Professional Documents
Culture Documents
Letter To Save Richardson Grove Ancient Redwoods Forest - Bruce Campbell
Letter To Save Richardson Grove Ancient Redwoods Forest - Bruce Campbell
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Date: Sat, 31 Jan 2009 17:12:46 -0800 (PST)
From: glenda hesseltine <gkhesseltine@yahoo.com>
Reply-To: gkhesseltine@yahoo.com
Subject: Fw: Comments on Draft EIR/EA & BA on Richardson
Grove hwy project
To: Barbara Kennedy <bkenn202@asis.com>,
Jan Bramlett <skywriter.5@hotmail.com>, Greg King
<gking@asis.com>,
Ken Miller <tamer1@suddenlink.net>, Kerul
<kerul@wildcalifornia.org>,
Scott Greacen <scott@wildcalifornia.org>, Sharon
<zerocut@aol.com>,
Becky Sandman <beckysandman@sbcglobal.net>
Did you all get a copy of this? I don't know who this guy is,
but he deserves a medal for the meticulous detail and
quality of work.
Bruce Campbell
1158 26th St. #883
Santa Monica, CA 90403
These are my comments on the Draft EIR/EA and the Biological Assessment
for the highway widening / re-alignment scheme targetting the most beautiful
area of the "Redwood Highway" in the only location along its route where ancient
redwood canopy covers the majority of the highway in a one mile stretch -- in the
Richardson Grove State Park area of southern Humboldt County.
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************
Here is a brief summary of 15 very important issues which were not adequately
addressed (if at all) in the DEIR/EA (as well as Biological Assessment) for the
highway project in the Richardson Grove area:
15. LIGHTS and NOISE -- seeing that the document downplays lights involved
with highway work at night, the next documents must analyze this situation in
terms of what the number of lights would be in regards to this night-work and how
many watts would be used, and how far would the light travel -- as compared to
basic traffic headlights through the Richardson Grove area. In addition, such an
analysis including measured decibel levels should occur regarding usual highway
noise as versus additional noise used for demolition, tree removal, grinding,
construction, etc.
********************************************************************************************
***********
In reviewing my scoping comments dated 6-5-08, I note that I called for a
thorough Environmental Impact Statement in my very first paragraph. I still call
for this more thorough document because the DEIR/EA was fairly skimpy, and
we need a much more thorough analysis on a number of fronts including on
federally-related issues. A full EIS is necessary because Highway 101 is a
federal highway, pressure and likely funding is coming from some federal
sources like the Federal Highway Administration, the project site is within a
quarter mile of the South Fork Eel River which has been designated as a
National Wild and Scenic River due to its "outstandingly remarkable values" of
"scenery" and "fish", because there are federally-listed species known to occur
(or with potential to occur) in the project area, and because Richardson Grove
State Park was designated as critical habitat for the federally-threatened Marbled
Murrelet on May 24, 1996.
B. Examine whether the Richardson Grove area could play a role in helping to
re-inhabit Marbled Murrelet Conservation Area #5 with murrelets, and whether
the highway proposal in the Richardson Grove area could impact the chances for
north coast murrelets to ever interbreed with murrelets in MM Conservation Area
#6 (without being captured and relocated).
I hope to attach a pdf file with several key pages from the document which had
this info, but now I will at least name the document and quote most of a key
paragraph here in regards to likelihood for extirpation of the murrelet in MMCZ 5
and MMCZ 6. This quote is from Page VII.6.6-74 of Volume 1B from the Draft
EIR for the Draft Jackson Demonstration State Forest Management Plan
prepared for the California State Board of Forestry and Fire Protection dated
December 2005. "The Zone Model projected an extirpation probability of 100%
within 40 years for Recovery Zones 5 and 6 with a 2% annual migration rate into
the zone. This projection is consistent with other sources and modeling efforts
(population decline of 4-7% per annum) (USFWS 1997, Beissinger and Nur
1997). Higher fecundity and immigration rates would lengthen the time to
extirpation in Zones 5 and 6. Conversely, slightly lower immigration rates in
Zone 5 would hasten extirpation."
