State Senator Pat Wiggins
710 E Street
Eureka CA 95501

Re: DEIR on proposed Highway 101 Corrider Project

Dear Senator Wiggins:

I am writing to urge your opposition to CalTrans' proposed construction on Highway 101 between Eureka and Arcata. My comments below are based on their Draft Environmental Impact Report because I believe our first legal step is to point out its shortcomings.

What is more important than the DEIR's shortcomings is CalTrans' apparent unwillingness even to consider mass transit, a bike trial, interurban rail, and protection of the 101 corridor from inevitable future flooding.

I hope you will urge CalTrans to open its consideration to include these options, and I would welcome any suggestions you have to influence their decisions.

The least environmental damaging options are not considered in the DEIR
The DEIR's alternatives do not include any mass transit or bike alternatives, even though such alternatives are supposed to be part of CalTrans' mandate. That the DEIR fails to consider mass transit and bike trails is its major flaw. The alternatives that were selected are far too narrow in their vision to cope with conditions of the 21st Century.
District 1 Director Fielder told me they considered mass transit in 2002 but rejected it as too expensive ($90 million, he and the DEIR say), but no basis for that number can be found. CalTrans staff also said the goal of the DEIR is to select the least environmental damaging alternative, but least damaging alternative (mass transit and bike trails) was ignored before the DEIR was even written.

The DEIR should include mass transit and bicycling alternatives that include: upgrading rail right-of-way to make it serviceable (and, incidentally, to provide levee or dike protection from expected increased storm frequency and intensity) and a functional bike path off the highway on either the west or east side of 101.

Estimates of vehicle trips are presented without any analysis or justification, and the estimates ignored some obvious future trends
The DEIR on page 6 asserts CalTrans' expectation that vehicle trips will increase by 50% by the year 2031, but no basis is provided for this estimate. Indeed, this is the basis upon which justification for everything in the EIR depends. By 2031, it is certain that fuel prices will be much higher, and many people will accommodate that eventuality by taking mass transit or riding bicycles. But they can only do so if mass transit and real bike trails are available.

As a practical matter, what drivers will note on the 101 corridor if traffic travels at 65 mph is a decreased driving time between Eureka and Arcata, and the DEIR fails to note that the difference is only one minute.

Estimates of fuel consumption are flawed
The DEIR notes on page 104 the increased fuel consumption and vehicle miles for Alternatives 1 and 2, but asserts that by 2031 Alternative 3 will reduce fuel consumption that is due to out-of-direction travel. However, it fails to present the increased fuel consumption all three construction alternatives will incur compared to bicycle and rapid transit, under which scenario fewer vehicle trips will be taken.

Moreover, by assuming a constant energy usage per vehicle mile traveled (6229 Btu/mile-day), the DEIR ignores the fact that vehicles utilize more fuel traveling at higher speeds such as 65 mph rather than 50 as they would in the no build alternative (and do now).

To assert that the construction alternatives contribute to a "temporary, one-time increase in energy" (page 252) is incorrect; the increase continues forever, both with respect to no construction and to the unevaluated mass transit alternative, once the construction alternatives have been implemented.

Unstated in the DEIR is the obvious conclusion that fuel consumption would be much less than the estimates presented, if mass transit and bike trail options had been considered.

The DEIR ignores California State policy to reduce greenhouse gas emissions
Moreover, in the year 2007, it is irresponsible and contrary to California State policy not to consider greenhouse gas emissions resulting from the four DEIR alternatives, when the mass transit and bike path alternative would emit far less of such emissions.

The DEIR's safety projections ignore or project incorrectly effects on adjoining roads
The DEIR takes no real account of the danger from increased traffic on Old Arcata Road as a result of the build alternatives, by claiming that the City of Eureka is going to upgrade the road, somewhere, sometime. The current level of traffic already makes this narrow road dangerous. Median closures on 101 will make it more so.

With respect to safety, the current 50 mph speed limit has evidently reduced the frequency and severity of accidents in the corridor. If properly evaluated, the no-build alternative should take account of the safety that now being experienced. For the DEIR to claim that this safety zone cannot or should not be continued is irresponsible.

At the bottom of page 218 and the top of page 219, the DEIR ignores what was the stated environmental objective by a cute, illogical twist of semantics, thereby also ignoring the wasteful nature of fuel consumption for all three alternatives--four, counting the no-build alternative. All four DEIR alternatives will waste, given the possibility of a better choice, vastly more energy than one enabling mass transit and bicycle potential in the Eureka-Arcata corridor.

The safety evaluation is both flawed for autos and non-existent for bicycles
The DEIR asserts that the current traffic patterns will become as dangerous as they were before the 50 mph speed limit was imposed, which is only true if speeds do increase. With proper enforcement, speed will continue to be reasonable, and the main reason stated for the three build alternatives is fallacious.

However, any cyclist will agree that the present bicycle route between Arcata and Eureka is dangerous, by virtue of the proximity of fast-moving traffic and bicyclists, even with the current 50 mph speed limit. It is only a matter of time until a cyclist is killed, and at least one has already been injured. Therefore, even the no-build alternative (DEIR Alternative 4) is dangerous.

The DEIR reaches the depth of hypocrisy on page 186, in advocating the removal of Eucalyptus trees because fallen limbs are a danger to cyclists, when at the same time it ignores the dangers to them from the high-speed traffic that all four DEIR alternatives promote. The way to eliminate these dangers is to build a separate bike trail.

Future storm damage to the 101 corridor is ignored
While claiming foresight through the year 2031, the DEIR does not consider future closings of 101 because of increases in storm frequency and intensity, which will flood the highway as storms did two winters ago. As the climate changes, this flooding is virtually certain, and an improved levee will eventually be required on the west side of the freeway. Of all California's coastal highways, this is one of the lowest and longest and therefore most at risk from damage resulting from higher sea levels and more violent storms. That certain risk of loss would be easy to mitigate with a proper levee. This levee would necessarily be large enough to support an improved rail roadbed and a bike trail.

There is certainly room for a separate bicycle trail on one side or the other of 101. Very likely NCRA cooperation will be necessary on the bay side of 101, but CalTrans could certainly install one on the east side at minimal cost; indeed, that should be one alternative that the DEIR evaluates.

Thank you for the opportunity to present my views, and I look forward to your response.

Sincerely,
John Schaefer, PhD