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Friday, December 18, 2009

Redwood Saviors or Cyber Criminals? Center Supporters Update Democracy

From the Center for Biological Diversity's weekly newsletter "Endangered Earth"

5,100 of the Center for Biological Diversity's supporters love the redwoods so much they deluged the California Department of Transportation with emails complaining of the agency's plan to slice a road through the gorgeous Richardson Grove in the state's remove North Coast.

Rather than responding to the public's concern, the Department of Transportation called the State Police Cyber Crime Division to report that they were under attack by hostile forces. Apparently interacting with the public was "diverting" the agency from its real job -- chopping down forests and paving the wilderness. A crime if there ever was one.

A police investigation determined that the agency was suffering from an acute case of citizen involvement, to which there is no cure.

Learn more about Richardson Grove. Then tell CalTrans today that the public wants its redwoods standing, not paved.

Monday, November 2, 2009

Center for Biological Diversity petition to Save Richardson Grove...

Center for Biological Diversity

Stop a Highway Project Through the Ancient Redwoods

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Ask any visitor to California's North Coast who has driven the Redwood Highway north from San Francisco, and they'll be able to tell you exactly where they passed through the fabled “Redwood Curtain.” At Richardson Grove State Park, just north of the Humboldt County line, Highway 101 narrows to a two-lane road winding through a dim, lush grove of ancient redwoods. These huge trees provide crucial habitat for endangered birds like the marbled murrelet; threatened salmon and steelhead still return each year to spawn in the creeks running through the park.

This iconic gateway to the redwoods is now gravely threatened by an ill-advised and unnecessary highway project. Caltrans and the Federal Highway Administration are on the brink of approving a proposal to widen and realign the portion of Highway 101 passing through Richardson Grove. Construction of the new road would cut through the vital root systems of the ancient redwoods, threatening the integrity of the grove and further jeopardizing the imperiled species that rely on old-growth redwood forests for their survival.

The point of the project is to make it possible for larger trucks to access this portion of Highway 101. Powerful business interests itching to bring big-box stores and runaway urban development to Humboldt County desperately want those larger trucks on the highway. This just adds insult to injury: The project will not only blow an even bigger hole through Richardson Grove, but could also spur new development that will forever alter the character of the North Coast.

Behind the future Redwood Curtain, travelers might find just one more big subdivision and one more big-box strip mall.

Please take a moment to tell Caltrans and the highway administration not to approve the Richardson Grove Improvement Project. Thus far, these agencies have ignored the project's threats to endangered wildlife and ancient redwoods, failed to look at other alternatives, and downplayed the growth-inducing effects of opening Highway 101 to oversized-truck traffic. This cathedral grove is far too important to both vanishing forest species and human visitors to be sacrificed for the short-term gains of a few powerful commercial interests in Humboldt County.

Click here now to sign the petition!

Tuesday, October 20, 2009


24 October 2009 - 2:00pm

Come out to Richardson Grove on the 24th of October for a community gathering in the Redwoods.

We will focus on environmental awareness on an international level as well as on a local level. There is a current proposal to widen HWY 101 in Richardson Grove. Let's all rally together to take a stand for a safe climate future. We don't need the road to be widened so that big trucks can come through bringing more stuff. Planet Earth needs our help, love, and support!

We will also come together with our fellow Redwoods to take a photo for so that they may deliver it to the media and world leaders.

-Natalynne Delapp from EPIC will speak

-Local activist/musician Darryl Cherney will speak and play some music

Carpooling and bike riding to the event is heavily encouraged~
The owners of Organic Grace have offered their store parking lot as a carpool meeting place.
Organic Grace is located at 906 Redwood Drive in Garberville.

We also encourage folks to call into KMUD's All Sides Now (707- 923-2513 ext. 170) You can then record your message with your thoughts and let folks know about the action.

Keep checking back for updates. If you have any questions please email me at

Tuesday, September 15, 2009

Redwood Curtain Bicycle Run Oct. 2-4

Recommendations for cyclists:

-Lightweight backpacking tent(or tarps) for camping
-Backpacking stove, small cooking pot, knife, fork, spoon, (unless your food is ready to eat)
-Clothing for both rain or shine(extra socks, extra underwear, thermals, rain gear, sweater, pants, shorts, long and shortsleeve shirt, etc. Choose outer clothing that is highly visible)
-Autumn rated sleeping bag(backpacking "stuff-sack-able" type recommended)
-Waterproof "stuff-sacks" for clothing and sleeping bag(heavy mil trash bags may suffice)
-Bicycle helmet(reflective vests are recommended as well as front and rear bicycle lights)
-Panniers and/or bicycle trailer(backpacks(especially weighted) are not recommended for long-distance touring, your back will thank you:)
-Water containers(stops for water can be made along tour)
-Extra bicycle tire inner-tubes, flat patch kit, bike tool, pocket knife, cordage, lighter, duct tape, small personal first aid kit, toiletries, sunscreen, toothpaste, toothbrush, biodegradable soap, etc.
-Food for at least the first day. Daily stops for supplies can be made along the ride, keep in mind that food choices and availability will diminish during day two. Lightweight foods high in carbs and protein are recommended. Cereals, sandwiches, and trail mixes are great for those who choose not to cook. (Meal options are more diverse when carrying a stove, but weight restrictions must also be a consideration)

The biggest mistake you can make is to pack too heavy, or to be unprepared for inclement weather. Test your skills and weight restrictions by doing your own 10-20 mile trial run with your gear. Keep in mind that if you forget or need something, there will be other riders that may be able to help you out. Don't bring everything including the kitchen sink! The three day ride will have multiple opportunities to stop and pick up forgotten necessary items.

The cycling distance for the event will be around 30-40 miles per day, mileage per day decreasing as we continue south to the Redwood Curtain.

Flags, signs, etc. are encouraged. However, comfort, safety and visibility are priorities.
Keep you messages positive. Remember, this ride is to bring awareness of the threats towards our State Parks and the Redwood Curtain. This is not a "Critical Mass"(although organizers support that type of action in the right place). This is a fun tour of life behind the Redwood Curtain and to show our support for our beloved State Parks. For safety, the ride will take place off of Hwy 101 and busy streets whenever possible.

Only two things will be provided by organizers: Camping and the safest possible route to Richardson Grove. PARTICIPANTS MUST PROVIDE THEIR OWN FOOD AND GEAR.
Be financially prepared for minor setbacks such as bicycle repairs. Emergency transportation will be available for injured bicyclists only. It is the complete responsibility of the participants of how to return home if you decide to leave the bicycle group before the destination. It is also the responsibility of the participants of how to return home after the ceremony at Richardson Grove on Sunday, Oct. 4th. We recommend that you plan ahead for how you will return. You may choose to bike back, and provide your own camping. Or have someone meet you to pick you up in a vehicle with your bike and gear. Or you may continue with the organizers to San Francisco. Camping will not be provided for bicyclists on Oct. 4th or beyond.

It is a fact that the ride will continue south to the Bay area. Depending upon circumstances unforeseen, we may continue to the State Capital in Sacramento. No matter what happens, we plan to have fun and embrace this adventure as a pilgrimage to the Redwood Curtain(Richardson Grove) the Bay Area...and possibly to Sacramento.

Now, let's ride to Support Our State Parks! To Protect Richardson Grove! To Defend The Redwood Curtain! And To Save Humboldt County!

Saturday, September 12, 2009

Eureka: Even more congested...

Broadway and 5th(Eureka, Ca)

Caltrans has avoided considering the consequences of increased large truck traffic through Humboldt County, including congestion, especially in Eureka, safety, pollution, & roadway maintenance. They ignore the disadvantages to local business of facilitating large franchise retailers.

There is no cumulative impacts evaluation that consider 199/197 and 299 STAA projects, or the 16,000 daily vehicular trips associated with the Eureka marina Center. The narrowly construed purpose ignores other modes of goods movement, such as a maritime highway, thereby subsidizing large trucking concerns.

Humboldt port is ready for appropriate development, and maritime transportation is far more efficient, resistant to rising fuel costs, and amenable to non-fossil fuels, but will not be economically feasible if it has to compete with cherry-picking trucking. 4f of the Federal Code requires such consideration when manipulating roadways in public parks when federal funds are involved.

Despite the fact that Richardson Grove is federally designated murrelet habitat, and there is no data as to occupied habitat, surveys will only be conducted after the project. The murrelets are going extinct south of Richardson Grove and need recruitable habitat. There is absolutely no scientific basis justifying the cutting of old growth redwood tree roots, and no credible evidence in the AR supporting such cutting.

Ken Miller

Tuesday, September 8, 2009

The glass hidden in the grass...

“Make the lie big, make it simple, keep saying it, and eventually they will believe it”. Adolf Hitler
Photo by The Arcata Eye

The publicly funded North Coast Prosperity website claims to "represent
business owners, entrepreneurs, industry cluster leaders and the interested public". I suppose that lying and spreading misinformation is "business as usual", for those intent on turning Humboldt County into Santa Rosa.

In the NCP's piece "Richardson Grove Project Gets Shot in the Arm", the site claims that "A two-year survey by a biologist will be done to monitor marbled murrellets and document their presence." This statement is inherently deceptive. According to Caltrans, they will be conducting the two year survey AFTER the completion of the RIP
(Richardson Grove Improvement Project). Just what are they trying NOT to prove in regards to the sensitive habitat?:

"Caltrans will replace 13 trash containers in Richardson Grove State Park with corvid proof waste receptacles. This is to benefit wildlife in the vicinity. (For example: Ravens are a predator of marbled murrellets that are known to nest in giant redwoods. Ravens scavenge trash and murrellet eggs. If the trash was not available then the eliminated primary food source would theoretically eliminate the scavengers...To avoid impacts to nesting migratory birds, vegetation removal will be done between Sept. 30 and March 1."

