Chapter 4 • Environmental Consequences

© Cameron Rognan
BDWNCA • RCNCA • SGFO Plan Amendment Chapter 4 595

Chapter 4: Environmental Consequences

INTRODUCTION

4.0 INTRODUCTION

This chapter discloses the direct, indirect, and cumulative impacts on the human environment anticipated to 

occur as a result of implementation of the alternatives 

developed for the long term management of public lands 

in the Beaver Dam Wash NCA and the Red Cliffs NCA. 

Similarly, the environmental consequences that could 

result from implementation of the alternatives developed 

to address the two planning issues that comprise the 

Amendment to the SGFO RMP are presented in 

this chapter.

The purpose of this chapter is to provide BLM decisionmakers and the public with an analysis of the environmental consequences of implementing any of the alternatives proposed in Chapter 2. This chapter is organized 

by resources and programs in the same order as the 

alternative tables and Chapter 3. Each topic area identifies the methods used for the analysis, including indicators, assumptions, and types and nature of impacts on 

that resource or program, from other resources/resource 

uses. The potential impacts related to the four alternatives developed for each NCA and the Amendment to 

the SGFO RMP are described, a summary comparison 

of the alternatives is presented, followed by an analysis 

of cumulative impacts. A separate section describing 

unavoidable adverse impacts, irretrievable or irreversible 

commitment of resources, and the relationship between 

local short-term uses and long-term productivity is presented at the end of the chapter for each of the NCAs and 

the Amendment.

Many management actions proposed in the alternative 

tables are planning-level decisions and do not result 

in direct, on-the-ground impacts. Some management 

actions may affect only certain resources and alternatives. This analysis identifies effects that may enhance or 

improve a resource as a result of management actions, as 

well as those impacts that have the potential to negatively 

affect a resource. If proposed management actions are 

not expected to impact a specific resource or program or 

if, in the professional judgment of BLM resource specialists, the impacts would be negligible, a detailed impacts 

analysis is not presented here.

In the management of the Beaver Dam Wash NCA and 

the Red Cliffs NCA, the long term management of the 

public lands must be consistent with the conservation, 

protection, and enhancement purposes for which the 

NCAs were Congressionally designated in 2009, through 

OPLMA. Proposed management for the Cottonwood 

Canyons and Red Mountain Wilderness units, located 

entirely or partially within the Red Cliffs NCA, is subject 

to the requirements of the Wilderness Act of 1964. Land 

use decisions are proposed for each NCA to conserve 

and protect their natural and heritage resources, while allowing for sustainable and compatible uses of the public 

lands of the NCAs. These decisions can result in tradeoffs that are disclosed in the analysis within this chapter. 

For example, when there are conflicts among resource 

uses or when a land use activity could result in unacceptable or irreversible impacts on the environment, BLM 

may restrict or prohibit such land uses in specific areas. 

The projected impacts on land use activities and the associated environmental impacts of land uses are characterized and evaluated for each of the alternatives. 

The SGFO RMP Amendment addresses two issues that 

resulted from the passage of OPLMA in 2009. At Section 

1979, OPLMA mandated BLM to identify areas of public 

land where biological conservation is a priority and 

undertake activities to conserve and restore plant and 

animal species and natural communities. This legislative 

direction would be accomplished through the proposed 

designation of new ACECs to direct special management attention to the protection of special status species’ 

habitats and populations. It would also be accomplished 

through proposed changes in the management of public 

lands in northwestern Washington County to protect 

crucial habitat and migration corridors for mule deer, 

other wildlife species, and diverse predators, species that 

may not meet both the relevance and importance criteria 

for ACEC designation. BLM has labeled this area the Bull 

Valley Mountains Multi-Species Management Area in 

the Amendment. 

The SGFO RMP Amendment would also modify current 

OHV area designations to comply with federal regulations and BLM’s Travel and Transportation Management 

guidance. The projected environmental consequences of 

the proposed alternatives are characterized and evaluated 

in this chapter.

Impact analysis is a cause-and-effect process. The detailed impact analyses and conclusions are based on: the 

BLM Planning Team’s knowledge of the public lands and 

resources of the NCAs and SGFO; reviews of existing 

literature; and information provided by resource specialists and scientists from other agencies and the public. 
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INTRODUCTION INTRODUCTION

4.0.3 Incomplete or Unavailable Information

The CEQ established implementing regulations for 

NEPA, requiring that a federal agency identify relevant 

information that may be incomplete or unavailable for 

the evaluation of reasonably foreseeable significant adverse impacts in an EIS (40 CFR 1502.22).

If the information is essential to a reasoned choice 

among alternatives, it must be included or addressed in 

an EIS. Scientific information will always be somewhat 

incomplete, as it relates infinitely complex ecosystems 

considered at various scales. The best available information pertinent to the decisions to be made was used in 

developing the NCA RMPs and Amendment.

Inventories of public land resources and uses are ongoing 

and databases updated on a continuous basis. However, 

certain information was unavailable for use in this planning process because inventories have either not been 

conducted, are not complete, or the data are not currently being collected.

For these resources, estimates were made concerning 

the number, type, and significance of potential impacts, 

using data from previous inventories and other sources 

of information. Some impacts cannot be quantified given 

the proposed management actions. In these situations, 

impacts are projected in qualitative terms or, in some 

instances, are described as unknown. Subsequent implementation or project-specific analysis would provide 

the opportunity to collect and examine the site-specific 

inventory data required to determine appropriate application of RMP-level decisions. Ongoing inventory efforts 

by the BLM and other agencies in the three planning 

areas will continue to update and refine information used 

to implement the RMPs and Amendment.

4.0.4 Cumulative Impacts

Cumulative impacts are effects on the environment that 

result from the impact of implementing any one of the alternatives identified in the NCA RMPs or Amendment, in 

combination with other actions outside the scope of these 

planning documents, either within the planning areas or 

adjacent to them. Cumulative impact analysis is required 

by CEQ regulations because environmental conditions 

result from many different factors that act together. The 

total effect of any single action cannot be determined by 

considering it in isolation, but must be determined by considering the likely result of that action in conjunction with 

many others. Evaluation of potential impacts considers incremental impacts that could occur from the proposed actions, as well as impacts from past, present, and reasonably 

foreseeable future actions. Management actions could be 

influenced by activities and conditions on adjacent lands 

beyond the planning area boundary; therefore, assessment 

data and information could span multiple scales, land 

ownerships, and jurisdictions.

4.0.4.1 Cumulative Analysis Methodology

The cumulative impacts discussion considers the alternatives in the context of the broader human environmentspecifically, actions that occur outside the scope and geographic area covered by the NCA RMPs or Amendment.

Because of the programmatic nature of the RMPs and 

the cumulative assessment, the analysis tends to be broad 

and generalized to address potential effects that could occur from a reasonably foreseeable management scenario 

combined with other reasonably foreseeable activities 

or projects. Consequently, this assessment is primarily 

qualitative for most resources because of lack of detailed information that would result from project-level 

decisions and other activities or projects. Quantitative 

information is used whenever available and as appropriate to portray the magnitude of an impact. The analysis 

assesses the magnitude of cumulative impacts by comparing the environment in its baseline condition with the 

expected impacts of the alternatives and other actions in 

the same geographic area. The magnitude of an impact is 

determined through a comparison of anticipated conditions against the naturally occurring baseline as depicted 

in the affected environment (see Chapter 3, Affected 

Environment) or the long-term sustainability of a resource or social system.

The following factors were considered in this cumulative 

impact assessment:

▶ Federal and non-federal actions;

▶ Potential for additive and synergistic effects or 

interactions among or between effects; 

▶ Scale of cumulative impacts across alternatives.

Temporal and spatial boundaries used in the cumulative analysis are developed on the basis of resources of 

concern and actions that might contribute to an impact. 

The baseline date for the cumulative impacts analysis is 

2014. The temporal scope of this analysis is the projected 

15-20 years that most RMPs remain in effect before being 

revised to address new or evolving issues. An RMP revision may be necessary if:

▶ New planning issues emerge that were not anticipated at the time an RMP was prepared;

▶ Major environmental changes or other factors that 

require changes to the management decisions in 

The baseline used for the impact analysis is the current condition or situation, as described in the Affected 

Environments for the two NCAs and public lands subject 

to the Amendment. Impacts on resources and resource 

uses are analyzed and discussed in detail commensurate 

with identified planning issues and concerns. At times, 

impacts are described using ranges of potential impacts 

or in qualitative terms.

4.0.1 Analytical Assumptions

Several assumptions were made to facilitate the analysis of 

the projected impacts. These assumptions set guidelines 

and provide reasonably foreseeable projected levels of development that could occur over the 20 year “life span” of 

the new RMPs being developed for the two NCAs. These 

assumptions should not be interpreted as constraining or 

redefining the management objectives and actions proposed for each alternative. The following general assumptions apply to all resource categories. Assumptions that 

relate to specific resources or programs are provided in the 

methods of analysis section for that resource.

▶ Sufficient funding and personnel would be available 

for implementing the management decisions in the 

approved RMPs for the Beaver Dam Wash NCA, 

the Red Cliffs NCA, and the approved Amendment 

to the SGFO RMP over the life of these plans.

▶ Implementing actions from any of the alternatives 

would be consistent with relevant federal laws, 

regulations, and agency policies, as well as any valid 

existing rights.

▶ Implementation-level actions necessary to execute 

the RMP level decisions would be subject to further environmental review, in compliance with 

NEPA and other legal authorities. However, the EIS 

that supports the RMPs for the two NCAs and the 

Amendment provides the necessary NEPA analysis 

for large-scale land use planning level decisions.

▶ Direct and indirect impacts of implementing the 

RMPs for the NCAs and the Amendment would 

occur primarily on public lands. 

▶ The analysis of impacts in this chapter is based on 

the best available data. Knowledge of the planning 

area and professional judgment, based on observation and analysis of conditions and responses 

in similar areas, are used to infer environmental 

impacts where data are incomplete or unavailable.

▶ Acreage figures and other numbers used in the 

analyses are approximate projections for comparison and analytical purposes only. Readers should 

not infer that they reflect exact measurements or 

precise calculations.

▶ Local climate patterns are predicted to change with 

warmer, drier conditions likely to occur over the life 

of the RMPs, potentially altering watershed functions, native vegetation communities, wildfire regimes, and affecting native species and their habitats.

▶ In the future, as changes in climate affect resources 

and necessitate changes in how resources are managed, BLM may reevaluate decisions made as part of 

this planning process and adjust management in the 

NCAs or on other public lands accordingly. 

▶ Substantive changes to land use plan level decisions 

would require that the RMPs be amended or revised, 

supported by an appropriate level of NEPA analysis.

4.0.2 General Methodology for Analyzing 

Impacts

Impacts can be both adverse and beneficial; to avoid 

confusion, they are defined as “adverse impacts” or “beneficial effects” in this analysis. Adverse impacts could 

result from management actions that diminish any of the 

fundamental components listed in the indicators sections 

below. Beneficial effects could result from management 

actions that maintain or enhance any of the fundamental 

components listed in the indicators sections below. The 

intensity of impacts are also described, where possible, 

using the following definitions:

Negligible: The impact or effect is at the lower level of 

detection; there would be no measurable change.

Minor: The impact or effect is slight but detectable; there 

would be a small change.

Moderate: The impact or effect is readily apparent; there 

would be a measurable change.

Major: The impact or effect is severe, highly noticeable, 

and potentially permanent.

Impacts/effects can be direct or indirect. Direct impacts/

effects are those caused by the management action and 

occur at the same time and place. Indirect impacts/effects 

are those that are reasonably foreseeable consequences of 

the action but are further removed in time or distance. 

Impacts are quantified where possible, but in the absence 

of quantifiable data, professional judgment was used. 

Impacts are sometimes described using ranges of potential impacts or in qualitative terms, if appropriate.
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INTRODUCTION INTRODUCTION

the approved RMP in order to continue to fulfill the 

conservation purposes of the two NCAs, as established in OPLMA.

Unless otherwise noted, the cumulative impacts analysis 

area (CIAA) includes the Beaver Dam Wash NCA; the 

Red Cliffs NCA; and public lands managed by the SGFO. 

However, spatial boundaries may be larger for resources 

that are mobile or that migrate (e.g., wildlife or migratory 

bird) than for stationary resources. For these resources, 

the adjacent public lands managed by BLM-Arizona Strip 

District, BLM-Nevada, Ely and Las Vegas Districts; the 

Pine Valley Ranger District of the Dixie National Forest; 

and Zion National Park, as well as all private, State and 

county lands may be included within the 

CIAA boundaries.

4.0.4.2 Past, Present, and Reasonably Foreseeable 

Future Actions

Past, present, and reasonably foreseeable future actions 

are considered in the analysis to identify the nature and 

extent of environmental impacts within a specific analysis area. Projects and activities are evaluated on the basis 

of proximity, connection to the same environmental systems, potential for subsequent impacts or activity, similar 

impacts, the likelihood a project will occur, and whether 

the action is reasonably foreseeable.

Projects and activities considered in the cumulative 

analysis were identified through various sources, including publicly available information and interactions with 

other federal, state, county, and local governmental entities, partners and public land users, and others. 

Effects of past actions and activities are manifested in 

the current condition of the resources, as described 

in the affected environment (see Chapter 3, Affected 

Environment). Reasonably foreseeable future actions 

are actions that could take place within the 20-year 

period that BLM typically estimates as the “life span” of 

an RMP. Reasonably foreseeable future action scenarios 

are projections made to predict future impacts-they 

are not planning decisions or resource commitments. 

Projections developed for analytical purposes are based 

on current conditions or trends and professional judgment. Unforeseen changes in factors such as economics, 

demand, and federal, state, and local laws and policies 

could result in different outcomes than those projected in 

this analysis.

Other potential future actions have been considered and 

eliminated from further analysis because there is a little 

likelihood that these actions would be implemented or 

because so little is known about the potential action that 

formulating an analysis of impacts would be premature. 

Federal actions, such as new species listings under the 

ESA, could require that BLM reconsider decisions from 

the RMPs or Amendment, because the consultations or 

impacts analyses might no longer be appropriate. Some 

potential future actions would have greater capacity to 

affect resource uses than others; however, until more 

information is available, no reasonable estimation of 

impacts can be made.

Projects and activities identified as having the greatest 

likelihood to generate potential cumulative impacts in 

the CIAA (defined as the Beaver Dam Wash NCA, the 

Red Cliffs NCA, and other public lands managed by the 

SGFO) when added to the RMP alternatives, are shown 

in Table 4-1.

Table 4-1 Past, Present, and Reasonably Foreseeable Plans, Projects, or Actions that Comprise the Cumulative Impact Scenario

Land Use Plans

SGFO RMP (1999) - This plan sets management, protection, and use goals and guidelines for public lands in Washington 

County managed by BLM’s SGFO. This RMP is being amended by the current planning effort to address new ACEC designations or other special management for priority biological areas and OHV area designations. 

Upon approval of the NCA RMPs and the issuance of Records of Decision for those RMPS, management goals, objectives, and 

decisions for the public lands of the NCAs will no longer be derived from the SGFO RMP. 

Washington County Master Plan (2010) - Countywide land use and growth plan for the County.

Cedar City Field Office RMP - This plan will set management, protection, and use goals and guidelines for the BLM Cedar City 

Field Office. This is an ongoing planning process and a decision is expected in 2016. 

Kanab Field Office RMP (2008)

Arizona Strip Field Office RMP (2008)

Ely District RMP (2008)

Dixie National Forest Land and Resource Management Plan (1986)

Zion National Park General Management Plan (2001)

Fish and Wildlife Population Management

UDWR has, and will continue, to manage large and small game populations, as well as some other wildlife species, to meet 

population management objectives, which are often set for specific management units, such as mule deer and bighorn sheep. 

Public lands provide habitats for diverse wildlife species and are the locations for facilities, like guzzlers and drinkers, that support UDWR management objectives for wildlife populations.

The Virgin River Recovery Program, a partnership of Federal, state, and private entities, has conducted, and will continue to 

support, activities to protect and improve populations and habitats for Virgin spinedace and other at-risk native fish of the 

Virgin River system. 

County-wide population growth, the development of non-federal lands, and the construction of new roads and highways will 

continue to impact and fragment habitats for diverse wildlife species. Wildfires, drought and climate change are projected to 

alter habitats and population movements for many species.

Vegetation and Habitat Management

Forestry - Past, current, and foreseeable forestry uses, particularly on nearby National Forest System lands include woodland 

products harvesting (e.g., poles and posts, Christmas trees).

Vegetation treatments - Mechanical vegetation conversion type treatments (e.g., chaining, drill seeding, brush mowing) were 

very common in the past on public and private rangelands in the CIAA. These treatments and maintenance of these vegetation 

treatments could continue to be authorized on some public lands managed by BLM, in Washington County, on the Arizona 

Strip and in southern Nevada, and on lands managed by other federal and state agencies. In addition, manual, biological, herbicidal, and mechanical treatments of tamarisk and Russian olive trees have been completed along rivers and streams throughout 

the CIAA and this type of restoration work is likely to continue in the foreseeable future.

Earlier vegetation conversion type treatments from the 1960s and 1970s were done largely to increase forage for livestock and 

continue to have an impact on native plants and fauna throughout the CIAA. More recent treatments have a wider range of 

positive objectives that include wildlife, hazardous fuel reduction, etc. This type of treatment is likely to continue in the foreseeable future.

Fire and Fuels Management

Hazardous fuels reduction projects, including chemical, biological, and mechanical treatments, will continue to be conducted 

on federal and non-federal lands.

Increasing recurrence and severity of drought conditions, temperature increases, changes in precipitation regimes, and increased dominance of exotic invasive species are predicted for the Mojave Desert, Great Basin, and Colorado Plateau ecoregions as a result of climate change. This could, in turn, increase the frequency and severity of wildfires.

Livestock Grazing

Livestock grazing on the public rangelands began in the mid-19th century and continues to the present day. Generally, livestock 

numbers, the type of livestock grazed (sheep and goats replaced by cattle), and the intensity of grazing have decreased since the 

passage of the Taylor Grazing Act. Grazing use on adjacent National Forest System lands is often highly coordinated with the

Table 4-1 Past, Present, and Reasonably Foreseeable Plans, Projects, or Actions that Comprise the Cumulative Impact Scenario
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Table 4-1 Past, Present, and Reasonably Foreseeable Plans, Projects, or Actions that Comprise the Cumulative Impact Scenario

BLM (e.g., permittees often have permits on both BLM and adjacent National Forest System lands). Grazing on private lands 

within the CIAA is expected to remain stable or slightly decrease as a result of residential development.

Recreation and Visitor Use

Population growth in southwestern Utah and adjacent areas of southern Nevada has been significant over the past 30 years. 

Public lands are providing recreational opportunities for increasingly larger numbers of local and regional users. The primary 

recreational activities that occur on public lands in Washington County are hiking, mountain biking, hunting, motorcycle 

and OHV riding, camping, and heritage tourism. Recreation-based visitor use in the region has increased in most areas in 

recent years and is expected to continue to increase on BLM-managed lands and on lands managed by other federal and state 

agencies.

Lands and Realty

Disposal of BLM-administered lands in Washington County and acquisitions of non-federal lands to consolidate habitats that 

benefit special status plant and animal species (particularly the threatened Mojave desert tortoise) have been ongoing since the 

SGFO RMP was approved in 1999. It is expected that disposal of public lands will be very limited in the future, as a majority 

of the lands identified in the RMP for disposal have been sold or exchanged for non-federal lands to achieve specific resource 

objectives. Public lands must be retained in federal ownership in the two NCAs, 14 designated Wilderness areas managed by 

BLM, and within administratively designated ACECs, limiting the availability of public lands in Washington County for future 

disposal. OPLMA requires that the proceeds from sales of public land in Washington County be used to acquire non-federal 

lands in the two NCAs and designated Wilderness areas. Acquisitions of non-federal lands could also be made through purchase from willing sellers, using other funding sources, or through transfer or exchange, if they would further resource goals 

and objectives from the relevant RMP that governs the adjacent federal lands.

Existing and Valid Rights – The major designated utility corridors through Washington County are located outside the boundaries of the two NCAs and include a number of interstate power transmission lines, natural gas and petroleum pipelines, 

and associated infrastructure, authorized through ROWs. Future developments are expected in the IPP-West-wide Energy 

Corridor, a one-mile designated utility corridor that separates the western sections of the Beaver Dam Wash NCA. A one-mile 

wide designated utility corridor forms the southwestern boundary of the Beaver Dam Wash NCA and includes the NavajoMcCullough and Dixie REA transmission lines and Rio Virgin fiber-optic line. Additional developments would be expected in 

the designated corridors in the future.

Warner Valley Reservoir – Flows from the Virgin River (below Pah Tempe Spring) are proposed to be impounded in a reservoir 

to be constructed in Warner Valley, by the Washington County Water Conservancy District, allowing more efficient management of this water for secondary water purposes and providing targeted instream flows for the endangered woundfin minnow 

and Virgin river chub. This proposal would require the use of public lands for a portion of the proposed reservoir site and is 

currently in the design and engineering phase.

Anderson Junction Reservoir - This proposal by the Washington County Water Conservancy District would construct a new 

water storage reservoir and pipeline system on federal and non-federal lands near Anderson Junction. Storage from the reservoir would provide secondary water for outdoor watering usage in the communities of Toquerville and La Verkin, thereby conserving the high-quality Toquerville Spring water for culinary use. Irrigation water for Pintura and Anderson Junction would 

be provided directly from the pipeline to the proposed reservoir.

Lake Powell Pipeline – This project, proposed by the State of Utah, would pipe water from Lake Powell and transport it to 

Washington and Kane counties. The project consists of approximately 139 miles buried of 69-inch pipe from Lake Powell to 

Sand Hollow Reservoir near St. George, to be located on federal, state, and private lands. It also includes pumping facilities 

near Glen Canyon Dam with booster pumping stations along the pipeline alignment to provide the approximately 2,000 foot 

lift needed to carry the water over the high point in the pipeline. The Federal Energy and Regulatory Commission is the lead 

Federal agency for the ongoing NEPA process.

Spread of Noxious Weeds and Non-Native (Exotic) Invasive Species

Noxious weeds and exotic invasive species, have invaded and will continue to invade many locations in the planning areas. 

Weed control on public lands employs integrated weed management tools, including biological, chemical, mechanical, manual, 

and educational methods. The 2007 Record of Decision for Vegetation Treatment on BLM Lands in Thirteen Western States, 

and the 2007 Programmatic Environmental Report guide the management of noxious weeds and exotic invasive species on 

BLM-managed public lands. Exotic invasive species are predicted to continue to proliferate under the current fire regime in the 

Mojave Desert and under predicted climate change scenarios relating to seasonal precipitation.

Table 4-1 Past, Present, and Reasonably Foreseeable Plans, Projects, or Actions that Comprise the Cumulative Impact Scenario

Climate Change

In 2001, the Intergovernmental Panel on Climate Change (IPCC) indicated that by the year 2100, global average surface temperatures would increase between 1.5 C to 6 C above 1990 levels, depending on the assumptions made in the predictive model 

(IPCC 2001). The IPCC has concluded that these changes in atmospheric composition are almost entirely the result of human 

activity, not the result of changes in natural processes that produce or remove these gases (IPCC 2007).

Climate change may also be driving more frequent and extreme droughts in the region that affect groundwater and surface water flows. Lower surface flows can impact riparian vegetation, aquatic systems (including fish), and wildlife. Particularly, lower 

spring peak flows would have an impact on the threatened and endangered native fish of the Virgin River system.
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AIR QUALITY

Chapter 4: Environmental Consequences BDWNCA

4.1 AIR QUALITY

Proposed management of the public lands under each of 

the alternatives described in Chapter 2 was evaluated to 

determine how air quality in the NCA could be affected. 

Existing conditions are described in Section 3.1, 

Air Quality.

4.1.1 Methods of Analysis

As air quality data specific to the NCA is currently not 

being collected, existing air quality conditions were 

estimated, based on air monitoring data collected in 

the greater St. George area. The analysis focuses on 

proposed management actions that could generate air 

pollutant emissions.

The analysis of potential impacts from air pollution 

emissions can be conducted either quantitatively or 

qualitatively. A quantitative analysis is typically conducted through the use of computer simulations, or 

modeling, that takes into account existing air quality, 

the proposed emission sources, and their spatial and 

temporal characteristics. This is referred to as dispersion modeling, and is used by regulatory agencies in 

the permitting of stationary sources of air pollution. To 

be able to conduct this type of analysis source-specific 

information is needed about future sources and activities which is not currently available (e.g. what sources 

and where).

Another type of modeling analysis is using photochemical or one-atmosphere models which take all the sources 

in the regional area and, using detailed meteorological 

and emissions parameters, estimates future air quality 

concentrations across the landscape. While applicable to 

planning level analysis, this type of model also requires 

detailed meteorological and emissions information 

which is not available for the planning area. In addition, 

a photochemical model is typically used in areas with 

large amounts of emissions. Given the size of the NCA 

and relatively minor emission levels, a photochemical 

model would be unlikely to discern any potential impacts 

from proposed management actions, above the background or margin of error in the model.

Given the minor amounts of sources and emissions associated with the NCA, and the lack of detailed source 

data needed to conduct any type of air quality modeling, 

this impact analysis for air quality will focus on a qualitative impacts analysis. An evaluation of the potential for 

management activities to generate pollutants of concern 

and their potential qualitative impacts will be presented.

4.1.1.1 Indicators

Based on the air quality conditions presented in the 

3.1.1 Existing Environment – Air Quality, the following 

criteria pollutants have been identified as pollutants of 

concern in Washington County and could be emitted as a 

result of proposed management actions identified in the 

four alternatives.

▶ Particulate Matter (PM): While the NCA and 

Washington County in general are currently well 

under the applicable NAAQS for PM10 and PM2.5), 

short-term dust events can create health and nuisance impacts. Activities such as motorized vehicle 

travel on unpaved roads, wildfires, and other surface 

disturbing activities can all contribute to the potential 

for particulate impacts.

▶ Volatile Organic Compounds (VOCs): VOCs, while 

not a criteria pollutant under the Clean Air Act, is 

a precursor gas that contributes to regional ozone 

formation. VOCs are emitted from a wide variety 

of sources, such as vegetation, fuel use, and many 

other area type sources.

4.1.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of 

the NCA; 

▶ Predictions of future air quality effects from BLMinitiated or authorized activities were based upon 

the range of management alternatives outlined for 

the NCA in Chapter 2; 

▶ All land use proposals would be analyzed for conformance with RMP goals, objectives, and decisions 

and resource impacts analyzed through the NEPA 

process. Whenever projects are authorized that 

could impact air resources or contribute to GHG 

emissions, impacts would be avoided or lessened to 

the extent possible through project design, BMPs, 

and other mitigation measures; 

▶ Recreational uses would be primarily non-motorized, casual, and dispersed over the life of the RMP;

▶ The magnitude of potential emissions increases 

as a result of all management actions identified in 

the alternatives developed for this RMP would be 
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Mountains Wilderness; the Cougar Canyon Wilderness, 

the Docs Pass Wilderness, the Tunnel Spring Wilderness 

(Nevada); the Red Mountain Wilderness, the Cottonwood 

Canyon Wilderness, the Cottonwood Canyons Wilderness, 

and the Pine Valley Mountains Wilderness.

4.1.3.1 Climate Change

Concentrations of certain gases in the earth’s atmosphere 

have been identified as being effective at trapping heat 

reflected off the earth’s surface thereby creating a “greenhouse effect.” As concentrations of GHGs increase, the 

earth’s surface warms and global climate is affected. 

Concentrations of greenhouse gases have increased dramatically in the earth’s atmosphere in the past century. 

Anthropogenic (man-made) sources and human activities have been attributed to these increases particularly 

for carbon dioxide, methane, nitrous oxide, and fluorinated gases (EPA 2010). 

The EPA has determined that six GHGs are air pollutants 

and subject to regulation under the Clean Air Act. The six 

are carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. Of 

these GHGs, carbon dioxide, methane, and nitrous oxide 

are emitted by some activities that are authorized on public lands in the NCA, while the remaining three GHGs 

are not emitted or are in very small quantities. Emissions 

of GHGs (especially carbon dioxide and methane), large 

wildland fires, and activities using combustion engines 

could contribute to the phenomena of climate change. 

 In the NCA, GHG emissions from all activities that 

would be authorized are predicted to be negligible to 

minor under all alternatives and are not expected to 

contribute to measurable or significant air quality and 

climate change impacts.

It is important to note that GHGs will have a sustained 

climatic impact over different temporal scales. For example, recent emissions of carbon dioxide can influence 

climate for 100 years. The IPCC’s latest report (IPCC 2014) 

states that the equilibrium climate sensitivity is likely in 

the range 1.5° C to 4.5° C (high confidence), extremely 

unlikely less than 1° C (high confidence), and very unlikely greater than 6° C (medium confidence). The climate 

sensitivity specifically due to CO2 is often expressed as the 

temperature change in °C associated with a doubling of 

the concentration of carbon dioxide in Earth’s atmosphere. 

This can take decades to centuries to be fully expressed.

Modeling of climate change scenarios indicate that predicted changes are likely to occur over several decades 

to a century and may not be measurably discernible 

within the reasonably foreseeable future. Existing climate 

prediction models are global or continental in scale; 

therefore they are not appropriate to estimate potential 

impacts of climate change in much smaller areas. The 

current state of the science involves calculating potential 

quantities of GHGs that may be added to the atmosphere 

from a particular activity. However, tools to analyze or 

predict how global or regional climate systems may be 

affected by a particular activity or activities within the 

planning area are not currently available. Assessing the 

impacts of GHG emissions on global climate change 

requires modeling on a global scale, which is beyond the 

scope of this analysis

4.1.4 Cumulative Impacts

Potential GHG emissions from all activities that would 

be authorized in the NCA under all alternatives are 

predicted to be negligible to minor under all alternatives 

over the life of the RMP and are not expected to contribute to measurable air quality and climate change impacts. 

4.2 WATER RESOURCES

This section discusses impacts on water quality from the 

proposed management actions of other resources and 

resource uses; existing water resource conditions are 

described in Section 3.2.2 Water Resources.

4.2.1 Methods of Analysis

4.2.1.1 Indicators

Indicators of adverse impacts on water resources include 

the following:

▶ Inability to meet state and federal water quality 

standards for surface and ground water;

▶ Inability to meet appropriate Utah Standards for 

Rangeland Health, based on measurement of nutrient loads, total dissolved solids, chemical constituents, fecal coliform, water temperature and other 

water quality parameters;

▶ Declining riparian zone health, with native vegetation type, diversity, density, and vigor departures 

from the NRV, based on ecological site conditions;

▶ Declining habitat quality for native fish, amphibians, and macro-invertebrates.

4.2.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA;

negligible to minor and unlikely to create or contribute to any measurable or significant adverse impacts.

Implementing management for the following resources 

or resource uses would have negligible or no impact on 

air quality because the level of activity is not expected 

to change between alternatives and the potential for 

emissions from the activity is considered to be very 

small. Therefore, these are not discussed in detail: Water 

Resources, Geologic and Paleontological Resources, Cave 

and Karst Resources, Soil Resources, Native Vegetation 

Communities, Fire and Fuels Management, Noxious 

Weeds and Invasive Species, Vegetation Resource Uses: 

Plant Materials, Special Status Species, Other Fish and 

Wildlife Species, Heritage Resources, National Historic 

Trails, National Natural Landmarks, ACECs, Visual 

Resource Management, Natural Soundscapes, Lands with 

Wilderness Characteristics, Lands and Realty, Public 

Education and Interpretation, and Scientific Research.

4.1.2 Direct and Indirect Impacts

The following list of land uses could potentially emit 

regulated air pollutants within the NCA: Vegetation 

Resource Uses: Livestock Grazing; Recreation and Visitor 

Services; and Travel and Transportation Management.

4.1.2.1 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing

Particulate emissions can be generated by surface disturbances that result when cattle trail or congregate 

around water sources. VOCs and methane (a GHG) can 

be generated by animal flatulence. The range of management alternatives in Chapter 2 would establish levels of 

grazing use that would be equal to or lower than current 

conditions, or would make the NCA unavailable for grazing over the life of the RMP. The magnitude of estimated 

criteria and GHG emissions for this activity are predicted 

to be negligible to minor under all alternatives and are 

not expected to contribute to measurable air quality and 

climate change impacts.

Emissions from the use of motorized vehicles and equipment related to livestock grazing management would 

have very little potential to contribute to air quality 

impacts, as these would be an exceedingly small quantity, 

short duration, and localized emissions. The estimated 

emissions of GHGs from livestock would be similar 

and negligible to minor for Alternatives A, B, and D. 

Alternative C would make the public lands of the NCA 

unavailable for livestock grazing over the life of the RMP, 

eliminating emissions related to this land use. 

4.1.2.2 Impacts from Management of Recreation 

and Visitor Services, and Comprehensive Travel and 

Transportation

These land uses and authorized activities could generate fugitive dust (PM) from motorized vehicles traveling 

on paved and unpaved roads, but are not expected to 

be of sufficient quantity or duration to create air quality 

issues with the NAAQS. Data collected from other areas 

in Washington County indicate that there are no significant major point sources of emissions (>100 tons/year) 

in the county.

Management actions in Alternatives B, C, and D propose 

to reclaim closed and redundant unpaved routes that are 

not required for administrative purposes or for use as 

fire breaks. These actions would be expected to minimize 

fugitive dust from soil erosion and to minimize the potential for measurable dust generation from public lands 

in the NCA.

Alternatives B, C, and D emphasize non-motorized recreational opportunities and more intensive management 

of recreational activities in the NCA, through land use 

restrictions and the preparation of implementation-level 

management plans. These alternatives would develop a 

professionally-designed non-motorized trail system that 

would enhance visitor experiences and lessen the potential 

that user-created social trails will remove vegetation and 

disturb soils, increasing fugitive dust emissions. 

Under all alternatives, Congressional designation of 

three Designated Road Areas in the NCA, where motorized vehicle travel is limited to a small number of routes, 

minimizes the potential for fugitive dust releases related 

to motorized vehicles traveling off-road or on a large 

number of unpaved roads. Proposed OHV area designations under all alternatives would designate the remaining areas of the NCA, outside of the Designated Road 

Areas, as Limited to Designated Roads and Trails. All 

alternatives would eliminate fugitive dust releases related 

to off-road travel and lessen potential release from travel 

on a large number of unpaved roads. Dust abatement 

practices, such as speed limits on unpaved roads or 

seasonal restrictions on vehicle travel on specific routes, 

could further reduce dust releases.

4.1.3 Summary of Impacts from Alternatives

Under all alternatives, proposed management would not 

be expected to create measurable fugitive dust releases 

and VOC emissions or to impact air quality within or 

adjacent to the NCA. There would be no impairment of regional Class I air quality areas, including the Beaver Dam 

AIR QUALITY WATER RESOURCES
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WATER RESOURCES WATER RESOURCES

all alternatives would be minimal, indirect, and shortterm; long-term effects would be primarily beneficial, as 

management actions conserve and protect soil and water 

resources and restore native vegetation communities.

Under Alternatives B, C, and D, re-vegetation of damaged riparian areas would be prioritized to maintain 

or restore proper functioning condition to springs and 

streams. These projects would be conducted using the 

least invasive methods possible, to lessen the amount of 

new surface disturbance and potential soil erosion. In 

the long-term, restoration of native plant species would 

benefit water resources, as these species are well-suited 

to local environmental conditions and can thrive without 

depleting soil health and water supplies. 

Alternative A would analyze proposed surface-disturbing 

projects to determine the suitability of soils to support 

such projects, but does not identify surface disturbance 

prohibitions that could protect soil and, therefore, water 

resources. Alternatives B, C, and D would provide additional protection for soils in riparian areas along Beaver 

Dam Wash and in ephemeral drainages, by prohibiting 

surface-disturbing activities within varying distances 

(250 feet, 1,000 feet, and 500 feet, respectively) from the 

edge of the riparian zone. Alternative C would be the 

most protective, limiting such disturbances to within 

1,000 feet of edge of the riparian zone, unless the project 

would enhance riparian conditions. Soil erosion potential 

would be lessened by these restrictions, helping to maintain watershed function and water quality.

4.2.2.2 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Under the three action alternatives, the goals are to 

protect, conserve, and restore desired plant communities, 

particularly those that provide critical habitats for special 

status species like the Mojave desert tortoise. These goals 

will also help to preserve water quality and the sustainability of stream flows in the Beaver Dam Wash. 

Alternative A would authorize vegetation treatments 

to achieve multiple management objectives, including 

conversions of vegetation types to benefit livestock, wildlife, or other management goals. While the use of native 

plant species for restoration and rehabilitation would 

be emphasized, non-native species could be used, when 

native species are not available or economically feasible. 

No specific treatment methods were precluded from use 

under this alterative.

Under Alternatives B, C, and D, vegetation treatments 

would only be authorized for re-vegetation of disturbed 

and fire-damaged lands and riparian areas, not for conversions of vegetation types. The three action alternatives 

emphasize the use of native plant species, particularly 

“early colonizing” species, for re-vegetation projects and 

identify more restrictive criteria than those of Alternative 

A related to the use of non-native species. Alternative 

C would not authorize the use of non-native species for 

vegetation treatments. 

Alternatives B and C would authorize non-invasive and 

minimally invasive methods to implement re-vegetation 

projects, to lessen the amount of new surface disturbance 

and potential soil erosion that could result from these 

projects. Alternatives A and D would authorize mechanical methods, like chaining and harrowing, that could 

create new and larger-scale surface disturbances that 

would leave soils vulnerable to wind and water erosion 

in the short-term, until vegetative cover is re-established. 

Alternatives B and C would better protect water quality 

from sediment run-off from vegetation treatment sites, 

when compared to other alternatives. 

The three action alternatives that propose to actively 

restore disturbed and fire-damaged vegetation communities would better protect water quality and more quickly 

return proper ecosystem functions, when compared to 

Alternative A. In the short term, however, soil surfaces 

would remain exposed to erosional forces, until vegetative cover is re-established. In the long-term, restoration 

of native plant species would benefit water resources, 

as these species are well-suited to local environmental 

conditions and can thrive without depleting soil health 

and water supplies. 

Impacts on water resources related to wildfires and fire 

suppression tactics can include increased soil erosion and 

runoff in the short term, depending on the size and severity of the fire and the soil and vegetation types that are 

damaged. Use of heavy equipment to suppress fires can 

cause soil compaction and displacement, while the application of large amounts of fire retardant can negatively 

affect biological soil crusts and soil productivity. 

Alternative A provides general management direction 

that full suppression tactics be employed to keep fire 

sizes small in Mojave Desert vegetation communities. 

Alternatives B, C, and D emphasize that full suppression of wildfires is required to conserve Mojave Desert 

native vegetation and critical habitat for federally-listed 

species. Full suppression could limit the size of fires and 

minimize the loss of vegetation cover that can lead to 

increased soil erosion into surface water sources in the 

▶ Water quality would be managed to meet federal 

and state water quality standards for surface water 

sources;

▶ Water quality would be managed to meet appropriate Utah Standards for Rangeland Health; 

▶ All land use proposals would be analyzed for 

conformance with RMP goals, objectives, 

and decisions and resource impacts analyzed 

through the NEPA process. Whenever projects 

are authorized that could affect water resources, 

impacts would be avoided or lessened to the extent 

possible through project design, BMPs, and other 

mitigation measures; 

▶ Soils would be managed to minimize erosion (relative to natural erosion rates) and maintain soil 

productivity; 

▶ Projects that help restore watersheds, desirable vegetation communities, or wildlife habitats (including 

surface disturbance associated with these efforts) 

would benefit water resources over the long term;

▶ The degree of impact attributed to any one disturbance or series of disturbances would be influenced 

by several factors, including proximity to drainages, 

proximity to surface water, intensity and duration 

of disturbance, reclamation potential of the affected 

area, existing vegetation, precipitation, and mitigating actions applied to the disturbance;

▶ BMPs would be followed for all authorized projects 

that would include surface disturbances 

(Appendix F).

Implementing management for the following resources 

or resource uses would have negligible or no impact on 

water resources and are, therefore, not discussed in detail 

in this analysis: Air Quality, Geologic and Paleontological 

Resources, Cave and Karst Resources, Soil Resources, 

Vegetation Resource Uses: Plant Materials, Heritage 

Resources, National Historic Trails, National Natural 

Landmarks, ACECs, and Natural Soundscapes.

4.2.2 Direct and Indirect Impacts

Impacts on water quality can be caused by natural and 

human-caused factors. Natural erosion that increases 

sedimentation or leaching of salts and other mineral elements (e.g., selenium) from soils can degrade water quality in surface water sources; the effects of natural erosion 

can be magnified and accelerated by surface-disturbances. Increased erosion and sedimentation to water bodies 

can result in changes to water chemistry and alter stream 

channel morphology. Contaminants, such as fecal waste 

from livestock, wildlife, and humans, may be directly introduced into surface water sources, also degrading water 

quality. Depending on the level of water quality degradation, surface waters may no longer capable of supporting 

beneficial uses identified by the State of Utah. 

Surface-disturbing activities in areas of low reclamation 

potential (e.g., “fragile soils,” soils derived from specific 

geologic formations) or in sensitive areas, such as stream 

channels and riparian habitats, would increase the potential for soil erosion and water quality impacts. They can 

also remove soil stabilizing agents, such as vegetative cover, 

soil crusts, and woody debris. Loss of one or more of these 

agents increases potential erosion and sediment transport 

to water bodies, leading to water quality degradation. 

Impacts on water resources could result from surface disturbances and increased soil erosion from activities like 

wildfire suppression tactics, livestock trailing, and some 

types of recreational uses. Direct and indirect adverse 

impacts can be mitigated through management actions 

that minimize, preclude, or stipulate how surface disturbances will be authorized; resource impacts that cannot 

be avoided would be minimized by the application of 

BMPs (Appendix F). Management actions developed to 

improve soil conditions, riparian vegetation, and proper 

functioning condition of watersheds would benefit water 

resources, in the short and long term.

4.2.2.1 Impacts from Management of Water 

Resources

Under all action alternatives, the goals of management 

are to conserve and protect water resources so that they 

can fulfill the purposes of the NCA and sustain ecosystem resiliency under changing climatic conditions. BLM 

would seek to acquire water rights from willing sellers 

to benefit wildlife and recreation and improve aquatic 

habitats and riparian areas.

Measures to improve or protect water quality involve 

protecting the integrity and health of the soil, minimizing surface disturbances that impair physical and biological soil crusts, reducing soil compaction, and maintaining vegetative cover.

Site-specific mitigation measures and the application of 

BMPs for surface disturbing activities would maintain 

soil stability and minimize wind and water erosion, protecting surface water sources from accelerated sedimentation. Post-fire ES&R actions would be implemented 

to minimize soil erosion that could impair water quality 

in surface water sources, such as Beaver Dam Wash and 

ephemeral drainages. Impacts on water resources under 
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WATER RESOURCES WATER RESOURCES

less acreage could be quickly treated. Not authorizing the 

use of mechanical equipment or herbicides in riparian 

areas would be highly protective of soil and water quality. 

4.2.2.4 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing

Improperly managed livestock grazing can remove effective ground cover, increasing the potential for impacts 

on water quality and soil erosion. Cattle can impair 

water quality by directly depositing manure and urine 

into surface water or in areas where runoff and leaching 

can transport these materials into surface water; and by 

reducing the capacity of riparian vegetation to provide 

shade, filter contaminants, and stabilize stream banks. 

The effects of livestock grazing on water quality can be 

managed by controlling the timing, intensity, duration, 

and spatial distribution of grazing.

Impacts from hoof action are detrimental to soil health 

because this type of disturbance favors establishment of 

noxious weeds and invasive species, destroys biologic 

soil crusts, or occurs in previously disturbed areas not 

suitable for livestock grazing. Destruction of biologic soil 

crusts reduces soil’s surface resistance to erosion, increasing soil loss and sediment transport into surface water 

sources, degrading water quality.

In the NCA, under Alternatives A, B, and D, livestock 

grazing would continue to be managed in the context 

of achieving Utah Standards for Rangeland Health and 

grazing management practices designed to minimize impacts to soils and water quality. Soil conditions and land 

health would be evaluated when permits are renewed 

or allotment management plans are revised. Periods of 

rest in livestock grazing allotments would help elevate 

effective ground cover and promote higher rates of litter 

accumulation. Increasing litter and ground cover would 

reduce erosion from overland flow and allow water to infiltrate more efficiently into soils, improving soil moisture 

and reducing erosion potential. Increased soil moisture 

also would help establish and maintain desirable plant 

species, which also reduces erosion potential.

Under Alternative A, B, and D, public lands would 

continue to be available for grazing, with the exception 

of the 1,063 acre fenced Woodbury Desert Study Area 

which would continue to be unavailable for grazing over 

the life of the RMP. Under Alternative B, the permitted use would be established at 1,861 AUMs, reflecting 

the 20 year average of actual use for the four allotments 

located within or partially within the NCA. This alternative would also establish grazing utilization levels at 40% 

of current year’s growth in designated critical habitat for 

desert tortoise. Alternative D would establish grazing 

utilization levels at 45% of current year’s growth in designated critical habitat for desert tortoise. Livestock would 

be excluded from all areas where re-vegetation projects 

have been initiated, until resource goals and objectives 

have been met.

Alternatives A, B, and D would allow the development 

of new range projects; Alternatives B and D would 

authorize only those range developments that further 

the purposes of the NCA and benefit diverse resource 

values. Seasons of use for all allotments would authorize 

only fall, winter, and early spring grazing, with grazing in 

designated critical tortoise habitat ending on March 15.

When compared to Alternative A, Alternatives B and 

D would be expected to provide slightly higher levels 

of protection for soil, vegetation, and water resources. 

Under Alternative B, the initial stocking rate would be reduced from 3,099 AUMs to 1,861 AUMs, potentially reducing the impacts of grazing on riparian resources and 

surface water quality in Beaver Dam Wash. Utilization 

on current year’s growth would be reduced between 

10 and 15%, respectively, under these alternatives. The 

reductions should improve the health and productivity of 

vegetation communities and lessen the potential for soil 

compaction and erosion. 

Under Alternative C, 61,995 acres of the NCA would be 

unavailable for grazing over the life of the RMP and all 

range developments that do not further the purposes of 

the NCA would be removed. This alternative would provide the highest level of protection for water resources of 

the four alternatives, as cattle would not be contributing 

to soil compaction or erosion, or to the loss of vegetative 

cover. It would also eliminate the introduction of livestock 

manure into surface water sources and impacts on water 

quality related to trampling of stream banks and sedimentation into surface sources, like Beaver Dam Wash. 

4.2.2.5 Impacts from Management of Special Status 

Species, Including BLM Sensitive Species

Under all alternatives, the goals are to protect, conserve, 

and restore critical habitats and assist the recovery and 

delisting of threatened and endangered species and preclude the need to list additional species under the ESA. 

By protecting, conserving, and enhancing these habitats, 

proper functioning condition of native vegetation communities, soils, and watersheds will be maintained. These 

actions would preserve surface water quality and stream 

flow sustainability. All alternatives propose implementing 

short and long term. No alternative would authorize 

wildfire use in the NCA.

Alternatives B, C, and D identify that full suppression 

tactics should be employed to minimize the loss of 

unburned and once-burned native vegetation communities, particularly late successional desert shrublands. 

Alternative C prohibits the use of backburning in these 

communities, while Alternative B and D require a caseby-case evaluation and specific approvals for the use 

of this tool. Use of backburning and heavy equipment 

during full suppression would create new surface disturbances that could increase soil erosion and sediment 

delivery to the Beaver Dam Wash, in the short term. The 

impacts related to fire suppression would be lessened to 

the extent possible through post fire ES&R actions under 

all alternatives and rehabilitation plans designed to reestablish vegetation cover to lessen soil erosion potential. 

Under Alternative A, various methods to accomplish 

hazardous fuel reduction projects could be authorized, 

including the use of prescriptive fires. Were prescriptive fires to be ignited in the NCA, the potential impacts 

on soils, native vegetation, and surface water sources 

would be higher than those under other alternatives. 

Prescriptive fires would be expected to remove larger 

acreages of native vegetation and damage soil crusts, increasing the likelihood of soil erosion and sedimentation 

in ephemeral washes that drain to the Beaver Dam Wash. 

Natural re-vegetation of Mojave Desert species would not 

occur for many years, leaving soils potentially exposed 

for the long term. 

Alternatives B, C, and D focus management on the creation of fuel breaks and hazardous fuel reduction projects 

intended to conserve and protect native Mojave Desert 

and Great Basin transition vegetation communities by 

lessening the potential for initial and “re-burn” fires. The 

desert shrublands of these communities are not fireadapted and recovery of late successional species, like 

blackbrush and Joshua trees, from fire or other surface 

disturbances will not occur for hundreds of years, if at all. 

Large scale prescriptive fires to reduce hazardous fuels 

would not be authorized under these alternatives.

Alternatives B and D provide the greatest flexibility in the 

methods that would be employed, including biological, 

herbicidal, targeted grazing, and mechanical methods. In 

the short term, the use of any of these methods on a large 

scale could leave soil surfaces exposed to wind and water 

erosion, potentially increasing run-off and sedimentation to surface water in Beaver Dam Wash. Water quality 

could be impacted until vegetation cover and soil crusts 

have been re-established. 

Alternative C restricts the methods that could be authorized to those that would create the least amount of 

new surface disturbance (hand removal and low impact 

mechanical methods), potentially lessening the potential 

for soil erosion that could negatively impact surface water 

quality in Beaver Dam Wash. Limiting treatments under 

Alternative C would benefit soils in terms of reducing 

treatment-related compaction, soil disturbance, and chemical applications, but could limit the acreage that is able to 

be protected quickly or cost-effectively from the threats of 

wildfires. Wildfires could continue to damage or destroy 

many acres of desert shrubs, before effective fuel breaks 

or hazard fuel reduction projects would be completed, 

increasing short and long-term soil erosion potential. 

Alternative A identifies mechanical and prescribed fire 

as the only tools that can be used to reduce hazardous 

fuel levels. As the native vegetation communities of the 

NCA are slow to recover and not fire-adapted, the use of 

mechanical equipment and/or prescriptive fire under this 

alternative would leave soils exposed to wind and water 

erosion in the short and long term.

4.2.2.3 Impacts from Management of Noxious Weeds 

and Invasive Species

Noxious weeds and invasive species can ultimately result 

in vegetative monocultures that are less effective than 

diverse native vegetation communities at protecting 

soils from erosion. Increased erosion and sedimentation 

to water bodies can change water chemistry and alter 

stream channel morphology. Eradication of noxious 

weeds and invasive species could create short-term surface disturbances, but over the long term, would benefit 

soils through surface stabilization with desirable species 

and reduced erosion potential. 

Under all alternatives, noxious weeds would be managed through Integrated Weed Management, in order to 

control, suppress and ultimately eradicate these species. 

Alternatives B, C, D would provide the BLM with a suite 

of options for controlling noxious weeds, while protecting 

soil and water resources. These alternatives identify strategies for controlling and ultimately eradicating non-native 

tamarisk and Russian olive in riparian areas, protecting 

stream flows and water quality in Beaver Dam Wash. 

Alternative C would limit the aggressiveness with which 

the BLM could treat weed infestations, by limiting methods only to hand tools, which could result in the expansion of some noxious weeds, at least in the short term, as 
610 Chapter 4 BDWNCA BDWNCA Chapter 4 611

WATER RESOURCES WATER RESOURCES

trails also have the potential to degrade water quality, as 

they contribute to the development of unauthorized “social” trails and trail braiding. These, in turn, create new 

soils and vegetation disturbances that increase erosion 

and sediment movement into surface waters. 

Alternative A provides very little specific management 

direction relating to dispersed recreation uses in the 

NCA and, therefore, does not limit or restrict activities 

that could degrade water quality, such as dispersed camping within the stream channel of Beaver Dam Wash or 

near springs. 

Alternatives B, C, and D develop a range of management 

alternatives for dispersed recreation that would minimize 

impacts on soils, vegetation, and surface water sources. 

Each of these alternatives would limit dispersed camping 

to designated, undeveloped campsites located in previously disturbed areas away from surface water sources.

Recreational prospecting is another activity that can 

negatively impact water resources. Alternative A does not 

identify any management actions related to this activity. 

Alternatives B and D would prohibit the use of portable 

suction dredges, as well as motorized and mechanized 

sluicing equipment that could impair water quality in the 

Beaver Dam Wash or ephemeral streams that flow into 

the Wash. Alternative C would prohibit all “casual use” 

recreational prospecting in the NCA, affording a higher 

level of protection for soil and water resources, when 

compared to the three other alternatives.

Recreational target shooting, where such use is concentrated near surface water sources, may also degrade water 

quality. Lead bullets left behind can leach into soils and 

nearby surface waters, resulting in elevated concentrations of lead. Under Alternative A, recreational target 

shooting could continue in the NCA, with no restrictions 

on locations or the types of backstops that could be used. 

Lead concentrations in surface water in the Beaver Dam 

Wash could increase, as a result of contamination of soils 

within and near ephemeral drainages where intensive 

target shooting occurs, as lead-contaminated soils could 

be carried during seasonal flooding events into the Wash. 

Alternatives B and D would provide for the continuation 

of recreational target shooting, with restrictions on locations and the types of backstops and targets that must be 

used. These alternatives could lessen the likelihood that 

lead concentrations in soils might contaminate surface 

water sources, by restricting the locations that recreational target shooting would be authorized. 

Alternative C would prohibit recreation target shooting 

and the discharge of firearms, except in the act of licensed hunting according to state laws during prescribed 

hunting season. This alternative would provide the highest level of protection to water resources related to this 

activity. The three action alternatives would better protect 

surface water sources from lead contamination related 

to concentrated recreational target shooting near water 

sources, when compared to Alternative A (No Action). 

Alternatives B, C, and D would develop a professionally-designed non-motorized trail system in the NCA 

(Appendix I for Criteria for the Placement of Natural 

Surface Trails), to provide high-quality experiences for 

diverse users, with trailheads and waysides that provide 

maps and interpretive information about the NCA’s purpose and values. This system would be expected to minimize the number of new social trails that are developed 

in the short and long term, protecting soil and vegetation 

and lessening the potential for accelerated erosion that 

could impair surface water quality. 

4.2.2.10 Impacts from Management of 

Comprehensive Travel and Transportation

Potential impacts or benefits to water resources across alternatives for OHV area designations can be estimated by 

comparing the number of acres that are Open, Limited, 

and Closed to OHV uses. Alternatives that close more 

acres to motorized travel would be expected to provide 

the highest level of protection to soils from surface disturbances, and, indirectly, to surface water sources and 

water quality.

Under all alternatives, the NCA would be managed as 

Limited to Designated Roads and Trails, with specific 

route designations (outside of the Congressionallyidentified Designated Road Areas) to follow through 

the TMP being prepared by BLM for public lands in 

Washington County. This OHV area designation would 

provide direct and indirect benefits to water resources, by 

eliminating off-road motorized vehicle travel and allowing for specific route designations to be made that would 

specifically protect nearby water sources.

4.2.2.11 Impacts from Management of Lands and 

Realty

Under all alternatives, acquisitions of non-federal lands 

within the NCA from willing owners could benefit the 

conservation and protection of water resources, and 

could help to protect water quality in the Beaver Dam 

Wash by lessening the potential for developments or 

post-fire ES&R treatments to stabilize soils and re-establish vegetation cover in habitats for special status species, 

helping to prevent accelerated erosion that could impair 

water quality in Beaver Dam Wash.

Alternatives B, C, and D prioritize the conservation and 

protection of critical habitats from the effects of wildfire, 

through the development of fuel breaks and hazardous 

fuel reduction projects. These alternatives also prioritize 

the restoration of disturbed and fire-damaged vegetation 

communities in designated critical habitats for Mojave 

desert tortoise and other at- risk species. Restoration of 

desired vegetation communities would help to lessen 

wind and water erosion of soils, minimizing the potential 

for water quality degradation through sedimentation.

4.2.2.6 Impacts from Management of Other Fish and 

Wildlife Species 

Under all alternatives, the goals are to protect, conserve, 

and restore watersheds, native vegetation communities 

and wildlife habitats. These actions would increase opportunities for improving overall ecosystem health and 

continue preservation of water quality and sustainability 

of stream flow. All alternatives propose implementing 

post-fire ES&R treatments to stabilize soils and reestablish vegetation cover to prevent accelerated erosion 

that could impair water quality in Beaver Dam Wash. 

Restoration of vegetation communities and habitats 

would also promote more efficient water storage in soils. 

Unlike Alternative A, Alternatives B, C, and D prioritize 

and specifically identify a range of methods for rehabilitating disturbed and fire-damaged vegetation communities. Alternative C would restrict treatment methods to 

non-invasive methods, minimizing surface disturbances 

and lessening the potential for erosion into surface water 

sources. This alternative would be more protective of 

water resources than Alternatives A, B, or D, but could 

result in fewer acres of rehabilitation work being accomplished, as the methods would be more labor intensive.

4.2.2.7 Impacts from Management of Visual 

Resources

Under Alternative A, the entire land base of the NCA 

(63,480 acres) would continue to be managed under 

VRM Class III designation. This alternative would 

provide fewer protections for soil and water resources, 

as moderate changes to the existing character of the 

landscape could be authorized. Many types of surface 

disturbing activities could be authorized within this 

VRM designation.

Under Alternatives B and D, the land base of the NCA 

would be managed under VRM Class II designation. 

Surface-disturbing activities could only be authorized if 

the disturbed area could be returned to a natural appearing condition. Under this VRM designation, ROWs for 

the construction of major above-ground power transmission lines with associated access roads could not be 

authorized in the NCA. Management under this VRM 

designation would subject fewer areas to anthropogenic 

sources of soil erosion and vegetation loss, directly and 

indirectly protecting water resources. 

Alternative C would manage a majority of the NCA under VRM Class II designation (46,916 acres) and 16,564 

acres as VRM Class I. This alternative would afford the 

highest level of protection level for soils, vegetation, and 

water resources, as VRM Class I would preclude the authorization of most surface disturbing activities, since the 

objective of this class is to preserve the existing landscape 

of the area.

4.2.2.8 Impacts from Management of Lands with 

Wilderness Characteristics

Under Alternatives A, B, and D, management would 

not focus on the protection of wilderness characteristics 

within the approximately 29,116-acre inventory area. 

Under Alternative C, BLM would commit to preserving wilderness characteristics on approximately 16,721 

acres, by managing motorized vehicle travel as Limited to 

Designated Roads and Trails, under VRM Class I, and as 

a ROW Exclusion area. These management prescriptions 

would minimize new surface disturbances that could 

accelerate soil erosion and introduce sediments into the 

Beaver Dam Wash.

4.2.2.9 Impacts from Management of Recreation and 

Visitor Services

Management of the NCA would conserve, protect, and 

enhance sustainable public recreation opportunities, as 

this was one of the purposes for which the NCA received 

Congressional designation. Under all alternatives, authorized recreation activities would be primarily dispersed 

in nature, and include large and small game hunting, 

rock climbing, camping, hiking, equestrian trail riding, 

and nature viewing and photography. Some commercial, 

competitive, and organized group activities could also 

be authorized.

Some of these recreational activities, such as dispersed 

camping, could impact water quality, particularly if human wastes and litter are deposited in springs or streams. 

Poorly constructed or maintained hiking, equestrian 
612 Chapter 4 BDWNCA BDWNCA Chapter 4 613

WATER RESOURCES GEOLOGIC AND PALEONTOLOGICAL RESOURCES

mandates of OPLMA related to motorized vehicle travel 

in three Designated Road Areas. 

The three action alternatives would provide greater protection for water resources, due to the proposed implementation of specific management actions developed to 

conserve, protect, and restore NCA resource values and 

fulfill the purposes for which the public lands received 

special Congressional designation. Alternatives B, C, and 

D would manage the NCA as a ROW Exclusion area and 

as Limited to Designated Roads and Trails for motorized 

vehicle travel, minimizing the potential for direct and 

indirect impacts on soils and water resources that could 

result from new ROW developments and off-road motorized OHV travel. 

Alternatives B and D would make public lands in the 

NCA available for livestock grazing, but with management changes that could lessen impacts on vegetation, 

soils, and water resources. Where monitoring identifies 

impacts on soil and water resources, these impacts would 

be mitigated through changes to the grazing management systems. Under Alternatives B and D, potential 

impacts on water resources related to livestock grazing 

would be expected to be minimal to moderate over the 

life of the RMP.

Under Alternative C, the proposed exclusion of livestock grazing from 61,995 acres of the NCA, proposed 

management as a ROW Exclusion area, and proposed 

management of 16,721 acres of lands with wilderness 

characteristics would provide the highest level of protection for soils and water resources, when compared to all 

other alternatives. 

4.2.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on water 

resources was limited to the 63,480 acres of the NCA 

and the lower Beaver Dam Wash watershed in Utah, as 

surface-disturbing activities and land uses are not expected to affect these resources outside of this area.

Reasonably foreseeable future actions within the NCA 

that could have an effect on water resources include 

wildfires and fire suppression, recreation and visitor uses, 

drought, and climate change. The impacts described 

above could result, but would be mitigated through application of BMPs and management actions identified 

under the management alternatives.

Under all alternatives, water resources would receive 

certain levels of protection due to management in accordance with the Clean Water Act, the Utah Fundamentals 

of Rangeland Health and Standards and Guidelines for 

Grazing Administration, and other applicable state and 

federal water quality standards. Site-specific mitigation 

and BMPs for surface-disturbing activities would further 

reduce impacts on water resources.

Past livestock grazing and recreation uses have affected 

soil and water resources, but, as described in Chapter 3, 

active management of grazing allotments has lessened 

these effects over time. Invasive annual grasses that fuel 

fire regimes atypical for Mojave Desert ecosystems now 

pose the greatest threats to the survival of native vegetation communities, productive soils and biological soil 

crusts, and functioning watersheds.

Recent droughts and potential climate changes that result 

in highly variable amounts of precipitation or changes 

in the timing of seasonal precipitation could decrease 

vegetative cover, increasing the potential for soil erosion, 

fugitive dust production, and impacts on surface water 

quality and availability.

4.3 GEOLOGIC AND PALEONTOLOGICAL 

RESOURCES

This section discusses impacts on paleontological resources and outstanding geologic features from proposed 

management actions of other resources and resource uses. 

Existing conditions concerning paleontological resources 

and outstanding geologic features are described in Section 

3.3.1, Geological and Paleontological Resources.

4.3.1 Methods of Analysis

For the purpose of assessing impacts, only those objectives and actions potentially affecting scientifically 

significant fossils were considered, as well as those 

objectives and actions potentially affecting outstanding 

geologic features. The following impact analysis provides 

a general description of common impacts on geological 

and paleontological resources from management actions 

identified in Chapter 2.

4.3.1.1 Indicators

Adverse impacts include the damage or destruction of 

nonrenewable fossil resources and the loss of information 

associated with these resources, as a result of surface disturbances or the unauthorized collection of fossil remains. 

Impact on outstanding geologic resources would be a 

management concern if they resulted in the destruction, 

severe damage, or alteration of the geologic feature to 

the point of non-recognition or loss of associated educational or scientific information. 

activities that could contribute sediments or pollutants to 

the stream.

Under Alternative A, 63,284 acres of the NCA would 

continue to be managed as an Avoidance area for the siting of new site-type and linear ROWs. Management of a 

majority of the NCA land base as a ROW Avoidance area 

could benefit water resources, as new surface disturbances related to land uses that could be granted under 

site-type and linear ROWs would not occur, lessening the 

potential for soil erosion and sedimentation to surface 

water in the Beaver Dam Wash. 

The narrow designated utility corridor that parallels 

either side of Old Highway 91 (196 acres through the 

NCA) would continue to be managed as a designated 

corridor for linear ROWs under Alternative A. Colocation of new linear ROWs within that corridor would 

be encouraged by BLM, wherever feasible. Future ROW 

developments within that corridor could create new 

surface disturbances, but these would be expected to be 

minor to moderate in scale, temporary in duration, and 

unlikely to impact water resources, as project-specific 

mitigation measures and BMPs would be implemented to 

minimize soil erosion and loss of vegetation. 

Alternatives B and D would manage the NCA as an 

Exclusion area for new site-type and linear ROWs, with 

only minor differences in the acreages proposed (63,420 

acres compared to 63,352 acres, respectively). Each 

alternative would maintain the designated corridor that 

parallels and is bisected by Old Highway 91, but limit 

the total corridor width to 100 feet (60 feet on either side 

of the highway center line, 60 acres total in the NCA) 

under Alternative B and 200 feet (100 feet on either side 

of the highway center line, 128 acres) in Alternative D. 

Linear ROWs would be restricted to subsurface installations only under both alternatives, to protect the scenic 

qualities of the NCA. The potential impacts on water 

resources that might result from future ROWs developments within the designated corridor could be slightly 

higher than to those predicted to occur under Alternative 

A because subsurface installations could disturb more 

acres of soil and vegetation than above-ground utility 

lines. The narrow width of the designated corridor under 

Alternatives B and D would limit the size and types of 

linear ROWs that could be accommodated within the 

corridor, lessening the scale of potential disturbances to 

soil and vegetation that could result in increased soil erosion in ephemeral washes that drain to the Beaver Dam 

Wash. Project-specific mitigation measures and BMPs 

would be implemented to minimize soil erosion, vegetation loss, and impacts on water resources. 

Alternative C would manage the entire NCA as an 

Exclusion area for new site-type and linear ROWs and 

would revoke the designated corridor along Old Highway 

91, subject to valid existing rights. Existing ROWs within 

that corridor and existing site-type ROWs would continue to remain valid as long as they are used for their 

identified purposes. Management or maintenance of 

existing facilities would continue under the terms and 

conditions of the ROW grant. 

Under the three action alternatives, management of 

a majority of the NCA as an Exclusion area for new 

ROWs would provide a higher level of protection for all 

resource values, including water resources, than under 

Alternative A, and should result in negligible impacts on 

water resources.

4.2.2.12 Impacts from Public Education and Outreach

Alternatives B, C, and D identify Public Education 

Outreach and Interpretation opportunities that would 

help to inform public land users about the ecological values of the NCAs and stewardship of these values through 

appropriate public land etiquette. This type of educational outreach would be expected to lessen impacts on soils, 

native vegetation, and watersheds, as public awareness 

and appreciation for the unique values of the NCA is increased and an understanding to the impacts of off-trail 

and damaging activities is enhanced.

4.2.2.13 Impacts from Scientific Research

Alternatives B, C, and D emphasize inventories to locate 

and evaluate all springs and seeps in the NCA and document all spring developments. Other research would be 

conducted to develop a conceptual groundwater model 

of quantity recharge of springs, seeps, and surface flows 

within the NCA and collect data and monitor changes in 

precipitation patterns (e.g., timing, frequency, intensity 

of events) that may affect water resources. These efforts 

could improve the understanding of hydrologic processes 

and enhance efforts to conserve and protect surface and 

groundwater in the NCA in the long term.

4.2.3 Summary of Impacts from Alternatives

Under Alternative A, management of land uses that have 

the potential to impact surface water resources, such 

as livestock grazing, recreation, ROWs, and motorized 

OHV uses, would continue as authorized by decisions 

from SGFO RMP, as modified by the Congressional 
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GEOLOGIC AND PALEONTOLOGICAL RESOURCES GEOLOGIC AND PALEONTOLOGICAL RESOURCES

4.3.2.1 Impacts from Management of Geologic and 

Paleontological Resources

All alternatives would comply with federal legal requirements and BLM policies that address the management of 

paleontological resources and other objects of scientific interest on public lands. Proposed surface-disturbing actions 

would continue to be reviewed and resource inventories 

conducted, as needed, to identify the potential for paleontological resources to be present, the depth and extent of 

ground disturbance, and the presence of the known localities in the vicinity. These measures would help ensure the 

protection of paleontological resources from impacts and 

help preserve opportunities for scientific, educational, and 

recreational uses of these resources.

Under all alternatives, monitoring patrols and condition 

assessments would be conducted at fossil localities and 

no commercial sale or use of petrified wood would be 

allowed in the NCA, helping to protect paleontological 

resources from vandalism and unauthorized collection.

Alternative A provides minimal management direction 

for geological and paleontological resources and makes 

no Use Allocations for these resources.

Under Alternatives B and D, allocating and managing 

100% of vertebrate and invertebrate fossil localities for 

Scientific Use, Conservation for Future Use and Public 

Use are proposed. Alternative C makes similar allocations for Scientific Use and Conservation for Future Use, 

but does not allocate localities to Public Use, providing a 

slightly higher level of protection for fossil resources, as 

Public Use could remove resources or result in vandalism 

or inadvertent resource degradation.

At times it is essential to use hand tools, and sometimes 

even mechanized tools, to inventory and collect paleontological specimens. Alternatives B and D would authorize the use of mechanized equipment, on a case-by-case 

and site- specific basis, to accomplish inventory and 

data recovery, for those researchers holding valid NCA 

Scientific Research Permits and BLM Paleontological 

Resource Use Permits. The impacts from Alternatives B 

and D on fossil resources could be negligible to minor, 

depending on the amount, scale, location, and access to 

the area and resource being excavated; mitigation measures would lessen negative impacts to the extent possible. Beneficial effects would result from the increased 

scientific knowledge gained by these research efforts.

Under Alternative C, mechanized equipment would 

not be authorized for inventory and collection of specimens. This alternative would provide a higher level of 

protection to adjacent fossil resources, soils and vegetation, but could limit the types of specimens that could be 

feasibly exposed for collection, by using only hand tools. 

In turn, this could limit the amount of scientific data that 

is made available through research efforts. 

Alternative B and C prohibit the collection of common invertebrate fossils for commercial or personal 

use. Alternative D would allow the casual collection of 

invertebrate fossils for personal use either by surface 

collection or the use of non-motorized hand tools that 

result in negligible surface disturbance. In the long-term, 

Alternative D could have negative impact to this type 

of paleontological resource, due to “over collecting” by 

the general public and the lack of oversight on what and 

where specimens are collected.

Alternative A allows for the continued collection of petrified [silicified] wood on public lands, as long as collection complies with federal regulations at CFR 3622 and 

is limited to 250 pounds per person per year for personal 

use. No commercial use is permitted to avoid the rapid 

depletion of the resource. However, this alternative does 

not explicitly define the methods that can be used to collect specimens or the locations where petrified wood collection is allowed, which could result in adverse impacts 

on scientifically-important exposures and the long-term 

loss of data. Overall depletion of petrified wood in the 

NCA could occur in the long term, as monitoring of 

quantities collected is not feasible.

Alternatives B and C would prohibit the collection of 

petrified wood for personal use and preserve this resource where it occurs in the NCA.

Alternative D would also allow the collection of petrified wood for personal use (in compliance with federal 

regulation in CFR 3622). The collection allowances are the 

same as Alternative A, but restrict collecting to the use of 

non-motorized hand tools. This alternative would provide 

a higher level of protection for this resource and other 

natural and heritage resources in the vicinity, but could result in the overall depletion of petrified wood in the NCA, 

as monitoring of quantities collected is not feasible.

Measures for interpretation, environmental education, 

use of paleontological resources or outstanding geologic 

features as interpretive sites may enhance appreciation 

and understanding of the fragile and finite nature of 

these resources; however, these uses can also lead to impacts resulting from access and use, such as exacerbated 

erosion from vehicle travel, vandalism, and unauthorized collection.

More generally, adverse impacts on paleontological resources and outstanding geologic features could occur if 

reasonably foreseeable future actions were to:

▶ Conflict with paleontological resource management 

objectives and guidelines established by the BLM;

▶ Disturb geologic formations with high sensitivity 

for scientifically important fossil resources (PFYC 

Classes 3 through 5); 

▶ Destroy or substantially damage or alter an outstanding geologic formation.

4.3.1.2 Assumptions

This analysis includes the following assumptions:

▶ Management actions proposed are designed to conserve, protect, and enhance the resources of 

the NCA; 

▶ Land use proposals would be reviewed for conformance with RMP goals, objectives, and decisions 

and resource impacts analyzed through the NEPA 

process. Whenever projects are authorized, impacts to significant paleontological resources and 

outstanding geological features would be avoided 

or lessened to the extent possible through project 

design, BMPs, and other mitigation measures; 

▶ Occurrences of paleontological resources are closely 

related to the geologic units that contain them; 

Probability for finding paleontological resources 

can be broadly predicted from the geologic units 

present at or near the surface;

▶ Geologic mapping can be used for assessing the 

potential for the occurrence of paleontological 

resources using the BLM’s PFYC system;

▶ Scientifically important fossils would continue to be 

discovered in the NCA;

▶ Discoveries are most likely to occur in geologic 

units classified as high potential PFYC Class 3-5;

▶ Increased knowledge of paleontological resources 

and outstanding geologic features in the planning 

area could lead to improved management that has a 

beneficial impact on the resource and results in an 

increased public stewardship ethic.

Implementing management actions for the following resources would have negligible or no impact on 

Geological and Paleontological Resources and are, 

therefore, not discussed in detail: Air Quality, Water 

Resources, Cave and Karst Resources, Soil Resources, 

Noxious Weeds and Invasive Species, Vegetation 

Resource Uses: Livestock Grazing, Vegetation Resource 

Uses: Plant Materials, Special Status Species, BLM 

Sensitive Species, Other Fish and Wildlife Species, 

Heritage Resources, National Historic Trails, National 

Natural Landmarks, ACECs, Lands with Wilderness 

Characteristics, and Natural Soundscapes.

4.3.2 Direct and Indirect Impacts

Shallowly buried paleontological resources can be 

exposed by natural erosion, which can be exacerbated 

by surface-disturbing activities in the general vicinity of 

the resources. Surface exposure can lead to discovery of 

paleontological resources, but fossils can be damaged or 

lost by the direct action of ground disturbance, subsequent erosion, and unauthorized collection. Measures to 

control erosion and loss of ground cover, such as reducing soil disturbances from land uses and authorized 

activities, as well as maintaining and restoring vegetation, 

have the potential for reducing damage or destruction of 

paleontological resources.

Data recovery excavations can have direct impacts on 

paleontological resources; the very nature of excavation 

is to remove in situ resources, resulting in destruction 

of the fossil locality. These effects are mitigated by data 

collected during excavation, which would be recorded in 

detail for future researchers to see, interpret, and further 

understand. In many cases, paleontological resources 

and outstanding geologic features are actually saved from 

destruction by collection.

Impacts on paleontological resources that would result 

from other types of land uses and authorized activities 

can typically be minimized by implementing mitigation measures, such as monitoring during construction 

activities, excavation of materials, or avoidance of surface 

exposures. If data recovery is the prescribed mitigation, 

fossils may be salvaged that have never been previously 

unearthed by natural processes; these newly-exposed 

fossils then become available for scientific research, 

education, display, and preservation into perpetuity. 

Unmitigated surface-disturbing activities could dislodge 

or damage paleontological resources and features that 

were not visible before surface disturbance.

Under all alternatives in Chapter 2, restrictions on 

surface-disturbing activities would be implemented to 

protect soils and water quality, fish and wildlife and their 

habitats, and heritage resources. These same restrictions 

would help to protect outstanding geological features and 

paleontological resources from damage.
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GEOLOGIC AND PALEONTOLOGICAL RESOURCES GEOLOGIC AND PALEONTOLOGICAL RESOURCES

II. Class I management would be the most protective of 

the scenic qualities of the NCA, as the level of change to 

the characteristic landscape must be very low and must 

not attract the attention of the viewer. Alternative C 

would provide the highest level of protection for paleontological resources and outstanding geological features. 

4.3.2.4 Impacts from Management of Recreation and 

Visitor Services

Some recreational activities can physically alter exposed 

or shallowly buried paleontological resources and outstanding geologic features. Intensive visitor use could 

result in vandalism to geologic features or unauthorized 

collection of fossil resources.

Under Alternative A, the public lands of the NCA would 

continue to be managed as part of the larger St. George 

Field Office ERMA, where casual and dispersed recreation would be emphasized and few management controls implemented to protect resource values. 

Under Alternatives B, C, and D the Beaver Dam Wash 

SRMA would be established and a Recreation Area 

Management Plan developed to identify specific management actions for recreational activities in the SRMA. 

Substantial resource protection would be provided under 

this alternative due to the ability to identify and manage 

specific recreational activities in areas that have significant paleontological or geological resources.

Under Alternatives B and D, casual rock collecting would 

be allowed under the following criteria: using only hand 

tools, no more than 50 pounds per year and only for personal use. These alternatives restrict collection but could 

be difficult to monitor and enforce, potentially limiting 

the level of resource protection that would be achieved 

for paleontological resources. Alternative C would 

prohibit casual rock collection in the NCA, providing a 

higher level of protection for these resource values.

4.3.2.5 Impacts from Management of Travel and 

Transportation

Motorized or mechanized vehicles can physically damage geological features and paleontological localities and 

public access can result in vandalism and unauthorized 

collection of fossils. These impacts are most directly related to the density and location of route networks that are 

designated on public lands, through the TMP process.

The impacts or benefits on geological features and paleontological localities related to OHV area designations can 

be estimated by comparing the number of acres that are 

designated as Open, Limited, and Closed to motorized 

vehicle travel and uses through the RMP. Alternatives that 

close more acres to motorized travel would be expected to 

reduce the potential for damage to paleontological localities and outstanding geological features.

All alternatives would designate the NCA as Limited to 

Designated Roads and Trails. While the specific route 

designations developed in the TMP would have the 

most direct and indirect benefits on paleontological and 

outstanding geological resources, the area designation of 

Limited to Designated Roads and Trails would eliminate 

impacts related to motorized off-road travel and allow 

specific route designations to be made that would protect 

adjacent resource values.

4.3.2.6 Impacts from Management of Lands and 

Realty

Under all alternatives, non-federal inholdings may be 

acquired in the NCA; such acquisitions would provide 

necessary protection to paleontological resources that 

might otherwise be negatively impacted, as acquired 

lands would be managed consistent with the conservation, protection, and enhancement purposes of the NCA.

Alternative A would continue to manage the NCA as a 

ROW Avoidance area for linear and site-type ROWs and 

retain the existing Old Highway 91 designated corridor. 

The potential that new ROW development in that corridor 

would impact paleontological resources is very low and 

no outstanding geological features occur in that corridor; 

mitigation measures and BMPs would be implemented to 

lessen potential impacts and salvage important specimens 

and scientific data that might be damaged or destroyed by 

new developments.

Alternatives B and D would manage the NCA as a ROW 

Exclusion area and retain the existing Old Highway 91 

designated corridor, define specific widths for the corridor 

and require that ROWs be limited to underground installations that could be accommodated within a narrow corridor bisected by a paved highway. New ROWs that might 

be authorized in the designated corridor would have a low 

potential to impact paleontological resources; mitigation 

measures and BMPs would be implemented to lessen impacts and salvage specimens and scientific data that might 

be damaged or destroyed.

Alternative C would manage the NCA as a ROW 

Exclusion area and revoke the designated utility corridor along Old Highway 91 through the NCA, subject to 

valid existing rights. This alternative would provide the 

highest level of protection to paleontological resources 

and outstanding geologic features, when compared to all 

other alternatives.

4.3.2.2 Impacts from Management of Native 

Vegetation, and Fire and Fuels

All alternatives propose to restore fire-damaged native 

vegetation communities through a variety of methods. 

Re-vegetation projects could benefit shallowly buried 

paleontological resources by lessening soil loss to erosion 

after vegetative cover is re-established. Alternatives A and 

D would authorize mechanical methods, like chaining 

and harrowing, that could expose or damage undocumented shallow subsurface paleontological resources; the 

potential for inadvertent damage would be avoided or 

minimized through project planning and review of the 

PFYC classifications for the project area.

Alternatives B and C would authorize non-invasive and 

minimally invasive methods to implement re-vegetation 

projects, to lessen the amount of new surface disturbance 

and potential soil erosion that could result from these 

projects. Both alternatives would provide a higher level 

of protection for undocumented shallow subsurface 

resources, when compared to Alternatives A and D.

High severity fires can cause cracking and spalling of 

surface and shallowly buried paleontological resources. 

Vegetation loss to fires can expose previously undiscovered fossil resources, allowing for their study and protection; however, locations exposed by fire can be susceptible to damage by subsequent erosion, vandalism, and 

unauthorized collecting.

Under Alternative A, full suppression of fires would 

generally be employed, but with some options for minimum impact tactics in special status species’ habitats. 

Alternatives B, C, and D would emphasize full suppression to conserve and protect native vegetation communities, particularly late successional shrublands. 

Fire suppression often requires the construction of fire 

lines and the use of heavy equipment that could directly 

impact paleontological resources or outstanding geologic 

features. Suppression-related impacts on important fossil 

localities or outstanding geological features would be 

avoided whenever possible, through the use of qualified 

Resource Advisors who could identify where resource 

values occur and make recommendations on how to 

avoid impacting them, while still ensuring firefighter 

safety and property protection. 

Fuels management under Alternative A would allow for 

mechanical hazardous fuel reduction treatments and 

prescribed fires; both methods could negatively impact 

surface fossil localities. Project planning would require the 

evaluation of PFYC and paleontological resource databases 

for the NCA to determine whether resources would be at 

risk and development project designs that would avoid 

impacts to scientifically important fossil localities. 

Fuels management under Alternatives B, C, and D would 

not authorize the use of prescriptive fire in the NCA, 

eliminating the potential for damage to fossil resources 

and outstanding geological features related to this 

management tool. These alternatives provide a range of 

methods for hazardous fuel reduction treatments and 

the construction of fire breaks that attempt to minimize 

new surface disturbances. Alternative C would limit 

these methods to hand tools and low impact mechanical 

equipment, providing the highest level of protection for 

shallow surface fossil localities from disturbances, when 

compared to all other alternatives.

4.3.2.3 Impacts from Management of Visual 

Resources

VRM Class I and II objectives provide protection of 

paleontological resources and outstanding geologic 

features by requiring that landscape modifications meet 

high standards for mitigation, usually reducing the scale 

of development that can be permitted in the area. Effects 

would be directly and indirectly reduced where surfacedisturbing activities are limited in the more sensitive 

VRM class areas. Use of the visual resource contrast rating system during project planning could reduce alterations to geologic features and visual intrusions on the 

surrounding landscape.

Under Alternative A, 63,480 acres would continue to be 

managed according to VRM Class III objectives, which 

would allow for modifications to the landscape that 

are noticeable to the casual observer. The potential for 

significant paleontological resources to be present within 

a project area would be evaluated during project design 

and authorization and avoidance or mitigation measures 

developed. Should inadvertent discoveries be made 

during project development, these would be evaluated 

and impacts mitigated, to prevent the loss of important 

scientific data or specimens.

Alternatives B and D would manage 63,480 acres as 

VRM Class II, requiring that the existing character of the 

landscape be retained. This designation would be more 

protective of paleontological resources as it would limit 

the types of projects and the scale of surface disturbances 

that could be authorized in the NCA.

Alternative C would manage the NCA under the most 

restrictive VRM classes, with 16,564 acres of the NCA 

managed as VRM Class I and 46,916 acres as VRM Class 
618 Chapter 4 BDWNCA BDWNCA Chapter 4 619

GEOLOGIC AND PALEONTOLOGICAL RESOURCES CAVE AND KARST RESOURCES

has an impact/effect on these resources. The second 

column lists whether the action(s) is a beneficial effect 

or an adverse impact. The third column provides a brief 

description of the impact/effect and the final column lists 

the intensity of the impact/effect.

4.3.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on paleontological resources and outstanding geological features 

is defined as the public lands of the NCA.

Impacts on paleontological resources and outstanding 

geologic features that have occurred in the past include 

destruction or damage of resources from vandalism, 

unauthorized collection, and the effects of natural processes, without the benefit of recovery, scientific study, 

or interpretation.

Increasing regional populations and demand for recreational uses of public lands in the NCA could increase 

the instances of unauthorized collection of fossils and 

vandalism; natural erosion would continue to impact 

some surface localities, potentially resulting in the unmitigated loss of scientific information. Public education 

and interpretation could help to reduce human-caused 

impacts, encouraging resource stewardship. The management alternatives proposed for the NCA include no present or future actions, or combination of actions, that are 

likely to result in cumulative impacts on paleontological 

resources and outstanding geological resources.

4.4 CAVE AND KARST RESOURCES

This section analyzes potential impacts to caves and karst 

landscapes and associated resources from proposed management actions described in Chapter 2. Existing conditions are described in Section 3.4 (Cave and Karst).

4.4.1 Methods of Analysis

Cave and Karst resource baseline information in Section 

3.4, Cave and Karst Resources, was reviewed for current 

understanding of known resources and to determine the 

condition of the resources. Also, all laws pertinent to determining effects on cave resources (e.g., FCRPA, ARPA) 

were considered and included in criteria for determining 

impacts. This known information was overlain with the 

actions found under each alternative in Chapter 2, and 

conclusions were drawn based on an understanding of 

how these types of actions may affect known and potentially discoverable resources.

4.4.1.1 Indicators

Indicators of beneficial and adverse impacts to cave and 

karst features can be defined by beneficial or negative 

changes to associated resources within the cave. The 

cave resources can be geologic, hydrologic, biological, 

recreational or cultural. Any change to these associated 

resources will be considered a change to the cave system 

as a whole.

Indicators of impacts to cave and karst resources include 

the following:

▶ Extent of ground-surface disturbing activities and 

their potential for effecting known or unknown 

cave and karst resources;

▶ Declines in populations or diversity of cave biota, 

such as bats or endemic invertebrates. Bats are extremely sensitive to visitor presence and may abandon a site if frequently disturbed. Cave endemics 

have adapted to a very unique micro ecosystem and 

are highly sensitive to outside influences such as the 

introduction of foreign substances (human waste, 

food crumbs, alteration of their environment, etc.);

▶ Vandalism, including graffiti in the form of spray 

paint or any other written format or carving into 

the bedrock or intentional damaging of formations 

and other cave resources;

▶ Impacts to or theft of artifacts, features, and cultural deposits in caves;

▶ Indications of overuse by recreation users, such as 

trails, trash, human waste and impacts to any other 

resource due to visitation;

▶ Any decline in water quality due to visitor use or 

any management action that may adversely affect 

the water quality in the cave and/or surrounding 

karst landscape.

Indicators of beneficial effects on cave and karst 

resources:

▶ Measures that restrict surface development or 

activities for the purpose of resource protection can 

provide direct and indirect protection of cave and 

karst resources from disturbance and from incompatible and unauthorized activities.

4.4.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA;

▶ Land use proposals would be reviewed for conformance with RMP goals, objectives, and decisions and 

resource impacts analyzed through the NEPA process. Impacts on significant cave and karst resources 

4.3.2.7 Impacts from Management of Public 

Education and Interpretation

Alternatives B, C, and D identify Public Education and 

Interpretation opportunities that would help to inform 

public land users about the geological values of the NCAs 

and stewardship of these values through appropriate 

public land etiquette. This type of educational outreach 

would be expected to lessen impacts on paleontological 

and outstanding geological resources, as public awareness and appreciation for the unique values of the NCA is 

increased. The management of paleontological resources 

or outstanding geologic features as interpretive sites may 

enhance appreciation and understanding of the fragile 

and finite nature of these resources; however, public 

visitation could also lead to impacts resulting from access 

and use, such as exacerbated erosion from vehicle travel, 

vandalism, and unauthorized collection.

4.3.2.8 Impacts from Management of Scientific 

Research

Under Alternatives B, C, and D, research opportunities 

would be pursued that further the scientific understanding of the earth’s history, through the study of the geologic formations and paleontological resources of the NCA. 

Knowledge gained would help the BLM more effectively 

and efficiently manage these resources and provide opportunities for the public to benefit from this research.

4.3.3 Summary of Impacts from Alternatives

Table 4-2 provides a summary of the impacts to paleontological resources and outstanding geological features. 

The first column lists the resource or resource use that 

Resource/Resource Use Impact/Effect Description Intensity

Geological/Paleontological

Effect

Paleontological surveys could identify more fossil localities that 

would be evaluated and management actions identified to protect 

significant values. 

Under Alternatives B and C, restrictions on the collection of 

common invertebrate fossils and petrified wood would conserve 

resource values.

Minor to 

Moderate

Cave and Karst

Effect

Inventories would identify previously undocumented caves and 

karsts. These would be evaluated and management actions identified to protect significant cave resourcesUnknown

Fire and Fuels

Impact

Fire suppression may damage surface or shallow fossil resources.

Post-fire erosion could result in burial or removal of surface and 

shallow fossil resources.

