar to that of the
proposed project because it would be the same width.
21The costs presented here are the total costs for all four project segments, with the cost of the alternative substituted
for the project’s cost for that segment (Segment 2 or Segment 3, depending upon the type of alternative).
Construction costs are escalated at a rate of 3.5% per year to 2014.
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Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 60
The impacts in Segment 1, Segment 2, and Segment 4 would be the same as those of the
proposed project. This alternative would not reduce any of the potentially significant impacts of
the proposed project.
Project Objectives – Overall, this alternative would achieve the project objectives of the
proposed project, as described in Section 1.3.6.1. Traffic congestion relief between Olive Street
and D Street under this alternative would be similar to that of the proposed project because it
would provide the same number of travel lanes. Therefore, the 24th Street corridor would operate
at Level of Service C to D during both morning and evening peak traffic hours. The Oak
Street/24th Street intersection would operate at a Level of Service D (morning peak traffic
period) and Level of Service C (evening peak traffic period in the future design year 2030). In
conjunction with proposed improvements in Segments 1 and 4, this alternative would achieve the
primary objective of the proposed project to relieve current traffic congestion and provide for
future traffic growth along the 24th Street corridor. It would also be consistent with General Plan
policies to increase traffic capacity in the project area.
This alternative would generally meet federal, state, and local design standards while reducing
traffic congestion, thus maintaining and enhancing traffic safety. This alternative would be more
disruptive of established residential districts than the proposed project and have a greater effect
on historic districts because it would require the acquisition of properties on both sides of 24th
Street and would require more property acquisitions (32 compared to 23) than the proposed
project.
Feasibility – This alternative would be economically feasible but socially infeasible because it
would require more property acquisitions than the proposed project.
This alternative would require 32 full parcel acquisitions on both sides of 24th Street compared
with 23 property acquisitions under the proposed project, a difference of 39 percent. Property
acquisitions on both the northern and southern sides of 24th Street would result in more
disruption of the existing residential community than widening either side of the street.
Estimated construction costs for this alternative of $53.2 million compared to estimated costs of
$46 million for the proposed project, a difference of 15 percent, are considered marginally
feasible. The City would need to directly fund the additional $7.2 million. This alternative could
reasonably be implemented based on current economic constraints.
Reasonableness – This alternative is unreasonable because it would cost more and be more
disruptive to the community than that of the proposed project, with the same public benefit.
Expending more public funds and creating more community disruption to achieve the same
public benefit is deemed to be unreasonable.
Summary – This alternative was eliminated from further consideration because it fails on three
of the four criteria: it does not avoid, reduce, or offset any potentially significant environmental
effects of the proposed project; it is infeasible; and it is unreasonable.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 61
1.3.6.5 Citizen-Suggested Alternatives
The following two alternatives (restriping of 24th Street and Hageman Flyover) were not
addressed in the 2013 FEIR. They are included here at the request of citizens. Restriping of 24th
Street (Alternative I) is a Segment 3 alternative. Hageman Flyover (Alternative J) is an off-site
alternative.
Alternative I – Restriping 24th Street
Improvements under this alternative would occur in Segment 3, as shown in the following
diagram.
Segment 1
Proposed Project
Segment 2
Proposed Project
Segment 3
Alternative I
Segment 4
Proposed Project
24th Street is on the National Highway System, which carries many large vehicles, and is the
direct connection between State Route 58/State Route 99 on the west and State Route 178 on the
east. The Circulation Element of the Metropolitan Bakersfield General Plan classifies 24th Street
(SR-178) as an Arterial roadway. It is not a designated Bike Route.
The standard right-of-way for an Arterial roadway is 110 feet wide and 90 feet curb-to-curb
without bike lanes. The standard includes two 12-foot-wide inside lanes and one 14-foot-wide
outside lane adjacent to the curb and gutter. In addition, an Arterial roadway includes a 14-foot-
wide raised median and 6-foot-wide sidewalks on both sides of the roadway.
Currently, from Olive Street to D Street, 24th Street does not meet the Arterial standards
described above. The right-of-way on this portion of 24th Street is 82.5 feet wide, and the
roadway is approximately 72 feet wide from curb to curb. The existing road has an 11-foot wide
median with left-turn pockets. The sidewalks on either side of 24th Street are not continuous.
Alternative I, proposed by the citizens, would restripe the existing 72-foot roadway to six lanes.
In both the eastbound and westbound directions, the outside lane of 24th Street between Elm
Street and B Street in Segment 3 would be restriped to a width of 13 feet and the two inside lanes
would each be restriped to 11 feet (Figure 1-26). Alternative I thus would reduce the width of
each lane by 1 foot below the City’s standard width. No shoulders would be accommodated.
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24th Street Improvement Project FEIR/EA Volume 3 63
A 2-foot-wide striped median would provide the separation between opposing lanes of traffic in
place of a standard 14-foot-wide raised median.
The entire roadway would be resurfaced and drainage would be re-engineered by lowering the
crown of the roadway and removing the dips at the cross street curb returns. Figure 1-27 shows a
cross-section of 24th Street under the Restriping Alternative compared to a standard cross-
section.
Several driveways and alleys enter onto 24th Street between Olive Street and D Street. The alleys
on the south side would need larger curb radii. All driveways along the north side of 24th Street
and garages facing 24th Street along the south side of the street between Elm Street and B Street
in Segment 3 would be removed to prevent residents from backing out into the street, which
could conflict with through traffic and thus create unsafe situations. Additional properties would
need to be purchased due to the closure of driveways eliminating access to the property.
The narrower lanes, in conjunction with the absence of an outside shoulder, would constrict the
flow of traffic on 24th Street, as well as restricting turning movements onto and from side streets
and alleys. The combination of narrow lanes and minimal separation between opposing lanes of
traffic would increase the potential for head-on accidents. No space would be available for left-
turn movements, the striped median would not provide sufficient width for vehicles to move out
of the travel lanes to make left turn movements, and the striped median would not prevent left-
turn movements onto or from 24th Street. Striping 24th Street to six lanes within the existing
roadway would reduce lines-of-sight below acceptable levels and restrict the ability of large
service vehicles, such as trash trucks, to turn into an alley. Large service vehicles would need to
occupy the two outside lanes to make turning movements, increasing the potential for rear-end
and side-swipe accidents. The sidewalk widths would not meet the City standard and, in some
areas, would not meet the Americans with Disabilities Act requirement for a minimum 4-foot-
wide sidewalk.
Alternative I would create conflicts between competing project design requirements. Where
sound walls are required, sidewalks may not be wide enough to meet the minimum 4-foot-width
required by the Americans with Disabilities Act. The narrow right-of-way would also require
trade-offs between line-of-sight requirements to maintain street and alley connections to 24th
Street and installation of necessary sound walls. Acquisition of additional rights-of-way could
alleviate some conflicts but, in some areas, additional rights-of-way could not be acquired
without modifying existing residential structures.
The Restriping 24th Street Alternative would cost an estimated $30.4 million in 2014 dollars and
require 12 full parcel acquisitions.22
22The costs presented here are the total costs for all four project segments, with the cost of the alternative substituted
for the project’s cost for that segment (Segment 2 or Segment 3, depending upon the type of alternative).
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 64
Figure 1-27. Cross-Section for Alternative I Compared to Arterial Standard
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 65
Screening Evaluation
Environmental – This alternative would have fewer environmental effects than those of the
proposed project primarily because fewer properties would need to be acquired and overall
construction activity would be less than under the proposed project. Restriping 24th Street
between Elm Street and B Street in Segment 3 would require some expansion of the project
footprint beyond the existing roadway, but the numbers of full property acquisitions required to
implement this alternative (12) would be about 48 percent, or less than half, of those required for
the proposed project. This alternative would require fewer construction materials than the
proposed project and would require less ground disturbance (18 acres) and thereby less potential
to unearth subsurface cultural and paleontological resources than the proposed project. Utility
conflict and relocation costs would be lower because the footprint would be smaller than that of
the proposed project. Construction noise impacts would be less than for the proposed project
because less construction activity would be needed.
This alternative also would not allow sufficient space for a landscaped median or landscaping
along the sides of 24th Street, and would thus have greater impacts on the visual and aesthetic
environment than would the proposed project. With fewer property acquisitions than the
proposed project, this alternative would have fewer impacts on historic districts. Because the
roadway would not be widened under this alternative, it would generate less storm water runoff
than would the proposed project. Operational noise levels in residences along 24th Street would
be higher than under the proposed project because the distance between the curb lane and
adjacent houses would be less, and no space would be available for the construction of sound
walls. Indoor and outdoor air pollutant levels would be higher for the same reason. This
alternative would have less of an impact on terrestrial wildlife than the proposed project because
the right-of-way would be narrower.
The impacts in Segments 1, 2, and 4 would be the same as those of the proposed project. This
alternative would have lesser impacts than the proposed project on property acquisitions, ground
disturbance, cultural, historic, and paleontological resources, water resources, and wildlife, while
having greater impacts on visual and aesthetic resources, operational noise, and air pollutant
exposure.
Project Objectives –This alternative would not achieve the objectives of the proposed project as
described in Section 1.3.6.1 because of the safety issues it would create with its implementation.
Restriping 24th Street between Elm Street and B Street would achieve the primary objective of
relieving traffic congestion along the 24th Street corridor. Traffic congestion relief between Olive
Street and D Street under this alternative would be similar to that of the proposed project because
it would provide the same number of travel lanes. Therefore, the 24th Street corridor would
operate at Level of Service C to D during both morning and evening peak traffic hours. The Oak
Street/24th Street intersection (Segment 2) would operate at a Level of Service D (morning peak
traffic period) and Level of Service C (evening peak traffic period in the future [design year
2030]). In conjunction with proposed improvements in Segments 1 and 4, this alternative would
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 66
achieve the primary objective of the proposed project to relieve current traffic congestion and
provide for future traffic growth along the 24th Street corridor. It would also be consistent with
General Plan policies to increase traffic capacity in the project area.
This alternative, however, would not be consistent with the objective of maintaining or
improving traffic safety, because it would not meet the prevailing mandatory design standards
identified in Caltrans’ Highway Design Manual for lane width for a facility of this type. Lane
widths influence operations, safety, quality of service, and the security felt by road users.
Narrower lanes make it more difficult for drivers to safely maneuver in emergency and non-
emergency situations. Studies show that lanes narrower than 12 feet increase the expected crash
frequency, both with same direction sideswipes and opposite direction vehicle crashes. For
instance, studies show that a roadway carrying 2,000 vehicles per day with 11 foot lanes can
expect 5 percent more crashes than the same roadway with 12 foot lanes (Federal Highway
Administration 2004).
Under this alternative, the space between the opposing lanes of traffic would be insufficient for
creating a proper median to separate oncoming traffic. The line of sight of drivers in the outside
lanes would also be restricted, creating a safety hazard. Turning movements onto or off of 24th
Street between Elm Street and B Street in Segment 3 would also be unsafe because of the
absence of a shoulder and because acceleration and deceleration would be virtually impossible
due to the speed requirements of the road. The American Association of State Highway and
Transportation Officials’ Highway Safety Manual (American Association of State Highway and
Transportation Officials 2010) research on accident data concluded that eliminating the right
shoulder from a facility increases crash frequency by 18 percent. In addition, for purposes of
access control and safety under this alternative, driveways opening onto 24th Street would need
to be eliminated, resulting in garages and properties with no vehicular access. Trash pickups and
other common services to residents along 24th Street would become more hazardous. Because
residents prefer sidewalks to have a buffer and be located well away from traffic, the distance
between high-speed traffic and sidewalks on 24th Street would be reduced, creating a potential
safety hazard. In summary, retrofitting the roadway with constrained movements, constricted
lane widths, high traffic volumes, and high speeds would create an unsafe operating condition.
Aside from the safety concerns itemized above, this alternative would have fewer effects on
historic districts and on established residential districts because it would require acquisition of
fewer parcels than the proposed project. It would cost less than the proposed project, so it would
provide more cost-effective transportation improvements. Overall, however, the serious safety
concerns associated with this alternative would outweigh any benefits and the objectives of the
proposed project would not be met.
Feasibility – Overall, this alternative to restripe 24th Street is considered to be both socially and
technically infeasible because it would create a number of unsafe conditions, and it would not
achieve the required roadway engineering design standards of either the federal, state, or city
government. Because 24th Street between Elm Street and B Street is a federal-aid route, the
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 67
Caltrans Highway Design Manual indicates that it must adhere to the American Association of
State Highway and Transportation Officials’ Policy on Geometric Design of Highways and
Streets for mandatory standards on lane width and medians, which this restriping alternative
would not, as indicated earlier.
This alternative would require full acquisition of 12 parcels, compared with 23 parcels under the
proposed project, or about 48 percent of the number required for the propose project. Properties
would need to be purchased where the closure of driveways eliminated access to the property.
Parcels also would need to be acquired at Elm and Beech Streets to provide access to the
northern side of 24th Street at that point. Still, in terms of the total number of parcels to be
acquired, this alternative could be deemed socially feasible. However, as discussed above,
because turning movements onto and off of side streets would be made much more risky,
because the City would need to purchase residential parcels on 24th Street that would otherwise
lose their access, and because critical and community services, such as garbage pickup, postal
and package delivery, and the like, would be made much more unsafe, the alternative is not
socially feasible.
Restriping 24th Street between Elm Street and B Street in Segment 3, as described above, initially
appears to be economically feasible because the estimated cost of this alternative would be $30
million in 2014 dollars, or $16 million (35 percent) less than the $46 million for the proposed
project. This alternative would not meet the approved mandatory design or safety standards,
however, so federal funds would not be obtained, making this alternative economically
infeasible.
Reasonableness – This alternative would not meet established design requirements and would
consume limited transportation improvement funds to create an unsafe, substandard
transportation facility. Also, as stated in the discussions of Project Objectives and Feasibility for
this alternative, with a substandard engineering design, if the alternative were to go forward it
may create a greater number of unsafe conditions involving head-to-head vehicle collisions and
same direction sideswipes and result in greater exposure of the City to lawsuits in which
plaintiffs seek to recover money to compensate for personal injuries or property damage.
Increasing the risk of tort liability is deemed to be unreasonable.
Summary – This alternative was eliminated from further consideration because it fails three of
the four criteria: it does not achieve the project objectives, it is infeasible, and it is unreasonable.
Alternative J – Hageman Flyover
A separate project has long been planned to extend State Route 204 (Golden State Avenue)
across State Route 99 to Hageman Road as a complement to the 24th Street Improvement Project
and provide for an additional connection and improvement for east-west traffic flow. The City of
Bakersfield and the County of Kern, in cooperation with Caltrans, District 6, plan to extend
Hageman Road in the northwestern corner of the City from its existing terminus at Knudsen
Drive, approximately 0.62 mile west of State Route 99, over State Route 99 to State Route 204
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Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 69
(Golden State Avenue), in Kern County, California (Figure 1-28). The project will extend along
State Route 204 (Golden State Avenue) to approximately 0.5 mile east of the Airport Drive Bridge
(the western limit of the Calloway Canal Bridge). The total length of the planned project will be
about 1.5 miles, and will include the installation of new bridges, modifications to an existing
bridge and interchange ramps, and transition striping areas. The Hageman Flyover will cost an
estimated $52 million in 2014 dollars and require the acquisition of one full parcel of land.
The intended purpose of the Hageman Flyover is to provide additional traffic capacity from the
northwest into downtown Bakersfield and points east along the State Route 178 corridor. Due to
the small number of roads crossing State Route 99, traffic has funneled onto just Olive Drive and
Rosedale Highway. Hageman Road is located very close to Olive Drive, so it would relieve
traffic congestion primarily at that facility and at the interchange of Oak Street with State Route
99. The Hageman Flyover is also intended to relieve traffic congestion on Airport Drive, State
Route 99, and State Route 204.
The extension of State Route 204 (Golden State Avenue) across State Route 99 to Hageman
Road (i.e., the Hageman Flyover) has become an alternative that citizens asked the City to
consider in lieu of going forward with the 24th Street Improvement Project. The relationship
between the Hageman Flyover project and proposed improvements to State Route 204 (Golden
State Avenue) may be confusing because they share a nexus at the northern end. To be clear, this
alternative includes only the improvements described above, and does not include improvements
to State Route 204 (Golden State Avenue).
Several public comments received on the 2012 Draft Environmental Impact Report for the 24th
Street Improvement Project expressed that consideration should be given to improving State
Route 204 (Golden State Avenue) instead of 24th Street. The Master Response to Comments
contained in the 2013 FEIR (Volume 2) explained that building a new freeway alongside State
Route 204 (Golden State Avenue) had been previously considered in numerous transportation
studies, including the Route 178 Corridor Study (1986), the Route 178 Alternatives Study (1994),
and the Bakersfield System Study (2002). The consensus of those studies was that a new freeway
parallel, above, or adjacent to State Route 204 (Golden State Avenue) would not be cost-
effective given a comparison of construction costs versus the traffic use that was forecasted. The
Bakersfield System Study recommended both upgrading State Route 204 (Golden State Avenue)
and widening 24th Street to six lanes through the Westchester neighborhood, demonstrating that
the one action was not expected to replace implementation of the other.
Having independent utility, the Hageman Flyover is programmed separately under the Thomas
Roads Improvement Program. Nevertheless, this alternative is further discussed below in light of
the four criteria under which all alternatives have been analyzed in the R-DEIR.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 70
Screening Evaluation
Environmental – This alternative would have lesser environmental effects than would the
proposed project, primarily because the new section of road would be shorter, fewer properties
would need to be acquired, construction would occur on primarily agricultural and industrial
properties, and overall construction activity would be less. As a consequence, this alternative
would require fewer construction materials and would cause less ground disturbance (20.7 acres)
with less potential to encounter subsurface cultural and paleontological resources. Utility conflict
and relocation costs would be lower. One parcel of full property acquisitions would be required,
which is less than those of the proposed project. Construction noise generation would be more
substantial than for the proposed project because of the larger construction footprint. However,
construction noise impacts would be less substantial than for the proposed project because most
of the construction would occur in an area with few sensitive receptors.
Long-term visual impacts, consisting primarily of a new road, would be greater than those of the
proposed project because the flyover would be constructed through an agricultural area that
currently has no road. Views from Kern River Parkway Trail would be most affected. This
alternative would have no impact on historic districts and fewer effects than the proposed project
on historic structures. This alternative would create a smaller area of impervious surfaces that
would generate less storm water runoff than the proposed project. Operational noise impacts
along 24th Street would be less than those of the proposed project because traffic volumes would
be approximately 13 percent lower. Operational noise impacts along the new flyover alignment
would be minimal because that area has few or no sensitive receptors. The flyover would divert
air pollutants from existing roads to the new alignment. The effects on biological resources
would be more adverse than for the proposed project because the right-of-way would traverse an
agricultural area that likely has some wildlife habitat value.
Project Objectives – Overall, this alternative would not meet the objectives of the proposed
project described in Section 1.3.6.1. As an approved project under the Thomas Roads
Improvement Program, Hageman Flyover will be constructed whether or not the 24th Street
Improvement Project is approved and implemented. The purpose of the Hageman Flyover was to
address the need for a direct traffic connection between the northwestern portions of the
Bakersfield metropolitan area and the downtown area. Thus, the Hageman Flyover would not
achieve the proposed project’s primary objective of relieving traffic congestion along the 24th
Street corridor primarily because that was not the purpose for which it was designed. As an
alternative to 24th Street, the Hageman Flyover also would not be consistent with regional
transportation planning objectives, which call for implementing both the Hageman Flyover and
the 24th Street Improvement Project – in addition to other transportation improvements – to
achieve acceptable traffic conditions in the central portion of metropolitan Bakersfield.
As shown in Figure 1-28, improvements to State Route 58 to the west of the project area and to
State Route 178 to the east of the project area were planned in anticipation of an increase in
traffic capacity along the 24th Street corridor. In all, five projects providing approximately 15.5
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 71
miles of mobility improvements have been completed for this purpose. The 24th Street
Improvement project is the final link in this regional strategy.
Diverting traffic from 24th Street to the Hageman Flyover located 3 miles to the north of 24th
Street would be inefficient because it is an indirect route that would add over 3 miles to an
average trip. This alternative also would be inconsistent with regional transportation planning,
which anticipates increased capacity along 24th Street with improvements to State Route 58 west
of the project area and with improvements to State Route 178 east of the project area. Traffic
studies indicate that the Hageman Flyover would reduce traffic volumes on 24th Street by about
13 percent,23 so even with construction of the Hageman Flyover, traffic Levels of Service along
24th Street would not meet the objective (Level of Service C).
The Hageman Flyover would meet the project objectives of maintaining or enhancing traffic
safety, minimizing effects on historic resources, and minimizing the disruption of established
residential districts. As an alternative to the widening of 24th Street between Olive Street and
D Street, however, it would not achieve the secondary project objective of providing cost-
effective transportation improvements, because of the high project cost and minimal reduction in
traffic congestion on 24th Street.
Feasibility – Overall, this alternative is considered to be socially feasible but economically
infeasible. As an approved project under the Thomas Roads Improvement Program, the
Hageman Flyover will be constructed whether or not the 24th Street Improvement Project is
approved and implemented. The one full parcel acquisition required for this alternative, or just 4
percent difference from the proposed project, would be considered socially feasible. The
Hageman Flyover is considered to be socially, environmentally, and technically feasible for
improving access to the downtown area from the northwest, inasmuch as it is one of the Thomas
Roads Improvement Program projects that has been approved and is awaiting funding.
Estimated construction costs would be $52 million for this alternative compared to $46 million
for the proposed project. As an alternative to the 24th Street Improvement Project, it is considered
to be economically imprudent because it would cost more than the proposed project while
providing less public benefit.
Reasonableness – As an approved project under the Thomas Roads Improvement Program, the
Hageman Flyover will be constructed whether or not the 24th Street Improvement Project is
approved and implemented. As an alternative to the 24th Street Improvement Project, however, it
is not considered to be reasonable because it would not relieve traffic congestion at the Oak
Street/24th Street intersection and along the 24th Street corridor between Olive Street and
D Street.
23Parsons, Hageman Road Extension to Golden State Avenue. Traffic Report. Volume 1. July 2009.
Chapter 3 Additional Information on Alternatives Considered but Eliminated from Further Discussion
24th Street Improvement Project FEIR/EA Volume 3 72
Summary – This alternative was eliminated from further consideration because it fails three of
the four criteria: it does not achieve the objectives of the proposed project, it is infeasible, and it
is unreasonable.
1.3.6.6 Conclusions
The evaluations of potentially feasible alternatives are summarized in Table 1.5. Of the several
alternatives considered and evaluated, only two alternatives (Alternative 1-Widen to the North
and Alternative 2-Widen to the South) were considered viable. These two alternatives are
analyzed in Chapter 2 of this document.
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24th Street Improvement Project FEIR/EA Volume 3 75
Chapter 4 Document Preparers
This document was prepared by the City of Bakersfield and its consultant, Parsons. The
following staff prepared this Recirculated Draft Environmental Impact Report:
Bruce Campbell, AICP, Principal Environmental Project Manager, Parsons. M.S., Environmental
Management and B.S., Environmental Biology. Over 35 years of experience.
Contribution: Author of Introduction, Alternatives, Utilities/Emergency Services,
Hazardous Wastes/Materials Air Quality, and Energy sections of Environmental Impact
Report.
Rosemarie Crisologo, Principal Environmental Specialist, Parsons. M.S., Environmental
Engineering and B.S., Biological Sciences. Over 30 years of experience. Contribution:
Author of Summary and Technical Review.
Areg Gharabegian, P.E., Principal Project Manager, Parsons. M.S., Science and B.S.,
Mechanical Engineering. Over 30 years of experience. Contribution: Author of Noise
Section of Environmental Impact Report.
Greg Gharib, Program Manager, Parsons. JD. 17 years of experience. Contribution: Technical
Advisor and Engineering Support for Environmental Impact Report.
Dennis Kearney, Environmental Planner, Parsons. B.S., Conservation and Resource Studies. 15
years of experience. Contribution: Technical Review of Environmental Impact Report
and Public Notices.
Greg King, Cultural Resources Specialist, Parsons. M.A., Public Historical Studies and B.A.,
History. Over 30 years of experience. Contribution: QA/QC Review and Author of the
Land Use, Community Impacts, Cultural Resources, and Paleontology Sections of
Environmental Impact Report.
William Knoetgen, P.E., Vice President, Program Director, Parsons. MBA; B.S., Civil/Structural
Engineering and Construction Management. 25 years of experience. Contribution: TRIP
Program Management and Technical Advisor for Environmental Impact Report.
Anne Kochaon, QEP, Principal Project Manager, Parsons. M.S., Environmental Engineering and
B.S., Chemistry. 30 years of experience. Contribution: Oversight, Management, and
QA/QC of Environmental Impact Report.
Leslie Provenzano, Environmental Planner, Parsons. M.Pl. (Master of Planning). Six years of
experience. Contribution: Author of Visual Aesthetics Section of Environmental Impact
Report.
Robert Scales, P.E., Senior Program Director (Traffic), Parsons. M.S., Transportation and B.S.,
Civil Engineering. Over 40 years of traffic engineering and transportation planning
Chapter 4 Document Preparers
24th Street Improvement Project FEIR/EA Volume 3 76
experience. Contribution: Author of Traffic and Transportation for Environmental Impact
Report.
Veronica Seyde, QSD, QSP, CPSWQ, CPESC, Parsons. M.S., Environmental Studies and B.A.,
Biology. 30 years of water quality and storm water management experience.
Contribution: Author of Water Quality Section of Environmental Impact Report.
Daniel Wagner, P.E., Senior Project Engineer, Parsons. B.S., Civil Engineering. 10 years of
experience. Contribution: Technical Advisor and Engineering Support for Environmental
Impact Report.
24th Street Improvement Project FEIR/EA Volume 3 77
Chapter 5 Distribution List
Federal Agencies
Jan Knight, Deputy Field Supervisor
USFWS
Sacramento Fish and Wildlife Office
2800 Cottage Way W-2605
Sacramento, CA 95825
Christine S. Lehnertz, Regional Director
National Park Service, Pacific West Region
333 Bush St., Suite 500
San Francisco, CA 94104-2828
Colonel William J. Leady, District Engineer
U.S. Army Corps of Engineers
1325 J Street
Sacramento, CA 95814-2922
U.S. Department of Agriculture
1400 Independence Ave., SW
Washington, D.C. 20250
Tom Plenys, Environmental Review Office
U.S. Environmental Protection Agency, Region 9
75 Hawthorne Street
San Francisco, CA 94105-3901
Department of the Interior
1849 C Street, N.W.
Washington, D.C. 20240
State Agencies
Julie Vance, Acting Regional Manager
California Dept. of Fish & Wildlife
1234 East Shaw Avenue
Fresno, CA 93710
California State Water Resources Control Board
1001 I Street
Sacramento, CA 95814
Major General Anthony L. Jackson, USMC (Ret.),
Director
California Department of Parks and Recreation
1416 9th Street
Sacramento, CA 95814
Central Valley Flood Protection Board
3310 El Camino Avenue, Room 151
Sacramento, CA 95821
California Emergency Management Agency
Mark Johnson, Planning Branch Chief
3650 Schriever Ave.
Mather, CA 95655-4203
James Ramos, Chairman
Native American Heritage Commission
915 Capitol Mall, Rm. 288
Sacramento, CA 95814
Director
California Department of Conservation
801 "K" Street
Sacramento, CA 95814
California Natural Resources Agency
John Laird, Secretary
1416 Ninth Street, Suite 1311
Sacramento, CA 95814
Department of Water Resources
1416 9th Street
Sacramento, CA 95814
California Highway Patrol
P.O. Box 942898
Sacramento, CA 94298-0001
Cy Oggins, Division Chief Environmental Planning
California State Lands Commission
100 Howe Avenue, Suite 100 South
Sacramento, CA 95825
Office of Historic Preservation
1725 23rd Street, #100
Sacramento, CA 95816
California Air Resources Board
1001 "I" Street
P.O. Box 2815
Sacramento, CA 95812
California Department of Transportation
Division of Transportation Planning, MS#32
P.O. Box 942874
Sacramento, CA 94274-0001
California Department of Transportation, District 6
1352 W. Olive Street
Fresno, CA 93778-2616
Chapter 5 Distribution List
24th Street Improvement Project FEIR/EA Volume 3 78
Regional Agencies
Central Valley Regional Water Quality Control Board-
Region
1685 "E" Street
Fresno, CA 93706
San Joaquin Valley Air Pollution Control District
Southern Region
34946 Flyover Court
Bakersfield, CA 93308
County Agencies
Charles Lackey, Director
County of Kern Floodplain Management
2700 M Street, Suite 500
Bakersfield, CA 93301
Craig M. Pope, Director
Kern County Public Works Department
2700 M Street, Suite 400
Bakersfield, CA 93301
Lorelei H. Oviatt, AICP, Director
County of Kern, Planning Department
2700 M Street, Suite 100
Bakersfield, CA 93301
Ahron Hakimi, Executive Director
Kern County Council of Governments
1401 19th Street, Suite 300
Bakersfield, CA 93301
Donny Youngblood, Sheriff
Kern County Sheriff’s Department
1350 Norris Road
Bakersfield, CA 93308
Kern County Fire Department
Brian Marshall, Fire Chief
5642 Victor Street
Bakersfield, CA 93308
Glen Stephens, P.E., Air Pollution Control Officer
Eastern Kern County Air Pollution Control District
2700 M Street, Suite 302
Bakersfield, CA 93301
Bob Neath, General Manager
Kern Regional Transit
2700 M Street, Suite 400
Bakersfield, CA 93301
Robert Lerude, Director
Kern County Parks and Recreation
2820 M Street
Bakersfield, CA 93301
Lynn Brooks, Assistant Public Works Director
Kern County Public Works Department
2700 M Street, Suite 400
Bakersfield, CA 93301
Local Agencies
Nick Fidler, Director
City of Bakersfield
Public Works Department
1501 Truxtun Avenue
Bakersfield, CA 93301
Greg Williamson, Chief of Police
Bakersfield Police Department
1601 Truxtun Ave.
Bakersfield, CA 93301
Historic Preservation Commission
City of Bakersfield
Economic & Community Dev.
1600 Truxtun Avenue Suite 300
Bakersfield, CA 93301
Roberta Gafford, City Clerk
City of Bakersfield
1600 Truxtun Avenue
Bakersfield, CA 93301
Art Chianello, Water Resources Manager
City of Bakersfield
Water Resources Department
1000 Buena Vista Road
Bakersfield, CA 93311
Jacquelyn R. Kitchen, Planning Director
Planning Division
Community Development Building
1715 Chester Avenue
Bakersfield, California 93301
Chapter 5 Distribution List
24th Street Improvement Project FEIR/EA Volume 3 79
Douglas R. Greener, Fire Chief
Bakersfield Fire Department
2101 H Street
Bakersfield, CA301
Dianne Hoover, Director
City of Bakersfield
Dept. of Recreation & Parks
1600 Truxtun Avenue (3rd floor)
Bakersfield, CA 93301
State Elected Officials
Office of Jean Fuller
State Senate 16th District
5701 Truxtun Avenue, Suite 150
Bakersfield, CA 93309
Shannon L. Grove
State Assembly 34th District
4900 California Ave., Ste 100-B
Bakersfield, CA 93309
Rudy Salas
State Assembly 32nd District
1430 Truxtun Ave., Suite 803
Bakersfield, CA 93301
Kevin McCarthy
House of Representatives 23rd District
4100 Empire Dr., Ste 150
Bakersfield, CA 93309
Office of U.S. Senator
Dianne Feinstein
2500 Tulare Street, Suite 4290
Fresno, CA 93721
David Valadao
House of Representatives 21st District
2700 M St., Ste 250 B
Bakersfield, CA 93301
Office of U.S. Senator
Barbara Boxer
2500 Tulare Street, Suite 5290
Fresno, CA 93721
County Elected Officials
Mick Gleason, Chairman
Kern County Board of Supervisors
1115 Truxtun Ave., 5th Floor
Bakersfield, CA 93301
Letitia Perez, Dist. 5
Kern County Board of Supervisors
1115 Truxtun Ave., 5th Floor
Bakersfield, CA 93301
Local Elected Officials
Mayor Harvey L. Hall
Bakersfield City Hall
1600 Truxtun Ave.
Bakersfield, CA 93301
Terry Maxwell, Councilmember, Ward 2
Bakersfield City Council
Bakersfield City Hall
1600 Truxtun Ave.
Bakersfield, CA 93301
Willie Rivera, Councilmember, Ward 1
Bakersfield City Council
Bakersfield City Hall
1600 Truxtun Ave.
Bakersfield, CA 93301
Ken Weir, Councilmember, Ward 3
Bakersfield City Council
Bakersfield City Hall
1600 Truxtun Ave.
Bakersfield, CA 93301
Bob Smith, Councilmember, Ward 4
Bakersfield City Council
Bakersfield City Hall
1600 Truxtun Ave.
Bakersfield, CA 93301
Harold Hanson, Councilmember, Ward 5
Bakersfield City Council
Bakersfield City Hall
1600 Truxtun Ave.
Bakersfield, CA 93301
Jacquie Sullivan, Councilmember, Ward 6
Bakersfield City Council
Bakersfield City Hall
1600 Truxtun Ave.
Bakersfield, CA 93301
Chris Parlier, Ward 7
Bakersfield City Council
Bakersfield City Hall
1600 Truxtun Ave.
Bakersfield, CA 93301
Chapter 5 Distribution List
24th Street Improvement Project FEIR/EA Volume 3 80
Interested Groups, Organizations, and Individuals
Blodgie Rodriguez, Chairperson
Kern County Hispanic Chamber of Commerce
231 H Street
Bakersfield, CA 93304
Kudzubitcwanap Palap Tribe
The Honorable Robert Gomez, Chairman
2619 Driller Ave.
Bakersfield, CA 93306
Mike Warner, President
Kern County Historical Society
PO Box 141
Bakersfield, CA 93302
Kathy Montes-Morgan, Chairperson
Tejon Indian Tribe
2234 4th Street
Wasco, CA 93280
Dr. Robert Arias, Superintendent
Bakersfield City School District
1300 Baker Street
Bakersfield, CA 93305
Carol A. Pulido
15011 Lockwood Valley Rd.
Frazier Park, CA 93225
Delia Dominguez
Kitanemuk and Yowlumne Tejon Indians
P.O. Box 10766
Bakersfield, CA 93389
Richard Chapman, Chairman/CEO
Kern Economic Development Corporation
2700 M Street, Suite 200
Bakersfield, CA 93301
Tule River Indian Tribe
Neil Peyron, Chairperson
P.O. Box 589
Porterville, CA 93258
Hall Ambulance
1001 21st Street
Bakersfield, CA 93301
Monache Inter-Tribal Association
Ronald Wermuth
P.O. Box 168
Kernville, CA 93238
Chumash Indian Council of Bakersfield
Julio Quair, Chairperson
729 Texas Street
Bakersfield, CA 93307
Robert Robinson, Co-Chairman
Kern Valley Indian Councils
P.O. 401
Weldon, CA 93283
Christine Lizardi Frazier, Superintendent
Kern County Superintendent of Schools 1300 17th Street –
CITY CENTRE
Bakersfield, CA 93301-4533
Nancy Kerr, Director of Libraries
Kern County Library
701 Truxtun Avenue
Bakersfield, CA 93301
David Laughing Horse Robinson, Chairman
Kawaiisu Tribe
P.O. Box 1547
Kernville, CA 93238
Tomeka Powell, President/CEO
Kern County Black Chamber of Commerce
1309 L Street
Bakersfield, CA 93301
Ruben Barrios, Chairman
Santa Rosa Rancheria
P.O. Box 8
Lemoore, CA 93245
Robert Gomez, Chairperson
Tubatulabals of Kern Valley
P.O. Box 226
Lake Isabella, CA 93240
Michahai Wukasachi Band of Eshom Valley
Kenneth Woodrow
1179 Rock Haven Ct.
Salinas, CA 93906
Nicholas Ortiz, President/CEO
Greater Bakersfield Chamber of Commerce
1725 Eye Street
Bakersfield, CA 93301
Karen King, CEO
Golden Empire Transit District
1830 Golden State Ave.
Bakersfield, CA 93301
Bryon Schaefer, Superintendent
Kern High School District
5801 Sundale Ave.
Bakersfield, CA 93309
Sierra Club
Kern-Kaweah Chapter
P.O. Box 3357
Bakersfield, CA 93385
24th Street Improvement Project FEIR/EA Volume 3 81
Chapter 6 References
The following documents were used in the preparation of this Recirculated Environmental
Impact Report:
American Association of Highway and Transportation Officials, 2010. Highway Safety Manual.
1,296 pages.
Barton-Aschman Associates, Inc., 1997. Moving Forward. Metropolitan Bakersfield Major
Transportation Investment Strategy. Final Strategy Report. Prepared for City of
Bakersfield, County of Kern, Kern Council of Governments, Golden Empire Transit
District, California Department of Transportation and the San Joaquin Valley Unified Air
Pollution Control District. 58 pages. December 29.
Barton-Aschman Associates, 1986. Route 178 Corridor Study. Prepared for Kern Council of
Governments, Caltrans and the City of Bakersfield. 110 pages. December.
Caltrans, 2015. Highway Design Manual. 786 pages. July 1.
Caltrans and City of Bakersfield, 2013. 24th Street Improvement Project. Final Environmental
Impact Report/Environmental Assessment with Finding of No Significant Impact and
Section 4(f) Evaluation. Volume 1 of 2. 638 pages. December.
Caltrans and City of Bakersfield, 2013 Final Relocation Impact Statement. Project ID: NCIIPLN
5109(111), NCIIPLN 5109 (110) 59 pages. June.
Caltrans and City of Bakersfield, 2012. 24th Street Improvement Project. Draft Environmental
Impact Report/Environmental Assessment with Finding of No Significant Impact and
Section 4(f) Evaluation. Volume 1 of 2. 590 pages. May.
City of Bakersfield. 2014. Administrative Report, February 12.
City of Bakersfield, 2009. Screening Criteria Report.
City of Bakersfield and County of Kern, 2002. Metropolitan Bakersfield General Plan. Adopted
on December 11, 2002. Effective February 26, 2003. 182 pages. December.
Federal Highway Administration, 2004. Road Safety Fundamentals. 120 pages. July.
Kern Council of Governments, 2010. 2011 Final Regional Transportation Plan. 317 pages.
July 15, 2010.
Parsons, 2009. Hageman Road Extension to Golden State Avenue Traffic Report. Volume 1 of 2.
264 pages. July.
RBF Consulting, 2011a. Supplemental Project Study Report to Request for Conceptual Approval.
On Route 58 and 178 in Bakersfield, Kern County. 06-Ker-178-PM 0.36/2.11 24th Street
Widening. Draft. 219 pages. November.
Chapter 6 References
24th Street Improvement Project FEIR/EA Volume 3 82
RBF Consulting, 2011b. Supplemental Project Study Report to Request for Conceptual
Approval. On Route 58, 99 and 178 in Bakersfield, Kern County, Between Gibson Street
and Olive Street. 06-Ker-58, 099, 178-PM 51.26/51.82, PM24.9/25.7, PN0.0/0.43
Construct Interchange at Oak Street. Draft. 173 pages. November.
RBF Consulting, 2011c. Supplemental Project Study Report to Request for Conceptual Approval.
On Route 178 (24th and 23rd Street) Oak Street to M Street – Widen Existing Highway.
06-Ker-178-PM 0.4/1.9. 298 pages. June.
URS Corporation, 2005a. Project Study Report (Project Development Support) State Route 178
in Bakersfield, Kern County between Oak Street and D Street. Widen to Six Lanes. 219
pages. June.
URS Corporation, 2005b. Project Study Report (Project Development Support) Construct
Interchange at Oak Street. On Route 178 in Bakersfield, Kern County Between 0.3
Kilometer West of Oak Street and 0.3 Kilometer East of Oak Street. 06-Ker-178-KP
0.3/0.9. 173 pages. June.
URS Corporation, 2002. Bakersfield System Study. Summary Report. Prepared for Kern Council
of Governments, City of Bakersfield, County of Kern and Caltrans. 52 pages. December.
24th Street Improvement Project FEIR/EA Volume 3 83
Appendix A Errata Sheet to the 2015 Draft
Environmental Impact Report
To comply with the Court’s ruling, the City of Bakersfield has decertified the Final
Environmental Impact Report/Environmental Assessment (December 2013) in September 2015.
The December 2013 environmental document is now referred to as the 2015 Draft
Environmental Impact Report (2015 DEIR). Actual revisions to the 2015 DEIR to analyze the
effects on various environmental resources of adding six cul-de-sacs on the south side of 24th
Street between Olive Street and D Street (for a total of eight) to the project description are
presented herein.
The bold colored text indicates the paragraph and page number in the 2015 DEIR where the
revised text belongs. Deleted text is shown in strikethrough (example); and inserted (added) text
is underlined (example). Sections of the 2015 DEIR are presented in the same order as they
appear in the original document, starting with the Summary, and continuing with Chapters 1
through 6, followed by the Appendices.
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 84
Revisions to “Summary” Section of the 2015 Draft Environmental
Impact Report
Paragraph 3 on page i is revised as follows:
This Final R-DEIR/Environmental Assessment has been prepared based on receipt of
comments from the public and reviewing agencies, and direction from the Court. The City of
Bakersfield and Caltrans have undertaken additional studies to address comments as needed.
The following project design changes planned between Olive Street and D Street were made
as a direct result of input from local residents:
Paragraph 2 on page ii is revised as follows:
Responses to comments received on the Draft Environmental Impact Report/Environmental
Assessment are included in Volume 2. Alternative 1 has been identified as the preferred
alternative to move forward, and the rationale is explained in Chapter 1, Identification of a
Preferred Alternative. In addition, a Notice of Determination will be signed and provided to
the State Clearinghouse for publishing, in compliance with the California Environmental
Quality Act (see SCH # 2008041070). To comply with NEPA, Caltrans, as NEPA lead
agency has issued a Finding of No Significant Impact (FONSI) which is included in this final
environmental document. A Notice of Availability (NOA) of the Finding of No Significant
Impact was sent to the affected agencies of federal, state, and local government, and to the
State Clearinghouse in compliance with Executive Order 12372.
