There are too many issues surrounding the Caltrans plan to widen Highway 99 from Ashlan Avenue in Fresno to Avenue 7 in Madera County to cover in just one blog post. This is the third and last in a series of posts that document the Island Park Six-Lane Project and offer my views on the substantial negative impacts this project will have on our nonprofit 501(c)3 Fresno Aquarium project and my beloved hometown since 1979…
During the process of implementing the San Joaquin River Settlement, there have been a series of meetings held to determine the course of action to restore the river and bring Chinook salmon spawning runs back to the stretch of the river that flows through Fresno. I had the pleasure of attending a number of these meetings and was impressed by the thought and planning of fisheries professionals that has gone into this process. A tremendous amount of time and government (read: taxpayer) expense has been dedicated to this restoration process, but this doesn’t seem to matter much to Caltrans as it plans its new Highway 99 freeway bridge over Reach 1 of this historic effort.
The FHWA (Federal Highway Administration) is very specific in its National Highway Runoff Data and Methodology Synthesis (2003) when it comes to how state transportation agencies (STAs) should conduct their studies when it comes to constituents in freeway runoff, especially when such runoff flows directly into environmentally sensitive waters such as the San Joaquin River. FHWA’s data quality objectives (DQOs) process is designed to help weigh the costs of data acquisition against the consequences of a decision error. In the Island Park Six-Lane Project Technical Studies, Caltrans simply states that as long as best management practices (BMPs) are followed, no significant impact would occur from the runoff expected to be generated by the new six lane freeway bridge over the San Joaquin River adjacent to the future Fresno Aquarium property (see photo above). Unfortunately, Caltrans cites no actual studies nor identifies what chemicals the runoff from this project might consist of. Caltrans states that its new retention basins to be sited next to the river will mitigate any impacts to the river even though the designs and required sizes of these retention basins are not provided nor analyzed.
To demonstrate that water-quality data are valid and technically supportable, FHWA requires sufficient documentation to prove that the data are meaningful, representative, complete, precise, accurate, comparable, repeatable, and admissible as legal evidence (Alm and Messner, 1984; FHWA, 1986; ITFM, 1995a, 1995b; USEPA, 1997).
FHWA’s DQOs process is intended to help weigh the costs and beneﬁts of local short-term monitoring requirements against regional and national long-term information needs, but FHWA also stresses that monitoring activities need to be improved and integrated to meet the full range of local, regional, and national information needs more effectively and economically (ITFM, 1995a).
Caltrans highway construction division has recently been criticized by California’s Legislative Analyst’s Office for its inefficiencies and overstaffing. With the majority of Caltrans environmental work being performed by outside consultants to expedite project delivery, the resulting lack of oversight often results in environmental corners being cut, cookie cutter approaches to wide ranging regional issues and bureaucratic unresponsiveness due to Caltrans personnel relying too heavily on these hired guns for the preparation of their environmental documents.
In the DQOs process, FHWA characterizes decision errors as Type I or Type II errors. Caltrans, stuck in a system that relies on outside consultants, has a much greater chance of making a Type II error than a Type I error. Let me explain.
A Type I error occurs when a determination is made, on the basis of available data, that problems exist when they do not really exist and a Type II error occurs when real problems exist but the determination is made, on the basis of available data, that no problems exist. A paid consultant who comes up with too many problems that end up not being real (Type I) simply won’t be a paid consultant for long, but one that simply doesn’t provide data (and therefore doesn’t find/disclose any problems) will have success in delivering projects for Caltrans quickly and will therefore be rewarded future contracts again and again.
But, there are serious problems associated with state transportation agencies attempting to avoid study of real project impacts. According to FHWA, consultants who substantially underestimate concentrations, loads, and the impacts of highway runoff pollutants—a Type II error— can actually cause worse problems down the line, subject their client (Caltrans) to high corrective costs, and negatively affect public perceptions about the veracity of environmental information provided by transportation agencies. Discovery of large prediction errors during the planning, design, and construction phases of a highway project could increase costs beyond project budgets. Type II errors discovered while monitoring runoff from a highway once it is in operation could result in regulatory actions, ﬁnes, and costs associated with additional BMPs.
Bottom line here – Caltrans may think they are the kings of Project Delivery, but if enough people call them on their lack of study of very real substantial impacts and how this lack of study negatively impacts the environment in addition to the the daily lives of California citizens Caltrans is supposed to serve, we may be able to force this state agency to reform its practices and take responsibility not only for Project Delivery, but also for following the guidelines established by the FHWA for the protection of our Nation, our aquatic resources and the motoring public.