August 22, 2022

Amit Bose, Administrator
Federal Railroad Administration
1200 New Jersey Ave SE
Washington, D.C. 20590

Re: Adding Necessary Wildlife Overpasses to Brightline West High-Speed Rail Project – Coalition Comments on FRA Brightline West NEPA Re-evaluation of Las Vegas to Apple Valley Segment

Dear Administrator Bose:

We write to request that the Federal Railroad Administration (FRA) ensures that the proposed Brightline West High-Speed Rail Project (“Project”) includes three wildlife overpasses as mitigation measures, which are necessary to avoid the permanent blockage of critical California wildlife movement areas resulting from the Project’s concrete barrier walls. Please accept these comments in response to the NEPA re-evaluation process that the FRA is currently undertaking regarding the Project segment between Las Vegas to Apple Valley. We also write to request a meeting with you to discuss this matter.

We greatly appreciate that FRA has stated that its “NEPA re-evaluation includes a review of design, regulatory, and the associated potential environmental impacts and associated mitigation. The NEPA re-evaluation also includes revisions to the project’s mitigation measures. In updating the re-evaluation, FRA would consider new information provided by the State of California (e.g. CDFW, Caltrans, etc.) and federal partners (e.g. NPS, BLM, etc.) regarding effects to wildlife and wildlife movement and currently proposed mitigation measures for wildlife and wildlife movement.”

We urge the FRA to incorporate the new scientific information provided by wildlife officials at the California Department of Fish and Wildlife (CDFW) and National Park Service (NPS) that demonstrate the Project – as currently designed – will cause significant adverse effects to wildlife and wildlife movement that are not adequately addressed in the existing NEPA document. The agencies have called on FRA to require three wildlife overpasses be included in the Project design as mitigation measures to ensure that the significant adverse effects posed by the Project’s currently proposed design can be appropriately mitigated and addressed.

We are grateful that FRA has sought the official positions of these expert wildlife agencies. Now is the time to act on the science and new information offered by those agencies, and add the wildlife overpasses as Project mitigations. Through this letter, we incorporate by reference the positions and contents of those comment letters that were submitted by CDFW and NPS earlier this year.

Without the three wildlife overpasses included in the Project as mitigation measures, the Project would cause permanent and complete blockage of critical California wildlife movement areas resulting from the Project’s concrete barrier walls. As the expert wildlife agencies have stated, this adverse effect would be caused entirely by the Project, not the I-15 highway.

We support the findings from scientists at CDFW, NPS and Caltrans that have identified the three wildlife overpasses as necessary to protect our world-class wildlife in the fragile California desert. Wildlife species of special status whose movements will be inhibited by this Project include the desert bighorn sheep, mountain lion, desert tortoise, Mohave ground squirrel, desert kit fox and Merriam bobcat, just to name a few. Wildlife overpasses preserve the movement of wildlife and provide for genetic diversity, connecting populations and allowing individuals to move between habitats, which will be increasingly essential in the face of climate change. Desert wildlife such as the bighorn sheep are of tremendous cultural significance to the San Manuel Band of Mission Indians and many other desert Native peoples.

We urge FRA to ensure this Project is designed correctly through the incorporation of three wildlife overpasses as Project mitigations. Thank you very much for your consideration, and we look forward to meeting with you to discuss this matter.


Mason Voehl, Executive Director
Amargosa Conservancy

Eric Hanson, Co-Chair & Policy Lead,
California Chapter
Backcountry Hunters & Anglers

Aimee J. Byard, Associate Director/Biologist
Bighorn Institute

Dan Whisenhunt, CEO
California Deer Association

Melissa Romero
Senior Legislative Affairs Manager
California Environmental Voters

Lori Jacobs, President
California Houndsmen for Conservation

Rick Travis, Legislative Director
California Rifle & Pistol Association

Mark Hennelly, Vice President of Government Relations
California Waterfowl Association

Linda Castro, Assistant Policy Director
California Wilderness Coalition

Mike Painter, Coordinator
Californians for Western Wilderness

Ileene Anderson, Public Lands Deserts Director
Center for Biological Diversity

Michael B. Murray, Chair
Coalition to Protect America’s National Parks

Pamela Flick, California Program Director
Defenders of Wildlife

Wendy Schneider, Executive Director
Friends of the Inyo

Kelly Herbinson, Executive Director
Mojave Desert Land Trust

Chris Clarke, Board President
Mojave National Preserve Conservancy

Edward L. LaRue, Jr., M.S., Chairperson
Desert Tortoise Council, Ecosystems Advisory Committee

Steve Bardwell, President
Morongo Basin Conservation Association
Fred Harpster, President
Black Brant Group

Chriss Bowles, President
California Bowmen Hunters/State Archery Association

Don Martin, President
California Chapter of the Wild Sheep Foundation

Fred Hull, Director
Mountain Lion Foundation

Neal Desai, Senior Program Director
National Parks Conservation Association

Bob Przeklasa, Ph.D., Executive Director
Native American Land Conservancy

Damon Nagami, Senior Attorney
Natural Resources Defense Council

Fraser Shilling, Ph.D., Director
Road Ecology Center at U.C. Davis
(University affiliation for identification purposes only)

Paul Williamson, President
San Francisco Bay Area Chapter Safari Club International

Gary F. Brennan, President
San Diego County Wildlife Federation

John Hiatt, Vice Chair
Sierra Club, CA/NV Desert Committee

Kenneth R. Ramirez, Chairman
San Manuel Band of Mission Indians

Lisa C. McNamee, Legislative Coordinator
SCI CA Coalition

Jay Ziegler, Director of Policy & External Affairs
The Nature Conservancy

Frazier Haney, Executive Director
The Wildlands Conservancy

Steve Miller, President
Tulare Basin Wetlands Association

Gray N. Thornton, President & CEO
Wild Sheep Foundation

U.S. Senator Dianne Feinstein
U.S. Senator Alex Padilla
Governor Gavin Newsom
Rhys Williams, Chief Deputy Cabinet Secretary, Governor’s Office, State of California Mark Tollefson, Senior Counselor, Governor’s Office, State of California
Wade Crowfoot, Secretary, California Natural Resources Agency
Chuck Bonham, Director, California Department of Fish and Wildlife
Toks Omishakin, Secretary, California State Transportation Agency
Tony Tavares, Director, California Department of Transportation
Mohsin Syed, Assistant Secretary of Government Affairs, U.S. Department of Transportation
Lynda Tran, Director of the Office of Public Engagement, U.S. Department of Transportation
Marlys Osterhues, Chief, Environment & Project Engineering Division, Federal Railroad Administration Matthew Mielke, Environmental Protection Specialist, Federal Railroad Administration
Matthew Strickler, Office of Asst. Secretary Fish, Wildlife and Parks, U.S. Department of the Interior Mike Gauthier, Superintendent, Mojave National Preserve, National Park Service