Batch Plant Traffic Disaster
by Mark Scaramella, April 18, 2012
After almost two days of public input and discussion the Supervisors unanimously approved the Environmental Impact Report for Northern Aggregate’s asphalt plant and expanded gravel mining operation.
A startlingly obtrusive industrial presence at the top of the Willits Grade on the west side of Highway 101, the quarry has been in place for many years. In today's much more sensitive environmental climate it probably would not have been approved. But it's there, and it's been there for years. The debate has been about its expansion in include an asphalt operation and to amend the County code to permit similar operations at the County's dozen or so other quarries.
Project supporters argued that expansion of the Ridgewood quarry will create jobs, provide needed asphalt from a local source, and bring increased revenue to the County. Several speakers commended the owners of the project — Frank Dutra and Randy Lucchetti — as responsible persons who will abide by whatever conditions the Supervisors might apply.
The Supervisors were persuaded that there would be adequate monitoring of the permit, and Northern Aggregates has agreed to pay for a “mitigation monitoring” program to at least partially finance whatever inspection and review the County does.
Several dozen opponents argued that the project would pollute the local area water and air, further degrade the otherwise rural landscape, reduce property values, and create a serious traffic safety problem.
The traffic engineer for the quarry's owners, Ms. MaryJoe Young, began her presentation by showing a diagram of the current traffic patterns.
“There are travel lanes and turn lanes both north and southbound. There are no turn lanes at the quarry entrance. The project proposes to add four turn lanes to make improvements at the quarry entrance. The first two are deceleration lanes, one in the northbound direction and one in the southbound direction. These two lanes provide additional space in the highway for trucks to enter and brake outside the highway, the flow of the highway. They also will add two acceleration lanes, one for trucks turning right out of the quarry and one for trucks turning left [up the grade]. These two lanes are meant for trucks to gain some speed before they move into the higher speed travel. There have been comments relative to the design of the northbound acceleration lane partly because it extends north of Black Bart Drive [where there is already a left turn lane] and partly because it is a change to the existing configuration where there will be accelerating and decelerating motorists sharing the [center] lane. Those lanes were all designed to the very rigorous standards of the highway design manual, the state's highway design manual and Caltrans has reviewed and supports the design. It is hard to visualize actually how it will operate and that's why we created this short model which animates the conditions of the use of all the turning lanes. We take what we call the peak, peak, peak condition, the high volumes of trucks turning out of the quarry in and out in an hour in a peak month of production in October in the year 2040 where [traffic] volumes on the highway at Black Bart Drive are expected to be more than one and a half times what they are today.”
Ms. Young turned to the overhead screen.
“The Green boxes are the trucks… the little white cars. This is not to scale. It is meant to show you the actual operations of the volumes and the speeds. You can see that the two travel lanes, trucks are staying outside the high flow speeds and there is no lane changes necessary as a result. There’s a car using the acceleration lane and is queued up to turn left onto Black Bart Drive. These lanes benefit all highway users, not just the quarry operator and their truck drivers. You can see a car that just turned left out a Black Bart Drive which will be able to utilize the acceleration lane for their northbound left and all the highway traffic will be able to be operate in a safe manner, safer conditions than today.”
Several speakers took serious issue with Ms. Young’s simplified “not to scale” assessment of the all-hours traffic hurtling up and down the Willits Grade.
Deborah Pruitt, a resident of the area: “I am confused by the model of the traffic situation that is not to scale and really cannot represent what it's like to turn in that intersection regularly like some of us do and have had close calls. So I just want to highlight that. The traffic that comes in there is not predictable and cannot be represented by a model situation. So if you add more variables you just add more potential for serious harm. What looks like a good idea does not necessarily mean it's a good decision now. Our community has no obligation to support this.”
Sheila Jenkins: “Access to the quarry is on a long sweeping curve and it's on an uphill grade below the crest of the summit which also reduces visibility. This is contrary to what the EIR claims which is that sight distances are adequate. Actually they are impaired. The traffic plan here at the quarry along this treacherous stretch of high speed expressway calls for a tripling of the current truck traffic. At least half of that truck traffic will head north entering the freeway, not from an interchange with a long outside acceleration lane, but instead they will be entering to a short center lane in the middle of the freeway that we call the conflict lane. That lane is only 469 feet long. This lane is not only short but it is going to be shared by the folks turning onto Black Bart Drive decelerating while the trucks leaving the quarry will be accelerating. So we will have in effect a Cessna 150 coming in for a landing with a 747 taking off behind it on a short runway in the middle of four lanes of high speed expressway on a blind curve. This is a very uncommon traffic plan contrary to what the EIR claims. How did this lane get so short? Well, through negotiations with Caltrans, behind closed doors which the public was not invited to. This letter [displays a letter on the screen] shows the lane reduced from nearly 600 feet to 469. Another letter successfully negotiated the southbound deceleration lane into the quarry from 400 feet and what is already undersized to only 200 feet. This does not in any way meet the Caltrans standards. Nonetheless, apparently Caltrans can be quite flexible if you are well-connected. But this comes at a price. The accident rate will increase by this right along with the death rate. This is a letter [displaying another letter on the screen] from the applicant's lawyer requesting that the mitigation measure requiring construction of an interchange be deleted claiming that the mitigation measures are adequate through 2040. But the intersection is currently operating at level of service “D” which is flunking. And it will be at level of service “E” by 2014, and level of service “F” by 2030. So there is nothing to support their claim that this intersection will be functioning adequately through 2040. They don't even want to share in the cost of a $36 million interchange. We are asking that they provide for a partial or full interchange out of the right-of-way. I urge you not to obligate the taxpayer for an interchange by being shortsighted. We are tired of the profits being privatized while the costs are socialized. This is the name of the game these days so please be on your guard.”