Further up on the page of the Jackson Forest document mentioned in the
previous paragraph is more info on the model used which predicted this
extirpation within 40 years (thus about 2044). To briefly summarize, McShane et
al. 2004 did the 5-Year Murrelet Status Review building on prior work to prepare
the Leslie Matrix models for each Marbled Murrelet Conservation Zone
(considered vital for the species recovery), and the conclusion was summarized
in the quoted section in the previous paragraph regarding 100% likelihood of
extirpation from MMCZ 5 and MMCZ 6 in 40 years -- which would be about the
year 2044.
E. If the document claims that mixed conifer stands can help pick up the slack as
far as providing some habitat for the Marbled Murrelet (due to dwindling numbers
of predominately ancient redwood stands), then the document must provide
sound scientific evidence that there is a reasonable likelihood of nesting success
by murrelets in mixed conifer stands in the state of California.
F. Highway 101 is known as the "Redwood Highway." Can you name one
location anywhere along Highway 101 where the redwood canopy goes as far
over the road for as far of a distance as at Richardson Grove State Park? Can
you name any predominately ancient redwood stand as large as Richardson
Grove within a half dozen miles of Highway 101 anywhere to the south of the
Humboldt / Mendocino County line?
G. What are likely cumulative impacts of projects by Caltrans including (but not
limited to) the work in the Confusion Hill area, the proposed "re-alignment" in the
Richardson Grove area, and other projects on Marbled
Murrelet CONSERVATION and RECOVERY, as well as on CONSERVATION
and RECOVERY of Coho Salmon and other native fish of the South Fork Eel
River? Since I have heard suggestion of widening of the Smith River Highway,
please include possible highway expansion (and impacts on murrelet
conservation and recovery) in that area in these calculations and analysis.
I. What will the cumulative impacts of the Richardson Grove project be from the
removal of some trees, from the cutting of the roots of some trees, from using
equipment (including heavy machines and tools) in many phases of the
construction process, from allowing heavier trucks on the roadway when the
project is completed, from soil compaction, and from raising the elevation of the
forest in the short, mid, and long-term including on the trees, on micro-organisms
including mycorrhizal fungi, and other species which inhabit and/or pass through
the Richardson Grove area?
J. Examine the impact of the Richardson Grove road alteration and tree-removal
project on tree transpiration, fog-drip, the hydrologic cycle, rainfall, temperature
extremes, fire risk, and on temperature and sedimentation of the South Fork Eel
River and its tributaries. (Caltrans has admitted that "Some drainage systems
will need to be extended and inlets modified." Also, waterlogging from impeded
drainage has been traced to killing tops of redwood trees, while roads have been
known to dry out some redwood forest areas which is responsible for
deterioration of habitat and die-back as well.)
************************************************************************************
The following are some important excerpts from the Final EIS for the Revision
of the Resource Management Plans of the Western Oregon Bureau of Land
Management which pertain to the Marbled Murrelet. The word chapter and the
chapter number is written on each page, followed by a hyphen and then the page
number of the volume. Chapter 3 - 299 says that, "The short-term actions that
are necessary to stabilize the murrelet population according to the recovery plan
include: * maintain occupied habitat * maintain large blocks of suitable habitat *
maintain and enhance buffer habitat * decrease risks of nesting habitat loss due
to fire and windthrow * reduce predation * minimize disturbance." The asterisks
in that quote were delineating bullet points in the document. I contend that the
proposed highway and retaining wall project in the Richardson Grove would have
an opposite impact than what biologists say is necessary to assure murrelet
survival and have a decent chance for species recovery.
From the same document and page: "The long-term conservation needs for the
murrelet according to the recovery plan include: * increase productivity
(abundance, ratio of juveniles to adults, and nest success) and population size *
increase the amount (stand size and number of stands), quality, and
distribution of suitable nesting habitat * protect and improve the quality of the
marine environment * reduce or eliminate threats to survivorship by reducing
predation in the terrestrial environment and anthropogenic sources of mortality at
sea". It continues: "The U.S. Fish and Wildlife Service (USDI USFWS 1997)
estimates that recovery of the marbled murrelet will require at least 50 years." It
continues: "Six conservation zones were designated in the marbled
murrelet recovery plan (USDI USFWS 1997). The recovery objectives for the
marbled murrelet are measured in each conservation zone with the objective of
ensuring a well-dispersed population of marbled murrelets."