What does Caltrans know about the endangered Marbled Murreletts in prime nesting area high in the trees of Richardson Grove(the last of such in the area) without pre-project surveys? Caltrans is admitting that Murrellets are in the grove by offering trash can mitigation and seasonal vegetation removal, but will conduct surveys after the project. This is contradictory to mitigating environmental impacts to resident endangered species.

Is Caltrans afraid of heights?

The NCP continues to claim that "With exception of the culvert excavation, the contractor will be required to use an air spade while excavating the soil within the structural root zone of redwood trees which will minimize physical injury to the tree roots." There is no minimization of physical injury to Redwood roots when excavation is the only option to realign the roadway right up to the base of these Ancient trees. Redwood root systems rely upon surface moisture. As anyone will notice the root systems on a toppled redwood tree, there are no deep roots or main "tap root". The root systems of Coast Redwoods cover the forest floor, just inches below the surface, and intertwine with each other. Excavation of any type around these Ancient Trees is similar to "girdling" a tree, and paving over them is much worse:

"While the tree roots may extend as far from the trunk as the tree is high, the only part of the root that can actually absorb water and minerals are the tiny, delicate root hairs in the last inch of each root activities can cause problems in two ways: damage to root hairs which means they can’t absorb water and minerals, and cutting off the roots air supply by paving, adding soil, or compacting soil above them. The end result is that the tree starves and the roots suffocate and die." Larry Caplan, Horticulture Educator, Purdue University

But wait! According to the NCP, a technological breakthrough in paving will help "minimize" damage to the roots from the pavement placed right on top of the Ancient tree roots:

"The new pavement will be (CTPB) “Cement Treated Permeable base to minimize the thickness of the structural section, provide greater porosity, minimize compaction of roots and minimize thermal exposure to roots from Hot Mix Asphalt paving.”"NCP Site

Lime(found in cement) is a poison, for humans, fish and especially for acid loving trees such as our Coast Redwoods. I myself have personally experienced this travesty. I recently removed an Oak Tree hanging over a customer's home that was over a century old. The customer was concerned that the Oak had succumbed to SOD(sudden oak death) and wanted the tree removed for safety and to protect the surrounding Oaks from the disease. After further research, we discovered that the tree had Lime poisoning, and the home's concrete foundation that covered less than half of the drip line of the oak tree had taken less than two decades to poison the tree to death:
"Lime is a major component of cement and as such is found in all concrete products and is also used for stabilizing earth and for some landscaping activities. Lime easily dissolves in water, just like sugar, to make the water and slurry strongly alkaline (pH 11-13), which burns and kills fish, insects and plants that come in contact with it, much the same way acid burns us." North Shore City, New Zealand Pollution Prevention Brocure

For those of you reading this that feel talking about tree roots is "for the birds", let us ponder the reasons behind the handful of local businesses that support this project. May God save them after the influx of non-local corporate Big Boxes and developers...

We live in a really special place. But what remains of our resources, our workforce, and the accomplishments made by Humboldt's entrepreneurs, local commerce, and advocates of sustainability and the environment are threatened by the greed of those who want to rip a hole in the Redwood Curtain. It is a fact that there are a few businesses who have vocalized support for the RIP. Let's look at their reasons, and debunk their claims for the necessity of the project, which are clearly based in greed:

While it can be argued that nearly every business on the North Coast is in some way affected by higher transportation costs, it is the small to mid-size manufacturers, specialty agriculture businesses and food producers that suffer most from the STAA restrictions." NCP site

You may wonder what started this whole mess. In the beginning, it was the beef industry( Humboldt Grass-Fed beef became a hot item for carnivores in and outside of Humboldt County, and the demand increased due to multiple reasons, such as fears of Mad Cow disease, the deplorable conditions of feed lots and the usage of hormones by corporate beef producers.

Now we have "
Grass-Finished" beef. This is the process of bringing grain-fed beef cows from the Central Valley and other parts of the state to Humboldt County, where the non-locally "grown" cows are given a two week vacation of Humboldt grass(not the smoking kind) and sun(or fog), before being shipped back to Stockton(or wherever) to slaughter. Since Humboldt County lacks a slaughterhouse, and that the County's bovine population numbers around 80,000 head(according to Martha Divine), the Grass Fed beef demand created the notion that the Redwood Curtain needs parting.

First off, the problem with Humboldt's trucking industry is that we are all dependent upon oil.

Richardson Grove didn't create the fuel crisis that we all suffered from during the Bush administration. And the election of President Obama won't solve the issue either, unless better fuel technologies are developed by the administration, instead of "cash for clunkers" programs that fuel American vehicle manufacturer's programs for unsustainability. An extra 5 or so linear truck trailer feet will not help much with transportation costs if diesel goes from $2.99per gallon back up to $4.20 a gallon(do the math). And the dangers from having these super-sized trucks navigating our city streets outweigh any current safety concerns for the scenic one mile stretch of the 101 through Richardson Grove. The Blue-Green Alliance has a lot of informative content regarding safety and fuel issues that debunks all of the proponents of the RIP claims for safety and efficiency. And guess what? The alliance is comprised of truckers...

Cypress Grove is a local business and a vocal supporter of the RIP. Why? Because the goat milk used for their cheese is trucked in all the way from Mexico. I suppose that there are not enough goats in the County to fill their order for their locally crafted but not so locally produced cheeses. Sun Valley Floral Farms? Not a very ethical or sustainable company to begin with. Unethical practices such as exploiting undocumented workers. Non-sustainable practices such as herbicide use. Remember, the sprays that Sun Valley utilizes drift right into an "organic" Humboldt Creamery supplier just East of Sun Valley, as the wind carries.

My hopes in sharing this information with you would not be to boycott any of the above businesses or industries, although it would be in the best interests of public health and business ethics to complain about these deplorable practices. My goal is to show you that not all businesses support the project. In fact, only a few are vocal in supporting a project that will in fact create an atmosphere of unhealthy competition with Big Boxes. A project that is supported by big development, purveyors of sub-urban sprawl.

The timing of this project goes in hand with the County's General plan, where the direction of Humboldt's development and land use policies will be decided for the next few decades. Out of area interests cannot wait to get their hands on Humboldt County's resources, which includes you, reader. The promise of minimum wage jobs is the promise of slavery. Big business policy is to make a profit, regardless of who is affected by their greed. To hire entire labor forces as part-time, to avoid paying benefits such as medical insurance and vacation. Take note that Eurekans stopped Wal-Mart from entering it's city limits. For a damn good reason. Let's keep Humboldt County local.
Save Richardson Grove. Save Humboldt County!

"There are men who have special interests in your career. They want to help you to grow. And then, siphon all your dough, why don't you find out for yourself. Then you will see the glass, hidden in the grass." Steven Patrick Morrisey

Sunday, August 23, 2009

"Four lanes from SF all the way to Oregon"

"Caltrans Project Engineer Eric Lund (center) was the guest speaker at last week’s meeting of the Garberville Rotary Club. Lund spoke about the Richardson Grove road widening project. He told the club that in the past, there was a vision that Highway 101 would eventually become four lanes from San Francisco all the way to Oregon. However in 2000, it became apparent that a bypass around (or the alternative of a tunnel below) Richardson Grove was not feasible. He also said a common misconception about the project is that the road will be straightened. In reality, the road will be “curvier” but wider. The project will minimize damage to trees and root systems in the surrounding ground by using “hand methods” instead of heavy equipment. Shown here with Lund are Caltrans Design Engineer Eric Shada (right) and Rotary club president Peter Connolly." Redwood Times
If Caltrans is concerned about the fragile and ancient ecosystems contained within Richardson Grove, why are they proceeding without wildlife surveys?
Do WE want "Four lanes from San Francisco all the way to Oregon", even outside of Richardson Grove, along "Scenic" Highway 101?
What is the grand vision of Caltrans for us here on the North pave paradise?

The 101 is a path through Nature's splendors, not a thoroughfare...

Please sign the below petition and help save Richardson Grove...

Wednesday, July 29, 2009

FHWA Administrator Reviews Highway Trust Fund With State Officials

WASHINGTON – Federal Highway Administrator Victor Mendez told state highway officials today what to expect if the highway trust fund falls short in the coming weeks during a "no surprises" discussion.

"Unless we shore up the trust fund, we will have no other choice than to pay the states less frequently for road and bridge repairs," Mendez said in a conference call with lead officials from 38 states and the District of Columbia. Mendez added that payments, currently made on a daily basis, could be made weekly or twice a month, depending upon the availability of funds.

The highway trust fund, which provides states about $40 billion each year for roads, bridges, and other infrastructure projects administered by the states, often fluctuates and is expected to drop by the end of August. A shortfall would not shut down the Federal-Aid Highway Program, nor would it prevent states from using federal dollars for highway projects. However, it would affect how quickly FHWA reimburses states.

Department of Transportation officials continue to work closely with Congress to prevent disruptions in payments to the states.

Monday, July 27, 2009

Reassessing the Richardson Grove Highway Project: A Consideration of the Consequences and Alternatives



The current broad public discussion concerning the Richardson Grove Highway Project (RGOPP) provides an unprecedented opportunity for North Coast communities to seek federal funding for the development of alternative transportation modalities, powered by non-fossil fuels, to meet the economic and ecological needs of our community. Short-sea shipping, for example, could serve coastal communities and help develop our Port in an appropriate way. Our academic, technical, labor, non-profit, business and government resources could collaborate on alternative initiatives that would avoid the need for disturbing Richardson Grove, a project that relies on anachronistic transport modalities and will foster uncontrollable and unwanted development.

Humboldt County will suffer significant adverse impacts if the Richardson Grove road project is approved. The project is too big, too consequential, and too transformative to be pushed through by CalTrans and the County Economic Development Department without the fully informed consent of the citizenry.

We believe that this project’s impacts on traffic through the county, its likely economic downsides, its risks to old growth redwood habitat, and its preclusion of better alternatives are matters of grave public concern that are trivialized by supporters of the RGOPP.

