CA Department of Transportation
12/15/08
RE:
Richardson Grove Operational
Improvement
Project
DISTRICT 1 – HUM – 101, PM 1.1/2.2
464800
Draft
Environmental Impact Report/ Environmental Assessment
and Programmatic Section 4 (f)
Evaluation
Ms
Harmon:
1.
Why is the RG project not being considered as part of the larger
project, which is to make all of District 1 compatible with STAA trucks? Please
refer to the following article: “The report details how various industries are
affected by the lack of a full-fledged truck route. Companies like Wal-Mart,
Home Depot, Safeway Food and Drug and Ray's
2.
What relationship do STAA trucks have to the servicing of Big Box/Big
Business stores? To servicing potential Port activity (see #14)?
3.
What evidence do you have that STAA compatibility will not induce
growth of Big Box/Big Business stores?
4.
In the “internet survey” of local businesses, did it pose the question
of what impacts the induction of Big Box stores by STAA truck traffic
compatibility would have on their businesses? Have you evaluated this
potential? If not, why not?
5.
Did the “internet survey” ask any businesses or other economic
interests about advantages of Humboldt’s relative geographic isolation? Has
CalTrans evaluated this? If not, why not?
6.
Did the “internet survey” ask whether Big Box stores are more likely
with than without unimpeded STAA traffic? Has CalTrans evaluated this? If not,
why not?
7.
If Big Box stores do not utilize STAA trucks, what do they use? Has
CalTrans evaluated this? If not, why not?
8.
If Big Box stores use smaller trucks, does not that contradict your assertion
that there is a dearth of smaller trucks due to their phasing out?
9.
Do you envision STAA trucks supplying Big Box stores throughout
District 1? Has CalTrans evaluated this? If not, why not?
10. What are the economic and
social consequences of inducing Big Box store growth and survival by enabling
STAA trucks to access them via STAA trucks without inconvenience? Has CalTrans
evaluated this? If not, why not?
11. What peer review or other
accepted statistical measure was used to determine the significance under CEQA
of the “internet surveys” of businesses?
12. If Dr Gallo relied on the
internet survey results, why should his conclusions be
considered significant under CEQA, if the surveys themselves cannot meet the
standard for significance?
13. Does the predicted 12.3% decrease in truck
traffic due to efficiency account for increases due to Big Box or other large
business development?
14. CalTrans Strategic Plan
allocates 15% of the $20 billion budget to infrastructure supporting ports, yet
no mention of the relation of this Project to the
15. XIIa claims less than
significant impact. Has the Big Box/Big Business-inducing consequences of STAA
truck traffic through District 1 been evaluated in order to make this claim?
Has CalTrans evaluated this? If not, why not?
16. XVa makes a similar less
than significant claim, but without analyzing the relation to Big Box
induction, can Cal Trans substantiate this claim? Has CalTrans evaluated this?
If not, why not?
17. The traffic safety data
points to an inappropriate, hazardous speed limit for the traffic and road
conditions through the very short, critical sections of RG. Surely, speed
limitations, including speed tables and other physical elements to constrain
speeds to 25MPH in the critical zones, would be far cheaper with no adverse
environmental consequences. At 25MPH, CO2 emissions conveniently flatten out.
18. “In addition, construction would occur within
the structural root zone of several large, mature redwoods abutting the
existing roadway and the root systems of these trees could be further
affected.” However, there is no biological evaluation of the effects of traffic
on the root systems of nearby redwoods. What scientific evidence have you
evaluated to assess these potential impacts? Has CalTrans evaluated this? If
not, why not?
19. If large redwood tree root
systems are adversely affected, what impact will these adverse effects have
related to edge effects, or other consequences to the ecosystem, including
nearby trees, if these affected redwoods suffer? Has CalTrans evaluated this?
If not, why not?
20. Without evaluating the
impacts to redwood roots, other than to acknowledge that they will be affected,
how can CalTrans check the “less than significant impact” box under Section
IVB?
21. It is well established that
redwood trees have shallow spreading roots that interconnect with those of
other redwood trees. They lack a deep tap root.
Hence, it is reasonable to assume they would be particularly susceptible
to ground compression forces and deranged hydrologic conditions. Widespread top
die-offs along 101 testify to adverse cumulative impacts related to roadside
traffic. Why have you not evaluated this biological reality, and how do you
propose to evaluate and mitigate?
“Generally, sequoias and redwoods are encircled by shallow roots, which extend four to six feet down and 125 feet (!) out from the tree. Redwoods have no taproot…;”
“In another experiment, marked water put into one redwood was detected in another 500 feet away, showing that the roots were connected.”