The top of Chapter 3 - 300 says, "The following recent documents summarize
the condition of the marbled murrelet across its range and are incorporated by
reference: * evaluation report for the five-year status review of the marbled
murrelet in Washington, Oregon, and California (McShane et al. 1994) * marbled
murrelet five-year review (USDI USFWS 2004b) * status and trends of
populations and nesting habitat for the marbled murrelet (Huff et al. 2006)". I do
want to point out that one should take the USFWS report with a grain of salt due
to undue political pressure on biologists during the George W. Bush
Administration -- for instance, there were efforts during that administration to
eliminate 96% of the designated critical habitat for the murrelet, and there were
attempts to de-list the murrelet from the federal Endangered Species Act as well.
Here is the first full paragraph on Chapter 3 - 305: "McShane et al. (2004)
produced a demographic model of marbled murrelet populations in
Washington, Oregon, and California by each of the six conservation zones.
Similar to previous studies, they found that populations in all conservation zones
are in decline with mean annual rates of decline between 2.1 percent and 6.2
percent. The highest rates of decline were in Zone 6 at the southern extent of
the range. Furthermore, they conclude it is likely that populations in Zone 5
and 6 could become nonviable in the near future."
The last paragraph on Chapter 3 - 305 reads: "The recovery plan states that
four of the six zones must be functional in order to effectively recover the
marbled murrelet in the short term and long term (e.g., to maintain viable
populations that are well distributed). However, based on the newest population
estimates, it appears only three of the zones contain relatively robust numbers of
marbled murrelets (Zones 1, 3, and 4). Zones 1 and 4 contain the largest
number of marbled murrelets compared to the other four zones, but areas of
concern remain. Of the population in Zone 4, there were 10 percent killed in oil
spills in 1997 (Bentivoglio et al. 2002; Ford et al. 2002)."
"The Siskiyou Coast Range Zone extends from North Bend, Coos County,
Oregon, south to the southern end of Humboldt County, California. It includes
waters within 2 kilometers (1.2 miles) of the Pacific Ocean shoreline (including
Humboldt and Arcata bays) and, in general, extend inland a distance of
56 kilometers (35 miles) from the Pacific Ocean shoreline and coincides with the
'Zone 1' boundary line described to the Forest Ecosystem Management
Assessment Team with minor adjustments (U.S. Department of Agriculture et al.
1993). The boundary encompasses all of the marbled murrelet critical habitat
units designated (the boundary extends slightly beyond 56 kilometers (35 miles)
in certain areas."
This zone has large blocks of suitable habitat critical to the three-state marbled
murrelet population recovery over the next 100 years. However, the amount of
suitable habitat protected in parks is probably not sufficient by itself to guarantee
long-term survival of marbled murrelets in this Zone. On the other hand, a
considerable amount of habitat is preserved in parks such that survival may be
more likely in this Zone than in several other Zones. Private lands at the
southern end of this Zone are important for maintaining the current distribution of
the species. There is already a considerable gap in distribution between
this area and the central California population in Zone 6. Efforts should be
implemented to, at a minimum, not expand the current distribution gap."
A key sentence later on Appendices - 205 under "2. Delineate and protect
areas of habitat within each Zone. 2.1 Protect terrestrial habitat essential for
marbled murrelet recovery" says, "Marbled murrelet population trends described
above (also see Appendix B) have led the U.S. Fish and Wildlife Service to
conclude that a number of areas, including nesting areas and feeding sites
well-distributed throughout its terrestrial and marine range, are essential to
the conservation of the species."
