Letter to the Editor: National Environmental Policy Act process is opportunity for public involvement

Stock image, St. George News

OPINION — As one of the fastest growing counties in the nation, Washington County’s future quality of life, environmental health and economic sustainability will be greatly influenced by key decisions that our public officials will soon be making.

As such, every county resident has a stake in these forthcoming decisions because we will all have to live with the resulting consequences.

For example, the federal National Environmental Policy Act process is expected to begin in late August on at least three significant and interconnected proposed actions.

These actions are: 1) the county’s proposal to the U.S. Fish and Wildlife Service to renew the county Habitat Conservation Plan under the Endangered Species Act for 25 years; 2) the Utah Department of Transportation’s right-of-way application to the Bureau of Land Management to construct the increasingly controversial proposed Northern Corridor/Washington Parkway highway through the Red Cliffs Desert Reserve and BLM Red Cliffs National Conservation Area; and 3) related proposals to amend the BLM Red Cliffs NCA Plan and the BLM Saint George Field Office Plan.

A separate NEPA environmental analysis process may resume soon with release of the long-anticipated Draft Environmental Impact Statement on the highly controversial proposed Lake Powell Pipeline.

Stock image of Lake Powell, St. George News

The BLM Saint George Field Office is expected to release a preliminary Environmental Assessment under NEPA later this year for its proposed transportation management plan. And the Dixie Metropolitan Planning Organization recently released their 2019-2050 Regional Transportation Plan for a public comment period ending Aug. 3 Many of the proposed projects in this Regional Transportation Plan will be subject to future NEPA analysis.

Despite the differences among these varied proposed actions, they have at least two things in common: they will have interconnected or overlapping cumulative effects, and they will collectively shape much of the county’s future in terms of how or whether an appropriate balance is struck between development and conservation.

Will transportation and land use planning be proactive and coordinated in service of fulfilling modern Vision Dixie and smart growth principles? Or will transportation planning follow reactive, ad hoc sprawl development patterns and sacrifice past conservation commitments in its wake?

Will we learn from the sprawl and related transportation mistakes of other metropolitan areas, or repeat them? Will we retain a unique character and world-class scenery, or succumb to becoming another congested, drab and polluted place like those many of us came here to escape? Should the priority be to serve the greater public interest in maintaining our beautiful scenery and environmental health, or rather to help rich developers and land speculators become richer?

Although proponents of these proposed actions tend to want to keep the NEPA analysis for each of them as narrow, limited and separate as possible, the factual reality is that they have many connections and raise significant questions at a larger scale.

For example, the Dixie Metropolitan Planning Organization’s current 2019-2050 Regional Transportation Plan has several road projects that apparently would connect to or serve the Northern Corridor/Washington Parkway.

A draft copy of the 2019-2030 Regional Transportation Plan produced by the Dixie Metropolitan Planning Organization, St. George, Utah, June 19, 2019 | File photo by Mori Kessler. St. George News

However, these projects may not be analyzed as part of the major upcoming NEPA analysis but rather in later, narrower analyses. This is called improper “segmenting” in NEPA parlance, and it may constitute “death by a thousand cuts” in terms of not achieving a holistic and sustainable future transportation system.

Fortunately, the NEPA analysis process requires that a “reasonable range of alternatives” be compared and analyzed. Indeed, the alternatives analysis is characterized as the “heart” of the NEPA process.

Public involvement and government transparency are important aspects of the NEPA process, and public review of the alternatives analysis allows for meaningful input rather than only providing an arrogant “take it or leave it” approach. As such, for residents who care about the county’s direction and future, the NEPA process is a crucial opportunity to become involved and express your concerns.

Beyond the required proposed action and no action alternatives that are always analyzed, there are usually other feasible alternatives to achieve the purpose of, and need for, the proposal that should also be analyzed. Failure to analyze these other feasible alternatives demonstrates improper pre-decisional bias and is arbitrary and capricious.

For example, on the UDOT application for the Northern Corridor/Washington Parkway, it is crucial that one or more alternatives outside of the Red Cliffs Desert Reserve and BLM Red Cliffs National Conservation Area be fully analyzed.

The land within the red border is the proposed “Zone 6,” nearly 7,000 acres of land that would be turned into additional protected tortoise habitat in exchange for a right-of-way route through the Red Cliffs Desert Reserve for the proposed Northern Corridor, St. George, Utah, March 28, 2018 | File photo by Mori Kessler, St. George News

On the county’s proposal to renew the Habitat Conservation Plan, it is crucial that denying the Northern Corridor UDOT application be fully analyzed, as well as removing the county’s improper attempt to link Northern Corridor approval to Zone 6 conservation.

This county linkage is ridiculous because the county does not own or control the BLM and SITLA land comprising Zone 6. On the Lake Powell Pipeline, it is crucial that one or more alternatives be fully analyzed involving a combination of water conservation, efficiency and reclamation methods that have proven successful elsewhere and that are likely to be much cheaper and more reliable than the pipeline.

The collective decisions that will ultimately be made at the conclusion of these NEPA processes on which alternatives to implement will greatly determine the county’s fate, good or bad. County residents have a clear stake in these outcomes and valuable but limited time opportunities to become involved.

I hope that residents will seize these opportunities before it is too late.

Submitted by RICHARD SPOTTS, St. George

Letters to the Editor are not the product of St. George News, its editors, staff or news contributors. The matters stated and opinions given are the responsibility of the person submitting them. They do not reflect the product or opinion of St. George News and are given only light edit for technical style and formatting.

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Letters to the Editor are not the product of St. George News, its editors, staff or news contributors. The matters stated and opinions given are the responsibility of the person submitting them. They do not reflect the product or opinion of St. George News and are given only light edit for technical style and formatting.

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