Section S.1 - Overview of Project Area
Paragraph 1 on page iii is revised as follows:
On November 14, 2012, the City by Resolution (No. 128-12) conditionally agreed to allow
cul-de-sacs of six streets on the south side of 24th Street between Beech Street and A Street as
a separate City project. The six cul-de-sacs were subsequently included in Alternative 1 –
Widen to the North (preferred alternative). The conditions require the following: 1) all
property owners along the affected street between 24th and 22nd Street must agree to the
closure by signing a petition, and 2) directly affected property owners must agree to donate
sufficient land to construct the six cul-de-sacs to City standards. On January 22, 2014,
Amendment No. 2 to Resolution No. 128-12 amended City policy to allow any street
identified in Resolution No. 128-12 in which 75 percent of property owners requested by
petition a cul-de-sac, to have that request come before the City staff for further consideration,
and ultimately to the City Council for approval.
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 85
Section S.2 - Purpose and Need
New subsection added on page iii following subsection on Need (before S.3 Proposed
Action):
Objectives
The primary objective of the 24th Street Improvement Project is to address existing traffic
congestion and future travel demand through 2035 along the 24th Street corridor from State
Route 99 to M Street. In the recent past, growth in Kern County has been concentrated in
metropolitan Bakersfield. Between 2000 and 2009, for example, growth in the City of
Bakersfield ranged from 1.1 to 5.2 percent per year, while overall county growth ranged from
1.2 to 3.2 percent. As the city grows, the amount of traffic also grows. The project would
relieve traffic congestion along the 24th Street corridor through 2035. Relieving traffic
congestion would, in turn, reduce energy consumption and reduce vehicle emissions of air
pollutants.
Other project objectives include: (1) maintaining consistency with regional transportation
planning objectives; (2) maintaining or enhancing traffic safety in the community; (3)
minimizing project effects on historic districts and structures; (4) minimizing disruption of
established residential districts, and (5) providing cost-effective transportation improvements
to the community.
Section S.3 - Proposed Action
Paragraph 1 on page vi is revised as follows:
Unique Features of the Build Alternatives
Alternatives 1 and 2 would include the above design features, but would differ where 24th
Street is widened to the north or south. Alternative 1 would widen 24th Street to the north of
its existing alignment, and add eight cul-de-sacs (two of which were a part of the project
description presented in the 2015 Draft Environmental Impact Report, and six new ones) on
the south side. Alternative 2 would widen 24th Street to the south of the existing roadway
alignment and would include two cul-de-sacs on the south side. The two build alternatives are
summarized below.
Paragraph 2 on page vi is revised as follows:
Alternative 1 (Widen to the North)
Alternative 1 would widen 24th Street to the north and encompass the State Route 99
interchange and auxiliary lane, Oak Street/24th Street intersection, 24th Street widening to the
north, and the 23rd Street/24th Street couplet area. Widening to the north along 24th Street
would add two travel lanes (one in each direction). The proposed centerline of the roadway
alignment would be shifted north of the existing alignment about 17 feet, which would
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 86
minimize the right-of-way acquisition on the south side of 24th Street required for the roadway
widening. In addition, this alternative would convert eight side streets on the south side of 24th
Street into cul-de-sacs. Impacts include full and partial right-of-way acquisitions and
reconstruction of Carrier Canal on the north and south sides of 24th Street.
Table S.1 on pages ix through xv is revised as follows:
Ap
p
e
n
d
i
x
A
Er
r
a
t
a
S
h
e
e
t
t
o
t
h
e
2
0
1
5
D
r
a
f
t
E
n
v
i
r
o
n
m
e
n
t
a
l
I
m
p
a
c
t
R
e
p
o
r
t
24
th
S
t
r
e
e
t
I
m
p
r
o
v
e
m
e
n
t
P
r
oj
e
c
t
F
E
I
R
/
E
A
V
o
l
u
m
e
3
87
Ta
b
l
e
S
.
1
.
S
u
m
m
a
r
y
o
f
P
o
t
e
n
t
i
a
l
I
m
p
a
c
t
s
f
r
o
m
A
l
t
e
r
n
a
t
i
v
e
s
En
v
i
r
o
n
m
e
n
t
a
l
R
e
s
o
u
r
c
e
No
-
B
u
i
l
d
A
l
t
e
r
n
a
t
i
v
e
(N
o
-
B
u
i
l
d
)
Al
t
e
r
n
a
t
i
v
e
1
(W
i
d
e
n
t
o
t
h
e
N
o
r
t
h
)
Al
t
e
r
n
a
t
i
v
e
2
(W
i
d
e
n
t
o
t
h
e
S
o
u
t
h
)
La
n
d
U
s
e
/
A
c
q
u
i
s
i
t
i
o
n
No
i
m
p
a
c
t
Te
m
p
o
r
a
r
y
c
o
n
s
t
r
u
c
t
i
o
n
e
a
s
e
m
e
n
t
s
(
3
.
3
3
3.
3
9
a
c
r
e
s
)
Pe
r
m
a
n
e
n
t
c
o
n
s
t
r
u
c
t
i
o
n
e
a
s
e
m
e
n
t
s
(
0
.
1
ac
r
e
s
)
Pa
r
t
i
a
l
A
c
q
u
i
s
i
t
i
o
n
(
1
.
3
6
1
.
3
8
a
c
r
e
s
)
Fu
l
l
a
c
q
u
i
s
i
t
i
o
n
(
5
.
0
7
a
c
r
e
s
)
Te
m
p
o
r
a
r
y
c
o
n
s
t
r
u
c
t
i
o
n
e
a
s
e
m
e
n
t
s
(3
.
2
5
a
c
r
e
s
)
Pe
r
m
a
n
e
n
t
c
o
n
s
t
r
u
c
t
i
o
n
e
a
s
e
m
e
n
t
s
(
0
.
1
ac
r
e
s
)
Pa
r
t
i
a
l
A
c
q
u
i
s
i
t
i
o
n
(
1
.
5
2
a
c
r
e
s
)
Fu
l
l
a
c
q
u
i
s
i
t
i
o
n
(
5
.
2
1
a
c
r
e
s
)
Co
n
s
i
s
t
e
n
c
y
w
i
t
h
S
t
a
t
e
,
Re
g
i
o
n
a
l
,
a
n
d
L
o
c
a
l
P
l
a
n
s
No
t
c
o
n
s
i
s
t
e
n
t
w
i
t
h
t
h
e
go
a
l
s
a
n
d
p
o
l
i
c
i
e
s
o
f
th
e
C
i
t
y
o
f
B
a
k
e
r
s
f
i
e
l
d
Ge
n
e
r
a
l
P
l
a
n
Co
n
s
i
s
t
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n
t
w
i
t
h
t
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g
o
a
l
s
a
n
d
p
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c
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s
o
f
t
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Ci
t
y
o
f
B
a
k
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r
s
f
i
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l
d
G
e
n
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r
a
l
P
l
a
n
Co
n
s
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s
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n
t
w
i
t
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t
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g
o
a
l
s
a
n
d
p
o
l
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c
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s
o
f
th
e
C
i
t
y
o
f
B
a
k
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r
s
f
i
e
l
d
G
e
n
e
r
a
l
P
l
a
n
Pa
r
k
s
a
n
d
R
e
c
r
e
a
t
i
o
n
No
i
m
p
a
c
t
Te
m
p
o
r
a
r
y
c
o
n
s
t
r
u
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t
i
o
n
e
a
s
e
m
e
n
t
i
n
B
e
a
c
h
Pa
r
k
(
0
.
1
1
a
c
r
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o
f
p
a
r
k
l
a
n
d
)
a
n
d
t
e
m
p
o
r
a
r
y
co
n
s
t
r
u
c
t
i
o
n
e
a
s
e
m
e
n
t
(
0
.
3
7
a
c
r
e
)
a
l
o
n
g
t
h
e
Ke
r
n
R
i
v
e
r
P
a
r
k
w
a
y
B
i
k
e
T
r
a
i
l
.
Pe
r
m
a
n
e
n
t
a
c
q
u
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s
i
t
i
o
n
o
f
0
.
8
a
c
r
e
o
f
B
e
a
c
h
Pa
r
k
p
r
o
p
e
r
t
y
(
n
o
n
-
a
c
t
i
v
e
a
r
e
a
)
.
Sa
m
e
a
s
A
l
t
e
r
n
a
t
i
v
e
1
.
Co
m
m
u
n
i
t
y
C
h
a
r
a
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d
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h
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s
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o
n
No
i
m
p
a
c
t
Te
m
p
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r
a
r
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p
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o
ne
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g
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o
r
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d
d
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r
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a
c
c
e
s
s
re
s
t
r
i
c
t
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o
n
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,
a
n
d
t
r
a
f
f
i
c
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l
a
y
s
.
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p
e
r
m
a
n
e
n
t
i
m
p
a
c
t
s
.
Sa
m
e
a
s
A
l
t
e
r
n
a
t
i
v
e
1
.
Re
l
o
c
a
t
i
o
n
No
i
m
p
a
c
t
23
f
u
l
l
p
a
r
c
e
l
a
c
q
u
i
s
i
t
i
o
n
s
a
n
d
2
9
4
1
p
a
r
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i
a
l
pa
r
c
e
l
a
c
q
u
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s
i
t
i
o
n
s
.
23
f
u
l
l
p
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r
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a
c
q
u
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s
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t
i
o
n
s
a
n
d
2
1
p
a
r
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a
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r
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a
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t
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s
.
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i
l
i
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e
s
No
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m
p
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t
Re
m
o
v
a
l
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r
r
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1
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e
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i
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w
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n
po
w
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a
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t
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a
n
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e
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i
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n
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u
i
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a
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a
c
t
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n
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m
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e
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i
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n
e
s
a
n
d
w
a
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r
l
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w
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l
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m
p
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t
a
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o
n
s
at
s
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l
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t
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s
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n
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t
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ex
i
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t
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g
c
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d
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t
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n
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l
i
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e
.
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p
e
n
d
i
x
A
Er
r
a
t
a
S
h
e
e
t
t
o
t
h
e
2
0
1
5
D
r
a
f
t
E
n
v
i
r
o
n
m
e
n
t
a
l
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m
p
a
c
t
R
e
p
o
r
t
24
th
S
t
r
e
e
t
I
m
p
r
o
v
e
m
e
n
t
P
r
oj
e
c
t
F
E
I
R
/
E
A
V
o
l
u
m
e
3
88
Ta
b
l
e
S
.
1
.
S
u
m
m
a
r
y
o
f
P
o
t
e
n
t
i
a
l
I
m
p
a
c
t
s
f
r
o
m
A
l
t
e
r
n
a
t
i
v
e
s
(
C
o
n
t
’
d
)
En
v
i
r
o
n
m
e
n
t
a
l
R
e
s
o
u
r
c
e
No
-
B
u
i
l
d
A
l
t
e
r
n
a
t
i
v
e
(N
o
-
B
u
i
l
d
)
Al
t
e
r
n
a
t
i
v
e
1
(W
i
d
e
n
t
o
t
h
e
N
o
r
t
h
)
Al
t
e
r
n
a
t
i
v
e
2
(W
i
d
e
n
t
o
t
h
e
S
o
u
t
h
)
Em
e
r
g
e
n
c
y
S
e
r
v
i
c
e
s
No
i
m
p
a
c
t
De
l
a
y
e
d
r
e
s
p
o
n
s
e
t
i
m
e
s
f
o
r
p
o
l
i
c
e
,
f
i
r
e
pr
o
t
e
c
t
i
o
n
,
a
n
d
e
m
e
r
g
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n
c
y
s
e
r
v
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s
d
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r
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n
g
co
n
s
t
r
u
c
t
i
o
n
d
u
e
t
o
s
h
o
r
t
-
t
e
r
m
t
r
a
f
f
i
c
d
e
l
a
y
s
a
n
d
in
t
e
r
m
i
t
t
e
n
t
r
o
a
d
d
e
t
o
u
r
s
.
No
l
o
n
g
-
t
e
r
m
o
p
e
r
a
t
i
o
n
i
m
p
a
c
t
s
w
i
t
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e
x
p
a
n
d
e
d
ve
h
i
c
u
l
a
r
c
a
p
a
c
i
t
y
.
Sa
m
e
a
s
A
l
t
e
r
n
a
t
i
v
e
1
.
Tr
a
f
f
i
c
a
n
d
Tr
a
n
s
p
o
r
t
a
t
i
o
n
/
P
e
d
e
s
t
r
i
a
n
an
d
B
i
c
y
c
l
e
F
a
c
i
l
i
t
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e
s
In
c
r
e
a
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d
t
r
a
f
f
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co
n
g
e
s
t
i
o
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a
n
d
de
g
r
a
d
a
t
i
o
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f
L
e
v
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l
o
f
Se
r
v
i
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m
p
o
r
a
r
y
s
t
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t
c
l
o
s
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r
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s
,
d
e
l
a
y
s
,
o
r
d
e
t
o
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r
s
t
o
ac
c
o
m
m
o
d
a
t
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o
n
s
t
r
u
c
t
i
o
n
a
c
t
i
v
i
t
i
e
s
.
No
l
o
n
g
-
t
e
r
m
o
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r
a
t
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o
n
a
l
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p
a
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t
s
.
Sa
m
e
a
s
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l
t
e
r
n
a
t
i
v
e
1
.
Vi
s
u
a
l
/
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e
s
t
h
e
t
i
c
s
No
i
m
p
a
c
t
Vi
s
i
b
i
l
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t
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o
f
c
o
n
s
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t
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n
t
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co
n
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r
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a
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i
a
l
s
t
a
g
i
n
g
,
c
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t
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t
i
o
n
li
g
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t
i
n
g
,
s
a
f
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t
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b
a
r
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r
s
a
l
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t
h
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e
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i
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r
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r
k
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B
i
k
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T
r
a
i
l
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a
n
d
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b
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u
s
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d
u
r
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g
co
n
s
t
r
u
c
t
i
o
n
.
Lo
n
g
-
t
e
r
m
i
n
c
r
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a
s
e
d
h
a
r
d
s
c
a
p
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e
a
t
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s
,
re
l
o
c
a
t
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o
f
h
o
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s
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n
g
,
a
n
d
r
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Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 93
Revisions to “Chapter 1 – Proposed Project” of the 2015 Draft
Environmental Impact Report
Section 1.1 – Introduction
Paragraph 1 on page 1 is revised as follows:
The California Department of Transportation (Caltrans), as assigned by the Federal Highway
Administration, in cooperation with the City, proposes to widen roadways, and make
interchange improvements on State Route 58 west of State Route 99, and on State Route 178
east of State Route 99, and install new cul-de-sacs in the City of Bakersfield in Kern County.
This stretch of highway is collectively referred to as 24th Street.
Section 1.3 – Alternatives
Introductory text on page 9 is revised as follows:
1.3 Alternatives
This section describes the proposed project alternatives selected for detailed consideration in
this document: the No-Build Alternative and two Build Alternatives (Alternatives 1 and 2).
The section also describes the identification of the Locally Preferred Alternative and the
Preferred Alternative, respectively. Lastly, this section describes 10 alternatives that were
considered but eliminated prior to detailed evaluation, and the reasons for rejecting these
alternatives.
The proposed project was initially two separate projects. One project consisted of a new
intersection at State Route 178 and Oak Street, and the other project consisted of the widening
of State Route 178 between Oak Street and D Street. The two projects were combined to
become the project discussed in this document.
The alternatives were developed by the Project Design Team through preparation of two
Project Study Reports in 2005 and two Supplemental Project Study Reports in 2009. The
Supplemental Project Study Reports identified two build alternatives along 24th Street and
23rd Street and an at-grade intersection alternative at Oak Street and 24th Street. These
alternatives were determined to be the most viable. The rationale for inclusion of
Alternatives 1 and 2 is based on engineering, environmental protection, and cost. Adding
capacity to an existing road to relieve traffic congestion involves some combination of
widening to one or both sides of the road. Alternatives 1 and 2 were developed to minimize
environmental impacts.
Comments received during the Draft Environmental Impact Report / Environmental
Assessment public circulation period requested that a number of project modifications be
incorporated into the roadway design. These public-requested modifications would provide
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 94
safety benefits by improving traffic circulation and would enhance the character of the
neighborhood. Modifications to the project design are incorporated into the Final
Environmental Impact Report/Environmental Assessment.
Section 1.3.1 Build Alternatives
The first full paragraph on page 19 is revised as follows:
Alternative 1 (Widen to the North)
Alternative 1 would widen 24th Street between Olive Street and D Street to the north, adding
two travel lanes (one in each direction). See Figures 1-7, 1-8, and 1-9. The proposed
centerline of the roadway alignment would be shifted north of the existing alignment about
17 feet, which would minimize the right-of-way acquisition on the south side of 24th Street
required for the roadway widening. Eleven driveways along the north side of 24th Street
would be eliminated. Eight cul-de-sacs would be constructed on side streets on the south side
of 24th Street. The impacts include reconstruction of Carrier Canal on the north and south
sides of 24th Street to accommodate the widening. The parkway (the area between the travel
lanes and sidewalks, ordinarily used as a planting area) on the north side, between Olive
Street and Carrier Canal, would vary in width from 10 feet to 15 feet to accommodate sight
distance at Olive Street. Carrier Canal would be extended on the north and south sides of 24th
Street to accommodate widening of 24th Street. The north side would require about 10 feet of
culvert extension in addition to reconstructing about 30 feet of transition area; the south side
would require about 100 feet of culvert extension in addition to reconstructing about 30 feet
of transition.
Figures 1-7 and 1-8 are revised as shown to include six additional cul-de-sacs.
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Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 97
Section 1.3.3 – Comparison of Alternatives
Paragraph 3 on page 34 is revised as follows:
Alternative 1 would result in 110 123 temporary construction easements, 23 full residential
parcel acquisitions, and 29 41 partial parcel acquisitions (1426 residential, 12 nonresidential,
and 3 vacant). Alternative 2 would result in 95 temporary construction easements, 23 full
residential parcel acquisitions, and 21 partial parcel acquisitions (7 residential, 11
nonresidential, and 3 vacant).
Paragraph 6 on page 34 is revised as follows:
Alternatives 1 and 2 would affect two historic districts north and south of 24th Street which
are eligible for listing in the National Register of Historic Places for the purposes of this
undertaking only. Specifically, Alternative 1 would result in 12 full parcel and 2 partial parcel
acquisitions; and 14 temporary construction easements in the historic district north of 24th
Street,; 9 full parcels and 6 16 partial parcel acquisitions; and 12 18 temporary construction
easements in the historic district south of 24th Street.
Table 1.3 on page 39 is revised as shown herein.
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.
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a
at
2
5
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n
s
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t
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e
p
t
o
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s
;
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u
c
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h
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a
t
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p
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a
b
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2
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h
ab
a
t
e
m
e
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a
s
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r
e
s
.
14
No
t
e
s
:
E
s
t
i
m
a
t
e
d
p
r
o
j
e
c
t
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Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 100
Section 1.3.5 - Locally Preferred Alternative
Paragraphs 2 and 3 under Project Features on page 45 are revised as follows:
Project Features
As shown in Table 1.3, the cost for Alternative 1 is $44.4 $46 million compared to $45.2
million for Alternative 2, a difference of about less than $1 million, or about 1 percent. That
difference is not enough to make Alternative 1 substantially superior to Alternative 2 on the
basis of cost.
Table 1.3 also provides detailed information on the property acquisitions needed for
Alternatives 1 and 2. As shown in that table:
Alternatives 1 and 2 would result in the same number of full parcel acquisitions.
Alternative 1 results in more partial parcel acquisitions but less total acreage in partial
parcel acquisitions than Alternative 2.
Alternative 1 results in more temporary construction easements (110 123 temporary
construction easements, or about 1429 percent more compared to Alternative 2) and
slightly more acreage in temporary construction easements than Alternative 2 (95
temporary construction easements).
Alternatives 1 and 2 each result in 3 permanent easements.
Paragraph 4 on page 46 is revised as follows:
Historic District South of 24th Street
Of the approximately 120 properties within this district that are assumed to be eligible for the
National Register for this project only, there would be 9 full acquisitions (7 contributing and 2
noncontributing properties), 6 16 partial acquisitions (1 six contributing and 5 10
noncontributing properties), and 12 18 temporary construction easements (35 contributing and
913 noncontributing properties). A total number of 1113 contributing properties and 16
noncontributing properties in this district would be affected, or about 10 11 percent of the
total properties in the district. About 85 percent of the properties within the historic district
south of 24th Street appear to be contributors, with 15 percent non-contributors.
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 101
Revisions to “Chapter 2 – Affected Environment, Environmental
Consequences, and Avoidance, Minimization, and/or Mitigation
Measures
Full Paragraphs 2 and 3 of the introductory text on page 54 are revised as follows:
The Draft Environmental Impact Report/Environmental Assessment was circulated for public
review from May 23, 2012 to July 16, 2012. Public hearings were held at the Rabobank
Convention Center on June 26, 2012 and at the City of Bakersfield Planning Commission,
City Hall South-City Council Chambers on July 5, 2012. All comments from the public
hearing and those received during the 45-day public review period have been were considered
and addressed in the Final Environmental Impact Report/Environmental Assessment.
Responses to comments are located in a separately bound document (FEIR/EA, Vol. 2). All
issues raised were addressed through clarification of text in the final environmental document,
responses to comments, and minor design changes to the project. Figures 1-7, 1-8, 1-10, and
1-11 have been were updated to incorporate the modifications to project designs since public
circulation of the Draft Environmental Impact Report/Environmental Assessment. The Final
Environmental Impact Report was subsequently de-certified (see Section 1.1 of this
document), triggering the need for this Recirculated Draft Environmental Impact Report.
It was determined that the proposed project would not result in significant adverse impacts on
the environment with implementation of proposed mitigation measures, except for the impact
to cultural resources. The City of Bakersfield is responsible for project compliance with the
California Environmental Quality Act. Findings for all significant impacts identified are
documented, a Statement of Overriding Considerations for impacts that will not be mitigated
below a level of significant is prepared, and will be adopted by the City Council. The City of
Bakersfield will file a Notice of Determination with the State Clearinghouse that identifies the
impacts. Caltrans, as assigned by the Federal Highway Administration, has prepared a Finding
of No Significant Impact in accordance with the National Environmental Policy Act.
Section 2.1.1 Land Use
2.1.1.1 Existing and Future Land Use
Paragraph 4 on page 57 is deleted:
Since the Draft Environmental Impact Report/Environmental Assessment was circulated, the
City has approved by Resolution (Resolution No. 128-12) an action that would conditionally
allow cul-de-sacs of streets on the south side of 24th Street between Beech Street and A Street
as a separate city project. This separate project is analyzed as part of cumulative impact
analysis in Section 2.4, Cumulative Impacts.
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 102
Paragraph 6 on page 57 is revised as follows:
Build Alternatives
Temporary work associated with the build alternatives include reducing the number of
operating lanes at the couplet, which would restrict north-south movements; closing
intersections; and using temporary construction easements for construction along the 24th
Street widening area, the couplet section, at the northernmost of Oak Street cul-de-sac, and
along the east bank of the Kern River north of the 24th Street Bridge. Under Alternatives 1
and 2, 110 123 parcels (145,296 147,823 square feet) and 95 parcels 141,982 square feet),
respectively, would be affected by temporary construction easements.
2.1.1.2 Consistency with State, Federal, Regional and Local Plans and
Programs
Paragraph 4 on page 61 is revised as follows:
Build Alternatives
The build alternatives—Alternatives 1 and 2—are consistent with the regional mobility goals
of the Kern Council of Governments, Caltrans, and the City of Bakersfield. Alternative 1
includes construction of eight cul-de-sacs that would close vehicular traffic on the south side
of 24th Street at Elm, Beech, Myrtle, Spruce, Pine, Cedar, A, and B Streets. Cul-de-sacs on
these streets prohibit direct access by vehicles from one residential neighborhood community
to the other, make such traffic slightly more circuitous, and create out of direction travel.
Studies conducted in the community on the nearby inventory of neighborhood resources and
institutions, however, did not identify any popular land use destinations located in either
neighborhood north or south of 24th Street that would be affected by the closures.
The following new paragraph is inserted after Paragraph 5 on page 61.
The project is consistent with overall goals for creating a pedestrian-friendly environment in
the residential neighborhood and compatible with the City’s goal to encourage livability. New
cul-de-sacs are compatible with adjacent residential land uses and zoning. The project would
convert only the amount of land required for a transportation-related use for the 24th Street
project. The land use conversion includes a portion of a city street and sliver portions of yards
from residential properties for the purposes of constructing cul-de-sacs. These combined land
use changes do not constitute a significant impact within the context of the land uses in this
portion of the City.
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 103
Section 2.1.2 Community Impacts
2.1.2.1 Community Character and Cohesion
Paragraph 1 on page 80 is revised as follows:
Build Alternatives
The project would affect existing transportation facilities that are being considered for
widening and intersection/interchange improvements to improve traffic operations,
accommodate existing and forecast traffic volumes, and achieve acceptable Levels of Service.
By making improvements to 24th Street, 23rd Street, and State Route 99, the project would
not divide an existing community or create a barrier between communities since currently
there are no strong interactions between these two communities. Also, 24th Street is an
existing road between the communities. The roadway would remain in the future, and the
project improvements would not create a new separation or boundary between the two
communities. Improvements to 24th Street, including the eight cul-de-sacs included in
Alternative 1, would not affect Bakersfield Racquet Club or Jastro Park, which are common
meeting grounds for the Downtown Bakersfield community, and therefore, would not
interfere with the activities of this community.
The following new paragraph is added after Paragraph 1 on page 80:
Construction of cul-de-sacs on eight local streets would affect local circulation and prevent
motor vehicles from entering or exiting those streets from 24th Street. In most cases, the
people who are expected to be on or park adjacent to the cul-de-sac will likely either live on
that block or be guests of those who do. To the extent that the cul-de-sacs would limit the
entry of vehicles from outside areas, there is likely to be an increased sense of ownership and
increased natural surveillance, which would likely foster an increased sense of security on the
streets on which cul-de-sacs are constructed. Cul-de-sacs would also be expected to increase
spontaneous outdoor activity by children, as those streets that are closed at one end become
safer from automobile traffic and there is greater pedestrian use of the sidewalks, where
provided. Significant impacts to community character and cohesion are not expected. In fact,
to the extent that the cul-de-sacs may encourage more neighbors to walk on the newly-
connected sidewalks or for children to bike within the protected street areas, thereby
increasing the frequency of personal face-to-face contact, community cohesion would also
likely increase.
2.1.2.2 Relocations and Real Property Acquisitions
Paragraph 4 on page 81 is revised as follows:
The temporary construction easement would be accessed by a cul-de-sac at the northernmost
end of Oak Street. Alternative 1 would result in 110 123 temporary construction easements
(3.33 3.39 acres); Alternative 2 would result in 95 temporary construction easements
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 104
(3.25 acres). See Table 2.7, Figure 2-6 (Sheets 1–5), and Figure 2-7 (Sheets 1–5) for the
location of temporary construction easements for Alternatives 1 and 2.
Table 2.7 on page 82 is revised as follows:
Table 2.7. Summary of Property Acquisitions for the Build Alternatives
Permanent Acquisitions
Temporary
Construction
Easements (TCEs)
Permanent Easements
Full Parcels Partial Parcels Number
of
Parcels
Size
(acres/
square feet)
Number
of
Parcels
Size
(acres/
square feet)Number of Parcels
Size
(acres/
square feet)
Number of Parcels
Size
(acres/
square feet)
Alternative1:
Total: 23
Residential: 23
Nonresidential: 0
Vacant: 0
5.07/
220,899
Total: 29 41
Residential: 14 26
Nonresidential: 12
Vacant: 3
1.36 1.38
(59,645)
(60,422)
110
123
3.333.39/
(145,296)
(147,823)
3 0.101/
(4,516)
Alternative2:
Total: 23
Residential: 23
Nonresidential: 0
Vacant: 0
5.21/
227,015
Total: 21
Residential: 7
Nonresidential: 11
Vacant: 3
1.52
(66,210) 95
3.25/
about
(141,982)
3
0.101/
(4,516)
Source: Final Relocation Impact Statement (June 2013).
Sheets 3 and 4 of Figure 2-6 on pages 87 and 88 are revised.
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Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 107
Paragraph 4 on page 103 is revised as follows:
Partial Acquisitions
Alternative 1 would result in a larger number of partial parcel acquisitions, with 14 26
residential and 15 nonresidential. Alternative 2 would result in 7 residential and 14
nonresidential partial parcel acquisitions. These parcels are shown in Figures 2-6 and 2-7.
Section 2.1.3 Utility and Emergency Services
Subsection “Fire, Law Enforcement, and Emergency Services” on page 111 is revised as
follows:
Fire, Law Enforcement, and Emergency Services
There are no public service facilities within the project study area; therefore, no direct
physical impacts would occur from long-term operation of the build alternatives.
The build alternatives would benefit circulation flow through the project area. The circulation
improvements would enable fire, law enforcement, and emergency service providers to
respond to emergency situations and move emergency equipment more efficiently through the
improved transportation corridor. Under Alternative 2, Tthe overall emergency service
response times through the study area would be maintained or improved.
Under Alternative 1, eight cul-de-sacs would constrain north-south cross-traffic within the
24th Street corridor. Neither the Bakersfield Fire Department nor the Bakersfield Police
Department identified that these new cul-de-sacs would delay provision of emergency
services. Emergency response vehicles would continue to have access to the eight residential
streets via 23rd Street. Although direct access to and from 24th Street will be eliminated for
these six streets in which it interfaces on the south (Beech Street, Myrtle Street, Spruce Street,
Pine Street, Cedar Street, and A Street) the improvements induced by the expansion of travel
lanes on 24th Street are expected to provide a safer and speedier response time for emergency
services by helping to avoid conflicts with slower-moving vehicles and oncoming traffic. In
the long-term, the overall emergency service response times through the study area would be
maintained or improved.
Section 2.1.4 Traffic and Transportation/Pedestrian and Bicycle Facilities
Subsection Environmental Consequences, Permanent Impacts, on page 121 is revised as
follows:
Permanent Impacts
Since the Draft Environmental Impact Report/Environmental Assessment was circulated, the
City has approved by Resolution (Resolution No. 128-12) action to conditionally allow the
construction of up to six of eight planned cul-de-sacs of streets on the south side of 24th Street
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 108
between Beech Street and A Street have been constructed as a separate city project. In
addition, during the public comment period, residents requested that a raised median be
constructed to enhance the roadway aesthetics and prevent left turns off of 24th Street due to
cut-through traffic concerns. So, two eastbound intersections (Beech Street and C Street) were
identified for left turns within the landscaped median. However, no left turns were identified
for westbound intersections.
An addendum traffic analysis was done to determine what effect, if any, would result from the
inclusion of a raised median, revised lane geometry along the 24th Street from Oak Street to
F Street, elimination of westbound left-turn lanes, provision of two left-turn lanes at the
intersections of Beech Street and C Street, and city-approved cul-de-sacs on the south side of
24tlh Street. The results of this analysis are incorporated into the analysis discussed below.
Section 2.1.5 Visual/Aesthetics
Paragraph 4 on page 132 is revised as follows:
To help evaluate potential visual impacts, computer simulations of the proposed road
improvements visible from each of the seven key viewpoints were prepared. Visual
simulations of both build alternatives are shown in Figures 2-12 through 2-18 2-18A (see
Figure 1-5 to 1-11 legends for description of site plan details), along with their corresponding
existing view photograph. In addition, Key Views 3, 4, and 5 highlight the landscaping that
would be included as part of the Draft Concept Landscape Plan (see Appendix I).
Figure 2-11 (Key View Locations) on page 135 is revised as shown herein.
A new Figure 2-18A (entitled “Key View 8 Existing and Proposed Conditions”) is added
after Figure 2-18 on page 149.
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Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 111
The following new paragraph is added at the top of page 153 after the end of the Key View
7 paragraph:
Key View 8
Key View 8 looks east toward the project area from the south side of 24th Street on the west
side of Cedar Street (see Figure 2-18A). Residential properties (on both sides of 24th Street)
and streetlights are visible within the foreground and middle ground of this view. Buildings
range from one to two stories in height and are generally made of wood and stucco. Mature
vegetation along 24th Street softens the hardscape features of the residential structures and
road. Existing landscaping throughout the view appears to integrate the residential uses to the
north and south. The two-way 24th Street and residential structures are visible in the
foreground and middle ground views. The existing visual quality and character of the site
from this key view is moderately high.
Paragraph 2 on page 153 is revised as follows:
Since the Draft Environmental Impact Report/Environmental Assessment was circulated, the
project has been modified, in response to public comments, to provide enhanced landscaping
in the median and parkway areas on both the north and south sides of the facility within
Segment 2 and Segment 3 from Oak Street on the west to C Street on the east, and along the
south side of 23rd Street between C Street and D Street (See Draft Concept Landscape Plan in
Appendix I). Six additional cul-de-sacs (for a total of eight) also have been added to the south
side of 24th Street. The analysis that follows takes into consideration these proposed
modifications.
The following heading on page 154 is revised as follows:
Permanent Impacts to Key Views 1–7 1-8
The following text is inserted after Paragraph 4 on page 156 (after the Key View 7
paragraph):
Key View 8
Improvements under Alternative 1 would result in a moderate to moderately high visual
change to existing views of the study area from this key view. The addition of a new cul-de-
sac at the terminus of Cedar Street would be visible to both pedestrians and motorists.
Placement of a roadway median on 24th Street would enhance the aesthetics of the area along
with concrete sidewalks that use softscape (plants) and hardscape similar in scale and material
as those contained in the historic districts located to the north and south of 24th Street. This
streetscape would be visible to both east- and west-bound travelers on 24th Street. Landscape
and aesthetic treatments would provide continuity of the appearance of a permanent cul-de-
sac at Cedar Street. Sensitive viewers would have a high viewer response to the project
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 112
changes, particularly after mature vegetation augments the unity of this key view. Building
the project would have a moderate to moderately high impact in this key view.
Section 2.1.6 Cultural Resources
Figure 2-19 (entitled “Impacts to Properties within the Historic Districts North and South of
24th Street – Alternative 1”) on page 167 is revised as shown on the following page.
Table 2.13 on page 166 is revised as follows:
Table 2.13. Permanent Uses and Temporary Occupancies
at the Historic Properties
Alternative 1 Alternative 2
Number of Full
Parcel
Acquisitions
Number of
Partial Parcel
Acquisitions
(total square
feet)
Number of Parcels
with Temporary
Construction
Easements
(total square feet)
Number of Full
Parcel
Acquisitions
Number of Partial
Parcel
Acquisitions (total
square feet)
Number of Parcels
with Temporary
Construction
Easements
(total square feet)
Historic District South of 24th Street
Parcels: 9 Parcels: 6 16
(6,978 7,755)
Parcels:12 18
(6,033 8,607) Parcels: 22 Parcels:3
(16,986)
Parcels: 11
(4,746)
Historic District North of 24th Street
Parcels: 12 Parcels: 2
(647)
Parcels: 14
(6,644) Parcels: 1 Parcels: 0
(0)
Parcels: 3
(±2,000)
Total Effects at the historic districts South and North of 24th Street
Parcels: 21 Parcels: 8 18
(7,625 8,402)
Parcels: 26 32
(12,677 15,251) Parcels: 23 Parcels: 3
(16,986)
Parcels: 14
(±6,746)
Source: Developed from the Right-of-Way data sheet
Paragraph 3 on page 176 is revised as follows:
To meet the requirements of the National Historic Preservation Act of 1966, as amended, and
its implementing regulations known as Section 106, a Finding of Effect (August 2012) was
prepared for this project to determine if the proposed project would result in an adverse effect
to a historic property (properties listed or determined eligible for listing in the National
Register of Historic Places) and to meet the requirements of the National Historic
Preservation Act of 1966, as amended, and its implementing regulations known as
Section 106. The Finding of Effect determined that Alternatives 1 and 2 of the proposed
project would not result in an adverse effect to the historic district north of 24th Street because
demolition of between 1 and 5 properties, depending on the alternative, would result in a
minimal change to the overall district, and the district would retain the overall character-
defining features of a post-World War II residential tract development that are notably its
curvilinear street patterns and the overall suburban character and setting of the neighborhood.
The construction of cul-de-sacs on eight local streets located on the south side of 24th Street,
that is, on the side opposite to the historic district to the north of 24th Street, would not be
expected to result in adverse effects to historical resources considered to be part of the historic
district located north of 24th Street.
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Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 114
Six new paragraphs are inserted before the first full paragraph on page 177:
Proposed cul-de-sacs on eight streets on the south side of 24th Street (Elm, Beech, Myrtle,
Spruce, Pine, Cedar, A, and B Streets) were not included in the earlier analysis of the
Project’s effects prepared under 36 CFR 800.5. The new cul-de-sacs would be located
adjacent to seven parcels considered to be historical resources; that is, contributors to the
south of the 24th Street historic district, determined eligible for the National Register of
Historic Places. Neither of the two houses next to the cul-de-sacs on Myrtle Street or Pine
Street is considered to be a contributor to the historic district. One house each on the proposed
Beech Street, Spruce Street, and A Street cul-de-sacs is considered to be a historic contributor.
Both residential properties next to the project cul-de-sac on Cedar Street are considered to be
district contributors. One historic house contributor is immediately adjacent to the cul-de-sacs
on Elm and B Streets, but both are proposed to be fully acquired for right-of-way purposes
under the preferred alternative, Alternative 1--Widen to the North.
The placement of cul-de-sacs on eight local streets at their northern intersection with 24th
Street, which is considered the northern edge of the south of 24th Street historic district, will
alter the streetscape character at those particular locations. In terms of their scale and height,
however, the cul-de-sacs would be constructed such that their physical characteristics would
not be intrusive and would not detract from the significant historic architectural character
imbued in the south of 24th Street historic district (see Figure 2-18A, which depicts a cul-de-sac
adjacent to a historic contributor on Cedar Street with a before and after visual simulation).
The cul-de-sacs would prevent motorists traveling east on 24th Street from turning right and
driving by historic residences south of 24th Street. With their focus on driving, however, these
motorists would not likely be able to discern the finer architectural distinctions of the
individual houses, so this change is not believed to be of consequence. Neither the existing
street grid pattern of the historic district south of 24th Street nor having a certain level of
vehicular traffic pass directly in front of historic residences were identified by qualified
architectural historians as character-defining aspects of the historic neighborhood when it was
evaluated for its potential eligibility for listing in the National Register of Historic Places and
California Register of Historic Resources. Instead, the significance of the south of 24th Street
historic district was determined to be wholly embodied in the variety of distinctive
architectural styles and eras represented in the historic neighborhood’s houses themselves. It
is the individual contributor buildings’ facades, massing, materials, roof eave lines,
fenestration, and other character-defining details of each contributor property that collectively
constitute the fabric and feel of the historic residential neighborhood and its sense of place.
None of these character-defining details would change with the introduction of cul-de-sacs to
the physical landscape at eight street locations at the district’s northern boundary, including in
five cases, minor alterations in the front yard areas of parcels containing historic houses needed
for cul-de-sac construction. Additionally, it is certain houses with architectural merit and not the
local surface streets located within the south of 24th Street historic district that are regarded as
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 115
contributing elements to the National Register historic district, so reductions in vehicular
access due to the new cul-de-sacs would not alter the current historic preservation status of the
district.
The construction of eight cul-de-sacs on the northern periphery of the historic district south of
24th Street would not appear to reduce the integrity of the district so as to threaten either its
National Register or California Register eligibility status. With the exception of those historic
contributors directly required for right-of-way acquisition for project implementation, each of
the historic properties adjacent to the proposed cul-de-sacs would continue to be eligible for
both the National Register and the California Register and also would remain historical
resources for the purposes of the California Environmental Quality Act.
Due to the anticipated removal of district contributors because of right-of-way acquisition
needs, an adverse effect determination of the project on the south of 24th Street historic district
was originally made in consultation with the California State Historic Preservation Officer
under Section 106 of the National Historic Preservation Act, without consideration at that
time given to constructing cul-de-sacs on city streets that intersect with 24th Street. Because
the project to widen 24th Street would result in an adverse effect, Caltrans, in cooperation with
the City of Bakersfield, developed and executed a Memorandum of Agreement with the State
Historic Preservation Officer in 2012, with commitments intended to mitigate adverse effects
to the south of 24th Street historic district.
The City of Bakersfield has thoroughly reconsidered the preferred alternative with inclusion
of the eight additional cul-de-sacs, and has determined that the cul-de-sacs would not result in
any new cultural resources impacts or impacts of greater severity than those impacts that were
identified in the Final Environmental Impact Report/Environmental Assessment (December
2013). Constructing cul-de-sacs at the edge of the historic district would not, by itself, be
considered a substantial adverse change or constitute a significant impact on historical
resources under the California Environmental Quality Act. No additional mitigation is
required.
Section 2.2.1 Water Quality and Storm Water Runoff
Paragraph 1 on page 195 is revised as follows:
Construction activities to widen 24th Street, including the installation of eight cul-de-sacs
included in Alternative 1, would temporarily affect the existing drainage patterns by requiring
the extension of Carrier Canal, which carries flows underneath 24th Street. To build the
extension of Carrier Canal, a temporary diversion conduit would be built next to Carrier Canal
to divert flows during construction. The temporary diversion is necessary to maintain the use
of the water by downstream holders of water rights for irrigation. It is estimated that the
diversion conduit would be used for three months, the time estimated to extend the 24th Street
culvert. The diversion conduit would be about 350 linear feet and consist of a triple-pipe
culvert.
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 116
Paragraph 5 on page 195 is revised as follows:
Build Alternatives
The project site has about 48 acres of impervious areas (for example, pavement and
buildings). Both build alternatives, including the installation of eight cul-de-sacs included in
Alternative 1, would increase the impervious areas by about 4 acres. As a result of the
increase in impervious areas, the estimated increase in surface water would be 5,400 cubic
feet. The estimated increase in surface water would likely affect the Kern River; therefore,
treatment control best management practices (ways to protect water quality) would be
implemented as a part of the proposed project. Based on available information, it is expected
there is sufficient area to treat the estimated increase in surface water generated from
impervious areas with the treatment control best management practices.