Minor to 

Moderate

Effect Loss of vegetation to fires may disclose new paleontological sites, 

facilitating evaluation and appropriate management. Unknown

Travel Management

Effect

Limited area designation for OHVs would protect resources from 

disturbances and impacts associated with off-road motorized 

vehicle travel.

Minor to 

Moderate

Visual Resources

Effect

VRM Class I and II designation would protect paleontological 

resources from disturbances and impacts associated with authorized developments, such as utility transmission lines.Minor

Recreation and Visitor 

Services Effect

Under Alternatives B, C, and D, more intensive management of 

recreation uses would lessen potential for surface disturbances 

that expose or damage surface and shallow fossil resources.

Moderate

Lands and Realty

Effect

Management as Avoidance or Exclusion to linear and site-type 

ROWs would protect surface and shallow fossil resources from 

disturbances related to developments, such as utility transmission 

lines.

Negligible 

to 

Moderate

Public Education and 

Outreach Effect

Under Alternatives B, C, D, development of an Interpretive 

Master Plan could increase public understanding of paleo-environments and life forms and enhance stewardship of geological 

and fossil resources.

Minor to 

Moderate

Scientific Research Effect Alternatives B, C, D pursue opportunities for research that would 

improve cave management.

Minor to 

Moderate

Table 4-2 Summary of Impacts to Geology and Paleontological Resources
620 Chapter 4 BDWNCA BDWNCA Chapter 4 621

CAVE AND KARST RESOURCES CAVE AND KARST RESOURCES

Alternative B would authorize the development of on-site 

interpretation for significant cave and karst resources 

that are managed for Public Use. This positive effect 

would provide an excellent opportunity to educate the 

visiting public about cave and karst resources and the 

potential impact they may have on them. It may have a 

small negative impact to actual resources based on what 

type and where interpretation might be required.

Alternative C allows for off-site interpretation for significant cave and karst resources that are managed for 

Conservation for Future Use and Scientific Use. This, 

too, would have a moderate positive effect and lessen the 

potential for any negative impacts that might result from 

on-site interpretation of resources.

4.4.2.4 Impacts from Management of Special Status 

Species, including BLM Sensitive Species

Alternative A provides no specific management direction 

relating to cave and karst features that provide habitats for 

special status species, including BLM Sensitive Species. 

Under Alternatives B, C and D, caves would be managed 

to protect habitats, particularly the various types of habitats required by bats (e.g. forging, roosting, maternity sites 

and winter hibernacula) and reduce the spread of contagious diseases, like White Nose Syndrome (WNS). The 

use of herbicides, pesticides or poisons that are injurious 

or toxic to bats or other special status or sensitive species 

would not be authorized. The installation of bat friendly 

gates would be required for caves and karst features that 

require restriction or closures. The alternatives would not 

authorize activities that have the potential to disturb bats 

within .25 mile radius of maternity roost sites or winter 

hibernacula in any cave, karst feature or abandoned mine. 

These management actions would have an overall positive and long term beneficial effect on any special status 

species that occupy caves and karsts, helping to protect 

species from human-caused impacts.

4.4.2.5 Impacts from Management of Heritage 

Resources

Under all alternatives, heritage resources would be managed consistent with the legal and regulatory requirements of NHPA and ARPA. Where caves and karsts contain archaeological materials, deposits, and features, their 

management as NRHP-eligible heritage resources could 

provide a high level of protection for these resources. 

Alternative A proposes to employ reasonable measures to 

reduce human impacts, looting, and vandalism, to apply 

conservation management to selected areas to maintain resources in present condition for future study, to 

authorize research studies, and provide for the stabilization, maintenance, and interpretation of sites for public 

enjoyment. It does not, however, provide specific management actions to implement these goals and objectives. 

Under Alternatives B, C, and D, 100% of all NRHPeligible site types that include caves, rock shelters, 

and alcoves with archaeological deposits, features, 

and materials would be allocated to the following Use 

Allocations: Scientific Use, Conservation for Future Use 

and Traditional Use. Management actions could include 

the installation of physical barriers (e.g. fencing, plantings, gates) to protect these sites. Gates or other physical 

barriers would be designed to allow unimpeded ingress 

and egress by bats or other cave fauna and protect cave 

micro-environments.

These alternatives also provide for the installation of 

informational signs on site etiquette and ARPA at caves, 

rock shelters, and alcoves, where evidence of public use 

exists. Signing could increase public awareness of cave 

and karst systems and lessen human-caused impacts on 

these resources, positively benefitting these resources.

4.4.2.6 Impacts from Management of Recreation and 

Visitor Services

Specific recreation activities, such as climbing or geocaching, could impact cave and karst resources by damaging cave geological formations, compacting or disturbing soils and introducing litter into cave ecosystems and 

disturbing bats or other cave fauna.

Alternative A contains no specific management direction 

related to these recreational uses within or near cave and 

karst resources.

Under Alternative B, C, and D, management goals, objectives, and proposed actions related to Recreation and 

Visitor Services would be expected to further the conservation and protection of cave and karst resources. These 

would develop implementation-level climbing management plans that identify authorized climbing areas, 

routes, and use restrictions developed to protect resource 

values, including caves and karsts.

All alternatives would allow for physical geocaching in 

the NCA, but Alternatives B, C, and D limit this activity 

to specific zones. Geocaching in caves could directly and 

indirectly impact cave formations and disturb or displace 

cave fauna. Alternatives B, C, and D would require that 

permission must be granted by BLM prior to placement 

of physical geocaches in the authorized zones, which 

could minimize the potential for geocaches to be approved that would impact cave resources. However, if the 

would be avoided or minimized through project 

design, BMPs, and other mitigation measures; 

▶ Caves and karsts will be inventoried to determine 

if they meet significance criteria under the FCRPA 

and whether they contain archaeological resources 

that make them eligible for listing to the NRHP.

Implementing management actions for the following resources would have no or negligible impacts 

on the cave and karst areas and are, therefore, not 

analyzed in this section: Air Quality, Soil Resources, 

Native Vegetation Communities and Fire and Fuels 

Management, Vegetation Resource Uses: Livestock 

Grazing, Vegetation Resource Uses: Plant Materials, 

Noxious Weeds and Invasive Species, Special Status 

Species, Other Fish and Wildlife Species, National 

Historic Trails, National Natural Landmarks, ACEC, 

Visual Resource Management, Natural Soundscapes, 

Lands with Wilderness Characteristics, Comprehensive 

Travel and Transportation Management, and Lands and 

Realty Management.

4.4.2 Direct and Indirect Impacts

Impacts to cave and karst resources can result from public land uses, including those that have a negative impact 

on the quality of water that enters a cave or karst or on 

cave-dwelling biota. Many caves are impacted by public 

visitation that damages geologic formations or introduces 

litter and human waste. The impacts can extend to any 

cultural, paleontological, or biological resources that occur in the cave.

4.4.2.1 Impacts from Management of Water 

Resources

Water sources and shallow aquifers may be important 

to caves and karst features and management actions to 

protect water resources could benefit specific caves and 

karst systems. 

All alternatives would implement actions to protect 

watersheds, reduce soil erosion and sedimentation into 

streams, and improve water quality in surface water 

sources. Similarly, all alternatives would seek to acquire 

non-federal lands that might benefit the conservation 

and protection of surface and groundwater resources. 

Alternatives B, C, and D would restrict surface disturbing 

activities within 500 feet, 1000 feet, and 250 feet, respectively, of riparian areas, to protect surface flows and native vegetation. Each of these management actions could 

benefit the protection of water quality and quantity that 

support cave and karst ecosystems and cave biota.

4.4.2.2 Impacts from Management of Geologic and 

Paleontological Resources

Alternative A proposes to apply the principles of conservation management to selected areas to maintain paleontological resources in the present condition, to authorize 

appropriate scientific studies of these resources, and to 

stabilize, maintain, and interpret selected sites for public 

education. It does not, however, provides specific management actions to implement these goals and objectives. 

Alternatives B, C, and D provide management direction 

for paleontological localities that include allocations 

of specific resources to Use Allocations and identifies 

how resources would be managed under each allocation. Proposed management of paleontological resources 

where they occur within or near cave and karst resources 

could help to prevent surface disturbances, erosion, 

inadvertent damage, and unauthorized collection of 

cave resources. The level of protection for cave and karst 

resources would be higher under these alternatives, when 

compared to Alternative A, because of the specificity of 

the proposed management actions.

4.4.2.3 Impacts from Management of Cave and Karst 

Resources

Alternative A provides no specific management direction 

for cave resources and karst systems in the NCA. 

Alternatives B, C, and D identify management goals, 

objectives, and actions designed to conserve and protect 

these resources for the benefit of present and future generations. Under these alternatives, systematic inventories 

would be conducted in areas with high potential for new 

caves and karst resources; newly-identified resources 

would be evaluated for significance under the FCRPA. 

Significant caves would be managed for Conservation for 

Future Use and Scientific Use.

Alternatives B and D would also evaluate caves and karst 

resources for significance for Public Use. Resources that 

are identified for Public Use could be a greater risk of 

impacts related to recreational and public uses, which 

can negatively affect cave structures, biota, and microenvironments. Alternatives B and D would develop 

implementation-level cave management plans for significant caves and karst resources that are identified for 

Public Use, to develop management objectives and actions needed to protect cave resources from the potential 

impacts of public visitation and recreational uses. These 

alternatives could result in the greatest positive effects 

for all cave and karst areas that are open to public and 

recreational use.
622 Chapter 4 BDWNCA BDWNCA Chapter 4 623

CAVE AND KARST RESOURCES SOIL RESOURCES

4.5 SOIL RESOURCES

This section discusses impacts on soils from proposed 

management actions of other resources and resource 

uses. Existing conditions concerning soils are described 

in Section 3.5 Soil Resources.

4.5.1 Methods of Analysis

4.5.1.1 Indicators

Indicators of adverse impacts on soil resources include 

the following:

▶ Erosion rates above natural conditions, based on 

ecological site descriptions;

▶ Formation of soil terracettes or pedestals;

▶ Formation of rills or gullies;

▶ The inability to meet Utah Standards and Guides 

(Appendix D);

▶ Declining soil health, with soils either unable to 

support vegetation and soil crusts, or not meeting 

site potential, based on ecological site conditions 

(e.g., vegetation type, diversity, density, and vigor).

4.5.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA;

▶ Land use proposals would be reviewed for conformance with RMP goals, objectives and decisions 

for resource values and analyzed through a NEPA 

process. Impacts on soil resources would be avoided 

or minimized through project design, BMPs, and 

other mitigation measures; 

▶ Soil resources would be managed to meet Standard 

1 of the Utah Standards and Guides (Appendix D);

▶ Soil resources would be managed to meet the goals 

of the Colorado River Basin Salinity Control Act;

▶ Projects that help restore watersheds, desirable vegetation communities, or wildlife habitats (including 

surface disturbance associated with these efforts) 

would benefit soil and water resources over the long 

term;

▶ Soils would be managed to minimize erosion (relative to natural erosion rates) and maintain soil 

productivity.

Implementing management for the following resources 

would have negligible or no impact on soils and are, therefore, not discussed in detail: Air Quality, Water Resources, 

Geological and Paleontological Resources, Cave and 

Karst Resources, Vegetation Resource Uses: Plant 

Materials, Special Status Species, BLM Sensitive Species, 

Other Fish and Wildlife Species, Heritage Resources, 

National Historic Trails, National Natural Landmarks, 

ACECs, Natural Soundscapes, Lands with Wilderness 

Characteristics, and Public Education and Interpretation.

cave location has not been included in BLM’s cave inventory database and permission is granted for a location 

that was not known to be a cave or karst, the resource 

impacts could be negligible to minor in the short and 

long term.

Alternatives B, C, and D identify Public Education and 

Interpretation opportunities that would help to inform 

public land users about the geological values of the NCAs 

and stewardship of these values through appropriate 

public land etiquette. These alternatives would allow for 

the development of on-site interpretation for significant 

cave and karst resources that are managed for Public Use. 

This action could benefit the protection of cave and karst 

resources, by educating visitors about cave safety and 

appropriate etiquette to lessen human caused impacts. 

Alternative C would authorize off-site interpretation for 

significant cave and karst resources that are managed for 

Conservation for Future Use and Scientific Use. This, too, 

would have a positive effect by increasing public awareness of and appreciation for cave and 

karst resources.

4.4.2.7 Impacts from Public Education and 

Interpretation

Alternatives B, C, and D identify Public Education and 

Interpretation opportunities that would help to inform 

public land users about the geological values of the NCAs 

and stewardship of these values through appropriate 

public land etiquette. These alternatives would allow for 

the development of on-site interpretation for significant 

cave and karst resources that are managed for Public Use. 

This action could benefit the protection of cave and karst 

resources, by educating visitors about cave safety and 

appropriate etiquette to lessen human caused impacts. 

Alternative C would authorize off-site interpretation for 

significant cave and karst resources that are managed for 

Conservation for Future Use and Scientific Use. This, too, 

would have a positive effect by increasing public awareness of and appreciation for cave and karst resources.

4.4.2.8 Impacts from Management of Scientific 

Research

Under Alternatives B, C, and D, research opportunities would be pursued to conduct spring inventories 

and ground water modeling in the NCA. This research 

could assist with the identification of potential new karst 

areas and the development of appropriate management 

strategies of these areas. Knowledge gained would help 

the BLM more effectively and efficiently manage these 

resources and provide opportunities for the public to 

benefit from this research. Scientific research could be 

authorized under all four alternatives to increase the 

scientific knowledge related to cave and karst ecological systems. Alternatives B, C and D would authorize 

research in cave and karst resources that do not contain 

cultural or paleontological resources through NCA 

Scientific Research Permits. Where cultural or paleontological resources are present, scientific research permits 

would be issued under the legal authorities of PARPA, 

ARPA, and FCRPA. Research studies would assist BLM 

to develop appropriate management strategies to conserve and protect cave and karst resources for present 

and future generations.

4.4.3 Summary of Impacts from Alternatives

Table 4-3 provides a summary of the impacts to cave 

and karst resources. The first column lists the resource or 

resource use that has an impact/effect on these resources. The second column lists whether the action(s) is a 

beneficial effect or an adverse impact. The third column 

provides a brief description of the impact/effect and the 

final column lists the intensity of the impact/effect.

4.4.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on 

caves and karst resources is limited to the Beaver Dam 

Mountains of southwestern Washington County. 

Regional population growth and greater demands for 

recreational use of public lands could increase the scope 

and intensity of impacts on cave resources and karst 

resources. As visitation to caves increases, the incidences 

of vandalism, damage to or removal of cave formations, 

disturbance or displacement of bats and other cave fauna 

would also be predicted to increase in frequency and 

severity. Other land uses and activities, on non-federal 

lands, could impair surface water runoff that may enter 

a cave or karst feature and impact micro-climates and 

biota. Authorized land uses on public lands in the NCA 

would be expected to have negligible impacts on cave 

and karst resources, as a result of compliance with federal environmental and resource protection laws, land 

use restrictions, and the implementation of mitigation 

measures, such as project design and BMPs. Reasonably 

foreseeable future actions, or combinations of foreseeable 

actions, are not expected to cumulatively impact caves 

and karst resources. 

Resource/Resource Use Impact/Effect Description Intensity

Water Resources Effect Groundwater modeling may identify new karst terrain Unknown

Geological/Paleontological Effect Paleontological surveys add protection for caves Unknown

Cave and Karst Effect Cave management plans for recreational uses protect resource 

values

Minor to 

Moderate

Native Vegetation Impact Alternatives A, B, and D authorize use of herbicides that could 

impact karst systems Unknown

Noxious Weeds and Invasive 

Species Impact Alternatives A, B, and D authorize use of herbicides that could impact karst systems Unknown

Special Status Species Effect Alternatives B, C, and D would protect bat habitats in and around 

caves

Moderate

Heritage Resources Impact Alternatives B, C, and D make use allocations that could protect 

cave resources with cultural materials

Minor to 

Moderate

Recreation and Visitor 

Services Effect Alternatives B, C, and D develop management plans for climbing areas that could protect cave and karst resources Moderate

Public Education and 

Outreach Effect

Alternatives B, C, and D would develop interpretation materials 

on and off-site to enhance public appreciation and stewardship of 

cave resources.

Minor to 

Moderate

Scientific Research Effect Alternatives B, C, and D would pursue opportunities for research 

studies that would improve management of cave resources.

Minor to 

Moderate

Table 4-3 Summary of Impacts to Cave and Karst Resources
624 Chapter 4 BDWNCA BDWNCA Chapter 4 625

SOIL RESOURCES SOIL RESOURCES

if the non-native species quickly establish and stabilize 

soils, lessening soil loss to wind and water erosion.

Alternatives B and D would emphasize the use of local and regionally-derived native seeds, plant materials, 

and cultivars for re-vegetation efforts. Both alternatives 

would establish specific criteria that must be met if nonnative species are to be approved for use in the NCA. 

Alternative B would require that five criteria could be 

met, including the requirement that exotic and naturalized species could be confined to the treatment area and 

that use of these species would facilitate the restoration 

of native species. Alternative D would only require that 

two criteria be met: desired native species are not available and the non-native species can be contained in the 

treatment area. When compared to Alternative A, these 

alternatives would help to ensure that non-native species 

approved for re-vegetation projects do not directly and 

negatively impact native vegetation communities and 

indirectly, soil productivity and stability in the long term. 

There could be beneficial effects to soils in the short 

term, if the non-native species quickly establish and stabilize soils, lessening soil loss to wind and water erosion.

Alternative C would require that only native species 

from local sources be approved for use in ES&R projects. 

If these projects cannot be implemented because local 

native seeds and plant materials are not available, soils 

could remain susceptible to wind and water erosion in 

the short term. Exotic invasive annuals would quickly 

dominate the fire damaged area, preventing the re-establishment of native species and impacting soil productivity and stability in the long term.

Under Alternatives B, C, and D, re- vegetation of damaged riparian areas would be prioritized to maintain 

or restore proper functioning condition to springs and 

streams. These projects would be conducted using the 

least invasive methods possible, to lessen the amount 

of new surface disturbance and potential soil erosion. 

Riparian restoration would better protect water quality 

and more quickly return proper ecosystem functions. In 

the long-term, restoration of native plant species would 

benefit water resources, as these species are well-suited 

to local environmental conditions and can thrive without 

depleting soil health and water supplies. 

Alternatives B, C, and D would provide additional 

protection for soils in riparian areas along Beaver Dam 

Wash and in ephemeral drainages, by prohibiting surface-disturbing activities within varying distances (250 

feet, 1,000 feet, and 500 feet, respectively) from the edge 

of the riparian zone. Alternative C would be the most 

protective, limiting such disturbances to within 1,000 feet 

of the edge of the riparian zone, unless the project would 

enhance riparian conditions. Soil erosion potential would 

be lessened by these restrictions, helping to maintain 

watershed function and water quality. 

The goal of wildfire suppression activities is to support the conservation and protection of NCA resource 

values and comply with legal, regulatory, and agency 

policy requirements. The rapid employment and appropriate suppression responses to minimize fire size 

and duration in the NCA would be common to all alternatives. Fire use would not be authorized under any 

alternative in the NCA.

Under Alternatives A, B, and D the use of backburning 

as a fire suppression tactic in late successional shrublands could be authorized. Alternatives B and D would, 

however, require that this tactic be evaluated and specific 

approval by the NCA Manager or Resource Advisor 

granted prior to its use, as these are not fire-adapted 

communities that will quickly or successfully naturally 

re-vegetate. Backburning could remove acres of unburned native vegetation, damage soil crusts, and leave 

soils exposed to wind and water erosion in the short and 

long term. Alternative C would not authorize the use of 

backburning, providing the highest level of protection to 

soils related to this particular fire suppression tactic.

The impacts on soils related to the management alternatives for Fuels Management would be the same as 

those described above under the Management of Native 

Vegetation Communities.

4.5.2.3 Impacts from Management of Noxious Weeds 

and Invasive Species

Under all alternatives noxious weeds would be controlled, suppressed, and ultimately eradicated using 

Integrated Weed Management methods. 

Alternatives B, C, and D specifically identify the methods 

that can be employed to control noxious weeds and invasive species. Alternatives B and D propose the widest array of methods, including any combination of biological 

controls, flaming, herbicides, mechanical methods, and 

hand removal. These would result in some short-term 

impacts on soils, disturbing or compacting soils in the 

treatment areas and removing vegetative cover. Control 

and eventual eradication of noxious weeds and invasive 

species would benefit soils, through surface stabilization 

with desirable native vegetation species.

Alternative C would limit noxious weed and invasive species control to hand removal methods. This 

4.5.2 Direct and Indirect Impacts

Soils on steep slopes and fragile or saline soils are 

particularly susceptible to impacts from surface 

disturbances and compaction, which can lead to 

accelerated erosion, soil loss, and reduced productivity. 

Disturbances can also damage soil stabilizing agents, 

such as vegetative cover, soil crusts, and woody debris. 

Loss of one or more of these agents increases potential 

erosion and sediment transport to water bodies, leading 

to water quality degradation. 

Direct and indirect adverse impacts can be mitigated 

through management actions that minimize, preclude, 

or stipulate how surface disturbances will be authorized; resource impacts that cannot be avoided would 

be minimized by the application of BMPs and other 

mitigation measures. Management actions developed to 

improve water resources, riparian vegetation, and proper 

functioning condition of watersheds would benefit soil 

resources, in the short and long term.

4.5.2.1 Impacts from Management of Soil Resources

Under all alternatives, management goals, objectives, and 

actions would strive to conserve and protect soils and 

implement actions to achieve the goals of the Colorado 

River Basin Salinity Control Act. Post-fire ES&R actions 

would be designed to minimize soil erosion and facilitate 

re-vegetation of desired native plant communities that 

would stabilize and protect soils.

Alternatives B, C, and D would utilize existing two-track 

roads and disturbed areas as the locations for non-motorized trails, trailheads and other facilities, to minimize 

new disturbances to soils and vegetation. Where new 

trails or other facilities are proposed, locations would 

be selected where soils are suitable for these developments, such as areas that are less prone to wind and water 

erosion. Alternative A contains no similar management 

decisions relating to the location of new recreation developments, and would, therefore, not protect soils to the 

same degree as the three action alternatives.

4.5.2.2 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Under all alternatives, land uses and authorized activities would be managed to ensure that ecological systems 

meet or exceed management objectives identified in the 

Utah Standards and Guides (Appendix D). The conservation, protection, and restoration of native vegetation 

communities would continue to be a management priority objective under all alternatives, directly and indirectly 

benefitting soil resources.

Alternative A would authorize hazardous fuel reduction 

and the development of fire breaks to conserve native 

vegetation communities, through mechanical methods 

and the use of prescriptive fire. These methods could 

impact soils, by removing vegetation cover, damaging 

soil crusts, and disturbing soil horizons. Depending on 

the size of the projects, the impacts on soils could be 

negative, moderate to major in scope, and long term, as 

Mojave Desert shrub species do not naturally re-vegetate 

quickly and are not fire-adapted. Soils could remain 

exposed to wind and water erosion in the long term, as a 

result of implementation of these methods.

Alternatives B, C, and D would not authorize the use 

of prescribed fire as a treatment method and would 

focus on developing strategically placed fuel breaks to 

help protect native vegetation communities. A range of 

management tools are proposed under these alternatives 

to develop fuel breaks that would have varying levels of 

impacts on soils.

Alternatives B and D would authorize the widest array of 

methods, including herbicides, targeted grazing, and mechanical clearing. Each of these methods would remove 

vegetation, disturb or compact soil surfaces, and leave 

soils susceptible to wind and water erosion. Alternative 

C would limit the development of fuel breaks to hand removal and low impact mechanical methods, resulting in 

less surface disturbance and fewer impacts on soils when 

compared to all other alternatives. Under these alternatives, the potential impacts on soils would be expected 

to be minor over the life of the RMP, as the fuel breaks 

would incorporate topographic features, major ephemeral drainages, and road networks to the extent possible, to 

minimize new surface disturbances and impacts on soils.

Under Alternative A, post fire ES&R actions and rehabilitation of fire-damaged lands could be conducted using 

non-native species, when native species are not available or 

are not economically feasible, or would not meet ecological objectives. This alternative imposes no requirements 

that the suitability of non-native species for use in the 

Mojave Desert have been clearly demonstrated through 

long term scientific studies or that the introduced non-native species could be confined to the treatment areas. The 

use of non-native species that have not been adequately 

studied, particularly under changing climate conditions, 

could introduce new noxious weeds and invasive species 

that directly impact native vegetation communities and 

indirectly, soil productivity and stability in the long term. 

There could be beneficial effects to soils in the short term, 
626 Chapter 4 BDWNCA BDWNCA Chapter 4 627

SOIL RESOURCES SOIL RESOURCES

the authorization of most surface disturbing activities, 

since the objective of this class is to preserve the existing 

landscape of the area.

4.5.2.6 Impacts from Management of Recreation and 

Visitor Services

Motorized and non-motorized recreational uses of 

public lands have the potential to negatively impact soils 

through surface disturbances, soil compaction, and loss 

of vegetative cover that increase soil susceptibility to 

wind and water erosion. Poorly constructed or maintained recreation trails can lead to trail widening and 

braiding and the proliferation of user-created routes. 

Under Alternative A, the public lands of the NCA 

would continue to be managed as part of the larger St. 

George Field Office ERMA, where casual and dispersed 

recreation would be emphasized and few management 

controls implemented to protect resource values. Current 

management would continue to allow dispersed camping 

within 50 feet of roads, potentially damaging vegetation, 

increasing soil compaction, introducing or spreading 

noxious weeds and invasive species, and increasing the 

risk of wildfires. Removal of dead and down wood for 

campfires would prevent decayed wood matter from 

returning to soils and providing nutrients back into the 

ecosystem. Authorizing noncommercial groups of up to 

75 persons to camp in open areas could continue to damage to soils and native vegetation on much larger scale 

than disturbed camping, with impacts similar to those as 

described above. 

Under Alternatives B, C, and D, the Beaver Dam Wash 

SRMA would be established with sustainable, primarily 

non-motorized, recreation opportunities authorized 

and enhanced. A Recreation Area Management Plan 

would be developed to identify specific management 

actions for recreational activities in the SRMA. Through 

implementation level planning, areas with steep slopes, 

and fragile or saline soils would be avoided as the 

locations for certain types of recreation uses and trails or 

other facilities developments. 

Each of these alternatives would limit dispersed camping to designated campsites that are located in previously 

disturbed areas that are not on fragile or saline soil types. 

Under Alternative C, certain types of activities that can 

be environmentally damaging, like recreational prospecting with mechanized equipment, would not be authorized in the NCA, helping to minimize soil disturbances 

and erosion.

Under the three action alternatives, a professionallydesigned non-motorized trail system would be developed in the NCA to provide high-quality experiences for 

diverse users, with trailheads and waysides that provide 

maps and interpretive information about the NCA’s 

purpose and values. This system would be expected to 

minimize the number of new social trails that are developed in the short and long term, as users would be 

more likely and able to use the designated trail system. 

Moderate to major levels of protection for soil resources 

would be realized in the short and long term under these 

alternatives, when compared to Alternative A, through 

the identification and management of recreational activities in appropriate locations.

4.5.2.7 Impacts from Management of Comprehensive 

Travel and Transportation

The impacts or benefits on soils and native vegetation 

related to OHV area designations can be estimated by 

comparing the number of acres that are designated as 

Open, Limited, and Closed to motorized vehicle travel 

and uses through the RMP. Area closures and limiting vehicle travel to designated roads and trails would 

minimize surface disturbances related to unauthorized 

cross-county travel and route proliferation.

All alternatives propose OHV area designations for the 

NCA, with specific route designations to follow through 

BLM’s development of a TMP for Washington County. 

Under all alternatives, the NCA would be managed as 

Limited to Designated Roads and Trails. Specific route 

designations developed in the TMP would directly and 

indirectly benefit soil resources, minimizing surface 

disturbances related to unauthorized cross-county travel 

and route proliferation.

4.5.2.8 Impacts from Management of Lands and 

Realty

All alternatives would provide for the acquisition of nonfederal inholding from willing sellers, providing benefits 

to soils by managing the acquired lands for the conservation, protection, and restoration of resource values. All 

alternatives would also manage the majority of lands 

within the NCA to avoid or exclude the granting of new 

ROWs that could authorize the development of utilities, 

roads, and communication sites.

Under Alternative A, 63,284 acres of the NCA would be 

managed as a ROW Avoidance area for linear and sitetype ROWs. The designated utility corridor that parallels, 

and is bisected by, Old Highway 91, would be retained 

(196 acres). New linear ROWs for the development of 

alternative would minimize impacts on soils, soil crusts, 

and desirable native vegetation species, but would be 

time consuming and labor intensive, potentially reducing 

the number, size, and effectiveness of weed treatments.

4.5.2.4 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing

Livestock grazing in the NCA must be consistent with 

the mandates of OPLMA at Section 1975 (e) (4) and conducted in a manner that conserves, protects, and enhances the ecological, scenic, wildlife, recreational, cultural, 

historical, natural, educational, and scientific resources of 

the NCA. Grazing management must also be conducted 

to achieve or make substantial progress toward achieving 

the Utah Standards for Rangeland Health for soils and 

upland and riparian vegetation communities.

Under all alternatives, the fenced Woodbury Desert 

Study Area (in the Castle Cliffs Allotment) would remain 

unavailable for livestock grazing over the life of the 

RMP. Soils and vegetation within the 1063 acre Study 

Area would be protected from direct or indirect impacts 

related to livestock use, including surface disturbances, 

compaction, or the introduction and spread of noxious 

weeds or invasive species.

Livestock grazing would continue to be authorized under 

Alternatives A, B, and D in the NCA. The current fall to 

early spring season of use would remain unchanged from 

the current situation under the three alternatives. 

Alternatives A and D would authorize livestock grazing 

on 61,995 acres and provide 3,099 initial AUMs of forage 

in the Beaver Dam Slope, Castle Cliffs, Cedar Pocket, and 

Scarecrow Peak Allotments. Alternative D would establish grazing utilization at 45% of annual growth on key 

species, which would reduce utilization from the current 

50 to 65% rates authorized for the allotments. These alternatives would be likely to result in similar impacts on 

soils, which would include soil disturbances and compaction where livestock trail and congregate. The proposed 

reduction in utilization could result in negligible beneficial effects on native vegetation, helping to maintain 

vegetative cover and soil stability. 

Alternative B would authorize grazing on 61,995 acres, 

but provide 1,861 initial AUMs of forage and reduce 

grazing utilization on key species to 40% of annual 

growth. The proposed changes under this alternative 

would likely result in fewer livestock being grazed and 

for shorter periods of time, which should benefit soils 

by reducing surface disturbances and compaction and 

maintaining vegetative cover. 

Alternative C would make all public lands within the 

NCA unavailable to livestock grazing, benefitting soils 

and vegetation on 61,995 acres by eliminating the soil 

and vegetation impacts that can be attributed to livestock 

grazing. Under this alternative, soil disturbances and 

compaction would be reduced, particularly along fence 

lines and around water sources, lessening the potential 

for wind and water erosion. Grazing impacts on native 

vegetation communities, including riparian vegetation 

within ephemeral drainages and along Beaver Dam 

Wash, would not occur. This alternative would provide 

the highest level of protection for soils and native vegetation when compared to all other alternatives.

4.5.2.5 Impacts from Management of Visual 

Resources

Under Alternative A, the entire land base of the NCA 

(63,480 acres) would continue to be managed under 

VRM Class III designation. This alternative would 

provide fewer protections for soil resources, as moderate 

changes to the existing character of the landscape could 

be authorized. Many types of surface disturbing activities could be authorized within this VRM Class, subject 

to specific reclamation requirements that would be terms 

and conditions attached to permits or other land 

use authorizations.

Under Alternatives B and D, the land base of the NCA 

would be managed under VRM Class II designation, including the designated utility and transportation corridor 

along Old Highway 91. Within this corridor, only subsurface installations would be authorized through ROWs. 

Subsurface installations would be consistent with this 

VRM designation, as surface-disturbing activities could 

be authorized if the disturbed area could be returned to 

a condition of appearing natural to a first-time observer. 

This requirement could result in short-term and negative 

impacts on soils related to subsurface installations within 

the designated corridor, which could disturb as much 

as 60 acres under Alternative B and 128 acres under 

Alternative D. Reclamation requirements would return 

the disturbed areas to a natural appearance, reducing 

the long-term impacts on soils. Management under this 

VRM designation would subject fewer areas of the NCA 

to anthropogenic sources of soil erosion and vegetation 

loss, directly and indirectly protecting soil resources. 

Alternative C would manage a majority of the NCA under VRM Class II designation (46,916 acres) and 16,564 

acres as VRM Class I. This alternative would afford 

the highest level of protection level for soils and native 

vegetation communities, as VRM Class I would preclude 
628 Chapter 4 BDWNCA BDWNCA Chapter 4 629

SOIL RESOURCES NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

vegetation. Management actions would help to ensure 

that erosion of fragile and saline soils does not result 

from land uses or authorized activities on public lands 

and that cryptobiotic soils are protected, reducing the potential for cumulative impacts to result from implementation of any of the alternatives.

4.6 NATIVE VEGETATION COMMUNITIES AND 

FIRE AND FUELS MANAGEMENT

This section discusses impacts on native vegetation communities from proposed management actions identified 

in Chapter 2 for other resources and resource uses. As 

the conservation and protection of native vegetation 

communities in the Mojave Desert is today directly 

linked to fire management and the reduction of hazardous fuels, a combined analysis is included here.

4.6.1 Methods of Analysis

This analysis is organized by resources and resource uses 

that could potentially affect native vegetation, particularly fire and fuels management. Impacts are analyzed 

using the indicators presented below; if no impact on an 

indicator is anticipated, the indicator is not mentioned in 

the analysis. An analysis of the impacts on native vegetation communities for each alternative follows the nature 

and type of impacts discussion.

4.6.1.1 Indicators

Indicators of adverse impacts on native vegetation include the following:

power lines, pipelines, or other utilities could continue to 

be granted in this designated corridor. Impacts on soils 

related to new project developments would be avoided to 

the extent possible or mitigated through project design, 

BMPs, and the terms and conditions of the ROW grant. 

Existing linear ROWs within the corridor, and for existing site-types in the NCA, would remain valid as long as 

they serve the purposes for which the ROW was granted. 

Maintenance of existing facilities would be conducted 

under the terms and conditions of the ROW grants. The 

potential for impacts on soils would be negligible to minor and would result primarily from new constructions 

within the designated corridor along Old Highway 91, 

under this alternative.

Under Alternates B and D, the NCA would be managed 

as a ROW Exclusion area, with the designated corridor 

along Old Highway 91 retained, but with variable widths 

and acreage by alternative. The narrow corridor widths 

proposed under either alternative would preclude large 

scale projects. Both alternatives would restrict new 

ROWs to subsurface installations only, in order to protect the scenic qualities of the NCA. 

 Disturbances to soils could be higher under either 

alternative, when compared to Alternative A, based on 

the requirement that only subsurface installations be 

authorized in the designated corridor. Under Alternative 

B, as many as 60 acres could be disturbed within the 

designated corridor, while under Alternative D, up to 

128 acres could be impacted. Impacts on soils related to 

new project developments within the designated corridor would be avoided to the extent possible or mitigated 

through project design, BMPs, and the terms and conditions of the ROW grant. Existing linear ROWs within the 

corridor and for existing site-types in the NCA would 

remain valid as long as they serve the purposes for which 

the ROW was granted. Maintenance of existing facilities 

would be conducted under the terms and conditions of 

the ROW grants. 

Alternative C would also manage the NCA as a ROW 

Exclusion area, but would revoke the designated corridor 

along Old Highway 91 through the NCA, eliminating 

impacts on soils related to the development of new ROWs 

in that corridor. Existing linear ROWs within the corridor 

and for existing site-types in the NCA would remain valid 

as long as they serve the purposes for which the ROW 

was granted. Maintenance of existing facilities would be 

conducted under the terms and conditions of the ROW 

grants. Maintenance of ROWs in the designated corridor 

along Old Highway 91 could result in negligible to minor 

small-scale soil disturbances over the life of the RMP.

4.5.2.9 Impacts from Management of Scientific 

Research

Alternatives B, C, and D identify research opportunities 

that would improve the management of soil resources, 

including detailed soil surveys and ecological site inventories in the NCA. Potential studies relating to soil crust 

function and regeneration in disturbed and fire-altered 

desert ecosystems could help to develop cost-effective 

methods to restore biological soil crusts. Functioning soil 

crusts would help to stabilize soils, restore soil productivity, and facilitate re-vegetation of damaged lands.

4.5.3 Summary of Impacts from Alternatives

Table 4-4 provides a summary of the impacts to soil 

resources. The first column lists the resource or resource 

use that has an impact/effect on soils. The second column lists whether the action(s) is a beneficial effect or 

an adverse impact. The third column provides a brief 

description of the impact/effect and the final column lists 

the intensity of the impact/effect.

4.5.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on soils is 

defined as the land base of the NCA, as management actions and authorized uses on public lands are not expected to affect soil resources outside of the NCA. Past actions 

within the CIAA that have affected soils resources included overgrazing of the public rangelands; “down wind” 

environmental contamination from radioactive fallout 

generated by above-ground nuclear weapons testing in 

south-central Nevada; utility and access road developments; noxious weeds and invasive species infestations, 

wildfires, and post-fire ES&R actions. Present and reasonably foreseeable future actions would include livestock 

grazing, wildfires, noxious weeds and invasive species 

controls, development of fire breaks and hazardous fuel 

reduction projects, re-vegetation projects, and the development of recreation trails and facilities. Under climate 

change scenarios, increased ambient temperatures, 

droughts, and changes in precipitation patterns could 

negatively impact native vegetation communities and 

soils, potentially increasing wind and water soil erosion.

Management proposed under all alternatives for the 

NCA would conserve and protect soil resources, minimizing impacts through the types of land uses that would 

be authorized. Project authorizations would require the 

implementation of BMPs and other mitigation measures 

that conserve and protect soils, soil crusts, and native 

Resource/Resource Use Impact/Effect Description Intensity

Water Resources

Effect

Under all alternatives, management decisions to protect surface water sources would benefit soils, by limiting surface 

disturbances.

Minor to 

Moderate

Geological/Paleontological Impact Alternative D would authorize mechanical excavations of paleontological resources that could disturb soils. Unknown

Native Vegetation

Impact

Treatment methods proposed under Alternatives A, B, and D 

could create short-term soil disturbances and increase potential 

for soil erosion.

Minor to 

Moderate

Effect

Alternative C proposes non-invasive and minimally invasive 

methods for treatments and restoration, providing highest level 

of protection for soils.

Moderate 

to Major

Noxious Weeds and Invasive 

Species Impact

Treatment methods proposed under all alternatives could disturb 

soils and remove vegetative cover, increasing potential for soil 

erosion in the short term.

Negligible 

to Minor

Special Status Species Effect Under all alternatives, management to conserve, protect, and 

restore habitats for special status species would benefit soils. Moderate

Livestock Grazing

Impact

Under Alternatives A, B, and D, livestock grazing would continue 

to be authorized, resulting in soil compaction and increased erosion potential where livestock congregate and trail. Moderate

Impact

Alternative C would make the NCA unavailable for grazing, 

benefiting soils by eliminating impacts of livestock congregating, 

trailing, and damaging native vegetation.

Moderate 

to Major

Recreation and Visitor 

Services Effect

Alternatives B, C, and D propose restrictions on recreation uses, 

such as dispersed camping and geocaching, and SRP authorizations that can disturb soils.

Negligible 

to 

Moderate

Travel Management

Effect

All alternatives manage motorized OHV use as Limited to 

Designated Roads and Trails, protecting soils from impacts related to cross-country travel.Moderate

Lands and Realty

Impact

Alternative A proposes to manage NCA as Avoidance area that 

could allow for new linear and site-type ROWs that would impact 

soils.

Unknown 

to Minor

Effect

Alternatives B, C, and D propose to manage the NCA as 

Exclusion area for new linear ROWs, protecting soils from development impacts

Minor to 

Moderate

Table 4-4 Summary of Impacts to Soil Resources
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NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

mycorrhizae, which would have a beneficial effect on 

efforts to re-vegetate disturbed and fire-damaged lands. 

Such actions would reduce the competitiveness of nonnative annual grasses and potentially re-establish native 

bunchgrasses and broad-leaved forbs that were formerly 

important components of native vegetation communities 

in the NCA. 

Alternatives B and D would allow use of non-native species, but only under very specific conditions and with 

constraints that would prevent the introduction of species 

that have not been scientifically evaluated for use in the 

Mojave Desert. The use of non-native species could help 

stabilize soils and prevent erosion in the short term, and, 

in the long term, could assist the re-establishment of native 

species. However, there is a risk that the non-native species 

could perpetuate and spread, altering native ecosystems 

and reducing the quality of biophysical settings. 

Alternative C would not allow the use of non-native species for re-vegetation projects and require the use of local 

native seeds and plant materials. Seed mixes would be 

tailored for ES&R projects to include more early successional species, include methods of protecting seeds from 

herbivory, and use hand or low impact methods of working seeds into the soil. This alternative could increase 

the chances of successful germination of seeds and the 

re-vegetation of native communities when compared to 

other alternatives, because it would minimize damage 

to biological soil crusts that sustain soil productivity. If 

local native seeds and plant materials were not available, 

re-vegetation projects could not be undertaken, potentially allowing exotic invasive annuals to proliferate and 

prevent native species from re-establishing in the short 

and long term.

Under Alternatives B, C, and D, land uses, including 

recreational uses and livestock grazing, that have the 

potential to impede the success of re-vegetation projects 

would be excluded from the project areas until project 

resource goals and objectives have been met. This would 

be a beneficial effect, furthering the likelihood that native vegetation communities could be restored in the 

long term.

Managing riparian areas to meet the Utah Standards of 

Rangeland Health, applying appropriate wildfire suppression strategies, use of post-fire ES&R actions and 

application of BMPs would protect riparian resources 

and prevent future damage. Monitoring of riparian areas 

and vegetation should help identify problems and lead to 

adaptive strategies that would help maintain these areas 

in satisfactory conditions.

Wildfires have already changed species composition in 

Mojave Desert vegetation communities, removing late 

successional shrublands and facilitating the conversion of 

large areas to exotic invasive grasslands. The goal of wildfire suppression activities will continue to be to support 

the conservation and protection of NCA resource values 

and comply with legal, regulatory, and agency policy 

requirements. Fire suppression can, however, involve 

ground-disturbing activities, such as the construction of 

fire lines and the use of heavy equipment that can directly impact native vegetation, soils, and water resources. 

Under Alternative A, fire management actions would 

include full suppression, but with some options for 

minimum impact tactics in special status species habitats. These options could be less successful at protecting 

unburned vegetation, given the rapid spread of fires that 

is possible in the Mojave Desert when fueled by invasive 

brome grasses. The use of backburning as part of suppression tactics could continue to be authorized, damaging or destroying unburned native vegetation in an effort 

to reduce fire size and spread.

The rapid employment and appropriate suppression 

responses to minimize fire size and duration in the NCA 

is common to Alternatives B, C, and D. The use of heavy 

equipment and the construction of fire line would damage or destroy some native vegetation, but the impacts 

would be less extensive that what could result from 

large-scale backburning. The use of backburning would 

be evaluated under Alternatives B and D, and minimized 

to the extent possible. Alternative C would not authorize 

the use of backburning as a suppression tool except when 

deemed essential to protect human life, property and the 

effective control of the fire.

Alternative A includes the potential use of prescribed fire 

to achieve management objectives. It is unlikely that this 

method would be employed, given the extent of damage 

and loss to native vegetation communities to catastrophic 

wildfires that have burned in the Mojave Desert since the 

SGFO RMP was approved in 1999.

Alternatives B, C, and D would not authorize large-scale 

prescriptive fires or fire use. Immediate and appropriate 

full suppression and prohibitions on the use of fire as a 

management tool would help to protect unburned native 

vegetation communities from fire-related impacts.

Alternative B could authorize the use of very small-scale 

prescriptive fires, no more than one acre in size outside 

of special status species critical habitats, for research 

purposes by qualified scientists under an NCA Research 

▶ Likelihood for impacts on native vegetation causing 

loss of ecological function, departure from the NRV, 

plant vigor or productivity;

▶ Introduction or spread of noxious weeds and invasive species;

▶ Declining numbers and/or varieties of pollinators;

▶ Conversion of desert shrub communities to exotic 

invasive grasslands.

Indicators of beneficial effects on native vegetation include the following:

▶ Control or eradication of noxious weeds and invasive species; 

▶ Increase in numbers and diversity of pollinators;

▶ Increased plant vigor or productivity.

Indicators of adverse impacts on fire and fuels management include the following:

▶ Alteration of vegetative cover that results in the shift 

of FRCCs away from NRV;

▶ A substantial increase in the risk of wildfire ignitions and the scale and intensity of fires;

▶ Management actions that substantially inhibit fire 

suppression or appropriate fuels treatments.

Indicators of beneficial effects on fire and fuels management include the following:

▶ Alteration of vegetative cover that shift FRCCs 

towards the NRV.

4.6.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA;

▶ The natural fire regime of the Mojave Desert has 

been altered by the presence of exotic invasive species, decreasing the fire-return intervals and fueling 

large scale, high intensity fires in an annual “burnreburn” cycle; 

▶ Noxious weeds and invasive species would continue 

to be introduced and spread as a result of natural 

processes and human activities;

▶ A direct relationship exists between fuel loading 

and potential fire intensity, severity, size, and fire 

suppression costs;

▶ Climatic changes will benefit exotic invasive species 

and negatively impact the health and productivity 

of native Mojave Desert vegetation communities.

Implementing management actions for the following resources would have no or negligible impact on 

Native Vegetation Communities and Fire and Fuels 

Management and are, therefore, not discussed in 

detail: Air Quality, Water Resources, Geologic and 

Paleontological Resources, Cave and Karst Resources, 

Soil Resources, Vegetation Resource Uses: Plant 

Materials, Special Status Species; Other Fish and 

Wildlife Species, Heritage Resources, ACECs, Natural 

Soundscapes, Lands with Wilderness Characteristics, and 

Public Education and Interpretation.

4.6.2 Direct and Indirect Impacts

Under Alternatives B, C, and D, the Native Vegetation 

Communities and Fire and Fuels Management goals and 

objectives are to conserve, protect, and restore native 

Mojave Desert vegetation communities. Management actions address the need to minimize the loss of unburned 

and once-burned native vegetation, to maintain ecosystem and watershed functions, protect soils, and provide 

quality habitats that meet the needs of special status species and other wildlife.

4.6.2.1 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Under all alternatives, ensuring that ecological systems 

meet or exceed management objectives in the Utah 

Standards for Rangeland Health and Guidelines for 

Grazing Management could protect, maintain, or enhance 

native vegetation, biophysical settings, and ecosystems.

All alternatives provide for the use of native plant species 

for restoration and rehabilitation. This would support 

biophysical settings and native habitat by supporting the 

health and vitality of these systems, and could provide 

additional seed sources when plant species establish 

and mature. 

Alternative A requires preparation of site-specific plans 

to identify desired plant communities, establishing 

specific management objectives, and recommending 

practices to be employed to achieve desired results. This 

alternative would authorize the use of non-native species, 

if natives were unavailable or deemed to be too expensive 

for use. Non-native species that have not been scientifically evaluated relating to the benefits or impacts of their 

use in the Mojave Desert could continue be introduced 

in the NCA with uncertain long-term outcomes.

Alternatives B, C, and D would provide for implementation-level restoration plans, use of microsite/fertile 

islands, carbon sequestration, use of supplemental water 

sources and inoculation of cryptogamic soil crust with 
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NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

and could ensure that seeds remain in the soil to germinate and restore vegetation, biophysical settings, and 

ecosystems. These actions would have beneficial effects in 

the short and long term.

4.6.2.2 Impacts from Management of Noxious Weeds 

and Invasive Species

Noxious weeds and invasive species alter the ecological characteristics of native vegetation communities 

and the quality of wildlife habitats. Weed control would 

continue to be implemented under all alternatives, 

using an Integrated Weed Management approach and 

relevant standard operating procedures and mitigation 

measures presented in the Final Vegetation Treatments 

Using Herbicides on BLM Lands in 17 Western States 

Programmatic Environmental Impact Statement (PEIS)

(BLM 2007). With proper implementation, weed treatment methods under all alternatives would eliminate or 

reduce infestations in the long term. 

Alternatives B, C, and D identify a slightly variable range 

of tools to control noxious weeds and invasive species, 

including the potential use of biological controls under 

project-specific plans. Biological controls for invasive 

annual brome grasses are currently in the experimental 

stage and may never be applicable on a broad scale, even 

over the life of the RMP. Alternative C would not authorize targeted grazing limiting an option to potentially 

control infestations. 

Alternatives A, B, and D would also allow chemical 

control of noxious weeds and invasive species in unburned vegetation communities. These could damage 

desired vegetation due to over-spray, improper herbicide 

selection or dosage, or improper timing of application. 

Alternatively, proper chemical control could reduce 

non-native plants while allowing natives to recover if the 

chemicals are selected and used correctly. These would be 

beneficial effects, although there would be a slight risk of 

adverse impacts associated with the use of herbicides.

Alternatives B and D would authorize the use of contracted targeted grazing for specific areas, such as along 

road shoulders, fences, or at trailheads, to control noxious weeds and invasive species and create fuel breaks. 

Domestic sheep and goat herds would not be contracted 

for targeted grazing in the NCA, where appropriate 

separation distances from desert bighorn sheep herds in 

the Beaver Dam Mountains could not be maintained to 

prevent the spread of infections and parasites to these 

wild herds. Targeted grazing in critical habitat for the 

Mojave desert tortoise would be experimental, require 

consultations with the USFWS under Section 7 of the 

ESA, and the environmental consequences are difficult 

to quantify at this time. Adverse impacts from targeted 

grazing could include trampling and denuding of native vegetation, the introduction and spread of noxious 

weeds and invasive species, soil compaction or accelerated erosion from hoof action. Positive effects from the 

use of targeted grazing could include the cost-effective 

reduction of noxious weeds and invasive species and the 

development of fire breaks that would help to conserve 

and protect native vegetation communities.

4.6.2.3 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing 

Under Alternatives A, B, and D, livestock grazing would 

continue to be managed to achieve the Utah Standards 

for Rangeland Health for upland and riparian vegetation 

communities, helping to conserve and protect the health 

and productivity of native vegetation communities in 

the NCA. The current fall, winter, and early spring seasons of use would not be changed under these alternatives, reducing potential impacts on native vegetation 

related to grazing during the spring and summer plant 

growth periods. 

Alternatives A and D would authorize livestock grazing on 61,995 acres and provides 3,099 initial AUMs of 

livestock forage. Alternative D would establish grazing 

utilization levels at 45% of the current year’s growth on 

key species, potentially further reducing the amount of 

forage available for livestock grazing. Establishing utilization levels at 45% would represent a minor reduction 

from current levels (which vary from 50-60% on key species), and could result in negligible to minor beneficial 

effects on native vegetation by conserving plant biomass, 

particularly when plants are stressed by changing climatic conditions. 

Alternative B would authorize livestock grazing on 

61,995 acres and provide 1,861 initial AUMs of livestock 

forage. Other changes proposed under this alternative 

would include establishing grazing utilization levels 

at 40% of the current year’s growth on key species. A 

reduction in initial AUMs of livestock forage and the 

establishment of a substantially lower utilization level on 

key species could result in moderate beneficial effects on 

native vegetation species. 

Cattle selectively consume the flowers and seed pods of the 

Joshua tree and banana yucca during the spring, negatively 

impacting the propagation success of these species. In 

fire-damaged Joshua tree woodlands, continued livestock 

Permit. Native vegetation loss related to research would 

be minimal and could be offset by the scientific knowledge gained. Alternative C would not authorize prescribed burns in the NCA for research purposes, avoiding any loss of native vegetation to fire. Alternative D 

could authorize the use of prescriptive fires, less than 5 

acres in size, for the purpose of research and scientific 

studies, under an NCA Research Permit.

Alternatives B, C, and D propose fuel breaks and hazard 

fuel reduction projects that would help to limit the accidental ignition and spread of wildfires, protecting native 

vegetation communities and critical habitats. The use of 

existing roads, topographic features, and drainages in 

the design of landscape level fuel breaks would minimize the amount of vegetation damage and loss under 

these alternatives.

Alternatives B and D propose the widest array of tools 

that could be used to create fuel breaks, including biological, herbicidal, hand removal, targeted grazing, small 

scale weed flaming, and low impact mechanical methods 

as the means to create the fuel breaks, without causing 

unacceptable levels of damage to native vegetation and 

species habitats. Alternative C would not authorize herbicide use to develop fire breaks and fuel reduction projects, eliminating the potential for impacts related to the 

use of chemical treatments.

All alternatives provide management direction related to 

the methods that can be employed for ES&R actions to 

restore fire-damaged areas. Alternative A would authorize the use of invasive mechanical methods to protect 

seed through chaining or harrowing. These methods 

could further disturb soils and destroy biological soil 

crusts, reducing the nitrogen fixing capabilities and productivity of the soils, and increasing the likelihood that 

exotic invasive brome grasses would proliferate.

Alternatives B, C, and D provide a broader range of potential management tools, but would emphasize use of the 

least invasive methods to accomplish the goals. Alternative 

C would only authorize the use of hand tools for re-vegetation projects and could reduce the success rate of seeding 

efforts. It would also reduce the chance that re-seeding 

activities could inadvertently lead to additional infestations of noxious weeds and invasive species.

All alternatives would emphasize the use of native species 

for ES&R actions and re-vegetation projects. The use of 

native plant species for restoration and rehabilitation 

would support biophysical settings and native habitat by 

supporting the health and vitality of these systems, and 

could provide additional seed sources when plant species 

establish and mature.

Alternatives A, B, and D would allow for the use of 

non-native species, if native species restoration would be 

ineffective or if native seeds are unavailable. Use of nonnative species could help stabilize soils and prevent erosion in the short term, and could provide stable land and 

moisture retention for native species to re-establish in the 

long term. However, there is a risk that the non-native 

species could perpetuate and spread, altering native ecosystems and reducing the quality of biophysical settings.

Alternative C would only authorize the use of native, 

locally derived seeds for restoration, potentially 

producing less biomass than Alternatives A, B, and D, 

but eliminating the risks associated with the use of nonnative species.

Alternatives B, C, and D propose methods to increase the 

success of restoration efforts that could improve vegetation recovery, density, and health in the Mojave Desert. 

If biological soil crusts were inoculated and restored, 

vegetation could re-establish within those areas and 

invasive, non-native plant species would be less likely to 

spread into these areas due to the protective nature of 

the cryptogamic mycorrhizae. Restoration in the Mojave 

Desert ecosystem, including soil crusts, can take 50 to 

100 years or more under natural conditions; use of methods to support restoration could help vegetation establish 

more quickly and prevent mortality during harsh natural 

conditions such as drought. These actions would have 

beneficial effects.

The use of early colonizing [early successional] native 

or native cultivar, annual and perennial species as nurse 

plants would support the regrowth of native vegetation, especially for establishment of plants during early 

growth stages, and could support the continued restoration of biophysical settings. Non-invasive and minimally 

invasive seeding and planting methods could lead to 

less surface disturbance, damage, disturbance or loss of 

vegetation, soil loss, and erosion. Non-invasive seeding methods could prevent or reduce the introduction 

of invasive, non-native plant species from vehicles or 

humans. Use of containerized plants would add larger 

plants into the ecosystem, which could allow those plants 

to establish into the re-vegetation area more rapidly than 

new seedlings.

Non-invasive and minimally invasive methods to protect 

seeds from being consumed by wildlife could prevent or 

reduce surface disturbance, reducing soil loss and erosion 
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NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

Alternative C would manage a majority of the NCA under VRM Class II designation (46,916 acres) and 16,564 

acres as VRM Class I. This alternative would afford the 

highest level of protection level for native vegetation 

communities from project-related impacts and developments, as under VRM Class II the level of change to the 

characteristic landscape must be very low and must not 

attract attention, while under VRM Class I the existing 

character of the landscape must be maintained.

4.6.2.5 Impacts from Management of Recreation and 

Visitor Services

The nature and type of impacts on native vegetation 

from recreational activities would be directly related to 

the location, intensity, and duration of those activities. 

Recreation management strives to minimize the impacts 

of recreational uses through facility developments, restrictions on inappropriate activities, and public education. 

Under Alternative A, the public lands of the NCA 

would continue to be managed as part of the larger St. 

George Field Office ERMA, where casual and dispersed 

recreation would be emphasized and few management 

controls implemented to protect resource values. Current 

management would continue to allow dispersed camping 

within 50 feet of roads, potentially damaging vegetation, 

increasing soil compaction, introducing or spreading 

noxious weeds and invasive species, and increasing the 

risk of wildfires. Removal of dead and down wood for 

campfires would prevent decayed wood matter from 

returning to soils and providing nutrients back into the 

ecosystem. Authorizing noncommercial groups of up to 

75 persons to camp in open areas could continue to damage soils and native vegetation on a much larger scale 

than disturbed camping, with impacts similar to those as 

described above. 

Under Alternatives B, C, and D, the Beaver Dam Wash 

SRMA would be established and recreation uses more 

intensively managed. Visitor amenities and facilities 

would be developed to improve visitor experiences and 

protect resource values. A Recreation Area Management 

Plan would be developed to identify specific management actions for recreational activities in the SRMA. 

Through implementation-level planning, impacts on native vegetation could be minimized through the location 

of authorized activities and recreation developments. 

Under the three action alternatives, a professionallydesigned non-motorized trail system would be developed 

in the NCA, to provide high-quality experiences for 

diverse users, with trailheads and waysides that provide 

maps and interpretive information about the NCA purposes and values. This system would be expected to minimize the number of new social trails that are developed 

in the short and long term, as users would be more likely 

and able to use the designated trail system. Moderate 

to major levels of protection for native vegetation communities would be realized in the short and long term 

under these alternatives, when compared to Alternative 

A, through the identification and management of recreational activities in appropriate locations. 

Each of these alternatives would limit dispersed camping to designated campsites that are located in previously 

disturbed areas, lessening the amount of vegetation that 

would be damaged as a result of this recreation use. 

Under Alternative C, certain types of activities that can 

be environmentally damaging, like recreational prospecting with mechanized equipment, would not be authorized in the NCA, helping to minimize soil disturbances 

and erosion.

4.6.2.6 Impacts from Management of Comprehensive 

Travel and Transportation

The impacts or benefits on native vegetation related to 

OHV area designations can be estimated by comparing 

the number of acres that are designated as Open, Limited 

to Existing Roads and Trails, Limited to Designated 

Roads and Trails, and Closed to motorized vehicle travel 

and uses through the RMP. Area closures and limiting 

vehicle to designated roads and trails would minimize 

surface disturbances related to unauthorized cross-county travel and route proliferation. 

All alternatives propose OHV area designations for the 

NCA, with specific route designations to follow through 

BLM’s development of a TMP for Washington County.

Under all alternatives, the NCA would be managed as 

Limited to Designated Roads and Trails. Specific route 

designations developed in the TMP would directly and 

indirectly benefit native vegetation communities, minimizing surface disturbances related to unauthorized 

cross-county travel and route proliferation.

4.6.2.7 Impacts from Management of Lands and 

Realty

All alternatives would provide for the acquisition of nonfederal inholding from willing sellers, providing benefits 

to native vegetation communities through the management of the acquired lands for conservation, protection, 

and restoration of resource values. All alternatives would 

also manage the majority of lands within the NCA to 

avoid or exclude the granting of new ROWs that could 

grazing under Alternatives A and D could significantly reduce the potential for natural re-vegetation of this species. 

A reduction in the utilization level on key species under 

Alternative D would provide negligible benefits to yuccas, cacti, or other desert species should fewer livestock be 

grazed or the grazing season shortened.

Alternative B would reduce the number of AUMs of 

livestock forage allocated by 1238 AUMs, potentially resulting in fewer livestock being grazed or a reduction in 

the grazing season. This would have a minor to moderate 

beneficial effect on the propagation success of yuccas. 

Fewer head of livestock being grazed or shorter grazing 

periods could allow more plants to successfully produce 

seeds or fruit during critical growth periods. Increased 

propagation success would particularly benefit the Joshua 

tree community, as it has been extensively damaged by 

recent wildfires in the NCA.

Alternative C would make the entire NCA unavailable 

to livestock grazing over the life of the RMP and would 

eliminate all grazing activities within the NCA. This 

alternative would result in major beneficial effects for all 

native Mojave Desert vegetation, as plant biomass would 

be conserved and propagation success for all plants 

increased in the short and long term. The overall health 

and productivity of native vegetation communities would 

be enhanced under this alternative over the life of the 

RMP. This alternative could, however, increase the risk 

that wildfires, fueled by exotic annual brome grasses, 

could increase in size and intensity, as livestock would 

not be reducing the volume of these fine fuels.

There is a currently a lack of scientific data regarding 

the effectiveness of livestock grazing, at current stocking rates and under current management systems, as a 

tool to reduce hazardous fine fuels that “carry” wildfires 

in the Mojave Desert. Cattle and other herbivores will 

consume newly-sprouted exotic annual brome grasses in 

the fall and spring, reducing some of the fuel loading that 

contributes to the current atypical fire cycle in the NCA. 

Grazing may also stimulate the growth of fire-resistant 

native bunch grasses. However, once the exotic brome 

grasses have matured and cured in late spring, they 

provide little nutritional value and will be avoided by 

livestock in favor of other available forage.

Recent fire history indicates that, at current stocking levels 

and under current grazing management systems, livestock 

grazing cannot reduce enough fine fuel loading to prevent 

wildfires from being ignited and “carried” in the Mojave 

Desert. The stocking levels and grazing management 

systems that are currently authorized in the NCA were 

developed to protect critical habitat for the threatened 

Mojave desert tortoise, minimize forage competition between cattle and tortoises during the spring, summer, and 

early fall months, and reduce the potential for trampling of 

active tortoise dens containing nests with eggs or juvenile 

tortoises during the breeding season. 

For livestock grazing to be a more effective hazardous 

fuel reduction tool, changes would be required to current grazing management strategies that could negatively 

impact the recovery and delisting of desert tortoises or 

other resource values.

4.6.2.4 Impacts from Management of Visual 

Resources

Alternative A would continue to manage the 63,480 

acres of NCA as VRM Class III, under which the existing 

character of the landscape must be partially retained and 

the level of change to the characteristic landscape moderate. Management under VRM Class III would allow the 

authorization of projects and surface disturbances that 

could damage or remove vegetation. The level of potential impacts would be negligible to minor, as all projects 

would be subject to specific mitigation and reclamation 

requirements. This VRM Class would not preclude the 

implementation of landscape level fuel breaks or hazardous fuel reduction projects that could increase the level 

of protection for native vegetation communities from 

further damage or loss to wildfire. 

The designated utility and transportation corridor along 

Old Highway 91 would be retained, allowing new ROW 

developments that could impact native vegetation communities to occur on a total of 196 acres within the NCA. 

Under Alternatives B and D, the land base of the NCA 

would be managed under VRM Class II designation, 

including the designated utility and transportation corridor along Old Highway 91. Within this corridor, only 

subsurface installations would be authorized through 

ROWs. Subsurface installations would be consistent with 

this VRM designation, as surface-disturbing activities 

could be authorized if the disturbed area could be returned to a condition of appearing natural to a first-time 

observer. This requirement could result in short-term 

and negative impacts on native vegetation communities related to subsurface installations within the designated corridor, which could disturb as much as 60 acres 

under Alternative B and 128 acres under Alternative D. 

Reclamation requirements would return the disturbed 

areas to a natural appearance, reducing the long-term 

impacts on soils. 
636 Chapter 4 BDWNCA BDWNCA Chapter 4 637

NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

60s, vegetation treatments, and motorized and nonmotorized recreational activities. Natural factors have 

included the introduction and spread of noxious weeds 

and invasive species, wildfires, and extended periods of 

drought and above average precipitation. 

Present and reasonably foreseeable future actions would 

include regional population growth, the expansion of 

the nearby communities of Beaver Dam and Littlefield, 

Arizona, and Mesquite, Nevada, the construction of new 

utilities in the IPP and Navajo-McCullough designated 

authorize the development of utilities, roads, and communication sites that would remove native vegetation 

within project areas.

Under Alternative A, 63, 284 acres of the NCA would 

be managed as a ROW Avoidance area for linear and 

site-type ROWs. The 196 acre designated corridor that 

parallels, and is bisected by, Old Highway 91, would 

be retained. New linear ROWs for the development of 

power lines, pipelines, or other utilities could be granted 

in that designated corridor. Impacts on native vegetation 

related to new project developments would be avoided to 

the extent possible or mitigated through project design, 

BMPs, and the terms and conditions of the ROW grant. 

Existing linear ROWs within the corridor and for existing site-types in the NCA would remain valid as long as 

they serve the purposes for which the ROW was granted. 

Maintenance of existing facilities would be conducted 

under the terms and conditions of the ROW grants. 

The potential for impacts on native vegetation would be 

negligible to minor and would result primarily from new 

constructions within the designated corridor along Old 

Highway 91 under this alternative.

Under Alternates B and D, the NCA would be managed 

as a ROW Exclusion area, with the designated corridor 

along Old Highway 91 retained, but with variable widths 

and acreage by alternative. The narrow corridor widths 

proposed under either alternative would preclude large 

scale projects. Both alternatives would restrict new 

ROWs to subsurface installations only, in order to protect the scenic qualities of the NCA. 

 Disturbances to native vegetation and soils could be 

higher under either alternative, when compared to 

Alternative A, based on the requirement that only 

subsurface installations be authorized in the designated 

corridor. Under Alternative B, as many as 60 acres could 

be disturbed within the designated corridor, while under 

Alternative D, 128 acres could be impacted. Impacts on 

native vegetation related to new project developments 

within the designated corridor would be avoided to the 

extent possible or mitigated through project design, 

BMPs, and the terms and conditions of the ROW grant. 

Existing linear ROWs within the corridor and for existing site-types in the NCA would remain valid as long as 

they serve the purposes for which the ROW was granted. 

Maintenance of existing facilities would be conducted 

under the terms and conditions of the ROW grants and 

should have a negligible impact on vegetation and soils. 

Alternative C would also manage the NCA as a ROW 

Exclusion area, but would revoke the designated corridor 

along Old Highway 91 through the NCA, eliminating impacts on native vegetation related to the development of 

new ROWs in that corridor. Existing linear ROWs within 

the corridor and for existing site-types in the NCA would 

remain valid as long as they serve the purposes for which 

the ROW was granted. Maintenance of existing facilities 

would be conducted under the terms and conditions of 

the ROW grants. Maintenance of ROWs in the designated corridor along Old Highway 91 could result in 

negligible small-scale disturbances to vegetation over the 

life of the RMP.

4.6.2.8 Impacts from Management of Scientific 

Research

Alternatives B, C, and D identify research opportunities 

that would improve the conservation, protection, and 

restoration of native vegetation communities in the NCA. 

Among the possible studies would be an evaluation of 

the long term effectiveness of herbicidal treatments for 

exotic invasive annual grasses in arid environments that 

could help to inform the selection of methods to create 

fuel breaks and native vegetation restoration projects. 

Other research opportunities could focus on the development of ecologically sustainable and cost-effective 

biological treatments to control and eradicate infestations 

of noxious weeds and invasive species. Potential studies 

relating to biological soil crust function and regeneration in disturbed and fire-altered desert ecosystems 

could help to develop cost-effective methods to restore 

biological soil crusts that would facilitate re-vegetation of 

damaged lands.

4.6.3 Summary of Impacts from Alternatives

Table 4-5 provides a summary of the impacts to native vegetation communities. The first column lists the 

resource or resource use that has an impact/effect on 

soils. The second column lists whether the action(s) is a 

beneficial effect or an adverse impact. The third column 

provides a brief description of the impact/effect and the 

final column lists the intensity of the impact/effect.

4.6.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on native 

vegetation communities would include the Beaver Dam 

Slope, within Utah, Arizona, and Nevada. Past humancaused actions within the CIAA on federal and nonfederal lands that have affected native vegetation communities include overgrazing of rangelands in late 19th and 

early 20th centuries, highway construction and utility 

developments, the “down-wind” effects of above-ground 

nuclear testing in south-central Nevada in the 1950s and 

Resource/Resource Use Impact/Effect Description Intensity

Water Resources Effect Protection of water resources benefits native vegetation. Unknown

Geological/Paleontological Impact Excavations could damage or destroy some native vegetation in 

area of project.

Negligible 

to Minor

Soil Resources Effect Protection of soil resources through project planning and BMPs 

benefits native vegetation.

Minor to 

Moderate

Native Vegetation

Effect

Rehabilitation of fire damaged lands through seeding and plantings of native species would improve biodiversity and persistence 

of native vegetation communities. 

Moderate 

to Major

Fire and Fuels Impact Fire suppression tactics, fuel breaks, and fuel reduction projects 

would damage or destroy some native vegetation.

Minor to 

Moderate

Effect Fuel breaks and fuel reduction projects would help to protect 

large areas from effects of wildfire.

Moderate 

to Major

Noxious Weeds and Invasive 

Species Impact Control and eradication of noxious weeds and invasive species could impact some native vegetation. Minor

Effect

Control and eradication of invasive brome species would benefit native vegetation by reducing fire hazards and increasing 

biodiversity.

Moderate 

to Major

Grazing

Effect

Alternative C would manage the NCA as unavailable for grazing, 

protecting native vegetation from trampling, weed infestations, 

and other impacts related to livestock use.

Moderate 

to Major

Impact

Alternatives A, B, and D continue to manage NCA as available for 

grazing, impacting native vegetation through trampling, grazing, 

and other impacts related to livestock use.

Minor to 

Moderate

Special Status Species Effect Management to conserve and restore habitats for at-risk species 

would benefit native vegetation communities.

Minor to 

Moderate

Heritage Resources Effect Allocation and management of heritage resources for conservation would help to protect native vegetation. Minor 

Old Spanish Trail NHT Effect Management of Trail Management Corridor to conserve integrity 

of setting would protect native vegetation from damage or loss. Moderate

Travel Management Effect Protection of native vegetation through management of vehicle 

travel as Limited to Designated Roads and Trails.

Minor to 

Moderate

Visual Resources Effect VRM Class I and II designations would protect naturalness, benefitting native vegetation. Minor

Lands with wilderness 

characteristics Effect Management to protect lands with wilderness characteristics under Alternative C would protect native vegetation. Minor

Recreation Effect Restrictions on dispersed camping by zone would protect native 

vegetation from damage or loss. Minor

Effect

Limits on numbers and types of commercial recreation permits 

would protect native vegetation from damage or loss related to 

recreation uses.

Negligible

Lands and Realty Effect Management as Avoidance or Exclusion areas for new ROWs 

would protect native vegetation from damage or loss. Moderate

Impact Authorizing new ROWs in the designated corridor along Old 

Highway 91 could damage or destroy some native vegetation.

Negligible 

to Minor

Table 4-5 Summary of Impacts to Native Vegetation Communities
638 Chapter 4 BDWNCA BDWNCA Chapter 4 639

NOXIOUS WEEDS AND INVASIVE SPECIES MANAGEMENT NOXIOUS WEEDS AND INVASIVE SPECIES MANAGEMENT

▶ Implementing management actions for the following resources would have negligible or no impact 

on the management of Noxious Weeds and Invasive 

Species and are, therefore, not discussed in detail: 

Air Resources; Geological and Paleontological 

Resources; Caves and Karsts; Soils Resources; 

Water Resources; Vegetation Resource Uses: Plant 

Materials; Other Fish and Wildlife; Heritage 

Resources; National Historic Trails; National 

Natural Landmark, ACECs; Visual Resources; and 

Natural Soundscapes.

4.7.2 Direct and Indirect Impacts

The likelihood for the introduction and spread of noxious 

weeds and invasive species could occur under all alternatives, as a result of many natural and human-caused factors. The conservation and protection of native vegetation 

communities to maintain plant health, species diversity, 

and intact biological soil crusts would help to prevent 

infestations and control the spread of noxious weeds and 

invasive species. Management actions that could affect 

the control and ultimate eradication noxious weeds and 

invasive species are described below.

4.7.2.1 Impacts from Management of Vegetation 

Communities

Alternative A addresses the management of desired plant 

communities within the context of meeting or exceeding 

management objectives for a wide array of resource uses 

and programs including livestock grazing, wildlife, or 

maintaining the scenic qualities of an area. Desired plant 

communities could include non-native species if these 

further management goals. Noxious weeds and invasive 

species could be introduced or spread through the use of 

non-native species under this alternative. 

Alternatives B, C, and D emphasize the conservation, 

protection, and restoration of native perennial and annual communities, late successional desert shrublands, 

and biological soil crusts. These goals would be met 

through efforts to prevent and suppress wildfires, control 

or eradicate noxious weeds and invasive species, and 

restore desired plant communities to disturbed and firedamaged landscapes. These actions would be designed 

to conserve and improve the overall health of vegetation communities, making them less susceptible to weed 

invasion or spread, in the short and long term. Noxious 

weed and exotic invasive control programs under these 

alternatives could have measureable beneficial effects on 

native communities in the short and long term, as weeds 

and non-native species are reduced in abundance and 

areal extent.

4.7.2.2 Impacts from Management of Fire and Fuels

Wildfires and fire suppression tactics that create new 

surface disturbance would increase the likelihood for 

weed introduction or spread by disturbing soil, damaging 

soil crusts, and removing vegetation. The increase in soil 

nutrients following fire and the use of retardants during suppression would favor spread and proliferation of 

invasive annual brome grasses. In desert shrubland communities, catastrophic fires and multiple fires can convert 

these fire-intolerant areas to invasive grasslands. 

Alternative A would continue to authorize many tools 

for hazardous fuels reduction, including the use of large 

scale prescribed fires in the NCA. As the Mojave Desert 

native vegetation communities are not fire-adapted species, this management tool could negatively impact the 

remaining unburned areas where blackbrush and Joshua 

trees are dominant, destroy biological soil crusts, and 

facilitate the spread of noxious weeds and exotic annual 

brome grasses.

Alternatives B, C, and D would emphasize the development of fuel breaks and reduction of hazardous fuels that 

threaten native desert vegetation communities in the 

NCA. None of these alternatives would authorize the use 

of prescribed fires as a management tool for hazardous 

fuel reduction. This would prevent fire-caused impacts 

on late successional desert shrublands and the introduction or spread of noxious weeds and exotic annual brome 

grasses.

Alternatives B and D would authorize the broadest array 

of tools and methods for these projects, including the use 

of mechanical methods and targeted livestock grazing 

for small-scale weed and invasive species control projects. Mechanical methods could damage soil crusts and 

create soil disturbances that leave soils susceptible to the 

establishment of noxious weeds and invasive species. The 

use of contracted grazing animals (e.g., domestic sheep 

or goat herds) to control infestations along roadways 

or at trailheads could increase the potential that noxious weeds and invasive species would be introduced or 

spread through hoof action and manure. 

Alternative C would limit the methods that could be 

used for fuel breaks and hazard fuel reduction projects to those that are the least impacting to soil crusts 

and that minimize new surface disturbances. Targeted 

grazing would not be among the methods that could be 

employed. Noxious weeds and exotic invasives would 

corridors along the boundaries of the NCA, and increased recreational uses of the public lands in the 

CIAA. Livestock grazing would be expected to continue 

on public, state, and private lands in the CIAA. Natural 

factors will continue to include droughts, wildfires, and 

changing temperature and precipitation regimes related 

to climate change.

Many of these past, present, and reasonably foreseeable 

future actions have or will create conditions that cause or 

favor other changes that impact native vegetation communities. Wildfires remove native vegetation and damage 

soils, leaving the fire-damaged areas more susceptible to 

weed invasion and soil erosion. Droughts reduce vegetation community health and productivity, leaving plants 

vulnerable to insect infestation or disease. In general, 

past resource use activities have cumulatively caused 

vegetation removal, fragmentation, weed spread, soil 

compaction, and erosion, whereas land planning efforts, 

vegetation and weed treatments have countered these effects by improving vegetation connectivity, productivity, 

diversity, and health.

Climate change within the CIAA could cause an increase 

or decrease in temperatures and precipitation, which 

would affect soil conditions, vegetation distribution, 

water flows, water quality, and water temperature. Such 

changes would alter the conditions to which vegetation 

communities are adapted, potentially creating conditions 

that could favor certain species or communities, weeds, 

or pests.

Impacts on native vegetation communities would be 

avoided or minimized over the life of the RMP, through 

management of the NCA as a ROW Avoidance or 

Exclusion area, through more intensive management of 

recreation activities in a SRMA, and by limiting motorized vehicle travel to designated roads and trails. Project 

authorizations would require the implementation of 

BMPs and other mitigation measures that conserve and 

protect native vegetation communities. Management 

actions would help to ensure that does not result from 

land uses or authorized activities on public lands are 

protected, reducing the potential for cumulative impacts 

to result from implementation of any of the alternatives.

4.7 NOXIOUS WEEDS AND INVASIVE SPECIES 

MANAGEMENT

This section discusses impacts on the control and eradication of noxious weeds and invasive species that might 

result from proposed management actions for other 

resources and land uses identified in the four alternatives 

in Chapter 2.

4.7.1 Methods of Analysis

This analysis focuses on those management alternatives 

or actions that have the potential to introduce or spread 

noxious weeds and invasive species in the NCA. In the absence of quantitative data, best professional judgment was 

used, and impacts are sometimes described using ranges 

of potential impacts or in qualitative terms, if appropriate.

4.7.1.1 Indicators

Indicators of adverse impacts on the noxious weeds 

and invasive species management program include the 

following:

▶ Replacement or substantial invasion of native 

communities with noxious weeds or invasive 

species, to the degree that such invasions cannot be 

successfully controlled or change the character of 

the native communities.

Indicators of beneficial effects on the noxious weeds or 

invasive species program include the following:

▶ Infestations are controlled, reduced, and ultimately 

eradicated.

4.7.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to conserve, protect, and enhance the resources of 

the NCA.

▶ Noxious weed and invasive species management 

actions are aimed at achieving or trending towards 

achieving Utah Standards for Rangeland Health;

▶ The degree of impact attributed to any one 

disturbance or series of disturbances would be 

influenced by several factors, including location, 

type, time, and degree of disturbance; existing 

vegetation; precipitation; and mitigating actions 

applied to the disturbance;

▶ Noxious weeds and invasive species could continue 

to be introduced and spread as a result of vehicle 

travel through the NCA, recreational activities, and 

surface-disturbances;

▶ Weed control would be carried out in coordination 

with the appropriate county weed management 

programs and adjacent land managers;

▶ Activities that would disturb soils could cause erosion, loss of topsoil, soil compaction, and could 

facilitate the invasion of noxious weeds and invasive species;
640 Chapter 4 BDWNCA BDWNCA Chapter 4 641

NOXIOUS WEEDS AND INVASIVE SPECIES MANAGEMENT NOXIOUS WEEDS AND INVASIVE SPECIES MANAGEMENT

Under Alternative C, 61,995 acres of the NCA would be 

unavailable for livestock grazing over the life of the RMP, 

reducing the potential for the introduction and spread 

of noxious weeds and invasive species where these are 

related to livestock grazing or the development of new 

range improvements.

4.7.2.5 Impacts from Management of Special Status 

Species, including BLM Sensitive Species 

Under all alternatives, the goals are to protect, conserve, 

and restore critical habitats and assist the recovery and 

delisting of threatened and endangered species and preclude the need to list additional species under the ESA. 

Alternatives B, C, and D prioritize the conservation and 

protection of critical habitats from the effects of wildfire, 

through the development of fuel breaks and hazardous 

fuel reduction projects. These alternatives also prioritize 

the restoration disturbed and fire-damaged vegetation 

communities in designated critical habitats for Mojave 

desert tortoise and other at- risk species. Restoration of 

desired vegetation communities would help to lessen 

the potential for the introduction and spread of noxious 

weeds and invasive species

All alternatives emphasize the full suppression of wildfires in designated critical habitat for the Mojave desert 

tortoise. Suppression actions could create new surface 

disturbances, where heavy equipment is used to create 

fire line or fire vehicles travel off-road. The use of fire 

retardant could act as a fertilizer, increasing the density 

of weeds or invasive species within infestation areas. The 

impacts of the fires and associated suppression tactics 

would leave soils susceptible to infestations. The implementation of post-fire ES&R actions would help to mitigate these impacts by stabilizing soils and re-establishing 

desired vegetation communities.

4.7.2.6 Impacts from Management of Lands with 

Wilderness Characteristics

Under Alternative C, wilderness characteristics would 

be maintained on 16, 721 acres, by managing these 

lands as a ROW Exclusion area, as VRM Class I, and as 

Limited to Designated Roads and Trails for motorized 

vehicles. This acreage would be closed to commercial 

and non-commercial fuelwood, Christmas tree, and post 

harvesting, as well as commercial and non-commercial 

seed collection. Activities and land uses that could be 

authorized under these management prescriptions would 

be unlikely to encourage the introduction or spread of 

noxious weeds and invasive species. 

Under Alternatives A, B, and D, management would not 

focus on maintaining wilderness characteristics within 

the 16, 721 acres. Alternative A would manage the lands 

as a ROW Avoidance area, as VRM Class III, and as 

Limited to Designated Roads and Trails for motorized 

vehicle travel. Under this alternative, some land uses and 

activities could be authorized that could result in new 

surface disturbances and the introduction or spread of 

noxious weeds and invasive species. 

Alternatives B and D would manage the 16,721 acres as a 

ROW Exclusion area, as VRM Class II, and as Limited to 

Designated Roads and Trails for motorized vehicles. This 

acreage would be closed to commercial and non-commercial fuelwood and post harvesting and commercial and 

non-commercial seed collection. Activities and land uses 

that could be authorized under these management prescriptions would be unlikely to encourage the introduction 

or spread of noxious weeds and invasive species.

4.7.2.7 Impacts from Management of Recreation and 

Visitor Services

Under Alternative A, the public lands of the NCA 

would continue to be managed as part of the larger St. 

George Field Office ERMA, where casual and dispersed 

recreation would be emphasized and few management 

controls implemented to protect resource values. Current 

management would continue to allow dispersed camping 

within 50 feet of roads, potentially damaging vegetation, 

increasing soil compaction, introducing or spreading 

noxious weeds and invasive species, and increasing the 

risk of wildfires. Authorizing noncommercial groups of 

up to 75 persons to camp in open areas could continue 

to damage resource values on a much larger scale, with 

impacts similar to those as described above. 

Under Alternatives B, C, and D, the Beaver Dam Wash 

SRMA would be established and recreation uses more intensively managed. Visitor amenities and facilities would 

be developed to improve visitor experiences and protect 

resource values. A Recreation Area Management Plan 

would be developed to identify specific management 

actions for recreational activities in the SRMA. Through 

implementation-level planning, the potential for the 

introduction of noxious weeds and invasive species could 

be minimized, through the proactive management of 

authorized activities.

Under the three action alternatives, a professionallydesigned non-motorized trail system would be developed in the NCA to provide high-quality experiences for 

diverse users, with trailheads and waysides that provide 

less likely introduced or spread under this alternative. 

However, the methods that would be authorized under 

this alternative would be labor intensive and likely reduce 

the acreage of fire breaks and fuels reduction projects 

that could feasibly be completed. 

Under all alternatives, BLM would seek funding and 

develop plans for post-fire ES&R actions to stabilize 

soils and restore vegetation on fire-damaged lands. 

Alternatives B, C, and D would emphasize the use of 

early colonizing native annual and perennial species 

that would be most likely to quickly re-establish soil 

cover, helping to prevent the introduction or spread of 

noxious weeds and invasive species. When compared to 

Alternative A, these alternatives would likely be more 

successful in preventing the introduction and spread of 

infestations on fire-damaged lands.

4.7.2.3 Impacts from Management of Noxious Weeds 

and Invasive Species

Noxious weeds and non-native (exotic) invasive infestations can become so widespread as to create vegetation 

monocultures that are typically poorly suited to protecting soils from erosional forces. Control and eradication 

of infestations can create short-term surface disturbances, but over the long term, help to conserve, protect, and 

restore healthy ecosystems.

Under all alternatives, Integrated Weed Management 

would be used to control, suppress and eradicate, where 

possible, noxious weeds and non-native (exotic) invasive 

infestations to support healthy plant communities in 

the NCA. Herbicide use protocols and standard operating procedures, described in the Programmatic EIS 

for Vegetation Treatments Using Herbicides (FEIS, BLM 

2007), would be followed to reduce impacts on nontarget vegetation from herbicide treatments. Noxious 

weed prevention measures would be included in relevant 

contracts and permits. All alternatives would focus weed 

inventory surveys and treatments on high use areas, and 

would require the use of weed-free materials for projects 

and weed-free hay by pack stock users.

Alternatives B, C, and D propose a range of tools and 

methods that could be employed for controlling noxious 

weeds and invasive species and protecting soil resources. 

These alternatives identify strategies for controlling 

and ultimately eradicating non-native tamarisk and 

Russian olive trees in ephemeral drainages and Beaver 

Dam Wash. Limiting weed treatments to non-invasive 

methods would be protective of soil and water quality, 

particularly for infestations within or near riparian areas. 

These management actions would help to reduce the 

extent of weed infestations in the NCA and prevent the 

introduction and spread of new weed species in the short 

and long term. 

Alternative C would limit the aggressiveness with which 

the BLM could treat infestations, by restricting methods 

to hand tools. Limiting weed treatments to non-invasive 

methods would be protective of soil and water quality, 

particularly for infestations within or near riparian areas. 

Because treatments would take longer to complete and be 

more labor intensive, some infestations could expand in 

areal extent or increase in plant numbers.

4.7.2.4 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing

Livestock grazing can be a contributing factor to the 

introduction and spread of noxious weeds and invasive 

species. Seeds and plant materials can be widely distributed across the landscape through manure and livestock trailing. Hoof action can disturb soil surfaces and 

damage or destroy biologic soil crusts, allowing noxious 

weeds and invasive species to become established. The 

construction and maintenance of range improvements 

could also lead to an increase in weeds from surface disturbance, as well as from contaminated equipment used 

for construction and maintenance. New range developments can alter livestock grazing and trailing patterns, 

potentially spreading infestations. In general, the more 

acres that are open to grazing under a given alternative, 

the greater the risk for impacts.

Under Alternatives A, B, and D, public lands would 

continue to be available for grazing, with the exception 

of the 1,063-acre fenced Woodbury Desert Study Area 

which would continue to be unavailable for grazing 

over the life of RMP. Under Alternative B, the permitted use would initially be established at 1,861 AUMs of 

livestock forage, rather than the current 3,099 AUMS. 

These alternatives would allow the development of new 

range projects; however, Alternatives B and D would 

authorize only those range developments that further the 

purposes of the NCA and benefit diverse resource values. 

The potential that noxious weeds and invasive species 

could be introduced and spread as a result of continued 

livestock grazing management would be greatest under 

Alternatives A and D, as 61,995 acres of the NCA would 

remain available for livestock grazing and at the same 

level of permitted use. Under Alternative B, this potential would be slightly lower, as permitted use would be 

reduced by 1,238 AUMs. 
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4.7.2.10 Impacts from Management of Scientific 

Research

Alternatives B, C, and D identify research opportunities 

that would improve the conservation, protection, and 

restoration of native vegetation communities in the NCA. 

Among the possible studies would be an evaluation of 

the long term effectiveness of herbicidal treatments for 

exotic invasive annual grasses in arid environments that 

could help to inform the selection of methods to create 

fuel breaks and native vegetation restoration projects. 

Other research opportunities could focus on the development of ecologically sustainable and cost-effective 

biological treatments to control and eradicate infestations 

of noxious weeds and invasive species.

4.7.3 Summary of Impacts from Alternatives

Under all alternatives, BLM would continue to implement Integrated Weed Management treatments to 

control and ultimately eradicate noxious weeds and 

invasive species. Herbicide use protocols and standard 

operating procedures, described in the Programmatic EIS 

for Vegetation Treatments Using Herbicides (FEIS, BLM 

2007) would be followed to reduce impacts on non-target 

vegetation from herbicide treatments. Noxious weed 

prevention measures would be included in ROW grants, 

permits, and contracts. All alternatives would focus weed 

inventory surveys and treatments in high use areas, and 

would require the use of weed-free materials for projects 

and weed-free hay by pack stock users.

