Sneaky Caltrans Avoids Public Comment on Richardson Grove

Caltrans is once again renewing its assault on the ancient redwoods in Richardson Grove State Park.  With their current conclusion of “findings of no significant impact” they are attempting to modify their original Environmental Impact Report without allowing for the re-opening of public comment. We cannot let them get away with it!

Caltrans is using a disordered process. In previous lawsuits filed by defenders of the redwoods and public land, the court found Caltrans was not in sync with existing law in reviewing impacts. This time around, Caltrans gathered together documents, new and old, (old documents from the previous shot-down proposal), attempting to either sneak through or ram through woefully inadequate documents in what the plaintiffs called a “disordered and informal process” that is not in keeping with the law. They gave this process their own stamp of approval on May 22, 2017. 

Caltrans is exhibiting an obsession with this project. Conceived in 1994 and first proposed in 2007, with an EIR* released in 2008 that received a large volume of comments, overwhelmingly opposing the highway expansion. After the final EIR came out in 2010, environmentalists filed a state lawsuit based on CEQA*, and then a federal lawsuit based on NEPA* 

The current lawsuit just filed in State Court by EPIC*, the Center for Biological Diversity, CATS, et al, cites specific violations of CEQA, which governs development that could affect the environment, at the state level), including: 

  • Failure to prepare and adopt an adequate EIR
  • Invalid use of an addendum  
  • Failure to provide the public its right of review 
  • Failure to evaluate significant environmental impacts 
  • Failure to evaluate and adopt feasible alternatives 
  • Failure to adequate disclose and evaluate cumulative impacts 
  • Failure to adopt mitigation measures or a mitigation monitoring plan  
  • Failure to adopt findings of the court

The lawsuit states:

“Caltrans proposes to engage in a multimillion dollar project and to endanger the survival of giant old-growth redwoods that have towered over the area for millennia, not to solve any safety issues, but rather to let an unknown number of bigger commercial trucks pass through a one mile stretch of road without the hassle of seeking an exemption. The short-sightedness of this Proposed Project is dumbfounding; and Caltrans review of it is contrary to state law.”  

The ancient redwoods of Richardson Grove, and indeed, the associated other plant and animal species that share the forest are a precious, irreplaceable and valuable beyond words part of the natural environment, and have a right to exist for their own sake as well as for future generations to experience.  

The Proposed Project contradicts Caltrans’ own acknowledgment of “the importance of redwoods.” The ancient redwoods in Richardson Grove State Park are protected trees, within which State Parks declares “it is impossible to install a new facility without causing damage.” Accordingly, State Parks further advises that:  

“There should be no construction activities in the Structural Root Zone of a protected tree … Any Intrusion into this zone is usually accompanied by significant injury to roots further from the trunk; this will shorten the useful life of the tree in the developed area by reducing vigor and introducing root disease. Furthermore, damage to any structural roots may cause an already structurally compromised tree to become hazardous.”  

Below are talking points you can use to communicate your opinions to Caltrans, to your elected representatives, and to spread the word about the need to stop this project. We need to put the brakes on Caltrans!

Flawed justification:  When Caltrans first proposed the Richardson Grove Highway Expansion Project, they argued it was needed on safety grounds. After that was shown to be baseless, they dropped that premise. Caltrans’ only justification this time around for this project, which clearly carries grave threats to the State Park, the forest and the ancient redwood trees themselves is to allow over-sized big rig trucks known as “STAA* trucks”. But this justification is flawed because these larger trucks already travel through this stretch of highway 101 through exemptions given by the state. Granting additional exemptions is not analyzed as an alternative, as required in the project proposal process.

Failure to pursue less impactful alternatives:  Lowering the speed limit through the Grove, a sound idea obvious to anyone who has traveled through Richardson Grove, on the grounds of safety as well as in recognition of the proximity of the paved road to the massive trunks of these ancient trees is also not analyzed as an alternative.

Failure to honestly and scientifically analyze impacts to ancient redwoods: It is not unreasonable to presume that the huge, old trees towering over this stretch of highway 101 are already heavily impacted by the pavement of the road coming right up to their massive trunks, covering a good portion of their root system, so any further impact would have even more serious repercussions. Impact from pavement, compaction and digging around the roots of redwoods is made especially severe because redwoods, unlike other large trees, do not have tap roots to stabilize them, but rather have a lateral, spreading root system close to the surface to take advantage of moisture that the tall branches capture and drip down to the root zone. 

Failure to adequately consider impacts to Coho Salmon:  The watershed of the South Fork of the Eel River, including its tributaries, is designated critical habitat under the ESA for the SONCC Coho. All of the work Caltrans is proposing to do is upslope for the South Fork of the Eel River. 

No meaningful assessment of the cumulative effects: Increased truck traffic and resulting development and increased sprawl needs to be analyzed. In addition, there is less need for this project now that upgrades have been made to highway 299, connecting 101 and I-5.  

There are many other repair and mitigation projects that should have higher priority, that the public supports and wants its tax monies directed toward. (For example, massive slides in Big Sur, Last Chance Grade in Humboldt County, and perpetual slides on northern highway 101, plus many others, particularly after this past winter.) 

The proposed project absolutely does not have our stamp of approval, and there is no amount of mitigation or legal concessions that could make it right. Please let Caltrans and your elected representatives know how you feel about this project.

Write to:

Malcolm Dougherty, Caltrans Director
1120 N St., MS49
Sacramento, CA  95814 


Brian Kelley
Secretary of Calif. State Transportation Agency
915 Capital Mall, Ste. 350B
Sacramento, CA 95814 

Also, contact YOUR representatives: Find your rep at


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Breaking: Coalition Sues to Stop Richardson Grove Project Again

Environmental groups and local residents today sued the California Department of Transportation (Caltrans) for approving a highway-widening project that would damage or destroy 1,000- to 2,000-year-old redwood trees in California’s iconic Richardson Grove State Park, along Highway 101 in Humboldt County.

Today’s lawsuit, filed in Humboldt County Superior Court, challenges the transportation agency’s latest approval of the controversial project. Three previous legal challenges blocked construction and forced Caltrans to rescind all project approvals in 2014. Caltrans quietly reapproved the project last month, purportedly to improve highway access for oversized commercial trucks.