Section 2.2.2 Paleontology
Paragraph 4 on page 200 is revised as follows:
Build Alternatives
Impacts to paleontological resources would not result from construction activities required for
either of the two build alternatives, including installation of eight cul-de-sacs included in
Alternative 1, because impacts to paleontological resources are considered permanent, not
temporary. See Permanent Impacts below.
Paragraph 5 on page 201 is revised as follows:
Based on the sensitivity of the area for paleontological resources, excavation below a depth of
5 feet in the latest Pleistocene native sediments within the project study area could result in
adverse impacts on nonrenewable paleontological resources. Installation of eight cul-de-sacs
included in Alternative 1 would not require excavation in excess of 2 feet and, for that reason,
would not result in impacts to paleontological resources. Ground-disturbing construction
activities such as excavation have the potential to encounter scientifically significant
paleontological resources. This could result in destruction of unique and valuable scientific
specimens and data.
Section 2.2.3 Hazardous Waste or Materials
Paragraph 4 on page 208 is revised as follows:
Temporary construction easements would be placed at the four service stations within the
project study area (Circle K at 2222 F Street, White Wash Car Wash/Lube at 2301 H Street,
Firestone Complete Auto Car at 2331 Chester Avenue, and Chevron, 2317 L Street). No
permanent right-of-way acquisitions would occur, and no excavation at these properties
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 117
would be required for construction of the proposed improvements to 24th Street, including the
eight cul-de-sacs included in Alternative 1.
Section 2.2.4 Air Quality
Paragraph 3 on page 219 is revised as follows:
Construction activities, including the eight cul-de-sacs included in Alternative 1, would
produce combustion emissions from various sources, such as site grading, utility engines,
onsite heavy-duty construction vehicles, equipment hauling materials to and from the site, and
motor vehicles transporting the construction crew. Exhaust and fugitive dust emissions
generated during project construction would vary daily as construction activity levels change.
Construction of the project would result in 5 acres or more of disturbed surface area (for non-
residential development), requiring submittal of a Dust Control Plan to the San Joaquin
Valley Air Pollution Control District before construction.
Paragraph 6 on page 219 is revised as follows:
The purpose of the project is to alleviate existing and future traffic congestion along 24th
Street during peak hours. The project would not generate new vehicular traffic trips since it
would not involve construction of new homes or businesses. However, it is it’s possible that
some motorists currently using other routes would be attracted to using the improved
roadway, resulting in increased vehicle miles traveled along 24th Street. The potential impact
of the proposed roadway improvement project, including the eight cul-de-sacs included in
Alternative 1, on regional vehicle emissions was calculated using traffic data for the proposed
project region and emission rates from the EMFAC2007 emission model.
Section 2.2.5 Noise and Vibration
Paragraph 3 on page 232 is revised as follows:
Build Alternatives
Two types of short-term noise impacts would occur during project construction., including the
installation of eight cul-de-sacs on the south side of 24th Street. The first would be from
construction crew commutes and transport of construction equipment and materials to the
project area. This would incrementally raise noise levels on access roads leading to the site.
Pieces of heavy equipment for grading and construction activities would be moved onsite and
remain for the duration of each construction phase, but would not add to the daily traffic
volume in the project area.
Sheets 3 and 4 of Figure 2-24 (entitled “Figure 2-24. Modeled Sound Barriers and Receiver
Locations – Alternative 1”) on pages 237 and 239, respectively, are revised as shown
herein.
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Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 120
Section 2.2.6 Energy
Paragraph 1 on page 277 is revised as follows:
Build Alternatives
Construction of the project, including the eight cul-de-sacs included in Alternative 1, would
entail a one-time energy expenditure to manufacture building materials, prepare the roadway
surface, and build the roadway widening and intersection/interchange improvements. The
one-time energy expenditure would be balanced by the improved system functionality of the
corridor and improved traffic flow operations over the design life of the project.
Paragraph 5 is revised as follows:
Build Alternatives
Implementation of the project, including the eight cul-de-sacs included in Alternative 1,
would alleviate existing traffic congestion, improve local circulation, and help reduce
congestion-related pollutant emissions in the corridor. When balancing energy used during
operation against energy saved by relieving congestion and other transportation efficiencies,
the build alternatives would not have substantial energy impacts.
Section 2.3 Biological Environment
Paragraph 2 on page 283 is revised as follows:
Figures 2-27 and 2-28 show where Alternatives 1 and 2, respectively, would affect biological
resources. The installation of eight cul-de-sacs on the south side of 24th Street, as part of
Alternative 1, would be located entirely within developed areas; natural communities would
not be affected. The installation of cul-de-sacs would not result in any impacts to animal
species, threatened and endangered species or invasive species. Wetlands and waters of the
United States are also considered sensitive both by federal and state agencies. These are
discussed in detail in Section 2.3.2. There are no wetlands or waters of the United States
within the area where cul-de-sacs will be installed.
Section 2.4 Cumulative Impacts
Paragraph 1 on page 325 is revised as follows:
In addition to the Thomas Roads Improvement Program projects, there are pending
development proposals in the project’s cumulative study area. Examples of reasonably
foreseeable actions by the City of Bakersfield include future development for which a General
Plan or Specific Plan has been adopted that designates future land uses; projects for which the
applicable jurisdiction has received an application for site development; or infrastructure
improvement projects planned by the local jurisdiction or other public agency. The reasonably
foreseeable development actions are listed in Table 2.28. Note that since the circulation of the
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 121
draft environmental document, the City by Resolution (No. 128-12) on November 14, 2012,
conditionally agreed to allow cul-de-sacs of streets on the south side of 24th Street between
Beech Street and A Street as a separate City project. The conditions that 1) all property
owners along the affected street between 24th and 22nd Street must agree to the closure by
signing a petition, and 2) directly affected property owners must agree to donate sufficient
land to construct the cul-de-sac to City standards.
Table 2.28 on page 326 is revised as follows:
Table 2.28. Cumulative City of Bakersfield Projects within the Study Area
Site Plan
Review #
Project
Location Project Title Project Description Project Type
SPR-08-
0500
2301 F Street Arco Mini-Mart Construction of a 3,000-square-foot
gas station with convenience
market and eight pump islands.
Commercial
SPR-08-
1650
2129 G Street Office Building Construction of a 975-square-foot
general office addition.
Office
SPR-09-
0586
2111 F Street Not available Construction of a 38-bed, 7,411-
square-foot residential care facility
on a 12,200-square-foot parcel;
related to: MOD 08-330- reduction
in parking from 32 to 25 spaces.
Commercial
SPR-08-
0297
900 22nd Street Church Construction of a 970-seat church
sanctuary and classrooms,
including three new offsite parking
lots.
Community
Service
SPR-09-
0670
2115 N Street Comm. GarageConstruction of a 3,920-square-foot
automobile detail shop.
Commercial
SPR-09-
0653
2116 P Street
or 821 22nd
Street
Not available Moving eight 960-square-foot
modular office buildings onto a
vacant site in a Community Center-
zoned district.
Office
SPR-09-
0558
2521 O Street Not available Construction of a 1,760-square-foot
general office building; related to
MOD 09-0557- permit for a 0-foot
side yard along 26th Street.
Office
SPR-10-
0011
2531 M Street Not available Construction of a 4,080-square-foot
office building.
Office
SPR-07-
2371
1918 L Street
or 1223 24th
Street
Ming Café Construction of an 875-square-foot
addition to an existing 2,732-
square-foot restaurant in the
central business-zoned district.
Commercial
Restaurant
Expansion
N/A Fresno to
Bakersfield
section of the
project
California
High-Speed
Rail Project
Construction of an about 114-mile
portion of a larger high-speed train
system that would connect to
sections traveling west to San
Francisco, south to Los Angeles
and later, north to Sacramento.
Transportation
N/A South side of
24th Street
between
Beech Street
and C Street.
N/A The project would entail
construction of cul-de-sacs at up to
eight different streets on the south
side of 24th Street, as specified in
the City Resolution No. 128-12.
Public Works
Appendix A Errata Sheet to the 2015 Draft Environmental Impact Report
24th Street Improvement Project FEIR/EA Volume 3 122
Section 3.2.2 Significant Environmental Effects of the Proposed Project
Paragraph 3 on page 339 continuing to page 340 is revised as follows:
Implementation of the project would result in potential short-term noise impacts during
construction of the project under Alternatives 1 (including the installation of eight cul-de-sacs
on the south side of 24th Street) and 2. Construction of the project would comply with local
jurisdiction noise restrictions as well as the Caltrans Standard Specifications Section 14-8.02
and Caltrans Standard Provisions S5-310, as outlined in Avoidance and Minimization
Measures NOI-1 and NOI-2. In addition, Avoidance and Minimization Measures NOI-3 and
NOI-4 would further minimize potential construction noise impacts. Therefore, potential
short-term construction noise impacts would be less than significant, and no mitigation
measures are required.
Paragraph 1 on page 340 is revised as follows:
A permanent increase in ambient noise level would occur as a result of the long-term use of
the project under Alternatives 1 (including the installation of eight cul-de-sacs on the south
side of 24th Street) and 2. A traffic noise impact would occur under the California
Environmental Quality Act when the future noise level with the project results in a
substantial increase in noise level from existing baseline noise levels.
Section 3.2.4 Significant Irreversible Environmental Changes
Paragraph 3 on page 344 is revised as follows:
Alternative 1 would require 23 full acquisitions (residential single-family) and 29 41 partial
acquisitions (14 26 residential, 12 nonresidential, and 3 vacant). Alternative 2 would require
23 full acquisitions (residential single-family) and 21 partial acquisitions (7 residential, 11
nonresidential, and 3 vacant). Acquisition and demolition of these parcels would result in
direct irreversible impacts. Based on the current availability of residential units in the city, a
sufficient residential market exists for potential project-related relocations.
24th Street Improvement Project FEIR/EA Volume 3 123
Appendix B ALTERNATIVES COST
ESCALATION
The development of the cost estimates for the alternatives considered but rejected from further
discussion is shown in Table B.1. The original cost estimates included in the 2005 Project Study
Reports (PSRs) for the Oak Street Interchange Project (URS Corporation 2005a) and 24th Street
Widening Project (URS Corporation 2005b) were escalated at 3.5 percent per year for
construction costs (to 2014 dollars) to be consistent with the 2014 Project Reports. The right-of-
way costs were used as originally escalated in the PSRs at 2.0 percent per year (to 2011 dollars),
without further escalation. The Alternative J Hageman Flyover cost estimate was developed
during the preparation of the Hageman Road Extension Project Environmental Document (Initial
Study/Mitigated Negative Declaration) finalized in 2014. These cost estimates for the alternative
segments were combined with the appropriate segments of the proposed project (Alternative 1)
to present a complete alternative.
Appendix B Alternative Cost Escalation
24th Street Improvement Project FEIR/EA Volume 3 124
Table B.1. Cost Estimates for Alternatives Considered but Eliminated from
Further Discussion
Alternative
Base
Estimate
(Million $)
Year Escalation
Rate
Escalated Costs
(Million $) Notes
TotalCost
Estimate
Escalated
(Million $)
A 21.5 2005 3.5% 28.8 Construction 45.9 2011 2.0% 17.1 Right of Way
B 21.8 2005 3.5% 29.2 Construction 43.7 2011 2.0% 14.5 Right of Way
C 11.9 2005 3.5% 15.9 Construction 17.3 2011 2.0% 1.4 Right of Way
D 2014 24.2 Construction 45.8 21.6 Right of Way
E 2014 11.5 Construction 13.6 2.1 Right of Way
F (Walls) 29.4 2005 3.5% 39.4 Construction 48.2 2011 2.0% 8.8 Right of Way
F (Slope) 22 2005 3.5% 29.5 Construction 46.0 2011 2.0% 16.5 Right of Way
G (1) 2014 17.7 Construction 33.3 15.6 Right of Way
G (2) 2014 17.3 Construction 31.8 14.5 Right of Way
G (3) 2014 17.1 Construction 30.4 13.3 Right of Way
G (4) 2014 15.0 Construction 28.2 13.2 Right of Way
H 2014 15.3 Construction 29.8 14.5 Right of Way
I 2014 3.2 Construction 7.0 3.8 Right of Way
J 2014 49 Construction 52.0 3 Right of Way
24th Street Improvement Project FEIR/EA Volume 3 125
Appendix C RESPONSES TO COMMENTS ON
R-DEIR
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 127
Contents
1. INTRODUCTION........................................................................................................... 129
1.1 Project Background .......................................................................................... 129
1.2 What is in this Document ................................................................................. 129
1.3 Public Review of the R-DEIR .......................................................................... 130
1.4 Distribution of the R-DEIR .............................................................................. 130
1.5 Summary of Comments Received on the Recirculated Draft EIR ................... 132
2. MASTER RESPONSES TO R-DEIR COMMENTS .................................................. 133
2.1 Master Response No. 16 – Issues Out of Scope of the R-DEIR ...................... 133
2.2 Master Response No. 17 – Supporting Information for 2013
FEIR/2015 DEIR.............................................................................................. 138
2.3 Master Response No. 18 – Alternatives ........................................................... 139
2.4 Master Response No. 19 – Project Costs ......................................................... 154
2.5 Master Response No. 20 – Cul-de-Sacs ........................................................... 155
2.6 Master Response No. 21 – Cultural Resources ................................................ 158
3. RESPONSES TO WRITTEN COMMENTS ON THE
RECIRCULATED DRAFT EIR ............................................................................. 163
4. RESPONSES TO ORAL TESTIMONY ON THE RECIRCULATED
DRAFT EIR .............................................................................................................. 449
5. RESPONSE TO PETITION CONCERNING THE R-DEIR ..................................... 493
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 129
1. Introduction
The Draft Environmental Impact Report/Environmental Assessment (DEIR/EA) and Section 4(f)
Evaluation for the 24th Street Improvement Project (Volume 1) was circulated to the public in
2012. Comments were received on the draft document, and responses to the comments were
included in Volume 2. The Final Environmental Impact Report/Environmental Assessment
(FEIR/EA) was completed in December 2013.
1.1 Project Background
The 2013 FEIR/EA was approved by the California Department of Transportation (Caltrans) as a
National Environmental Policy Act (NEPA) Lead Agency and certified by the City of
Bakersfield (City) as a California Environmental Quality Act (CEQA) Lead Agency in February
2014. Following certification of the 2013 FEIR/EA, a legal challenge to the adequacy and
completeness of the 2013 FEIR was filed in Kern County Superior Court (Court). Citizens
Against the 24th Street Widening Project filed a Petition for a Writ of Mandamus against the City
and Caltrans alleging defects in the 2013 FEIR under CEQA [Case No. S-1500-CV-
281556KCT]. On May 1, 2015, the Court ruled that the 2013 FEIR certified by the City in
February 2014 was deficient in two respects: (a) the project description and environmental
analysis in the 2013 FEIR should have included six additional cul-de-sacs requested by local
residents (for a total of eight cul-de-sacs), and (b) the 2013 FEIR did not adequately and
completely consider and analyze the eight potentially feasible alternatives discussed in Section
1.3.6 of the document.
On July 10, 2015, the Court finalized its ruling ordering the City to void the certification of the
2013 FEIR and the approval of the proposed project, and issued a writ enjoining further activities
that could result in any change in the physical environment until full compliance with CEQA is
effected. In response to the Court’s ruling, the Bakersfield City Council decertified the 2013
FEIR in September 2015. With its decertification, the 2013 FEIR became the 2015 Draft
Environmental Impact Report (2015 DEIR). In compliance with the Court ruling on the cul-de-
sacs and the alternatives analysis, the City released a Recirculated Draft Environmental Impact
Report (R-DEIR) for public review in January 2016.
1.2 What is in this Document
Written comments and oral testimony on the R-DEIR received during the public review period,
and responses to these comments are provided in this document. In response to comments
received, minor revisions to the R-DEIR were made; Appendix A of this document contains the
Recirculated Final EIR.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 130
1.3 Public Review of the R-DEIR
The public review period for the R-DEIR opened on January 11, 2016, and closed on
February 25, 2016 (45 days).
1.4 Distribution of the R-DEIR
A Notice of Availability of the R-DEIR was sent to 523 residents and businesses of record within
an approximately 500-foot radius of the Project site. The R-DEIR was made available on the
City’s website and in local public libraries. The Notice of Availability of the R-DEIR was also
sent to entities shown in Table 1.
Table 1. Distribution of the 24th Street Improvement R-DEIR
Type Recipient No. Sent
Federal
Agencies
USFWS – Sacramento Fish and Wildlife Office
U.S. Army Corps of Engineers
U.S. Environmental Protection Agency, Region 9
National Park Service, Pacific West Region
U.S. Department of Agriculture
Department of the Interior
6
State Agencies California Department of Fish & Wildlife (Region 4)
California Department of Parks and Recreation
California Emergency Management Agency
California Department of Conservation
Department of Water Resources
California State Lands Commission
California Air Resources Board
California State Water Resources Control Board
Central Valley Flood Protection Board
Native American Heritage Commission
California Natural Resources Agency
California Highway Patrol
Office of Historic Preservation
California Department of Transportation (District 6)
California Department of Transportation – Division of Transportation
Planning
Office of Planning and Research (State Clearinghouse)
16
Regional and
County
Agencies
Central Valley Regional Water Quality Control Board – Region 5
San Joaquin Valley Air Pollution Control District (Southern Region)
County of Kern Floodplain Management
Kern County Public Works Department
County of Kern, Planning Department
Kern County Council of Governments
Eastern Kern County Air Pollution Control District
11
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 131
Type Recipient No. Sent
Kern Regional Transit
Kern County Parks and Recreation
Kern County Public Works Department
Kern County Clerk
Local Agencies City of Bakersfield – Public Works Department
City of Bakersfield – Economic & Community Development
Bakersfield City Clerk
City of Bakersfield – Planning Division
City of Bakersfield – Water Resources Department
City of Bakersfield – Dept. of Recreation & Parks
Bakersfield Police Department
Bakersfield Fire Department
8
Elected
Officials
State
Office of U.S. Senator – Dianne Feinstein
Office of U.S. Senator – Barbara Boxer
Office of Jean Fuller – State Senate 16th District
Shannon L. Grove – State Assembly 34th District
Rudy Salas – State Assembly 32nd District
Kevin McCarthy – House of Representatives 23rd District
David Valadao – House of Representatives 21st District
County
David Couch, Chairman – Kern County Board of Supervisors
Mike Maggard, Dist. 3 – Kern County Board of Supervisors
Local
Mayor Harvey L. Hall
Bakersfield City Council:
Willie Rivera, Councilmember, Ward 1
Terry Maxwell, Councilmember, Ward 2
Ken Weir, Councilmember, Ward 3
Bob Smith, Councilmember, Ward 4
Harold Hanson, Councilmember, Ward 5
Jacquie Sullivan, Councilmember, Ward 6
Chris Parlier, Ward 7
17
Organizations,
Groups and
Individuals
Kern County Hispanic Chamber of Commerce
Kern County Historical Society
Tubatulabals of Kern Valley
Kudzubitcwanap Palap Tribe
Tejon Indian Tribe
Carol A. Pulido
Bakersfield City School District
Kitanemuk and Yowlumne Tejon Indians
Tule River Indian Tribe
Monache Inter-Tribal Association
Kern Valley Indian Councils
Kern County Black Chamber of Commerce
23
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 132
Type Recipient No. Sent
Kern Economic Development Corporation
Hall Ambulance
Chumash Council of Bakersfield
Kern County Superintendent of Schools
Kawaiisu Tribe
Santa Rosa Rancheria
Greater Bakersfield Chamber of Commerce
Golden Empire Transit District
Kern High School District
Michahai Wukasachi Band of Eshom Valley
Sierra Club
Libraries Kern County Library (Beale Memorial and Wilson Branch)
Kern County Law Library
3
1.5 Summary of Comments Received on the Recirculated Draft EIR
Comments were received from members of the community who sent letters and e-mail messages,
and attended a public hearing on January 21, 2016. The types of comments received during the
public review period are summarized in Table 2. Letters were sorted into the categories listed in
Table 2, and were assigned the appropriate code, as shown (e.g., “F”). Within each category,
letters were numbered sequentially (e.g., “F-1,” “F-2”) continuing from the last number assigned
to the comment letters received on the 2012 Draft EIR/EA. Within each letter, comments were
numbered sequentially (e.g., “F-1-1,” “F-1-2”).
Table 2. Summary of Comments Received on the 24th Street Improvement R-DEIR
Type of Comment Number Received
Written comments from federal agencies (Comment Coding “F”) 0
Written comments from state agencies (Comment Coding “S”) 0
Written comments from local/regional agencies and organizations
(Comment Coding “L”) 2
Written comments from businesses (Comment Coding “B”) 0
Written comments from individuals (representing the general public)
(Comment Coding “GP”) 60
Oral comments received at the January 21, 2016 public hearing
(Comment Coding “OC”) 13
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 133
2. Master Responses to R-DEIR Comments
Chapter 2 of the December 2013 FEIR/EA provided 15 Master Responses to comments received
on the DEIR/EA. In a similar manner, Master Responses to the most prevalent topics and issues
raised during the R-DEIR public review period were prepared and sequentially numbered (as
Master Response Nos. 16 through 21). Master Responses to common issues raised in public
comments on the R-DEIR are as follows:
Master Response No. 16: Issues Out of Scope of the R-DEIR
Master Response No. 17: Supporting Information for 2013 FEIR /2015 DEIR
Master Response No. 18: Alternatives
Master Response No. 19: Project Costs
Master Response No. 20: Cul-de-Sacs
Master Response No. 21: Cultural Resources
2.1 Master Response No. 16 – Issues Out of Scope of the R-DEIR
The R-DEIR was prepared to address two specific issues identified by the Court as deficient in
the original environmental document:
The analysis of six cul-de-sacs as a separate project; and
Insufficient discussion and analysis of the eight potentially feasible alternatives that were
eliminated from consideration.26
Other environmental issues associated with the project were previously addressed in the original
DEIR/EA that was circulated for public review in 2012 and finalized in Volumes 1 and 2 of this
FEIR. All public comments received during the 2012 DEIR/EA circulation were addressed in
Chapters 2 through 10 of Volume 2. Comments on the environmental document must be made in
a timely manner to allow the lead agency a reasonable opportunity to respond adequately to
issues within its areas of special jurisidiction prior to certification of the FEIR. Additionally,
requiring all pertinent comments, questions, corrections, and recommendations to be made
within a reasonable period following publication of the DEIR encourages an efficient and final
agency review process that is in the public interest.
The public review of the R-DEIR was intended to provide an opportunity for the public to
comment on this current document, not to reopen the comment periods for earlier project
documents. In accordance with CEQA, comments on the information, analyses, and conclusions
contained in the 2012 DEIR/EA or 2013 FEIR/EA, and not on the R-DEIR, that were made
during the public review period for the R-DEIR will not be addressed.
26 [Proposed] Order Granting Petition for Writ of Mandate, entered August 20, 2015; see items A and 2(c).
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 134
CEQA specifically provides for limiting comments to the R-DEIR. CEQA Guidelines Section
15088.5, Recirculation of an EIR Prior to Certification, Subsection (f)(2) states,
… the lead agency may request reviewers to limit their comments to the revised
chapters or portions of the recirculated EIR. The lead agency need only respond
to (i) comments received during the initial circulation period that relate to
chapters or portions of the document that were not revised and recirculated, and
(ii) comments received during the recirculation period that relate to the chapters
or portions of the earlier EIR that were revised and recirculated.
The City included such a request limiting the scope of public and agency review, both within the
text of the R-DEIR and in the Notice of Availability announcing the start of the public review
period. Despite these written requests, numerous comments were made about topics that are not
within the scope of the R-DEIR. No changes to the original DEIR/EA or the R-DEIR are
required in response to comments on subjects other than the additional six cul-de-sacs, the
alternatives considered but rejected, associated revisions of the 2013 FEIR/EA/2015 DEIR/EA,
and information in the R-DEIR on the review and approval process.
Among the letters and oral public hearing testimony received during the public review period for
the R-DEIR were comments on the following out-of-scope topics and issues:
The original text of the 2012 DEIR/EA;
Environmental issues addressed in the 2012 DEIR/EA and in public and agency
comments on that document;
The Section 4(f) Evaluation;
The Finding of Effect;
Population growth in Bakersfield;
The 2013 FEIR;
The Findings, approval resolution, and Statement of Overriding Considerations
accompanying the certification of the FEIR;
City Resolutions about the installation of cul-de-sacs;
Other information provided to the public by the City in documents other than the R-DEIR
or in forums other than the public review process for the 24th Street Improvement Project;
and
Information contained in the City’s 2015 brief to the Court.
There are also comments submitted during public review of the R-DEIR that restate comments
from public review of the 2012 DEIR/EA, and for which responses are provided in Volume 2 of
the FEIR. These comments are beyond the scope of topics and issues addressed in the R-DEIR,
and no additional response from the City is required.
The following subsections address specific out-of-scope issues and topics that were raised in
multiple comment letters.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 135
2.1.1 Court Briefs
Some commenters refer to information presented in the City’s brief to the Superior Court.27
Citizen concerns about information the City provided in documents other than the R-DEIR or
presented in forums other than the R-DEIR public review process should be addressed directly to
the City. The purpose of the public review period was solely to receive comments on the
adequacy and completeness of the R-DEIR in addressing the addition of six cul-de-sacs to the
Project Description and the elimination of potentially feasible alternatives from detailed
consideration.
2.1.2 Purpose and Need
Some comments questioned the need for the project or the ability of the project to achieve its
purposes, or interpreted the purposes of the project too broadly. The purposes of and need for the
project were addressed in Chapter 1 of the original DEIR/EA and are carried through this FEIR
(Chapter 1 of Volume 1). The ability of the preferred alternative to fulfill those purposes was
addressed in the original FEIR/EA that was decertified. The purpose and need did not change
with the addition of the cul-de-sacs. The project would relieve traffic congestion and would not
generate traffic because no traffic-generating land uses are included in the project. It is not a
purpose of the project, and the project is not capable of decreasing the volume of motorists
wishing to drive into or through downtown Bakersfield.
2.1.3 Project Description
Some comments questioned the description of the project in terms of segments, or the integration
of the Oak Street Interchange and 24th Street Widening projects into a single project. The
descriptions of project alignment Segments 1, 2, 3, and 4 appear in the 2012 DEIR/EA and, with
the exception of adding the cul-de-sacs to the description of Segment 3, are reproduced in
Chapter 1 of the R-DEIR solely for informational purposes.
The description of the project in terms of its two major elements – an intersection and a roadway
segment – does not call into question the validity of the project or its analysis. This aspect of the
project description was included in the original DEIR/EA, and was not changed in the R-DEIR.
Traffic engineers determined that alleviating traffic congestion at the Oak Street/24th Street
intersection and along 24th Street between Elm Street and B Street would shift the congestion to
other points along 24th Street in the absence of improvements in Segments 1 and 4.
27 Citizens Against the 24th Street Widening Project v. City of Bakersfield [Case #S-1500-CV-281556KCT]
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 136
A number of comments on the Project Description raised various design issues associated with
the project. The design features of the project were described in the 2012 DEIR/EA with some
design modifications later incorporated into the 2013 FEIR based on public comments. No
design changes besides adding six cul-de-sacs to the south side of 24th Street occurred during the
R-DEIR preparation. Therefore, design modifications other than the cul-de-sacs are not a subject
of the R-DEIR.
Based on the above information, the City has addressed comments on the six new cul-de-sacs
described in the R-DEIR, as well as comments on their environmental effects.
2.1.4 Traffic Study
Many commenters addressed various traffic issues associated with the project, including traffic
congestion, vehicle volumes, road capacity, travel times, levels of service, and traffic safety. The
traffic and transportation analysis for the project was presented in Volume 1, Chapter 3 of this
FEIR and was addressed in responses to public comments in Volume 2 of the FEIR (Master
Response No. 14: Traffic Demand in the 24th Street Corridor; Responses to Comments B-6-2,
GP-083-1, GP091-1, GP-094-2, GP-094-4, GP-098-1, GP-251-2, GP-251-5, GP-252-5, GP-253-
1, GP-253-2, GP-255-3, GP-255-4, and GP-260-2). The issues of traffic and transportation were
addressed in the R-DEIR only in terms of whether the potentially feasible alternatives were
capable of achieving the primary objective of the proposed project, which is to relieve current
and anticipated future traffic congestion on 24th Street.
Traffic congestion is typically expressed in terms of the Level of Service (LOS) for intersections
and road segments; LOS definitions are found in Figures 1-3 and 1-4 in Chapter 1, Volume 1, of
this FEIR. The current and projected future LOS on 24th Street are provided in Tables 1.1 and 2.9
in Volume 1 of this FEIR. Comments on the traffic analysis were addressed in responses to
Comments B-9-12, GP-106-1, and GP-251-2 in Volume 2 of this FEIR.
Several comments about travel times through the 24th Street corridor question the content of the
traffic study. Comments on travel times received during public review of the 2012 DEIR/EA
were addressed in FEIR Volume 2, Master Response 2.1 – Consideration of Improvements to
State Route 204 Instead of the Proposed 24th Street Improvement Project, Master Response 2.7 –
Quality of Life and Community Cohesion, and Master Response 2.14 – Traffic Demand in the
24th Street Corridor, and in responses to Comments B-9-7 and GP-271-5. The travel times cited
in 24th Street Improvement Project reports include the intersection delay from one end of the
corridor to the other end of the corridor. Additionally, undocumented anecdotal observations
made by motorists at various times and places, and lacking in data on the overall context in
which the observations were made, do not constitute useful data that can be integrated into a
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24th Street Improvement Project FEIR/EA Volume 3 137
scientifically based traffic study. Finally, travel time information is not useful in predicting
traffic conditions at other times and locations, or in the future. As noted above, the traffic study
was not a topic in the R-DEIR.
2.1.5 Crosswalks
Some comments asked about the status of the crosswalks, made recommendations about their
design or operation, or expressed concerns about their safety. Crosswalks were described as an
element of the project in Chapter 2 of Volume 1 and addressed in responses to public comments
in Volume 2 of the FEIR (refer to Master Response No. 10: Pedestrian and Bicycle Access and
GP-24-5, GP-36-8, GP-52-1, GP-93-4, GP-95-1, GP-100-1, GP-111-11, GP-116-2, GP-140-2,
GP-160-5, GP-163-1, GP-182-1, GP-187-2, GP-193-14, GP-196-4, P-4-2, OC-7-1, OC-13-1,
OC-34-4, OC-46-1, OC-47-1). The issue of crosswalks was not addressed in the R-DEIR.
2.1.6 Traffic Signal Synchronization
Several commenters suggested that traffic signals should be synchronized to resolve traffic
congestion issues on 24th Street. Transportation System Management (TSM) alternatives, such as
adjusting traffic signal timing, were considered in Section 1.3.1 of Volume 1 of this FEIR, Build
Alternatives. Traffic signal synchronization was subsequently incorporated into the project. As
stated on page 32 of the 2013 FEIR /2015 DEIR under Transportation System Management and
Transportation Demand Management Alternatives, “Although transportation system
management measures alone could not satisfy the purpose for and need of the project, all of the
strategies listed above have been incorporated into all four segments of the build alternatives for
this project.” The traffic analysis prepared for the project assumes that vehicle flows through the
intersections are optimized (e.g., signals are synchronized to achieve optimum flows), so the
benefits of this measure are already reflected in the projections of future traffic conditions under
the proposed project.
Signal synchronization and timing adjustments were further addressed in responses to comments
on the 2012 DEIR/EA (refer to Volume 2, Master Response No. 2 – Design Modifications
Incorporated in the Project Design, in Master Response No. 15 – Access to and from the
Neighborhoods North and South of 24th Street, and in responses to Comments B-9-6, GP-095-2,
GP-260-4, GP-264-3, and GP-274-1). Master Response No. 15 states that, “Also, traffic signals
would be coordinated for progressive flow for both eastbound and westbound traffic on the 24th
Street and 23rd Street/24th Street couplet through Downtown Bakersfield. Synchronized traffic
signals would minimize traffic delays and reduce the likelihood of motorists cutting through the
neighborhoods north and south of 24th Street.” The response to Comment #R-5-2 states that
“signal timing optimization ... [has] been incorporated into all four segments of the project.”
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24th Street Improvement Project FEIR/EA Volume 3 138
In fact, the City has already synchronized the traffic signals in the project area to the extent
practicable. The traffic signals along 23rd and 24th streets in downtown Bakersfield are
synchronized to facilitate east-west traffic flows through the downtown, and the signals in the
24th Street/23rd Street couplet area are pre-timed. The signals at the Oak Street and Buck Owens
Boulevard intersections with 24th Street are also synchronized. The traffic signal timing plans are
periodically reviewed to optimize vehicular throughput and to minimize motorist delay. The
timing plans are not dynamic or adaptive.
The traffic signals along the 24th Street corridor at Oak Street and F Street are too far apart to
achieve synchronization of these two signals; there are no traffic signals on the two-way portion
of 24th Street between Elm Street and B Street. In addition, the traffic volumes along Oak Street
at 24th Street require a higher proportion of green time for the northbound movement versus the
east-west movement, compared to F Street. As a result, traffic queues occur in the east-west
direction primarily at Oak Street, at F Street in the eastbound direction, at Eye Street, and at
M Street in the westbound direction, but also frequently in the eastbound direction.
Thus, signal timing was included in the proposed project and is an issue that has been previously
addressed. Consideration of traffic signal synchronization as a project design modification or a
new alternative is unnecessary and is outside the scope of the R-DEIR.
2.2 Master Response No. 17 – Supporting Information for
2013 FEIR/2015 DEIR
Several commenters expressed an opinion that the baseline data used in the 2013 FEIR /2015
DEIR were outdated. CEQA Guidelines Section 15125(a) provides that the EIR describe the
physical environmental conditions “as they exist at the time the NOP [Notice of Preparation] is
published. The environmental setting will normally constitute the baseline by which a lead
agency determines whether an impact is significant.” Thus, the EIR generally presents baseline
environmental conditions as they existed at the time the NOP was released.
The original DEIR/EA was released in 2012. The data used to prepare the original DEIR/EA
were reasonably current and the best available information at that time. In certifying the 2013
FEIR, the City expressed its determination that the information upon which the impact analyses
and conclusions were based was adequate.
Trends in environmental information, such as traffic volumes, noise and air pollutant levels, local
population growth, and resource consumption, tend to be gradual and predictable. Incremental
year-to-year variations and changes are generally not expected to substantially affect impact
significance levels, and reasonable projections of future conditions can be made. Planning
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 139
documents are typically deemed to be reasonably current if they have been prepared or updated
within the last 3 to 5 years, and that standard is often applied to environmental documents except
where specific data are known to be out of date. Absent a specific showing that particular data
are out of date, the mere passage of time does not render the baseline information in the
document invalid.
Concerns expressed in the comments about the publication dates of various source materials and
anecdotal observations about the information and data that were used in the document do not by
themselves justify the preparation of new technical studies for the EIR. These commenters have
not demonstrated that circumstances surrounding the project have substantially changed.
2.3 Master Response No. 18 – Alternatives
2.3.1 Screening Criteria
Several commenters had comments on or questions about the content, justification for, or
application of the project objectives or other alternative threshold screening criteria used in the
R-DEIR.
As stated in CEQA Guidelines Section 15124(b), the purposes of the project objectives outlined
in the EIR are developed to support the evaluation of a reasonable range of alternatives, and to
support the required Findings and possible Statement of Overriding Considerations. The
proposed project itself is not subject to the alternatives screening criteria for the simple reason
that it is not an alternative under CEQA. The requirements for the Project Description are found
in CEQA Guidelines Section 15124, while the requirements for the Project Alternatives are
found in Section 15126.6.
The four screening criteria considered in the R-DEIR (Environmental Impacts, Project
Objectives, Feasibility, and Reasonableness) are consistent with Court guidance and CEQA
Guidelines. CEQA does not prohibit a lead agency from further defining alternative selection
criteria to be more project-specific or more understandable in terms of local conditions, or from
including additional selection criteria. As stated in CEQA Guidelines Section 15126.6(c):
Among the factors that may be used to eliminate alternatives from detailed
consideration in an EIR are: (i) failure to meet most of the basic project
objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental
impacts. [Emphasis added]
The phrasing of this passage reflects the intent of CEQA to allow lead agencies broad discretion
in selecting or rejecting alternatives for analysis in the EIR, as long as the focus of alternatives
selection is on those alternatives that could avoid or otherwise mitigate significant environmental
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 140
effects. Similarly, the consideration, weighting, and tradeoffs among the individual elements of a
selection criterion (e.g., the project objectives) are within the City’s discretion, as long as its
conclusions are reasonable and its reasoning is clearly explained in the environmental document.
The focus of the CEQA alternatives analysis is on identifying and analyzing alternatives that
could avoid, reduce, or offset potentially significant environmental impact (Criterion #1) while
still achieving most of the objectives of the project (Criterion #2). For the 24th Street
Improvement Project, the potentially significant unmitigable impacts that could be addressed via
an alternative are parcel acquisitions, relocations, and impacts on a historic district. Thus, valid
alternatives would generally be those that achieved substantial relief from projected future traffic
congestion and required fewer parcel acquisitions in a historic district than would be required for
the project.
Criterion #3 (Feasibility) and Criterion #4 (Reasonableness) serve to narrow the field of potential
alternatives, beyond those that could achieve the project objectives and avoid or reduce
potentially significant environmental impacts, to those that the lead agency could reasonably be
expected to implement. The commenters’ concern about feasibility and reasonableness is that
they not be used to unreasonably disqualify otherwise acceptable potential alternatives that could
accomplish the project’s purpose. The R-DEIR provides detailed descriptions of the social,
economic, and technical feasibility elements of Criterion #3 – Feasibility – and a robust
description of Criterion #4 – Reasonableness – to aid in the evaluation of those factors. Some
elements of these criteria are intended to address the City’s financial obligations and its
responsibility for maintaining public safety.
2.3.2 Alternatives Suggested by Commenters
Commenters on the R-DEIR suggested several alternatives. These included:
Hybrid alternatives that combined two or more previously identified alternatives;
Road Diet, which consists of reducing the capacity of the roadway;
Intelligent Transportation Systems (ITS) or Adaptive Signal Control Technology (ASCT);
Transportation Demand Management alternatives, which focus on strategies that increase
over- all system efficiency by encouraging a shift from single-occupant vehicle (SOV)
trips to non-SOV modes, or shifting auto trips out of peak periods;
Offsite alternatives; and
One-way streets.
The City has evaluated a range of project alternatives throughout the environmental review
process, including those alternatives identified in several studies prior to and during preparation
of the original DEIR/EA in 2012. Master Response to Comment No. 1 in Chapter 2 of the FEIR
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 141
Volume 2 addressed some offsite alternatives that were suggested during public review and
explained why none of these alternatives would be an appropriate alternative to the proposed
project. Pursuant to the CEQA Guidelines (§15126.6), an EIR need not consider every
conceivable alternative, but must consider a reasonable range of alternatives that will foster
informed decision-making and public participation.
The fundamental purpose of considering alternatives to the project as proposed, according to the
CEQA Guidelines, is to identify opportunities for avoiding, reducing, eliminating, or offsetting
potentially significant environmental impacts of the proposed project. The alternatives to be
considered in the EIR should focus on that purpose. The significant, unavoidable impacts of the
proposed project are the acquisition of a substantial number of properties in Segment 3 and the
associated relocation and historic resources impacts. Thus, potential alternatives that would
primarily affect Segments 1, 2, or 4 would not contribute to a reasonable range of feasible
alternatives nor foster informed discussion of the project’s major environmental effects.
Some of the alternatives identified by commenters are described very briefly or generally. The
descriptions of these alternatives do not provide enough details for the City to determine whether
the potential alternative would (a) be capable of achieving a substantial reduction in traffic
congestion on 24th Street; (b) substantially reduce one or more potentially significant impacts of
the proposed project; or (c) be sufficiently distinct from other alternatives as to contribute to a
reasonable range of alternatives. In accordance with CEQA Guidelines Section 15088, the level
of detail in the lead agency’s response should correspond to the level of detail in the comment: a
general comment requires only a general response.
Hybrid Alternatives
Hybrid alternatives are alternatives that combine two or more other alternatives that, as stand-
alone alternatives, would be incapable of achieving the project’s basic objective. Some
commenters identified hybrid alternatives, but did not describe them in sufficient detail to allow
for meaningful analysis. Hybrid alternatives were described as:
Combine multiple traffic operations strategies, or
Traffic operations strategies in combination with capacity improvements
There is potentially an endless supply of such alternatives, and it would not be possible to
address them all even if they were adequately described, which they are not. Examples offered of
hybrid alternatives in the second category included adaptive signal control or road diet without
defining specifically what these strategies were, or how and to what degree they would improve
traffic congestion. In any event, CEQA does not require the lead agency to analyze every
conceivable alternative (CEQA Guidelines Section 15126.6).
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 142
Some of the alternatives suggested in the comments do not meet the primary objective of the
project to substantially reduce existing and future traffic congestion along the 24th Street
corridor. For example, the hybrid alternatives that include as one of their elements the Hageman
Flyover cannot substantially reduce existing or future traffic congestion on 24th Street because
the reductions in 24th Street traffic that would result from implementing the Hageman Flyover
were already assumed in the traffic study for the proposed project. In other words, the
projections of future traffic conditions provided in the 2012 DEIR/EA already took this reduction
into account and, even with construction of the Hageman Flyover, there would be substantial
future traffic congestion along 24th Street if the project is not implemented (see Master Response
No. 18 – Alternatives [Hageman Flyover Alternative]).
Hybrid alternatives that include as one of their elements traffic signal synchronization fail to
acknowledge that the proposed project, as described in the 2013 FEIR /2015 DEIR, includes
traffic signal synchronization. Traffic signal synchronization cannot contribute further to
reducing existing or future traffic congestion because the traffic model assumes that the signal
timing has already been optimized. Future traffic flows along the 24th Street corridor were
modeled as if the signals were synchronized to maximize the throughput of vehicles, and the
model still projected substantial traffic congestion.
