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

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