California Transportation Plan 2050 - Comments
Total Page：16
File Type：pdf, Size：1020Kb
December 20, 2018 Sent via email and FedEx (if applicable) California Department of Transportation (Caltrans) Division of Transportation Planning California Transportation Plan Office of State Planning 1120 N Street, MS 32 Sacramento, CA 95814 (916) 654-2852 [email protected] Re: California Transportation Plan 2050 - Comments Dear California Transportation Plan 2050 Planners: These comments are submitted on behalf of the Center for Biological Diversity (the “Center”) regarding the California Transportation Plan (CTP) 2050. The Center is encouraged by Caltrans’ commitment to increase safety and security on bridges, highways, and roads and create a low-carbon transportation system that protects human and environmental health. To achieve these goals, it is imperative that Caltrans integrate wildlife connectivity into the design and implementation of California’s transportation infrastructure. The Center urges Caltrans to improve driver safety and minimize the impact of roads and traffic on wildlife movement and habitat connectivity with the following actions: 1. Collect and analyze standardized roadkill and wildlife vehicle collision data. 2. Build climate-wise wildlife crossing infrastructure in high priority areas. 3. Prioritize wildlife movement and habitat connectivity on ALL transportation projects. 4. Designate an expert unit dedicated to address wildlife connectivity issues. This unit should form strategic collaborations and partnerships with other connectivity experts. 5. Evaluate the effectiveness of wildlife crossing infrastructure to inform future mitigation. 6. Upgrade existing culverts to facilitate wildlife connectivity as part of routine maintenance. 7. Provide up-to-date guidance for best practices for climate-wise connectivity. 8. Engage with volunteer and community scientists and platforms. 9. Improve multimodal transportation design. 10. Allocate more funding to prioritize wildlife connectivity. The Center is a non-profit, public interest environmental organization dedicated to the protection of native species and their habitats through science, policy, and environmental law. The Center has over 68,000 thousand members and online activists throughout California and the United States. The Center has worked for many years to protect imperiled plants and wildlife, open space, air and water quality, and overall quality of life for people in location of Project. I. ROADS CREATE BARRIERS THAT LEADTO HABITAT LOSS AND FRAGMENTATION, WHICH HARMS WILDLIFE AND PEOPLE Desert tortoise crossing the road in Joshua Tree National Park. Photo Credit: National Park Service. Roads and traffic are drivers of habitat loss and fragmentation, which have been identified as major stressors on California’s unique ecosystems and biodiversity (CDFW 2015). As barriers to wildlife movement and the cause of injuries and mortalities due to wildlife vehicle collisions, roads and traffic can affect an animal’s behavior, movement patterns, reproductive success, and physiological state, which can lead to significant impacts on individual wildlife, populations, communities, and landscapes (Trombulak and Frissell 2000, Haddad et al. 2015, van der Ree 2015, Ceia-Hasse et al. 2018). For example, habitat fragmentation from roads and traffic has been shown to cause mortalities and harmful genetic isolation in mountain lions in southern California (Riley et al. 2006, 2014, Vickers et al. 2015), increase local extinction risk in amphibians and reptiles (Cushman 2006, Brehme et al. 2018), cause high levels of avoidance behavior and mortality in birds (Benitez-Lopez et al. 2010, Loss et al. 2014), and alter pollinator behavior and degrade habitats (Trombulak and Frissell 2000, Goverde et al. 2002, Aguilar et al. 2008). In addition, wildlife vehicle collisions pose a major public safety and economic threat. Over the last three years (2015-2017) it is estimated that 7,000 to 23,000 wildlife vehicle collisions have occurred annually on California roads (Shilling et al. 2017, Shilling et al. 2018, State Farm Insurance Company 2016, 2018). These crashes result in human loss of life, injuries, emotional trauma, and property damages that can add up to $300-600 million per year. December 20, 2018 Page 2 Caltrans’ mission statement is to “[p]rovide a safe, sustainable, integrated, and efficient transportation system to enhance California’s economy and livability” (Caltrans 2018a). Thus, Caltrans should include an additional goal in the CTP 2050 to maintain and improve climate-wise connectivity to sustain functional, healthy ecosystems and ensure public safety. This can be accomplished by avoiding intact wildlife corridors and the implementing effective wildlife crossing infrastructure. Crossing structures are