Environmental Damage Marbled Murrelet, photo from U.C. Berkeley

Marbled Murrelet
Richardson Grove is  federally designated Marbled Murrelet critical habitat. Cal Trans proposes to conduct a two year survey, but only after the project is completed. Post-project surveys are neither mitigation nor relevant without pre-surveys.

Old-Growth Redwood Trees
No old-growth redwood trees will be cut down, but the roots of many trees will be deeply cut. Redwoods have shallow roots, which intertwine with neighboring trees. There is no guarantee that cutting roots will not eventually kill old-growth trees.

Alternative Must Be Considered
Federal law allows the Secretary of  Transportation to approve a transportation  project involving land in a public park only if   “… there are no feasible and prudent  alternatives…” (49USC§303).

Why has CalTrans not considered the alternatives?

The Environmental Impact Report is insufficient
The California Department of Parks and Recreation, North Coast Redwoods District, has serious concerns about the project, which are expressed in their comments on the DEIR:

"After careful review, the North Coast Redwoods District has identified several inconsistencies in the DEIR and there is a general lack of data or information that is necessary for our staff to make qualified determinations as to the impact to the State Park resources and viability of the mitigation measures that are presented. There are inconsistencies between the CEQA checklist and the Environmental Consequences section of the DEIR. Several sections of the DEIR and not consistent with CEQA for which we believe additional analysis or mitigation measures need to be developed. The document also contains numerous mitigation measures that are not enforceable and are therefore not compliant with CEQA.

Because of the apparent inconsistencies, lack of clear mitigation methods and a lack of sufficient data to evaluate the proposed project, we are not able to make a determination on some critical aspects of the project's impact to the State Park. We are concerned that the document does not meet the requirement to be an enforceable environmental tool."

"...it is unclear that the proposed action will not result in significant adverse effect to trees, including old-growth redwood, and that adequate mitigation may not have been incorporated into the DEIR"

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"...the project may result in significant adverse effect to sensitive resources, including old-growth redwoods, listed species such as the marbled murrelet, and the park." State Parks, NCRD.