The Richardson Grove Project is linked to two other STAA truck access bottlenecks, one over Highway 299 at Buckhorn Summit, and the other along Highways 199/197 in Del Norte County along the Middle Fork Smith River. STAA truck traffic will then facilitate interstate and interregional commerce, as well as the unexamined potential for sprawl development along these routes as large franchise operations benefit from the efficient delivery systems. The risk to local businesses remains unevaluated but is clearly significant. Richardson Grove is critical Marbled Murrelet habitat, yet population demographics are unknown, and Caltrans proposes to survey for the endangered seabird only after the project. Analogously, the consequences of redwood root compaction and other disturbances related to the Project on the vitality of 28-30 ancient redwood trees are unknown.

Caltrans has narrowly construed the purpose of the Project to allow STAA access through the Grove, rather than to facilitate the movement of goods into and out of the County. Consequently, no feasible, reasonable alternatives are, or can be, considered.

However, approval of the project is not inevitable.

Rest of Article

Sunday, July 12, 2009

Blue Green Alliance Leads Array of Labor, Environmental Organizations in Opposition to Bigger Trucks

Labor Unions, National Environmental Groups Endorse McGovern, Lautenberg Bills

WASHINGTON, D.C. (June 19, 2009) The Blue Green Alliance, along with an array of labor unions and environmental organizations, said today that they oppose allowing heavier and longer trucks, including huge triple-trailer trucks, on the nation's highways. The coalition said they will work to pass a bill that would extend the "freeze" on truck size and weight to the entire National Highway System (NHS).

Joining the Blue Green Alliance in opposition to bigger trucks and in support of the Safe Highways and Infrastructure Preservation Act (H.R. 1618, S. 779) are the Sierra Club, International Brotherhood of Teamsters, Natural Resources Defense Council, Laborers' International Union of North America, Environment America, Communications Workers of America and the Service Employees International Union.

"The facts are clear: heavier trucks would be dirtier and would unnecessarily contribute to air pollution and global warming," said David Foster, Executive Director of the Blue Green Alliance. "The Safe Highways and Infrastructure Preservation Act will help prevent truck weights and lengths from increasing while taking action to improve the environment and make America more energy secure."

These national labor and environmental organizations are working to debunk the arguments of major corporate interests claiming bigger trucks would mean fewer trucks on the road and reduced fuel use. The Teamsters and the Sierra Club said bigger trucks will mean greater challenges for truck drivers and motorists, more fuel squandered and more pollution and global warming emissions.

Today, laws limiting triple trailers and other so-called "longer combination vehicles" apply only to the 46,000 mile Interstate Highway system. The Safe Highways and Infrastructure Preservation Act would apply this standard to the full 160,000 mile NHS, which would save millions of gallons of fuel and billions of taxpayer dollars because limiting truck weight would reduce wear and tear on infrastructure, mainly bridges.

In addition to wrecking roads and bridges, allowing heavier and longer trucks would mean more fuel consumption and a move away from energy efficiency at a time when reducing fuel use and global warming emissions is a national imperative.

"We need to make transportation choices that cut back on fuel waste and reduce emissions, or we will all pay a steep price," said Carl Pope, Executive Director of the Sierra Club. "Bigger trucks would mean more fuel wasted and more global warming emissions at a time when all Americans are realizing we need to go in the exact opposite direction. "

"This is about highway safety and protecting our environment," said James P. Hoffa, General President of the International Brotherhood of Teamsters. "Teamsters are the safest drivers on the road and know the risks of bigger trucks. Heavier or longer trucks are harder to handle, putting lives at risk, damaging the highway infrastructure and consuming more fuel."

Read the letter signed by labor and environmental groups supporting SHIPA or visit

The Blue Green Alliance is a national partnership of labor unions and environmental organizations dedicated to expanding the number and quality of jobs in the green economy. Launched in 2006, the Blue Green Alliance now unites more than six million people in pursuit of good jobs, a clean environment and a green economy.

Groups organize against bigger trucks

By Jill Dunn, July 6, 2009

An alliance of labor and environmental groups is campaigning for a bill that would freeze truck size and weight on the National Highway System.

The Blue Green Alliance is comprised of the Sierra Club, Teamsters union, Natural Resources Defense Council, Laborers’ International Union of North America, Environment America, Communications Workers of America and the Service Employees International Union.

They support the Safe Highways and Infrastructure Preservation Act, or H.R. 1618 and S. 779. The House bill was referred to committee March 20 and has 91 co-sponsors and the Senate bill was referred to committee April 1 and has 3 co-sponsors.

The alliance and the Owner-Operator Independent Drivers Association support the current limit of 80,000 pounds and 53-foot limits for tractor-trailer rigs on interstate highways of the National Highway System.

The NHS covers about 160,000 miles of highway, while interstates represent 44,000 miles.

The American Trucking Associations, the National Private Truck Council and some shipping organizations favor expanding these limits. They support the Safe and Efficient Transportation Act of 2009, or H.R. 1799, which was referred to committee March 30 and has 26 co-sponsors.

That legislation would allow trucks a maximum gross weight of 97,000 pounds, provided the vehicle has at least six axles, including a tridem axle group with a weight limit of 51,000 pounds. Axle weight increases of up to 2,000 pounds would be authorized at the state's option.

The Truck Safety Coalition also formed to battle against relaxing current limits. That coalition is comprised of Citizens for Reliable and Safe Highways and Parents Against Tired Truckers.

More information on the alliance is available at

Sunday, May 24, 2009

Who supports this project anyways?

The only "people" who are promoting this project is big development.

The Times-Standard printed SIX letters supporting the project, opposed to the massive public outcry of opinion denouncing the project in both the Times-Standard and North coast Journal.

Let's look at the special interests attached to the small enclave of project supporters. Then maybe we can evaluate whether their interests in the project are to help the community...or exploit it.

-J. Warren Hockaday-
-Eureka Chamber of Commerce Executive Director
-Member, Timber Heritage Association
-J. Warren on our port-"Eureka Chamber of Commerce Executive Director J. Warren Hockaday endorsed Option B, citing a predicted "dramatic increase in Pacific Rim Trade" that "other ports can't take due to air quality issues."(Mr. Hackaday would prefer to spoil OUR air)

-Ray Flynn-
-Former Humboldt County Assessor(Hmmmm...)
-Chairman of the Buckeye Conservancy influencing 300,000 acres of forests and ranchland in the county.(The "conservancy" is actually a band of foresters and ranchers dedicated to streamlining timber harvest permits and challenge regulatory restrictions in order to make it easier for landowners to clearcut paradise).
-Ray flynn on Prop. 13-"Though personal income was rising almost as fast as property values, that was little consolation to retired people, or people otherwise on a limited income. Ray Flynn, Humboldt County's assessor at the time, says that though the boom in Humboldt County wasn't as dramatic as it was in the state's urban areas, he witnessed its effect."I had a lot of people sitting across from me crying their eyes out," Flynn says. "They said, "You're forcing me out of my home.'"(Thanks a lot, Ray)

-Mark Loughmiller-
-Executive Director Arcata Recycling Center(Ok...but...)
-Official Arcata "Hippiecrit"
-Mark Loughmiller on population growth-"Loughmiller added, however, that a curbside program can be effective if it collects enough tonnage, since commercial haulers can increase recyclable pick up without a corresponding cost hike. "We need a bigger population base, so perhaps we can look at the possibility of combining Arcata, Eureka and McKinleyville. It's all about volume - if you don't have it, it won't work.""(For Mark, it's all about volume...not community)

-Kit Mann-
-Vice President Kokatat(Korpatat)
-Kit Mann on unions and federal employer regulations- "Invoking the "C" word - "corporation," that is - Kit Mann, vice president and production manager of Kokotat, noted that it is necessary for a business to be profitable to be good, in the basic sense of covering insurance, worker's compensation, benefits and so on. He said, "I have a very deep and abiding commitment to my employees," but argued that the intervention of a third party - whether the government, a union or shareholders - interrupts the relationship between a corporation and its employees."(It's a very deep and abusive relationship when employees are buggered by Kit)
-Kit Mann on Kokatat-"Most people there don't stick it out. Kit Mann, the vice-president of Kokatat, says they hire new people all the time. That's partly because those jobs have high turnover because they are difficult and monotonous."It takes a certain type of person to do that every day," Mann says. "I have a lot of respect for [the workers]. I couldn't do what they do.""(But you can exploit [the workers] just like a big box or corporate chain, right Kit? Where is your conscience?)

-Charles Fiedler-
-CalTrans District 1 Director
-State employee caught with hand in Headwaters Fund cookie jar. (Is this a conflict of interests? A State employee dipping into local funds to promote an unpopular project that would benefit Caltrans district 1 employees? Enough said...)

-Bryan Plumley-
-President of the Arcata Downtown Business Association($)
-Arcata Economic Development Corp. Loan Committee($$)
-Arcata's Economic Development Committee($$$)
-Financial advisor for Edward Jones' Arcata office($$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$)
-Former Third District Supervisor Candidate(Nice try Brian)
-Former President Arcata Mainstreet Board of directors(See ya!)
Brian Plumley on development-"Economic development is a key to a lot of other problems," he said. "With success in that area, a community is able to deal with poverty, housing shortages and drug abuse."(You have it backwards, Brian. Overdevelopment IS the source of a lot of problems, such as poverty, housing shortages and drugs. Get your facts straight)

In summation:
-Project supporters were paid for their endorsements.
-ALL of the above project supporters have financial interests in the mass development of Humboldt County.
-Project supporters clearly have little or no regard for air quality, environmental regulations, retirees and low income residents, workers rights and union organizations, smartgrowth advocacy, and overall community cohesion. This may appear to be a generalization, but after analyzing the facts, it is more than apparent that the handful of paid project supporters have interests opposed to a sustainable and community based lifestyle for Humboldt County residents.

In short, they want to profit from the collapse of the Humboldt Nation.

