NCDOT Highway Right-of-Ways Win Wildflower Awards

Each year, awards sponsored by The Garden Club of North Carolina are given to the best-looking flower beds along highways in every region of the state – awards that recognize the efforts of North Carolina Department of Transportation staff who carry out the agency’s wildflower program, which for 37 years has enhanced the overall appearance and environmental quality of North Carolina’s highways.

[Above photo by NCDOT]

The 2022 Wildflower Awards were presented to NCDOT teams during the April Board of Transportation meeting by NCDOT Roadside Environmental Engineer David Harris. And a Flickr album with photos of the winners is available here.  

“Our wildflower beds wouldn’t be successful without the hard work put in by our staff. Their commitment to creating detailed flower beds for everyone to enjoy deserves every recognition,” he explained in a statement. “The Wildflower Program is a long-lasting initiative, and we can’t wait to see the beautiful blooms that are due to grow in 2023.”

State DOTs across the country are not only involved in a variety of wildflower- and pollinator-support efforts, many also use special teams to help preserve native animals and plants during infrastructure projects, which also in some cases using natural vegetation to aid in safety projects, such as the construction of snow fences.

On the pollination side, in October 2021 the Georgia Department of Transportation and the Georgia Association of Conservation Districts or GACD began installing 15 pollinator habitat sites in designated locations as part of a joint effort to educate state residents about the important role “pollinators” such as bees, butterflies, and other insects play in Georgia’s agricultural sector.

“This partnership provides Georgia DOT with the unique opportunity to create a safe and beautiful place for families and travelers to get up close and personal with the wildflowers and grasses [to] learn about how they impact the world around us,” explained Felicity Davis, a landscape architect manager with the Georgia DOT.

“We carefully considered the locations for these gardens and with pedestrian safety in mind, we determined the best option would be at rest areas and Welcome Centers across the state,” she said.

Meanwhile, in March 2022, the Minnesota Department of Transportation began “rejuvenating” seven so-called “living snow fences” in southwest Minnesota as part of a month-long effort to ensure the 20-year-old plantings can survive for another two decades. The agency noted that a “living snow fence” is comprised of trees, shrubs, native grasses, and/or wildflowers to trap snow as it blows across fields, piling it up before it reaches a bridge or roadway.

“A living snow fence is more than landscaping and highway beautification, it serves a purpose,” explained Dan Gullickson, Minnesota DOT’s blowing snow control shared services program supervisor. “We use nature to control blowing snow and rejuvenating these living snow fence sites will safeguard the health and vitality of the plantings.”

Where native plant preservation is concerned, the Arizona Department of Transportation uses “biomonitor” teams from Northern Arizona University or NAU to help the agency’s work crews find and relocate endangered species – including snakes, birds and fish – from construction sites.

Specifically, the biomonitor teams train construction workers and other involved in transportation projects to identify any endangered species and what to do if they come across one. The teams also monitor construction activity and help safely remove any endangered species out of harm’s way.

USDOT Initiates Wildlife-Vehicle Collision Prevention Project

The U.S. Department of Transportation recently began what it calls a “first-of-its-kind” pilot program to prevent wildlife-vehicle collisions and improve habitat connectivity.

[Above photo by the Colorado DOT]

Created and funded by the $1.2 trillion Infrastructure Investment and Jobs Act or IIJA enacted in November 2021, that pilot program – dubbed the “Wildlife Crossings Pilot Program” and managed by the Federal Highway Administration – will make grant funding available to states and communities to construct wildlife crossings over or below busy roads, add warning signs for drivers, acquire mapping and tracking tools, and more.

FHWA is making a total of $350 million available over five years, including more than $111 million in grants through its first round of funding in 2023. The agency also noted that roughly 200 people are killed – and many more are injured – annually in the United States in more than one million collisions involving wildlife and vehicles.

“There are proven practices to prevent crashes between vehicles and wildlife, and with this investment, we’re going to take commonsense steps to reduce collisions and make roads safer for rural and urban communities alike,”FHWA Administrator Shailen Bhatt said in a statement.

“Communities that may not previously have had access to funding for these critical projects can finally make roads safer while protecting wildlife and their movement corridors,” he added.

FHWA noted that grants are available for all wildlife-vehicle collision prevention activities, including but not limited to research, planning, design, and construction.