The remaining hybrid alternatives suggested by commenters would either not meet the project’s
objectives or would be infeasible due to the short-comings in one or both of their elements:
Hybrid alternatives that included the Restriping Alternative would be eliminated for the
same reasons for which that alternative was rejected,
Hybrid alternatives that included Adaptive Signal Control Technology (see below) would
not meet the project’s basic objectives due to the upper limit on traffic congestion relief
available with that technology;
Hybrid alternatives that included a Road Diet would be eliminated for the same reasons
for which a Road Diet alternative was determined to be unacceptable (see below); and
Hybrid alternatives that included a shift to one-way streets would be unacceptable due to
the upper limit on traffic congestion relief available with that technology.
Road Diet
A “Road Diet” consists of “removing travel lanes from a roadway and utilizing the space for
other uses and travel modes” (Federal Highway Administration, 2014. Informational Guide.
Safety Program. November). The benefits of a road diet are improved safety and increased
capacity of alternative travel modes (e.g., bicycles, public transit, and pedestrians). The negative
effects of road diets, however, include reduced capacity and an increase in through-vehicle delay.
Thus, a road diet is not an appropriate alternative to the proposed project because it would fail to
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24th Street Improvement Project FEIR/EA Volume 3 143
achieve the primary objective of the project, and would actually increase future traffic congestion
on 24th Street.
Adaptive Signal Control Technology
Some commenters suggested the installation of ASCT. This technology is estimated to be
capable of achieving a 10 percent reduction in traffic congestion in systems that are already well-
managed (Federal Highway Administration, January 2016). At present, only about 1 percent of
traffic signals in the United States use ASCT (Federal Highway Administration, January 2016),
and research on ASCT is ongoing. Additionally, ASCT would not be feasible as an alternative to
the project because, to achieve its estimated effectiveness, it must be implemented on a
systemwide basis rather than just on a specific roadway section. For example, the adaptive signal
control system being installed in the Meadowlands in northern New Jersey will include an
areawide grid of 144 traffic signals to serve more than 3 million vehicles per day (New Jersey
Sports and Exposition Authority, 2016). Implementing ASCT just on the 24th Street corridor
would not achieve the primary objective of the proposed project. Citywide implementation of
ASCT would be a long-term planning and engineering effort far broader in scope than the
current 24th Street Improvement Project. The ultimate result – an estimated 10 percent reduction
in traffic volumes – would still not achieve the primary objective of the proposed project.
Intelligent Transportation Systems
One commenter suggested ITS as an alternative to the proposed project, citing its use in the
United Kingdom and quoting from the Kern County Regional Transportation Plan, but offering
no specific implementation strategies for the 24th Street corridor. ITS integrates sensors (e.g.,
induction loops, video cameras, Bluetooth signals, audio input), wireless communications,
computers, vehicle identification technology, global positioning systems, and various types of
data to increase the efficiency of transporation systems. ITS includes ASCT (addressed
separately above), car navigation, variable message signs, parking and weather information,
automatic emergency vehicle notification systems, automatic road enforcement, variable speed
limits, and collision avoidance systems.
These systems and measures are generally not feasible as stand-alone alternatives to the proposed
project, but are rather a broad spectrum of high-technology transportation enhancements to a
larger road project, some of which (e.g., variable speed limits) are still experimental. As with
ASCT, these systems are typically implemented as an extensive network rather than on a single
road because doing so improves their effectiveness and better justifies their cost. The commenter
does not explain how a combination of variable message signs, variable speed limits, collision
avoidance systems, pre-trip or in-auto information (e.g., weather, road conditions, parking) and
other such measures could substantially reduce traffic congestion on 24th Street.
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24th Street Improvement Project FEIR/EA Volume 3 144
Transportation Demand Management (Signage)
Commenters also recommend the use of directional signs to divert traffic from 24th Street to
other east-west routes. However, the commenters fail to show that signage, alone or in
combination with other measures, would constitute a feasible alternative to the proposed project.
Drivers on 24th Street include local residents, commuters, local services and deliveries, out-of-
town visitors, and inter-regional travelers passing through Bakersfield on business and pleasure
trips. A reasonable person would conclude that having different reasons for driving, different
origins and destinations, and different levels of familiarity with the local road network would
affect drivers’ responses to the posting of new directional signs. The commenters do not identify
which types of drivers would be the target audience, what percentage of that group would be
sufficiently influenced by directional signs so as to alter their intended route, or what the
environmental impacts would be of diverting 24th Street traffic to other east-west travel routes.
In the absence of supporting information from the commenter on this potential alternative, the
City can make some reasonable observations about this concept. For motorists approaching 24th
Street from the northwest or southwest, signs on SR- 99 already direct motorists to SR-204,
California Street, or SR-58 rather than to 24th Street, so additional signs would do little to divert
more of this eastbound traffic. For westbound regional traffic on SR-178 connecting through
Bakersfield to westbound SR-58 or southbound SR-99, an existing off-ramp leads directly from
SR-178 onto 24th Street, so signage alone is unlikely to divert many motorists to a less direct
route. For motorists exiting downtown Bakersfield to the west, 24th Street (north), Truxton
Avenue (central), and California Avenue (south) are the east-west routes available to drivers,
depending upon their location and destination; however, Truxton Avenue does not provide
access to SR-99. Thus, 24th Street is the most convenient route west from the northern and
central portions of downtown Bakersfield. The City thus concludes that directional signage
would have only a minor effect on traffic volumes on 24th Street, and would not substantially
achieve the project’s basic objective.
Offsite Alternatives
Suggested offsite alternatives – those that go to the north or south of the 24th Street corridor and
do not affect 24th Street between SR-99 and M Street – would be ineffective and would ignore
decades of regional transportation planning and improvements intended to accommodate growth
in the Bakersfield metropolitan area. Planned improvements to the north of 24th Street on
SR-204, along with construction of the Hageman Flyover, assure adequate east-west traffic
capacity to the north of downtown Bakersfield, and adequate access to the downtown from the
northwest. Centennial Corridor and Westside Parkway, along with other existing travel routes,
assure adequate east-west traffic capacity to the south of downtown Bakersfield and access to the
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24th Street Improvement Project FEIR/EA Volume 3 145
downtown from the southwest. The only remaining missing link in the regional road network
surrounding downtown Bakersfield is improving the east-west traffic capacity through the
central portion of downtown Bakersfield and access to the downtown area directly from the west.
A failure to increase east-west traffic capacity through central Bakersfield and access into the
downtown area from the west would leave substantial unresolved traffic congestion. It also
would undermine long-term regional transportation and land use planning programs and the
designs of other complementary major transportation improvement projects that have anticipated
an increase in traffic capacity along the 24th Street corridor.
One-Way Streets
Some commenters have suggested that the alteration of two-way north-south streets in the
24th Street/23rd Street couplet area could substantially improve traffic flows along 24th Street.
This alternative would consist of altering F Street and L Street to one-way operation southbound
and H Street and M Street to one-way operation northbound. This proposal was presented to the
City in 2014 and, after the Fire Department stated that it would require rerouting of their vehicles
and affect their emergency response times (Bakersfield Fire Department Memo of January 31,
2014), the City decided not to consider it further. The City’s traffic engineers estimate that this
alternative would provide, at best, perhaps a 10 percent improvement in traffic capacity28
compared with a 33 percent increase for the proposed project (see traffic study for the proposed
project in the 2013 FEIR/2015 DEIR).
2.3.3 Hageman Flyover Alternative
Many commenters commented on the Hageman Flyover Project, one of the transportation
projects to be constructed as part of the Thomas Roads Improvement Program (TRIP).
Comments included the following issues:
Whether construction of the Hageman Flyover would avoid the need to widen 24th Street.
Whether the Hageman Flyover would add 3 miles to the average trip for motorists now
driving south on Highway 99 to 24th Street to access the downtown, or whether it would
shorten their trip and relieve traffic congestion at Highway 99 and 24th Street.
The source of the estimated 13 percent reduction in traffic on 24th Street from construction of
the Hageman Flyover (to provide documentation).
Why the 1986 Bakersfield Systems Study estimate that the Hageman Flyover would reduce
traffic on 24th Street by 14,000 vehicles differs from the 13 percent estimate.
28 According to the federal Department of Transportation’s Quality is Service Handbook, a 20% increase in capacity
is possible (tables at end of 2013 edition). If north-south traffic now gets 35% of signal green time (a reasonable
assumption), a 20% improvement would lower this to 28% of green time. East-west traffic would then get 72%
instead of 66% of green time. 72% / 66% is about 9%.
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Whether the City should build the Hageman Flyover first and then see if the 24th Street
improvements are still needed.
The timing of the Hageman Flyover construction.
The extension of Hageman Road to Golden State Avenue is a key element of the overall
transportation improvement program for Metropolitan Bakersfield. The Hageman Flyover
project is included in the adopted Kern Council of Governments (COG) Regional Transportation
Plan (RTP)/Sustainable Community Strategy (SCS) (Kern Council of Governments, 2014). Both
the Hageman Flyover project and the 24th Street Improvement Project are needed to address east-
west transportation needs, as well as other TRIP projects that will connect SR-58 east of SR-99
with Westside Parkway. Both the Hageman Flyover and 24th Street improvements are listed as
“regionally significant” and illustrated as “near-term highway projects” in the RTP.
The Hageman Road Extension to Golden State Avenue Traffic Report (Parsons, 2009) predicted
that construction of the Hageman Flyover would reduce traffic volumes along Olive Drive,
Rosedale Highway, 24th Street, Mohawk Street, Coffee Road, and Calloway Drive. Daily traffic
volumes along 24th Street in Year 2035 for the Build Hageman Road Extension Alternative are
forecast to be 13,000 vehicles per day lower compared to the No Build Alternative. Stated in
another way, the traffic volumes along 24th Street would be 13,086 vehicles per day higher per
day in 2035 if the Hageman Road extension was not constructed. The forecast model predicted a
daily volume of 102,058 on 24th Street to the west of F Street under the no-build scenario:
13,086/102,058 = 12.8 percent. Both the Build Hageman Road Extension Alternative and the No
Build Hageman Road Extension Alternative assume that 24th Street would be widened to six
lanes between Oak Street and the one-way couplet in downtown Bakersfield.
This volume of diverted traffic (13,086 vehicles per day) is reasonably consistent with the results
of the Route 178 Corridor Study that was published in 1986. That study considered a “Northern
Alignment Alternative” for a freeway that would run along, above, or adjacent to Golden State
Avenue from SR-178 to SR-99, continuing north to Seventh Standard Road, and then running
west to Interstate 5 (I-5) as a freeway. This study found that a Northern Alignment Alternative
(new freeway) would divert approximately 15,000 vehicles per day from the 23rd/24th Street
corridor by year 2010.
The Hageman Road extension would allow residents living along Hageman Road who desire to
travel to downtown Bakersfield to avoid the need to travel north to Olive Drive, or south to
Rosedale Highway, to cross SR-99. For motorists now traveling south on SR-99, the Hageman
Road extension would not alter their likely route to downtown, as they can currently exit SR-99
to Golden State Avenue. For motorists now traveling westbound on SR-178 (east of downtown),
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these travelers would continue to use 23rd/24th Streets to reach Rosedale Highway as the most
direct route, rather than traveling 3 miles out of direction to drive north along Golden State
Avenue to Airport Drive, and then south along Airport Drive and SR-99 to reach Rosedale
Highway.
Both the Hageman Road Extension and the 24th Street widening projects are needed. The need
for 24th Street capacity improvements was identified in 1986. The Hageman Road extension
project was identified in 2002 as part of the Bakersfield Systems Study.
As for the question about when the Hageman Flyover Project would be constructed, the funding
source for this project is yet to be determined. The project’s environmental document has been
completed and the project is anticipated to be at 65% design in spring 2016.
2.3.4 Restriping Alternative
Design
Section 1.2.6.5 of the R-DEIR provides a detailed description of a citizen-generated proposal to
restripe 24th Street to provide six lanes in lieu of construction or right-of-way acquisition. The
R-DEIR explains City design standards, the citizen restriping proposal, construction
requirements to accommodate the restriping proposal, right-of-way required to implement the
citizen restriping proposal, research regarding the safety of narrower lanes and lack of shoulder
areas for high-volume roadways, and engineering assessments of the feasibility of the restriping
proposal. Comments on the R-DEIR allege that additional information is needed, over and above
that provided in the R-DEIR. Supplementary information is therefore provided in this master
response in the interest of providing a comprehensive description of this alternative.
The Metropolitan Bakersfield General Plan Circulation Element adopted on December 3, 2002,
and most recently updated on April 16, 2014, identifies circulation needs, depicts the proposed
circulation system, and sets forth standards and criteria for the design, operation, and levels of
service of circulation facilities.
The Circulation Element addresses freeways, arterials, and collector roadways. 24th Street
(SR-178), from SR-99 to M Street is identified in the Circulation Element as having an annual
average daily traffic (AADT) traffic volume of 41,500 as of 1999-2000. The plan also indicates
that streets having volumes above 30,000 vehicles per day are considered to be “heavy volume”
facilities. The plan specifically indicates that traffic volumes are approaching capacity (as of
Year 2000) on 24th Street (SR-178) from Highway 99 to M Street.
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The intersection of Oak Street with 24th Street (SR-178) is identified in the Circulation Element
as one of the busiest intersections in the metropolitan area and a bottleneck, as of Year 2000.
Relieving traffic congestion on 24th Street (SR-178) is specifically identified as an objective of
the Circulation Element.
24th Street (SR-178) from SR-99 to M Street is identified on the Circulation Element map as an
“arterial” roadway, adopted on December 3, 2002, and all subsequent updates. The Circulation
Element states that, “the plan calls for widening of existing substandard arterials to the full
110 feet where possible with six travel lanes…” (Page III-6, Chapter III – Circulation Element –
Streets). Within that 110-foot right-of-way for arterial streets, the pavement width is specified as
96 feet for an arterial with bike lanes and 90 feet for an arterial without bike lanes.
The Circulation Element indicates that programs will be carried out by the City and Kern County
to implement the goals and policies of the Circulation Element affecting streets. Program 2 states:
“Revise city and county street standards as necessary to conform with standards set forth under
the Circulation Element. Endorse, adopt, or incorporate as appropriate standards from special
studies…” Program 3 states: “Evaluate need for additional right-of-way at certain locations at
time of establishment of plan lines and/or street design through an engineering study.”
The City of Bakersfield Subdivision and Engineering Design Policy Manual, approved on
October 26, 1989, specifies “Standard Street Sections” for a major arterial on Sheet S-26, page
ST-10 (page 114 of 224). Within the 110-foot right-of-way, the outside travel lane shall be
15 feet wide, the middle travel lane 11 feet wide, and the inside travel lane 12 feet wide adjacent
to the 14-foot-wide median. This identical Standard Street Section is included in the Proposed
Subdivision & Engineering Design Manual in Division Five Streets dated May 17, 2013.
The Proposed Subdivision & Engineering Design Manual states as its purpose and scope, “This
division (Division Five Standards for Streets) establishes the minimum acceptable standards of
design, materials, and methods to be used in the construction of streets in the City right-of-way.
All transportation facilities in the City of Bakersfield are to be planned, designed, operated, and
maintained to provide safe mobility for all users, including bicyclists, pedestrians, transit riders,
and motorists appropriate to the function and context of the facility.”
Caltrans has its own Highway Design Manual (HDM). The foreword of the HDM states that the
purpose of the manual is to establish uniform policies and procedures to carry out the State
highway design functions of Caltrans. The Caltrans HDM states in Chapter 300, Index 301.1, the
minimum lane width on multilane highways shall be 12 feet, except for cases in which the posted
speed limit is less than or equal to 40 miles per hour (mph) and annual average daily truck traffic
(AADTT) is less than 250 vehicles per lane where such facilities are located in urban, city, or
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town centers. In those cases, the minimum lane width shall be 11 feet. The posted speed on 24th
Street is 35 mph, but the estimated truck traffic (RBF, 2011) is greater than 250 vehicles per
lane, so the standard requires 12-foot-wide lanes.
Index 302.1 indicates that shoulder widths on state facilities in urban areas shall be 8 feet.
Section 305.1 addresses median width standards. The HDM states that for conventional
highways, the appropriate minimum median width in urban areas should be 12 feet for medians
without left-turn bays and 14 feet for medians that are intended to accommodate left-turn lanes.
Both City of Bakersfield and Caltrans design standards are relevant to the dimensioning of travel
lanes along the 24th Street corridor because the roadway is included in the Surface
Transportation Assistance Act of 1982 (STAA) Network as a “Terminal Access” route for use by
interstate trucking.
The 24th Street corridor is part of the National Highway System (NHS) and, as such, must be
designed to meet federal standards for the NHS. Federal requirements identified in 23 Code of
Federal Regulations (CFR) Part 109 (Standards) require the highway to be designed in
accordance with criteria “best suited” to accomplish NHS objectives. This language makes clear
the federal intent that the NHS provide superior, rather than substandard, roads. An alternative
design that included multiple design exceptions could not be characterized as “best-suited” to
achieve NHS objectives.
With regard to the safety of highways developed using federal funds, Federal Highway
Administration (FHWA) policy applies (23 CFR 626.2c): “An important goal of the FHWA is to
provide the highest practical and feasible level of safety … and to reduce highway hazards …”
An alternative based on substandard lane widths, a substandard median, and substandard
sidewalk widths does not provide “the highest practical and feasible level of safety.”
Commenters question the need for the 24th Street Improvement Project to meet State of
California and FHWA standards to receive federal funding. Design exceptions are allowed, but
each design exception must go through a formal review and approval by both Caltrans and
FHWA. This alternative is speculative because approvals of all necessary design exceptions for
its implementation at both the State and federal levels are not assured.
Citizen-Generated Alternative
The City of Bakersfield Public Works Director made the following observations in an
Administrative Report to the Mayor and City Council dated February 12, 2014. Under the topic
of traffic, the report notes:
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“The proposed (24th Street Widening) project, as designed, includes additional travel
lanes, paved shoulders, raised median islands, and removal of nearly all left-turn
movements, (and) it is anticipated that the safety of the roadway would be greatly
enhanced with the project.
“A comment was made regarding the feasibility of removing the left-turn lanes from the
center of 24th Street and restriping the existing roadway to 6 lanes between Oak and
C Streets.
“The existing roadway, from curb to curb, is 71 feet wide. Using 12-foot-wide lanes,
6-foot-wide shoulders, and a 2-foot-wide striped median requires a width of 86 feet, so
the roadway as designed, with even a minimum striped median, cannot fit into the current
width. Subtracting 1 foot for a double yellow-striped separation between the eastbound
and westbound traffic and then dividing the remaining 70 feet by six lanes would result in
six lanes of (averaging) 11.67 feet; this cross section does not meet local, state, or federal
standards. Since the project would use federal funds, Caltrans and/or FHWA would not
approve it in this configuration.”
In response to this Administrative Report, citizens proposed restriping the roadway between
Elm Street and B Street to six lanes by providing 13-foot-wide outside lanes, 11-foot-wide inside
lanes, and a 2-foot-wide striped median to separate opposing lanes of traffic.
To fulfill the intent of this alternative definition, the entire roadway would need to be resurfaced,
and drainage would need to be re-engineered by lowering the crown of the roadway and
removing the dips at the cross street curb returns. Resurfacing the roadway would trigger the
need for compliance with Department of Justice/Department of Transportation Joint Technical
Assistance on The Title II of the Americans with Disabilities Act (ADA) Requirements to
Provide Curb Ramps when Streets, Roads, or Highways are Altered through Resurfacing (Joint
Technical Assistance), published on July 8, 2013. All curb returns at connecting streets and
alleys would be affected, requiring right-of-way from the adjacent properties. Corner radii at the
alleys would be affected the most, to comply with the ADA requirements and to provide
sufficient sight distance to allow vehicles to safely exit as well as enter the alleys. City of
Bakersfield Design Standard 5.4.1.3 states that, “Curb return radii shall be 30 feet at intersections
which include major streets or industrial streets.” Standard 5.4.1.4 states, “Where the angle of
intersection is acute, or where a sight distance problem may be anticipated, an increased property
line radius may be required by the City Engineer.”
Figure C-1 illustrates the right-of-way deemed to be required to implement the citizen-proposed
restriping alternative.
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Alley and Driveway Access
Access from the alleys and access to/from driveways fronting 24th Street are of
particular concern, and the primary reason why additional right-of-way would be
required to implement proposed lane restriping. The driver’s line of vision lies
approximately 5 feet behind the front of the vehicle for all but the shortest vehicles or
cab-forward vehicles such as garbage trucks. Without new right-of-way, the front end
of vehicles exiting the alleys would stick out into the curb lane of 24th Street because
the distance between the right-of-way line (upon which privacy walls have typically
been constructed) and the curb face is only 5 feet. Therefore, the front end of a
vehicle exiting the alley could be sideswiped by passing vehicles, particularly wider
vehicles such as 102-inch-wide trucks and buses. Furthermore, vehicles occupying
the curb lane on 24th Street, fearing collision with vehicles exiting alleys, could
abruptly change lanes into the center lane, thereby increasing the risk of a crash.
As noted in the R-DEIR, driveways into the garages of houses located on the north
side of 24th Street would need to be closed because the distance between the face of
curb and the garage door is insufficient to provide safe storage for all but the shortest
of four-wheeled vehicles. This is a concern now, but it is less of a problem due to the
relatively wider curb lane dimension of approximately 16 to 17 feet. Most of the
driveways on 24th Street within Segment 3 lead directly to residential garages. In the
few instances where there is enough space to move the driveway access to a side
street or alley, the driveway would need to attach to and align with the existing garage
locations, either directly or with enough capacity for vehicles to turn into the garage.
Only 2 of the 12 required parcels may have the space required for this reconstructed
configuration, depending on the approval of the property owner. Replacing driveways
with side street parking would eliminate access to the garages of each of these homes.
Removing access to these garages would justify a full parcel acquisition because the
loss of off-street parking would lower the property value and the lack of access would
be inconsistent with City requirements for offstreet parking.
Restriping 24th Street to six lanes results in a through lane at the edge of the curb,
with no shoulder. This arrangement forces vehicles backing out of a driveway onto
24th Street to reverse into oncoming traffic, increasing the risk of vehicular accidents
on 24th Street. To alleviate this undesirable condition, the driveways should be
designed to allow vehicles to turn around so that they can depart in a forward
direction. The National Cooperative Highway Research Program (NCHRP) Report
659 Guide for the Geometric Design of Driveways (2010) includes driveway size
requirements to allow a full turn-around where necessary for safety reasons.
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Assuming passenger cars only, a T- or Y-shaped turn-around requires an area of 60
by 20 feet, and a circular turnaround requires a radius to face of outer curb of 30 feet.
The driveways along 24th Street exist alongside residential homes, which limit the
area in which the driveways can be expanded to meet these turn-around requirements.
Driveways that cannot meet these requirements would need to be removed, so the
properties themselves would need to be acquired due to the loss of access. Even
where parcels are large enough to allow a driveway with a full turn-around,
acquisition of the parcel is advisable because there is no way to require the residents
to always depart in a forward direction.
Center Median
The R-DEIR notes that the absence of a center median would also be a safety
concern. To reiterate text from the R-DEIR, “No space would be available for left-
turn movements, the striped (2-foot-wide) median would not provide sufficient width
for vehicles to move out of the travel lanes to make left-turn movements, and the
striped median would not prevent left-turn movements onto or from 24th Street.” In
other words, vehicles could, and likely would, turn left from the eastbound inside
through travel lane to the north side tree-named streets even though a double solid
yellow line pavement marking was deployed to prohibit such movements. Likewise,
vehicles exiting the north side tree-named streets onto 24th Street could physically
cross three westbound lanes to turn left onto eastbound 24th Street, in the face of a
“No Left Turn” sign.
Summary
The Administrative Report reflects the engineering knowledge, experience, and
judgment of the City of Bakersfield Public Works Director. The design of the
Restriping Alternative reflects the engineering knowledge, experience, and judgment
of the professional engineers who developed the proposed project. The City and
Caltrans, and their design engineers, must ultimately accept responsibility for the
design of the roadway facilities within the public right-of-way. In the collective
professional judgment of these engineers and the City’s Public Works Director,
restriping 24th Street to provide six lanes within the current right-of-way is not an
acceptable long-term solution due to the combination of safety and design concerns
described in the R-DEIR and in these responses to comments. The need to acquire
right-of-way along most of the north side frontage to implement the restriping
proposal indicates that little is realistically saved by implementing the restriping
proposal compared with the proposed project.
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24th Street Improvement Project FEIR/EA Volume 3 154
2.4 Master Response No. 19 – Project Costs
A number of commenters questioned the anticipated costs of the project, its
components, funding sources, future City debt, and the development of cost
estimates.
2.4.1 Cost Considerations and Estimates
With regard to costs, the cost-estimating process and assumptions were the same for
all of the alternatives. Acquisition of parcels along the 24th Street corridor is a major
cost item for all alternatives. Pavement, curb, and striping for any of the alternatives
would cost about the same amount.
The project costs presented in the R-DEIR are the current estimates prepared by the
design consultant and approved by the City Public Works Department. The cost
estimate of $46 million pertains to the capital outlay cost for construction and right-
of-way acquisition. The cost estimate of $65 million includes the capital outlay cost
plus the capital outlay support costs for environmental, design, and construction
management activities. These estimates include the costs to construct the cul-de-sac
treatments along the south side of 24th Street between Oak and B streets
(approximately $200,000).
2.4.2 Funding Sources
The costs for other TRIP projects have been estimated, and the City’s estimated
future funding available from the cited sources has been allocated to them. The City
has a 5-year Capital Improvement Program (CIP) in which these projects are
programmed. Funding sources are identified in the CIP and are approved by the City
Council annually.
2.4.3 Cost Feasibility
Some commenters questioned the evaluations of the economic feasibility of the
potential alternatives addressed in Section 1.3.6.1 of the R-DEIR. The text of the R-
DEIR explains that the City has allocated available sources of transportation funding
to multiple improvement projects, and that additional costs would be outside of the
City’s budget and would add to its long-term debt burden. While modest increases in
project costs beyond what the City has allocated for the 24th Street Improvement
Project might not strictly be infeasible, they could be considered imprudent. Project
cost is a factor that the City Council would weigh carefully and that would strongly
influence its decisions.
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Economic feasibility, however, is only one of four factors determining the feasibility
of an alternative, the other three being environmental, social, and technical feasibility.
Only Alternative C (Kern River Crossing) and Alternative J (Hageman Flyover) were
determined to be infeasible, overall, due to economic considerations.
Alternative C – Kern River Crossing, was found to not achieve the project’s
objectives and to be unreasonable, so it would have been eliminated even if it
were determined to be economically feasible; and
Alternative J – Hageman Flyover, was also found to not achieve the project’s
objectives and to be unreasonable, so it would have been eliminated even if it
were determined to be economically feasible.
In short, project cost considerations did not, by themselves, lead to any of the
potential alternatives being eliminated from consideration.
2.5 Master Response No. 20 – Cul-de-Sacs
A number of commenters questioned the evaluation, environmental impacts of,
appearance of, or traffic or safety issues associated with the cul-de-sacs.
2.5.1 Impact Evaluation
Several commenters questioned the process by which the environmental impacts of
the six new cul-de-sacs were assessed, such as if new technical studies were
undertaken. No new studies were required for the evaluation of the cul-de-sacs, nor
was there a need for new information to be gathered because the cul-de-sacs were
analyzed using the original baseline information from the 2012 DEIR/EA that was
used to evaluate the other elements of the project. The evaluation of the cul-de-sacs,
like the original environmental impact analysis, consisted of employing information
on the baseline environmental conditions, the results of the technical studies (i.e.,
traffic, cultural resources, visual/aesthetics), and professional judgment to identify the
potential environmental impacts of the cul-de-sacs in the context of the other
elements of the project.
The cul-de-sacs were added into the environmental analyses via R-DEIR Appendix A
– Errata Sheet to the 2013 FEIR/2015 DEIR, which describes the changes to that
document required to incorporate the cul-de-sacs. The new cul-de-sacs are discussed
in about the same level of detail as other minor elements of the project. Overall, the
presence of six additional cul-de-sacs on the south side of 24th Street did not
substantially change the conclusions in the 2013 FEIR /2015 DEIR about the
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environmental impacts of the project. Statements about the cul-de-sacs in the Errata
Sheet are consistent with statements in other chapters of the R-DEIR.
2.5.2 Visual Resources and Aesthetics
Some commenters were concerned about the appearance of the cul-de-sacs or
whether the City would install and maintain appropriate landscaping and other
decorative treatments. The aesthetic quality of the cul-de-sacs is addressed in Section
2.1.5 of the R-DEIR, Appendix A. The existing temporary barriers separating 24th
Street from streets designated for new cul-de-sacs will be removed when the
environmental review process for the proposed project has been completed and its
status is resolved. The landscaped planters, sidewalks, and other features to be
constructed along the south side of 24th Street are part of the project and will be
addressed by the City following approval of the project. The proposed project would
substantially alter visual conditions on 24th Street between Elm Street and B Street.
Adding six cul-de-sacs would not substantially change the degree of visual impact of
the proposed project.
2.5.3 Safety
Several commenters were concerned about the effects of the cul-de-sacs on traffic
safety, including egress from 24th Street, access for emergency services, and cut-
through traffic using the alley in lieu of the (now cul-de-saced) street.
Residents living south of 24th Street between Oak Street and the downtown one-way
couplet of 23rd and 24th Streets have petitioned the City requesting the closure of
access to 24th Street. These residents have long been concerned about motorists
“cutting through” their neighborhood to avoid congestion ahead along 24th Street. In
response to these petitions, the City has installed temporary barriers on the southern
leg of north-south streets intersecting with 24th Street. These temporary barriers,
along with curbs, gutters, and sidewalks that have been installed, effectively create
cul-de-sacs at the junctions of the north-south “tree”-named streets with 24th Street.
The 24th Street Improvement Project would replace these temporary barriers with
permanent curb and gutter, sidewalks, and landscaping along 24th Street.
Residents and visitors to tree-named street residences may park along the curb
fronting the properties. These residents and visitors typically access these properties
using 21st Street, 19th Street, and Truxtun Avenue. Ambulance, fire, police, and other
emergency vehicles use these same roads to access the tree-named streets. Prior to
installing the temporary barriers, each of the emergency service providers was
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consulted regarding the safety of the temporary barriers, and the replacement of the
temporary barriers with permanent cul-de-sacs. The emergency service providers all
consented to the installation of the temporary barriers and the replacement of these
temporary barriers with permanent cul-de-sac installations.
Since installation of the temporary barriers, City staff have received numerous
informal telephone calls, personal contacts, letters, and testimony before the City
Council by residents of the tree-named streets indicating their support for the project
and feeling of enhanced safety conditions resulting from the elimination of traffic
cutting through their neighborhood via side streets.
2.5.4 Alleys
Access to the north-south alleys has been retained with the installation of the
temporary barriers, and will be retained with construction of the proposed 24th Street
Improvement Project. The alleys are used by residents to access their garages, which
are located behind the houses lining the tree-named streets. Between 24th Street and
22nd Street, five to six single-family dwelling units front each side of the tree-named
streets. For the most part, the garages to these housing units are accessed from alleys
that run behind the residences. Each alley serves 10 to 12 residences. These vehicle
movements can access/egress the alleys via 22nd Street or 24th Street. In addition to
residents using the alleys, trash collection trucks also use the alleys. These uses of the
alleys would continue with installation of the permanent cul-de-sac treatments at the
intersections of the tree-named streets with 24th Street.
No traffic counts of vehicles using the alleys have been conducted. Each single-
family dwelling generates approximately 10 vehicle trips per day, based on counts
reported by the Institute of Transportation Engineers. These 10 vehicle trips include 5
outbound movements and 5 inbound movements. As many as 10 trips per hour could
be expected during any one “peak” hour. Based on these trip generation rates, roughly
100 to 120 vehicle trips per day would be expected to use the alleys if all of the trips
generated by the adjacent housing used the alleys. The number of alleyway trips is
likely to be lower, however, because visitors and service trips by plumbers, painters,
domestic helpers, etc. likely arrive and depart using the tree-named streets. This level
of alley use constitutes extremely light travel.
Prior to the “tree-named” streets being closed to traffic on 24th Street, turning
movements onto these streets from 24th Street were counted for the traffic study
(Traffic Study 2010 and Addendum 2013). These trips include residents, visitors and
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service providers, and drivers cutting through the neighborhood to circumvent traffic
congestion on 24th Street. After accounting for the trips generated by the residents
(see above), the “other” use of the side streets provides an estimate of “worst-case”
cut-through traffic. The number of “cut-through” trips is likely to be lower, however,
because a single-lane alley is not as convenient as a two-way side street. This level of
alley use, combined with the estimated trips generated by local residents, would still
be considered light. But if it is discovered that the alleys are used inappropriately by
cut-through traffic, the inappropriate use or additional traffic can be controlled by
traffic calming measures and speed limit enforcement.
In the past year, with access to the tree-named streets south of 24th Street closed, the
City has received no inquiries from residents concerning unexpected higher levels of
use of the alleys, indicative of nonresidents possibly cutting through the
neighborhood via the alleys.1 This information provides another indication that the
level of traffic in the alleys with the side streets closed off from 24th Street does not
constitute a substantial safety concern.
2.6 Master Response No. 21 – Cultural Resources
Comments were received about the impacts of cul-de-sacs on two historic districts
that were determined to be eligible for the National Register of Historic Places. This
Master Response adds to the detailed discussion contained in Section 2.1.6, Cultural
Resources, in Volume 1 of the 2013 FEIR/EA that was decertified, Section 2.1.6,
Cultural Resources in the R-DEIR, and Master Response No. 12 – Cultural Resources
found in Volume 2 of the FEIR.
Evaluations of impacts on historic resources in the context of CEQA rely heavily on
the degree to which changes to a resource or its setting would render that resource no
longer eligible for inclusion in the California Register, which includes resources
formally determined eligible for listing in the National Register. The California
Register regulations include language similar to that of the National Register not only
for eligibility, but also for defining integrity, and for all intents and purposes, are
frequently used interchangeably by historic preservation professionals.
A “substantial adverse change” is defined in CEQA as “physical demolition,
destruction, relocation, or alteration of the resource or its immediate surroundings
such that the significance of an historical resource would be materially impaired”
1 Personal communication, Ryan Starbuck, City of Bakersfield, April 29, 2016.
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(Public Resources Code Section 5020.1(q)). In addition, the significance of an
historic resource is considered materially impaired when a project: “demolishes or
materially alters in an adverse manner those physical characteristics of an historical
resource that convey its historical significance and that justify its inclusion in, or
eligibility for inclusion in the California Register of Historical Resources as
determined by a lead agency for purposes of CEQA.”
While demolition and destruction are fairly obvious significant impacts, it is more
difficult to assess when change or alteration of a historical resource crosses the
threshold of substantial adverse change. The CEQA Guidelines provide that a project
that demolishes or alters those physical characteristics of an historical resource that
convey its historical significance (i.e., its character-defining features) can be
considered to materially impair the resource’s significance.
The evaluation of integrity is comprised of seven factors. The seven aspects of
integrity are: Location, Design, Setting, Materials, Workmanship, Feeling, and
Association. The relevant aspects of integrity depend on the National
Register/California Register criteria for which properties have been determined to be
significant. For example, it is generally understood by preservation planners that a
historic district whose contributors were found to be significant under Criterion A
(“associated with broad patterns of history”) would be likely to convey its
significance primarily through integrity of location, setting, and association. A
property consisting of contributors found to be eligible solely under Criterion C
(architectural design significance) would usually rely primarily on integrity of design,
materials, and workmanship of the buildings.
As discussed in Section 2.1.6, Cultural Resources, in the 2012 DEIR/EA, the historic
district north of 24th Street was found to be significant by Caltrans under Criterion A
as an early example of a post-war tract housing development. Therefore, the historic
property, a district comprised of approximately 400 contributors, consists of houses
of similar style and construction and, despite proposed demolitions of one or more
buildings that would result from implementing the project, the historic district would
retain the overall character-defining features of a post-war tract development, with
little effect on its overall suburban character and setting. Caltrans determined that the
project would not adversely affect the historic district, which means that the project
might impact the resource in some way, but the impact is not so severe as to diminish
the qualities that make the resource (i.e., the historic district) significant. The
California State Historic Preservation Officer (SHPO) concurred with the historic
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district boundary definition, eligibility determination, and effect finding (Please see
Appendix D in the 2013 FEIR/2015 DEIR). The new cul-de-sacs to be placed on the
south side of 24th Street are not visible from most of the several hundred contributor
properties comprising the historic district north of 24th Street. Therefore, the cul-de-
sacs are judged not to represent substantial alterations to the historic district, as is
discussed in Section 2.1.6, Cultural Resources in the R-DEIR.
The historic district south of 24th Street was determined to be eligible for the National
Register under Criterion C because of its collection of architecturally distinguished
residences representing different styles and periods, as discussed in Section 2.1.6,
Cultural Resources in the original 2012 DEIR/EA. Caltrans determined that the
historic district south of 24th Street would be adversely affected by direct physical
impacts associated with removing buildings, reducing landscaping, and increasing
hardscape (including potential sound walls), as well as changes in the visual character
and setting of the district. The analysis contained in Section 2.1.6, Cultural Resources
in the R-DEIR discussed the ways the proposed project – with the incorporation of six
additional cul-de-sacs – could further affect the setting of the historic district south of
24th Street. The additional impacts would not be full demolitions but rather partial
acquisitions of parcels and temporary construction easements: the total amount of
additional right-of-way required for construction of the cul-de-sacs is deemed to be
small in terms of the size of the historic district.
The total 777 additional square feet that would be required from contributor parcels
from the south of 24th Street historic district represents less than half the size of an
average house footprint in the project area. The total 1,574 additional square feet
needed for temporary construction easements is, by definition, of short-time duration,
and all temporary activities and land use impacts would cease when the project was
complete. That information is displayed for the reader in Table 2.3 in R-DEIR
Section 2.1.6, Cultural Resources, Appendix A. Most importantly, as stated in Section
2.1.6, Cultural Resources in the R-DEIR, these changes have no bearing on the
character-defining features (i.e., architectural qualities) of the contributors that give
the south of 24th Street district its National Register significance. Nor, as illustrated in
the visual simulation showing a cul-de-sac in front of a historic contributor in Figure
2-18A in Section 2.1.5, Visual/Aesthetics in the R-DEIR, does the visibility or
presence of new cul-de-sacs in themselves constitute a “material impairment” of
historic resources as defined by the CEQA Guidelines because their presence does not
impair the reasons the contributors were found to possess significance. The placement
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of cul-de-sacs does not preclude any of the contributors from continuing to express
their historic architectural significance.
To address the adverse effects to the historic district south of 24th Street that would
occur, a Memorandum of Agreement was prepared. The agreement document
contains nine specific implementable measures to help offset project impacts on
historic properties. Executed by Caltrans, the SHPO, and the City, the Memorandum
of Agreement was filed with the Advisory Council on Historic Preservation on
January 8, 2013 (see Appendix D in the 2013 FEIR/2015 DEIR).
Under CEQA, the lead agency is responsible for the identification of “potentially
feasible measures to mitigate significant adverse changes in the significance of an
historical resource.” As indicated in the original 2012 DEIR/EA, the loss of an
historical resource through demolition is generally regarded as an adverse
environmental impact that cannot be mitigated to a less-than-significant and adverse
level. However, CEQA requires that all feasible mitigation be undertaken even if it
does not mitigate below a level of significance.
The consultation process required under Section 106 of the National Historic
Preservation Act, including coordination with the SHPO and inviting the federal
Advisory Council on Historic Preservation to participate in consultation to resolve the
adverse effects, are discussed in Section 2.1.6, Cultural Resources in the 2013 FEIR
and in Master Response No. 12 in its Volume 2. Unlike their role under Section 106
with respect to federally sponsored projects, the SHPO is not required to review and
comment on projects prepared under the auspices of CEQA. Although the Office of
Historic Preservation (OHP) can, and often does, comment on documents prepared
for CEQA purposes, there is no legal requirement that they do so and, when they do,
such comments are merely advisory and do not carry the force of law. According to
Sean de Courcy, Historian in the Local Government & Environmental Compliance
Unit of the OHP, given the volume of projects in review, if staff are aware that a
project has had a Memorandum of Agreement prepared under the auspices of Section
106 of the National Historic Preservation Act, it would be rare for them to make
additional comments under CEQA, especially given that the OHP staff was consulted
and actively involved in developing the agreed-upon mitigation for impacts to historic
properties, as demonstrated in their signing the document (Personal Communication,
December 16, 2015). The OHP was subsequently provided a copy of the R-DEIR and
chose not to comment, though the notice forwarded from the State Clearinghouse in
the Office of Planning and Research indicated that historic resources would be
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impacted by the project. The SHPO had the opportunity to review the R-DEIR for
both its analysis of impacts to historical resources and its conclusions that no
additional mitigation is needed and chose to not make any comments.
All historic property evaluations, effects and impacts analysis, and mitigation
measures development related to the proposed project, including impacts analysis
related to the proposed incorporation of cul-de-sacs south of 24th Street, were
prepared by experienced personnel exceeding the Secretary of Interior’s Professional
Qualification Standards for history and architectural history in accordance with Title
36, Part 61, Appendix A of the CFR.
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3. Responses to Written Comments on the
Recirculated Draft EIR
Throughout the 45-day public review period for the R-DEIR, a total of 62 members of the
public submitted written comments related to the project. A sequential comment code has
been assigned to each letter or message (representing a continuation of coding of General
Public comments on the previously prepared 2013 FEIR/EA as provided in Chapter 7 of this
Volume 2). A copy of each written comment and the response to each question or comment
on the R-DEIR is presented in this chapter. Multiple letters submitted by the same individual
are grouped together and treated as one set of written comments. These written comment
letters or email messages are summarized on Table 3.
