|One of the most illegal highways ever proposed|
June 2006: last gasp?
“Great biological diversity takes long stretches
of geologic time ... The richest ecosystems build slowly over millions
of years. It is further true that by chance alone only a few species are
poised to move into novel adaptive zones, to create something spectacular
and diversity. A panda or sequoia represents a magnitude of evolution
that comes along only rarely. It takes a stroke a luck and a long period
of probing, experimentation, and failure. Such a creation is part of deep
history, and the planet does not have the means nor we the time to see
it repeated.” -
“Extinction is not something to contemplate. It is something to
“The Modified Project is ‘likely to adversely affect’
Fenders’s blue butterfly because the possibility of incidental takes
resulting from butterfly impacts with vehicles using the facility.”
Critical Habitat for Endangered Species
The WEWP restoration activities have included controlled burnings to restore native wet prairie and other wetland habitat required by rare plants, Fender’s Blue Butterfly and other species, and control non-native species not as adapted to frequent low-intensity fire. Many of these burns have been conducted in areas in and near the WEP route(s). Neither the FEIS nor the SDEIS discuss how these controlled burns could be continued adjacent to a four to six lane elevated freeway with commuter traffic and triple trailer trucks, since smoke could impair highway safety. Would the Parkway be closed in these sections on days that controlled burns were scheduled? Would controlled burns be prohibited in the West Eugene Wetlands to accommodate commuter and truck traffic? This critical concern should be discussed in the new DEIS, since it relates to the ability to restore and maintain the frequent fire regime that the wet prairie ecosystem flourished with for millennia prior to fire suppression in the mid 1800s. (Grass field burnings in the Willamette Valley were scaled back a number of years ago after thick smoke obscured visibility on I-5, causing a multiple fatality chain collision.
The WEWP controlled burns are much more limited in scale, posing much less health hazards than the massive grass field burns – which could be replaced with a variety of alternative methods for dealing with the agricultural wastes: ethanol production, composting, crop substitution, straw bales for natural building construction, among others.
The nearby Fern Ridge Research Natural Area, which would have to cede a portion of land to the ultimate “Phase 3" of the WEP (the widening of Highway 126 from Goble Lane all the way to Veneta) has also conducted occasional controlled burning (although that burning was along a road that went along the edge of the property, not through the middle of it). The new DEIS should state whether cessation of West Eugene Wetlands controlled burning on either side of the highway would constitute grounds for a “license to kill” under the Endangered Species Act (euphemistically called “take”). Since the Endangered Fender’s Blue Butterfly is totally dependent upon Endangered Kincaid’s Lupine,, abandoning the use of controlled burning to restore/maintain native habitat along the WEP could ultimately risk extirpation of this population of Fender’s Blue Butterfly.The new DEIS should list if there is precedent for a major highway being constructed through native wet prairie habitat that shelters numerous rare and endangered plants and animal species - and whether those populations remained viable during and after highway construction. In other words, are the promises of an “environmentally friendly highway” based on any prior experience – with peer reviewed analysis not conducted by paid advocates for highway construction - or are these claims essentially public relations?
The SDEIS claims that Fender’s Blue Butterfly would eventually regain lost habitat “via compensatory mitigation.” (p. 4-9) The new DEIS should explain how long an “eventually” is, and what these animals will do while waiting for these new habitats to be viable enough to support them. In addition, the claim that this animal and its larval host species are not in the project area is unclear – since elsewhere in the SDEIS nearly the entire West Eugene Wetlands is listed in the project area. The SDEIS stated that Kincaid’s lupine is in the project area although not immediately in the footprint of the highway.
“Construction activities in the Bertelsen Slough area would pose a hazard to western pond turtles in habiting the area.” (SDEIS p. 4-7) So would operation of the road (turtle road-kill, turtle poisoning from road runoff).
“The numbers of animals lost via roadkill would not be expected to be of significance to viability of local populations. Both alternatives would alter animal movement patterns, including those of the western pond turtle.” (SDEIS p. 4-7)
The new DEIS should include estimates of the numbers of Fender’s Blue Butterfly that would be squashed on the fenders of cars and trucks, and compare the road kill estimates with the ODOT Charette Alternative. The new DEIS should describe how animals can be screened from entering the highway near Bertelsen Slough (the main natural refuge in the existing West Eugene industrial/commercial area) since the Bertelsen / WEP intersection is proposed to beat grade.The street lights on the WEP would contribute to a “take” of Fender’s Blue Butterfly. This should be addressed in a revised Biological Opinion and in a new DEIS.
Terry Street - more lights to cope with curve/line of sight issues
butterflies live in the early spring, when the evening rush hour is more likely to still be using headlights than the summertime evening rush hour
The discussion about the impacts of Fender’s Blue Butterfly ignore the impacts that highway lighting would have upon this Federally Endangered species. The BLM’s June 2001 EA specifically stated that lighting confuses this species into thinking it is daytime, and then while flying to the lights is at great risk of being eaten by bats. Therefore, lighting the WEP, especially at the WEP / Terry intersection (assuming that Terry St is put back into the TransPlan), would constitute a “take” that would threaten the continued viability of this species in the heart of the West Eugene Wetlands. The issue of lights upon butterfly habitat will need to be further examined in a new DEIS.
West Eugene Wetlands Recreation, Access and Environmental Education Plan
and Revised Environmental Assessment - June 2001 http://www.edo.or.blm.gov/nepa/coastrange/ea/wetlandPlan.pdf
Non - Federally Listed Species
Karner Blue Butterfly - endangered species of the Great Lakes (similar situation of rare habitat)
Karner blue butterflies live in areas described as oak savannas and pine
barren ecosystems. These ecosystems are likely to contain many different
herbaceous plants and grasses with scattered small groves of trees and
shrubs. The open sunny nature of these systems creates the right conditions
for wild lupine, a plant that the Karner blue caterpillar depends on.
Wild lupine is the only plant that the caterpillar is known to feed on
and therefore critical to survival of the butterfly. Adult Karner blues
feed on nectar from a variety of wild flowers like the horsemint, butterflyweed,
and bachelors button.