August 22, 2022
Amit Bose, Administrator
Federal Railroad Administration
1200 New Jersey Ave SE
Washington, D.C. 20590
amitabha.bose@dot.gov
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.
Sincerely,
| 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 |
CC:
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