“Caltrans keeps pushing this nonsensical project that would do terrible damage to ancient redwoods in our state park, with no benefits to the community,” said Aruna Prabhala, an attorney at the Center for Biological Diversity. “There’s just no compelling traffic or safety reason to destroy these beautiful trees. The changes Caltrans claims it’s made to the project won’t protect more than 100 giant redwoods from being damaged or killed.”

The “Richardson Grove Operational Improvement Project” would cut into and pave over the roots of more than 100 of Richardson Grove’s ancient redwoods, including trees up to 2,000 years old, 18 feet in diameter and 300 feet tall. Caltrans has pursued this project solely to benefit passage for oversized commercial trucks and continues to rely on inadequate environmental review.

“EPIC is disappointed that Caltrans has continued to push forward, ignoring previous court warnings about the need to honestly evaluate the effects of its road widening on old-growth redwoods,” said Tom Wheeler, executive director and staff attorney at the Environmental Protection Information Center. “Caltrans’ road widening shows no respect for sacred parkland and irreplaceable ancient trees.”

“Caltrans does not seem to get that we the people, by law, have a place at the table when important decisions are made affecting our environment, and in the case of this iconic and beloved grove of ancient redwoods, just how important it is to protect irreplaceable magnificent old trees when decisions made are of such consequences,” said Patty Clary, executive director of Californians for Alternatives to Toxics.

Today’s suit was filed by the Center for Biological Diversity; the Environmental Protection Information Center (EPIC); Californians for Alternatives to Toxics; Friends of Del Norte; and longtime local residents Bess Bair, Trisha Lee Lotus, Jeffrey Hedin and David Spreen. The suit challenges Caltrans’ violations of the California Environmental Quality Act, and inadequate evaluation of environmental impacts, a misleading conclusion that the project would have no significant impact on the environment, and a flawed determination that none of the proposed highway alterations would threaten the stability of any old-growth redwoods.


Richardson Grove State Park, where tourists often first encounter large redwoods when heading north on Highway 101, is home to one of the last protected stands of accessible old-growth redwood trees in the world and is a jewel of the state park system. The park also contains essential habitat for threatened and endangered species such as the northern spotted owl, and its creeks support runs of imperiled salmon and steelhead trout.

Caltrans first proposed the project in 2007, claiming the highway-widening is needed to accommodate large-truck travel. However, Caltrans acknowledges that Highway 101 through Richardson Grove is already designated for larger trucks and does not have significant safety problems. The agency cannot demonstrate that the project is necessary for safety or would benefit the local economy.

There has been substantial local opposition to the project, led by the Save Richardson Grove Coalition, a diverse group of community members including economists, business owners, scientists and Northern California tribes with longstanding ties to the grove. In 2012 a federal court stopped the project, citing numerous errors in Caltrans’ mapping and measurement of affected old-growth redwoods and stating that the agency had been “arbitrary and capricious” in its use of what the court called “faulty data.” In 2014 a California Court of Appeal ordered Caltrans to reevaluate the environmental impacts of the project under state law, finding that it had failed to fully assess impacts on ancient redwoods or provide measures to reduce potentially severe harm to the trees.

Caltrans re-approved the project again and now claims it made changes to better protect old-growth redwood trees, such as impacting fewer trees, less excavation, and less depth of surface pavement.

However, the “changes” to the project do not markedly differ from what the courts previously rejected as inadequate, and Caltrans has not answered the questions and concerns raised about structural damage to redwoods from cutting into their roots.

The attorneys for the plaintiffs in this suit are Philip Gregory of Cotchett, Pitre & McCarthy LLP; Stuart Gross of Gross & Klein LLP; and Sharon Duggan, a staff attorney with EPIC and a long-time expert on environmental law.

Click here to read the petition.

Click here to view additional articles about Richardson Grove.


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DON’T Let Long Big Rig Trucks onto the Scenic California Redwood Highway!

DON’T Let Long Big Rig Trucks onto the Scenic California Redwood Highway!

A petition from wild Smith River canyon resident Wendy Bertrand is circulating among international tourists and regional visitors who come every year to enjoy the pristine Smith River and redwood forests of Del Norte County, where the Smith River flows from Oregon down into California’s rugged lush landscape.Bertrand’ petition urges Caltrans to Keep Super Trucks away from The Smith River, and maintain existing size restrictions prohibiting the long industrial big rig (STAA) trucks from traveling on the scenic two-lane California Redwood Highway 197/199.

The Smith River

Photo of The Smith River by Gisèle Albertine

Without any economic, social or environmental benefits, Caltrans has developed this project to remove size restrictions, allowing trucks averaging 78 feet in length and up to 80,000 lbs. to routinely travel the steep and winding shoulderless road; dangerous because of the many blind corners around which a deer, tourist, oncoming motorist or RV might appear. The size and weight of the trucks make it difficult to stop suddenly or to safely negotiate double and triple hairpin turns. Just last year, a park visitor looking at the redwoods was killed by a tractor trailer truck that couldn’t stop in time.

Bertrand, an architect, is passionate about taking care of place and hopes that having the support of outdoor enthusiasts, whether on the trail, on a bicycle, holding a fishing rod, at a picnic table or in an RV, will increase the stakeholders’ voice to be loud enough to focus Caltrans’ attention on the fact that people and nature are equally important parts of the context of transportation planning  and this project only harms the character and livability of a treasured part of California’s forested northwest.

For years, Bertrand, along with others in the community, has been writing letters, attending meetings, and collecting over 600 local signatures against the STAA trucks on this corridor, and yet the project keeps rolling along, without any fiscal benefits to County residents or visitors, and with no concern for the negative impact to the human environment. In her research, Bertrand also found that internal Caltrans policies and design standards have not been followed.

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Photo of Jedediah Smith State Park by Russ Bishop on flickr.

Every year, hundreds of thousands of visitors from near and far around the world travel Highway 197/199 on their way to Jedediah Smith State Park, a UNESCO World Heritage site famous for its massive old-growth redwood trees, family camping and picnicking sites, kayaking, hiking trails, fishing, and swimming. The highway also borders the unspoiled Smith River, Del Norte’s water supply and one of California’s most treasured wild and scenic rivers, home to chinook and coho salmon, steelhead and sea run cutthroat trout.

Bertrand, who has lived in Del Norte for 25 summers, decided to appeal to everyone who enjoys the serenity and natural beauty of the area, reasoning that they had a vested interest in the cultural, economic, and safety concerns of the current project, currently delayed by the court for ecological impact issues. She is concerned about the toll on the human environment of those who visit and those who live in Gasquet, Hiouchi, or nearby Crescent City. “Why would Caltrans want to run us down?” She wonders!

