APPENDIX G RESPONSES TO DRAFT EIS COMMENTS

Spaghetti Bowl Interchange Final Environmental Impact Statement

JULY 2019 | BI0218191221LAS APPENDIX G – RESPONSES TO DRAFT EIS COMMENTS | G-1

APPENDIX G – RESPONSES TO DRAFT EIS COMMENTS Comments Received During Draft EIS Availability Period During the Draft Environmental Impact Statement (EIS) availability period, Nevada Department of Transportation (NDOT) and Federal Highway Administration (FHWA) received a total of 456 comments from cooperating and participating agencies, local officials, interest groups, and the public, including verbal testimony from the public hearing. All comments are in this appendix within the following two sections:

∑ G.1: Agency Comments (pages G-1 through G-46)

∑ G.2: Public Comments (Written and Verbal) (starting on page G-47)

Chapter 4 of the Final EIS presents a summary of the public comments and responses to the comments.

The transcript of comments received at the December 12, 2018, public hearing follows the public comments in Section G.2. Note that the verbal and written comments in the transcript are also included in the public comments.

G.1 Agency Comments The commenting agencies are listed in the table below. Each letter and NDOT’s and FHWA’s responses are on pages G-1 through G-43.

Date of Letter/Email Agency

December 10, 2018 Federal Railroad Administration

December 14, 2018 Sparks Fire Department

December 27, 2018 Reno-Tahoe Airport Authority

January 14, 2019 Nevada National Guard

January 14, 2019 University of Nevada, Reno

January 15, 2019 Reno-Sparks Indian Colony

January 29, 2019 U.S. Department of the Interior, Bureau of Indian Affairs

February 4, 2019 U.S. Environmental Protection Agency

February 15, 2019 U.S. Department of the Interior, Office of Environmental Analysis

June 7, 2019 Nevada State Historic Preservation Office

Undated State Assemblyman Michael Sprinkle



Federal Railroad Administration

Comment noted.



Date: December 14, 2018 at 9:44:16 AM PST To: "[email protected]" Mr. Keller, Thank You for the presentation on 12/12. My only comment from the Sparks Fire perspective is from Alt. 2, the sooner we can get on eastbound I-80 the better for emergency response. If I am looking at the map correctly, the Kietzke on-ramp will not put us on the freeway until @ 21st Street. Which means an eastbound emergency response will have to come Reno. A 4th Street entrance would still be optimal. Thank You, Jim Reid Division Chief of Operations Sparks Fire Department 1605 Victorian Ave Sparks, NV 89431 [email protected] Office: (775) 353-2265 Cell: (775) 291-8616 Fax: (775) 353-1629

Sparks Fire Department

For the Preferred Alternative (Alternative 2) the Fourth Street/Prater Way and Rock Boulevard interchanges will be combined at Kietzke Lane. This was done to simplify ramp braiding with the Spaghetti Bowl ramps and improve weaving movements to the Pyramid Way interchange. The Kietzke Lane on-ramp to eastbound I-80 is about 1,500 feet to the east of the existing Fourth Street/Prater Way on-ramp. Fourth Street does not have enough capacity to warrant freeway access since it is now a two-lane, 25-mph street. Additionally, removing the Fourth Street interchange makes I-80 safer, reducing crashes. To respond to crashes on eastbound I-80 in this 1,500-foot segment of I-80 in Sparks, either the Sparks Fire Department would need to travel west to enter eastbound I-80 at Wells Avenue or the Reno Fire Department would have to respond.

mailto:[email protected]:[email protected]:[email protected]:(775)%20353-2265tel:(775)%20291-8616tel:(775)%20353-1629



Reno-Tahoe Airport Authority Note: Most of the comments in the Reno-Tahoe Airport Authority (RTAA) letter and memorandum are focused on the removal of the southbound direct-connect ramp from I-580 to the airport. The inclusion of the ramp (the “RTAA Preferred Alternative”) as part of the Preferred Alternative (Alternative 2) answers most of the concerns expressed in this letter.

