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VERIFIED PETITION for WRIT of MANDATE and INJUNCTIVE RELIEF; I COTCHETT, PITRE & Case No

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VERIFIED PETITION for WRIT of MANDATE and INJUNCTIVE RELIEF; I COTCHETT, PITRE & Case No 1 TABLE OF CONTENTS 2 Page 3 I. INTRODUCTION............................................................................................................. 1 4 II. PARTIES ........................................................................................................................... 6 5 A. PETITIONERS .......................................................................................................... 6 6 B. RESPONDENTS....................................................................................................... 11 7 III. JURISDICTION AND VENUE ..................................................................................... 11 8 9 IV. OUR RICHARDSON GROVE AND CALTRANS’ PLAN FOR ITS DESTRUCTION ............................................................................................................. 12 10 A. DRIVING THROUGH HISTORY .............................................................................. 12 11 ESTROYING UR EDWOODS 12 B. D O R ............................................................................ 13 13 C. THE GROVE IS THREATENED BY TRUCKS ........................................................... 15 14 D. CALTRANS FAILED TO PROPERLY PROVIDE FOR PUBLIC REVIEW .................... 19 15 E. CALTRANS’ DRAFT AND FINAL EIR WERE DEFICIENT ...................................... 21 16 F. CALTRANS HAS SINCE FAILED TO CORRECT ITS ERRORS IDENTIFIED BY THE 17 LOTUS COURT OR OTHERWISE ADDRESS THE SHORTCOMINGS IN THE 2010 FEIR IN DISREGARD OF THE PUBLIC’S CEQA ROLE ........................................ 24 18 V. PETITIONERS HAVE COMPLIED WITH ALL PROCEDURAL 19 REQUIREMENTS .......................................................................................................... 28 20 A. IRREPARABLE HARM AND ARBITRARY AND CAPRICIOUS ACTION .................... 28 21 B. EXHAUSTION OF ADMINISTRATIVE REMEDIES ................................................... 29 22 C. ATTORNEYS’ FEES ................................................................................................ 30 23 24 VI. CLAIMS FOR RELIEF ................................................................................................. 30 25 FIRST CAUSE OF ACTION (Violation of CEQA – Invalid Use of An Addendum) ............................................................. 30 26 SECOND CAUSE OF ACTION 27 (Violation of CEQA – Failure to Prepare and Adopt an EIR) ............................................... 31 28 LAW OFFICES VERIFIED PETITION FOR WRIT OF MANDATE AND INJUNCTIVE RELIEF; i COTCHETT, PITRE & Case No. MCCARTHY, LLP 1 THIRD CAUSE OF ACTION (Violation of CEQA - Failure to Support Decision with Valid CEQA Document) ............... 32 2 3 FOURTH CAUSE OF ACTION (Violation of CEQA - Failure to Provide The Public Its Right of Review) ........................... 32 4 FIFTH CAUSE OF ACTION 5 (Violation of CEQA - Failure to Evaluate Significant Environmental Impacts) .................. 33 6 SIXTH CAUSE OF ACTION 7 (Violation of CEQA - Failure to Evaluate and Adopt Feasible Alternatives) ...................... 34 8 SEVENTH CAUSE OF ACTION (Violation of CEQA - Failure to Adequate Disclose and Evaluate Cumulative Impacts)... 36 9 EIGHTH CAUSE OF ACTION 10 (Violation of - Failure to Adopt Mitigation Measures ) .......................................................... 37 11 NINTH CAUASE OF ACTION 12 (Violation of CEQA – Failure to Adopt Findings) ................................................................... 38 13 TENTH CAUSE OF ACTION (Violation of CEQA - Response to Comments) ........................................................................ 40 14 15 ELEVENTH CAUSE OF ACTION (Violation of CEQA - Failure to Adopt a Mitigation Monitoring Plan ) ............................... 42 16 TWELFTH CAUSE OF ACTION 17 (Injunctive Relief) ....................................................................................................................... 42 18 PRAYER FOR RELIEF............................................................................................................. 