This is a call for action, as Paul Revere rode to warn the rebel colonialists that the British were invading. "The corporations are coming...the corporations are coming! One if by land(101), two if by sea(Bay), and three if by air(Arcata airport)."

There is a single light in the churchtower. Now is the time for action! Let's kick those greencoat$ out of Humboldt!

Saturday, May 23, 2009

Richardson Grove: A look at the bigger picture

The impact of widening Richardson Grove will affect both the “left” and the “right,” this is not limited to an environmental or political issue. This is a social and economic issue that will adversely affect everyone, unless you are the developer, builder or landowner.

Richardson Grove is not the only front in this battle for our way of life. The gateways to exploiting our paradise have been opened throughout Humboldt's history, such as with the timber, gold, whaling, and ganja booms. These booms all had their windfalls for the few, steady and honest work for the many, and of course their various detriments to the land, and native populations. These booms also bring more people. Then the retraction, or “bust” as resources plummet, demand dwindles and profiteers jump ship (sayonara Charlie Hurwitz).

The commercial boom is not quite different, except for the fact that the future of small business owners will be bleak. Whether the plan is to create a bigger harbor, reinstate the rail system, build a larger airport, free up timber lands for tract homes or as in this case ... widen the highway thoroughfare to the nearest major city (San Francisco) and seaport (Oakland); the overall plan is for a few to profit from the hard work of the many. The bigger picture is the plan to develop Humboldt.

The shock wave from small business collapse will be felt by all native (or current) Humboldt residents. As corporate chains and “big boxes” create vacant storefronts, wages will begin to fall. Profits will leave Humboldt County (remember the corruption of PL after the Maxxam takeover?), and homes will become vacant. Meth and gangs will become rampant. Opportunities for entrepreneurial pursuits will cease to exist in a corporatised wasteland of McDonald's, Home Depots, and cookie cutter tract homes and mini-malls.

I lived through this type of change myself. In fact, by the time my hometown was overrun by mass commercialism, I was old enough to move out. I've worked so many different jobs, sometimes as much as two full-time jobs while sleeping in my car between them. Jobs were easy to get because no one wanted them, like graveyard shifts at Taco Bell or a security guard at the apartment complex. All to pay for a place that was beyond my means, impress a girl that was beyond my means, and live up to mass media's imposed living standards, which were beyond my means.

My point is not to scare you with fear tactics. I am simply sharing my experience of my hometown community that became a zombified version of some Orweilian nightmare. The world won't end for Humboldtians if the project goes through. Some trees that have been around for thousands of years will probably die eventually from root disturbances, but at least that Caltrans worker will have a meager paycheck and a slim retirement plan for their 80 or so years on the planet. Some people will definitely benefit. But most of us will see Humboldt permanently distorted, and you can't go back once this occurs. There are some people in our community that welcome this, but they do not have the foresight or experience of Southern Californication.

Is it more than widening the highway through virgin redwood stands? It should be for all of Humboldt's labor force that has had its shares of ups and downs. There's always that “greeter” position for minimum wage at Wal-Mart, a company that leaves Medi-Cal and food stamp information in their break rooms.

Jeff Musgrave lives in Arcata.

Sunday, May 10, 2009

The Hole in the Headwaters Fund...To Make a Hole in Richardson Grove

After the sale of Headwaters Preserve by Maxxam operated Pacific Lumber to the State of California, $22 million dollars was allocated to Humboldt County to offset economic loss of the timberlands to the local economy.

$12 million came from the State earmarked for "Economic Assistance".

The $10 million that came from the feds was deemed "Direct Payment" to Humboldt County.

However, the citizens of Humboldt County had been bamboozled . The fund that was intended to improve "economic prosperity and quality of life for all Humboldt County residents" was pirated by a County bureaucracy elected for the special interests of developers. While displaced workers
were forced to work minimum wage jobs, timber community infrastructures collapsed(such as Rio Dell's wastewater cease and desist), and vacant homes turned into meth houses; the fund was squandered during a recession for grants and loans for promoting the corporatisation of Humboldt County.

Aside from using the fund to promote and study "Super Sizing" the Bay and Airport Terminal, county officials misappropriated these funds to serve the interests of Big Box development and to rip Humboldt County wide open for commercialization. "Among those(interests) were the Caltrans project to widen U.S. Highway 101 through Richardson Grove".

Even the local media was influenced with the public fund. "My Word" editorials submitted to the Times-Standard were discovered to have been funded by the Headwaters Fund by Dr. Ken Miller(Thank you Dr. Ken!):

A recent Quarterly Report to the Headwaters Grant Fund reveals money was approved to pay for assistance in “submission of approximately six ‘My Word’ editorials in support of the Richardson Grove Project.” Coincidentally (or not) The T-S archives show in fact six “My Words” supporting the widening through the ancient redwood grove.

Submissions came from:
J Warren Hockaday Ray Flynn Mark Loughmiller Kitt Mann Charles Fiedler Bryan Plumley

The campaign is a line item in their 2/25/09 Grant update report on their accomplishments to date:
“Hired a PR Contractor to manage the EIR summarization, a letter-writing campaign, media outreach, business and public outreach.”


“Assisted in submission of approximately six “My Word” editorials in support of RG Project, written by business owners affected by the restrictions.”

We taxpayers who funded the Headwaters Fund, and constitute “the public,” should have been told that a media campaign, including letters to the editor and six “My Word” OpEd’s, was being funded by public funds.

Essentially, The Headwaters Fund was a "gift" from the State to Humboldt County(at the time, predominantly timber industry workers)from economic impact of Headwaters Deal, with the intentions of "Economically Assisting" the timber community while providing a "Direct Payment" to the county to offset infrastructure loss. But the sale of PL's timberlands to the State came at a cost to everyone, from the tireless efforts from environmentalists, the loss of livelihood for timber workers, and the State taxes paid for the land acquisition by everyone.

In effect, the fund was a "Stimulus Package" for the people of Humboldt, not for the development interests of big business or big development(Does this treacherous tale sound familiar, as with the bank bail-outs?). How did they get their hands on our money, anyway? Who let the fox into the chicken coop?

Don't be a chicken. Say No to the Corporatisation of Humboldt!

Save Richardson Grove. Save Humboldt County!

Thursday, April 30, 2009

We must all protect the Redwood Curtain from the Imperial Cruisers

I had to post this one as a Star Wars fan :)

Editor’s Note: This letter is addressed to the editor of the North Coast Journal and was submitted to the Redwood Times for publication as well.

In Star Wars, Chapter IV, R2-D2 and C3PO are spiraling down in the escape pod and you can’t see Leia’s crippled ship, only the distant triangle of the Imperial Cruiser that holds it in its bay. Then everyone chuckles when C3PO comments, “The damage doesn’t look as bad from out here.” Since so many people have written to the NCJ explaining the obvious to Hank Sims et al, concerning the Richardson’s Grove realignment, that is not the purpose of this letter. Obviously you have the same perspective concerning it that C3PO had of Leia’s ship and you discount it.
The bottom line is that the project is expensive, unnecessary and more than just “slightly” damaging to the grove. It’s only one mile of highway where big trucks will lose little time by slowing down and driving safely. Besides, there are better alternatives. The damage that will ensue looks slight only to you town dandies way up in the north county. So, what is your vested interest in this project going through, and why are you, the pot, calling the kettle “ham-headed?” Somehow you’ve even managed to make your cartoonist turn his perspective around to a far less accurate one than he had in the previous issue. Our stand in Southern Humboldt is not a “knee-jerk reaction.” From down here the serious damage this will bring home for us is obvious.
My question is, why are you promoting this travesty and discounting the damage? Can you answer that question in your paper, rather than just rhetorically pointing at someone else that was paid off? That’s what this letter is about. Like many other readers down here I’d just like a straight answer to that. No games down here in So Hum, just honest perspectives and concern for our environment.

Saxon Roe

Tuesday, April 14, 2009

"The Town Dandy" eats "Humboldt Pie"...

Proponents of the Cal-Trans project to widen Highway 101 through Richardson Grove State Park in Humboldt County, California have another fire to extinguish. One that may as well “burn-out” of control.

After Richardson Grove supporters were likened to MAXXAM’s failed recall effort by Hank Sims(The Town Dandy), commander and editor of the once community minded North Coast Journal; Hank has apparently but unapologetically changed his tone about the corrupted special interest enclave receiving Headwaters funding to promote the largely contested project.

Included in Hank’s vicious attack was The Northcoast Environmental Center(NEC), a long-term non-profit information center devoted to providing education to the public regarding industry’s role in the destruction of our planet Earth. The NEC was apparently attacked by Mr. Sims due to the center’s providing of a donation drop for the Friends of Richardson Grove, those who are opposing the destructive and unwarranted Cal-Trans project to widen Highway 101 through the State Park.

One of the ironies of the attack was the fact that the role of the NEC was crucial in stopping the accelerated destruction from MAXXAM’s plundering of Pacific Lumber. Pacific Lumber became the main focus of action in the fight to save the redwoods in a two decade+ long resistance to corporate greed and from which Earth First!, Judy Bari, Darryl Cherney, Julie Butterfly Hill and other pioneers of enviro/eco-action were conceived.

Richardson Grove State Park is considered by many as "The Gateway to the Redwoods", an archway of amazingly tall Virgin Old Growth Stands which tower above Highway 101 as you enter Humboldt County Redwoods State Park. Despite the fact that William Richardson(25th governor of California) vetoed every state park funding bill during his reign(simliar to our current governor's slash and burn fiscal tactics), the park stands to this day. The park includes the ninth largest Coastal Redwood(sequoia sempervirens), camping and fishing along the Eel River, and is the closest State Park containing Old Growth Redwoods north of San Francisco. This Cal-Trans project is only one of many ecologically sensitive projects promoted by our current "greenwashed" governor.