Table 3. Individual Comments Received on the 24th Street Improvement R-DEIR
Item
Comment
Code Format
Date of
Comment Commenter Subject of Comment(s)
1 GP-202 email 1/19/16 Anna Camp Smith Safety (crosswalk at A Street); crosswalk
with synchronized traffic signal.
2 GP-203 email 1/19/16 Austin Smith Safety (crosswalk at A Street); crosswalk
with synchronized traffic signal.
3 GP-204 email 1/19/16 Debbie Camp Safety (crosswalk at A Street); crosswalk
with synchronized traffic signal.
4 GP-205 WC 1/21/16 and
2/17/16
Anthony Ansolabehere Impact of signal coordination on traffic
flow; coordinating lights as an alternative
or to improve traffic; 1-way streets to
improve traffic flow in couplet area; four
segments, goals and piecemealing; project
costs $46M vs. $65M construction cost;
safety of completed cul-de-sacs;
alternatives considered/eliminated;
combining 24th with Oak Street projects;
CEQA implications; daily traffic vs. peak
hour traffic counts; traffic forecasts;
growth patterns; CEQA implications;
traffic congestion on 24th; projections in
FEIR; CEQA implications; financing of
project; copy of loan agreement; CEQA
implications; cost of the restriping
alternative (exclusion of cost of property
acquisitions); Hageman Flyover traffic
relief; project objectives; population
growth in Bakersfield and Kern County;
effect of gas prices on growth. Use of
outdated traffic data; traffic patterns after
opening of Westside Parkway; safety of
the use of alleys.
5 GP-206 WC 1/21/16 and
2/23/16
Robert Braley Project does not achieve goals of
improving traffic flow, safety, reduce
emissions; project does not reduce traffic
volume; No congestion or bottleneck;
Time to travel from Oak to B (not as
reported in the R-DEIR; light
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synchronization is simple solution; travel
time; study of proper synchronization;
adding 1 lane will not improve travel
times; project is not needed; project will
disrupt neighborhood, safety degradation,
delay emergency response; Hageman
provides volume relief to Rosedale Hwy
and 23rd/24th.
6 GP-207 email 1/22/16 Emery Rendes (Golden
Empire Transit District)
Correction to the number of bus turnouts
on westbound 23rd Street
7 GP-208 email 2/2/16 Scott Tobias (Comments in support of project.)
8 GP-209 email 2/2/16 Bradley Barnett (Comments in support of project.)
9 GP-210 email 2/2/16 Jeanne Radsick (Comments in support of project.)
10 GP-211 email 2/15/16 Mike Hawkesworth (Comments in support of project)
11 GP-212 email + WC 2/15/16 and
2/22/16
Wayne Kress and Leslie
Walters
(Comments in support of project)
12 GP-213 email 2/19/16 Lila Ray (Comments in support of project)
13 GP-214 WC 2/22/16 Alex Morales Safety of school crossing at 24th Street and
Alder Street; opposes crosswalk on north
side of 24th.
14 GP-215 WC 2/21/16 and
2/25/16
Judith Harniman Safety and costs
15 GP-216 email + WC 2/24/16 Tomas delToro-Diaz (Comments in support of project and
includes a Petition in support of project 1)
16 GP-217 WC 2/24/16 Jorge delToro, M.D. (Comments in support of project)
17 GP-218 email + WC 2/24/16 Scott Kuney (Comments in support of project)
18 GP-219 email 2/24/16 Josh Hawkesworth (Comments in support of project)
19 GP-220 email + WC 2/24/16 Bart Hill (Comments in support of project)
20 GP-221 WC 2/19/16 Ruiz Family Property Acquisition for cul-de-sac on B
Street; plans and street drawings
21 GP-222 email + WC 2/25/16 Dominique Minaberrigarai
for Spruce Street Families
(Comments in support of project)
22 GP-223 email + WC 2/24/16 Jack Thompson (Comments in support of project)
23 GP-224 email + WC 2/25/16 Vanessa Vangel Level of Caltrans involvement; effects of
demolition on historic resources; cul-de-
sac impacts on historic resources;
neighborhood agreement on soundwalls
and impact of no agreement; level of
SHPO involvement in project review;
validity of past reports and data; costs of
cul-de-sac related landscaping installation
and maintenance; ROW impacts from
demolition and parcel acquisition;
alternatives criteria; validity of build
alternatives.
24 GP-225 email + WC 2/25/16 Minner and Associates Increased freeway traffic onto 24th Street;
increased maintenance of 24th Street;
consideration of safer project alternative;
submission of alternate freeway system
plan.
25 GP-226 email + WC 2/25/16 Councilman Terry
Maxwell (Ward 2)
Validation of system improvements;
Hageman Flyover’s effect on project area
traffic; missing reference; validity of
traffic model based studies; City growth
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trends; consistency of project with
Centennial Corridor Project; 24th Street
travel lane widths vs. established
standards; rationale for traffic data
locations; absence of peak hour traffic
data; absence of traffic info from NW
portion of City to project area;
landscaping plans vs. age of 24th Street;
resurfacing history of 24th Street; TRIP
program impacts on Oak Street; cost
savings and traffic reductions of Hageman
Flyover vs. no improvement project.
26 GP-227 email + WC 2/25/16 Bob Coons Agreement with addition of cul-de-sacs
and addition of aesthetic walls; need for
balanced improvements to north and
south side of 24th Street; protect historical
integrity of neighborhoods; revisit
Highway 204/Golden State Highway
alternative; project cost effectiveness.
27 GP-228 email + WC 2/25/16 Jamie Hall (Channel Law
Group )
Pareto Planning study (103 pages) – 124
comments
28 GP-229 email + WC 2/25/16 Julian Quattlebaum, III
(Channel Law Group )
Alternatives; driveways; property
acquisitions; Hageman Flyover; hybrid
approach; trip end point; injunction;
glyphosphate cancer risk.
29 GP-230 email 2/25/16 Don Skelton Traffic from cul-de-sacs.
30 GP-231 email + WC 2/25/16 J. Miguel Flores Improper limiting of public comments;
CEQA; cumulative; alternatives; traffic;
property acquisition; health assessment
study.
31 GP-232 WC 2/25/16 Kristine Kleier (Comments in support of project)
32 GP-233 email 2/25/16 Anne Seydel
33 GP-234 email 2/25/16 Michael and Lara
Riccomini
(Comments in support of project)
34 GP-235 email 2/25/16 Richard Beene (Comments in support of project)
35 GP-236 email 2/25/16 Christian and Kristen
Bellue
(Comments in support of project)
36 GP-237 email 2/25/16 Bob, Wayne, Kelley, Lisa,
Bill, Anna Bellue
(Comments in support of project)
37 GP-238 email 2/25/16 Bettina and Gary Belter (Comments in support of project)
38 GP-239 email 2/25/16 Greg Bynum (Comments in support of project)
39 GP-240 email 2/25/16 Mon-Lai Cheung (Comments in support of project)
40 GP-241 Email +WC 2/25/16 Dewey Compton (Comments in support of project)
41 GP-242 email 2/25/16 Mary Demler (Comments in support of project)
42 GP-243 email 2/25/16 Dennis and Nancy Frick (Comments in support of project)
43 GP-244 Email +WC 2/25/16 Chad Garone (Comments in support of project)
44 GP-245 Email +WC 2/25/16 Stephen Hale (Comments in support of project)
45 GP-246 email 2/25/16 Rebecca and John Hall (Comments in support of project)
46 GP-247 email 2/25/16 William Hickey (Comments in support of project)
47 GP-248 email 2/25/16 Charles Hong (Comments in support of project)
48 GP-249 Email +WC 2/25/16 Casilda Lee (Comments in support of project)
49 GP-250 email 2/25/16 Greg Lee (Comments in support of project)
50 GP-251 email 2/25/16 John and Lesa MacKessy (Comments in support of project)
51 GP-252 Email +WC 2/25/16 Michael Mariani (Comments in support of project)
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52 GP-253 Email +WC 2/25/16 Robert Massey (Comments in support of project)
53 GP-254 email 2/25/16 David Milazzo (Comments in support of project)
54 GP-255 email 2/25/16 Jake and Nika Morse (Comments in support of project)
55 GP-256 Email +WC 2/25/16 Nick Ortiz (Greater
Bakersfield Chamber of
Commerce)
(Comments in support of project)
56 GP-257 Email +WC 2/25/16 Joseph and Gina Pearl (Comments in support of project)
57 GP-258 email 2/25/16 Hellen Pierce (Comments in support of project)
58 GP-259 email 2/25/16 Kyle Ray (Comments in support of project)
59 GP-260 email 2/25/16 Linda Riccomini (Comments in support of project)
60 GP-261 Email +WC 2/25/16 Bernadette Root (Comments in support of project)
61 GP-262 email 2/25/16 Alexis and Mike Roy (Comments in support of project)
62 GP-263 email 2/25/16 Hallie Thomson (Comments in support of project)
Type: Federal (F), State (S), Local/Regional Agency (LR), Business (B), General Public
(GP)
WC = Written Comment Letter Received in advance of Public Hearing
1 Please see Item P6 in Chapter 4.
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Response to Comment Letter GP-202
Comment
Code Response
GP-202-1 The commenter asks why crosswalks were not addressed in the R-DEIR, and expresses the opinion that a
flashing beacon at the crosswalk is inadequate to create safe conditions for pedestrians. Crosswalks were a
topic addressed in the 2013 FEIR/2015 DEIR. Please see Master Response No. 16 – Issues Out of Scope of
the R-DEIR (Crosswalks).
GP-202-2 The commenter expresses the opinion that a signalized crosswalk that is synchronized with traffic signals
would result in a safer, more connected community. This opinion about the value of a signalized crosswalk
is acknowledged. Please see also Master Response No. 16 – Issues Out of Scope of the R-DEIR
(Crosswalks).
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 169
Response to Comment Letter GP-203
Comment
Code Response
GP-203-1 The commenter notes that crosswalks were not addressed in the R-DEIR. Crosswalks were
addressed in the 2013 FEIR/2015 DEIR. Please see Master Response No. 16 – Issues Out of Scope
of the R-DEIR (Crosswalks).
GP-203-2 The commenter expresses the opinion that a flashing beacon at crosswalks is inadequate and that a
signalized crosswalk synchronized with the traffic signals would result in a safer, more connected
community. This opinion about the value of a signalized crosswalk is acknowledged. Please see
also Master Response No. 16 – Issues Out of Scope of the R-DEIR (Crosswalks).
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Response to Comment Letter GP-204
Comment Code Response
GP-204-1 The commenter notes that crosswalks were not addressed in the R-DEIR. Crosswalks were
addressed in the 2013 FEIR/2015 DEIR. Please see Master Response No. 16 – Issues Out of Scope
of the R-DEIR (Crosswalks).
GP-204-2 The commenter expresses the opinion that a signalized crosswalk would result in a safer, more
connected community. This opinion about the value of a signalized crosswalk is acknowledged.
Please see also Master Response No. 16 – Issues Out of Scope of the R-DEIR (Crosswalks).
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Response to Comment Letter GP-205
Comment
Code Response
GP-205-1 The commenter states that signal coordination is not part of the project and asks why signal coordination is
not considered as an alternative. Signal coordination is addressed in Volume 1 of the 2013 FEIR/2015 DEIR.
Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Signal Synchronization).
GP-205-2 The commenter asks what the effects of one-way streets would be on traffic flow through the 24th /23rd Street
couplet area. The project is intended to relieve traffic congestion primarily in Segments 2 and 3;
improvements in Segments 1 and 4 are secondary, and separate alternatives for these segments are not
necessary. Please see Master Response No. 18 – Alternatives (Alternatives Suggested by Commenters).
GP-205-3
The commenter asks whether each segment of the project would not need a separate EIR, and whether the
sections were described so as to exclude alternatives. Describing the project alignment in terms of four
segments does not call into question the validity of the project or its analysis, and does not constitute
piecemealing of the project; in fact, it is the opposite of piecemealing – an integration of the necessary road
improvements along the corridor. Describing the project alignment in terms of its four distinct segments
provides a clear understanding of the project elements. Please see Master Response No. 16 – Issues Out of
Scope of the R-DEIR (Project Description).
GP-205-4 The commenter asks whether $46M is the construction cost or total project cost. For an explanation of
project costs, please see Master Response No. 19 – Project Costs. For a discussion of the cul-de-sacs effects
on traffic circulation and safety, please see Master Response No. 20 – Cul-de-Sacs.
GP-205-5
The commenter requests that the R-DEIR re-visit the Bakersfield Systems Study (BSS) alternatives analysis.
Section 1.3.6 in the R-DEIR describes the relationship between the BSS regional alternatives and the 24th
Street alternatives. The 20 potential regional alternatives are identified in the BSS. A review of the BSS
regional alternatives analysis is outside the scope of the R-DEIR now under review.
The commenter also requests that BSS workshop comments be reviewed for consistency with comments on
the previous 24th Street Improvements Project FEIR completed in 2013. The BSS is cited in the R-DEIR, and
the reader can review that source for additional information on the 20 alternatives it considered and on the
process by which the number of regional alternatives was reduced from 20 to 6. The consistency of BSS
workshop comments with public comments on the decertified 2013 FEIR is outside the purview of the
R-DEIR.
GP-205-6
The commenter asserts that combining the Oak Street / 24th Street intersection project and the 24th Street
widening project misrepresents the scope of the project. The description of the project in terms of its primary
elements – an intersection and a roadway segment - does not call into question the validity of the project or
its analysis. This aspect of the project description was included in the 2012 DEIR, and was not changed in
the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Project Description).
GP-205-7
The commenter expresses the opinion that the daily traffic counts in Table 1.4 are not consistent with the
tables in the 2013 FEIR/2015 DEIR that present peak-hour traffic. The purpose of Table 1.4 was to compare
daily traffic volumes on 24th Street with those on other busy arterials in Bakersfield. The traffic metrics
presented in the R-DEIR were selected for different analytical purposes than those of the City’s Department
of Public Works, and need not be the same as the metrics used by Public Works for engineering evaluations
of other streets. For the limited purpose of comparing traffic volumes among major arterials in downtown
Bakersfield, the Table 1.4 data also need not be for the same year as forecasts of 24th Street traffic volumes
presented in the FEIR.
The commenter also cites changes in population growth patterns in Bakersfield and questions the accuracy of
the traffic forecasts. The 2015 forecasts to which the commenter refers were presented in the previously
circulated DEIR; traffic projections were not addressed in the R-DEIR. Please see also Master Response No.
16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-205-8 The commenter questions the existence of traffic congestion on 24th Street. Vehicle travel times and traffic
congestion are not addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the
R-DEIR (Traffic Study).
GP-205-9
The commenter asserts that statements made about the City’s existing financial obligations under Economic
Infeasibility in the discussion of feasibility (Criterion #3) are “false and misleading.” The phrase “obligated
to service future debt” does not mean that loans are already in place for other TRIP projects, only that the
costs of these other projects have been estimated and the City’s estimated future funding available from the
cited sources has been allocated to them. The City has several important transportation improvement projects
in process, and allocating the available present and expected future funds among them is the normal and
expected budgeting process. Please see also Master Response No. 19– Project Costs.
Appendix C Responses to Comments on R-DEIR
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GP-205-10
The commenter asks why design standards cannot be set aside for the Citizen-Suggested Alternatives, as they
allege was done for Centennial Corridor. The standards establish basic design features that ensure the safe
and efficient flow of traffic. By definition, designs that do not meet the standards may thus result in less
efficient and less safe conditions. Caltrans and the City evaluate potential design exceptions on a case-by-
case basis, and may find that a particular exception is allowable without substantially compromising traffic
flow efficiency or safety. Because the nature, extent, and degree of design exceptions are site-specific, the
acceptance of design exceptions on one project is not a rationale for accepting design exceptions on other
projects, and does not set a precedent. Please see Master Response No. 19 – Project Costs and Master
Response No. 18- Alternatives (Restriping Alternative).
GP-205-11
The commenter observes that the Hageman Flyover was an alternative to the widening of 24th Street in the
1986 Route 178 Corridor Project study, and cites the estimate that it would divert roughly 14,000 vehicles
per day from the 24th Street corridor. The comment goes on to question those data in light of recent
population growth and other road improvement projects. Please see Master Responses No. 16 – Issues Out of
Scope of the R-DEIR (Project Traffic Study), No. 17 – Supporting Information for 2013 FEIR/2015 DEIR,
and No. 22 – Hageman Flyover Alternative.
GP-205-12
The commenter asks whether it would violate CEQA to not consider recent population growth in Bakersfield,
and asks why that information was not included in the R-DEIR. Population growth was not a topic of the
R-DEIR; please see Master Response No. 16 – Issues Out of Scope of the R-DEIR.
The commenter goes on to ask about the effect that demographics and gas prices will play in the future
growth of Bakersfield. It is the environmental impacts of the project, not those resulting from population
growth or gas prices, that are addressed in the DEIR. Questions about the future population growth of
Bakersfield and about gas prices are not comments on the 24th Street project or the content of the R-DEIR.
Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR.
GP-205-13 The commenter cites the traffic study as a “primary problem” with the R-DEIR, and quotes text from the
2013 FEIR / 2015 DEIR about traffic forecasts. The traffic analysis for the project was addressed in Volume
1 of the 2013 FEIR / 2015 DEIR. Please see Master Responses No. 16 – Issues Out of Scope of the R-DEIR.
GP-205-14 The commenter cites recent road improvement projects and requests a new traffic study. The traffic analysis
was presented in Volume 1 of the 2013 FEIR / 2015 DEIR. Please see Master Responses No. 16 – Issues Out
of Scope of the R-DEIR.
GP-205-15
The commenter observes that the Hageman Flyover would provide a direct route from downtown Bakersfield
and claims it would reduce traffic on 24th Street. The Hageman Flyover is included in the baseline case for
the project’s traffic study. Please see Master Response No. 18 - Alternatives (Hageman Flyover Alternative).
The commenter also asserts that the traffic analysis is “erroneous,” but does not explain in what way the
traffic analysis is deficient. Traffic was addressed in Volume 1 of the 2013 FEIR / 2015 DEIR. Please see
Master Responses No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-205-16
The commenter states that motorists are using alleys to enter and exit 24th Street now that temporary cul-de-
sacs are in place, creating a safety issue. The commenter states that cul-de-sacs result in more motorists using
the alleys along the south side of 24th Street, but no data are provided. Regardless of the roadway design,
drivers are primarily responsible for determining when it is safe to enter the flow of traffic, and for avoiding
collisions with vehicles exiting 24th Street. Please see Master Response No. 20 – Cul-de-Sacs (Safety).
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Response to Comment Letter GP-206
Comment
Code Response
GP-206-1 The commenter makes a general statement on the purposes (goals) of road projects, and then claims –
without supporting evidence – that the project does not achieve any of them. The purpose of and need for the
project were not addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the
R-DEIR (Purpose and Need).
GP-206-2
The commenter expresses an opinion that a better way (than the project) to achieve road project goals is to
reduce traffic volumes, and observes that the proposed project does not do so. The only feasible way to
reduce vehicle volumes that would be consistent with the project objectives would be via off-site alternatives
that diverted a substantial volume of traffic from the 24th Street corridor. Previous studies (e.g., the
Bakersfield System Study) considered alternatives that diverted traffic to the north or to the south of 24th
Street, and found them to be ineffective in substantially reducing traffic on 24th Street. Please also see Master
Response No. 18 –Alternatives.
GP-206-3 The commenter expresses an opinion that the 24th Street corridor is not a bottleneck and no traffic congestion
exists. The R-DEIR does not describe current traffic congestions or other existing traffic conditions on 24th
Street. This information was presented in the 2012 DEIR. Please see Master Response No. 16 – Issues Out of
Scope of the R-DEIR (Traffic Study).
GP-206-4 The commenter expresses an opinion about the information contained in the City’s court filings and provides
anecdotal observations on travel time along the 24th Street corridor. The R-DEIR does not address traffic
congestion or travel time under existing conditions. Please see Master Response No. 16 – Issues Out of Scope
of the R-DEIR (Court Briefs and Traffic Study).
GP-206-5 The commenter expresses an opinion about the relative values of new traffic lanes and signal
synchronization. Please also see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Signal
Synchronization).
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 208
GP-206-6 The commenter expresses opinions about the value of informal anecdotal observations of travel times, their
role in understanding traffic flows, and the effects of properly synchronized signals. Please see Master
Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study, Traffic Signal Synchronization).
GP-206-7 The commenter expresses opinions about the effectiveness of adding travel lanes in improving travel time,
about the current level of congestion, and about the need for the project. Please see Master Response No. 16
– Issues Out of Scope of the R-DEIR (Project Description and Traffic Study).
GP-206-8
The commenter expresses an opinion about the effectiveness on traffic congestion of widening 24th Street.
The project’s potential effects on noise, air quality, aesthetics, and safety are addressed in the appropriate
sections of the 2013 FEIR / 2015 DEIR, Volume 1. The traffic analysis for the project was presented in
Volume 1 of the 2013 FEIR / 2015 DEIR; please see Master Response No. 16 – Hageman Flyover
Alternative. The effects of the cul-de-sacs on egress and emergency response are addressed in Master
Response No. 20 – Cul-de-Sacs.
GP-206-9
The commenter expresses the opinion that the Hageman Flyover would provide volume relief to the 24th
Street corridor. The extension of Hageman Avenue to Golden State is a valuable element of the overall
transportation improvement program for Metropolitan Bakersfield. The Hageman extension project is
included in the adopted Regional Transportation Plan, and the preparation of design plans is underway.
Please see Master Response No. 18 - Alternatives (Hageman Flyover Alternative).
GP-206-10
The commenter asks why the document goes beyond its stated purpose. The commenter does not identify
how the R-DEIR is believed to go beyond its stated purpose, so a specific response cannot be formulated.
The R-DEIR addresses the two defects identified by the Court (cul-de-sacs and potentially feasible
alternatives eliminated prior to detailed evaluation) and associated issues, as well as process and procedural
issues raised by the preparation of the R-DEIR. Text from the 2013 FEIR (decertified) is reproduced in the
R-DEIR for purposes of clarity and context only, and thus is not subject to comment. As stated on page i of
the R-DEIR, the City will respond to any comments that pertain to “the revised and recirculated portions of
the 2015 DEIR, as set forth” in the R-DEIR. The R-DEIR goes on to state, on page vi, that, “The City will
only respond to comments on the new material included in this R-DEIR.”
GP-206-11 The commenter questions why the SR-99 off-ramps are included in the project. The project description,
including the SR- 99 ramps, was presented in the original 2012 DEIR, along with the rationale for including
them in the project. Please see Master Response No. 16 - Issues Out of Scope of the R-DEIR (Project
Description).
GP-206-12
The commenter asks for a definition of traffic “congestion” and how the term applies to 24th Street. Traffic
congestion for the project is defined in terms of Level of Service (LOS), as described in Figures 1-3 and 1-4
of Volume 1 of this FEIR. As explained in the previous DEIR and this FEIR, the proposed project would
improve the LOS on 24th Street. Please also see Master Response No. 16 - Issues Out of Scope of the R-DEIR
(Project Description).
GP-206-13 The commenter asks why the most recent available information was not used. The baseline environmental
conditions for the EIR are based on the publication date of the Notice of Preparation. Please see Master
Response No. 17 - Supporting Information for 2013 FEIR/2015 DEIR.
GP-206-14 The commenter expresses a concern about the scope of public review of the R-DEIR. Please see response to
Comment No. GP-206-10.
GP-206-15
The commenter expresses a concern that no documentation is provided for statements about the cul-de-sacs
in the Key Issues summary. The statement cited on page vi of the R-DEIR is a summary of information
provided in the body of the report. The cul-de-sacs were added into the project description and the
environmental analyses and are present in Appendix A as an Errata Sheet to the previously prepared FEIR.
The impacts of cul-de-sacs construction are discussed at approximately the same level of detail as other
minor elements of the project. In general, expert opinion supported by facts, reasonable assumptions
predicated upon facts, and reasoned analysis constitutes substantial evidence.
GP-206-16
The commenter asks the City to explain and document the “re-evaluation.” The R-DEIR did not re-evaluate
the environmental impacts of any elements of the proposed project that were evaluated in the 2013 FEIR /
2015 DEIR. Six additional cul-de-sacs that are new elements of the project are evaluated in the R-DEIR. The
term “re-evaluation is not used in conjunction with the cul-de-sacs in the R-DEIR. Please see Master
Response No. 20 – Cul-de-Sacs (Impact Evaluation).
GP-206-17
The commenter requests documentation that the cul-de-sacs improve traffic safety. The R-DEIR does not
state that cul-de-sacs improve traffic safety. The R-DEIR states only that some residents made such claims in
requesting that the City install cul-de-sacs on their streets. Blockages on 24th Street due to traffic accidents
are upset conditions that are not reasonably foreseeable (as to their frequency, timing, severity, or impacts),
and thus are not required by CEQA to be addressed. In any case, the risk of a motorist being delayed for a
substantial period on 24th Street is an annoyance and inconvenience, but is not a safety issue. Emergency
access to 24th Street was addressed in Section VIII.g of the Initial Study/Negative Declaration for installation
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 209
of the cul-de-sacs (24th Street Cul-de-Sacs) which was released in 2012 (SCH No. 2012091065). Please also
see Master Response No. 20 – Cul-de-Sacs.
GP-206-18 The commenter asks why the City is using outdated evaluations and if the City intends to update or correct
the information. The traffic-related impacts of the project were not a topic of the R-DEIR. Please see Master
Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-206-19
The commenter claims that there is no congestion on the 24th Street corridor. The R-DEIR does not address
traffic congestion under existing conditions or travel time. Additionally, information provided by the City to
the Court is not relevant to the adequacy or completeness of the R-DEIR, which is the subject of the current
public review. Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Court Briefs and
Traffic Study).
GP-206-20 The commenter asks the City to explain, document, and justify the project’s “capacity goal” and how the
City intends to achieve it. The R-DEIR does not address traffic capacity or congestion. Please see Master
Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-206-21
The commenter questions travel time information provided by the City to the Court, and claims that
synchronizing the traffic signals would improve drive times. Traffic congestion and circulation, travel times,
and signal synchronization were addressed in the original DEIR. Information provided by the City to the
Court is not relevant to the adequacy or completeness of the R-DEIR, which is the subject of the current
public review. Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Court Briefs, Traffic
Study, and Traffic Signal Synchronization).
GP-206-22
The commenter questions why the traffic signals along 24th Street are not synchronized, and asks why signal
synchronization is not addressed in the R-DEIR. Travel time and signal synchronization are not addressed in
the R-DEIR because these topics were addressed in the 2013 FEIR / 2015 DEIR. Please see response to
Comment No. GP-206-21 and Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study
and Traffic Signal Synchronization).
GP-206-23 The commenter asks the City to provide documentation for the information it provided to the Court. Travel
time and signal synchronization are topics that are not addressed in the R-DEIR. Please see response to
Comment No. GP-206-21 and Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Signal
Synchronization).
GP-206-24
The commenter asks what information the City has on travel times through the downtown, what plans the
City has for synchronization, and what the City expects the effect to be on traffic. Traffic flows and signal
synchronization are addressed in the 2013 FEIR / 2015 DEIR. Documentation for the traffic study is also
provided in Volume 1. Please see response to Comment No. GP-206-21 and Master Response No. 16 –
Issues Out of Scope of the R-DEIR (Traffic Signal Synchronization).
GP-206-25 The commenter asks how the increase in capacity will improve traffic flow. Travel times and traffic capacity
are not addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR
(Traffic Study).
GP-206-26 The commenter claims that the R-DEIR does not explain what improvement in traffic flows or drive times
are expected to result from the proposed project. Traffic flow and circulation were addressed in the 2012
DEIR. Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-206-27 The commenter claims that the City has not identified in the R-DEIR the goals of the project, and asks how
an increase in capacity has a positive effect. Traffic congestion is expressed in terms of traffic level of
service. Traffic congestion and capacity were addressed in the original DEIR. Please see Master Response
No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-206-28 The commenter claims that the R-DEIR does not address how synchronizing the traffic signals would have
positive effects. Traffic signal synchronization is addressed in the 2013 FEIR / 2015 DEIR. Please see
Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Signal Synchronization).
GP-206-29 The commenter asks that the R-DEIR address drive times. Travel times are not addressed in the R-DEIR.
Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-206-30 The commenter asks why the R-DEIR ignores Section 4f requirements. A Section 4(f) evaluation was
prepared in response to federal environmental review requirements, as provided in the 2012 DEIR/EA, and
was not updated or addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the
R-DEIR.
GP-206-31 The commenter asks why all 4 segments of the project alignment are bundled into one project. The project
was described in terms of 4 segments in the 2012 DEIR to facilitate understanding, and has never been
changed. Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Project Description).
GP-206-32 The commenter asks for an explanation of traffic congestion, why new information is not used, and why
drive times and signal synchronization are not addressed in the R-DEIR. Traffic congestion for the project is
defined in terms of Level of Service (LOS), as described in Figures 1-3 and 1-4 of Volume 1 of this FEIR.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 210
As noted in the original DEIR, the proposed project would improve the LOS on 24th Street. Please see also
Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Signal Synchronization).
GP-206-33 Please see response to comment GP-206-31 above.
GP-206-34
The commenter requests an explanation of why the Hageman Flyover would not help alleviate the need for
Segment 1 of the project. As explained in the R-DEIR and in Master Response No. 18 - Alternatives
(Hageman Flyover Alternative), the Hageman Flyover project, as an approved transportation improvement
project, is already accounted for in regional traffic models, and thus is part of the baseline traffic conditions
against which the effects of the proposed project are assessed.
GP-206-35 The commenter requests an explanation of how the proposed project would improve traffic flow and drive
times along the 24th Street corridor. The traffic study was provided in the 2012 DEIR. Please see Master
Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-206-36 The commenter requests an explanation for the inclusion of Segment 1 in the project. Segment 1 was
included to assure that the proposed project comprehensively addressed the traffic issues along the 24th Street
corridor. Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Project Description).
GP-206-37 The commenter expresses the opinion that the landscaping component of the project would not be
implemented and, if it was, the City would not have the water available to irrigate the landscaping. Your
comment is acknowledged.
GP-206-38
The commenter requests documentation that the cul-de-sacs have decreased the risk of accidents from
motorists cutting through the side streets to avoid congestion on 24th Street. The R-DEIR does not claim that
the cul-de-sacs were installed for safety reasons, but states only that residents have made such claims. The
transcript of the City Council meeting at which the cul-de-sac Resolution was approved is sufficient
documentation and is cited in the text.
GP-206-39 The commenter speculates on the reasons why the City changed the requirements for approving cul-de-sacs.
The City’s resolution and the motivations for the original resolution and amendment have no bearing on the
adequacy or completeness of the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the
R-DEIR.
GP-206-40 The commenter misstates the text of the R-DEIR, alleging that it cites safety as an issue in installing the cul-
de-sacs. Please see response to Comment No. GP-206-38. Emergency access is addressed in Master
Response No. 20 – Cul-de-Sacs (Safety).
GP-206-41 The commenter provides anecdotal information on traffic conditions in downtown Bakersfield. Please see
Master Response No. 16 – Issues Out of Scope of the RDEIR.
GP-206-42 The commenter erroneously claims that the R-DEIR cites safety as an issue in installing the cul-de-sacs. The
R-DEIR does not state that cul-de-sacs improve traffic safety. The R-DEIR states only that some residents
made such claims in requesting that the City install cul-de-sacs on their streets. Please also see Master
Response No. 20 – Cul-de-Sacs (Safety).
GP-206-43 The commenter expresses an opinion about the relevance of the background documents supporting the
analyses in the 2013 FEIR / 2015 DEIR. Please see Master Response No. 17 – Supporting Information for
2013 FEIR/2015 DEIR.
GP-206-44 The commenter recommends the use of timely, appropriate documents on growth, traffic trends, and use in
the R-DEIR. Please see Master Response No. 17 – Supporting Information for 2013 FEIR/2015 DEIR.
GP-206-45 The commenter expresses an opinion about the relevance of a 10-year old Project Study Report. Please see
Master Response No. 17 – Supporting Information for 2013 FEIR/2015 DEIR.
GP-206-46 The commenter cites information on traffic capacity from the 2013 FEIR/2015 DEIR. Traffic capacity was
not addressed in the R-DEIR. The noise and air quality impact analyses in the 2012 DEIR explain how noise
and air pollutant levels would be affected by the project. Please see Master Response No. 16 – Issues Out of
Scope of the R-DEIR (Traffic Study).
GP-206-47
The commenter expresses an opinion that increasing the capacity of 24th Street would not reduce accidents,
or decrease noise or pollution, but would increase the number of vehicles. The project would not generate
vehicle trips. It would accommodate vehicle volumes already predicted to occur due to regional land use
changes that would induce additional vehicle trips. Please also see Master Response No. 16 – Issues Out of
Scope of the R-DEIR.
GP-206-48
The commenter expresses a preference for decreasing traffic volumes on 24th Street rather than increasing
capacity. Traffic capacity is addressed in the 2013 FEIR/2015 DEIR; please see Master Response No. 16 –
Issues Out of Scope of the R-DEIR.
The commenter also asks about how the project would “decrease volume through downtown.” It is not an
objective of the proposed project to decrease traffic volumes through the downtown.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 211
GP-206-49
The commenter requests documentation on how the City determined the accident rate on 24th Street, and also
asked what would be a typical accident rate, and how increasing the vehicle capacity would lower the
accident rate. The accident history was provided to the City Council on February 12, 2014 as part of the
approval resolution for the 24th Street Improvement Project FEIR. The accident data are derived from police
dispatch logs covering the period from January 2008 until December 2013, during which time 322 accidents
were recorded.
GP-206-50 The commenter asks why building Hageman Flyover first would not be prudent. The discussion of
Alternative J in the R-DEIR explains why building the project instead of the Hageman Flyover would better
achieve the project’s objectives. Please also see Master Response No. 18 - Alternatives (Hageman Flyover
Alternative).
GP-206-51
The commenter asks why the project would have less environmental impact than building the Hageman
Flyover and why that alternative was found to be “environmentally infeasible.” That conclusion is not found
in the R-DEIR.
The original DEIR and R-DEIR comprehensively address the relative benefits of the project and offsite
alternatives such as the Hageman Flyover. The discussion of environmental issues for the Hageman Flyover
on page 70 of the R-DEIR identifies some environmental impacts of the Hageman Flyover that would be
greater than those of the proposed project, and some that would be less than those of the project, but does not
provide an overall conclusion. The Environmental criterion is whether or not the alternative could reduce,
avoid, or offset one or more potentially significant environmental effects; Table 1.5 on page 73 of the
R-DEIR indicates that Hageman Flyover could do so.
GP-206-52 The commenter asks why the proposed project would be more “socially sound” than the Hageman Flyover.
As stated on page 71 of the R-DEIR under Alternative J (Feasibility), the evaluation concluded that Hageman
Flyover would be socially feasible. The alternatives threshold selection criteria do not apply to the proposed
project.
GP-206-53 The commenter asks why the proposed project would be more technically feasible than the Hageman
Flyover. As stated on page 71 of the R-DEIR under Alternative J (Feasibility), the Hageman Flyover would
be technically feasible. The alternatives selection criteria do not apply to the proposed project.
GP-206-54
The commenter asks why the Hageman Flyover Alternative would be remote or speculative. The discussion
of Reasonableness under Alternative J does not state that this alternative would be remote or speculative. The
last paragraph on page 71 explains why this alternative is deemed to be unreasonable specifically as an
alternative to the proposed project.
The commenter goes on to ask ”how could Hageman not be funded.” in lieu of funding the 24th Street
Improvement Project. The Hageman Flyover is a separate, approved project in the Thomas Roads
Improvement Program, and no need exists to choose one project over the other; the Hageman Flyover will be
constructed whether or not the 24th Street Improvement Project is approved.
Finally, the commenter argues that the Hageman Flyover cannot be considered speculative or
unconventional, and includes no unnecessary elements. The City agrees with this statement.
GP-206-55 The commenter expresses an opinion that the Hageman Flyover was eliminated because it does not have 4
segments. Hageman Flyover was not eliminated because it does not have four segments. It was eliminated
because it does not meet the primary objective of the project, and because it is infeasible and unreasonable
specifically as an alternative to the proposed project.
GP-206-56 The commenter asks what is an offsite alternative. An offsite alternative is one that occurs in a location other
than where the proposed project would occur.
GP-206-57 The commenter asks why the Hageman Flyover would not relieve congestion on the 24th Street corridor, and
thus reduce traffic volumes and related environmental effects. Please see Master Response No. 18 -
Alternatives (Hageman Flyover Alternative).
GP-206-58
The commenter expresses an opinion that old documents cannot be relied upon and that statements derived
from them must be updated. Please see Master Response No. 17 – Supporting Information for 2013
FEIR/2015 DEIR.
The commenter further claims that traffic volumes are overstated and that new information must be used. See
Master Response No. 16 – Issues Out of Scope of the R-DEIR.
GP-206-59
The commenter acknowledges that both the 24th Street project and the Hageman Flyover are planned projects
within the TRIP program, but appears to suggest that the regional transportation program be re-analyzed or
re-prioritized before being implemented. The suggested approach to build Hageman Flyover first and then
see if other improvements were needed is not an appropriate planning or engineering approach to addressing
regional transportation demand because it does not allow sufficient time to design, fund, and construct new
transportation facilities to accommodate the planned growth of the community, as envisioned in the City’s
General Plan. Please see also Master Response No. 18 - Alternatives (Hageman Flyover Alternative).
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 212
GP-206-60
The commenter requests supporting information for the evaluation of the Hageman Flyover Alternative
under Alternatives Threshold Selection Criterion #1 – Environmental. The commenter claims that the
R-DEIR characterizes the visual impacts of Hageman Flyover as “so severe that they would eliminate” the
alternative. No such statement is made in the R-DEIR. The evaluation of this alternative under Criterion #1
concludes that Hageman Flyover, as a large, new, linear, elevated urban structure traversing a rural area,
would have a greater visual impact on the landscape than adding two lanes to an existing at-grade 4-lane
arterial through an urban area. The City believes the facts and reasoning provided are sufficient to support its
conclusions. Furthermore, the Hageman Flyover Alternative was not excluded on this basis; as shown in
Table 1.5 in the R-DEIR, Alternative J (Hageman Flyover) passed Criterion #1 (Environmental).
GP-206-61 The commenter requests documentation for the statement that Hageman Flyover reduces traffic volumes on
24th Street by about 13 percent. The source of the 13 percent reduction estimate will be further documented
in the FEIR. Please see also Master Response No. 18 - Alternatives (Hageman Flyover Alternative).
GP-206-62 The commenter speculates on the potential effects of implementing the Hageman Flyover. Please see Master
Response No. 18 - Alternatives (Hageman Flyover Alternative) for an explanation of why these events would
not occur.
GP-206-63 The commenter asks why the Hageman Flyover would not be a proper alternative to the proposed project.
The original DEIR and R-DEIR comprehensively address the relative benefits of the proposed project and
the Hageman Flyover, and the reasons why Hageman Flyover would not be a substitute for the 24th Street
Improvement Project.
GP-206-64 The commenter states that the project is based on 30-year old plans. That is not the case. Traffic data for the
project were deemed to be current as of the publication of the 2013 FEIR / 2015 DEIR, as explained in
Master Response No. 14: Traffic Demand in the 24th Street Corridor. Please also see Master Response No.
16 – Issues Out of Scope of the R-DEIR..
GP-206-65 The commenter expresses opinions about the age of the documentation supporting the project and about why
the City chooses to continue implementing the TRIP program as currently designed. Please see Master
Response No. 17 – Supporting Information for 2013 FEIR/2015 DEIR.
GP-206-66
The commenter asks several questions about new information, population growth, vehicle volumes and
capacity, drive times, traffic signal synchronization, the relevance to the project of the SR-99 ramps, and the
Hageman Flyover. Please see Master Responses No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study
and Traffic Signal Synchronization), No. 17 – Supporting Information for 2013 FEIR/2015 DEIR, and No. 22
– Hageman Flyover Alternative.
GP-206-67 The commenter questions the accuracy of the R-DEIR statement that using Hageman Flyover would be 3
miles extra for the average driver. Please see Master Response No. 18 - Alternatives (Hageman Flyover
Alternative).
GP-206-68 The commenter asserts that the R-DEIR ignores several significant issues regarding the Hageman Flyover
Alternative. Please see Master Response No. 17 – Supporting Information for 2013 FEIR/2015 DEIR.
GP-206-69 The commenter discusses improvements to SR-99 intended to facilitate traffic exiting at SR-204. Traffic was
not a topic addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the
R-DEIR (Traffic Study).
GP-206-70 The commenter asserts that the R-DEIR does not provide current information on SR-204. Traffic was not a
topic addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR
(Traffic Study).
GP-206-71 The commenter asserts that the R-DEIR does not provide current information on Rosedale Highway. Traffic
was not a topic addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the
R-DEIR (Traffic Study).
GP-206-72 The commenter believes that Allen, Verdugo, Calloway, Coffee, and Fruitvale Roads need to be studied.
Traffic was not a topic addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of
the R-DEIR (Traffic Study).
GP-206-73 The commenter states an opinion that the project will increase traffic volumes and related environmental
effects. The commenter’s opinions about the relative environmental merits of the proposed project and
Alternative J are acknowledged.
GP-206-74 The commenter asks why no information has been provided by the City to justify dismissing the Hageman
Flyover as an alternative to the proposed project. Please see the discussion of Alternative J in the R-DEIR
and Master Response No. 18 - Alternatives (Hageman Flyover Alternative).
GP-206-75 The commenter asserts that no information has been provided by the City about changes in traffic flow
patterns into downtown Bakersfield from the northwest. The traffic study for the project was presented in the
2013 FEIR/2015 DEIR, and was not a topic addressed in the R-DEIR. Please see Master Response No. 16 –
Issues Out of Scope of the R-DEIR (Traffic Study).
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GP-206-76 The commenter claims that the R-DEIR ignores population growth. Traffic projections were not addressed in
the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-206-77 The commenter states an opinion that Hageman Flyover cannot be properly evaluated without considering
population growth in the northwest area. Please see response to Comment No. GP-206-76.