The Smith River

Photo of The Smith River by Gisèle Albertine

Highway 197/199 is the only road available to local residents conducting their daily business. Bertrand maintains that allowing the long industrial trucks (STAA Trucks) on the canyon’s only road is inappropriate, negatively impacting the recreational values and rural livability.  A more direct road for big rigs on their way to Eureka will soon be available on Highway 299 via I-5. These trucks already serve Del Norte, a county of 25,000 people, on Highway 101. Rather than cutting into rock cliffs and cutting down trees, as the current project calls for, Bertrand is calling on local residents, regional and worldwide tourists, and native peoples to sign the petition urging Caltrans to use the budgeted $61 million California taxpayers’ dollars to enhance the planet’s sustainability, the recreation and ecotourism economy, along with citizens’ livability per the stated Caltrans mission, while not allowing access to the long heavy dangerous STAA trucks.

Says Bertrand, “This will be my first petition, but I feel strongly that Caltrans taxpayers dollars should benefit the population and the place, rather than distressing, depreciating, and threatening tribes, all the visitors and residents, as well as the physical natural setting we depend on and love.”

Concerned parties can sign the petition here: DON’T Let Long Big Rig Trucks onto the Scenic California Redwood Highway!

By Wendy Bertrand

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My Word: Conflicting rationales for the Richardson Grove project

When the Richardson Grove project was first announced in September 2007 the Caltrans rationale for the project was “safety.” The safety concern cited was the potential for two big-rigs or a big-rig and another vehicle passing side by side to collide because one might “off-track” and hit the other vehicle.“Off-tracking “is caused when the back end of a big-rig swings out over the double yellow line while rounding a sharp curve. Currently that is the reason why only California legal trucks are allowed in Richardson Grove as well as on stretches of Highways 197/199 through the Smith River canyon.

Photo by Jack Gescheidt

Opponents of the project consulted CHP accident reports and found no documented accidents in the Grove attributed to off-tracking. To this day, there still has not been a documented accident in the Grove caused by off-tracking. Nevertheless Caltrans still cites this as a safety concern. Yet and in defiance of all logic it insists that it must make Highway 101 accessible to even larger Federal standard STAA trucks.

One year ago on April 10, 2014, a bus was heading north on Interstate 5 carrying high school students, prospective enrollees in HSU. An STAA FedEx big-rig heading south inexplicably crossed the wide grassy median and collided with the bus. Ten lives were lost in the horrific crash – 9 of the lives in the bus – the driver of the big-rig was victim 10.

Interstate 5 is as straight as an arrow between Redding and Sacramento. This crash occurred in broad daylight. Now think about one of these 80,000 gross weight monsters with no length limit (as per Federal standards) on our rural roads and hurtling through Eureka during rush hour. This is the “safety” Caltrans wants to inflict on our area.

This is not the end of the insanity. Every year the trucking industry lobbies Congress to increase the gross weight of these vehicles. Recently a 97,000 pound gross weight was proposed. The industry has lobbied for fewer restrictions on driver rest time requirements as well as for longer trailers. An effort was made recently to increase the length of double trailers from the present 28 feet to 33 feet. Nothing in the Caltrans documentation for this project addresses truck safety or the possibility for longer and heavier trucks on our rural roads.

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In a recent nationally broadcast episode on highway safety by ABC’s 20/20 newsmagazine the first 10-minute segment was devoted to big-rig accidents. In 2012 there were 330,000 accidents nationally involving big-rig trucks resulting in over 4,000 deaths. In accidents involving a big-rig and a car there is a 97% fatality rate for car occupants. Please see the website <>

Why the push by Caltrans to make Highway 101 STAA accessible and put us all at risk?

Highway 299 is already being made STAA accessible so the east-west corridor will be open between Redding and Eureka. Obviously our safety is not their concern. Opening Highways 197/199 and 101 will provide north-south Interstate truck access from Grants Pass to the Bay Area. Caltrans claims this will not result in an increase in truck traffic. It even claims that there will be a decrease in truck traffic. This decrease in truck traffic will probably result from driving our local truckers out of business. Our local truckers (Goselin, A-Tech, Oak Harbor, Al Lewis, Joe Costa, et al.) have been delivering goods and freight between the Bay Area and Crescent City for years. Caltrans claims it wants the STAA access for “businesss” but nowhere does it discuss the effect of competition by the Interstate trucking firms on our local trucking businesses or the jobs they provide.

Recently our tourism industry announced a new marketing campaign promoting Humboldt County as “Magical” and “Mystical.” Please ask yourself how magical and mystical it will appear to tourists trying to cross Broadway when one of these STAA trucks thunders through Eureka. Please remember also that these trucks will be coming to a rural road near you to either refuel or make delivery. Northing restricts them from leaving the highway so ask yourself how magical is that? Caltrans’ thinking is magical if they think this is about safety!

Many thanks!  Do not hesitate to contact me at  Barbara Kennedy

Originally posted in the Times Standard on 4/12/15

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Caltrans District 1: Wake up and smell the 21st Century

It is time for a change. Now is time to rein in Caltrans. Last year, an independent report—the SSTI Assessment and Recommendations, authored by the State Smart Transportation Initiative—was released. Commissioned at the behest of Governor Brown, the report found that Caltrans is stuck in an “era of [i]nter-state building” despite calls (since the 1970’s) for more multimodalism, sustainability and less reliance on auto-mobilty. The study also finds that Caltrans has not developed sufficient communications skills and procedures to either explain its own decisions or to take into account important material from communities and partners; and has not fully adapted to the multi-stakeholder environment in which it finds itself. The pattern of inadequate response to community concerns about social and environmental impacts of highway development, as well as a lack of legal accountability becomes apparent when a series of projects are looked in their entirety.

Four Caltrans projects on California’s North Coast stand as examples of this “stuck-in-the-past” project planning.

Richardson Grove

The highway “realignment” through Richardson Grove State Park seriously threatens mammoth ancient redwood trees—a fact confirmed by the 1st District Court of Appeal, which ruled in 2012 that Caltrans failed to adequately analyze the impact of its proposed project on the ancient redwoods. This should have come as no surprise to Caltrans. In 2010, by Caltrans own admission, the agency found the project, as proposed, “may cause significant adverse impacts to old growth trees in this unique natural community.” California State Parks likewise expressed concern in its comments to the Draft Environmental Assessment, “The Draft EA does not provide an assessment of the number of trees that will have their structural root zone compromised. Without such an assessment the State Parks cannot adequately assess the proposed action’s impacts on old-growth redwoods and other mature trees. Caltrans therefore must assume that the proposed action will result in significant adverse effects to old-growth redwoods and that adequate mitigation needs to be developed.” (Emphasis added.)

