Issue 7 - Conserve Southwest Utah

7. The highway would require damaging changes to the Red Cliffs’ management plans

What the Draft EIS does or doesn’t say:

Changes to management plans necessary to accommodate the NCH include the following[1]:
- - Allow the highway to travel through an “avoidance area”
  - Downgrade the visual rating and allow damage of scenery
  - Downgrade the recreational rating and allow damage of the visitor experience

The problem:

BLM would have to grant a “one-time exception” to allow the NCH in an avoidance area where sensitive resources like the threatened Mojave desert tortoise, its critical habitat and archaeological sites are supposed to be protected. Such exceptions are “strongly discouraged”. Furthermore, the NCH right-of-way is larger than the current avoidance area can fit[2].
There is no justification to downgrade the Visual Resource Management (VRM) class to accommodate the NCH. Since the NCH would dominate the view of the casual observer, it doesn’t conform to the current objective to retain the scenery[3]. The NCH would cause long-term, negative visual impacts from road cuts and fills, vehicle traffic, lighting, vertical elements, interchanges and two large bridges[4]. It would be a new and prominent feature in an otherwise undeveloped landscape, causing a negative intrusion onto the landscape[5].
There is no justification to downgrade the Special Recreation Management Area around the NCH. Recreators would be subject to stark or obvious visual change to the natural setting, frequent highway noise, increased contact with people on trails, and the ability to hear groups of people on a more constant basis[6].

Commenting guidance:

It is very concerning that BLM would weaken protections for Red Cliffs to allow the NCH.
BLM should not allow a one-time exception to grant a right-of-way in an Avoidance Area because they haven’t met the criteria that would allow them to do this. The Draft EIS fails to show that the NCH can be built without causing the “take” of federally-listed species; the adverse modification of designated critical habitats; and adverse effects to cultural/historical sites or eligible properties. These conditions have not been met[7].
BLM is required to consider options for locating the highway outside of Red Cliffs. Two feasible alternatives to the NCH were studied and found effective[8].
BLM should not downgrade the Visual Resource Management Class to allow a highway. This action would defeat the purpose of having a National Conservation Area. The NCH violates the objective to partially retain the existing character of the landscape.
BLM should not downgrade the recreation class to accommodate the NCH because this change would negatively impact the experience of quiet, non-motorized recreation in the Red Cliffs, especially on the T-bone, Cottontail, and City Creek Trails.
BLM should definitely dismiss any alternative that would allow construction of above and below ground utilities in the NCH right-of-way, because power poles, gas lines, towers, etc. would further degrade the scenic qualities of the landscape and would put the threatened Mojave desert tortoise at risk.

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

Add a personal note:

Why is the scenery and recreation protected in Red Cliffs important to you? How do these values improve your life?
How would your enjoyment of the scenery and recreation opportunities in Red Cliffs be negatively impacted by the new highway?
What trails do you use in Red Cliffs from which the new highway would be visible? How would the highway detract from your experience? (See map below).

[1] DEIS Vol 2, page 2-9, Table, Alternative B Column

[3] DEIS Vol 2, section 3.13.2.3

[4] DEIS Vol 2, Section 3.13.2.3 and 3.13.2.4

[5] DEIS Vol 2, section 4.1.5.7 and 4.1.5.8

[6] DEIS Vol 2, section 3.15.2.3

[7] DEIS Vol 2, page 2-9, Table, Alternative A Column, Section E

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