The agency added that it seeks to award funds for both non-construction and construction projects via the new program, including research on safety innovations, mapping and tracking tools, and the design and construction of overpasses and underpasses.

A recent blog post by the Pew Trusts highlights how the growing success of wildlife crossings – bridges, underpasses, and culverts designed to help animals avoid vehicle traffic – across the U.S. is drawing a surge of interest from policymakers seeking to reduce wildlife-vehicle collisions and protect animals.

Meanwhile, state departments of transportation have already been working on a variety of wildlife-vehicle collision prevention initiatives over the last several years.

For example, to date, Colorado DOT said it has built more than 60 wildlife mitigation structures crossing above or under highways throughout the state. Additionally, it has installed 400 miles of high big game fencing along state and U.S. highways or next to the interstates.

In August 2022, the agency completed a wildlife overpass and underpass on U.S. Highway 160 in the southwestern part of the state; a stretch of road where more than 60 percent of all crashes are due to wildlife-vehicle collisions.

In April 2022, the Oregon Department of Transportation received a special one-time allocation of $7 million in general funds from the Oregon legislature to invest in wildlife corridor projects statewide.

The Oregon DOT said it has had “great success” with wildlife undercrossing structures in recent years, with five crossings built to date in the state, all on U.S. 97, leading to an 86 percent reduction in wildlife-vehicle collisions.

Concurrently, a research document released in July 2022 by an international pool funded study led by the Nevada Department of Transportation provides an “authoritative review” of the most effective measures to reduce animal-vehicle collisions, improve motorist safety, and build safer wildlife crossings.

Caltrans to Help Build Highway/Rail Wildlife Overpass

The California Department of Transportation, the California Department of Fish and Wildlife (CDFW), and passenger rail provider Brightline West plan to jointly design and construct three wildlife overcrossings across Interstate 15 and the future Brightline West high-speed rail system connecting Las Vegas and Southern California.

[Above photo by Caltrans]

Those overcrossings seek to provide a sustainable and safe path for wildlife – especially for bighorn sheep – over the existing northbound and southbound highway lanes and the future 218-mile high-speed rail system to be built within the median, explained California Governor Gavin Newsom (D).

“Roadways and rail lines must be designed to connect, not divide,” he said in a statement. “This project will not only protect the precious wildlife and habitat of the Mojave Desert region but will also get people between Las Vegas and Southern California safely and efficiently – preserving one of the most popular corridors in our state.”

Beyond building those three wildlife overcrossings, the Brightline West project aims to maintain or improve more than 600 culverts and large-scale crossings under I-15 that exist today as well as restore and install desert tortoise fencing and directional wildlife exclusionary fencing.

Over the past year, Brightline, Caltrans and CDFW said they have worked together to develop a coordinated plan to fund, design, construct and maintain these wildlife overcrossings. The parties intend to fund the overcrossings using a mix of Caltrans, CDFW and Brightline West capital resources, while also seeking federal dollars.

Concurrently, a recent blog post by the Pew Trusts highlights how the growing success of wildlife crossings – bridges, underpasses, and culverts designed to help animals avoid vehicle traffic – across the U.S. is drawing a surge of interest from policymakers seeking to reduce wildlife-vehicle collisions and protect animals.

State departments of transportation across the country continue investing in a variety of wildlife crossing projects.

For example, to date, Colorado DOT said it has built more than 60 wildlife mitigation structures crossing above or under highways throughout the state. Additionally, it has installed 400 miles of high big game fencing along state and U.S. highways or next to the interstates.

In August 2022, the agency completed a wildlife overpass and underpass on U.S. Highway 160 in the southwestern part of the state; a stretch of road where more than 60 percent of all crashes are due to wildlife-vehicle collisions.

Meanwhile, a research document released in July 2022 by an international pool funded study led by the Nevada Department of Transportation provides an “authoritative review” of the most effective measures to reduce animal-vehicle collisions, improve motorist safety, and build safer wildlife crossings.

With as many as two million collisions with large mammals in the United States leading to approximately 200 human deaths every year, the review compiled, evaluated, and synthesized studies, scientific reports, journal articles, technical papers, and other publications from within the United States and beyond to determine effectiveness of 30 different mitigation measures.