1. In December 2018, NDOT sent a letter and comment response matrix to RTAA addressing the RTAA’s concerns on the Agency Administrative Draft EIS and how those concerns were addressed. The Final EIS addition of the southbound direct-connect ramp to the airport alleviates many of the RTAA’s concerns raised in their comment letter on the Administrative Draft of the Draft EIS.

2. The traffic forecast is not deficient because the traffic forecasts used for the Spaghetti Bowl study are consistent with the 2040 Regional Transportation Commission of Washoe County’s (RTC) Regional Transportation Plan (RTP) model provided to the project team in 2017. The Reno-Tahoe International Airport Master Plan was still in development when the 2040 RTP model was finalized. The 2040 RTP model provided to NDOT does not reflect the growth the RTAA identifies. That may be because RTC has not adopted the airport’s projected growth in their model yet or the RTP model is just not that precise when looking at one or two links among hundreds of links.

To account for the airport growth (as stated in the December 2018 Airport Master Plan), NDOT conducted a sensitivity test where the airport direct-connect traffic was doubled and run through the Alternative 2 alignment, including the reconstruction of Plumb Lane as a diverging diamond interchange. This represented a 65 percent increase in airport in/out traffic when compared to existing traffic volumes. The analysis shows that the intersections along Plumb Lane will still work at level of service C or better under Alternative 2 in 2040.



3. Recognizing Plumb Lane and the direct-connect ramps to and from I-580 are the main access points to the terminal area of the airport, there is a well-established circulation system providing access, especially in emergency situations. Emergency services can access all sides of the airport from I-580 via Mill Street, Plumb Lane, and Moana Lane interchanges; from I-80 via Rock Boulevard and McCarran Boulevard interchanges; and locally from arterial streets including Mill Street/Terminal Way (Reno Fire Department on Mill Street), Neil Road/Terminal Way/National Guard Way/Aviation Way (such as from Reno Fire Department stations on Moana Lane or Mira Loma Drive), Rock Boulevard, and McCarran Boulevard. As stated in the RTAA memo, most of the emergency access concern is related to the potential loss of the southbound direct-connect ramp from I-580. Including the ramp in the Preferred Alternative will preserve the existing emergency access to the airport.

4. Alternative 2 meets the project’s purpose and need, which is to:

∑ Reduce Travel Delay. High traffic volumes and an outdated freeway design contribute to congestion and travel delays.

∑ Improve Safety. The higher crash rates experienced along I-80 and I-580/US 395 in the study area, compared to similar urban freeways in Nevada, make safety improvement a key need.

∑ Bridge Condition. Most of the bridges in the study area are at or approaching the end of their planned service life. Furthermore, many are not wide enough to meet NDOT standards for traffic lane and shoulder widths.

∑ Importance of I-80 and I-580/US 395 in the Regional Transportation System. I-80, I-580, and US 395 are part of the National Highway System, providing important local and regional connections.

Including the southbound direct-connect ramp from I-580 in the Preferred Alternative eliminates the stated concern.

Alternative 2 improves safety along the freeways, ramps, and cross streets using a mix of ramp braiding and changes in access, reducing the locations where unsafe weaving of traffic would occur.



5. Based on RTAA and public comments in support of the southbound I-580 direct-connect ramp to Reno-Tahoe International Airport, NDOT added this ramp to Alternative 2, the Preferred Alternative. The impacts of including this ramp in the Preferred Alternative are documented in the Final EIS. Adding this ramp to the Preferred Alternative addresses most of the concerns in this memo.



6. At the outset of the study, NDOT and FHWA identified potential participating agencies. Per SAFETEA-LU Section 6002 guidance, “The lead agencies cannot know with certitude all the agencies with a potential interest until the alternatives have been developed...” (https://www.fhwa.dot.gov/hep/guidance/section6002/page02.cfm#Toc148770571).