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Caltrans initially informed the public that the purpose of project was to enhance safety and goods movement; however it changed tack during the environmental review process, and ultimately concluded that the Proposed Project is not a safety project and concluded that the economic impacts of the proposed project on Humboldt County businesses and trucking firms would be negligible.

After seven-years and three lawsuits Caltrans has rescinded its approval of the Richardson Grove Project and withdrawn its federal Finding of No Significant Impact. Now the project cannot proceed until additional environmental analysis about the impacts of the project on the environment are completed and approved by the courts.

It didn’t have to be this way. Richardson Grove is world-class state park and the ancient redwood trees it protects deserve the fullest protection under the law—and yet, Caltrans repeatedly failed to follow the law. Instead the agency and Humboldt County advanced a public relations campaign to promote highway expansion saying that the project would be good for business and have “no significant impact,” despite the fact that to date it has not provided the public with any legitimate evidence, criteria for decision making, meaningful explanation why or analysis to substantiate that conclusion. Instead of properly analyzing viable alternatives that better reflect the needs of Californians and the environmental realities of our times, Caltrans has wasted time and money trying to prove its project is benign.

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Caltrans estimates that new documentation will be available in fall 2015 and public comment will be re-opened. EPIC is committed to taking all steps to preserve Richardson Grove State Park’s old-growth redwoods and looks forward to reading and analyzing Caltrans’ next iteration of documentation.

Willits Bypass

The Willits Bypass is draining 90 acres of precious wetlands for a giant interchange made for a four-lane freeway that will do little to relieve local congestion. Caltrans’ implementation of the Bypass has seen a laundry list of environmental permit and cultural violations including being charged with violating the U.S. Clean Water Act when erosion at the site sent pollution streaming into a protected creek and destroying a known Native American archaeological site that was supposed to be protected by law. The impact is so severe that Caltrans is required to do the largest environmental mitigation in its history to compensate. But Caltrans has had trouble meeting permit and mitigation requirements. In June 2014, Caltrans was so far behind in its environmental requirements the U.S.


Photo by Caltrans

Army Corps of Engineers suspended the permit and shut down most work on the bypass for more than 3-weeks. Then there was the stunning collapse of a 150-foot section of the Bypass viaduct on January 22, 2015, dumping cement and debris right into Haehl Creek! More recently Caltrans requested an additional $64.7 million in funding from the California Transportation Commission for what it calls “unforeseen issues.”

If compelled, Caltrans could implement design changes to the northern interchange such as reducing the footprint from 4-lanes to 2-lanes, which would reduce environmental impacts, damage to cultural sites and save money.

Smith River Highway 199

The Smith River

Photo of The Smith River by Gisèle Albertine

A highway development project planned for Highway 199 and 197 in the northwestern-most corner of California poses direct and indirect threats to our redwood parks and the unparalleled salmon habitat of the wild Smith River in Del Norte County. In response to a lawsuit by EPIC, Caltrans has agreed to reassess impacts of the highway-widening project on protected salmon and their habitat along the Wild and Scenic Smith River. A settlement agreement will keep in place a court-ordered halt of construction work until Caltrans completes consultation with the National Marine Fisheries.


Four Bridges Project

Lastly, Caltrans’ Four Bridges Project is proposing to upgrade four existing bridges along the Avenue of the Giants, a world-famous scenic drive through the ancient redwood groves of Redwood State Park. EPIC found that the agency’s initial release of the project proposal violated the California Environmental Quality Act as it failed to adequately provide the public with access to various environmental studies, which the agency relied on to justify its conclusion that the project would have no significant impact and that further study wasn’t needed.

The North Coast community deserves an honest, transparent, and open discussion about the impacts of highway development on its irreplaceable natural treasures, and about the costs and the benefits of this infrastructure development. This discussion must include recognizing the viability of alternatives that will meet needs for goods movement and transportation, as well as protect the rare and sensitive environments.

.Image result for photos of four bridges in redwood state park, ca

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Yet, Caltrans has refused to be forthright with residents about the direct impacts of its highway development projects, much less been willing to engage the public in a productive manner when concerns are raised. In the absence of credible leadership by Caltrans, EPIC has challenged the legality of these projects with the immediate intent of protecting rare and sensitive environments, and with the long-term goal of leveraging successful court action into political momentum that will lead to a serious reform of the agency and change in culture. A major restructuring of the Caltrans is under way as a result of the SSTI Report; the question remains whether the recommendations of the independent review combined with the reality check of the court orders will be sufficient impetus to bring Caltrans out of the past.

Last Chance Grade

Caltrans may have an opportunity to get it right with Last Chance Grade—a stretch of U.S. Highway 101 about ten miles south of Crescent City which sits precariously high above the Pacific Ocean and experiences frequent landslides due to the geological instability of the area Caltrans is in the beginning stages of planning for the Last Chance Grade Project along Highway 101. The agency is considering possible alternatives and reroutes in an attempt to find a long-term solution for the Last Chance Grade. U.S. Congressman Huffman’s office is working to develop a stakeholder group for facilitated discussions regarding potential projects to address Last Chance Grade. This group would work to identify one or two alternatives for a project that would ensure that U.S. Highway 101 is protected from a serious failure of the roadway and environmental harms are reduced. The group’s discussions would parallel and inform the current public process Caltrans has embarked on.

Photo by Caltrans

There is no question that Caltrans needs significant reform to bring it into step with best practices in the transportation field, with the state of California’s policy expectations and the true needs of North Coast residents. While the lawsuits are effective for enforcing the law, they do not permanently stop projects, and reform is what will lead to sustainable transportation solutions for rural communities. This reform is not only the demand of citizen organizations like EPIC; it is the recommendation of one of the nation’s leading authorities on sustainable transportation. The time has arrived to rein in Caltrans.

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Supervisors still support Richardson Grove project

Mad River Union: 3/11/15

By Daniel Mintz

HUMBOLDT – Court rulings have set back the California Department of Transportation’s Richardson Grove project but the Board of Supervisors’ unanimous support of it has not wavered.