Under Alternative B, C, and D, management actions 

would focus on the conservation, protection, and restoration of watersheds, soils, and native vegetation communities. Emphasis would be placed on re-vegetation of disturbed and fire-damaged landscapes with healthy native 

vegetation communities that would not be susceptible to 

the introduction or spread of noxious weeds and invasive species. The three action alternatives also propose 

to manage the NCA as a ROW Exclusion area and limit 

OHV motorized travel to designated roads, lessening the 

potential that weeds and exotic invasive species will be 

introduced or spread as a result of surface disturbances 

related to the development of utilities and access roads 

under ROWs or from off-road OHV use.

4.7.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on 

noxious weeds and invasive species extends outside the 

NCA boundaries, to include federal and non-federal 

lands on the Beaver Dam Slope of Utah, the Arizona 

Strip, and southern Nevada, as management actions on 

these adjoining lands would have the potential to influence resource conditions in this tri-corner region of the 

northeastern Mojave Desert.

Past actions on federal and non-federal lands within the 

CIAA that have influenced the introduction and spread 

of noxious weeds and invasive species include overgrazing by domestic livestock, highway construction and 

utility developments, vegetation treatments, treatments, 

and motorized and non-motorized recreational activities. Natural factors that influenced the introduction and 

spread of noxious weeds and invasive species included 

wildfires, extended periods of drought, and above average precipitation. 

Many of these land uses and natural factors created conditions that caused or favored changes to native vegetation communities and soil conditions, facilitating the introduction and spread of weed infestations. For example, 

overgrazing by sheep throughout the early decades of the 

20th century altered the species composition of native 

Mojave Desert communities, removing some perennial 

and annual native grass species and damaging soil crusts. 

Exotic annual brome grasses and noxious weeds were 

able to quickly establish, creating a fine fuel understory 

that today fuels catastrophic wildfires in native vegetation communities that are not fire adapted. Fire-damaged 

lands, in turn, are more susceptible to weed invasive and 

soil erosion. 

Present and reasonably foreseeable future actions would 

include regional population growth; the expansion of 

the nearby communities of Beaver Dam and Littlefield, 

Arizona, and Mesquite, Nevada; the construction of new 

utilities in the IPP and Navajo-McCullough designated 

corridors that are adjacent to, but outside of the NCA; 

and increased recreational use of the public lands in the 

CIAA. Livestock grazing would be expected to continue 

on federal and non-federal lands in the CIAA.

Natural factors will continue to include droughts, 

wildfires, and changing temperature and precipitation 

regimes related to climate change. Droughts reduce 

vegetation community health and productivity, leaving plants vulnerable to insect infestation or disease. 

Climate change within the CIAA could cause an increase 

or decrease in temperatures and precipitation, which 

would affect soil conditions, vegetation distribution, 

water flows, water quality, and water temperature. Such 

changes would alter the conditions to which vegetation 

communities are adapted, potentially creating conditions 

that are predicted to favor invasive annual grasses, as well 

as other weed species.

maps and interpretive information about the NCA’s purpose and values. This system would be expected to minimize the number of new social trails that are developed 

in the short and long term, as users would be more likely 

and able to use the designated trail system. Moderate 

to major levels of protection for soils and native vegetation communities would be realized in the short and 

long term under these alternatives when compared to 

Alternative A, minimizing the potential for the introduction and spread of weed infestations. 

Each of these alternatives would limit dispersed camping 

to designated campsites that are located in previously disturbed areas, lessening the amount of soil and vegetation 

that would be damaged and minimizing the potential for 

the introduction and spread of weed infestations. 

4.7.2.8 Impacts of Travel and Transportation 

Management

The impacts or benefits on soils, native vegetation, and 

the introduction of noxious weeds and invasive species 

related to OHV area designations can be estimated by 

comparing the number of acres that are designated as 

Open, Limited, and Closed to motorized vehicle travel 

and uses through the RMP. Area closures and limiting 

vehicles to designated roads and trails would minimize 

surface disturbances related to unauthorized cross-county travel and route proliferation and the potential for new 

weed infestations. 

Under all alternatives, the NCA would be managed as 

Limited to Designated Roads and Trails, with the specific route designations (outside of the Congressionallyidentified Designated Route Areas) to follow through 

BLM’s development of a TMP for Washington County. 

The specific route designations developed in the TMP 

would directly and indirectly minimize new surface 

disturbances from route proliferation and off-trail travel 

that would facilitate the introduction and spread of noxious weeds and invasive species.

4.7.2.9 Impacts from Management of Lands and 

Realty

Under Alternative A, 63, 284 acres of the NCA would 

be managed as a ROW Avoidance area for linear and 

site-type ROWs. The 196-acre designated corridor that 

parallels, and is bisected by, Old Highway 91, would 

be retained. New linear ROWs for the development of 

power lines, pipelines, or other utilities could be granted 

in that designated corridor. Project design, BMPs, and 

terms and conditions attached to ROW grants would 

minimize the risk that noxious weeds and invasive 

species be introduced through new developments to the 

extent possible; the ROW grant holder would be required to control infestations within the ROW. Existing 

linear ROWs within the corridor and existing site-type 

ROWs in the NCA would remain valid as long as they 

serve the purposes for which the ROWs were granted. 

Maintenance of existing facilities would be conducted 

under the terms and conditions of the ROW grants and 

should not result in the introduction or spread of noxious weeds and invasive species. 

Under Alternatives B and D, the NCA would be managed 

as a ROW Exclusion area, with the designated corridor 

along Old Highway 91 retained, but with variable widths 

and acreages by alternative. Both alternatives would 

restrict new ROWs to subsurface installations only, to 

protect the scenic qualities of the NCA. 

Disturbances to native vegetation and soils could be 

higher under either alternative, when compared to 

Alternative A, based on the requirement that only 

subsurface installations be authorized in the designated 

corridor. Under Alternative B, as many as 60 acres could 

be disturbed with the designated corridor, while under 

Alternative D, 128 acres could be impacted. Impacts 

on soils and native vegetation related to new project 

developments within the designated corridor would 

be avoided to the extent possible or mitigated through 

project design and BMPs. The terms and conditions 

of the ROW grant would require that the ROW grant 

holder prevent the introduction and spread of infestations during project development and over the life of 

the ROW. Existing linear ROWs within the corridor and 

existing site-type ROWs in the NCA would remain valid 

as long as they serve the purposes for which the ROW 

was granted. Maintenance of existing facilities would be 

conducted under the terms and conditions of the ROW 

grants, requiring the control and eradication of noxious 

weeds and invasive species within the ROW. 

Alternative C would also manage the NCA as a ROW 

Exclusion area, but would revoke the designated corridor 

along Old Highway 91 through the NCA, eliminating 

impacts on native vegetation and soils related to the development of new ROWs in that corridor. Existing linear 

ROWs within the corridor and existing site-types ROWs 

in the NCA would remain valid as long as they serve the 

purposes for which the ROW was granted. Maintenance 

of existing facilities would be conducted under the terms 

and conditions of the ROW grants, requiring the control 

and eradication of noxious weeds and invasive species 

within the ROW.
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livestock management requirements, season-of use 

changes, changes in kind of livestock, modified grazing 

systems, construction of range improvements, decreased 

AUMs or other actions needed to meet soil, water, or 

vegetation objectives or provide protection for other 

resources.

In some cases, specific management actions could 

enhance rangeland conditions, long-term forage production, and potentially improve animal distribution and 

livestock health. These would be beneficial effects on 

livestock grazing. For example, construction of range 

improvements would generally enhance rangeland health 

in the long term; however construction of the project, in 

the short term, may economically impact the permittee. 

Rangeland management changes may also be designed to 

provide protection for other resources or resource uses. 

In these instances, management changes may impose 

additional limitations on livestock grazing, but do not 

enhance rangeland conditions. Details for key types of 

impacts are included below.

A summary of impacts is provided in Table 4-6, 

Summary of Impacts to Livestock Grazing by Alternative.

4.8.2.1 Impacts from Management of Water 

Resources

Management of soil resources generally fosters healthy 

plant communities, which can benefit livestock grazing 

by maintaining or increasing the forage base. Likewise, 

managing for healthy watersheds provides for necessary 

water sources and improved forage conditions for livestock grazing in the long term. Protecting water quality 

and watershed health could require short or long-term 

changes in livestock management, such as deferred or 

shortened grazing periods, exclusion, and increased 

livestock herding.

Under Alternative A, factors effecting water conditions 

would generally persist, while striving to ensure that 

actions related to the Virgin River and its tributaries, 

including the Beaver Dam Wash in the NCA, continue 

to further the goals of the Colorado River Basin Salinity 

Act. Livestock forage and water supplies are likely to 

remain static in the long term. Specific grazing management practices designed to protect vegetation, soils, and 

water could be required on some small localized area 

with soil erosion concerns, which could have negligible 

to minor impacts on the livestock operation(s) involved.

Under Alternatives B, C, and D, factors affecting water 

quality would be measured, using the UDWQ standard 

of beneficial use and the applicable Utah Standards and 

Guides (Appendix D). Specific grazing management 

practices designed to protect vegetation, soils, and water 

could be required on some small localized areas with 

soil erosion susceptibility, which could have negligible to 

minor impacts to livestock operation(s) involved.

Under Alternatives B and D, acquisition of non-federal 

land within grazing allotment boundaries in the NCA 

to benefit watershed protection could potentially benefit livestock grazing by making additional acreage and 

AUMs available to grazing.

4.8.2.2 Impacts from Management of Soil Resources

Management of soil resources generally fosters healthy 

plant communities, which can benefit livestock grazing 

by maintaining or increasing the forage base. Likewise, 

managing for healthy watersheds provides for necessary water sources and improved forage conditions for 

livestock grazing, in the long term. Protecting water 

quality and watershed health could require short or longterm changes in livestock management such as deferred 

or shortened grazing periods, exclusion, and increased 

livestock herding.

Alternative A would continue to focus on ensuring that 

soils management along Beaver Dam Wash in the NCA 

continue to further the goals of the Colorado River Basin 

Salinity Act. Livestock forage and soil conditions are 

likely to remain static in the long term. Specific grazing 

management practices designed to protect vegetation, 

soils, and water quality could be required on some small 

localized areas with soil erosion susceptibility, which 

could have negligible to minor impacts to livestock 

operation(s) involved.

Alternatives B and D propose management actions to 

conserve and protect soil and water resources in the 

long term, but that may restrict grazing management 

in the short term. Specific grazing management practices designed to protect vegetation and soils could be 

required on some small localized areas with soil erosion 

concerns, which could have minor impacts to livestock 

operation(s) involved. Normal day-to-day livestock 

grazing operations may be restricted on some allotments 

where large acreages have been damaged by wildfires 

that damaged or destroyed native vegetation, leaving 

soils susceptible to wind and water erosion. Under these 

alternatives, re-vegetation projects to restore vegetative 

cover and biological soil crusts would require closures or 

restrictions on livestock grazing within the project areas, 

until resource objectives are met. Depending on the size, 

location, resource objectives, and duration of closures 

Over the life of the RMP, the introduction and spread of 

noxious weeds and invasive species would be prevented 

or minimized, through management of the NCA as a 

ROW Avoidance or Exclusion area, through more intensive management of recreation activities, and by limiting 

motorized vehicle travel to designated roads and trails. 

Project authorizations would require the implementation 

of BMPs and other mitigation measures that conserve 

and protect native vegetation communities. Vegetation 

conditions would be improved through restoration treatments, weed prevention and control, habitat improvements, and prevention of wildfires. In general, all alternatives would work toward achieving improved land health 

and controlling and ultimately eradicating noxious weeds 

and invasive species, but would differ in the methods 

used to reach those goals.

4.8 VEGETATION RESOURCE USES: LIVESTOCK 

GRAZING

This section discusses impacts on livestock grazing from 

proposed management actions of other resources and 

resource uses. Existing conditions concerning livestock grazing are described in Chapter 3 at Section 3.9, 

Livestock Grazing.

4.8.1 Methods of Analysis

Livestock grazing is analyzed using the indicators and 

assumptions included below. Adverse impacts can generally be described in terms of direct closures to grazing, 

reductions in permitted use, surface use restrictions, or 

other measures that would require changes in livestock 

management. Beneficial effects are generally actions that 

increase forage availability or quality and actions that 

increase management flexibility for livestock operators.

Available information was obtained through relevant literature, standards and guidelines assessments, monitoring, and consultation with the public, livestock grazing 

permittees, and interdisciplinary teams. 

4.8.1.1 Indicators

Indicators of adverse impacts on livestock grazing include the following:

▶ Management of public lands as unavailable to livestock grazing;

▶ Decreasing permitted AUMs in areas available to 

livestock grazing due to various resource issues or 

conflicts, or cumulative management actions;

▶ Restricting or prohibiting the ability to construct or 

maintain range improvements and conduct treatments (infrastructure and vegetation).

Indicators of beneficial effects on livestock grazing include the following: 

▶ Management of public lands as available to livestock 

grazing;

▶ Public lands that meet Utah Standards for 

Rangeland Health and Guidelines for Grazing 

Management.

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ All new and existing leases and permits would be 

subject to terms and conditions determined by the 

authorizing officer to achieve the management and 

resource condition objectives for the public lands 

and also managed to meet Utah Standards and 

Guides (Appendix D).

▶ Construction of range improvements (e.g., fences, 

pipelines, water wells, troughs, and reservoirs) 

would result in a localized loss of vegetation cover 

throughout their useful life. Vegetation could be 

re-established through reclamation practices along 

water pipelines.

▶ New range improvements would be subject to limitations as specified in the RMP, and must meet the 

objectives of the NCA. Range improvements would 

generally lead to improved livestock distribution 

and vegetation management, which in turn would 

support vegetation objectives.

Implementing management actions for the following 

resources would have no impact or negligible impacts on 

livestock grazing and are, therefore, not discussed in detail: Air Quality, Geologic and Paleontological Resources, 

Cave and Karst Resources, Vegetation Resource Uses: 

Plant Materials, National Historic Trails, National 

Natural Landmarks, ACECs, Natural Soundscapes, Lands 

with Wilderness Characteristics.

4.8.2 Direct and Indirect Impacts

Impacts on livestock grazing activities are generally the 

result of activities that affect forage levels, areas available 

to grazing, kind of livestock, season and/or timing of use, 

the ability to construct range improvements, or activities that result in human disturbance or harassment of 

livestock within grazing allotments.

Implementation of particular livestock grazing management actions may adversely impact the permittee by 

increasing operational costs, through more intensive 
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and restrictions required for the re-vegetation projects, 

livestock operations could be moderately impacted in the 

short and long-term.

4.8.2.3 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Management of vegetation resources may directly benefit livestock grazing by improving forage conditions. 

Vegetation treatments designed to reduce invasive annual 

brome grasses could have short-term impacts on livestock grazing, as these species provide forage for cattle. 

These treatments would be conducted in concert with 

re-vegetation projects to restore desired plant species to 

help prevent the re-establishment of infestations. The 

re-vegetation projects would require closures or restrictions on livestock grazing within the project areas, until 

resource objectives are met. Depending on the size, 

location, resource objectives, and duration of closures 

and restrictions required for the re-vegetation projects, 

livestock operations could be moderately impacted in 

the short and long-term. In the long term, both actions 

would generally enhance rangeland conditions, including 

maintaining or improving the forage base and rangeland 

health. In general, vegetation management could require 

closures or restrictions on grazing uses, reductions in 

utilization levels, season of use, and AUMs in the short 

and long term.

Under Alternative A, site-specific plans would be prepared in order to identify desired plant communities, 

establish specific management objectives, and recommend practices to be employed to achieve desired results. 

The implementation of these plans could potentially have 

a moderate impact on livestock grazing, based on specific 

recommendations stated in the plans, such as vegetation 

treatments, livestock reductions, range improvements, 

etc., all of which have the potential to negatively impact or beneficially effect livestock grazing. Short-term 

impacts include restricting livestock from use of the 

treatment area for a minimum of one to two complete 

growing seasons. This alternative has the potential for 

a minor to moderate impact on livestock grazing. Long 

term effects include the potential for increased forage 

and improvement of the ecosystem as a whole.

Under Alternatives B and D, proposed management 

actions are generally limited to fuel breaks and hazardous fuels reduction in order to protect certain habitat 

types. The impacts of these projects on livestock grazing 

would be similar to those described above. Hazardous 

fuel projects, which in the NCA would focus primarily 

on reducing invasive annual grasses, would generally 

be conducted in concert with re-vegetation projects to 

restore desired plant species. The re-vegetation projects 

could require closures or restrictions on livestock grazing, reductions in utilization levels, season of use, and 

AUMs in the short and long term within the project 

areas, until resource objectives are met. Depending on 

the size, location, resource objectives, and duration of 

closures and restrictions required for the re-vegetation 

projects, livestock operations could be moderately impacted in the short and long-term. In the long term, both 

actions would generally enhance rangeland conditions, 

including maintaining or improving the forage base and 

rangeland health.

Under Alternatives A, B, and D, managing riparian habitat 

in compliance with Utah Standards for Rangeland Health 

and Guidelines for Grazing Management (BLM 1997) has 

the potential to directly impact livestock grazing through 

site-specific exclusion of livestock or adjusting season of 

use and livestock numbers. Allowing riparian habitat to 

maintain proper functioning condition would benefit 

grazing livestock by indirectly providing cleaner and more 

reliable water and more dependable forage.

Alternative A continues to provide for the management 

for wildfires are in accordance with the “Guidelines in 

Fighting Wildfire in Desert Tortoise Habitat” and “minimum tool” principles. While full suppression has recently 

been employed for all fires within critical habitat for the 

Mojave desert tortoise, this alternative could authorize 

less intensive suppression responses. Under that scenario, 

impacts to livestock grazing could be moderate to major, 

due to the fact that “minimum tool” methods might not 

be successful in quickly suppressing wildfires or limiting 

their size. Mojave Desert native vegetation communities 

are not fire-adapted and late successional desert shrublands will not recover for decades or even centuries, if ever. 

This eliminates many key forage species often utilized by 

livestock and encourages the proliferation of non-native 

invasive species. Under this alternative, management 

ignited (prescriptive) fires could continue to be authorized, 

which could further damage or destroy native vegetation 

and reduce available forage for livestock.

Under Alternatives B, C, and D, full and immediate 

suppression of all wildfires within the NCA would be 

required to protect unburned areas. The use of backburning as a fire suppression tactic would vary across these alternatives, being evaluated for use on a case-by-case basis 

in Alternatives B and D, and prohibited in Alternative C 

with few exceptions. No management-ignited (prescriptive) fire would be authorized in Alternatives B, C, and D, 

Resource/Resource Use Impact/Effect Description Intensity

Water Resources Impact Protection of water sources may require exclosure fencing, reducing acreage available for grazing.Negligible 

to Minor

Soil Resources

Impact

Re-vegetation projects would be temporarily closed to grazing 

until resource objectives are met.

Negligible 

to 

Moderate

Effect

Protection of native vegetation from loss or damage by wildfires 

would benefit livestock grazing, maintaining forage.

Restoration of fire-damaged native vegetation communities could 

benefit livestock grazing by increasing forage.

Minor to 

Major

Fire and Fuels

Impact

Fire suppression tactics could reduce forage through surface 

disturbances or backburning.

Fuel breaks would remove native vegetation and decrease available forage.

Negligible 

to Major

Noxious Weeds and Invasive 

Species

Effect

Management of noxious weeds would help to maintain native 

vegetation communities that provide forage for livestock.

Efforts to reduce invasive species would improve rangeland 

health and help to minimize threats to native vegetation communities from wildfires.

Negligible 

to Major

Impact

Controlling or eradicating exotic brome grasses would 

lessen available forage for livestock, until native species are 

re-established.

Minor to 

Moderate

Livestock Grazing Impact Alternative C makes 61,995 acres unavailable for grazing. Major

Impact Alternative B reduces initial AUM levels from 3099 to 1861 Moderate

Special Status Species

Impact

Protection habitats and populations of special status species could 

require modifications to livestock grazing levels and management 

strategies.

Minor to 

Major

Effect

Protection of habitats and populations from loss to or damage by 

wildfires would benefit livestock grazing, maintaining forage.

Restoration of fire-damaged habitats could benefit livestock grazing by improving rangeland health and increasing forage.

Minor to 

Major

Travel Management

Effect

OHV area designation of Limited to Designated Roads and Trails 

would protect soils and native vegetation from motorized vehicle 

off-road impacts, benefitting grazing by maintaining forage levels.

Minor

Visual Resources

Effect

VRM Class I and II designations would lessen potential for 

impacts to soils and native vegetation from authorized developments, benefitting grazing.Minor

Lands with wilderness 

characteristics Effect Alternative C would manage land uses to protect wilderness characteristics, lessening impacts on soils and native vegetation. Minor

Recreation and Visitor 

Services Effect

Restrictions on dispersed camping to designated sites would 

minimize new surface disturbances and potential for humancaused fires, protecting native vegetation and livestock forage.

Negligible 

to Minor

Effect Closure or restrictions on recreational target shooting could 

protect livestock from injuries or mortality. Negligible

Lands and Realty Effect Management as Avoidance or Exclusion areas protects native 

vegetation that provides forage for livestock from developments.

Minor to 

Moderate

Table 4-6 Summary of Impacts to Livestock Grazing by Alternative
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A, although still considered a minor impact overall. 

Compared to Alternative A, this action would limit the 

flexibility in constructing range improvements and could 

limit the ability of operators to fully utilize the resources 

within an allotment.

The impacts on livestock grazing management resulting 

from the voluntary relinquishments of grazing permits 

would be similar to those identified under Alternative 

C, however the degree of impact on overall livestock 

grazing would be directly tied to the number of AUMs 

that would no longer be available, as a result of permit 

relinquishment and would be difficult to quantify at this 

time. Benefits to resources values that are potentially affected by livestock grazing are analyzed in the respective 

sections of this chapter and would be similar in scope, if 

not intensity, to those evaluated under Alternative C for 

the areas of the NCA that are within the boundaries of 

the allotment for which the grazing permit is 

voluntarily relinquished.

Alternative C would make the entire NCA unavailable to livestock grazing over the life of the RMP and 

would eliminate all grazing activities on the portions 

of the Beaver Dam Slope, Castle Cliffs, Cedar Pocket, 

and Scarecrow Peak allotments that intersect the NCA 

(61,995 total acres). This would remove 3,099 AUMs 

from livestock use and require operators that graze 

livestock only on those portions of the allotments that 

extend outside of the NCA. Livestock grazing would be 

eliminated on portions of each allotment, as follows:

▶ Beaver Dam Slope Allotment: 30,470 acres

▶ Castle Cliffs Allotment: 8,310 acres

▶ Scarecrow Peak Allotment: 21,131 acres

▶ Cedar Pocket Allotment: 2,066 acres

The other impacts on livestock grazing management 

described under Alternatives A, B, and D would not occur 

under Alternative C, because the NCA would be unavailable for livestock grazing. The overall impact to livestock 

grazing from this alternative would be major and long 

term. Livestock operations depend greatly on the use of 

public rangelands to sustain base herds. Permittees who 

are unable to graze on public lands could experience substantial increases to their operations’ costs for feed, potentially to the point where remaining in the livestock business may not be economically feasible. Additional costs 

could also be incurred to construct fencing to exclude 

livestock from the NCA portions of the allotments. The 

areas outside the NCA that could potentially remain available for grazing within each allotment would be smaller in 

acreage, and would require changes to the grazing permits 

relating to stocking rates and AUMs and other grazing 

practices, to provide for the continuation of grazing.

Under Alternative D, the impacts on livestock grazing 

management would be similar to those identified under 

Alternative A with two exceptions. Grazing utilization 

levels would be set at 45% of the current year’s growth, 

potentially further reducing the amount of forage available for livestock grazing. The construction of range improvements would only be authorized if they further the 

purposes of the NCA and benefit diverse resource values. 

Compared to Alternative A, this action could limit the 

flexibility in constructing range improvements and could 

limit the ability of operators to fully utilize the resources 

within an allotment.

4.8.2.6 Impacts from Management of Special Status 

Species, Including BLM Sensitive Species

Management actions protect habitats and populations 

of special status species and BLM Sensitive Species may 

impact livestock grazing operations through the loss of 

forage, increased difficulty of access, increased costs, or 

reductions in livestock numbers. Impacts could range 

from moderate to major, depending on the scope and 

duration of the required actions.

Under Alternatives A, B, and D, season of use restrictions 

intended to eliminate competition for forage between 

livestock and threatened Mojave desert tortoises would 

continue to be in effect and result in no new or different 

impacts on livestock grazing, as these restrictions have 

been in force since 1999.

Under Alternative A, seasonal closures (April 1 – August 

30) could also be required within 1⁄2 mile of any active 

nests for the Southwestern willow flycatcher and yellowbilled cuckoo. If active nests were to be identified within 

the Beaver Dam Wash, impacts to livestock grazing 

would be minor, resulting in the need for the removal of 

livestock, through fencing, herding, or other methods.

Alternatives B and D address the need to monitor land 

uses in the Beaver Dam Wash to identify impacts on water quality and riparian vegetation that comprise aquatic 

habitats for special status or BLM Sensitive Species fish, 

amphibians, and invertebrates. If livestock grazing were 

shown to be causing degradation of aquatic habitats, 

restrictions or modifications to grazing management 

practices could be required. The impact to livestock grazing could be negligible to minor, depending on the scope 

of changes that might be required.

except for scientific research. Wildfires in the NCA have 

the potential for major impacts to livestock grazing due 

to their irreversible impacts on key forage species and 

habitat. They also encourage the proliferation of weed 

and invasive species infestations.

Alternatives A, B, and D would authorize the use of 

non-native species when conducting post-fire soil 

stabilization and re-vegetation. However, non-native 

species would only be approved when the use of these 

species encourages the restoration of native species and 

also benefits threatened and endangered species. The 

use of non-native forage species could have a moderate 

positive effect on livestock grazing in the NCA, because 

some non-native species might more easily establish and 

initially be more productive than the native species in the 

Mojave Desert.

Alternative C authorizes only the use of native species for 

ES&R; however, under this alternative, the NCA would 

be unavailable for grazing over the life of the RMP and 

no impact on grazing operations would result.

4.8.2.4 Impacts from Management of Noxious Weeds 

and Invasive Species

Alternatives A, B, and D would utilize Integrated Weed 

Management approaches to control noxious weeds and 

invasive species using the most environmentally appropriate and effective techniques. These alternatives could have 

a minor to moderate negative impact on livestock grazing, 

related to potential closures and use restrictions on grazing 

during and after weed treatments. Control and/or eradication could also have minor to moderate beneficial effects 

by improving rangeland health and minimizing the potential for the loss of forage to catastrophic wildfires fueled by 

invasive annual brome grasses.

4.8.2.5 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing

Managing livestock grazing to achieve the Utah 

Standards for Rangeland Health for upland and riparian 

vegetation communities could affect livestock grazing 

operators by increasing operating costs and decreasing 

the number of AUMs available for livestock use. In an effort to achieve the standards, livestock operators could be 

required to implement changes to their grazing practices, 

such as modifying seasons of use, reducing utilization 

levels and stock rates, and constructing additional range 

improvements. Although these actions would help to 

enhance rangeland conditions and increase long-term 

forage production, AUMs could be reduced for some 

operators on a permanent or long-term basis until rangeland conditions improve to an acceptable level.

Alternative A authorizes livestock grazing on 61,995 

acres and provides 3,099 initial AUMs within the NCA, 

allowing for grazing to continue on the Beaver Dam 

Slope, Castle Cliffs, Cedar Pocket, and Scarecrow Peak 

Allotments under current terms and conditions. Grazing 

within the Beaver Dam Slope ACEC would continue to 

have an authorized season of use from November 1 to 

March 15; areas of the allotments outside of the ACEC 

would continue to have seasons of use through May 31. 

Establishing grazing utilization levels as a percentage 

(45%-60% depending on the allotment) of the current 

year’s growth on allotments would limit grazing intensity 

in these areas and could result in reduced AUM use. The 

construction of range improvements would continue to 

be authorized to improve livestock distribution, potentially maintaining or improving rangeland conditions 

and long-term forage production. This alternative continues the current livestock grazing management systems 

and would, therefore, have no or negligible impacts on 

grazing operations.

Voluntary relinquishments of grazing permits could result in an overall reduction in livestock grazing activities. 

Although relinquished permits would be available for 

application by qualified applicants, the BLM could determine that such action is not compatible with land use 

plan goals and objectives and thereby eliminate future 

grazing within the allotment.

Under Alternative B, livestock grazing in the Beaver Dam 

Slope, Castle Cliffs, Cedar Pocket, and Scarecrow Peak 

Allotments would sustain minor to moderate impacts 

based on reductions to the initial AUMs that would 

be authorized. Permitted use would be reduced to the 

average of 20 years of actual use; 1,861 initial AUMs of 

livestock forage would be provided under this alternative. This could further reduce the AUMs available for 

livestock use in a given season and could result in shorter 

grazing periods or the turnout of fewer livestock.

Other changes proposed under this alternative would 

include establishing the grazing utilization level at 40% of 

the current year’s growth, which could further reduce the 

amount of forage available for livestock grazing. The construction of range improvements would only be authorized if they further the purposes of the NCA and benefit 

diverse NCA resource values. The impacts on livestock 

grazing management from establishing grazing utilization levels and the construction of range improvements 

would be greater than those identified under Alternative 
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vehicle travel would be limited to specific routes in the 

Congressionally-identified Designated Road Areas within the NCA until the Travel Management Plan is completed for the NCA. Management under Alternative A 

would not adequately resolve potential conflicts between 

recreational uses and livestock grazing, particularly if 

visitor numbers increase, as expected, given the greater 

public interest the NCA will likely generate.

Under Alternatives B and D, recreation would be managed as the Beaver Dam Wash SRMA and emphasize 

more intensive recreation management and the development of visitor amenities and facilities. These alternatives 

would lessen recreation-related impacts on native vegetation and soils, benefitting livestock grazing by helping to 

improve rangeland health and maintain forage production. 

Alternatives B and D would also benefit livestock grazing by restricting recreational target shooting to specific 

locations and requiring specific types of targets. These 

alternatives would lessen the likelihood that recreational 

target shooting would maim or kill livestock or damage 

water storage tanks and troughs; no similar restrictions 

would be in place under Alternative A. When compared to 

Alternative A, the effects of recreation management under 

Alternatives B and D on livestock grazing would be minor 

to moderate and beneficial in the short and long term.

4.8.2.11 Impacts from Management of Comprehensive 

Travel and Transportation

The impacts or benefits on livestock grazing management related to OHV area designations can be estimated 

by comparing the number of acres that are designated as 

Open, Limited, and Closed to motorized vehicle travel 

and uses through the RMP. Alternatives that close more 

acres to motorized travel would be expected to reduce the 

potential for vehicles to kill or injure livestock and prevent 

the introduction or spread of weed or exotic invasive seeds 

and plant materials through tires and vehicle undercarriages. Area closures and limiting vehicle travel to designated roads and trails also protect soils and vegetation 

from surface disturbances related to unauthorized crosscounty travel and route proliferation. Intact soil horizons, 

soil crusts, and vegetation communities would maintain 

rangeland health and benefit livestock through availability 

of quality forage.

Under all alternatives, the NCA would be managed as 

Limited to Designated Roads and Trails. Specific route 

designations developed in the TMP would directly and 

indirectly benefit livestock grazing by minimizing surface disturbances related to unauthorized cross-county 

travel and route proliferation, lessening the likelihood that 

noxious weed seeds and plant materials will be spread 

through vehicle tires and undercarriages and that livestock 

would be injured or killed by motorized vehicles.

4.8.2.12 Impacts from Management of Lands and 

Realty

Acquisition of non-federal lands within the NCA could 

improve access, increase acreage, and provide additional 

resources, such as water sources available for grazing. 

Short-term impacts from the granting of linear and sitetype ROWs and the construction of power lines or pipelines can include forage removal, livestock displacement, 

and an increased potential for noxious weed introduction 

and proliferation.

Under Alternatives A, B, and D, lands acquired within 

the NCA would be managed to further the conservation 

and protection purposes of the NCA and could minimally 

benefit livestock grazing management. Under Alternative 

A, the NCA would be managed as a ROW Avoidance 

area, with the exception of the 196-acre designated corridor along Old Highway 91. Under Alternatives B and 

D, the NCA would be managed as a ROW Exclusion 

area, with the designated corridor along Old Highway 91 

being retained, but with variable widths by alternative. 

Management of the NCA as an Avoidance or Exclusion 

area, with the exception of the narrow designated corridor 

along Old Highway 91, would prevent disturbances to soils 

and vegetation related to the construction of linear and 

site-type ROWs, protecting forage for livestock and moderately benefitting livestock grazing management.

4.8.2.13 Impacts from Management of Public 

Education and Interpretation

In general, Alternatives B, C, and D, would provide additional opportunities for educating visitors about the 

history of livestock grazing on the Beaver Dam Slope and 

about modern livestock grazing practices, which could 

lead to a greater public understanding of this long-term 

use of public lands.

4.8.2.14 Impacts from Management of Scientific 

Research 

In general, Alternatives B, C, and D would provide opportunities for scientific research focused on ecological 

processes, native vegetation community responses to fire, 

exotic invasive species and predicted climate change, and 

the effects on livestock grazing on Mojave desert tortoise 

populations and habitats. Research projects have potential 

for minor to moderate impacts to livestock grazing, depending on nature and scope of research proposed and the 

changes that would be required to grazing management.

4.8.2.7 Impacts from Management of Other Fish and 

Wildlife Species

Under Alternative A, B, and D, management and restoration of native wildlife populations into their historic 

ranges in the NCA could have negligible to minor shortand long-term impacts on livestock operations, by creating potential competition for forage use and water. Water 

developments designed to provide new water sources for 

wildlife could increase water availability for livestock, 

promoting improved distribution of both livestock 

and wildlife.

Limiting fences to specific designs that allow safe passage by big game and other wildlife may not effectively 

prevent livestock from moving into and out of fenced 

pastures. Operator’s herding and management costs 

could be increased where fencing does not effectively 

control livestock movement. Where livestock operators 

are required to construct new fencing or modify existing 

fences to meet wildlife safe passage standards, impacts 

could include increased costs for construction and maintenance of fencing.

4.8.2.8 Impacts from Management of Heritage 

Resources

Alternative A identifies no specific management actions 

for heritage resources that directly address livestock 

grazing management. However, BLM would continue to 

be required to comply with federal historic preservation 

laws, such as the NHPA, and take into account the effects 

of agency sponsored and authorized activities on sites that 

are listed to or eligible for listing to the NRHP. If heritage 

resource inventory or site monitoring reveal that adverse 

impacts on NRHP- listed or eligible properties are occurring as a result of livestock grazing practices, management 

actions would be taken to eliminate impacts.

Under Alternatives B and D, Use Allocations and identified management actions for heritage resources would 

affect relatively small, localized areas of the NCA, with 

minimal effects on forage or grazing practices. The location of new range developments could be constrained 

or precluded by the need to avoid adverse effects to the 

integrity and data potential of sites that are listed to 

or eligible for listing to the NRHP. If heritage resource 

inventory or site monitoring reveal that adverse impacts 

on listed or eligible properties are occurring as a result of 

livestock grazing practices, management actions would 

be taken to eliminate impacts.

4.8.2.9 Impacts from Management of Visual 

Resources

VRM Class I or, to a lesser extent, Class II can limit livestock grazing operations through restrictions on range 

improvements and other facilities. Range improvements 

may be authorized under all VRM classes; however, the 

design and placement of new range improvements in 

VRM Class I and II areas must repeat the basic elements 

of form, line, color, and texture found in the predominant natural features of the characteristic landscape. As a 

result, the cost of construction of fences, water tanks, and 

other range improvements could increase.

Alternative A would be the least restrictive, as all acreage within the NCA would continue to be designated as 

VRM Class III; impacts on livestock grazing operations 

related to visual resource management would be negligible. Alternatives B and D would designate all acreage 

within the NCA as VRM Class II, requiring that range 

improvements and facilities must not attract the attention of the casual observer. The impacts to livestock 

grazing operations could be minor to moderate under 

Alternatives B and D.

4.8.2.10 Impacts from Management of Recreation and 

Visitor Services

Under all alternatives, recreational activities could directly impact livestock grazing through human activities, and 

indirectly through rangeland degradation that may result 

from these activities. Pasture gates can be left open by 

recreational users, allowing livestock to move into areas 

that are not authorized for grazing; motorized vehicles 

can kill or injure cattle on or near roadways, hunters and 

target shooters can injure or kill grazing animals, and 

water sources, fences, or other range improvements can 

be vandalized. Recreational uses may also damage or destroy native vegetation, disturb soils and soil crusts, and 

introduce weeds and exotic invasive species that degrade 

rangeland health.

Under Alternative A, impacts on livestock grazing from 

recreational uses would continue to be minor, as current visitor numbers are low and there are no developed recreation areas, trails, or other amenities that 

specifically attract visitors. The NCA would continue 

to be managed within the SGFO ERMA, with emphasis 

continuing to be on dispersed and generally unmanaged 

recreation. Restrictions on group sizes and the type of 

Special Recreation Permits that could be authorized in 

the Beaver Dam Slope ACEC would continue to be in 

place under this alternative, to protect critical habitat 

and populations of Mojave desert tortoise. Motorized 
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VEGETATION RESOURCE USES: LIVESTOCK GRAZING VEGETATION RESOURCE USES: PLANT MATERIALS

or augment forage for livestock in the allotments that are 

crossed by the corridors.

Future actions or factors anticipated to affect livestock 

grazing in the CIAA could include implementation of 

actions recommended in the 2014 Northeast Mojave 

Recovery Unit Implementation Plan for the Mojave 

desert tortoise developed by the Utah/Arizona Recovery 

Implementation Team, an advisory group chartered by 

the USFWS, under the auspices of the Revised recovery plan for the Mojave population of the desert tortoise 

(2011). Actions are likely to include increased efforts 

to control invasive annual brome grasses and wildfires 

through landscape-wide fire breaks and fuel treatments 

in the CIAA. As ongoing research studies identify more 

effective and environmentally sustainable treatment 

methods, it is likely that larger areas would be treated and 

livestock grazing restricted in those areas, until resource 

objectives are met in the project areas. Future listings of 

other native species under the ESA could also impose 

restrictions on livestock grazing.

4.9 VEGETATION RESOURCE USES: PLANT 

MATERIALS

This section discusses impacts on the use of plant materials that might result from proposed management actions 

for other resources and land uses identified in the four 

alternatives in Chapter 2.

4.9.1 Methods of Analysis

This analysis focuses on those management alternatives 

or actions that have the potential to impact the use of 

plant materials. In the absence of quantitative data, best 

professional judgment was used, and impacts are sometimes described using ranges of potential impacts or in 

qualitative terms, if appropriate.

4.9.1.1 Indicators

Indicators of adverse impacts on the management of 

plant materials include:

▶ Diminished productivity or loss of biodiversity in 

native plant communities;

▶ Unavailability of a wide variety of local native plant 

seeds, plants, and cuttings for scientific research and 

restoration purposes.

Indicators of beneficial impacts on the management of 

plant materials include:

▶ Increased productivity and biodiversity in native 

plant communities;

▶ Availability of a wide variety of local native plant 

seeds, plants, and cuttings for scientific research and 

restoration purposes.

4.9.1.2 Assumptions

The analysis includes the following assumption:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ Plant materials would be available to use in restoration projects and scientific studies.

Implementing management actions for the following resources would have negligible or no impact on 

noxious weeds and are, therefore, not discussed in 

detail: Air Quality, Water Resources, Geologic and 

Paleontological Resources, Caves and Karst Resources, 

Soil Resources, Native Vegetation Communities, Fire and 

Fuels Management, Noxious Weeds and Invasive Species, 

Vegetation Resource Uses: Livestock Grazing, Special 

Status Species, BLM Sensitive Species, Other Fish and 

Wildlife Species, Heritage Resources, National Historic 

Trails, National Natural Landmarks, ACECs, Visual 

Resource Management, Natural Soundscapes, Lands 

with Wilderness Characteristics, Recreation and Visitor 

Services, Comprehensive Travel and Transportation 

Management, Lands and Realty, and Public Education 

and Interpretation.

4.9.2 Direct and Indirect Impacts

4.9.2.1 Impacts from Management of Vegetation 

Resource Uses: Plant Materials

Alternative A would continue to authorize the commercial and non-commercial harvesting of fuelwood (pinyon 

pine and Utah juniper only), Christmas trees, and native 

seeds from selected grasses, forbs, and shrubs from 

approximately 9016 acres of the NCA. These acres are 

outside of the Beaver Dam Slope ACEC and designated 

critical habitat for the Mojave desert tortoise. All of this 

acreage is within the Congressionally-defined Designated 

Road Areas, requiring that access to the harvesting and 

collection areas must be non-motorized. This alternative could result in negligible to minor impacts on the 

unburned acres of pinyon-juniper woodlands if fuelwood harvesting were to occur in these areas. It could 

also impact the natural re-vegetation of fire-damaged 

woodlands and desert shrublands by removing seeds and 

seed sources. The lack of motorized vehicle access and 

few harvest opportunities would lessen the potential that 

continued management of these acres for commercial 

and non-commercial fuelwood, Christmas tree, and post 

4.8.3 Summary of Impacts from Alternatives

Livestock grazing management practices would continue 

to be evaluated through monitoring and changes made 

through the grazing permitting process, where Utah 

Standards for Rangeland Health are not being met or not 

making progress toward meeting standards.

Alternative A would continue livestock grazing management in the four allotments that overlap the NCA under 

the current terms and conditions of the grazing permits 

and approved grazing management strategies. This alternative would result in no changes from current conditions and, therefore, no impacts to the livestock grazing 

management or livestock operators.

Under Alternative B, livestock grazing in the Beaver Dam 

Slope, Castle Cliffs, Cedar Pocket, and Scarecrow Peak 

Allotments would sustain minor to moderate impact 

based on reductions to the initial AUMs that would 

be authorized. Permitted use would be reduced to the 

average of 20 years of actual use; 1,861 initial AUMs of 

livestock forage would be provided under this alternative. This could further reduce the AUMs available for 

livestock use in a given season and could result in shorter 

grazing periods or the turnout of fewer livestock. Grazing 

utilization levels would be set at 40% of the current year’s 

growth, which could further reduce the amount of forage available for livestock grazing. This alternative could 

result in minor to moderate impacts on livestock grazing 

and could limit the ability of operators to fully utilize the 

resources within an allotment. Minor negative impacts 

and/or beneficial effects from other resource uses under 

this alternative may also affect livestock grazing.

Alternative C would make the entire NCA unavailable to livestock grazing over the life of the RMP and 

would eliminate all grazing activities on the portions 

of the Beaver Dam Slope, Castle Cliffs, Cedar Pocket, 

and Scarecrow Peak allotments that intersect the NCA 

(61,995 total acres). The overall impact to livestock 

grazing from this alternative would be major and long 

term. Permittees who are unable to graze on public lands 

in the NCA could experience substantial increases to 

their operations’ costs for feed and range improvements, 

potentially to the point where remaining in the livestock 

business may not be economically feasible.

Under Alternative D, the impacts on livestock grazing 

management would be similar to those identified under 

Alternative A with two exceptions. Grazing utilization 

levels would be set at 45 % of the current year’s growth, 

potentially further reducing the amount of forage 

available for livestock grazing. The construction of range 

improvements would only be authorized if they further 

the purposes of the NCA and benefit diverse resource 

values. Compared to Alternative A, this action could 

limit the flexibility in constructing range improvements 

and could limit the ability of operators to fully utilize the 

resources within an allotment.

4.8.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts includes 

BLM-managed grazing allotments on the Beaver Dam 

Slope of Utah, Arizona, and Nevada. These allotments 

include designated critical habitat for the threatened 

Mojave desert tortoise, are within the Northeast Mojave 

Recovery Unit for desert tortoise, and grazing management practices are managed by BLM to fulfill the recommendations from the recovery plan for the Mojave 

Desert (1994, revised 2011) and USFWS Biological 

Opinions. Past actions or factors that have affected 

livestock grazing on the Slope include overgrazing of the 

rangelands, road and highway construction, the development of range improvements and vegetation treatments, 

and the construction of major interstate power transmission lines and gas pipelines in designated utility corridors 

that cross three states in the CIAA. Other factors that 

have impacted the CIAA include prolonged periods of 

drought, proliferation of noxious weeds and invasive 

species, particularly the annual brome species, and more 

recently, larger and more frequent wildfires that have 

contributed to current ecological conditions.

Present actions or factors affecting livestock grazing are 

mainly those that reduce available grazing acreage and 

restrict management actions or the level of forage production in those areas. Key examples include the effects 

of droughts, exotic invasive species that are fueling an 

atypical annual fire regime in the Mojave Desert, large 

wildfires, and restrictions on grazing in specific locations 

(e.g., riparian areas) or at certain times to lessen impacts 

on threatened and endangered species and habitats. The 

construction of new utilities in the IPP and NavajoMcCullough designated corridors that are adjacent to, 

but outside of the boundaries of the NCA, has been 

ongoing over the past three decades and is predicted to 

be ongoing over the life of the RMP. Impacts to other 

resource values, including special status species, are mitigated or compensated related to these ROWs, but can 

impact livestock grazing through the short-term loss of 

forage and disturbances to livestock during the construction phases. In the long term, “greenstripping” in the designated corridors by the utility companies would restore 
654 Chapter 4 BDWNCA BDWNCA Chapter 4 655

SPECIAL STATUS SPECIES SPECIAL STATUS SPECIES

4.10.1.1 Indicators

Indicators of adverse impacts on special status species 

include the following:

▶ Likelihood for degradation, alteration, loss or 

avoidance of habitat;

▶ Likelihood of injury or mortality;

▶ Likelihood of interference with species movement 

patterns that lead to substantial population declines;

▶ Likelihood of impacts on survival or reproductive 

success.

4.10.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA;

▶ Consultations under Section 7 of the ESA would 

be conducted with the USFWS for all land uses in 

the NCA that have the potential to affect populations and designated critical habitats for federallylisted species;

▶ The health of species is tied to the health of the 

habitats and vegetation on which they depend and 

thus impacts on habitats and vegetation would affect special status species;

▶ Special status species would be more sensitive than 

common species to habitat fragmentation, development, or changes in habitat conditions, as populations are often already highly fragmented, require 

specific microhabitats, and are especially sensitive 

to disturbance and human presence;

▶ Impacts on special status species would be more 

significant than impacts on common species because population numbers are low and population 

viability is already uncertain.

Implementing management actions for the following 

resources would have no or negligible impacts on special 

status species and are, therefore, not discussed in detail: 

Air Quality, Geologic and Paleontological Resources, 

Cave and Karst Resources, Soil Resources, Vegetation 

Resource Uses: Plant Materials, Other Fish and Wildlife 

Species, Heritage Resources, National Historic Trails, 

National Natural Landmarks, and Natural Soundscapes.

4.10.2 Direct and Indirect Impacts

4.10.2.1 Impacts from Management of Water 

Resources

Under all alternatives, the acquisition of non-federal 

tracts along the Beaver Dam Wash from willing sellers 

could increase protection of surface water resources from 

disturbances related to developments. Such acquisitions 

could potentially improve aquatic and riparian habitats, benefitting Virgin spinedace, the desert sucker, and 

riparian obligate species, such as the Southwest willow 

flycatcher and western yellow-billed cuckoo. 

Under all alternatives, the application of BMPs and other 

site-specific mitigation measures for surface disturbing 

land uses or post fire ES&R projects would help to maintain soil stability, minimize wind and water erosion, and 

ensure that surface disturbances do not impair aquatic 

and riparian habitats that support special status species. 

These measures would reduce the likelihood for decreased population viability or the need to list candidate, 

proposed, and BLM Sensitive Species under the protection of the ESA.

4.10.2.2 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Under all alternatives, managing upland and riparian 

communities to meet the Utah Standards of Rangeland 

Health, post-fire ES&R actions, and applying BMPs 

would protect special status species habitats, helping to 

ensure that populations have access to suitable forage, 

cover, and areas suitable for reproduction.

Under Alternative A, vegetation conversion treatments 

could continue to be authorized to benefit livestock or 

other wildlife species, as well as post fire ES&R projects 

that include the use of non-native species. Vegetation 

conversion treatments could impact habitat and populations of the desert tortoise or other special status species 

that rely on native Mojave Desert plants to provide forage 

that satisfies their unique physiological adaptation to 

this arid environment. The continued use of non-native 

species, like forage kochia, which has never been scientifically studied for use in the Mojave Desert for post fire 

ES& R actions could result in negative impacts on native 

vegetation communities that provide critical habitats for 

special status species. These impacts could include the 

potential that introduced non-native species become invasive, particularly under changing climactic conditions, 

displacing or impeding the re-establishment of desirable 

native species. 

Alternatives B, C, and D would not authorize vegetation 

conversions and propose fuel breaks and hazard fuel 

reduction projects that would help to limit the accidental ignition and spread of wildfires. The use of existing 

roads, natural drainages, and topographic features to limit surface disturbances associated with the development 

harvesting or seed collection from selected species would 

comprise a measureable impact on native vegetation 

communities over the life of the RMP. 

All alternatives would allow for the collection of plant materials for use by Native Americans for religious, ceremonial, and traditional purposes. This would have a negligible 

effect on native plant communities, as these uses would 

remove small amounts of material from localized areas.

Under Alternatives B, C, and D, the NCA (63, 480 acres) 

would be closed to commercial and non-commercial 

fuelwood, Christmas tree and post harvesting, as well 

as commercial and non-commercial seed collection 

and plant materials collection. This management would 

continue to have a beneficial effect on native vegetation communities, by preventing biomass loss, surface 

disturbances, accidental human-caused fires, and other 

impacts that can be associated with commercial and noncommercial harvesting and collection.

Alternatives B, C, and D would authorize collection of 

native seeds, plants, seedlings, cuttings, biological soil 

crust communities and species for scientific research 

through an NCA Scientific Research Permit and a Utah 

BLM Specimen Collection permit, where required. These 

alternatives would also authorize the collection of native 

seeds, seedlings, plants, cuttings, biological soil crust 

communities and species for conservation and future use 

in restoration projects. The availability of locally-derived 

seeds and plant materials would improve the success of 

restoration projects and help to prevent the introduction 

of noxious weeds and invasive species.

Alternative C would authorize the harvesting and collection of seeds and plant materials for use in ecological 

restoration projects only in the NCA. Alternatives B and 

D would expand the areas where harvested and collected 

plant materials could be used to similar habitats outside 

the NCA. For projects within or in adjacent areas to the 

NCA, the use of locally-derived seeds and plant materials would improve the success of restoration projects and 

help to prevent the introduction of noxious weeds and 

invasive species.

4.9.2.2 Impacts from Scientific Research

Alternatives B, C, and D would authorize the collection of seeds and other plant materials under an NCA 

Scientific Research Permit for use in research studies. 

These alternatives would pursue opportunities for studies 

to be conducted that enhance native species or native 

cultivars, develop effective controls for exotic invasive 

species, and new methods to improve the success of 

re-vegetation techniques in disturbed and fire-damaged 

native vegetation communities of the Mojave Desert, 

potentially benefitting all resource values of the NCA.

4.9.3 Summary of Impacts from Alternatives

Under Alternatives B, C, and D, management actions 

would focus on the conservation, protection, and restoration of native vegetation communities by not authorizing 

permits for commercial and non-commercial harvesting and collection of plant materials. The collection and 

use of the seeds and plant materials for research and 

ecological restoration projects in the NCA or adjacent 

similar habitats could benefit special status species and 

other wildlife that rely on native plant species to meet 

their nutritional and other habitat requirements. Native 

Americans would continue to be able to use these resources for religious, ceremonial, and traditional purposes under these alternatives, providing a beneficial effect 

for the continuation of traditional cultural practices.

4.9.4 Cumulative Impacts

The CIAA was defined as the 63,480 acres of the NCA, as 

the effects of management of plant materials would not 

extend beyond the boundaries of the NCA. Commercial 

and non-commercial fuelwood and post harvesting , as 

well as seed and plant materials collection, has not been 

permitted on 54,464 acres of the NCA since 1999 when 

the SGFO RMP was approved. Under Alternatives B, C, 

and D, this management decision would be expanded to 

encompass all acres of the NCA. The continued management of the public lands as closed to commercial and 

personal use plant materials harvesting and collection 

would not create a new or unusual impact on commercial 

ventures or individuals especially in light of the vehicular 

access constraints. Opportunities to harvest and collect 

plant materials for commercial and non-commercial uses 

continue to be available on other public lands managed 

by the SGFO, on the Dixie National Forest and on public 

lands managed by BLM on the Arizona Strip and in 

southern Nevada.

4.10 SPECIAL STATUS SPECIES: THREATENED, 

ENDANGERED, CANDIDATE, AND SPECIES 

PROPOSED FOR LISTING UNDER ESA, AND 

BLM SENSITIVE SPECIES

4.10.1 Methods of Analysis

The analysis presented is largely qualitative due to the 

lack of data on the occurrences of special status species.
656 Chapter 4 BDWNCA BDWNCA Chapter 4 657

SPECIAL STATUS SPECIES SPECIAL STATUS SPECIES

strongly positive impact on the management of habitats 

for many special status species.

4.10.2.3 Impacts from Management of Noxious 

Weeds and Invasive Species

Under all alternatives, weed and invasive species controls would be implemented under relevant standard 

operating procedures and mitigation measures presented 

in the Final Vegetation Treatments Using Herbicides on 

BLM Lands in 17 Western States PEIS (BLM 2007). With 

proper implementation, weed treatment methods under 

all alternatives would control or eradicate noxious weeds 

and invasive species.

Alternatives B, C, and D identify a slightly varied range 

of tools to control weeds and exotic invasives, including 

the potential use of biological controls under projectspecific plans. Biological controls for invasive annual 

brome grasses are currently in the experimental stage 

and may never be applicable on a broad scale, even over 

the life of the RMP. Alternative C would not authorize 

the use of contracted grazing animals for specific types of 

projects, limiting an option that could be cost-effective to 

potentially control noxious weeds and invasive species. 

This limitation would help to prevent the introduction 

and spread of undesirable exotic species by the grazing 

animals and eliminate any risk of injuries or mortalities 

to special status species that might occupy or enter the 

project area. 

Under these alternatives, controlling noxious weeds and 

invasive species in riparian areas, using biological controls, hand removal, herbicide, mechanical methods, and 

targeted grazing methods, could pose some risk to habitats 

of Southwest willow flycatcher and yellow-billed cuckoo 

if the vegetation removal occurred too quickly or during 

nesting season. Consultation with USFWS would help to 

ensure that the projects would be designed in a way that 

would have no negative impact on these species.

4.10.2.4 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing

Livestock grazing could cause impacts on special status 

species’ habitats, to varying degrees, through the introduction or spread of noxious weeds, through dietary 

competition, or through the trampling dens and burrows. Under all alternatives, continuing to manage the 

Woodbury Desert Study Area as unavailable for livestock 

grazing would protect special status species and habitats 

within the area and allow for continued scientific research in an area where desert tortoises and other Mojave 

Desert species have been the focus since the 1930s.

Alternatives A would continue current management in 

the four allotments, authorizing 3,099 AUMs of livestock 

forage and managing under the current seasons of use. 

The fall-winter-early spring seasons of use were established in 1999 to minimize forage competition between 

cattle and desert tortoise during the spring, summer, and 

fall months, when tortoises were active and reproducing. The impacts or benefits to the desert tortoise of this 

grazing management regime have not been rigorously 

evaluated within the NCA. Tortoise density monitoring data collected over the past decade in the multi-state 

Northeast Mojave Recovery Unit, in which the NCA is 

located, suggest that tortoise populations are increasing 

(USFWS 2014), but the factors that are contributing to 

the apparent increase have not been conclusively isolated.

Under this alternative, closing burned areas to grazing for a minimum of one to two years (depending on 

whether it was treated following being burned) would be 

negligibly beneficial to desert tortoise and riparian dependent species, as it would allow a minimal level of recovery to occur before livestock would be reintroduced.

Considering voluntary relinquishments of grazing 

permits on a case-by-case basis for re-issuance would 

have a neutral to positive effect on special status species, depending on whether or not allotments are closed 

and for how long. The more closures and the greater the 

duration, the more positive the effect would be. Each 

AUM removed would allow up to 800 pounds of forage 

per year to be available for desert tortoise or other special 

status species that experience dietary overlap with cattle.

Authorizing range developments on a case-by-case 

basis could have a slightly positive to moderately negative impact on special status species and habitats. Range 

improvements that draw cattle away from riparian areas 

could benefit Southwestern willow flycatcher, yellow 

billed cuckoos, and native fish that rely on riparian and 

aquatic habitats. Desert tortoise, Gila monsters, and 

other sensitive reptiles could be negatively impacted by 

range improvements that encourage grazing in previously ungrazed areas, increasing the risks of trampling of 

dens and burrows and injuries and mortalities to juveniles of these species.

Alternative B would continue to make public lands 

available for grazing in the four allotments that overlap 

the NCA, but provide an initial 1,861AUMs of livestock 

forage through a reduction in permitted use. Utilization 

levels of current year’s plant growth would be established at 40%, a reduction from the current levels. The 

seasons of use would be the same as those identified 

of fuel breaks would help to protect habitats for special 

status species. Minimizing the loss of unburned and once 

burned native vegetation would be strongly beneficial to 

desert tortoise and other at-risk species. 

These alternatives propose the use of a variety of methods to develop fuel breaks, while minimizing the level of 

impacts on soils, native vegetation, and water resources. 

Alternatives B and D would authorize the use of some 

surface disturbing equipment, but would minimize impacts on habitats by using existing roads, drainages, and 

topographic features to lessen new surface disturbances 

causing unacceptable levels of damage to special status 

species’ habitats. 

Alternative C would not authorize herbicide use to develop fire breaks and fuel reduction projects, eliminating the 

potential for impacts on special status species’ habitats 

that might result from the use of chemical treatments. 

This alternative would minimize disturbances but might 

also limit the number of fuel breaks or fuel reduction 

projects that could be completed, leaving more unburned 

areas of native vegetation vulnerable to the effects of fire. 

 Consultations under Section 7 of the ESA would be conducted with the USFWS for all project proposals that have 

the potential to affect special status species’ populations 

and designated critical habitats for federally-listed species. 

Impacts would be avoided through project monitoring by 

qualified biologists and the identification of tortoise dens 

or occupied Southwestern willow flycatcher nests within a 

project area, helping to ensure that the “incidental take” of 

tortoises would not result from these actions. 

Alternative C would only use native, locally derived 

seeds for restoration, potentially producing less biomass 

than Alternatives A, B, and D. Alternative C would only 

authorize the use of hand tools for re-vegetation projects 

and could reduce the success rate of seeding efforts. It 

would also reduce the chance that re-seeding activities 

could inadvertently lead to increased levels of noxious 

weeds and invasive species.

Alternatives B and D would allow for invasive methods 

of seed protection, such as chaining or harrowing, to be 

used. These methods could increase the potential for 

brome grass infestations, if native vegetation restoration 

methods are not successful in the short term, further 

damaging the quality of habitat for desert tortoise or 

other special status species. The crushing of tortoise dens, 

or injuries and mortalities to tortoises would be avoided, 

through reasonable and prudent measures developed 

through consultations under Section 7 of the ESA conducted with the USFWS. 

Under Alternatives B, C, and D, upland and riparian areas where ES&R projects or other vegetation restoration 

efforts have been conducted would be unavailable for 

livestock grazing until all resource objectives have been 

met. When compared to Alternative A, under which livestock grazing might only be excluded from project areas 

for two growing seasons, these alternatives would help to 

ensure that re-vegetation efforts have a higher potential 

for success. All special status species would benefit from 

the restoration of native vegetation communities that 

meet their habitat and nutritional requirements.

In general, actions that reduce wildfire numbers, size, 

and frequency would benefit desert tortoises, Gila monsters, and other at-risk Mojave Desert wildlife species, 

by protecting native vegetation communities and soil 

resources, minimizing the potential that exotic invasive 

species will proliferate.

Alternative A still includes a small role for the potential 

use of prescribed fire to achieve management objectives. 

Prescriptive fires would have a negative impact on special 

status species’ habitats, resulting in increased acreage 

of fire-damaged habitat and possible injuries and mortalities of individuals. Burned areas would provide less 

thermal cover and significantly reduced forage for desert 

tortoise and other at-risk species.

Under Alternatives B, C, and D, full suppression methods 

would be employed to minimize fire size and duration 

would be employed, benefitting all special status species, including those that occupy aquatic and riparian 

habitats. Wildfire use to achieve management objectives 

would not be authorized under any of these alternatives, 

again benefitting desert tortoises and other at-risk species. Minimizing the use of backburning would reduce 

or eliminate the loss of unburned habitats damage to fire 

suppression tactics.

The potential impacts to and benefit of proposed fuels 

management actions on special status species and their 

habitats by alternative are described above under Native 

Vegetation Community Management.

Under Alternatives B and D, research related to fireeffects in the Mojave Desert could be authorized, but 

limited to different sizes, one acre and five acres, respectively. Habitat damage from the research could be offset 

by the scientific knowledge gained. Although uncertainty 

exists with any research project, there is a potential for a 
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values and research potential of the Joshua Tree National 

Natural Landmark and the Woodbury Desert Study Area. 

This alternative would continue to manage the ACEC 

as an Avoidance area for new utility and transportation 

ROWs, outside of the designated utility corridor along 

Old Highway 91, and under VRM Class III. Motorized 

vehicle uses would be limited to the designated roads 

identified by Congress in the three Designated Road 

Areas (pursuant to OPLMA, Section 1975) and through 

the approved TMP. 

Under Alternatives B, C, and D, the ACEC designation 

would be revoked, but would not result in lesser levels 

of protection for the relevance and importance values of 

the ACEC. As shown in Table 4-7, Congressional segregations, management, and uses identified in OPLMA 

Section 1975 provide protections that are equal or superior to those provided by ACEC designation for: entry, 

appropriation, and disposal under the public land laws; 

location, entry, and patenting under the mining laws; and 

operation of the mineral leasing, mineral materials, and 

geothermal leasing laws. Alternatives B, C, and D propose management decisions across all resource uses and 

programs that would provide similar or higher levels of 

protection than the management prescriptions identified 

under Alternative A.

The proposed revocation of the ACEC designation would 

also apply to public lands outside of the NCA, within the 

designated IPP and Navajo-McCullough utility corridors. 

The revocation would not result in a loss of protection 

for the relevance and importance criterion for the ACEC, 

which are critical habitat and populations of tortoise 

within the two designated utility corridors, as the legal 

requirements of the ESA would continue to be in effect. 

Consultations under Section 7 with the USFWS for all 

developments within those corridors would continue to 

address avoidance of “incidental take” of tortoises and 

mitigation/compensation for the adverse modification of 

critical habitat.

Alternatives B, C, and D include other management actions to benefit desert tortoise and other special status 

species, including the potential to authorize population 

augmentations, translocations, and predator control. 

Tortoise population augmentation and translocation of 

desert tortoises to the NCA, coupled with disease and 

genetic screening, could help to re-establish tortoise density and genetic variability, better ensuring reproductive 

success, a major benefit, with no adverse impacts.

Project and species level planning would ensure that 

predator control only occurs if scientifically supported, 

and could be discontinued if found to be ineffective or 

counterproductive. This would have a greater benefit to 

special status species when compared to Alternative A.

Maintaining habitat connectivity would support species 

health and population viability. Contiguous, uninterrupted habitat could protect special status species from 

human disturbances and provide breeding, migration 

and foraging areas that would benefit all species.

4.10.2.6 Impacts from Management of ACECs

Impacts from the continuation, expansion, or revocation of the ACEC designation for the Beaver Dam 

Slope ACEC are addressed above under “Impacts from 

Management of Special Status Species, including BLM 

Sensitive Species.”

4.10.2.7 Impacts from Management of Visual 

Resources

Alternative A would continue to manage the land base of 

the NCA (63,480 acres) as VRM Class III, which allows 

for changes to the existing landscape to occur. Surface 

disturbances could be authorized that could impact 

habitats and populations of special status species. Should 

such actions be proposed in designated critical habitats 

for federally-listed or proposed species, the potential 

take of listed species and the adverse modification of 

critical habitats would be avoided, lessened, or mitigated 

through the implementation of the Reasonable and 

Prudent Measures and Terms and Conditions developed in the project-specific Biological Opinions that 

would be prepared by USFWS, through consultations 

under Section 7 of the ESA. Impacts to BLM Sensitive 

Species under this alternative would be avoided or 

lessened to the extent possible, through project design, 

the use of BMPs, and appropriate mitigation measures. 

Management under VRM Class III would provide some 

level of protection for special status species, and potential 

impacts would be expected to be negligible to minor, 

based on compliance with the ESA for federally-listed or 

proposed species and the implementation of protective 

measures for BLM Sensitive Species.

Alternatives B and D would manage all of the NCA as 

VRM Class II, under which very little change to the 

existing character of the landscape would be authorized, 

providing minor to moderate beneficial effects for special 

status species and their habitats. Under these alternatives, it would be unlikely that projects or developments 

could be authorized that would adversely modify designated critical habitats or result in the “incidental take” of 

federally-listed or proposed species. Compliance with the 

under Alternative A. This alternative would likely increase the amount of forage that would be available for 

desert tortoise and special status species and reduce the 

potential for direct impacts, such as collapse of dens, 

injuries, or mortalities.

Under Alternative C, 61,995 acres of the NCA would be 

unavailable for grazing, benefiting desert tortoise and 

other at-risk species by reducing competition for forage 

and eliminating other direct and indirect impacts on 

populations and habitats. Each cattle AUM requires 800 

pounds of forage and by eliminating 3,099 AUMs (current permitted level), as much as 2.5 million pounds of 

forage could be available for use by special status species 

and other wildlife. The introduction or spread of noxious 

weeds and invasive species that can result from manure 

and trailing would be eliminated. All grazing-related impacts to riparian areas and on surface water quality in the 

Beaver Dam Wash and at the Welcome Springs complex 

would be eliminated, potentially benefitting aquatic and 

terrestrial species that utilize these sensitive areas.

Implementation of this alternative could reduce the 

amount of surface water that is available to special status species, as a majority of the water rights to natural 

springs that are within or near the NCA are held by the 

livestock operators, developed and delivered through 

pipelines to troughs, drinkers, and small catchments to 

benefit their grazing operations. If the public lands of 

the NCA were unavailable for grazing over the life of the 

RMP, it is likely that the only water sources that would 

be available for special status species and other wildlife 

would be the flows in Beaver Dam Wash and seasonal 

precipitation carried by ephemeral drainages. There 

would be no option to increase surface water sources for 

special status species or other wildlife, as under current 

State of Utah statutes, BLM cannot acquire new water 

rights and must make beneficial use of existing federal 

water rights for domestic livestock grazing. Limitations 

on surface water sources under Alternative C, when 

compared to Alternatives A, B, and D, could negatively 

impact some BLM Sensitive Species, but would not adversely or significantly affect a majority of the federallylisted species (e.g., desert tortoises or riparian obligate 

avian species) as they do not rely on water delivered to 

livestock troughs or catchments. 

Under Alterative D, livestock grazing would continue 

to be authorized in the four allotments that overlap the 

NCA as described under Alternative A. Utilization would 

be established at 45% of current year’s plant growth, 

lower than under Alternative A (50-60%) but higher than 

under Alternative B. Development of new Allotment 

Management plans for Beaver Dam Slope, Castle Cliffs 

and Scarecrow Peak Allotments could result in minor 

to moderate beneficial effects for diverse special status 

species, as the management actions related to livestock 

grazing that would assist the recovery and delisting of 

these species could be addressed in those plans. 

Under Alternatives B and D, retiring grazing permits 

that have been voluntarily relinquished and not making 

the allotments associated with those permits available 

for grazing over the life of the RMP could have a neutral to strongly positive impact on special status species. 

Additional forage would be available for special status 

species, livestock related impacts on riparian areas and 

water quality could be eliminated or reduced, and the potential for noxious weeds and invasive species introduced 

or spread lessened. 

These alternatives would also only authorize new range 

improvements if they further the conservation purposes 

of the NCA for all natural and cultural resource values. 

This would benefit special status species’ habitats and 

populations by ensuring that new developments do not 

result in habitat degradation, fragmentation, or loss or 

fragmentation or introduce new land uses that would 

cause at-risk species to abandon key habitat areas.

4.10.2.5 Impacts from Management of Special Status 

Species, Including BLM Sensitive Species

Under all alternatives, non-federal lands could be purchased or acquired within the NCA and federal lands 

retained in federal ownership, benefitting special status 

species’ habitats and populations by ensuring that acquired lands are managed to assist recovery and delisting. Installation of tortoise barrier fencing along Old 

Highway 91 through the NCA would reduce the potential for tortoise mortalities along this highway; overall, 

there would be a minor positive effect from this action.

Continuing to manage the 1,063-acre fenced Woodbury 

Desert Study Area as unavailable for livestock grazing would protect desert tortoises, other at-risk Mojave 

Desert species and their habitats within the area. It would 

also allow for continued scientific research in an area 

where tortoises have been the focus since the 1930s.

Under Alternative A, the approximately 48,519 acre 

Beaver Dam Slope ACEC (93% within the NCA) would 

continue to be managed as an administrative designation, 

providing special management attention to the protection of desert tortoise populations and habitat, other 

at-risk Mojave Desert plants and wildlife, and the natural 
660 Chapter 4 BDWNCA BDWNCA Chapter 4 661

SPECIAL STATUS SPECIES SPECIAL STATUS SPECIES

SGFO RMP, leaving tortoise populations vulnerable to 

recreational target shooting impacts under Alternative A.

Alternative D would continue to authorize recreational 

target shooting within the NCA, but require that only 

specific types of targets be used and that all target trash 

be removed by shooters. This alternative would provide a 

minimally higher level of protection for critical habitats 

by reducing shooting litter, but would confer no protection to desert tortoises or other wildlife from injuries or 

fatalities caused by recreational target shooting or the 

threat of wildfires. Like Alternative A, this alternative is 

not in conformance with recommended restrictions in 

tortoise habitat from the Recovery Plan.

Alternatives B and C would prohibit or restrict damaging recreational activities. Alternative B would prohibit 

recreational target shooting in designated critical habitat 

for the Mojave desert tortoise, lessening the potential that 

tortoises would be accidentally or deliberately harmed 

or killed by this activity on 50,908 acres of the NCA. 

Alternative C would prohibit recreational target shooting within the NCA, eliminating this potential threat to 

desert tortoises and other wildlife species. Outside of 

designated critical tortoise habitat, Alternative B would 

authorize recreational target shooting, but require the use 

of specific target types . It would also require the removal 

of all target trash, lessening the potential that lead bullets 

could be ingested by other wildlife, leach lead into soils, 

and that litter would continue to damage habitats or 

attract common ravens or other predators that prey on 

juvenile and immature desert tortoise.

4.10.2.10 Impacts from Management of 

Comprehensive Travel and Transportation

The nature and type of impacts on special status species 

population and habitats from transportation and travel 

management could include habitat avoidance, interference of movement, and increased likelihood of injury/

mortality due to presence of human activities along 

routes. Surface disturbances or habitat fragmentation and 

loss could also result from motorized and non-motorized 

vehicle travel. These impacts are most directly related to 

the density and location of route networks that are designated on public lands, through the TMP process.

The impacts or benefits on special status species and 

habitats related to OHV area designations can be estimated by comparing the number of acres that are designated as Open, Limited, and Closed to motorized vehicle 

travel and uses through the RMP. Alternatives that close 

more acres to motorized travel would be expected to 

reduce the potential for vehicles to kill or injure special 

status species. Area closures and limiting vehicle travel to 

designated roads and trails also protect soils and vegetation from surface disturbances related to unauthorized 

cross-county travel and route proliferation. Intact soil 

horizons, soil crusts, and vegetation communities would 

maintain the quality of habitats critical for at-risk species.

Under all alternatives, the NCA would be managed as 

Limited to Designated Roads and Trails. Specific route 

designations developed in the TMP would directly and 

indirectly benefit special status species, minimizing surface disturbances related to unauthorized cross-county 

travel and route proliferation, thereby reducing the 

potential for injuries and fatalities of desert tortoise or 

other special status species from motorized vehicle travel 

off designated routes.

4.10.2.11 Impacts from Management of Lands and 

Realty

Under all alternatives, acquisitions of non-federal inholdings within the NCA from willing owners would be 

beneficial for special status species and critical habitats. 

Acquired lands would be managed consistent with the 

Congressionally-defined purposes for the NCA and the 

goals, objectives, and management decisions from the 

approved NCA RMP; these decisions emphasize the conservation and protection of special status species populations and their habitats.

Under Alternative A, the NCA would be managed as a 

ROW Avoidance area, with the exception of the 196-acre 

designated corridor along Old Highway 91. New ROWs 

could be granted for the development of power lines, 

pipelines, or other utilities in that designated corridor. 

Impacts to desert tortoise and other special status species 

would be avoided to the extent possible through project 

design, BMPs, and stipulations developed through Section 

7 consultations and project-specific Biological Opinions. 

Adverse modification of designated critical habitat would 

be mitigated through compensation or habitat acquisition. Impacts to avian species related to power lines would 

also be mitigated through project design. The potential for 

impacts on special status species would be negligible to 

minor under this alternative.

Under Alternates B and D, the NCA would be managed 

as a ROW Exclusion area, with the designated corridor along Old Highway 91 retained, but with variable 

widths by alternative (100 feet and 250 feet in total width, 

respectively). The narrow corridor widths proposed 

under either alternative would generally preclude large 

ESA and protective measures for BLM Sensitive Species 

would reduce the potential for negative impacts to a 

negligible level. 

Alternative C would manage 16,564 acres of the NCA as 

VRM Class I and 46,916 acres as VRM Class II. These 

VRM class designations would provide the highest 

level of protection to special status species’ habitats and 

populations, when compared to the other alternatives, 

as the entire land base of the NCA would be managed to 

protect its scenic qualities, thereby limiting the types of 

developments or projects that could result in damage or 

loss of habitats or populations. This alterative would result in moderate positive effects on special status species. 

4.10.2.8 Impacts from Management of Lands with 

Wilderness Characteristics

Alternatives A, B, and D would not manage lands within 

the NCA to maintain wilderness characteristics. This 

management decision would not measurably or negatively impact special status species or their habitats, as 

all alternatives propose management actions that would 

conserve, protect, and restore NCA ecosystems and the 

species that rely upon them.

Under Alternative C, management of 16,721 acres to 

maintain wilderness characteristics could help conserve 

and protect habitats for special status species. These acres 

would be managed as a ROW Exclusion area and under 

VRM Class I designation. Motorized vehicle travel would 

be Limited to Designated Roads and Trails and no commercial and non-commercial woodland product harvesting, native seed or plant material collection would be 

permitted. Maintaining wilderness characteristics would 

minimize human intrusions and protect habitats, providing a slightly more beneficial effect on special status 

species when compared to the other alternatives.

4.10.2.9 Impacts from Management of Recreation and 

Visitor Services

Alternative A would carry forward the SGFO ERMA 

which emphasizes dispersed recreation activities with 

few management controls or developed facilities. Current 

management would continue to allow dispersed camping 

within 50 feet of roads, which can damage habitats, increase soil erosion, introduce or spread weed infestations, 

and increase the risk of wildfires. Removal of dead and 

down wood for campfires would prevent decayed wood 

matter from returning to soils and providing nutrients 

back into the ecosystem.

Authorizing noncommercial groups of up to 75 persons 

to camp in open areas would continue to damage 

habitats, as described above. Large groups could cause 

special status species to abandon habitats, moving 

from high-quality habitat to areas of lower quality, less 

desirable habitat.

Alternatives B, C, and D would establish the Beaver Dam 

Wash SRMA and intensive management decisions related 

to recreation uses. Visitor amenities and facilities would 

be developed to improve visitor experiences and protect resource values. Under the three action alternatives, 

a professionally-designed, non-motorized trail system 

would be developed in the NCA to provide high-quality 

experiences for diverse users, with trailheads and waysides 

that provide maps and interpretive information about the 

NCA purposes and values. This system would be expected 

to minimize the number of new social trails that are 

developed in the short and long term, as users would be 

more likely and able to use the designated trail system. If 

social trails and trail braiding does not occur, the potential 

for new weed infestations related to dispersed recreational 

uses would be reduced under these alternatives.

The three action alternatives would provide higher levels 

of protection for soils, water, and native vegetation, 

potentially benefitting special status species by protecting 

habitats. Each of these alternatives would limit dispersed 

camping to designated, undeveloped campsites located 

in previously disturbed areas, away from surface water 

sources protecting aquatic habitats.

Alternative A identifies no restrictions or prohibitions on 

certain types of recreational activities, such as paintball 

activities, recreational target shooting, and recreational 

prospecting with mechanized equipment, which can 

be environmentally damaging or pose threats to special status species. The Mojave desert tortoise or other 

species could continue to be accidentally or deliberately 

injured or killed by recreational target shooting, critical 

habitats damaged by target trash, and wildfires started 

by exploding targets. The Desert tortoise (Mojave population) Recovery Plan (Recovery Plan) (1994) specifically 

recommended prohibiting recreational target shooting in 

tortoise habitat, as this activity has been shown to impact 

tortoise populations and damage habitat throughout 

the range of the species. The Biological Opinion issued 

by the USFWS in 1998, through the Section 7 consultation on the Proposed SGFO RMP, included a Term and 

Condition that mandated BLM not to authorize the 

discharge of firearms, except in the act of licensed hunting in tortoise habitats for the reasons listed above. This 

mandate was not implemented on public lands in the 

NCA through management decisions in the approved 
662 Chapter 4 BDWNCA BDWNCA Chapter 4 663

SPECIAL STATUS SPECIES SPECIAL STATUS SPECIES

toward achieving land health but would differ in the time 

and methods used to reach that goal.

4.10.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on special 

status species would include habitats for the Mojave 

desert tortoise and other at-risk Mojave Desert species 

on the Beaver Dam Slope, within Utah, Arizona, and 

Nevada. It does not encompass the entire Northeastern 

Mojave Recovery Unit, but rather the Utah-Arizona subunit, including habitat east of the Mormon Mountains 

in Lincoln County and north of Lime Kiln Canyon in 

Mohave County.

The CIAA for Virgin River fishes, southwest willow 

flycatcher and western yellow-billed cuckoo includes 

Beaver Dam Wash to its confluence with the Virgin 

River, near Beaver Dam, Arizona.

Past human-caused actions within the CIAA, both on 

federal and non-federal lands, that have affected special 

status species populations and habitats included overgrazing of rangelands during the late 19th and early 

20th centuries; the construction of highway and roads; 

utility developments; environmental contamination by 

down-wind radioactive “fallout” from repeated aboveground nuclear tests conducted on the Nevada Test Site 

in south-central Nevada during the 1950s and 60s; water 

developments and diversions; range improvements and 

vegetation treatments; and motorized and non-motorized recreational uses. In general, past human activities 

and land uses have cumulatively resulted in the loss, 

degradation, and fragmentation of habitats and population declines that prompted the listing of species under 

the protection of the ESA or their inclusion on BLM 

Sensitive Species lists. 

Prolonged droughts, the introduction and spread of 

noxious weeds and invasive species, and wildfires are 

natural factors that have also cumulatively impacted special status species. Many of these natural factors created 

conditions that caused or favored habitat changes. For 

example, wildfires removed vegetative cover and damaged soil crusts, leaving soils more susceptible to wind 

and water erosion and weed invasion. The “burn-reburn” 

fire cycle in areas of the CIAA has converted late successional shrubland communities into invasive brome grasslands that provide poor quality habitat for Mojave Desert 

species. Drought conditions have reduced the health of 

native vegetation communities, making them more prone 

to insect infestations or disease. 

Present and reasonably foreseeable future actions would 

include regional population growth, the expansion of 

nearby communities, like Beaver Dam and Littlefield, 

Arizona; the construction of new utilities in the IPP and 

Navajo-McCullough designated utility corridors that are 

adjacent, but not within the NCA; hazard fuel reduction projects, noxious weed and exotic invasive species 

control, and increasing recreational uses of public lands. 

Livestock grazing is expected to continue on some federal and non-federal lands in the CIAA. 

Future actions or factors anticipated to benefit Mojave 

desert tortoise populations and its critical habitat in the 

CIAA could include implementation of actions recommended in the 2014 Northeast Mojave Recovery Unit 

Implementation Plan for the Mojave desert tortoise, developed by the Utah/Arizona Recovery Implementation 

Team, an advisory group established by the USFWS, 

under the auspices of the Revised recovery plan for the 

Mojave population of the desert tortoise (2011). While 

specifically directed toward assisting the recovery and 

de-listing of the threatened Mojave desert tortoise, these 

actions would cumulatively benefit all special status species in the NCA.

Actions are likely to include increased efforts to control 

invasive annual brome grasses and wildfires through 

landscape-wide fire breaks and fuel treatments in the 

CIAA. As ongoing research studies identify more effective and environmentally sustainable broad-scale treatment methods, it is likely that larger areas will be treated 

and efforts made to restore native vegetation communities and special status species’ habitats. Land uses, including livestock grazing, that have the potential to impact 

habitat restoration projects, would not be authorized 

in those areas until resource objectives are met. Future 

listings of other native species under the ESA could also 

impose restrictions on livestock grazing and other land 

uses determined to be detrimental to the protection and 

recovery of desert tortoises. 

Climate change within the CIAA could cause an increase 

or decrease in seasonal temperatures and precipitation, 

which would affect soil conditions, vegetation distribution, and surface water resources. Such changes would 

place special status species at greater risk of extinction, 

particularly those species that cannot adapt to changed 

conditions or migrate to areas where habitat conditions 

are favorable.

scale developments. Both alternatives would restrict new 

ROWs to subsurface installations only, avoiding impacts 

to avian species that could occur with above-ground 

power transmission lines. Impacts to desert tortoise and 

other special status species populations and habitats 

would be avoided or minimized to the extent possible 

through project design, BMPs, and stipulations developed through Section 7 consultations and project-specific 

Biological Opinions. Adverse modification of designated 

critical habitat would be mitigated through compensation 

or habitat acquisition.

Alternative C would revoke the designated utility and 

transportation corridor along Old Highway 91 through 

the NCA, eliminating impacts on special status species 

and habitats related to the development of new utilities in 

that corridor. Existing ROWs within that corridor would 

continue to be recognized as valid, allowing maintenance 

of an existing fiber-optic line or erosion control structures along the highway. These activities could result in 

small-scale, localized surface disturbances that could 

cause negligible to minor adverse modification of tortoise 

critical habitat. Such impacts would be minimized to 

the extent possible through project design, BMPs, and 

stipulations developed through Section 7 consultations 

and project-specific Biological Opinions. Adverse modification of designated critical habitat would be mitigated 

through compensation or habitat acquisition.

4.10.2.12 Impacts from Management of Public 

Education and Interpretation

Alternatives B, C, and D propose actions that would educate the public about native species of the NCA with an 

emphasis on those at-risk species that are federally-listed 

under the ESA or managed as BLM Sensitive Species. 

Education outreach would be accomplished through 

on and off-site interpretation, public land etiquette 

messaging, through multiple media and venues, and 

through volunteer participation in resource protection 

and enhancement projects. The effects of public education should be beneficial for special status species and 

other resource values of the NCA, potentially reducing 

human-caused impacts on species and habitats because 

of increased awareness and appreciation.

4.10.2.13 Impacts from Management of Scientific 

Research 

Alternatives B, C, and D would pursue opportunities for 

research on natural, wildlife, riparian, and water resources, which could directly and indirectly improve management of special status species’ habitats by improving 

the scientific understanding of ecological processes and 

natural systems. Under the three action alternatives, 

Mojave Desert fire ecology and re-vegetation could be 

studied under NCA Science Research Permits, potentially yielding findings that help to conserve and protect 

special status species populations and habitats from the 

effects of fires, invasive species proliferation, and improve 

the success of re-vegetation projects.

4.10.3 Summary of Impacts from Alternatives

Under Alternative A, special status species populations 

and habitats would continue to be managed in compliance with laws, regulations, and agency policies, and in 

furtherance of the goals of approved USFWS recovery 

plans. Habitat degradation and loss to wildfires and 

drought would continue, as this alternative does not 

emphasize full suppression of all wildfires and the development of large scale fuel breaks. Surface disturbances 

related to wildfires, livestock grazing at current levels in 

burned and unburned habitats and riparian areas, unmanaged dispersed camping, and other recreational activities would continue to degrade, fragment, or destroy 

habitats for some special status species. 

Management of the NCA to “conserve, protect, and 

enhance” a broad range of resource values under 

Alternatives B, C, and D would benefit special status species and their habitats. Changes are proposed for those 

land uses, such as livestock grazing, recreation, and the 

granting of ROWs to minimize negative impacts on the 

ecological values that comprise quality habitats for special status species: native vegetation communities, soils, 

and water resources. The management of wildfires and 

hazardous fuels under the three action alternatives would 

be more comprehensive and effective, when compared to 

Alternative A, helping to lessen the threat that wildfires 

will continue to pose on special status species and their 

habitats in the NCA and throughout the Mojave Desert.

Under Alternative C, the BLM would focus on resource 

protection by limiting land uses and authorized activities 

that have the potential to negatively impact special status 

species and their habitats. Management would employ 

the least invasive tools and methods and emphasize the 

use of native vegetation to restore and improve habitats.

Under Alternatives B, C, and D, impacts on special 

status species would be minimized to the extent practical and feasible through restrictions on uses and activities. Habitat conditions would be improved through 

treatments, weed prevention and control, and habitat 

improvements. In general, all alternatives would work 
664 Chapter 4 BDWNCA BDWNCA Chapter 4 665

OTHER FISH AND WILDLIFE SPECIES OTHER FISH AND WILDLIFE SPECIES

Alternatives B, C, and D would provide for implementation-level restoration plans, use of microsite/fertile 

islands, carbon sequestration, use of supplemental water 

sources and inoculation of cryptogamic soil crust with 

mycorrhizae would have a beneficial effect on efforts 

to re-vegetate disturbed and fire-damaged lands. Such 

actions would reduce the competitiveness of non-native 

annual grasses and potentially re-establish native bunchgrasses and broad-leaved forbs that were formerly important components of native vegetation communities in the 

NCA. These actions would help to restore quality habitats 

for all fish and wildlife species, providing adequate forage, cover, and breeding/nesting areas.

Alternatives B and D would allow use of non-native 

species, but only under very specific conditions and with 

constraints that would prevent the introduction of species that have not been scientifically evaluated for use in 

the Mojave Desert. The use of non-native species could 

help stabilize soils and prevent erosion in the short term, 

and, in the long term, could assist the re-establishment 

of native species. However, there is a risk that the nonnative species could perpetuate and spread, altering 

native ecosystems and reducing the quality of biophysical 

settings for all wildlife. 

Alternative C would not allow the use of non-native species for re-vegetation projects and require the use of local 

native seeds and plant materials. Seed mixes would be 

tailored for ES&R projects to include more early successional species, include methods of protecting seeds from 

herbivory, and use hand or low impact methods of working seeds into the soil. This alternative could increase 

the chances of successful germination of seeds and the 

re-vegetation of native communities, when compared 

to other alternatives because it would minimize damage 

to biological soil crusts that sustain soil productivity. If 

local native seeds and plant materials were not available, 

re-vegetation projects could not be undertaken, potentially allowing exotic invasive annuals to proliferate and 

prevent native species from re-establishing in the short 

and long term.

Under Alternatives B, C, and D, land uses, including recreational uses and livestock grazing, that have the potential to impede the success of re-vegetation projects would 

be excluded from the project areas until project resource 

goals and objectives have been met. This would be a beneficial effect, furthering the likelihood that native vegetation communities could be restored in the long-term.

Managing riparian areas to meet the Utah Standards 

of Rangeland Health, applying appropriate wildfire 

suppression strategies, use of post-fire ES&R actions and 

application of BMPs would protect riparian resources 

and prevent future damage. Monitoring of riparian areas 

and vegetation should help identify problems and lead to 

adaptive strategies that would help maintain these areas 

in satisfactory conditions.

Wildland fires and fire suppression tactics that create 

new surface disturbances would increase the likelihood 

for weed introductions or spread by disturbing soil, damaging soil crusts, and removing vegetation. The increase 

in soil nutrients following fire and the use of retardants 

during suppression would favor spread and proliferation 

of invasive annual brome grasses. In desert shrubland 

communities, catastrophic fires and multiple fires can 

convert these fire-intolerant areas to invasive grasslands. 