I shall now quote "3.1.1.2 Maintain potential and suitable habitat in larger
contiguous blocks while maintaining current north/south and east/west
distribution of nesting habitat." "By maintaining occupied sites and
suitable habitat in larger blocks with low levels of fragmentation, several
objectives will be met. Larger stands will (1) have more nesting and hiding
opportunities, (2) provide for multiple alternative nesting sites for individual pairs
of birds over time, (3) facilitate nesting for multiple pairs of birds (and
thus promote increased social contact), and (4) provide greater interior forest
habitat conditions (to reduce potential nest and adult predation, increase
protection of nests from windstorms and environmental changes, and
reduce loss of habitat from windthrow and fire). Larger stands also may
provide a core of birds to attract or develop sufficient activity and eventual
nesting by subadults or nonbreeding adult birds to replace breeding adults lost
from this habitat over time due to natural causes or human activities. The more
contiguous the habitat distribution, the lower the likelihood of future
large gaps in distribution of the species due to catastrophic events such as
oil spills or large wildfires. Preventing further erosion of the already
patchily-distributed nesting habitat is a key element in buffering the
species against such catastrophic events. This is especially important in
areas where gaps already occur. Furthermore, it is currently unknown how
nesting success differs with distance from the coast, and far inland habitat may
be as important to species survival as those nearer the shore. Therefore, it is
important to maintain both north/south and east/west distribution of suitable
habitat."
And finally, my last quote from this document, under "3.2.2 Improve Distribution
of Nesting Habitat", some key sentences read: "3.2.2.1 Improve and develop
north/south distribution of nesting habitat. Improving the distribution of
nesting habitat helps to buffer existing populations against poor breeding
success and catastrophic loss and probably facilitates gene flow among
separated populations. Three major gaps in existing habitat are particularly
apparent: (1) from the southern Olympic Peninsula in Washington to Tillamook in
northwestern Oregon; (2) between Patrick's Point and southern Humboldt Bay in
northern California (see Figure 1); and (3) throughout most of the Mendocino
Zone and the northern part of the Santa Cruz Mountains Zone (between
southern Humboldt County and central San Mateo County). These three
geographic gaps represent probable partial barriers to gene flow across
them." That paragraph also says, "Portions of the Mendocino Zone and
Santa Cruz Mountains Zone also contain blocks of unsuitable habitat that
probably naturally created small gaps in the murrelet's terrestrial range.
Again, loss of suitable habitat around these small natural gaps has greatly
widened them. These gaps have probably grown together and eliminated
suitable nesting habitat over a large section of their range."
************************************************************************************
I wanted to give some quotes from the document which makes it sound like
legal statutes require consideration of geographical and ecological distribution of
a species -- in this case the murrelet. Here is an important quote from page
100-101 of the DEIR/EA: "Primary constituent elements of the designated critical
habitat for the Marbled Murrelet consist of physical and biological features that
are essential to the conservation of the species within areas occupied by the
species at the time of listing that may require special management
considerations and protection. These include such factors as space for individual
and population growth and for normal behavior, food, water, air, light, minerals,
cover or shelter, sites for breeding and rearing of offspring, and habitats that are
protected from disturbance or are representative of the historic
geographical and ecological distribution of a species." Thus, this is where
concerns about murrelet north/south distribution comes into play, while the
Marbled Murrelet Conservation Zones are a good help in analyzing likelihood of
survival and recovery (or extirpation).
I want to point out that the DEIR/EA stated that USFWS designated critical
habitat for the MAMU of 5-24-96 including 39,958 acres in southern Humboldt
County including Richardson Grove State Park. There is also admission that,
"due to the sensitivity of the species, it was determined that the project 'May
Affect, and is likely to Adversely Affect' Marbled Murrelet." (pg. 103). Documents
relating to this project also admits that Richardson Grove is suitable nesting
habitat and that the South Fork Eel River is a migration corridor for the murrelet.
Seeing that there were inadequate considerations of opening the
canopy, damaging roots (including mid and longer-term impacts), and other
factors, it was improper to conclude that the project would not adversely impact
murrelet designated critical habitat. Both a quote which I think I included from
the WOPR, as well as personally hearing that state parks is looking at closing
picnic areas, campgrounds, and even parks on the North Coast if murrelet
population numbers continue to plummet -- thus, the corvid-proof trash
containers should occur without a damaging project prompting it!