Utah Introduces ‘Roadkill Reporter’ App for Motorists

The Utah Division of Wildlife Resources (Utah DWR) and Utah Department of Transportation recently introduced a free mobile phone application called “The Roadkill Reporter” to make it easier for motorists to report the location and description of any dead animals on or near roads for removal.  

[Above photo by Utah DWR

Available through both the Google Play store and Apple’s App Store, the new Roadkill Reporter app – developed over the last two years with funding from both state agencies – serves another purpose, as well: Pinpointing where the agencies need to build wildlife crossings on state highways. 

“It is important for us to understand how many wildlife-vehicle collisions occur in Utah,” explained Utah DWR Migration Initiative Coordinator Blair Stringham in a statement. “This new app will allow us to know exactly when and where collisions occur, which will help us identify hot spot areas on Utah highways. We can then work with Utah DOT and other partners to install underpasses, fencing, wildlife overpasses, and other structures to reduce collisions in those areas and keep wildlife and people safe.” 

Along with providing information about potential areas for wildlife crossings, the data collected through the app will also benefit the Utah Wildlife Migration Initiative and its efforts to learn more about the annual migration patterns of different animal species in Utah.  

The Utah Wildlife Migration Initiative is a program that tracks and studies the migration patterns of different wildlife and fish species in the state. Most of the data comes from animals wearing GPS tracking devices or from fish tagged with implanted transmitters. The tracking data benefits wildlife because biologists can identify where the animals spend large portions of time and then make habitat improvements in those areas. 

“For years, wildlife carcass data has been a key factor in Utah DOT and Utah DWR’s decision-making process to make Utah roads safer and improve wildlife population health,” noted Utah DOT Natural Resource Manager Matt Howard. “The new app will make it easier for the public to use and will give us more and better information to guide future mitigation efforts.” 

The most reported wildlife-vehicle collisions in Utah are with deer and elk. So far, in 2022, there have been 4,900 reported collisions with deer, 166 reported collisions with elk, and 20 reported collisions with moose. However, the actual number of collisions is likely twice as high, because many incidents just go unreported, Utah DWR noted. 

Many state departments of transportation have beefed up efforts to address wildlife crossing needs on state roads in recent years. 

For example, in August, the Colorado Department of Transportation recently completed the state’s newest wildlife overpass and underpass on U.S. Highway 160 in the southwestern part of the state, celebrating the accomplishment with a ribbon-cutting event. 

To date, Colorado DOT said it has built more than 60 wildlife mitigation structures crossing above or under highways throughout the state. Additionally, it has installed 400 miles of high big game fencing along state and U.S. highways or next to the interstates. 

Meanwhile, a research document recently released by an international pool-funded study led by the Nevada Department of Transportation provides an “authoritative review” of the most effective measures to reduce animal-vehicle collisions, improve motorist safety, and build safer wildlife crossings. 

With as many as two million collisions with large mammals in the United States leading to approximately 200 human deaths every year, the review compiled, evaluated, and synthesized studies, scientific reports, journal articles, technical papers, and other publications from within the United States and beyond to determine the effectiveness of 30 different mitigation measures. 

Ultimately, the report provides best management practices to reduce animal-vehicle collisions, increase habitat connectivity, and implement cost-effective solutions.

Arizona DOT Highlights Elk Fencing Project

The Arizona Department of Transportation recently highlighted the benefits of its collaboration with the Arizona Game & Fish Department (AZGFD) to reduce elk-vehicle crashes on northbound I-17 south of Flagstaff in a blog post.

[Above photo by Arizona DOT]

In 2011, AZGFD noted a high number of elk-vehicle crashes occurred along a stretch of I-17 near Munds Park.  Because a full-grown bull elk can weigh upwards of 700 pounds, crashing into something that large can destroy a vehicle and cause serious injury or death to vehicle occupants, as well as the animal. 

In 2012, after a series of studies, AZGFD and the Arizona DOT installed ungulate – “ungulate” means “hoofed mammal” – fencing in four locations near Munds Park on I-17. In most instances, Arizona DOT works crews modified existing right-of-way fences with bolts and barbed wire, eliminating the need for completely new fencing and poles.

This project produced almost immediate results, both agencies said. From the 20 documented elk-vehicle crashes that occurred along this strip of I-17 from 2007 to 2010, only one occurred between 2010 and 2014.