Stacy Rohrbaugh. “I live on Ridgeview Road. Instead of an interchange they have designed a conflict lane in the middle of a four-lane highway. 469 feet — that's how much conflict lane there is from the quarry entrance to Black Bart intersection. A truck and its trailer are 75 feet long. That leaves 394 feet of lane for the trucks to accelerate and turning cars to decelerate, not the 600 feet minimum of roadway that is required for each of those actions. So driving north rounding the bend before the quarry access driving 70 or 75 mph in the fast lane, a driver comes upon a truck that has pulled out into the conflict lane. The driver has a split-second decision to make. The best case scenario would be to swerve in front of the truck into the 200 feet of roadway because at this point that is all that's left of the conflict lane. The truck, fully loaded and accelerating, will need to come to a stop to wait for the driver to turn onto Black Bart Drive. This puts the trucker in risk of rear-ending the car. The other scenario would have the truck in the middle of the conflict lane. Then the decision is to pull in behind the truck, abruptly decelerate, risk being rear-ended by traffic in the fast lane, or again swerving in front of the truck and risk being rear-ended by the truck. Each of these scenarios happens in less than 200 feet of conflict lane. The EIR states that a prudent driver will not have to make any abrupt stops. We need to think about worst-case scenarios and what they may look like. It is unclear to me why our leadership wishes to make an already substandard intersection worse for the citizens. We need to really consider putting significant unavoidable impacts into play. How much risk are you willing to be liable for? Do these impacts really fit into the general plan? Do not certify this bad EIR. Keep the code, please.”
At the end of the Monday hearing, Board Chair John McCowen suggested “both because of the complexity of some of the comments that have been received, and also the lateness of the hour, we might not be doing our best deliberation if we take it up now.” The Board adjourned for the day.
After an overnight rest to collect their thoughts, the traffic arguments resumed.
Supervisor Hamburg: “I noticed that there was a comment made that the amount of truck traffic coming in and out of the quarry would be tripled. I don't know what that was based on — 75,000 tons a year to the 200,000 tons a year? If that was the calculation that was made, I think a lot of people forget that a lot of that raw material that has been leaving the site as raw material would instead be staying on the site and going to the asphalt plant and not leaving as raw material but actually leaving as finished product. I noticed in the EIR on page 217 where it talks about in peak days that you would have a truck turning left into the quarry every 5.5 minutes and one turning out of the quarry every 4.4 minutes which is — that's pretty intense, that's pretty intense traffic. I guess my question to the traffic experts is, how would you characterize the increased peak today versus peak say when this plant is up and running? How much additional traffic?”
EIR consultant Leonard Charles: “You're looking at the EI — the traffic?”
Hamburg: “No, I'm not actually. You’re not the main traffic guy here.”
Charles: “I could sit here and look these over myself but I am not a traffic engineer either, so there is an increase in traffic, I think that number is wrong, that 5.5 and 4.4. I think whoever in my office wrote that got it backwards, but in any case, you know, it's within that area. And again that's for the peak worst-case site day but the overall increase in traffic, uh, let’s, let's see —”
Hamburg: “I feel like I saw it somewhere in the document. But I just can't put my finger on it.”
Supervisor John McCowen: “Supervisor Pinches might have a follow-up on that.”
Supervisor John Pinches: “Well, if you are putting out a truck every 4.4 minutes I would like to hire that loader operator.” Everybody laughed.
Charles: “Well, it includes both aggregate and asphalt so they would be coming from two different facilities.”
Hamburg: “I mean, if it wasn't for the increased traffic you would not have these major mitigations on Highway 101 that are part of this project and I'm sure nobody's forgetting that, but all the same it's a lot of trucks.”
Charles: “And I should have included it because a lot of people spoke on this subject, and I don't want to insinuate that the lawyer's letter is the only thing we paid any attention to, but there was obviously a number of people from the community who expressed their concerns about the safety of the intersections, what happens during bad weather conditions, foggy conditions, etc. And we looked at all that in the EIR. I realize that people will disagree with it. But again I think that an important issue to remember is that this is not a new project being put on this site, it's the baseline condition which is big heavy trucks moving out into the fast lanes of traffic now or you know, or, so, you know. And so the impacts actually get reduced despite the counterintuitive thing that you are increasing the traffic considerably particularly during peak days, it's actually safer with lower traffic coming out of there under existing conditions.