The controversy regarding the project began after Cal-trans submitted a controversial project to allow longer trucks into and out of Humboldt County through Richardson Grove. The issues include the fact that the project will disturb the roots of these ancient trees resulting in the probable demise of millennial redwoods, absolute and unavoidable disturbances to endangered species such as the Marbled Murrelet(brachyramphus marmoratus) and the Northern Spotted Owl(Strix occidentalis), along with the root of the issue…the gutting of Humboldt County by big business.

The bottleneck at Richardson Grove has helped prevent the commercial corporate takeover of small businesses throughout Humboldt County by limiting the length of trucks entering the grove. This is where the special interest portion of the Cal-Trans project enters into the tale. Discovered by concerned local residents Dr. Ken Miller and David Spreen, apparently over $25,000 of public grant money was spent by the Community Development Services department to sway public opinion regarding the controversial project by using print and online media. Tactics as sinister as paying citizens to submit editorials supporting the project to the local Times-Standard paper were even utilized, along with the publicly financed North Coast Prosperity website. But why and by whom?

The funding to promote the unnecessary project came from The Headwaters Fund, a triumph for environmentalists in the battle for the Redwoods against MAXXAM. The Headwaters Fund was a twelve million dollar public fund crafted after the sale of The Headwaters Forest by Pacific Lumber to the State of California. The fund was developed by the State to offset losses to timber industry jobs and the local economy after the Headwaters sale, which also included stricter environmental controls on timber practices. Imagine how those who participated in the Headwaters Campaign feel after hearing that the fund they helped fight to create was being used to destroy the Richardson Grove Redwoods, and Humboldt County!

Essentially, the fund was to be used to promote education for timber workers(never happened), local business development(low wage jobs for ex-timber employees), and rebuild and maintain community infrastructure(City of Rio Del on cease and desist for storm water pollution into Eel River). Despite the fact that small amounts of the fund have been used in the form of loans for existing and startup businesses, the bulk of what the fund has supported has been redevelopment and to fund and promote special interest projects, such as the expansion of Arcata airport and highway projects, such as this one.

Considering the fact that Cal-Trans filed an incomplete and ineffectual environmental impact report(EIR) intended to address concerns about the impacts to Richardson Grove and concerned resident species; the massive community outcry against the necessity of the project; impacts to local business from out of area corporations offering lower wages and product standards; increased traffic and pollution along Highway 101 including amplified congestion and air pollution issues in Eureka; and now…the corruption attached to the misuse of Headwaters Funding to promote an unpopular state project aimed at bringing in Wal-Mart and Home Depot trucks coinciding the corporatization of our small town county that is big on local sustainability and fair trade.

I cannot see this project going through, and if it does, we will put a stop to it through non-violent resistance.

Whew…That was lot to say! Like a big piece of blackberry pie.

In fact, I think it’s a big piece of “Humboldt pie“… just for you , Hank Sims!

Monday, March 2, 2009

Conflict of interests...

This one is sick...

From the Sub-Standard 02/25/09:

"The public criticism of the Headwaters Fund's five-year report took nearly as long as the report to the Board of Supervisors Tuesday.

Patrick Cleary, chairman of the Headwaters Fund board, presented the report covering the fund's work between 2003 and 2008.

Originally, the fund started at a shade more than $18 million, Cleary said. Now it totals almost $21 million. During the past five years, the fund has distributed $1.6 million in grants, $951,000 in community investment grants and $2.5 million in community investment loans.
One of the main focuses in the past half-decade has been on infrastructure -- amounting to $5 million although the local needs are much more.

”We've had to pick and choose our spots,” Cleary said.

Among those were the Caltrans project to widen U.S. Highway 101 through Richardson Grove; Horizon's addition of a flight to Los Angeles; providing upfront money to bring Delta Airlines service to the North Coast; and leveraging funds to acquire an $8.5 million Federal Aviation Administration grant and funding a study on the Humboldt Bay Harbor Recreation and Conservation District's Redwood Dock."

One more major reason why this project must be stopped...The fund should be used for the Trees, not against them!

Wednesday, February 11, 2009

My public comment for Caltrans...

Dear Ms. Harmon,

I am deeply concerned about the proposed project for Richardson Grove. After reading the EIR for the said project, it is more than apparent that the project has had little or no consideration in regards to the detrimental impact to the park, species of concern, and millennial Old Growth Redwoods.

It is a fact that only three percent remains of our original forests. Since there is such a miniscule amount of original growth remaining, it is necessary to protect our inheritance. The Richardson Grove project puts our arboreal inheritance in jeopardy, a grove that is owned by the people of the State of California, the same people that pay your salary.

It is evident that the EIR fails to address a mitigated impact to the grove. For example, the EIR states:

"The noise of construction is not expected to exceed ambient traffic noise (Appendix E). Noisy equipment will include jack hammering, concrete sawing, and concrete grinding as well as the back-up warning signal on heavy equipment."

This statement is difficult to comprehend, for obvious reasons. Jack hammering is a foreign noise event to the Grove, as opposed to ambient traffic noise. Ambient by your own definition infers to typical day to day highway and park background noise, and activities such as jack hammering are foreign activities to Richardson Grove. Normal traffic noise is typical for the Grove, as a human based activity that has taken wildlife decades to grow accustom to in the area. Therefore, construction activities cannot be compared to the ambient sounds of route 101, as it exists currently.

Furthermore, Appendix E in the EIR states that a heavy truck or motorcycle(the loudest ambient noise makers according to the DIR) creates a 81-84 decibel noise level. Yet, In the same appendix, the EIR states that activities such as Jack hammering(89dba), concrete sawing(90dba), various 5HP equipment(85dba), and pneumatic tools(85dba) exceed the highest ambient noise level of traffic. How can these construction activities not exceed ambient traffic noise, when the EIR states that the activities will?

The EIR continues to literally debunk itself by stating:

"To minimize traffic delays during peak travel hours there may be some night work as well as day work. For night work, lighting will be directed downward toward the work area to avoid disturbance to foraging northern spotted owls."

Foraging Owls(no matter the type), depend heavily upon small ground creatures for food, typically rodents. Owls hunt by swooping onto these rodents from a perch. Owls are primarily nocturnal, and their night hunting activities WILL be disrupted by construction disturbances to their prey, especially by "night work". How will "directing the light downward" mitigate this issue, as they depend upon nocturnal foraging of small animals that will be forced to evacuate during construction? What difference does it make where the focus of these imposing lights is directed?

The EIR further baffles me by hypocritically stating:

"To avoid impacting nesting migratory birds, any tree and shrub removal will also take place outside of the bird breeding season. The bird breeding season is March 1 to September 1."
"The noise and activity disturbance generated by the construction of this project will not substantially exceed the existing disturbance levels. However, the temporary noise, night work, and activity associated with project construction, is likely to disturb murrelets that are nesting in the area."
"4.1. Construction Noise
The noise of construction is not expected to substantially exceed ambient traffic noise (traffic background noise; Appendix E). Noisy equipment will include jack hammers, concrete saws, and concrete grinders as well as the back-up warning signal on heavy equipment. Because the project area already experiences high noise level from vehicular traffic. The additional noise of construction noise will have no impact on breeding birds in the project area."

I am well aware of the nesting season forestry guidelines for the Marbled Murrelet, one of many endangered species present in Richardson Grove. In fact, the Marbled Murrelet's presence on local timberlands prohibits most major road construction and timber extraction activities during said nesting season. Yet the Richardson Grove project proposes high decibel noise disturbances from equipment such as excavators, jackhammers, concrete saws, augers, ground compactors, and other various noise making equipment during nesting season. The noise from this equipment, as stated above in paragraph five and six, creates foreign and threatening sounds to creatures nesting in the grove, and cannot be compared to "ambient" traffic noise. Moreover, the EIR states that temporary noise, night work, and activity is likely to disturb nesting Murrelets. Yet, somehow the additional construction noise will not impact breeding birds in the project area. Which one of these conflicting statements is factual?

Here is one of my favorite statements, completely based out of reality:

"4.2. Construction Activity
Richardson Grove State Park has year-round campgrounds and foot trails, and is subject to a high level of vehicle and pedestrian traffic. The construction work for this project will not substantially increase activity in the park. Therefore, there will be no effect to special status species due to increased human activity levels."

From what I understand, Richardson Grove is a State Park and is protected year round from harmful activities by all visitors, including loud noise and music. Increased human activities during the summer are typical ambient sounds made by annual increases of visitor traffic(see paragraphs five and six). However, construction sounds WILL effect special status species due to the fact that these sounds are foreign(as opposed to normal ambient sound levels) and threatening towards nesting species. This justification for increased human activity levels is ridiculous, and I find it hard to believe that anyone could interpret construction sounds as being comparable to the ambient sounds from a normal or even increased flow of visitor traffic.

At least we can all agree on this statement:

"4.4. Root Impacts to Large Redwoods
This work will involve the structural root zones of approximately 25 large redwood trees ranging in diameter from 3 feet to 15 feet DBH as listed below....Additional paving and the placement of shoulder backing could cause soil compaction and disturbance within the structural root zones of large redwoods. Studies have shown that compaction of the soils within the root zone can have an adverse effect on these trees (Arnold 1975). Adverse effects to large trees may be a significant impact to this unique natural community."

In order to protect the remaining three percent of original growth, valiant measures of non-violent civil disobedience have taken place here in Humboldt County over the past decades. In the EIR, it is stated that no large trees will be cut. However, it is important to understand the long-term effects of disturbing this sacred place, a place that is often referred to as the gateway to the Giant Redwoods. Therefore, any threatening action taken against the Richardson Old Growth, including root disturbances that would likely lead to any Old Growth Redwood(s) demise, will be taken very seriously by local and experienced Forest Defenders. If the Richardson project is given a green light under the current project plans, it is my opinion that a massive community based resistance will rise up to protect Richardson Grove. I do not believe that the State is prepared to handle this situation, both legally and financially. Moreover, I don't feel the State can afford such unneeded and unnecessary projects during the current fiscal crisis regarding the State's budget.