Arizona DOT said this is but one example of the state mitigating wildlife issues through partnerships among multiple agencies. The agency noted it also collaborated with AZGFD to construct wildlife underpasses and elk crossings along State Route 260 east of Payson and desert bighorn sheep overpasses near historic Hoover Dam on US 93.

The wildlife protection efforts undertaken by Arizona DOT are reflective of similar initiatives spearheaded by state departments of transportation nationwide.

For example, in July and August every year, the North Carolina Department of Transportation temporarily lowers speed limits from 55 mph to 20 mph on the William B. Umstead Bridge – locally known as the old Manns Harbor Bridge – at dusk and dawn during the roosting period of purple martin bird flocks.

NCDOT noted in a statement that it has collaborated with the Coastal Carolina Purple Martin Society since 2007 to educate the public about the purple martin flocks, to protect both the birds and motorists.

Meanwhile, the Colorado Department of Transportation recently completed the state’s newest wildlife overpass and underpass on U.S. Highway 160 in the southwestern part of the state, celebrating the accomplishment with a ribbon-cutting event.

To date, Colorado DOT said it has built more than 60 wildlife mitigation structures crossing above or under highways throughout the state. Additionally, it has installed 400 miles of high big game fencing along state and U.S. highways or next to the interstates.

On the research front, a report released by an international pool funded study led by the Nevada Department of Transportation in July provides an “authoritative review” of the most effective measures to reduce animal-vehicle collisions, improve motorist safety, and build safer wildlife crossings.

With as many as two million collisions with large mammals in the United States leading to approximately 200 human deaths every year, the review compiled, evaluated, and synthesized studies, scientific reports, journal articles, technical papers, and other publications from within the United States and beyond to determine effectiveness of 30 different mitigation measures.

Ultimately, the report provides best management practices to reduce animal-vehicle collisions, increase habitat connectivity, and implement cost-effective solutions, Nevada DOT said.

Arizona DOT Protects Plants During I-17 Project

As the Arizona Department of Transportation starts work on the  I-17 Improvement Project from Anthem Way to Sunset Point, it is taking steps protect the natural landscape along this stretch of scenic highway corridor as well. 

[Above photo by the Arizona DOT]

The agency said its work crews are removing native vegetation – including saguaros, palo verde trees and ocotillos – from the 23-mile project corridor to temporary nurseries, before eventually replanting them alongside an improved and wider highway. 

Drivers who regularly travel I-17 between Anthem Way and Sunset Point may see some of what the Arizona DOT describes as “plant salvage” work during the next several months. Plant salvage crews from the Kiewit-Fann Joint Venture developer team will collect hundreds of viable native trees, “accents” (such as ocotillos and yuccas), saguaros and other cacti from the construction area. Altogether, roughly two-thirds of the right-of-way along the 23-mile project area will remain undisturbed, meaning no plant salvaging will be necessary.

“October is usually the prime time for salvaging the plant material, just because our temperature is not too hot and not too cold,” said David Casselbury, a landscape architect with Arizona DOT, in a statement. “We’re hoping the general public will enjoy driving along the highway and seeing this plant material back in its natural environment once the project is complete.” 

The salvaged trees and cacti are not the only plants returning to the natural landscape once the improvement project is finished, the agency added, as it plans to add native seed mixes and nursery-grown plants to the highway construction area. Those efforts help to achieve the long-term goal of successfully revegetating areas within the construction area considered “landscape-able” with a mix of plants that will thrive and restore the natural environment for years to come. 

Restoring native plants has been an integral part of many Arizona DOT projects for more than 35 years, according to the agency.

For example, Arizona DOT spent the last four years relocating a rare and endangered species of cactus growing near the Pinto Creek bridge replacement project along U.S. 60 near Globe-Miami. Initiated in 2018, this relocation effort is the latest step in a long-term partnership between the Arizona DOT and the Desert Botanical Garden in Phoenix to protect hedgehog cactuses that only grow in one tiny area of the state.

The agency also relies on ‘biomonitor’ teams from Northern Arizona University or NAU to help its work crews find and relocate endangered species – including snakes, birds and fish – from construction sites.

Specifically, those biomonitor teams train construction workers and other involved in transportation projects to identify any endangered species and what to do if they come across one. The teams also monitor construction activity and help safely remove any endangered species out of harm’s way.