GP-206-78 The commenter asks why elements of the regional transportation program cannot be changed. Please see
Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-206-79 The commenter suggests that Hageman Flyover be built before 24th Street improvements are made. Please
see response to Comment No. GP-206-59.
GP-206-80 The commenter offers an opinion that the cost differences between the proposed project and the Hageman
Flyover – a difference of $6 million – are minor. Please see Master Response No. 19 – Project Costs.
GP-206-81 The commenter claims that superficial excuses are used to discredit the Hageman Flyover Alternative. Please
see Master Response No. 17 – Supporting Information for 2013 FEIR/2015 DEIR and Master Response No.
18 – Alternatives (Hageman Flyover Alternative).
GP-206-82 The commenter asks why the Hageman Flyover would not relieve congestion on the 24th Street corridor, and
thus reduce traffic volumes and related environmental effects. Please see Master Response No. 18 -
Alternatives (Hageman Flyover Alternative).
GP-206-83 The commenter believes that the R-DEIR should mention the benefits of the Hageman Road Alternative. The
evaluation of this Alternative J in the R-DEIR is for the purpose of determining whether it should receive
detailed consideration in the EIR; to the extent appropriate, its relative costs and benefits are addressed.
Please also see response to Comment No. GP-206-82.
GP-206-84 The commenter asks why the City insists on increasing capacity on 24th Street. Please see Master Response
No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-206-85
The commenter questions the inclusion of the SR-99 ramps in the project because, “they have no impact” on
traffic congestion on 24th Street. As explained in Section 1.3.6 in Chapter 3 of the R-DEIR, the City
determined that improvements to these ramps were necessary to achieve the basic objective of the project.
Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study) and Master Response
No. 18 - Alternatives (Hageman Flyover Alternative).
GP-206-86
The commenter acknowledges that both the 24th Street project and the Hageman Flyover area planned
projects within the TRIP program, but appears to suggest that the regional transportation program be re-
analyzed or re-prioritized before being implemented. The suggested approach to build Hageman Flyover first
and then see if other improvements were needed is not an appropriate engineering or planning approach to
addressing regional transportation demand because it does not allow sufficient time to design, fund, and
construct new transportation facilities to accommodate the planned growth of the community, as envisioned
in the City’s General Plan. Please see also Master Response No. 18 - Alternatives (Hageman Flyover
Alternative).
GP-206-87 The commenter asks why 10-year to 30-year old information is used. Please see Master Response No. 17 –
Supporting Information for 2013 FEIR/2015 DEIR.
GP-206-88 The commenter asks why 10-year to 30-year old information is used and why alternatives are not considered.
Please see Master Response No. 17 – Supporting Information for 2013 FEIR/2015 DEIR.
GP-206-89 The commenter requests an explanation for the City’s assertion that traffic flows would improve with the
project. Travel times are not addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of
Scope of the R-DEIR (Traffic Study).
GP-206-90 Travel times are not addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of
the R-DEIR (Traffic Study).
GP-206-91 The commenter asks why the Hageman Flyover Alternative would add 3 miles to an average trip. Please see
Master Response No. 18 - Alternatives (Hageman Flyover Alternative).
GP-206-92 The commenter expresses a preference for the Hageman Flyover Alternative. Please see Master Response
No. 18 - Alternatives (Hageman Flyover Alternative).
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Response to Comment Letter GP-207
Comment
Code Response
GP-207-1 The commenter requests that the list of Segment 4 improvements be corrected for the correct number of bus
turnouts. The text will be revised as suggested by the commenter.
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Response to Comment Letter GP-208
Comment
Code Response
GP-208-1 Your comment is acknowledged.
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Response to Comment Letter GP-209
Comment
Code Response
GP-209-1 Your comment is acknowledged.
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Response to Comment Letter GP-210
Comment
Code Response
GP-210-1 Your comment is acknowledged.
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Response to Comment Letter GP-211
Comment
Code Response
GP-211-1 Your comment is acknowledged.
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Response to Comment Letter GP-212
Comment
Code Response
GP-212 Your comments are acknowledged.
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Response to Comment Letter GP-213
Comment
Code Response
GP-213-1 Your comments are acknowledged.
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Appendix C Responses to Comments on R-DEIR
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Response to Comment Letter GP-214
Comment
Code Response
GP-214-1 The commenter states that the school crossing at Alder Street is a hazard. Please see Master Response No. 16 –
Issues Out of Scope of the R-DEIR (Crosswalks).
GP-214-2 The commenter suggests that the sidewalks should be on the south side of 24th Street. Please see Master
Response No. 16 – Issues Out of Scope of the R-DEIR (Project Description).
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Response to Comment Letter GP-215
Comment
Code Response
GP-215-1
The commenter quotes text from the R-DEIR’s Overview of Environmental Document Processing for the
Proposed Project – Environmental Document Processed to Date. The purpose of this text was to
summarize the previous environmental review process for the project, not to “reassert that their [the City’s]
comments were comprehensive.”
The commenter requests information on how the R-DEIR was circulated. All individuals and organizations
that received a copy of the 2012 DEIR and the decertified 2013 FEIR were included in the distribution list
for the R-DEIR. A Notice of Availability was published in one English-language and one Spanish-language
newspaper in accordance with CEQA public notification requirements. Notices were mailed to elected
officials. Copies of the R-DEIR were sent to the State Clearinghouse for distribution to State agencies, and
the R-DEIR was made available at the TRIP offices, Community Development Department, Kern Council
of Governments, Beale Memorial Library, Kern County Public Library, Kern County Law Library, and on
the City’s website. The R-DEIR was made available for public review from January 11, 2016 to
February 25, 2016 (a 45-day period). A public hearing before the Planning Commission occurred on
January 21, 2016.
GP-215-2 The commenter objects to the wording of the introductory paragraph to the Citizen-Suggested Alternatives.
The first paragraph of Alternative I has been revised.
GP-215-3
The commenter expresses a concern that individuals who submitted comments on the project in 2012 will
believe that the proposed project is a “done deal.” The City Council publicly rescinded its approval of the
project. The public review of the R-DEIR was properly noticed, and the text of the R-DEIR described the
issues on which public comments would be accepted. These actions should have been sufficient to dispel
any impression that the project was not still being reviewed and considered by the City.
GP-215-4 The commenter questions the meaning of “intended.” The phrase “are intended to” has been revised to
“would.”
GP-215-5 The commenter asserts that current traffic volumes are down. Traffic was not a topic addressed in the
R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-215-6
The commenter asks about significance determinations for the eight eliminated alternatives, where are the
support documents, and why are they not referenced. The R-DEIR is the current document. The decertified
FEIR has become a part of the original DEIR, and was referred to as the 2015 DEIR in the R-DEIR. The
thresholds referred to in this section of the document are screening thresholds, not significance thresholds.
All of the documentation concerning the eight eliminated alternatives is provided in Chapter 3 of the R-
DEIR.
GP-215-7 The commenter asks why Caltrans did not participate in the R-DEIR. The 2013 FEIR (CEQA) was
decertified but the EA (NEPA) was not decertified, so there are no federal requirements to satisfy, as
explained on page 1 of the R-DEIR (Introduction).
GP-215-8 The commenter asserts that the project is circumventing Caltrans traffic safety requirements. The design of
the project is not a topic in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the
R-DEIR (Project Description).
GP-215-9 The commenter asks for data to support predicted trends. Traffic is not a topic addressed in the R-DEIR.
Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-215-10 The commenter reproduces a sentence from the Project Description, which was originally addressed in the
original DEIR and which was reproduced in the R-DEIR solely for purposes of clarity. Please see Master
Response No. 16 - Issues Out of Scope of the R-DEIR (Project Description).
GP-215-11
The commenter asks what the estimated costs of the proposed project are. Project construction costs were
presented in the R-DEIR without engineering and construction support costs so that they would be
comparable to the cost estimates for the potentially feasible alternatives. Project engineering and
construction support costs for the proposed project are estimated at about $19 million. Project funding
sources are described under Criterion #3 in Section 1.3.6.1 of the R-DEIR. Please also see Master Response
No. 19 – Project Costs.
GP-215-12 The commenter asks why traffic safety concerns for residents on the north side of 24th Street were not
addressed in the R-DEIR. Traffic safety is addressed in the Traffic and Transportation / Pedestrian and
Bicycle Circulation section of the original DEIR. Traffic safety is not addressed in the R-DEIR, except in
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conjunction with the installation of cul-de-sacs on the south side of 24th Street. Please see Master Response
No. 16 - Issues Out of Scope of the R-DEIR (Traffic Study).
GP-215-13 The commenter asks how traffic patterns have been affected by the cul-de-sacs. Please see Master
Response No. 20 – Cul-de-Sacs (Alleys).
GP-215-14
The commenter questions the characterization of cul-de-sac effects as minor. Traffic safety is addressed in
the Traffic and Transportation / Pedestrian and Bicycle Circulation section of the original DEIR. Traffic
safety is not addressed in the R-DEIR, except in conjunction with the installation of cul-de-sacs on the
south side of 24th Street. Traffic speeds are not addressed at all, under the assumption that vehicle speeds
would be controlled by the posted speed limit. Please also see Master Response No. 16 - Issues Out of
Scope of the R-DEIR (Traffic Study).
GP-215-15
The commenter asks whether Caltrans and the State Historic Preservation Officer were contacted during
the R-DEIR review process. Caltrans was the federal lead agency for the project and responsible for
approval of the Final EA for the project. The California State Historic Preservation Officer concurred with
the historic district boundary definition, eligibility determination, and effect finding (See Appendix D in the
2013 FEIR/2015 DEIR). Both agencies received copies of the R-DEIR and were invited to submit
comments.
GP-215-16
The commenter misreads the R-DEIR text as stating that the cul-de-sacs would have a substantial impact
on the aesthetic environment; they would not. As stated in the text of the R-DEIR, the project would have a
“moderate to moderately high” impact on the aesthetic environment, with or without the cul-de-sacs (i.e.,
their minor effect is insufficient to affect the determination); thus, the statements in the text are not
contradictory.
The commenter also questions why residents were not informed. The proper forum for informing residents
about the impacts of the project on aesthetic resources is the DEIR, which was released in January 2016 for
that purpose.
GP-215-17 The commenter asks why out-dated studies are being used. Please see Master Response No. 17 –
Supporting Information for 2013 FEIR/2015 DEIR.
GP-215-18 The commenter asks why the R-DEIR should be more valid than older documents that were not entirely
accurate. Please see Master Response No. 17 – Supporting Information for 2013 FEIR/2015 DEIR.
GP-215-19
The commenter asks how the public was informed about the scope of the Regional Transportation Plan.
The EIR for the Regional Transportation Plan (RTP) complied with CEQA requirements for public review.
The CEQA public review process adequately informs the public about the potential environmental impacts
of a proposed project. If citizens have questions about the conclusions of the EIR, or need more clarity,
they may submit comments to that effect during the public review of the EIR. The RTP addresses potential
transportation alternatives at a general level of detail; project-level environmental documents provide more
specific information on exact routes and specific properties and resources to be affected.
GP-215-20 The commenter asks where the analysis to support the downtown’s capacity for development is. This was
not a topic addressed in the R-DEIR. Please see Master Response No. 17 – Supporting Information for
2013 FEIR/2015 DEIR.
GP-215-21
The commenter asks how safety issues are being addressed for residents on the north side of 24th Street.
Accident potential and traffic safety for the proposed project – without the additional six cul-de-sacs - were
addressed in Section 2.1.4, Traffic and Transportation / Pedestrian and Bicycle Facilities, presented in the
original DEIR, and in the responses to comments on the DEIR (Volume 2: GP-69-12). The addition of cul-
de-sacs would eliminate a source of traffic conflicts, smoothing traffic flows and incrementally increasing
the hourly vehicle capacity of the road. Posted speed limits reflect a safe speed consistent with road design
and, while average vehicles speeds could increase modestly, these improvements are not expected to
increase the number of motorists exceeding the speed limit. The cul-de-sacs pose no safety issue for
residents on the north side of 24th Street. No analysis is required to justify the identification of traffic safety
as a secondary project objective – public safety is an objective community good.
GP-215-22 The commenter asks where additional funds would come from to cover any increased costs. Potential
funding sources for the proposed project are identified under Criterion #3 in Section 1.3.6.1 of the R-DEIR.
GP-215-23 The commenter’s opinion about the reasonableness of the project is acknowledged. Alternatives G1-G4
considered the utility of a frontage road in facilitating access to the neighborhoods north and south of 24th
Street, but these alternatives were found to be infeasible.
GP-215-24 The commenter asks what analysis has been conducted on the safety of residents. Please see response to
Comment No. GP-215-21.
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Response to Comment Letter GP-216
Comment
Code Response
GP-216 Your comments are acknowledged.
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Response to Comment Letter GP-217
Comment
Code Response
GP-217 Your comments are acknowledged.
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Response to Comment Letter GP-218
Comment
Code Response
GP-218 Your comments are acknowledged.
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Response to Comment Letter GP-219
Comment
Code Response
GP-219 Your comments are acknowledged.
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Response to Comment Letter GP-220
Comment
Code Response
GP-220 Your comments are acknowledged.
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Response to Comment Letter GP-221
Comment
Code Response
GP-221-1
The commenter wishes to know if their property would be acquired by the City for the 24th Street project. The parcel
acquisitions discussed and illustrated in the R-DEIR and 2013 FEIR/2015 DEIR are “worst-case” parcel acquisitions
intended for purposes of environmental impact analysis. To minimize project costs and community disruption, however,
the City strives to minimize parcel acquisitions, and this issue is continually evaluated during the design phase of the
project. The City may determine during final design that one or more parcel takes or partial parcel takes can be avoided.
Inquiries about specific properties should be addressed directly to the City.
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Response to Comment Letter GP-222
Comment
Code Response
GP-222 Your comments are acknowledged.
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Response to Comment Letter GP-223
Comment
Code Response
GP-223 Your comments are acknowledged.
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Response to Comment Letter GP-224
Comment
Code Response
GP-224-1 The commenter wishes to know why Caltrans was not involved in the R-DEIR. The 2013 FEIR (CEQA) was
decertified but the EA (NEPA) was not decertified, so there are no federal requirements to satisfy, as
explained on page 1 of the R-DEIR (Introduction).
GP-224-2 The commenter asks how Caltrans was involved in the decision not to participate in the R-DEIR. Caltrans
and the City determined that as lead agency under CEQA, the City is responsible for preparation of the
R-DEIR. Caltrans was involved as the lead agency for the EA on the project, which was not decertified, so
the NEPA process for the project is complete.
GP-224-3 The commenter raises several issues, including whether there is a with- and-without cul-de-sacs analysis,
specific impacts on neighborhoods, and supporting documentation. Please see response to Comment GP-228-
6, which addresses this issue.
GP-224-4
The commenter provides information relayed from a town hall meeting regarding motorists using the alleys
to reach their destinations; this information is not sufficient to determine whether this is a substantial traffic
issue. Quantitative information on the frequency with which this occurs, the locations where it occurs, the
times of day, and the conditions under which it occurs is not provided. Master Response No. 20 – Cul-de-
Sacs (Alleys), addresses this issue.
GP-224-5 The commenter questions whether it is safe to merge onto 24th Street. Please see response to Comment No.
GP-224-4.
GP-224-6 The commenter asks why the project is not analyzed using current data. Please see Master Response No. 17 -
Supporting Information for 2013 FEIR/2015 DEIR.
GP-224-7 The commenter questions why the State of California relinquished ownership of 24th Street. Relinquishment
of 24th Street is outside the scope of the R-DEIR. To the City’s knowledge, the project is complying with all
federal and State of California requirements; the commenter did not identify any specific requirements with
which the City is believed to be out of compliance.
GP-224-8 The commenter calls for speculation. There is no credible potential for the State to reassume ownership of
24th Street. The City is not required to address in the R-DEIR future events that are remote or speculative.
GP-224-9
The commenter asks about historic walls on the south side of 24th Street. Historic properties may include
landscaping, walls, and other original character-defining property features. However, none of the DPR 523
forms in the Historic Property Survey Report included walls. The City is not aware of any historic walls, or
in what context a City employee may have mentioned them. Without more specific information on when and
where this information was provided, and by whom, the City can provide no further response.
GP-224-10 The commenter requests “the facts” that the proposed project requires the least amount of right-of-way to
achieve the project’s purpose. The 2013 FEIR/2015 DEIR provides information on the amount of right-of-
way needed for the proposed project and for other alternatives. The R-DEIR updated that information based
on the additional partial parcel acquisitions needed for the construction of six additional cul-de-sacs
GP-224-11
The commenter asks whether the project is evaluated under the same criteria as are the eight potential
alternatives. The proposed project was not re-analyzed or re-evaluated in the R-DEIR, except for the one new
element that was added to the project description – six additional cul-de-sacs on the south side of 24th Street.
The environmental impact analysis of the six cul-de-sacs was added to and integrated with the previous
environmental impact analysis of the project that was presented to the public in the 2012 DEIR. The criteria
described in Section 1.3.6.1 of the R-DEIR are Alternatives Threshold Selection Criteria used to screen
potentially feasible alternatives to the project to identify those alternatives that are appropriate to include in
the EIR; the proposed project is not subject to the Alternatives Threshold Screening Criteria.
GP-224-12
The commenter questions whether the City will fund and maintain the landscaping elements depicted in
Figure 2-18A in the R-DEIR. The R-DEIR depicts the cul-de-sacs as they are described in the Project
Description; the visual elements shown are all part of the project. The purpose of the EIR is to identify the
potential significant impacts of the project. Project implementation, operation, and maintenance are outside
of the scope of the R-DEIR and of CEQA.
GP-224-13
The commenter believes that Alternatives 1 and 2 should be treated as a single project, and requests that the
City conduct a “comprehensive review” of other Caltrans projects. Alternatives 1 and 2 were described in the
2012 DEIR, and were not a topic of the R-DEIR. The issue raised in this comment is outside the scope of the
R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of the R-DEIR.
Also, because the impact of property acquisitions on historic districts is deemed to be one of the potentially
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significant impacts of the project, alternatives that provide the City with a choice – such as impacting only
the historic district to the south or only the historic district to the north – are clearly distinct alternatives
under CEQA.
GP-224-14
The commenter alleges that the City did not comply with a 2008 request of Caltrans concerning 24th Street.
This issue is outside of the scope of the R-DEIR. The City is the lead agency for the project under CEQA,
and in that capacity the City determines the description of its proposed project and the number and nature of
alternatives to be considered in its document. Any request made to the City by Caltrans five years before the
2012 DEIR was published is an issue that clearly was resolved between the City and Caltrans, as Caltrans
was the lead agency for the project under NEPA. Please see Master Response No. 16 – Issues Out of Scope of
the R-DEIR.
GP-224-15 The commenter claims that the City failed to propose legally adequate mitigation measures for the project.
Noise mitigation measures for the proposed project were identified in the 2012 DEIR (Section 2.2.5) and the
2013 FEIR/2015 DEIR. The issue raised in this comment is outside the scope of the R-DEIR. Please see
Master Response No. 16 – Issues Out of Scope of the R-DEIR.
GP-224-16 The commenter asks that the City speculate on the consequences of property owners not agreeing with the
construction of sound walls. Please see response to Comment No. GP-224-15.
GP-224-17 The commenter questions whether the Federal Highway Administration would approve the project without
the sound walls as a mitigation measure. Sound wall mitigation and future federal agency approvals are not
addressed in the R-DEIR, and are out of scope of this document. Please see Master Response No. 16 – Issues
Out of Scope of the R-DEIR. Please also see response to Comment No. GP-224-15.
GP-224-18 The commenter cites text from the original DEIR that was reproduced in the R-DEIR for the purpose of
adding the cul-de-sacs to the Cultural Resources analysis. The information about the Finding of Effect was
originally provided in the 2013 FEIR/2015 DEIR. Please see Master Response No. 16 – Issues Out of Scope
of the R-DEIR.
GP-224-19 The commenter asks whether California’s State Historic Preservation Officer (SHPO) was involved in the R-
DEIR process. As stated in the Executive Summary on page viii of the R-DEIR, the addition to the project of
minor elements (cul-de-sacs) did not trigger a change in the Finding of Effect under Section 106 of the
National Historic Preservation Act. Thus, no action by SHPO was necessary.
GP-224-20 The commenter misunderstood the text of the Executive Summary to say that the cul-de-sacs do not require
additional evaluation. The process referred to is the preparation of a Finding of Effect. Please see response to
Comment No. GP-224-19.
GP-224-21
The commenter believes that the cul-de-sacs have effects on the integrity of the historic district. The original
Finding and the basis on which it was made by a qualified professional historian are described in the 2013
FEIR/2015 DEIR. The effects of the cul-de-sacs on the historic district, also evaluated by a qualified
professional historian, are described in the R-DEIR. No additional documentation is required. The SHPO has
concurred with the findings, satisfying the requirement for evaluation by an independent party. Please see
also Master Responses No. 16 – Issues Out of Scope of the R-DEIR and No. 21 – Cultural Resources.
GP-224-22 The commenter questions whether cul-de-sacs are consistent with the character of the historic district. Please
see Master Response No. 21 – Cultural Resources.
GP-224-23
The commenter alleges that the City has circumvented the State Historic Preservation Officer in the R-DEIR
and requests the location within the Administrative Record of the Memorandum of Agreement (MOA) among
the City, Caltrans, and the State Historic Preservation Officer. The MOA was Item 95 in the Administrative
Record for the 2013 FEIR, and will be included in the Administrative Record for the current FEIR. Please
see also response to Comment No. GP-224-19.
GP-224-24
The commenter questions the effects of the proposed new cul-de-sacs on the historic districts. The adverse
effects of the project on the historic districts to the north and to the south of 24th Street are described in the
2013 FEIR/2015 DEIR (Section 2.1.6), and supplemented in the R-DEIR (Section 2.1.6 of the Errata Sheet
in Appendix A). The facts and assumptions upon which the conclusions of the impact analysis are based are
presented in those sections. In the absence of specific questions about that supporting information, the
analyses of these issues are deemed to be adequate. Please also see Master Response No. 21 – Cultural
Resources.
GP-224-25
The commenter rejects the conclusion that the cul-de-sacs would have no impact on the historic district north
of 24th Street. The issue of the potential impacts of the project on the historic district to the north of 24th St.,
this issue was addressed in the 2013 FEIR/2015 DEIR (Section 2.1.6). The 2012 DEIR concluded on page
180 that the project would have no impacts on the northern district. This topic was not addressed in the
R-DEIR, and is out of the scope for public review of this document. Please see responses to Comments GP-
224-19 and GP—224-21. Please also see Master Response No. 16 – Issues Out of Scope of the R-DEIR.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 265
GP-224-26
The commenter asks for documentation supporting the City’s installation of the cul-de-sacs. As described in
Section 1.3 of the R-DEIR, Policy History of South of 24th Street Cul-de-Sacs, an Initial Study / Negative
Declaration was prepared for installation of the cul-de-sacs. As required under CEQA, that IS/ND was
prepared by the City of Bakersfield’s professional environmental planning staff, publicly noticed in
accordance with CEQA and City requirements, and approved via the City’s normal approval process for
environmental documents.
GP-224-27 The commenter asks at what point studies would expire. Please see Master Response No. 17 – Supporting
Information for 2013 FEIR/2015 DEIR.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 266
Appendix C Responses to Comments on R-DEIR
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Response to Comment Letter GP-225
Comment
Code Response
GP-225-1
The commenter states that using 24th Street as part of the SR-178 freeway is opposed by most Bakersfield civil
engineers. 24th Street is an existing travel corridor, and would not become a freeway with implementation of
the project. A change in the posted speed limit is not part of the project. Traffic-related issues were addressed in
Section 2.1.4, Traffic and Transportation / Pedestrian and Bicycle Facilities, presented in the 2013 FEIR/2015
DEIR, and in the responses to comments (Volume 2: GP-69-12). The analysis did not find that the project
would create a dangerous situation, nor does the commenter provide any substantial evidence to that effect.
Traffic safety was not addressed in the R-DEIR. Please see Master Response No. 16–Issues Out of Scope of the
R-DEIR (Traffic Study).
The City would be responsible for maintaining 24th Street. The commenter does not provide any reasoned
argument or substantial evidence that maintenance of 24th Street would become more difficult or dangerous
than it is at present with implementation of the project. This is a summary comment without specifics. Please
see responses to subsequent Comments GP-225-2.
GP-225-2
The commenter recommends extending the SR-178 freeway through downtown Bakersfield from P Street to
SR-99 below grade. A depressed northeast-to-southwest freeway through downtown Bakersfield would be
similar to Alternative F – Depressed Arterial, but on a different alignment. This alternative would have
environmental, feasibility, and reasonableness constraints greater than those of Alternative F because it would
be a new road through a dense urban core rather than a road expansion through a residential district. This
alternative also might not meet the project objective of substantially reducing traffic congestion on 24th Street
because, while it would account for regional through-traffic on SR-178, 24th Street would still carry local east-
west traffic into and out of downtown Bakersfield.
GP-225-3 The commenter provides a copy of an October 25, 1999 memo on “Planning Bakersfield’s Freeway System.”
Please see response to Comment GP-225-2.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 276
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Response to Comment Letter GP-226
Comment
Code Response
GP-226-1
The commenter asks about the improvement in traffic capacity on 24th Street with the proposed project. Traffic
capacity and circulation were addressed in the 2012 DEIR and 2013 FEIR/2015 DEIR. Traffic congestion was
not addressed in the R-DEIR. Please see Master Response No. 16 - Issues Out of Scope of the R-DEIR (Traffic
Study).
The commenter also requests an evaluation of the effect on 24th Street traffic congestion of altering existing
two-way north-south streets in the 24th Street/23rd Street couplet area to one-way operation. With regard to the
alternative of one-way streets, please see Master Response No. 18 - Alternatives (Alternatives Suggested by
Commenters).
GP-226-2
The commenter asks about the number “(23)” appearing in the text on page 71 of the R-DEIR. That is a
reference to footnote 23, which reads, “Parsons, Hageman Road Extension to Golden State Avenue, Traffic
Report. Volume 1, July 2009.
The commenter questions the information in the Hageman Road Extension to Golden State Avenue Traffic
Report and questions the accuracy of the traffic models. The traffic projections in the Hageman Road
Extension report yield estimates similar to other studies of how much 24th Street traffic would be accounted for
by the Hageman Flyover, as explained in Master Response No. 18 - Alternatives (Hageman Flyover
Alternative) and Master Response No. 17 – Supporting Information for 2013 FEIR/2015 DEIR..
GP-226-3 The commenter asks what studies have been made of vehicle trips to the downtown from the northwest.
Vehicle trips are not a topic of the R-DEIR. Please see Master Response No. 18 - Alternatives (Hageman
Flyover Alternative).
GP-226-4 The commenter asks about whether design standards are being applied consistently. Please see Master
Response No. 18 - Alternatives (Restriping Alternative) for more information on the applicable standards.
GP-226-5
The commenter wants the existing 24th Street compared to the City’s design standards, states that there have
not been any accidents involving a driveway on the north side of 24th Street in 40 years, and questions the need
to purchase homes with driveways that take access from 24th Street. Existing conditions on 24th Street are not
relevant to the evaluation of potentially feasible alternatives presented in the R-DEIR. The discussion of
property acquisitions in the R-DEIR is based on the concept that if a parcel takes its driveway access from 24th
St, that access could create an unsafe situation under the sub-standard design of Alternative I, and the City
should acquire that parcel. Please see Master Response No. 18 - Alternatives (Restriping Alternative).
GP-226-6
The commenter asks whether the individuals who proposed Alternative I were contacted. As explained in
Master Response No. 18 – Alternatives (Restriping Alternative), citizens proposed a restriping alternative with
6 lanes and lane widths matching those of Alternative I; the City provided the other design details. If the
depiction of the alternative in the R-DEIR was not a fair representation of the concept, the remedy available to
those individuals who proposed it would have been to provide comments during the public review period so
that the City could modify the description of the alternative.
GP-226-7
The commenter identifies what are claimed to be inconsistent statements about the Hageman Flyover. The
R-DEIR acknowledges that the Hageman Flyover would result in a minor decrease in traffic volumes on 24th
St. As explained in the R-DEIR, the effects of the Hageman Flyover project are already reflected in the traffic
analysis presented in the 2013 FEIR/2015 DEIR. With that understanding, the statements are consistent. Please
see Master Response No. 18 - Alternatives (Hageman Flyover Alternative).
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 281
GP-226-8 The commenter asks what the cost savings would be if the Hageman Flyover eliminated the need for the
proposed project. Please see response to Comment No. GP-226-7. A discussion of potential cost savings would
be completely speculative because the Hageman Flyover could not eliminate the need for the project. Please
see Master Response No. 18 - Alternatives (Hageman Flyover Alternative).
GP-226-9 The commenter asks why none of the traffic data are peak-hour data. Traffic count data are addressed in
Section 2.1.4 in the 2013 FEIR/2015 DEIR: Traffic and Transportation / Pedestrian and Bicycle Facilities. This
topic is not addressed in the R-DEIR. Please see Master Response No. 16 - Issues Out of Scope of the R-DEIR
(Traffic Study).
GP-226-10 The commenter questions the data in Table 1.4 in the R-DEIR. Please see Master Response No. 17 –
Supporting Information for 2013 FEIR/2015 DEIR.
GP-226-11
The commenter asks when 24th Street was last resurfaced and how often the street is restriped, and also asks
about the “severe crowning” on 24th and 23rd Streets. The current crowning and resurfacing and restriping
history of 24th Street is irrelevant to the evaluation of potentially feasible project alternatives in the R-DEIR.
Such inquiries can be made directly to the City’s Department of Public Works, but no response is required in
the context of the CEQA environmental review.
GP-226-12 The commenter asks whether there has ever been any landscaping on 24th Street. The landscaping history of
24th St. is irrelevant to the evaluation of potentially feasible project alternatives in the R-DEIR. Such inquiries
can be made directly to the City’s Department of Public Works, but no response is required in the context of
the CEQA environmental review.
GP-226-13 The commenter asks whether the alternative would maintain existing left-turn pockets. Please see Master
Response No. 18 - Alternatives (Restriping Alternative).
GP-226-14 The commenter questions the consistency with which design standards are applied. The current designs of
other streets in Bakersfield and other street-widening plans of the City are not topics of discussion in the
R-DEIR. Please see Master Response No. 18 - Alternatives (Restriping Alternative).
GP-226-15
The commenter questions the projected effects of the Hageman Flyover on 24th Street. Please see Master
Response No. 18 - Alternatives (Hageman Flyover Alternative). Because Hageman Flyover is an approved
TRIP project, it was included in the regional traffic model upon which the traffic analysis for the 24th Street
Improvement Project is based. In other words, the future baseline traffic volume numbers for 24th Street
already reflect the beneficial effects of the Hageman Flyover. Please also see Master Response No. 16 - Issues
Out of Scope of the R-DEIR (Traffic Study).
GP-226-16 The commenter asks several questions about existing traffic conditions, traffic projections, and elements of the
project description. Current and future traffic levels of service for Oak Street and 24th Street are provided in the
2013 FEIR/2015 DEIR, and were not revised in the R-DEIR. Please see Master Response No. 16 - Issues Out
of Scope of the R-DEIR (Project Description, Traffic Study).
GP-226-17
The commenter questions why the project would do more to alleviate traffic congestion than would the
Hageman Flyover. The commenter also suggests that eliminating the 24th Street Improvement Project would
save money, and that diverting traffic to another route (offsite alternative) would also eliminate the need for the
proposed project. Finally, the commenter questions the accuracy of population and traffic projections for the
project. Please see Master Response No. 16 - Issues Out of Scope of the R-DEIR (Traffic Study), Master
Response No. 17 – Supporting Information for 2013 FEIR/2015 DEIR, and Master Response No. 18 -
Alternatives (Hageman Flyover Alternative).
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 282
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 283
Response to Comment Letter GP-227
Comment
Code Response
GP-227-1 Your comment is acknowledged.
GP-227-2
The commenter cites the California Supreme Court’s declaration that, “The EIR is the primary means of
achieving the Legislature's considered declaration that it is the policy of this state to ‘take all action necessary to
protect, rehabilitate, and enhance the environmental quality of the state.’” Thus, the City is implementing the
intent of the Legislature in conducting the CEQ review of the proposed project. This general statement of policy
does not require specific project elements such as decorative walls or landscaping.
GP-227-3 Your comment is acknowledged.
GP-227-4 The commenter expresses the belief that a fresh look at the SR-204 / Golden State Highway alternative is
needed. The SR-204 / Golden State Highway alternative was addressed in Master Response No. 1 to the 2013
FEIR/2015 DEIR (Volume 2). Please also see Master Response No. 16 - Issues Out of Scope of the R-DEIR.
Appendix C Responses to Comments on R-DEIR
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Response to Comment Letter GP-228
Comment
Code Response
GP-228-1
The commenter notes that Volume 2 of the 2013 FEIR was not available on line. The R-DEIR document was
available on the City and TRIP websites. The Notice of Availability for the R-DEIR indicated that questions on
this project were to be directed to Janet Wheeler, Public Outreach Manager at the TRIP Office. Printed copies
and CDs of Volume 2 of the 2013 Final EIR/EA were available by request during the public review period of
the R-DEIR. Volume 2 was not available online due to a broken link on the website that occurred when the
City’s new site went online in February 2016. The TRIP website was not included in the roll out of the new
City website. Volume 2 was in a “flipbook” format, which is not supported by the system on the new City
website. Volume 2 has been posted to the City’s old website and will be available on the new TRIP website
when it goes online.
GP-228-2 The commenter questions whether the R-DEIR complies with the Court’s ruling and with the requirements of
CEQA. The City believes that the R-DEIR fully complies with relevant CEQA guidance and with the Court’s
ruling, as detailed in more-specific responses to comments below.
GP-228-3
The commenter claims that the four alternative selection criteria are inconsistent with CEQA and the Court’s
ruling, and that the alternatives screening analysis is flawed. With respect to the alternatives, the City complied
with the Court’s direction to provide more robust explanations about why eight potentially feasible alternatives
were not selected for detailed evaluation in the DEIR. The Court outlined other possible courses of action open
to the City, but refrained from limiting the City’s discretion as lead agency to fulfill its CEQA responsibilities
as it determined to be appropriate. Please see also response to Comment No. GP-228-5.
GP-228-4
The commenter claims the proposed project would fail the four alternatives selection criteria. The Alternatives
Threshold Selection Criteria are intended to assist in screening potentially feasible alternatives to the proposed
project for inclusion in the EIR. They are not applied to the project itself, as the project provides the baseline
for determining which alternatives are feasible and would avoid or substantially lessen any significant effects
of the proposed project. See also Master Response No. 18 – Alternatives (Screening Criteria).
GP-228-5
The commenter claims that the R-DEIR, together with the 2013 FEIR / 2015 DEIR, have failed to consider a
reasonable range of alternatives. The City has considered a wide range of alternatives. The 2012 DEIR and
2013 FEIR/2015 DEIR presented a reasonable range of alternatives. This comment quotes the CEQA
Guidelines requirement for the EIR to present a reasonable range of alternatives, but fails to define, describe, or
illustrate what the commenter believes to be a reasonable range of alternatives. The listing of new potentially
feasible alternatives, as well as alternatives which the City, Caltrans, Kern Council of Governments, or others
have considered and rejected, does not constitute a reasoned argument as to why a particular alternative is
believed to be feasible, specifically how it would substantially fulfill the objectives of the project, or why it is
sufficiently distinct from other alternatives as to be added to the EIR. Please see Master Response No. 18 –
Alternatives.
The commenter also believes the entire 2013 FEIR / 2015 DEIR should have been circulated. However, CEQA
allows just the revised portions of the document to be recirculated.
GP-228-6
The commenter claims that the analysis of the cul-de-sacs in the R-DEIR is flawed, but does not provide
specific examples to support this statement. The City believes that the modest level of consideration given to
the cul-de-sacs is appropriate because these elements of the project generally have only minor or minimal
adverse effects and, according to the CEQA Guidelines Section 15126.2(a), the EIR “shall focus on the
significant environmental effects of the proposed project.”
The commenter suggests that “with-cul-de-sacs” and “without-cul-de-sacs” alternatives are both needed to
have a true understanding of the impacts of the cul-de-sacs. The City believes that the R-DEIR appropriately
describes the impacts of the cul-de-sacs. CEQA defines a project as, “the whole of an action” (CEQA
Guidelines Section 15378) and discourages segmentation or piecemealing of a project for purposes of
environmental impact analysis. The proper comparison under CEQA is between the proposed project (in the
current case, with the cul-de-sacs included) and the baseline conditions (without cul-de-sacs), which does
provide an understanding of their effects.
A “without cul-de-sacs” variant of the proposed project design would be appropriate for consideration only if it
avoided or otherwise mitigated one or more significant impacts of the project. As discussed extensively in the
R-DEIR, the six new cul-de-sacs do not cause or contribute to any of the significant impacts of the project.
Therefore, the “without cul-de-sac” alternative suggested by the commenter is not warranted.
GP-228-7 Your comment is acknowledged. This text restates information from the R-DEIR.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 389
GP-228-8
The commenter claims that the 2013 FEIR/2015 DEIR constrains the project’s purpose. As explained in the
R-DEIR, previous transportation planning documents have considered regional and area demand for mobility.
The EIR for the 24th Street Improvement Project is a project-level document that builds on the results of
previous studies to consider the implementation of a specific element of the regional TRIP program. Please
also see Master Response No. 16 - Issues Out of Scope of the R-DEIR (Traffic Study).
GP-228-9 The commenter observes that the 2013 FEIR / 2015 DEIR does not clearly enumerate the project’s objectives.
The objectives are included in the R-DEIR. Please see Master Response No. 16 - Issues Out of Scope of the
R-DEIR (Project Description).
GP-228-10
The commenter notes that the R-DEIR provides the project objectives. One of the purposes of the R-DEIR was
to screen potentially feasible alternatives for detailed analysis in the EIR. A clear and detailed set of project
objectives aids in that process. The statement of objectives in the R-DEIR is intended to clarify and expand
upon the purpose and need statement provided in the 2013 FEIR/2015 DEIR, which was a joint CEQA/NEPA
document prepared following the adopted Caltrans format.
GP-228-11 The commenter claims that the Alternatives Threshold Selection Criteria apply to the proposed project. Please
see response to Comment No. GP-228-4. Please also see Master Response No. 18 – Alternatives (Selection
Criteria).
GP-228-12
The commenter claims that the use of Level of Service in the traffic study is counter to recent State guidance.
As noted in the comment, the “new thresholds have yet to be finalized.” They are not now a requirement for
determining the adequacy of an EIR. The traffic study for the project was prepared prior to this change in
policy, and was included in the 2012 DEIR and 2013 FEIR/2015 DEIR. Please also see Master Response No.
16 - Issues Out of Scope of the R-DEIR (Traffic Study).
GP-228-13
The commenter claims that the reasons for addressing the eight potentially feasible alternatives were not
provided in the R-DEIR. As explained in Section 1.3.6, the City, Caltrans, and Kern Council of Governments
conducted a lengthy and exhaustive evaluation of a wide range of potential alternatives, and concluded that
(page 24 of the R-DEIR), “This comprehensive and extensive project development process led to the
refinement of a limited set of alternatives that represented the most viable candidates for consideration in the
Draft Environmental Impact Report / Environmental Assessment (May 2012) [emphasis added].” (Page 24 of
the R-DEIR). The engineering feasibility and traffic effects of these alternatives had been evaluated in detail,
preliminary environmental reviews had been completed for them, and preliminary cost estimates had been
prepared. It is entirely appropriate that the EIR for the project explain to the public why, following this
extensive evaluation, these alternatives were not further analyzed in the 2012 DEIR.
GP-228-14
The commenter claims that “The R-DEIR fails to explain why only two of the numerous alternatives presented
to the City during the EIR process are addressed in the R-DEIR.” As stated in Section 1.3.6 in Chapter 3 of the
R-DEIR, “Two alternative scenarios suggested by the Petitioner that expanded the range of alternatives
were added to this Recirculated Draft Environmental Impact Report for further analysis [emphasis added].”
Thus, other alternatives that had been suggested were deemed not to expand the range of alternatives. Hybrid
alternatives that included Hageman Flyover clearly would not achieve project objectives because, as explained
in the R-DEIR and further explained in Master Response No. 18 - Alternatives (Hageman Flyover Alternative)
– the Hageman Flyover project is already accounted for in the future baseline traffic volumes and thus would
not further reduce them, rendering any such hybrid alternatives clearly infeasible. TSM and TDM alternatives
were addressed in the 2012 DEIR and 2013 FEIR/2015 DEIR and, to the extent reasonable, were incorporated
into the proposed project.
GP-228-15
The commenter claims that the City has misstated the Court’s discussions as affirmative direction. The
commenter quotes a statement from page 22 of the Court transcript from the preliminary hearing on the petition
for writ held on May 1, 2015, and erroneously presents this statement as a requirement of the Court. In a
preamble to this quoted language, the judge clarifies in the previous paragraph, “[A]nd this is not a mandate,
but this is how the Court would suggest the Respondents would likely need to proceed.” (5/1/15 transcript,
pages 21-22.) Moreover, during the further hearing on the writ held on July 10, 2015, the Court indicated that,
“[T]he Court is unable to speculate or make any assumptions as to what potentially feasible alternatives will, in
fact, finally be discussed and analyzed in any future CEQA documents….” (7/10/15 transcript, pages 6-7.) The
commenter misconstrues preliminary discussions involving suggestions and speculation by the Court as
“requirements.” The Court also allows the City discretion in presenting this information.
GP-228-16
The commenter notes that no alternatives were proposed for Segments 1 or 4 of the project alignment. The
alternatives proposed by citizens were determined to be infeasible for reasons other than their potential
environmental effects. The overall project alignment was presented in terms of 4 segments only for
convenience of description. There is no requirement under CEQA that an alternative be considered for each
and every project feature. Project alternatives should be focused on attaining the objectives of the project as a
whole and reducing one or more potentially significant impact of the project, not on accounting for each piece
of the alignment.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 390
GP-228-17 The commenter misconstrues this general discussion by the Court of the alternatives development process as
“direction.” The Court subsequently applies these general principles to the particular facts of the current case to
determine whether the Petitioner’s claims have merit. Please also see response to Comment No. GP-228-15.