Caltrans officials updated the project’s status at the March 3 board meeting. The project has run into roadblocks in court – a state appeals court ruling decertified its Environmental Impact Report (EIR) and, in 2012, a federal judge issued an injunction against its federal environmental review.

Photo courtesy Caltrans


Caltrans has agreed to re-do the federal review. Project Manager Kim Floyd told supervisors that the new version will be released this fall.

Construction is expected to begin in 2017 but Floyd said her agency is expecting more lawsuits along the way.

Charlie Fielder, Caltrans’ district manager, said the project’s challenges belie its careful approach and minimal impacts.

“Who would think such a minor amount of work would take as much time and staff resources and generate the kind of controversy it has,” he told supervisors. “Unfortunately, it’s gotten mired down in what I call a lot of bureaucracy and technicalities.”

The project would allow access of standard-sized, 53-foot long truck trailers through Richardson Grove. Floyd said about 56 trees would be removed, 31 of them within Richardson Grove State Park.

Only two redwoods would be cut, she added, one four inches in diameter and the other eight inches.

But work and paving done in the root health zone of 116 redwoods is one of the project’s biggest issues and the appeals court found that it needs additional study.

When Supervisor Rex Bohn asked Floyd how much has been spent on what he called “the lawyers full employment act,” Floyd said her agency has paid out $1 million for opposing attorney’s fees and $8 million has been spent on staff time.

During public comment, Weott resident Barbara Kennedy noted that lawsuits against the project have so far prevailed and she disputed portrayals of the project as being carefully planned.

“It’s obvious that Caltrans did not do a particularly spectacular job with their EIR, otherwise a federal judge would not have issued an injunction citing all the errors in the EIR… not to mention the California Court of Appeals,” she said. “This is not a ‘full attorneys employment act’ or whatever you’re saying – these are legitimate issues that were not responded to in [the EIR’s] public comment.”

Natalynn DeLapp, the executive director of the Environmental Protection Information Center, one of three environmental groups involved in the lawsuits, said the legal outcomes have shown that Caltrans didn’t “give the consideration that the park deserves.”

She said the lawsuits were filed to ensure protection of a public trust resource and recommended prioritization of infrastructure needs through a public process.

But Floyd said that a “tree by tree analysis” has been done and a professional arborist concluded that the project won’t threaten the health of redwood trees.

Supervisors highlighted the project’s importance to a variety of businesses and expressed confidence that its impacts are limited.

Board Chair Estelle Fennell said perceptions of the project have often been based on misunderstanding. A prevalent belief is that larger redwoods will be cut. “That confusion has grown and clarity is a big issue here,” she continued.

Supervisors encouraged Caltrans to continue its work. In giving his support, Supervisor Ryan Sundberg told Fielder and Floyd, “Thanks for not letting this project die.”

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Caltrans Seeks Public Input on Statewide Long-Range Transportation Plan Deadline is April 17 for public input, comments

California Department of Transportation:

Date:  March 4, 2015
District:  Headquarters
Contact:  Tamie McGowen
Phone:  (916) 657-5060

SACRAMENTO – With seven workshops and a webinar slated for March, Caltrans invites the public to help shape the state’s transportation future by offering their input and comments on the California Transportation Plan 2040 (CTP 2040), which lays out a vision for California’s transportation future to support a vibrant economy and our greenhouse gas emission reduction goals.

“We are creating a long-term vision for California’s transportation system, and the public will play a key role in that,” said Caltrans Director Malcolm Dougherty. “We are looking at innovative ways on how to best improve the sustainability of the state’s transportation system through strategies such as more transit service, safer bicycling and walking facilities and reduced congestion through less single occupant vehicle use.”

The CTP 2040 is a statewide policy plan designed to meet California’s future transportation needs and to support achieving a statewide reduction in greenhouse gas emissions 80 percent below 1990 levels by 2050. It envisions a fully integrated, multimodal and sustainable transportation system.

The interactive workshops will include a short overview presentation, maps and exhibits, and activities to share information about transportation concerns. They will also help shape the final CTP 2040 document, which will help inform how California transportation dollars are invested. Caltrans is also seeking the public’s input to help insure that the CTP 2040 is fully consistent with the department’s mission, vision and goals to reduce single occupant vehicle use, promote active transportation to reduce emissions and improve public health and support the “Complete Streets” principle.

Caltrans has scheduled these events throughout the month for public comment. The public can also review and comment on the plan, in addition to doing so via these events, The deadline for comments is April 17, 2015.

The CTP 2040 scenarios also support the Governor’s goal to reduce petroleum use in vehicles by up to 50 percent by 2030.

For an opportunity to review and comment on the draft plan, please attend any of these seven public workshops:

• Sacramento: 4-7 p.m., March 10, North Natomas Library, 4660 Via Ingoglia

• Redding: 4-7 p.m., March 12, City of Redding Community Room, 777 Cypress Ave.

• San Diego: 4-7 p.m., March 17, San Diego Valencia Park/Malcolm X Public Library, 5148 Market St.

• Riverside: 4-7 p.m., March 18, Riverside City College, 4800 Magnolia Ave.

• Los Angeles: 4-7 p.m., March 19, Southern California Association of Governments, 818 West 7th St., 12th Floor

• Fresno: 4-7 p.m., March 24, Fresno City College, 1101 East University Ave.

• Oakland: 4-7 p.m., March 26, Joseph P. Bort Metrocenter, 101 Eighth St., Oakland

• Webinar: 2-3 p.m., March 5, visit:

The development of the CTP is an open and collaborative planning process that includes governmental agencies, the private sector, advocacy groups, community organizations, and the public. To view the draft plan, informational materials, and to receive more details on the public workshops, please visit:

Those unable to attend a meeting in person, can comment via an email to or by sending a letter or a completed comment card to: California Department of Transportation, Division of Transportation Planning, Office of State Planning, 1120 N St., MS 32, Sacramento, CA 95814. Comments must be submitted by 5 p.m., April 17.

Providing safe mobility for all users—including pedestrians, transit riders, bicyclists and motorists—supports the mission of Caltrans to “Provide a safe, sustainable, integrated and efficient transportation system to enhance California’s economy and livability.” The CTP 2040 helps support this mission while furthering an ongoing conversation about California’s transportation future. Each year, Caltrans conducts numerous community and public outreach events and workshops to solicit public input and comment, including on efforts to reduce greenhouse gas emissions in transportation. Last year, Caltrans also hosted multiple community meetings across California about how to improve transportation between regions of the state as part of the “Interregional Transportation Strategic Plan.” To keep up on current information about the department, follow Caltrans on Twitter at or visit

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Caltrans updates board on Richardson Grove, says litigation ‘likely’

Times Standard Newspaper: 3/3/15

Supporters and opponents of Caltrans’ Richardson Grove Improvement Project gathered in the Humboldt County Board of Supervisors chamber on Tuesday to hear an update and voice their opinions on the controversial Highway 101 project.

