Dear Kim Floyd, Caltrans project manager:

Thank you for the opportunity to review and comment on the Eureka - Arcata Route 101 Corridor Improvement Project.

Wrong Problem

We believe the wrong problem is being studied. The purpose and need of this project is stated to be safety, traffic operating conditions, long-term roadway maintenance, and highway design standards. While all this is commendable, it is clear that a comprehensive, multimodal transportation solution would better meet the needs of the region.

We therefore believe the Draft EIR should be withdrawn, and a new one prepared that includes the integration of bicycle, rail, pedestrian trail, and bus rapid transit. While it has been suggested and generally agreed upon that such a project is desirable, to undertake it separately is inefficient, and all the suggested alternatives, include
Number 7, the No Build, would almost surely look different in such circumstances. Combining the two initiatives into a single project would provide for more a far more optimal solution, and could save many millions of dollars.

The same logic used to justify combining the Route 101 Corridor Safety Improvement project with the RRR work (page 30) applies to combining this with a Bike/Hike/Trail initiative. These include minimizing wetland impacts, simplifying coordination with public agencies, minimizing construction activities, achieving efficient traffic management during construction, achieving a higher degree of compliance with the Federal Highway Administration policy of setting logical project termini of sufficient length to address environmental matters in a broad scope, ensuring a higher degree of independent utility. All of these would be accomplished with a combined initiative.

Questionable Project Elements

So while we believe the EIR is fundamentally flawed in that it has the wrong purpose and need, the document as prepared has other problems. Many conclusions are reached using fuzzy logic and questionable data. Support for some conclusions are based on a number of value analysis studies that were done before the Safety Corridor was implemented, and now have questionable validity. Some of the more recent value analysis work appears to been done without adequate public participation, such as the 2005 Value Analysis which the EIR states was done entirely with Caltrans personnel. It is this study which attempts to justify the removal of numerous large trees within the nine-meter "clear recovery zone", despite the very high environmental impact that would result.

Because of this decision to combine the RRR project with the Route 101 Corridor Safety Improvement project, all three "build" alternatives include the RRR work. Many of the items listed under this portion of the project are easily justified, and have minor environmental impact. Three of these, however, differ in that their environmental impact is large, and the benefit cost ratio is questionable.

Specifically these are (with original numbering from pages 33-34 of the EIR)

1) Extend or establish the existing Route 101 right-side acceleration and deceleration lanes at the following intersection locations listed from south to north in
Table 2-1. The intersections are Cole Avenue, Mid-City Motor World, Simpson Sawmill, Indianola Cutoff, Bracut, and Bayside Cutoff.

These are not all equal in value or impact. In particular the proposal to establish acceleration and deceleration lanes for the Simpson Mill would necessitate the removal of approximately 300 mature eucalyptus trees. The amount of traffic entering and exiting this facility is small, and there is no record of an accident having ever occurred at this intersection. This item does not therefore appear environmentally justified. Even if the other acceleration and deceleration lanes are constructed, this one should be dropped from consideration.

2. Close all remaining Route 101 median crossings consisting of: Airport Road, Mid-City Motor World, Simpson Sawmill, Indianola Cutoff, Bracut, and Bayside Cutoff.

This item clearly cannot be supported as a "stand alone" item because of its economic impact. It is discussed as part of the Route 101 Corridor Safety Improvement project and is therefore out of place in this context.

11. Remove existing large trees within the corridor that are within the nine-meter (thirty feet) clear recovery zone.

The proposal to remove all trees within the clear recovery zone is not fully justified due to the resulting environmental damage. The EIR shows the partial removal of the eucalyptus tree row still has High Impact even after mitigation. While it is entirely possible for some trees to pose an excessive hazard and have their removal justified, the "all or nothing" approach suggested here is not satisfactory. We believe a tree-by-tree analysis will show that the eucalyptus trees should remain, and only selected trees on the east side pose a hazard.

Failure to Adequately Address All Feasible Alternatives

We have serious problems with the Alternatives Considered but Dropped from Further Consideration portion of this EIR (pages 42-45).

The logic used to drop alternatives 5 and 6, and PSR Alternative Y2 is vague, poorly documented, and laced with unsupported conjecture.

The traffic volumes predicted for Route 101 between Eureka and Arcata are not supported by either historic growth patterns, or projections by the California Department of Finance for population growth.