GP-228-18
The commenter claims that the R-DEIR applies the environmental screening criterion inappropriately. The
R-DEIR’s statement of Criterion #1 was applied in the context of potentially significant environmental effects.
Criterion #1 was phrased to acknowledge the reality that potential alternatives often reduce or avoid one or
more potentially significant impacts while creating or exacerbating others that affect different resources to
different degrees. In these more typical scenarios, the City must evaluate tradeoffs among diverse beneficial
and adverse effects and render a judgment about the overall merits of the alternative. To do otherwise would
merely shift environmental impacts from one resource to another.
The commenter concludes that, “By excluding alternatives that may reduce one or more significant impacts …
the R-DEIR keeps the City’s decision makers from complying with their duty to minimize environmental
damage ...” However, the commenter fails to identify a single alternative that actually was inappropriately
rejected due to the application of Criterion #1. The two citizen-recommended potential alternatives evaluated in
the R-DEIR were both determined to reduce one or more potentially significant impacts of the project.
GP-228-19
The commenter claims that an a priori weighting of project objectives conflicts with the CEQA Guidelines.
Nowhere do the CEQA Guidelines indicate, however, that lead agencies may not assign different weights to
competing objectives. Where more than one objective exists, lead agencies must balance the accomplishment
of one or more objectives against the fulfillment of others. Disclosing to the public one consideration in this
balancing process is clearly consistent with CEQA’s intent that the agency decision-making process be as open
as possible.
The commenter also claims that the prioritization of project objectives supplants the judgment of the lead
agency (City Council) for the judgment of the lead agency’s (City) staff. Prior to its review by the City
Council, the entire R-DEIR represents the professional judgment of the City staff, as informed by its long
association with and work for the City Council. The City Council must certify the Final EIR prior to approval
of the project. If the City Council disagrees with any of the information in the R-DEIR, it may decline to
certify it and direct City staff to make appropriate revisions.
GP-228-20
The commenter claims that the R-DEIR develops its own definition of feasibility. However, the R-DEIR
merely expands upon the CEQA definition of feasibility and incorporates specifics that can be applied to the
project. Section 15126.6(f)(1) of the CEQA Guidelines provides the following guidance regarding feasibility:
Among the factors that may be taken into account when addressing the feasibility of alternatives are site
suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory
limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional
context), and whether the proponent can reasonably acquire, control or otherwise have access to the alternative
site (or the site is already owned by the proponent)
The commenter misstates the R-DEIR’s definition of economic feasibility by omitting the actual statement of
the criterion. The first sentence under Economic Infeasibility on page 29 of the R-DEIR states, “The alternative
would be [economically infeasible if it was] so costly that implementation would be prohibitive, or the relative
costs are such that implementation would be imprudent.” The remainder of the paragraph describes the funding
sources for the project and the effects of any increased costs on the City’s finances.
GP-228-21
The commenter claims that “environmental feasibility” is a form of double-counting of the environmental
effects of an alternative. However, Section 15364 of the CEQA Guidelines defines feasibility as “capable of
being accomplished in a successful manner within a reasonable period of time, taking into account economic,
environmental, legal, social, and technological factors [emphasis added].” Thus the City’s consideration of
environmental feasibility – a consideration that is broader than the narrow consideration of significant impacts
under Criterion #1 – is entirely consistent with CEQA.
GP-228-22
The commenter cites CEQA’s “rule of reason” in questioning the R-DEIR’s Criterion #4 – Reasonableness.
The commenter thus confuses the “rule of reason,” as applied to the range of alternatives to be presented in the
EIR, with “reasonableness” as it pertains to the screening of potentially feasible alternatives. The guidance of
“reasonable alternatives selected to foster informed decision making and public participation” pertains to the
range of alternatives, not to their individual feasibility. The commenter acknowledges that the R-DEIR
definition “mirrors, in part, the Court’s and CEQA Guidelines definition.” The R-DEIR adds the concept of
providing a public benefit at a higher cost because – as a public agency – the City has a fiduciary duty to spend
public funds responsibly. The R-DEIR adds the concept of public safety because the City should not analyze in
the EIR an alternative that the City could not approve or implement due to serious public safety concerns.
GP-228-23
The commenter claims that the City modified standard alternatives selection criteria to increase the probability
that potential alternatives would be eliminated. The City augmented the basic definitions of the selection
criteria to improve their clarity and applicability to local conditions and the particular type of project being
considered. The R-DEIR provides thorough explanations of the decision processes through which the City
determined whether or not the potentially feasible alternatives should be included in the EIR.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 391
GP-228-24 The commenter notes that none of the potential alternatives passed all four screening criteria. Please see
response to Comment No. GP-228-5 and No. GP-228-23. The commenter refers to “standard classes of
alternatives” and quotes a Federal Highway Administration guidebook rather than identify the exact issues to
be addressed, as required by CEQA.
GP-228-25 The commenter claims that the R-DEIR inappropriately fails to identify alternatives to the proposed project. A
reasonable range of alternatives have been considered over the course of environmental review process for this
project. Please see response to Comment No. GP-228-5 and Master Response No. 18 – Alternatives.
GP-228-26 The commenter claims that the R-DEIR incorrectly eliminated Alternative I – Restriping Alternative. This is a
summary statement that is broken out into individual comments below. Please refer to responses to Comments
GP-228-27 to GP-228-73. Please also see Master Response No. 18 – Alternatives (Restriping Alternative).
GP-228-27 The commenter objects to the text written in the first paragraph under Alternative I – Restriping Alternative.
The text of the first paragraph under Alternative I has been revised.
GP-228-28 The commenter claims that no substantial evidence was provided that Alternative I does not meet design
standards. Please see Master Response No. 18 - Alternatives (Restriping Alternative).
GP-228-29 The commenter claims that no substantial evidence was provided that projects using federal funds must comply
with specified design standards. Please see Master Response No. 18 - Alternatives (Restriping Alternative).
GP-228-30 The commenter notes that the R-DEIR incorrectly states that 24th Street is described in the Circulation Element
to the Metropolitan General Plan as a “major arterial.” The commenter is correct; 24th Street is classified in the
General Plan Circulation Element as an Arterial. The R-DEIR text will be revised to reflect the correct
classification.
GP-228-31 The commenter observes that the standard 110-foot right-of-way in Bakersfield is taken from the Circulation
Element of the Metropolitan Bakersfield General Plan, and asks that this source be noted in the FEIR. This
information will be added to the FEIR. Please also see Master Response No. 18 – Alternatives (Restriping
Alternative).
GP-228-32 The commenter requests that a citation be provided for raised median and sidewalk requirements. The
standards for medians are drawn from the City of Bakersfield’s Subdivision and Engineering Manual. Please
see Master Response No. 18 – Alternatives (Restriping Alternative).
GP-228-33 The commenter requests that a citation be provided for the City’s design standards, and that the City explain its
choice of lane widths for the Restriping Alternative. The explanation for the choice of lane widths and the
citations to design standards are both provided in Master Response No. 18 – Alternatives (Restriping
Alternative).
GP-228-34
The commenter requests an explanation for the inclusion of a median in Alternative I – Restriping Alternative
and for the choice of a striped median rather than a raised median. The highway design criteria include a
median; the existing median on 24th Street is about 10.5 feet wide. According to City of Bakersfield’s
Subdivision & Engineering Manual, the appropriate median for an arterial such as 24th Street is 14 feet wide.
When choosing between a two-foot-wide raised median and a striped median, the striped median is safer.
A two-foot-wide raised median is unsafe except when used for separating the left-turn lane from the opposing
lane. Even then, a wider median nose is desirable. Traffic on 24th Street is assumed to travel at the speed limit
of 40 miles per hour. A two-foot-wide raised median would be of concern because vehicles could ride up onto
it and be thrown off course. With the striped median, the City would likely install vertical stanchions to
separate the traffic and to prevent unlawful left turn movements.
GP-228-35 The commenter requests that the driveway and alley issues associated with the Restriping Alternative be
compared to those of the proposed project. The impacts of the Restriping Alternative are evaluated relative to
those of the proposed project. Please see Master Response No. 18 - Alternatives (Restriping Alternative).
GP-228-36
The commenter questions whether driveways along 24th Street could be reconfigured to allow vehicles to turn
around (e.g., hammerhead driveways). The commenter also requests that the locations where driveways would
create a potential conflict with traffic on 24th Street be identified. These issues are addressed in Master
Response No. 18 - Alternatives (Restriping Alternative).
Finally, the commenter asks whether the affected properties could be granted a variance from off-street parking
requirements. Both the requesting and the granting of such a variance are speculative. Loss of off-street
parking would probably lower the property value and the owner may prefer to have the City purchase the
property, and the City may be reluctant to grant multiple variances from parking requirements in the same area.
GP-228-37 The commenter requests that the R-DEIR address whether narrow lanes improve traffic capacity. While some
studies appear to suggest that this is the case, the City believes that narrower lanes prompt drivers to be more
cautious, slowing down and decreasing hourly lane capacity. Please also see Master Response No. 18 -
Alternatives (Restriping Alternative).
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 392
GP-228-38 The commenter claims that 11-foot wide lanes are safer than 12-foot wide lanes, and requests that this issue be
addressed in the R-DEIR. Please see response to GP-228-39 and Master Response No. 18 - Alternatives
(Restriping Alternative).
GP-228-39
The commenter claims that the City has not supported its statements that the Restriping Alternative would
increase the potential for head-on crashes. Narrower lanes, in addition to a narrower median, move opposing
lanes of traffic closer together, and this increases the potential for a head-on collision. Narrower lanes, plus a
narrower median, reduce the space within which a driver can maneuver to avoid a collision. Narrower lanes
also limit the driver’s line of sight, especially on curves and at taper points, giving a driver less advance
warning of an impending collision. Please also see Master Response No. 18 - Alternatives (Restriping
Alternative).
GP-228-40 The commenter questions whether a narrow, raised median rather than a striped median would prevent illegal
left-hand turns into side streets along 24th Street. Please see response to Comment GP-228-34.
The commenter also requests that the R-DEIR address whether eliminating left-turn lanes would increase
capacity. Please see Master Response No. 18 - Alternatives (Restriping Alternative).
GP-228-41 The commenter questions whether the City has provided sufficient support for its statement that the Restriping
Alternative would reduce lines of sight below acceptable levels. Please see Master Response No. 18 -
Alternatives (Restriping Alternative).
GP-228-42
The commenter claims that the City has not provided “substantial evidence” that large service vehicles such as
trash trucks would need to occupy the two outside lanes on 24th Street to turn into an alley. Because of their
greater width and length, over-sized service vehicles generally have a larger turning radius than most passenger
vehicles, while the narrower outside lane reduces the space available for turning, increasing the potential for
such vehicles to encroach into the adjoining lane while turning into an alley. Please see Master Response No.
18 - Alternatives (Restriping Alternative).
The commenter also requests that the R-DEIR identify the locations where these events would occur; these
locations would be any alley off of 24th Street in the area to be restriped.
Finally, the commenter asks whether this issue could be avoided by limiting the cul-de-sacs. However, no cul-
de-sacs are proposed under the Restriping Alternative.
GP-228-43
The commenter questions whether the 10.5-foot difference between the existing 72-foot street and the 82.5-
foot wide right of way could be used to meet Americans with Disabilities Act (ADA) requirements for
sidewalks in the Restriping Alternative. While the existing road is only 72 feet wide, the Restriping Alternative
is based upon the 82.5-foot right of way. These dimensions are explained both in the R-DEIR and in Master
Response No. 18 - Alternatives (Restriping Alternative).
The commenter requests the locations where the sidewalk standards would not be met. As indicated in the R-
DEIR, the City’s sidewalk standards would generally not be met. The width available for sidewalks along the
south side of 24th Street is generally 3.5 feet, whereas the ADA standard is 4 feet and the City design standard
is 6 feet. Figure 20 in Master Response No. 18 – Alternatives (Restriping Alternative) illustrates where City-
standard 6-foot sidewalks would encroach into the existing right-of-way. Acquiring 2 feet of right-of-way on
the south side of 24th Street would allow for compliance with ADA standards while acquiring 2.5 feet would
allow compliance with City standards.
GP-228-44
The commenter requests information about potential conflicts between sound walls and sidewalks in the
Restriping Alternative. The proposed Restriping Alternative has been generally defined, based upon input from
citizens, for purposes of preliminary CEQA evaluation. The R-DEIR notes that the constraints of building
within the existing 82.5-foot right-of-way could create design conflicts and tradeoffs that would not arise with
the proposed project, which would have a much wider right of way. Potential conflicts between the placement
of sound walls and sidewalks in this constrained context are an example of the types of tradeoffs to be
expected. Limited right-of-way acquisitions could alleviate such conflicts (see response to Comment GP-228-
43). Please also Master Response No. 18 - Alternatives (Restriping Alternative).
GP-228-45 The commenter asks that the R-DEIR identify locations where the narrow right-of-way would require trade-
offs with line-of-sight requirements and sound wall placement. Line of sight issues are discussed in Master
Response No. 18 - Alternatives (Restriping Alternative) and illustrated in Figure 20.
GP-228-46 The commenter requests that the R-DEIR explain why 12 full parcels would need to be acquired for this
alternative. The parcel acquisitions are addressed in Master Response No. 18 – Alternatives (Restriping
Alternative) and the parcels that would need to be acquired are shown in Figure 20.
GP-228-47 Please see response to Comment No. GP-228-46.
GP-228-48 The commenter requests more information on the impacts of the Restriping Alternative on visual and aesthetic
resources. The proposed project is the appropriate basis of comparison for the alternative. Under Criterion #1,
the consideration is whether the alternative would avoid one or more potentially significant impacts of the
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 393
project. Alternative I could not provide the landscaping that would be included in the proposed project because
the right-of-way would be much narrower. The lack of landscaping would result in greater adverse aesthetic
impacts than the proposed project. Consequently, Alternative 1 would not avoid or minimize significant
impacts on aesthetic resources. A more-detailed analysis is not needed to make this determination.
GP-228-49
The commenter requests additional information on the impacts of the Restriping Alternative on historic
resources. As explained in Master Response No. 21 – Cultural Resources, the basis for the eligibility of the
historic district to the south of 24th Street is the architectural features of the residential structures. Both the
Restriping Alternative and the proposed project would involve minor takes of land along the edges of the
affected parcels;
As discussed in R-DEIR Section 1.3.6.5, Citizen-Suggested Alternatives, Alternative I – Restriping Alternative
would require full 12 parcel acquisitions; six of these are considered to be National Register-eligible
contributors to the historic districts located north and south of 24th Street, whereas the proposed project would
require thirteen full parcel acquisitions from contributors the north and south of 24th Street historic districts
combined. Therefore, as discussed, Alternative I - Restriping Alternative would have less severe impacts on
historical resources than that of the proposed project. Because the right of way acquisition impacts from
Alternative I – Restriping Alternative on contributors to the historic district south of 24th Street would be
reduced from seven to one, it may also result in a Finding of No Adverse Effect under Section 106 of the
National Historic Preservation Act. That formal determination, however, has not yet been made. As for the
historic district north of 24th Street, both Alternative I – Restriping Alternative and the proposed project would
require full acquisition of the same number of National Register-eligible contributors.
As explained on page viii in the Executive Summary of the R-DEIR, additional consultation with SHPO is not
required.
GP-228-50
The commenter requests more information on the impacts of the Restriping Alternative on air quality. The
level of quantitative analysis necessary to determine whether an air quality standard would be violated is not
necessary to support the conclusion that air quality impacts of this alternative would be greater than those of
the project. It is sufficient to observe that air pollutant concentrations decrease rapidly (at a geometric rate)
with increasing distance from their sources and the Restriping Alternative would move cars in the outside lane
roughly 5 feet closer to the edge of the right-of-way than for a road that met all design standards. Because the
proposed project would yield more right-of-way than needed, however, additional landscaping would be
provided over and above basic requirements, further separating 24th Street residences from air pollutants
emitted by 24th Street traffic.
GP-228-51 The commenter notes that Alternative I meets Criterion #1, as stated in the R-DEIR.
GP-228-52 The commenter summarizes the discussion of Alternative I – Restriping Alternative in the R-DEIR, and claims
to have refuted many of its assumptions about safety. Please refer to Master Response No. 18 - Alternatives
(Restriping Alternative).
GP-228-53 The commenter correctly states information from the R-DEIR about Alternative I.
GP-228-54 The commenter questions whether the R-DEIR provides sufficient support for its statement that the Restriping
Alternative would not meet City design standards. Please see Master Response No. 18 - Alternatives
(Restriping Alternative).
GP-228-55
The commenter requests the full citation for “Federal Highway Administration 2004,” and notes that there is
conflicting information on the effects of lane width on safety and other aspects of motor vehicle traffic. The
City and Caltrans continue to adhere to Federal Highway Administration policy, which indicates that, for low-
speed arterial roads, narrower lanes are associated with increased sideswipe crashes, reduced free-flow speeds,
and large vehicles off-tracking into adjacent lanes or shoulders. Higher speeds are associated within an
increased potential for head-on crashes (Federal Highway Administration 2016
http://safety.fhwa.dot.gov/geometric/pubs/ mitigation strategies/chapter3/3_lanewidth.cfm). Please also see
Master Response No. 18 - Alternatives (Restriping Alternative).
GP-228-56
The commenter requests that the City explain what constitutes a “proper” median and why a two-foot striped
median would be insufficient. What the City considers to be a “proper” median is indicated in the text on page
63 of the R-DEIR, which states, “Atwo-foot-wide striped median would provide the separation between
opposing lanes of traffic in place of a standard 14-foot-wide raised median.” Please see Master Response No.
18 - Alternatives (Restriping Alternative) for an explanation of the shortcomings of a two-foot wide median.
The commenter also claims that 24th Street currently lacks a median. The City observes that the existing
opposing traffic is separated by a +10-foot center turn lane which is striped but not raised.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 394
GP-228-57 The commenter requests support for the statement that the line of sight of drivers in the outside lanes would be
restricted. Narrower lanes bring cars in adjacent lanes closer together and narrow the spaces between rows of
cars, foreshortening the driver’s view down the road. Please also see Master Response No. 18 - Alternatives
(Restriping Alternative).
GP-228-58
The commenter claims that “no explanation” is given as to why a shoulder cannot be provided in the Restriping
Alternative. The R-DEIR lays out the dimensions of the roadway within the 82.5-foot right-of-way, and those
dimensions make it clear that there is only space for a 2-foot shoulder. With regard to turning onto and off of
24th Street, the current 16-foot to 17-foot outside lane (travel lane plus shoulder) allows for vehicles to use the
shoulder for entering and exiting 24th Street whereas the Restriping Alternative would require vehicles to pull
directly into traffic when entering and not allow vehicles to pull out of traffic when exiting 24th Street. Please
see Master Response No. 18 - Alternatives (Restriping Alternative).
GP-228-59 The commenter alleges “no substantial evidence” has been provided that the 13-foot outside lane would not
function as an 11-foot wide lane and a 2-foot wide shoulder. The City cannot provide “substantial evidence”
for a statement that was not made in the R-DEIR. Please see Master Response No. 18 - Alternatives (Restriping
Alternative).
GP-228-60 The commenter claims “no substantial evidence” was provided to support the need to eliminate driveways
along 24th Street under the Restriping Alternative or the manner in which trash pickups and other services
could become more hazardous. Please see Master Response No. 18 - Alternatives (Restriping Alternative).
GP-228-61
The commenter requests information on where the sidewalk would be narrower under the Restriping
Alternative. Figure 20 shows the locations of and widths of the sidewalks under this potential alternative. The
section of R-DEIR text quoted by the commenter does not address the width of the sidewalk, however, but the
distance between pedestrians on the sidewalk and vehicles in the outside travel lane. Please see Master
Response No. 18 - Alternatives (Restriping Alternative).
GP-228-62 The commenter concludes that Alternative I – Restriping Alternative meets Objective 1b (safety). The City
disagrees with this conclusion. Please see Master Response No. 18 - Alternatives (Restriping Alternative).
GP-228-63 The commenter observes that Alternative I would be superior to the project in terms of meeting some of the
project’s objectives. The Draft R-DEIR acknowledges that Alternative I would be superior in this regard.
GP-228-64 See response to Comment GP-228-63.
GP-228-65
The commenter alleges that the Restriping Alternative meets the project objective for safety. The City
disagrees. As stated on page 28 of the Draft R-DEIR under Criterion #2, the issue of safety is paramount, and
clearly outweighs considerations related to historic districts and cost-effectiveness of an alternative. Safety
concerns also outweigh the ability of the alternative to achieve the desired level of future traffic relief. This
concern is supported by substantial evidence in the technical literature indicating a high potential for head-on
collisions and increased risk of other types of accidents within the 24th Street corridor. Please see Master
Response No. 18 – Alternatives (Restriping Alternative).
GP-228-66 The commenter claims that Alternative I would meet most of the project’s objectives. Please see response to
Comments No. GP-228-47, GP-228-48, and GP-228-49.
GP-228-67 The commenter argues that an alternative that meets one of the two basic objectives of the project meets
“most” of the basic project objectives. As stated in the R-DEIR, City staff believe that the safety issues raised
by the alternative outweigh its consistency with the other basic objective (traffic congestion relief) and its
consistency with secondary objectives.
GP-228-68
The commenter claims a lack of substantial evidence in support of a summary statement about the social and
technical feasibility of the Restriping Alternative. The design deficiencies leading to a conclusion that the
alternative was not technically feasible are explained in the R-DEIR, and Master Response No. 18 -
Alternatives (Restriping Alternative), supplements that discussion. A reasoned argument on this issue provided
by qualified engineers, supported by factual information constitutes substantial evidence.
The determination that the alternative was socially infeasible is made on page 67 of the R-DEIR, based on the
combined issues of safety, parcel acquisitions, and limits on community services. Master Response No. 18 -
Alternatives (Restriping Alternative), provides additional information on the effects of this alternative on the
safety of turning movements onto and off of 24th Street, the rationale for the parcel acquisitions, and ways in
which community services are compromised.
GP-228-69 The commenter claims a lack of substantial evidence to support the statement in the R-DEIR that the design of
24th Street must adhere to certain mandatory design standards. This issue is addressed in Master Response No.
18 - Alternatives (Restriping Alternative).
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 395
GP-228-70
The commenter notes that the Restriping Alternative would be socially feasible on the basis of the number of
required full parcel takes. The Draft R-DEIR acknowledges that Alternative I would be superior in this regard.
The commenter then compares the impacts of the Restriping Alternative with those of the proposed project and
concludes that, ”these same criticisms would apply to the project.” The City disagrees – both turning
movements and operation of service vehicles (e.g., trash trucks) would be more hazardous under the Restriping
Alternative due to the narrower lanes and lack of shoulder.
Finally, the commenter suggests that the proposed project could be screened out based on the Alternatives
Threshold Selection Criteria. Please refer to Master Response No. 18 – Alternatives for this issue.
GP-228-71
The commenter claims a lack of “substantial evidence” to support the R-DEIR’s evaluation of the Restriping
Alternative. The City believes otherwise, that the R-DEIR provides sufficient relevant information to support
its conclusions about the Restriping Alternative. The CEQA Guidelines (Section 15384) define “substantial
evidence” as (a) “enough relevant information and reasonable inferences from this information that a fair
argument can be made to support a conclusion,” and (b) “facts, reasonable assumptions predicated upon facts,
and expert opinion supported by facts.” These constitute “substantial evidence” even if “other conclusions
might also be reached.”
The evaluation of the Restriping Alternative in the R-DEIR consists of reasonable inferences and professional
opinions of registered engineers and other professionals. These inferences and opinions are supported by facts
such as the existing and proposed roadway dimensions, the available right-of-way, and other design details, as
well as vehicle speeds and traffic volumes. They are also supported by reasonable assumptions, such as that a
motorist would decelerate prior to turning off of 24th Street or accelerate into traffic upon turning onto 24th
Street, and that other vehicles would need to adjust their speeds accordingly. Together, these facts,
assumptions, reasonable inferences, and professional opinions constitute fair arguments that strongly support
the conclusions about the Restriping Alternative that are presented in the R-DEIR.
The commenter also claims that the Restriping Alternative could qualify for design exceptions and thus meet
Criterion #3 for technical feasibility. According to the CEQA Guidelines (Section 15364), among the factors
that “may be” taken into account when addressing the potential feasibility of an alternative are “… general plan
consistency, other regulatory limitations …” The design standards expressed in the City’s Circulation Element
(part of the Metropolitan Bakersfield General Plan) thus are relevant. An alternative that is substantially
inconsistent with the City’s design standards is deemed to be infeasible (remote and speculative) because there
is no assurance that an alternative that deviates substantially from the City’s design standards, as well as State
and federal design standards, which this alternative clearly does, would ultimately receive the appropriate
waivers and exceptions and thus be successfully implemented. The City’s traffic engineering staff believe that
it would not, as stated in Master Response No. 18 – Alternatives (Restriping Alternative).
GP-228-72
The commenter claims a lack of supporting information for the City’s evaluation of the reasonableness of
Alternative I – Restriping Alternative. This discussion of “reasonableness” draws information from the
discussion of other criteria, primarily on the topics of safety and feasibility; the support for the statements
found here is provided under Criteria #2 and #3. Note that the text here states, “… as indicated above …”The
City does not believe it is necessary to repeat that information under the Criterion #4 heading, but will add
cross-references to the text for clarity.
GP-228-73
The commenter asserts that the Restriping Alternative meets all four alternative selection criteria, based on a
lack of substantial evidence to support the conclusions reached in the R-DEIR; As discussed in the R-DEIR, in
Master Response No. 18 - Alternatives (Restriping Alternative), and responses to Comments GP-228-68, GP-
228-69, GP-228-71, among other responses, the City has provided a sufficient rationale for determining that
the Restriping Alternative does not meet all four criteria.
GP-228-74 The commenter requests information on when the Hageman Flyover project would be implemented. The
Hageman Flyover project is at 65% design. However, no funding source has been confirmed. No definite
construction schedule is known.
GP-228-75 The commenter finds the references to the Hageman Flyover as the “planned project” confusing. The text will
be revised to make the status of the alternative clearer.
GP-228-76 The commenter concludes that the Hageman Flyover would provide “traffic movements” similar to those of the
proposed project. Please see Master Response No. 22- Hageman Flyover Alternative. This alternative would
not provide a traffic benefit similar to that of the proposed project.
GP-228-77 The commenter recommends building the Hageman Flyover and then assessing whether the 24th Street
Improvements are still needed. The discussion of Alternative J in the R-DEIR explains why building the
project instead of the Hageman Flyover achieves the project’s objectives. Please also see Master Response No.
18 – Alternatives (Hageman Flyover Alternative).
GP-228-78 The commenter recommends a new alternative that would include improvements to SR-204 along with
implementation of the Hageman Flyover. Please see Master Response No. 18 - Alternatives (Hageman Flyover
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 396
Alternative). The Hageman Flyover is an approved TRIP project, so it was included in the regional traffic
model upon which the traffic analysis for the project is based. In other words, the benefits of implementing the
Hageman Flyover are already reflected in the future No Project traffic volumes along 24th Street. Therefore, in
terms of relieving future traffic congestion along 24th Street, the Hageman Flyover would have no effect.
The effects of such a hybrid alternative would thus rest solely upon improvements to SR-204. SR-204, as an
alternative, was addressed in Master Response No. 1 to the 2013 FEIR/2015 DEIR, Consideration of
Improvements to State Route 204 Instead of the Proposed 24th Street Improvement Project (Consideration of
State Route-204 as an Avoidance Alternative Under Section 4(f)). No further evaluation of a potential SR-204
alternative is required or warranted.
GP-228-79 The commenter notes that studies cited in the R-DEIR are 14 – 30 years old. Please see Master Response No.
17 - Supporting Information for 2013 FEIR/2015 DEIR.
GP-228-80
The commenter concludes that the Hageman Flyover alternative is superior to the proposed project on
environmental issues. The text of the R-DEIR acknowledges that Hageman Flyover, as an off-site alternative,
would avoid some of the potential environmental impacts of the proposed project. The Hageman Flyover
would not achieve the primary objective of the proposed project – relieving existing traffic congestion on 24th
Street in the corridor from west of State Route 99 to east of M Street, while also providing the roadway
capacity necessary to handle the future traffic volumes anticipated by the growth in population and
employment through 2035.
GP-228-81
The commenter questions the significance of the visual impacts of the Hageman Flyover. At the screening level
of evaluation appropriate for identifying potential alternatives to include in the EIR, the relevant issue is
whether the alternative would avoid, reduce, or offset one or more potentially significant impacts of the
proposed project. The visual impacts of the Hageman Flyover would be more adverse than those of the
proposed project, as stated in the R-DEIR, so this alternative clearly would not avoid, reduce, or offset the
visual impacts of the proposed project. No additional evaluation of its effects on visual resources is necessary.
GP-228-82
The commenter observes that Alternative I would have fewer impacts than the proposed project on some
environmental resources. The text of the R-DEIR acknowledges that Hageman Flyover, as an off-site
alternative, would have lesser environmental impacts on historic districts than the proposed project. The
Hageman Flyover would not achieve the primary purpose of the proposed project – relieve existing traffic
congestion on 24th Street in the corridor from west of State Route 99 to east of M Street, while also providing
the roadway capacity necessary to handle the future traffic volumes anticipated by the growth in population
and employment through 2035.
GP-228-83
The commenter claims that the R-DEIR does not provide information to support its determinations about
habitat value. At the screening level of evaluation appropriate for identifying potential alternatives to include in
the R-DEIR, no rigorous evaluation of the relative habitat values of the proposed project alignment and
Hageman Flyover alternative alignment were prepared. The City believes that this level of effort is unnecessary
to determine which alignment has the greater potential effects on native wildlife. In a 2006 Defenders of
Wildlife article entitled “Habitat in Agricultural Landscapes: How Much is Enough? A State-of the Science
Literature Review,” author Kristen Blann writes that,
“Agricultural lands in many cases provide more suitable habitats for native wildlife and birds than do
fragmented and extensively modified urban or suburban lands. Such lands often serve as a buffer
between natural areas and more highly altered landscapes, providing food, cover, and breeding habitat,
enabling movement and exchange of plant and animal populations.”
Any number of additional literature sources can be cited as it is generally understood by professional biologists
that agricultural landscapes retain more of their original wildlife habitat value than do more highly modified
suburban residential areas.
GP-228-84 The commenter disagrees with the City’s evaluation of the Hageman Flyover alternative. The Hageman
Flyover is not capable of achieving the primary objective of the project, as explained both in the R-DEIR and
in Master Response No. 18 - Alternatives (Hageman Flyover Alternative).
GP-228-85 The commenter questions the supporting information for the R-DEIR’s conclusion that the Hageman Flyover
Alternative would not meet the basic project objectives. Please see Master Response No. 18 - Alternatives
(Hageman Flyover Alternative).
GP-228-86
The commenter offers definitions of objectives, goals, and strategies. The Regional Transportation Plan
identifies specific improvements (projects) that are intended to achieve regional transportation goals. Specific
projects such as the 24th Street Improvements Project are thus RTP objectives, as that term is defined in the
comment. The 24th Street Improvements Project and Hageman Flyover are not competing strategies; they are
complementary improvement plans that – together – are considered necessary to achieve regional
transportation goals.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 397
GP-228-87
The commenter draws an erroneous conclusion from the information provided in the R-DEIR and quoted in the
comment. The Hageman Flyover does not serve the same purpose as does the 24th Street Improvements
Project. The Hageman Flyover serves a complementary purpose in the regional transportation network, and its
effects on traffic volumes on 24th Street are a minor side effect of its implementation, not its primary purpose
or effect. A 13-percent reduction in vehicle volumes on 24th Street is not “substantial evidence” that this
alternative could achieve the project objectives. Instead, this minor reduction in traffic volumes is substantial
evidence that the Hageman Flyover could not achieve the project’s objectives.
GP-228-88 The commenter does not agree with the statement in the R-DEIR that the Hageman Flyover would be an
indirect route that would add about 3 miles to the average trip. Please see Master Response No. 18 -
Alternatives (Hageman Flyover Alternative).
GP-228-89
The commenter asserts that if the Hageman Flyover Alternative is rejected for not meeting the project
objectives, that the proposed project must be similarly rejected. As discussed in Master Response No. 18 –
Alternatives (Screening Criteria), the proposed project is not subject to the Alternatives Threshold Selection
Criteria.
As explained in the R-DEIR and in Master Response No. 18 - Alternatives (Hageman Flyover Alternative),the
Hageman Flyover would contribute no further reductions in traffic congestion on 24th Street, whereas the
proposed project would substantially reduce existing and future traffic congestion. The City’s goal is Level of
Service (LOS) C, although LOS D is still acceptable. Caltrans policy is to “maintain a target LOS at the
transition between LOS ‘C’ and LOS ‘D’ on State highway facilities (California Department of Transportation,
2002, Guide for the Preparation of Traffic Impact Studies). The proposed project would substantially achieve
LOS C between the SR-99 ramps and C Street in the morning peak hour and between Oak Street and B Street
in the evening peak hour.
GP-228-90
The commenter summarizes the R-DEIR’s conclusions about which project objectives are met by the Hageman
Flyover Alternative and incorrectly assumes that it meets Objective 2b (consistency with regional
transportation planning objectives). As stated on page 70 of the R-DEIR, the Hageman Flyover Alternative
would not be consistent with regional transportation planning – as an alternative to the 24th Street Improvement
Project – because those plans call for implementing both the Hageman Flyover and the 24th Street
Improvement Project.
GP-228-91
The commenter believes that if the proposed project were not implemented, the Hageman Flyover alternative
would become more cost-effective as a project to reduce traffic congestion on 24th Street. A cost-benefit
evaluation of the Hageman Flyover alternative as a project to reduce traffic congestion on 24th Street is not
influenced by whether or not the proposed project is implemented. It is simply a comparison of the cost of the
alternative with the potential reduction in traffic volumes. The Hageman Flyover would reduce traffic volumes
on 24th Street by about 13,000 vehicles per day at a cost of about $52 million. As explained in Master Response
No. 18 - Alternatives (Hageman Flyover Alternative), the benefits of that project are already included in the
baseline traffic numbers for the 24th Street traffic study.
GP-228-92 The commenter questions the application of the project objectives in the R-DEIR. If the failure of a potentially
feasible alternative to achieve the primary purpose of the project were not sufficient to dismiss it, then the
screening of potential alternatives would serve no purpose. The Hageman Flyover alternative would not
“provide the roadway capacity necessary to handle the future traffic volumes …”
GP-228-93
The commenter believes that the Hageman Flyover Alternative would cost less than the proposed project by
saving the City the $46M implementation cost. Please see responses to Comments No. GP-228-91 and No. GP-
228-92. The CEQA Guidelines do not require an agency to consider a potential alternative that does not
substantially achieve the primary purpose of the project.
The commenter questions the cost feasibility evaluation of the Hageman Flyover Alternative and the current
cost of the proposed project. The quoted section of the CEQA Guidelines refers to the cost of an alternative
rather than to its cost-benefit ratio (i.e., capital cost per increment of congestion reduction). The issue here is
not the actual dollar costs of the proposed project compared to those of the alternative, but on the efficiency
with which public funds are dispensed. As a public agency, the City is obligated to exercise due diligence in
spending public funds and incurring long-term debt on behalf of its citizens.
GP-228-94
The commenter questions the conclusion in the R-DEIR that the Hageman Flyover Alternative is not
reasonable. The R-DEIR acknowledges that the Hageman Flyover is a planned TRIP project. The
reasonableness of an alternative, however, must be considered in light of its ability to achieve the objectives of
the proposed project. “Reasonable” means “practical,” “rational,” or “logical” in this context. It is not practical,
rational, or logical to accept as a replacement for the 24th Street Improvement Project an alternative that is
incapable of achieving its basic objective of relieving existing and future traffic congestion. Please see Master
Response No. 18 - Alternatives (Hageman Flyover Alternative).
GP-228-95 The commenter claims that the Hageman Flyover Alternative meets all four alternative selection criteria and
should have been carried forward for detailed analysis in the DEIR. The City has demonstrated that this
alternative does not achieve the basic objective of the project. Please see Master Response No. 22– Hageman
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 398
Flyover Alternative.
GP-228-96 The commenter quotes a statement in the Court’s ruling that “Candidate alternatives … may be excluded from
the EIR.” The proposed project is not a “candidate alternative”. Under CEQA, there is a project and there are
alternatives to that project. CEQA does not require the same criteria used to evaluate potential alternatives also
be applied to the proposed project. Please see response to Comment No. GP-228-4.
GP-228-97 The commenter provides a detailed critique of the 2013 FEIR. Please see Master Response No. 16 – Issues Out
of Scope of the R-DEIR
GP-228-98 The commenter provides a detailed critique of the City’s approval resolution for the 2013 FEIR. Please see
Master Response No. 16 – Issues Out of Scope of the R-DEIR
GP-228-99 The commenter evaluates the consistency of the proposed project with Criterion #2 (Project Objectives) of the
Alternatives Threshold Selection Criteria. Please see Master Response No. 18 – Alternatives (Screening
Criteria).
GP-228-100 The commenter claims that the project’s traffic study overstates the ability of the project to provide roadway
capacity. The traffic study was not a topic addressed in the R-DEIR. Please see Master Response No. 16 –
Issues Out of Scope of the R-DEIR (Traffic Study). Please also see response to Comment No. GP-228-4.
GP-228-101 The commenter claims that project costs have escalated from $46M to 62.8M. Project costs have not escalated
as stated. Please see responses to Comments No. GP-228-4 and No. GP-228-96, and Master Response 19 –
Project Costs.
GP-228-102 The commenter seeks to apply one of the four alternative selection criteria (“reasonableness”) to the proposed
project. These criteria do not apply to the project, as explained in Master Response No. 18 - Alternatives
(Selection Criteria).
GP-228-103 The commenter recommends that the R-DEIR consider TSM and TDM alternatives to the proposed project.
TSM/TDM alternatives were discussed in Section 1.3 of the 2012 DEIR and 2013FEIR/2015DEIR. Please see
Master Response No. 18 – Alternatives (Alternatives Suggested by Commenters).
GP-228-104
The commenter asserts that the proposed project is a roadway capacity “strategy.” The 24th Street Improvement
Project is a road widening and improvements project that is the concrete result of a long process of conceiving
and evaluating various strategies. The “operational strategies” listed in the comment are standard engineering
and planning considerations that are taken into account on every road project, including the proposed project,
and do not rise to the level of being independent, stand-alone alternatives comparable to those already
addressed in the 2013 FEIR/2015 DEIR and R-DEIR. Please see Master Response No. 18 – Alternatives
(Alternatives Suggested by Commenters).
GP-228-105 The commenter suggests that the R-DEIR consider Adaptive Signal Control Technology. Please see response
to Comment No. GP-228-103 and Master Response No. 18 – Alternatives (Alternatives Suggested by
Commenters).
GP-228-106
The commenter states that the R-DEIR should include several hybrid alternatives. The Hageman Flyover
hybrid alternatives are infeasible and do not achieve project objectives because the Hageman Flyover would
provide no additional reduction in traffic volumes beyond that which is already accounted for in the baseline
and project traffic numbers. The Restriping hybrid alternative is no improvement over the Restriping
Alternative because the Restriping Alternative would achieve sufficient relief of future traffic congestion by
itself. A Roadway Diet alternative would not achieve the basic purpose of the project. Finally, one-way north-
south streets in the 24th Street couplet area would not reduce future traffic congestion where it is needed - in
Segments 2 and 3 of the 24th Street alignment. Please see Master Response No. 18 – Alternatives (Alternatives
Suggested by Commenters).
GP-228-107 The commenter claims that the 2013 FEIR and the R-DEIR are fatally flawed for not having identified the
environmentally superior alternative. The alternatives to the project were evaluated in the 2013 FEIR/2015
DEIR, and were not a topic addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope
of the R-DEIR.
GP-228-108
The commenter expresses an opinion that the City’s acquisition of properties along 24th Street makes changes
to the project and EIR more difficult to accomplish. The City’s acquisition of parcels along 24th Street
following certification of the 2013 FEIR and approval of the project by the City Council was in full compliance
with CEQA.
In Saltonstall v. City of Sacramento (2015) 234 Cal.App.4th 549, the Court ruled that the City’s acquisition of
property interests for construction of a new arena for the Sacramento Kings in advance of project approval did
not demonstrate a pre-commitment, and further noted that ”property acquisition did not foreclose any
mitigation measures or alternatives”, and that property acquisition neither compelled the City to approve the
project nor to reject mitigation measures.
The commenter also requests that the R-DEIR address the environmental effects of the City’s interim actions.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 399
Crime is a social rather than an environmental impact. The commenter does not provide direct evidence that
the cul-de-sacs have affected the crime rate in the project area. What is presented in the comment is a recent
trend in the crime rate and an unsupported assertion that the cul-de-sacs are the root cause. The comment itself
demonstrates uncertainty in referring to the cul-de-sacs’ “apparent effect on crime.” An association does not by
itself demonstrate cause and effect.
Any temporary conditions in the project area resulting from the suspension of the project, such as vacant
houses or temporary K-rails on the cul-de-sacs, will be resolved soon with the completion of the CEQA
process. The acquired properties along 24th Street will either be demolished and become part of a road
improvement project or they will be sold to new owners who will maintain them. The K-rails on the south side
of 24th Street will be removed whether the cul-de-sacs are finished or restored to their original condition.
GP-228-109
The commenter claims that “project related” safety concerns (i.e., concerns created by the 24th Street
Improvements project) were the catalyst for the residents requests to install cul-de-sacs. In fact, as stated in the
first paragraph of Section 1.3 in the R-DEIR (Policy History of South of 24th Street Cul-de-Sacs), the residents’
concerns about safety date back to at least the 1990s. Residents petitioned the City in 2006 to close Elm Street
to through traffic. The 24th Street Improvement Project merely offered a convenient vehicle for installation of
the desired permanent cul-de-sacs.
