Points for Highway Scoping Comments

Comments are due January 6, 2020

HOW TO SUBMIT YOUR COMMENT

COMMENTS ARE PUBLIC

PLEASE INCLUDE YOUR CONCERNS ABOUT THE HIGHWAY AND WHAT POINTS YOU THINK SHOULD BE ANALYSED IN THE EIS.

BLM and US Fish Wildlife Service Should Study these Issues in the Draft Environmental Impact Statement (EIS):

  1. Alternative road improvements for the Northern Corridor Highway traffic that are located outside the Red Cliffs National Conservation Area and Red Cliffs Desert Reserve. READ MORE
  2. The direct, indirect and cumulative effects the highway would cause to the 9 resource values the NCA was designated to protect, recover and enhance in the 2009 Omnibus Public Lands Management Act (OPLMA). They include: Ecological, Scenic, Scientific, Cultural, Historical, Educational, Natural, Recreational, Wildlife including the threatened Mojave desert tortoise and other threatened, endangered, sensitive, and non-listed species found in the Red Cliffs NCA/Reserve. READ MORE
  3. The direct, indirect and cumulative effects to the threatened Mojave desert tortoise and its critical habitat from a highway inside the Red Cliffs NCA/Reserve which is currently home to the densest population of threatened tortoise anywhere in its range. BLM and USFWS should consider the cumulative impacts resulting from the direct mortality during and following construction; introducing construction activities into a dedicated Reserve area; habitat fragmentation; direct habitat loss; impairing the efficacy of an already minimally sized reserve and tortoise population; degrading habitats that would not otherwise be disturbed; the spread of exotic and invasive plant species; increasing the risk of fire, which has already decimated tortoise populations in the Reserve; increasing predation of tortoises by common ravens and coyotes; possibly promoting disease and impairing tortoise health by introducing chemicals associated with vehicles; and, increasing access to Reserve areas that could result in poaching and vandalism of tortoises of the federal take authorization previously granted under the ESA; the disruption of natural washes that provide water for plants for food for the tortoise; the continued drainage of chemicals from the highway; and the lights and noise of traffic. READ MORE
  4. The cost-benefit analysis of a highway inside the Red Cliffs NCA versus road improvements outside of the NCA.
  5.  The effects of all the current land uses in Zone 6 on tortoise habitat proposed as mitigation for the highway, including the following: Zone 6 is scarred by illegal dump sites, target shooting, off-trail mountain biking, OHV/ATV use, and more. The land hosts major competitive sporting events that are not compatible with threatened species recovery. Finally, 100% of the tortoises in Zone 6 are already protected under the Endangered Species Act which applies to both the BLM and State lands in Zone 6. READ MORE
  6. The conflict surrounding how the Red Cliffs Desert Reserve’s 62,000 acres were set aside for permanent protection as mitigation for releasing the 300,000 acre of private and state land for economic development in December 1995. But now the county has changed its mind and wants to protect marginal habitat in ZONE 6 as mitigation across town in exchange for a highway through the best tortoise habitat in the NCA.
  1. The concern that the proposed highway undermines and violates federal laws (Endangered Species Act, Omnibus Public Lands Management Act, Federal Land Management Policy Act); agency policy (BLM Manual 6220 – National Monuments, National Conservation Areas, and Similar Designations); resource management plans (Red Cliffs NCA RMP, St. George Field Office RMP) and the Washington County Habitat Conservation Plan, and establishes a dangerous precedent for harming National Conservation Lands and Threatened & Endangered Species in other parts of the country.
  2. The effects on the tortoise and its habitat from utilities (power, water, gas, etc.) that could be constructed in the Right of Way for the proposed Northern Corridor Highway now and in the future. As well as impacts from future utility developments that could be constructed in or near the Right of Way for the proposed Northern Corridor Highway, including applications to expand this Right of Way to accommodate such projects. In 2018, Dominion Energy proposed to route a major natural gas pipeline through the Red Cliffs NCA/Reserve following the path of the proposed Northern Corridor Highway. They anticipated that this project would have created a new disturbance area where the pipeline route left the corridor approximately 1,640 feet long.

 

ADDITIONAL RESOURCES (Do Not Copy/Paste into your comment)