NDOT first met with RTAA on June 15, 2017, to provide a project overview. During this meeting NDOT noted the project would study consolidating airport access at Plumb Lane. At an October 31, 2017, meeting NDOT discussed alternatives and specifically the direct-connect ramps and consolidating access at Plumb Lane. In June 2018, the RTAA was formally invited as a participating agency. Prior to Draft EIS approval, NDOT met with the RTAA ten times, making the RTAA one of the stakeholders met with most often during the study.

https://www.fhwa.dot.gov/hep/guidance/section6002/page02.cfm#Toc148770571



7. See comment response number 2.



8. NDOT updated the statistics based on RTAA data from December 2018 (https://renoairport.com/sites/default/files/statistics02/05/2019%20-%2010%3A48/Passenger%20and%20Cargo%20Statistics%20-%20Dec%202018.pdf) there were 4.21 million total passengers in 2018, an increase of 4.8 percent. In 2018, the airport handled 148.9 million pounds of air cargo, a decrease of 2.2 percent from 2017. Text was updated as follows:

The impact of the growing Reno-Sparks economy on Reno’s airport and the importance of the airport in serving the area’s economy can be seen in the growth in the number of passengers served and cargo shipped. Reno-Tahoe International Airport served more than 4.21 million passengers in 2018, an increase of 4.8 percent from 2017. This is the fourth consecutive year the Reno-Tahoe International Airport had year-over-year growth in passenger numbers. Reno-Tahoe International Airport handled nearly 148.9 million pounds of air cargo in 2018, a decrease of 2.2 percent from 2017, but a 10-million-pound increase from 2016.



9. Building the direct-connect ramps as part of a separate project would not remove the Plumb Lane interchange on I-580 and the interchanges south of Plumb Lane from this current Spaghetti Bowl study. As the direct-connect ramp is now part of the Preferred Alternative, this is a moot point.



10. The Plumb Lane interchange is and always has been part of the proposed action, regardless of inclusion of the direct-connect ramp.



11. Updated table 3.12-2 includes the project timeframe for these three RTAA projects of “Future project (2021 – 2036).”



12. To evaluate whether the project would increase carbon monoxide concentrations that would violate National Ambient Air Quality Standards (NAAQS) due to traffic delay at congested intersections, NDOT performed a quantitative carbon monoxide hot-spot analysis following U.S. Environmental Protection Agency’s (EPA) Guideline for Modeling Carbon Monoxide from Roadway Intersections (1992) and Using MOVES2014 in Project-Level Carbon Monoxide Analyses (2015). Following EPA’s guidance, NDOT then selected the three intersections with the highest volume and the three intersections with the highest delay for each alternative for further analysis.

The hot-spot modeling results (updated in May 2019 to include a receiver on Plumb Lane near Wooster High School) showed that carbon monoxide concentrations at the worst-case intersections for Alternatives 1, 2, and 3 would not exceed the 1-hour or 8-hour carbon monoxide air quality standards. All other intersections within the study area would have lower carbon monoxide concentrations than these worst-case intersections. Therefore, the project would not cause new violations of the NAAQS for carbon monoxide in the study area.



13. The RTAA comment does not explain what “land use conflicts” mean in this context. However, the Spaghetti Bowl Interchange Community Impacts Assessment Technical Report (Appendix D.2) notes that Alternatives 1 and 2 would consolidate access to and from I-580/US 395 to Plumb Lane. Those who access Wooster High School via I-580 to and from the north would experience a small increase (approximately one-quarter mile) in trip length. They would enter the school parking lot from Harvard Lane on the west side of the school rather than from Matley Lane on the east side of the school. Entrances to the school parking lot will still be available from Matley Lane.

14. The RTAA’s Preferred Alternative flyover ramp was added to Alternative 2 and NDOT analyzed the potential impacts of this ramp as part of the Final EIS. This southbound exit ramp to the airport would not impact the man-made irrigation ditch located near the airport. The exact location of the planned water quality detention basin in this area will be coordinated with the final design of the direct-connect ramp.

15. Impacts to that area were assessed. See Appendix D.11, page 4-1. “Small areas of natural vegetation along roadways… would be affected by construction.” NDOT and FHWA coordinated with U.S. Fish & Wildlife Service on potential biological impacts and received a Biological Opinion for the project. Lastly, NDOT’s current design of the southbound direct-connect ramp would use the existing bridge east of I-580, limiting impacts in this area.



Nevada National Guard

Based on the comments NDOT received in support of the southbound I-580 direct-connect ramp to Reno-Tahoe International Airport, NDOT added this ramp to Alternative 2, the Preferred Alternative. The impacts of including this ramp in the Preferred Alternative are documented in the Final EIS.