The Natural Environment Study was incorrect in stating that the murrelet is a
"threatened" species for both the federal and state levels. It is actually listed as
state-endangered (as it says in another document). I find it telling that there is
mention of preventing root impacts under the single MAMU-related paragraph in
that study -- this indicates to me that there is concern among biologists that
larger redwoods will be negatively impacted which could seriously impact the
canopy, fire danger, vulnerability to natural disturbances, etc. due to the
proposed project in the Richardson Grove area. There is the ridiculous claim that
the noise and activity around tree removal and construction will be not much
more than background -- give us watt and decibel estimate numbers please!!
There is an admission that, "the temporary noise, night work, and activity
associated with project construction, is likely to disturb murrelets that are nesting
in the area." But then a lawyer apparently concluded that the project will not
adversely modify MAMU Critical Habitat. What time frame did that last
conclusion consider -- just the short-term?
2053. The Legislature further finds and declares that it is the policy of the state
that state agencies should not approve projects as proposed which would
jeopardize the continued existence of any endangered species or threatened
species or result in the destruction or adverse modification of habitat essential to
the continued existence of those species, if there are reasonable and prudent
alternatives available consistent with conserving the species or its habitat which
would prevent jeopardy.
2055. The Legislature further finds and declares that it is the policy of this state
that all state agencies, boards, and commissions shall seek to conserve
endangered species and threatened species and shall utilize their authority in
furtherance of the purposes of this chapter.
2061. 'Conserve,' 'conserving,' amd 'conservation' mean to use, and the use of,
all methods and procedures which are necessary to bring any endangered
species or threatened species to the point at which the measures provided
pursuant to this chapter are no longer necessary. These methods and
procedures include, but are not limited to, all activities associated with scientific
resources management, such as research, census, law enforcement, habitat
acquisition, restoration and maintenance, propagation, live trapping, and
transplantation, and, in the extraordinary case where population pressures within
a given ecosystem cannot be otherwise relieved, may include regulated taking."
****************************************************************************************
Page VII.6.6-75 of the Jackson Demonstration State Forest Draft Management
Plan told of researchers C.J. Ralph and Miller's findings that "the most important
factor in indicating occupied stands was density of old-growth canopy cover" --
still referring to the murrelet obviously.
The 1997 Marbled Murrelet Recovery Plan at page 119 says, "To fulfill the
initial objective of stabilizing population size, this recovery plan focuses on
protecting adequate nesting habitat by maintaining and protecting occupied
habitat and minimizing the loss of unoccupied but suitable habitat". That same
MM Recovery Plan on page 121 said that short-term actions "are critical because
of the length of time necessary to develop most new nesting habitat (100-200
years). ... Short-term actions include: (1) maintaining occupied habitat; (2)
maintaining large blocks of suitable habitat; (3) maintaining and enhancing buffer
habitat...."
In relation to the three paragraphs above and some other Marbled Murrelet
points made and questions asked in these scoping comments, even if corvids
feeding on human food scraps at campgrounds and in truck stop / areas with
stores in the Richardson Grove area results in no current Marbled Murrelet
nesting in the fairly immediate Highway 101 area, yet still the Richardson Grove
so-called "re-alignment" should not negatively impact what biologists call "short-
term actions" which are needed to protect murrelet habitat. Please examine how
each of the offered alternatives (including the "No Action Alternative") impact the
important short-term actions which are summarized as "maintaining occupied
habitat" -- I would add occasional habitat rather than just current nesting habitat
-- plus "maintaining large blocks of suitable habitat" and "maintaining and
enhancing buffer habitat."
*******************************************************************
CALTRANS PROCESS, PRESSURE, ECONOMICS, AND GROWTH
Who paid for the one study (Cambridge Systematics, Inc. 2003) which claimed
that local residents pay 10 to 15% more for goods due to "poor truck access"
which was said to increase the decline in locally-owned business out of Humboldt
County?
It appears that Caltrans (and likely the FHWA and powerful elements of the
business community) has been laying the groundwork for the Highway 101
widening / re-alignment at Richardson Grove since perhaps around 2002. In
future environmental impact documents, please include all Caltrans
correspondence with government agencies and the business community
regarding the highway project in the Richardson Grove area.