Chapter Five in the EIR is apparently supposed to address concerns regarding negative effects and impacts to Richardson Grove. Yet I cannot find any type of mitigation or minimalization in regards to the project's effects on Old Growth root systems except this vague and non-descript statement:

"5.6. Additional Measures
Due to the uniqueness of this natural community, measures will be taken to avoid and minimize impacts. Daily work windows will be observed. Disturbed areas will be replanted. To mitigate for potential structural root zone impacts to large redwoods and potential impacts to elements of marbled murrelet Critical Habitat Caltrans will implement out-of-kind mitigation. In coordination with California Department of Parks and Recreation, Caltrans will replace the 13 existing trash containers near parking, picnic and camping areas in Richardson Grove State Park with corvid proof waste receptacles to enhance habitat for nesting migratory birds in Richardson Grove."

In summary, I would have to infer that this project is beyond unnecessary, inherently destructive, and poorly planned. The "out-of-mind" mitigation for issues such as noise pollution imposed on endangered nesting species(trash can lids?), root structure disturbances(trash can lids??), and construction zone impacts(more trash can lids???) can only describe where this project is headed, approved or not.

Into the trashcan...

For the trees,

Jeff Muskrat

Thursday, February 5, 2009

Public Comment Period for Richardson Grove Extended

From Times-Substandard 02/05/09

"Caltrans officials announced Wednesday that the comment period for the Richardson Grove Improvement Project draft environmental document has been extended to March 12."

I bet that Scott Greacen really put a fire under Kim's rear. So what are you waiting for? Tell Cal-trans to leave Richardson alone!

Kim Floyd (Project Manager)
P.O. Box 3700
Eureka 95502

And while you are at it, tell Assembly Member Karen Bass , Governor Arnold Schwarzenegger (if you live in California) , Senator Barbara Boxer (if you live in California) , Senator Darrell Steinberg , and Senator Dianne Feinstein (if you live in California) to uphold state and federal environmental reviews.

Wednesday, February 4, 2009

The Out-of-Mind Mitigation for Richardson Grove

Thank Goddess for organizations like EPIC...and thank you, Scott!

Richardson grove Operational Improvement Project
Draft Environmental Impact Report/Environmental Assessment and Programmatic Section 4 (f) Evaluation

Dear Ms. Harmon:

This letter is submitted on behalf of the Environmental Protection Information Center (EPIC), the North Coast Environmental Center (NEC), Friends of the Eel River (FOER) and Californians for Alternatives to Toxics (CATs). EPIC is a Humboldt County based non-profit organization that actively works to protect and restore forests, watersheds, coastal estuaries, and native species in northwest California. EPIC was established in 1977 by local residents in Humboldt County. EPIC works to ensure that state and federal agencies follow their mandate to uphold environmental laws and protect endangered species. Many of EPIC's members use the Eel River for boating, fishing, bird watching and general recreation, as well as for aesthetic enjoyment. Particularly, members of EPIC visit and use Richardson Grove State Park, and rely upon its beauty and natural resources for personal and professional enhancement. Members of EPIC have an interest in knowing that California remains alive with wildlife and natural wonders, still beautiful and available to enjoy and utilize when they choose. NEC is also a Humboldt County based non-profit organization, whose mission is to promote understanding of the relations between people and the biosphere and to conserve, protect and celebrate terrestrial, aquatic and marine ecosystems of northern California and southern Oregon. Since its establishment in 1971, NEC has worked to conserve the area's biological assets and to stimulate public awareness in securing the future of these natural treasures, which are vital to sustaining physically, economically, and culturally healthy communities. FOER is also a non-profit conservation organization based on the North Coast, whose primary mission is to restore the Eel River and all her tributaries to a natural state of abundance, wild and free. CATs is a public interest, membership non-profit organization whose mission is to give the general public, particularly residents of northern California, control over toxic chemicals in their environment. This mission arises from a broader underlying concern for our membership in relation to their dependence on the environment for their sustained health, education, cultural activities and livelihood.

EPIC, NEC, FOER and CATs (hereinafter EPIC) oppose this project as presented. Fundamentally, the DEIR/EA fails to adequately justify the need for the project, describe the project, and assess the project's significant environmental effects. On these grounds alone, the DEIR must be supplemented and recirculated. In addition, inadequate public notice requires that the DEIR be recirculated, per the requirements of the California Environmental Quality Act (CEQA) and its supporting regulations. As well, the DEIR fails to adequately analyze and disclose the potentially significant impacts of the proposed action sufficiently to support a finding of no significant impact (FONSI) under the National Environmental Policy Act (NEPA). Thus, an Environmental Impact Statement (EIS) must be prepared, and adequate public participation solicited and obtained, before any ground-disturbing activities can be undertaken pursuant to the proposed action. The DEIR/EA suggests by its flaws a project that has been rushed to completion before thorough consideration of the potential impacts and implications of the proposed action, and a predetermined action that is being justified using carefully selected data and analyses that minimize those potentially significant impacts. Such analysis fails to meet the letter or the purpose of either CEQA or NEPA.

Inadequate Notice Requires Recirculation of the DEIR

We have checked the CEQAnet website repeatedly during the week of January 26, 2009, and there is no record of CalTrans having submitted the Richardson Grove DEIR to the State Clearinghouse. Such submittal is required by law. It is our understanding, as of the date of these comments, that Caltrans submitted the DEIR for Richardson Grove to the State Clearinghouse on January 27, 2009; and that the document apparently won't be posted until February 5. We have been informed that the State Clearinghouse number is 2009012070. A search of the CEQAnet data baseon the morning of January 30, 2009, does not include any documents for that number. Because Caltrans has failed to follow mandatory public review requirements, by not posting the DEIR with the State Clearinghouse, EPIC and the public have been denied our right of full review. EPIC reserves the right to supplement these comments during the required review period, which properly commences when Caltrans complies with the requirement to post the DEIR with the State Clearinghouse.

Inadequate Project Description

The DEIR advises that the purpose of the roadway realignment is to accommodate STAA truck travel, to remove restriction of STAA vehicles and improve safety and operation of Highway 101 and goods movement. Assuming that the current roadway does not accommodate STAA trucks, the DEIR lacks a description of what engineering changes and criteria are necessary to accommodate STAA trucks. The project description includes a statement that the roadway is to be realigned so that two STAA trucks passing in the opposite direction can be accommodated. But no standards are outlined to justify the realignment. It appears that Caltrans expects everyone to just assume that the realignment as proposed on the designs accommodates STAA truck travel as intended, without providing the public with the engineering specifications necessary for that truck travel. How wide must a road be for two STAA trucks at any given point? What must be the minimum curve distance or alignment? Because the DEIR does not provide the roadway standards necessary for a STAA truck, it is impossible to evaluate whether the proposed realignment is adequate, necessary, the best alternative, or the most environmentally sound alternative. The DEIR lacks the very information necessary to evaluate what standards govern a realignment, and proceeds on the undemonstrated premise that such a realignment is in fact necessary. The DEIR declares that the current roadway geometrics do not meet current design standards for design speed, curve radii, shoulder width, superelevation rates, stopping sight and corner sight distances, distance to a fixed object, steepness of side slopes, and alignment consistency. (DEIR at p. 41.) However, the DEIR does not advise as to what are those current design standards, and how the proposed project will meet those standards. In the absence of this information, it is really impossible to evaluate the validity of the proposed project as the appropriate alternative, even if one were to concede that the project is necessary. The lack of this information also makes it impossible to evaluate the validity of the impact analysis, particularly on the natural resources to be affected. Nor do the Layout Maps in Appendix L provide this information. All they do is layout the proposed design, without any indication as to whether the design satisfies standards necessary to accommodate STAA trucks as desired. Moreover, the layout maps have no engineering stamp on them, and bear a disclaimer that the State of California shall not be responsible for their accuracy or completeness. EPIC questions the validity of the project description as well because it is not at all clear that the roadway needs to change to accommodate STAA trucks. An STAA truck is defined as any tractor-semitrailer combination or set of doubles with length configuration such that the truck may legally operate only on National Network Highways, Terminal Access Highways, or signed accesses to service. According to Caltrans Truck Route Classifications,1 the STAA Network is the National Network (NN), Terminal Access (TA) and Service Access routes together make up the STAA Network. These are the routes that allow STAA trucks. According to this same document, Terminal Access (TA) routes are portions of State routes or local roads that can accommodate STAA trucks. The Caltrans map for Truck Networks on California State Highways District 1 show Highway 101 to be a Terminal Access (STAA) route. A TA sign is posted on Highway 101 north, at the junction of Highway 1 and 101 at Leggett. Thus it appears from Caltrans own statements and signage that the portion of road for which this project is contemplated already is currently designated for STAA trucks. The necessity of the project is also in question because there appears to be little recognition of the need for this project by the California Transportation Commission or even Caltrans. EPIC reviewed the Caltrans website to locate listing of the proposed project. Certain documents are keenly relevant to statewide transportation planning, particularly in terms of identifying what is priority and necessary for California transportation. EPIC found a dearth of reference for this project. The December 29, 2006 Corridor Management Plan for Route 101: Golden Gate-Oregon Border (Corridor Management Plan) references only a feasibility study for STAA access to Humboldt County, but does not list the project as necessary.2 A Corridor Management Plan is a document that identifies the recommended system management strategies for a given State Highway System facility based on comprehensive performance and assessment and evaluation.3 This document notes that Route 101 is designated as a High Emphasis Focus Route in the State Interregional Transportation Strategic Plan (ITSP).4 The Richardson Grove project area is not identified as a segment which does not meet current Route Concept.5 The project is also not listed in the 2006 State Transportation Improvement Program (STIP) Projects.6 From this, once can ascertain that as of the end of 2006, the State did not recognize this project as necessary. The project is not listed in the 2008 State Transportation Improvement Program. The project is included in an updated Long Lead list from August 27, 2008, which identifies the Richardson Grove project to realign the highway. A Long Lead list identifies projects for which development work has begun but is not currently programmed. The project is not listed in the 2008 Interegional Transportation Improvement System. This is the listing that provides funding for projects to improve movement of people and goods to and through urbanized areas. The project is not included in the 2008 State Highway Operation and Protection Program (SHOPP) approved on March 13, 2008. However, the project is not included in the most recent January 2009 SHOPP list. The only listing for the area near Richardson Grove indicates, at line 18, an entry for area between MP 0.2 and 126.00 on Highway 101 to reconstruct guard railing. Given the apparent contradictions between the prioritization assigned this project in relevant planning documents and the priority claimed in the DEIR, EPIC questions the validity of the claimed necessity and urgency of the proposed project, and wishes to underscore the rapidity with which this project has proceeded under Caltrans direction. Have all internal steps and Caltrans process requirements been followed as this project has moved toward to this point? EPIC is quite concerned that Caltrans may have ignored some of its own internal procedures in order to fast-track this project and its environmental analysis. Please document that all relevant procedures have been followed, or provide appropriate discussion clarifying what normally relevant procedures may not have been followed, why such decisions were taken, and what the possible implications may be of such short cuts around CalTrans normal procedures for a project of this type, magnitude, and potentially significant impact on the environment. In its search to understand why and how this project has progressed to this point, EPIC also consulted the CEQAnet database, posted by the State Clearinghouse of the Office of Planning and Research.7 When a state agency acts as a lead agency for a project, it must submit the draft EIR to the State Clearinghouse, even when it has independently provided notice of the DEIR to other agencies. (Guidelines 15205.) The State Clearinghouse, in turn, posts notice of that document on the CEQAnet database. EPIC searched the CEQAnet database for all Caltrans planning projects and all projects in Dsitrict 1, for all environmental documents and within a time frame from January 1 2008 to the present. EPIC did not find the Richardson Grove DEIR listed anywhere on the CEQAnet database. The DEIR itself provides no evidence that it was submitted to the State Clearinghouse. This appears to be a clear violation of state law. The DEIR has not been properly circulated for public review. This seems to suggest yet again that this project has been fast-tracked without compliance with proper procedure. The project also appears to be a done deal, a predetermined decision taken in advance of the analysis reflected in the DEIR. In additional to the strong circumstantial evidence that this is the case, the DEIR itself declares that [a]fter the public circulation period, all comments will be considered, and the Department will confirm the proposed build alternative and make the final determination of the project's effect on the environment . . the Department will certify that the project complies with CEQA, prepare findings for any significant impacts identified, prepare a Statement of Overriding Considerations for impacts that will not be mitigated below a level of significance, and certify that the findings and Statement of Overriding Considerations have been considered prior to project approval.8 Such pre-determination nullifies the public's right of review, and prejudices CalTrans against any concerns and evidence which would urge a different outcome. It also makes a mockery of the CEQA review process, making the DEIR illegitimate. The DEIR does not provide a discussion of overriding considerations. In fact, it claims there will be no unavoidable significant effects. EPIC questions how it is that a project that has yet to even be identified by any of the major state transportation planning and funding mechanisms can be predetermined with issuance of only a DEIR. We believe this to be illegal.

