July 12, 2020

Mr. Kirk Skierski,

Deputy Director of Planning Department
Siskiyou County
806 South Main Street (Email: planning@co.siskiyou.ca.us)
Yreka, CA 96097

Re: Initial Study/Mitigated Negative Declaration for Southern Oregon Ready Mix Project

Dear Mr. Skierski:

Thank you for the opportunity to comment on the IS/MND for the Southern Oregon Ready Mix
Project (RMP). I am a past Board member and President of the Volcanic Legacy Community
Partnership (VLCP) from 2009 to 2020. The VLCP is a 501(c)3 nonprofit corporation, formed in
2003, to promote the 500-mile Volcanic Legacy Scenic Byway (VLSB). The byway received federal
designation as a National Scenic Byway and All American Road in 1997 (Oregon section) and 2002
(California section). It is one of only 31 All American Roads in the United States with this
distinction. This magnificent scenic drive winds its way from Crater Lake National Park in Oregon,
through Lava Beds National Monument to Lassen Volcanic National Park and Lake Almanor in
northeastern California.

To receive an All American Road designation, a highway must possess multiple intrinsic qualities
that are nationally significant and contain one-of-a-kind features that do not exist elsewhere. The
road or highway must also be considered a “destination unto itself.” That is, it must provide an
exceptional traveling experience so recognized by travelers that they would make a drive along the
highway a primary reason for their trip (Federal Register, May 18, 1995). The VLSB achieved
national recognition because it met all six required “intrinsic qualities” for National Scenic Byway
All American Road designation. These qualities include scenic, natural, cultural, historic,
recreational, and archaeological. In the Mount Shasta area, the VLSB follows Interstate 5 (I-5) from
State Route 89 near Mt. Shasta City to State Route (SR) 97 in Weed. This area has some of the
most impressive geologic features along the byway—Black Butte, the Mount Shasta volcanoes to
the east, and the high lakes country around Mt. Eddy to the west. Outdoor recreation and tourism
are significant economic drivers in Mt. Shasta City.

The National Scenic Byways Program is administered by the Federal Highway Administration under
policy issued in the Federal Register, May 18, 1995. This policy states: “Any road nominated for
the National Scenic Byway or All-American Road designation will be considered to be a designated
State scenic byway.” Upon federal designation as a National Scenic Byway All American Road in
2002, the VLSB also became a designated California Scenic Highway. The Federal Register also
clarified: “Moreover, the terms State Scenic Byway, National Scenic Byway, or All American Road
refer not only to the road or highway itself but also to the corridor through which it passes.” In the
Federal Register, “Corridor means the road or highway right-of-way and the adjacent area that is
visible from and extending along the highway. The distance the corridor extends from the highway
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could vary with the different intrinsic qualities.”

The VLSB in California falls under the California Streets and Highways Code, Chapter 2, Division 1,
Section 260 which states: “It is the intent of the Legislature in designating certain portions of the
state highway system as state scenic highways to establish the State's responsibility for the
protection and enhancement of California's natural scenic beauty by identifying those portions of
the state highway system which, together with the adjacent scenic corridors, require special scenic
conservation treatment.

263. The state scenic highway system is hereby established and shall be composed of the highways
specified in this article. The highways listed in Sections 263.1 to 263.8, inclusive, are either eligible
for designation as state scenic highways or have been so designated.

263.3. The state scenic highway system shall also include:

Route 5 from:
(f) Route 89 near Mt. Shasta to Route 97 near Weed.”

After reviewing the IS/MND, I find the analysis regarding the impact on byway’s scenic corridor to
be incomplete relative to the above codes. I am also concerned this project is being implemented
prior to the completion of CEQA. My specific comments are:

1. The IS/MND mistakenly declares I-5 is not an officially-designated scenic highway. The VLSB
is a National Scenic Byway All American Road and a CA Scenic Highway.

Remedy: Please amend IS/MND, Section 4.0, Aesthetics, to incorporate this information.

2. The proposed RMP is situated on the southwest flank of Mount Shasta, and the south flank
of Black Butte. It is directly adjacent to I-5 where much of it will be prominently visible.
Moreover, the RMP will be visible to northbound motorists within the immediate
foreground of a scenic view of Mount Shasta, one of the most iconic volcanoes in California
and the Cascade Range. It will also be entirely visible along Springhill Drive, a public road.

