5. The cumulative effects are not adequately addressed


What the Draft EIS does or doesn’t say:

  • The Draft EIS states that it’s important to analyze the compounding impact the NCH will have on the environment when added to other past, present, and reasonably foreseeable future actions.
  • However, the Draft EIS only considers impacts from projects (roads, utilities) planned 15-20 years in the future[1].

The problem:

  • By limiting its attention to the next 15-20 years, the BLM ignores impacts from additional planned roads and infrastructure, including road projects planned in the 2019-2050 Draft Regional Transportation Plan.[2] The Western Corridor, extensions of Navajo Dr. and Green Valley Dr., and the Babylon Road are excluded due to the inappropriately short BLM planning horizon. These roads would further damage and fragment Red Cliffs and Zone 6, and would make the poor Zone 6 mitigation argument even worse. (See map below).
  • The Draft EIS provides no justification for concluding Zone 6 can mitigate damage caused by the NCH, much less any other damage incurred by development elsewhere in the county.
  • The Draft EIS discloses that the Upper Virgin River Recovery Unit (home to the tortoises in the Red Cliffs) is the smallest, most isolated recovery unit and densities of tortoises there are declining by 3.2 percent per year[3].
  • The cumulative impacts of Lake Powell Pipeline on tortoise habitat were not adequately addressed.

Commenting guidance:

  • The BLM’s planning horizon must include all planned future developments that negatively impact Red Cliffs and Zone 6, and not be limited by the 15-20-year time frame.
  • The planned future roads and pipelines, on top of the NCH, will cause direct habitat loss, degradation, fragmentation, and take of the threatened Mojave desert tortoise.
  • In an area this vulnerable, the “death by a thousand cuts” approach to managing Red Cliffs can not be allowed to continue.

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

Add a personal note:

  • Are you aware of any cumulative impacts (past, present or future projects) that may interact with or compound the damage the new highway will cause to Red Cliffs? If they didn’t end up in the Reasonably Foreseeable Future Projects or Actions table[4] BLM needs to know!
  • Why is it important to stop this “death by a thousand cuts” approach to managing the Red Cliffs?


[1] DEIS Vol 2, section

[2] 2019-2050 Regional Transportation Plan, Babylon Road on page 21; Western Corridor on page 20. Extensions of Green Valley Dr. and Navajo Dr. have been removed from this plan.

[3] DEIS Vol 2, section 3.48

[4] DEIS Vol 2, page 3-179


Map of planned highways that would impact Zone 6

Projects 132 and 133 are two highways that would fragment Zone 6. Project 137 would hug its western boundary, breaking the Red Bluffs Area of Critical Environmental Concern in half and preventing tortoises from crossing. The future highways planned for Zone 6 will devastate the Mojave desert tortoise population there.