I note that Cambridge Systematics, Inc. apparently got hired and wrote a report
entitled "Transportation for Economic Development". This same company has
also done a study and report in regards to expanding the 710 Long Beach
Freeway whose southern end is around the giant Ports of Long Beach and Los
Angeles. Does this group focus on advising how to expand port and
transportation infrastructure to help major commercial interests move goods, or
what would you say is their focus?
It is claimed that, "Several businesses, including lumber, floral, food, and other
manufacturing, as well as the local newspaper, have noted higher costs and
have considered relocating out of the County." Companies like Maxxam / Pacific
Lumber has essentially liquidated their forests, taken the proceeds out of the
county, and have declared bankruptcy. Timberland areas and floral farms have
their land (with the floral farm being raided due to hiring a lot of illegal workers
since apparently the boss did not even want to pay the already pretty low wages
paid to legal workers in Humboldt County, so it is difficult for them to pick up and
go. A local newspaper relocating is almost a contradiction in terms, and if they
did and remained sort of a local newspaper, would they print the paper
elsewhere and truck copies into the Humboldt Bay area in STAA trucks?
Besides the alleged economic boom for larger companies, did Dr. Gallo, CS
Inc., or anyone else study what the impact of "opening the Redwood Curtain" at
Richardson Grove means for tourist businesses, other smaller businesses, basic
wages, and trucker wages in Humboldt County? Also, in my 6-5-08 scoping
comments, I specifically asked about companies and personnel in the locales
where some trucks are reloaded so as not to bring STAA trucks along Highway
101 at the Eel River Canyon and through Richardson Grove. I saw no response
to this query or mention of the issue. Here is what was numbered point # 24 in
my scoping comments of 6-5-08: 24. I notice that there are nine companies
mentioned on this URL
<http://www.dot.ca.gov/hq/traffops/trucks/routes/eureka.htm>http://www.dot.ca.g
ov/hq/traffops/trucks/routes/eureka.htm which geographically range from
Petaluma to Crescent City to Redding who are "Companies for Hire" in order to
reach Eureka legally. What will the economic impact be on these companies if
the proposed project on Highway 101 in the vicinity of Richardson Grove is
carried out? Also, what will the impact of this highway project be (in post-
construction phase) on the employment rate and economy of Leggett, California?
Note that even your document admitted a "psychological" effect from further
widening of Highway 101 by Richardson Grove. Is this effect included in your
analysis in regards to potential growth impacts resulting from the project near the
Grove? Do you know of any advertising campaigns in the works to get investors
and companies to focus on economic development in Humboldt County?
Note: The effect of the highway project in the Richardson Grove area on
"scenery" should be evaluated for drivers, vehicle passengers, bicyclists, hikers,
others visiting or passing through the area by whatever means, as well as for
local residents, those in rehabilitation at Singing Tree, those who work in the
immediate or general area doing whatever task including store employees, law
enforcement personnel, highway workers, and state park employees.
There needs to be a thorough analysis of the effects of the various alternatives
on not only temperature and sedimentation in the Eel River, but also in the
tributary streams including in the Richardson Grove area and the area to its
north. How might each of the alternatives impact the slope stability situation not
far north of where much of the hillside removal and shoulder creation work is
projected to occur -- seeing that a large storm, seismic
disturbance, and/or further highway or slope deterioration there could result in
more catastrophic collapse and clearly impact both sedimentation and water
temperature in the South Fork Eel River.
The document says that stumps (I imagine from the mid-size and larger trees
to be cut) would remain in place. While this would be better for redwood tree
roots than uprooting the stumps, but it is a serious visual blight for park visitors
and for those travelling through the Grove along the highway as well -- this
deterioration of an Outstandingly Remarkable Value must be carefully assessed.
********************************************************************************************
**********
While clearly I have focused this comment more on the Marbled Murrelet than
other species, but I wanted to make several points regarding the Northern
Spotted Owl. In various parts of the DEIR/EA and BA, I read that there was a
NSO nest a quarter mile to the north of the project, that there was no known NSO
nest within a quarter mile of the project site, and that the nest to the north is a
half mile away. Please get clear and share the correct info on such. Since the
NSO is to the north of the project, removing many trees in its foraging territory
between the stand to the north (which I imagine may have some remnant large
conifer trees) and the ancient stand at Richardson Grove State Park would hurt
NSO foraging habitat. Also, night-work with bright lights would illuminate the
ground which might discourage some rodents from their usual activities and thus
not be available for consumption by the NSO. Have there been any studies
whether opening up canopy more can encourage barred owls to become more
established in the vicinity?