Alternative A still includes a small role for the potential 

use of prescribed fire to achieve management objectives. 

Prescriptive fires would have a negative impact on fish 

and wildlife habitats, resulting in increased acreage of 

fire-damaged habitat and possible injuries and mortalities of individuals. Burned areas would provide less thermal cover and significantly reduced forage for terrestrial 

species. Soil erosion would be higher on fire-damaged 

areas and could increase sedimentation to the Beaver 

Dam Wash, potentially affecting the quality of aquatic 

and riparian habitats that benefit many species of native 

fish and wildlife.

Under Alternatives B, C, and D, full suppression tactics 

would be employed to minimize fire size and duration 

would be employed, benefitting all wildlife, including 

those that occupy aquatic and riparian habitats. Wildfire 

use to achieve management objectives would not be authorized under any of these alternatives. The use of backburning would be carefully evaluated as a fire suppression tactic, to minimize the loss of unburned habitats and 

direct impacts, such as fire-caused injuries or mortalities 

on wildlife species. 

Alternative A would continue to authorize many tools 

for hazardous fuels reduction, including the use of large 

scale prescribed fires in the NCA. As the Mojave Desert 

native vegetation communities are not fire-adapted species, this management tool could negatively impact the 

remaining unburned areas where blackbrush and Joshua 

trees are dominant, destroy biological soil crusts, and 

facilitate the spread of noxious weeds and exotic annual 

brome grasses.

Alternatives B, C, and D, emphasize the development 

of fuel breaks and reduction of hazardous fuels that 

4.11 OTHER FISH AND WILDLIFE SPECIES

This section discusses impacts on those fish and wildlife 

species from proposed management actions for other 

resources and resource uses described in Chapter 2. 

Existing conditions of fish and wildlife and descriptions 

of habitat requirements for various species are described 

in Chapter 3.

4.11.1 Methods of Analysis

Adverse impacts to fish and wildlife populations could 

result from management actions that diminish any of the 

fundamental components of their habitats listed in the indicators section below. Beneficial effects could result from 

management actions that maintain or improve fish and 

wildlife habitats and help to sustain healthy populations.

4.11.1.1 Indicators

Indicators of adverse impacts on fish or wildlife habitats 

and populations include the following:

▶ Likelihood of habitat degradation or removal 

through changes to the vegetation communities, 

water resources, and other habitat components;

▶ Likelihood of habitat avoidance due to human presence or habitat alteration;

▶ Likelihood of interferences with species’ movement 

patterns that decreases the ability of a species to 

breed or overwinter successfully to a degree that 

would lead to substantial population declines;

▶ Likelihood of impacts on survival or reproduction 

species caused by disruptive activities;

▶ Likelihood of injuries or mortalities in populations 

as a direct result of management actions.

4.11.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA;

▶ Healthy and sustainable wildlife populations can 

be supported where there is a diverse mix of plant 

communities to supply structure, forage, cover, and 

other specific habitat requirements;

▶ Habitat conditions and quality are directly linked to 

the health, vigor, and cover of vegetation communities, particularly desired native plant communities 

for fish and wildlife species;

▶ Impacts on terrestrial wildlife from displacement 

depend on the location, extent, timing, or intensity 

of the disruptive activity. Impacts would be greater 

for wildlife species that have limited habitat or a low 

tolerance for disturbance/disruption;

▶ Habitat would be managed in coordination with 

UDWR, to further herd management objectives and 

species-specific management plans.

Implementing management actions for the following 

resources would have negligible or no impact on fish 

and wildlife habitats and are, therefore, not discussed 

in detail: Air Quality, Water Resources, Geologic and 

Paleontological Resources, Cave and Karst Resources, Soil 

Resources, Vegetation Resource Uses: Plant Materials, 

Special Status Species, Heritage Resources, National 

Historic Trails, National Natural Landmarks, ACECs, 

Visual Resource Management, Natural Soundscapes, 

Lands with Wilderness Characteristics, Public Education 

and Interpretation, and Scientific Research.

4.11.2 Direct and Indirect Impacts

4.11.2.1 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Under all alternatives, the goals and objectives for the 

management of native vegetation communities are to 

conserve and protect areas from the negative impacts 

of wildfires and to restore damaged communities with 

desired species. Management actions address the need to 

minimize the loss of unburned and once-burned native 

vegetation, to maintain ecosystem and watershed functions, protect soils, and provide quality habitats for the 

fish and wildlife species of the NCA.

Under all alternatives, ensuring that ecological systems 

meet or exceed management objectives in the Utah 

Standards for Rangeland Health and Guidelines for 

Grazing Management could protect, maintain, or enhance 

native vegetation, biophysical settings, and ecosystems.

All alternatives provide for the use of native plant species for restoration and rehabilitation. Use of native 

species would maintain the health and vitality of native 

vegetation communities and could provide seed sources 

for restoration uses. 

Alternative A requires preparation of site specific plans to 

identify desired plant communities, establishing specific 

management objectives, and recommending practices to 

be employed to achieve desired results. This alternative 

would authorize the use of non-native species, if natives were unavailable or deemed to be too expensive for 

use. Non-native species that have not been scientifically 

evaluated relating to the benefits or impacts of their use 

in the Mojave Desert could continue to be introduced in 

the NCA, with uncertain long-term outcomes.
666 Chapter 4 BDWNCA BDWNCA Chapter 4 667

OTHER FISH AND WILDLIFE SPECIES OTHER FISH AND WILDLIFE SPECIES

1,861 AUMs, reduce utilization on key species to 40%, 

and make no changes to the current grazing season of 

use. This alternative would potentially lessen the dietary 

competition between cattle and some wildlife species and 

the damage or loss of vegetative cover and forage, based 

on a reduction in livestock numbers, when compared to 

Alternatives A and D. These changes could improve quality and quantity of habitat for many wildlife species.

Under Alternatives A, B, and D, the continuation of livestock grazing would confer a minor to moderate benefit 

to some terrestrial and avian wildlife species, as the water 

troughs and catchments that support livestock grazing also provide artificial water sources for wildlife. The 

livestock operators on the four allotments hold perfected 

water rights on various natural spring sources and wells, 

inside and outside of the NCA and make beneficial use of 

the water for their livestock; these sources are also generally accessible by wildlife. The continuation of livestock 

grazing would help to ensure that these artificial water 

sources remain available to wildlife over the life of 

the RMP. 

Under these alternatives, the older pasture and boundary fences associated with grazing management could 

continue to restrict movement for larger wildlife species, 

such as desert bighorn sheep and mule deer, and contribute to habitat fragmentation. These impacts on wildlife 

movement would be lessened in the future, as new replacement fencing would be required to meet BLM specifications that allow for safe passage by wildlife. Under 

Alternative B, new range developments would only be 

authorized if they further the conservation purposes for 

diverse resource values in the NCA. This requirement 

would help to ensure that authorized developments also 

benefit wildlife by minimizing impacts on populations 

and habitats. 

Under Alternatives A, B, and D, continued livestock grazing could also provide an, as yet, unquantified or verified hazardous fuel reduction benefit, as cattle consume 

some of the annual biomass of the invasive brome grasses 

that fuel and carry wildland fires that damage or destroy 

wildlife habitats. 

Alternative C would make public lands in these allotments within the NCA unavailable for livestock grazing, 

benefitting wildlife by eliminating dietary competition, 

as well as damage to or loss of vegetative cover and forage 

on approximately 61,995 acres of public land. Over the 

long term, removing livestock would improve habitats for 

wildlife as native vegetation, including perennial grasses, 

shrubs, and succulents, would not be selectively grazed 

by large, non-native herbivores. 

Implementation of this alternative could negatively impact some terrestrial and avian species, as water troughs 

and catchments on the allotments that provide artificial 

water sources for wildlife might no longer be available. 

However, water rights could be acquired by BLM or others (e.g. UDWR) from willing sellers and a filing made 

with the State Engineer to change the beneficial use from 

livestock to wildlife. Similarly, BLM holds perfected 

water rights in the NCA and filings could be made with 

the State Engineer to change the beneficial use of those 

water rights from livestock to wildlife. This change would 

continue to make water available for wildlife under 

Alternative C. 

Under this alternative, range improvements and fences 

would be evaluated for removal. The removal of existing 

fencing would enhance the safe passage of mule deer, 

smaller game, and other wildlife species through the 

NCA, increasing habitat connectivity, and lessening the 

habitat fragmentation created by pasture and allotment 

boundary fencing. Overall, the beneficial effect from the 

cessation of livestock grazing in the NCA on many wildlife species would be expected to be moderate to major, 

in the short and long term. 

Alternative C would result in the removal of all livestock 

over the life of the RMP, reducing the amount of invasive 

annual brome grasses that are consumed by cattle during 

the grazing season. This could increase the number and 

severity of wildfires that are fueled by invasive species, 

potentially damaging or destroying additional acres of 

native vegetation that provide habitats for terrestrial 

and avian species, in the short term. Over the life of the 

RMP, however, hazardous fuel treatments and native 

vegetation restoration projects would reduce the abundance and distribution of the invasive brome grasses, 

lessening the potential threats to wildlife habitats from 

catastrophic wildfires.

Under Alternatives A, B, and D, livestock grazing in 

riparian areas could continue to cause soil compaction, 

erosion, sedimentation, and the influx of nutrients into 

riparian areas along the ephemeral drainages and in 

Beaver Dam Wash within the NCA. The impacts associated with grazing would continue to degrade aquatic 

habitats in Beaver Dam Wash that support native fish 

populations and riparian vegetation that provides habitat 

for many terrestrial and avian species. Alternative B 

would result in fewer impacts, as the initial allocation 

of AUMs would reduce livestock numbers by 40%. The 

threaten native desert vegetation communities in the 

NCA. None of these alternatives would authorize 

the use of prescribed fires as a management tool for 

hazardous fuel reduction. This would prevent fire-caused 

impacts on late successional desert shrublands and the 

introduction or spread of noxious weeds and exotic 

annual brome grasses.

Alternatives B and D would authorize the broadest array 

of tools and methods for these projects, including the 

use of mechanical methods and targeted livestock grazing. Mechanical methods could damage soil crusts and 

create new surface disturbances that would be susceptible to the establishment of noxious weeds and invasive species. The use of targeted grazing animals would 

increase the potential that noxious weeds and invasive 

species could be introduced or spread, through hoof action and manure. 

Alternative C would limit the methods that could be used 

for fuel breaks and hazard fuel treatments to those that 

are the least impacting to soil crusts and that minimize 

new surface disturbances. Targeted grazing would not be 

among the methods that could be employed.

Noxious weeds and exotic invasives would less likely be 

introduced or spread under this alternative.

The three action alternatives would provide higher levels 

of protection for fish and wildlife species and their habitats, by minimizing surface disturbances and fire effects, 

when compared to Alternative A.

4.11.2.2 Impacts from Management of Noxious Weeds 

and Invasive Species 

Noxious weeds and invasive species alter the ecological characteristics of native vegetation communities 

and the quality of wildlife habitats. Under all alternatives, weed control would continue to be implemented, 

using an Integrated Weed Management approach and 

relevant standard operating procedures and mitigation 

measures presented in the Final Vegetation Treatments 

Using Herbicides on BLM Lands in 17 Western States 

Programmatic Environmental Impact Statement (PEIS)

(BLM 2007). With proper implementation, weed treatment methods under all alternatives would eliminate or 

reduce infestations in the long term. 

Alternatives B, C, and D identify a variable range of tools 

to control noxious weeds and invasive species, including 

the potential use of biological controls, under projectspecific plans. Biological controls for invasive annual 

brome grasses are currently in the experimental stage 

and may never be applicable on a broad scale, even over 

the life of the RMP. 

Alternatives A, B, and D would also allow chemical 

control of noxious weeds and invasive species in unburned vegetation communities. These could damage 

desired vegetation due to over-spray, improper herbicide 

selection or dosage, or improper timing of application. 

Alternatively, proper chemical control could reduce infestations, while preventing impacts on native species, if 

the chemicals are selected and used correctly.

Alternatives B and D would authorize the use of targeted 

grazing to control noxious weed and exotic invasive 

species and create fuel breaks in selected areas. Adverse 

impacts could include trampling and denuding of native vegetation, the introduction and spread of noxious 

weeds and invasive species, soil compaction or accelerated erosion from hoof action. Positive effects from the 

use of targeted grazing could include the cost-effective 

reduction of noxious weeds and invasive species, as well 

as creating fire breaks that would help to conserve and 

protect native vegetation communities. 

Targeted grazing using domestic sheep and goats would 

only be conducted where effective separation distances 

could be maintained from desert bighorn sheep herds 

in the Beaver Dam Mountains, preventing the spread of 

infections and parasites to the wild sheep. All domestic 

sheep or goats contracted for targeted grazing projects 

would be contained within the specified project area 

through temporary fencing, and removed from the NCA 

after project completion.

4.11.2.3 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing

Alternatives A and D would continue to make 61,995 

acres within Beaver Dam Slope, Castle Cliffs, Cedar 

Pocket, and Scarecrow Peak Allotments available for 

grazing, with an initial allocation of 3,099 AUMs for 

livestock forage and a fall to early spring grazing season 

of use. These alternatives would continue dietary competition between cattle and some wildlife species; damage 

or loss of vegetative cover and forage for some wildlife 

species could result from grazing and livestock trailing. 

Alternative D would reduce the utilization level on key 

species to 45% (from 50% to 65% depending on allotment), providing a minor benefit to wildlife by lessening 

the impacts of grazing on those species. 

Alternative B would also continue to make 61,995 acres 

within the four allotments available for grazing, but 

would reduce the initial allocation of livestock forage to 
668 Chapter 4 BDWNCA BDWNCA Chapter 4 669

OTHER FISH AND WILDLIFE SPECIES OTHER FISH AND WILDLIFE SPECIES

and Closed to motorized vehicle travel and uses through 

the RMP. Alternatives that close more acres to motorized 

travel would be expected to reduce the potential for vehicles to kill or injure wildlife. Area closures and limiting 

vehicle travel to existing or designated roads and trails 

also adds protection to soils and vegetation from surface 

disturbances related to unauthorized cross-county travel 

and route proliferation. Intact soil horizons, soil crusts, 

and vegetation communities would maintain the quality 

of habitats critical for diverse wildlife species.

All alternatives propose to designate the NCA as Limited 

to Designated Roads and Trails, with specific route 

designations (outside of the Congressionally-identified 

Designated Road Areas) to follow through BLM’s development of a TMP for Washington County. The benefits 

to wildlife species would be the same across all alternatives, protecting soils and vegetation from surface disturbances related to unauthorized cross-county travel and 

route proliferation and helping to maintain or improve 

the quality of wildlife habitats.

4.11.2.7 Impacts from Management of Lands and 

Realty

Under all alternatives, acquisitions of non-federal inholdings within the NCA from willing owners would be beneficial for native fish and wildlife. Acquired lands would 

be managed consistent with the Congressionally-defined 

purposes for the NCA and the goals, objectives, and 

management decisions from the approved NCA RMP; 

these decisions emphasize the conservation and protection of wildlife populations and their habitats.

Under Alternative A, the NCA would be managed as a 

ROW Avoidance area, with the exception of the 196 acre 

designated corridor along Old Highway 91. New ROWs 

could be granted for the development of power lines, 

pipelines, or other utilities in that designated corridor. 

Impacts to soils and native vegetation would be avoided 

to the extent possible through project design and BMPs. 

Impacts to avian species related to power lines would 

also be mitigated through project design. The potential 

for impacts on wildlife species and habitats would be 

negligible to minor under this alternative.

Under Alternatives B and D, the NCA would be managed 

as a ROW Exclusion area, with the designated corridor 

along Old Highway 91 retained, but with variable widths 

by alternative (100 feet and 250 feet in total width, respectively). The narrow corridor widths proposed under 

either alternative would generally preclude large scale developments. Both alternatives would restrict new ROWs 

to subsurface installations only, avoiding impacts to 

avian species that could occur with above-ground power 

transmission lines. Under these alternatives, the potential 

impacts on wildlife species and their habitats would be 

less than under Alternative A and mitigated to the extent 

possible through project design and the implementation 

of BMPs. 

Alternative C would also manage the NCA as a ROW 

Exclusion area and revoke the designated utility and 

transportation corridor along Old Highway 91 through 

the NCA, eliminating impacts on wildlife and habitats 

that could result from the development of new utilities in 

that corridor. Existing ROWs within that corridor would 

continue to be recognized as valid existing rights, allowing maintenance of an existing fiber-optic line or erosion 

control structures along the highway. These activities 

could result in small-scale, localized surface disturbances 

of soils and native vegetation. This alternative would more 

effectively protect wildlife species and habitats, minimizing the potential for new developments in the NCA.

4.11.3 Summary of Impacts from Alternatives

Under Alternative A, native fish and wildlife populations and their habitats would continue to be managed in 

compliance with laws, regulations, and agency policies, 

and in furtherance of relevant UDWR management plans. 

Habitat degradation and loss to wildfires would continue, 

as this alternative does not emphasize full suppression of 

all wildfires and the development of large scale fuel breaks. 

Surface disturbances related to wildfires, livestock grazing at current levels in burned and unburned habitats and 

riparian areas, unmanaged dispersed camping, and other 

recreational activities would continue to degrade, fragment, or destroy habitats for some wildlife species. 

Management of the NCA to “conserve, protect, and enhance” a broad range of resource values under Alternatives 

B, C, and D would benefit native fish and wildlife. Changes 

are proposed for those land uses, such as livestock grazing, 

recreation, and the granting of ROWs, to minimize negative impacts on the ecological values that comprise quality 

habitats for native species: native vegetation communities, 

soils, and water resources. The management of wildfires 

and hazardous fuels under the three action alternatives 

would be more comprehensive and effective, when compared to Alternative A, helping to lessen the threat that 

wildfires will continue to damage or destroy habitats and 

impact wildlife populations in the NCA.

Under Alternative C, the BLM would focus on resource 

protection by limiting land uses and authorized activities 

impacts on aquatic and riparian wildlife habitats related 

to continued livestock grazing would be moderate, in the 

short and long term.

Alternative C would make the NCA unavailable to livestock grazing, removing livestock from aquatic habitats 

and riparian areas in ephemeral drainages and Beaver 

Dam Wash. This would improve surface water quality 

and eliminate impacts on riparian vegetation, benefitting 

native fish and wildlife that depend on these habitats.

4.11.2.4 Impacts from Management of Other Fish and 

Wildlife Species

Under all alternatives, new wildlife guzzlers or collection 

catchments could be developed, in collaboration with 

UDWR. These could provide a beneficial effect of diverse 

game and non-game species by providing additional water 

sources. All alternatives would allow for the re-introduction, translocation and transplantation of priority native 

wildlife, which could fill key niches to balance native ecosystems and would provide a beneficial effect on fish and 

wildlife habitat. New fencing projects would be required to 

meet specific design standards that allow safe passage by 

big game and other wildlife under all alternatives.

4.11.2.5 Impacts from Management of Recreation and 

Visitor Services

Alternative A would carry forward the SGFO ERMA 

which emphasizes dispersed recreation activities with 

few management controls or developed facilities. Current 

management would continue to allow dispersed camping within 50 feet of roads that can damage habitats, 

soil erosion, introduce or spread weed infestations, and 

increased risk of wildfires. Removal of dead and down 

wood for campfires would prevent decayed wood matter 

from returning to soils and providing nutrients back into 

the ecosystem.

Authorizing noncommercial groups of up to 75 persons to 

camp in open areas would continue to damage habitats, as 

described above. Large groups could cause some wildlife 

species to abandon habitat, moving from high-quality 

habitat to areas of lower quality, less desirable habitat.

Alternatives B, C, and D would establish the Beaver Dam 

Wash SRMA and intensive management decisions related 

to recreation uses. Visitor amenities and facilities would 

be developed to improve visitor experiences and protect 

resource values. Under the three action alternatives, a 

professionally-designed non-motorized trail system would 

be developed in the NCA to provide high-quality experiences for diverse users, with trailheads and waysides that 

provide maps and interpretive information about the NCA 

purposes and values. This system would be expected to 

minimize the number of new social trails that are developed in the short and long term, as users would be more 

likely and able to use the designated trail system. If social 

trails and trail braiding does not occur, the potential for 

new weed infestations related to dispersed recreational 

uses would be reduced under these alternatives.

Under Alternatives B, C, and D, restrictions could be 

placed on climbing or rappelling recreational activities in 

the NCA, during lambing and breeding seasons for desert bighorn sheep. Such restrictions could improve the 

reproductive success of the herds and increase bighorn 

sheep herd numbers to meet UDWR objectives.

Under Alternative A, recreational target shooting would 

continue to be authorized in the NCA, with no restrictions. Alternative D would also continue to authorize this 

recreational use, but require that specific target types be 

used and that all shooting litter, including lead bullets, 

removed. When compared to Alternative A, this would 

help to protect habitat quality for all fish and wildlife, but 

provide little protection to any species from injuries or 

mortalities that might result from recreational 

target shooting.

Alternative B would prohibit recreational target shooting on 50,908 acres of the NCA, providing a substantially higher level of protection of habitats and wildlife 

species from impacts related to this activity compared 

to Alternatives A and D. Alternative C would prohibit 

recreational target shooting in the NCA, eliminating the 

threats of injuries or death for all species and preventing 

the degradation of habitats that result from target littering and soil or surface water contamination from the 

leaching of lead bullets.

4.11.2.6 Impacts from Management of Comprehensive 

Travel and Transportation

The nature and type of impacts on native fish and wildlife 

population and habitats from transportation and travel 

management could include habitat avoidance, interference of movement, and increased likelihood of injury/

mortality due to presence of human activities along 

routes. Surface disturbances, habitat fragmentation and 

loss could also result from motorized and non-motorized 

vehicle travel. These impacts are most directly related to 

the density and location of route networks that are designated on public lands through the TMP process.

The impacts or benefits on wildlife and habitats related to 

OHV area designations can be estimated by comparing 

the number of acres that are designated as Open, Limited 
670 Chapter 4 BDWNCA BDWNCA Chapter 4 671

HERITAGE RESOURCES HERITAGE RESOURCES

This section analyzes the effects on heritage resources 

that could result from the proposed management actions 

for other resources and land uses presented in the four 

alternatives described in Chapter 2. Current management and information on heritage resources that have 

been identified in the NCA are described in Chapter 3 at 

Section 3.13 Heritage Resources.

4.12.1 Methods of Analysis

Baseline data on heritage resources in the NCA was 

derived from literature reviews, Class II and III level field 

investigations, and consultations with Native Americans 

and other knowledgeable parties. These data are geographically biased toward past project-specific undertakings and may not accurately predict where and how 

many resources may exist in areas of the NCA where 

similar efforts to identify heritage resources have not 

yet been conducted. Given the incompleteness of the 

baseline data, this analysis generally does not attempt to 

precisely quantify affected resources.

The resulting analysis was based on an understanding 

of how land uses and authorized activities may affect 

heritage resources. Federal laws implementing regulations and other pertinent guidance (e.g., Secretary of the 

Interior Standards and Guidelines) relating to the determination of effects on heritage resources were considered 

and included in criteria for determining impacts.

4.12.1.1 Indicators

Indicators of adverse effects on heritage resources include 

the following:

▶ Extent to which surface-disturbing activities adversely affect the integrity of heritage resources, or 

areas of importance to Native American or other 

traditional communities;

▶ Extent to which an action increases the potential for 

erosion or other natural processes to degrade the 

integrity of heritage resources over time;

▶ Extent to which an action reduces the availability 

of heritage resources for appropriate uses, including access to sacred sites or Traditional Cultural 

Properties by Native Americans.

Indicators of actions that generally benefit the conservation and protection of heritage resources:

▶ Measures that restrict or limit land uses and authorized activities that have the potential to adversely 

affect the NRHP-eligibility characteristics of historic 

properties;

▶ Measures that preserve or improve the setting of 

a heritage resource, where setting contributes to 

the NRHP-eligibility characteristics of a historic 

property.

4.12.1.2 Assumptions

This analysis includes the following assumptions:

▶ Management actions proposed are designed to conserve, protect, and enhance resources in the NCA;

▶ Undertakings are defined as federal or federally-assisted actions and those requiring a federal permit, 

license, or approval.

▶ Federal regulations at 36 CFR 800, Section 106 of 

the NHPA, and the Utah Programmatic Agreement 

will be applied for all undertakings; and adverse 

effects on heritage resources would be avoided 

or appropriately mitigated. Impacts on heritage 

resources are assessed by applying the criteria of 

“adverse effect”, as defined in 36 CFR Part 800.5a: 

“An adverse effect is found when an action may 

alter the characteristics of a historic property that 

qualify it for inclusion in the NRHP in a manner 

that would diminish the integrity of the property’s 

location, design, setting, workmanship, feeling, or 

association. Adverse effects may include reasonably 

foreseeable effects caused by the action that may 

occur later in time, be farther removed in distance, 

or be cumulative.”

▶ Native Americans or other traditional communities 

may have concerns about potential impacts on heritage resources, sacred sites, or Traditional Cultural 

Properties. There may be areas of importance to 

contemporary Native Americans that are not readily 

identifiable outside of those communities. These 

concerns would be identified and resolved through 

appropriate levels of consultation required by law, 

regulations, and agency policies.

▶ Cultural resource inventories have been completed 

on approximately 7 % of the public lands in the 

NCA. Additional inventories will continue to be 

conducted over the life of the RMP to develop a 

more comprehensive understanding of the types of 

heritage resources that occur in the NCA and their 

distribution on the landscape.

Implementing management actions for the following 

resources would have no impact or negligible impacts 

on heritage resources and are, therefore, not discussed in 

detail: Air Quality, Water Resources, Vegetation Resource 

that have the potential to negatively impact native species 

and their habitats. Management would employ the least 

invasive tools and methods and emphasize the use of native vegetation to restore and improve habitats.

Under Alternatives B, C, and D, impacts on fish and 

wildlife populations and habitats would be minimized to 

the extent practical and feasible, through restrictions on 

uses and activities. Habitat conditions would be improved through treatments, weed prevention and control, 

and habitat improvements.

4.11.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on native 

fish and wildlife populations includes the Beaver Dam 

Slope of southwestern Utah, northwestern Arizona, and 

southeastern Nevada.

The CIAA for native fishes, amphibians, and riparian obligate avian species is the lower Beaver Dam Wash, from 

the NCA boundary to its confluence with the Virgin 

River, near Beaver Dam, Arizona.

Past human-caused actions within the CIAA, both on 

federal and non-federal lands, that have affected native fish and wildlife populations and habitats included 

overgrazing of rangelands during the late 19th and early 

20th centuries; the construction of highways and roads; 

utility developments; environmental contamination by 

down-wind radioactive “fallout” from repeated aboveground nuclear tests conducted on the Nevada Test Site 

in south-central Nevada during the 1950s and 60s; water 

developments and diversions; range improvements and 

vegetation treatments; and motorized and non-motorized recreational uses. In general, past human activities 

and land uses have cumulatively resulted in the loss, 

degradation, and fragmentation of habitats and some fish 

and wildlife population declines.

Prolonged droughts, the introduction and spread of noxious weeds and invasive species, and wildfires are natural 

factors that have also cumulatively impacted fish and 

wildlife populations and habitats. Many of these natural 

factors created conditions that caused or favored habitat 

changes. For example, wildfires removed vegetative cover 

and damaged soil crusts, leaving soils more susceptible to 

wind and water erosion and weed invasion. The “burnreburn” fire cycle in areas of the CIAA has converted late 

successional shrubland communities into invasive brome 

grasslands that provide poor quality habitat for native 

wildlife. Drought conditions have reduced the health of 

native vegetation communities, making them more prone 

to insect infestations or disease. 

Present and reasonably foreseeable future actions would 

include regional population growth, the expansion of 

nearby communities, like Beaver Dam and Littlefield, 

Arizona; the construction of new utilities in the IPP and 

Navajo-McCullough designated utility corridors that are 

adjacent, but not within the NCA; hazard fuel reduction projects, noxious weed and exotic invasive species 

control, and increasing recreational uses of public lands. 

Livestock grazing is expected to continue on some federal and non-federal lands in the CIAA. 

Future actions are likely to include increased efforts 

to control invasive annual brome grasses and wildfires 

through landscape-wide fire breaks and fuel treatments 

in the CIAA. As ongoing research studies identify more 

effective and environmentally sustainable broad-scale 

treatment methods, it is likely that larger areas will be 

treated and efforts made to restore native vegetation 

communities, improving wildlife habitats. Land uses, 

including livestock grazing, that have the potential to impact habitat restoration projects, would not be authorized 

in those areas, until resource objectives are met. Future 

listings of other native species under the ESA could also 

impose restrictions on livestock grazing and other land 

uses determined to be detrimental to the recovery of 

listed species. These restrictions could benefit all native 

fish and wildlife species by protecting habitats and minimizing impacts on populations related to land uses and 

human activities. 

Climate change within the CIAA could cause an increase 

or decrease in seasonal temperatures and precipitation, 

which would affect soil conditions, vegetation distribution, and surface water resources. Such changes would 

place some wildlife species at greater risk of population 

declines, particularly those species that cannot adapt to 

changed conditions or migrate to areas where habitat 

conditions are favorable.

4.12 HERITAGE RESOURCES

OPLMA Section 1975 (a) directs BLM to “conserve, 

protect, and enhance for the benefit and enjoyment of 

present and future generations” the cultural, historical, 

educational, and scientific resources of the Beaver Dam 

Wash NCA. To satisfy this Congressional mandate, the 

goals and objectives of heritage resource management 

focus on: conserving and protecting sites and landscapes; 

promoting stewardship through public outreach and 

education; encouraging scientific research; facilitating 

Native American traditional uses; and engaging interested groups in these efforts.
672 Chapter 4 BDWNCA BDWNCA Chapter 4 673

Under Alternative C, field investigations and collection of fossil specimens would be restricted to the use of 

hand tools. This alternative would generally minimize 

the potential for adverse effects to heritage resources 

related to these activities, as would compliance with the 

above-referenced federal laws, regulations, and the Utah 

Programmatic Agreement.

4.12.2.3 Impacts from Management of Caves and 

Karst

Alternative A provides no specific goals, objectives, or 

management actions related to the management of caves 

and karsts in the NCA. Potential impacts on heritage 

resources would continue at current or higher levels as 

a consequence of a lack of baseline data about cave and 

karst resources and no systematic management strategies 

in place for cave and karst resources. 

Alternatives B, C, and D would initiate systematic inventories of high potential geologic formations to identify 

caves and karsts in the NCA and evaluate them for significance under the FCRPA. As caves may contain cultural 

resources, including rock art, artifacts, biological materials, and buried stratified deposits, this inventory could 

increase the database on heritage resources in the NCA 

and assist with the development of management plans to 

ensure that these resources are appropriately conserved 

and protected.

4.12.2.4 Impacts from Management of Native 

Vegetation Communities, Fire and Fuels, and Noxious 

Weeds and Invasive Species

All alternatives would strive to conserve, protect, and 

restore native vegetation communities through direct 

management actions to reduce the threat of wildfires and 

restrictions on land uses and authorized activities that 

can impact native vegetation. These goals would be compatible with heritage resource preservation, particularly 

as they relate to maintaining the integrity of setting and 

place for site types for which these contribute to NRHP 

eligibility. All alternatives propose the control and eventual eradication of noxious weeds and invasive species. 

Reductions in invasive annual brome grasses that fuel 

wildfires in the NCA could lessen the potential for future 

wildfires that could damage or destroy fire-susceptible 

heritage resources, such as historic buildings or other 

wooden structures. 

Under Alternative A, the development of fire breaks, 

hazardous fuel reduction projects, and vegetation type 

conversion projects could be authorized, on a case-by-case 

basis. These could be accomplished through prescriptive 

fires and ground-disturbing mechanical vegetation treatments. Compliance with the requirements of Section 106 

of the NHPA would continue under this alternative and 

would include efforts to identify heritage resources within 

the project areas and evaluate these resources for NHRP 

eligibility. Adverse effects to historic properties would be 

avoided or mitigated for these undertakings. The use of 

prescriptive fire would have some potential to adversely 

affect heritage resources if the fire were to escape and 

burn outside of the prescribed fire area. Implementation 

of this alternative could have negligible to minor impacts 

on heritage resources, primarily because it could authorize 

prescriptive fires as treatment options. 

Alternatives B, C, and D also propose the development 

of fire breaks and hazardous fuel reduction projects to 

protect intact native vegetation communities. Prescriptive 

fires and vegetation conversions would not be authorized 

under any of the three alternatives. Alternatives B and 

D would authorize a range of tools, including biological 

controls, herbicides, targeted grazing, and mechanized 

equipment. While any of the tools proposed for use have 

the potential to adversely affect the integrity and scientific data potential of heritage resources, compliance with 

the federal historic preservation laws, in particular the 

requirements of Section 106 of the NHPA, would lessen 

the potential that any negative impacts result from these 

undertakings. Under these alternatives, BLM would identify heritage resources within the project areas and evaluate these resources for NHRP eligibility. Adverse effects to 

historic properties would be avoided or mitigated for these 

undertakings through consultations with the USHPO, 

American Indian Tribes, and other interested parties. 

Alternatives B, C, and D identify a range of management 

actions and tools to restore disturbed and fire-damaged areas of the NCA through re-vegetation projects. 

Alternatives B and D, as well as Alternative A, would 

emphasize the use of native species, but provide for the 

use of non-native species, when certain criteria are met. 

Only Alternative C would not authorize the use of nonnative plant species and would, therefore, restore the 

natural settings of cultural landscapes or historic properties where these have been lost to surface disturbances, 

wildfires, and noxious weed and exotic invasive infestations. For heritage resources for which the integrity of 

the site’s setting and place comprises an eligibility factor 

for NRHP listing, Alternative C would provide a higher 

level of protection of those values, as it would employ 

only native vegetation species for re-vegetation projects. 

Uses: Plant Materials; National Natural Landmark; 

ACECs; and Natural Soundscapes.

4.12.2 Direct and Indirect Impacts

Compliance with the requirements of Section 106 of the 

NHPA would continue under all alternatives and would 

include efforts to identify heritage resources and evaluate 

these resources for NHRP eligibility. Should the identification of NRHP-listed or eligible properties occur as a result of a proposed undertaking, adverse effects to historic 

properties would be avoided through project design or 

impacts lessened to the extent possible through mitigation treatments, such as archaeological data recovery. 

Natural processes, including wildfires and erosion, could 

continue to affect the integrity of heritage resources under all alternatives.

4.12.2.1 Impacts from Management of Water and Soil 

Resources

Under all alternatives, management goals strive to protect water and soil resources, through land use restrictions, BMPs, and project-specific mitigation measures 

that maintain soil stability, minimize erosion, and protect 

water quality. Management actions related to achieving 

these goals could provide direct or indirect protections to 

heritage resources, as high densities of sites are typically 

located in close proximity to water sources in arid lands. 

Springs and other water sources are also often identified 

by Native Americans as being sacred places and of traditional cultural importance. 

Land uses that create surface disturbances and excessive soil erosion, particularly near natural water sources, 

would be restricted to protect water quality. Such restrictions could directly or indirectly help to maintain the 

integrity of heritage resources that are near these sources, 

including site assemblages, surface architectural features, 

and buried stratified cultural deposits, and prevent the 

loss of scientific information. Actions that protect natural 

water sources could help preserve resources of traditional 

cultural importance to Native Americans.

4.12.2.2 Impacts from Management of Geologic and 

Paleontological Resources

Alternative A identifies goals for the management of 

cultural and paleontological resources that include conservation of paleontological resources in selected areas, 

providing opportunities for scientific research, and identifying public use sites for interpretation. No specific Use 

Allocations are made for specific types of paleontological 

localities or outstanding geological features. 

Alternatives B, C, and D allocate paleontological resources to three Use Allocations that are consistent with the 

purposes for the NCA from OPLMA. Alternatives B and 

D allocate paleontological resources to Scientific Use, 

Conservation for Future Use, and Public Use. Alternative 

C would limit these allocations to Scientific Use and 

Conservation for Future Use. Measures to protect paleontological localities of scientific interest and outstanding geologic resources include restrictions on the use of 

mechanized equipment for field studies and specimen 

collection and minimizing the potential for inadvertent 

impacts on heritage resources within the general vicinity 

of these activities.

Alternative A allows for the continued collection of petrified (silicified) wood on public lands, as long as collection complies with federal regulations at CFR 3622 and 

is limited to 250 pounds per person per year for personal 

use. However, this alternative does not explicitly define 

the methods that can be used to collect specimens or 

the locations where petrified wood collection is allowed, 

which could result in inadvertent adverse effects on historic properties in the vicinity of these activities. 

Alternatives B and C would prohibit the collection of 

common invertebrate fossils and petrified wood for commercial and personal use, reducing the likelihood that 

archaeological materials could be inadvertently collected 

or that surface disturbing collection activities could 

inadvertently impact the integrity and data potential of 

heritage resources. 

Alternatives A and D allow for casual collection of rocks 

and minerals and recreational collecting of common invertebrates fossils, increasing the likelihood that archaeological materials could be inadvertently collected or that 

surface disturbing collection activities could impact the 

integrity and data potential of heritage resources. 

 Alternatives B and D authorize the use of hand tools for 

fossil specimen collection by researchers with valid NCA 

Scientific Research Permits and BLM Paleontological 

Resource Use Permits. These alternatives would also 

evaluate the use of mechanized equipment for this purpose, on a case-by-case and site-specific basis. As specimen collection activities would be a federally-authorized 

activity, regulations at 36 CFR 800, Section 106 of the 

NHPA, and the Utah Programmatic Agreement would be 

applied and adverse effects on historic properties within 

the “area of potential effect (APE)” of the activity would 

be avoided or appropriately mitigated. 

HERITAGE RESOURCES HERITAGE RESOURCES
674 Chapter 4 BDWNCA BDWNCA Chapter 4 675

Wildfires would continue to negatively impact the integrity of heritage resources, their scientific data potential, 

and expose sites to increased wind and water erosion 

and vandalism, by removing native vegetative cover. 

Under Alternatives B, C, and D, all fires would be fully 

and quickly suppressed, to limit fire size and conserve 

the NCA resource values. Alternative A would continue 

to provide the option that minimum impact methods be 

employed and that fire use could be authorized. Should 

these suppression approaches be employed, fires might 

not be suppressed or contained quickly, increasing the 

likelihood for adverse effects to heritage resources, particularly those that are fire-susceptible.

Backburning, as a fire suppression tactic, has the potential to cause the same types of impacts on heritage resources as wildfires. Alternatives B and D would require 

that backburning be evaluated on a case-by-case basis 

and its use restricted to minimize the loss of unburned 

areas of native vegetation. Alternatives C would not 

authorize the use of backburning in late successional 

Mojave Desert shrublands, protecting heritage resources 

within approximately 37,280 acres of the NCA from 

types of negative impacts that could result from this suppression tactic. 

During fire suppression, cross-country fire vehicle travel, 

the construction of fire line, and the use of heavy equipment creates new surface disturbances and the loss of 

native vegetation. The potential for adverse effects related 

to these actions on heritage resources would be lessened to the extent possible through the use of qualified 

archaeological Resource Advisors during fire suppression. However, damage to or loss of heritage resources 

could result from the need to take immediate actions to 

minimize the size of fires, as well as protect human life 

and property. The post-fire indirect effects on heritage 

resources, such as increased susceptibility to wind and 

water erosion or looting based from the loss of on-site 

vegetation, would be lessened to the extent possible 

through ES&R actions to stabilize soils in the short term 

and restore native vegetation in the longer term. 

4.12.2.5 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing

Livestock grazing has the potential to adversely affect 

the integrity and scientific data potential of heritage 

resources, through disturbances to soil and vegetation 

that increase erosion, through damage to architectural 

structures and features, and the displacement of artifacts 

within archaeological sites. 

The development of range improvements is an undertaking subject to project-level analysis and Section 106 

review. Under all alternatives, new range developments 

would only be authorized after consultations have been 

conducted, in compliance with the requirements of 

Section 106 of the NHPA, and adverse effects to historic 

properties avoided or mitigated.

Under Alternatives A, B, and D, management actions 

proposed to protect soils, native vegetation, and water 

resources would lessen the potential for impacts related 

to livestock grazing on springs and natural water sources 

that may be of cultural importance to Native Americans. 

Alternatives A and D continue to make 61,995 acres in 

the NCA available for livestock grazing and provide 3,099 

initial AUMs of forage, allowing for grazing to continue 

on the Beaver Dam Slope, Castle Cliffs, Cedar Pocket, 

and Scarecrow Peak Allotments under current terms 

and conditions. The season of use in these allotments 

would continue to be limited to approximately 5 months 

(fall to spring). The construction of range improvements 

would continue to be authorized to improve livestock 

distribution, but Alternative D would only authorize new 

developments if they further the purposes of the NCA 

and benefit diverse resource values. Under both alternatives, previously documented and as yet undiscovered 

heritage resources could continue to be impacted by hoof 

action during livestock trailing that damages or displaces 

surface artifacts or by soil erosion and the loss of vegetative cover in areas where cattle concentrate use, such as 

near water sources.

Under Alternative B, 61,995 acres of the NCA would be 

available for livestock grazing and 1,861 initial AUMs of 

forage provided for livestock. The season of use in these 

allotments would continue to be limited to approximately 

5 months (fall to spring). The construction of range improvements would continue to be authorized. 

Alternative B would provide higher level of protection 

to heritage resources related to livestock grazing impacts 

when compared to Alternatives A and D. Alternative B 

would authorize 1,861 initial AUMs of livestock forage, which would result in fewer head of cattle grazing 

within the allotments (and/or shorter grazing periods), 

when compared to the potential 3,099 AUMs that would 

be available for use under Alternatives A and D. Fewer 

impacts on the integrity of heritage resource artifact 

assemblages, structures, and features would be expected 

to result from livestock grazing, based on the proposed 

reductions in AUMs. 

Alternative C would make the entire NCA unavailable 

to livestock grazing over the life of the RMP and would 

eliminate all grazing activities on the 61, 995 acres of 

the four allotments that intersect the NCA (61,995 total 

acres) and remove 3,099 AUMs from livestock use. This 

alternative would provide the highest level of protection 

for heritage resources, eliminating threats and potential 

impacts to the integrity and scientific data potential of 

heritage resources that are generally attributed to livestock grazing.

4.12.2.6 Impacts from Management of Special Status 

Species, including BLM Sensitive Species

Under Alternative A, approximately 45,822 acres of the 

Beaver Dam Slope ACEC within the NCA would continue to be managed for the protection of Mojave desert 

tortoise populations and habitat and other special status 

species. The ACEC management prescriptions, which 

include limiting motorized vehicle travel to designated 

routes and management as an Avoidance area for new 

linear and site-type ROWs, would provide minor to 

moderate beneficial effects for heritage resources, lessening the potential for surface disturbances and developments that could adversely impact heritage resources. 

Under Alternatives B, C, and D, the ACEC administrative 

designation would be revoked, but management actions 

would continue to emphasize the protection of habitats 

and populations of other wildlife through land use restrictions. The NCA would be managed as an Exclusion area 

for new linear and site-type ROWs and as Limited to 

Designated Roads and Trails for motorized vehicle travel. 

This management would provide moderate to major beneficial effects for heritage resources, eliminating the potential for impacts to NRHP-eligible properties related to 

ROW developments or motorized vehicle off-road travel.

All alternatives also propose management actions to 

conserve, protect, and restore habitats for special status 

species, through hazard fuel reduction treatments, and 

restoration of damaged habitats. Under Alternative A, 

hazardous fuel reduction projects proposed to protect 

native vegetation communities would have the fewest constraints on the methods to be utilized, including 

the use of prescribed fire and mechanical treatments. 

Both methods would have some potential to directly or 

indirectly impact heritage resources within or near the 

project areas, through increased soil erosion or the loss 

of protective vegetation cover. Alternatives B, C, and D 

would emphasize the use of non-invasive or minimally 

invasive methods for hazardous fuel treatments and 

would not authorize the use of prescriptive fire. Similarly, 

these alternatives would restrict the methods used for 

re-vegetation projects to methods that result in little or 

no surface disturbance. These alternatives would provide a higher level of protection for all types of heritage 

resources from impacts associated with actions to conserve, protect, and restore habitats. 

4.12.2.7 Impacts from Management of Heritage 

Resources

Through land use planning, BLM allocates heritage resources into one of six Use Allocations, according to their 

nature and relative preservation value. Each allocation 

category has corresponding management actions and desired outcomes. As examples, sites allocated to Scientific 

Use are managed as available for appropriate research, 

where the desired outcome would be to preserve the 

resource until research or data collection is conducted. 

Under the Conservation for Future Use allocation, 

protective measures are implemented to preserve the resource until the conditions for use are met. The management action for resources allocated to the Traditional Use 

category would be tribal consultation and determination 

of limitations to achieve long-term preservation. The 

management action for resources allocated to the Public 

Use category would be to determine permitted uses, 

and the desired outcome would be long-term preservation and on-site interpretation. In the Experimental Use 

category, the corresponding management action would 

be to determine the nature of the experiment and the 

desired outcome would be to protect the resource until 

it is used. Lastly, for resources placed in the Discharged 

from Management category allocation, the management 

action would be to remove protective measures and the 

desired outcome would be no use after recordation, and 

the resource would not be preserved.

Alternative A identifies general goals for the management of heritage resources that include conservation of 

resources in selected areas, opportunities for scientific 

research, and the identification of public use sites for 

interpretation. No specific Use Allocations are made for 

specific site types under this alternative and no specific 

management actions are identified by heritage resource 

site types under this alternative. 

Under Alternatives B, C, and D, all heritage resources, 

not only those that are currently documented but also 

those that will be identified and documented in the 

future over the life of the RMP, would be allocated to four 

Use Categories: Scientific Use, Conservation for Future 

Use, Public Use, and Traditional Use. These allocations are consistent with the conservation, protection, 

HERITAGE RESOURCES HERITAGE RESOURCES
676 Chapter 4 BDWNCA BDWNCA Chapter 4 677

HERITAGE RESOURCES HERITAGE RESOURCES

and enhancement purposes for which the NCA was 

Congressionally-designated through OPLMA. Eligible 

sites or groups of sites would be nominated for inclusion 

to the NRHP, whenever warranted. The integrity of setting and place for cultural landscapes would be conserved, protected, and restored, wherever feasible.

Management actions are identified for specific site types 

under each Use Allocation, to minimize threats and meet 

long-term conservation goals, through implementationlevel management plans, regulatory signing, physical barriers, site monitoring, restrictions on authorized activities 

and land uses, and public education. 

The allocation of specific site types to Public Use would 

enhance opportunities for public enjoyment of heritage 

resources through the identification of appropriate sites 

for interpretation and public appreciation. For sites 

identified as appropriate for Public Use, implementationlevel plans would identify opportunities for on and 

off-site interpretation, visitor registers, informational and 

directional signing, and other visitor amenities. Class 

III intensive archaeological field inventories would be 

conducted prior to the management of a specific site for 

Public Use to identify and evaluate potential effects to 

other heritage properties that may be in close proximity.

Heritage tourism opportunities identified under the 

three alternatives would increase public awareness and 

appreciation for the early explorers and traders who 

pioneered routes through this portion of the Mojave 

Desert, including those associated with the Old Spanish 

National Historic Trail. Interpretation would be provided 

at Welcome/ Orientation pullouts and wayside exhibits 

along the Mojave Desert Joshua Tree Scenic By-way to 

increase public awareness of the history of explorations 

through the NCA and the importance of the trails and 

routes that were pioneered in the westward expansion of 

this country.

Alternatives B, C, and D would promote opportunities for volunteer involvement in Site Stewardship and 

Docent programs that increase public awareness of the 

need to conserve and protect heritage resources. Youth 

and veteran groups, citizen stewards, and other volunteers would be invited to participate in site clean-up and 

restoration, as well as archaeological inventory and data 

recovery projects that enhance public understanding of 

NCA and regional heritage resources.

4.12.2.8 Impacts from Management of National 

Historic Trails

Management actions identified to conserve, protect, and 

restore National Historic Trail resources, qualities, values, 

and associated settings would generally complement 

and be consistent with the protection of other heritage 

resources.

Under Alternative A, no goals or objectives were identified for the Old Spanish National Historic Trail, as it had 

not been Congressionally-designated to the National 

Trail System when the SGFO RMP was approved in 1999. 

Management actions identified in the RMP were limited 

to the marking and signing of those portions of the OST 

where it crossed public lands managed by the SGFO. 

This alternative would manage the OST consistent with 

the requirements of the National Trails System Act, BLM 

Manual 6280, and adopt relevant provisions of the trailwide Comprehensive Plan for the OST, when it has been 

completed by BLM and the National Park Service (NPS) 

as joint administrators.

Alternatives B, C, and D include goals and objectives to 

conserve, protect, and restore trail resources, qualities, 

values, and associated settings and primary uses, and to 

provide premier trail visitor experiences for the benefit of the public. A 12,506 acre OST National Historic 

Management Corridor (OST Management Corridor) 

would be established under these three alternatives that 

includes the legislatively-designated OST route and the 

potential Armijo Route through the NCA and encompasses the trail resources, qualities, values, and associated 

trail settings. 

Under Alternatives B and D, the OST Management 

Corridor would be managed as VRM Class II, as a ROW 

Exclusion area, and motorized vehicle use would be 

Limited to Designated Roads and Trails. The narrow 

designated utility and transportation corridor that parallels and is bisected by Old Highway 91 would be retained 

under these alternatives, but its width would be better 

defined than under Alternative A, limited to 100 total 

feet in width under Alternative B and 200 feet in total 

width under Alternative D. Only subsurface installations 

would be authorized within that corridor under these 

alternatives, to protect the scenic qualities and associated 

setting of the OST. Should trail-related archaeological 

resources, trail traces, or remnants be identified within 

the designated corridor as a result of an undertaking, compliance with the applicable federal legislation 

(e.g. National Trails System Act, NHPA) would help to 

prevent the loss of trail resources or historic properties. 

Where adverse effects to historic properties could not 

be avoided, appropriate mitigation would be developed 

through Section 106 consultations. 

Management under VRM Class II and a ROW 

Exclusion area would provide a high level of protection 

for trail resources, qualities, values, associated settings 

and trail visitor experiences by ensuring that ROWs and 

project proposals are not authorized that could negatively impact trail values.

Under Alternative C, the 12,506 acre corridor would 

be managed as a ROW Exclusion area and the designated utility corridor along Old Highway 91 would be 

revoked, subject to valid existing rights. Management of 

the OST Management Corridor would be VRM Classes 

I and II, and as a ROW Exclusion area, providing a 

high level of protection for trail resources, values, and 

experiences, by limiting the types of developments and 

land uses that could be authorized within the 12,506 

acres of the corridor. 

Alternatives B, C, and D would emphasize the identification and protection of routes and any associated 

trail features, sites, and artifacts are identified for their 

historical, scientific, educational, interpretative, and 

recreational values. Altered landscapes within the OST 

Management Corridor would be restored to an identified trail-era condition, wherever feasible. Actions 

to improve the naturalness of the Trail Management 

Corridor would include closure and rehabilitation 

with native vegetation of all identified social trails and 

redundant routes. 

Alternatives B, C, and D identify opportunities for providing interpretation at Welcome or Orientation pullouts and wayside exhibits within the OST Management 

Corridor, along Old Highway 91 and the Mojave Desert 

Joshua Tree Scenic By-way, increasing public awareness 

and the quality of visitor experiences related to the OST 

through various interpretive media.

Alternatives B, C, and D would collaborate with partners (e.g., user groups, trail organizations) to design and 

construct a non-motorized trail to provide retracement 

opportunities within the OST Management Corridor. 

Alternatives B and D would authorize retracement 

opportunities along Old Highway 91 and the Mojave 

Desert Joshua Tree Scenic By-way, while Alternative C 

would limit retracement opportunities to the Mojave 

Desert Joshua Tree Scenic By-way.

4.10.2.9 Impacts from Management of ACECs

Under Alternative A, the approximately 48,519-acre 

Beaver Dam Slope ACEC would continue to be managed as an administrative designation, providing special 

management attention to the protection of Mojave 

desert tortoise populations and habitat, special status 

and BLM Sensitive Species, and the natural values and 

research potential of the Joshua Tree National Natural 

Landmark and the Woodbury Desert Study Area. 

Approximately 45,822 acres of the ACEC are within the 

boundaries of the NCA.

Continuing to manage 45,822 acres of the NCA as a 

designated ACEC would provide minor to moderate 

beneficial effects for heritage resources, as the ACEC 

would be managed as an Avoidance area for new utility 

and transportation ROWs and motorized vehicle travel 

Limited to Designated Roads and Trails. Management 

as an Avoidance area for ROWs would lessen, but not 

totally preclude the potential for new ROW developments that could adversely affect NRHP-eligible 

heritage resources. Compliance with the provisions 

of Section 106 of the NHPA would help to mitigate 

adverse effects to historic properties through project 

design to avoid properties within the project APE. 

Where adverse effects could not be avoided, appropriate mitigation would be developed through Section 106 

consultations and implemented; whenever archaeological data recovery comprises the treatment employed to 

lessen adverse effects, scientific data is recovered, but 

the physical site is destroyed. 

The conservation and protection of cultural and historic resources are among the identified purposes in 

OPLMA for Congressional designation of this NCA. 

The loss of heritage resources, even when mitigation 

measures have been applied, as a result of federally-authorized undertakings would not be consistent with the 

Congressionally- identified conservation purposes of 

the NCA. 

Under Alternatives B, C, and D, the ACEC designation would be revoked, but would not result in lessor 

levels of protection for the special status species and 

other resource values, including heritage resources. 

Congressional segregations, management, and uses 

identified in OPLMA at Section 1975 provide protections that are equal or superior to those provided 

by ACEC designation for: entry, appropriation, and 

disposal under the public land laws; location, entry, 

and patenting under the mining laws; and operation of 

the mineral leasing, mineral materials, and geothermal 
678 Chapter 4 BDWNCA BDWNCA Chapter 4 679

HERITAGE RESOURCES HERITAGE RESOURCES

leasing laws. Alternatives B, C, and D also propose management decisions that would provide similar or higher 

levels of protection than the management prescriptions 

identified under Alternative A. These include management of the NCA as a ROW Exclusion area and limiting 

motorized vehicle travel to designated roads and trails. 

The segregations and proposed management actions to 

restrict land uses to benefit special status species and 

critical habitats would also help to conserve and protect 

heritage resources by eliminating or limiting those land 

uses and authorized activities that have the potential to 

damage or destroy these resources.

4.12.2.10 Impacts from Management of Visual 

Resources

Management under VRM classes that restrict the level of 

the change to the characteristic landscape can benefit all 

heritage resources by limiting the types of facilities that 

can be developed within that landscape and the nature 

and extent of land uses that have the potential to impair 

visual resources. 

Alternative A would continue to manage the 63,480 acres 

of NCA as VRM Class III, under which the existing character of the landscape must be partially retained and the 

level of change to the characteristic landscape moderate. 

The natural scenic qualities of cultural landscapes and 

the integrity of the setting for heritage resources could 

be impacted under this VRM class, but the potential for 

such impacts to occur would be very low. Under this 

alternative, the NCA would continue to be managed as a 

ROW Avoidance area, minimizing the potential that new 

ROWs would be granted to authorize the development of 

utilities, highways, or other projects. 

The Congressionally-identified purposes of the NCA 

include the conservation, protection, and enhancement 

of its scenic qualities, further minimizing the likelihood 

that land uses or projects would be authorized that would 

impact the existing character of the landscape, even 

under the current VRM Class III designation. Should 

such a land use or project be proposed, this undertaking 

would be subject to project-level analysis and Section 106 

review. Adverse effects to historic properties that could 

result from authorization of a land use or project proposal would be avoided or lessened to the maximum extent 

possible, through project design and other measures 

developed through Section 106 consultations.

Alternatives B and D would manage 63,480 acres as 

VRM Class II, requiring that the existing character of 

the landscape is retained and that the level of change to 

the characteristic landscape should be low. Compared to 

Alternative A, management under this VRM Class would 

provide a slightly higher level of protection for the natural scenic cultural landscapes and the integrity of setting 

for heritage resources, by limiting the types of developments and actions that could occur within the NCA. 

Alternative C would manage a majority of the NCA under VRM Class II designation (46,916 acres) and 16,564 

acres as VRM Class I. This alternative would afford the 

highest level of protection level to the natural setting of 

cultural landscapes and the integrity of heritage resource 

settings. Under VRM Class II, the level of change to the 

characteristic landscape must be very low; the objective 

under VRM Class I is to preserve the existing landscape 

of the area. The types of developments that could occur 

within the NCA would be very limited under this alternative, protecting all heritage resources from land use 

and project-specific impacts.

4.12.2.11 Impacts from Management of Lands with 

Wilderness Characteristics

Under Alternatives A, B, and D, no acres within the NCA 

are proposed for management of lands with wilderness 

characteristics. Alternative C proposes to protect 16,721 

acres of the NCA for their wilderness characteristics 

through management under VRM Class I and as a ROW 

Exclusion area for new linear and site-type ROWs. 

Management under Alternative C would afford a slightly 

higher level of protection for heritage resources when 

compared to the other alternatives, through management 

under VRM Class I. This class would restrict land uses 

and surface disturbances that would result in changes 

to the landscape that attract the viewer’s attention. The 

natural settings of cultural landscapes and the integrity 

of many heritage resource site types would be conserved 

and protected, as the types of developments and land 

uses that could be authorized would be very limited.

4.12.2.12 Impacts from Management of Recreation 

and Visitor Services

Greater public awareness of the Congressional designation of the NCA, in concert with local and regional 

population growth, is anticipated to attract more recreational users to the NCA. The impacts of recreation 

activities on heritage resources would vary, depending on 

the intensity and extent of disturbances that result from 

the activity. Dispersed camping, off-trail horseback riding or mountain biking, and cross-country OHV travel 

would be examples of recreation uses that could damage or destroy the integrity and information potential of 

heritage resources. Increased public access to certain site 

types, such as sites with standing architectural structures, 

could inadvertently damage these resources, as visitors 

collapse walls attempting to take photographs or displace 

surface artifacts. The potential for vandalism and unauthorized collection of artifacts from sites can often be 

linked to increased recreational activities or improved 

public access.

Alternative A would continue to manage the NCA lands 

as part of the larger SGFO ERMA; management decisions for the ERMA provide for more dispersed and less 

structured recreation on public lands. Dispersed camping, recreational prospecting, recreational target shooting, the use of metal detectors, geocaching, and many 

other types of dispersed recreational activities would 

continue to be authorized activities in the NCA. 

Geocaching activities and metal detecting could continue to create surface disturbances that can impact the 

integrity and scientific information potential of heritage 

resources and result in the unlawful collection of artifacts. Permanent and irreversible damage to rock art sites 

could be the outcome of the continued authorization 

of recreational target shooting and paintball activities, 

particularly when these resources are used as targets or 

backdrops (intentionally or unintentionally) for shooting. 

Under Alternatives B, C, and D, more intensive management of recreation uses is proposed through the 

establishment of the Beaver Dam Wash SRMA and the 

preparation of implementation-level plans for recreational activities and visitor services. Three Recreation 

Management Zones would be established within the 

SRMA with specific objectives and a range of authorized 

uses and activities that are compatible with the zone 

management objectives. Each of these alternatives would 

limit dispersed camping to designated and previously 

disturbed campsites located away from sensitive natural 

resources and from heritage sites. 

These alternatives would limit physical geocaches to 

specific zones and require approval from BLM, helping 

to ensure that locations are not within sensitive areas for 

natural or cultural resources. 

Alternatives B and C would prohibit recreational metal 

detecting; Alternative D would only allow metal detection that creates minimal surface disturbances. When 

compared to Alternative A, these alternatives would 

lessen the potential for impacts on heritage resources 

through surface disturbances that can impact the 

integrity and scientific information potential of heritage 

resources and the unlawful collection of artifacts. 

Alternatives A and D would continue to authorize 

recreational target shooting in the NCA, continuing the 

threat of permanent and irreversible damage to rock art 

sites and sites with standing structures. Alternative D 

would require the use of paper targets and appropriate 

backstops, but these requirements would likely not be 

sufficient to adequately protect high-risk site types, such 

as rock art sites, from target shooting vandalism. 

Alternative B would prohibit recreational target shooting within 50,908 acres of the NCA to protect special 

status species, particularly the threatened Mojave desert 

tortoise, and other resource values from impacts related 

to this activity. Alternative C would prohibit recreational 

target shooting in the NCA. These alternatives would 

lessen the likelihood that permanent and irreversible 

damage to rock art sites would result from the authorization of recreational target shooting.

The types and numbers of SRPs would be more intensively managed under these alternatives, when compared 

to Alternative A. The prohibitions and limitations on 

recreation uses and SRPs identified in the three action 

alternatives would lessen the potential for direct, indirect, 

and inadvertent impacts on the integrity and scientific 

information potential of heritage resources.

4.12.2.13 Impacts from Management of 

Comprehensive Travel and Transportation

All alternatives propose OHV area designations for the 

NCA, with specific route designations to follow through 

BLM’s development of a TMP for Washington County.

When the TMP is approved, all alternatives would designate the entire acreage of the NCA (63,480 acres) as 

Limited to Designated Roads and Trails, providing direct 

and indirect benefits to heritage resources by restricting off-road motorized vehicle travel that can adversely 

impact the integrity and scientific information potential 

of many types of heritage resources.

4.12.2.14 Impacts from Management of Lands and 

Realty

As a result of Congressional designation of the NCA in 

2009, all alternatives now require that public lands in the 

NCA be retained in federal ownership. Federal historic 

preservation laws would be applied to all undertakings within the NCA, requiring that adverse effects on 

NRHP-listed or eligible properties be assessed, avoided, 

or appropriately mitigated. Federal ownership would 

provide a major and positive benefit to the long-term 
680 Chapter 4 BDWNCA BDWNCA Chapter 4 681

HERITAGE RESOURCES HERITAGE RESOURCES

conservation and protection of heritage resources. Under 

all alternatives, non-federal inholding within the NCA 

could be acquired and managed to conserve, protect, 

and enhance the cultural and historical values of the 

acquired lands. 

The granting of ROWs across public lands for the development and operation of power transmission lines, roads, 

pipelines, communication sites, and other land use authorizations can impact the setting and integrity of heritage resources. Under all alternatives, defining Exclusion 

and Avoidance areas for linear and site-type ROWs 

reduces the potential for effects on heritage resources 

related to these land use authorizations. Designating utility and transportation corridors across public lands, and 

siting ROWs within those corridors, may not eliminate 

or reduce the potential for effects on these resources, but 

does localize the effects to specific areas.

Compliance with the requirements of Section 106 of the 

NHPA would continue under all alternatives and would 

include efforts to heritage resources in the NCA and 

evaluate these resources for NHRP eligibility. Should the 

identification of trail-related resources occur as a result 

of undertakings proposed by BLM or others, adverse effects to historic properties would be assessed and avoided 

or mitigated.

Under Alternative A, the NCA is currently managed as a 

ROW Avoidance area, with the exception of a designated 

utility and transportation corridor of varying widths ( totaling 196 acres) that parallels both sides of Old Highway 

91. Alternative A would continue to allow new ROWs to 

be granted for utilities in that designated corridor, potentially impacting heritage resources within the corridor. 

Through compliance with the requirements of Section 

106 of the NHPA, adverse effects to historic properties 

would be assessed and avoided or mitigated.

Under Alternatives B, C, and D, a majority of the NCA 

would be designated as a ROW Exclusion area, protecting heritage resources from surface-disturbing activities 

and visual intrusions that could result from the development of linear and site-type ROWs. Alternative B would 

manage 63,420 acres of the NCA as a ROW Exclusion 

area, while retaining the existing designated utility and 

transportation corridor along Old Highway 91. This alternative would define the corridor to be 100 feet in total 

width, comprising a total of 60 acres, and would limit 

new utility ROWs to subsurface installations only within 

the designated corridor. The construction of new subsurface installations in the designated corridor would result 

in new surface disturbances and potential adverse effects 

on historic properties within the APE of the specific 

undertaking. Adverse effects would be avoided or appropriately mitigated, through treatments approved through 

the Section 106 process.

Alternative C would manage 63,480 acres of the NCA as 

ROW Exclusion area and revoke the designated utility and transportation corridor along Old Highway 91, 

subject to valid existing rights. This alternative would 

provide the highest level of protection to all types of 

heritage resources when compared to the other alternatives, eliminating the potential for adverse effects related 

to surface disturbances and visual impacts on site and 

landscape settings.

Alternative D would manage 63,352 acres of the NCA 

as a ROW Exclusion area, while retaining the existing 

designated utility and transportation corridor along Old 

Highway 91. This alternative would define the corridor 

width to be 200 feet (128 acres) and would limit new 

utility ROWs to subsurface installations only within the 

designated corridor. The potential impacts on heritage 

resources would be similar to those described under 

Alternative B.

4.12.2.15 Impacts from Management of Public 

Education and Interpretation

Alternative A would not preclude public education outreach or interpretation of heritage resources, but does not 

identify specific or detailed management actions, nor are 

specific site types allocated to Public Use.

Under Alternatives B, C, D, the allocation of specific site 

types to Public Use would enhance opportunities for 

public education outreach and interpretation of heritage 

resources. Implementation-level plans would identify opportunities to increase public understanding of the legal 

protections afforded heritage resources on public lands, 

as well as appropriate site etiquette. The development of 

on and off-site interpretation and educational programs 

could increase public understanding of and appreciation 

for heritage resources, fostering a higher level of stewardship and potentially reducing incidences of vandalism, 

site looting, and other direct and indirect impacts, when 

compared to Alternative A. 

4.12.3 Summary of Impacts from Alternatives

The Congressionally-defined purpose of the NCA is to 

“conserve, protect, and enhance” the resource values of 

the NCA, including its “cultural and historical” resources. 

This mandate focuses the proposed management goals, 

objectives, and decisions for the three action alternatives. 

Under all alternatives, Congressional segregations, management, and uses identified in OPLMA Section 1975 

provide protections for heritage resources from: entry, 

appropriation, and disposal under the public land laws; 

location, entry, and patenting under the mining laws; 

and operation of the mineral leasing, mineral materials, and geothermal leasing laws. All alternatives would 

provide a similar level of conservation and protection 

for heritage resources within the context of undertakings 

and compliance with the requirements under Section 106 

of the NHPA. All alternatives would manage motorized 

OHV travel as Limited to Designated Roads and Trails, 

minimizing the potential for adverse effects to heritage 

resources from off-road motorized vehicle travel.

Alternative A would continue certain land use restrictions, including management of the NCA as a ROW 

Avoidance area, lessening the potential that heritage 

resources would be adversely affected related to the development of utilities outside of the designated corridor 

along Old Highway 91. Other management decisions for 

special status species, BLM Sensitive Species and other 

wildlife similarly limit land use and some authorized 

activities, helping to protect heritage values.

Alternatives B and D propose management of the NCA 

as a ROW Exclusion area, providing an even higher level 

of protection for heritage resources related to the potential development of utilities outside of the designated 

utility corridor, when compared to Alternative A. 

Alternative C would manage the NCA as a ROW 

Exclusion area and revoke the designated utility 

and transportation corridor along Old Highway 91, 

providing the highest level of protection for heritage 

resources, as it relates to the potential development of 

linear and site-type ROWs that could adversely affect 

historic properties.

Alternatives B, C, and D propose more intensive management of recreation activities, through zoning and 

prohibitions on certain activities that can be damaging to 

natural and cultural resources. These alternatives would 

also make changes to current livestock grazing management, with Alternative B reducing the number of AUMs 

that would be authorized and Alternative C making all 

public lands within the NCA unavailable for livestock 

grazing over the life of the RMP. Of the three action 

alternatives, Alternative C emphasizes management actions that minimize the authorization of land uses that 

create new surface disturbances and employ the least invasive methods to accomplish resource goals and objectives. This alternative would generally provide the highest 

level of protection for heritage resources when compared 

to all other alternatives.

4.12.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on heritage 

resources would include federal and non-federal lands on 

the Beaver Dam Slope in Utah and the Arizona Strip. 

Past human-caused actions within the CIAA that have 

affected heritage resources include overgrazing of rangelands, road and highway construction, utilities development in the designated IPP and Navajo-McCullough corridors that are adjacent to but outside of the boundaries 

of the NCA; utility developments and highway construction in the designated corridor along Old Highway 91 

through the NCA; water developments and diversions, 

range improvements and vegetation treatments, and 

motorized and non-motorized recreational uses. Natural 

factors have included the introduction and spread of 

noxious weeds and invasive species, wildfires, native vegetation loss, soil erosion, and flooding of the Beaver Dam 

Wash and its tributary drainages.

Present and reasonably foreseeable future actions would 

include continued regional population growth, the expansion of local communities near the NCA, like Beaver 

Dam and Littlefield, Arizona, the construction of new 

utilities in designated corridors, hazard fuel reduction 

treatments, noxious weed control, and increasing recreational uses of public lands. Livestock grazing in expected to continue on public and private lands in the CIAA. 

Natural factors will continue to include wildfires fueled 

by exotic invasives, droughts, wind and water-caused soil 

erosion, and flooding of the Beaver Dam Wash and its 

tributary drainages.

Climate change within the CIAA could cause an increase 

or decrease in temperatures and precipitation, which 

would affect soil conditions, vegetation distribution, 

water flows, water quality, and water temperature. Such 

changes would alter the conditions to which vegetation 

communities are adapted, potentially creating conditions 

that could favor certain species or communities, weeds, 

or pests. 

The cumulative impacts on heritage resources in the 

CIAA would be primarily beneficial effects that are moderate to major in scope and intensity. Congressional segregations, management, and uses identified in OPLMA 

Section 1975 for the Beaver Dam Wash NCA provide 

protections for heritage resources on 63,500 acres of public land from: entry, appropriation, and disposal under 

the public land laws; location, entry, and patenting under 
682 Chapter 4 BDWNCA BDWNCA Chapter 4 683

NATIONAL HISTORIC TRAILS NATIONAL HISTORIC TRAILS

high potential historic sites or high potential route 

segments;

▶ Limits on BLM’s ability to manage the trail for the 

purpose of identifying and protecting the historic 

route and its historic remnants and artifacts for 

public use and enjoyment, including interpretation, 

education, appreciation, and vicarious experiences;

▶ Necessity of relocating the OST Management 

Corridor in order to provide for the conservation 

and enjoyment of the nationally-significant resources, qualities, values, and associated landscape 

settings through which the trail segments may pass, 

or the primary use or uses of the trail.

4.13.1.2 Assumptions

This analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ Congressional designation of a trail as part of the 

National Trails System signifies that the trail area is 

of significant scenic, historic, cultural, recreational, 

or natural value;

▶ Undertakings will comply with 36 CFR 800, Section 

106 and the Utah Programmatic Agreement; 

▶ Impacts on a NHT are assessed by applying the 

criteria of “adverse effect,” as defined in 36 CFR 

Part 800.5a: “An adverse effect is found when an 

action may alter the characteristics of a historic 

property that qualify it for inclusion in the NRHP 

in a manner that would diminish the integrity of the 

property’s location, design, setting, workmanship, 

feeling, or association. Adverse effects may include 

reasonably foreseeable effects caused by the action 

that may occur later in time, be farther removed in 

distance, or be cumulative”;

▶ Adverse effects on the NHT would be avoided or 

appropriately mitigated;

▶ Impacts on a NHT are assessed by applying the 

criteria of substantial interference and incompatibility with the nature and purposes of the National 

Trail, as described in BLM Manual 6280. Substantial 

interference is assessed by determining if an activity 

or use affects (hinders or obstructs) the nature and 

purposes of a designated National Trail;

▶ BLM Manual 6280 identifies mitigation for NHTs 

as the elimination or moderation, to the greatest extent possible, of the intensity and duration 

of the adverse impact to the nature and purposes; 

resources, qualities, values, and associated settings; 

and the primary use or uses of the OST from incompatible activities. Mitigation may include compensating for the impact by replacing or providing 

substitute resources or environments;

▶ NHT protection and mitigation measures apply to 

all proposed federal or federally-assisted undertakings, and would be applied at project design and 

implementation phases;

▶ Degradation of the NHT from natural processes 

(e.g., wildfires, erosion) would continue, regardless 

of avoidance of human caused impacts;

▶ Potential impacts on the NHT and its setting from 

subsequent undertakings (implementation of the 

planning decisions or site-specific project proposals) will be identified and mitigated through subsequent NEPA analyses and consultations under 

Section 106 of NHPA;

▶ Uses that will not substantially interfere with the 

nature and purposes of the OST may be authorized;

▶ Uses that are incompatible with the purposes 

for which the OST was established will not be 

authorized; 

▶ Analysis area is defined as the OST National 

Historic Trail Management Corridor (OST 

Management Corridor), as depicted on Map 2-5.

Implementing management for the following resources 

would have no impact or negligible impact on the OST 

and are not discussed in detail here: Air Quality, Water 

Resources, Geologic and Paleontological Resources, Cave 

and Karst Resources, Soil Resources, Noxious Weeds and 

Invasive Species, Vegetation Uses: Livestock Grazing, 

Vegetation Resource Uses: Plant Materials, Special 

Status Species, Other Fish and Wildlife Species, National 

Natural Landmarks, ACECs, Natural Soundscapes, Lands 

with Wilderness Characteristics, and Scientific Research.

4.13.2 Direct and Indirect Impacts

The integrity of the trail setting, any trail surface manifestation, and associated historic period sites could be damaged or destroyed by incompatible land uses. Compliance 

with the requirements of Section 106 of the NHPA would 

continue under all alternatives and would include efforts 

to identify OST traces or associated historic period sites 

in the NCA and evaluate these resources for NHRP eligibility. Should the identification of trail-related resources 

occur as a result of undertakings proposed by BLM or 

others, adverse effects to historic properties would be 

the mining laws; and operation of the mineral leasing, 

mineral materials, and geothermal leasing laws. All 

alternatives would provide a similar level of conservation 

and protection for heritage resources within the context 

of undertakings and compliance with the requirements 

under Section 106 of the NHPA. Management goals, 

objectives, and decisions for the Draft RMP have been 

developed to emphasize the resource conservation, protection, and enhancement purposes for which the NCA 

was Congressionally-designated in 2009. 

On nearby public lands on the Arizona Strip, the 

1,048,325-acre Grand Canyon-Parashant National 

Monument was established by Presidential Proclamation 

7265 and is jointly managed by BLM and NPS to protect 

its scientific and historic resources that include paleontological and archaeological resources. As a result of 

Congressional designation and Presidential Proclamation, 

nearly 1,100,000 acres of the CIAA will be managed in 

perpetuity to conserve and protect heritage resources for 

the benefit of current and future generations.

4.13 NATIONAL HISTORIC TRAILS

The Old Spanish National Historic Trail (OST) is the 

only Congressionally-designated National Historic Trail 

(NHT) that crosses the Beaver Dam Wash NCA and 

other public lands in Washington County, UT. This section discusses the potential impacts and beneficial effects 

on the OST that could result from the proposed management actions identified in the four alternatives presented 

in Chapter 2; Section 3.14.2 in Chapter 3 provides an 

overview of the history, significance, and current condition of that segment of the legislatively-designated route 

of the OST through the NCA.

The National Trails System Act (NTSA), Section 3 (3) 

defines national historic trails as follows:

“National historic trails...follow as closely as possible 

and practicable the original trails or routes of travel of 

national historic significance. Designation of such trails 

or routes shall be continuous, but the established or 

developed trail, and the acquisition thereof, need not be 

continuous on-site. National historic trails (NHT) shall 

have as their purpose the identification and protection of 

the historic route and its historic remnants and artifacts 

for public use and enjoyment.”

The nature and purposes of the OST are to afford the 

public the opportunity to connect to the trail resources 

and the trail story.

4.13.1 Methods of Analysis

Baseline information in Section 3.14.2 described the 

condition of the OST and informed this analysis. Also, all 

laws pertinent to determining effects on NHTs were considered and included in criteria for determining impacts.

4.13.1.1 Indicators

Potential impacts on the integrity and settings of NHT 

traces and any associated historic period sites, features, 

or objects are assessed by applying the criteria of “adverse effect”, as defined in the implementing regulations 

for Section 106 of the NHPA at 36 CFR 800. Substantial 

interference and incompatibility with the nature and 

purposes of National Trails are evaluated in accordance 

with the NTSA section 7 (c) and BLM Manual 6280. 

Indicators of adverse effects on the OST could include 

the following:

▶ Conflicts with management goals and objectives 

that sustain NHT qualities;

▶ Proposed uses incompatible with maintaining NHT 

qualities;

▶ Loss of integrity or a loss of archaeological information, resulting from physical damage or destruction 

of all or parts of an NHT;

▶ Alteration of a significant element of a NHT;

▶ Introduction of visual or auditory elements that 

diminish the integrity of a trail’s historic character;

▶ Increased access to trail resources, resulting in erosion, looting, and vandalism;

▶ A lack of action that results in deterioration of an 

NHT resource;

Indicators of substantial interference and incompatibility with the nature and purposes of the OST include the 

following:

▶ Affects to the effective management of the nature 

and purposes of the OST, trail resources, qualities, 

values, uses (including public access and enjoyment) and associated settings;

▶ Affects to the characteristics that made the OST 

worthy of Congressional designation;

▶ Affects to high-potential historic sites or high 

potential route segments (Federal Protection 

Components) on NCA lands;

▶ Affects to OST properties, including remnants, 

sites, features, and objects from the associated 

period of significance that may be eligible for listing 

on the NRHP and/or determined by the National 

Trail administration agencies to qualify as possible 
684 Chapter 4 BDWNCA BDWNCA Chapter 4 685

NATIONAL HISTORIC TRAILS NATIONAL HISTORIC TRAILS

re-establish as mature stands for centuries, if at all. Under 

all alternatives, all fires would be fully and quickly suppressed to limit fire size and conserve the fire-susceptible 

native communities. Alternatives B, C, and D would 

require that the fire suppression technique of backburning be minimized or avoided entirely, to prevent the loss 

of unburned native vegetation communities.

 The use of heavy equipment and other tactics employed 

during fire suppression could create new surface disturbances and loss of native vegetation that could impact 

OST trail traces and associated historic period sites. 

The potential for damage or loss of these trail resources 

would be lessened by the use of qualified Resource 

Advisors during fire suppression, but adverse effects 

could result from the need to take immediate actions to 

minimize the size of fires, while still protecting human 

life and property.

The impacts on the scenic qualities and integrity of the 

OST setting related to wildfires and fire suppression 

would be mitigated to the maximum extent possible, 

through ES&R actions to stabilize soils in the short term 

and restore native vegetation in the long term.

4.13.2.2 Impacts from Management of Heritage 

Resources

Under all alternatives, heritage resources would be conserved, protected, and restored for the benefit of present 

and future generations, consistent with the mandates 

from OPLMA. Compliance with the requirements of 

Section 106 of the NHPA would continue under all 

alternatives and would include efforts to identify OST 

traces or associated historic period sites in the NCA and 

evaluate these resources for NHRP eligibility. Should the 

identification of trail-related resources occur as a result 

of undertakings proposed by BLM or others, adverse effects to historic properties would be assessed and avoided 

or mitigated. Through this process, adverse effects would 

be avoided or lessened to the maximum extent possible 

through appropriate mitigation. 

Alternative A does not make specific Use Allocations 

for heritage resources in the NCA or within the OST 

Management Corridor. 

Under Alternatives B, C, and D, heritage resources currently documented or projected to occur in the NCA 

and the OST Management Corridor are designated to 

four Use Allocations: Scientific Use, Conservation for 

Future Use, Public Use, and Traditional Use. These allocations are consistent with the conservation, protection, and enhancement purposes for which the NCA was 

Congressionally-designated through OPLMA. Eligible 

sites or groups of sites would be nominated for inclusion 

to the NRHP, whenever warranted. The integrity of setting and place for heritage landscapes would be conserved, protected, and restored, wherever feasible.

Alternatives B, C, and D allocate all historic roads, 

trails, and associated travel-related sites and features to 

Scientific Use, Conservation for Future Use, and Public 

Use. Class III inventory of each travel corridor would be 

completed to establish baseline data on linear heritage 

resources and associated historic period sites. These use 

allocations would further the goals of OST preservation 

of associated historic period sites by not authorizing 

research studies that would directly impact the integrity 

and information potential of sites and by restricting the 

collection of surface artifacts, unless threatened by loss or 

destruction. The conservation of setting and place would 

be emphasized in Cultural Resource Project Plans, based 

on historic contexts. For sites identified as appropriate for 

Public Use, implementation-level plans would identify 

opportunities for on and off-site interpretation, visitor 

registers, informational and directional signing, and 

other visitor amenities. 

The Use Allocations to Scientific Use and Conservation 

for Future Use would help to conserve and protect OSTassociated historic period sites through the development 

of historic contexts, Cultural Resource Project Plans, and 

restrictions on research studies that would impact site 

integrity, and on the collection of surface artifacts, unless 

threatened by loss or destruction.

The Use Allocations to Public Use would enhance opportunities to provide premier trail visitor experiences, 

through the identification of appropriate historic period 

sites that are associated with the OST for interpretation 

and public appreciation.

4.13.2.3 Impacts from Management of National 

Historic Trails

Under Alternative A, no goals or objectives were identified for the OST, as it had not been Congressionallydesignated to the National Trail System. Management 

actions identified the marking and signing of those portions of the OST that cross public lands. This alternative 

would manage the OST based on the requirements of the 

National Trails System Act, BLM Manual 6280 and adopt 

relevant provisions of the trail-wide Comprehensive Plan 

for the OST, when it has been completed by BLM and the 

NPS as joint administrators.

assessed and avoided or mitigated. Through this process, 

adverse effects would be avoided.

Natural processes, including wildfires, erosion, weed 

infestations and drought, could continue to have impacts 

on the integrity of the trail setting and associated historic 

period sites under all alternatives. These would be mitigated to the extent possible through fire management, 

ES&R actions, noxious weed control and eradication, and 

other management actions proposed to conserve, protect, 

and restore NCA resource values.

Measures to conserve, protect, and restore habitats of 

special status species and other fish and wildlife could 

help protect the setting and associated trail resources of 

the OST, by limiting adverse effects related to new surface 

disturbances, soil erosion, and loss of native vegetation.

Under all alternatives, the BLM would continue to work 

with the NPS and non-federal partners, like the Old 

Spanish Trail Association, to manage the OST. The OST 

Comprehensive Administration Strategy will be used 

to provide guidance for administration of the trail and 

a vision to be fulfilled through future resource-specific 

studies and site and route segment management plans.

4.13.2.1 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

All alternatives would strive to conserve, protect, and 

restore native vegetation communities, through direct 

management actions and through restrictions on land 

uses and specific activities. These goals would be compatible with NHT preservation and management goals, 

particularly as they relate to maintaining the integrity of 

setting for historic trails and associated historic sites and, 

where feasible, restoring native vegetation communities 

that were present during the period of significance for a 

particular NHT. All alternatives propose the control and 

eventual eradication of noxious weeds and invasive species, through Integrated Weed Management, that could 

help to restore native vegetation communities to those 

that would have been present on the landscape in the 

mid-19th century, during the period of significance for 

the OST.

Under Alternative A, the development of fire breaks, 

hazardous fuel reduction projects, and vegetation 

type conversion projects could be authorized, on a 

case-by-case basis in the proposed OST Management 

Corridor and elsewhere in the NCA. These could be 

accomplished through prescriptive fires and grounddisturbing mechanical vegetation treatments, with both 

methods having the potential to damage trail setting and 

resources should they be identified in the proposed OST 

Management Corridor. Compliance with the requirements of Section 106 of the NHPA would continue under 

this alternative and would include efforts to identify OST 

traces or associated historic period sites in the NCA and 

evaluate these resources for NHRP eligibility. Should the 

identification of trail-related resources occur as a result 

of undertakings proposed by BLM or others, adverse effects to historic properties would be assessed and avoided 

or mitigated. Through this process, adverse effects would 

be avoided.

Alternatives B, C, and D also propose the development 

of fire breaks and hazardous fuel reduction projects to 

protect intact, native vegetation communities. Vegetation 

type conversions would not be authorized under any 

of the three alternatives. Alternatives B, and D would 

authorize a range of tools, including herbicides, targeted 

grazing, and mechanized equipment. Alternative C emphasizes the least invasive methods to accomplish these 

projects and would be the most protective of OST properties, through the minimization of surface disturbances. 

As these would be federal undertakings, adverse effects 

to OST-associated historic properties would be avoided 

or appropriate mitigation measures developed through 

consultations under Section 106 of the NHPA.

Potential impacts to the associated setting of the OST 

would be expected to result if large scale fuel reduction 

projects were to be authorized under any of the alternatives. As described above, adverse effects to the integrity 

of the trail setting would also be avoided or appropriate 

mitigation measures developed through consultations 

under Section 106 of the NHPA.

Alternatives B, C, and D identify a range of management actions and tools to restore disturbed and firedamaged areas of the NCA through re-vegetation projects. 

Alternatives B and D, as well as Alternative A, would 

emphasize the use of native species, but provide for the use 

on non-native species when certain criteria are met. Only 

Alternative C would not authorize the use of non-native 

plant species and could, therefore, restore the 19th century 

trailside vegetation in the OST Management Corridor 

where it has been lost to surface disturbances, wildfires, 

and the invasion of exotic annual brome grasses.

Wildfires could continue to negatively impact the scenic 

qualities of the OST Management Corridor by destroying additional acres of native Mojave Desert vegetation, 

particularly the iconic Joshua tree forests that would 

have intrigued early travelers on the OST. Many Mojave 

Desert shrubs are not fire tolerant species and will not 
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NATIONAL HISTORIC TRAILS NATIONAL HISTORIC TRAILS

only allow limited modifications to the character of the 

landscape, and any changes must not attract the viewer’s 

attention. Management under this VRM Class would 

help to preserve the integrity of the associated setting, as 

well as any trail traces, sites and artifacts, minimizing the 

potential for impacts based on authorized land uses 

and activities.

Alternative C would manage 7,544 acres of the OST 

Management Corridor as VRM Class II and 4,962 acres 

under VRM Class I. This alternative would afford the 

highest level of protection level to the associated trail 

setting and the integrity of trail traces, sites, and artifacts. 

Under VRM Class II, the level of change to the characteristic landscape must be very low; under VRM Class I, the 

objective of visual resource management is to preserve 

the existing landscape of the area. The types of developments that could occur within the OST Management 

Corridor would be very limited under this alternative, 

protecting all trail resources and values from land use 

and project-specific impacts.

4.13.2.5 Impacts from Management of Recreation and 

Visitor Services

Greater public awareness of the Congressional 

designation of the NCA, in concert with local and 

regional population growth, is anticipated to attract 

more recreational users to the NCA. Increased recreation 

use could affect the trail setting and any trail traces 

that might be discovered through direct disturbances, 

such as soil compaction or the introduction and spread 

of noxious weeds. If archaeological sites or features 

are identified that are associated with the period of 

significance of the OST in the NCA, the integrity of 

these sites could be impacted by recreational uses that 

destroy features or displace artifacts, by vandalism, and 

unauthorized collection of artifacts.

The potential for these effects increases when recreation 

uses are authorized that alter the visual or audible character of the setting, or when recreational use is concentrated in sensitive areas. The effect of repeated uses 

or visits over time could also increase the intensity of 

effects; repeated visits to sites can create social trails, and 

direct people to trail segments that are too sensitive for 

heavy use or create access to remote segments that were 

previously undisturbed. Developing Wayside exhibits 

with educational and interpretive materials about the 

OST could minimize potential direct and adverse recreation–related impacts, encouraging public stewardship of 

the trail and its historic importance.

Alternative A provides no specific decisions for recreation management associated with the OST, other than to 

identify signing the route where it crosses public lands. 

Public lands of the NCA would continue to be managed 

as part of the SGFO ERMA, which emphasizes little or 

no facilities development and less structured types of 

recreational activities. Dispersed camping, recreational 

prospecting, the use of metal detectors, and geocaching 

would continue to be authorized activities in the ERMA. 

These activities could damage or destroy unidentified 

trail traces and historic period sites or features that are 

associated with the OST, through new surface disturbances, artifact displacement and the potential removal 

of metal artifacts. 

Under Alternatives B, C, and D, more intensive management of recreational uses is proposed through the 

establishment of the Beaver Dam Wash SRMA and the 

preparation of implementation-level plans for recreational activities and visitor services. Three Recreation 

Management Zones would be established within the 

SRMA with specific objectives and a range of authorized 

uses and activities that are compatible with the zone 

management objectives. 