GP-228-110
The commenter states that the analysis of the cul-de-sacs in the Errata Sheet contradict the R-DEIR’s statement
that the cul-de-sacs would have minor to negligible effects on environmental resources. No information is
offered by the commenter in support of this general statement. The City believes, however, that the R-DEIR’s
supplemental analysis of the project’s environmental impacts – with the additional cul-de-sacs included –
demonstrates clearly that the cul-de-sacs are responsible for only very minor changes in the environmental
footprint of the project.
GP-228-111
The commenter asserts that the cul-de-sacs analysis is hidden in the Errata Sheet. The 40-page Appendix A
cannot be characterized as “hidden” as it is by far the largest section of the R-DEIR. The provision of only
those changes to the 2015 DEIR necessary to comply with the Court order is entirely consistent with CEQA
Guidelines Section 15088.5(c), which states, “(c) If the revision is limited to a few chapters or portions of
the EIR, the lead agency need only recirculate the chapters or portions that have been modified.”
GP-228-112 The commenter alleges that the analysis of cul-de-sacs in the Errata Sheet is conclusionary. The cul-de-sacs, as
a minor project element, were addressed at a level of detail similar to or greater than that of other minor
elements of the project, and based on the consideration of respective resources specialists.
GP-228-113
The commenter alleges that the analysis of cul-de-sacs in the Errata Sheet is conclusionary. Please see response
to Comment GP-228-112.
The commenter claims that an increase in crime is associated with the cul-de-sacs. Crime is a social ill, rather
than an environmental impact, and is not within the scope of CEQA documents. Please see response to
Comment No. GP-228-108.
GP-228-114
The commenter reproduces Table 2.7 from the R-DEIR, and characterizes the changes in parcel acquisitions
and temporary construction easements due to the addition of six cul-de-sacs as “substantial.” To be clear, the
cul-de-sacs would increase the acreage of partial parcel acquisitions by 777 square feet, a one percent increase,
and would increase the temporary construction easements by 2,527 square feet, a two percent increase. The
cul-de-sacs would not change the number of full parcel takes. These changes due to adding six cul-de-sacs are
therefore not substantial.
GP-228-115 The commenter cites a lack of “substantial evidence” that emergency services were consulted on the effect of
the cul-de-sacs on local response times. Please see Master Response No. 20 - Cul-de-Sacs (Safety).
GP-228-116
The commenter reflects a misreading of the R-DEIR text. The commenter cites a concise summary of the
impacts from the Executive Summary rather than citing the more-detailed explanation in the body of the
R-DEIR. As explained in the R-DEIR, the 24th Street project would have a moderate to moderately high visual
resources impact without the six additional cul-de-sacs. When the cul-de-sacs are considered as part of the
project, it would still have a moderate to moderately high impact on visual resources. In other words, the cul-
de-sacs would not substantially alter the overall impact of the project on visual resources, so no need for
mitigation specifically for the cul-de-sacs exists.
The commenter makes a general comment regarding the design and implementation of the cul-de-sacs, but
does not elaborate on what it considers to be the “important questions.” Because this comment is not specific
enough, no response can be formulated.
GP-228-117
The commenter asserts that the R-DEIR’s summary of cultural resources impacts conflicts with the more-
detailed discussion of cultural resources in Appendix A-Errata Sheet. The summary in the R-DEIR has been
clarified by inserting the following text (indicated in underlined text below):
“On the south side of 24th Street, the partial parcel acquisitions required to construct the additional cul-
de-sacs would not alter the conclusions reached in the 2013 FEIR about the proposed project’s adverse
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 400
effects on the historic district south of 24th Street. The Section 106 process addresses a federal
requirement that has been met by the proposed project and that does not require additional evaluation.
The City of Bakersfield, as lead agency under CEQA, is responsible for the historical resources impact
analysis. The State Historic Preservation Office will have an opportunity to comment on this R-DEIR
when it is distributed to State of California agencies by the State Clearinghouse.” [Note: Footnotes
were not reproduced in this RTC]
As discussed in Section 2.1.6 Cultural Resources and Master Response No. 21 – Cultural Resources of the
R-DEIR, a determination has been made that adding six cul-de-sacs to the proposed project would create no
further impacts on the character-defining architectural features of any contributors to the historic district,
considered a historical resource under CEQA, and therefore no additional mitigation is required beyond that
which has been stipulated in the Memorandum of Agreement
The information in Table S.1 in Appendix A, has been revised at one location (as indicated in italics below) to
be consistent with Table 2.13 in the R-DEIR:
Historic District South of 24th Street: A finding of adverse effect was concurred with by the State
Historic Preservation Officer, consisting of 9 full parcel acquisitions (7 contributing properties), 6
partial parcel acquisitions (1 contributing property), and 12 TCEs (3 on contributing properties).
Additional impacts from adding six cul-de-sacs to the project has increased the numbers of partial
parcel acquisitions to 16 (6 contributing properties) and the number of TCEs to 18 (5 on
contributing properties). The direct physical impacts to the 11 18 contributing properties represents
25 about 36 percent of contributing properties identified to be in the Area of Potential Effect (APE)
and about 10 11 percent of contributors within the district as a whole (based on the approximate
ratio of 85% contributing and 15% noncontributing properties within the historic district to the
south).
The magnitude of the proposed partial parcel acquisitions in the historic district south of 24th Street is not
related to the impacts of the six cul-de-sacs on historic resources. As indicated in Section 2.1.6 Cultural
Resources and Master Response No. 21 – Cultural Resources, in no cases do these acquisitions affect any of
the character-defining features of the contributors which provides their significance under National Register
Criterion C (architectural design) or which qualifies them as historical resources under CEQA. Therefore no
recirculation of the DEIR is necessary.
GP-228-118 The commenter quotes text from the R-DEIR referring to “an addendum traffic analysis” that is not included in
the R-DEIR. The comment reflects a misreading of the R-DEIR text. The quoted paragraph is from the
decertified 2013 FEIR. It is reproduced in the R-DEIR solely to show that the two words, “city approved” are
deleted from the text.
GP-228-119 The commenter suggests that “with-cul-de-sacs” and “without-cul-de-sacs” alternatives are both needed to
have a true understanding of the impacts of the cul-de-sacs. This issue is addressed in response to Comment
GP-228-6. The magnitude of the effects of the cul-de-sacs on historic resources is addressed in the response to
Comment GP-228-117. Please also see Master Response No. 21 – Cultural Resources.
GP-228-120
The commenter states, correctly, that CEQA Guidelines Section 15088.5 applies to recirculation of a Draft EIR
prior to certification, and then confusingly argues that despite the de-certification of the previous FEIR, this
provision does not apply to the 24th Street Improvement Project. No rationale is provided for this distinction,
and the CEQA Guidelines do not distinguish between a project that has not proceeded beyond the DEIR and a
project that has been returned to the DEIR stage to address deficiencies. It is reasonable to conclude that if the
FEIR was set aside by order of the Court, the current status of the project is as if the FEIR had not been
certified.
To be clear, CEQA Guidelines Section 15088.5 (c) states: If the revision is limited to a few chapters or
portions of the EIR, the lead agency need only recirculate the chapters or portions that have been modified.
Lead agencies are specifically authorized to limit their consideration to the changes in the proposed project and
the potential environmental impacts that derive from those changes. This limitation is reasonable because in-
depth review of the overall project has already occurred and its general sufficiency has already been upheld.
The CEQA Guidelines allow both recirculated documents and supplemental documents to be prepared and
circulated as stand-alone documents. In any case, the mere need to compare some information in the R-DEIR
with information in the 2013 FEIR/2015 DEIR does not justify re-opening the entire 2013 FEIR/2015 DEIR to
a second round of public review and comment.
GP-228-121 The commenter expresses an opinion about the usefulness of the R-DEIR and 2013 FEIR/2015 DEIR together
as an informational document. The commenter’s opinion about the usefulness of the combined DEIR is
acknowledged. The general issues raised in this comment are addressed more specifically in other responses.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 401
GP-228-122
The commenter expresses opinions about the organization of the 2013 FEIR/2015 DEIR, the currency of its
information, and differences in how significance is determined under CEQA and NEPA. The 2013 FEIR/2015
DEIR is not the subject of this public review period. That the EIR document is unwieldy does not render it
inadequate, incomplete, or otherwise deficient. Please see Master Response NO. 16 – Issues Out of Scope of the
RDEIR and Master Response No. 17 - Supporting Information for 2013 FEIR/2015 DEIR
GP-228-123
The commenter questions the “combined DEIR’s” lack of a summary table in the format “typically included in
EIRs.” The commenter’s expectations for a specific format for the information required by CEQA go beyond
the requirements of CEQA Guidelines Section 15123. Chapter 3 of the 2013 FEIR/2015 DEIR, California
Environmental Quality Act Evaluation, provides a concise summary of the potentially significant impacts of
the proposed project and proposed mitigation measures. The adequacy of this summary section was not raised
during public review of the 2012 DEIR. It is not a topic addressed in the R-DEIR.
GP-228-124
The commenter claims that the 2013 FEIR and the R-DEIR are fatally flawed for not having identified the
environmentally superior alternative. This aspect of the adequacy of the EIR was not raised during public
review of the 2012 DEIR. It is not a topic addressed in the R-DEIR. Please see Master Response No. 16 -
Issues Out of Scope of the R-DEIR. Please note that the Environmentally Superior Alternative was presented in
the Facts and Findings document prepared by staff to the City Council.
GP-228-125
The commenter claims that the “combined” DEIR fails to provide a “reasonable” range of alternatives. The
2012 DEIR and 2013 FEIR/2015 DEIR analyzed a reasonable range of feasible alternatives, following a
lengthy and thorough consideration of potential onsite and offsite alternatives whose consideration was
documented in Project Study Reports, Supplemental Project Study Reports, and previous studies and plans
included in the Administrative Record and summarized in Section 1.3.6 of the R-DEIR. Master Response No.
1, Consideration of Improvements to State Route 204 Instead of the Proposed 24th Street Improvement Project,
provides further consideration of potential project alternatives identified by the public during the public review
period for the 2012 DEIR.
The issue of a “reasonable range” of alternatives was raised in a lawsuit brought against the City following its
certification of the FEIR on the 24th Street Improvements project. After considering this claim, the Court’s
remedy was to order the City to “provide additional information and analysis that clearly discloses the reasons
for selecting potentially feasible alternatives and then adequately analyzes and discusses whether or not each of
the potentially feasible alternatives satisfies at least one of the four threshold criteria under Guidelines Section
15126.6.” In response to the Court’s order, the City committed to preparing a Recirculated DEIR that “clearly
discloses the reasons for selecting potentially feasible alternatives and discusses whether or not each of the
potentially feasible alternatives satisfies at least one of the four threshold criteria …” The City fulfilled that
commitment.
The comment is a summary statement that does not identify which alternatives the commenter believes should
be included in the EIR, or describe the range of alternatives that would be deemed reasonable or feasible.
GP-228-126 The commenter recommends revising and recirculating the entire DEIR for the 24th Street Improvement
Project, but provides neither reasoned argument nor substantial evidence to support the need to do so. The
R-DEIR addresses the two limited flaws in the EIR identified by the Superior Court.
GP-228-127 The commenter requests that the traffic study for the proposed project be re-done. Please see Master Response
No. 16 – Issues Out of Scope of the R-DEIR (Traffic Study).
GP-228-128 The commenter claims that costs for the project have escalated from what was presented in the R-DEIR. Please
see Master Response No. 19 – Project Costs.
GP-228-129
The commenter claims that the R-DEIR does not comply with CEQA and must be redone. As evident in the
City’s responses to previous comments, the combined document fully complies with CEQA and with the order
of the Court. The document accurately describes the project alignment and surrounding study area, adequately
analyzes viable alternatives, comprehensively identifies and analyzes potential environmental impacts, and
provides appropriate mitigation measures for potentially significant impacts.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 402
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 403
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 404
Response to Comment Letter GP-229
Comment Code Response
GP-229-1 The commenter asserts that the R-DEIR fails to support its discussions of financial feasibility with
substantial evidence. Please see Master Response No. 19 – Project Costs (Cost Feasibility).
GP-229-2 Your comment is acknowledged. The anecdote supports the contention that the City would need to acquire
these properties.
GP-229-3 The commenter states that the R-DEIR failed to consider a widening of SR-204 in lieu of a freeway. SR-
204 widening alternatives were considered during public review of the 2012 DEIR (Master Response No.
1: Consideration of Improvements to State Route 204 instead of the Proposed 24th Street Improvement
Project). Please also see Master Response No. 18 - Alternatives.
GP-229-4 The commenter speculates on the starting point for some trips on 24th Street, and questions whether the
Hageman Flyover Alternative would add 3 miles to some trips. This issue is addressed in Master Response
No. 22- Hageman Flyover Alternative.
GP-229-5 The commenter describes an encounter with a City worker on one of the parcels acquired for the project.
City maintenance activities at acquired properties and casual comments by City workers to passersby
about City policies are not pertinent to the content of the R-DEIR. Please see Master Response No. 16 –
Issues Out of Scope of the RDEIR.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 405
Response to Comment Letter GP-230
Comment
Code Response
GP-230-1
The commenter provides unsupported observations and opinions. Observations such as “a fact noticed by all” do
not constitute evidence. The magnitude, location, and time of day / day of week of a “clearly noticeable increase
in traffic volume” cannot be ascertained. Without quantitative data, these observations are difficult to reconcile
with the traffic analysis. The traffic analysis provided in the 2013 FEIR/2015 DEIR concluded that the volume of
diverted traffic was very low.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 406
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 407
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 408
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 409
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 410
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 411
NOTE: Comment Letter GP-231 from Mr. Flores contains 8 attachments which are not
included at this time to conserve space:
1. Exhibit 1. Webpage from TRIP website showing 24th St. Project Status, indicating that
comments only on two revised sections can be sent to Janet.
2. Exhibit 2. RFQ/RFP Calif High Speed Rail Station Area Plan Downtown Bakersfield (with
1.3 Project Location, 2.2.3 Vision Plan, 2.2.6 Implementation Strategy marked)
3. Aerial map of Bakersfield and HSR Stations presentation (13 slides)
4. 14 more slides on HSR stations
5. HSR FEIR/EIS Fresno to Bakersfield (Land Use Section, pages 3.13-1 through 3.13-50).
6. HSR FEIR/EIS Fresno to Bakersfield (Land Use Section, pages 3.13-51 through 3.13-64).
7. Exhibit 3. City, developers turn more attention to East Hills Mall (7/9/14 article by Theo
Douglas in The Bakersfield Californian). Exhibit 4. CVBT article New 200-plus home
development set for Bakersfield on a blog. July 30, 2015. HSR Alignment diagram
8. Economic Development Projects (7 slides).
9. Exhibit 5. A Guide for Health Impact Assessment (California Dept of Public Health).
Response to Comment Letter GP-231
Comment
Code Response
GP-231-1 The commenter questions the limiting of public comments to the topics addressed in the R-DEIR. This
limitation is strictly in accordance with CEQA Guidelines Section 15088.5. Please see Master Response No.
16 - Issues Out of Scope of the R-DEIR.
GP-231-2 The commenter argues that the City is subject to CEQA provisions that govern subsequent and supplemental
EIRs (CEQA Guidelines Section). The CEQA Guidelines section cited by the commenter applies only where a
lead agency has certified a FEIR and approved the project (Section 15162[c]). It does not apply to a draft
document prior to certification of the FEIR.
GP-231-3
The commenter claims that the City is required to revisit its cumulative impacts analysis for the project. The
commenter cites as its authority CEQA Guidelines Section 15355, which defines the term “Cumulative
Impacts” but does not address the EIR requirement for cumulative impact analysis; those requirements are
specified in CEQA Guidelines Section 15130. The 2012 DEIR included a cumulative impacts analysis (see
Section 2.4). The public commented on that analysis during the public review period for the DEIR (see
Comments B-9-11 and GP-093-6 and their responses in Volume 2 of the 2013 FEIR/2015 DEIR). Please see
Master Response No. 16 - Issues Out of Scope of the R-DEIR. Furthermore, the 3 projects cited in the
comment as warranting inclusion in the cumulative impacts analysis are speculative, as they have not reached
the point where they are “reasonably foreseeable” as specific projects that could be evaluated in the R-DEIR.
GP-231-4 The commenter questions whether the R-DEIR examined a reasonable range of alternatives. Please see GP-
228-5. Please see also Master Response No. 16 - Issues Out of Scope of the R-DEIR (Traffic Signal
Synchronization) and Master Response No. 8 – Alternatives (Alternatives Suggested by Commenters).
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 412
GP-231-5
The commenter asserts that the R-DEIR failed to explore transportation management alternatives such as
limiting commercial traffic or prohibiting trucks. The City considered both Transportation Demand
Management and Transportation System Management measures during the development of the proposed
project, as addressed in Chapter 1 of the 2013 FEIR/2015 DEIR, but believed that such measures did not
constitute a stand-alone alternative warranting detailed evaluation. Preliminary project studies (RBF 2011)
indicated that in the project design year of 2035, trucks would constitute approximately 3 percent of the
average daily vehicle volume. Thus, prohibiting trucks, alone, would not achieve the project objectives. Also,
because trucks prohibited from using 24th Street would need to enter or pass through downtown Bakersfield
via another route, this measure would simply shift up to 2,700 trucks per day to another highway or arterial,
potentially creating or exacerbating traffic congestion on another route.
The effects of limiting commercial vehicles on traffic congestion on 24th Street are unknown. The City has no
data on how many commercial vehicles would use 24th Street in the design year, so the potential of this
measure to contribute to achieving the project’s objective cannot be estimated. This measure, like the limits on
truck traffic, would shift commercial traffic to other local routes, with unknown consequences on traffic
congestion. Additionally, a ban on commercial traffic during peak traffic periods – which could be several
hours per day – could adversely affect the residents because commercial vehicles serving the area would use
side streets to reach their destinations. Please see Master Response No. 18 - Alternatives (Alternatives
Suggested by Commenters).
GP-231-6
The commenter expresses an opinion that by purchasing parcels along 24th Street in advance of completing
the CEQA process, the City has developed “financial momentum” to approve the project. The City’s
acquisition of parcels along 24th Street following certification of the 2013 FEIR and approval of the project by
the City Council was in full compliance with CEQA.
The commenter cites for support Save Tara v. City of West Hollywood, a case where the central question was
the proper point in the development process to initiate environmental review under CEQA. A more
appropriate case in this instance is Saltonstall v. City of Sacramento (2015) 234 Cal.App.4th 549. In the latter
case, the Court ruled that the City’s acquisition of property interests for construction of a new arena for the
Sacramento Kings in advance of project approval did not demonstrate a pre-commitment, and further noted
that, “property acquisition did not foreclose any mitigation measures or alternatives”, and that property
acquisition neither compelled the City to approve the project nor to reject mitigation measures..
GP-231-7 The commenter wants the City to prepare a health risk assessment for the project because of the vehicle-
related particulate matter emissions. The air quality analysis in the 2012 DEIR addressed particulate and
MSAT emissions, which are regulated according to their health effects. This topic was not addressed in the
R-DEIR. Please refer to Master Response No. 16 - Issues Out of Scope of the R-DEIR.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 413
Response to Comment Letter GP-232
Comment
Code Response
GP-232 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 414
Response to Comment Letter GP-233
Comment
Code Response
GP-233-1
The commenter asks whether traffic studies have been done on certain streets in the project area. No studies have
been conducted on Drake, F, or B Street north of 24th Street because the volume of traffic traveling south across
24th Street into the cul-de-sac streets (from the north side to the south side) was very low according to the
intersection turning movement counts collected in 2007 and 2008. Please see Master Response No. 16 – Issues
Out of Scope of the RDEIR (Traffic Study).
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 415
Response to Comment Letter GP-234
Comment
Code Response
GP-234 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 416
Response to Comment Letter GP-235
Comment
Code Response
GP-235 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 417
Response to Comment Letter GP-236
Comment
Code Response
GP-236 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 418
Response to Comment Letter GP-237
Comment
Code Response
GP-237 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 419
Response to Comment Letter GP-238
Comment
Code Response
GP-238 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 420
Response to Comment Letter GP-239
Comment
Code Response
GP-239 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 421
Response to Comment Letter GP-240
Comment
Code Response
GP-240 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 422
Response to Comment Letter GP-241
Comment
Code Response
GP-241 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 423
Response to Comment Letter GP-242
Comment
Code Response
GP-242 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 424
Response to Comment Letter GP-243
Comment
Code Response
GP-243 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 425
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 426
Response to Comment Letter GP-244
Comment
Code Response
GP-244 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 427
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 428
Response to Comment Letter GP-245
Comment
Code Response
GP-245 Your comments are acknowledged.
Response to Comment Letter GP-246
Comment
Code Response
GP-246 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 429
Response to Comment Letter GP-247
Comment
Code Response
GP-247 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 430
Response to Comment Letter GP-247
Comment
Code Response
GP-247 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 431
Response to Comment Letter GP-248
Comment
Code Response
GP-248 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 432
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 433
Response to Comment Letter GP-249
Comment
Code Response
GP-249 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 434
Response to Comment Letter GP-250
Comment
Code Response
GP-250 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 435
Response to Comment Letter GP-251
Comment
Code Response
GP-251 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 436
Response to Comment Letter GP-252
Comment
Code Response
GP-252 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 437
Response to Comment Letter GP-253
Comment
Code Response
GP-253 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 438
Response to Comment Letter GP-254
Comment
Code Response
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 439
GP-254 Your comments are acknowledged.
Response to Comment Letter GP-255
Comment
Code Response
GP-255 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 440
Response to Comment Letter GP-256
Comment
Code Response
GP-256 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 441
Response to Comment Letter GP-257
Comment
Code Response
GP-257 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 442
Response to Comment Letter GP-258
Comment
Code Response
GP-258 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 443
Response to Comment Letter GP-259
Comment
Code Response
GP-259 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 444
Response to Comment Letter GP-260
Comment
Code Response
GP-260 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 445
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 446
Response to Comment Letter GP-261
Comment
Code Response
GP-261 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 447
Response to Comment Letter GP-262
Comment
Code Response
GP-262 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 448
Response to Comment Letter GP-263
Comment
Code Response
GP-263 Your comments are acknowledged.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 449
4. Responses to Oral Testimony on the
Recirculated Draft EIR
A total of 13 verbal comments were received as testimony during the January 21,
2016 Public Hearing held at City Council Chambers (City Hall South). Testimony is
summarized on Table 4.
Table 4. Oral Testimony Received on the 24th Street Improvement R-DEIR
Comment
Code
Date of
Comment Commenter Subject of Comment(s)
OC-70 1/21/16 Anthony AnsolabehereCoordinating traffic lights as an alternative; One-way streets; four
segments is piecemeal approach; $46M vs. $65M cost; are cul-de-
sacs included in the cost? 20 regional alternatives in BSS; 12 busiest
arterial roads daily totals vs. peak traffic totals; traffic volumes have
not met forecast (traffic has not grown); traffic time not supported;
future traffic debt; restriping not in accordance with design manual
standards; straighten the “S” curve; restriping cost in relation to total
project cost; Hageman flyover; lack of data on commuters to
downtown since opening of West Park Freeway; population growth.
OC-71 1/21/16 Vanessa Vangel Was 24th St widening project analyzed and evaluated under the same
criteria as other 8 alternatives? Social feasibility. Is City financially
prepared to pay for and maintain cul-de-sacs? Is City financially
prepared to pay for and maintain cul-de-sacs? Why circumventing
SHPO evaluation of cul-de-sacs? Alts 1 and 2 should be one
alternative with a Plan A and B; 2008 Caltrans required City to
evaluate 3 alternatives and No Build = CEQA violation? Soundwalls
on north side – fully enforceable mitigation measures, CEQA
violation, would FHWA approve without the soundwalls?
OC-72 1/21/16 Robert Braley Project does not achieve any goals; project does not reduce volume;
there is no bottleneck; lights not synchronized (solution?). Have you
studied traffic times and properly synchronized lights; project not
needed; should decrease volume. Project will disrupt neighborhood
with same number of cars, noise, air pollution, ugliness of
soundwalls, and degradation of safety with emergency response
delay. Hageman provides volume relief with 20-yr old traffic data.
Volume relief to Rosedale Hwy; 23rd/24th is solution.
OC-73 1/21/16 Lamar Kerley (Comments in support of cul-de-sacs)
OC-74 1/21/16 Bob Coons Should coordinate traffic lights on 24th and signs on 178 directing
traffic to Hwy 99 via 204. Removal of 204 option is ill-considered.
Inefficiency of diverting traffic to Hageman is debatable. Forecasts
have not met projected expectations. Fiscally irresponsible to spend
$40M for 24th Street as 56% of $71M City income for 2015/2016.
City should consider costs and effects of project.
OC-75 1/21/16 Judith Harniman Moving road north by 17 ft and elimination of 11 driveways does not
mention additional driveways on south side which will be dangerous.
Why was addition of frontage roads an option that was taken away?
Isn’t widening both sides and bringing road closer to existing
structures what they are now proposing to do?
OC-76 1/21/16 Valerie Munoz Is it reasonable to open up earth and expose 90+ years of spores into
atmosphere of Bakersfield? Beautification of cul-de-sacs is not set in
stone. Obstinance of TRIP – take bulldozers out of Westchester.
OC-77 1/21/16 Wayne Kress (Comments in support of project)
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 450
OC-78 1/21/16 Mike Hawkesworth Kern COG’s estimates of traffic should be looked at for existence and
accuracy of estimates – 10-yr projections.
OC-79 1/21/16 J. Miguel Flores PRC 21166. R-DEIR is woefully inadequate because of changes to
the environment and circumstances that merit further study and
baseline conditions associated with proposed downtown development
in light of High Speed Rail – part of cumulative impact analysis;
future development of North Hills Mall is proposed. Health
assessment study needed – diesel trucks and cancer-causing
particulate matter, sensitive receptors. City’s property acquisitions
have pre-committed the City to project and foreclosed alternatives,
post hoc rationalization for action already taken, illegitimizes process,
forecloses informed decision making.
OC-80 1/21/16 Thomas Deltoro-Diaz (Comments in support of project)
OC-81 1/21/16 Vanessa Vangel (Clarification of misconceptions on numbers of persons in opposition
vs. in favor)
OC-82 1/21/16 Commissioner Richard
Schwartz
Worthwhile comments; the City is not synchronizing roads or
exploring one-way streets.
OC = Oral Comment at Public Hearing
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 451
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 452
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 453
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 454
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 455
Response to Oral Testimony OC-70
Comment
Code Response
OC-70-1 The commenter asks why there are no references to coordinating traffic signals in the R-DEIR. Traffic
was not a topic addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of
the R-DEIR (Traffic Signal Synchronization). Please also see the Response to Comment GP-205-2.
OC-70-2 The commenter claims that describing the project in four segments for descriptive purposes creates a
piecemeal approach. The proposed project was initially described in four segments in the 2012 DEIR.
The R-DEIR did not change that description. Please see Master Response No. 16 – Issues Out of Scope
of the R-DEIR (Project Description).
OC-70-3 The commenter states that the R-DEIR is not clear whether the cul-de-sacs were included in the cost
estimates. Please see Master Response No. 19 – Project Costs.
OC-70-4 The commenter asks about the alternatives addressed in the Bakersfield System Study. Please see the
Response to Comment No. GP-205-5.
OC-70-5
The commenter asserts that the daily traffic volumes presented in the R-DEIR are not relevant. The peak
hour traffic volumes are used for the level of service analysis which indicates that the signalized
intersections are heavily used during peak hours. Congestion is prevalent on many roadways during
morning and afternoon peak hours. However, heavy traffic volumes persist along the 24th Street corridor
for twelve hours of the day. The reporting of daily traffic volumes provides an indicator of overall
intensity of use, indicating that 24th Street, with only four through movement travel lanes, has far more
traffic using the facility than many of the six lane arterial streets in Metro Bakersfield.
OC-70-6 The commenter asserts that traffic volumes have not met forecasts. Please see Master Response No. 16
– Issues Out of Scope of the R-DEIR (Traffic Study).
OC-70-7 The commenter claims that the R-DEIR provides no support for traffic time study calculations. Traffic
was not a topic addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of Scope of
the R-DEIR (Traffic Study).
OC-70-8 The commenter questions the future indebtedness of the City for transportation projects. Funding and
financing for the project are addressed in the R-DEIR. Please see the discussion of future debt service
under Criterion #3 in Section 1.3.6.1 of the R-DEIR.
OC-70-9
The commenter notes other road projects in Bakersfield where lanes have been restriped. The status of
other roads in Bakersfield is not relevant to the screening of potentially feasible alternatives to the
project; the City is not obligated to consider speculative alternatives based on project designs that would
violate adopted, generally accepted design standards such as those contained in the Circulation Element
to the Metropolitan Bakersfield General Plan (see response to Comment GP-228-71). See also Master
Response No. 18 – Alternatives (Restriping Alternative).
OC-70-10
The commenter questions the costs of the Restriping Alternative. The project includes the
reconstruction of the Oak Street intersection with 24th Street, improvements to the roadway between SR
99 and Oak Street, resurfacing 23rd and 24th Streets and their intersections with north-south running
streets in downtown Bakersfield, and restriping or widening 24th Street between the downtown one-way
couplet and Oak Street. The referenced cost of $30 million is required primarily for the elements of the
project from SR 99 to Oak Street, and the one-way couplet roadways in downtown Bakersfield.
OC-70-11 The commenter asks about the ability of the Hageman Flyover to reduce traffic on 24th Street and the
effects of population growth in the northwest on traffic forecasts. Please see Master Response No. 18 -
Alternatives (Hageman Flyover Alternative) and Master Response No. 16 – Issues Out of Scope of the
R-DEIR (Traffic Study).
OC-70-12 The commenter questions the population growth assumptions used for the R-DEIR. Population growth
was not a topic addressed in the R-DEIR. Please see Master Response No. 17 – Supporting
Information for 2013 FEIR/2015 DEIR.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 456
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 457
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 458
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 459
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 460
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 461
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 462
Response to Oral Testimony OC-71
Comment
Code Response
OC-71-1 The commenter asks whether the proposed project was evaluated under the Alternatives Threshold
Screening Criteria. Please see Master Response No. 18 – Alternatives (Screening Criteria).
OC-71-2 The commenter asks whether the City can finance all of the landscaping elements depicted in the
R-DEIR. The CEQA process addresses the potential environmental effects of the project. Following
certification of the FEIR and approval of the project, a lead agency may choose not to implement the
project, or elements of it, depending on funding and other considerations.
OC-71-3 The commenter claims that the City is circumventing review by the State Historic Preservation Office.
Please see Master Response No. 21 – Cultural Resources.
OC-71-4 The commenter expresses the opinion that Alternatives 1 and 2 should be considered as one project.
Please see response to Comment No. GP-224-13.
OC-71-5 The commenter references an alleged 2008 directive from Caltrans to the City. Please see response to
Comment No. GP-224-14.
OC-71-6 The commenter raises an issue about fully enforceable mitigation (sound walls) that was raised
previously. Please see response to Comment No. GP-224-15.
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 463
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 464
Appendix C Responses to Comments on R-DEIR
24th Street Improvement Project FEIR/EA Volume 3 465
Appendix C Responses to Comments on R-DEIR
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Appendix C Responses to Comments on R-DEIR
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Response to Oral Testimony OC-72
Comment
Code Response
OC-72-1 The commenter asserts that the proposed project would do nothing to improve the flow of traffic. The
proposed project would increase the number of travel lanes on 24th Street, and would thus attain the
goals of the project.
OC-72-2
The commenter observes that the proposed project would not reduce traffic volumes. The Traffic Study
presented in the 2012 DEIR established the need for the project, and traffic issues were not further
addressed in the R-DEIR. Offsite alternatives that would reduce traffic volumes on 24th Street have been
considered previously and, as discussed in Master Response to Comment No. 1 to the 2013 FEIR/2015
DEIR, would not be sufficient to eliminate the need for the proposed project. Please also see Master
Response No. 16 - Issues Out of Scope of the R-DEIR (Traffic Study).
OC-72-3 The commenter recommends traffic signal synchronization. Please see Master Response No. 16 - Issues
Out of Scope of the R-DEIR (Traffic Signal Synchronization).
OC-72-4 The commenter asks about travel times and signal synchronization. Please see Master Response No. 16 -
Issues Out of Scope of the R-DEIR (Traffic Study).
OC-72-5
The opinion expressed by the commenter about project effects is noted. Reducing traffic congestion
should result in lower levels of air pollutants and enhanced traffic safety. Preventing motorists from
cutting through the neighborhood south of 24th Street would enhance pedestrian safety. As noted in
Section 2.1.3, of the 2013 FEIR/2015 DEIR, Utilities and Emergency Services, the proposed project
would not result in delays in emergency response. Because the commenter does not address the
adequacy or completeness of the R-DEIR, no further response is necessary.
OC-72-6 The commenter claims that the Hageman Flyover Alternative would provide volume relief. Please see
Master Response No. 18 - Alternatives (Hageman Flyover Alternative).
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Response to Comment Letter OC-73
Comment
Code Response
OC-73-1 Your comment is acknowledged.
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Response to Oral Testimony OC-74
Comment
Code Response
OC-74-1 The commenter recommends synchronizing the traffic signals. Please see Master Response No. 16 –
Issues Out of Scope of the R-DEIR (Traffic Signal Synchronization).
The commenter also recommends the use of directional signs to divert traffic from 24th Street. Please
see Master Response No. 18 – Alternatives (Alternatives Suggested by Commenters).
OC-74-2
The commenter asserts that the majority of citizens favor an SR-204 alternative to the 24th Street
Improvement Project. As evidenced by the volume of traffic using the 24th Street corridor between SR
178 and Rosedale Highway and the Truxtun Avenue extension to Westside Parkway, the great majority
of residents select the direct route choice using the 23rd/24th Street corridor compared to the indirect path
of SR 204/SR 99.
OC-74-3
The commenter questions whether diverting traffic three miles north to Hageman Flyover would be
inefficient. Motorists do select Golden State/SR 204 as a desirable route to travel between the northwest
and downtown Bakersfield and points east. Currently, the only path available is to connect Olive Drive
with Golden State via SR 99. An auxiliary lane has recently been constructed along SR 99 between
Golden State and Olive drive to aid this transition. The extension of Hageman Drive to Golden State
will further aid the connection between the northwest and downtown Bakersfield. Some residents living
along or to the south of Hageman Drive and its connecting local streets choose to drive south from the
northwest to Rosedale Highway, because Olive Drive is highly congested, particularly approaching SR
99. The Hageman Drive extension to Golden State will provide an alternative route to access downtown
and points east, thereby relieving traffic volumes on Rosedale Highway and the 24th Street corridor. All
of these factors have been taken into consideration in the development of the TRIP roadway
improvement program. Please refer to Master Response No. 18 – Alternatives.
OC-74-4
The commenter believes that, historically, traffic forecasts have not met expectations. In 1965, Caltrans
reported that the daily traffic volume using 24th Street east of Oak Street was 15,000 vehicles per day
(vpd). In 1980, the volume was 26,500 vpd. In 1985, the volume was 45,500 vpd. In 2010, the volume
was 62,000 vpd. The volume has since declined slightly due to the construction on Rosedale Highway
and the opening of the Westside Parkway connection to Truxtun Avenue. Motorists are clearly selecting
the most time advantageous routes when making their route selection choices.
OC-74-5 The opinion of the commenter about the advisability of committing funding to the proposed project is
acknowledged.
OC-74-6 The commenter hopes that the City will consider the costs and effects of the project. The City will
consider the FEIR prior to making a decision on the proposed project. The FEIR identifies the
construction and property acquisition costs and the environmental effects of the proposed project.
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Response to Oral Testimony OC-75
Comment
Code Response
OC-75-1 The commenter is concerned that the proposed project will increase safety risks for residents on the south
side of 24th Street. The traffic analysis for the project was included in the 2012 DEIR and 2013
FEIR/2015 DEIR. Traffic safety was not a topic addressed in the R-DEIR. Please see Master Response
No. 16 - Issues Out of Scope of the R-DEIR (Traffic Study).
OC-75-2 The commenter asks why a frontage road was considered. The alternative which included frontage roads
along 24th Street was considered, but not retained for detailed evaluation. The rationale for this selection
is addressed in Chapter 3, Section 1.3.6 of the R-DEIR.
OC-75-3
The commenter is asking whether the project would widen both sides of 24th Street and bring the road
closer to existing structures. “Widening Both Sides of 24th Street” is potential alternative H, described on
page 58 of the R-DEIR; that is not the proposed project. The project preferred alternative, widening to the
north, moves traffic farther away from existing structures along the south side of the roadway.
Acquisition of parcels along the north side of the current roadway will move the centerline farther to the
north, so the edge of pavement will be moved farther from the nearest structures which remain, compared
with existing conditions. Construction of the cul-de-sacs would require the acquisition of portions of
parcels on side streets south of 24th Street, but there would be no widening of 24th Street on its south side.
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Response to Oral Testimony OC-76
Comment
Code Response
OC-76-1 The commenter questions whether it is reasonable to excavate soil on the project site. This issue was
addressed in Master Response No. 6 to comments on the 2013 FEIR/2015 DEIR (Valley Fever and Other
Health Risks). Air quality and construction impacts were not topics addressed in the R-DEIR. Please see
Master Response No. 16 - Issues Out of Scope of the R-DEIR.
OC-76-2
The commenter observes that the existing temporary barriers on the cul-de-sacs are “not pretty.” The
aesthetic quality of the cul-de-sacs is addressed in Section 2.1.5 of the 2013 FEIR/2015 DEIR and
Chapter 3, Section 2.1.5 of the R-DEIR. The existing temporary barriers do not represent post-project
conditions. Once environmental review of the proposed project has been completed, the status of the
project will be resolved and the temporary barriers will be removed. The landscape planters and other
cul-de-sac features are part of the project and will be implemented if the project is approved. The
proposed project would substantially alter visual conditions on 24th Street between Elm Street and B
Street. Adding six cul-de-sacs would not substantially change the degree of visual impact of the proposed
project.
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Response to Oral Testimony OC-77
Comment
Code Response
OC-77-1 Your comment is acknowledged.
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Response to Oral Testimony OC-78
Comment
Code Response
OC-78-1 The commenter suggests looking at Kern Council of Government’s traffic estimates. Traffic estimates
and projections were not addressed in the R-DEIR. Please see Master Response No. 16 – Issues Out of
Scope of the R-DEIR (Traffic Study).
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Response to Oral Testimony OC-79
Comment
Code Response
OC-79-1
The commenter cites “changes in the environment and circumstances” surrounding the project that
warrant further study, and refers to Public Resources Code 21166 for support. The commenter states only
a portion of Public Resources Code Section 21166, the full text of which reads:
21166. When an environmental impact report has been prepared for a project pursuant to this division,
no subsequent or supplemental environmental impact report shall be required by the lead agency or by
any responsible agency, unless one or more of the following events occurs:
(a) Substantial changes are proposed in the project which will require major revisions of the
environmental impact report.
(b) Substantial changes occur with respect to the circumstances under which the project is being
undertaken which will require major revisions in the environmental impact report.
(c) New information, which was not known and could not have been known at the time the
environmental impact report was certified as complete, becomes available.[Emphasis added]
This provision of CEQA pertains to agency actions following the certification of a FEIR. It limits the
circumstances under which agencies can require new or supplemental environmental review. The
conditions cited in this provision are not a mandatory trigger for new or supplemental environmental
analysis prior to the completion of an FEIR. See also Master Response No. 17 – Supporting Information
fo 2013 FEIR/2015 DEIR and, with regard to cumulative development, response to Comment GP-231-3.
Please see response to Comment GP-231-3 for the issue of cumulative impact analysis.
OC-79-2
The commenter expresses an opinion that the City should have prepared a health assessment study for the
project. Air quality impacts of the project were addressed in Section 2.2.4 of the 2012 DEIR and 2013
FEIR/2015 DEIR. The air quality impact analysis addressed air pollutant emissions from diesel trucks.
The ambient air quality standards for criteria air pollutants are health-based, with an adequate margin of
safety, so projects that do not cause standards to be exceeded can be presumed to have minimal effects on
human health. Section 2.2.4 also addressed the human health impacts of toxic air pollutants. Air quality
and human health impacts were not addressed in the R-DEIR, and thus were outside of the scope of the
document currently in review. Please see Master Response no. 16 – Issues Out of Scope of the RDEIR.
OC-79-3
The commenter expresses an opinion that by purchasing parcels along 24th Street in advance of
completing the CEQA process, the City is pre-committed to the proposed project and has foreclosed the
consideration of alternatives. In Saltonstall v. City of Sacramento (2015) 234 Cal.App.4th 549, the Court
ruled that the City of Sacramento’s acquisition of property interests for construction of a new arena for
the Sacramento Kings in advance of project approval did not demonstrate a pre-commitment, and further
noted that, ”property acquisition did not foreclose any mitigation measures or alternatives”, and that
property acquisition neither compelled the City to approve the project nor to reject mitigation measures.
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Response to Oral Testimony OC-80
Comment
Code Response
OC-80-1 Your comment is acknowledged.
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Response to Oral Testimony OC-81
Comment
Code Response
OC-81-1 Your comment is acknowledged.
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Response to Oral Testimony OC-82
Comment
Code Response
OC-82-1 The commenter believes that the City is not synchronizing the traffic signals or considering one-way
streets. Please see Master Response to Comments No. 16 – Issues Out of Scope of the R-DEIR (Traffic
Signal Synchronization) and Master Response No. 18 – Alternatives (Alternatives Suggested by
Commenters).
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5. Response to Petition Concerning the
R-DEIR
A total of one petition was received concerning the 24th Street Improvement Project.
This petition is summarized in Table 5.
Table 5. Petitions on the 24th Street Improvement R-DEIR
Comment
Code
Date of
Petition Petition
No of Residents Who
Signed Petition
P-6 2/24/16 Homeowners of Beech Street in the Neighborhood of
Westchester
13
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Response to Petition P-6
Comment
Code Response
P-6 Your comments are acknowledged.