This was just sent in and an auto reply stated that if it was "received prior to June 17th," it would be part of the public record and responded to in the Final Environmental Document for CalTrans' proposed widening of Carbon Canyon Road (State Route 142) at the S-curves in Chino Hills. It was understood, however, that today was the last day to submit such comments, so we'll see.
The proposed project to “improve” Carbon Canyon Road (State Route 142) by widening it at the S-curves in Chino Hills is couched as an imperative to improve safety because of community concerns.
It should be noted, though, that those expressions were not based on the idea that large trucks were crossing the centerline and, therefore, the road should be widened to accommodate more of these vehicles.
Rather, community members were reflecting what has been long understood—Carbon Canyon Road was not built to handle any vehicle with more than four axles and this is clearly represented in existing road alignments and widths elsewhere along its length, not just at the S-curves.
This misrepresentation and flawed interpretation is worsened by the claim that the truck ban instituted just two years ago was intended to be temporary and that the cities of Brea and Chino Hills understood this when signing the agreement.
Adding to the problem is the unaccountable lack of reasonable noticing to those in affected areas of the Canyon, but also to those using the state highway. This bare minimum of informing just 32 households among hundreds near the project area leaves the indelible impression of a deliberate attempt to evade public scrutiny and minimize community input. For a government agency, funded by our tax dollars and ostensibly tasked with acceptable levels of transparency, to engage in what can only be termed subterfuge, is deeply disappointing and can only lead to further erosion of trust.
While the original Draft Initial Study required public comment by 16 May, despite almost no public notice of a reasonable level, it was only after a considerable outcry that CalTrans decided to hold a sole public meeting, and this by Zoom, on 10 June. The lack of a face-to-face gathering is suggestive of a clear lack of interest by the agency in fairly and responsibly engaging with its own constituency, a stunningly tone-deaf circumstance that defies reason and sense.
Despite this, nearly 100 residents attended an in-person gathering while many more logged in from elsewhere, including City of Chino Hills staff and officials. The input provided to CalTrans officials was clear and unambiguous and, after more than two hours, not a single person expressed any support for the proposal.
As already noted, the insistence that it was understood, by the terms of the 2024 agreement, that the truck ban was to be temporary, was not just met with disbelief by residents, but by city elected officials and staff.
Also striking was the curt dismissal by agency personnel that other areas with similar structural constraints, notably the sharp, narrow curves in Sleepy Hollow (I have a direct view of the most problematic of these), were simply irrelevant because of being outside the limits and scope of this project. The widening of the S-curves to facilitate five-axle or larger truck traffic will, in fact, encourage more use, but, with conditions unchanged elsewhere, as at Sleepy Hollow, the risks become greater.
The Draft Initial Study offers a Proposed Mitigated Negative Declaration, which asserts that there would be no significant effects relative to air quality and greenhouse gas emissions. One conclusion for this is that “the project will/would not increase capacity,” while it is added that no air quality study is needed. Yet, if the “operational improvements” are declared to make it easier for trucks with more than four axles to negotiate the S-curves, is the position by the agency that this won’t be an encouragement for more trucks to use this route? Isn’t there a distinction to be made between “capacity” and “use”? The Study also avers that because of “improving operation,” this means that “as such, long-term operations would not result in impacts to air-quality.” These conclusions look to be based purely on the agency’s internal review, but shouldn’t there be an opportunity for an independent, third-party review of these issues? It should be added that massive residential construction, as well as commercial and industrial development, in south Chino and south Ontario, will undoubtedly add many more vehicles, cars and trucks, to SR-142. Has a traffic study accounted for this?
Under “Land Use and Planning,” it is remarked that SR-142 is a “main connector between Orange County and Chino Hills” and “an alternative” to state routes 57, 60 and 91, but there is no acknowledgment of which kind of vehicles are and should be so connected and how much of an alternative Carbon Canyon Road is, given its inherently limited capacity, especially compared to the multi-lane freeways designed to accommodate and handle much larger vehicles. Further, this section talks about “residents” of four Chino Hills neighborhoods (this would need reworking, as there are more than four and “Litel/Ayala” and “Chino Hills Estates” are, to my understanding, not actual neighborhoods in the area), but clearly the vast majority of users of the highway are not locals and, as noted above, the number of commuters will increase dramatically in coming years.
In the “Noise” section, this, too, is dismissed because of the faulty assumption that “capacity” is equal to “use” and that there would be no increase of truck traffic, with noisier engines and brakes than most other vehicles.
With “Public Services,” the criteria regarding police and fire protection is that there would be no “acquired or displaced” stations or no “affect [on] the level of service,” but, again, this appears to be a presumption that there would be no demonstrable increased use.
Again, under “Transportation,” the claim is repeated that, because the proposed project “does not involve any capacity increasing elements,” but is merely providing “operational improvements to accommodate freight trucks,” a VMT (Vehicle Miles Traveled) analysis is not required. As to the assertion that widening the curves will enhance safety and there is no impact whatsoever with respect to hazards due to “incompatible uses,” it should be noted that doing so will actually increase speeds and there is already a long history of accidents in this section, involving damage to personal property, utility poles, as well as injury and death, which could be viewed as “incompatible uses” and are obvious detriments to safety.
To sum up, this Draft Initial Study appears to be incomplete and insufficient, lacking in a deep, detailed analysis of traffic and pollution and questionable in its lack of distinction between capacity and use. The almost total lack of public engagement and the half-hearted attempt, late in the process, to hold a Zoom meeting, which built barriers between the agency and its constituents, also is highly problematic. Lastly, the misinterpretation of community concerns about trucks crossing the centerline and the claims about the understanding of the truck ban as temporary and subject to rescinding regardless of the outcome of this proposal are just implausible.
You have heard clearly and unequivocally from the City of Chino Hills, the Chino Valley Fire District, San Bernardino County Fourth District Supervisor Curt Hagman and 32nd District State Senator Kelly Seyarto. You have also heard resoundingly from constituents who expressed unanimity at the meeting and, presumably, have done so, or nearly so, in public comment.
Please heed the undeviating views of our local officials and
residents and utilize our taxpayer money and your human resources for Cal Trans
projects elsewhere in District 8.
