The following is a list of points you can make when commenting on the Caltrans DEIR. This list is slightly longer than the one found in the action alert. Suggested points to make in your letter:

Overall Points

• Mono Lake and its adjacent shorelands are a spectacular natural resource being restored to health. The highway project must comply with all existing protections, such as water quality and Scenic Area regulations. The DEIR does not adequately identify and analyze the significant environmental impacts of the project or present a full range of alternatives. Mono Lake deserves the highest level of protection from highway project impacts.
• After great effort by the stakeholder members of the Project Development Team to identify concerns and possible solutions, it is disappointing that all the DEIR build alternatives create significant ecological, visual, and water quality impacts.
• The DEIR outlines some mitigation measures but lacks measurable performance goals, lacks discussion of the impacts of the mitigation measures themselves, and does not provide evidence of local success with the suggested measures.
• The DEIR provides three alternatives: two construction alternatives and one “no build” alternative. Given the significant impacts of the construction options presented, the lack of response to agency concerns, the lack of supporting studies, and other inadequacies, Caltrans should select the “no build” alternative.

Safety points

• Both alternatives incorporate “design speed” increases to 60 mph, meaning curve straightening
  and faster traffic speeds. An alternative should be created which does not include design speed
  increase—as called for by the Project Development Team. This alternative would allow the impacts of curve straightening to be separated from impacts due to other actions.
• This stretch of highway is 20% safer than the statewide average for similar stretches and the
  DEIR does not analyze how higher speeds may reduce safety.

Fill slope points

• The DEIR does not acknowledge Mono Lake’s Outstanding National Resource Water status (the maximum protection of water quality possible under the Clean Water Act) or
  address the water quality concerns stated in writing by the Lahontan Regional Water Quality
  Control Board, in particular that movement of the highway toward the lake makes it likely that
  erosion prone fill slopes as well as highway spills and runoff will directly pollute Mono Lake.
• Revegetation of fill slopes is promised in the DEIR, but no criteria are set, no tests are cited that
  demonstrate success, and there is no plan for follow-up monitoring and action if revegetation does not occur as promised.
• The DEIR fails to explain how the fill slopes will be constructed and the associated impacts. Standard practice would call for construction roads and staging areas mere feet from the lake, creating totally unacceptable ecological and visual impacts.
• Fill slopes will have significant negative effects on the sensitive and unique wetland and riparian habitat areas that are highly productive for wildlife such as the rare Mountain Beaver and birds such as the endangered Willow Flycatcher.

Retaining wall points

• Use of retaining walls would create permanent visual scars, a concern expressed by the Forest Service and not addressed adequately in DEIR alternatives.
• Retaining walls obstruct deer and other wildlife movement. The DEIR does not examine the
  possible significant impact of increased wildlife deaths resulting from animals trapped on the
  highway, especially in combination with an increase in the speed of traffic.

DEIR adequacy points

• The DEIR fails to consider that Mono Lake is rising to a higher level as ordered by the State
  Water Resources Control Board. The DEIR does not adequately address associated impacts tied
  to the lake’s future closer proximity to the highway, creation of new wetlands, and lakeshore
  dynamics.
• The DEIR says “the project as currently proposed would have no adverse effect on any listed or
  sensitive species … .” But scientists have found Willow Flycatchers, a State Endangered Species
  and Forest Service Sensitive Species, in the project area and the DEIR anticipates losses to their
  riparian habitats. The DEIR must analyze impacts to Willow Flycatchers and incorporate
  protection protocols.
• The DEIR gives cursory treatment to Mountain Beaver, a State Species of Concern. The DEIR must incorporate expert analysis of Mountain Beaver habitat and presence, and incorporate meaningful protection for beavers and their habitat beyond just "construction will stop until the beaver leaves".
• The impacts of project components such as shoulder widening, rockfall control, pullouts, and
  realignment are not separately identified. It is virtually impossible to understand the causes of
  specific impacts and comment meaningfully as a result.
• The DEIR claims that the lands at Mono Lake are not of recreational or wildlife significance
  and exempts them from federal 4(f) protection, contrary to the written request of the US Forest
  Service. The DEIR states that the project is “consistent with the Mono Basin National Forest
  Scenic Area Management Plan” despite the Forest Service’s written notice that the project as
  designed “negatively impacts the goals and objectives outlined” in that plan. The DEIR will not
  be adequate unless federal 4(f) rules apply and the Forest Service determines the project
  compatible!
• Scientists have studied Mono Lake’s hydrology, geomorphology, and other characteristics for decades but none of their work is included in the DEIR, nor is any reference to the detailed studies conducted for the 1993 Los Angeles water rights EIR. These omissions leave critical gaps in projecting lake behavior at the higher management level (such as investigating how wave dynamics may move the shoreline westward into the fill slope area), determining where wetlands will be restored, and understanding current conditions.
• The DEIR contains an inadequate range of alternatives. None significantly reduce or eliminate visual impacts from cut slopes, fill slopes, and retaining walls. All these would have a negative effect on the visitor experience.
• Alternative 2 relies on a “design exception,” a critical component of a sensitive project, but does not commit to allowing one. This is misleading. Alternative 2 (and other even more appropriate approaches) can not be anticipated to be built unless Caltrans commits in writing to allowing design exceptions during the environmental review process.

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Last Updated January 04, 2005 Copyright © 1996-2005, Mono Lake Committee. (how to contact us)