According to Caltrans, “The purpose of the proposed project is to adjust the roadway alignment so that two Surface Transportation Assistance Act (STAA) trucks passing in opposite directions could be accommodated.” This defined purpose is so narrowly cast that is limits the resulting alternatives and analysis.
“While this may seem like a mere issue of semantics, the consequences are actually profound and cannot be overstated. For example, given the background and setting described and documents referenced by Caltrans, the underlying purpose and need described is not to accommodate STAA trucks on this particular section of this particular highway, but rather to improve the movements of goods in and out of the North Coast. Improving the movements of goods could be accomplished through other means than the proposed action, but because Caltrans has crafted such a restrictive purpose and need, they have incorrectly identified the preferred alternative as the only viable solution. In other words, viable alternatives to improve the movement of goods into and out of Humboldt County exist, and these could very well cause less environmental impacts, and could avoid impacts to Richardson Grove State Park altogether. However, Caltrans never considers such alternatives of gives them a “hard look”–as is required by law, and deserves.”–Cynthia Elkins March 11, 2009 comments on DEIR.
Caltrans’ Final Environmental Impact Report for the Richardson Grove Highway Improvement Project can be read here.