Giants: The Colossal Trees of Pacific North America, by Audrey Grescoe, with references (but not tied specifically to text). Roberts Rinehart Pub. 1997 pg 21.
“”A redwood does not have a taproot.; it sends out shallow, lateral roots that usually reach no deeper than about 12 feet. The major roots are about one inch in diameter or larger, and they may spread outward more than 50 feet in every direction. The root system also consists of many small, fibrous roots that may form a dense mat in the top three feet of soil (italics added). Redwood roots often interlock with the roots of adjacent trees, forming extensive networks that stabilize the tree and help keep it upright during fierce winds or pounding floods.”
Coast Redwood, A Natural and Cultural History, by Michael Barbour, PhD, Sandy Lyons, and Mark Borchert, PhD, Cachuma Press, 2001, pg 25
21 a. Why is there no actual analysis or
evaluation of the biological impacts to the roots of the redwood trees? The reference to Park estimates of a
Structural Root Zone is generic ("a tree"), not at all specific to
redwood trees, which have widespread, interconnected root systems. You reference
Sec 4.4 of the Natural
Environment Study
States that:
“This work will involve the structural root zones of approximately
25 large redwood trees ranging in diameter from 3 feet to 15…”
“The Structural Root Zone
of a (italic added) tree is
the circular area with the tree trunk at the center and a radius equal to 3
times the diameter of the tree trunk measured at breast height (California
Department of Parks and Recreation 2005).
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 (
And in Environmental
Consequences, 4.6 under Cumulative Impacts:
“Impacts to mature redwood forest and impacts to listed species
are the principal environmental effects that require a cumulative impact
analysis.”
21b. How
is it possible to avoid or mitigate redwood root compression without an
analysis of the extent and vulnerability of the root systems?
Your glib assurances, as in Chapter 5. Mitigation and Minimization Measures, where
you state “No heavy equipment will be staged or parked within the dripline
of mature trees in unpaved areas.” are irrelevant in the face of this critical data
gap.
Notwithstanding the well-established fact that the root zones of
mature redwood trees-and some of these 15 big trees are over 9 feet DBH-extends
as far as 500 feet from the tree, the
dripline may not even be three times
the DBH (see referenced quotes below).
Substantial evidence in addition to that of
22. Why is there no mitigation
for the predictable effects of increased traffic overlying the root systems of
old growth redwoods?
23. You project a 50% increase
in traffic in 20 years. What will be the
likely and potential impacts on the redwood ecosystem of such increased traffic
on the proposed Project stretches?
24. Has CalTrans made any provision for improved
bicycle safety in this Project? Has CalTrans evaluated this? If not, why not?
25. Short-sea shipping has been
touted as an immediately feasible transport modality out of
26. Since 15% of CalTrans’
budgeted priorities is targeted to port
infrastructure, why is short-sea shipping not considered in this DEIR as
justification for the “No Build” alternative?
27. If this Project is considered part of an
overall, incremental effort by CalTrans to make District1 STAA truck
compatible, and the overall effect of this, when considered with all the other
past and planned projects relevant to this overarching goal, is to induce Big
Box/Big Business stores, how can CalTrans claim that there will be less than
significant impacts due to cumulatively considerable incremental effects?
(XVIIb) (see #1)
28. Section
4(f) of the Department of Transportation Act of 1966, codified in federal law
at 49
29. Why
are the cumulative effects of this Project considered apart from those of
related foreseeable CalTrans Projects which would open Del Norte and Humboldt
to STAA trucks, such as the 299 and 199 Projects? Since Del Norte County economics are included
in the benefits touted in the Gallo Report, the RG Project clearly cannot be
viewed as an isolated Project independent of these other Projects which are on
the drawing board.
30. Please provide an independent evaluation of
the methods, data, results, and conclusions of the Gallo Report and any other
survey used by CalTrans to develop the economic analyses cited in the
DEIR. Credible critiques reveal
substantial flaws which invalidate the purported conclusions, rendering them
insubstantial under CEQA (see Dave Spreen comments, for example). Clearly, these so-called surveys were
designed and interpreted to support pre-determined outcomes, a fraudulent
enterprise at best. Why were surveys not
designed that could evaluate all of the foreseeable and probable effects of
this Project, rather than the adorned, unsubstantiated, subjective (largely
guesswork) perspectives of a few business owners?
31. “NEPA requires that an EIS
be prepared when the proposed federal action (project) as a whole has the
potential to “significantly affect the quality of the
human environment.” If unimpeded STAA truck traffic enhances Big Box/Big
Business advantages over local business throughout District 1, why does this
fact not trigger an EIS? (see #1)
Thank
You,
Ken
Miller