The DEIR Does Not Establish That This Project is Necessary for Safety

The DEIR tries to support the need for the project on the basis of safety. On February 15, 2008, pursuant to a Public Records Act request, EPIC received from Caltrans the CHP information on traffic accidents in the Richardson Grove stretch of Highway 101. But the studies it refers to do not show what the DEIR states.9 The report date is February 13, 2008. What the tables reveal is that for the stretch of Highway 101 from mile post 0.920 to 2.120 which is the scope of the project, for a period of 5 years, there were only 6 accidents involving trucks, two of which occurred within one minute of each other on August 16, 2004 at 11:10 and 11:11 p.m, and only one of the five involved two trucks going in opposite directions. Notably, there have been no truck accidents since June 21, 2005. The CHP Report to the Legislature from August 2005, which evaluated the effect of Vehicle Code 35401.710 advised that there were no collisions, citations, verbal warnings, complaints, or highway incidents involved licensed carriers of livestock vehicles on the identified portions of Highway 101.11 Thus, the evidence does not support a claim that this project is necessary to allow more room for trucks because trucks are involved in or cause accidents.

The DEIR Fails to Establish That The Project Is Necessary for Goods Movement and the Economy

As noted in Mr. David Spreen's comment letter of January 23, 2009, the DEIR's economic analysis and rationale for the proposed project largely hinges on a suggestive but indeterminate economic survey (the Gallo report) and inappropriate use of the IMPLAN economic analysis tool. Having heard from many other local business owners, including small business and people involved in transportation, EPIC believes that the proposed project will benefit some local business while injuring others. While such actions may be valid public actions if properly analyzed and disclosed, a state agency may not legally proceed on the basis of one-sided analysis that minimizes or fails even to present the negative economic impacts of the proposed action.

The Project Fails to Provide for Nonmotorized Access, as Required by CalTrans Policy and the California Highway code

Contrary to its own policy, and California highway code, and despite the fact that its project will lead to more big trucks travelling at higher speeds through the narrow grove, Caltrans has failed to provide for improved bicycle or pedestrian access as part of this project. Highway 101 is designated part of the Pacific Coast Bike Route. Note that CalTrans own guide to this section of the Pacific Coast Bike Route shows typical bicycle tourists travelling along the narrow roadway through Richardson Grove. There are no bike lanes along this stretch of Highway 101; indeed, there is in many areas no shoulder at all beyond the paved area of the road. Thus, bicyclists and pedestrians must either walk through the state park (where bicyclists may not ride, on or off the provided paths, which do not run the length of the park) or risk life and limb by attempting to share the road with motorized vehicles. CalTrans Deputy Directive Accomodating Non-Motorized Travel, dated 3-26-01, states that the Department fully considers the needs of non-motorized travelers (including pedestrians, bicyclists, and persons with disabilities) in all programming, planning, maintenance, construction, operations, and project development activities and products. Similarly, California highway code (887.8. (b)) requires the agency to provide funding for bike access provisions as part of a project (w)here the traffic safety or capacity of the highway would be increased. Caltrans has refused to do so here, suggesting instead that State Parks may build a bike path at some point in the future. EPIC believes that the proposed action is likely to increase risks to bicyclists in particular, by leading to increased traffic, from larger trucks, and inevitalby travelling at higher speeds due to the larger roadway. The DEIR fails entirely to analyze or discuss such impacts. Though the project clearly affects traffic safety and highway capacity, the project fails to provide any provision for bicyclists or pedestrians. Instead, it suggests that State Parks is considering the issue and may at some indeterminate point in the future construct an adequate bike and pedestrian path to channel non-motorized traffic off the stretch of Highway 101 under consideration in this project. EPIC takes the position that CalTrans may not properly displace its responsibilities regarding non-motorized transportation to State Parks, nor may CalTrans defer provision of non-motorized access to some intederminate later date. It is in fact because such displaced and deferred responsibilities are routinely ignored that we have policies and laws requiring CalTrans to deal with such issues as part of a given project. In addition to this substantive point, CalTrans failure to adequately disclose and analyze the relevant facts around these issues renders the DEIR/EA inadequate under CEQA and NEPA. The agency's failure to articulate a reasoned rationale for its departure from its stated policy, or any rationale whatsoever for its failure to provide adequate non-motorized access, suggests arbitrary and capricious agency action. Finally, we note that because a bike route through Richardson Grove State Park will necessarily risk potentially significant impacts on important cultural and environmental resources, an EIR/EIS is required to properly analyze and document such a project. Because we believe that such non-motorized access must be provided as part of the present proposed action, it is our position that an EIS is required for this project.

Impacts to Ancient Redwood Trees and Groves.

