Under the leadership of Lupe Gutierrez, community member and candidate for Del Norte County, California District 3 Supervisor, we—the undersigned community members, property owners, taxpayers, and voters of Del Norte County, along with concerned citizens from a wider community— respectfully submit this formal request for the establishment of a public comment period regarding the 197/199 Safe STAA Access Project (SCH#2008082128).

This request is based on the following concerns:

·       The public has not been provided an opportunity to comment on this project since 2010.

·       Over the past 16 years, there has been significant turnover in the community, including property sales and the passing of long-time residents. Many current property owners and residents have not had the opportunity to review or comment on this project.

·       The proposed plan does not adequately analyze or address potential community impacts, including property devaluation, reduced marketability, and overall quality of life concerns.

·       The proposed plan did not adequately study noise impact on the community and failed to conduct adequate public consensus.  Nor does it include adequate feasible and reasonable noise abatement studies, raising concerns about compliance with the California Environmental Quality Act (CEQA). Additionally, no comprehensive analysis of post-construction noise impacts to the community has been conducted.

·       If federally funded, the project must comply with Federal Highway Administration (FHWA) noise regulations, which appear not to have been fully addressed. 

·       The devastating Smith River Complex fire of 2023 which significantly changed the landscape and lives of the communities of the proposed project area. This burn scar surrounds the proposed construction sites and has not yet been sufficiently treated by land management. The steep sloped woodlands above your proposed construction sites are mostly-burnt standing dead timber, which has significantly changed the hydrology directly above your proposed blast sites. The increased risks of severe landslides are significant and the proposed plan of blast removal of extreme amounts of rock below the dead untreated burn scar will contribute to a significant increase in instability and danger to both environmental and public safety.

·       The project proposes roadway widening and curve modifications that may impact the root systems of mature and old-growth redwood trees along Highway 197. The environmental review does not adequately assess these impacts, which could result in significant and unmitigated harm.

·       The project area contains ophiolite formations known to include elevated levels of toxic heavy metals. The current plan does not include sufficient geological or environmental analysis regarding the potential release and impact of these materials on wildlife, the Wild and Scenic Smith River, construction workers, or the public.

·       A 2022 incident involving the overturning of a chemical transport truck resulted in the release of over 2,000 gallons of hot asphalt binder into the Wild and Scenic Smith River. The proposed project would increase access for similar transport vehicles, thereby increasing the risk of future environmental hazards.

·       The project does not adequately evaluate alternative safety measures to influence driver behavior including:

o   Implementation or studies of automated speed enforcement under California SB 720;

o   Installation and studies of additional warning signage;

o   And, reduction of speed limits in high-risk areas.

Based on these concerns, it is our position that the current proposal does not sufficiently evaluate the potential impacts on the Wild and Scenic Smith River, the surrounding community, or public safety.

While we all share the goal of improving roadway safety, our community is united in one clear and reasonable request: the establishment of a formal public comment period.

Contact Information for Lupe Gutierrez:
Phone: 707-357-1223
Email: lcg4270@gmail.com

Thank you for your time and consideration.

Sincerely,