useful as mitigation for new projects and as retroactive restoration in areas where existing roads have high incidence of wildlife vehicle conflict or where species movement has been severely impacted. When appropriately implemented, wildlife crossing infrastructure has been shown to improve wildlife permeability and reduce wildlife vehicle collisions (Dodd et al. 2004, 2012, Bissonnette and Rosa 2012, Sawyer et al. 2012, Sawaya et al. 2014, Kintsch et al. 2018). Thus, by maintaining and restoring climate-wise habitat connectivity that facilitates movement required for current and future species ranges and behaviors, Caltrans would improve driver safety while allowing California’s special biodiversity to thrive. II. CALTRANS IS NOT ADEQUATELY ADDRESSING WILDLIFE MOVEMENT OR HABITAT CONNECTIVITY ISSUES A baby black bear was struck by a car on the road and a red fox feeds on roadkill. Photo credit: Robert Berdan. Because Caltrans has authority and jurisdiction over most of California’s roads and highways, Caltrans is the best suited agency to make roads safe for both motorists and wildlife. Caltrans should be proactively addressing the environmental and public safety impacts that result from the maintenance, design, construction, and traffic of California roads. However, Caltrans is failing to keep people safe and ecosystems healthy by neglecting to acknowledge the need for appropriate data to determine priority areas for preserving, enhancing, or developing effective wildlife connectivity on existing or planned roads. Caltrans is falling behind other state transportation departments that are prioritizing road safety and wildlife connectivity in their project design and implementation. A. Caltrans has insufficient data to identify priority areas, determine the magnitude of the problem, and inform effective mitigation In July and August of 2018 the Center requested roadkill and wildlife vehicle collision data under the California Public Records Act (PRA), Government Code § 6250 et seq. In December 20, 2018 Page 3 response to the PRA requests, the Center received various documents, including records and summary reports of animal hits from 2010 to 2017 from the Transportation Systems Network (TSN) (these are reported animal vehicle collisions), carcass removal data from 2001 to 2018 from Caltrans Division of Maintenance, and website links to spatial data (i.e., GIS layers) for the locations of bridges, underpasses, culverts, and traffic volume (Appendix 1). In addition, the Center received a 2017 contract not to exceed $250,000 between Caltrans and the Western Transportation Institute (WTI) to conduct a hotspot analysis for large mammal-vehicle collisions in California, the data used by WTI for their analyses, and summaries of WTI’s preliminary analyses (Appendix 2). Following a close review of the documents, it became apparent that Caltrans has failed to systematically collect or record roadkill data. This is concerning because systematic, reliable roadkill and animal vehicle collision data are needed to accurately identify the existence and magnitude of road safety and conservation issues (Donaldson 2017, Shilling et al. 2018). Carcass removal data input varied and often did not include important details like species information, date and time information, or specific location information. For example, the 52 recorded roadkill pickups in 2017 in District 7 (Los Angeles and Ventura Counties) included two dogs, one coyote, one raccoon and 48 unidentified species. These data are insufficient for meaningful analyses. Alarmingly, four of the 12 Caltrans Districts (9, 10, 11, and 12) had no roadkill data for the past seven years (2011-2017), even though they cumulatively had an average of ~1200 roadkill pickups annually from 2004 to 2010. In addition, several of the remaining Districts with data, including Districts 4 (the San Francisco Bay Area) and 7 (Los Angeles and Ventura Counties), had markedly less records compared to previous years. The lack of data and low numbers contradict a study conducted by the UC Davis Road Ecology Center, which identified wildlife vehicle collision hotspots in all of these Districts using independently collected roadkill data from the California Roadkill Observation System and Caltrans animal crash data (Shilling et al. 2018). See Figure 1. Figure 1. Map of Caltrans Districts and identified wildlife vehicle collision hotspots. Sources: Caltrans, Shilling et al. 2018. December 20, 2018 Page 4 According to the WTI summary regarding carcass removal (Appendix 2.2), the number of records in the database for species of concern to human safety (except for mule deer) or biological conservation were low, and “[l]ooking at the species distribution maps for CA, there are probably many more hit of these species in locations that did not report