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
In response to comments made by
CalEPA to the Bay Area to Central Valley 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.
Introduction
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
The State of California has the highest diversity of native
flora (CDFG 2003). The “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 (Vierheilig, 2008). 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.
Conclusion
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.
References:
·
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
— CHSRA
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
·
National Park Service –
Bryce Canyon,
Sequoia & King Canyon (2012)
·
Vierheilig, Larry