Simply stating that "Continual funding of additional enforcement would require an ongoing financial commitment by HCAOG, Caltrans Office of Traffic Safety Programs, the state Office of Traffic Safety, or the California Transportation Commission with funding approvals by the State Legislature in many instances" does not mean this cannot be done.

Most of the remaining arguments for dropping these alternatives from consideration are disingenuous. The argument set forth here that these alternatives do not meet Need and Purpose are speculative or based on unsubstantiated assertions.

Examples include (italics added) with brief comments:

"Left turn movements could result in a higher percentage of fatal plus injury accidents than the State average."

This is speculative.

"The slower posted speed limit ... result in operational conflicts."

No support for this assertion and it seems counter-intuitive.

"The LOS on Route 101 would degrade ...causing...greater driver frustration".

Frustration is not a problem unless it leads to dangerous behavior.

"Review of safety corridors across the state has show their effectiveness is short lived"

This is not necessarily applicable to this safety corridor. This one is of a short length and may have different effectiveness. Furthermore the safety corridor could be further improved. This is discussed in more depth later in this letter.

"If a long-term project were not implemented, median closure would likely still be necessary"

This is speculative.

What is also bothersome is that Alternative 5, Alternative 6, and PSR Alternative Y2 all appear to be clearly superior to Alternative 7, the No Build Alternative. We do not see how these three alternatives can be discarded in favor of one clearly inferior. All three of these alternatives are clearly feasible and should be further analyzed and reevaluated against the Purpose and Need.

Growth at Indianola

In Section 3.1.2 under Environmental Consequences it is suggested that the Construction of an Interchange at Indianola Cutoff "...it is not reasonably foreseeable that any of the project alternatives would likely induce substantial growth".

We strongly disagree with the arguments leading up to this conclusion. The EIR makes it clear that one of the major obstacles leading to the abandonment of proposals by Sam's Club, Costco, and Wal-Mart was caused by Traffic Mitigation costs associated with the project. Construction of the Indianola Interchange removes most of this impediment.

Furthermore other arguments regarding economic growth happening in non-rural areas, zoning restrictions, and Coastal Development permits are not at all insurmountable. Common sense dictates construction of this interchange dramatically increases the likelihood of development of a large retail establishment at this location.

Safety Corridor

While mentioned earlier in the discussion of Alternatives 5 and 6, we would like to make further observations about the Safety Corridor.

In the discussion of the Safety Corridor on pages 114-117 it is mentioned other safety corridors in the state experienced increases in collision rates over time. This is used to infer that the same thing will happen with the Eureka - Arcata Safety Corridor. This argument is not compelling.

This safety corridor is short in length, and will become approximately one mile shorter if the signalization at Airport Road is accomplished. There is a high probability its short length reduces driver frustration and improves compliance. This possibility is not discussed.

No consideration is given to improving what is already a highly effective safety corridor so it functions even better and its effective life is extended. Additions such as overhead message boards, fully illuminating the speed limit signs to match the "your speed" readouts, flashing beacons at all five remaining unsignalized intersections, and "Enforced by CHP " signs on the "Please Turn on Headlights" signs as has been done on other safety corridors in the state are just a few examples of initiatives that could result in such improvements.

Realignment of the Southbound Lanes

Of all the problems with the EIR the one that gives the greatest concern is the impact on visual aesthetics of the proposed acceleration and deceleration lanes at the Simpson Mill, and resulting environmental damage to the scenic landscape. The row of eucalyptus trees are nearly 81 years old, and have an expected remaining life of many more years. They are considered a cultural landmark. They slow southbound traffic by an average of four miles per hour, and screen the Simpson Mill from view. The photo simulations in the EIR show clearly the magnitude of the impact of their removal would be immense.

The desired improvements to the clear recovery zone on the west side of the highway and acceleration/deceleration lanes for the Simpson Mill can be accomplished by moving the southbound Route 101 lanes toward the median. The logic to discard this option was questionable. Notions of problems with geometric alignments are not backed up with engineering data, and the argument about wetlands is not quantified and does not appear to be an overriding consideration. We do not believe the arguments put forth for not considering the realignment of the southbound lanes are adequate. This seems clearly feasible and should be further studied.

Sincerely yours,
Ron Kuhnel
Board Member
Keep Eureka Beautiful