By: Nevada County Transportation Commission (NCTC)
Jan. 19, 2009 - Below is the full text of the letter sent by the Nevada County Transportation Commission (NCTC) to Tom Last at the City of Grass Valley regarding comments on the draft Environmental Impact Report for the Idaho-Maryland Mine Project.
SUBJECT: Comments on the Draft Environmental Impact Report for the Idaho-Maryland Mine Project
Dear Mr. Last:
Thank you for the opportunity to review the Draft Environmental Impact Report (EIR) for the Idaho- Maryland Mine Project. After reviewing the Draft EIR and the associated traffic studies, I had an opportunity to review Caltrans comments and I offer the following additional comments on the project.
Caltrans noted that the traffic impacts of the project will be reduced as long as employee shift changes do not fall within existing peak traffic times. This is also true for truck trips that would be generated by mine operations. During the review of Appendix I - Idaho-Maryland Mine Project Traffic Study, NCTC staff noted that the daily trip generation numbers contained in Table 2C were understated.
Therefore, I believe it is important that the corrected daily trip numbers be used in further analysis of the project's impacts on transportation in and around the Grass Valley area. Since the project is designed to avoid traffic impacts during the A.M. and P.M. Peak Hours of traffic, it will be important that the "Peak Hour of the project" is analyzed for its impacts as well.
Caltrans also commented that a location impacted, even at off-peak times, is the existing short weave on the freeway between the Idaho-Maryland/East Main Street on-ramp and the Bennett Street off-ramp. The Environmental Impact Report does not contain a discussion of the impact of truck traffic on this weave section, and I believe the report should also consider the impact of traffic during shift changes at this location.
The report does not address the impacts of truck traffic on SR 49 south of Grass Valley, SR 174 east of Grass Valley, or on SR 20 west of Grass Valley or east of Nevada City. These impacts may not be significant, but the EIR should document that they have been considered and are appropriately addressed.
It also would be important for the EIR to include a discussion of how the trip distribution for the trucks from the mine operation was determined, and to quantify the number of trucks that will be entering and leaving the project site during the various hours of the day.
The Draft EIR and Appendix I - Idaho-Maryland Mine Project Traffic Study use numerous tables and figures to present details of baseline and project traffic in both the short range and 2030 scenarios. A list of land development projects near the proposed Idaho-Maryland Mine Project that are considered "approved" for construction in the near-term is provided along with the associated trip generation for those projects. However, for the long range (2030) scenario the document only states that future baseline peak hour traffic volumes were developed based on the citywide traffic demand model. It is requested that a table showing assumed increases in land use and the associated traffic generation for the long range scenario be added to the report. This table should indicate what land uses are assumed for the Special Development Areas in the Grass Valley sphere of influence.
The analysis identifies a list of short range roadway improvement projects and notes that they are included in the long range scenario. However, the analysis does not disclose if there are other long range roadway improvements included in the analysis. Additional information regarding long range roadway improvements would be helpful. For example, it is important to know if the analysis assumes that the Dorsey Drive Interchange is in place.
Please provide the Nevada County Transportation Commission with copies of any further information regarding this project. If you have any questions regarding these comments, please contact me at (530) 265-3202.
Sincerely,
Daniel B. Landon
Executive Director
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