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Writing a Comment in as little as 15 Minutes Part II
Writing an Actual Comment

In this bulletin we will walk you through the whole process of writing an actual comment on the Northern Corridor Highway (NCH) Draft Environmental Impact Statement (DEIS). We will start by showing the final comment and then walk through the process our author, Art Haines, used to write it. 

We encourage you to also write at least one comment for the Lake Powell Pipeline (LPP).  The only difference from these instructions is that you will want to use the CSU Commenting Guidance for the LPP.
 
Comment on NCH Issue #9: BLM must pause the environmental review for the Northern Corridor Highway to issue a supplemental study of the impacts of recent devastating wildfires in Red Cliffs


Dear Bureau of Land Management:

The Draft Environmental Impact Statement for the Northern Corridor Highway is deficient because it does not address the impact of the recent Turkey Farm Road and Cottonwood Trail Fires.  These fires burned approximately 14,000 acres (20%) of the Red Cliffs Zone 3 – an area home to the largest population of threatened Mojave desert tortoise in the Reserve.  The fires most likely traveled through low, medium and perhaps high-density tortoise habitat resulting in the deaths of many tortoises. It is reasonable to anticipate that recent fires caused a mortality rate in desert tortoise of 15% or more.

This damage to the Red Cliffs Desert Reserve comes at a time when the tortoise population was already in decline. Within Red Cliffs, tortoise surveys between 1999 and 2020 show an overall decline of 41 percent due to drought and wildfire. The number of tortoises in Zone 3 declined by 31% between 2017 and 2019, suggesting that this population is already under stress.

The Council on Environmental Quality regulation 40 CFR 1502.9(c)(1)(ii) requires an agency to supplement a DEIS when there are “significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts.”  Clearly the impact of the recent fires represents “Significant New Circumstances”. Conditions in Red Cliffs have changed dramatically, and the current DEIS is no longer adequate for calculating the impacts of the NCH.

BLM must pause preparation of the environmental analysis and review of the proposed NCH under the National Environmental Policy Act, the Federal Land Policy and Management Act, and the Omnibus Public Land Management Act of 2009. After the full ecological impacts of recent fires are examined and assessed, BLM must issue a supplemental DEIS.

On a personal note, since moving to Southwest Utah over a decade ago, I have come to appreciate how amazing the desert tortoise is in its ability to survive and thrive in our desert environment.  I have also come to love the land that comprises Zone 3, the route for the NCH.  It would be a travesty to allow the NCH to proceed without a full examination of the current conditions in the Desert Reserve. 

Thank you for your consideration of these comments.

Sincerely,
Arthur C Haines
New Harmony, Utah
art@emailaddress
 
Instructions 1-2
  1. Open your email program and start a new email.
  2. On your email:
  • Paste this email address: “BLM_UT_NorthernCorridor@blm.gov” into the “To:” line.
  • In the “Subject line” type: Comment on the Northern Corridor Highway Draft Environmental Impact Statement
  • Begin the body of the email with Dear Bureau of Land Management:
How this should look in your email

            To: BLM_UT_NorthernCorridor@blm.gov 
             Subject: Comment on the Northern Corridor Highway Draft
                           Environmental Impact Statement
 
            Dear Bureau of Land Management:
Instructions 3-6
  1. Go to the NCH Commenting Guidance web page .
  2. Review the menu of the nine commenting issues/topics listed for the NCH.  Select one by clicking on the blue issue number.
  3. You can copy the entire Issue page or the specific bullet points on the page that are of interest to you.
  4. Return to your email and paste what you copied into the body of your email.
 
How this should look: 
 
I decided that I wanted to address Issue 9: BLM must pause the environmental review for the Northern Corridor Highway to issue a supplemental study of the impacts of recent devastating wildfires in Red Cliffs.
 
Here are the steps I took
 
     I clicked on this NCH Link that is also in Instruction #3 above.
 
     I clicked on the blue Issue #9 on the Save Red Cliffs web page
 
     I copied the entire Issue #9 language into my “email”.
 
     I deleted the bullet points I did not want to address.
 
Here are the issues that remained, that is, the issues I will address in my comments.
 