Each of these alternatives would manage dispersed camping in the Frontcountry and Backcountry Zones only in 

designated and previously disturbed campsites that are 

not in close proximity to sensitive natural or cultural resources. Alternatives B and C would prohibit recreational 

metal detecting; Alternative D would only allow metal 

detection that creates minimal surface disturbances. 

Alternatives B and D would limit recreational prospecting to minimally invasive practices, while Alternative 

C would prohibit this activity within the NCA. The 

types and numbers of SRPs would be more intensively 

managed under these alternatives, when compared to 

Alternative A. The more intensive management of all 

types of recreation uses identified in the three action alternatives would lessen the potential for direct, indirect, 

and inadvertent impacts on the integrity of any OST trail 

traces or associated resources and values that might be 

discovered in the NCA.

4.13.2.6 Impacts from Management of 

Comprehensive Travel and Transportation

Travel management without limitation or designation 

can result in adverse effects such as degrading the integrity and setting of sensitive trail segments and associated resources, and unauthorized collection, looting, or 

vandalism of associated archaeological sites. Restricting 

motorized and mechanized vehicle uses to designated 

Compliance with the requirements of Section 106 of 

the NHPA would continue under all alternatives and 

would include efforts to identify OST traces or associated historic period sites in the NCA and evaluate these 

resources for NHRP eligibility. Should the identification 

of trail-related resources occur as a result of undertakings 

proposed by BLM or others, adverse effects to historic 

properties would be assessed and avoided or mitigated. 

Alternatives B, C, and D include goals and objectives to 

conserve, protect, and restore trail resources, qualities, 

values, and associated settings and primary uses and to 

provide premier trail visitor experiences for the benefit 

of the public. A 12,506 acre OST Management Corridor 

would be established under these three alternatives that 

includes the legislatively-designated OST route along Old 

Highway 91 and the potential Armijo Route through the 

NCA. The Management Corridor would be managed as a 

ROW Exclusion area under these alternatives. 

This designated utility corridor that follows, and is 

bisected by Old Highway 9, would be retained under 

Alternatives A, B, and D, but would vary in width by 

alternative. Alternative A would allow the development 

of new utilities, including overhead power transmission 

lines, within a variable width corridor that could be as 

much as 300 feet wide. New installations of this type 

could impact the associated setting of the trail and negatively impact trail visitor experiences. Adverse effects to 

NRHP-eligible trail-related sites, artifacts, and features 

would be avoided through project design or lessened to 

the maximum extent possible through treatment plans 

developed through consultations under Section 106 of 

the NHPA.

Alternative B would limit the width of the designated 

corridor to 100 feet in total width, while Alternative D 

would designate a 200-foot wide corridor. Alternatives B 

and D would minimize the visual intrusions that could 

result from the development of new utilities in the corridor, by limiting them to subsurface installations that 

would create short-term contrasts through disturbances 

to soils and vegetation, but no permanent or visible towers or structures that would impact the integrity of the 

associated setting of the OST. Adverse effects to NRHPeligible trail-related sites, artifacts, and features would be 

avoided through project design or lessened to the maximum extent possible through treatment plans developed 

through consultations under Section 106 of the NHPA.

Alternative C would revoke the designated utility corridor through the NCA, providing the highest level of 

protection for OST properties and the associated setting 

when compared to the three other alternatives. 

Alternatives B, C, and D would emphasize the identification and protection of routes and any associated 

trail features, sites, and artifacts that are identified for 

their historic, scientific, educational, interpretative, and 

recreational values. Altered landscapes within the OST 

Management Corridor would be restored to an identified 

trail-era condition, wherever feasible. Actions to improve 

the naturalness of the Trail Management Corridor would 

include closure and re-vegetation of social trails.

Alternatives B, C, and D identify opportunities for providing interpretation at Welcome or Orientation pullouts and wayside exhibits within the OST Management 

Corridor along Old Highway 91 and the Mojave DesertJoshua Tree Scenic By-way, increasing public awareness and the quality of visitor experiences on the OST 

through various interpretive media.

Alternatives B, C, and D would collaborate with partners (e.g., user groups, trail organizations) to design and 

construct a non-motorized trail to provide retracement 

opportunities within the OST Management Corridor. 

Alternatives B and D would authorize retracement 

opportunities along Old Highway 91 and the Mojave 

Desert-Joshua Tree Scenic By-way, while Alternative C 

would limit retracement opportunities to the Mojave 

Desert-Joshua Tree Scenic By-way. Alternative A identifies no similar action or opportunities.

4.13.2.4 Impacts from Visual Resource Management

Visual resource management has the potential to impact 

the natural scenic qualities of a NHT. Effects to a trail’s 

historic setting can be directly and indirectly reduced, 

where VRM designations limit surface-disturbing activities in areas with higher scenic qualities. Impacts on the 

setting of many types of archaeological sites must be 

considered in the Section 106 process, regardless of VRM 

designation, which provide additional opportunities to 

mitigate adverse effects on historic properties and the 

historic trail landscape.

Under Alternative A, an OST Management Corridor 

would not be designated and the NCA would continue 

to be managed as VRM Class III. Projects or land uses 

that could create moderate and noticeable changes to 

the landscape could be authorized, potentially impacting 

trail properties and the associated setting of the OST. 

Alternatives B and D propose managing the 12,506-acre 

OST Management Corridor and surrounding areas of 

the NCA as VRM Class II. This VRM designation would 
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legislatively-depicted route of the OST and the potential 

Armijo Route through the NCA.

Alternative D would manage 63,352 acres of the NCA 

as a ROW Exclusion area, while retaining the existing 

designated utility and transportation corridor along Old 

Highway 91. This alternative would define the corridor 

width to be 200 feet (128 acres) and would limit new utility ROWs to subsurface installations only within the designated corridor. Impacts to the setting of the OST that 

could result from the construction of new utilities in that 

designated corridor would be lessened by the stipulation 

that ROWs would only be granted for subsurface installations, such as fiber-optic lines. The construction of new 

subsurface installations in the designated corridor would 

result in direct and short-term disturbances to soils and 

vegetation. The potential impacts to the setting of the 

OST related to new subsurface installations in the designated corridor would be negligible to minor, because of 

the narrow width of the corridor, its location on either 

side of a paved highway, and re-vegetation along the 

ROW that would occur in the long term. Adverse effects 

to NRHP-eligible trail-related sites, artifacts, and features 

would be avoided through project design or lessened to 

the maximum extent possible through treatment plans 

developed through consultations under Section 106 of 

the NHPA.

4.13.2.8 Impacts from Management of Public 

Education and Interpretation

Alternative A would mark and sign the OST where it 

crosses public lands, but not provide public education 

outreach or interpretation.

Under Alternatives B, C, D, the OST Management 

Corridor would provide new opportunities for heritage 

tourism and auto-touring along Old Highway 91 and the 

Mojave Desert Joshua Tree Scenic By-way. Public education outreach would be enhanced through Welcome 

Stations, Orientation panels, and wayside exhibits. These 

measures would enhance appreciation and understanding 

of the fragile and finite nature of the NHT and provide 

premier visitor experiences along the OST, fulfilling one 

of the public purposes for which Congress designated the 

OST to the National Trails System in 2002.

4.13.3 Summary of Impacts from Alternatives

Alternative A would not emphasize the identification 

and protection of the historic route and its historic 

remnants and artifacts for public use and enjoyment 

through the identification and management of an OST 

Management Corridor. This alternative would manage 

the OST based on the requirements of the National 

Trails System Act, BLM Manual 6280, and adopt relevant 

provisions of the trail-wide Comprehensive Plan for the 

OST, when it has been completed by BLM and the NPS 

as joint administrators.

The legislatively-designated route along Old Highway 

91 would continue to be managed as VRM III and an 

existing designated utility corridor paralleling this road 

would continue to be available for all types of linear 

ROWs. Impacts to the trail setting could occur under this 

alternative, but would be lessened to the extent possible 

through project design and other mitigation.

Public education outreach related to the OST would be 

limited to the signing of the legislatively-designated route 

through the NCA and would not provide other opportunities for NHT-related education and recreation.

Under Alternatives B, C, and D, the designation of an 

approximately 12,506 acre OST Management Corridor 

would help to further the protection of the setting and 

any physical evidence of the historic trail for public use 

and enjoyment. Management actions are proposed for 

the Management Corridor relating to Recreation and 

Visitor Services, Travel and Transportation Management, 

Visual Resource Management and Lands and Realty that 

are designed to conserve, protect, and restore the integrity of the setting and any trail-related heritage resources 

from adverse effects. These alternatives would also 

provide education and interpretation opportunities that 

would enhance awareness and appreciation of the Old 

Spanish NHT. Direct and indirect, moderate, short and 

long-term beneficial effects would be expected to result 

from implementation of these actions.

4.13.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on the Old 

Spanish NHT was defined as all lands within the Beaver 

Dam Wash NCA and adjacent lands on the Beaver Dam 

Slope of Arizona. Management of the Old Spanish NHT 

outside of the NCA in Washington County would continue as described under Alternative A in the Summary 

of Impacts above, until a revision to the current SGFO 

RMP is completed, at an unknown future date.

Past human-caused actions within the CIAA that have affected the legislatively-designated Northern Route of the 

OST and the potential Armijo Route included the development of late 19th century wagon roads and early 20th 

century auto roads, including Old Highway 91 within the 

travel corridor established by the OST. The development 

of these later transportation routes may have damaged or 

trails generally reduces the risk of these impacts and 

helps protect the integrity and setting of the NHT. The 

closure of areas to multiple methods of travel provides 

the highest level of protection for trail resources. Direct 

effects are identified through inventory of the trail segments, and adverse effects addressed through avoidance 

by redesign or mitigation of roads and trails that could 

impact the OST.

Under all alternatives, the proposed OHV area designation for the OST Management Corridor would be 

Limited to Designated Roads and Trails, providing 

protections to the trail and NHT resources from impacts 

related to off-road travel by motorized vehicles.

Alternatives B, C, and D would collaborate with partners (e.g., user groups, trail organizations) to design and 

construct a non-motorized trail to provide retracement 

opportunities within the OST Management Corridor. 

Alternatives B and D would authorize retracement 

opportunities along Old Highway 91 and the Mojave 

Desert-Joshua Tree Scenic By-way, while Alternative C 

would limit retracement opportunities to the Mojave 

Desert Joshua Tree Scenic By-way. Alternative A identifies no similar action or opportunities.

4.13.2.7 Impacts from Management of Lands and 

Realty

The granting of ROWs across public lands for the development and operation of power transmission lines, 

communication sites, and other land use authorizations 

can impact the setting and associated archaeological resources of an historic trail. Under all alternatives, 

defining Exclusion and Avoidance areas for linear and 

site-type ROWs reduces the potential for effects on NHTs 

related to these land use authorizations. Designating utility and transportation corridors across public lands, and 

siting ROWs within those corridors, may not eliminate 

or reduce the potential for effects on the setting or associated trail resources of a NHT.

According to BLM Manual 6280, to the greatest extent 

possible for national historic trails, BLM must consider 

locating proposed ROWs outside of high potential historic sites and high potential route segments. The BLM 

may approve proposed ROWs, subject to terms and conditions that are related to the policy and purposes of the 

NTSA. The BLM may permit ROWs that will not substantially interfere with NHT purposes, and must make 

efforts, to the extent practicable, to avoid granting ROWs 

that would be incompatible with the purposes for which 

the NHT was designated.

Under Alternative A, the NCA is currently managed as a 

ROW Avoidance area, with the exception of a designated 

utility and transportation corridor of varying widths (totaling 196 acres) that parallels both sides of Old Highway 

91. The legislatively-depicted route of the OST generally 

follows the alignment of Old Highway 91, effectively 

within and adjacent to the designated utility corridor. 

Alternative A would continue to allow new ROWs to be 

granted for utilities in that designated corridor, potentially impacting the associated setting of the OST within the 

boundaries of the NCA. High potential route segments 

have not been identified within the designated utility corridor and no high potential historic sites have yet been 

recorded in that corridor.

Under Alternatives B, C, and D, a majority of the NCA 

would be designated as a ROW Exclusion area, protecting the OST Management Corridor and its resources 

from surface-disturbing activities and visual intrusions 

that could result from the development of linear and sitetype ROWs. Alternative B would manage 63,419 acres of 

the NCA as a ROW Exclusion area, while retaining the 

existing designated utility and transportation corridor 

along Old Highway 91. This alternative would define the 

corridor width to be 100 feet in total width, comprising 

a total of 60 acres, and would limit new utility ROWs 

to subsurface installations only within the designated 

corridor. The construction of new subsurface installations in the designated corridor would result in direct 

and short-term disturbances to soils and vegetation. The 

potential impacts to the setting of the OST related to 

subsurface installations in the designated corridor would 

be negligible because of the narrow width of the corridor, its location on either side of a paved and maintained 

highway, and natural re-vegetation that would minimize 

visual contrasts in the long term. Adverse effects to 

NRHP-eligible trail-related sites, artifacts, and features 

would be avoided through project design or lessened to 

the maximum extent possible through treatment plans 

developed through consultations under Section 106 of 

the NHPA.

Alternative C would manage 63,480 acres of the NCA as 

a ROW Exclusion area and revoke the designated utility and transportation corridor along Old Highway 91, 

subject to valid existing rights. This alternative would 

provide the highest level of protection for the proposed 

OST Management Corridor, when compared to the other 

alternatives, eliminating the potential for new surfacedisturbances and visual intrusions to the setting of the 
690 Chapter 4 BDWNCA BDWNCA Chapter 4 691

NATIONAL NATURAL LANDMARKS NATIONAL NATURAL LANDMARKS

designation is: “The Joshua Tree Natural Area is the only 

Joshua tree forest in Utah and the northernmost stand 

of tree yuccas in the country. The site clearly illustrates 

the flora and fauna of the Joshua tree association and 

includes a number of plants and animals that reach the 

northern edge of their range.”

4.14.1.1 Indicators

Indicators of adverse impacts to the NNL include the 

following:

▶ Degradation of the values for which the area received NNL designation.

Indicators of beneficial effects to the NNL include the 

following:

▶ Protection of the values for which the area received 

NNL designation.

4.14.1.2 Assumptions

The analysis includes the following assumption:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ The management goals and objectives of the Beaver 

Dam Wash NCA RMP will accomplish protection 

for the NNL by providing management prescriptions that preserve the ecological values for which 

the NNL was designated.

Implementing management for the following resources 

or resource uses would have negligible or no impact on 

the NNL and are, therefore, not discussed in detail: Air 

Quality, Water Resources, Geologic and Paleontological 

Resources, Cave and Karst Resources, Soil Resources, 

Vegetation Resource Uses: Plant Materials, Special Status 

Species, BLM Sensitive Species, Other Fish And Wildlife 

Species, Heritage Resources, National Historic Trails, 

Lands with Wilderness Characteristics, and 

Natural Soundscapes.

4.14.2 Direct and Indirect Impacts

4.14.2.1 Impacts from Management of Native 

Vegetation, and Fire and Fuels

Under all alternatives, the Native Vegetation 

Communities and Fire and Fuels Management goals 

and objectives are to conserve, protect, and restore native Mojave Desert vegetation communities. 

All alternatives provide for the use of native plant species for restoration and rehabilitation. Alternative A 

would authorize the use of non-native species, if natives 

were unavailable or deemed to be too expensive for 

use. Non-native species that have not been scientifically 

evaluated relating to the benefits or impacts of their use 

in the Mojave Desert could continue be introduced in the 

NNL, with uncertain long-term outcomes. 

Alternatives B and D would also allow use of non-native 

species, but only under very specific conditions and with 

constraints that would prevent the introduction of species that have not been scientifically evaluated for use in 

the Mojave Desert.

Alternatives B, C, and D would provide for implementation-level restoration plans, use of microsite/fertile islands, 

carbon sequestration, use of supplemental water sources 

and inoculation of cryptogamic soil crust with mycorrhizae would have a beneficial effect on efforts to re-vegetate 

disturbed and fire-damaged lands in the NNL. 

Under Alternative A, fire management actions would 

include full suppression, but with some options for 

minimum impact tactics in special status species’ habitats. These options could be less successful at protecting 

unburned vegetation, given the rapid spread of fire that 

is possible in the Mojave Desert when fueled by invasive 

brome grasses. The use of backburning as part of suppression tactics could continue to be authorized, damaging or destroying unburned native vegetation in an effort 

to reduce fire size and spread. 

The rapid employment and appropriate suppression 

responses to minimize fire size and duration in the NCA 

is common to Alternatives B, C, and D. The use of heavy 

equipment and the construction of fire line would damage or destroy some native vegetation, but the impacts 

would be less extensive than what could result from 

large-scale backburning. The use of backburning would 

be evaluated under Alternatives B and D, and minimized 

to the extent possible. Alternative C would not authorize 

the use of backburning as suppression tool except when 

deemed essential to protect human life, property and the 

effective control of the fire. 

Under Alternatives B, C, and D, intact native vegetation 

communities in the NNL would be conserved and protected to the extent possible from the damaging effects of 

future fires, through appropriate fire suppression tactics. 

Limitations on the use of backburning under these alternatives would better protect unburned vegetation in the 

NNL than would management under Alternative A.

destroyed trail traces and historic period sites that were 

associated with the period of significance for the OST. 

Other past actions in the CIAA that may have affected 

the OST included overgrazing of public rangelands, 

water developments and diversions, range improvements and vegetation treatments, and major interstate 

utilities developments in the designated IPP and NavajoMcCullough corridors, located adjacent to, but outside 

of, the NCA boundaries. Natural factors have included 

the introduction and spread of noxious weeds and invasive species, wildfires, soil erosion, and flooding of the 

Beaver Dam Wash and its tributary drainages.

Present and reasonably foreseeable future actions would 

include continued regional population growth, the expansion of local communities near the NCA, like Beaver Dam 

and Littlefield, Arizona, hazard fuel reduction treatments, 

noxious weed control, and increasing recreational uses 

of public lands. Livestock grazing is expected to continue 

on public and private lands in the CIAA. Natural factors 

will continue to include wildfires fueled by exotic brome 

grasses, droughts, and wind and water-caused soil erosion. 

The construction of new overhead power transmission 

lines in the one-mile wide IPP and Navajo-McCullough 

designated corridors, located outside of the NCA, would 

be expected to occur as reasonably foreseeable future 

actions. Existing power transmission lines in these corridors are visible from some locations within the OST 

Management Corridor, particularly along the potential 

Armijo Route through Bulldog Canyon in the NCA. 

New utility developments could minimally impact the 

associated setting of the OST and the quality of visitor 

experiences in localized areas within the Management 

Corridor, but would not comprise a substantial interference with the nature and purposes of the NHT.

Developments could also occur on the private and state 

lands within the legislatively-depicted Northern Route 

and the potential Armijo Route through the NCA. These 

developments could also minimally impact the associated trail setting and quality of visitor’s experiences within 

localized areas within the OST Management Corridor. 

Climate change within the CIAA could cause an increase 

or decrease in temperatures and precipitation, which 

would affect soil conditions, vegetation distribution, 

water flows, water quality, and water temperature. Such 

changes would alter the conditions to which vegetation 

communities are adapted, potentially creating conditions 

that could favor certain species or communities, weeds, 

or pests. 

The cumulative impacts on the Old Spanish NHT in 

the CIAA would be primarily beneficial effects that are 

moderate to major in scope and intensity. Congressional 

segregations, management, and uses identified in 

OPLMA at Section 1975 for the Beaver Dam Wash NCA 

provide protections for all types of heritage resources on 

63, 480 acres of public land from: entry, appropriation, 

and disposal under the public land laws; location, entry, 

and patenting under the mining laws; and operation of 

the mineral leasing, mineral materials, and geothermal 

leasing laws. All alternatives would provide a similar 

level of conservation and protection for trail resources, 

within the context of undertakings and compliance 

with the requirements under Section 106 of the NHPA. 

Management goals, objectives, and decisions for the Draft 

RMP have been developed to emphasize the resource 

conservation, protection, and enhancement purposes for 

which the NCA was Congressionally-designated in 2009. 

Implementing guidance from the OST Comprehensive 

Administration Strategy could increase public awareness 

of the trail and trail resources and assist in the protection 

of these values, reducing the potential for adverse cumulative impacts in the long term.

4.14 NATIONAL NATURAL LANDMARKS

The NNL Program recognizes and encourages the conservation of sites that contain outstanding biological and 

geological resources. It is the only natural areas program 

of national scope that recognizes the best examples of 

biological and geological features in both public and 

private ownership. NNLs are owned by a variety of land 

stewards, and participation in the program is voluntary.

The approximately 1,047-acre Joshua Tree NNL is located 

entirely within the NCA (Map 3-19). NPS registered this 

area to the National Landmark System in 1966 because 

the Joshua tree forest was considered to be the best example of this natural community at the northern extreme 

of its range in the Mojave Desert. Sadly, catastrophic 

wildfires in 2005-2006 damaged or destroyed many of 

the Joshua trees of the NNL.

This section analyzes impacts to the NNL from proposed 

management actions described in Chapter 2. Existing 

NNL conditions are described in Section 3.14.3 National 

Natural Landmark.

4.14.1 Methods of Analysis

Impacts to the NNL are analyzed by how the proposed 

management actions in the Chapter 2 alternatives 

could enhance or detract from the criteria which led 

to NNL designation. The NPS description for the 1966 
692 Chapter 4 BDWNCA BDWNCA Chapter 4 693

4.14.2.2 Impacts from Management of Noxious 

Weeds and Invasive Species

Under all alternatives, an Integrated Weed Management 

approach and relevant standard operating procedures 

would be employed to control and eradicate weed and 

exotic invasive species infestations in the short and 

long term. Alternatives B, C, and D identify a slightly 

variable range of tools in the management of noxious 

weeds and invasive species, including the potential 

use of biological controls, under project-specific plans. 

Biological controls for invasive annual brome grasses 

are currently in the experimental stage and may never 

be applicable on a broad scale, even over the life of the 

RMP. Alternatives A, B, and D would also allow chemical control of noxious weeds and invasive species in 

unburned vegetation communities. 

Reductions in the biomass of exotic invasive brome grasses 

would lessen the potential that future wildfires would 

damage or destroy the remaining mature Joshua trees 

within the current NNL or intact Joshua tree forests that 

might be included within the adjusted NNL boundaries.

4.14.2.3 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing

Livestock grazing would continue to impact the native vegetation, soils, and natural appearance of the 

NNL in localized areas under Alternatives A, B, and D. 

Approximately 185 acres of the 1,047-acre NNL is currently within the fenced Woodbury Desert Study Area 

and would remain unavailable to livestock grazing under 

all alternatives. If the boundaries of the NNL were to be 

adjusted to include unburned areas within the NCA, some 

or all of the native vegetation of the NNL could continue 

to be impacted by grazing under Alternatives A, B, and 

D. Under Alternatives A and D, livestock numbers would 

remain at current levels and managed under the current 

fall, winter, or early spring seasons of use. Livestock would 

continue to selectively graze on Joshua tree flowers and 

seed pods during the spring, reducing the reproductive 

success of this species and the potential that natural revegetation in fire-damaged areas of the NNL can occur.

Alternative B would reduce the number of AUMs 

that would be authorized by 60 %, when compared to 

Alternatives A and D, providing a higher level of protection for the natural values of the NNL. This alternative 

would lessen the impacts of livestock grazing on Joshua 

trees, as fewer head of cattle would be permitted or the 

grazing period shortened.

Alternative C would offer the most protection for the 

NNL regardless of location, as the entire NCA would be 

unavailable for livestock grazing over the life of the RMP. 

Under this alternative, the reproductive success of Joshua 

trees would not be impacted by livestock, enhancing the 

likelihood that natural re-vegetation in fire-damaged 

areas of the NNL can occur.

4.14.2.4 Impacts from Management of National 

Natural Landmarks

The approximately 1,047-acre Joshua Tree NNL is 

located entirely within the NCA (Map 3-19). The NPS 

registered this area to the National Landmark System 

in 1966 because the Joshua tree forest was considered 

to be the best example of this natural community at the 

northern extreme of its range in the Mojave Desert. 

Sadly, catastrophic wildfires in 2005-2006 damaged or 

destroyed many of the Joshua trees of the NNL. Under 

Alternative A, current management of the NNL would 

continue under the decisions related to other resource 

uses and programs.

Alternatives B, C, and D propose to coordinate with the 

NPS to administratively adjust the boundaries of the NNL 

to encompass areas of the NCA where mature Joshua tree 

forests remain undamaged by wildfires. Interpretive signing would be provided on and off-site to enhance visitor 

experiences of the NNL and its ecological values.

4.14.2.5 Impacts from Management of Visual 

Resources

Managing the NNL as VRM Class II in Alternatives 

B and D would provide indirect protection for scenic 

values. In Alternative C, approximately 50% of the NNL 

would be managed as VRM Class I for the protection of 

wilderness characteristics. The VRM Class I is overlapped 

by the Primitive Recreation Management Zone which 

prohibits motorized use and allows for no trail construction. VRM classes proposed under Alternatives B, C, and 

D would provide a higher level of protection for the natural resource values of the NNL from development-related 

impacts than would Alternative A, which would continue 

to manage the NNL under VRM Class III.

4.14.2.6 Impacts from Management of Recreation and 

Visitor Services

Public lands of the NCA would continue to be managed 

as part of the SGFO ERMA, which emphasizes little or 

no facilities development and less structured types of 

recreation activities. Dispersed camping, the use of metal 

detectors, and geocaching would continue to be authorized activities in the ERMA. Dispersed camping could 

NATIONAL NATURAL LANDMARKS NATIONAL NATURAL LANDMARKS

increase the risk of human-caused fires and could damage or destroy Joshua trees and other native vegetation 

in the NNL through surface disturbances and cutting or 

collection of firewood for campfires. 

Under Alternatives B, C, and D, more intensive management of recreation uses is proposed through the 

establishment of the Beaver Dam Wash SRMA and the 

preparation of implementation-level plans for recreational activities and visitor services. Three Recreation 

Management Zones would be established within the 

SRMA with specific objectives and a range of authorized 

uses and activities that are compatible with the zone 

management objectives. 

Each of these alternatives would manage dispersed camping in the Frontcountry and Backcountry Zones only in 

designated and previously disturbed campsites that are 

not in close proximity to sensitive natural resources. The 

types and numbers of SRPs would be more intensively 

managed under these alternatives when compared to 

Alternative A. The more intensive management of all 

types of recreation uses identified in the three action alternatives would lessen the potential for direct, indirect, 

and inadvertent impacts on the natural values, including 

the remaining Joshua trees, of the NNL.

4.14.2.7 Impacts from Management of 

Comprehensive Travel and Transportation

Under Alternative A, motorized vehicle access to the 

NNL would continue to be available, as the unimproved 

road into the NNL from the Mojave Desert Joshua Tree 

Scenic By-way was designated by Congress as open to 

public use (OPLMA at Section 1975).

Under Alternatives B, C, and D, motorized vehicle travel 

would be managed under the OHV area designation 

Limited to Designated Roads and Trails. Coordination 

between BLM and the NPS relating to the administrative 

adjustment of the NNL boundary would help to ensure 

that public motorized vehicle access is maintained to 

facilitate visitation and interpretation of the NNL and its 

ecological values.

4.14.2.8 Impacts from Management of Public 

Education and Interpretation

Alternatives B, C, and D provide for the development of 

educational and interpretive materials, through various 

media and venues, to inform visitors about the resource 

values of the NNL and appropriate public land etiquette 

to protect native vegetation communities and prevent 

wildfires. Alternative A contains no similar management 

actions. Increased public awareness of and appreciation 

for the ecological significance of the Joshua tree forest 

could foster greater stewardship of this iconic Mojave 

Desert species, benefitting all natural resources of the 

NNL, over the life of the RMP.

4.14.2.9 Impacts from Management of Scientific 

Research

Under Alternatives B, C, and D, research opportunities 

would be pursued that further the scientific 

understanding of post-fire recruitment of Joshua trees in 

the NNL and increased understanding of the distribution 

and abundance of yucca moths and other pollinators. 

Increased knowledge could result in the development 

of new methods to improve the success of native desert 

shrub re-vegetation efforts and, in the long term, help to 

ensure that mature Joshua tree forests again cover 

the NNL.

4.14.3 Summary of Impacts from Alternatives

Proposed management under all alternatives would 

directly or indirectly benefit the Mojave Desert ecological values for which the NNL was administratively 

designated by the NPS to the National Landmark System 

in 1966. Alternatives B, C, and D would prioritize the 

protection of late successional shrublands, including 

unburned Joshua trees in the NNL and elsewhere in the 

NCA, through appropriate fire suppression tactics and 

hazardous fuel reduction. Restoration of fire damaged 

native vegetation communities would emphasize the 

use of native species and minimize disturbances to soils 

and biological soil crusts, to prevent noxious weed and 

exotic invasive species infestations. Management alternatives for other resource programs and uses would further 

the goals of conservation and protection of the Mojave 

Desert ecological values that warranted administrative 

designation, within the current or adjusted boundaries of 

the NNL.

4.14.4 Cumulative Impacts

The CIAA is defined as the Mojave Desert ecosystem of 

the Beaver Dam Slope in Utah. Past activities that have 

impacted the native vegetation communities of the CIAA 

included overgrazing of public rangelands, range improvements, vegetation treatments, and post-fire ES&R 

projects. Natural factors included droughts and the 

introduction and spread of noxious weeds and invasive 

species that altered the natural fire regime of the Mojave 

Desert. Over the past 20 years, exotic invasive brome 

grasses have fueled the catastrophic wildfires that burned 

or reburned 80% of the blackbrush-Joshua tree communities in the NCA. 
694 Chapter 4 BDWNCA BDWNCA Chapter 4 695

AREAS OF CRITICAL ENVIRONMENTAL CONCERN VISUAL RESOURCES

ESA related to BLM-authorized or implemented land 

uses and activities would continue to be in force on 

public lands, should the ACEC designation be administratively revoked by BLM, minimizing the potential 

for short or long-term impacts on desert tortoises and 

critical habitat.

4.15.3 Summary of Impacts from Alternatives

National Conservation Area status provides protections that are equal to or superior to those provided by 

ACEC designation for all relevant and importance values. 

Retaining the ACEC designation would be redundant and 

unnecessary. The ACEC designation would also be revoked for the 3,447 acres of the ACEC that are outside the 

NCA, but within two designated utility corridors. These 

acres support populations of threatened Mojave desert 

tortoise and are designated critical tortoise habitat, but legal requirements for compliance under the ESA related to 

BLM-authorized or implemented land uses and activities 

would continue to be in force on public lands, minimizing the potential for short or long-term impacts on desert 

tortoises and critical habitat.

4.15.4 Cumulative Impacts

The cumulative impacts analysis area (CIAA) is designated critical tortoise habitat in Washington County, Utah; 

in Mohave County, AZ north of Limekiln Canyon; and in 

Lincoln County, Nevada, east of Mormon Peak.

There would be no cumulative adverse impacts from 

revoking the Beaver Dam Slope ACEC within the CIAA, 

as Congressionally-mandated segregations, management, 

and uses for the Beaver Dam Wash NCA provide equal 

or higher levels of special management for the relevance 

and importance values related to a majority of land uses 

and authorized actions. Alternatives B, C, and D propose 

goals, objectives, and management actions that would 

provide similar or higher levels of protection than the 

management prescriptions identified under Alternative 

A (No Action). The ACEC designation would remain in 

Alternative A, but would provide no additional protection for the relevance and importance criteria.

4.16 VISUAL RESOURCES

This section analyzes potential impacts to visual resources from proposed management actions described in 

Chapter 2. Existing conditions are described in Section 

3.15, Visual Resources.

4.16.1 Methods of Analysis

Impacts to visual resources are analyzed by how the 

proposed VRM classifications in the Chapter 2 alternatives could alter the visual appeal of the existing landscape, which is described in Chapter 3 through a VRI. 

A VRI is a systematic process designed to determine the 

extent and quality of visual resources in a given area. 

The two main components of a VRI are Scenic Quality 

and Sensitivity. These two components, combined with 

Present and reasonably foreseeable future actions that 

could benefit the protection of the NNL values within 

its current boundaries would include increased efforts 

to create landscape level fire breaks, noxious weed and 

invasive species control efforts, management of habitats 

to recover special status species, and restrictions on land 

uses and authorized activities in furtherance of the conservation, protection, and enhancement purposes of the 

NCA. Changes to livestock grazing management could 

lessen the impacts of the selective grazing by cattle on 

Joshua tree flowers and seed pods, potentially increasing 

the reproductive success of this species.

4.15 AREAS OF CRITICAL ENVIRONMENTAL 

CONCERN

This section analyzes impacts to Areas of Environmental 

Concern (ACECs) from proposed management actions described in Chapter 2. Existing ACEC conditions are described in Section 3.14.4, Areas of Critical 

Environmental Concern.

4.15.1 Methods of Analysis

The analysis of potential impacts to the Beaver Dam 

Slope ACEC compares the existing ACEC management 

prescriptions from the SGFO RMP to the Congressional 

segregations, management, and uses identified for the 

NCA in OPLMA and proposed management goals, 

objectives, actions in Alternatives B, C, and D that would 

address land uses and authorized activities not addressed 

by Congress in the NCA legislation.

4.15.1.1 Indicators

Indicators of adverse impacts on ACECs include the 

following:

▶ Degradation of the relevant and important values 

for which the area was proposed or designated.

Indicators of beneficial effects on ACECs include the 

following:

▶ Protection of the relevant and important values for 

which the area was proposed or designated.

4.15.1.2 Assumptions

The analysis includes the following assumption:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ The goals, objectives, and management direction from the Beaver Dam Wash NCA RMP 

would accomplish resource protection by providing management prescriptions that, in concert 

with Congressionally-mandated segregations, 

management, and uses, are equal to or superior to 

those provided by ACEC designation.

4.15.2 Direct and Indirect Impacts

The Beaver Dam Slope ACEC is 49,269 acres in size, with 

45,822 acres (93%) located inside the NCA, and 3,447 

acres (7%) outside the NCA. The ACEC acreage that is 

outside the NCA boundary is entirely within two designated utility corridors that border the NCA, the IPP and 

Navajo-McCullough corridors.

The relevance and importance values for which this ACEC 

was designated in the SGFO RMP were the threatened 

Mojave desert tortoise, other at-risk Mojave Desert plant 

and animal species, and the natural values and research 

potential of the Joshua Tree NNL and the Woodbury 

Desert Study Area. Management prescriptions for the 

ACEC were developed to prevent the loss or disturbance 

of critical habitat for the desert tortoise and the natural 

resource values of the area.

Revoking the administrative designation of the Beaver 

Dam Slope ACEC, where it overlaps the NCA, would not 

result in lesser levels of protection for the relevance and 

importance values of the ACEC. As shown in Table 4-7, 

Congressional segregations, management, and uses identified in OPLMA at Section 1975 provide protections that 

are equal or superior to those provided by ACEC designation for: entry, appropriation, and disposal under the 

public land laws; location, entry, and patenting under the 

mining laws; and operation of the mineral leasing, mineral materials, and geothermal leasing laws. Alternatives 

B, C, and D propose management decisions that would 

provide similar or higher levels of protection than the 

management prescriptions identified under Alternative 

A (No Action). The ACEC designation would remain in 

Alternative A, but would provide no additional protection for the relevance and importance criteria.

The 3,447 acres of the ACEC that are located outside 

the NCA, and within the designated IPP and NavajoMcCullough utility corridors, are also within designated 

critical habitat for the Mojave desert tortoise and support tortoise populations. Neither designated corridor 

crosses the Joshua Tree NNL or the Woodbury Desert 

Study Area. Requirements under the ESA, including 

consultation under Section 7 with the USFWS, would 

continue to address mitigation/compensation for the 

adverse modification of critical habitat and “take” of 

tortoises, whenever new utility developments or modifications to existing ROWs are proposed in either corridor. The legal requirements for compliance under the 

Existing Beaver Dam Slope ACEC Management Prescriptions Beaver Dam Wash NCA Legislative Withdrawals (OPLMA) 

and Proposed Management Alternatives

Fluid Mineral Leasing Category 3 - No Surface Occupancy Withdrawn from operation of mineral leasing, mineral materials, and geothermal leasing laws

Mining Plans of Operation required Withdrawn from entry, location, and patenting under the 

mining laws, subject to valid existing rights

Closed to mineral material sales Withdrawn from operation of mineral leasing, mineral materials, and geothermal leasing laws

Retain lands in public ownership unless transfer would benefit 

desert tortoise recovery

Withdrawn from entry, appropriation, and disposal under the 

public land laws

Non-federal inholdings may be acquired through purchase, 

exchange, or donation and would be managed under ACEC 

prescriptions

Acquired lands become part of the NCA and are withdrawn 

from operation of public land laws, mining law, mineral leasing, mineral materials, and geothermal leasing laws

Motorized vehicles uses “Limited to Designated” Roads Motorized vehicle uses “Limited to Designated” Roads

ROW Avoidance Area ROW Exclusion Area-Alternatives B, C, D

VRM Class III VRM Class II-Alternatives B, C, D

Closed to commercial and non-commercial fuelwood 

harvesting

Closed to commercial and non-commercial fuelwood harvesting-Alternatives B, C, D

Closed to commercial and non-commercial seed harvesting Closed to commercial and non-commercial seed harvestingAlternatives B, C, D

Table 4-7 Impact Analysis for Revocation of the Beaver Dam Slope ACEC Designation
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VISUAL RESOURCES VISUAL RESOURCES

4.16.2.1 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Landscape-level fuel breaks and vegetation treatments 

to control invasive non-native annuals and restore native species are proposed in the NCA in Alternatives 

B, C, and D. A variety of methods for the fuel breaks 

and vegetation treatments are proposed. Alternative D 

includes any combination of biological controls, flaming, herbicides, mechanical methods, and hand removal. 

Alternative B has an identical suite of options, minus the 

flaming. Alternative C proposes the most conservative 

methods of treatment, limited to low-invasive mechanical options and hand removal only.

Improperly designed or located fuel breaks could require intensive manipulation of vegetation, have a direct 

impact on the scenic quality, and could be out of compliance with proposed VRM Class II. The sensitivity rating 

of the landscape could also be impacted as the entire 

Old Highway 91 viewshed could be affected. Fuel break 

design calls for the use of topographic features, water 

courses, ephemeral drainages, road networks and utility 

corridors. Utilization of these natural and constructed 

features would lessen the impact on native vegetation and 

help preserve the quality of the existing viewshed.

Despite this, impacts would likely occur in all alternatives, with varying levels of intensity. Even when done 

with care, landscape level fuel breaks and vegetation 

treatments would negatively impact the scenic quality of the NCA landscape in the short term. Impacts in 

Alternative D could range from moderate to major, depending on the scale of the project and the tools selected. 

Alternatives B or C could range from minor to moderate 

because the tool section would be more restricted. In 

all alternatives, it would be possible to be out of compliance with VRM objectives in the short term (less than 

five years). Over the long term, as restoration projects 

increase the abundance and distribution of native vegetation and the landscape regains a more natural looking 

appearance, it is anticipated that even VRM Class II 

objectives would be met.

While large fuel breaks are not a desirable option for a 

scenic landscape, they may be required to protect special status species’ habitats or other resource values. A 

well-designed fuel break would work to preserve scenic 

quality, which could be lost for decades in the event of a 

catastrophic wildfire.

Fire suppression in the NCA calls for immediate full suppression due to the presence of invasive brome species 

capable of fueling catastrophic wildfires, a non-fire 

adapted landscape, and the presence of critical tortoise 

habitat. Alternative A would continue to allow backburning within the NCA as a fire suppression tactic, 

while Alternative C would prohibit use of this tactic in 

late successional scrublands, Joshua tree communities, 

and blackbrush dominant landscapes, to minimize the 

loss of unburned native vegetation to fire suppression. 

Alternatives B and D identify the potential for backburning to be authorized but it would require pre-approval 

from the NCA Manager (Alternative B) or the on-scene 

Resource Advisor (Alternative D).

Wildland fire can cause great contrast to the natural 

landscape, removing large swaths of vegetation and 

leaving behind visible scars. Fire and fire suppression 

can have dramatic impacts to visual resources but can 

also preserve larger areas that would have otherwise 

burned over. Prohibiting backburning, or restricting it to 

those situations where it is absolutely necessary, has the 

potential to protect large swaths of unburned landscape, 

which would preserve the NCA scenic qualities. Because 

of the potential variability in fire starts, fire behavior, 

and employed suppression techniques, it is not possible 

to quantify potential impacts, but they could range from 

minor to major.

4.16.2.2 Impacts from Management of Noxious 

Weeds and Invasive Species

A variety of methods for managing noxious weeds are 

proposed. Alternative D includes any combination of biological controls, flaming, herbicides, mechanical methods, and hand removal. Alternatives A and B have an 

identical suite of options, minus the flaming. Alternative 

C is the most conservative, with hand removal only.

Noxious weed management would require intensive manipulation of vegetation and could have a direct impact 

on scenic quality. Impacts could occur in all alternatives, 

with varying levels of intensity. Impacts in Alternative D 

could range from minor to moderate, depending on the 

scale of the project and the tools selected. Alternative B 

could range from negligible to minor for the same reasons. Over the long term, management of noxious weeds 

in Alternatives A, B, and D could have positive effects on 

scenic quality. Given the potential variability of noxious 

weed control results, it is not possible to quantify the 

intensity of any beneficial effects.

Alternative C would restrict noxious weed treatments 

to hand removal methods, only. Not allowing spraying 

would likely diminish scenic quality over time because 

distance zones, form a VRI. By overlaying these components in GIS, the combination of attributes determine the 

inventory class, VRI Class I, II, III, or IV. A VRI is only 

an inventory; it is not a land use plan decision. Its purpose in the planning process is to disclose the potential 

impacts/effects to the public and to the decision maker.

Because every acre of public land is required to have 

a VRM Class, impacts to visual resources are easily 

quantified. For example, if a change was proposed from 

VRM Class II to VRM Class III, more surface disturbing 

activities could be allowed and this would have greater 

potential impacts to the VRI classes of Scenic Quality 

and Sensitivity. If the reverse decision were true, the VRI 

Classes would receive greater protection and the effects 

would be beneficial.

Adverse impacts to Visual Resources could result from 

management actions that diminish any of the fundamental components of Scenic Quality or Sensitivity listed 

in the indicators section below. Beneficial effects could 

result from management actions that maintain or protect 

Scenic Quality and Sensitivity.

4.16.1.1 Indicators

Indicators of adverse impacts on visual resources include 

the following:

▶ A proposed VRM class that could allow a degradation of the existing Scenic Quality rating;

▶ A proposed VRM class that could allow surface 

disturbing activities to a landscape with a high 

Sensitivity rating.

Indicators of beneficial effects on visual resources include 

the following:

▶ A proposed VRM Class that offers equal or greater 

protection of existing Scenic Quality and Sensitivity 

ratings.

4.16.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources in the 

NCA.

▶ More protective VRM Classes are consistent with 

the values described in the enabling legislation for 

the NCA;

▶ Scenic vistas within the NCA would become more 

valuable over time, increasing in sensitivity, as measured by public concern or interest;

▶ Architectural design standards that create a unique 

and recognizable identity for the NCA would be 

incorporated during the design phase for all new 

surface disturbing projects, regardless of size or 

potential impact to visual resources.

Implementing management for the following resources or 

resource uses would have negligible or no impact on visual 

resources and are therefore not discussed in detail: Air 

Quality, Water Resources, Geologic and Paleontological 

Resources, Cave and Karst Resources, Soil Resources, 

Vegetation Resource Uses: Plant Materials, Special Status 

Species, BLM Sensitive Species, Other Fish and Wildlife 

Species, Heritage Resources, Natural Soundscapes, Public 

Education and Interpretation, and Scientific Research.

4.16.2 Direct and Indirect Impacts

Visual Resources in the NCA are primarily influenced by 

the volume and density of developments within the two 

one-mile wide designated corridors that are outside the 

NCA, but along its boundaries, by utility developments 

within the designated utility corridor within the NCA 

along Old Highway 91, and by the potential for additional large scale wildfires that will further damage the scenic 

qualities of the NCA, by removing native vegetation 

communities and increasing the proliferation of invasive 

annual brome grasses.

Alternative A would continue to manage the 63,480 acres 

of NCA as VRM Class III, under which the existing character of the landscape must be partially retained and the 

level of change to the characteristic landscape moderate.

Alternatives B, C, and D each identify a different management emphasis for visual resources. Because utility 

development has the most significant impact, the VRM 

management class alternatives are a mirror image of the 

ROW alternatives in the Lands and Realty section.

Alternatives B and D would manage 63,480 acres as 

VRM Class II, requiring that the existing character of 

the landscape is retained and that the level of change to 

the characteristic landscape should be low. Management 

under this VRM Class would provide a higher level of 

protection for the scenic qualities of the NCA than would 

Alternative A, as developments that result in obvious 

changes to the characteristic landscape would 

not be authorized.

Alternative C proposes the most restrictive management 

of visual resources, with 16,564 acres of the NCA managed as VRM Class I and 46,916 acres as VRM Class II. 

Class I management would be the most protective of the 

scenic qualities of the NCA, as the level of change to the 

characteristic landscape must be very low and must not 

attract attention.
698 Chapter 4 BDWNCA BDWNCA Chapter 4 699

VISUAL RESOURCES VISUAL RESOURCES

The Congressionally-defined purposes for NCA designation and the segregations from OPLMA at sec. 1975 

related to all forms of entry, appropriation, and disposal 

under the public land laws; location, entry, and patenting 

under the mining laws; and operation of the mineral leasing, mineral materials and geothermal leasing laws would 

provide protections that are equal or superior to those 

provided by ACEC designation for visual resources in 

all alternatives. ACEC designation would remain under 

Alternative A, but would provide no additional protection for the relevance and importance values. For a more 

detailed analysis that compares current ACEC management prescriptions to proposed NCA management 

prescriptions, please see Table 4-7 Impact Analysis for 

Revocation of the Beaver Dam Slope ACEC Designation.

4.16.2.7 Impacts from Management of Visual 

Resources

Impacts to visual resources are analyzed by how the proposed VRM classifications in the Chapter 2 alternatives 

could alter the visual appeal of the existing landscape, 

which is described in Chapter 3 through a VRI. The 

two main components of the BDWNCA VRI are Scenic 

Quality and Sensitivity. These are described in Chapter 3.

Alternative A would continue to manage the entire land 

base of the NCA under VRM Class III, which allows for 

moderate changes to the landscape and would not preclude most types of surface disturbing activities.

At a landscape level, VRM Classes I and II afford more 

protection to areas with high scenic quality and/or highly 

sensitive landscapes. VRM Class III and IV provide 

progressively fewer protections. To adequately analyze 

potential impacts to the visual landscape of the NCA, it is 

necessary to understand the proposed VRM designations 

in each of the action alternatives. 

Alternatives B and D propose to manage the NCA under 

VRM Class II. Alternative C proposes to manage 46,916 

acres of the NCA as VRM Class II and 16, 564 acres 

under VRM Class I. Alternative C provides the highest 

protection for visual resources, in concert with the proposed management of the entire NCA a ROW Exclusion 

area. No highways, roads, or utility development would 

be allowed in this alternative. 

Designating all acres as VRM Class II with an overlapping designation of ROW Exclusion, would prohibit 

surface disturbing activities and protect all components 

of the VRI. The beneficial effects would be both direct 

and indirect, as the scenic quality of NCA would be 

preserved by prohibiting future utility, road, and highway 

development. This alternative would also protect the high 

sensitivity of the Highway 91 viewshed. 

Alternatives B and D are identical and slightly less protective of visual resources than Alternative C. In these 

two alternatives, a narrow ROW corridor would be designated on both sides of Highway 91. Utility development 

would be limited to underground installations, similar 

to the existing fiber-optic lines already on the east side 

of the highway. Because the underground installation is 

low impact to visual resources, VRM Class II designation 

remains in both alternatives. 

For Alternatives B and D, there could be minor impacts 

to visual resources from underground utility installation. These impacts would be temporary and reclamation 

would meet VRM Class II objectives. Impacts would be 

negligible to minor.

4.16.2.8 Impacts from Management of Lands with 

Wilderness Characteristics

There are two areas within the NCA where the SGFO 

inventory shows that lands with wilderness characteristics are present. Both of the lands with wilderness characteristics areas are entirely within the Congressionallyidentified Designated Road Areas, within which 

Congress designated a small number of existing roads 

for public motorized vehicle travel, through OPLMA 

at Section 1975. Managing those areas specifically to 

protect their wilderness characteristics is proposed only 

in Alternative C, and only where lands with wilderness characteristics are overlapped by the Primitive 

Recreation Management Zone. One of the proposed 

management prescriptions is VRM Class I. 

The two lands with wilderness characteristics areas contain a small number of primitive motorized routes. Those 

routes were closed by Congress in OPLMA. Neither of 

the two areas contains non-motorized trails, either existing or proposed in the TMP. One of the two areas is within critical desert tortoise habitat. Both of the areas are 

entirely within the NCA. Both of the areas are within the 

proposed Primitive Recreation Management Zone which 

prohibits motorized use and allows for no trail construction. Because of the combination of these factors, any 

surface disturbing activities would be prohibited, regardless of any decision to manage specifically for the protection of lands with wilderness characteristics.

Alternative A would continue to manage the entire land 

base of the NCA under VRM Class III, which allows 

for moderate changes to the landscape and would not 

preclude most types of surface disturbing activities. This 

weed infestations would be difficult to control using hand 

removal methods only. Impacts would be indirect, but 

could range from negligible to minor.

4.16.2.3 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing

Livestock grazing can impact scenery, but the impacts 

tend to be localized, such as areas within a 1⁄4 mile 

distance of livestock water sources and along fencelines 

where cattle trail. Cattle tend to congregate in these 

locations and the impact to vegetation and soils can 

be severe. Such localized impacts are not visible on a 

landscape scale and their impacts to scenic quality are 

negligible. Current and proposed livestock AUMs under 

Alternatives A, B, and D are quite low and the numbers 

would need to be much higher to measurably impact 

visual resources. Alternative C would make the NCA 

unavailable to livestock grazing over the life of the RMP 

and range improvements could be removed, potentially 

restoring the naturalness to many areas of the NCA.

4.16.2.4 Impacts from Management of National 

Historic Trails 

Under Alternative A, an OST Management Corridor 

would not be designated and the NCA would continue 

to be managed as VRM Class III. Projects or land uses 

that could create moderate and noticeable changes to 

the landscape could be authorized, potentially impacting 

trail properties and the associated setting of the OST. 

Alternatives B, C, and D propose managing a 12,506 acre 

OST Management Corridor. Under Alternatives B and D, 

the OST Management Corridor and surrounding areas of 

the NCA would be managed as VRM Class II. This VRM 

designation would only allow limited modifications to 

the character of the landscape, and any changes must not 

attract the viewer’s attention. Management under this 

VRM Class would help to preserve the integrity of the associated trail setting, as well as any trail traces, sites and 

artifacts, minimizing the potential for impacts based on 

authorized land uses and activities.

Alternative C would manage 7,544 acres of the OST 

Management Corridor as VRM Class II and 4,962 acres 

under VRM Class I. This alternative would afford the 

highest level of protection level to the associated trail 

setting and the integrity of trail traces, sites, and artifacts. 

Under VRM Class II, the level of change to the characteristic landscape must be very low; under VRM Class I, the 

objective of visual resource management is to preserve 

the existing landscape of the area. The types of developments that could occur within the OST Management 

Corridor would be very limited under this alternative, 

protecting all trail resources and values from land use 

and project-specific impacts.

4.16.2.5 Impacts from Management of National 

Natural Landmarks

Alternative A would continue to manage the entire land 

base of the NCA under VRM Class III, which allows 

for moderate changes to the landscape and would not 

preclude most types of surface disturbing activities. This 

alternative would provide minimal protection for the scenic qualities and naturalness of the NNL, as new developments and surface-disturbing activities that create visual 

contrasts could be authorized and be consistent with the 

objectives of that VRM Class.

Alternative B and D propose to manage the entire NCA 

under VRM Class II. Both alternatives would provide 

a higher level of protection for the scenic qualities and 

naturalness of the NNL, when compared to Alternative 

A. To be consistent with the objectives of VRM Class II, 

the existing character of landscape must be retained and 

changes should not attract the attention of the observer. 

Projects and surface-disturbances could only be authorized that can be made to appear natural and unnoticeable to the casual observer.

Alternative C proposes to manage 46, 916 acres of the 

NCA under VRM Class II and 16,564 acres under VRM 

Class I. Under both VRM Classes, the scenic qualities 

and naturalness of the landscape of the NNL would be 

afforded the highest level of protection from alterations 

and intrusions, based on the objectives of these management classes.

4.16.2.6 Impacts from Management of ACECs

Revoking the administrative designation of the 49,269 

acre Beaver Dam Slope ACEC where it overlaps the 

NCA in Alternatives B, C, and D would have no adverse 

impact to visual resources.

The current ACEC management prescriptions are:

▶ Fluid Mineral Leasing Category 3 (No Surface 

Occupancy);

▶ Closed to off-road vehicle use;

▶ Closed to fuelwood harvesting;

▶ Closed to mineral material sales;

▶ Designated ROW Avoidance area;

▶ Mining plans of operation required;

▶ VRM Class III designation;

▶ Retain in public ownership.
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VISUAL RESOURCES VISUAL RESOURCES

second column lists whether the action(s) is a beneficial 

effect or an adverse impact. The third column provides 

a brief description of the impact/effect and the final 

column lists the intensity of the impact/effect. A description of intensity levels can be found in the “Methods 

of Analysis” section at the beginning of the Visual 

Resources section.

Alternative C provides the highest protection for visual 

resources, with the entire NCA designated as a ROW 

Exclusion area. Alternatives B and D are identical and 

slightly less protective of visual resources than Alternative 

C. In these two alternatives, a narrow ROW corridor 

would be designated on both sides of Highway 91. Utility 

development would be limited to underground installations, similar to the existing fiber-optic lines already on 

the east side of the highway. Because the underground 

installation is low impact to visual resources, the VRM 

Class II designation remains in both alternatives.

4.16.4 Cumulative Impacts

The CIAA for visual resources is the NCA and the viewshed extending beyond the planning area. Past and present 

actions within the CIAA that have affected visual resources 

include wildfires and noxious weed invasion, both of 

which have introduced modifications to the landscape.

Over the life of the plan, continued population growth in 

the large and small communities surrounding the NCA 

would erode natural night sky conditions in the CIAA. 

Extended drought conditions combined with urban 

growth construction activities would contribute to prolonged periods of fugitive dust and during certain times 

of year, could degrade visual resources. 

The growing need to decrease the potential for catastrophic fire in the region through vegetation treatments 

aimed at reducing fuel loads would alter the visual landscape in the short term. It should be noted that short term 

in this instance could last for five years or more.

alternative would provide minimal protection for the scenic qualities of the lands with wilderness characteristics 

as developments and surface-disturbing activities that 

create visual contrasts could be authorized.

Alternatives B and D propose to manage the entire NCA 

under VRM Class II. Alternative C proposes to manage 

46,916 acres of the NCA as VRM Class II and 16,564 

acres under VRM Class I. The lands with wilderness 

characteristics would be managed under VRM Class I 

under Alternative C, helping to ensure that the existing 

character and scenic qualities of the landscape 

are retained.

4.16.2.9 Impacts from Management of Recreation and 

Visitor Services

Washington County’s year-round climate, combined 

with rapid population growth and the NCA’s accessibility via Old Highway 91, has resulted in a steady increase 

in recreational use, although that use is considerably less 

when compared to the Red Cliffs NCA and the greater St. 

George metropolitan area. 

The NCA’s major attraction is hunting for upland game 

birds, staging for mule deer hunting, rock climbing, and 

motorized touring, all set in a stunning backdrop of 

the pinyon-covered Beaver Dam Mountains dropping 

steadily to the Joshua tree -blanketed Beaver Dam Slope.

The management of recreational activities in the NCA 

can have both adverse impacts and beneficial effects to 

visual resources. Impacts from trail and trailhead development are direct, localized, and negligible to minor as 

they are comprised of minor surface disturbances and 

are not visible at a landscape scale. The development of 

uniform design standards for recreational facilities would 

be visually attractive and give the NCA a unique and 

recognizable identity.

4.16.2.10 Impacts from Management of 

Comprehensive Travel and Transportation

At the land use planning level, travel and transportation management is limited to OHV area designations. 

Individual route designations are implementation-level 

decisions that will be made in the TMP being prepared 

by BLM for public lands in Washington County, as mandated by OPLMA at sec. 1979. 

Under all alternatives, including Alternative A, the NCA 

would be managed as Limited to Designated Roads and 

Trails. OPLMA, at sec. 1975, identified three Designated 

Road Areas within the NCA and those roads that are 

available for public motorized vehicle travel within each 

Designated Road Area. This legislative section directed 

BLM to manage motorized vehicle travel in all areas of 

the NCA, outside of the Designated Road Areas, also as 

Limited to Designated Roads and Trails, with the specific 

route designations to be made by the TMP currently being drafted by the SGFO.

4.16.2.11 Impacts from Management of Lands and 

Realty

Impacts to visual resources are analyzed by how the proposed Lands and Realty actions in the Chapter 2 alternatives could alter the visual appeal of the existing landscape, which is described in Chapter 3 through a VRI. 

The two main components of the NCA VRI are Scenic 

Quality and Sensitivity.

At a landscape level, ROW Exclusion affords more protection to areas with high scenic quality and/or highly 

sensitive landscapes. ROW Avoidance provides progressively fewer protections, and ROW Corridors are designed to accommodate a wide variety of development.

Alternative C provides the highest protection for visual 

resources, with the entire NCA designated as a ROW 

Exclusion area and the designated utility corridor along 

Old Highway 91 would be revoked. No highways, roads, 

or utility development would be allowed in this alternative. The proposed VRM designation of Class II is compatible with these protections.

In Alternative C, there would be no adverse impacts to 

visual resources. Designating all acres as VRM Class 

II with an overlapping designation of ROW Exclusion, 

would prohibit surface disturbing activities and protect all 

components of the VRI. The beneficial effects would be 

both direct and indirect, as the scenic quality of the NCA 

would be preserved by prohibiting future utility, road, and 

highway development. This alternative would also protect 

the high sensitivity of the Old Highway 91 viewshed.

Alternatives B and D are identical and slightly less 

protective of visual resources than Alternative C. In 

these two alternatives, a narrow ROW corridor would be 

designated on both sides of Old Highway 91. Utility development would be limited to underground installation, 

similar to the existing fiber-optic lines already installed 

on the east side of the highway. Because underground 

installation is low impact to visual resources, the VRM 

Class II designation remains in both alternatives.

4.16.3 Summary of Impacts from Alternatives

Table 4-8 provides a summary of the impacts to visual 

resources. The first column lists the resource or resource 

use that has an impact/effect on visual resources. The 

Resource/Resource Use Impact/Effect Description Intensity

Native Vegetation Impact Fuel breaks require intensive vegetation manipulation Unknown

Impact Fuel breaks may not meet Class II objectives in short term Major

Fire and Fuels Impact Fire and fire suppression can cause great contrast in the landscape Major

Effect Immediate fire suppression can protect visual resources Major

Effect Limiting managing backburning can preserve visual resources Major

Noxious Weeds Impact Large scale projects could require intensive vegetation 

manipulation Unknown

Livestock Grazing Impact Livestock grazing impacts are typically small and localized Negligible

National Historic Trails Effect VRM Class II in all alternatives is compatible with NHT 

objectives Moderate

National Natural Landmark Effect VRM Class II in all alternatives is compatible with NNL 

objectives Moderate

Visual Resources Effect Alternative C is most protective with VRM Class II on every acre Moderate

Impact Alternative B, D designate ROW corridor along Highway 91 but 

restrict use to subsurface installations Negligible

Effect Working to preserve night skies would the visual experience Minor

Wilderness Characteristics Effect VRM Class II offers no additional protection None

Recreation Effect Scenic quality is a recreation attraction Moderate

Impact Some recreation activities can impact visual resources Minor

Transportation Impact Travel management was completed by Congress for most of NCA Minor

Effect OHV area designations in all alternatives offer visual protection Moderate

Lands and Realty Effect Alternatives B, C, D manage as ROW exclusion area, highest level 

of protection for visual resources Major

Impact Alternatives B, and D require subsurface installations only in 

designated corridor along Old Highway 91 Minor

Table 4-8 Summary of Impacts to Visual Resource Management
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NATURAL SOUNDSCAPES

soundscapes to visitors until such time as acoustic data 

has been collected and analyzed.

4.17.4 Cumulative Impacts

The CIAA for Natural Soundscapes is similar to the 

extent for Visual Resources. It is defined by the topography that surrounds the NCA; the Beaver Dam Mountain 

to the north and east and extending to Interstate 15 in 

Arizona in the south. Past and present actions within the 

CIAA that have affected natural soundscapes have not 

been identified.

Over the life of the plan, continued population growth 

in the small communities surrounding the NCA would 

slowly erode the natural soundscape within the CIAA. 

An increase in population would result in a corresponding increase in vehicle traffic during certain times of 

year. It would also be expected to increase the amount of 

recreational target shooting on non-federal lands and on 

federal lands where this activity continues to be authorized, which can disturb the natural soundscape.

Development of new utilities and maintenance of existing power transmission and pipelines in the IPP and 

Navajo-McCullough designated corridors, outside of the 

NCA boundaries, would have a corresponding increase 

in maintenance vehicle traffic which would impact the 

natural soundscape within the CIAA.

4.18 LANDS WITH WILDERNESS 

CHARACTERISTICS

This section discusses impacts to lands with wilderness 

characteristics from the proposed management actions 

of other resources and resource uses. Existing conditions 

concerning these lands are described in Section 3.17 

Lands with Wilderness Characteristics.

The BLM is required under FLPMA to maintain inventories of all public lands and their resources, including 

lands with wilderness characteristics, and to consider 

such information during the land use planning process. 

In support of the development of the new RMP, a comprehensive review of the public lands within the NCA 

was completed to identify the presence or absence of 

lands with wilderness characteristics. Two areas, totaling 29,036 acres, were found to have wilderness characteristics within the NCA. An overview of the inventory 

process, as well as the findings, is located in Chapter 3.17 

and a full description can be found at www.blm.gov/

nxld. This analysis discusses potential adverse impacts 

or beneficial effects of planning decisions on lands with 

wilderness characteristics. 

4.18.1 Methods of Analysis

The analysis of potential impacts to lands with wilderness 

characteristics is based on two data sources: visitor use 

statistics and GIS data. The GIS data includes designated 

wilderness area boundaries, management unit boundaries, vegetation types, terrain models, wildlife habitat, 

transportation inventories, dispersed recreation inventories, aerial photography, fire history, and known historical/archaeological sites.

4.18.1.1 Indicators

Indicators of impacts on lands with wilderness characteristics include degradation of any components of 

the inventoried characteristics: naturalness, solitude, 

and opportunities for primitive, unconfined recreation. 

Indicators of beneficial effects include the protection or 

enhancement of any components of those same inventoried characteristics.

4.18.1.2 Assumptions

The analysis includes the following assumptions:

▶ Congressional segregations pursuant to the designation of the NCA (OPLMA, section 1975) provide a 

very high level of protection for lands with wilderness characteristics;

▶ Management actions proposed in the draft RMP 

are designed to conserve, protect, and enhance 

resource values of the NCA.

Implementing management for the following resources 

or resource uses would have negligible or no impact on lands with wilderness characteristics and are, 

therefore, not discussed in detail: Air Quality, Water 

Resources, Geologic and Paleontological Resources, 

Cave and Karst Resources, Soil Resources, Native 

Vegetation Communities, Fire and Fuels, Noxious 

Weeds and Invasive Species, Vegetation Resource 

Uses: Livestock Grazing, Vegetation Resource Uses: 

Plant Materials, Special Status Species, Other Fish and 

Wildlife Species, Heritage Resources, National Historic 

Trails, National Natural Landmarks, ACECs, Visual 

Resource Management, Natural Soundscapes, Recreation 

and Visitor Services, Comprehensive Travel and 

Transportation Management, Lands and Realty, Public 

Education and Interpretation, and Scientific Research.

4.18.2 Direct and Indirect Impacts

Inventory data found that in two areas of the NCA, totaling 29,036 acres, lands with wilderness characteristics are 

present. Managing those areas specifically to protect their 

wilderness characteristics is proposed only in Alternative 

Expansion of utilities in the designated IPP and NavajoMcCullough ROW corridors along the boundaries of the 

NCA will continue to impact visual resources in the CIAA. 

Application of visual resource design principles for 

permitted projects, activities, and uses on public lands 

would do much to maintain the quality of visual resources within the CIAA.

4.17 NATURAL SOUNDSCAPES

This section discusses impacts on natural soundscapes 

from the proposed management actions of other resources and resource uses. Existing soundscape conditions are 

described in Section 3.16, Natural Soundscapes.

Protection of the acoustical environment has received 

growing attention as a result of the increased understanding of its role in ecosystem health and visitor enjoyment. 

Noise levels and their impact on NCA visitors cannot be 

effectively analyzed without data. The proposed installation of acoustical monitoring equipment that measures 

sound levels would make this possible.

4.17.1 Methods of Analysis

The analysis of potential impacts to the Natural 

Soundscape in the NCA is based on the local knowledge 

of recreation/wilderness planners. While ambient noise 

levels have not been measured or documented, areas 

where noise is prevalent or absent have been noted during field visits by BLM staff.

4.17.1.1 Indicators

Indicators of adverse impacts on natural soundscapes 

include the following:

▶ Excessive ambient noise that is sufficient to degrade the visitor experience. Noises come primarily 

from automobile and other land-based motorized 

use, aircraft overflight, gunshots, and large group 

activities.

Indicators of beneficial effects on visual resources include 

the following:

▶ Areas where natural quiet is prevalent.

4.17.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ Ambient noise from traffic on Old Highway 91 cannot be mitigated;

▶ Ambient noise from traffic on Old Highway 91 

does not introduce audible elements that would 

measurably impair a visitor’s vicarious experiences 

of the legislatively-designated route of the Old 

Spanish Trail National Historic Trail;

▶ NCA visitors should expect regular vehicle 

noise in the Rural and Frontcountry Recreation 

Management Zones;

▶ NCA visitors can find solitude and natural quiet in 

the Backcountry and Primitive Zones;

▶ The NCA will pursue opportunities to install acoustical monitoring equipment.

Implementing management for the following resources 

or resource uses would have negligible or no impact on 

natural soundscapes and are therefore not discussed 

in detail: Air Quality, Water Resources, Geologic and 

Paleontological Resources, Cave and Karst Resources, 

Soil Resources, Native Vegetation Communities, Fire 

and Fuels, Invasive Species Management, Vegetation 

Resource Uses: Livestock Grazing, Vegetation 

Resource Uses: Plant Materials, Special Status Species, 

BLM Sensitive Species, Other Fish and Wildlife 

Species, Heritage Resources, National Historic Trails, 

National Natural Landmarks, ACEC, Visual Resource 

Management, Lands and Realty, Public Education and 

Interpretation, and Scientific Research.

4.17.2 Direct and Indirect Impacts

Identifying and providing opportunities for visitors 

to experience natural soundscapes would be implemented primarily through the proposed Recreation 

Management Zones. Solitude is a consistent component 

of Backcountry and Primitive Zones and is closely correlated with natural quiet.

Certain areas of the Beaver Dam Mountains on the 

eastern end of the NCA, and in the badlands west of 

Beaver Dam Wash, have ample opportunity to experience 

natural quiet, free of the sights and sounds of the nearby 

Highway 91 and other developed roads. While these are 

certainly beneficial effects, it is not possible to adequately 

quantify the value to individual visitors as everyone’s 

perception of solitude and natural quiet is different.

4.17.3 Summary of Impacts from Alternatives

Solitude is a consistent component of Backcountry and 

Primitive Recreation Management Zones and is closely 

correlated with natural quiet. Visitors have ample opportunity within the NCA to experience natural quiet, free 

of the sights and sounds of the nearby urban interface. It 

is not possible to adequately quantify the value of natural 

LANDS WITH WILDERNESS CHARACTERISTICS
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LANDS WITH WILDERNESS CHARACTERISTICS RECREATION AND VISITOR SERVICES

tactics. To a lesser extent, range and wildlife management 

projects can affect areas with wilderness characteristics. 

These impacts normally come from vegetation treatments and the installation, maintenance, and use of 

range/wildlife catchments and wildlife drinkers.

The growing need to decrease catastrophic fire potential 

in the region through the reduction of fuel loads would 

gradually and visibly alter landscapes where treatments 

are conducted, with short-term reductions in the quality 

of solitude, naturalness, and opportunities for primitive/

unconfined recreation. Such projects could also preserve 

wilderness characteristics outside the treatment areas by 

preventing catastrophic wildfires.

Through the passage of OPLMA, at Title I, Section O in 

2009, Congress designated 14 new wilderness areas on 

BLM-managed lands in Washington County; three areas 

in Zion National Park, and a new wilderness area, the 

Cottonwood Forest Wilderness, on the Dixie National 

Forest, in the Pine Valley Ranger District. 

As a result of the 2009 wilderness designations, there are 

approximately 309,280 acres of designated wilderness 

in Washington County; this acreage represents approximately 19.6% of the county land base. The approximately 

132,000 acres of designated wilderness managed by the 

SGFO comprises approximately 20% of the total BLMmanaged acres in Washington County, or one in every 

five acres is designated wilderness.

4.19 RECREATION AND VISITOR SERVICES

This section analyzes potential impacts to recreation 

resources from the proposed management actions of 

other resources and resource uses. Existing conditions 

concerning recreation are described in Section 3.18, 

Recreation and Visitor Services.

As part of the RMP process, the SGFO has two options 

for recreation management area allocations: 1) designating the entire NCA as a SRMA; 2) leaving in place the 

existing designation of ERMA.

In an SRMA, management actions are focused on protecting specific, high-quality recreation opportunities 

that are targeted to achieve beneficial outcomes. Benefits 

from recreation opportunities can include personal benefits to participants in the form of improved health and 

well-being; benefits to local communities, both social 

and economic; and benefits to the environment through 

increased protection via targeted infrastructure development, interpretation, and outreach. 

Benefits are dependent on the specific recreational 

activities as well as the physical, social, and operational 

settings where those activities occur (Appendix H). 

Changes in recreation activities or settings can result in 

changes to the experiences visitors have and to the personal, community, and environmental benefits that result 

from those experiences. 

Even though it lacks the heavy, intensive use that the 

RCNCA receives, the NCA status has given Beaver Dam 

Wash a higher profile and a corresponding uptick in visitation. The area has long been a popular destination for 

rock climbers as there are classic limestone crags around 

every corner. The area is also a favorite winter/spring 

destination for ATV riders, as they wind among the giant 

Joshua Trees amidst blooming spring perennials. Upland 

game bird hunters also enjoy quail hunting on the lower 

slopes of the Beaver Dam Mountains. Because of the 

overlap of critical tortoise habitat and a diverse set of recreational activities, and growing visitation, SRMA status 

is proposed in all action alternatives. 

The proposed SRMA is divided into RMZs. The management zones in Alternatives B, C, and D use the standard 

BLM terminology of Frontcountry, Backcountry, and 

Primitive, with each having specific management prescriptions. In Alternative A, the NCA is an ERMA and 

has no management zones.

4.19.1 Methods of Analysis

The analysis of potential impacts to recreation activities 

and opportunities were analyzed using two data sources: 

visitor use statistics and GIS. Visitor use is tracked using 

digital traffic counters, which count both motorized and 

non-motorized visitors. Counters are moved periodically to track visitation in different locations. The GIS 

data used in this analysis includes, but is not limited 

to: administrative boundaries, vegetation types, wildlife habitat, T&E habitat, T&E species occurrence data, 

motorized routes, non-motorized trails, campgrounds, 

dispersed campsites, climbing areas, aerial photography, 

terrain models, fire history, and known historical/cultural sites. In the absence of data, analyses were based on 

the expertise of recreation/wilderness planners and other 

applicable resource specialists.

Adverse impacts to recreation opportunities could result 

from management actions that diminish any of the 

fundamental components listed in the indicators section 

below. These could be restrictions on certain activities or 

changes to the physical, social, and administrative settings that would limit recreation opportunities. 

C and only where these lands are within the proposed 

Primitive Recreation Management Zone. Prescriptions 

under Alternative C include management under VRM 

Class I, as Limited to Designated Roads and Trails for 

motorized vehicle travel, as a ROW Exclusion area, and 

as closed to commercial and non-commercial fuelwood 

harvesting and seed and plant materials collection.

Under all alternatives, the lands would continue to be 

segregated from the operation of the public land laws, 

the mining laws, the mineral leasing, mineral materials, and geothermal leasing laws, pursuant to OPLMA at 

Section 1975.

Alternative A would continue to manage these lands 

under VRM Class III, as ROW Avoidance area, as available for livestock grazing, and for dispersed recreation, 

within in the larger SGFO ERMA. Motorized vehicle 

travel would be managed as Limited to Designated Roads 

and Trails, consistent with the legislative mandates from 

OPLMA at section 1975. The lands would continue to 

be closed to commercial and non-commercial fuelwood 

harvesting and seed and plant materials collection.

Under Alternatives B and D, lands identified as having wilderness characteristics would be managed under 

VRM Class II, as ROW Exclusion area, and as available 

for livestock grazing. Recreation uses would be managed consistent with the prescriptions identified for 

the proposed Primitive Recreation Management Zone. 

Motorized vehicle travel would be managed as Limited to 

Designated Roads and Trails, consistent with the legislative mandates from OPLMA at section 1975 (Table 4-9). 

The lands would continue to be closed to commercial 

and non-commercial fuelwood harvesting and seed and 

plant materials collection.

4.18.3 Summary of Impacts from Alternatives

The inventory completed for lands with wilderness 

characteristics identified two areas in the NCA, totaling 

29,036 acres, where wilderness characteristics are present. Alternative C proposes to manage these acres specifically to protect their wilderness characteristics, through 

VRM Class I designation, an OHV area designation of 

Limited to Designated Roads and Trails, and as closed to 

commercial and non-commercial fuelwood harvesting 

and seed and plant materials collection. 

Under Alternative A, current management might not adequately protect wilderness characteristics, as management 

under VRM Class III and as a ROW Avoidance area would 

not restrict the types of projects and surface disturbing 

activities that could be authorized within the 29,036 acres 

identified as having wilderness characteristics.

Although Alternatives B and D do not propose to manage these lands for wilderness characteristics, management decisions proposed for all other resources 

or resource use programs, including the OHV Area 

Designation and management of the NCA as a ROW 

Exclusion area, would provide a high level of protection 

for lands with wilderness characteristics.

4.18.4 Cumulative Impacts

The CIAA for lands with wilderness characteristics is all of 

Washington County, including all designated wilderness 

managed by BLM, USFS, and NPS, and all areas that were 

inventoried and wilderness characteristics found to be 

present. Using guidance from BLM Manual 6310, SGFO 

staff conducted an inventory of all public lands (outside of 

the currently designated wilderness areas) in Washington 

County to determine the presence or absence of lands with 

characteristics. Wilderness characteristics are attributes of 

public lands for which decisions to protect these characteristics are made through the RMP process. 

Wilderness characteristics are primarily affected by the 

number and proximity of motorized travel corridors; the 

volume and type of traffic on those corridors; the quantity and type of recreational users; and fire suppression 

NCA Management Under All Alternatives, OPLMA Section 1975

Withdrawn from all forms of entry, appropriation, and disposal under public land laws;

Withdrawn from location, entry, and patenting under the mining laws;

Withdrawn from operation of mineral leasing, mineral materials, and geothermal leasing laws; 

Motorized vehicle use Limited to Designated Roads

Proposed Management of Lands with 

Wilderness Characteristics-Alternative C

Proposed Management of NCAAlternative A (No Action)Proposed Management of NCAAlternatives B and D

VRM Class I VRM Class III VRM Class II

ROW Exclusion Area ROW Avoidance Area ROW Exclusion Area

Closed to Commercial and Non-Commercial Fuelwood Harvesting

Table 4-9 Summary of Impacts to Lands With Wilderness Characteristics by Alternative
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RECREATION AND VISITOR SERVICES RECREATION AND VISITOR SERVICES

opportunities within an already disturbed landscape. 

Under Alternatives B, C, and D, these opportunities 

would enhance visitor experiences and support nonmotorized recreational uses of the NCA.

Riparian areas in the desert are rare and tend to attract 

visitors, drawn by the cooler temperatures, lush vegetation, and presence of water. One of the best ways to 

manage visitor use and protect riparian resources would 

be to construct sustainable trails or other facilities that 

would meet visitor experience needs, as well designed 

trails would minimizing social trailing and visitor-caused 

disturbances in sensitive riparian areas. Alternatives B, C, 

and D would require that projects authorized in riparian 

areas meet the objective of improving riparian resources, 

which would be met by the development of trails or other 

recreation facilities that would prevent degradation of 

riparian areas from unmanaged visitation.

Fire suppression in the NCA calls for immediate full 

suppression under all alternatives, to minimize the loss of 

native vegetation and protect critical habitats for special 

status species, including the desert tortoise.

Backburning is prohibited as a fire suppression tactic 

in Alternative C in late successional scrublands, Joshua 

tree communities, and blackbrush dominant landscapes. 

Alternatives B and D allow backburning but it would require pre-approval from the NCA Manager (Alternative 

B) or the on scene Resource Advisor (Alternative D).

Wildland fire can cause great contrast to the natural 

landscape, removing large swaths of vegetation and leaving behind visible scars. Wildfire results in the immediate 

loss of recreation opportunities as a burned, fire-scarred 

landscape degrades the visitor experience. Fire suppression can have dramatic impacts to recreational opportunities but those efforts can also preserve larger areas 

that would have otherwise burned over. Prohibiting 

backburning, or restricting it to those situations where it 

is absolutely necessary has the potential to protect large 

swaths of unburned landscape, which would preserve the 

recreational opportunities in the NCA.

Because of the potential variability in fire starts, fire 

behavior, and employed suppression techniques, it is not 

possible to quantify potential impacts.

4.19.2.5 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing

Impacts to recreation from livestock grazing include soil 

compaction, vegetation trampling and manure deposition impacts at popular campsites and trails. The intensity of the impact varies with the visitor’s experience of 

recreating in areas where livestock are present. Example: 

visitors from within the Intermountain West are more 

accustomed to recreating in areas with livestock impacts. 

In addition, livestock grazing facilities often impact the 

physical setting: stock ponds, catchments, and other 

facilities all contrast with the natural landscape and can 

degrade the visitor experience.

Livestock grazing could complement recreation 

management in the NCA through interpretation at 

wayside and trailheads. One of the many facets of 

heritage tourism could be a focus on the history of 

livestock grazing, from the early settlers to present day 

ranching. Visitors could develop a greater appreciation 

for historic uses of the landscape.

Under Alternatives A, B, and D, livestock grazing would 

continue to be available throughout the NCA, with 

available AUMs (1,861) in Alternative B proposed to be 

initially established at 60% lower than those available 

under Alternatives A and D (3,099). Alternative C would 

make the NCA unavailable to livestock grazing over the 

life of the RMP.

Impacts to recreation opportunities from livestock grazing are difficult to quantify. Grazing allotments in the 

NCA are restricted to specific times of year outside of the 

desert tortoise active season, which means that livestock 

can be seen in the NCA from November to March. 

Unfortunately, since the NCA can be unbearably hot in 

the summer, this is also the season when recreation use 

is at its peak. Impacts to recreation are direct and vary by 

location, ranging from negligible to minor.

4.19.2.6 Impacts from Management of Vegetation 

Resource Uses: Plant Materials

Dispersed camping in Alternative C would only be authorized in the Primitive Recreation Management Zone. 

Not allowing the collection of dead and down materials 

for campfires in Alternative C would remove the option of having a campfire in the NCA unless the visitor 

brought their own fuel. This would have direct and minor impacts on recreational uses of the NCA, potentially 

decreasing the quality of the camping experiences for 

some visitors.

4.19.2.7 Impacts from Management of Special Status 

Species, Including BLM Sensitive Species

Under all alternatives, management decisions and actions 

identified to assist the recovery and delisting of special 

status species have some potential to conflict or constrain 

recreational opportunities. Such constraints may include 

closures, either short or long term, of specific lands to 

Beneficial effects could result from management actions 

that maintain or enhance any of the fundamental components listed in the indicators section below. These could 

be improved access for certain activities or changes to the 

physical, social, and administrative settings that would 

enhance recreation opportunities. 

4.19.1.1 Indicators

Indicators of adverse impacts to recreation include the 

following:

▶ Management actions that could result in the elimination or reduction of recreation opportunities in 

the NCA;

▶ Management actions that could result in increased 

conflict between recreation opportunities and other 

resources or resource uses;

▶ Management actions and allowable use restrictions 

that could result in increased conflict between different recreation users.

Indicators of beneficial effects on recreation include the 

following: 

▶ Management actions that could result in the expansion or improvement of recreation opportunities in 

the NCA;

▶ Management actions that could result in decreased 

conflict between recreation opportunities and other 

resources or resource uses;

▶ Management actions and allowable use restrictions 

that could result in decreased conflict between different recreation users.

4.19.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ The basic restrictions on the type of allowable recreation activities identified for critical tortoise habitat 

will remain in place;

▶ Population growth in Washington County and 

name recognition across the west will result in 

increased visitation to the NCA.

Implementing management for the following resources 

or resource uses would have negligible or no impact on 

to Recreation opportunities and are therefore not discussed in detail: Air Quality, Water Resources, Noxious 

Weeds and Invasive Species, Other Fish and Wildlife 

Species, ACEC, and Lands and Realty.

4.19.2 Direct and Indirect Impacts

Recreation opportunities in the NCA are primarily 

influenced by the number and quality of proposed nonmotorized trails and trailheads; the number and quality of dispersed campsites; the quality of on and off-site 

interpretation; and the quality of proposed facilities. 

Alternatives B, C, and D each identify a different management emphasis for recreation resources. Each alternative would satisfy the Congressionally-defined purposes 

of conservation, protection, and enhancement of diverse 

resource values and uses of the NCA.

Alternative D would be the least restrictive, with proposed construction of a non-motorized trail system in 

the Congressionally-defined Designated Road Areas of 

the NCA.

4.19.2.1 Impacts from Management of Geologic and 

Paleontological Resources

Under Alternatives B, C, and D, the identification of new 

paleontological resources that would be appropriate as 

Public Use Sites would enhance recreation opportunities, 

as these are attractions for most visitors. 

Casual collection of petrified wood and invertebrate 

fossils would be prohibited in Alternatives B and C, but 

proposed to be authorized in Alternative D if surface 

disturbance is negligible. Fossil and petrified wood collection are popular activities and their prohibition could 

have minor impacts to recreational experiences.

4.19.2.2 Impacts from Management of Cave and Karst 

Resources

Systematic inventories of cave and karst resources could 

result in increased recreation opportunities, if significant 

caves were discovered that are appropriate for management as Recreational caves.

4.19.2.3 Impacts from Management of Soil Resources

Under Alternatives B, C, and D, locating new trails, 

trailheads, and other recreation facilities on soils that 

are capable of handling recreational activities could have 

indirect, but negligible impacts to recreation opportunities. Where soils are not suitable for these purposes, trails 

would not be developed, potentially reducing the number 

of new recreation facilities that could be developed.

4.19.2.4 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Fuel breaks and hazardous fuels reduction projects may 

offer opportunities for new trail development in areas 

where fuel reduction is already a priority. Locating nonmotorized trails within fuel breaks could create new 
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RECREATION AND VISITOR SERVICES RECREATION AND VISITOR SERVICES

natural soundscapes, when compared to the No 

Action Alternative.

4.19.2.13 Impacts from Management of Lands with 

Wilderness Characteristics

Alternative A would continue to manage these lands 

under VRM Class III, as ROW Avoidance area, as available for livestock grazing, and for dispersed recreation, 

within in the larger SGFO ERMA. Motorized vehicle 

travel would be managed as Limited to Designated Roads 

and Trails, consistent with the legislative mandates from 

OPLMA at section 1975. The lands would continue to 

be closed to commercial and non-commercial fuelwood 

harvesting and seed and plant materials collection.

Under Alternatives B and D, lands identified as having wilderness characteristics would be managed under VRM Class II, as ROW Exclusion area. Recreation 

uses would be managed consistent with the prescriptions identified for the proposed Primitive Recreation 

Management Zone. Motorized vehicle travel would be 

managed as Limited to Designated Roads and Trails, 

consistent with the legislative mandates from OPLMA at 

section 1975 (Table 4-9). 

The two areas with wilderness characteristics contain 

a small number of primitive motorized routes. Those 

routes were closed by Congress in OPLMA. Neither 

of the two areas contains non-motorized trails, either 

existing or proposed in the SGFO TMP. Because of the 

combination of these factors, recreation opportunities 

would not change if the areas were managed specifically 

to protect lands with wilderness characteristics. For a 

more detailed comparative analysis, see Table 4.9 in 

Lands with Wilderness Characteristics.

4.19.2.14 Impacts from Management of Recreation 

and Visitor Services

Revoking the existing ERMA and replacing it with the 

Beaver Dam Wash SRMA would provide long-term management direction consistent with current and proposed 

management practices and national policy.

The management zones in Alternatives B, C, and D, 

simplify recreation management by making the management zones, but not the rules, invisible to the public. The 

proposed management zones of Rural, Frontcountry, 

Backcountry, and Primitive are designed to assist BLM 

staff in deciding where management controls will be employed and funds will be spent. If a visitor crosses from 

the Frontcountry zone into Backcountry zone, interpretative displays would not be provided and directional/

regulatory signs would be fewer.

Under all alternatives, motorized vehicle travel (except 

for administrative and emergency response access) within the three Congressionally-identified Designated Road 

Areas is limited to the roads shown on the legislative map 

from OPLMA for the Beaver Dam Wash NCA. Under 

Alternatives B, C, and D, all non-motorized recreational 

uses must be on designated trail, except in the Primitive 

Zone. Within this zone, cross-country travel by hikers, 

equestrian, and mountain bikers would be authorized, 

until such time as this use results in unacceptable changes to or degradation of resource values in the NCA. An 

activity level plan (RAMP) would be prepared to guide 

management of the recreation zones and include adaptive management options and thresholds to identify how 

levels of change would be measured and management 

modified to protect NCA values.

Recreation Activity Management Plan

Developing implementation-level plans in Alternatives 

B, C, and D to manage specific activities would benefit 

recreation opportunities in the long-term by gathering 

site-specific public input and identifying specific needs 

and opportunities.

Architectural Standards

Developing uniform architectural standards in 

Alternatives B, C, and D for all site improvements, recreational facilities, site fixtures, structures, and associated 

spaces would provide the NCA with a recognizable identity and would improve the visitor experience. Alternative 

A identifies no similar actions and opportunities would 

be foregone to enhance visitor experiences through an 

easily identifiable “look” for NCA recreation facilities.

Dispersed Camping

Alternative A would continue to authorize dispersed 

camping anywhere within 50 feet of a designated route.

Alternatives B, C, and D would authorize dispersed 

camping in all management zones. In the Frontcountry 

and Backcountry, which are accessible by road, dispersed 

campsites would be designated, with the number of designated sites varying by alternative. Each campsite would 

be visibly marked and would have ample parking, a tent 

or trailer site, and a metal campfire ring. 

A dispersed campsite inventory conducted in 2013 identified 46 dispersed campsites of varying quality in the 

NCA, with several more just outside the boundary. All 46 

would be designated in Alternative D, with 38 and 30 to 

be designated in Alternatives B and C, respectively.

organized, competitive, or even casual recreation uses, 

to protect habitat impacts or to prevent disturbances to 

species during key periods, such as breeding or migration periods. Restrictions may also be imposed on the 

development of new trails or other recreation facilities 

within designated critical habitats. Project planning, in 

consultation with the USFWS, would lessen potential 

impacts on special status species and critical habitats, so 

that sustainable and appropriate recreational uses can 

continue to be provided over the life of the RMP. For a 

more detailed analysis of the interaction between recreational use and special status species’ habitat in the NCA, 

please see “Impacts from Management of Recreation and 

Visitor Services” in this same section.

4.19.2.8 Impacts from Management of Heritage 

Resources

Alternative A provides only generalized management 

direction relating to the management of heritage 

resources on public lands. Alternatives B, C, and D 

make Use Allocations for a broad array of heritage 

resource site types, including management for Public 

Use and interpretation.

