Saturday, October 5, 2013

Fracking on our agriculture

One concern about fracking that did not get much attention is its effects on agriculture.  A reduction of agricultural output is attributable directly to loss of land and an indirectly to the effect of truck traffic emissions.  It may seem insignificant by comparison to water contamination and earthquakes.  However, much of the Fracking in California occurs in and around the Central Valley, one of the most agriculturally productive regions in the US.  A diminished crop output from California will surely be felt across the country.
A case study to what is about to happen in California is the situation in Pennsylvania, where fracking for natural gas has spanned across the countryside.  Fracking sites dot the rural farming landscape bringing hundreds of truck trips onto small country roads.  Each fracking site must have an access road for the heavy equipment and so a spider web of new roadways spreads across the region.  Farmers who lease their land to fracking may not realize all that comes along with the activity.  Even when fracking doesn’t cause spills or earthquakes and doesn’t contaminate groundwater, even when everything goes according to plan, fracking takes over farm land and brings with it heavy truck traffic.  Both of which diminish the agricultural output of the state.

Since the year 2000, over 7000 gas wells were fracked in Pennsylvania.  This fracking activity mostly happens in rural agricultural areas where the loss of land and increased emissions reduce the agricultural productivity of the area.  The maps show that fracking activity mostly occurs on land that is 15-50% cultivated.  While each individual fracking site may seem small, access roads and pipelines add to the loss of acreage.  The cumulative land-grab is significant when added to leaks and water contamination that also degrade productive agriculture land.  Yet another significant effect is truck emissions that reduce crop output.  In the past few years, many reports identified the direct negative health effects on farmers and their animals.  However, the indirect effects of the truck pollution were not closely looked at, in connection with fracking activity.  As hundreds of trucks travel to these fracking sites, the air quality diminishes, people’s health declines and agriculture output decreases.
The effects of traffic emissions on agriculture are significant and well documented.  A study in 1999 found that a mere 10% emissions reduction from truck traffic is estimated to increase agricultural output in the US by $70 million (1990-dollar values).  The same study estimated the economic losses from all traffic related pollution in California to be approaching $2 billion (1990-dollar values).  Diesel vehicles and equipment account for over two thirds of the particulate matter polluting our air.  California took a lead role in pollution reduction and experienced health and economic benefits.  Fracking activity would set us back and decrease our agricultural production output.
High concentration of pollutants inhibits plant growth and therefore reduces plant productivity.  Ozone and particulates enter the leaves and hamper the photosynthesis process.  This reduced plant growth and productivity, which translates into losses in agriculture.  California made strides to curb car and truck emissions in efforts to reduce their negative health effects such as asthma.  These steps helped increase agricultural productivity; fracking will reverse that progress.
The deleterious effects of traffic emissions have been recorded many times over.  The California Air Resource Board (ARB) has conducted numerous studies that show the correlation between gasoline and diesel exhaust and asthma in the Central Valley.  These studies show that high levels of particulate matter are the result of smoking cars and diesel engines.  Other studies show that diesel trucks contribute to the high levels of VOC’s in the central valley.  Fracking would elevate both VOC’s and particulate matter concentrations in the region.  It would increase particulate matter from its associative truck traffic and VOC’s from methane emissions, leaks and evaporation ponds.  What is in-store for California can be observed by fracking activity in Pennsylvania.  California however, may have more to lose.
Here is an industry determined to get every last drop of oil and gas out of the ground if they can make ‘a buck’ selling the stuff.  They coerce and manipulate farmers to get the rights to frac for oil in California, while our state’s agriculture declines, our health deteriorates and our air and water are in jeopardy.  If ever there was a case of profits over people, this clearly is one.  Particularly considering, that this crude is of such poor quality it is headed for export, profiting only the oil industry.  The disingenuous choice, our state’s government makes by allowing dirty oil extraction rather than increasing sustainable energy production is troubling, especially, when our states agriculture is on the line.  Choosing oil over veggies is not a sustainable choice.  Fracking activity contradicts climate change mitigation regulations established by AB32.  Fracking is particularly harmful in California, the food basket of the country.  We cannot afford this risky endeavor that only benefits the oil industry at our collective expense.
Cahill Thomas A. Steven S. Cliff, Michael Jimenez-Cruz and Kevin D. Perry, DELTA Group, University of California, Davis and Dept. of Meteorology University of Utah; Continuous Analysis of Fresno Aerosols by Size, Time and Elemental Concentrations, March – December 2001,
California Air Resource Board, CRPAQS Documents and Publications, Central California air quality studies CCOS & CRPAQS, April 7, 2009
Fox, Josh; GasLand the movie, 2010
Griffiths Heather; Integrated Pest Management Modelling Specialist/OMAFRA, Effects of Air Pollution on Agricultural Crops, Revision of Factsheet Air Pollution on Agricultural Crops, Order No. 85-002; Printed June, 2003
Lurmann, Fred, Siana Alcorn, Manidipa Ghosh and Sonoma Technology Inc. Petaluma, CA Tasks 6.1 and 6.2: Phase Distributions and Secondary Formation During Winter in the San Joaquin Valley; Presented to: CRPAQS Data and Workshop, Sacramento CA, March 9-10 2004
Murphya J.J., M.A. Delucchic, D.R. McCubbind, H.J. Kime, The cost of crop damage caused by ozone air pollution from motor vehicles, Journal of Environmental Management Volume 55, Issue 4, April 1999, Pages 273–289
Roberts, David; 10 reasons why fracking for dirty oil in California is a stupid idea Grist Magazine, 18 Mar 2013
Royte, Elizabeth, Fracking Our Food Supply; Are dying cattle the canaries in the coal mine? Farmers and ranchers are sounding alarms about the risks to human health of hydraulic fracturing.  November 28, 2012 This article appeared in the December 17, 2012 edition of The Nation.
Union of Concerned Scientist, Diesel Engines and Public Health, 01/08/08
US EPA, Benefits and Costs of the Clean Air Act, Second Prospective Study - 1990 to 2020, August 15, 2013
The Clean Air Act and the Economy, August 15, 2013
Maps Sources
Pennsylvania Department of Environmental Protection, PA DEP Oil & Gas Reporting Website - Statewide Data Downloads By Reporting Period 9/24/2013
Permits and Drilled Wells (a.k.a. Spuds):
PAMAP Program Land Cover for Pennsylvania, 2005 The Pennsylvania State University Publication Date:200708
PASDA Pennsylvania Spatial Data Access
Stratification of Pennsylvania 2002 United States Department of Agriculture, National Agricultural
Publication Date:  2002

