I am writing to urge the Bureau of Land Management (BLM) to deny Utah Department of Transportation’s right-of-way application for the Northern Corridor Highway through Red Cliffs National Conservation Area (NCA). There are better routes that keep Red Cliffs NCA intact while protecting recreation, wildlife habitat, cultural resources, and scenic vistas.
I respectfully request that the federal agencies comprehensively analyze the following issues as they formulate the Final Supplementary Environmental Impact Statement (SEIS) for the proposed Northern Corridor Highway project:
Alternatives. The Draft SEIS clearly shows that in comparison to the alternatives outside the NCA, a Northern Corridor Highway route through Red Cliffs NCA would:
- Negatively impact homeowner property values and quality of life values in the Green Springs, Middleton, Warm Springs, and Brio neighborhoods;
- Affect the highest number of historic properties and Indigenous resources;
- Increase the spread of noxious weeds and invasive species;
- Increase the probability of catastrophic wildfire on a fire return interval as short as every 5-10 years;
- Degrade the recreation user experience, landscape character, and scenic vistas; and
- Negatively impact more acres of desert tortoise habitat and lead to the translocation and indirect impact of more adult tortoises.
Fulfilling Promises Made. The Red Cliffs NCA is an unsuitable location for a highway and the Northern Corridor Highway would compromise the very values that led to the establishment of Red Cliffs in 1995 by Washington County leaders. More protections were added in 2009 when Congress passed the Omnibus Public Land Management Act, establishing the Red Cliffs NCA with the purpose “to conserve, protect, and enhance, for the benefit and enjoyment of present and future generations, the ecological, scenic, wildlife, recreational, cultural, historical, natural, educational, and scientific resources of the National Conservation Area.” Additionally, it emphasized the imperative to safeguard every species within the NCA and those designated as threatened or endangered. I strongly urge the federal agencies to analyze the impacts of the proposed highway in this context and evaluate and disclose whether the proposed highway is consistent with BLM’s statutory direction.
Taxpayer Money. The agencies must include a detailed accounting of the value of all lands acquired with public funds that would be directly or indirectly impacted by the highway alternatives (including the additional Section 6 Lands and Land and Water Conservation Fund Lands detailed in the Draft SEIS). Taxpayers deserve a transparent analysis of how land purchased to permanently protect conservation and recreation purposes would be degraded by a four-lane highway through Red Cliffs NCA.
Impacts to the Mojave Desert Tortoise. I request that the agencies further evaluate the species-wide impacts of the highway alternatives to the Mojave desert tortoise population in Red Cliffs—especially given the species’ extinction trajectory and the recent “uplisting” of the tortoise to “endangered” under the California Endangered Species Act. Scientific research shows that tortoise populations in Red Cliffs are important to the tortoise gene pool in surrounding areas beyond Washington County. Furthermore, FWS scientists assert that threats resulting in mortality, permanent habitat loss, habitat fragmentation, and habitat degradation are among the most significant to the Mojave desert tortoise. I ask that BLM and FWS compare and analyze how the highway alternatives would impact the success of species management plans (including restoration of burned habitat and minimization of threats like wildfires, development, and human activities) critical to range-wide population and habitat integrity.
Zone 6 Assumptions. The Draft SEIS includes impacts from a potential future scenario where Zone 6 is developed if the highway right-of-way through Red Cliffs NCA is denied. These lands are worthy of permanent protection and are not a bargaining chip. The BLM and FWS should consider options to maintain or bolster the protection of Zone 6 lands as habitat necessary in maintaining and recovering the tortoise, which is on an extinction trajectory and faces increased fire risk due to climate change, population growth, and surging invasive plants—especially in light of recent fires and the increased take (or number of tortoises to be killed) requested under the 2020 Habitat Conservation Plan.
Verified Traffic Analysis. I urge BLM to conduct an independent review and verification of Washington County’s updated transportation analysis (including the model’s input parameters, values and assumptions). The BLM should share this information with the public, since it will be unavailable during the Draft SEIS public comment period. It is a conflict of interest for Washington County to fund this traffic analysis, and the results should only be included in the final SEIS if the assumptions, results, and conclusions can be independently verified. Moreover, BLM should evaluate the appropriateness of including the updated traffic analysis given the SEIS process only includes “those resources that warrant reconsideration based on new information or changed conditions beyond what was presented in the Final EIS.”
