The City of Roseville has issued a Subsequent Draft Environmental
Impact Report (SDEIR) for the City's proposed 2020 Transportation
System Capital Improvements Program Update (CIP Update). Comments
on the City's SDEIR can be submitted to the City through March 19,
2007 and should be sent to Rob Jensen, City of Roseville Public
Works Dept., 311 Vernon Street, Roseville, CA 95678. Individuals
interested in promoting safe and efficient bicycle transportation
within the City should consider submitting comments. The following
might prove useful:

As an advocate for safe and efficient pedestrian, bicycle and motor
vehicle use of public transportation/roadway systems, I am concerned
about the disconnect between the City's current Bicycle Master Plan
(BMP) update process and the City's review of the proposed CIP
Update. I am also concerned that the City has failed to identify
the significant impacts that occur to bicycle transportation and
public safety when additional motor vehicle trips are added to
public roadways, especially when those roadways are of substandard
design and/or do not contain adequate bicycle facilities.

At the BMP update workshop hosted by the City on November 28, 2006,
there was considerable discussion regarding the bicycle community's
concerns with the removal of existing bicycle facilities as a result
of roadway "improvement" projects. At that workshop, City of
Roseville staff indicated that they agreed this was an issue that
needed to be addressed to ensure that the potential impacts on
bicycle transportation/safety were considered for any project that
could affect existing bicycle facilities.

The City's SDEIR for the CIP Update
(http://www.roseville.ca.us/civica/filebank/blobdload.asp?
BlobID=8199) identifies at Impact 4.1-8 (page 4.1-48) that CIP
roadway improvements could be inconsistent with the City's BMP. No
reference to specific BMP policies is provided and the document does
not acknowledge that the City has formally initiated a process to
update the BMP. Although Impact 4.1-8 speaks to a potential
inconsistency with the BMP, the impact (and remainder of the DSEIR)
fails to address the direct effects that would occur as a result of
the removal of bicycle facilities in association with a
roadway "improvement" project. Direct effects include reduced
bicycle use for transportation as a result of disruption of
efficient bicycle circulation, reduced bicycle safety at
intersections, and increased air pollutant emissions and traffic
congestion due to the increased number of individuals who will
choose to drive motor vehicles instead of cycling as a result of
these combined increased risk and inconvenience factors. The DSEIR
fails to identify these direct impacts of the proposed CIP Update.

The DSEIR also fails to discuss that the City has collected
statistical information during its BMP update (as presented during
the November 28, 2006 workshop) which identifies that the
predominant factors influencing individual decisions to ride or
drive are associated with interaction with motor vehicles and the
availability of safe and adequate bicycle transportation
facilities. These statistics provide substantial evidence that any
removal of existing bicycle facilities from public roadways within
the City will have a direct effect on bicycle use, public safety,
air quality, and traffic congestion.

The mitigation identified for Impact 4.8-1 merely suggests that the
City might look into acquiring right of way to enable the retention
or relocation of bicycle facilities, but does not require the City
to ensure that bicycle facilities be retained or replaced. The
DSEIR suggests that this measure would mitigate the impact on
bicycle transportation to a less than significant level, but, in
fact, there is no performance standard identified and no evidence
presented with regard to how this mitigation would serve to make the
proposed CIP Update consistent with the City's BMP. Further,
because the DSEIR fails to acknowledge the actual impacts of
removing bicycle facilities (including those discussed above) the
DSEIR also fails to identify mitigation measures that might be
available to minimize the direct impacts that would occur with
adoption of the proposed CIP Update.

The DSEIR also identifies several significant and unavoidable
impacts associated with increased motor vehicle trips on roadways
outside of the City. Many roadways in Placer County and other
adjacent jurisdictions are used by bicyclists for transportation
and/or recreation. Although impacts to motor vehicle circulation
may be adequately evaluated using level of service projections for
roadways and intersections, the same approach can not be used for
determining impacts to bicycle operation. Bicycle safety and
individual's decisions to use bicycles for transportation is
directly associated with safety and convenience. The addition of
motor vehicle trips on any roadway (especially roadways with
substandard bicycle facilities such as bike lanes/shoulders, signal
operations, etc.) compound the existing deterrents to bicycle use.

The absence of the City's acknowledgement of these significant
effects on bicycle transportation result in an inadequate assessment
of the proposed CIP Update and, more importantly, result in the
City's failure to explore true mitigation measures that may be
available to minimize the effects of transportation system
improvements and increased motor vehicle trips on the City's (and
adjacent jurisdictions') roadways. Transportation system
improvements implemented by the City should address bicycle and
pedestrian facilities and circulation with the same priority as that
given to motor vehicle circulation. As such, the City should
consider the following:

1. Modify the proposed CIP Update to include a requirement that any
and all roadway improvements shall not eliminate or otherwise
adversely affect existing bicycle facilities.

2. Modify the proposed CIP Update to require that any and all
roadway/intersection improvements on City streets which do not
currently include bicycle facilities shall install bicycle
facilities (Class II bike lanes, bicycle-activated signal detection,
etc) as part of the improvement project.

3. Recirculate the DSEIR with revisions to identify and explore
mitigation for all impacts associated with substandard bicycle
facilities and increased motor vehicle trips, and include the
following mitigation commitments:

a) The City of Roseville shall include in any and all roadway
improvement projects the retention or installation of bicycle
facilities adequate to promote safe and efficient bicycle use.

b) The City of Roseville Bicycle Transportation Planner shall review
all proposed roadway improvement projects and shall identify any
aspect of a proposed roadway improvement project that could
adversely affect bicycle transportation (including construction-
related impacts) and shall advise Public Works of these potential
effects. Modifications to the project shall be incorporated to
eliminate all such adverse effects on bicycle transportation and
bicycle facilities.

Thank you for considering these important issues.