Colorado DOT Building I-70 Wildlife Crossing

The Colorado Department of Transportation recently began work on the I-70 Genesee wildlife-crossing project, one of several I-70 Floyd Hill projects to improve both highway safety and traffic flow ahead of construction on the $700 million main project.

[Above image by Colorado DOT]

The I-70 Genesee wildlife-crossing project consists of a dedicated wildlife underpass going under I-70 between the exits for Lookout Mountain and Genesee. Additionally, crews will place wildlife fencing along both east and westbound I-70 that extends from the Genesee Exit to the Lookout Mountain Exit.

The agency noted that this area has the highest number of wildlife-vehicle collisions on the I-70 Mountain Corridor east of the Eisenhower-Johnson Memorial Tunnel.

“The new underpass at I-70 Genesee is the first major wildlife crossing to be constructed along the I-70 Mountain Corridor, and it will allow wildlife to safely cross underneath the interstate at a location which has historically been a hotspot for wildlife related crashes,” said Colorado DOT Executive Director Shoshana Lew in a statement.

“Reducing animal-vehicle conflicts and improving wildlife connectivity is a major element to the overall improvement of travel time reliability, safety, and mobility in the I-70 Floyd Hill project area,” she added.

The plan calls for construction of two new I-70 bridges, followed by excavation under those bridges to create the wildlife underpass. Once the underpass is complete, crews will install the wildlife fencing. Altogether, bridge and underpass construction should wrap up by the spring of 2024.

To date, Colorado DOT has built more than 60 wildlife mitigation structures crossing above or under highways throughout the state. Additionally, it has installed 400 miles of high big game fencing along state and U.S. highways or next to the interstates.

In August, the agency completed the state’s newest wildlife overpass and underpass on U.S. Highway 160 in the southwestern part of the state.

In October 2021, Colorado DOT and the Colorado Parks and Wildlife agency completed wildlife underpasses along a rural stretch of Interstate 25 between Colorado’s two largest cities, Denver and Colorado Springs.

That wildlife mitigation system is part of a $419 million transportation improvement project – known as the I-25 South Gap project – that aims to improve safety and travel on 18 miles of I-25 south of the Denver metropolitan region; a route that more than 87,000 motorists use on a daily basis.

Wildlife, Environment Key Focal Points of I-70 Project

Key initial components of the $700 million I-70 Floyd Hill project kicked off recently by the Colorado Department of Transportation include the construction of wildlife crossings and fences as well as a “mobility hub” to provide transit and electric vehicle services.

[Above photo by the Colorado DOT]

The project will rebuild a seven-mile stretch of I-70 from exit 248 northwest of Evergreen to exit 241 in eastern Idaho Springs and work to eliminate a bottleneck on one of the most congested stretches of the I-70 Mountain Corridor.

Early construction begins this fall with a new wildlife crossing at Genesee and roundabouts along US 40 between Evergreen and Floyd Hill, with major construction on the corridor starting in spring 2023.

“The I-70 Floyd Hill Project will improve travel time, reliability, and safety,” explained Shoshana Lew, executive director of the Colorado DOT, in a statement.

“By eliminating the bottleneck at Floyd Hill, the project will significantly ease congestion and decrease the number and severity of crashes through more consistent traffic flow and speeds,” she said. “The project will provide alternate emergency access through a newly connected frontage road system that strengthens safety and mobility for thousands of Coloradans that rely on I-70 to access their communities and for the millions who visit the mountains annually. Essential to this project are multi-modal options, including our Pegasus van service which already started last spring, and improvements to the Greenway trail for pedestrians and cyclists to enjoy Clear Creek County.”

Key wildlife and environmental improvements involved in the I-70 Floyd Hill project include:

  • Improving the multimodal Greenway trail.
  • Building wildlife crossings and fencing, and restoring nearby creek and riparian areas to protect and preserve the local environment and wildlife.
  • Developing a mobility hub with electric vehicle infrastructure and accessibility options that integrate into the state’s I-70 transit service, including the new Pegasus van service added in May 2022 to the corridor.
  • Providing permanent air quality monitors and coordinating rural broadband access with local communities.

FHWA Helps Initiate $1B Fish Passage Program

The Federal Highway Administration, along with the U.S. Fish & Wildlife Service and the National Ocean and Atmospheric Administration, recently made $1 billion in grants available over the next five years via a new “fish passage” program established by the $1.2 trillion Infrastructure Investment and Jobs Act or IIJA enacted in November 2021.