Wednesday, May 29, 2013

To:            CHSRA – California High-speed Rail Authority
Chairman Dan Richard California High-Speed Rail Authority Board
770 L Street, Suite 800 Sacramento, CA 95814
FROM:          Tami Etziony, Mills College 5000 MacArthur Blvd. Oakland, CA 94613
Subject:     High-speed Rail Route as a Path to Promote California Native Species
Date:          5/29/2013
CC:           Mark Henderson, Mills College Public Policy Department
High Speed Rail (HSR) EIR 2010, regarding wildlife protection, I would like to expand the discussion and include concerns for native plants of California.  The proposed HSR project could provide a rare opportunity to support an ecosystem that faces overwhelming challenges.  The long path of the HSR should be landscaped exclusively with native plants.  Caltrans currently implements several programs, which incorporates native species.  These types of programs should be expanded and adopted to the HSR project’s landscaping plan.
A future passenger on the HSR riding through the Central Valley, will mostly sees a blur of greenery and farm fields.  The view from California wild life’s perspective is quite different.  By comparison, to the highway system the HSR is a huge barrier cutting the state in half (Map page 10).  The HSR does address the needs of wildlife crossings in its EIR/EIS but not native plant species.  The HSR EIR/EIS mitigation plan includes fencing along the route with passageways to bridge accessibility for wildlife.  This plan includes consideration for special status species, although, without much detail as to what these mitigations entail.  When embarking on such a massive project that will bisect the state’s coastal regions from the Sierra Nevada, there is an opportunity to address systemic environmental issues.
California’s native plants are at a constant struggle with invasive species over resources.  These native plants are the backbone of a healthy ecosystem and a support structure to wildlife.  The HSR project creates an opportunity to boost the concentration of native plants along this massive route, which will promote the well-being of our wildlife. 
Existing state policies set a precedent for recognizing the importance and value of our wildlife and native species.  The Department of Fish and Game developed the California Wildlife Action Plan Report as a collaborative conservation approach.  The plan states its objectives clearly:
Actively managing public and private lands to mitigate the impacts of human activities on native habitats; maintain wildlife corridors and habitat connectivity; safeguard surface and groundwater quality; impede the establishment of invasive species; and employ beneficial fire management practices requires engagement by every Californian.  (CDFG, 2005)
Caltrans, the California Department of Transportation, has also developed several plans to promote native species.  Both drew on the information in the California Natural Diversity Database (CNDDB, 2003).  Native eco-communities in the Central Valley shrunk by over 90% in the past 150 years, mostly through conversion for agricultural use (California Essential Habitat Connectivity Project, 2010).  The HSR route could become a path of connectivity for many different native communities along the Central Valley.

