Diane Higgins

4649 Aster Ave

McKinleyville, CA 95519

Deborah Harmon, Senior Environmental Planner

CA Department of Transportation
1656 Union Street
Eureka, CA 95501
Via E-mail to Kim_Floyd@dot.ca.gov

January 30, 2009

Ms Harmon:

Regarding the Richardson Grove Operational Improvement Project Draft Environmental

Impact Report/ Environmental Assessment and Programmatic Section 4 (f) Evaluation:

I am concerned that the Draft EIR for the proposed Richardson Grove Operational
Improvement project is deficient in several respects.

The analysis of Project’s potential to induce growth is inadequate and appears to be

biased. The DEIR states that

“Opening US Route101 in southern Humboldt County to STAA

trucks could have a positive impact on the attractiveness of
Humboldt County, and to a lesser extent, Del Norte County to
potential investors.”

However, there is no analysis of the type of growth that would ensue. Would the likely
outcome of this investment be increased growth in Humboldt County? Would these
investors build new shopping malls, new housing tacks, new industry? The DEIR fails to
address this question.

The DEIR relies upon economic evaluations and predictions from an undefined sub-set of
the business community

“More specifically, representatives of the business community in

Humboldt County have indicated that the lack of STAA truck
access is a disadvantage to doing business.”

“Representatives of the business community” is a vague entity. What percentage of

Humboldt County businesses do these representative represent? Was this information
gathered using statistically valid survey methods? What businesses, specifically, are
disadvantaged by the lack of STAA trucks? What businesses will be harmed by the
Diane Higgins 1/30/09

Project through increased traffic and alterations to the physical characteristics of

Richardson Grove?

The DEIR bases its assumptions about economic impacts and growth on the Gallo, 2008
report: Realigning Highway 101 at Richardson Grove: The Economic
Impact on Humboldt and Del Norte Counties. The report is not included
in the DEIR appendices, nor does the DEIR state where to access this
report. It does not appear to be available on the Internet. The public
should be able to readily access and review this study, and to see
comments by peer reviewers. Was the study peer reviewed?

The Project would open the Highway 101 corridor to increased traffic, not only to
Humboldt County, but to Del Norte County and points north. However, the DEIR
considers only the potential for increased truck traffic to Humboldt County, and does not
consider increased truck traffic through the county. It is very likely that the number of
trucks driving through Humboldt County would increase once the “bottleneck” at
Richardson Grove is eliminated. This would bring increased air pollution, noise and
congestion to the portions of Hwy 101 in Humboldt County, including the City of
Eureka, where the highway is the main north-south thoroughfare. By ignoring the
potential impacts of increased through-traffic, the DEIR analysis has taken a piecemeal
approach. The cumulative increase in traffic, noise and pollution brought by all the new
traffic should have been evaluated. The DEIR is deficient in this regard.

State Highway Code 887.8(b) states that:

"Where the traffic safety or capacity of the highway would be increased, the
department shall pay for the construction and maintenance of non-motorized
transportation facilities approximately paralleling the highway."

The proposed project does not include provisions for bicycle or pedestrian facilities. The
DEIR does not address this issue.

The DEIR does not consider the viable alternative of transporting goods by short sea
shipping. This alternative would eliminate the need for the Project and save the public
money, while reducing fuel consumption, pollution, noise and congestion. Humboldt Bay
is ready receive ships now. (See article in the Eureka Times Standard http://www.times-
standard.com/localnews/ci_11078314 ).

The DEIR was informed by surveys (cited above) about potential impacts to the economy
and growth. Did these surveys include questions about using short sea shipping? Lack of
consideration of this alternative is a serious omission.

Diane Higgins
4649 Aster Avenue
McKinleyville, CA 95519