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Re: NCRA/NWP WORKING ON RAILROAD SANTA ROSA
Author: Hipshot
Date: 07-03-2008 - 21:26
Fear has nothing to do with anything. At this time there is nothing to disclose. Literally, there is nothing to be said! That may make the EIR short and simple: “Dear Sir or Madam: Beats the hell out of us!”
The last qualified engineering study was done by Shannon & Wilson more than nine years ago and is now seriously out of date. From a purely technical perspective (the debate regarding the need for the railroad notwithstanding and political posturing aside), nobody knows what really needs to be done in the Eel River canyon to restore the railroad. Nobody has made an unbiased determination of a reasonable economic standard of rehabilitation. Is a sensible design goal an economic life of 5 years, 50 years or 500 years.
Without knowing what needs to be done, a meaningful cost estimate is impossible. Without knowing what needs to be done, one is being asked to determine the impacts on the environment of unknown actions of indefinite scope taken at nameless places at some unspecified time in the future. It is simply not possible to determine how to mitigate the effects of actions which are not knowable in either scope, time or space. The set of possible alternative actions becomes nearly infinite. Moreover, the well-intentioned -- but possibly uniformed -- musings of Board members regarding when they would like to reopen to Eureka are not sufficiently substantive to establish a predicate for reopening the North End. No public agency has the money to tackle such a Gordian task.
At some future date, a justification for reopening the North End may appear – or not. If and when such a justification appears, then the NCRA can determine if it will be part of the project. If they are, then CEQA must be followed. If NCRA chooses not to be part of the project, then the STB’s NEPA regulations apply. But for now, a few self-absorbed Marinites are trying to screw the shipping public on the south end by tying a regulatory tin can the NCRA’s tail in the form of an impossible hurdle: “Here, divide this by zero to ten decimal places.”
The last qualified engineering study was done by Shannon & Wilson more than nine years ago and is now seriously out of date. From a purely technical perspective (the debate regarding the need for the railroad notwithstanding and political posturing aside), nobody knows what really needs to be done in the Eel River canyon to restore the railroad. Nobody has made an unbiased determination of a reasonable economic standard of rehabilitation. Is a sensible design goal an economic life of 5 years, 50 years or 500 years.
Without knowing what needs to be done, a meaningful cost estimate is impossible. Without knowing what needs to be done, one is being asked to determine the impacts on the environment of unknown actions of indefinite scope taken at nameless places at some unspecified time in the future. It is simply not possible to determine how to mitigate the effects of actions which are not knowable in either scope, time or space. The set of possible alternative actions becomes nearly infinite. Moreover, the well-intentioned -- but possibly uniformed -- musings of Board members regarding when they would like to reopen to Eureka are not sufficiently substantive to establish a predicate for reopening the North End. No public agency has the money to tackle such a Gordian task.
At some future date, a justification for reopening the North End may appear – or not. If and when such a justification appears, then the NCRA can determine if it will be part of the project. If they are, then CEQA must be followed. If NCRA chooses not to be part of the project, then the STB’s NEPA regulations apply. But for now, a few self-absorbed Marinites are trying to screw the shipping public on the south end by tying a regulatory tin can the NCRA’s tail in the form of an impossible hurdle: “Here, divide this by zero to ten decimal places.”
