California Department of Transportation
Comments on the draft Environmental Impact Report (DEIR) for the Arcata General Plan 2045 Update

There are many, many errors and omissions in the draft EIR for the General Plan update, as it was submitted. For more on the EIR and the comments, see portal page for EIR articles and Comments on the draft EIR from Fred Weis — What was submitted  

Some highlights:

• “We recommended that the Arcata General Plan recognize the Great Redwood Trail when discussing connectivity to Manila.”
  That would include the segment of The Great Redwood Trail that exists within the L Street Corridor, home of the new L Street Corridor linear park. All omitted from the draft EIR.

• “Figure 4.2-5 on page 381 shows a proposed new traffic signal at Route 255 and L Street. We note that L Street does not currently connect to Route 255. Please clarify the purpose of the proposed signal.”
  Note: This traffic signal could be for the pedestrian / bike crossing, to help people who are on the Great Redwood Trail in the L Street corridor to cross Samoa Boulevard (State Route 255).

• “The Arcata General Plan should mention the Caltrans planning efforts to pursue construction a freeway cap along US 101 between 14th Street and Sunset Avenue.”
• “Under the Transportation Regulatory Framework of the DEIR, the description of the City of Arcata Local Coastal Program states: “There are no transportation policies in the City of Arcata’s Local Coastal Plan applicable to the Project.” We encourage the City to support multimodal improvements to State highway corridors within the Coastal Zone to help support multimodal access to the Coast.”
• “The Arcata General Plan Update mentions providing clear signage along bicycle  boulevards. Please also include bike route sign guidance for the Hammond Trail, the Humboldt Bay Trail, and the Pacific Coast Bike Route (PCBR) specifically.”
• “The Arcata General Plan Update may provide an opportunity to modify the PCBR [editor’s note:  Pacific Coast Bike Route] so that it runs through Arcata as much as possible, thereby reducing the portion of the bike route that utilizes US 101, with consideration for creating an efficient route for multi-day touring bicyclists.”
• “The Arcata General Plan should describe any planned and/or desired changes that
  concern transit along the Route 255 corridor, including but not limited to, signal
  prioritization, express bus service, and transit stops.”

• “We note that there are developed areas within the City of Arcata that lack storm drain systems to convey stormwater runoff away from impervious surfaces such as roads and structures.  … There are times when sections of road in this neighborhood become inundated, and at least one home is put at risk during intense or prolonged storms. As there are listed species in the Caltrans ditch, it can be prohibitively time consuming to obtain environmental clearance to clear the ditch that drains this developed area within the City of Arcata.”
• “One of the data sources listed in the City’s VMT [editor’s note: Vehicle Miles Travelled analysis in the draft EIR] stems from the Humboldt County Regional Travel Demand Model. The base year for the model is 2015, using Census data from 2010.”
• “The city should coordinate with Humboldt Transit Authority (HTA) and Arcata and Mad
  River Transit Service (A&MRTS) to offer transit as a viable alternative to the automobile
  when encouraging infill development in the coastal zone.”

• “Page 357 of 1990 of the DEIR (Transportation setting) states that the Humboldt County  Association of Governments (HCAOG) is the Metropolitan Planning Organization (MPO) for Humboldt County. This statement should be revised to say that HCAOG is the Regional Transportation Planning Agency (RTPA) for Humboldt County.”

  There is a major distinction between an MPO and an RTPA. The authors of the draft EIR should know this. 

Text has been copied from the PDF of the original letter.
The original letter is below, here.

March 22, 2024

Mr. David Loya
Community Development Department
Arcata City Hall
736 F Street
Arcata, CA 95521

Dear Mr. Loya:

Thank you for giving Caltrans the opportunity to review and comment on the draft  Environmental Impact Report (DEIR) for the Arcata General Plan 2045 Update, which includes a new “Gateway Plan” Element. Other General Plan elements will receive varying levels of modification. The “Transportation and Circulation,” “Land Use,” and “Public Facilities and Infrastructure” elements will receive comprehensive updates to be consistent with the new Gateway element as well as other State mandates. The “Local Coastal  Element” will serve as the Local Coastal Program for approving land uses within Arcata’s Coastal Zone, which comprises approximately one-third of the land area of the city. We offer the following comments:

We appreciate and support the City of Arcata’s leadership and partnership in integrating land use and transportation and in working to develop a multimodal transportation network.

