4. A proposed addition to Red Cliffs (Zone 6) does not mitigate NCH damage


What the Draft EIS does or doesn’t say:

  • The Draft EIS claims that Zone 6 can mitigate for damage caused by the NCH to the threatened Mojave desert tortoise and its critical habitat[1].
  • The Draft EIS doesn’t address the impacts of 3 major highways, planned after the year 2040, that would adversely impact tortoise habitat in Zone 6.
  • There are many cases where the Draft EIS discloses the poorer condition of Zone 6 compared to the Red Cliffs.
  • The management of the 6,800 acres in Zone 6 is split fairly evenly between SITLA (the state school trust with a mission to generate revenue by selling and leasing its lands) and the BLM, most of which is already protected in an Area of Critical Environmental Concern.
  • The Draft EIS discloses the poor quality of many areas in Zone 6, but fails to address the need for rehabilitation[2].

The problem:

  • Since SITLA is required to make money from their lands, there is no assurance of permanent protection for their part of Zone 6. Washington County plans to purchase a fraction of the SITLA land[3], leaving the rest to be acquired through tedious land exchanges that require funding that may not be available in the future.
  • Zone 6 can’t make up for damage the NCH will cause to the threatened Mojave desert tortoise and its habitat in Red Cliffs because it is a heavily-recreated and damaged area. Additionally, the long-term viability of the tortoise population there has not been proven[4].
  • Zone 6 can’t make up for damage the NCH will cause to the purpose of the Red Cliffs NCA, including its ecological, scenic, wildlife, recreational, cultural, historical, natural, educational, and scientific resources.
  • Zone 6 is comprised of land that cannot be permanently protected (SITLA) and land that is largely already-protected (ACEC). It is disconnected from Red Cliffs and cannot be considered as mitigation for the NCH.
  • Controlling recreation in Zone 6 would be difficult. Many uses that are incompatible with recovery of threatened species would be allowed to continue, including OHV travel, target shooting, and five annual competitive mountain bike races[5].
  • The Draft EIS fails to show how adding Zone 6 can make up for damage the NCH would cause to Red Cliffs:
      • The stability of the Zone 6 tortoise population is not addressed, and the accuracy of tortoise population estimates is questioned[6].
      • The scenic/visual quality of Red Cliffs is greater than Zone 6[7].
      • Zone 6 is a heavily-recreated, damaged area that is home to multiple conflicting recreational uses, many of which will continue if Zone 6 is added. Detailed plans for how Zone 6 would be managed, and at what cost, were not included in the Draft EIS.
      • The presence of cultural resources (petroglyphs, etc.) in Zone 6 cannot make up for damage to 8 unique National Register of Historic Place-eligible sites in Red Cliffs that would be caused by the NCH[8].
      • The Draft EIS states that Zone 6 contains 50 miles of trails open to motorized OHV use, 30 miles of single-track, non-motorized trails, and 42 miles of social trails, but fails to show how recreation in Zone 6 could mitigate for loss of quiet, non-motorized recreation on trails in Red Cliffs[9].
  • Despite all of this, if BLM and USFWS declare that Zone 6 is effective mitigation, the NCH can proceed.

Commenting guidance:

  • The Draft EIS discloses damage caused by the NCH to threatened wildlife, scenery, recreation and cultural sites, but fails to show how Zone 6, a disconnected area located ten miles away, can provide mitigation for that damage.
  • Zone 6 is composed of land that cannot be permanently protected (SITLA) and land that is already protected. There is nothing to be gained in protection by adding Zone 6.

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

Add a personal note:

  • Have you spent time in Zone 6 recreating? What has your experience been like?
  • Do you think that existing recreation uses in Zone 6 are compatible with recovery of the threatened Mojave desert tortoise?
  • Do you think that Zone 6 can make up for damage caused to your favorite resources (trails, scenery, wildlife, etc.) in Red Cliffs?

See important maps below.

[1] DEIS Vol 2, page 3-39 (poor quality)

[2] DEIS Vol 2, page 3-39

[3] DEIS Vol 2, page 2-18. Washington County plans to purchase three times the acres of land inside the NCH right-of-way (about 860 acres) leaving approx. 2,400 acres for BLM to acquire through land trade.

[4] DEIS Vol 2, page 3-65 (viability questionable) and 3-49 (survey methods incomparable)

[5] DEIS Vol 2, page 3-129 and 3-134

[6] DEIS Vol 2, page 3-49

[7] DEIS Vol 2, pages 3-101 vs. 3-105 for comparison of scenic values

[8] DEIS Vol 2, page 3-119

[9] DEIS Vol 2, page 3-129


Map of Zone 6



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