After three lawsuits were filed against the transportation agency concerning the project’s federal and state environmental reviews, Caltrans Project Manager Kim Floyd predicted more of the same.

“We will obtain environmental clearance again and we’ll likely be sued again,” she said.

The project seeks to alter the alignment of 1.1 miles of U.S. Highway 101 through the Richardson Grove State Park in order to allow passage of industry standard-sized trucks that conform to the Surface Transportation Assistance Act, or STAA. STAA trucks are currently prohibited north of Leggett, with ongoing Buckhorn Summit project on State Route 299 working to allow STAA truck access from the east.

Since 2010, two federal lawsuits and one lawsuit at the state level have been filed against the project, with concerns ranging from impacts to the root zones of old-growth redwood trees lining the roadway to impacts of nearby waterways and endangered species. Floyd and two other Caltrans representatives — District 1 Director Charlie Fielder and Deputy District Director for Maintenance and Operations Matt Brady — were at Tuesday’s meeting along with representatives of the Environmental Protection Information Center, which was one of the plaintiffs in the lawsuits. EPIC Executive Director Natalynne DeLapp said that the controversy of the project is an indication that not all factors have been thoroughly addressed by Caltrans and not fully vetted by the community.

“If we work together on these controversial projects they become less controversial,” she said. Floyd said that Caltrans has held several meetings regarding the project since 2007 and has reviewed over 800 public comments on it. She further said that EPIC declined to attend some of these discussions and filed the lawsuits instead.

The state level litigation eventually went to the Court of Appeal where a judge ruled that Caltrans had to reevaluate its submitted environmental impact report. Floyd said Caltrans expects to have those studies done by this fall. Caltrans agreed to rescind its approval of its federal environmental review in order for the second federal lawsuit to be dropped. Floyd said that if all goes as anticipated, the project will get clearance from the environmental agencies in 2016, with construction beginning in 2017.

One of the main areas of dispute in the litigation was what impact the project would have on old growth redwoods and root zones. Floyd said the project construction would remove about 56 trees, 31 of which would be located in the state park, and with two being redwood trees between 4 to 6 inches in diameter. The largest tree that would be removed would be 26 inches in diameter, with no old growth redwoods being removed, Floyd said.

Third District Supervisor Mark Lovelace said that protecting old growth is an essential aspect of the project.

“There is reason that projects like this deserve this level of scrutiny,” he said. “If something does go wrong, these redwoods are irreplaceable.”

Second District Supervisor and board Chairwoman Estelle Fennell said there has been confusion over the size and impact of the project.

“It is such a small project that people can’t understand that it’s not going to impact something,” she said.

With Caltrans spending over $1 million in litigation costs since 2010, 1st District Supervisor Rex Bohn said the lawsuits are creating what he called the “lawyers’ full employment act.”

“We paid a million dollars for the opposition lawyers,” he said. “The cost of Willits (Bypass Project) has been over $40 million. As it was noted, maybe an ‘i’ hasn’t been dotted and a ‘t’ hasn’t been crossed, but the basics for the project have not changed.”

Bohn said passage of STAA trucks — which could carry up to 53-foot-long trailers — would help improve commerce for businesses in and out of Humboldt County. With trucks being able to haul larger trailers through the park if the project is completed, Bohn said there will be fewer trucks on the roadway, and thus less greenhouse gas emissions.

“I know that doesn’t sound well when you’re trying to raise money to fight these things, but the problem is that is a fact,” Bohn said. “We’re missing the point here. We’re trying to make this safer for our traveling public.”

Barbara Kennedy of Weott said that the project will affect much more than Humboldt County and “only a few businesses.”

“Richardson Grove State Park belongs to the state of California and the people of California,” she said. “It does not belong to the people of Humboldt County exclusively or to a handful of business that are advocating for this. People from all around the world and all around the world come here to appreciate the trees for which the park was originally founded to preserve.”

Will Houston can be reached at 707-441-0504.

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Willits Bypass: 150 foot bypass span collapses

Willits News: 1/29/15

By Adrian Baumann

A 150-foot long span of the viaduct being poured for the Willits Bypass collapsed completely Thursday with workers on top and around the site. Two men were trapped in the debris. One freed himself while the other was extracted by Little Lake Fire Department; several workers were injured, three were taken to Frank R, Howard Hospital and one was airlifted directly to Santa Rosa. No one was killed. The three admitted to Howard Hospital were released that evening, while the man sent to Santa Rosa remains in the hospital.

The collapsed occurred at about 2:15 p.m. on Thursday Jan. 22, just north of where the viaduct crosses East Valley St. (Center Valley Rd.) and directly above where it spans Haehl Creek. The falsework for this span of the viaduct, the timber and I-beam scaffolding that supports the concrete forms, has been up for months. Earlier Jan. 22 crews from Flatiron, a CalTrans subcontractor, were pouring concrete for the final box girders, which make up the long spans of the viaduct.

Several workers were atop the structure when it collapsed. Workers described running for their lives as the structure swayed and buckled beneath them. One man, clearly shaken, pointed out that his hardhat was still sitting on the pile of debris.

Little Lake Fire Department responded with two chief officers, heavy rescue, two engines, and 17 total personnel. They initially requested heavy rescue from Brooktrails, and four advanced life support ambulances and an air ambulance.

Little Lake Fire Chief Carl Magann described the situation upon arriving:

“We identified that we had one person that was entrapped in the collapse. One individual was partially entrapped, self-extricated when we got on-scene. He got himself out. And then the one patient, we assisted Flatiron in getting him out from entrapment. He was pinned in by the structure itself, so we worked with flat-iron and we got him out, got him stabilized and transported to CalStar 4, and got him out. He was talking to us, but he was hurt, I don’t know what the extent of the injuries were.”

He continued, “Basically it was just getting the lumber and debris out from where he was. We wound up using a circle saw to get in there and cut some of the debris out. But we didn’t have to use any of our specialized equipment for that.”