Also, impacts to the NSO must be evaluated not only in the local region, but
also in regards to indirect and cumulative impacts if allowing STAA truck
movement would encourage a rash of additional extractive activities which could
have deleterious effects on NSO habitat.
********************************************************************************************
**********
What fill dirt will be used to raise the roadway several feet for at least one of
the proposed areas for realignment, what will the source of the fill dirt be, what
toxic materials may be present in the fill dirt, and what non-native plant species
seeds may be in the fill dirt or on tires of construction vehicles, and might this
promote non-native plants and an increase in the use of herbicides in the
vicinity? Will the fill dirt to raise the elevation of the road interfere with the root-
structure of the forest or interfere with the "A horizon" (top layer of soil) since
what was the "A horizon" will no longer be the top layer of soil? Also, due to
plans of shaving some hillsides and building a major retaining wall, will this
increase use of herbicides on highway shoulder(s) north of Richardson Grove
State Park?
One serious drawback of the DEIR/EA and BA is the almost absent section and
analysis on hazardous waste/materials. From my reading, only the striping paint
with lead, plus the lead deposited on vegetation from vehicles, were mentioned
under this heading. Besides including immediately below my wording from my 6-
5-08 scoping comments, I wanted to also ask what CTPB is made out of and
what its contaminants are. Would allowing more permeability through this
substance lead to more toxic material reaching the roots of redwood trees
including to mycorrhizal fungi? Also, what are the exact components and
contaminants in "soil binders" and "dust palliatives"? So, please list all
substances contained in CTPB and in hot asphalt mix as well.
"Hazardous waste" is the first bullet point under "studies have been conducted
in the following areas" in the Caltrans brochure. I urge you to call that
"hazardous materials" rather than waste, since some might claim that if one uses
a hazardous material as part of normal operation that it is being used and thus is
not a waste. I am partly referring here to Caltrans' historic prolific use of toxic
herbicides. If the "shoulder area" is expanded at least in portions of the
Richardson Grove State Park and its vicinity along Highway 101, will it bring
about an increase (or any) herbicide use in these specific areas? If so, list all
active and inert ingredients in each formulation which may be used, the
synergistic impact of these ingredients mixed together, and the impact of these
on human health and on native salmonid species. We also need more info on
why certain disposal sites were chosen related to this project, and what the
likelihood is of sediments and other materials from the project entering the South
Fork Eel River.
It is disturbing that page iii of the DEIR/EA says that, "the Department will
confirm the proposed build alternative". I believe that will be the case -- however,
one is supposed to be considering submitted evidence rather than just rubber-
stamping what Caltrans is under pressure to approve.
********************************************************************************************
**********
Here is an important quote from page 100-101 of the DEIR/EA: "Primary
constituent elements of the designated critical habitat for the Marbled Murrelet
consist of physical and biological features that are essential to the conservation
of the species within areas occupied by the species at the time of listing that may
require special management considerations and protection. These include such
factors as space for individual and population growth and for normal behavior,
food, water, air, light, minerals, cover or shelter, sites for breeding and rearing of
offspring, and habitats that are protected from disturbance or are
representative of the historic geographical and ecological distribution of a
species." Thus, this is where concerns about murrelet north/south distribution
comes into play, while the Marbled Murrelet Conservation Zones are a good help
in analyzing likelihood of survival and recovery (or extirpation).
Sincerely yours,
Bruce Campbell
Attached in PDF and in U.S. mail is a cover page and several key pages from the
Draft Environmental Impact Report for the Draft Jackson Demonstration State
Forest Management Plan SCH# 2004022025 discussing murrelet populations,
Marbled Murrelet Conservation Zones, and the probability of extirpation of the
murrelet south of the Humboldt / Mendocino County line