Under all alternatives, management actions may be 

required to protect significant heritage resources from 

impacts related to recreational uses, including the installation of physical barriers or land use restrictions, such 

as closures. These could negatively impact recreationists, 

but would be expected to be negligible to minor in scope.

Under Alternatives B, C, and D, the management of 

Public Use sites could include research studies, the development of interpretive materials and other visitor amenities that would enhance visitor’s recreational experiences 

in the NCA, as heritage tourism is an increasing popular 

use of public lands.

4.19.2.9 Impacts from Management of National 

Historic Trails 

Establishment and management of the OST Management 

Corridor could provide additional opportunities for 

recreational experiences, and foster stewardship and appropriate behaviors that protect the NHT resources and 

values. Adding facilities, exhibits, and non-motorized 

retracement trails to support these activities would enhance the visitor experience, but they could also change 

undeveloped settings and have a very low potential of reducing opportunities for experiences such as adventure, 

exploration, solitude, and escape from noise and crowds.

A lack of supporting management objectives and actions for the OST under Alternative A would limit 

additional opportunities for activities and experiences. 

Lack of a management presence would not encourage appropriate visitor behavior that protects the NHT 

resources and values.

4.19.2.10 Impacts from Management of National 

Natural Landmarks

The approximately 1,047 acre Joshua Tree NNL is located 

entirely within the NCA (Map 3-19). NPS registered this 

area to the National Landmark System in 1966 because 

the Joshua tree forest was considered to be the best example of this natural community at the northern extreme 

of its range in the Mojave Desert. Sadly, catastrophic 

wildfires in 2005-2006 damaged or destroyed many of 

the Joshua trees of the NNL.

The NNL is a popular attraction and the NCA is proposing 

to work with the NPS to move the NNL from its current 

location, to an unburned area of the NCA that is representative of a mature northern Joshua tree forest. This would 

provide visitors with an experience that is indicative of 

NCA values and one that cannot easily be replicated.

4.19.2.11 Impacts from Management of Visual 

Resources

Under Alternatives B, C, and D, proposed management 

under VRM Classes I and II and decisions to incorporate 

visual design considerations into project design and to 

reduce or prevent impacts to night skies would enhance 

the recreational experience in the NCA by conserving 

and protecting its scenic qualities. Alternative A would 

continue to manage the NCA under VRM Class III and 

contains no similar management decisions regarding 

facilities design considerations. Overall, this alternative would provide a lower level of protection for scenic 

qualities of the NCA, when compared to the three 

action alternatives.

4.19.2 12 Impacts from Management of Natural 

Soundscapes

Visitors to the Primitive and Backcountry management zones within the NCA have ample opportunity to 

experience natural quiet, free of the sights and sounds of 

nearby St. George and Mesquite. While these are certainly beneficial effects, it is not possible to adequately 

quantify the value to individual visitors as everyone’s 

perception of solitude and natural quiet is different. 

Alternative A identifies no actions to determine locations 

where natural soundscapes should be protected and contains no management decisions that would help to meet 

the objectives of conserving natural quiet. Alternatives 

B, C, and D would provide higher levels of protection for 
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RECREATION AND VISITOR SERVICES RECREATION AND VISITOR SERVICES

▶ Event staging takes place outside the NCA or takes 

place on designated roads and/or at trailheads 

inside the NCA;

▶ The event causes no new surface disturbance;

▶ Event scheduling complies with seasonal restrictions to protect wildlife and habitats, (e.g., restrictions on events during desert tortoise active season, 

generally between March 15 and October 15).

Group size limits for competitive events would be set 

on a case-by-case basis by incorporating the following 

factors: type of event, length of event, number of participants, potential for resource impacts, potential for 

impacts to other visitors, and compatibility with RMZs.

Washington County is a popular venue for running, triathlon, and cycling events. It also plays host to scouting 

events, church events, school classes, and historical reenactments. Allowing those events to occur in or travel 

through the NCA could raise the profile of the NCA. 

Adverse impacts are not likely given the restrictive event 

criteria and the group-size factors.

Rock Climbing

Rock climbing is the most popular recreational activity 

in the NCA, with the frequently visited Woodbury Road 

Crags of Black and Tan, Kelly’s Rock, and the Solstice all 

inside the NCA boundary. During development of this 

plan, NCA staff met with the Southern Utah Climbers 

Alliance and identified other cliff faces within the NCA 

that would be desirable climbing locations in the future.

A climbing management plan would be developed as 

part of the Recreation Master Plan for the NCA. It would 

identify where climbing would be authorized in the future, 

identify restrictions, and establish monitoring protocols. 

In the interim, all existing climbing sites would remain 

open in all alternatives. In Alternatives B and D, six of the 

locations identified during planning would be authorized 

for new climbing routes. In Alternative C, no new routes 

would be authorized until the climbing management 

plan is complete. No impacts to climbing opportunities 

are anticipated in any alternative.

Other Recreational Activities

Geocaching is a popular activity in the NCA. Physical 

geocaches would be allowed in the Frontcountry and 

Backcountry Zones in Alternatives B and D, provided 

they are compliant with other zone restrictions. They are 

allowed only the Frontcountry in Alternative C. Virtual 

geocaches are allowed in all management zones. 

All geocache placements would require permission from 

NCA staff who review the submitted coordinates and 

evaluate the potential impacts of the placement. This review process is already in place and impacts to recreation 

opportunities would be negligible in Alternatives B and 

D, with possibly minor impacts in Alternative C.

Recreational Prospecting

Recreational prospecting, or “casual use” as defined in 

BLM Handbook H-3809, includes hand panning, nonmotorized sluicing, and collection of geochemical, rock, 

soil, or mineral specimens using non-motorized hand 

tools. These uses would be allowed in Alternative B and 

D with permission from the NCA Manager. They would 

not be allowed in Alternative C. 

Recreational prospecting is generally not a popular activity and the demand is quite low. Impacts to recreational 

opportunities would be negligible. 

Discharge of Firearms and Hunting

Regardless of alternative, wherever target shooting is 

authorized, firearms must be discharged toward a proper 

backstop and target must be constructed of wood, cardboard, paper, or similar unbreakable materials. This decision is in place to try and stop the proliferation of “target 

trash,” which is the number one activity when it comes to 

defacing public lands.

Impacts to target shooting from existing and proposed 

closures would be negligible as there are still thousands 

of acres of public land in the county where target shooting is an acceptable activity. Requiring target shooters to 

clean up after themselves is compliant with existing littering laws and is no different than what is required of other 

recreational users.

Hunting is allowed throughout the NCA, provided it is 

in compliance with state hunting laws. No impacts to 

recreational opportunities would occur. 

Monitoring

Developing a comprehensive program to monitor recreational impacts would not affect recreational opportunities, but it would allow for greater protection of NCA 

values, including critical habitat.

4.19.2.15 Impacts from Management of 

Comprehensive Travel and Transportation

Regardless of alternative, the OHV area designation 

for the NCA will continue to be Limited to Designated 

Roads and Trails.

Designating dispersed campsites would eliminate the 

need for off-road parking, helping to protect soil horizons, native vegetation, and special status species’ habitats over the long term. Providing metal campfire rings 

would help to prevent the accidental ignition of wildfires 

by recreationists, lessening the potential of human caused 

fires in a landscape that is not fire-adapted. Prevention of 

wildfire would help to conserve and protect high-quality 

visitor experiences and recreational opportunities in the 

NCA. Because dispersed camping opportunities are preserved, impacts to dispersed camping in any of the action 

alternatives would be negligible.

New Trail Construction

The designation, construction, and maintenance of individual roads and trails are not land use plan decisions. 

They are implementation decisions, meaning they are 

lower tier, and making changes to those decisions would 

not require a land use plan amendment. The SGFO is 

working on a comprehensive travel and transportation 

plan that analyzes every road and trail within the field office boundary, including both NCA’s. This planning effort 

includes everything from paved roads to non-motorized 

singletrack. It also includes proposed trails, many of 

which were submitted by organized user groups representing hikers, mountain bikers, and equestrians. The 

travel planning effort is on a separate, but parallel track 

to the land use planning effort. Its release will follow 

closely behind this plan.

There is a decision in Chapter 2 that states design and 

construct the non-motorized trail system to professional 

standards to ensure that trail design:

▶ Addresses the needs of equestrians, hikers, climbers, and mountain bikers;

▶ Protects diverse NCA resource values from direct or 

indirect recreation impacts by promoting compliance with regulatory requirements and visitor use 

restrictions;

▶ Results in sustainable systems;

▶ Provides high-quality experiences;

▶ Serves the abilities of non-motorized recreational 

users;

▶ Offers opportunities for looping, varying distances, 

linking between geographic areas and trailheads, 

and connecting to heritage and other educational 

resources.

▶ Minimizes user conflicts by separating user groups 

whenever feasible;

▶ Limits the desire to venture off-trail.

New trails would be constructed in the Rural, 

Frontcountry, or Backcountry Zones, as shown in the 

TMP for Alternatives B, C, and D. This is an implementation decision and it is included for information purposes 

only, because the travel plan is certainly the most anticipated part of the current planning efforts.

The travel plan for the NCA mirrors the aspirational 

goals of the individual alternatives in this plan. But it also 

recognizes the reality that visitation in the NCA will continue to grow. The travel plan is based on the assumption 

that in order to protect critical habitat, the trail system 

must provide the experience that visitors are seeking. 

The full details and analysis will be released in the travel 

management plan for the NCA.

Special Recreation Permits

In Alternatives B and C, limiting the number of SRPs 

to 10% of overall visitation would keep the ratio of 

commercial use to other visitors consistent over time. 

Existing commercial activity is about 3% of total visitation, so Alternative B allows for significant amount of 

growth in private sector guiding businesses. It is anticipated that it would take 10-15 years before the 10% 

threshold is reached. Beneficial effects to private sector 

businesses would be indirect and minor to moderate.

In Alternative D, the number of SRPs would be limited to 

20% of overall visitation. This would allow for large-scale 

growth in private sector guiding businesses, but it would 

also increase the number of complaints from individual 

visitors about large guided groups. It is likely that the 

20% threshold would never be reached. Beneficial effects 

to the private sector would be indirect and minor to 

moderate. Impacts to the visitor experience could range 

from negligible to moderate.

Group size limits for SRPs would be set on a case-by-case 

basis in Alternatives B and D. Example: guided hikes can 

become cumbersome and unpleasant for participants and 

other trail users when group size exceeds 12, including 

guides. But the same cannot be said for guided motor 

coach tours driving 21 passenger vans. This decision 

would allow BLM Recreation staff maximum flexibility 

when reviewing new SRP applications. Alternative C is 

more restrictive, limiting all groups to a maximum size of 

15, including guides.

Competitive events of any kind would not be authorized 

in Alternative C. Competitive non-motorized events and 

organized group events could be authorized in the NCA in 

Alternatives B and D, if they meet the following criteria:
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RECREATION AND VISITOR SERVICES COMPREHENSIVE TRAVEL AND TRANSPORTATION MANAGEMENT

4.20 COMPREHENSIVE TRAVEL AND 

TRANSPORTATION MANAGEMENT

TTM is the process of planning for and managing 

transportation systems on public lands. Traditionally, 

BLM’s Travel and Transportation Program focused 

primarily on motor vehicle use. Within the framework 

of TTM, the program has been significantly expanded to 

encompass all forms of transportation, including travel 

by foot, horseback, bicycle, motorcycle, aircraft, and 

four-wheeled vehicles (ATVs, cars, and trucks). This new 

direction is important for the St. George area because 

even though the vast majority of routes in Washington 

County are available for motorized use, the number of 

non-motorized trails is far larger than those of a typical 

BLM field office.

Additionally, TTM expands on the traditional approach 

to transportation planning by implementing an interdisciplinary structure, in that all resources, resource uses, 

and accompanying modes of travel on public lands are 

addressed holistically. The goals, objectives, and desired 

future conditions of all resources and resource uses are 

recognized and addressed with TTM.

4.19.2.16 Impacts from Management of Public 

Education and Interpretation

Developing an interpretive master plan that creates 

a long-term vision to guide interpretive services 

could enhance the visitor experience at trailheads, 

campgrounds, and interpretive sites. It would also raise 

awareness of the fragility of the desert environment and 

encourage recreational users to stay on trails and respect 

the environment.

4.19.2.17 Impacts from Management of Scientific 

Research

One of the biggest gaps in current desert tortoise research is the lack of data about the impacts that nonmotorized recreational activities have on the tortoise. 

The impact of motorized recreation is well documented, 

but there is no valid research on the non-motorized 

side. Questions that need to be answered are: Can a 

well-designed hike/bike trail system coexist with critical 

habitat? What is the “zone of influence” of a trail system? 

The NCA provides the perfect laboratory to conduct such 

studies and the effects of such research could have farreaching implications.

4.19.3 Summary of Impacts from Alternatives

Table 4-10 provides a summary of the impacts to recreation and visitor services. The first column lists the 

resource or resource use that has an impact/effect on recreation. The second column lists whether the action(s) is 

a beneficial effect or an adverse impact. The third column 

provides a brief description of the impact/effect and the 

final column lists the intensity of the impact/effect. A description of intensity levels can be found in the “Methods 

of Analysis” section at the beginning of the Recreation 

and Visitor Services section.

4.19.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on recreation resources includes all of Washington County, 

including Zion National Park and Dixie National Forest, 

Pine Valley Ranger District. It also includes the Northern 

Arizona Strip where roads and trails share the Arizona/

Utah boundary.

At the broadest level, the physical, social, and operational 

recreation character of BLM public lands is changing 

from natural to more developed, from less crowded to 

more contacts with other users, and from less restrictive to more rules and regulations. These changes would 

impact the activity opportunities that can be offered and 

the recreation experience and benefit opportunities that 

can be produced by land managers and partners.

Past and present actions that have had, and continue to 

have cumulative impacts, on recreation include adjacent 

BLM and USFS management plans, increased visitation 

(especially from residents within the planning area and 

those from the surrounding region), local community expansion, and advances in outdoor recreation equipment.

Forest plans for adjacent National Forest System lands 

and RMPs for adjacent BLM-managed lands have closed 

areas and routes to motorized recreation, causing many 

users to move to BLM-administered lands in the SGFO.

Increasing urban and suburban populations in 

Washington County have greatly increased the level 

of recreational use on BLM-managed lands. There is a 

strong correlation between population growth, visitation, 

and recreation in large part because many new residents 

have moved to the area specifically because of easy access 

to recreation opportunities on BLM- managed lands. 

The expanding suburban development footprint has also 

placed many new neighborhoods directly adjacent to 

BLM property boundaries, resulting in increased trespass 

onto private property and resource impacts from private 

property owners accessing public lands from adjoining 

private land.

The combination of the region’s growing population, the 

NCA planning areas longer season of use in comparison 

to many of Utah’s destinations, and the bounty of desirable recreation settings have combined to greatly increase 

use in the planning area.

Advances in technology are at least partly responsible for 

increased recreation across the planning area. Motorized 

vehicles are more capable of accessing any type of terrain, 

improvements in mountain biking have made that activity increasingly popular, and enhancements in equipment 

and clothing have made day hiking and camping more 

accessible to more people.

Reasonably foreseeable trends that would result in 

cumulative impacts on recreation include continued 

growth patterns in demand for all recreation experiences, 

increased demand for close-to-home recreation opportunities for local residents, continued and increased visitation from a growing regional population, and increased 

popularity of adjacent public lands and private resorts.

Resource/Resource Use Impact/Effect Description Intensity

Geological/Paleontological Effect Paleontological surveys could lead to more Public Use sites Unknown

Impact Petrified wood/fossil collection prohibited in Alternatives B, C Minor

Cave and Karst Effect Inventories could lead to increased caving opportunities Unknown

Soils Impact Recreation developments should be sited on stable soils Minor

Native Vegetation Effect Fuel breaks offer potential new trail development options Unknown

Effect Well-designed trails help protect riparian areas Minor

Livestock Grazing Impact Trampling and manure impacts at popular campsites and trails Minor

Effect Alternative C manages NCA as unavailable for grazing, eliminating impacts to recreation sites and facilities Minor

Impact Active grazing season is identical to heaviest recreation use 

periods Minor

Plant Material Uses Impact Collection of dead and downed wood prohibited in Alt C Minor

Special Status Species Impact Balancing recreation use with Special Status Species is difficult Moderate

Heritage Resources Effect Interpretation of heritage resources can enhance experiences Minor

National Historic Trails Effect Adding facilities and exhibits would enhance the visitor 

experiences Moderate

National Natural Landmark Effect Relocating the NNL would make it a popular destination Moderate

Visual Resources Effect Working to preserve night skies would enhance recreation Minor

Natural Soundscapes Effect Preserving natural soundscapes would enhance recreation Negligible

Lands with Wilderness 

Characteristics Effect Lands with wilderness characteristics protected by OPLMA withdrawals and limitations on motorized vehicle use. None

Recreation Effect SRMA status would improve recreation management Moderate

Impact Dispersed camping only in designated sites in Alts B, C, D Minor

Effect New trail construction would improve access and opportunities Moderate

Impact Commercial recreation permits limited to % of overall visitation Negligible

Effect Competitive events could increase public awareness of NCA Minor

Effect Climbing access would be enhanced by a management plan Minor

Impact Geocaching is restricted to Frontcountry Zone in Alt C Negligible

Effect Target shooters must use appropriate backstops Moderate

Effect Target trash will not be tolerated Moderate

Effect Tortoise/non-motorized recreation research is needed Unknown

Transportation Impact Travel management was completed by Congress for most of NCA Major

Effect Closed to OHV designation in Alt C provides no extra protection Negligible

Education Effect Interpretive master plan would enhance recreation over time Moderate

Table 4-10 Summary of Impacts to Recreation and Visitor Services
714 Chapter 4 BDWNCA BDWNCA Chapter 4 715

COMPREHENSIVE TRAVEL AND TRANSPORTATION MANAGEMENT LANDS AND REALTY

Designated Roads and Trails” applies to the entire NCA 

and has been in place since 1990.

4.20.4 Cumulative Impacts

The cumulative impacts analysis boundary for transportation and access includes the planning area and immediately adjacent segments of state and local road networks 

including those in Lincoln County, Nevada and Mohave 

County, Arizona, State Trust Lands, including development actions in and surrounding the planning area 

that could produce long-term cumulative impacts on 

transportation and access. Under all alternatives, there 

would be no variation in OHV area designations. The 

designation of “Limited to Designated Roads and Trails” 

applies to the entire NCA and has been in place since the 

designation of the NCA through OPLMA in 2009.

4.21 LANDS AND REALTY

Lands and realty actions are implemented to support 

various resource management goals, such as land acquisitions to protect habitat. They also authorize public 

uses, such as ROWs or film permits. Because of the 

administrative/support nature of the program, impacts 

are not discussed in relation to the realty program itself, 

but instead to the outcomes of the program, including 

land tenure (ownership) changes and the opportunities 

and constraints on those seeking land use authorizations within the NCA. For example, resource decisions 

to manage areas as Avoidance or Exclusion areas to new 

ROWs to protect special status species’ habitats would 

limit opportunities for the installation of communication 

sites or the construction of utility transmission lines.

4.21.1 Methods of Analysis

4.21.1.1 Indicators

Indicators of beneficial effects on land tenure and land 

use authorizations include the following:

▶ Ability to acquire non-federal inholdings in the 

NCA;

▶ Ability to accommodate the demand for land use 

authorizations;

▶ Ability to accommodate preferred routes or locations for new ROWs, while protecting NCA values.

Indicators of adverse impacts on land tenure and land 

use authorizations include the following:

▶ Inability to acquire non-federal inholdings in the 

NCA;

▶ Inability to accommodate the demand for ROWs 

and other land use authorizations.

Because land tenure adjustments and land use authorizations are a land use, rather than an environmental 

component, impacts on land tenure and land use authorizations are a direct result of actions from other resource 

programs and resource uses. The discussion of the effects 

on land tenure and land use authorizations under each 

alternative is limited to the effects on existing and future 

authorized uses and land tenure, including mitigation 

measures, restrictions, costs, and issuance or denial of 

proposals. Management actions of other resources were 

assessed to determine restrictions or limitations to land 

use authorizations (including ROWs) and land tenure.

4.21.1.2 Assumptions

The analysis includes the following assumptions:

▶ Pursuant to OPLMA Section 1975, BLM will manage all land and interests in land acquired by the 

United States within the National Conservation 

Area as withdrawn from all forms of entry, appropriation, or disposal under the public land laws; 

location, entry, and patent under the mining laws; 

and operation of the mineral leasing, mineral materials, and geothermal leasing laws, subject to valid 

existing rights; 

▶ Under all alternatives, BLM would work with holders of mining claims that were active at the time of 

NCA designation to provide reasonable access to 

these claims, but would ensure that undue and unnecessary degradation of NCA resource values does 

not result from access or development activities. 

Claimants could be impacted to varying degrees by 

reasonable requirements to prevent undue and unnecessary degradation of NCA resources;

▶ Under all alternatives, reasonable access would be 

allowed to the State School Trust Lands so that those 

lands can be developed in a manner that will provide 

funds for the common schools (Cotter Decision, 

State of Utah v. Andrus, 486F. supp. 996, 1979);

▶ Land acquisitions will depend upon having willing 

sellers and available funding;

▶ Land acquisitions will acquire both surface and 

subsurface rights, whenever possible, to avoid the 

creation of split estates;

▶ All land use authorizations would be managed to 

minimize impacts on the ecological, scenic, wildlife, 

recreational, cultural, historical, natural, educational, and scientific resources of the NCA; 

▶ ROW holders may continue their authorized use as 

long as this use is in compliance with the purposes 

At the land use planning level, travel and transportation 

management is limited to Off-Highway Vehicle Area designations. Individual route designations are implementation-level decisions.

OHV area designations support resource programs 

and are designed to help achieve their objectives. Those 

designations adhere to the management prescriptions for 

all other resources and resource uses in each alternative. 

As a support function, transportation and travel management is not impacted by other resources and resource 

uses. Instead, transportation and travel management decisions impact other resources and resource uses. These 

impacts are discussed in each of the individual resource 

sections. The existing conditions for travel and transportation management are described in Section 3.19 Travel 

and Transportation Management. The travel plan for 

the NCA mirrors the aspirational goals of the individual 

alternatives in this plan. 

4.20.1 Methods of Analysis

Impacts are quantified where possible. In the absence 

of quantifiable data, professional judgment was used. 

Impacts are sometimes described using ranges of potential impacts or in qualitative terms, if appropriate. 

Impacts can be both adverse and beneficial. To avoid 

confusion on the part of the reader, in this document 

they are defined as adverse impacts or beneficial effects.

Adverse impacts to Travel and Transportation 

Management could result from management actions that 

diminish any of the fundamental components listed in 

the indicators section below. 

Beneficial effects could result from management actions 

that maintain or enhance any of the fundamental components listed in the indicators section below. 

4.20.1.1 Indicators

The area designations created by Congress in OPLMA, 

and the management approach and assumptions for 

each alternative would guide the area designations in 

this plan and set the stage for future route designations within the BDWNCA. Such designations would 

only be applied outside the area designations created 

by Congress. The Congressional area designations are 

Limited to Designated Roads and Trails. The indicator 

is the number of acres designated as open, closed, and 

limited to designated roads and trails on public lands 

within the BDWNCA.

4.20.1.2 Assumptions

The analysis includes the following assumptions:

▶ Individual route designations are implementationlevel decisions that will be addressed in the TMP 

and tiered to the OHV Area Designations in this 

Amendment;

▶ There would be no impact on use of existing highways or county-maintained roads. The existing 

transportation network is extensive enough to meet 

current and known transportation needs;

▶ Reasonable access will be allowed to the State 

School Trust Lands so that those lands can be developed in a manner that will provide funds for the 

common schools (Cotter Decision, State of Utah v. 

Andrus, 486F. supp. 996, 1979);

▶ Proposed area designations would not affect ROW 

holders, permitted uses, county or state roads, or 

other valid existing rights. Travel closures and limitations apply only to public access.

4.20.2 Direct and Indirect Impacts

Management decisions for the following resources 

would have negligible or no impact on Travel and 

Transportation Management and are, therefore, 

not discussed in further detail: Air Quality, Water 

Resources, Geologic and Paleontological Resources, 

Cave and Karst Resources, Soil Resources, Native 

Vegetation Communities and Fire and Fuels, Noxious 

Weeds and Invasive Species, Vegetation Resource 

Uses: Livestock Grazing, Vegetation Resource Uses: 

Plant Materials, Special Status Species, Other Fish and 

Wildlife Species, Heritage Resources, National Historic 

Trails, National Natural Landmarks, ACECs, Visual 

Resource Management, Natural Soundscapes, Recreation 

and Visitor Services, Comprehensive Travel and 

Transportation Management, Lands and Realty, Public 

Education and Interpretation, and Scientific Research.

4.20.2.1 Impacts from Comprehensive Travel and 

Transportation Management

Proposed OHV Designations

Under all alternatives, management that is in place would 

continue and the entire NCA would be managed as 

Limited to Designated Roads and Trails. There would be 

no impacts to OHV area designations as current management would continue.

4.20.3 Summary of Impacts from Alternatives

Under all alternatives, there would be no variation in 

OHV area designations. The designation of “Limited to 
716 Chapter 4 BDWNCA BDWNCA Chapter 4 717

LANDS AND REALTY LANDS AND REALTY

4.21.2.2 Impacts from Management of Heritage 

Resources and National Historic Trails

Under Alternative A, the NCA would be managed as 

a ROW Avoidance area, with the exception of the 196 

acre designated corridor along Old Highway 91. New 

ROWs could be granted for the development of power 

lines, pipelines, or other utilities in that designated corridor. Compliance with Section 106 of the NHPA would 

require inventory, resource assessments, and avoidance 

of adverse impacts or the implementation of mitigation 

measures for NRHP-eligible or listed properties, including those associated with the OST. This management 

decisions would generally require that proponents to 

find alternative locations outside the NCA, potentially 

increasing project costs. The requirements related to the 

protection of heritage resources within the designated 

corridor could also increase project costs and result in 

construction delays

Under Alternates B and D, the NCA would be managed 

as a ROW Exclusion area, with the designated corridor 

along Old Highway 91 retained, but with variable widths 

by alternative. The narrow corridor widths proposed under either alternative would preclude large scale projects. 

Both alternatives would restrict new ROWs to subsurface 

installations only. These management decisions would 

also generally require that proponents to find alternative 

locations outside the NCA, potentially increasing project costs. The requirements related to the protection of 

heritage for developments within the designated corridor 

could also increase project costs and result in construction delays.

Alternative C would revoke the designated utility and 

transportation corridor along Old Highway 91 through 

the NCA, eliminating impacts on special status species 

and habitats, related to the development of new utilities 

in that corridor. These management decisions would always require that proponents to find alternative locations 

outside the NCA, potentially increasing project costs.

4.21.2.3 Impacts from Management of Visual 

Resources

Alternative A would continue to manage the NCA as 

VRM Class III and the designated utility corridor along 

Old Highway 91. These VRM classes would not impact 

the siting of new ROWs for utilities within the designated 

corridor, as necessary changes to the existing character of 

the landscape can be made under VRM Class III.

Alternatives B and D would manage the NCA as 

VRM Class II, providing a higher level of protection 

to the scenic qualities of the NCA, when compared to 

Alternative A. In these two alternatives, a narrow designated utility corridor would be retained on both sides 

of Highway 91, but new ROWs limited to underground 

installation, similar to the existing fiber-optic line already 

installed on the east side of the highway. Because underground installation is low impact to visual resources, the 

VRM Class II designation would remain in both alternatives and would comprise a minor impact on lands and 

realty actions. 

Alternative C would manage the NCA as VRM Class 

II and revoke the designated utility corridor along Old 

Highway 91. The NCA would be designated a ROW 

Exclusion area and no new linear ROW for highways, 

roads, or utility development could be authorized. This 

alternative would negatively impact the lands and realty 

program by eliminating options for land uses authorized 

by linear or site-type ROWs.

4.21.2.4 Impacts from Management of Lands and 

Realty

Valid existing ROWs would continue to be recognized, 

until relinquished, under all alternatives. 

Alternative A would continue the current designation of 

the NCA as a ROW Avoidance area and maintain the designated corridor of variable widths along Old Highway 

91. New ROWs for linear and site-type ROW could continue to be granted, within the designated corridor and at 

existing communication sites. New ROWs could potentially be granted elsewhere in the NCA, if specific criteria 

identified in the 1999 St. George RMP were to be met. 

This alternative would provide the greatest flexibility for 

the Lands and Realty program and the fewest constraints 

on fulfilling demand for new ROWs.

Alternatives B and D would manage the NCA as a ROW 

Exclusion area for linear ROWs, retain the designated 

corridor along Old Highway 91, but limit new ROWs 

for utilities to those types of linear facilities, such as 

fiber-optic lines or small pipelines, that can be feasibly 

and economically be installed subsurface and within a 

narrow designated corridor that is bisected by a paved 

highway. As the only linear ROW currently developed 

within this corridor is a fiber-optic line, it is likely that 

industry demand can be met in the short and long term. 

The NCA would be managed as an Avoidance area for 

site-type ROWs, unless specific criteria can be met. This 

alternative would restrict the types of land use authorizations that could be made, creating a negative and minor 

to moderate impact on the Lands and Realty program.

for the ROW and the terms and conditions of the 

grant;

▶ Upon renewal, assignment, or amendment of existing ROWs, additional mitigation or modification 

stipulations may be included, if the requested actions do not adequately protect NCA values.

Implementing management for the following resources 

or resource uses would have no impact or negligible 

impacts on land tenure and land use authorizations and 

are, therefore, not discussed in detail: Air Quality, Water 

Resources, Geologic and Paleontological Resources, 

Cave and Karst Resources, Soil Resources, Native 

Vegetation Communities, Fire and Fuels Management, 

Noxious Weed and Invasive Species Management, 

Vegetation Resource Uses: Livestock Grazing, Vegetation 

Resource Uses: Plant Materials, Other Fish and Wildlife 

Species, National Natural Landmarks, ACECs, Natural 

Soundscapes, Lands with Wilderness Characteristics, 

Recreation and Visitor Services, Comprehensive Travel 

and Transportation Management, Public Education and 

Interpretation, and Scientific Research.

4.21.2 Direct and Indirect Impacts

Under all alternatives, no public lands would be transferred out of federal ownership, pursuant to OPLMA, 

thereby protecting resource values of the NCA. Over the 

life of the RMP, a maximum of 8,619 acres of non-federal 

land within the NCA could be acquired through purchase, exchange, transfer, or donation.

Alternative A would continue to manage the NCA as 

a ROW Avoidance area and retain the existing Old 

Highway 91 designated corridor, with a variable width, 

would preclude large scale linear or site-type developments. New right-of-way proponents would be encouraged to locate proposed facilities within the designated 

Old Highway 91 corridor or other designated corridors 

that are outside the NCA boundaries. This management 

decision could increase costs for project proponents.

Alternatives B and D would manage the NCA as a ROW 

Exclusion area for linear ROWs and retain the existing Old Highway 91 designated corridor, define specific 

widths for the corridor, and require that ROWs be limited to underground installations that could be accommodated within a narrow corridor bisected by a paved 

highway. For site-type ROWs, Alternatives B and D 

would manage the NCA as an Avoidance area, with specific criteria. These management decisions would generally require that proponents to find alternative locations 

outside the NCA, potentially increasing their costs. 

Alternative C would manage the NCA as a ROW 

Exclusion area for linear and site-type ROWs and revoke 

the designated utility corridor along Old Highway 91 

through the NCA. These management decisions would 

require that proponents to find alternative locations outside the NCA, potentially increasing project costs.

4.21.2.1 Impacts from Management of Special Status 

Species, Including BLM Sensitive Species

Under Alternative A, the NCA would be managed as a 

ROW Avoidance area, with the exception of the 196 acre 

designated corridor along Old Highway 91. New ROWs 

could be granted for the development of power lines, 

pipelines, or other utilities in that designated corridor. 

Impacts to desert tortoise and other special status species 

would be avoided to the extent possible through project design, BMPs, and stipulations developed through 

Section 7 consultations and project-specific Biological 

Opinions. Adverse modification of designated critical 

habitat would be mitigated, through compensation or 

habitat acquisition. Impacts to avian species related to 

power lines would also be mitigated through 

project design. 

The requirements related to the protection of habitats 

and populations of special status species could increase 

project costs and result in construction delays.

Under Alternates B and D, the NCA would be managed 

as a ROW Exclusion area, with the designated corridor 

along Old Highway 91 retained, but with variable widths 

by alternative. The narrow corridor widths proposed under either alternative would preclude large scale projects. 

Both alternatives would restrict new ROWs to subsurface 

installations only. These management decisions would 

generally require that proponents to find alternative 

locations outside the NCA, potentially increasing project 

costs. The requirements related to the protection of habitats and populations of special status species for developments within the designated corridor could also increase 

project costs and result in construction delays.

Alternative C would revoke the designated utility and 

transportation corridor along Old Highway 91 through 

the NCA, eliminating impacts on special status species 

and habitats, related to the development of new utilities 

in that corridor. These management decisions would 

require that proponents to find alternative locations outside the NCA, potentially increasing project costs.
718 Chapter 4 BDWNCA BDWNCA Chapter 4 719

LANDS AND REALTY SOCIAL AND ECONOMIC CONDITIONS

4.22 SOCIAL AND ECONOMIC CONDITIONS

Socioeconomics addresses the social and economic effects of management of BLM-administered land. In this 

context, the word “impact” may indicate positive or negative effects, depending on the context. For instance, an 

alternative may have a particular stated economic impact 

on the socioeconomic study area (Washington County) 

in terms of economic output, labor income, and jobs; this 

impact can be considered a benefit to the economy, but 

may also represent a loss of economic activity compared 

to another alternative.

4.22.1 Methods of Analysis

4.22.1.1 Assumptions

The analyses in this section are based on the following 

assumptions: 

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ Marketplace economic benefits (e.g., labor earnings and employment) to the socioeconomic study 

area (Washington County) will accrue from certain 

activities on BLM-administered land, identified in 

the analyses below;

▶ Nonmarket values will accrue from a range of activities on BLM-administered land, identified in the 

analyses below;

▶ Government revenues (fees, payments in lieu 

of taxes, etc.) derived from activities on BLMadministered lands will continue to be modest and 

not change dramatically over the course of the planning period given the types of activities anticipated 

during the planning period (e.g., no revenues from 

energy minerals);

▶ Demand for use of BLM-administered land for livestock grazing will remain at historical rates through 

the study period;

▶ Demand for use of BLM-administered land for 

recreational activities, including motorized and 

non-motorized use, will remain steady or increase 

through the study period;

▶ Activities and resources available on BLMadministered land will continue to be important to 

the quality of life of current and future study area 

residents;

▶ Employment and labor income, along with migration of retirees who bring non-labor income, will 

continue to be the main drivers of economic and 

population growth in the socioeconomic study area.

4.22.1.2 Economic Impact Analysis – Market Values

This subsection describes methods related to analysis of 

economic impacts that are reflected in market transactions. The next subsection describes methods for analysis 

of impacts to nonmarket values. The analysis of marketbased economic impacts uses two general approaches: 

quantitative analysis and qualitative analysis.

4.22.1.3 Quantitative Analysis using the IMPLAN 

Model

The quantitative analysis approach is used when possible 

given adequate available information. In this study, adequate data were available for quantitative analysis for two 

resource uses: livestock grazing and recreation. The basic 

strategy used is to first identify and quantify the primary 

impacts of an economic activity affected by management decisions. For instance, primary impacts include 

the value of livestock sold to the cattle market (specifically, the portion of that value attributable to grazing on 

BLM-administered public lands), and the expenditures 

made locally by recreationists for food, lodging, gasoline, 

guide services, and other goods and services attributable 

to recreation on BLM-administered land. Next, where 

primary impacts can be quantified, they can generally 

also be run through an economic model to estimate the 

economic activity that is generated as the primary impact 

ripples through the economy, “upstream” to providers of 

goods and services necessary for production, and “downstream” as income generated from production is spent by 

the households that receive the income.

The upstream, downstream, and total effects are estimated in this study through use of the IMPLAN (Impact 

analysis for Planning) model. The IMPLAN model was 

originally developed by the USFS and is commonly used 

by the BLM and many other government and private sector organizations to estimate the total economic impacts 

of various activities, actions, and policies. The model 

tracks inter-industry and consumer spending in a local 

(or regional) economy, allowing estimation of indirect 

and induced economic impacts in the local economy that 

result from the original economic activity or a change 

in economic activity. Indirect impacts result from local 

inter-industry purchases caused by the direct impact; for 

example, when a recreation outfitter purchases supplies 

from other local businesses. Induced impacts result from 

re-spending of labor income; that is, local purchases of 

groceries, medical services, and other goods and services 

In Alternative C, the NCA would be designated as a ROW 

Exclusion area for linear and site-type ROWs and the 

existing Old Highway 91 designated corridor would be revoked through the NCA. The impacts on the authorization 

of land use ROWs would be negative, moderate to major 

and long-term on the Lands and Realty program. The 

impacts would reflect the narrow width of the designated 

corridor along Old Highway 91 that currently limits the 

size and number of linear ROWs that could be built in that 

corridor. The proximity of two, one-mile wide designated 

corridors, the IPP and Navajo McCullough corridors, 

along the boundaries of the NCA would also lessen the 

impact, as these provide opportunities for new and large 

scale transmission lines, pipelines, and other linear ROWs 

to be granted to meet industry demand. 

4.21.3 Summary of Impacts from Alternatives

Alternative A would continue the current designation of 

the NCA as a ROW Avoidance area and maintain the designated corridor of variable widths along Old Highway 91. 

New ROWs for linear and site-type ROW could continue 

to be granted, within the designated corridor and at existing communication sites. New ROWs could potentially be 

granted elsewhere in the NCA, if specific criteria identified 

in the 1999 St. George RMP were to be met. This alternative would provide the greatest flexibility for the Lands 

and Realty program and the fewest constraints on fulfilling 

demand for new ROWs.

Alternatives B and D would manage the NCA as a ROW 

Exclusion area for linear ROWs, retain the designated corridor along Old Highway 91, but limit new ROWs for utilities 

to underground installations. Site-type ROWs would need 

to meet specific criteria to be authorized in the NCA. This 

alternative would restrict the types of land use authorizations that could be made, creating a negative and minor to 

moderate impact on the Lands and Realty program.

In Alternative C, the NCA would be designated as a ROW 

Exclusion area for linear and site-type ROWs and the 

existing Old Highway 91 designated corridor would be revoked through the NCA. The impacts on the authorization 

of land use ROWs would be negative, moderate to major 

and long-term on the Lands and Realty program.

4.21.4 Cumulative Impacts

The CIAA is identified as western Washington County, 

southeastern Nevada, and northern Arizona. Cumulative 

impacts to land tenure and land use authorizations occur 

through changes in land tenure, through special designations, through the development of land resources and in 

changes in access to the land. 

Past human-caused actions within the CIAA included 

the settlement and expansion of communities, land 

tenure adjustments through sale, exchange, transfer, and 

donation, and the construction road, highway, and utility 

construction, water developments and diversions. 

Present and reasonably foreseeable future actions would 

include continued regional population growth, the 

expansion of rural and urban communities, land tenure 

adjustments, and the granting of ROWs across public 

lands for energy transmission, highways, water development projects, and communication sites. There are no 

reasonably foreseeable future projects involving land use 

authorizations and land tenure adjustments of federal, 

state, and private lands in the CIAA:

The number of land use authorizations granted for use 

of public lands, particularly ROWs and permits, is a 

function of demand for these uses. Future development 

of adjacent state and private lands would likely result in 

additional requests for and approval of land use authorizations for facilities such as roads, utilities, and communication sites. 

Over the life of the RMP, land tenure adjustments 

could result in the acquisition of a maximum of 8,619 

acres of non-federal land within the boundaries of the 

NCA through purchase, exchange, transfer, or donation. No disposal of public lands within the NCA could 

occur, reducing the pool of lands available for transfer from federal ownership by approximately 63,500 

acres. Management of the NCA as an Avoidance and/

or Exclusion area for linear and site-type ROWs would 

have a cumulative impact of reducing or precluding the 

granting of new ROWs for use of public lands within the 

NCA. Demand for these land use authorizations would 

be displaced to other federal, state, or private lands 

within the CIAA.
720 Chapter 4 BDWNCA BDWNCA Chapter 4 721

SOCIAL AND ECONOMIC CONDITIONS SOCIAL AND ECONOMIC CONDITIONS

▶ Snow Canyon State Park visitor expenditure data 

(Utah State Parks 2009) for local visitors were 

utilized for “Day Trip – Local” visitor expenditures. 

Based on this park’s location in proximity to the 

St. George metropolitan area, which is probably 

the origin of most local users of the NCA, this data 

source was considered to match well to this BLM 

visitor segment. Expenditure data for non-local 

park visitors could not be broken down by the 

camping and motel use segments used in the BLM 

NCA visitation data, and were not utilized.

▶ National Visitor Use Monitoring (NVUM) survey 

expenditure data for U.S. National Forests (White 

et al. 2013) were utilized for all recreation segments 

except “Day Trip – Local.” The NVUM program 

provides a robust data source (most national forests 

are surveyed on a five-year cycle) that is widely 

used for recreation economic impact analysis for 

areas besides USFS-managed lands. This is done by 

identifying national forest units that are reasonably 

analogous to another recreation management area, 

and applying the recreational expenditure data from 

NVUM to other area-specific recreation use data 

or estimates. The Pine Valley Ranger District of the 

Dixie National Forest is classified as an averageexpenditure National Forest, thus the NVUM 

expenditure data for this class of forest were utilized 

for the NCA economic impact analysis. The NVUM 

expenditure data are based on the NVUM survey 

expenditure data across all forests in that class, thus 

it is statistically a very robust dataset.

by households of employees of the affected industries. 

The re-spending within a socioeconomic study area 

represented by indirect and induced impacts is often 

referred to as the “multiplier effect.” Outputs of the 

IMPLAN model include employment, labor income, and 

gross regional economic output. It is important to note 

that IMPLAN, based on some of its data sources, does 

not distinguish between full-time and part-time jobs. 

Sectors with higher labor earnings per job are likely to 

reflect a high proportion of full-time jobs, while sectors 

with low labor earnings per job often reflect a significant 

number of part-time jobs.

The specific methodology used for the IMPLAN analysis 

for grazing involved three major steps:

▶ Identifying the amounts of forage utilized on BLMadministered lands in the NCA under each management alternative;

▶ Estimating the direct economic value per unit of 

forage use;

▶ Estimating the economic impacts based on the total 

value of production.

The amount of forage utilized within the Beaver Dam 

Wash NCA was determined by review of BLM grazing 

permits for the four grazing allotments that include land in 

the NCA. BLM range specialists estimated the animal unit 

months (AUMs) of forage available on the NCA portions 

of the four allotments. One AUM is equal to the amount of 

forage consumed by a cow and calf during a 1 month grazing period. The economic impact analysis assumes that 

actual use of the total AUMs allocated to grazing would 

occur at recent historical rates. Specifically, over the period 

2007–2011, billed use was 57.1 percent of total permitted 

use for three of the four allotments that overlap the NCA 

(data were not available for the Cedar Pockets allotment). 

This percentage was applied to the total AUMs that would 

be available within the NCA under each alternative. Actual 

use is likely to vary from year to year; the economic impacts would vary accordingly.

The direct value of production per AUM was estimated 

based on state livestock production value data and ratios 

in the livestock economics literature. According to 

Workman (1986), it takes 16 AUMs to produce a marketable cow. Thus, the average value of an AUM can be 

estimated using data on the value of cattle production 

per bred cow and dividing by 16.

The value per AUM for cattle was based on an 8 year 

average (2005–2012) of the annual value of production of 

cattle and numbers of bred cows statewide from statistics 

of the Utah Department of Agriculture and Food (2013). 

The methodology and data for calculation of the average 

value of cattle production from one AUM of forage are 

shown in Table 4-11.

The average value per AUM was multiplied by the 

number of AUMs available in each alternative. The result 

was the total economic value of livestock production, 

which was entered into Sector 11, Cattle Ranching and 

Farming, of the IMPLAN model. The model calculated 

“leakage” of some of this value out of the socioeconomic 

study area, and the “multiplier effect” re-spending of the 

remaining value within the study area.

The quantitative economic impact analysis for recreation 

involved three major steps:

▶ Quantifying recreation use levels for the NCA 

(number of visits by recreation “segment”);

▶ Estimating the local expenditures per visit by recreation segment;

▶ Estimating the economic impacts based on the total 

expenditures.

The economic impact results for recreation consist of one 

set of figures for all alternatives. The analysis does not address differences between the alternatives. This is because 

the differences in management actions affecting recreation 

cannot be quantified. Differences in impacts between the 

alternatives are discussed qualitatively. It is also important to note that the analysis assumes future recreation 

use levels remain constant at recent actual use levels. This 

assumption may mean that the results underestimate the 

economic effects of recreation. Population trends in the 

United States, the Rocky Mountains and the socioeconomic study area would tend to indicate that travel and recreation will increase in the future; however, it is not entirely 

clear that outdoor recreation is increasing.

The SGFO tracks recreation use levels in the NCA, based 

on data from traffic counters, visitor registers, and interactions between field office staff and recreationists. Data 

for 2013, presented in Table 4-12, were utilized for the 

economic impact analysis.

A variety of data sources were considered for development of estimates of local expenditures per visit by recreation segment, as follows:

▶ National Park visitor expenditure data for two 

nearby national park units (Zion National Park and 

Cedar Breaks National Monument) were rejected 

because these areas see high levels of international 

visitation, which is not consistent with Beaver Dam 

Wash NCA visitation.

Trip Description Visitor 

Type

Visitor 

Count

Percent

Day Trip—Local Local 3,052 34.

Day Trip—Non-local Non-local 2,806 31.6

Overnight—Camping Local 487 5.5

Overnight—Camping Non-local 2,545 28.6

Overnight—Motel Non-local 0 0.0

Total 8,890 100

(Source: BLM recreation data.)

Year Value of 

Production 

(1,000 $s)1

Beef Cows That 

Have Calved 

(1,000 Head)2

Value Per Cow Conversion to 

AUMs (AUMs/

Cow)3

Value of Production 

Per AUM (Nominal 

$)

Value of 

Production Per 

AUM (2013 $)4

2005 $351,595 347 $1,013.24 16 $63.33 $74.92

2006 $250,377 325 $770.39 16 $48.15 $55.09

2007 $222,428 344 $646.59 16 $40.41 $44.91

2008 $194,134 365 $531.87 16 $33.24 $36.10

2009 $185,904 350 $531.15 16 $33.20 $35.60

2010 $221,377 336 $658.86 16 $41.18 $43.71

2011 $261,808 333 $786.21 16 $49.14 $51.09

2012 $277,971 330 $842.34 16 $52.65 $53.75

Average 2005–2012 (8 years) $45.16 $49.39

1

Utah Department of Agriculture and Food 2013, p. 51.

2

Utah Department of Agriculture and Food 2013, p. 50.

3Workman 1986.

4

Nominal dollars adjusted to 2013 dollars by applying gross domestic product (GDP) deflator factors (GDP chained price 

index) from the 2014 Federal Budget Historical Tables, accessed February 2014 at http://www.whitehouse.gov/omb/budget/

Historical.

Table 4-12 Recreation Visitation at the Beaver Dam Wash 

NCA 2013

Table 4-11 Value of an AUM for Cattle Production
722 Chapter 4 BDWNCA BDWNCA Chapter 4 723

SOCIAL AND ECONOMIC CONDITIONS SOCIAL AND ECONOMIC CONDITIONS

The results of the analysis for grazing are taken to represent the economic impact of that activity, since local 

residents buy only a very small proportion of the total 

output of the livestock industry. In the case of recreation, 

however, local residents make considerable recreationrelated expenditures (gas, food, and so on while on local 

trips), so it is fair to include those expenditures in an 

analysis of the economic role (“contribution”) of recreation. Put another way, expenditures by local and nonlocal recreationists alike help keep local businesses going. 

However, the term “economic impact” is used in both 

cases for simplicity.

All dollar figures for the results below are in constant 2013 

dollars. The base year used in the IMPLAN model is 2012, 

the latest year for which IMPLAN datasets are available. 

Adjustments were made to model inputs and outputs to 

properly account for differences in the dollar year.

4.22.1.4 Qualitative Analysis

Where primary impacts cannot be readily quantified, often the economic impacts can still be described 

qualitatively. In such cases, the focus of the analysis is 

to describe the type of impact in a base scenario (here, 

Alternative A) and then assess the relative changes (qualitative indications of increases or decreases in costs or 

the value of production) that would be likely under other 

alternatives. In this study, the market-based economic 

effects of the alternatives were addressed qualitatively for 

the following resource uses: plant materials harvesting, 

recreation (in addition to the quantitative analysis), lands 

and realty management, and special designations.

4.22.1.5 Economic Impact Analysis- Nonmarket Values

The term nonmarket values refers to the benefits individuals attribute to experiences of the environment 

or uses of natural and cultural resources that do not 

involve market transactions and therefore lack prices. 

Nonmarket values capture a wide range of benefits (or 

costs), including those associated with the direct use 

of a resource (for example, the benefits received from 

hiking in a wilderness), as well as those associated with 

indirect uses of a resource (for example, flood prevention 

provided by a wetland). These are collectively referred to 

as use values. Nonmarket values also include what are referred to as passive use values, which include the benefits 

provided by leaving a natural resource in a particular 

condition for future generations (bequest value) or the 

benefits provided by knowing that a resource exists in a 

particular condition (existence value). Because these values are not generally expressed in the marketplace, they 

are difficult to estimate but nonetheless BLM guidance 

calls for efforts to be made to identify and assess impacts to nonmarket values in the planning process (BLM 

Instruction Memorandum No. 2013-131, Guidance on 

Estimating Nonmarket Environmental Values, May 31, 

2013). The Socioeconomic Baseline Report discusses 

nonmarket values further. Nonmarket values associated 

with Alternative A are analyzed qualitatively in this EIS, 

as are the impacts of the action alternatives on nonmarket values, generally relative to Alternative A.

4.22.1.6 Social Impact Analysis

Social impacts may be driven by economic impacts, such 

as when changes in employment due to management 

decisions lead to impacts on population, housing, and 

community services. Other impacts may be more purely 

social and cultural in nature and can include impacts on 

quality of life, recreation values, amenity values, and traditional land uses and associated cultural values. Social 

impacts may be marginal or substantial, depending on 

the degree to which new and revised management actions alter the course set in previous BLM decisions.

Sometimes social impacts can be quantified; however, in 

this analysis social impacts are described qualitatively. 

Based on the management actions under consideration, 

the alternatives will not produce major differences in 

local employment or other factors that would lead to 

quantifiable impacts on population, housing, and community services.

The qualitative social impacts analysis approach used 

here is to address impacts based on the varying points 

of view of key types of stakeholders. The Socioeconomic 

Baseline Report (Pinkham 2012) identifies several broad 

categories of stakeholders to this planning process. These 

categories reflect different linkages people have to public 

lands. They also reflect distinct sets of attitudes, beliefs, 

values, opinions, and perceptions about public resources 

and the effects of various management policies and 

actions. Categorization of stakeholders is not meant to 

imply that all individuals and social groups fit neatly into 

a single category; many specific individuals or organizations may have multiple interests and would see themselves reflected in more than one stakeholder category. 

The point of categorization is to allow differentiation of 

social impacts based on broad differences in points of 

view. The social impacts analysis below assesses the alternatives against the different points of view in the broad 

stakeholder categories.

Table 4-13 summarizes the expenditure figures used for 

the economic impact analysis, by recreation segment. The 

original data for both Snow Canyon and NVUM are expressed as per party spending; figures were adjusted to per 

person spending by applying an average group size of 2.3. 

This is the average group size as determined by the BLM.

Total expenditures by recreation segment are the product of multiplying the NCA visits per segment by the 

expenditures per visit per person for the applicable 

segment. The expenditures were parsed into the following IMPLAN model sectors (Table 4-14) according to 

the expenditure distributions for each segment from the 

expenditure source data.

The model calculates “leakage” of some of the expenditures out of the socioeconomic study area; e.g., expenditures at gasoline stations largely flow out of the study 

area, while a higher proportion of expenditures at food 

service establishments remains in the study area, due to 

the higher local labor requirements of this industry. The 

total economic impacts are the direct impacts (the initial 

expenditures that stay in the study area) plus the indirect 

and induced impacts (the “multiplier effect”) from the 

re-spending of the expenditures that remain within the 

study area.

The term “economic impact” is often used loosely in EISs. 

In the field of regional economics, “economic impact” 

refers specifically to the effects of “new” income in the 

study area. Thus, it is an appropriate measure to use for 

activities such as oil and gas development and livestock 

grazing, which export much of their product out of the 

socioeconomic study area, and, thereby, bring new income into the study area. For the recreation industry, the 

economic analysis is technically an analysis of “economic 

contribution,” which includes the effects of all spending 

attributable to BLM-administered land by recreationists from outside the study area (new income), and of 

spending by recreationists who live within the study area 

(recycled income).

Trip Description Visitor Type Total Expenditures 

Per Visit Per Person

Source/Comments

Day Trip—Local Local $43.79 Snow Canyon State Park (Utah State Parks 2009).

Day Trip—Non-local Non-local $29.70 NVUM (White et al. 2013)

Overnight—Camping Local $31.08 NVUM (White et al. 2013)

Overnight—Camping Non-local $29.61 NVUM (White et al. 2013)

Overnight—Motel Non-local $73.11 NVUM (White et al. 2013). Snow Canyon non-local park 

visitor expenditure is similar.

Number Sector Name

324 Retail—Food and Beverages

326 Retail—Gasoline Stations

328 Retail—Sporting Goods, Hobby, Book, 

Music

330 Retail—Miscellaneous

336 Transit and Ground Passenger 

Transportation

402 Recreation and Entertainment

406 Museums, Historical Sites, Zoos, and Parks

409 Amusement Parks, Arcades, Etc.

410 Other Amusement and Recreation 

Industries

411 Hotels and Motels

412 Other Accommodations

413 Food Services and Drinking Places

Table 4-13 Expenditures by Per Visit Per Person by Recreation Segment

Table 4-14 IMPLAN Model Sectors
724 Chapter 4 BDWNCA BDWNCA Chapter 4 725

SOCIAL AND ECONOMIC CONDITIONS SOCIAL AND ECONOMIC CONDITIONS

designation. If recreational use of the NCA increases, 

the economic benefits of recreation to the Washington 

County economy would increase. If recreation activity 

were to change, the economic impacts would occur at the 

rates per 1,000 visits shown in Table 4-16.

Lands and realty management actions sometimes have 

important economic implications. ROWs on BLMadministered land are sometimes important to local or 

regional economic development. Alternative A provides 

for a utility ROW corridor of 196 acres and designates 

the remainder of the NCA as an Avoidance area for new 

ROWs. Thus, Alternative A allows for some level of future development of ROWs in the designated corridor. 

Under Alternative A, BLM lands and realty actions could 

include acquisition of state and private lands within the 

NCA. BLM would work with willing property owners or 

administrators to acquire NCA in-holdings and edgeholdings that are in the public interest. The economic 

effect of land passing from private to BLM ownership is 

a reduction in local government property taxes from the 

parcel. At the same time, federal payments through PILT 

to local government typically increase.

Special designations of land for conservation purposes 

(parks, monuments, NCAs, wilderness areas, other conservation lands) often raise concerns about potential negative 

impacts on traditional, commodity-based uses of public 

lands, but also often attract “amenities-based” economic 

4.22.1.7 Environmental Justice Impact Analysis

The Socioeconomic Baseline Report provides definitions 

and describes methods for analysis of potential environmental justice (EJ) issues. In short, the baseline report 

presents a screening analysis designed to identify communities within Washington County with minority or 

low-income populations that qualify as potential EJ populations based on guidance from the CEQ. This analysis 

identified two potential EJ populations in Washington 

County. The EJ section below provides a qualitative assessment of the likelihood of disproportionately adverse 

human health or environmental (including economic) 

impacts to these populations.

4.22.2 Social and Economic Effects

4.22.2.1 Summary Economic Impact Tables

This section summarizes the quantitative analysis of the 

market value economic impacts of the alternatives. For 

this study, adequate data were available for livestock grazing and recreation to allow quantitative economic impact 

analysis using the IMPLAN model. Table 4-15 shows 

the results of the IMPLAN analysis of the market-based 

economic impacts of grazing by alternative.

The results in 14 are based on analysis of the production value of the AUMs allocated to livestock grazing in 

the NCA under each alternative. These results assume 

that actual use of the total AUMs allocated to grazing 

would occur at recent historical rates. Specifically, over 

the period 2007–2011, billed use was 57.1 percent of 

total permitted use for three of the four allotments that 

overlap the NCA (data were not available for the Cedar 

Pockets allotment). This percentage was applied to the 

total AUMs that would be available within the NCA under each alternative. Actual use is likely to vary from year 

to year; the economic impacts would vary accordingly.

Table 4-16 shows the results of the IMPLAN analysis of 

the market-based economic impacts related to recreation, including the impacts of motorized recreation 

(management actions under Comprehensive Trails and 

Travel Management).

The economic impact results in Table 4-16 are the best 

estimates that can be made given current estimated 

visitation levels and the nature of the recreation-related 

management actions. It is not possible to reliably estimate differences in recreational visitation levels under 

the different alternatives. None of the management actions in the alternatives would result in definitively quantifiable changes to recreational use of the NCA. While 

the alternatives cannot be differentiated quantitatively 

for recreation, some potential differences in market and 

nonmarket values associated with recreation are discussed in the alternative-focused sections below.

The tables above show that for the NCA, the economic 

impacts of recreation exceed the economic impacts 

of grazing. For instance, under Alternative A the total 

economic output generated by recreation in the NCA is 

$227,500, while the total economic output generated by 

grazing (assuming average actual use rates) is $148,600.

4.22.2.2 Alternative A

Economic Impacts-Market Values

The following resource uses may have economic impacts 

that are reflected in market transactions: plant materials 

harvesting, grazing, recreation, lands and realty management (land acquisitions and ROWs), and special designations. Of these, only grazing and recreation are amenable 

to quantification. The impacts of the other resource uses 

are addressed qualitatively only.

Alternative A allows for noncommercial harvesting of fuelwood and Christmas trees and limited collection of seeds 

and other plant materials. However, the SGFO RMP closed 

the Beaver Dam Slope ACEC to fuelwood harvest, and 

the 2006 Jarvis Fire destroyed most of the pinyon-juniper 

woodland in the northwestern portion of the NCA. These 

factors, difficult accessibility, steep terrain, existing prohibitions on cross-country OHV travel, and a small number 

of suitably-sized trees, have resulted in very limited use of 

the NCA for woody products or other plant materials. This 

would continue under Alternative A; thus the economic 

impact of Alternative A associated with plant materials 

harvesting would be negligible.

Grazing in the NCA under Alternative A would support, on average, $148,600 of total economic output, 

$19,200 of labor income, and 3.3 jobs annually in 

Washington County (Table 4-15). These figures are 

based on use of the available AUMs in this alternative 

(3,099) at the 2007–2011 average billed use rate of 57.1 

percent. Actual use and economic impacts would likely 

vary from year to year. 

Recreation in the NCA under Alternative A would support $227,500 of total economic output, $81,700 of labor 

income, and 3.6 jobs annually in Washington County 

(Table 4-16). These figures are based on current (2013) 

levels of recreation activity in the NCA (8,890 visits). It 

is possible and likely that recreation activity will increase over the course of the planning period. The NCA 

lands have historically been little known as a recreation resource; this is likely to change given the NCA 

Alt. A Alt. B Alt. C Alt. D

Direct Economic Output $87,400 $52,000 $0 $87,400

Percent Difference from Alt. A N/A - 40 - 100 0

Total Economic Output $148,600 $89,200 $0 $148,600

Percent Difference from Alt. A N/A - 40 - 100 0

Total Labor Earnings $19,200 $11,500 $0 $19,200

Percent Difference from Alt. A N/A - 40 - 100 0

Total Jobs Per Year 3.3 2.0 $0 3.3

Percent Difference from Alt. A N/A - 40 - 100 0

All figures are in 2013 dollars.

Estimates are of the impacts on the economy of Washington County.

Total Economic 

Impact1

Current Visitation 

Levels

Economic Impact1

per 1,000 Visits

Direct Economic 

Output $146,200 $16,400

Total Economic 

Output $227,500 $25,600

Total Labor 

Earnings $81,700 $9,200

Total Jobs Per 

Year 3.6 0.41

All figures are in 2013 dollars.

Estimates are of the impacts on the economy of Washington 

County.

Estimates include all motorized and non-motorized recreation.

1

Technically, these figures reflect “economic contribution,” as 

they include the effects of NCA recreation-related spending 

by Washington County residents. See the Analysis Methods 

section for discussion of this distinction.

Table 4-15 Annual Local Economic Impacts of Grazing in Beaver Dam Wash NCA

Table 4-16 Annual Local Economic Impacts of Recreation in 

Beaver Dam NCA
726 Chapter 4 BDWNCA BDWNCA Chapter 4 727

SOCIAL AND ECONOMIC CONDITIONS SOCIAL AND ECONOMIC CONDITIONS

resources may be used for a variety of purposes, including education and research, but may also enhance the 

nonmarket value of an individual’s hiking experience at 

the NCA.

The Beaver Dam Wash NCA is located in southwestern Utah along an ecological transition zone between 

the Mojave Desert and the Great Basin. Straddling this 

transition zone contributes to the existence at the NCA 

of unique flora and fauna found in the region. The NCA 

hosts many other common and uncommon species as 

well. A wide range of nonmarket values are derived from 

these resources. For instance, healthy populations of 

these species contribute to use values held for recreation 

opportunities such as hunting and wildlife observation 

both within and outside the boundary of the NCA. They 

also contribute to use values gained from educational 

experiences and research. Furthermore, nonmarket passive use values can be derived from the protection and 

preservation of important habitat for threatened and 

endangered species.

One of the purposes of the NCA is to protect and help 

recover populations of the Mojave desert tortoise and 

other at-risk species. Such an effort to protect the tortoise 

and other rare species in the NCA contributes to existence values (value in knowing the resource will exist in a 

particular condition) and bequest values (for the benefit 

of future generations) held by some people, both inside 

and outside the socioeconomic study area, for preservation of these species. Evidence of this is provided by the 

number of studies that have monetized passive use values 

associated with various threatened, endangered, and rare 

species in the United States over the years, summarized 

in Richardson and Loomis (2009). While none of these 

previously conducted studies focused on the Mojave 

desert tortoise specifically, results demonstrate that the 

public places a positive nonmarket value on the protection of various threatened, endangered, and rare species. 

Given the potential size of the human population outside 

the study area that values these sensitive species found 

at the Beaver Dam Wash NCA, the nonmarket passive 

use values associated with their protection could be quite 

large. However, these values cannot be readily quantified.

Alternative A, which continues current management of 

land in the NCA, provides considerable protection for 

the species and habitats found in the NCA, as it implements management recommendations from USFWSapproved recovery plans and Biological Opinions issued 

under Section 7 of the ESA. The Beaver Dam Slope 

ACEC has been managed for the protection of desert 

tortoises, designated critical habitat, and diverse desert 

plant and animal species. Thus, Alternative A provides 

for protection of nonmarket values associated with these 

species and habitats.

However, Alternative A may not adequately protect some 

of these values. For instance, in some cases recreation opportunities may compete with wildlife habitat preservation. Under Alternative A, provisions for various management challenges do not exist; for instance, regarding 

strategies for managing wildfires in special status species’ 

habitat, or conditions for authorizing new land uses in 

these habitats. Further, in requiring that a management 

plan be developed for the NCA, Congress implicitly recognized that current management would be insufficient 

to achieve the purpose of the NCA noted at the beginning 

of this section, which includes conserving, protecting, 

and enhancing ecological and wildlife resources.

The NCA contains unique geological, paleontological, 

archaeological, and cultural resources, each of which may 

contribute to nonmarket values held by some members 

of the public. Fossil resources can be found in the Kaibab 

limestone formations that make up the Beaver Dam 

Mountains, which themselves are 1.7 billion years old, 

making them the oldest exposed rocks in Utah. The NCA 

has caves and karsts with unique geological, biological, cultural, or recreational values. Previous work has 

uncovered archaeological records of ancient people who 

once lived in the area, including evidence of Archaic, 

Ancestral Puebloan, and Southern Paiute occupations 

and land use. The NCA also contains Euro-American 

historic sites from the 19th century, such as wagon roads, 

telegraph lines, and the Arrowhead Trails Highway, the 

first all-weather road connecting Los Angeles, Las Vegas, 

and Salt Lake City in the early 20th century. Additionally, 

the OST, a designated National Historic Trail, traverses 

the NCA. These resources contribute to nonmarket use 

values, such as those held for recreation and education 

opportunities, as well as passive use values, such as the 

benefits received from preservation of unique geological, 

paleontological, archaeological, and historic features for 

future generations (bequest values). A study conducted 

by Loomis et al. (2005) monetized nonmarket values 

associated with recreation opportunities at various sites, 

including Canyons of the Ancients National Monument, 

which contains a wealth of archaeological resources. 

Results of this study demonstrate that there are significant 

nonmarket benefits associated with such cultural sites.

Alternative A has few provisions regarding management 

of archaeological and cultural resources in the NCA, 

activity such as new recreational visitation and migration 

of persons interested in living near high-quality public 

lands. For this RMP/EIS, this matter is essentially moot. 

The NCA was Congressionally-designated in 2009; its 

designation is not subject to change through this or future 

BLM planning processes. Further, any “designation effects” 

(attraction of visitors and migrants) pertaining to the 

existing Beaver Dam Slope ACEC that overlaps much of 

the NCA are surpassed by the amenity attraction effects of 

the NCA designation. The Old Spanish National Historic 

Trail, Congressionally-designated to the National Trails 

System in 2002, would continue to attract some attention 

for persons interested in historic trails.

Economic Impacts – Nonmarket Values

The Congressionally-designated purpose of the Beaver 

Dam Wash NCA is “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 Beaver Dam Wash National Conservation 

Area” (OPLMA).

This purpose speaks to the nonmarket values provided 

by the resources and uses of the NCA. While some of 

the listed components have market-based aspects—for 

instance, NCA visitors make purchases of gasoline, food, 

and equipment in order to recreate in the NCA—each of 

these components is importantly if not primarily characterized by the unpriced benefits they provide to present 

and future generations.

Table 4-17 summarizes key resources and resource uses 

in the NCA that provide nonmarket values. The table 

identifies whether the resource or use reflects a use 

value or passive use value. These nonmarket values are 

described in more detail in the paragraphs immediately following the table, along with the implications of 

Alternative A for these values. An important consideration for many of the resources listed in Table 4-17 is that 

they are often dual commodities, meaning they are both 

inputs to biophysical processes as well as endpoints that 

people may place a value on (Boyd and Krupnick 2009). 

For example, members of the public may place passive 

use values on the Beaver Dam Slope ACEC within the 

Beaver Dam Wash NCA, but this protected area also 

likely serves as an input to maintaining healthy Mojave 

desert tortoise populations and other wildlife species, 

which are themselves resources that people hold nonmarket values for. The concept of dual commodities for 

interconnected ecological processes can apply to other 

resources as well, such as geological formations and 

cultural and archaeological resources. For instance, these 

Resources and Resource Uses1 Primary Nonmarket Value

Use Value2 Passive Use 

Value3

Threatened, endangered, and rare species—Mojave Desert tortoise, southwestern willow 

flycatcher •

Plants species—blackbrush, Joshua trees •

Wildlife—migratory birds, bats, reptiles, Gila monster, raptors, desert bighorn sheep •

Geological—1.7 billion year old Precambrian rock: oldest exposed rock in UT •

Paleontological—Fossils •

Archaeological and historical—19th century Euro-American historic sites, Arrowhead Trails 

Highway, evidence of Archaic, Ancestral Puebloan, and Southern Paiute people, Old Spanish 

National Historic Trail, rock shelters, caves with cultural deposits

•

Areas with wilderness characteristics—Beaver Dam Mountains South, Joshua Tree, Beaver 

Dam Wash •

Recreation—dispersed camping, OHV use, rock climbing, horseback riding, hunting, primitive 

recreation, sightseeing, wildlife viewing, hiking, photography •

Education and research—ecological, wildlife, plants, paleontological, archaeological, geological, 

historical •

Traditional uses—livestock grazing, Native American uses •

1

List of resources and uses is based on Chapter 3, but is not exhaustive.

2

Some resource uses that provide nonmarket use value to participants also provide passive use value to a broader public.

3

Many of the resources people place a passive use value on can also contribute to the magnitude of use values held for recreation, education, research, and traditional use opportunities at the NCA.

Table 4-17 Type of Nonmarket Values Associated with the Beaver Dam Wash NCA
728 Chapter 4 BDWNCA BDWNCA Chapter 4 729

SOCIAL AND ECONOMIC CONDITIONS SOCIAL AND ECONOMIC CONDITIONS

opportunities and has few provisions to address conflicts 

between recreation and other uses or between different 

recreational uses. Alternative A does not reflect current 

best practices for managing recreation in ways that optimize recreational experiences for a broad array of users 

while simultaneously protecting other resource values.

To date, the NCA has received little use for educational 

purposes. However, it has been a locus of research activities addressing the Mojave desert tortoise. Given the varied 

and outstanding natural resources of the NCA, it could 

provide additional research and education opportunities. 

Alternative A includes a few education-oriented management actions; these are aimed at resource protection 

through education and are very general. Education also is 

mentioned as an end in itself, under Heritage Resources: 

“provide for stabilization, maintenance, and interpretation of selected sites for public enjoyment and education.” 

Alternative A also includes management actions supporting research to support management of the tortoise and 

other sensitive species, and more broadly to “provide for 

legitimate field research by credible scientists and institutions.” In general, Alternative A allows for realization of 

nonmarket values associated with education and research, 

but does not actively encourage these activities.

The NCA supports nonmarket values associated with 

traditional uses of BLM resources, such as livestock grazing and Native American uses. As with recreation, public 

land managed for livestock grazing provides both market 

values (in this case, forage that generates cash value when 

livestock are sold) and nonmarket values. The nonmarket values associated with livestock grazing include the 

scenic value of open livestock range and ranch operations (Ellingson et al. 2006), including private land that is 

maintained in ranching in part because of the availability 

of public grazing lands. Nonmarket values also include 

the traditions, customs, and culture of ranching in the 

American West (Tanaka et al. 2005), which have experiential use value to ranching participants, surrounding 

communities, and to some visitors (Mangan et al. 2005).

Grazing and ranching also have passive use value (existence value and bequest value) to the non-using public 

who, for instance, appreciate the historic and living 

cultural icon of the American cowboy and independent rancher, and wish to see that heritage continue. In 

2007, the Governor’s Public Land Policy Coordinating 

Office commissioned Utah State University to conduct 

a statewide social survey on how Utah residents use and 

value public land resources, and their views about public 

land management. To achieve adequate sample size, two 

or more counties’ responses were combined, in this case 

Washington and Iron Counties. For these two counties, 

over 37 percent of the respondents indicated that grazing 

on public lands was very important to their area’s quality 

of life. The study did not distinguish among the various 

public land management entities, such as BLM versus the 

USFS (Krannich 2008). Another indicator of the nonmarket value of grazing land is that purchases of ranches 

sometimes occur at prices in excess of the production 

value of the forage on the land (Bartlett et al. 2002, Taylor 

2006). However, some people see nonmarket opportunity 

costs associated with livestock grazing, such as the potential for forage losses for wildlife or for conflicts between 

livestock grazing and other lifestyles that utilize public 

lands (Todres et al. 2003).

Livestock grazing is available on four allotments that 

overlap the NCA: Beaver Dam Slope, Castle Cliffs, Cedar 

Pocket, and Scarecrow Peak. Twelve livestock operators 

are licensed to graze the four allotments. Actual use of 

each allotment has been less than permitted use in recent 

years. This reflects the difficult livestock grazing situation 

in an arid region that is experiencing long-term impacts 

to forage availability from wildfires, droughts, and invasive species. On three of the allotments, grazing within 

the Beaver Dam Slope ACEC has been limited since 1999 

by the SGFO RMP to November 1 to March 15, with a 

limited area also available until May 31, in order to protect 

tortoises during their active season. Under Alternative A, 

grazing would continue to be available on all four allotments. A total of 3,099 AUMs of forage would be available, 

more than has been used in recent years. The November 1 

to March 15 limitation within the ACEC would continue, 

and grazing after March 15 would be eliminated. Thus, 

Alternative A would not make large changes to the current 

availability of grazing in the NCA, and would therefore 

continue to support the nonmarket values associated with 

livestock grazing in the NCA.

BLM-administered land is sometimes important to the 

cultural traditions of Native American tribes. They may 

utilize these lands to gather plants used in medicinal 

and cultural practices, to honor ancestors, for religious 

and cultural ceremonies, and for other purposes. These 

activities provide nonmarket use value to the tribe 

members, and may provide passive use values to tribe 

members and to others who appreciate these traditional 

cultural practices and wish to see them sustained. During 

the scoping period for the EIS, the Paiute Indian Tribe 

of Utah and the Shivwits Band of the Paiutes submitted 

comments indicating their desire to see their ancestral 

and these few provisions are very general. This is also 

true of its provisions for geological and paleontological 

resources. Alternative A does not reflect current best 

practices for protection of these various resources, and 

thus provides only limited protections for and support of 

the nonmarket values associated with these resources.

Although it does not contain designated wilderness, the 

Beaver Dam Wash NCA has three units totaling 29,036 

acres that have been identified as having the following 

wilderness characteristics: naturalness, outstanding opportunities of solitude, and outstanding opportunities 

for primitive, unconfined recreation. The first unit is the 

Beaver Dam Mountains South. This land unit is characterized by rugged mountains rising out of gently sloping alluvial plains. There are no human-made features within the 

unit other than overgrown and infrequently used routes 

for travel. The second area with wilderness characteristics 

is the Joshua Tree unit, which is also located in the Beaver 

Dam Mountains. The third area in the NCA with wilderness characteristics is the Beaver Dam Wash unit. Both use 

and passive use nonmarket values can be derived from the 

three designated areas with wilderness characteristics. The 

use values some visitors may hold for these areas include 

the opportunity to experience primitive recreation, to 

experience natural darkness and starry night skies, to have 

enhanced wildlife viewing opportunities, and to enjoy 

solitude and natural quiet. The provisioning and protection of areas with wilderness characteristics also protects 

the bequest values that some people place on ensuring that 

future generations can experience nature in an undisturbed fashion. Preservation of the overall naturalness of 

the Beaver Dam Wash NCA and its areas with wilderness 

characteristics also contribute to potential existence values 

(simply knowing that the resource will exist in its current 

state) held by some individuals.

Alternative A has no specific management actions with 

respect to lands with wilderness characteristics. Other 

actions would provide some protections for the nonmarket values associated with these lands in the NCA. 

However, by not directly addressing wilderness characteristics, Alternative A may not adequately protect 

nonmarket values associated with these lands.

Recreation is one the primary uses of the Beaver Dam 

Wash NCA. The NCA currently has no developed recreation facilities, trailheads, or trails. Rock climbing the 

limestone formations of the Beaver Dam Mountains is 

the most popular recreation activity in the NCA. OHV 

riding and motor vehicle touring are also popular uses 

of the NCA. Other activities include dispersed camping, 

horseback riding, and hunting for birds, deer, and desert 

bighorn sheep.

As discussed in the market values section above, there 

are clear economic benefits associated with the expenditures made in the local economy by recreational users 

of the NCA. In addition, some visitors who participate 

in these recreation opportunities receive an economic 

benefit above and beyond any costs actually paid to participate in them. Thus, a nonmarket use value can be held 

by some people for each of the recreation opportunities 

in the NCA. Economists use the term consumer surplus 

to refer to the difference between the maximum dollar 

amount a consumer would be willing to pay to enjoy 

a good or service, and the actual payments made. This 

additional, unpaid value is a nonmarket use value, and 

many studies have quantified this value for various activities and locations. Loomis (2005) has summarized the 

findings from 1,239 studies covering much of the nation 

from 1967 to 2003. Rosenberger (2012) has prepared an 

online database of 352 documents from economic valuation studies that estimated the nonmarket use value of 

recreation activities in the U.S. and Canada from 1958 to 

2006. Loomis found that (updated here to 2013 dollars), 

consumer surplus for rock climbing ranged from a low 

of $44 per person per day to a high of $75 per person per 

day. Consumer surplus for OHV riding ranged from $28 

to $50, and consumer surplus for hunting ranged from 

$60 to $209. Economists use a methodology known as 

“benefits transfer” to apply values from the economics 

literature to determine total consumer surplus at another 

location. This methodology requires considerable research and great care in order to ensure that the transfer 

is appropriate and the results valid. Conducting this type 

of analysis was beyond the scope and needs for this EIS. 

However, the values cited above do show that nonmarket 

values are substantially greater than zero and should be 

considered–qualitatively in this case–real and important 

to BLM decision making.

Alternative A includes a number of management actions 

for recreation and visitor services and a related resource 

use, comprehensive trails and travel management. In 

addition, some of its management actions for various 

resources (e.g., visual resource management (VRM) 

land classifications) have implications for recreation. In 

general, the recreation-relevant management actions of 

Alternative A are fairly high-level and lack prescriptive 

or permissive specificity. For instance, the NCA would 

be managed as an ERMA. This type of BLM management 

framework is oriented toward unstructured recreation 
730 Chapter 4 BDWNCA BDWNCA Chapter 4 731

SOCIAL AND ECONOMIC CONDITIONS SOCIAL AND ECONOMIC CONDITIONS

roads per the Congressional designation and related limitations to OHV use would continue. 

Non-Motorized Recreation Stakeholders would have 

mixed views on Alternative A. Because it carries forward 

familiar policies, some would find it favorable. Others 

would be less favorably inclined, because under current 

management, there is limited regulation of recreation activities and therefore some potential for conflicts between 

different recreational uses. Further, some recreationists 

appreciate the NCA for its ecosystem, flora, and fauna, 

and would feel that Alternative A inadequately protects 

these resources.

Livestock Grazing Stakeholders would favor Alternative 

A because it carries forward current policies that these 

stakeholders have managed to for many years. 

Economic Development Stakeholders would find 

Alternative A relatively favorable. It provides for a ROW 

corridor and allows for the limited possibility of other 

ROW development (the balance of the NCA would be 

managed as a ROW Avoidance area, while the other alternatives manage the balance as a ROW Exclusion area). 

4.22.2.3 Alternative B

Economic Impacts-Market Values

Alternative B would prohibit the commercial and noncommercial harvest of fuelwood and Christmas trees, 

and limit collection of seeds and other plant products to 

scientific purposes and restoration projects in southwestern Utah. This would not significantly change this use of 

the NCA, as there has been little use of the NCA for plant 

materials products in recent years. The economic impact 

associated with plant materials harvesting would negligible, as in Alternative A.

Grazing in the NCA under Alternative B would support, 

on average, $89,200 of total economic output, $11,500 

of labor income, and 2.0 jobs annually in Washington 

County (Table 4-15). These figures are based on use of 

the AUMs available in this alternative (1,861) at the 

2007–2011 average billed use rate of 57.1 percent. Actual 

use and economic impacts would likely vary from year to 

year. These impacts are 40% less than the corresponding 

figures for Alternative A. 

A usual caveat on analyses of the economic impact of 

grazing on BLM-administered land is to note the possibility that loss of access to BLM forage (AUMs) could be 

critical to grazing operations that are highly dependent 

on BLM forage. If an operator in this situation could 

not find alternative forage sources, the operator might 

go out of business, which would create a much larger 

economic loss. Given the low number of AUMs available 

in the NCA compared to the AUMs utilized by a typical 

livestock operation, and the fact that use of these AUMs 

is split between several operators, it is very unlikely that 

loss of access to some AUMs under Alternative B compared to Alternative A would lead to this result.

With respect to recreation, based on the available data 

and the difficulties inherent in quantifying the impacts 

of recreation-related management actions, recreation 

(motorized and non-motorized) in the NCA under 

Alternative B would provide the same economic impact to Washington County as Alternative A. As with 

Alternative A, it is likely that recreation activity under 

Alternative B will increase over the course of the planning period, and the economic benefits to Washington 

County would increase accordingly. If recreation activity 

were to change due to the management actions in this 

alternative and/or growth, the economic impacts would 

occur at the rates per 1,000 visits shown in Table 4-16.

Like Alternative A, Alternative B would provide for a 

ROW corridor, but reduced from 196 to 60 acres. The 

remainder of the NCA would be designated a ROW 

Exclusion area. Thus, it is possible that Alternative B could 

preclude some beneficial economic development through 

ROW development. The impacts of land acquisition under 

Alternative B would be the same as Alternative A.

The economic impact of Alternative B associated with 

special designations would be essentially the same as 

Alternative A. However, it is possible that management 

actions associated with establishment of a management 

corridor for the Old Spanish National Historic Trail, 

designated in 2002, would increase visitation to the trail, 

resulting in some level of benefits to the local economy. 

Revocation of the Beaver Dam Slope ACEC under this 

alternative would have no impact, because any “designation effects” (attraction of visitors and migrants) pertaining to the ACEC are surpassed by the amenity attraction 

effects of the NCA designation.

Economic Impacts-Nonmarket Values

Relative to Alternative A, Alternative B would provide 

additional support to nonmarket values associated with 

unique species and habitats found within the NCA, by 

protecting those species and habitats through:

▶ Actions to manage fire fuels proactively, suppress 

wildfires in special status species’ habitats, and limit 

prescriptive fires;

landscapes protected from development and managed to 

ensure long-term sustainable use by tribal members and 

the larger public. They also recommended that BLM provide for protection of cultural antiquities, native plants, 

and wildlife; and provide assurances of access to public 

lands for utilization for hunting, fishing, gathering, and 

carrying out ceremonial/spiritual practices. Alternative 

A allows for the collection of vegetative products for 

Native American ceremonial or religious purposes, 

excluding federally-listed species. Alternative A also 

states that BLM will collaborate with Indian tribes and 

other interested parties in developing and implementing 

plans for the restoration, stabilization, protection, and/

or interpretation of appropriate historical, archaeological, 

or paleontological sites and resources on public lands in 

Washington County. Thus, Alternative A provides some 

support for the nonmarket values associated with the 

traditional uses of Native Americans, but has no other 

provisions explicitly supporting or protecting traditional 

Native American uses of BLM-administered land.

In summary, Alternative A, which would continue current management practices for the NCA, would provide 

some protections for many of the nonmarket values associated with the NCA. However, the impact of continuing 

current management would probably include some losses 

to nonmarket values as a result of inadequate protections. 

Further, opportunities to enhance these nonmarket values “for the benefit and enjoyment of present and future 

generations” (OPLMA) by clarifying management and 

adding best practices would be foregone.

Social Impacts

In general, social impacts of BLM management actions 

are of two primary types:

▶ Social impacts driven by economic impacts – For 

instance, such impacts may occur when changes in 

employment due to BLM management decisions 

lead to changes in population that drive impacts to 

housing, schools, community services, crime, community cohesion, etc.

▶ Social impacts that are more purely social and cultural in nature – These include impacts on intangible aspects of quality of life, attitudes and beliefs, 

traditional land uses and associated cultural values, 

and so on.

Regarding social impacts driven by economic impacts, 

these types of changes to public infrastructure and services, or to community cohesion, usually only occur in 

situations where major resource development activities 

generate large new employment opportunities, resulting 

in a significant influx of workers. For example, this type 

of impact has occurred in parts of Utah and Wyoming 

where high levels of oil, gas, or coal development are 

occurring. No similar major economic development 

based on uses of BLM-administered land in the Beaver 

Dam Wash NCA is underway, and Alternative A is not 

expected to change that. Therefore, significant social impacts driven by economic impacts likely would not occur 

under the Alternative A.

Regarding impacts that are more purely social and 

cultural in nature, the five high-level stakeholder categories identified and described in the Attitudes and Beliefs 

section of the Socioeconomic Baseline Report are used 

below to assess key social impacts of the alternatives. 

Stakeholders have distinct sets of attitudes, beliefs, values, 

opinions, and perceptions about public lands and the effects of various management policies and actions. These 

views reflect different cultural and economic linkages 

people have to public lands. By looking at the alternatives 

from different points of view, one can identify potential 

social and cultural impacts on each stakeholder group. 

The categorization of stakeholders is not meant to imply 

that all individuals and social groups fit neatly into a 

single category; many specific individuals or organizations may have multiple interests and would see themselves reflected in more than one stakeholder category. 

The point of the categories used here is to allow differentiation of social impacts based on broad differences 

in sociocultural linkages to public lands and associated 

points of view.

Habitat and Resource Conservation Stakeholders would 

find Alternative A unsatisfactory. These stakeholders believe protecting species and ecosystems is a fundamental 

social value, and is not sufficiently accomplished by the 

current policies carried forward by Alternative A. They 

believe current management does not place enough importance on sensitive species and essential habitats, and 

would view this alternative as leading to the long-term 

demise of these populations and habitats. This stakeholder category also includes persons interested in the conservation of geological, paleontological, archaeological, 

and cultural resources, who generally would not favor 

this alternative based on a view that current management 

does not adequately protect these resources.

Motorized Recreation Stakeholders generally would find 

Alternative A to be favorable. It carries forward policies 

that these stakeholders are familiar with that manage the 

designated road areas created by Congress. Current open 
732 Chapter 4 BDWNCA BDWNCA Chapter 4 733

SOCIAL AND ECONOMIC CONDITIONS SOCIAL AND ECONOMIC CONDITIONS

In the area of education and research, as just noted, 

Alternative B includes multiple provisions for education and interpretation activities connected to the NCA’s 

geological, paleontological, archaeological, and cultural 

resources. These provisions aim to protect resources, 

and to enhance user experiences. Alternative B also 

includes many provisions for education, interpretation, 

and research related to ecological resources and sensitive 

species at the NCA; these provisions are largely aimed at 

protecting these resources but would likely contribute to 

public understanding and enjoyment. The alternative also 

clarifies access to NCA resources for research, and conditions for research activities. Alternative B would enhance 

education and research-related nonmarket values relative 

to Alternative A. 

With respect to nonmarket values associated with 

traditional uses, Alternative B would reduce the AUMs 

available from 3,099 to 1,861, which is the 20-year average of actual use in the NCA. This would have some 

impact on grazing in good forage years when a higher 

level of forage use might have occurred, and might result 

in a lower long-term average of actual use. Given the 

relatively small number of AUMs involved, it is unlikely 

that this management change would have a major impact 

on the operators. Thus the impacts to nonmarket values 

associated with livestock grazing would be similar to 

Alternative A. 

Like Alternative A, Alternative B allows for personal use 

collection of native plant materials (excluding all federally-listed native plant species) by Native Americans for 

religious, ceremonial, and traditional purposes (through 

permits). Alternative B also specifically emphasizes 

Native American involvement in research at various heritage sites, and allocates and manages for Conservation 

Use and/or Traditional Use heritage sites identified as 

Sacred Sites by Native Americans. Alternative B would 

enhance the nonmarket values associated with traditional 

Native American uses of the NCA.

In summary, relative to Alternative A, Alternative B 

would provide greater protection and enhancement 

of most nonmarket values associated with the NCA. 

Levels of a few nonmarket values would be the same as 

Alternative A, and it is unlikely that Alternative B would 

lead to any significant nonmarket value losses relative to 

Alternative A.

Social Impacts

Major economic development based on uses of BLMadministered land in the Red Cliffs NCA is not expected 

under Alternative B; therefore, social impacts driven by 

economic development would not occur under this alternative. Impacts that are more purely social and cultural 

in nature could occur as indicated by the likely views of 

different stakeholder groups regarding this alternative.

Habitat and Resource Conservation Stakeholders would 

favor this alternative over Alternative A. Alternative B 

includes many provisions that these stakeholders would 

find more protective of sensitive species and habitats. 

Persons within this stakeholder category who are concerned with the conservation of geological, paleontological, archaeological, and cultural resources would also favor this alternative over Alternative A, as it also includes 

additional protections for these resources.

Motorized Recreation Stakeholders would view 

Alternative B similarly to Alternative A. Its OHV designation of the NCA as Limited to Designated Roads and 

Trails is only an administrative change relative to management under Alternative A.

Non-Motorized Recreation Stakeholders would have 

mixed views on Alternative B, which puts in place a different recreation management framework than current 

policies under Alternative A. In general, this framework 

would control recreation activities to a higher degree. 

