Continental Shelf

Richardson Grove State Park, by TheJosephBoys -- Creative Commons license: Attribution-Noncommercial-No Derivative Works 2.0 Generic

I wrote a couple of times in December about the draft environmental impact report (EIR)/environmental assessment (EA) prepared by the California Department of Transportation for the Richardson Grove improvement project. I thought I’d share the comments I sent to CalTrans.

As a reminder, the comment period has been extended by one week to end on Friday, January 30, 2009.

California Department of Transportation
1656 Union Street
Eureka, CA 95501

Attention: Deborah Harmon, Senior Environmental Planner

Object: Richardson Grove Operational Improvement Project Draft Environmental Impact Report/ Environmental Assessment

Ms. Harmon,

I have read the Richardson Grove Operational Improvement Project Draft Environmental Impact Report/ Environmental Assessment (draft EIR/EA) and I would like to offer some comments. I am an environmental engineer with over a decade of experience in conducting environmental impact assessments under the National Environmental Policy Act (NEPA), the California Environmental Quality Act (CEQA) and similar regulations, and I live in Humboldt County.

I believe that some aspects of the project have been insufficiently studied to meet the requirements of NEPA and CEQA. Aspects I am concerned with are the traffic and safety impacts, effects of decompaction and recompaction on the root mass of old-growth trees, and the range of alternatives proposed.

Traffic. Although the draft EIR/EA evaluates the existing traffic component of the environmental setting, it provides no analysis of the effects on traffic and road safety that can be expected to occur due to the increased capacity and the new presence of larger freight vehicles, the Surface Transportation Assistance Act of 1982 (STAA)-compliant trucks that are the reason for this project. The document offers no projection of the expected volume and composition of traffic, or the resulting effect on accident rates.

I note that there is mention that:

Caltrans is also considering reducing the existing posted speed limit of 40 mph through Richardson Grove to 35 mph as an independent action from the proposed operational improvement project.

However, there is no discussion of the effects on traffic and safety of the project with and without this measure.

Traffic and safety considerations are particularly important to discuss because there is a perception in the general public that the Richardson Grove Operational Improvement Project is proposed in response to safety concerns and will help improve conditions, even though the draft EIR/EA clearly states that no such improvement is expected to result. It does not say, however, whether conditions are expected to worsen.

Old-Growth Trees. Construction activities will result in excavation, decompaction, backfill, and recompaction of soils in and near the root zone of old-growth trees, particularly Coast redwoods, which is harmful to the trees. The draft EIR/EA analyses the projected effect by stating that:

Many of the large redwoods within and adjacent to the project area are likely affected by compaction resulting from the existing Route 101 roadway and park facilities (campsites, trails, roads, park structures). The proposed project is not anticipated to substantially increase the magnitude of compaction that presently exists.

However, no effort is made to support this conclusion with data. I would like to see a discussion of the results of comparable construction work conducted in old-growth areas in the past, such as the along other segments of U.S. 101, the Newton B. Drury Parkway, U.S. 199, etc. Were the old-growth redwoods unharmed by such work? If there were instances of trees being damaged, how frequent were they?

Alternatives Range. While it appears that several design options and alignments were evaluated as part of the proposed project, the draft EIR/EA provides very little information on or analysis of realistic alternatives bracketing the proposed project. I do not believe it has met the requirements of CEQA and NEPA in this regard.

I hope the final EIR/EA will be revised to provide more information on these topics; as it stands, I believe the document does not provide sufficient information to support a determination of no significant impacts, with or without mitigations.

Sincerely,

Sophie Lagacé