2. BLM failed to select the best alternative in preferring the NCH


What the Draft EIS does or doesn’t say:

  • The BLM-preferred alternative for the NCH travels through the Red Cliffs NCA[1].
  • BLM offers no explanation for this preference.
  • The Draft EIS shows that the two alternatives located outside of Red Cliffs reduce traffic congestion better[2] than the NCH and don’t cause environmental damage[3].
  • The Draft EIS doesn’t disclose the cost of any of the alternatives, but it’s clear that making improvements to existing roadways will cost far less than building a new highway in a National Conservation Area.
  • Conserve Southwest Utah’s (CSU’s) Community Transportation Alternatives to the NCH weren’t given fair analysis in the Draft EIS. Some were considered, but with negative modifications.

The problem:

  • Alternatives outside the protected area (the Red Hills Parkway Expressway and the One-way Couplet) provide better traffic relief at key intersections than the BLM-preferred alternative and cause much less damage to the environment, quality of life, and the threatened Mojave desert tortoise[4].
  • The Draft EIS failed to explain or justify its decision to dismiss 3 of CSU’s alternatives.
  • The Draft EIS failed to consider the cost of the NCH to the taxpayer when data exists. Plans show[5] that the NCH and connected projects will cost $150 million. Other plans show that the Red Hills Parkway Flyovers could be modified to cost as little as $17 million[6].
  • CSU’s alternative 6 (the lack of implementing growth planning integrated with transportation planning) is the underlying reason for the new highway’s need statement. Failure to implement smart growth planning cannot be dismissed as being out-of-scope.
  • The DEIS considered two CSU alternatives outside Red Cliffs (Red Hills Parkway Expressway and One-way Couplet), but they were modified or misinterpreted to maximize their cost and business impact[7].

Commenting guidance:

  • BLM fails to explain why the NCH is their preference. This explanation should be provided for the public understanding.
  • BLM ignored its own analysis on the efficacy of the Red Hills Parkway Expressway and the One-way Couplet in solving the alleged congestion issues, and appears to be bowing to political pressure.
  • The Secretary of the Interior and BLM cannot legally approve the NCH since it is not compatible with the purpose of the Red Cliffs NCA.
  • Washington County should:
      • Optimize the design and implement the Red Hills Parkway Expressway and One-way Couplet Alternatives.
      • Revisit and implement Vision Dixie (CSU alternative 6) in order to avoid additional self-inflicted growth and related traffic issues.
      • Properly consider the other CSU alternatives in future planning. 

Use elements of the “problem” statements to bolster your points. 

Add a personal note:

  • What are your specific concerns with the BLM-preferred Alternative 3?
  • Why do you support the Red Hills Parkway Expressway? The One-way Couplet?
  • How would these alternatives minimize damage to the resource values and species in Red Cliffs that you care about?
  • What is the value of protecting Red Cliffs in a rapidly-growing community?
  • Why should Red Cliffs be considered “off-limits” to roads and development?

Scroll down to see an important map and tables. 

[1] DEIS Executive Summary, section ES-4.1, page ES-6

[2] DEIS Vol 3, Appendix J, page 16, table 4

[3] DEIS Executive Summary, section ES-5, table ES.5.1

[4] DEIS Executive Summary, section ES-5, table ES.5.1

[5] CSU Comments on the Draft 2019-2015 Regional Transportation Plan, Pg. 8-9

[6] UDOT Red Hills Parkway Flyover Analysis

[7] CSU’s Community Transportation Alternatives, alternative 1 (Flyover) and 2 (improving Red Hills Parkway) pages 9 and 10 roughly correspond to the DEIS alternatives 5 (Red Hills Parkway Expressway) and 6 (Widening Red Hills Parkway). However, the DEIS alternatives (DEIS Vol 3, Appendix J section 4.7 and 4.8 on page 11) cause more business impact.  CSU alternative 4 (Downtown Loop) corresponds to DEIS alternative 9 (section 4.9 on page 12), except causes more impact to businesses and requires the median removed on St George Bvld.



A- Map of Northern Corridor Highway alternatives analyzed in the Draft EIS


B- Table comparing congestion relief at key intersections among the alternatives

The CSU Alternatives score higher than the County/UDOT/BLM Alternatives. LOS= Level of Service at peak traffic times at key intersections projected for the year 2040. Green= good. Yellow= fair. Red= poor. Dark red= fail. 

C- Table comparing travel times among the alternatives


Travel times are less for the CSU Alternatives.

D- Table comparing Mojave desert tortoise impacts among the alternatives

Note that the Red Hills Parkway Expressway and One-way Couplet cause little to no damage to the threatened Mojave desert tortoise and its habitat.