Some non-motorized recreation stakeholders may find 

the new framework and rules less to their liking. Others 

would appreciate the clarifications that would be made 

regarding what recreation activities can take place where 

and when. They would also appreciate that this alternative would help resolve conflicts between different types 

of recreation.

Livestock Grazing Stakeholders would view this alternative less favorably than Alternative A because it reduces 

the AUMs available for livestock grazing from 3,099 to 

1,861. Alternative B also provides that when grazing 

permits are relinquished, the allotment or portion of 

allocation associated with those permits within the NCA 

would no longer be available for livestock grazing over 

the life of the RMP. Other operators might want access to 

the forage in question.

Economic Development Stakeholders would find 

Alternative B less favorable than Alternative A because it 

provides for a reduced ROW corridor and manages the 

balance of the NCA as a ROW Exclusion area.

▶ Greater specificity on use of native seeds and plant 

materials, and methods for their introduction;

▶ Closing the NCA to commercial and noncommercial harvesting of most vegetative products;

▶ Additional and more specific actions regarding 

control and eradication of invasive species;

▶ Additional provisions for public education efforts;

▶ Additional provisions for research efforts;

▶ Implementation of land use restrictions and other 

measures to protect particularly sensitive areas (riparian areas, species status species habitat);

▶ Inventorying and monitoring of certain species 

populations and habitats;

▶ Authorization for the translocation and population 

augmentation of certain sensitive species;

▶ Various limitations on and conditions for authorizing activities in sensitive areas that could have negative impacts, such as Special Recreation Permits;

▶ Use of species-friendly measures for various structures; e.g., “bat-friendly” gates in caves, wildlife 

escape ramps in watering troughs, etc.;

▶ Clarification of recreation management policies 

and measures through development of a Recreation 

Area Management Plan, establishment of the Beaver 

Dam Wash Special Recreation Management Area 

and three Recreation Management Zones, provisions to guide site improvements and facilities 

changes, development of a Climbing Management 

Plan, and other recreation-related actions;

▶ Establishing criteria for design and construction of 

the non-motorized trail system, including protection of diverse (non-recreation) NCA values;

▶ Requiring, where new trail development would 

result in surface disturbance in designated critical habitats, restoration of an equivalent acreage of 

similar quality habitat;

▶ Converting most of the NCA from designated 

ROW Avoidance area to designated ROW Exclusion 

area.

In short, through the types of actions noted above, 

Alternative B would positively impact nonmarket values 

associated with species and habitats at the NCA. Relative 

to Alternative A, it would better “conserve, protect, and 

enhance” (OPLMA) ecological and wildlife resources of 

the NCA and thereby increase “the benefit and enjoyment of present and future generations” (OPLMA) of the 

associated nonmarket values.

Relative to Alternative A, Alternative B would better 

protect and enhance nonmarket values associated with 

the NCA’s geological, paleontological, archaeological, and 

cultural resources. It would provide greater specificity 

on allocation of and access to these resources. It would 

prohibit commercial and non-commercial collection of 

fossils and petrified wood, which would help ensure opportunities for their in-situ enjoyment by current visitors 

and future generations. It provides for activity level plans 

(e.g., Cultural Resource Project Plans, Interpretation 

Plans) to direct management of archaeological and 

cultural resource public use sites. It would put in place 

a variety of management actions to stabilize and protect 

these sites.

Alternative B provides no specific management actions 

for lands with wilderness characteristics that differ from 

Alternative A, other than maintaining a current inventory of areas with wilderness characteristics and analyzing 

any impacts on a project-specific basis. However, some 

of the other management actions of Alternative B would 

help maintain wilderness characteristics. Therefore, 

Alternative B would be somewhat more protective of the 

nonmarket values of lands with wilderness characteristics 

than Alternative A.

With respect to recreation, in order to reduce the impacts of recreation on sensitive species and habitats, 

Alternative B would limit and control recreation activities more than Alternative A. It would do so through a 

number of prescriptive management actions in the RMP, 

and through development of a Recreation Management 

Plan and establishment of the Beaver Dam Wash Special 

Recreation Management Area and three Recreation 

Management Zones. Greater control of recreation activities might be seen by some recreationists as negatively 

impacting their recreational experience. However, it is 

at least as likely that by clarifying policies and rules for 

recreation—what, where, when, etc.,—confusion could 

be reduced, conflicts could be avoided between different types of recreation and with others uses, and thereby, 

recreational experiences would be enhanced. Further, 

other actions under Alternative B would probably enhance recreational experiences. These actions include 

moving the NCA from VRM Class III to Class II, and 

increased educational and interpretive efforts for geological, paleontological, archaeological, and cultural resources—resources that are often visited by recreationists. On 

balance, relative to Alternative A, Alternative B would 

enhance nonmarket values associated with recreation. 
734 Chapter 4 BDWNCA BDWNCA Chapter 4 735

SOCIAL AND ECONOMIC CONDITIONS SOCIAL AND ECONOMIC CONDITIONS

members of the general public who appreciate protection 

of these resources.

Alternative C would manage 16,721 acres to protect wilderness characteristics. Thus it would better protect and 

enhance nonmarket values associated with wilderness, 

relative to both Alternative A and Alternative B.

Alternative C generally takes the same approach to recreation management as that noted in the nonmarket values 

subsection for Alternative B. Thus, relative to Alternative 

A, Alternative C would better protect and enhance the 

associated nonmarket values. Relative to Alternative B, 

Alternative C manages most of the NCA as VRM Class 

I (vs. the less restrictive Class II of Alternative B), which 

would enhance nonmarket values for some recreationists. 

It also has several provisions that are more or less restrictive on recreation activity:

▶ All SRPs would be limited to a group size of 12;

▶ SRPs for competitive non-motorized would not be 

authorized;

▶ Casual rock collection and recreational prospecting 

would not be allowed;

▶ Use of dead and down materials for campfires 

would not be allowed;

▶ Approximately 8,000 acres would be moved from 

the Backcountry Zone to the Primitive Zone, which 

has somewhat lower levels of management control.

The net effect of these changes relative to Alternative B is 

difficult to say. It is likely the levels of recreation-related 

nonmarket values under Alternative C would be similar 

to Alternative B.

In the area of education and research, Alternative C 

includes essentially the same provisions as Alternative B 

for education, interpretation, and research activities. Thus, 

Alternative B would enhance education and research-related nonmarket values relative to Alternative A, and would 

provide similar levels of these values to Alternative B.

With respect to traditional uses, Alternative C 

would close the NCA to livestock grazing. Therefore, 

Alternative C would no longer support the nonmarket 

values associated with grazing and ranching in the area. 

The scope of this impact is not entirely clear, but the 

number of AUMs is small relative to the total forage requirements of a typical livestock operation; therefore, the 

operators would probably be able to adjust and remain in 

operation. Thus the losses to grazing-related nonmarket 

values regionally probably would be small. Alternative 

C’s actions related to Native Americans are the same as 

Alternative B. Thus the nonmarket values associated with 

Native American traditional uses would be the same as 

in Alternative B, and better protected and enhanced than 

under Alternative A.

In summary, relative to Alternative A, Alternative C 

would generally provide greater protection and enhancement of many of the nonmarket values associated with 

the NCA. Relative to Alternative B, it would provide 

similar or somewhat greater support for most nonmarket 

values. However, by eliminating grazing, Alternative C 

would no longer support nonmarket values associated 

with grazing and ranching, but the regional impact of 

this change is probably limited. 

Social Impacts

Major economic development based on uses of BLMadministered land in the Red Cliffs NCA is not expected 

under Alternative C; therefore, social impacts driven by 

economic development would not occur under this alternative. Impacts that are more purely social and cultural 

in nature could occur as indicated by the likely views of 

different stakeholder groups regarding this alternative.

Habitat and Resource Conservation Stakeholders 

would favor this alternative over all other alternatives. 

Alternative C includes the framework of Alternative 

B that these stakeholders would find more protective 

of sensitive species and habitats than Alternative A, 

and they would appreciate that Alternative C further 

strengthens some of the measures aimed at protecting 

these resources. Alternative C also includes some measures for geological, paleontological, archaeological, and 

cultural resources that are somewhat more protective of 

these resources than Alternative B. 

Motorized Recreation Stakeholders would view 

Alternative C similarly to Alternatives A and B. While 

Alternative C closes a large portion of the NCA to 

OHV use, this only affects administrative use; public 

OHV access to the NCA would remain the same as in 

Alternatives A and B.

Non-Motorized Recreation Stakeholders would view this 

alternative similarly to Alternative B – some would favor 

it over Alternative A and some would not. It is likely that 

(compared to Alternative B) more persons within this 

group would find Alternative C less preferable because 

some additional actions under Alternative C would preclude certain activities. These actions include limitations 

on group sizes for SRPs, non-authorization of SRPs for 

competitive non-motorized events, and prohibitions on 

casual rock collection and recreational prospecting.

4.22.2.4 Alternative C

Economic Impacts-Market Values

The economic impact of Alternative C associated 

with plant materials harvesting would be the same 

as Alternatives A and B; the relevant actions under 

Alternative C differ only marginally from Alternative B.

Grazing in the NCA under Alternative C would have no 

beneficial economic impact on the Washington County 

economy, because the NCA would be unavailable for 

grazing. This represents economic losses, compared 

to Alternative A, of $148,600 of total economic output, $19,200 of labor income, and 3.3 jobs annually in 

Washington County (Table 4-15). This assumes that the 

operators currently using forage in the NCA are unable 

to find substitute sources of forage.

As with Alternative B, a usual caveat on analyses of the 

economic impact of grazing on BLM-administered land 

is to note the possibility that loss of access to BLM forage 

(AUMs) could be critical to grazing operations that are 

highly dependent on BLM forage. If an operator in this 

situation could not find alternative forage sources, the 

operator might go out of business, which would create a much larger economic loss. Given the low number 

of AUMs available in the NCA compared to the AUMs 

utilized by a typical livestock operation, and the fact that 

use of these AUMs is split between several operators, it 

is unlikely that loss of access to all AUMs in the NCA 

under Alternative D would lead to this result.

Based on the available data and the difficulties inherent 

in quantifying the impacts of recreation-related management actions, recreation (motorized and non-motorized) 

in the NCA under Alternative C would provide the same 

economic impact to Washington County as Alternative 

A. As with Alternative A, it is likely that recreation activity under Alternative C will increase over the course 

of the planning period, and the economic benefits to 

Washington County would increase accordingly. If recreation activity were to change due to the management 

actions in this alternative and/or growth, the economic 

impacts would occur at the rates per 1,000 visits shown 

in Table 4-16 above.

Alternative C would designate the entire NCA as a ROW 

Exclusion area and would not designate the ROW corridor provided for in Alternative A. Thus, it is possible that 

Alternative C could preclude some beneficial economic 

development through ROW development. The impacts of 

land acquisition under Alternative B would be the same 

as Alternative A.

The economic impact of Alternative C associated with 

special designations would be the same as Alternative B.

Economic Impacts-Nonmarket Values

Alternative C includes virtually all of the provisions 

noted in the nonmarket values subsection for Alternative 

B that would protect species and habitats in the NCA. 

Thus, relative to Alternative A, Alternative C would better protect and enhance the associated nonmarket values. 

Relative to Alternative B, Alternative C would provide 

somewhat increased protection and enhancement of 

nonmarket values associated with the NCA’s species and 

habitats, through the following actions:

▶ Increasing the riparian area buffer against new surface disturbing activities from 150 to 200 meters;

▶ Limiting collection of seeds and native plant materials to use for scientific study and restoration projects within the NCA;

▶ Some more stringent recreation-related provisions, 

including: limiting the group size for SRPs, and not 

authorizing SRPs for competitive non-motorized 

and organized group events in the NCA;

▶ Limiting all OHV travel to designated roads and 

trails;

▶ Designating the NCA a ROW Exclusion area.

On the other hand, approximately 8,000 acres would 

be moved from the Backcountry Zone to the Primitive 

Zone, which has somewhat lower levels of management 

control. The net effect of these various differences with 

Alternatives B and C is difficult to say. It is likely the 

levels of nonmarket values associated with species and 

habitats under Alternative C would be somewhat greater 

than under Alternative B.

Alternative C is also very similar to Alternative B with 

respect to management of geological, paleontological, 

archaeological, and cultural resources, thus it would improve the protection and enhancement of the associated 

nonmarket values relative to Alternative A. It is more 

restrictive than Alternative B in a few respects. It would 

prohibit casual rock collection. It would also allocate and 

manage for Scientific Use and Conservation Use (not 

Public Use) most paleontological sites and cave/karst 

sites, and most National Register eligible archaeological 

and cultural sites. These actions would reduce the nonmarket use values obtained by the visiting public from 

these resources, possibly increase use values obtained by 

researchers, and probably maintain or enhance passive 

use values (existence and bequest values) received by 
736 Chapter 4 BDWNCA BDWNCA Chapter 4 737

SOCIAL AND ECONOMIC CONDITIONS SOCIAL AND ECONOMIC CONDITIONS

Alternative B, and would provide increased protections 

of those values relative to Alternative A.

Alternative D generally takes the same approach to 

recreation management as that noted in the nonmarket 

values subsection for Alternative B. Thus, relative to 

Alternative A, Alternative D would better protect and 

enhance recreation-related nonmarket values. Alternative 

D has the same VRM classifications as Alternative B. It 

also has several additional provisions that are somewhat 

less restrictive than Alternative B on recreation activity. 

These include:

▶ Designating a greater number of sites for dispersed 

camping and setting a higher limit for SRP recreation visits as a proportion of total visits;

▶ Providing for a higher limit on visitation under 

SRPs;

▶ Allowing for competitive running and bicycling 

events on roads and trails (under conditions);

▶ Allowing collection of common fossil materials and 

petrified wood;

▶ Allowing non-hunting discharge of firearms 

throughout the NCA.

However, Alternative D also moves all land managed as 

Primitive Zone under Alternative B into the Backcountry 

Zone, which has somewhat higher levels of management 

control. The net effect of these various changes relative to 

Alternative B (and other changes relative to Alternative 

C) is difficult to say. It is likely the levels of recreationrelated nonmarket values under Alternative D would be 

similar to Alternatives B and C.

In the area of education and research, Alternative D 

includes essentially the same provisions as Alternative 

B for education, interpretation, and research activities. Thus, Alternative D would enhance education and 

research-related nonmarket values relative to Alternative 

A, and would provide similar levels of these values to 

Alternative B.

Regarding traditional uses, the AUMs available for 

livestock grazing are the same in Alternative D as in 

Alternative A, and other grazing-related management 

actions are the same as in Alternative B. Therefore, the 

impacts to nonmarket values associated with livestock 

grazing would be similar to Alternative A, and thus 

similar to Alternative B. Alternative D’s actions related to 

Native Americans are essentially the same as Alternative 

B. Thus the nonmarket values associated with Native 

American traditional uses would be the same as in 

Alternative B, and better protected and enhanced than 

under Alternative A.

Relative to Alternative A, Alternative D would generally provide greater protection and enhancement of most 

of the nonmarket values associated with the NCA, and 

similar levels of most nonmarket values as Alternatives B 

and C. For livestock grazing, Alternative D would provide 

similar levels of nonmarket values as Alternatives A and B, 

and greater levels than Alternative C.

Social Impacts

Major economic development based on uses of BLMadministered land in the Red Cliffs NCA is not expected 

under Alternative D; therefore, social impacts driven by 

economic development would not occur under this alternative. Impacts that are more purely social and cultural 

in nature could occur as indicated by the likely views of 

different stakeholder groups regarding this alternative.

Habitat and Resource Conservation Stakeholders would 

find this alternative similar to or slightly less favorable 

than Alternative B, and less favorable than Alternative 

C. This is because some of its measures, while similar 

to those of Alternatives B and C, are less protective of 

sensitive species and habitats than Alternative C, and 

somewhat less protective than Alternative B. Persons 

within this stakeholder category who are concerned with 

geological, paleontological, archaeological, and cultural 

resources would have similar views of this alternative.

Motorized Recreation Stakeholders would view 

Alternative D in the same way as Alternative B; its OHV 

area designations are the same, and other OHV-related 

provisions are the same.

Non-Motorized Recreation Stakeholders would view this 

alternative similarly to Alternative B – some would favor 

it over Alternative A and some would not, depending on 

their views on the general recreation management framework of Alternatives B, C, and D, which seeks to better 

protect sensitive species and habitats and reduce the 

potential for conflicts between recreation uses. Most of 

Alternative D’s recreation-related provisions are the same 

as, or more permissive than, Alternative B; therefore, it 

is likely that some non-motorized recreationists would 

prefer Alternative D to Alternatives B and C.

Livestock Grazing Stakeholders would view Alternative D 

somewhat less favorably than Alternative A. Alternative D 

makes the same amount of forage (3,099 AUMs) available as Alternative A, but is very similar to Alternative B 

regarding other grazing-related provisions that operators 

would find less preferable than Alternative A.

Livestock Grazing Stakeholders would view Alternative 

D unfavorably because livestock grazing would no longer 

be authorized under this alternative. They would perceive 

potential impacts to their operations, livelihoods, and 

broader customs and culture of grazing and ranching in 

the area.

Economic Development Stakeholders would find 

Alternative C the least favorable alternative because it 

manages all of the NCA as a ROW Exclusion area and 

does not provide for a ROW corridor.

4.22.2.5 Alternative D

Economic Impacts-Market Values

The economic impact of Alternative D from plant materials harvesting would be the same as Alternatives A, 

B, and C; the relevant actions under Alternative D differ 

only marginally from Alternative B.

Grazing in the NCA under Alternative D would provide 

the same economic impact to Washington County as 

Alternative A, because the available AUMs would be the 

same with respect to this resource use. 

Based on the available data and the difficulties inherent 

in quantifying the impacts of recreation-related management actions, recreation (motorized and non-motorized) 

in the NCA under Alternative D would provide the same 

economic impact to Washington County as Alternative 

A. As with Alternative A, it is likely that recreation activity under Alternative D will increase over the course 

of the planning period, and the economic benefits to 

Washington County would increase accordingly. If recreation activity were to change due to the management 

actions in this alternative and/or growth, the economic 

impacts would occur at the rates per 1,000 visits shown 

in Table 4-16 above.

Like Alternative A, Alternative D would provide for a 

ROW corridor, but decreased from 196 to 128 acres. 

The remainder of the NCA would be designated a ROW 

Exclusion area. Thus, Alternative D would provide for 

decreased potential for development of the existing ROW 

corridor, and it could preclude some beneficial economic 

development through authorization and development 

of other ROWs. The impacts of land acquisition under 

Alternative B would be the same as Alternative A.

The economic impact of Alternative D associated with 

special designations would be the same as Alternative B.

Economic Impacts-Nonmarket Values

Alternative D includes most of the provisions noted in 

the nonmarket values subsection for Alternative B that 

would protect species and habitats in the NCA; therefore, 

it would better protect and enhance nonmarket values 

associated with species and habitats than Alternative 

A. However, there are some differences that make 

Alternative D less protective of species and habitats, and 

their associated nonmarket values, than Alternative C, 

and somewhat less protective than Alternative B. Most of 

these differences are relatively modest:

▶ Reduced conditions on the geographic sourcing and 

native/non-native status of seeds and plant materials used for re-vegetation efforts;

▶ Reduction in the riparian zone buffer to 100 meters, 

from 150 meters in Alternative B and 200 meters in 

Alternative C;

▶ Designating a greater number of sites for dispersed 

camping and setting a higher limit for SRP recreation visits as a proportion of total visits.

On the other hand, Alternative D would manage all 

of the NCA as either Frontcountry or Backcountry 

Zone. These designations are more restrictive than 

the Primitive Zone designation that is included in 

Alternatives B and C; for instance, the Frontcountry and 

Backcountry Zones limit all non-motorized travel to 

designated trails while the Primitive Zone does not. The 

net effect of these various differences with Alternatives 

B and C is difficult to say. It is likely the levels of nonmarket values associated with species and habitats under 

Alternative D would be similar to Alternative B and 

perhaps somewhat less than Alternative C.

With respect to geological, paleontological, archaeological, and historical resources, Alternative D is essentially 

the same as Alternative B, thus it would generally improve the protection and enhancement of the associated 

nonmarket values relative to Alternative A. Alternative 

D would also allow non-commercial collection of common invertebrate fossils and petrified wood. This would 

increase use value to the collectors, but over time would 

reduce use values to persons who would have reduced 

opportunities to view these resources in situ, and would 

reduce passive use value to persons who value in situ 

preservation of these resources.

Alternative D provides no specific management actions 

for lands with wilderness characteristics, like Alternative 

B. Also like Alternative B, other management actions under Alternative D do provide some protection for these 

lands. Therefore, Alternative D would have the same impacts on nonmarket values associated with wilderness as 
738 Chapter 4 BDWNCA RCNCA Chapter 4 739

IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES

Economic Development Stakeholders would favor the 

increased size of the ROW corridor in Alternative D rela-

tive to Alternative A, but would not favor management of 

the balance of the NCA as a ROW Exclusion area.

4.22.2.6 Environmental Justice Effects

Under the Executive Order on EJ, each federal agency 

must identify and address “disproportionately high and 

adverse human health or environmental effects of its pro-

grams, policies, and activities on minority populations 

and low-income populations” (EO 12898, §59 Federal 

Register 7629, 1994). Environmental effects include 

economic effects, such as costs imposed on persons in 

proximity to a federal action. Based on the EJ screen-

ing criteria and analysis presented in the Socioeconomic 

Baseline Report, no places in Washington County meet 

the criteria for potential EJ populations based on minor-

ity population. One place in Washington County meets 

the criteria for a potential EJ population based on pover-

ty status. This is Hildale City, based on the high percent-

age of its population living under the poverty level. In 

addition, according to federal guidance for considering 

EJ within the NEPA process (Council on Environmental 

Quality, 1997), Indian Tribes within the affected area 

of the proposed action must be considered in the EJ 

analysis. The analysis determined that a high proportion 

(estimated at 44 percent) of Native American individu-

als in Washington County are living in poverty, and thus 

the Native American population of the county meets the 

criteria to be considered a potential EJ population.

Further assessment determined that the potential for 

disproportionately high and adverse human health or en-

vironmental effects on these populations from the RMP 

alternatives is low. “Disproportionate” and “adverse” are 

the key concepts in this assessment. An EJ impact only 

exists if the impact on the identified population is harm-

ful, and “appreciably exceeds or is likely to appreciably 

exceed” the impact to the general population or other 

appropriate comparison group. In this case, the appro-

priate reference population is the general population of 

Washington County. The analysis results are as follows: ▶ Hildale City – This community is located at a considerable distance from the NCA. Thus it is unlikely 

to be adversely impacted by management decisions 

in the NCA RMP.

▶ Native American population in Washington 

County—This population is unlikely to experience 

both adverse and disproportionately high impacts 

from management decisions in the NCA RMP. No 

Native Americans are known to currently hold any 

grazing permits or Special Recreation Permits in 

the SGFO, so this population would not be affected 

by management actions affecting those permits. 

It is unlikely that any other activities allowed or 

prohibited by the RMP alternatives would have 

adverse health or environmental impacts on Native 

Americans in Washington County at rates that are 

disproportionate to any adverse impacts experi-

enced by other residents, particularly given that the 

Native American population is not concentrated 

in any one area (see the Socioeconomic Baseline 

Report). Federal EJ guidance also recognizes im-

pacts to Native American cultural sites as potential 

EJ impacts. With respect to such sites—ethno-his-

toric sites, sacred sites, traditional cultural proper-

ties and traditional use areas—all RMP alternatives 

have provisions for consultations with American 

Indian Tribes as required by federal historic preser-

vation laws, to inform and direct resource allocation 

and other management decisions related to these 

heritage resources. The action alternatives (B, C, 

and D) also would develop activity level Cultural 

Resource Project Plans for multiple types of heritage 

resources in consultation with culturally-affiliated 

American Indian Tribes. These consultations should 

allow for avoidance or mitigation of impacts to 

heritage resources. In summary, it is unlikely that 

the RMP alternatives would have disproportionately 

high and adverse human health or environmen-

tal effects on the Native American population of 

Washington County.

4.23 IRREVERSIBLE AND IRRETRIEVABLE 

COMMITMENT OF RESOURCES

Section 102(2)(C) of NEPA requires a discussion of any 

irreversible or irretrievable commitments of resources that 

are involved in the proposal should it be implemented. An 

irretrievable commitment of a resource is one in which the 

resource or its use is lost for a period of time (e.g., modifi-

cations to the landscape from fire or other vegetation treat-

ments). An irreversible commitment of a resource is one 

that cannot be reversed (e.g., the extinction of a species or 

destruction of significant heritage resources).

Implementing some of the management decisions or 

actions identified in the RMP could result in the irrevers-

ible or irretrievable commitment of resources. As exam-

ples, the development of new trails or trailhead parking 

areas would remove vegetation and this resource would 

be lost for a period of time at those locations. However, 

the majority of actions proposed under the alternatives 

RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES AND LONG-TERM 

PRODUCTIVITY

would focus on the conservation, protection, and restora-

tion of NCA, minimizing the potential for the irrevers-

ible or irretrievable commitment of resource values.

4.24 RELATIONSHIP BETWEEN LOCAL SHORTTERM USES AND LONG-TERM PRODUCTIVITY

Section 102(C) of NEPA requires discussion of the 

relationship between local, short-term uses of human 

environment, and the maintenance and enhancement 

of long-term productivity of resources. As described in 

the introduction to this chapter, “short term” is defined 

as anticipated to occur within one to five years of imple-

mentation of the activity. “Long-term” is defined as fol-

lowing the first five years of implementation but within 

the life of the RMP (projected to be 20 years).

Across all alternatives, certain management actions, such 

as fire suppression, hazardous fuel reduction projects or 

noxious weed control, could result in short-term effects, 

such as increased localized soil erosion, fugitive dust 

emission, vegetation loss or disturbances to wildlife. 

Alternative C would emphasize land use restrictions 

and the use of the least invasive methods to accomplish 

resource objectives and result in the fewer short-term re-

source commitments, when compared to Alternatives A, 

B, and D. In the long term, the three action alternatives 

would be expected to more effectively restore damaged 

landscapes, increase biodiversity, and enhance the longterm productivity of the public lands of the NCA than 

the No Action Alternative.
RCNCA Chapter 4 741

AIR QUALITY

Chapter 4: Environmental Consequences RCNCA

4.25 AIR QUALITY 

This section addresses the potential effects of emissions 

of air pollutants from specific activities authorized, or 

conducted by the BLM under each alternative. Existing 

conditions are described in Section 3.1 Air Quality.

4.25.1 Methods of Analysis

Air resources were evaluated within the NCA to determine how air quality could be affected by future management of the public lands under each of the alternatives 

described in Chapter 2. As air quality data specific to the 

NCA is currently not being collected, existing air quality conditions were estimated, based on air monitoring 

data collected in the greater St. George urban area. The 

analysis was developed based on management actions 

and activities that would be authorized within the NCA 

that could generate air pollutant emissions.

The analysis of potential impacts from air pollution emissions authorized by BLM can be conducted either quantitatively or qualitatively. A quantitative analysis is typically 

conducted through the use of computer simulations, or 

modeling, that takes into account existing air quality, the 

proposed emission sources, and their spatial and temporal 

characteristics. This is referred to as dispersion modeling, 

and is used by regulatory agencies in the permitting of 

stationary sources of air pollution. To be able to conduct 

this type of analysis, source-specific information is needed 

about future sources and activities, which is not currently 

available (e.g. what sources and where). 

Another type of modeling analysis is using photochemical or one-atmosphere models, which take all 

the sources in the large area and, using detailed meteorological and emissions parameters, estimates future 

air quality concentrations across the landscape. While 

applicable to planning level analysis, this type of model 

also requires detailed meteorological and emissions 

information which is not available for the planning area. 

In addition, a photochemical model is typically used in 

areas with large amounts of emissions. In this instance, 

however, a photochemical model would be unlikely to 

discern any potential impacts from BLM-authorized or 

initiated activities above the background or margin of 

error in the model. 

Given the minor amounts of sources and emissions associated in the NCA, and the lack of detailed source data 

needed to conduct any type of air quality modeling, this 

impact analysis for air quality will focus on a qualitative 

impacts analysis. An evaluation of the potential for management activities to generate pollutants of concern, their 

potential qualitative impacts, and potential management 

strategies for control will be presented. In addition, those 

conditions under which a more detailed subsequent 

analysis should be conducted will be identified to assist 

in future management decisions related to project authorization and management.

4.25.1.1 Indicators

Based on the air quality conditions presented in the 3.1.1 

Existing Environment- Air Quality, the following criteria 

pollutants have been identified as pollutants of concern 

in Washington County and could be emitted as a result 

of proposed management actions identified in the four 

alternatives.

▶ Particulate Matter (PM): While the NCA and 

Washington County, in general, are currently 

well under the applicable NAAQS for PM10 and 

PM2.5), short-term dust events can create health 

and nuisance impacts. Activities such as motorized 

vehicle travel on unpaved roads, wildfires, and other 

surface disturbing activities can all contribute to the 

potential for particulate impacts.

▶ Volatile Organic Compounds (VOCs): VOCs, while 

not a criteria pollutant under the Clean Air Act, is 

a precursor gas that contributes to regional ozone 

formation. VOCs are emitted from a wide variety 

of sources, such as vegetation, fuel use, and many 

other area type sources.

4.25.1.2 Assumptions

Major assumptions used in this impact analysis include 

the following:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ Predictions of future air quality effects from BLMinitiated or authorized activities were based upon 

the range of management alternatives outlined for 

the NCA in Chapter 2; 

▶ All land use proposals would be analyzed for conformance with RMP goals, objectives, and decisions 

and resource impacts analyzed through the NEPA 

process. Whenever projects are authorized that 

could impact air resources or contribute to GHG 

emissions, impacts would be avoided or lessened to 
742 Chapter 4 RCNCA RCNCA Chapter 4 743

AIR QUALITY

the extent possible through project design, BMPs, 

and other mitigation measures; 

▶ Recreational uses would be primarily non-motorized, casual, and dispersed over the life of the RMP;

▶ The magnitude of potential emissions increases as 

a result of all management actions identified in the 

alternatives developed for this RMP would be negligible to minor and unlikely to create or contribute 

to any measurable or significant adverse impacts.

Implementing management for the following resources 

or resource uses would have negligible or no impact on 

air quality because the level of activity is not expected 

to change between alternatives and the potential for 

emissions from the activity is considered to be very 

small. Therefore, these are not discussed in detail: Water 

Resources, Geologic and Paleontological Resources, 

Cave and Karst Resources, Soil Resources, Native 

Vegetation Communities, Fire and Fuels Management, 

Noxious Weeds and Invasive Species Management, 

Vegetation Resource Uses: Livestock Grazing, Vegetation 

Resource Uses: Plant Materials, Special Status Species, 

BLM Sensitive Species, Other Fish and Wildlife Species, 

Heritage Resources, Wilderness, ACEC, Visual Resource 

Management, Natural Soundscapes, Lands with 

Wilderness Characteristics, Lands and Realty, and Public 

Education and Outreach, and Scientific Research.

4.25.2 Direct and Indirect Impacts

None of the land uses or management actions identified 

in the range of alternatives for the NCA would impair 

any Class I air quality areas within 50 kilometers of the 

planning area, including Zion National Park and all 

designated wilderness areas in Washington County managed by BLM, NPS, and the USFS. Management actions 

proposed are designed to conserve, protect, and enhance 

the resources of the NCA.

4.25.2.1 Impacts from Management of Recreation 

and Visitor Services, and Comprehensive Travel and 

Transportation

These land uses and authorized activities could generate 

fugitive dust (PM) and combustion emissions (NO2, VOC) 

from motorized vehicles traveling on paved and unpaved 

roads. Emissions from this source category are represented 

in the emissions monitoring data shown in Chapter 3.1, 

from data collected at monitoring sites outside of the 

NCA, but are not expected to be of sufficient quantity or 

duration to create air quality issues with the NAAQS.

Approximately 19,989 acres of the nearly 45,000 acre 

NCA are within designated wilderness areas where no 

motorized or mechanized vehicle uses will be authorized 

under any alternatives and all other recreation uses are 

primitive and unconfined. All alternatives emphasize 

non-motorized recreational activities and limit motorized 

vehicle travel to designated roads, through the OHV area 

designation. Emission levels would not be predicted to 

measurably increase over time and would continue to be 

negligible to minor in both the short and long term. Dust 

abatement practices, such as speed limits on unpaved 

roads, could adequately mitigate fugitive dust emissions 

related to recreational activities and motorized vehicle 

travel, should emission levels measurably increase.

4.25.3 Summary of Impacts

For all alternatives considered by this analysis, the magnitude of the changes in emissions would be insufficient 

to have the potential to cause significant impacts to air 

quality within or adjacent to the planning area. 

Particulate matter (PM10, PM2.5) in the form of fugitive 

dust is the pollutant of most concern for the planning 

area. Coarse fugitive dust (PM10), such as would be released through surface disturbances related to motorized 

vehicle travel on unpaved roads, is considered to be a 

localized pollutant, rather than a regional scale pollutant, 

and can create elevated short-term impacts and nuisance 

level conditions. Under all alternatives, BLM would 

implement BMPs, dust abatement measures, or other 

management actions to reduce particulate emissions 

resulting from management actions.

4.25.3.1 Climate Change

Concentrations of certain gases in the earth’s atmosphere 

have been identified as being effective at trapping heat 

reflected off the earth’s surface thereby creating a “greenhouse effect”. As concentrations of GHGs increase, the 

earth’s surface warms and global climate is affected. 

Concentrations of greenhouse gases have increased dramatically in the earth’s atmosphere in the past century. 

Anthropogenic (man-made) sources and human activities have been attributed to these increases particularly 

for carbon dioxide, methane, nitrous oxide, and fluorinated gases (USEPA 2010). 

The EPA has determined that six GHGs are air pollutants 

and subject to regulation under The Clean Air Act. The 

six are carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. 

Of these GHGs, carbon dioxide, methane, and nitrous 

oxide are emitted by some activities that are authorized 

on public lands in the NCA, while the remaining three 

GHGs are not emitted or in very small quantities. 

WATER RESOURCES

In the NCA, GHG emissions from all activities that would 

be authorized are predicted to be negligible to minor 

under all alternatives and are not expected to contribute to 

measurable or significant air quality and climate 

change impacts.

It is important to note that GHG will have a sustained 

climatic impact over different temporal scales. For example, recent emissions of carbon dioxide can influence 

climate for 100 years. The IPCC’s latest report (IPCC,2014) 

states that the equilibrium climate sensitivity is likely in 

the range 1.5° C to 4.5° C (high confidence), extremely 

unlikely less than 1° C (high confidence), and very unlikely greater than 6° C (medium confidence). The climate 

sensitivity specifically due to CO2 is often expressed as the 

temperature change in ° C associated with a doubling of 

the concentration of carbon dioxide in Earth's atmosphere. 

This can take decades to centuries to be fully expressed. 

Modeling of climate change scenarios indicate that predicted changes are likely to occur over several decades 

to a century and may not be measurably discernible 

within the reasonably foreseeable future. Existing climate 

prediction models are global or continental in scale; 

therefore they are not appropriate to estimate potential 

impacts of climate change in much smaller areas. The 

current state of the science involves calculating potential 

quantities of greenhouse gases that may be added to the 

atmosphere from a particular activity. However, tools to 

analyze or predict how global or regional climate systems 

may be affected by a particular activity or activities within the planning area are not currently available. Assessing 

the impacts of GHG emissions on global climate change 

requires modeling on a global scale, which is beyond the 

scope of this analysis.

4.25.4 Cumulative Impacts

Potential GHG emissions from all activities that would 

be authorized in the NCA under all alternatives are 

predicted to be negligible to minor under all alternatives 

over the life of the RMP and are not expected to contribute to measurable air quality and climate change impacts. 

4.26 WATER RESOURCES

This section discusses impacts on water resources, with a 

focus on water quality, that could result from implementation of any of the proposed management actions identified for other resources and land uses in the alternatives 

presented in Chapter 2; existing water resource conditions are described in Section 3.23 Water Resources.

4.26.1 Methods of Analysis

4.26.1.1 Indicators

Indicators of adverse impacts on water resources include 

the following:

▶ Inability to meet state and federal water quality 

standards for surface and ground water;

▶ Inability to meet appropriate Utah Standards for 

Rangeland Health, based on measurement of nutrient loads, total dissolved solids, chemical constituents, fecal coliform, water temperature and other 

water quality parameters;

▶ Declining riparian zone health, with native vegetation type, diversity, density, and vigor departures 

from the Natural Range of Variability, based on 

ecological site conditions;

▶ Declining aquatic habitat quality for special status 

species and BLM sensitive native fish, amphibians, 

and macro-invertebrate communities.

4.26.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ Water quality would be managed to meet state and 

federal water quality standards for surface and 

ground water;

▶ Water quality would be managed to meet Utah 

Standard for Rangeland Health #4;

▶ Soils would be managed to minimize erosion (relative to natural erosion rates) and maintain soil 

productivity;

▶ Increased soil erosion above natural rates leads to 

decreases in surface water quality;

▶ Projects that help restore watersheds, desirable vegetation communities, or wildlife habitats (including 

surface disturbance associated with these efforts) 

would benefit water resources over the long term;

▶ The degree of impact attributed to any one disturbance or series of disturbances would be influenced 

by several factors, including proximity to drainages, 

proximity to surface water, intensity and duration 

of disturbance, reclamation potential of the affected 

area, existing vegetation, precipitation, and mitigating actions applied to the disturbance;

▶ BMPs would be followed for all authorized projects 

that would include surface disturbances (Appendix 

F).
744 Chapter 4 RCNCA RCNCA Chapter 4 745

WATER RESOURCES

Implementing management for the following resources 

would have no impact or negligible impacts on water quality and are, therefore, not discussed in detail in 

this analysis: Air Quality, Geologic and Paleontological 

Resources, Cave and Karst Resources, Vegetation Resource 

Uses: Livestock Grazing, Vegetation Resource Uses: Plant 

Materials, Other Fish and Wildlife Species, Heritage 

Resources, Wilderness, ACECs, Natural Soundscapes, and 

Lands with Wilderness Characteristics.

4.26.2 Direct and Indirect Impacts

Impacts on water quality can be caused by natural and 

human-caused factors. Natural erosion that increases 

sedimentation or leaching of salts and other mineral 

elements from soils can degrade water quality in surface water sources; the effects of natural erosion can 

be magnified and accelerated by surface-disturbances. 

Increased erosion and sedimentation to water bodies 

can result in changes to water chemistry and alter stream 

channel morphology. Contaminants, such as fecal waste 

from wildlife and humans may be directly introduced 

into surface water sources, also degrading water quality. Depending on the level of water quality degradation, 

surface waters may no longer be capable of supporting 

beneficial uses identified by the State of Utah.

Surface-disturbing activities in areas of low reclamation 

potential (e.g., “fragile soils,” soils derived from specific 

geologic formations) or in sensitive areas, such as stream 

channels and riparian habitats, would increase the potential for soil erosion and water quality impacts. They can 

also remove soil stabilizing agents, such as vegetative cover, 

soil crusts, and woody debris. Loss of one or more of these 

agents increases potential erosion and sediment transport 

to water bodies, leading to water quality degradation. 

Impacts on water resources could result from surface 

disturbances associated with fire suppression and vegetation treatments that leave soil surfaces exposed to wind 

and water erosion. Direct and indirect impacts can be 

mitigated through management actions that minimize, 

preclude, or stipulate how surface disturbances are authorized; resource impacts that cannot be avoided would 

be minimized by the application of BMPs (Appendix F). 

Management actions developed to improve soil conditions, riparian vegetation, and proper functioning condition of watersheds would benefit water resources in the 

short and long term.

4.26.2.1 Impacts from Management of Water 

Resources

Under all alternatives, the goals of management are to 

conserve and protect water resources so that they can 

fulfill the purposes of the NCA and sustain ecosystem 

resiliency under changing climatic conditions. Under 

Alternatives B, C, and D, BLM would seek to acquire water rights from willing sellers to benefit wildlife and recreation and improve aquatic habitats and riparian areas. 

These alternatives would also seek to acquire non-federal 

land inholdings from willing sellers that would benefit 

the protection and management of water resources.

Site-specific mitigation measures and the application of 

BMPs for surface disturbing activities would maintain 

soil stability and minimize wind and water erosion, protecting surface water sources from accelerated sedimentation. Post-fire ES&R actions would be implemented to 

minimize soil erosion that could impair water quality in 

Leeds and Quail Creeks and the Virgin River.

Re-vegetation treatments could be authorized in damaged riparian areas to restore proper functioning condition to surface water sources under all alternatives. 

Under Alternatives B, C, and D, re- vegetation of damaged riparian areas would be prioritized to maintain 

or restore proper functioning condition to springs and 

streams. These projects would be conducted using the 

least invasive methods possible, to lessen the amount 

of new surface disturbance and potential soil erosion. 

Riparian restoration would better protect water quality 

and more quickly return proper ecosystem functions. In 

the long-term, restoration of native plant species would 

benefit water resources, as these species are well-suited 

to local environmental conditions and can thrive without 

depleting soil health and water supplies.

Alternative A would analyze proposed surface-disturbing 

projects to determine the suitability of soils to support 

such projects, but does not identify surface disturbance 

prohibitions that could protect soil and, therefore, water 

resources. Alternatives B, C, and D would provide additional protection for soils in riparian areas along Quail 

Creek, Leeds Creek, the Virgin River, and in ephemeral 

drainages by prohibiting surface-disturbing activities 

within varying distances (250 feet, 1,000 feet, and 500 

feet, respectively) from the edge of the riparian zone. 

Alternative C would be the most protective, limiting such 

disturbances to within 1,000 feet of edge of the riparian 

zone, unless the project would enhance riparian conditions. Soil erosion potential would be lessened by these 

WATER RESOURCES

restrictions, helping to maintain watershed function and 

water quality.

4.26.2.2 Impacts from Management of Soil Resources

Maintaining or improving water quality usually means 

minimizing soil erosion, by preserving soil integrity and 

health. Measures to improve or protect water quality 

often involve reducing soil disturbances and compaction 

and minimizing the loss of vegetation cover, all of which 

help to maintain soil health.

Alternative A would analyze proposed surface-disturbing 

projects to determine the suitability of soils to support 

such projects, but it does not identify surface disturbance 

prohibitions that could protect soil and water resources. 

Alternatives B, C, and D would provide additional protection for soils in riparian areas along Leeds and Quail 

Creeks, the Virgin River, and in ephemeral drainages, by 

prohibiting surface-disturbing activities within varying 

distances from the edge of the riparian zone. 

Alternative C would be the most protective of the action 

alternatives, limiting such disturbances to within 1,000 

of the edge of the riparian zone, unless the project would 

enhance riparian conditions. Soil erosion potential would 

be lessened by these restrictions, helping to maintain 

watershed function and water quality. 

4.26.2.3 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Under all alternatives, the goals are to protect, conserve, 

and restore desired plant communities that provide critical 

habitats for special status species like the Mojave desert 

tortoise and other wildlife. These goals will also help to 

preserve water quality and the sustainability of stream 

flows in Leeds and Quail Creek and the Virgin River. 

Alternative A would authorize vegetation treatments 

to achieve multiple management objectives, including 

conversions of vegetation types (e.g., sagebrush steppe 

to grasslands) to benefit wildlife, or other management 

goals. While the use of native plant species for restoration 

and rehabilitation would be emphasized, non-native species could be used, when native species are not available 

or economically feasible. No specific treatment methods 

were precluded from use under this alterative.

Under Alternatives B, C, and D, vegetation treatments 

would only be authorized for re-vegetation of disturbed 

and fire-damaged lands and riparian areas, not for conversions of vegetation types. The three action alternatives 

emphasize the use of native plant species, particularly 

“early colonizing” species that could quickly re-establish 

vegetation cover to lessen wind and water erosion for 

re-vegetation projects. They also include more restrictive 

criteria than those of Alternative A related to the use of 

non-native species. Alternative C would not authorize 

the use of non-native species for vegetation rehabilitation 

in the NCA. 

Alternatives B and C would authorize non-invasive and 

minimally invasive methods to implement re-vegetation 

projects, to lessen the amount of new surface disturbance 

and potential soil erosion that could result from these 

projects. Alternatives A and D would authorize mechanical methods, like chaining and harrowing, that could 

create new and larger-scale surface disturbances that 

would leave soils vulnerable to wind and water erosion 

in the short term, until vegetative cover is re-established. 

Compared to Alternatives A and D, Alternatives B and C 

would better protect water quality from degradation associated with potential sediment run-off from vegetation 

treatment sites. 

The three action alternatives that propose to actively 

restore disturbed and fire-damaged vegetation communities would better protect water quality and more quickly 

return proper ecosystem functions when compared to 

Alternative A. In the short term, however, soil surfaces 

would remain exposed to erosional forces, until vegetative cover is re-established. In the long-term, restoration 

of native plant species would benefit water resources, 

as these species are well-suited to local environmental 

conditions and can thrive without depleting soil health 

and water supplies. 

Impacts on water resources related to wildland fires and 

fire suppression tactics can include increased soil erosion 

and runoff in the short term depending on the size and 

severity of the fire and the soil and vegetation types that 

are damaged. Use of heavy equipment to suppress fires 

can cause soil compaction and displacement, while the 

application of large amounts of fire retardant can negatively affect biological soil crusts and soil productivity. 

Alternatives B, C, and D focus management on the 

creation of fuel breaks and hazardous fuel reduction 

projects intended to conserve and protect intact and native Mojave Desert and Great Basin transition vegetation 

communities by lessening the potential for initial and 

“re-burn” wildland fires. The desert shrublands of these 

communities are not fire-adapted and recovery of late 

successional species, like blackbrush, from fire or other 

surface disturbances will not occur for hundreds of years, 

if at all. 
746 Chapter 4 RCNCA RCNCA Chapter 4 747

WATER RESOURCES

Alternatives B and D provide the greatest flexibility in 

the methods that would be employed for these projects, 

including biological, herbicidal, targeted grazing, and 

mechanical methods. In the short term, the use of any of 

these methods on a large scale could leave soil surfaces 

exposed to wind and water erosion, potentially increasing run-off and sedimentation to streams, like Leeds and 

Quail Creeks, and the Virgin River. Water quality could 

be impacted until vegetative cover and soil crusts have 

re-established. 

Alternative C restricts the methods to those that would 

create the least amount of new surface disturbance (hand 

removal and low impact mechanical methods), potentially lessening the potential for soil erosion that could 

negatively impact surface water quality. Limiting treatments under Alternative C would benefit soils in terms of 

reducing treatment-related compaction, soil disturbance, 

and chemical applications, but could limit the acreage 

that is able to be protected quickly or cost-effectively 

from the threats of wildfires. Wildfires could continue to 

damage or destroy many acres of desert shrublands, before effective fuel breaks or hazard fuel reduction projects 

would be completed, increasing short and long-term soil 

erosion potential. 

Alternative A identifies mechanical and prescribed fire as 

the only tools that can be used to reduce hazardous fuel 

levels. As a majority of the native vegetation communities of the NCA are not fire-adapted and slow to recover, 

the use of mechanical equipment and/or prescriptive fire 

under this alternative would leave soils exposed to wind 

and water erosion in the short and long term.

Alternative A provides general management direction 

that full suppression tactics be employed to keep fire 

sizes small in Mojave Desert vegetation communities and 

critical desert tortoise habitat. Alternatives B, C, and D 

identify that full suppression tactics should be employed 

to minimize the loss of unburned and once-burned 

native vegetation communities, particularly late successional desert shrublands. 

Alternative C prohibits the use of backburning in late 

successional shrublands, while Alternatives B and D 

require a case-by-case evaluation and specific approvals 

for the use of this tool. Use of backburning and heavy 

equipment during full suppression would create new 

surface disturbances that could increase soil erosion 

and sediment delivery to Leeds and Quail Creeks or the 

Virgin River in the short term. The impacts related to 

fire suppression would be lessened to the extent possible 

through post-fire emergency stabilization actions under 

all alternatives and rehabilitation plans designed to reestablish vegetation cover to lessen soil erosion potential.

4.26.2.4 Impacts from Management of Noxious 

Weeds and Invasive Species

Noxious weed and invasive species infestations can 

become so widespread as to create vegetation monocultures that are typically poorly suited to protecting soils 

from erosional forces. Increased erosion and sedimentation to water bodies can change water chemistry and 

alter stream channel morphology. Eradication of noxious 

weeds or invasive species can create short-term surface disturbances, but over the long term, benefit soils 

through surface stabilization with desirable species and 

reduced erosion potential.

Under all alternatives, Integrated Weed Management 

would be used to control, suppress and eradicate, where 

possible, noxious weeds and invasive species to support 

healthy plant communities across the planning area. 

Alternatives B, C, and D propose a range of tools and 

methods that could be employed for controlling noxious 

weeds and protecting soil resources. These alternatives 

identify strategies for controlling and ultimately eradicating non-native tamarisk and Russian olive in riparian 

areas along Leeds and Quail Creeks and the Virgin River, 

helping to protect stream flows and water quality. 

Alternative C would limit the aggressiveness with which 

the BLM could treat weed infestations, by restricting 

methods only to hand tools, which could result in the 

expansion of some noxious weeds, as treatments would 

take longer to complete and be more labor intensive. The 

loss of desirable vegetation communities could result 

in the loss of soil stabilization and increased erosion 

potential. At the same time, limiting weed treatments to 

non-invasive methods would be protective of soil and 

water quality, particularly for infestations within or near 

riparian areas. 

4.26.2.5 Impacts from Management of Special Status 

Species, Including BLM Sensitive Species

Under all alternatives, the goals are to conserve, protect, 

and restore critical habitats and assist the recovery and 

delisting of threatened and endangered species. All alternatives propose implementing post-fire ES&R treatments 

to stabilize soils and re-establish vegetation cover in 

habitats for special status species, helping to prevent accelerated erosion that could impair water quality in Leeds 

and Quail Creeks and in the Virgin River.

Alternatives B, C, and D emphasize the full suppression 

of wildfires in designated critical habitat for the Mojave 

WATER RESOURCES

desert tortoise, which could create new surface disturbances where heavy equipment is used to create large fire 

breaks. The impacts of wildfires and suppression tactics 

would leave in the burn areas exposed to wind and water 

erosion that could degrade surface water quality in the 

NCA. The implementation of post-fire ES&R actions 

would help to mitigate these impacts by stabilizing soils 

and re-establishing vegetation. 

Alternatives B, C, and D prioritize the conservation and 

protection of critical habitats from the effects of wildfire, 

through the development of fuel breaks and hazardous 

fuel reduction projects. These alternatives also prioritize 

the restoration disturbed and fire-damaged vegetation 

communities in designated critical habitats for Mojave 

desert tortoise and other at- risk species. Restoration of 

desired vegetation communities would help to lessen 

wind and water erosion of soils, minimizing the potential 

for water quality degradation through sedimentation.

4.26.2.6 Impacts from Management of Visual 

Resources

Under Alternative A, approximately 24,870 acres of the 

NCA would be managed as VRM Class III and 19,989 

acres as Class I, (Cottonwood Canyon and Red Mountain 

Wilderness areas). Class III designation would allow for 

moderate changes to the landscape and the authorization of activities or developments that could create new 

surface disturbances. Depending on the locations of the 

activities or developments, increased soil erosion could 

impact water quality in surface sources, like the Virgin 

River or its tributaries in the NCA.

Alternatives B, C, and D propose a range of VRM 

management options, with Alternative C proposing to 

manage 21,574 acres as VRM Class I and 23,284 acres 

as VRM Class II. Alternative C would afford the highest 

protection level for soils and water resources by limiting 

actions or developments that could impact the existing 

character of the landscape. Alternative D would provide 

less protection of the existing character of the landscape, when compared to the other three alternatives, 

as it would designate 6,534 acres as Class IV. Under 

this VRM designation, new utilities or transportation 

systems, including above-ground power lines or new 

highways, could be authorized that would measurably 

modify the scenic qualities of the landscape. These 

modifications would result in new surface disturbances 

that could accelerate soil erosion and negatively impact 

surface water sources.

4.26.2.7 Impacts from Management of Recreation 

and Visitor Services

Alternative A would continue the management of recreational activities and public uses, as authorized through 

the Reserve PUP. Non-motorized recreational uses in the 

Lowland Zone would continue to be on designated trails; 

off-trail travel would be authorized in the Upland Zone. 

Motorized vehicle travel would be Limited to Designated 

Roads, including the Babylon Road. Dispersed camping would continue to be limited to the two designated 

Wilderness areas, the Upland Zone, and Sand Cove 

Primitive Camping area. Recreational target shooting 

would continue to be prohibited as would the discharge of 

firearms, except in the act of licensed hunting according to 

state laws during prescribed hunting seasons. The current 

management decisions provide considerable protection to 

Leeds and Quail Creeks, as well as the Virgin River. 

Alternatives B, C, and D include the development of a 

professionally-designed non-motorized trail system in 

the NCA, to provide high-quality experiences for diverse 

users, with trailheads and waysides that provide maps and 

interpretive information about the NCA purposes and values. This system would be expected to minimize the number of new social trails that are developed in the short and 

long term, protecting soil and vegetation and lessening the 

potential for accelerated erosion that could impair surface 

water quality in the streams and in the Virgin River.

Alternatives B, C, and D propose changes related to zoning 

of the NCA, through the establishment of four Recreation 

Management Zones to guide management of recreational 

uses. Dispersed camping would be prohibited in the Rural 

and Frontcountry Zones under the three alternatives. 

Alternatives B and D would allow dispersed camping in 

the Backcountry Zone, while Alternative C would prohibit 

this activity in the Backcountry Zone. These restrictions 

on dispersed camping could help to prevent human waste 

and litter from being deposited in surface water sources in 

these zones.

4.26.2.8 Impacts from Management of 

Comprehensive Travel and Transportation

All alternatives propose OHV area designations for the 

NCA, with specific route designations to follow through 

BLM’s development of a TMP for Washington County. 

While the specific route designations developed in the 

TMP would have the most direct and indirect benefits on 

water resources, all alternatives are identical and afford a 

high level of protection to soils and water quality, based 

on the area designations. Potential impacts or benefits 

to water resources across alternatives for OHV area 
748 Chapter 4 RCNCA RCNCA Chapter 4 749

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designations can be estimated by comparing the number 

of acres that are Open, Limited, and Closed to OHV uses. 

Alternatives that close more acres to motorized travel 

would be expected to provide the highest level of protection to soils from surface disturbances, and, indirectly, to 

surface water sources and water quality.

Under all alternatives, the 19,989 acres of designated 

wilderness in Red Mountain and Cottonwood Canyon 

Wilderness areas would continue to be managed as 

Closed to all motorized uses. The remainder of the NCA 

would be managed as Limited to Designated Roads and 

Trails, with specific route designations to follow in the 

TMP. No areas would be managed as Open to off-road 

travel, benefitting water resources by protecting soils and 

water quality.

4.26.2.9 Impacts from Management of Lands and 

Realty

Under all alternatives, 19,989 acres in two designated 

wilderness areas would continue to be managed as an 

Exclusion area for the siting of new site-type and 

linear ROWs. 

Alternative A would continue to manage designated 

utility corridors along State Route 18 and I-15 through 

the NCA as the potential location for linear ROWs and 

encourage the use of these corridors. Approximately 

24,686 acres of the NC A, outside of the designated 

wilderness areas and utility corridors, would be managed 

as a ROW Avoidance area. ROWs could be granted in 

the Avoidance area, if no other feasible alternative routes 

are available or designated corridors are not available. 

Existing ROWs for utilities, including water lines, power 

lines, and associated facilities would remain valid existing rights and could be maintained under the terms and 

conditions of the ROW grant. This alternative could 

result in impacts on water resources related to new developments under ROWs in the designated corridor along 

I-15, as it crosses Quail Creek. The use of BMPs and 

standard mitigation would help prevent or mitigate impacts on surface water sources wherever project-related 

impacts could occur.

Alternative B would manage approximately 41,023 acres of 

the NCA as a ROW Exclusion area, 3,652 acres as a ROW 

Avoidance area, and 183 acres within the two designated 

corridors, along State Route 18 and I-15. This alternative 

would provide greater protection to water resources, when 

compared to Alternatives A and D, as new surface disturbances related to utilities developments and access road 

construction would not be authorized across a majority of 

the land base of the NCA, lessening the potential for soil 

erosion and sedimentation to surface water.

Alternative B would carry forward the designated utility 

corridors along State Route 18 and I-15. The continued 

management of a designated corridor along I-15 through 

the NCA would have the potential to increase soil erosion and impair water quality in Quail Creek, which 

flows through the designated corridor, should large scale 

power transmission lines and access roads be constructed 

under ROWs in this corridor. The use of BMPs and standard mitigation would help prevent or mitigate projectrelated impacts.

Alternative C would manage approximately 44,809 acres 

of the NCA as a ROW Exclusion area, protecting soil 

and water resources, as new ROWs would not be authorized. It would retain the existing designated utility corridor along State Route 18 (50 acres) but revoke 

the designated utility corridor along I-15 (133 acres), 

through the NCA, subject to any valid existing rights. 

Revocation of this corridor would help to protect water 

quality in Quail Creek, as new linear ROWs for utilities 

or transportation purposes would not be granted in this 

area of the NCA. Development-related surface disturbances that could accelerate erosion for the gypsum-rich, 

fragile soils in that area would not occur, minimizing the 

potential for the introduction of sediments or saline soils 

to the stream channel.

Alternative D would manage 38,325 acres of the NCA 

as ROW Exclusion area, but would retain the existing 

designated utility corridors along State Route 18 and 

I-15 (183 acres) and would designate a new utility and 

transportation corridor, totaling 6,350 acres in size, in 

which new utilities and the new multi-lane roadway proposed by Washington County (the “northern transportation route”) could be constructed. Surface disturbances 

during utilities development in the I-15 corridor could 

increase soil erosion and the potential for impacts on 

surface water in Quail Creek.

Construction of a multi-lane highway in the new utility and transportation corridor could alter drainage 

patterns, directly or indirectly impacting surface water 

sources located downstream on state and private lands. 

This alternative would make approximately 6,534 acres of 

the NCA available for new ROWs developments, providing less protection for water resources than the three 

other alternatives. The use of BMPs and standard mitigation measures would help prevent or lessen impacts to 

the maximum extent possible during developments in 

WATER RESOURCES

the three designated utility corridors proposed under 

Alternative D.

4.26.2.10 Impacts from Management of Public 

Education and Interpretation

Alternatives B, C, and D identify Public Education 

Outreach and Interpretation opportunities that would 

help to inform public land users about the ecological values of the NCAs and stewardship of these values through 

appropriate public land etiquette. This type of educational outreach would be expected to lessen impacts on soils, 

native vegetation, and watersheds, as public awareness 

and appreciation for the unique values of the NCA is increased and an understanding to the impacts of off-trail 

and damaging activities is enhanced.

4.26.2.11 Impacts from Management of Scientific 

Research

Science management would pursue opportunities for 

field investigations, water quality monitoring, data 

collection, and research to further the conservation, 

protection, and restoration of Mojave Desert and transitional ecosystems. Under Alternatives B, C, and D, 

research opportunities would be pursued that further the 

scientific understanding natural processes and causeand-effect relationships between management actions 

and resource responses. Knowledge gained would help 

the BLM more effectively and efficiently manage public 

lands for the conservation, protection, and restoration of 

healthy ecosystems, conferring a long-term public benefit. Alternatives B, C, D are expected to result in greater 

understanding of ecosystem processes, including water 

resources, which could translate into better management 

strategies in the face of changing climatic conditions.

4.26.3 Summary of Impacts from Alternatives

Under Alternative A (No Action), management of land 

uses and authorized activities that have potential to 

impact soils and water resources, such as recreation and 

ROWs for utilities and transportation developments, 

would continue as authorized by management decisions 

in the SGFO RMP that were developed to implement 

Washington County’s HCP. These decisions would continue to provide direct and indirect, moderate and long 

term beneficial effects on watersheds, soils, and native 

vegetation communities that comprise special status species’ habitats.

Under Alternatives B, C, and D, management actions 

would focus on the conservation, protection, and restoration of watersheds, soils, and native vegetation communities that provide critical habitats for special status 

species, and other fish and wildlife. These would include 

measures to prevent future wildfires, as these pose the 

greatest single threat to the Mojave Desert and Great 

Basin ecosystems that overlap in the NCA and other resource values of the NCA. Emphasis would be placed on 

re-vegetation of disturbed and fire-damaged landscapes 

with healthy native vegetation communities that would 

not be susceptible to the establishment or spread of noxious weeds and invasive species.

Alternatives B and C propose to manage recreation 

uses, motorized vehicle travel, and ROWs to provide 

higher levels of resource protection, when compared to 

Alternatives A and D. The potential beneficial effects on 

native vegetation, soils and water resources under these 

alternatives would be moderate, direct, and long term. 

Under Alternative C, the proposed management of a 

majority of the acreage of the NCA as a ROW Exclusion 

area, the revocation of the designated utility corridor 

along I-15 that crosses Quail Creek would provide a 

higher level of protection for water resources, when 

compared to the other alternatives, based on restrictions 

on land uses.

Alternative D proposes the management of three designated corridors where new utilities and transportation 

routes could be constructed under ROWs. The authorization of new power transmission lines, pipelines, or other 

linear ROWs across Quail Creek could result in negative, 

minor to moderate short-term impacts on surface water 

quality. The impacts described above would be mitigated 

to the maximum extent possible, through the application 

of BMPs and other management actions. This alternative 

would make approximately 6,534 acres of the NCA available for new ROWs developments, providing less protection for water resources than the three other alternatives.

4.26.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on water 

resources extends outside the NCA boundaries, to 

include public lands managed by BLM and USFS-Dixie 

National Forest; State Lands (SITLA, UDWR, Snow 

Canyon State Park) and private and municipal lands 

within and adjacent to the boundaries of the NCA. 

Management actions on these adjoining lands would 

have the potential to influence resource conditions and 

desired outcomes in the NCA. 

Under all alternatives, water resources would receive 

certain levels of protection due to management in accordance with the Clean Water Act, and applicable state and 

federal water quality standards.
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Past, present, and reasonably foreseeable future actions 

and conditions within the CIAA that have affected and 

will likely continue to affect water resources include 

domestic livestock grazing, motorized recreational activities, utilities construction, road and highway construction and maintenance, urban developments, wildland 

fires, and drought. 

Reasonably foreseeable future actions within the NCA 

that could have an effect on soil and water resources include the development of fire breaks and hazardous fuel 

reduction projects, fire suppression, recreation and visitor uses, ROW maintenance actions and potential new 

developments, depending upon the alternative selected. 

The impacts described above could result, but would be 

mitigated to the maximum extent possible, through the 

application of BMPs and other management actions.

Natural processes, such as wildfires, drought, flood 

events, and climate change, will continue to impact soils, 

native vegetation, and water resources in the long and 

short term. Invasive annual grasses that fuel fire regimes 

atypical for Mojave Desert and Great Basin ecosystems 

now pose the greatest threats to the survival of native 

vegetation communities, biological soil crusts, and functioning watersheds.

Recent drought and potential climate change resulting in 

more frequent future droughts could decrease vegetative 

cover, increasing the potential for soil erosion, desertification, and fugitive dust production. These additional 

stresses to vegetation communities could contribute towards vegetation loss and establishment of less desirable 

species. This could, in turn, affect water quality.

4.27 GEOLOGIC AND PALEONTOLOGICAL 

RESOURCES

This section discusses impacts on paleontological resources and outstanding geologic features from 

proposed management actions of other resources and 

resource uses. Existing conditions concerning paleontological resources and outstanding geologic features are described in Section 3.3.1, Geological and 

Paleontological Resources.

Paleontological resources include any fossilized remains, 

traces, or imprints of organisms preserved in or on the 

earth’s crust that are of scientific interest and that provide information about the history of life on earth. BLM 

policy is to manage paleontological resources for scientific, educational, and recreational values and to protect 

or mitigate these resources from adverse impacts. To 

accomplish this goal, paleontological resources must be 

professionally identified and evaluated, and paleontological data should be considered as early as possible in 

the decision-making process. Requirements under all 

alternatives to identify paleontological resources in areas 

of high potential prior to ground disturbance would allow evaluation, avoidance, recovery, or other mitigation 

to preserve the scientific, educational, and interpretive 

resource uses.

Outstanding geologic features are natural rock structures 

such as monuments, arches, faults, and mud cracks having uncommon, rare, or exceptional aesthetic, educational, or scientific value, or well-known markers for 

historic events or sensitive cultural areas. These features 

are currently not surveyed or inventoried.

4.27.1 Methods of Analysis

Potential impacts on paleontological resources were 

evaluated using the recently revised PFYC system (BLM 

IM 2008-009, Potential Fossil Yield Classification System 

for Paleontological Resources on Public Lands). For the 

purpose of assessing impacts, only those objectives and 

actions potentially affecting scientifically significant fossils were considered, as well as those objectives and actions potentially affecting outstanding geologic features.

The following impact analysis provides a general description of common impacts on geological and paleontological resources from management actions identified in 

Chapter 2.

4.27.1.1 Indicators

Adverse impacts include the damage or destruction 

of nonrenewable fossil resources and the loss of 

information associated with these resources, as a result 

of surface disturbances or the unauthorized collection of 

fossil remains.

Impacts on outstanding geologic resource would be a 

management concern if they resulted in the destruction, 

severe damage, or alteration of the geologic feature to 

the point of non-recognition or loss of associated educational or scientific information. 

More generally, adverse impacts on paleontological resources and outstanding geologic features could occur if 

reasonably foreseeable future actions were to:

▶ Conflict with paleontological resource management 

objectives and guidelines established by the BLM;

▶ Disturb geologic formations with high sensitivity 

for scientifically important fossil resources (PFYC 

Classes 3 through 5); or

GEOLOGIC AND PALEONTOLOGICAL RESOURCES

▶ Destroy or substantially damage or alter an outstanding geologic formation.

4.27.1.2 Assumptions

This analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resource values 

of the NCA;

▶ Land use proposals would be reviewed for conformance with RMP goals, objectives, and decisions 

and resource impacts analyzed through the NEPA 

process. Whenever projects are authorized, impacts to significant paleontological resources and 

outstanding geological features would be avoided 

or lessened to the extent possible through project 

design, BMPs, and other mitigation measures;

▶ Occurrences of paleontological resources are closely 

related to the geologic units that contain them. The 

probability for finding paleontological resources can 

be broadly predicted from the geologic units present at or near the surface;

▶ Geologic mapping can be used for assessing the 

potential for the occurrence of paleontological 

resources using the BLM’s PFYC system;

▶ Scientifically important fossils would continue to be 

discovered in the NCA;

▶ Discoveries are most likely to occur in geologic 

units classified as high potential PFYC Class 3-5;

▶ Increased knowledge of paleontological resources 

and outstanding geologic features could lead to 

improved management that has a beneficial impact 

on the resource and results in an increased public 

stewardship ethic.

Implementing management actions for the following 

resources would have no impact or negligible impact on 

Geological and Paleontological Resources and are, therefore, not discussed in detail: Air Quality, Water Resources, 

Cave and Karst Resources, Soil Resources, Noxious Weeds 

and Invasive Species Management, Vegetation Resource 

Uses: Livestock Grazing, Vegetation Resource Uses: Plant 

Materials, Special Status Species, BLM Sensitive Species, 

Other Fish and Wildlife Species, Heritage Resources, 

Wilderness, ACECs, Natural Soundscapes, and Lands with 

Wilderness Characteristics.

4.27.2 Direct and Indirect Impacts

Shallowly buried paleontological resources can be 

exposed by natural erosion, which can be exacerbated 

by surface-disturbing activities in the general vicinity of 

the resources. Surface exposure can lead to discovery of 

paleontological resources, but fossils can be damaged or 

lost by the direct action of ground disturbance, subsequent erosion, and unauthorized collection. Measures to 

control erosion and loss of ground cover, such as reducing soil disturbances from land uses and authorized 

activities, as well as maintaining and restoring vegetation 

have the potential for reducing damage or destruction of 

paleontological resources

Data recovery excavations, whether for paleontological 

or heritage resources, can have direct impacts on paleontological resources; the very nature of excavation is to 

remove in situ resources, resulting in destruction of the 

fossil locality. These effects are mitigated by data collected during excavation, which would be recorded in 

detail for future researchers to see, interpret, and further 

understand. In many cases, paleontological resources 

and outstanding geologic features are actually saved from 

destruction by collection.

Under all alternatives in Chapter 2, restrictions on surfacedisturbing activities would be implemented in order to 

protect soils and water quality, special status species and 

their habitats, other fish and wildlife and their habitats, 

and heritage resources. Where surface-disturbance is prohibited, outstanding geological features and paleontological resources would be protected from damage. 

4.27.2.1 Impacts from Management of Geologic and 

Paleontological Resources

All alternatives would comply with federal legal requirements and BLM policies that address the management of 

paleontological resources and other objects of scientific 

interest on public lands, including the Paleontological 

Resources Protection Act of 2009. Proposed surfacedisturbing actions would continue to be reviewed and 

resource inventories conducted, as needed, to identify the 

potential for paleontological resources to be present, the 

depth and extent of ground disturbance, and the presence of the known localities in the vicinity. These measures would help ensure the protection of paleontological resources from impacts due to federally-authorized 

surface-disturbing activities and help preserve opportunities for scientific, educational, and recreational uses of 

these resources.

Under all alternatives, monitoring patrols and condition 

assessments would be conducted at fossil localities and 

no commercial sale or use of petrified wood would be 

allowed in the NCA. This will have positive direct impact 

to paleontological resources.
752 Chapter 4 RCNCA RCNCA Chapter 4 753

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Alternative A provides minimal management direction 

for geological and paleontological resources and makes 

no Use Allocations for these resources.

Alternatives B, C and D propose to conduct paleontological surveys in areas with high potential for scientifically important fossil localities (PFYC Classes 3, 4 and 

5). Areas of the NCA with high potential important fossil 

localities include the Red Mountain and Cottonwood 

Canyon Wilderness. These alternatives would positively 

affect resource protection by identifying and assessing 

localities and any outstanding geologic features in high 

potential areas. 

Under Alternatives B and D, allocating and managing 

100% of trackways, vertebrate and paleo-botanical fossil 

localities for Scientific Use, Conservation for Future Use 

and Public Use is proposed. Alternative C makes similar allocations for Scientific Use and Conservation for 

Future Use, but does not allocate localities to Public Use, 

providing a slightly higher level of protection for fossil 

resources, as public use could remove resources or result 

in vandalism or inadvertent resource degradation.

At times it is essential to use hand tools, and sometimes 

even mechanized tools, to inventory and collect paleontological specimens. Authorization for the use of hand tools 

to those researchers holding valid NCA Scientific Research 

Permits and BLM paleontological Resource Use Permits is 

proposed under Alternatives B and D. These alternatives 

would also authorize the use mechanized equipment, on 

a case-by-case and site- specific basis. The impacts from 

Alternatives B and D could be minor to major, depending on the amount, scale, location and access to the area 

and resource being excavated; mitigation measures would 

lessen negative impacts to the extent possible.

Under Alternative C, mechanized equipment would not 

be authorized for inventory and collection of specimens. 

This alternative would provide a higher level of protection to fossil resources and adjacent soils and vegetation, 

but could limit the types of specimens that could be 

feasibly exposed for collection, by only using hand tools. 

Alternatives B and C prohibit the collection of common invertebrate fossils for commercial or personal 

use. Alternative D would allow the casual collection of 

invertebrate fossils for personal use either by surface 

collection or the use of non-motorized hand tools that 

result in negligible surface disturbance. In the long-term, 

Alternative D could have negative impact to this type 

of paleontological resource, due to “over collecting” by 

the general public and the lack of oversight on what and 

where specimens are collected.

Alternative A allows for the continued collection of petrified (silicified) wood on public lands, as long as collection complies with federal regulations at CFR 3622 and 

is limited to 250 pounds per person per year for personal 

use. No commercial use is permitted to avoid the rapid 

depletion of the resource. However, this alternative does 

not explicitly define the methods that can be used to collect specimens or the locations where petrified wood collection is allowed, which could result in adverse impacts 

on scientifically-important exposures and the long-term 

loss of data. Overall depletion of petrified wood in the 

NCA could occur in the long term, as monitoring of 

quantities collected is not feasible.

Alternatives B and C would prohibit the collection of 

petrified wood for personal use and preserve this resource where it occurs in the NCA, providing for the 

long term protection of the resource and its scientific 

information potential. 

Alternative D would also allow the collection of petrified wood for personal use (in compliance with federal 

regulation in CFR 3622). The collection allowances are 

the same as Alternative A, but this alternative restricts 

collection to the use of non-motorized hand tools. This 

alternative would provide a higher level of protection for 

this resource and other natural and heritage resources in 

the vicinity, but could result in the overall depletion of 

petrified wood in the NCA, as monitoring of quantities 

collected is not feasible.

4.27.2.2 Impacts from Management of Native 

Vegetation Communities and Fire and Fuels

All alternatives propose to restore fire-damaged native 

vegetation communities, through a variety of methods. 

Re-vegetation projects could benefit shallowly buried 

paleontological resources by lessening soil loss to erosion 

after vegetative cover is re-established. Alternatives A and 

D would authorize mechanical methods, like chaining 

and harrowing, could expose or damage undocumented 

shallow subsurface paleontological resources; the potential for inadvertent damage would be avoided or minimized through project planning and review of the PFYC 

classifications for the project area.

Alternatives B and C would authorize non-invasive and 

minimally invasive methods to implement re-vegetation 

projects, to lessen the amount of new surface disturbance 

and potential soil erosion that could result from these 

projects. Both alternatives would provide a higher level 

GEOLOGIC AND PALEONTOLOGICAL RESOURCES

of protection for undocumented shallow subsurface 

resources, when compared to Alternatives A and D.

High severity fires can cause cracking and spalling of 

surface and shallowly buried paleontological resources. 

Vegetation loss to fires can expose previously undiscovered fossil resources, allowing for their study and protection; however, locations exposed by fire can be susceptible to damage by subsequent erosion, vandalism, and 

unauthorized collecting.

Under Alternative A, full suppression of fires would 

generally be employed, but with some options for minimum impact tactics in special status species’ habitats. 

Alternatives B, C, and D would emphasize full suppression to conserve and protect native vegetation communities, particularly late successional shrublands. 

Fire suppression often requires the construction of fire 

lines and the use of heavy equipment that could directly 

impact paleontological resources or outstanding geologic 

features. Suppression-related impacts on important fossil 

localities or outstanding geological features would be 

avoided whenever possible, through the use of qualified 

Resource Advisors who could identify where resource 

values occur and make recommendations on how to 

avoid impacting them, while still ensuring firefighter 

safety and property protection.

Fuels management under Alternative A would allow for 

mechanical hazardous fuel reduction treatments and 

prescribed fires; both methods could negatively impact 

surface fossil localities. Project planning would require the 

evaluation of PFYC and paleontological resource databases 

for the NCA to determine whether resources would be at 

risk and development project designs that would avoid 

impacts to scientifically important fossil localities.

Fuels management under Alternatives B, C, and D would 

not authorize the use of prescriptive fire in the NCA, 

eliminating the potential for damage to fossil resources 

and outstanding geological features related to this 

management tool. These alternatives provide a range of 

methods for hazardous fuel reduction treatments and 

the construction of fire breaks that attempt to minimize 

new surface disturbances. Alternative C would limit 

these methods to hand tools and low impact mechanical 

equipment, providing the highest level of protection for 

shallow surface fossil localities from disturbances, when 

compared to all other alternatives.

4.27.2.3 Impacts from Management of Visual 

Resources

Outstanding geologic features can contribute to the 

visual character and may be considered in determining VRM classifications. VRM Class I and II objectives 

provide protection of paleontological resources and 

outstanding geologic features by requiring that landscape 

modifications meet high standards for mitigation, usually 

reducing the scale of development that can be permitted in the area. Effects would be directly and indirectly 

reduced where surface-disturbing activities are limited 

in the more sensitive VRM class areas. Use of the visual 

resource contrast rating system during project planning 

could reduce alterations to geologic features and visual 

intrusions on the surrounding landscape.

Alternative A would retain VRM Class III for 24,870 

acres of the NCA and manage the 19,989 acres of designated wilderness in the Cottonwood Canyon and Red 

Mountain Wilderness areas as VRM Class I. Landscape 

modifications under VRM Class III could result in 

surface-disturbing activities that damage significant paleontological resources or outstanding geologic features.

Under Alternative B, 21,034 acres would be managed as 

VRM Class II, 19,989 acres of designated wilderness as 

VRM Class I, 3,652 acres as VRM Class III, and 184 acres 

would be managed as VRM Class IV further reducing 

the acreage where surface-disturbing activities that damage significant paleontological resources or outstanding 

geologic features.

Alternative C would manage visual resources most protectively, with 21,574 acres of the NCA managed as VRM 

Class I and 23,285 acres as VRM Class II. No areas would 

be managed as VRM Class III or IV. Alternative C would 

provide the greatest level of protection from impacts 

from large-scale surface-disturbing activities, providing 

the highest level of protection for paleontological resources and outstanding geological features.

Alternative D proposes to manage 19,989 acres as VRM 

Class I, 18,336 acres as VRM Class II and 6,534 acres as 

VRM Class IV. Management under VRM Class IV would 

not preclude large-scale surface-disturbing activities, 

providing the lowest level of protection for paleontological resources and outstanding geological features.

4.27.2.4 Impacts from Management of Recreation 

and Visitor Services

Recreation can physically alter exposed or shallowly buried paleontological resources and outstanding geologic 
754 Chapter 4 RCNCA RCNCA Chapter 4 755

GEOLOGIC AND PALEONTOLOGICAL RESOURCES

features, leading to damage from erosion, and facilitate 

unauthorized collection and vandalism. 

Alternative A would continue to manage the NCA within 

the Red Mountain/Santa Clara SRMA and the SGFO 

ERMA for dispersed recreation uses that generally do 

not include developments or facilities. The management 

of recreational activities and public uses would continue 

as authorized through the implementation-level PUP. 

Non-motorized recreational uses in the Lowland Zone 

would continue to be on designated trails; off-trail travel 

would be authorized in the Upland Zone. Motorized 

vehicle travel would be Limited to Designated Roads, 

including the Babylon Road. Dispersed camping would 

continue to be limited to the two designated wilderness areas, the Upland Zone, and Sand Cove Primitive 

Camping Area. The current management decisions provide considerable protection to paleontological resources 

as a result of use prescriptions.

Alternatives B, C, and D would not carry forward the 

existing SRMA and ERMA designations, but would 

establish the Red Cliffs SRMA to provide for high-quality 

visitor experiences. Management of the SRMA would 

include rules and guidelines to limit or control activities 

that could impact other NCA resource values through 

management tools such as designated campsites or group 

size limits. A Recreation Area Management Plan would 

be completed to identify authorized recreation and public uses for the SRMA; management decisions from the 

PUP for public lands would not be carried forward under 

these alternatives. 

Alternatives B, C, and D propose the development a 

professionally-designed non-motorized trail system in 

the NCA, to provide high-quality experiences for diverse 

users, with trailheads and waysides that provide maps 

and interpretive information about the NCA purposes 

and values. Beneficial effects would be expected from the 

new trail system, as it would minimize the number of new 

social trails that are developed in the short and long term, 

potentially protecting many resource values from impacts.

4.27.2.5 Impacts from Management of 

Comprehensive Travel and Transportation

Motorized or mechanized vehicles can physically damage geological features and paleontological localities, and 

public access can result in vandalism and unauthorized 

collection of fossils. These impacts are most directly 

related to the density and location of route networks 

that are designated on public lands, through a Travel 

Management Plan process.

The impacts or benefits on geologic features and paleontological localities related to OHV area designations 

can be estimated by comparing the number of acres 

that are designated as Open, Limited to Existing Roads 

and Trails, Limited to Designated Roads and Trails, and 

Closed to motorized vehicle travel and uses through the 

RMP. Alternatives that close more acres to motorized 

travel would be expected to reduce the potential for damage to paleontological localities and outstanding geological features.

All alternatives propose identical OHV area designations 

for the NCA, with specific route designations to follow 

through BLM’s development of a TMP for Washington 

County. OHV area designations under all alternatives 

would designate all acres as either Closed or Limited to 

Designated Roads and Trails.

All alternatives would limit OHV use to Designated 

Roads and Trails on 24,870 acres and designate 19,989 

acres as Closed to all motorized travel. These designations could provide benefits to paleontological resources 

in the long term, as all OHV use would be on designated 

roads and trails, avoiding the damaging effects of vehicle travel across exposed surfaces or localities. For the 

remainder of the NCA, primarily in designated wilderness areas, no motorized OHV use would be authorized. 

No designations of Open to Cross-country OHV use and 

Limited to Existing Roads and Trails would occur. 

4.27.2.6 Impacts from Management of Lands and 

Realty

Under all alternatives, non-federal inholdings may be 

acquired in the NCA; such acquisitions may provide 

necessary protection to geological and paleontological 

resources that may otherwise be negatively impacted, as 

acquired lands would be managed consistent with the 

conservation, protection, and enhancement purposes of 

the NCA.

Alternative A would continue to manage 24,686 acres of 

the NCA as a ROW Avoidance area and two designated 

utility corridors, one along State Route 18 and one along 

I-15. Unless specific criteria are met, new ROWS for utilities and transportation facilities would not be authorized 

in the Avoidance area. Geological and fossil resources 

would be protected from impacts related to new developments within the Avoidance area.

Existing ROWs could be modified to allow for upgrades 

to existing power transmission lines, water lines, and associated facilities that could result in damage or destruction to scientifically important fossil localities. Impacts 

GEOLOGIC AND PALEONTOLOGICAL RESOURCES

to these resources would be lessened to the extent 

possible through inventories to identify high potential 

areas, project design modifications, and project-specific 

mitigation measures that would be implemented prior to 

project authorization.

Alternative B would manage a total of 41, 023 acres of the 

NCA as a ROW Exclusion area and would carry forward 

two designated utility corridors, one along State Route 18 

and one along I-15. Approximately 183 acres would continue to be managed as a ROW Avoidance area. Geologic 

and paleontological resources would be protected from 

the impacts related to new ROWs development under 

this alternative when compared to Alternative A. 

Existing ROWs could be modified to allow for upgrades 

to existing power transmission lines, water lines, and 

associated that could result in damage or destruction to 

scientifically important fossil localities. Impacts to these 

resources would be lessened to the extent possible through 

inventories to identify high potential areas, project design 

modifications, and project-specific mitigation measures 

that would be implemented prior to project authorization. 

Alternative C would manage a total of 44,809 acres of 

the NCA as a ROW Exclusion area, protecting 24,870 

acres of soil and native vegetation from impacts related 

to new ROW developments. Under this alternative, the 

designated utility corridor along I-15 would be revoked 

through the NCA, providing additional protection to paleontological resources. Modifications to existing ROWs 

in the State Route 18 corridor could occur and potential 

impacts to paleontological resource values identified and 

mitigated as described under Alternatives A and B.

Alternative D would manage 38,325 acres of the NCA as 

a ROW Exclusion area and carry forward the two designated utility corridors along State Route 18 and I-15. 

New utilities could be developed under ROWs in either 

corridor and existing ROWs could be modified to allow 

for upgrades to existing power transmission lines, water 

lines, fiber-optic lines, and associated facilities that could 

result in resource impacts of geological and paleontological resources.

This alternative would also designate a new utility and 

transportation corridor, where new ROWs could be 

granted for the development of linear ROWs, such 

as highways, power transmission lines, water and gas 

lines, fiber-optic lines, and associated facilities, including access routes, and site-type ROWs. A ROW could 

also be granted in this corridor for the construction of 

Washington County’s proposed “northern transportation 

route” multi-lane roadway.

The designation of utility and transportation corridors, 

totaling 6,534 acres in size, under Alternative D would 

allow for development of new utilities and transportation systems, including Washington County’s proposed 

“northern transportation route”, under ROWs that could 

damage or destroy fossil resources of scientific interest within some or all of this acreage over the life of the 

RMP. Impacts to these resources would be lessened to 

the extent possible through inventories to identify high 

potential areas, project design modifications, and project-specific mitigation measures that would be implemented prior to project authorization. Potential impacts 

on paleontological resources and geologic resources that 

could result from Alternative D would be negative, minor 

to major in scope, and long term in the NCA.

4.27.2.7 Impacts from Public Education and 

Interpretation

Alternatives B, C, and D identify Public Education and 

Interpretation opportunities that would help to inform 

public land users about the geological values of the NCAs 

and stewardship of these values through appropriate 

public land etiquette. This type of educational outreach 

would be expected to lessen impacts on paleontological 

and outstanding geological resources, as public awareness and appreciation for the unique values of the NCA is 

increased. The management of paleontological resources 

or outstanding geologic features as interpretive sites may 

enhance appreciation and understanding of the fragile 

and finite nature of these resources; however, public 

visitation could also lead to impacts resulting from access 

and use, such as exacerbated erosion from vehicle travel, 

vandalism, and unauthorized collection.

4.27.2.8 Impacts from Management of Scientific 

Research

Under Alternatives B, C, and D, research opportunities 

would be pursued that further the scientific understanding of earth’s history, through the study of the geologic 

formations and paleontological resources of the NCA. 

Knowledge gained would help the BLM more effectively 

and efficiently manage these resources and provide opportunities for the public to benefit from this research.

4.27.3 Summary of Impacts from Alternatives

Table 4-18 summarizes potential impacts to geological and paleontological resources. The first column lists 

the resource or resource use that has an impact/effect 

on paleontology. The second column lists whether the 
756 Chapter 4 RCNCA RCNCA Chapter 4 757

CAVE AND KARST RESOURCES

action(s) is a beneficial effect or an adverse impact. The 

third column provides a brief description of the impact/

effect and the final column lists the intensity of the 

impact/effect.

4.27.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on paleontological resources and outstanding geological features 

is defined as the public lands of the NCA.

Impacts on paleontological resources and outstanding 

geologic features that have occurred in the past include 

destruction or damage of resources from vandalism, 

unauthorized collection, and the effects of natural 

processes, without the benefit of recovery, scientific 

study, or interpretation.

Increasing regional populations and demand for recreational uses of public lands in the NCA could increase 

the instances of unauthorized collection of fossils and 

vandalism; natural erosion would continue to impact 

some surface localities, potentially resulting in the unmitigated loss of scientific information. Public education 

and interpretation could help to reduce human-caused 

impacts, encouraging resource stewardship. The management alternatives proposed for the NCA include no present or future actions, or combination of actions, that are 

likely to result in cumulative impacts on paleontological 

resources and outstanding geological resources.

4.28 CAVE AND KARST RESOURCES

This section analyzes potential impacts to caves and 

karst landscapes and associated resources from proposed 

CAVE AND KARST RESOURCES

management actions described in Chapter 2. Existing 

conditions are described in Section 3.25. 

Impacts to cave and karst resources can result from 

surface activities and the direct and indirect impact of 

other management activities such as mining, grazing and 

excavation of other resources. Other indirect impacts to 

caves and karsts would be surface disturbing activities 

that have a negative impact to water quality that enters 

into a cave or karst terrain. The degradation of water 

quality could have a negative impact on the aquifer and 

cave dwelling biota and aquatics.

Many caves and associated resources receive negative impacts from recreational use. These impacts may be to the 

actual cave itself in the form of broken formations, compacted soils from trails, etc. The impacts can also be to 

the associated resources within the cave, such as cultural, 

paleontology, water and biological resources. However, 

there are caves that can easily sustain recreational use. 

These caves generally do not have an abundance of 

unique geologic formations (speleothems) or other resources that can be impacted by the visiting public. 

4.28.1 Methods of Analysis

Cave and Karst resource baseline information in Section 

3.25, Cave and Karst Resources, was reviewed for current 

understanding of known resources and to determine the 

condition of the resources. Also, all laws pertinent to determining effects on cave resources (e.g., FCRPA, ARPA) 

were considered and included in criteria for determining 

impacts. This known information was overlain with the 

actions found under each alternative in Chapter 2, and 

conclusions were drawn based on an understanding of 

how these types of actions may affect known and potentially discoverable resources.

4.28.1.1 Indicators

Indicators of beneficial effects and adverse impacts to 

cave and karst features can be defined by beneficial or 

negative changes to associated resources within the cave. 

The cave resources can be geologic, hydrologic, biological, paleontological, recreational, or cultural. Any change 

to these associated resources will be considered a change 

to the cave system as a whole.