I propose that the HSR authority’s landscaping plan promote native species diversity by using only native California plants.  Numerous native plant nurseries throughout the state would benefit from this opportunity and could develop public/private partnerships with the CHSRA.  The California Native Plant Link Exchange provides information about native plants, their horticulture characteristics and nurseries that supply them.  This landscaping plan will encourage awareness of the diversity and importance of native California plants in horticultural application. 
California’s rich natural heritage
CDFG 2003).5,047 California native plant species represent 32 % of all vascular plants in the United States” (CDFG 2003).  The state is also a global hotspot of plant diversity CDFG 2003).California native species are diverse and unique.  The collection of natives includes the tallest and the oldest known trees, respectively the Giant Sequoia and Methuselah, Pinus longaeva   4,765 years old (National Park Service, 2012).  From a native rose to a honeysuckle, currants to buckwheat species, sage to fuchsia, California’s native plants both resemble their Mediterranean cousins or show their unique features as in the coastal redwood. 

Conserving the unique landscape of California will preserve more than just the view; it would support healthy wildlife, fungi and microbial communities.  This vegetation filters rainwater and is the basis for a healthy ecosystem.  The native plants grant access to food and shelter to local insects, reptiles, birds and mammals This wildlife has struggled with human encroachment and now, with climate change.  A substantial path of native plants would encourage bio-diversity and help countless species with climate change movement.
Many conservation efforts around the state cultivate native species.  The California Native Plants Society (CNPS) has worked since 1965 to protect California's native plant heritage and preserve its splendor for future generations.  CNPS, along with California Native Plant Link Exchange, has compiled lists of nurseries supplying native plants.  A collaborative effort with the CHSRA would boost the conservation of California’s unique and rich biodiversity.
CalEPA comments to HSR
The CalEPA submitted comments to the Final Program HSR EIR/EIS.  One of their comments stated that the assessment did not take into account the cumulative effects of future subsequent development attributable to the HSR project and its stations.  The EPA suggested that CHSRA follow the Caltrans cumulative analysis guidelines for a reasonably foreseeable future development projects.  The EPA also noted that the landscape plan was insufficient to assess this cumulative impact and should include large-scale mitigation, due to elements such as a continuous fence along the HSR, which impedes wildlife movement (CHSRA, 2012). 