University of Nevada, Reno

1. Alternative 1 would acquire property from University of Nevada, Reno (UNR) on the north side of I-80 near Center Street. The Preferred Alternative, Alternative 2, would not acquire any UNR-owned property in this area. Alternative 1 would impact two buildings adjacent to I-80 at UNR’s Valley Road Field Laboratory. These buildings are used for research and storage. Alternative 2 would acquire a narrow strip of land (about 15 to 35 feet wide) from the south end of the Valley Road Field Laboratory along I-80. The acquisition would be about 0.65 acre. Based on aerial photos and a meeting with Valley Road Field Lab staff, it does not appear that any buildings or activities at the Valley Road Field Lab would be affected by this acquisition. See Section 3.2 of the Final EIS.

2. Alternative 2 has been identified as the Preferred Alternative. The impacts to the Valley Road Field Laboratory is one of the reasons Alternative 3 is not the Preferred Alternative. Thus, the impacts mentioned will not occur.



(See previous page)



Reno-Sparks Indian Colony

1. The Reno-Sparks Indian Colony (RSIC) Tribal Council endorsed Alternative 2 on January 30, 2019. NDOT and FHWA welcome the opportunity to continue working with RSIC in the future.

2. The letter correctly points out that the timing of future phases depends on availability of state and federal funds. NDOT and FHWA will continue to work with RSIC to minimize impacts to the best of NDOT’s ability from all phases of the project’s construction.



3. This section has been revised to 15 feet, rather than 20 feet.

4. As page 3.2-38 of the Draft EIS and page 3.2-42 of the Final EIS indicate, NDOT and FHWA commit to building a screening wall and landscaping along the eastern edge of the RSIC to mitigate for I-580 ramps and frontage roads moving significantly closer to RSIC residences. NDOT will also build a screening wall along I-580 adjacent to the RSIC.

The screening walls are not intended as a traffic noise barrier but will provide some noise-level reduction. Therefore, NDOT will not install double-paned glass windows in RSIC residences because the walls will reduce highway noise levels below the FHWA noise abatement criteria.

NDOT has also committed to burying the overhead power line on RSIC’s east boundary to mitigate visual impacts.

5. NDOT has agreed to perform the additional air quality modeling the RSIC requested. The results will be provided to RSIC.

6. Table 3.4-1 has not been revised. The Draft and Final EISs present a large amount of data. To enhance readability of the EIS, appendices are used to provide data for those readers that are interested in more detail. Section 3.4 has been modified to add a reference to Appendix D.5A Table B-1 so the reader interested in noise levels at a specific location can more easily locate this information.



7. NDOT and FHWA agree on the importance of continuing the productive relationship with RSIC during final design and construction of the Spaghetti Bowl Interchange.



From: Lewis, Charles Sent: Tuesday, January 29, 2019 8:41 AM To: Abdalla, Abdelmoez (FHWA) Subject: BIA Comments on Draft EIS, Section 4(f) Evaluation and Section 6(f) Evaluation, I-80/I-580/US 395 Interchange, Cities of Reno and City of Sparks, Washoe County, NV (Spaghetti Bowl) Del, The Bureau of Indian Affairs (BIA), Western Region has reviewed the subject Draft EIS (albeit briefly), comments provided by the Reno Sparks Indian Colony (Colony), and most importantly, the response-to-comments provided by Federal Highways (FHWA) and the Nevada Department of Transportation. We note that comment responses and conflict resolution with those issues concerning tribal trust land were, for the most part, amenable to Colony staff and leadership. Accordingly, BIA has no comment on the Spaghetti Bowl Draft EIS at this time. The BIA appreciates the sincerity with which FHWA consulted with Colony and the great lengths that you went to in order to address their concerns to the mutual benefit of both parties. You are to be commended on your efforts. If you have any questions or require additional information, please feel free to contact me. Chip Lewis Chip Lewis Regional Environmental Protection Officer DOI-BIA/WRO/EQS (602) 379-6750

Bureau of Indian Affairs

Comment noted.



