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Why do EIRs include Discredited Alternatives

Updated: Apr 5, 2023

Alternative Scenarios in EIRs

Many folks have been wondering why there is still discussion of the ‘interim trail’ in the Draft Environmental Impact Report (DEIR) for Rail Trail Segments 8 and 9, despite the track-removal idea being defeated in the June 2022 election by a landslide. This alternative has been repeatedly found inferior, and has also been publicly rejected by the electorate. So why is it still being studied?


Environmental Impact Reports (EIRs) are created to learn the most environmentally friendly way to complete a project. At the heart of this process, planners typically study at least 3 different scenarios:

  • the Proposed Project Scenario

  • one or more Alternative-Build scenarios (in this case, the 'interim trail' alternative)

  • a No-Build scenario

If the EIR doesn't contain both a No-Build scenario and an Alternative-Build scenario it is vulnerable to legal challenge. In the EIR study, each scenario is scored in all of the different environmental impact categories. Then the planners add up the final scores to get the overall environmental-impact rankings for each scenario.


The final Environmental Impact Report is extensive and measures impacts on nature, such as trees and native-animal habitat and impacts on people, such as aesthetics and air quality. It also contains the recommendations for how to mitigate the impacts. To mitigate an impact means to compensate for it by either reducing the damage directly or doing something beneficial to balance the scales. For example, on the construction site the crews will put straw bollards across drainage to filter and clean construction runoff water. If the plan calls for removing trees, mitigation typically includes planting many more trees than were removed. Mitigation may also include other environmental projects like habitat restoration elsewhere in the county.

For Rail Trail segments 8 and 9, the Ultimate Trail option with the trail built next to the tracks is the official Proposed Project. Before the election, an ‘Interim Trail’ option was added to the EIR as one of the Alternative study scenarios to be scored against this Proposed Project.



DEIR Study Results are In

The Draft EIR for Segments 8 and 9 has been released, and the study has confirmed that the Proposed Project (the Ultimate Trail Configuration) is superior to all other build scenarios. Here is an excerpt from the Draft EIR summary, where you can see the final scores. The acronyms in the table go from least impact to greatest impact. NI = No Impact, LTS = Less than Significant without Mitigation, LTSM = Less than Significant with Mitigation, and SU = Significant & Unavoidable impact.



We can see from the completed DEIR that the proposed project ‘Ultimate Trail’ option has lesser environmental impacts than the other build options. Compared to the Interim Trail option, the Proposed Project requires fewer trees to be cut, has less disruption to habitat, and has fewer overall environmental impacts. This is unsurprising since the ‘Interim Trail’ option would require first track demolition and trail construction, followed ultimately by trail demolition and track and trail re-construction. ​


Segments 8 and 9 Trail Project Moving Forward

Because the completed DEIR shows that the Ultimate Trail option is best for the environment among the build options, the planners can continue moving forward with the project. All of this is great news for construction starting on time. Current estimates put construction starting sometime next year in 2023 or early in 2024, pending a grant from the California Transportation Commission (CTC). We expect to hear about final grant awards in early December from the CTC.


You can read the whole DEIR here, it’s interesting to look at one of the steps that we take in California to protect the environment. ​

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