A large portion of the debris fell directly into Haehl Creek, poisoning the water and endangering wildlife. The debris fell into Haehl Creek just upstream of where it meets Baechtel Creek. Wayne Briley of REHIT, the Mendocino County department responsible for hazardous materials response, explained that wet concrete is extremely alkaline, with a pH of up to 13 or 14. Meters, which are in the creek at all times measured a brief spike in pH up to 11, but relatively few dead fish were eventually found, and the quick work of game wardens and Flatiron minimized environmental damage.

Game Warden Steve White of California Department of Fish and Wildlife worked with Flatiron to install earthen dams upstream and downstream of the debris in Haehl Creek and diverted water around the rubble.


Clean up began over the weekend on the wreckage of the spilled concrete, bent rebar, broken falsework and shattered formwork that had been slated to become the newest span of the viaduct section of the Willits Bypass. The nearly 950 cubic yards of fluid concrete, and many more tons of steel I-beams and heavy timbers that make up the falsework came tumbling down on Thursday afternoon, the cause of the collapse remains unclear.


According to Little Lake Fire Chief Carl Magann five people were injured in the accident, one declined treatment, two were sent by ambulance to Howard Hospital, another was driven in a private vehicle, with the fifth flown to Santa Rosa; neither CalTrans, nor the primary contractor Flatiron, would make any comment about the workers’ condition except to say that they suffered “non-life threatening injuries.” Three of the men hospitalized worked for Flatiron, with another working for AECOM, another CalTrans contractor.

A California Occupational Safety and Health Administration spokesperson said three workers were injured, two seriously.

As for how many workers were actually on top of and around the span when it collapsed, we may have to wait for the OSHA report to know for sure. Frisbie says that, “Based on the current information it appears there were 4 above and 2 below.” While the official report put out by Magann states that, “It was estimated that 18-20 workers were on the section prior to collapse, most workers successfully running onto the still standing portions of the new freeway.” It is unclear why the discrepancy exists.

Magann’s report also states, “We witnessed one of the Flat-Iron workers self-extricate from the collapsed structure, covered in wet concrete, but denying any injuries. Several workers rode the section down to the ground with several reported injuries.”

In the moments after the arrival of the fire department a headcount was done by the workers, determining that only one man was missing. In the report Magann praises the workers from Flatiron for aiding in freeing their trapped coworker, at personal risk.

Once the injured people had been transported the fire fighters ordered a shut down of all machinery and total silence to listen for anyone else trapped in the rubble, they then used their thermal imaging cameras to search for anyone else who was trapped, finding no one.


In serious mishaps the site is temporarily taken over by CalOSHA, which conducts an investigation of the site, to ensure worker safety and to try to figure out what went wrong. CALOSHA finished their preliminary investigation of the site over the weekend, clearing the way for the primary contractor on this section of the job, Flatiron Construction, to begin clearing the debris.

CalOSHA will now conduct interviews with the workers, and continue to inspect and monitor the site. They were informed of the collapse soon after it happened, but because they are based in Sacramento could not begin their inspection till the following day. By law CalOSHA has six months to complete the investigation.

Spokesman Peter Milton explained, “Basically they have asked for documentation which I don’t believe they’ve received yet…One of the things that they did was they gave parties the ok to begin taking the rubble apart, clear the site so the engineers can inspect it…and we don’t know what it was yet, but that’s what the investigation is trying to find out.”


CalTrans expected to be done with clean up by the end of the Jan. 30. Structural work on the viaduct and other bridges, which had been suspended, resumed across the project. Work on the collapsed span, however, will not resume until engineers have determined the extent of the damage and conduct tests. It’s very likely that the sections near the collapsed portion were also damaged, and the columns at the site were clearly tilted. Engineers will need to test and examine the whole area, understand what went wrong, and if the nearby structures were damaged, before reconstruction can begin.

CalTrans maintains that, because the dry weather has allowed work to continue through the winter, this collapse will not actually significantly delay completion of the bypass.

The cost of that section of the viaduct, also known as “frame 1,” is roughly $3 million dollars according to CalTrans spokesman Phil Frisbie. However, CalTrans confirmed that the additional costs incurred by clean up, delays, and reconstruction will apparently not fall to CalTrans or the taxpayer, but will covered by Flatiron, likely through their insurance.


Not to be confused with scaffolding, which are temporary platforms for workers to stand on, falsework supports the bridge itself while it’s being constructed. Built like temporary bridges, out of big timber posts and steel I-beams girders, and thoroughly cross-braced, the falsework holds up the forms into which the concrete will eventually be poured.

During the pour the falsework must support the full weight of the concrete as it hardens. In fact, the spans are not self supporting until they are “stressed.” Concrete is strongest when it is under tension—after the concrete has hardened long cables placed inside the walls of the box-girders are tensioned.

This means that the falsework must be capable of holding up many tons of concrete while it sets up. Though the weight of concrete varies depending on kind, for 950 cubic yards roughly 1,700 tons is a good estimate. And in addition to the weight of the concrete, there is the weight of the falsework itself.

While the official investigation into the cause of the collapse gets started rumors and pet theories abound in the community. One idea now repeated several times is that the ground beneath the falsework gave out, perhaps as a result of the December flood, or that the ground in which the columns were placed were unstable.

CalTrans provided some details in response to these theories: work on the falsework began in April 2014, finishing up in Jan. 2015; the footings of the falsework are anchored to piles driven into the ground.

Frisbie described the system for double checking the falsework as, “redundant inspections,” which he said were done by CalTrans and contractors, “during erection, during final adjustments, immediately prior to placement of concrete, and continuously during concrete placement.” Frisbie also maintains that at least one inspection was preformed after the December flood.


Flatiron which is based in Colorado, with several divisions across the United States and Canada, has been building bridges for CalTrans since 1991. They are one of CalTrans biggest contractors.

In July 2007 Flatiron, which at that time was called FCI Constructors, suffered another bridge falsework collapse, in Oroville. A 50 foot high span over Highway 149 came crashing down while workers were atop. Carpenter Jeffrey Doll rode the collapsing bridge down and was severely injured. Rob Sylvester, a FedEx contract driver, was also badly hurt when debris from the collapse crashed down on his truck. He was pinned inside for hours, and in 2010 settled out of court with Flatiron. He did not say how much he won, but did donate $25,000 to local firefighters.

After an investigation CalOSHA eventually fined Flatiron $6,750.