CHSRA responded that it is unreasonable to include cumulative impacts from future development since the route is not established yet and the plan accounts for ten to fifteen year timeline.  Additionally, due to the extent of the project and its scope, CHSRA noted that various counties are on the path of the HSR project and each has its own impacts and requirements for mitigation (CHSRA, 2012).  Therefore, CHSRA creates a report for each section of the project. 
CHSRA states that Caltrans has no guidance on cumulative impact analysis.  Caltrans however, has released such a report; Guidance for Preparers of Cumulative Impact Analysis (2012), which compiles the mitigation approaches for both NEPA and CEQA for a long-term analysis. 
Caltrans practices and commitment to mitigation
Caltrans, in fact, has comprehensive assessments for natural plant and animal communities in California.  Previous experiences with CEQA and NEPA resulted in Caltrans guidelines for planting native species.  For example, “California native wildflowers must be included with all projects with Federal participation” (Caltrans, Highway Planting General Policy).  They also created detailed plans for wildlife access in their Wildlife Crossings Guidance Manual (Caltrans, 2009).  Caltrans however, will reject native species in favor of exotics when “wildflowers would not be compatible with the adjacent urban landscape environs.”  Moreover, their plans do not involve trees and shrubs, which provide a comprehensive habitat to many more species.

The commitment of their landscape design team to “preserve and enhance the environment through sustainable solutions” does show a strong support for landscaping with a broad perspective and environmental goals (Caltrans, Landscape Architecture). 
“In the 1990’s, federal transportation policy shifted emphasis, giving State and local governments more flexibility in determining transportation solutions.  This allows funding for projects that protect the environment, provide for bicycle and pedestrian mobility, and promote highway beautification.”  (Caltrans, Landscape Architecture).

Caltrans and the California Department of Fish and Game had previously addressed the issues of environmental conservation:
Caltrans and the California Department of Fish and Game (CDFG) sponsored this study to conserve and ensure the continued existence of California wildlife and biodiversity …considering environmental needs of trans­portation projects early in the planning process, …(which) allow Caltrans and CDFG to meet requirements set forth in the safe, accountable, flexible, efficient transportation equity act…  (CNDDB, 2003)
Caltrans and the California Dept. of Fish and Game both have comprehensive plans to include California natives and support wildlife.  Both the California Natural Diversity Database and the California Essential Habitat Connectivity Project address the need for conservation efforts to increase native species populations (CNDDB, 2003; DOT, 2010).  CHSRA, as a state transportation project should integrate these plans’ inputs in its landscaping designs and promote native species for the benefit of future generations of the people and wildlife of California.
CHSRA commitment to mitigation – California HSR Project EIR/EIS
Merced to Fresno Section 2011
The CHSRA has an extensive mitigation program for HSR construction disturbance of environmental resources (CHSRA, 2012).  The program details mitigation response for each endangered and special status species (CHSRA, 2012).  Consideration for migratory birds and wetlands conditions are included (CHSRA, 2012).  The program also pledges to prevent and control the spread of invasive species (CHSRA, 2012).
Through aerial and field survey methods, endangered and special status species will be identified and cataloged.  Mitigation efforts include propagation of certain plants and redistribution.
The EIR/EIS plan acknowledged that the Central Valley includes several natural environments; California prairie, marshlands, valley oak savanna and riparian woodlands, that historically characterize the region (CHSRA, 2012).  Currently agriculture claims most of the Central Valley lands.  The native plant population suffers overcrowding due to agriculture and horticulture introduction of invasive exotic species to California.
Native plants evolved to coexist and flourish within their specific habitat region, each region has its own unique landscape.  The native species also provided services to their regional environment.  Native plants are a source of food and shelter for local animals; in addition, they are instrumental in reduction of fire danger, water purification and erosion control (DOT, 2010).  Their value to the California landscape is great and the HSR route presents a rare opportunity to reverse this detrimental trend of habitat loss.  For this aim, the HSR landscaping plan would require an expansion beyond its current intent of mitigation to pre-project conditions.
While NEPA’s standards are “based on the criteria of context and intensity,” CEQA looks at “substantial adverse effects” (CHSRA, 2012).  CEQA is more general and takes into account habitat and natural community (CHSRA, 2012).  However, neither one entertains restoration to a higher standard than pre-project conditions.  Since both NEPA and CEQA require mitigation that relate to each specific project’s prior conditions, they limit environmental improvements.
Climate change consequences
Climate change will affect the ecology of California and result in migration of many species.  Climate change is predicted to reduce snow packs and therefore decrease water flow in the early summer (DOT, 2010).  This will increase fire danger and reduce aquifer levels.  Increase winter rainfall and stronger, more frequented storms create conditions ripe for landslides and erosions (DOT, 2010).  Both plants and animals move north and to higher elevations to find comparable conditions to their current habitat (DOT, 2010).  The California Essential Connectivity project encourages the use of corridors to support species movement.  If the HSR adopts the native plants plan, it would become a passage, habitat and refuge for native species.  Although the HSR path cannot be considered an adequate corridor for many species since, it is not sufficiently wide or up to their species requirements, it would nonetheless act as a support system for climate migration.  By providing food and shelter, the route could assist migrating animals on their way to a new habitat.  The native plant path would become a seed bank for local species, which encourages bio-diversity by increasing the gene pool of a wider variety of natives.
California has one of the highest concentrations of invasive exotic species that compete with dwindling native species populations.  The HSR project traverses the states’ vast Central Valley.  This massive project could promote the resurgence of native California’s plant populations by landscaping with native plants exclusively.  The scope of this landscaping will benefit many local subsections of California’s environment by supporting their individual terrain and wildlife’s needs.  All along the High Speed Rail route native animals, birds and insects populations affected over the past century by invasive species and human encroachment would rebound.  This is a precious opportunity to provide native fauna an extended habitat.  The EIR mentions landscaping without much detail.  Encouragingly, as noted previously, Caltrans already has a policy that states, “California native wildflowers must be included with all projects with Federal participation.”  Caltrans’ practices are not perfect but expanding on the incorporation of native species in landscaping will elevate the HSR project to a model of sustainability.  The massive High Speed Rail project is a perfect opportunity to increase the density of native plant populations in California.