McCowen: “And the traffic improvements, I think it's been established, are actually justified based on the existing conditions but, and, so maybe why the applicant is being required to pay for this is because the additional contribution would then be cumulatively considerable? [“Cumulatively considerable” is a special — but highly subjective — planning term that means if something is “cumulatively considerable” i.e., has a significant cumulative impact, and McCowen was using it to lead the witness, Mr. Charles.]
Charles: “Partly that, and partly that you don't really have the ability to condition the existing conditions and make them come up to it. I mean you can condition the, even if you did the Alternative 3 which is just the expansion of the quarry, that gives you the ability to condition that…
McCowen: “That's discretionary?”
McCowen: “By the same token and the supposed interchange to the extent that deals with the existing traffic based on Black Bart there would be no mechanism to require any of them to make a contribution even though they might benefit.”
Charles: “No. It’s only—”
McCowen: “It's only for a current project or a new project that might come along.”
Charles: “And that's where they rightfully point out that if that was the mitigation measure and it was not being funded by the applicant you couldn't use it as a mitigation measure because the residents out there in the subdivision out there are not going to pay for it so it is the county that would have to pay for it. And you don't have any money. So it wouldn't get funded. So then you would have an unmitigated impact in that case.”
McCowen: “But you also can't make an applicant pay more than their proportionate share, so—?” [Shrugs, looks inquisitive.]
Charles: “Right on! Yes. That's thankfully not my business.”
McCowen: “So if that really— is that even a feasible mitigation then to even include? It struck me when I first read it that this is really dreamland to be talking about an interchange would be funded given that there is no one to assess the existing impact to.”
Charles: “If, if, if you think that's the case as a board, again, you could find that there is the potential over the long term that the mitigation measures that can be implemented that are included in the EIR are not satisfactory and really that you think it is eventually going to have to be an interchange there and there is no way to fund it. And if you did that then you would have a significant impact that you would have to add to your, to your statement of overriding considerations if you were to go ahead and approve the project.”
Hamburg: “I also want to point out that the southbound departure lane is not actually warranted based on Caltrans calculations. Isn't that right? At least that's what I —”
Charles: “I believe that's true.”
McCowen: “It said that only the 300 foot taper was actually warranted and that they are required to do the 1400 plus the 300 or —?
Hamburg: “Well, they are doing 1090 feet in addition to the 300 foot taper which is — and that 1000 feet is beyond the warrants that Caltrans would require.”
McCowen: “But again we have that leeway based on the discretionary permit before us?”
Charles: “It is not warranted under base conditions, but now I have to go see if it's warranted under —”
Hamburg: “Page 220? Is that the place it shows up?”
Charles: [Pages through thick document. Runs finger down page. Looks back and forth, up and down.] “Right. It's only a tapered warrant, that is correct. [Turns more pages looks at more paragraphs.]
McCowen: “They say it is based on the observation of the truck driver turns and their disruption to the flow of traffic indicate the need for the full acceleration lane.”
Charles: “The — I want to go back to what you are saying Supervisor McCowen about the infeasability of the interchange. I'm looking at that mitigation measure. It says if the monitoring report that goes on shows that safety or operational problems at either intersection, there is a safety, that an evaluation will be conducted with potential additional mitigation measures that should be considered for implementation and one of those is a partial, or… and other ones are limits on how many trucks can be loaded during peak hours, limits on trucks making left turns in and out of the access driveway during peak hours, and provision of a partial or full interchange at the highway intersection. So that is part of that but not the entire, the entirety of that mitigation.”
* * *
That was it. Traffic problem addressed.
In fact, according to prior testimony at the Planning Commission, the average number of trucks going in or out of the quarry per hour at the present time is about 18 trucks or one every 3.3 minutes. With the batch plant and the increased volume, they expect up to 50 trucks per hour at peak hours. (Almost one every minute.) Accordingly, up to 15 trucks per hour would be making the left turn into the northbound, uphill center “conflict” lane during the busiest hours (about one every four minutes just for that one lane in that one direction from the asphalt plant alone).
I drive that stretch in both directions on my way to and from the printer in Willits every Tuesday night. It’s true that most of the time traffic is fairly light, and in ordinary weather the additional traffic from the quarry would be somewhat mitigated by a northbound center turn lane (the acceleration lane) and a northbound deceleration center lane at the quarry entrance for trucks turning left into the quarry. But it’s also true that in rainy weather you simply cannot see the road because the yellow and white lane markers are worn down both in the middle of the highway and on the sides and the roadway cannot be seen in the glare of oncoming headlights reflecting off the wet surface at night. Besides the occasional thick fog, several times a year it snows or freezes or both at the top of that grade at the gravel mining entrance making the road and the oncoming traffic not only invisible, but extremely slippery. Add high winds which are common in the area to the existing 65 mph speed limit, which few drivers observe, and you quickly get to what Ms. Pruitt called “more variables which just add more potential for serious harm.”
When the permit comes up for discussion in the next few weeks, additional attention will be paid to the traffic problem created by the entering and exiting batch plant trucks. If not, the traffic associated with the asphalt plant will virtually assure that the area is bad accidents waiting to happen.