When planning for transportation and circulation, it may be helpful to recognize the  need for both mobility and access when planning for all modes of travel. Facilities that prioritize mobility will serve longer-distance travel more efficiently, whereas access-oriented routes provide links to traveler destinations. For roads and bikeways, these concepts are generally built into the functional classifications, however, access management may be needed to maintain the safe functioning of the route.

Caltrans offers to partner with the City to improve mobility and circulation for Arcata residents in the following capacities:

Providing intercity connections. Connecting pedestrian and bicyclist facilities from Arcata to other nearby communities. We have already seen the interest in, and benefits provided by the Bay trail, which took the first step in connecting Eureka and Arcata along US Route 101. This could also happen along State Route (SR) 255, which would provide a safe and convenient connection between Arcata and Manilla. The Annie and Mary Trail will someday connect Blue Lake and Arcata via SR 299. The McKinleyville Multimodal Connections Project discussed how to connect McKinleyville and Arcata along US 101. Moving forward, many of these projects may be led by Caltrans or require Caltrans oversight, but a significant level of involvement will be needed from the City.

Providing intra-city connections. Improvements to intersections and at interchanges along highway routes 101, 299, and 255 will present additional opportunities to coordinate. Where collaboration with the State can be foreseen, please identify where, in the transportation and circulation element, Caltrans’ participation is anticipated.

Circulation and Mobility Element
The General Plan Transportation and Circulation and Local Coastal Program (LCP) elements should be, and remain, consistent with the Humboldt County Regional Transportation Plan (VROOM) regional plans, policies and projects, especially that advance improving active transportation (bicycle/pedestrian) and transit networks and connectivity, equity and climate adaptation.

Page 357 of 1990 of the DEIR (Transportation setting) st ates that the Humboldt County Association of Governments (HCAOG) is the Metropolitan Planning Organization (MPO) for Humboldt County. This statement should be revised to say that HCAOG is the Regional Transportation Planning Agency (RTPA) for Humboldt County. In California, RTPAs serve the same transportation planning and programming purpose as MPOs for rural parts of the State. Unlike MPOs, however, RTPAs are not subject to the requirement to develop a Sustainable Community Strategy (SCS) per SB 375.

The Arcata General Plan should mention the Caltrans planning efforts to pursue construction a freeway cap along US 101 between 14th Street and Sunset Avenue.

Route 255 / Samoa Blvd
The Arcata General Plan should describe any planned and/or desired changes that concern transit along the Route 255 corridor, including but not limited to, signal prioritization, express bus service, and transit stops.

We recommended that the Arcata General Plan recognize the Great Redwood Trail when discussing connectivity to Manila. Figure 4.2-5 on page 381 shows a proposed new traffic signal at Route 255 and L Street. We note that L Street does not currently connect to Route 255. Please clarify the purpose of the proposed signal. Is it intended to signalize the bike trail crossing near the railroad tracks or does the City plan on extending L Street to connect to SR 255? Additional traffic studies may be needed for either option as well as an Intersection Control Evaluation (ICE) to verify that a traffic signal is the preferred method of traffic control. For more information about the Caltrans ICE policy and practices, please view the Caltrans website:  <https://dot.ca.gov/programs/traffic-operations/ice>.

Easternmost Sunset Roundabout
This is an opportunity to mention any planned and/or desired changes concerning the existing G Street overpass. Caltrans is currently considering opportunities by which this overpass might be improved, including the potential decoupling of same from the northbound (NB) US 101 offramp to Sunset Avenue.

Giuntoli / Route 299 Ramp Roundabouts
We recommend that the City consider connecting the proposed roundabouts at the SR 299 on/off ramps to Boyd Road and West End Road, respectively. This would allow each  roundabout to consolidate both the on/off ramp intersection with the nearby local road intersection resulting in significant connectivity and traffic flow improvements.

