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