The DEIR takes the remarkable position that the construction and cutting of the structural root systems of numerous ancient redwood trees will not cause harm to those trees, or the ecology which supports them and is provided by them. Richardson Grove has existed for centuries. As William Cullen Bryant is quoted in the brochure for Richardson Grove State Park, The groves were God's first temples. It is here where you first encounter significant old-growth redwood forests when driving north. The DEIR notes that the roadway was initially created in 1915, nearly a century ago. During this time, the grove remains intact, healthy, habitat for rare species, and a wonder for all to behold and experience. Richardson Grove is the threshold to the redwood region, and offers any traveler the cathedral experience as s/he drives through. It is an unparalleled experience along Highway 101 as one drives south from the congestion of the Bay Area and its North Bay region. There is a balance here that is finely tuned over time, and should not be undone. It particularly should not, and under CEQA may not legally, be undone on the basis of hasty and inadequate analysis of potential impacts. This project will dramatically alter that balance, because of its impact on the many ancient trees which now shelter the road at its edge. Redwood science is clear that redwood root systems are shallow, lateral roots, which graft to other redwood roots to develop an interconnected root system for several trees. It is common knowledge that redwood trees have a shallow and interconnected root system, and impacts to one tree's root system can mean the demise of several related trees in a grove. The interconnected root systems create a below ground network of trees.12[W]hen marked radioactive water was injected into a tree in a study grove near Arcata, California, its trace was located in a tree 500 feet away.13 In general, soil compaction of a tree's root system will disrupt respiration processes which power every function of the tree.14 Redwoods are particularly prone to adverse impacts from soil compaction due to their shallow root systems. Redwood trees have a tap root, but it is their shallow roots, stretching wide and interweaving with those of neighboring trees, that give them a firm base . . . The roots are sensitive, however, to compaction of the soil and may be suffocated by gravel and logging debris that does not allow soil aeration.15 An undisturbed layer of thick, damp mulch on the forest floor is essential to the health of these trees.16 The proposed realignment will harm that root system, by cutting and compacting structural root systems. This will occur through construction. It will occur from compacting the roots, as well as the road development with its associated creosote and tar elements. The project has the strong likelihood of smothering roots. This project has the potential for very negative effects on very old trees. The DEIR admits that roadbed material will be placed within the structural root zone of these ancient trees. Yet, there is no correlation between the location of large trees and the cut and fill activities. The Layout Maps do not provide this, nor does the Visual Impact discussion in Appendix K or the discussion in the Natural Environment Study in Appendix I. While it identifies an additional 0.14 acre of roadbed material it does not specify how much fill will occur on what trees. And because the Layout Maps are so difficult to read, particularly as to cut and fill, the DEIR does not provide adequate information to evaluate the full adverse effect which will likely occur. Moreover, in the long term the trees will suffer from increased root compaction and more intense vehicle impacts as a consequence of the road widening and realignment. The DEIR concedes that several of these ancient trees will be affected by construction activities, and in some cases the realignment will move the roadbed even closer to the trees. The list of trees to be affected is staggering: 40 trees, with nearly half of those over 6 feet in diameter and several in the range of 10-15 feet in diameter. The DEIR plainly acknowledges that adverse effects to large trees may be a significant impact to this unique natural community. It proposes mitigation, which simply is not adequate. To quote the Natural Environment Study, [t]o mitigate for potential structural root zone impacts to large redwoods and potential impacts to elements of marbled murrelet Critical Habitat Caltrans will implement out-of-kind mitigation. In coordination with California Department of Parks and Recreation, Caltrans will replace the 13 existing trash containers near parking, picnic and camping areas in Richardson Grove State Park with corvid proof waste receptacles to enhance habitat for nesting migratory birds in Richardson Grove . . . Before activities associated with vegetation removal and road construction (including culvert installation and wall construction) begin, a qualified biologist approved by USFWS will conduct a training session for all personnel. The mitigation is focused on an effort to protect against harm to the marbled murrelet and the northern spotted owl, two protected bird species which depend upon the old growth habitat afforded by these ancient redwoods. It does not speak at all to the potential to kill these trees by cutting their root systems. Nor does it address the other environmental and cultural ramifications of such serious harm to these trees. This is a potentially significant environmental impact, which is neither adequately analyzed nor disclosed. Such outcome-oriented The DEIR opines that the magnitude of compaction on these ancient trees will not substantially increase from what presently exists. What this glib conclusion ignores is that however remarkable it may be, the current relationship of road to ancient tree groves is in balance the trees are healthy and not dying as a consequence of road adjacency. The DEIR does not analyze how the effect of cutting roots, and placing spoils and fill on root systems, and bringing the road closer to some trees will alter that balance. It does not bother to deal with this fundamental issue. The other proposed mitigation amounts directly related to the structural root zone impacts to this: excavating by hand, but with the caveat that mechanized equipment may be used with permission, use of an air spade while doing excavation, cutting roots less than 2 inches with a sharp instrument, new pavement will be Cement Treated Permeable Base to provide greater porosity and minimize compaction, use of a brow log for ares where fill will be placed next to trunks of redwoods which are greater than three feet in diameter. None of these deal directly with the imperative to not cut roots, and to not compact the root systems. These are all measures which are not documented as capable of ensuring the long term safety of these trees.

Lack of consideration of viable alternatives.

The DEIR considers only the project and the no action alternative. By refusing to consider other, potentially lower-impact means to its chosen end, CalTrans has essentially predetermined the result of its CEQA and NEPA analysis. The consideration of alternatives is the heart of modern environmental analysis, and is necessary in order to insure that the agency has taken the required hard look at its proposed action and potential impacts.

Cumulative Impacts

The DEIR fails to mention the proposed Marina Center development within the City of Eureka, currently under review through circulation of its DEIR. It is relevant because that project states that it is being designed to accommodate STAA trucks. Is that project or its applicant driving this project, or had any influence on the manner in which this project is being forced? We believe the projects are related and Caltrans must evaluate the effects of increased STAA road traffic to accommodate the big box stores contemplated by the Marina Center development. The DEIR also fails to discuss the Humboldt Bay Harbor District plans to increase container shipping in the port, which will depend upon increased truck traffic down highway 101.

Significant Impacts and Analysis

The DEIR fails to mention the Richardson Grove State Park General Development Plan in its discussion of consistency with planning documents. All California State Parks must have general plans before permanent facilities can be provided, and once adopted, the plan is direct long-term management of the Park. The Richardson Grove General Development Plan was adopted in October 1956, according to the State Parks website, which provides a copy of the two-page plan. That plan shows a "proposed highway 101" as a bypass around the Park. While EPIC takes no position on such an alternative in the context of the proposed project, the Caltrans proposal is not consistent with the Park's management plan. The DEIR fails to address this issue EPIC found thee Layout Maps difficult to read, and incomplete. The legend on the first map does not include all the features that are inserted on maps which follow, such as on 7, 14-17, 19 and 20 have some orange features that are not defined. The legend refers to "existing hydraulics". Hydraulics is the study of water, yet it appears what is being referenced is pipes. The"proposed edge of pavement" light blue line is practically invisible on most of the pages, which further prevents the reader from understanding what is being proposed and based on what criteria. On sheet 13, it is unclear precisely where the modification of berm will occur - as the map does not precisely pinpoint the modification as is shown on other maps using arrows. There are yellow lines on some of the pages, such as on 14-16, yet the legend does not indicate what those represent. The proposed retaining wall does not appear to be depicted on the sheets for the area where it is proposed. And the reader should not have to see how contours are labeled to determine cut and fill. The designs should show the limit of cut slope and the limit of fill slope. The contours on the maps are not well labeled. Nor do the maps show any proposed transfer of easements from State Parks to Caltrans. This is part of the proposed project and it is not disclosed for review. And there is no analysis of what effects the transfer of easements and/or right-of-way to Caltrans will have on the Richardson Grove State Park. By failing to provide this data and analysis, Caltrans is segmenting the analysis of this project, which is not permissible under CEQA and NEPA. The DEIR states that [f]loristic surveys were conducted in April and July 2007 (Appendix G). (DEIR at p. 95.)Appendix G simply provides a list of trees, shrubs, ferns and relatives, grasses and relatives, and herbs. There is no documentation of how this survey was conducted, who conducted it, and under what authority. Did State Parks participate in this survey, or authorize it? In order for the survey to be credible, it had to follow proper protocol. In the absence of any information as to how it was conducted, it is impossible to assess its validity. Moreover, since the area of the survey is on State Park land, at a minimum State Parks should have been involved, either by allowing the survey to occur, guiding it to ensure no harm to special species, and/or contributing to it given its particular and specialized knowledge and experience with the ecology and environment. The mitigation ratio for disturbing habitat is not adequate. A significantly greater amount of habitat is being disturbed and impacted than is being replaced or mitigated. Replacing mature trees, no matter their size, with seedlings, does not provide a 1 to 1 ratio of mitigation, because there will be a 5 to 20 year temporal separation from the time of the impact to the time of actual mitigation. This is not accounted for, nor is this impact adequately evaluated. It appears that CalTrans intends to excavate soils that contains hazardous lead, and keep, reuse it or dispose of it onsite, so as to avoid compliance with hazardous waste laws. This will also impact the overall redwood ecology and its health, yet the DEIR fails to even acknowledge the potential for heavier soils smothering tree systems. The Biological Assessment notes the potential for impact to marbled murrelets and northern spotted owl. It does not adequately consider the best available scientific information for both species, which would indicate that both species are in serious decline, and that the key federal frameworks for the species conservation and recovery, having been seriously damaged by the George W. Bush administration, may no longer provide an adequate set of measures preventing continuing jeopardy to both species.

The DEIR/EA Does Not Adequately Support a Finding of No Significant Impact; an EIS is required.

Given the potentially significant impacts noted above, and in the comment letters submitted by the Intertribal Sinkyone Wilderness Council, Bruce Campbell, and others, the DEIR/EA fails to provide a level of analysis and disclosure necessary to support a finding of no significant impact. Therefore, an EIS is required. Similarly, because potentially significant impacts go unaddressed in the document, adequate mitigations may not be prescribed.


As noted, the DEIR fails to make the case that the proposed project is necessary; both the document and external indicia indicate that the project has been brought forward in the CalTrans process much more rapidly than would normally be the case. The fact that the DEIR does not discuss or provide a reasoned argument for this acceleration, nor discuss the potential consequences of this acceleration, is an additional reason that the document must be rewritten and recirculated. The existing balance within Richardson Grove is fundamental to maintaining one of the most extraordinary places, not only within California, but on Earth. CalTrans must undertake any modification to this balance with the utmost caution. This DEIR appears instead to offer a hastily assembled series of justifications for a decision already made. Such a process makes a mockery of the commitments that the people of California made in CEQA, and the people of the United States in NEPA, to ensuring that public agencies take a hard look at decisions with potentially significant environmental impacts.


Scott Greacen
Executive Director

List of enclosures for Richardson Grove Draft EIR
�CalTrans Deputy Directive �Accomodating Non-Motorized Travel� 3-26-01CalTrans Truck Route ClassificationsCalTrans Truck Networks for California State Highways District 1Corridor Management Plan for Route 101, 12/29/06�California Department of Transportation OTM22131 Table B Accident Reports.� California Highway Patrol, United States Highway 101 Over-Length Vehicle Study Report to Legislature, August 2005, excerpts.Richardson Grove State Park Brochure. Coast Redwood:� A Natural and Cultural History, Ed. by John Evarts and Marjorie Popper, Cachuma Press 2001, p. *, excerpts.Eifert, Larry, The Distinctive Qualities of Redwoods, Humboldt Redwoods Interpretive Association 1998, p. 18, excerpts.Coder, Dr. Kim D., Soil Compaction Impacts on Tree Roots, University of Georgia 2000.Johnston, Verna R., California Forests and Woodlands, A Natural History University� of California Press 1994, p. 16, excerpts.Hewes, Jeremy Joan, Redwoods, The World�s Largest Trees, Gallery Books 1984, p. 12, excerpts.Richardson Grove State Park, General Development Plan, October 1956.� ��