Continental Shelf

As I mentioned recently, the draft environmental impact report (EIR)/environmental assessment (EA) for the Richardson Grove improvement project is available for review on the California Department of Transportation’s Website.

The Times-Standard had two articles this week on the matter: Sunday, an overview of the project, and Tuesday, a more detailed description of local businesses’ arguments for and against the project.

Trees

My first look at the EIR/EA leaves me with a favourable impression of the level of effort put into the design of the road realignment. Although up to 87 trees would have to be removed, including 29 in the State Park proper, most are smaller trees. Some 65 out of 87 trees to be removed measure less than 12 inches in diameter at breast height (diameter of the tree trunk 4.5 feet above ground, or DBH); 15 are in the 12- to 18-in. DBH category; and 7 range from 18- to 24-in. DBH (3 Douglas firs, 3 tan oaks, and one big leaf maple).

Nevertheless, 7 coast redwoods ranging from 6- to 16-in. DBH, as well as 27 Douglas fir trees ranging from 4- to 22-in. DBH, are proposed for removal. Moreover, 30 redwoods ranging from 18- to 182-in. DBH would be affected by “root impacts”, meaning changes in soil compaction in the root zone, which can cause erosion, reduce absorption of nutrients, affect seed germination, etc. The EIR/EA concludes that the affected trees, being located along US 101, are already affected and “[t]he proposed project is not anticipated to substantially increase the magnitude of compaction that presently exists.”

Safety

One of the important reasons often cited in the need for the project is road safety. The EIR shows accident statistics for the last five years, comparing this stretch of road to the state average for similar road segments. The total accident rate is about twice the state average (33, corresponding to 3.47 collisions per million vehicle miles, vs. 1.73 statewide); interestingly, however, there were no fatalities, compared to a rate of 0.036 collisions involving fatalities per million vehicle miles, statewide.

The collisions were split about half-and-half between northbound and southbound, and also about half-and-half between daytime and night. One third hit a tree, another third hit another vehicle; 20% were rear-ended. The EIR describes the listed causes:

The primary collision factors for these collisions were listed as “improper turn” (14) and “speeding” (9). Other factors listed included “fell asleep” and “influence of alcohol.” The road surface was listed as “dry” for over two-thirds of the 33 collisions.

Truck traffic made up 14-17% of the total traffic during the survey period, and trucks were involved in 26 of the 164 collisions (16%), so trucks were apparently not involved in an unusually high or low proportion compared to their traffic volume.

The EIR admits that “[t]he project would not appreciably improve the existing conditions for bicyclists and pedestrians, neither would it decrease the conditions that currently exist.”

So how would the new alignment affect the safety conditions? On the one hand, there is little to do to prevent bad driver behaviour or habits; road improvements can incite drivers to even more risky behaviour. On the other hand, every second of reaction time added, every extra foot, is an increased chance to avoid a collision. But then, the road would also open to heavier truck traffic…

Business

The EIR/EA identifies the prime reason for the project as the need to allow larger trucks (65-foot trailers instead of the current 53-foot allowed maximum length) to use this stretch and reach behind the Redwood Curtain to service the North Coast. Not only would this allow goods deliveries that are difficult or impossible along the current road, but it would also allow certain businesses to realize economies of scale or to decrease their transloading costs.

As pointed out in the Times-Standard articles lined above, not all business owners are happy with the idea, particularly the ones along the affected road segment whose businesses would be directly impacted during and after the construction.

Moreover, I find this to be an interesting situation in terms of environmental review. The National Environmental Protection Act (NEPA), which is triggered by the Federal Highway Administration (FHWA) funding, does take socio-economic impacts into account; however, the project was only the object of an Environmental Assessment (EA), the lower level of review under NEPA; and NEPA only requires evaluation of impacts, not mitigation. (The EIR also serves as the EA.)

The California Environmental Quality Act (CEQA), for which the EIR was prepared, demands that the environmental impacts of any state project be evaluated and mitigated as far as reasonably feasible. But it does not take economic effects into account, except as causes of environmental impacts. That makes the analysis of the project an interesting exercise in trade-offs.

Getting back to the road safety issue, I’m not convinced that opening this road (and other tricky segments of US 101 north of it) to more truck traffic would result in improved safety. I am annoyed that I can find no projection in the EIR of traffic increases after the project implementation; nor are resulting traffic conditions considered as a potential impact.

But another economic factor that may trump this is the possibility, raised in Tuesday’s T-S article, that the shorter trucks that are currently allowed on 101:

“will be completely eliminated as trucking companies make moves to meet emission standards pursuant to Assembly Bill 32.”

The EIR also notes that:

“the fleet of non-STAA [shorter] vehicles is aging. According to this same study by Cambridge Systematics, Inc., “Transportation for Economic Development”, truck manufacturers are no longer making non-STAA trailers.”

Commenting

The public comment period is open until January 23, 2009 (the Times-Standard says Jan. 30, and the comment period may have been extended, but the EIR says Jan. 23; better safe than sorry.) Comments can be submitted to Deborah Harmon, Senior Environmental Planner, California Department of Transportation, 1656 Union Street, Eureka, CA 95501; or submit comments via email to deborah_harmon@dot.ca.gov.

Remember that although the agencies have to respond to all written comments, the response will merely be “Comment noted” if the comment is not substantive. For example, a comment to the effect that you don’t like an aspect of the project, or that you don’t trust a proponent’s intention, is not substantive; it’s an opinion. A substantive comment is one that points out a failing in the document to meet the CEQA or NEPA requirements. For example, pointing to an impact that is subject to review under one or both of the regulations, and which is not sufficiently studied in the document (and providing evidence that this is true) would constitute a substantive comment.