[Above photo by the WSDOT]

Formally entitled the “National Culvert Removal, Replacement and Restoration-Culvert Aquatic Organism Passage” program, it seeks to help communities remove and repair culverts found under roads that can prevent fish passage. FHWA said the program’s aim is to help state, local, and tribal governments protect local economies that count on healthy fisheries while also making key roads less prone to flooding.

“Many tribal and underserved coastal communities depend on thriving fish populations for their livelihoods, and this program, which will remove, replace, and repair harmful culverts, will improve the natural environment and the economic wellbeing of Tribal, coastal, and low-lying communities,” said Stephanie Pollack, FHWA’s acting administrator, in a statement.

“[These] grants will both help restore fish populations and make roads more durable and resilient to climate events, creating cascading benefits for communities that rely on the fisheries economy,” she added.

The agency explained that barriers to freshwater migration are a major cause of declining populations of anadromous fish, which live primarily in the ocean, but return to freshwater streams to spawn. This fish passage program seeks to help remove or redesign culverts and “weirs” that create such barriers, allowing anadromous fish populations – including salmon, sturgeon, lamprey, shad, and river herring – to access freshwater habitats for spawning.

FHWA noted that a “weir” allows for the controlled passage of water over a low-headed dam, while a culvert allows for the subterranean passage of water through a channel underneath an obstacle, such as a road.

Tribes, state, and local governments can apply for a portion of the $196 million of fiscal year 2022 funding currently available through this new program via a notice of funding opportunity issued by FHWA on October 6.

Across the country, state departments of transportation regularly provide support to a wide variety of efforts aimed at protecting numerous wildlife species and their habitats – such as birds, pollinating insects, bats, cactus, and of course fish.

For example, the Arizona Department of Transportation recently illustrated in an April blog post how ‘biomonitor’ teams from Northern Arizona University or NAU help the agency’s crews find and relocate endangered species – including snakes, birds, and fish – from construction sites.

Specifically, those biomonitor teams train construction workers and others involved in transportation projects to identify any endangered species and what to do if they come across one. The teams also monitor construction activity and help safely remove any endangered species out of harm’s way.

In terms of fish protection, the Washington State Department of Transportation went so far as to build an “engineered creek” to provide a better and safer avenue to spawning areas.

The engineered creek includes native vegetation, strategic bends, and elevation changes designed to support “every life cycle of fish,” WSDOT explained. It features places for fish to lay eggs and hide from predators, allowing the salmon to “naturally move” from freshwater to saltwater habitats and back again.

University Ecologists Studying Idaho’s Roadside Vegetation

Ecologists at Idaho State University are working with the Idaho Transportation Department to turn state roadsides into veritable “Swiss army knives” of vegetation so they are both more fire-resistant and more welcoming to pollinating insects.

[Above photo by Idaho State University]

Joshua Grinath, assistant professor of community and global change ecology at the school, and his students recently wrapped up the first growing season at three experimental sites along I-15 in Eastern Idaho.

They are working with three different types of ecosystems at those sites, figuring out how to make the land more hospitable to native plants and less so for invasive weeds. That research also includes increasing the habitat’s fire resistance, while becoming a more attractive habitat for pollinators like bees and butterflies.

[Editor’s note: In a July 2021 episode of the Environmental Technical Assistance Program or ETAP Podcast, Matthew Quirey – a  landscape design and research fellow with The Ray – explained how roadside landscapes, more often termed the “right-of-way,” are now being viewed as “habitat assets” instead of maintenance burdens among state departments of transportation.]

Grinath’s research team is testing how different combinations of mowing, herbicide treatments, and seed applications can improve native plant survival in those roadside locales.

This research received its primary funding via a grant from the Idaho Transportation Department, with additional funds supplied by ISU’s College of Science and Engineering, as well as the school’s Office for Research.

In September, the team received additional funding to test how adding certain types of bacteria, fungi, and micronutrients to the soil may improve restoration.

“Roadside management is most commonly focused on a single issue, such as erosion control, but other challenges may be able to be addressed simultaneously,” Grinath explained in a blog post. “Considering these issues simultaneously will help Idaho Transportation Department save taxpayers money and address urgent land management concerns.”