U.S. Environmental Protection Agency

1. FHWA and NDOT will continue to coordinate with EPA and the U.S. Army Corps of Engineers to verify water resources impacts and determine mitigation. Coordination with the Corps of Engineers is occurring now regarding the first phase of construction (referred to as the Spaghetti Bowl Xpress), which will involve a new bridge crossing of the Truckee River. The existing bridge pier will remain in place during the Spaghetti Bowl Xpress phase.

FHWA and NDOT will coordinate with EPA, the Corps of Engineers, and the U.S. Fish and Wildlife Service when the river diversion plan and dewatering plan are developed for construction in the Truckee River, including removal of the pier. This construction is expected to occur in phase 4 in the mid-2030s.



2. NDOT will plant native seed mixes, plants, and trees in disturbed areas, including where pavement will be removed. NDOT is planning a series of stormwater detention basins that will treat stormwater run-off before it enters the Truckee River. These basins, discussed in Section 3.8 Water Resources, will improve water quality in the Truckee River.

3. In the first phase of construction (Spaghetti Bowl Xpress) NDOT is designing landscaping and a 10-foot-tall “screening wall” adjacent to the Reno-Sparks Indian Colony. The wall will provide a visual and noise barrier for RSIC residences, the Head Start program, and Anderson Park.

There are no other residences, parks, or schools adjacent to the Spaghetti Bowl Xpress. NDOT and FHWA will seek opportunities in the design of future phases to incorporate landscaping and vegetative barriers where they might reduce impacts to sensitive receivers.

4. NDOT and FHWA are continuing to consult with affected communities in developing mitigation measures. As noted above, a screening wall and landscaping will be installed as part of the project’s first phase, the Spaghetti Bowl Xpress.

NDOT will consider potential neighborhood-scale enhancements developed in conjunction with nearby residents or neighborhood advisory boards and City of Reno/City of Sparks. Please see Table 3.3-4 in Section 3.3, Environmental Justice, of the Final EIS.



5. NDOT and FHWA will continue to explore opportunities to reduce the project’s residential displacement impacts as future phases are designed. The first phase of construction, the Spaghetti Bowl Xpress, will have no residential displacements.



U.S. Department of the Interior, Office of Environmental Analysis

1. In a follow-up conversation with the National Park Service and Nevada State Parks trail coordinator on February 28, 2019, both agencies confirmed that the portion of the River Trail in the study area is not a Land and Water Conservation Fund property and therefore not subject to Section 6(f) conversion requirements. The temporary occupancy of Fisherman’s Park #1 is not anticipated to exceed 180 days.



2. Section 6.10.1 of the Final EIS has been modified to eliminate the reference to 0.9 acre, implying a one-for-one replacement ratio.

3. If the Preferred Alternative is modified to affect a Land and Water Conservation Fund property, NDOT and FHWA will notify the National Park Service and prepare a supplemental Section 6(f) assessment if needed.



Nevada State Historic Preservation Office

Comment noted.



State Assemblyman Michael Sprinkle

Based on the comments NDOT received in support of the southbound I-580 direct-connect ramp to Reno-Tahoe International Airport, NDOT added this ramp to Alternative 2, the Preferred Alternative. The impacts of including this ramp in the Preferred Alternative are documented in the Final EIS.



Local Resolutions of Support for the Project City of Reno



City of Sparks



Regional Transportation Commission of Washoe County

Washoe County Commission

APPENDIX G – RESPONSES TO DRAFT EIS COMMENTSComments Received During Draft EIS Availability PeriodG.1 Agency CommentsFederal Railroad AdministrationSparks Fire DepartmentReno-Tahoe Airport AuthorityNevada National GuardUniversity of Nevada, RenoReno-Sparks Indian ColonyBureau of Indian AffairsU.S. Environmental Protection AgencyU.S. Department of the Interior, Office of Environmental AnalysisNevada State Historic Preservation OfficeState Assemblyman Michael SprinkleLocal Resolutions of Support for the Project

Date post:	28-Jan-2021
Category:	Documents
Upload:	others
View:	1 times
Download:	0 times

APPENDIX G RESPONSES TO DRAFT EIS COMMENTS › wp-content › uploads › ...The transcript of...

Documents