·         Bloom, Jonathan (2012, February 20) “Woman's concern prompts study about I-280 deer”
   Bunn, David, Andrea Mummert, Marc Hoshovsky, Kirsten Gilardi, Sandra Shanks
California’s Natural Diversity; California Wildlife Action Plan Report
California Wildlife: Conservation Challenges
Prepared by the UC Davis Wildlife Health Center
California Department of Fish and Game, 1416 Ninth Street (12th floor), Sacramento, CA 95814 © 2005, 2007 by the California Department of Fish and Game
All rights reserved. Published 2007.
·         California Dept. of Fish and Game (CDFG)
California Natural Diversity Database Special Animals. January 2003
Wildlife and Habitat Data Analysis Branch.  The resource Agency of California.

State of California The Natural Resources Agency Biogeographic Data Branch
California Natural Diversity Database SPECIAL ANIMALS (898 taxa) January 2011

·         Department of Fish and Game Biogeographic Data Branch
Vegetation Classification and Mapping Program
List of California Vegetation Alliances October 22, 2007
Native Plants for Wildlife

  California Gardens Nursery

  California  Native Plant  Link Exchange

  California Native Plant Society

 ·      California Natural Diversity Database
(CNDDB, 2003) – Most recently updated in 2010

  California’s Own Landscape Design (viewed on line o
·         Caltrans
1.      Examples of current practices:
2.      Guidance for Preparers of Cumulative Impact Analysis (2012)
3.      Highway Planting General Policy

4.      Wildlife Crossings Guidance Manual
Wildlife Crossings Guidance Manual, Version 1.0 as of March 2009.
5.      Caltrans Landscape Architecture


Draft Environmental Impact Report / Statement: Merced to Fresno

Bay Area to Central Valley HST Partially Revised FINAL Program EIR (April 2012)

Responses to comments ;  CHSRA Staff Summary of and Brief Response to Comments on the Final Program EIR/EIS

 Angie Schmitt Friday, July 15, 2011

·         DOT – Dept. of Transportation 2010
California Essential Habitat Connectivity Project: A Strategy for Conserving a Connected California February 2010 Prepared for: California Department of Transportation California Department of Fish and Game With Funding From: Federal Highways Administration