The California Department of Fish and Wildlife (CDFW) had Flatiron installed dams and pumps by the evening of the collapse, routing the water flowing in Haehl creek around the debris, and isolating the wet concrete from the flow of the creek.

The dams and diversions in Haehl Creek will be maintained by CDFW until the debris can be cleared and the creek bed remediated. However, CDFW spokesman Andrew Hughan, said that with only 14 dead fish found, none of which were steelhead, the damage was surprisingly minor, “So we’re pleased—we got lucky and we’re pleased with how the effort’s gone so far, and we’re also satisfied that CalTrans and the contractor are doing what they need to do in regards to the fish and the creek.”

He also pointed out that contractors had laid down plastic over the entire area before the pour as a protective measure. When the bridge collapsed the plastic helped contain the wet concrete, acting as a barrier with the creek bed, and minimizing the amount that actually got mixed into the fish habitat.

Steelhead are an endangered species, which is one of the main reason’s for CDFW quick involvement. Said Hughan, “There are several dozen fish in the creek there, waiting to go back to sea, and now with the blockage they are now stuck. Now that being said, Steve [White, the game warden] is confident that CalTrans will build a diversion or get that concrete out of the creek in plenty of time for those steelhead to migrate to the ocean.”

Adding, “As far as the department of Fish and Wildlife is concerned the condition in the creek is stable for now and we can live with the conditions that exist in the creek right now, the most important thing is to find out why it happened and that it does happen again.”

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Action Alert: Tell Caltrans to study impacts before advancing the Four Bridges Project

By Lucy Allen

The California Department of Transportation (Caltrans) is proposing to upgrade four existing  bridges along the Avenue of the Giants, a world-famous scenic drive along old Highway 101, through the ancient redwood groves of Redwood State Park.

Take Action: Tell Caltrans that it needs to adequately study impacts, and adequately inform the public, before they move forward with the project.

Elk Creek Bridge
Elk Creek Bridge

Caltrans released an Initial Study with Proposed Mitigated Negative Declaration for the “Avenue of the Giants – Four Bridges Project” over the holidays, comments are due on Monday, February 2.  (A “Mitigated Negative Declaration” is a CEQA document that essentially says that environmental impacts will be mitigated below significant levels, and therefore that further study of the project impacts is unnecessary.) As proposed, this project would involve upgrades to bridge and guard railings and repaving of the existing roadway on each side of four bridges on Avenue of the Giants/Route 254, and all of this work would occur within and around ancient redwoods and important salmon habitat. Yet, despite the precious resources potentially threatened by this project, Caltrans is pushing the project through without adequately analyzing or disclosing to the public the impacts of the project.

 Tell Caltrans:
* Impacts to redwoods need to be fully analyzed, and all conclusions need to be fully explained to the public, before work begins in and around their roots.
* Adequate, and fully explained, measures to avoid spills or other stream disturbances need to be developed before Caltrans begins working over streams with important fish habitat.
* Caltrans needs to recirculate the Initial Study with Proposed Mitigated Negative Declaration with all underlying studies and documents in order to be transparent with the public about the project and its potential impacts to public resources, and in order to comply with CEQA which requires that the public be provided this information for comment.

Impacts to Trees
Caltrans maintains that the project area contains 46 coastal redwood trees. While the Initial Study and Proposed Mitigated Negative Declaration notes that “[i]t is difficult to develop a mitigation strategy that adequately offsets a project’s impacts to old growth redwood trees, due to their size and age,” it nevertheless concludes that the study will have “less than significant” impacts on these trees. The impacts on each tree in the area were rated on a 0-6 scale corresponding with the magnitude of impacts of the projects on the tree: eleven trees were rated “0” (no effect); fourteen were rated “1” (effect of root zone disturbance is extremely minor with no decline in foliage density or tree health); and twenty-two were rated “2” (effect of root zone disturbance is very slight with no decline in foliage density or tree health). Exactly how this rating system was developed, or how the trees were rated, however, was not disclosed. For trees rated “2,” for instance, the Initial Study indicates that there may be project activities closer than 10 feet from the base of these trees. Caltrans needs to explain why it believes that this work occurring so close to the trees would cause only “very slight”  root zone disturbance.

Various avoidance, minimization, and mitigation measures are proposed to reduce impacts to redwoods. Many, however, contain inadequate descriptions regarding how they will be carried out. For example, one such measure is “no roots greater than two inches in diameter will be cut,” however the Initial Study does not describe how work crews will achieve this.

In short, Caltrans has not demonstrated that it takes seriously the great responsibility of working near our precious ancient redwoods, and that it deserves our trust when they say that the project will leave these trees unharmed.

Impacts on Fish
The bridges at issue span Ohman Creek, Elk Creek, Bridge Creek and Bear Creek, all four of which provide habitat for Chinook and Coho salmon, among other aquatic creatures. As with its analysis of impacts on redwoods, Caltrans concludes that the impacts of the project on fish will be “less than significant,” but it provides little evidence to support this conclusion.

Furthermore, the document acknowledges that unexpected impacts to fish can occur from “unintended spills, increased sedimentation, and alteration of pH.”

Collapse Jan. 22, 2015. Photo Credit: Steve Eberhard Willits News
Collapse Jan. 22, 2015. Photo Credit: Steve Eberhard Willits News

As we have unfortunately learned from the recent collapse of the overpass at Willits Bypass, which spilled wet concrete into a nearby stream, raising the pH of the stream to a level that can kill fish immediately, unintended events can have huge impacts. But the “avoidance, minimization, and/or mitigation measures” provided in the Initial Study for the Four Bridges Project for potential impacts to anadromous fish are vague and inadequate. Before starting work above and around these streams, Caltrans should provide additional assurances that spills and other disturbances of the creeks in the project area will be prevented, and it should develop and circulate for public review a site-specific emergency response plan for spills or other disturbances of the streams.

CEQA violations
CEQA requires that all documents referenced in a proposed mitigated negative declaration be made available to the public. (See Cal. Pub. Res. Code § 21092; CEQA Guidelines  § 15072). In this Mitigated Negative Declaration, however, many conclusions rely entirely on referenced documents and surveys, which were not made publicly available, in clear violation of CEQA.

While ultimately it may be that Caltrans believes it has put adequate measures in place to reduce environmental impacts of this project to acceptable levels, it needs to prove this to the public by publicly releasing all underlying documents so that the public – as a participant in the process for informed decision-making – can review and comment on all the information.

This must be done before Caltrans can act to decide this project.

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