42 19 20 21 22 23 24 25 26 27 28 LAW OFFICES VERIFIED PETITION FOR WRIT OF MANDATE AND INJUNCTIVE RELIEF; ii COTCHETT, PITRE & Case No. MCCARTHY, LLP 1 Petitioners Bess Bair, Trisha Lee Lotus, Jeffrey Hedin, David Spreen, the Center for 2 Biological Diversity, Environmental Protection Information Center, Californians for Alternatives 3 to Toxics, and Friends of Del Norte (hereinafter collectively referred to as “Petitioners”) allege 4 as follows based on information and belief, except where specifically indicated: 5 I. INTRODUCTION 6 1. This action continues the ongoing battle of trucks versus trees. Petitioners are 7 duty bound once again to seek assistance by this Court in compelling Respondents, California 8 Department of Transportation and Malcolm Dougherty as Director of the California Department 9 of Transportation (hereinafter referenced collectively as “Caltrans” or “Respondents”), to meet 10 their obligations to adequately evaluate and consider the environmental impact of a proposed 11 major highway construction project set to widen the highway through the ancient old-growth 12 redwoods of Richardson Grove State Park (“Richardson Grove” or the “Park”), which Caltrans 13 has misnamed the “Richardson Grove Operational Improvement Project” and which is referred 14 to herein as the “Proposed Project” or “Richardson Grove Project.” 15 2. Richardson Grove provides the gateway to majestic old-growth redwoods that 16 exist nowhere outside California’s northern coast, and, even there, in a fraction of their former 17 extent. U.S. Highway 101 threads through the Park for approximately a mile. Rated as one of 18 the 100 finest state parks in America, thousands of visitors annually trek to this historic gem, 19 seeking to enjoy the awe, reverence, and spirituality of the Richardson Grove. Visitors are 20 offered a true glimpse of history as they drive amidst old-growth redwoods ranging between 21 1,000 and 3,000 years old, some as large as 18 feet in diameter, immediately adjacent to or 22 abutting Highway 101. The ancient redwood forest of Richardson Grove, furthermore, provides 23 critical and essential habitat for numerous species of Northwest coastal California plants and 24 animals that have evolved in conjunction with its redwoods. The survival of these plants and 25 animals depends on the continued survival of the Richardson Grove. 26 3. At a time in which Californians are bearing witness to an increasing 27 disappearance of the State’s natural wonders at an alarming and accelerating rate, Caltrans is 28 once again attempting to plow through a destructive and needless highway widening project that LAW OFFICES VERIFIED PETITION FOR WRIT OF MANDATE AND INJUNCTIVE RELIEF; 1 COTCHETT, PITRE & Case No. MCCARTHY, LLP 1 will both waste millions of taxpayer dollars and likely destroy one of the last remaining 2 irreplaceable stands of ancient old-growth Redwoods, without studying the severe and permanent 3 environmental consequences. 4 4. This case is also very much about a state agency’s disregard for the public’s 5 rightful role in the review and decision-making process guaranteed by the California 6 Environmental Quality Act (“CEQA”). On a project such as Richardson Grove, CEQA 7 mandates public accountability. CEQA also requires that Caltrans engage as a partner with the 8 public in evaluating share expertise, disclosing agency analyses, checking for accuracy, detecting 9 omissions, discovering public concerns, and soliciting counter proposals. 10 5. This action follows successful state and federal court challenges to Caltrans’ 11 initial 2010 approval of the Richardson Grove Operational Improvement Project. In both actions 12 the Courts found Caltrans’ environmental review lacking and not in compliance with governing 13 law. Ultimately Caltrans rescinded all of its approvals: on June 26, 2014, Caltrans set aside and 14 rescinded its approval of the Richardson Grove Operational Project and certification of its 2010 15 Final Environmental Impact Report (“2010 FEIR”), and on November 17, 2014, Caltrans 16 withdrew and rescinded its 2010 Finding of No Significant Impact (“2010 FONSI”). 17 6. Since then Caltrans has cobbled together various documents and studies, in an 18 transparent effort to rehabilitate its 2010 decisions, which had been found legally deficient, 19 without providing any opportunity for the public to review and comment on the purported new 20 analyses these documents and studies contain. Not only do these purportedly new analyses fail 21 to comply with CEQA’s substantive requirements, this type of disordered and informal process 22 of environmental review is simply not allowed. 23 7. On May 22, 2017, Caltrans reapproved the Richardson Grove Project, claiming 24 changes to the Proposed Project and the environmental impacts from those changes are “minor,” 25 while attempting to justify its conclusion based on some twenty-six documents that have been 26 developed over the course of nearly four years and comprise hundreds of pages. Caltrans failed 27 to comply with its duty to ensure public participation in its decision-making process, particularly 28 in the face of the significant changed circumstances that invalidated its previous decisions. LAW OFFICES VERIFIED PETITION FOR WRIT OF MANDATE AND INJUNCTIVE RELIEF; 2 COTCHETT, PITRE & Case No. MCCARTHY, LLP 1 8. Caltrans claims to have corrected the glaring errors that accompanied Caltrans’ 2 initial 2010 approval of the Richardson Grove Operational Improvement Project.
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