Remedy: The RMP is a stark contrast from the scenic vistas visitors expect to see here. The
County’s conclusion that there is “No Impact” on scenic resources (p. 4-3) and that impact
on the existing visual character is “Less than Significant” (p. 4-4) is not supported by the
analysis. Please provide a visual simulation analysis to validate your conclusions. Some
CEQA documents apply quantitative simulation models using measures for visual classes,
size and scale, viewer sensitivity, distance zones, landform contrast, etc. However, these
measures are no substitute for how people actually feel about visual intrusions. The
impact on visual quality is a highly personal valuation. A good visual simulation model
would also survey the people who live around Mt. Shasta and those who visit with the

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 expectation of seeing views worthy of the byway’s designation. Ultimately, it is people’s
perception of what constitutes a visual impact. I believe the proposed project falls in the
“potentially significant” category.

3. The California Streets and Highways Code, Section 261, provides guidance for the
protection of scenic highways and their adjacent corridors. “In the development of official
scenic highways, the department shall give special attention both to the impact of the
highway on the landscape and to the highway's visual appearance. The standards for
official scenic highways shall also require that local governmental agencies have taken such
action as may be necessary to protect the scenic appearance of the scenic corridor, the
band of land generally adjacent to the highway right-of-way, including, but not limited to,
(1) regulation of land use and intensity (density) of development;  (2) detailed land and site
planning;  (3) control of outdoor advertising;  (4) careful attention to and control of
earthmoving and landscaping;  and (5) the design and appearance of structures and
equipment.”

The IS/MND says “The County General Plan does not include any polices for the protection
of views or identify any view sheds, or scenic vistas that should be protected” (p. 4-3). This
is incorrect. I’ve attached the County’s General Plan Scenic Highways Element (adopted in
1975) which identifies I-5 from SR 89 south of Mt. Shasta to SR 97 in Weed as a Scenic
Freeway. The General Plan Scenic Highways Element states: “The Scenic Route Element is
intended to provide for the preservation of scenic highways for the enjoyment of the
general public . . .” (p. 2). It further states: Scenic Corridors are areas that extend beyond
the Scenic Route right-of-way to which development controls should be applied for
purposes of preserving and enhancing nearby views or maintaining unobstructed distant
views along the scenic routes” (p. 5). “Widths of Scenic Corridors may vary from the depths
of adjacent lots in urban areas to one or more miles in agricultural and forest lands. Within
these corridors, controls should be developed to restrict unsightly use of the land, control
height of the structures, control signs and billboards, and provide site and architectural
guidance along the entire Scenic Corridor” (pp. 5-6).

Remedy: The IS/MND concludes: “The Proposed Project is not located within the vicinity of
an officially designated scenic highway. No impact would occur” (p. 4-3). This finding is not
substantiated by the analysis. Please cite State code and the County Scenic Highways
Element as policy for the I-5 scenic corridor. Describe how the RMP achieves the
“Objectives” in the County’s Scenic Highways Element on page 7 and is consistent with the
management “Principles” (pp.10-12) and the “Minimum Standards” (pp. 13-16).

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 4. No mitigation measures were required for Section 4.1 Aesthetics since no significant visual
impacts were identified (p. 4-5).

Remedy: Corrections to the previous items in the IS/MND and a more in-depth discussion
of visual impacts should reveal appropriate mitigation measures to best screen the RMP
site.

5. It appears clearing and grading of the site has already occurred prior to completion of
CEQA and the County’s approval for rezoning and authorization to proceed.

Remedy: Please explain how this occurred as it shows a lack of intent by the proponent to
conform to county policies and CEQA.

There is a reason the RMP site was zoned for agricultural and not industrial uses. It undoubtedly
had to do with the scenic nature of prominent views of Mount Shasta and Black Butte from I-5,
which was constructed before the County adopted its zoning ordinance. It also is because the City
of Mt. Shasta has many other acres of vacant industrial land. It does not need more industry to be
located where it would adversely affect the scenic views that are renown here.

Summary Request: CEQA requires Siskiyou County to correctly assess the aesthetic impacts the
proposed project may create. The IS/MND fails to do that. An Environmental Impact Report must
be prepared in light of such inadequacies before this project is circulated for another round of
public review.

Please place my name on your mail list to receive future CEQA documents and other information
related to this project. Thank you.

Sincerely,
Elizabeth Norton
Elizabeth Norton
PO Box 1651
Susanville, CA 96130
530-251-7368
bobliz@live.com

Enclosure: Siskiyou County General Plan Scenic Highways Element