Bike Plans
The Arcata General Plan Update mentions providing clear signage along bicycle boulevards. Please also include bike route sign guidance for the Hammond Trail, the Humboldt Bay Trail, and the Pacific Coast Bike Route (PCBR) specifically.

New bike routes/facilities across Giuntoli Lane that interconnect SR 299, US 101, the Hammond Trail, and the Murray Trail access via Heindon Road should be considered.

The Arcata General Plan Update may provide an opportunity to modify the PCBR so that it runs through Arcata as much as possible, thereby reducing the portion of the bike route that utilizes US 101, with consideration for creating an efficient route for multi-day touring bicyclists. This may be an opportunity to plan for a connection between the southbound (SB) US 101 on- and offramps to South G Street and the existing Arcata portion of the Humboldt Bay Trail. US 101 is an access-controlled freeway through most of Arcata, so the bike trail connection would have to be installed at the southern terminus of South G Street where the freeway transitions to expressway. A connection at this location would allow bicyclists traveling southbound on US 101 to exit the freeway and access the Humboldt Bay Trail.

Transit
The city should coordinate with Humboldt Transit Authority (HTA) and Arcata and Mad River Transit Service (A&MRTS) to offer transit as a viable alternative to the automobile when encouraging infill development in the coastal zone. This applies to clustering new development, subdivisions, mixed use, industrial, commercial use, residential use etc. The impact of transit is magnified when cities and the County undertake land use decisions that favor transit such as increasing density or prioritizing areas around transit stops for development.

Among the region’s transit agencies, please include HTA and A&MRTS in the list of stakeholders for regional collaboration.

Hydrology
We note that there are developed areas within the City of Arcata that lack storm drain systems to convey stormwater runoff away from impervious surfaces such as roads and structures. An example of this is the developed area between F Street and US 101, and between SR 255 and 11th St. Much of this area depends on the ditch system that was designed to accept highway runoff. There are times when sections of road in this neighborhood become inundated, and at least one home is put at risk during intense or prolonged storms. As there are listed species in the Caltrans ditch, it can be prohibitively time consuming to obtain environmental clearance to clear the ditch that drains this developed area within the City of Arcata. The residents of this and other developed areas would be better served by the installation of storm drains designed to properly drain the area during winter storms.

Appendix G: VMT
One of the data sources listed in the City’s VMT stems from the Humboldt County Regional Travel Demand Model. The base year for the model is 2015, using Census data from 2010. The horizon year of the model is 2045, which matches the horizon year of the General Plan Update. We recommend working with the Caltrans Travel Demand modeling staff to maintain the model on a regular basis to ensure its longterm functionality.

Local Coastal Element
Under the Transportation Regulatory Framework of the DEIR, the description of the City of Arcata Local Coastal Program states: “There are no transportation policies in the City of Arcata’s Local Coastal Plan applicable to the Project.” We encourage the City to support multimodal improvements to State highway corridors within the Coastal Zone to help support multimodal access to the Coast.
 
We request that the General Plan Update anticipate and promote a collaborative approach to working with Caltrans to plan for a resilient transportation network within the Coastal Zone in the face of Climate Change and Sea Level Rise.

The Caltrans District System Planning office will be developing a Corridor Management Plan for SR 255 in the first half of 2024. Beyond the highway facility itself, we will look to improve multimodal modes of travel along the highway corridor. As one of the primary origin and destinations for SR 255, the City is expected to be a key stakeholder in shaping the choice of travel modes along the corridor.

The LCP should also be consistent with Caltrans SR 255 Corridor Management Plan and City of Arcata’s 23/24 STP grant, South Arcata Multi-Modal Safety Improvements Plan.

Please contact me with questions or for further assistance with the comments provided
at (707) 684-6879 or email: <[email protected]>.

Sincerely,

JESSE ROBERTSON
Transportation Planning
Caltrans District 1

c: Netra Khatri, City Engineer, City of Arcata
Beth Burks, Executive Director, Humboldt County Association of Governments
Hank Seemann, Deputy Director, Humboldt County Public Works
State Clearinghouse

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