Friday, November 29, 2007
To the editor -

Your editorial criticizing Marin County supervisors for supporting Novato’s challenge to the North Coast Railroad Authority (NCRA) contained some egregious factual errors.

It stated that with regard to the track north of Willits, “there's (sic) no plans to use the tracks anytime in the near future.” Au contraire. There are indeed such plans, or at least that’s what the NCRA is telling us up here at the other end of the line, where we keep hearing about startup dates in 2009 or 2010. And a central point of Novato’s lawsuit – which my organization supports as well – is that CEQA forbids public bodies like the NCRA breaking up their environmental analyses into little bites to avoid consideration of the cumulative impacts of large projects. NCRA is trying to dodge disclosure requirements to keep their gravy train of public funding running.

SMART is looking out 20 years in preparing its supplemental EIR. In this time frame, the proposed restarting of freight service to Eureka is not at all speculative, particularly in light of the signed agreement the NCRA has with the Humboldt Bay Harbor District.

Your editorial stated that if the NCRA did make it to Eureka, this would involve “as many as three roundtrips per day of up to 60 cars each.” That’s incorrect. According to a June 19 letter from NCRA to SMART, that’s the number of trains associated with operations limited to south of Willits. According to a feasibility study just released by the Humboldt Bay Harbor District, each “container ship that discharges and loads all its cargo at Humboldt Bay (3,000 import and 3,000 export containers) would generate 24 unit trains (12 import trains and 12 export trains assuming 250 containers per unit train).”

One can only speculate regarding how many total trains would operate out of Eureka, but NCRA Executive Director Stogner has cited 16 trains per day as being the maximum number the NCRA could operate on the single track through Sonoma and Marin counties. This is the number of trains that we hope the court will require the NCRA to evaluate. CEQA is about disclosure. Your editorial board seems to take the view the public doesn’t need to know what’s coming its way.

Sincerely,

Scott Greacen
Executive Director
EPIC – the environmental protection information center
POB 147 Eureka California
707-822-7711