What the DEIS does or doesn’t say:
  • Within Red Cliffs, tortoise surveys between 1999 and 2020 show an overall decline of 41 percent due to drought and wildfire.
  • The number of tortoises in Zone 3 declined by 31% between 2017 and 2019, suggesting that this population is already under stress.
  • 2005 wildfires burned approximately 11,500 acres in Red Cliffs, killing 15% of the desert tortoise population in Zone 3. It is reasonable to anticipate that recent fires may cause a mortality rate in desert tortoise of 15% or more.
 The Problem:
  • The Turkey Farm Road and Cottonwood Trail Fires have burned approximately 14,000 acres (20%) of Red Cliffs Zone 3 – an area home to the largest population of threatened Mojave desert tortoise in the Reserve.
  • The fires most likely traveled through low, medium and perhaps high-density tortoise habitat. (See map below).
  • Conditions in Red Cliffs have changed dramatically, and the current DEIS is no longer adequate for calculating the impacts of the NCH.
 Commenting Guidance:
  • BLM must pause preparation of the environmental analysis and review of the proposed NCH under the National Environmental Policy Act, the Federal Land Policy and Management Act, and the Omnibus Public Land Management Act of 2009.
  • Council on Environmental Quality regulation 40 CFR 1502.9(c)(1)(ii) requires an agency to supplement a DEIS when there are “significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts.”
  • Recent wildfires have burned over 20% of the land in Red Cliffs. The DEIS’s disclosure of previous wildfire impacts in Red Cliffs in no way accounts for the current damage.
Instruction 7 (and final comment!)

       7. Review all the information you have pasted into your email. Now delete
          unneeded/unwanted language, edit, rearrange, and add personal comments            to create a comment in your own language. This is the step where
          you make  the letter more individualized which improves the
          effectiveness of the letter with the Bureau of Land Management (BLM).

How this should look

I composed this comment using the bullet points from the section above. Note that about 90% of this comment was a cut and paste effort except for one paragraph of personal observations.  The sections that are my own original words are highlighted in the blue below.

Here is the result:

Dear Bureau of Land Management:

The Draft Environmental Impact Statement for the Northern Corridor Highway is deficient because it does not address the impact of the recent Turkey Farm Road and Cottonwood Trail Fires.  These fires burned approximately 14,000 acres (20%) of the Red Cliffs Zone 3 – an area home to the largest population of threatened Mojave desert tortoise in the Reserve.  The fires most likely traveled through low, medium and perhaps high-density tortoise habitat resulting in the deaths of many tortoises. It is reasonable to anticipate that recent fires caused a mortality rate in desert tortoise of 15% or more.

This damage to the Red Cliffs Desert Reserve comes at a time when the tortoise population was already in decline. Within Red Cliffs, tortoise surveys between 1999 and 2020 show an overall decline of 41 percent due to drought and wildfire. The number of tortoises in Zone 3 declined by 31% between 2017 and 2019, suggesting that this population is already under stress.

The Council on Environmental Quality regulation 40 CFR 1502.9(c)(1)(ii) requires an agency to supplement a DEIS when there are “significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts.”  Clearly the impact of the recent fires represents “Significant New Circumstances”. Conditions in Red Cliffs have changed dramatically, and the current DEIS is no longer adequate for calculating the impacts of the NCH.

BLM must pause preparation of the environmental analysis and review of the proposed NCH under the National Environmental Policy Act, the Federal Land Policy and Management Act, and the Omnibus Public Land Management Act of 2009. After the full ecological impacts of recent fires are examined and assessed, BLM must issue a supplemental DEIS.

On a personal note, since moving to Southwest Utah over a decade ago, I have come to appreciate how amazing the desert tortoise is in its ability to survive and thrive in our desert environment.  I have also come to love the land that comprises Zone 3, the route for the NCH.  It would be a make a mockery of the DEIS process to allow the NCH to proceed without a full examination of the current conditions in the Desert Reserve. 

Thank you for your consideration of these comments.

Sincerely,
Arthur C Haines
New Harmony, Utah
art@emailladdress
Conserve Southwest Utah
Conserve Southwest Utah
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