Indicators of adverse impacts to cave and karst resources 

include the following:

▶ Extent of ground-surface disturbing activities and 

their potential for effecting known or unknown 

cave and karst resources;

▶ Decline in the numbers of any biological resource, 

such as bats or endemic invertebrates. Bats are extremely sensitive to visitor presence and may abandon a site if frequently disturbed. Cave endemics 

have adapted to a very unique micro ecosystem and 

are highly sensitive to outside influences such as the 

introduction of foreign substances (human waste, 

food crumbs, alteration of their environment, etc.);

▶ Vandalism to the cave that could include graffiti in 

the form of spray paint or any other written format 

or carving into the bedrock or intentional damaging 

of formations and other cave resources;

▶ Indications of overuse by recreation users, such as: 

trails, trash, human waste and impacts to any other 

resource due to visitation;

▶ Any decline in water quality due to visitor use or 

any management action that may adversely affect 

the water quality in the cave and/or surrounding 

karst landscape;

▶ Impact to, or theft of, cultural materials within the 

cave.

Indicators of beneficial impacts on cave and karst 

resources:

▶ Measures that restrict surface development or 

activities for the purpose of resource protection can 

provide direct and indirect protection of cave and 

karst resources from disturbance and from incompatible and unauthorized activities; and

▶ The extent to which an action preserves or improves 

the setting, where relevant, to certain cave and karst 

resources.

4.28.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ Caves will continue to be discovered in the Red 

Cliffs NCA. These caves will be inventoried to 

determine if they meet criteria to be listed as 

Significant under the FCRPA of 1988;

▶ Surveys required prior to surface disturbance in 

areas known or suspected to contain significant 

cave and karst resources would result in the identification and evaluation of previously undiscovered 

resources. In addition, continuing scientific research 

within the planning area will identify new resources. BLM would then manage these newly discovered 

resources accordingly.

Resource/Resource Use Impact/Effect Description Intensity

Geological/Paleontological

Effect

Paleontological surveys could identify more fossil localities that 

would be evaluated and management actions identified to protect 

significant values. 

Under Alternatives B and C, restrictions on the collection of 

common invertebrate fossils and petrified wood would conserve 

resource values.

Minor to 

Moderate

Cave and Karst

Effect

Inventories would identify previously undocumented caves and 

karsts. These would be evaluated and management actions identified to protect significant cave resources.Unknown

Fire and Fuels

Impact

Fire suppression may damage surface or shallow fossil resources.

Post-fire erosion could result in burial or removal of surface and 

shallow fossil resources.

Minor to 

Moderate

Effect Loss of vegetation to fires may disclose new paleontological sites, 

facilitating evaluation and appropriate management. Unknown

Travel Management

Effect

Limited area designation for OHVs would protect resources from 

disturbances and impacts associated with off-road motorized 

vehicle travel.

Minor to 

Moderate

Visual Resources

Effect

VRM Class I and II designation would protect paleontological resources from disturbances and impacts associated with authorized 

developments, such as utility transmission lines.

Minor

Recreation and Visitor 

Services Effect

Under Alternatives B, C, and D, more intensive management of 

recreation uses would lessen potential for surface disturbances 

that expose or damage surface and shallow fossil resources.

Moderate

Lands and Realty

Effect

Management as Avoidance or Exclusion to linear and site-type 

ROWs would protect surface and shallow fossil resources from 

disturbances related to developments, such as utility transmission 

lines.

Negligible to 

Moderate

Public Education and 

Outreach Effect

Under Alternatives B, C, and D, development of an Interpretive 

Master Plan could increase public understanding of paleo-environments and life forms and enhance stewardship of geological 

and fossil resources.

Minor to 

Moderate

Scientific Research

Effect

Alternatives B, C, and D pursue research opportunities that would 

improve understanding of the earth’s history through studying 

geologic formations and paleontological resources of the NCA.

Minor to 

Moderate

Table 4-18 Summary of Impacts to Geologic and Paleontological Resources
758 Chapter 4 RCNCA RCNCA Chapter 4 759

CAVE AND KARST RESOURCES

Implementing management actions for the following 

resources would have no adverse impacts on the cave 

and karst areas and are therefore not analyzed in this 

section: Air Quality, Soil Resources, Native Vegetation 

Communities and Fire and Fuels Management, Noxious 

Weeds and Invasive Species Management, Vegetation 

Resource Uses: Livestock Grazing, Vegetation Resource 

Uses: Plant Materials, Other Fish and Wildlife Species, 

Wilderness, ACECs, Visual Resource Management, 

Natural Soundscapes, Lands with Wilderness 

Characteristics, and Comprehensive Travel and 

Transportation Management.

4.28.2 Direct and Indirect Impacts

Many cave and karst features are evaluated based solely 

on their surface or initial values without in-depth studies, and therefore may not seem as though they qualify 

for significance status. However, most of these features 

contain significant resources that are not immediately 

recognizable and do not become apparent until additional studies are conducted. Adverse impacts, especially on 

unidentified resources, resulting from ongoing unevaluated or unsupervised activities, natural processes, and 

unanticipated events would continue.

Impacts to cave and karst resources can result from 

surface activities and the direct and indirect impact of 

other management activities such as mining, grazing and 

excavation of other resources. Other indirect impacts to 

caves and karsts would be surface disturbing activities 

that have a negative impact to water quality that enters 

into a cave or karst terrain. The degradation of water 

quality could have a negative impact on the aquifer and 

cave dwelling biota and aquatics.

Most caves and associated resources receive negative impacts from recreational use. These impacts may be to the 

actual cave itself in the form of broken formations, compacted soils from trails, etc. The impacts can also be to 

the associated resources within the cave, such as cultural, 

paleontology, water and biological resources. However, 

there are caves that can easily sustain recreational use. 

These caves generally do not have an abundance of 

unique geologic formations (speleothems) or other resources that can be impacted by the visiting public.

4.28.2.1 Impacts from Management of Water 

Resources

Water sources and shallow aquifers may be important to 

cave and karst features, and management actions to protect water resources could benefit specific caves and karst 

systems. Actions to protect watersheds and municipal 

source waters through surface use restrictions and erosion controls would provide incidental protections from 

effects due to surface disturbance and erosion.

All alternatives would implement actions to protect 

watersheds, reduce soil erosion and sedimentation into 

streams, and improve water quality in surface water 

sources. Similarly, all alternatives would seek to acquire 

non-federal lands that might benefit the conservation 

and protection of surface and groundwater resources. 

Alternatives B, C, and D would restrict surface disturbing 

activities within 500 feet, 1000 feet, and 250 feet, respectively, of riparian areas, to protect surface flows and native vegetation. Each of these management actions could 

benefit the protection of water quality and quantity that 

support cave and karst ecosystems and cave biota.

4.28.2.2 Impacts from Management of Geologic and 

Paleontological Resources

Alternative A proposes to apply the principles of conservation management to selected areas to maintain paleontological resources in the present condition, to authorize 

appropriate scientific studies of these resources, and to 

stabilize, maintain, and interpret selected sites for public 

education. It does not, however, provide specific management actions to implement these goals and objectives. 

Alternatives B, C, and D provide management direction 

for paleontological localities that include allocations 

of specific resources to Use Allocations and identifies 

how resources would be managed under each allocation. Proposed management of paleontological resources 

where they occur within or near cave and karst resources 

could help to prevent surface disturbances, erosion, 

inadvertent damage, and unauthorized collection of 

cave resources. The level of protection for cave and karst 

resources would be higher under these alternatives, when 

compared to Alternative A, because of the specificity of 

the proposed management actions. 

4.28.2.3 Impacts from Management of Cave and Karst 

Resources

Alternative A provides no specific management direction 

for cave resources and karst systems in the NCA. 

Alternatives B, C, and D identify management goals, 

objectives, and actions designed to conserve and protect 

these resources for the benefit of present and future generations. Under these alternatives, systematic inventories 

would be conducted in areas with high potential for new 

cave and karst resources; and newly-identified resources 

would be evaluated for significance under the FCRPA. 

CAVE AND KARST RESOURCES

Significant caves would be managed for Conservation for 

Future Use and Scientific Use. 

Alternatives B and D would also evaluate cave and karst 

resources for significance for Public Use. Resources that 

are identified for Public Use could be a greater risk of 

impacts related to recreational and public uses, which 

can negatively affect cave structures, biota, and microenvironments. Alternatives B and D would develop 

implementation-level cave management plans for significant cave and karst resources that are identified for 

Public Use, to develop management objectives and actions needed to protect cave resources from the potential 

impacts of public visitation and recreational uses. These 

alternatives could result in the greatest positive effects 

for all cave and karst areas that are open to public and 

recreational use.

Alternative B would authorize the development of on-site 

interpretation for significant cave and karst resources 

that are managed for Public Use. This positive effect 

would provide an excellent opportunity to educate the 

visiting public about cave and karst resources and the 

potential impact they may have on them. It may have a 

small negative impact to actual resources based on what 

type and where interpretation might be required.

Alternative C allows for off-site interpretation for significant cave and karst resources that are managed for 

Conservation for Future Use and Scientific Use. This 

too would have a moderate positive effect and lessen the 

potential for any negative impacts that might result from 

on-site interpretation of resources.

4.28.2.4 Impacts from Management of Special Status 

Species, including BLM Sensitive Species

Alternative A provides no specific management direction 

relating to cave and karst features that provide habitats for special status species, including BLM Sensitive 

Species. Under Alternatives B, C and D, caves would be 

managed to protect habitats, particularly the various 

types of habitats required by bats (e.g. forging, roosting, 

maternity sites and winter hibernacula) and reduce the 

spread of contagious diseases, like White Nose Syndrome 

(WNS). The use of herbicides, pesticides or poisons that 

are injurious or toxic to special status species and BLM 

Sensitive Species would not be authorized. The installation of bat friendly gates would be required for caves 

and karst features that require restriction or closures. The 

alternatives would not authorize activities that have the 

potential to disturb bats within .25 mile radius of maternity roost sites or winter hibernacula in any cave, karst 

feature or abandoned mine. These management actions 

would have an overall positive and long term beneficial 

effect on all species that occupy caves and karsts, helping 

to protect species from human-caused impacts.

4.28.2.5 Impacts from Management of Heritage 

Resources

Under all alternatives, heritage resources would be managed consistent with the legal and regulatory requirements of NHPA and ARPA. Where caves and karsts contain archaeological materials, deposits, and features, their 

management as NRHP-eligible heritage resources could 

provide a high level of protection for these resources. 

Alternative A proposes to employ reasonable measures to 

reduce human impacts, looting, and vandalism, to apply 

conservation management to selected areas to maintain 

resources in present condition for future study, to authorize research studies, and provide for the stabilization, 

maintenance, and interpretation of sites for public enjoyment. It does not, however, provides specific management actions to implement these goals and objectives. 

Under Alternatives B, C, and D, 100% of all NRHPeligible site types that include caves, rock shelters, 

and alcoves with archaeological deposits, features, 

and materials would be allocated to the following Use 

Allocations: Scientific Use, Conservation for Future Use 

and Traditional Use. Management actions could include 

the installation of physical barriers (e.g. fencing, plantings, gates) to protect these sites. Gates or other physical 

barriers would be designed to allow unimpeded ingress 

and egress by bats or other cave fauna and protect cave 

micro-environments.

4.28.2.6 Impacts from Management of Recreation 

and Visitor Services

Specific recreation activities, such as climbing or geocaching, could impact cave and karst resources, by damaging cave geological formations, compacting or disturbing soils and introducing litter into cave ecosystems and 

disturbing bats or other cave fauna.

Alternative A contains no specific management direction 

related to these recreational uses within or near cave and 

karst resources.

Under Alternatives B, C, and D, management goals, objectives, and proposed actions related to Recreation and 

Visitor Services would be expected to further the conservation and protection of cave and karst resources. These 

would develop implementation-level climbing management plans that identify authorized climbing areas, 
760 Chapter 4 RCNCA RCNCA Chapter 4 761

CAVE AND KARST RESOURCES

routes, and use restrictions developed to protect resource 

values, including caves and karsts.

All alternatives would allow for physical geocaching in 

the NCA, but Alternatives B, C, and D limit this activity 

to specific zones. Geocaching in caves could directly and 

indirectly impact cave formations and disturb or displace 

cave fauna. Alternatives B, C, and D would require that 

permission be granted by BLM prior to placement of 

physical geocaches in the authorized zones, which could 

minimize the potential for geocaches to be approved 

that would impact cave resources. However, if the cave 

location has not been included in BLM’s cave inventory 

database and permission is granted for a location that 

was not known to be a cave or karst, the resource impacts 

could be negligible to minor in the short and long term.

4.28.2.7 Impacts from Management of Lands and 

Realty

Under all alternatives, the Red Mountain and 

Cottonwood Canyon Wilderness areas would be managed as ROW Exclusion areas, protecting karst terrain 

and cave resources from new developments, such as 

power lines, communication sites, or roads that could 

impact these resources.

Alternative A would continue to manage approximately 

24,686 acres of the NCA, outside of the designated wilderness areas and utility corridors, as a ROW Avoidance 

area. ROW’s could be granted in the Avoidance area, if no 

other feasible alternative routes are available or designated corridors are not available. The use of BMPs and standard mitigation would help prevent or mitigate impacts 

on karst terrain or cave resources related to new ROW 

developments, but may not entirely eliminate all impacts 

in the designated corridors or elsewhere in the NCA.

Alternatives B would manage approximately 41,023 

acres of the NCA as a ROW Exclusion area, 3,652 acres 

as a ROW Avoidance area, and 183 acres within the two 

designated corridors, along State Route 18 and I-15. This 

alternative would provide greater protection to karst 

terrain or specific cave resources, when compared to 

Alternatives A and D, as new surface disturbances related 

to utility developments and access road construction 

would not be authorized in the Exclusion area, which 

comprises a majority of the land base of the NCA.

Alternative C would manage approximately 44,809 acres 

of the NCA as a ROW Exclusion area, protecting cave 

and karst resources as new ROWs would not be authorized within the NCA, unless mandated by federal laws 

or court decisions.

Alternative D would manage 38,325 acres of the NCA as 

a ROW Exclusion area, would retain two existing designated utility corridors, and designate a third corridor, 

comprised of 6,350 acres, where new utilities and the 

“northern transportation route” highway proposed by 

Washington County could be authorized (Map 2-46). 

Developments within this corridor could have a measurable and potentially negative impact on cave resources 

as these have been documented within the proposed 

boundaries of this new corridor. The construction of a 

new highway or water lines could alter drainage patterns 

that impact cave ecosystems or increase public access, resulting in vandalism to cave structures or fauna. Such impacts would be mitigated to the extent possible through 

project design and siting, making the intensity and severity of the impacts difficult to calculate at this time.

4.28.2.8 Impacts from Management to Public 

Education and Outreach

Alternatives B, C, and D identify Public Education and 

Interpretation opportunities that would help to inform 

public land users about the geological values of the NCAs 

and stewardship of these values through appropriate 

public land etiquette. Alternatives B and D would 

allow for the development of on-site interpretation for 

significant cave and karst resources that are managed 

for Public Use. This action could benefit the protection 

of cave and karst resources, by educating visitors about 

cave safety and appropriate etiquette to lessen humancaused impacts. Alternative C would authorize off-site 

interpretation for significant cave and karst resources 

that are managed for Conservation for Future Use and 

Scientific Use. This, too, would have a positive effect by 

increasing public awareness of and appreciation for cave 

and karst resources. 

4.28.2.9 Impacts from Management of Scientific 

Research

Under Alternatives B, C, and D, research opportunities would be pursued to conduct spring inventories 

and ground water modeling in the NCA. This research 

could assist with the identification of potential new karst 

areas and the development of appropriate management 

strategies of these areas. Knowledge gained would help 

the BLM more effectively and efficiently manage these 

resources and provide opportunities for the public to 

benefit from this research. Scientific research could be 

authorized under all four alternatives to increase the 

scientific knowledge related to cave and karst ecological systems. Alternatives B, C and D would authorize 

research in cave and karst resources that do not contain 

CAVE AND KARST RESOURCES

cultural or paleontological resources, through NCA 

Scientific Research Permits. Where cultural or paleontological resources are present, scientific research permits 

would be issued under the legal authorities of PARPA, 

ARPA, and FCRPA. Research studies would assist BLM 

to develop appropriate management strategies to conserve and protect cave and karst resources for present 

and future generations.

4.28.3 Summary of Impacts from Alternatives

Table 4-19 provides a summary of the impacts to cave 

and karst resources. The first column lists the resource 

or resource use that has an impact/effect. The second 

column lists whether the action(s) is a beneficial effect 

or an adverse impact. The third column provides a brief 

description of the impact/effect and the final column lists 

the intensity of the impact/effect.

4.28.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on cave 

and karst resources is limited to Federal and non-federal 

lands within the boundaries of the NCA. 

Regional population growth and greater demands for 

recreational use of public lands could increase the scope 

and intensity of impacts on cave and karst resources. As 

visitation to caves increases, the incidences of vandalism, 

damage to or removal of cave formations, disturbance 

or displacement of bats and other cave fauna would 

also be predicted to increase in frequency and severity. 

Other land uses and activities on non-federal lands could 

impair surface water runoff that may enter a cave or karst 

feature and impact microclimates and biota. Authorized 

land uses on public lands in the NCA would be expected 

to have negligible impacts on cave and karst resources, 

as a result of compliance with federal environmental and 

resource protection laws, land use restrictions, and the 

implementation of mitigation measures, such as project 

design and BMPs. Reasonably foreseeable future actions, 

or combinations of foreseeable actions, are not expected 

to cumulatively impact caves and karst resources. 

As new caves are found through systematic surface inventories for caves or through other means, they will all 

be thoroughly inventoried and evaluated for Significance 

under the FCRPA. There are six categories that may deem 

a cave eligible for Significance under the Act: Geologic, 

Hydrologic, Cultural, Biological, Recreational and 

Educational. Laws that pertain to other resources (ARPA, 

PRPA) that may be found in the cave will lend additional 

protection to the cave and its associated resources. It is 

through this inventory and evaluation process that a cave 

will be deemed adequate for recreational use and will be 

managed as such through a comprehensive cave management plan.

Resource / Resource Use Impact/Effect Description Intensity

Water Resources Effect Groundwater modeling may identify new karst terrain. Unknown

Geological/Paleontological Effect Paleontological surveys add protection for caves. Unknown

Cave and Karst Effect Cave management plans for recreational uses protect resource 

values.

Minor to 

Moderate

Native Vegetation Impact Alternatives A, B, and D authorize use of herbicides that could 

impact karst systems. Unknown

Noxious Weeds and 

Invasive Species Impact Alternatives. A, B, and D authorize use of herbicides that could impact karst systems. Unknown

Special Status Species Effect Alternatives B, C, and D would protect bat habitats in and around 

caves.

Moderate

Heritage Resources Effect Alternatives B, C, and D make use allocations that could protect 

cave resources with cultural materials.

Minor to 

Moderate

Recreation and Visitor 

Services Effect Alternatives B, C, and D develop management plans for climbing areas that could protect cave and karst resources. Moderate

Public Education and 

Outreach Effect

Alternatives B, C, and D would develop interpretation materials 

on and off-site to enhance public appreciation and stewardship of 

cave resources.

Minor to 

Moderate

Scientific Research Effect Alternatives B, C, and D would pursue opportunities for research 

studies that would improve management of cave resources.

Minor to 

Moderate

Table 4-19 Summary of Impacts to Cave and Karst Resources
762 Chapter 4 RCNCA RCNCA Chapter 4 763

SOIL RESOURCES

4.29 SOIL RESOURCES

This section discusses impacts on soils and water quality 

from proposed management actions of other resources 

and resource uses. Existing conditions concerning soils 

and water are described in Section 3.2.2.6, Soils and 

Water Quality.

4.29.1 Methods of Analysis

4.29.1.1 Indicators

Indicators of adverse impacts on soil resources include 

the following:

▶ Erosion rates above natural conditions, based on 

ecological site descriptions;

▶ Formation of terracettes or pedestals;

▶ Formation of rills or gullies;

▶ The inability to meet Utah Standards for Rangeland 

Health and Guidelines for Grazing Management;

▶ Declining soil surface health, with soils either unable to support vegetation and crust, or not meeting 

site potential, based on ecological site conditions 

(e.g., vegetation type, diversity, density, and vigor).

4.29.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ Soil resources would be managed to meet Standard 

1 of the Utah Standards for Rangeland Health;

▶ Soil resources would be managed to meet the goals 

of the Colorado River Basin Salinity Control Act

▶ Projects that help restore watersheds, desirable vegetation communities, or wildlife habitats (including 

surface disturbance associated with these efforts) 

would benefit soil and water resources over the long 

term;

▶ Soils would be managed to minimize erosion (relative to natural erosion rates) and maintain soil 

productivity; 

▶ The degree of impact attributed to any one disturbance or series of disturbances would be influenced 

by several factors, including proximity to drainages, 

proximity to existing groundwater wells, location 

within the watershed, time and degree of disturbance, reclamation potential of the affected area, 

existing vegetation, precipitation, and mitigating 

actions applied to the disturbance;

▶ Increased soil erosion above natural rates leads to 

decreases in water quality.

Implementing management for the following resources 

would have negligible or no impact on soil and are 

therefore not discussed in detail: Air Quality, Water 

Resources, Cave and Karst Resources, Vegetation 

Resource Uses: Plant Materials, Special Status Species, 

BLM Sensitive Species, Other Fish and Wildlife species, Heritage Resources, Wilderness, ACECs, Natural 

Soundscapes, Lands with Wilderness Characteristics, 

Comprehensive Travel and Transportation Management, 

and Public Education Outreach and Interpretation.

4.29.2 Direct and Indirect Impacts

Surface-disturbing activities can often result in removal of essential soil stabilizing agents such as vegetation, 

soil crusts, litter, and woody debris. These soil features 

function as living mulch by retaining soil moisture 

and discouraging annual weed growth. Loss of one or 

more of these agents increases potential erosion and 

sediment transport to water bodies, leading to water 

quality degradation. 

Direct and indirect adverse impacts on soil resources 

can be mitigated through restrictions on surface-disturbing activities. Impacts that cannot be avoided would 

be minimized by the application of BMPs or other mitigation measures.

Resource management actions that minimize, preclude, or 

stipulate surface-disturbing actions would help yield beneficial impacts by maintaining or improving soil conditions.

Soil resources, especially on steep slopes and in fragile 

or saline soils, are susceptible to adverse impacts from 

surface disturbance and compaction, which can lead to 

accelerated erosion, soil loss, and reduced productivity. 

Increased erosion would lead to increased sedimentation 

to area streams decreasing water quality and potentially 

contributing to morphologic instability. Likewise, soils 

on steep slopes or those soils identified as being "fragile" 

or saline can be more difficult to reclaim once disturbed. 

Increased compaction may also contribute to accelerated 

erosion and sedimentation.

4.29.2.1 Impacts from Management of Geologic and 

Paleontological Resources

As additional paleontological surveys and inventories are 

conducted throughout the NCA, it is possible that more 

significant paleontological resources will be discovered 

that warrant specimen collection through excavation.

SOIL RESOURCES

Under Alternatives B and D, the use of mechanized 

equipment for specimen recovery could be authorized. 

The use of equipment for excavation work could negatively impact biological soil crusts, remove vegetation, 

and leave soils in the project area susceptible to wind 

and water erosion. Impacts on soils would be minimized 

to the extent possible, through the research design and 

post-data recovery backfilling and stabilization. The area 

of disturbance associated with specimen recovery using 

mechanized equipment would likely be small and the 

impacts on soils negligible in the short and long term.

Alternative C would not allow the use of mechanized 

equipment for the excavation of paleontological resources. This alternative would reduce any possible negative 

impacts on soils by limiting the excavation methods to 

hand tools.

4.29.2.2 Impacts from Management of Soil Resources

Under all alternatives, management goals, objectives, and 

actions would strive to conserve and protect soils and 

implement actions to achieve the goals of the Colorado 

River Basin Salinity Control Act. Post-fire ES&R actions 

would be designed to minimize soil erosion and facilitate 

re-vegetation of desired native plant communities that 

would stabilize and protect soils.

Alternatives B, C, and D would utilize existing two-track 

roads and disturbed areas as the locations for non-motorized trails, trailheads and other facilities, to minimize 

new disturbances to soils and vegetation. Where new 

trails or other facilities are proposed, locations would 

be selected where soils are suitable for these developments, such as areas that are less prone to wind and water 

erosion. Alternative A contains no similar management 

decisions relating to the location of new recreation developments, and would, therefore, not protect soils to the 

same degree as the three action alternatives.

4.29.2.3 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Alternative A would authorize vegetation treatments 

to achieve multiple management objectives, including 

conversions of vegetation types (e.g., sagebrush steppe to 

grasslands) to benefit wildlife, or other management goals. 

While the use of native plant species for restoration and rehabilitation would be emphasized, non-native species could 

be used when native species are not available or economically feasible. No specific treatment methods were precluded from use under this alternative. Under Alternatives 

B, C, and D, treatments would only be authorized for 

re-vegetation of disturbed and fire-damaged lands and 

riparian areas, not for conversions of vegetation types. 

Alternatives A and D would authorize mechanical methods, like chaining and harrowing, that could create new and 

larger-scale surface disturbances. The use of mechanized 

equipment could result in short-term and negative impacts 

on biological soil crusts and soil horizons, disturbing soils 

and leaving them susceptible to wind and water erosion 

until vegetative cover has been re-established. Alternatives 

A, B, and C would authorize non-invasive and minimally 

invasive methods to implement re-vegetation projects, to 

lessen the amount of new surface disturbance and potential 

soil erosion that could result from these projects.

The three action alternatives emphasize the use of native plant species, particularly “early colonizing” species 

that could quickly re-establish vegetation cover to lessen 

wind and water erosion of soils. They also include more 

restrictive criteria than Alternative A related to the use of 

non-native species. Alternative C would not authorize the 

use of non-native species for vegetation rehabilitation in 

the NCA.

Under Alternative A, fire management actions would 

include full suppression, mechanical non-fire fuel treatments and prescribed fire. Under Alternatives B, C, and 

D, prescribed fire would not be authorized in any of the 

ecological system of the NCA for hazard fuel reduction or vegetative type conversion, as these are not fire 

adapted communities in which fire has historically played 

an important role in the ecosystem. Alternative C would 

be expected to cause fewer impacts on soil resources 

when compared to other alternatives. Suppression of 

any wildland fire or prescribed burn could have adverse 

impacts through the removal or loss of vegetation, which 

would allow additional erosion and soils compaction from 

equipment and personnel. However, due to the potential 

variability of fire starts and behavior, it is not possible to 

quantify potential impacts.

Landscape-level fuel breaks are proposed in the NCA in 

Alternatives B, C, and D. These fuel breaks would incorporate topographic features, water courses, major ephemeral drainages, road networks, and utility corridors, to 

minimize new surface disturbances and the loss of native 

vegetation. Fuel breaks would require intensive manipulation of vegetation and would have a direct impact on soil 

resources. Impacts would occur in all alternatives, with 

varying levels of intensity. Impacts in Alternative D could 

range from moderate to major, depending on the scale 

of the project and the tools selected. Alternatives B or C 

could range from minor to moderate for the same reasons.
764 Chapter 4 RCNCA RCNCA Chapter 4 765

SOIL RESOURCES

4.29.2.4 Impacts from Management of Noxious 

Weeds and Invasive Species 

Under all alternatives Integrated Weed Management 

would be employed to control, suppress and eradicate, 

where possible, noxious weeds and invasive species to support healthy plant communities across the planning area.

Alternative D includes any combination of biological 

controls, flaming, herbicides, mechanical methods, and 

hand removal. Alternatives A and B have a similar suite 

of options, but do not include flaming. Alternative C is 

the most conservative, with hand removal identified as 

the only treatment method that would be employed. 

Noxious weed management would require intensive manipulation of vegetation and would have a direct impact 

on soils. Impacts could occur in all alternatives, with 

varying levels of intensity. Impacts in Alternative D could 

range from moderate to major depending on the scale 

of the project and the tools selected. Alternative B could 

range from minor to moderate for the same reasons. 

Over the long term, Alternatives A, B, and D could have 

positive effects on soil character. Given the potential variability of noxious weed control projects, it is not possible 

to quantify the intensity of the beneficial effects.

By contrast, the proposed hand tools only method identified under Alternative C would limit the aggressiveness 

with which the BLM could treat weed infestations, which 

could result in the expansion of noxious weeds and the 

potential replacement of desirable/functional vegetation 

communities. The loss of desirable vegetation communities could result in the loss of soil stabilization and 

increased erosion potential. At the same time, limiting weed treatments would be protective of soil health 

in other ways through limiting the application of toxic 

herbicides, which can kill much of the soil food web in 

treatment areas.

4.29.2.5 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing 

Under all alternatives, a majority of the land base 

of the NCA would continue to be unavailable for 

livestock grazing. However, grazing would continue to 

be authorized in the Veyo and Sand Wash Allotments, 

including those areas of the allotments that overlap the 

NCA boundaries. As cattle do not use those areas of the 

allotments, there would continue to be no impacts on 

soils related to grazing uses.

Alternatives B, C, and D would make the Diamond 

Valley Allotment (1,780 acres) unavailable for grazing, 

both inside and outside of the NCA boundaries. As this 

allotment has not been actively grazed for more than 20 

years, closure of this allotment would have no immediate 

beneficial effect on soil resources. In the long term, this 

action would protect soils and native vegetation from all 

potential impacts related to livestock grazing, including 

soil compaction, the loss of biological soil crusts, and 

damage to native vegetation. This action would protect 

soils and native vegetation from any potential impacts 

related to future livestock grazing, including soil compaction, the loss of biological soil crusts, and damage to 

native vegetation.

4.29.2.6 Impacts from Management of Visual 

Resources

Managing for VRM Classes I and II would exclude project authorizations that impact the scenic qualities of the 

NCA, such as overhead power transmission lines. Such 

restrictions would subject fewer areas to anthropogenic 

sources of soil erosion and vegetation loss. On the other 

hand, managing for VRM Class I may also limit flexibility for vegetation treatments, resulting in a potential 

decline in soil health (and, indirectly, water quality) over 

the long term.

Under Alternative C, there would be few impacts to soil 

resources. Designating all acres outside of wilderness as 

VRM Class II with an overlapping designation of ROW 

Exclusion, would protect all components of the VRI. 

The beneficial effects to soils would be both direct and 

indirect by prohibiting future utility, road, and highway 

development. 

Alternative B would be less protective than Alternative 

C. The two alternatives are similar, but have one major 

difference. Where Alternative C would manage the NCA 

only under VRM Classes I and II, Alternative B has 3,652 

acres of VRM Class III and 184 acres of VRM Class IV. 

These acres encompass the existing utility developments 

that parallel Cottonwood Road. In this alternative, the 

VRM Class III acres would be designated as a ROW 

Avoidance area. The Class III designation could allow for 

future utility development within the Avoidance area if 

no other viable options were available.

For Alternative D, there could be moderate to major impacts to soil resources, depending on the type and scope 

of proposed developments under ROWs.

4.29.2.7 Impacts from Management of Recreation 

and Visitor Services

Alternatives B, C and D would revoke the existing ERMA 

and replace it with the Red Cliffs SRMA, providing 

SOIL RESOURCES

long-term management direction consistent with current 

management practices and national BLM policy.

Developing implementation-level plans in Alternatives 

B, C, and D to manage specific activities would benefit 

recreation opportunities in the long-term by gathering site-specific public input and identifying specific 

needs and opportunities. This action would better assist 

in management of activities that would have a negative 

impact to soils.

Under Alternative A, Sand Cove Primitive Camping Area 

would continue to be managed as a primitive and permitted camping area, with no designated campsites and 

no developed facilities, visitor amenities, or designated 

campsites. Due to the unmanaged camping and parking 

in the area, little vegetation remains, and trash and human waste are evident.

Under Alternative B, primitive camping facilities would 

be developed and vehicle access to the camping area 

restricted. Group sizes would be limited to 20 campers. 

Compared to Alternative A, these actions would benefit soils and native vegetation, reducing or eliminating 

the impacts created by uncontrolled vehicle travel and 

dispersed camping. Vegetative reclamation of this area 

would have a direct positive effect to soils by preventing 

compaction and soil erosion. Impacts on soils related to 

human wastes could continue, as no restroom facilities 

would be provided.

Alternative C would close the Sand Cove Primitive 

Camping Area to overnight camping, but continue to 

provide for day use of the area. The impacts on soils and 

native vegetation would be lessened under this alternative, 

as day users would create fewer new disturbances when 

compared to overnight camping, typically by large groups.

Under Alternative D, camping facilities would be developed at Sand Cove Primitive Camping Area and would 

include metal fire rings, vault toilets, vehicle access 

improvements, and a kiosk for interpretive displays. The 

group size limit would allow as many as 40 campers. Soils 

and vegetation would be disturbed in the short term, 

during the construction of these facilities; however, there 

would be positive effects in the long term, as impacts 

associated with camping would be minimized. New 

disturbances to soils and vegetation would be avoided, as 

camping would be limited to designated areas and vault 

toilets would reduce or eliminate human waste being 

deposited directly into the soil.

4.29.2.8 Impacts from Management of Lands and 

Realty

Under all alternatives, 19,989 acres in two designated 

wilderness areas would continue to be managed as an 

Exclusion area for the siting of new site-type and linear 

ROWs.

Alternative A would continue to manage approximately 

24,686 acres of the NCA, outside of the designated wilderness areas and utility corridors, as a ROW Avoidance area. 

ROWs could be granted in the Avoidance area if no other 

feasible alternative routes are available or designated corridors are not available. Existing ROWs for utilities, including water lines, power lines, and associated facilities would 

remain valid existing rights and could be maintained 

under the terms and conditions of the ROW grant. This 

alternative would continue to manage designated utility 

corridors along State Route 18 and I-15 through the NCA 

as the potential location for linear ROWs and encourage 

the use of these corridors.

This alternative could result in impacts on soils, including 

compaction, damage to cryptobiotic crusts, and erosion 

related to new developments under ROWs in the designated corridors and potentially in the ROW Avoidance area 

if specific criteria are met. The use of BMPs and standard 

mitigation would help prevent or mitigate impacts, but 

could not entirely eliminate soil impacts in the designated 

corridors or elsewhere in the NCA.

Alternative B would manage approximately 41,023 acres 

of the NCA as a ROW Exclusion area, 3,652 acres as 

a ROW Avoidance area, and 183 acres within the two 

designated corridors along State Route 18 and I-15. This 

alternative would provide greater protection to soils, 

when compared to Alternatives A and D, as new surface disturbances related to utilities developments and 

access road construction would not be authorized in the 

Exclusion area which comprises a majority of the land 

base of the NCA.

Alternative B would carry forward the designated utility 

corridors along State Route 18 and I-15. The continued 

management of designated corridors would be expected 

to result in soil loss, compaction, and erosion related to 

the potential construction and maintenance of linear 

ROWs in the corridors. The use of BMPs and standard 

mitigation would help prevent or mitigate impacts, but 

could not entirely eliminate soil loss and compaction 

related to construction and maintenance of facilities in 

the designated corridors.
766 Chapter 4 RCNCA RCNCA Chapter 4 767

NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

Alternative C would manage approximately 44,809 acres 

of the NCA as a ROW Exclusion area, protecting soil 

resources, as new ROWs would not be authorized within 

the NCA unless mandated by federal laws or court 

decisions. It would retain the existing designated utility corridor along State Route 18 (50 acres) but revoke 

the designated utility corridor along I-15 (133 acres), 

through the NCA, subject to any valid existing rights. 

Revocation of this corridor would help to protect fragile 

soils in this area of the NCA, as new linear ROWs for 

utilities or transportation purposes would not be granted. 

Development-related surface disturbances that could 

accelerate erosion for the gypsum rich soils in that area 

would not occur, minimizing the potential for the introduction of saline soils into the Virgin River watershed, 

through Quail or Leeds Creeks.

Alternative D would manage 38,325 acres of the NCA 

as a ROW Exclusion area, but would retain the existing 

designated utility corridors along State Route 18 and 

I-15 (183 acres) and would designate a new utility and 

transportation corridor, totaling 6,350 acres in size, in 

which new utilities and the new multi-lane roadway proposed by Washington County (the “northern transportation route”) could be constructed. Surface disturbances 

during utilities development in the I-15 corridor could 

increase fragile soil erosion and the potential for impacts 

on surface water in Quail or Leeds Creeks. Construction 

of a multi-lane highway in the new corridor could alter 

drainage patterns directly or indirectly impacting surface 

water sources located downstream on state and private 

lands. This alternative would make approximately 6,534 

acres of the NCA available for new ROW developments, 

providing less protection for soil and water resources 

than the three other alternatives. The use of BMPs and 

standard mitigation measures would help but could not 

entirely eliminate soil loss and compaction related to 

construction and maintenance of facilities in the designated corridors.

4.29.2.9 Impacts from Management of Scientific 

Research

Alternatives B, C, and D identify research opportunities 

that would improve the management of soil resources, 

including detailed soil surveys and ecological site inventories in the NCA. Potential studies relating to soil crust 

function and regeneration in disturbed and fire-altered 

desert ecosystems could help to develop cost-effective 

methods to restore biological soil crusts. Functioning soil 

crusts would help to stabilize soils, restore soil productivity, and facilitate re-vegetation of damaged lands.

4.29.3 Summary of Impacts from Alternatives

Table 4-20 provides a summary of the impacts to soil 

resources. The first column lists the resource or resource 

use that has an impact/effect on soil resources. The 

second column lists whether the action(s) is a beneficial 

effect or an adverse impact. The third column provides 

a brief description of the impact/effect and the final column lists the intensity of the impact/effect.

4.29.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on soil 

is comprised of the public lands of the NCA. Past and 

present actions within the CIAA that have affected soil 

resources include wildfires, noxious weeds and invasive 

species proliferation, and livestock grazing. Management 

proposed under all alternatives for the NCA would 

conserve and protect soil resources, minimizing impacts 

through the types of land uses that would be authorized. 

Project authorizations would require the implementation of BMPs and other mitigation measures that conserve and protect soils, soil crusts, and native vegetation. 

Management actions would help to ensure that erosion 

of fragile and saline soils does not result from land uses 

or authorized activities on public lands and that cryptobiotic soils are protected, reducing the potential for 

cumulative impacts to result from implementation of any 

of the alternatives.

4.30 NATIVE VEGETATION COMMUNITIES AND 

FIRE AND FUELS MANAGEMENT

4.30.1 Methods of Analysis

This analysis is organized by resources and resource uses 

that could potentially affect native vegetation, particularly fire and fuels management. Under each subheading, a 

general description of the nature and type of impacts on 

all vegetation under all alternatives is presented, with additional analysis for each vegetation community or habitat as appropriate and applicable. Impacts are analyzed 

using the indicators presented below; if no impact on an 

indicator is anticipated, the indicator is not mentioned 

in the analysis. An analysis of the impacts on habitats 

and vegetation for each alternative follows the nature and 

type of impacts discussion.

4.30.1.1 Indicators

Indicators of adverse impacts on native vegetation include the following:

▶ Likelihood for impacts on native vegetation causing 

loss of ecological function or departure from the 

NRV;

NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

▶ Introduction or spread of noxious weeds and invasive species;

▶ Declining numbers and/or varieties of pollinators; 

▶ Conversion of desert shrubland communities to an 

earlier seral stage or invasive grassland; 

▶ Reduced plant vigor or productivity. 

Indicators of beneficial effects on native vegetation include the following:

▶ Control or eradication of noxious weeds and invasive species; 

▶ Increased plant vigor or productivity.

Indicators of adverse impacts on fire and fuels management include the following:

▶ Alteration of vegetative cover (standing and nonstanding) that results in a substantial upward shift 

in the FRCCs of the planning area (away from 

NRV);

▶ A substantial increase in the risk of wildland fire 

ignitions; and

▶ Management actions that substantially inhibit a 

response to wildland fire or appropriate treatments 

to prevent wildland fire.

Indicators of beneficial impacts on fire and fuels management include the following:

▶ Alteration of vegetative cover that results in a substantial downward shift in the FRCCs of the planning area (towards NRV).

4.30.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions are designed to conserve, protect, and enhance the resources of the NCA;

▶ Climatic fluctuation would continue to influence the health and productivity of habitats and 

vegetation;

▶ Short-term effects would occur over a time frame of 

two years or less and long-term effects would occur 

over longer than two years;

▶ Management would work toward preserving 

remaining areas of unburned, native vegetation, 

Resource/Resource Use Impact/Effect Description Intensity

Water Resources Effect Under all alternatives, management decisions to protect surface 

water sources would benefit soils, by limiting surface disturbances.

Minor to 

Moderate

Geological/Paleontological Impact Alternative D would authorize mechanical excavations of paleontological resources that could disturb soils. Unknown

Native Vegetation

Impact

Treatment methods proposed under Alternatives A, B, and D 

could create short-term soil disturbances and increase potential 

for soil erosion.

Minor to 

Moderate

Effect

Alternative C proposes non-invasive and minimally invasive 

methods for treatments and restoration, providing the highest 

level of protection for soils.

Moderate to 

Major

Noxious Weeds and 

Invasive Species Impact

Treatment methods proposed under all alternatives could disturb 

soils and remove vegetative cover, increasing potential for soil erosion in the short term.

Negligible to 

Minor

Special Status Species Effect Under all alternatives, management to conserve, protect, and 

restore habitats for special status species would benefit soils. Moderate

Recreation and Visitor 

Services Effect All alternatives propose restrictions on recreation uses and SRP authorizations that can disturb soils.

Negligible to 

Moderate

Travel Management

Effect

All alternatives manage motorized OHV use as Limited to 

Designated Roads and Trails, protecting soils from impacts related 

to cross-country travel.

Moderate

Lands and Realty

Impact

Alternative A proposes to manage NCA as an Avoidance area that 

could allow for new linear and site-type ROWs that would impact 

soils. Alternative D proposes designation of a new 6, 534 acre 

utility corridor where development of new linear ROWs could 

impact soils.

Unknown to 

Major

Effect

Alternatives B and C propose to manage the NCA as an Exclusion 

area for new linear ROWs, protecting soils from development 

impacts.

Minor to 

Moderate

Table 4-20 Summary of Impacts to Soil Resources
768 Chapter 4 RCNCA RCNCA Chapter 4 769

NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

especially those areas that are critical habitat for 

Mojave desert tortoise;

▶ The degree of impact attributed to any one disturbance or series of disturbances would be influenced 

by several factors, including location; the type, 

time, and degree of disturbance; existing vegetation; 

precipitation; and mitigating actions applied to the 

disturbance;

▶ Noxious weeds and invasive weeds would continue 

to be introduced and spread as a result of ongoing 

vehicle traffic, recreational activities, wildlife, and 

surface-disturbances;

▶ The natural fire regime of the Mojave Desert has 

been altered; Mojave Desert native vegetation communities have long fire-return intervals and fuel 

small, low-intensity fires that generally are unable to 

spread to a significant size without the presence of 

invasive grasses;

▶ The presence of non-native, invasive vegetation species increases fire frequency, size and intensity and 

shortens the fire-return interval;

▶ A direct relationship exists between fuel loading 

and potential fire intensity, severity, size, and fire 

suppression costs.

Implementing management actions for the following resources would have no or negligible impact 

on vegetation and are, therefore, not discussed in 

detail: Air Quality, Water Resources, Geologic and 

Paleontological Resources, Cave and Karst Resources, 

Soil Resources, Vegetation Resource Uses: Livestock 

Grazing, Vegetation Resource Uses: Plant Materials, 

Special Status Species, BLM Sensitive Species, Other 

Fish and Wildlife Species, Heritage Resources, 

Wilderness, ACECs, Natural Soundscapes, Lands with 

Wilderness Characteristics, and Public Education and 

Interpretation.

4.30.2 Direct and Indirect Impacts

Under all alternatives, the Native Vegetation 

Communities and Fire and Fuels Management goals are 

to protect, conserve, and enhance native vegetation communities and wildlife habitat. By protecting, conserving, 

and enhancing these habitats, the BLM will preserve 

proper functioning condition of vegetation communities, 

soils, and watersheds.

Minimizing the loss of unburned and once burned native vegetation would be strongly beneficial to maintain 

ecosystem and watershed functions, protecting soils, and 

providing habitats that meet the needs of special status 

species and other wildlife.

4.30.2.1 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Alternative A ensures that ecological systems meet or 

exceed management objectives in the Utah Standards 

for Rangeland Health (Appendix D). This could protect, 

maintain, or enhance vegetation, biophysical settings, 

and ecosystems by preventing over use or over utilization 

of forage by livestock species. 

Alternative A includes preparation of site specific plans 

to identify desired plant communities, establishing 

specific management objectives, and recommending 

practices to be employed to achieve desired results. This 

could lead to specialized management for those plant 

communities, possibly improving vegetation and ecosystem health.

All alternatives provide for the use of native plant species for restoration and rehabilitation. This would support biophysical settings and native habitat by supporting the health and vitality of these systems, and could 

provide additional seed sources when plant species 

establish and mature. 

Alternatives A, B, and D would allow for some use of 

non-native species for vegetation restoration. Non-native 

species could more quickly re-establish soil cover, helping to stabilize soils and prevent erosion in the short 

term. In the long term, non-native species might increase 

soil moisture retention, facilitating the re-establishment 

of native species. However, non-native species could also 

persist and spread, altering native ecosystems, reducing 

the quality of biophysical settings, and not facilitate the 

restoration of native species.

Alternative C would only authorize the use of native, locally derived seeds for restoration, potentially producing 

less biomass than Alternatives A, B, and D, but eliminating the risks associated with the use of non-native 

species. This alternative would help to ensure that native 

species that have been scientifically demonstrated to 

meet the unique nutritional needs of desert tortoise are 

available to assist with recovery efforts for this threatened species.

Alternatives B, C, and D propose methods to increase 

the success of restoration efforts, which could improve 

vegetation recovery, density, and health in the NCA. If 

biological soil crusts were inoculated and restored, vegetation could more quickly re-establish within damaged 

areas and invasive, non-native plant species would be less 

NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

likely to spread into these areas due to the protective nature of the soil crusts. Restoration in the arid ecosystems, 

including soil crusts, can take 50 to 100 years or more 

under natural conditions; use of methods to support 

and enhance restoration could help vegetation establish 

more quickly and prevent mortality during harsh natural 

conditions, such as drought. These actions would have 

beneficial effects.

The use of early colonizing (early successional) native 

or native cultivar, annual and perennial species as nurse 

plants would support the regrowth of native vegetation, especially for establishment of plants during early 

growth stages, and could support the continued restoration of biophysical settings. Non-invasive and minimally 

invasive seeding and planting methods could lead to 

less surface disturbance, damage, disturbance or loss of 

vegetation, soil loss, and erosion. Non-invasive seeding methods could prevent or reduce the introduction 

of invasive, non-native plant species from vehicles or 

humans. Use of containerized plants would add larger 

plants into the ecosystem, which could allow those plants 

to establish into the re-vegetation area more rapidly than 

new seedlings.

Non-invasive and minimally invasive methods to protect 

seeds from being consumed by wildlife could prevent 

or reduce surface disturbance, reducing soil loss and 

erosion and could ensure that seeds remain in the soil to 

germinate and restore vegetation, biophysical settings, 

and ecosystems.

Under all alternatives, managing riparian areas to meet 

the Utah Standards of Rangeland Health, applying appropriate wildfire suppression strategies, use of post-fire 

ES&R actions, and application of BMPs would protect 

riparian resources and prevent future damage.

Fire and fuels management could cause short-or longterm changes to the species composition and conditions 

of habitats and vegetation communities. Fuels treatments 

and fire suppression activities would reduce the likelihood for a large-acreage fire and subsequent complete 

conversion to weeds, which would change the disturbance regime by shortening the fire return interval.

Under Alternative A, fire management actions would 

include full suppression, but with some options for 

minimum impact tactics in special status species’ habitats. These options could be less successful at protecting 

unburned vegetation, given the rapid spread of fires that 

is possible when fueled by invasive brome grasses. The 

use of backburning as part of suppression tactics could 

continue to be authorized, damaging or destroying native 

vegetation in an effort to reduce fire size and spread. 

The rapid employment and appropriate suppression 

responses to minimize fire size and duration in the NCA 

is common to Alternatives B, C, and D. Suppression of 

any wildland fire could have adverse impacts through 

the removal or loss of vegetation. The use of backburning would be evaluated under Alternatives B and D, and 

minimized to the extent possible. Alternative C would 

not authorize the use of backburning as a suppression 

tool, except when deemed essential to protect human life, 

property and the effective control of the fire. 

Alternative A still includes a small role for the potential 

use of prescribed fire or wildfire use to achieve management objectives. It is unlikely that these methods would 

be employed, given the extent of damage and loss to native vegetation communities in the NCA since the SGFO 

RMP was approved.

Alternatives B, C, and D would not authorize large-scale 

prescriptive fires and fire use. Immediate and appropriate 

full suppression and prohibitions on the use of fire as a 

management tool would help to protect unburned native 

vegetation communities from fire-related impacts.

Alternatives B, C, and D propose fuel breaks and hazard 

fuel reduction projects that would help to limit the accidental ignition and spread of wildfires, protecting native 

vegetation communities and critical habitats. The use 

of existing features (roads, drainages, utility corridors) 

would ensure that the fuel breaks minimize the amount 

of new disturbance and vegetation damage.

Alternatives B and D proposes the widest array of tools 

that could be used to create fuel breaks, including biological, herbicidal, hand removal, targeted grazing, small 

scale weed flaming, and low impact mechanical methods, 

as the means to create the fuel breaks, without causing 

unacceptable levels of damage to native vegetation and 

species habitats. Alternative C would not authorize herbicide use to develop fire breaks and fuel reduction projects, eliminating the potential for impacts related to the 

use of chemical treatments. 

All alternatives provide management direction related to 

the methods that can be employed for ES&R actions to 

restore fire-damaged areas. Alternative A would authorize the use of invasive mechanical methods to protect 

seed, through chaining or harrowing. 

Alternatives B, C, and D provide a range of potential 

tools, but emphasize use of the least invasive methods 

to accomplish the goals. Alternatives B and D would 
770 Chapter 4 RCNCA RCNCA Chapter 4 771

NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

provide a range of management options for seed protection, with Alternative D allowing for more invasive methods of seed protection, such as chaining or harrowing, to 

be used. The use of mechanical methods could destroy 

biological soil crusts, increase surface disturbance that 

could lead to brome grass infestations and future fires. 

Alternative C would only authorize the use of hand tools 

for re-vegetation projects and could also reduce the 

chance that re-seeding activities could inadvertently lead 

to increased levels of invasive species.

4.30.2.2 Impacts from Management of Noxious 

Weeds and Invasive Species

Weeds and invasive species alter the ecological characteristics of native vegetation communities and the quality 

of wildlife habitats. Weed control would continue to be 

implemented under all alternatives, using an Integrated 

Weed Management approach and relevant standard 

operating procedures and mitigation measures presented 

in the Final Vegetation Treatments Using Herbicides on 

BLM Lands in 17 Western States PEIS (BLM 2007). With 

proper implementation, weed treatment methods under 

all alternatives would eliminate or reduce noxious weeds 

and invasive species. 

Alternatives B, C, and D identify a slightly variable range 

of tools to control weeds and invasive species, including 

the potential use of biological controls, under project-specific plans. Biological controls for invasive annual brome 

grasses are currently in the experimental stage and may 

never be applicable on a broad scale, even over the life of 

the RMP. Alternative C would not authorize targeted grazing limiting an option to potentially control invasive species, but one that could potentially damage tortoise dens 

and cause juvenile tortoise injuries or mortalities. 

Alternatives A, B, and D would also allow chemical 

control of invasive species in unburned rangeland. These 

could damage desired vegetation due over-spray, improper herbicide selection or dosage, or improper timing 

of application. Alternatively, proper chemical control 

could reduce non-native plants while allowing natives to 

recover, if the chemicals are selected and used correctly. 

These would be beneficial effects, although there would 

be a slight risk of adverse impacts associated with the use 

of herbicide.

Alternatives B and D authorize the use of targeted grazing to manage invasive plants and to create fuel breaks. 

Targeted grazing is still somewhat experimental in desert 

tortoise habitats, based on concerns about trampling of 

dens and burrows, damage to other vegetation, and the 

potential spread of noxious weeds and invasive species 

by grazing animals. The long-term effects of use of this 

management tool are difficult to predict at this time. 

Positive effects could include the removal of large areas 

of non-native annual grasses cost-effectively, creating fire 

breaks that would reduce the chance of accidental ignition and give firefighters a greater ability to contain or 

control fires. 

4.30.2.3 Impacts from Management of Visual 

Resources

In general, VRM Classes I and II would restrict surfacedisturbing activities and prevent substantial changes to 

native vegetation. However, VRM Class I restrictions 

could also constrain vegetation management so that 

certain native vegetation objectives may be difficult to 

achieve. Areas managed as VRM Class III would allow 

for more changes to the existing character of the landscape that could damage or destroy additional acres of 

native vegetation.

Alternative A would retain VRM Class III for 24,870 

acres of the NCA and manage the 19,989 acres of designated wilderness in the Cottonwood Canyon and Red 

Mountain Wilderness areas as VRM Class I.

Alternative B would manage the 19,989 acres of designated wilderness in the Cottonwood Canyon and Red 

Mountain Wilderness areas as VRM Class I; 21, 034 

acres as Class II, and retain VRM Class III designation 

for 3,652 acres, and manage 184 acres as VRM Class IV. 

Native vegetation would be protected on a substantially 

larger number of acres of the NCA, based on the requirements under the VRM classes to maintain the scenic 

qualities of the landscape.

Alternative C would manage 21,574 acres, including the 

two designated wilderness areas, as VRM Class I and 

the remainder of the NCA (23,285 acres) as VRM Class 

II. This alternative would provide the highest level of 

protection for native vegetation communities, as all NCA 

acres would be managed to maintain the existing visual 

qualities of the landscape and preclude disturbances or 

changes that would impair those qualities. 

Alternative D would manage the 19,989 acres of designated wilderness in the Cottonwood Canyon and Red 

Mountain Wilderness areas as VRM Class I; 18,336 

acres as VRM Class II, and 6,534 acres as VRM Class IV. 

This VRM class would allow the greatest changes to the 

existing landscape character and the highest potential for 

adverse impacts on soils and native vegetation communities, related to developments in the designated utility and 

NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

transportation corridor that is proposed to accommodate 

new utilities and Washington County’s “northern transportation route” multi-lane roadway. 

4.30.2.4 Impacts from Management of Recreation 

and Visitor Services

Substantial analysis and planning has been used to determine the locations and types of recreation that would be 

appropriate to fulfill the resource conservation purpose 

of the NCA. Unmanaged recreation and poorly designed 

facilities will generally result in soil, water and vegetation 

damage or loss and the spread of noxious weeds and invasive species. Impacts are more likely to occur in easily 

accessible areas where visitation would be highest. 

Alternative A would continue to manage the NCA within 

the Red Mountain/Santa Clara SRMA and the SGFO 

ERMA for dispersed recreation uses that generally do not 

include developments or facilities. The management of 

recreational activities and public uses would continue, as 

authorized through the implementation-level PUP. Nonmotorized recreational uses in the Lowland Zone would 

continue to be on designated trails; off-trail travel would 

be authorized in the Upland Zone. Motorized vehicle 

travel would be Limited to Designated Roads, including 

the Babylon Road. Dispersed camping would continue 

to be limited to the two designated wilderness areas, the 

Upland Zone, and Sand Cove Primitive Camping Area. 

Alternatives B, C, and D would not carry forward the 

existing SRMA and ERMA designations, but would establish the Red Cliffs SRMA, to provide for high-quality 

visitor experiences. Management of the SRMA would 

include rules and guidelines to limit or control activities 

that could impact other NCA resource values through 

management tools such as designated campsites or group 

size limits. A Recreation Area Management Plan would 

be completed to identify authorized recreation and public uses for the SRMA; management decisions from the 

PUP for public lands would not be carried forward under 

these alternatives. 

Alternatives B, C, and D propose the development of a 

professionally-designed non-motorized trail system in 

the NCA, to provide high-quality experiences for diverse 

users, with trailheads and waysides that provide maps 

and interpretive information about the NCA purposes 

and values. This system would result in impacts on soils 

and native vegetation as a result of single-track trail construction that could be minor but permanent. Beneficial 

effects would be expected from the new trail system, as it 

would minimize the number of new social trails that are 

developed in the short and long term, protecting soil and 

vegetation and lessening the potential for soil compaction and erosion and destruction of native vegetation. 

These alternatives also propose changes related to zoning 

of the NCA, through the establishment of four Recreation 

Management Zones to guide management of recreational 

uses. Dispersed camping would be prohibited in the Rural 

and Frontcountry Zones under the three alternatives. 

Alternative B would allow dispersed camping only at designated sites in the Backcountry Zone and provide metal 

fire rings. Camping and campfires would be prohibited 

elsewhere in the Backcountry Zone, lessening the potential for damage to native vegetation and wildfires started 

from unattended campfires. 

Alternative C would prohibit this activity in the 

Backcountry Zone. Under These restrictions on dispersed camping could help to protect soils and native 

vegetation, lessening the potential for soil compaction or 

erosion and destruction of native vegetation. They could 

also minimize the potential for wildfires that are started 

by unattended campfires. 

Alternative D would authorize dispersed camping and 

campfires in the 14,248 acres of the Backcountry Zone. 

This could have long-term, moderate impacts on soils 

and vegetation, due to soil compaction, damage to native 

vegetation, and increased risk of wildfires. 

Alternatives A, B, and D propose to maintain or upgrade 

existing camping and day use facilities at the Red Cliffs 

Recreation Area within the NCA. Alternatives B and D 

could authorize expansion of the existing facilities, to accommodate demand. Expansion could remove additional 

native vegetation, resulting in a minor, but permanent, 

negative impact.

Alternative C would manage the Recreation Area only 

for day use, decommissioning the campsites and providing additional day use amenities and parking. Providing 

facilities for increased day use could negatively impact 

soils and vegetation, as higher numbers of visitors would 

use the designated trails of the Recreation Area, potentially increasing trail tread width and soil compaction. 

The elimination of overnight camping could reduce the 

potential for wildfires started by unattended campfires. 

Alternative A would continue to manage the Sand Cove 

Primitive Camping Area under a no fee permit system; 

no amenities would be provided. Native vegetation and 

soils would continue to be impacted by unmanaged 

camping and parking use of the area by large groups 

where no fire rings or sanitary facilities are provided. 
772 Chapter 4 RCNCA RCNCA Chapter 4 773

NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

Alternatives B and D would develop camping facilities 

at Sand Cove Primitive Camping Area and continue to 

manage it under a permit system. Vault toilets, fire rings, 

and other amenities would be provided and camping 

limited to 20 or 40 persons, under Alternatives B and 

D, respectively. These restrictions and amenities could 

help to protect soils and native vegetation, lessening the 

potential for soil compaction or erosion and destruction 

of native vegetation. They could also minimize the 

potential for wildfires that are started by unattended 

campfires. 

Alternative C would eliminate camping in this area, 

providing the highest level of protection to soils and 

vegetation, when compared to the other alternatives.

4.30.2.5 Impacts from Management of 

Comprehensive Travel and Transportation

The impacts or benefits for native vegetation related to 

OHV area designations can be estimated by comparing 

the number of acres that are designated as Open, Limited 

to Existing Roads and Trails, Limited to Designated 

Roads and Trails, and Closed to motorized vehicle travel 

and uses through the RMP. Alternatives that close more 

acres to motorized travel would be expected to reduce 

the potential for vehicles to kill or injure livestock and 

prevent the introduction or spread of weed or invasive 

species’ seeds and plant materials through tires and 

vehicle undercarriages. All alternatives propose identical 

OHV area designations for the NCA, with specific route 

designations to follow through BLM’s development of a 

TMP for Washington County. OHV area designations 

under all alternatives would designate all acres as either 

Closed or Limited.

All alternatives would continue to manage the NCA 

as Closed to motorized vehicles on 19,989 acres and 

Limited to Designated Roads and Trails on 24,870 acres. 

No acres would be managed as Limited to Existing Roads 

and Trails or Open to Cross-country OHV use.

All alternatives propose approximately the same acreage 

of area closures and limitations on vehicle travel to 

existing or designated routes. All alternatives would 

result in moderate to major, short and long-term 

beneficial effects on soils and vegetation, by managing 

motorized vehicles and other travel to avoid or minimize 

surface disturbances related to unauthorized crosscounty travel and route proliferation. Intact soil horizons, 

soil crusts, and vegetation communities would maintain 

the health of native vegetation.

4.30.2.6 Impacts from Management of Lands and 

Realty

Under all alternatives, 19,989 acres in the two designated 

wilderness areas would be managed as ROW Exclusion 

areas, protecting soils and native vegetation from 

development-related impacts. Existing ROWs could 

be modified to allow for upgrades to existing power 

transmission lines, water lines, and associated facilities; 

such upgrades could result in damage or loss of 

vegetation and impacts on soils. These impacts would 

be lessened to the maximum extent possible, through 

project design, BMPs, and terms and conditions of the 

ROW grants. 

Alternative A would continue to manage 24,686 acres of 

the NCA as a ROW Avoidance area and two designated 

utility corridors (183 acres), one along State Route 18 

and one along I-15, would be carried forward. Unless 

specific criteria are met, new ROWS for utilities and 

transportation facilities would not be authorized in the 

Avoidance area. Soils and native vegetation would be 

protected from impacts related to new developments 

within 24,686 acres of the NCA.

Alternative B would manage a total of 41,023 acres of the 

NCA as a ROW Exclusion area and would carry forward 

two designated utility corridors, one along State Route 

18 and one along I-15. Approximately 3,652 acres would 

continue to be managed as ROW Avoidance area. Soils 

and native vegetation would be protected from the impacts 

related to new ROWs development on 21,218 more acres 

under this alternative, when compared to Alternative A, a 

major beneficial effect on these resources. 

Alternative C would manage a total of 44,808 acres of 

the NCA as a ROW Exclusion area, protecting 24,870 

acres of soil and native vegetation from impacts related 

to new ROW developments. Under this alternative, the 

designated utility corridor along I-15 would be revoked 

through the NCA, providing additional protection to 

soils and upland and riparian vegetation along Quail 

Creek from impacts related to new ROW developments. 

Alternative D would manage 38,324 acres of the NCA 

as a ROW Exclusion area and carry forward the two 

designated utility corridors along State Route 18 and 

I-15 that total 183 acres in size. New utilities could be 

developed under ROWs in either corridor, impacting 

soils and vegetation within these areas through the NCA

Alternative D would also designate a new utility and 

transportation corridor, totaling 6,350 acres in size, 

where new ROWs could be granted for the development 

NATIVE VEGETATION COMMUNITIES AND FIRE AND FUELS MANAGEMENT

of linear ROWs, such as power transmission lines, 

water and gas lines, fiber-optic lines, and associated 

facilities, including access routes, as well as new site-type 

ROWs. A ROW could also be granted in this corridor 

for the construction of Washington County’s proposed 

“northern transportation route” multi-lane roadway. 

Over the life of the RMP, soils and native vegetation 

could be damaged or destroyed within some or all of 

the acreage within this designated corridor as a result 

of new ROW developments. Impacts on these resources 

would be lessened to the maximum extent possible 

for each project, through project design, BMPs, revegetation, and terms and conditions of the ROW grants. 

However, potential impacts on soils and vegetation from 

the designation of this new utility and transportation 

corridor, in concert with the 183 acres included in 

existing designated corridors along State Route 18 and 

I-15 that would be carried forward, would be negative, 

major, short and long term.

4.30.2.7 Impacts from Management of Scientific 

Research

Alternatives B, C, and D identify research opportunities 

that would improve the conservation, protection, and 

restoration of native vegetation communities in the NCA. 

Among the possible studies would be an evaluation of 

the long-term effectiveness of herbicidal treatments 

for exotic invasive annual grasses in arid environments 

that could help to inform the selection of methods to 

create fuel breaks and native vegetation restoration 

projects. Other research opportunities could focus on 

the development of ecologically sustainable and costeffective biological treatments to control and eradicate 

infestations of noxious weeds and invasive species. 

Potential studies relating to biological soil crust function 

and regeneration in disturbed and fire-altered desert 

ecosystems could help to develop cost-effective methods 

to restore biological soil crusts that would facilitate revegetation of damaged lands.

4.30.3 Summary of Impacts from Alternatives

Table 4-21 displays a comparative summary of impacts 

by alternatives. Alternative A would continue current 

management and provide moderate protection levels 

for native vegetation through recreation and travel 

management under the PUP; management of 19,989 

acres as a ROW Exclusion area and 24,686 acres as an 

Avoidance area for new ROWs.

Use of a systematic approach for resource management 

under Alternatives B and C would generally improve 

management of vegetation. Fire and Fuels management 

under these alternatives would be more comprehensive 

and effective compared to Alternative A, potentially 

reducing the risk of catastrophic wildfire. Restoration of 

disturbed and damaged vegetation communities would 

strive to restore native species and control noxious weeds 

and invasive species using the most appropriate and least 

invasive methods. Impacts from recreation uses would 

be reduced, as the BLM would develop professionally 

designed and sustainable trail systems and other facilities 

to protect resource values and provide for high-quality 

visitor experiences. 

Alternative D would include many of the same beneficial 

management aspects as Alternatives B and C, as they relate 

to the conservation, protection, and restoration of soils 

and native vegetation and more effective fire prevention 

and hazardous fuel reduction. Management decisions 

under this alternative related to Lands and Realty 

management would not meet the conservation, protection, 

and enhancement purpose of the NCA for ecological 

resources, including soils and vegetation. The designation 

of utility and transportation corridors, totaling 6,534 acres 

in size, would allow for development of new utilities and 

transportation systems, including Washington County’s 

proposed “northern transportation route”, under ROWs 

that could damage or destroy native vegetation within 

some or all of this acreage over the life of the RMP.

4.30.4 Cumulative Impacts

Past human actions within the CIAA, on federal, state, 

municipal, and private lands that have affected these 

resources include the development of utilities, road and 

highway construction, mineral materials harvesting, 

mining, grazing by livestock, and vegetation treatments. 

These have resulted in the temporary and permanent 

loss of native vegetation and the erosion of soils. 

Other factors, such as prolonged droughts, wildfires, 

insects, and disease have also caused changes to native 

vegetation communities. Wildland fires have removed 

vegetative cover, potentially accelerating soil erosion 

and the introduction and spread of weeds and invasive 

species. Drought conditions have impacted the health 

of vegetation communities, making them susceptible to 

disease and insect infestations.

Climate change within the CIAA could cause an increase 

or decrease in temperatures and precipitation, which 

would affect soil conditions, vegetation distribution, 

water flows, water quality, and water temperature. Such 

changes would alter the conditions to which vegetation 
774 Chapter 4 RCNCA RCNCA Chapter 4 775

NOXIOUS WEEDS AND INVASIVE SPECIES MANAGEMENT

communities are adapted, potentially creating conditions 

that could favor certain species or communities, weeds, 

or pests.

4.31 NOXIOUS WEEDS AND INVASIVE SPECIES 

MANAGEMENT

This section discusses impacts on the control and eradication of noxious weeds and invasive species that might 

result from proposed management actions for other 

resources and land uses identified in the four alternatives 

in Chapter 2. 

4.31.1 Methods of Analysis

This analysis focuses on those management actions that 

have the potential to introduce or spread noxious weeds 

in the NCA. In the absence of quantitative data, best professional judgment was used, and impacts are sometimes 

described using ranges of potential impacts or in qualitative terms, if appropriate.

4.31.1.1 Indicators

Indicators of adverse impacts on the control and eradication of noxious weeds and invasive species include:

NOXIOUS WEEDS AND INVASIVE SPECIES MANAGEMENT

▶ Replacement or substantial invasion of native communities with noxious weeds or non-native invasive 

species, to the degree that such invasions cannot be 

successfully controlled or change the character of 

the native communities.

Indicators of beneficial impacts:

▶ Reduction or eradication of noxious weeds and 

invasive species.

4.31.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA;

▶ Noxious weed and invasive species management 

actions are aimed at achieving or trending towards 

achieving Utah Standards for Rangeland Health;

▶ The degree of impact attributed to any one disturbance or series of disturbances would be influenced 

by several factors, including location, type, time, 

and degree of disturbance; existing vegetation; 

precipitation; and mitigating actions applied to the 

disturbance;

▶ Noxious weeds and invasive species could continue 

to be introduced and spread as a result of ongoing 

vehicle traffic in and out of the planning area, recreational activities, wildlife and livestock grazing and 

movements, and surface-disturbing activities;

▶ Activities that would disturb soils could cause erosion, loss of topsoil, and soil compaction, which 

could affect the ability of native vegetation to regenerate and could facilitate the invasion of noxious 

weeds.

Implementing management actions for the following 

resources would have negligible or no impact on noxious 

weeds and are, therefore, not discussed in detail: Air 

Quality, Water Resources, Geologic and Paleontological 

Resources, Caves and Karst Resources, Soil Resources, 

Vegetation Resource Uses: Livestock Grazing, Vegetation 

Resource Uses: Plant Materials, Other Fish and Wildlife 

Species, Heritage Resources, Wilderness, ACECs, Visual 

Resource Management, Natural Soundscapes, Lands 

with Wilderness Characteristics, Public Education and 

Interpretation, and Scientific Research.

4.31.2 Direct and Indirect Impacts

The likelihood for the introduction and spread of noxious weeds and non-native invasive species could occur 

under all alternatives, as a result of many natural and 

human-caused factors. Impacts on native vegetation 

communities would be because the health of vegetation communities is linked to the presence, distribution, and abundance of noxious weeds and invasive 

species. Management of native vegetation communities 

to maintain plant health, species diversity, and intact 

biological soil crusts help to prevent infestations and 

control the spread of noxious weeds and invasive species. 

Management actions that could affect the control and ultimate eradication of noxious weeds and invasive species 

are described below.

4.31.2.1 Impacts from Management of Native 

Vegetation Communities and Fire and Fuels 

Management

Alternative A addresses the management of desired plant 

communities within the context of meeting or exceeding 

management objectives for a wide array of resource uses 

and programs, including livestock grazing, wildlife, and 

non-consumptive purposes. Desired plant communities 

could include non-native species, if these further management goals. Noxious weeds and invasive species could 

be introduced or spread through the use of non-native 

species under this alternative. 

Alternatives B, C, and D emphasize the conservation, 

protection, and restoration of native perennial and annual communities, late successional desert shrublands, 

and biological soil crusts. These goals would be met 

through efforts to prevent and suppress wildfires, control 

or eradicate noxious weeds and invasive species, and 

restore desired plant communities to disturbed and firedamaged landscapes. These actions would be designed 

to conserve and improve the overall health of vegetation 

communities, making them less susceptible to weed invasion or spread, in the short and long term. Management 

actions under these alternatives could have incidental 

and negligible impacts on weed and invasive species 

spread, as the result of noxious weed or invasive species 

control programs.

Under Alternatives B, C, and D, BLM would emphasize 

the development of fuel breaks and reduction of hazardous fuels that threaten native desert vegetation communities in the NCA. Alternatives B and D would authorize the broadest array of tools and methods for these 

projects, including the use of mechanical methods and 

targeted livestock grazing. Mechanical methods could 

damage soil crusts and create new surface disturbances 

that would be susceptible to the establishment of noxious 

weeds and invasive species. The use of grazing animals 

would increase the potential that noxious weeds and 

Resource/Resource Use Impact/Effect Description Intensity

Water Resources Effect Protection of water resources benefits native vegetation Unknown

Geological/Paleontological Impact Excavations could damage or destroy some native vegetation in 

area of project.

Negligible 

to Minor

Soils Resources Effect Protection of soil resources through project planning and BMPs 

benefits native vegetation.

Minor to 

Moderate

Native Vegetation

Effect

Rehabilitation of fire damaged lands through seeding and plantings of native species would improve biodiversity and persistence 

of native vegetation communities. 

Moderate 

to Major

Fire and Fuels Impact Fire suppression tactics, fuel breaks, and fuel reduction projects 

would damage or destroy some native vegetation

Minor to 

Moderate

Effect Fuel breaks and fuel reduction projects would help to protect 

large areas from effects of wildfire.

Moderate 

to Major

Noxious Weeds and Invasive 

Species Impact Control and eradication of noxious weeds and invasive species could impact some native vegetation. Minor

Effect

Control and eradication of invasive brome species would benefit native vegetation, by reducing fire hazards and increasing 

biodiversity.

Moderate 

to Major

Special Status Species Effect Management to conserve and restore habitats for at-risk species 

would benefit native vegetation communities.

Minor to 

Moderate

Heritage Resources Effect Allocation and management of heritage resources for conservation would help to protect native vegetation. Minor 

Travel Management Effect Protection of native vegetation would occur through management of vehicle travel as Limited to Designated Roads and Trails.Minor to 

Moderate

Visual Resources Effect VRM Class I and II designations would protect naturalness, benefitting native vegetation. Minor

Lands with Wilderness 

Characteristics Effect Management to protect lands with wilderness characteristics under Alternative C would protect native vegetation. Minor

Recreation Effect Restrictions on dispersed camping by zone would protect native 

vegetation from damage or loss. Minor

Effect

Limits on numbers and types of commercial recreation permits 

would protect native vegetation from damage or loss related to 

recreation uses.

Negligible

Lands and Realty

Effect

Management as Avoidance or Exclusion area for new ROWs 

would protect native vegetation from damage or loss to 

developments.

Moderate

Impact Authorizing new ROWs in designated corridors identified under 

Alternative D could damage or destroy native vegetation.

Minor to 

Moderate

Table 4-21 Summary of Impacts to Native Vegetation Communities
776 Chapter 4 RCNCA RCNCA Chapter 4 777

NOXIOUS WEEDS AND INVASIVE SPECIES MANAGEMENT

invasive species could be introduced or spread, through 

manure and trailing. 

Alternative C would limit the methods that could be used 

for fuel breaks and hazard fuel treatments to those that 

are the least impacting to soil crusts and that minimize 

new surface disturbances. Targeted grazing would not 

be among the methods that could be employed. Noxious 

weeds and invasive species would less likely be introduced or spread under this alternative.

Wildland fires and fire suppression tactics that create 

new surface disturbance would increase the likelihood 

for weed introduction or spread by disturbing soil, damaging soil crusts, and removing vegetation. The increase 

in soil nutrients following fire and the use of retardants 

would favor spread and proliferation of invasive annual 

brome grasses or other invasive species. In late-successional desert shrubland communities, catastrophic fires 

and multiple fires convert these fire-intolerant areas to 

invasive grasslands. 

Under all alternatives, BLM would seek funding and 

develop plans for post-fire emergency stabilization and rehabilitation to stabilize soils and restore vegetation on fire 

damaged lands, Alternatives B, C, and D would emphasize 

the use of early colonizing annual and perennial species 

that would be most likely to quickly re-establish soil cover, 

helping to prevent the introduction or spread of noxious 

weeds and invasive species. When compared to Alternative 

A, these alternatives would likely be more successful in 

preventing the introduction and spread of noxious weeds 

and invasive species on fire-damaged lands.

4.31.2.2 Impacts from Management of Noxious Weeds 

and Invasive Species

Noxious weed or invasive species infestations can become so widespread as to create vegetation monocultures 

that are typically poorly suited to protecting soils from 

erosional forces. Control and eradication of noxious and 

invasive species can create short-term surface disturbances, but over the long term, help to conserve, protect, 

and restore healthy ecosystems.

Under all alternatives, noxious weeds would be managed 

through Integrated Weed Management, to control, suppress and eradicate, where possible, noxious weeds and 

invasive species to support healthy plant communities in 

the NCA. Herbicide use protocols and standard operating procedures, described in the PEIS for Vegetation 

Treatments Using Herbicides (FEIS, BLM 2007 ), would 

be followed to reduce impacts on non-target vegetation 

from herbicide treatments. Noxious weed prevention 

measures would be included in relevant contracts, permits, and cooperative agreements. All alternatives would 

focus weed inventory surveys and treatments on high use 

areas, and would require the use of weed-free materials 

for projects and weed-free hay by pack stock users.

Alternatives B, C, and D propose a range of tools and 

methods that could be employed for controlling noxious 

weeds and protecting soil resources. These alternatives 

identify strategies for controlling and ultimately eradicating non-native tamarisk, Russian olive, and Big Reed, in 

ephemeral drainages, Leeds and Quail Creeks, and along 

the Virgin River. These management actions would help 

to reduce the extent of weed infestations in the NCA and 

prevent the introduction and spread of new weed species 

in the short and long term. 

Alternative C would limit the aggressiveness with which 

the BLM could treat weed infestations, by restricting 

methods only to hand tools, which could result in the 

expansion of some noxious weeds, as treatments would 

take longer to complete and be more labor intensive. The 

loss of desirable vegetation communities could result 

in the loss of soil stabilization and increased erosion 

potential. At the same time, limiting weed treatments to 

non-invasive methods would be protective of soil and 

water quality, particularly for infestations within or near 

riparian areas. 

4.31.2.3 Impacts from Management of Special Status 

Species, Including BLM Sensitive Species 

Under all alternatives, the goals are to protect, conserve, 

and restore critical habitats and assist the recovery and 

delisting of threatened and endangered species and preclude the need to list additional species under the ESA. 

By protecting, conserving, and enhancing these habitats, 

proper functioning condition of native vegetation communities, soils, and watersheds will be maintained. All 

alternatives propose implementing post-fire ES&R treatments to stabilize soils and re-establish native vegetative 

cover in habitats for special status species, helping to 

prevent the introduction or spread of noxious weeds and 

invasive species.

Alternatives B, C, and D prioritize the conservation and 

protection of critical habitats from the effects of wildfire, 

through the development of fuel breaks and hazardous 

fuel reduction projects. These alternatives also prioritize 

the restoration disturbed and fire-damaged vegetation 

communities in designated critical habitats for Mojave 

desert tortoise and other at-risk species. Restoration 

of desired vegetation communities could lessen the 

NOXIOUS WEEDS AND INVASIVE SPECIES MANAGEMENT

potential for infestations of noxious weeds and for invasive annual brome grasses to proliferate in disturbed and 

fire-damaged critical habitats.

4.31.2.4 Impacts from Management of Lands with 

Wilderness Characteristics

Under Alternatives A, B, and D, management would 

not focus on the protection of wilderness characteristics 

within the 1,586 acre inventory area. Under Alternative 

C, BLM would commit to preserving wilderness characteristics on 1,586 acres, through closures to motorized 

vehicle travel, commercial and non-commercial woodland products harvesting, as well as management under 

VRM Class I and as a ROW Exclusion area. These land 

use closures and restrictions would preclude the types of 

surface disturbances that could lead to soil disturbances 

and the introduction or spread of noxious weeds and 

invasive species. 

4.31.2.5 Impacts from Management of Recreation and 

Visitor Services

Management of the NCA would conserve, protect, and 

enhance sustainable public recreation opportunities, 

as this was one of the purposes for which the NCA 

received Congressional designation. Recreation would 

be primarily dispersed in nature and include hiking, 

mountain biking, rock climbing, equestrian trail riding, 

hunting, and nature viewing and photography. Some 

commercial, competitive, and organized group activities 

could also be authorized.

Poorly constructed or maintained hiking, equestrian or 

ATV trails contribute to the development of unauthorized “social” trails and trail braiding. These, in turn, 

create new soils and vegetation disturbances that increase 

the potential for weed infestations. Dispersed camping 

and other recreational activities could lead to soil disturbances and the introduction or spread of noxious weeds 

and invasive species. 

Alternative A would continue the management of recreational activities and public uses, as authorized through 

the PUP for the Reserve. Non-motorized recreational 

uses in the Lowland Zone would continue to be on designated trails; off-trail travel would be authorized in the 

Upland Zone. Motorized vehicle travel would be Limited 

to Designated Roads, including the Babylon Road. 

Dispersed camping would continue to be limited to the 

two designated wilderness areas, the Upland Zone, and 

Sand Cove Primitive Camping Area. The current management decisions would help to minimize the introduction and spread of noxious weeds and invasive species, by 

limiting motorized vehicle travel to designated roads and 

managing non-motorized uses on designated trails in the 

Lowland Zone. The potential for weed introduction and 

spread would be highest in the Upland Zone, where offtrail travel is permitted.

Alternatives B, C, and D include the development of a 

professionally-designed non-motorized trail system in the 

NCA to provide high-quality experiences for diverse users, 

with trailheads and waysides that provide maps and interpretive information about the NCA purposes and values. 

This system would be expected to minimize the number of 

new social trails that are developed in the short and long 

term, protecting soil and vegetation and minimizing the 

potential for introduction and spread of noxious weeds. 

Alternatives B, C, and D propose changes related to 

zoning of the NCA, through the establishment of four 

Recreation Management Zones to guide management of 

recreational uses. Dispersed camping would be prohibited in the Rural and Frontcountry Zones under the three 

alternatives. Alternative B would allow dispersed camping in the Backcountry Zone but only at designated sites 

and prohibited entirely under Alternative C. Dispersed 

camping could occur anywhere in the Backcountry 

Zone under Alternative D. Where dispersed camping is 

restricted or limited to designated sites, the potential for 

this activity to introduce noxious weeds or invasive species would be minimized.

4.31.2.6 Impacts from Management of 

Comprehensive Travel and Transportation

Potential impacts or benefits to the prevention of noxious weed and invasive species infestations can be 

estimated by comparing the number of acres that are 

Open, Limited, and Closed to OHV use. Alternatives that 

close more acres to motorized travel would be expected 

to provide the highest level of protection to soils from 

surface disturbances, and, indirectly, to the prevention of 

noxious weed and invasive species infestations. All alternatives propose identical OHV area designations for the 

NCA, with specific route designations to follow through 

BLM’s development of a TMP for Washington County. 

Under all alternatives, none of the NCA would be 

managed as Open to Cross-country Vehicle Travel or 

Limited to Existing Roads and Trails. All alternatives 

would designate 24,870 acres as Limited to Designated 

Roads and Trails, and 19,989 acres as Closed to OHV 

use. Because all alternatives are the same, impacts would 

not vary across alternatives. This is expected to minimize the potential for new infestations of noxious weeds 
778 Chapter 4 RCNCA RCNCA Chapter 4 779

NOXIOUS WEEDS AND INVASIVE SPECIES MANAGEMENT

and invasive species, and also help to sustain healthy, 

native vegetation, making these areas less susceptible to 

weed invasion.

4.31.2.7 Impacts from Management of Lands and 

Realty

Under all alternatives, 19,989 acres in the designated 

Cottonwood Canyon and Red Mountain Wilderness 

areas would continue to be managed as an Exclusion area 

for the siting of new site-type and linear ROWs. As new 

developments under ROWs would not be authorized, the 

potential for the introduction or spread of noxious weeds 

and invasive species as a result of surface disturbances 

due to those types of land use authorizations would be 

eliminated in both wilderness areas.

Alternative A would continue to manage the NCA as a 

ROW Avoidance area and retain two designated utility corridors along State Route 18 and I-15 through the 

NCA, as the recommended locations for linear ROWs. 

Noxious weed prevention measures would be implemented, through project design, BMPs, and terms and 

conditions on ROW grants, lessening the potential for 

the introduction and spread of weed and exotic invasive 

species infestations during construction of new facilities 

and maintenance of existing ROWs.

Alternatives B and D would manage the NCA as a ROW 

Exclusion area, but retain the two existing designated 

corridors for siting new linear ROWs. Each alternative 

would minimize the potential for the introduction and 

spread of noxious weeds within the NCA related to the 

granting of new ROWs, except in the designated corridors. Alternative D would also designate a third, variable 

width utility and transportation corridor that would extend north-south through the NCA. The authorization of 

new power transmission lines, pipelines, associated facilities and access roads, and Washington County’s proposed 

“northern transportation route” multi-lane roadway, 

within the proposed 6,350 acre designated corridor could 

introduce and spread noxious weeds and invasive species, as a result of new soil disturbances, loss of vegetative 

cover, and the use of heavy equipment and motorized 

vehicles during construction. Noxious weed prevention 

measures would be implemented, through project design, 

BMPs, and terms and conditions on the ROW grants, 

lessening the potential for the introduction and spread 

of infestations during construction of new facilities and 

maintenance of existing ROWs.

However, the management of three designated utility and 

transportation corridors, particularly a new 6,350 acre 

corridor through the heart of the NCA, could directly 

and negatively impact BLM’s ability to control and eradicate noxious weeds in this area of the NCA. This impact 

would be direct, negative, major in scope and intensity, 

and potentially long-term.

Alternative C would revoke the designated utility corridor along I-15 through the NCA and would not designate new utility and transportation corridors through the 

NCA. Approximately 44,809 acres of the NCA would be 

managed as a ROW Exclusion area, conferring the highest level of protection to soil and vegetation resources, as 

new ROWs would not be authorized. Surface-disturbing 

activities related to new utility and transportation facilities being constructed under ROWs grants would not 

occur under this alternative, which would not only minimize the potential for new infestations of noxious weeds 

and invasive species, but would also help to sustain 

healthy, native vegetation, which would make these areas 

less susceptible to weed invasion.

4.31.3 Summary of Impacts from Alternatives

Under all alternatives, BLM would continue to implement noxious weed and exotic invasive species treatments over the life of the RMP. Herbicide use protocols 

and standard operating procedures, described in the 

Programmatic EIS for Vegetation Treatments Using 

Herbicides (FEIS, BLM 2007) would be followed to reduce impacts on non-target vegetation from treatments. 

Noxious weed prevention measures would be included in 

contracts and permits. All alternatives would focus weed 

inventory surveys and treatments in high use areas, and 

would require the use of weed-free materials for projects 

and weed-free hay by pack stock users.

Under Alternatives B, C, and D, management actions 

would focus on the conservation, protection, and restoration of watersheds, soils, and native vegetation communities that provide critical habitats for special status 

species, and other fish and wildlife. These would include 

measures to prevent future wildfires, as these pose the 

greatest single threat to the Mojave Desert and Great 

Basin ecosystems that overlap in the NCA and other resource values of the NCA. Emphasis would be placed on 

re-vegetation of disturbed and fire-damaged landscapes 

with healthy native vegetation communities that would 

not be susceptible to the establishment or spread of noxious weeds and invasive species.

Alternatives B and C propose to manage recreation uses, 

motorized vehicle travel, and land use authorizations 

to provide higher levels of resource protection when 

VEGETATION RESOURCE USES: LIVESTOCK GRAZING

compared to Alternatives A and D. The potential beneficial effects on control and eradication of weeds and 

exotic invasive species, under these alternatives would be 

moderate, direct, and long term.

Alternative D proposes the management of three designated corridors where new utilities and transportation 

routes could be constructed under ROWs. The authorization of new power transmission lines, pipelines, 

or Washington County’s proposed multi-lane road or 

“northern transportation route” within the proposed 

new 6,350 acre designated corridor could introduce and 

spread weed infestations, as a result of new soil disturbances, loss of vegetative cover, and the use of heavy 

equipment and motorized vehicles during construction. 

Noxious weed prevention measures and BMPs would be 

implemented to lessen the impacts associated with these 

actions during the construction and maintenance phases 

of each project. However, the management of three 

designated utility and transportation corridors, particularly a 6,350 acre corridor that traverses the length of the 

NCA, would impact BLM’s ability to control and eradicate noxious weeds on a majority of the public lands. This 

impact would be direct, negative, moderate to major in 

scope and intensity, and long-term.

4.31.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on the 

control and eradication of noxious weeds and invasive 

species extends outside the NCA boundaries, to include 

public lands managed by BLM and USFS-Dixie National 

Forest; State Lands (SITLA, UDWR, Snow Canyon 

State Park), and private and municipal lands within and 

adjacent to the boundaries of the NCA. Management 

actions on these adjoining lands would have the potential 

to influence resource conditions and desired outcomes in 

the NCA. 

Past, present, and reasonably foreseeable future land 

uses and human activities within the CIAA that have 

affected and will likely continue to influence the introduction and spread noxious weeds and invasive species 

include domestic livestock grazing, motorized recreational activities, utilities construction, urban development, road and highway construction and maintenance, 

natural factors such as drought, flooding, and wildland 

fires have removed native vegetation, accelerated soil 

erosion, and left areas vulnerable to weed and invasive 

species infestations.

Many of these past land uses created conditions that 

cause or favor changes to native vegetation communities 

and soil conditions. For example, overgrazing by sheep 

and cattle throughout the early decades of the 20th 

century altered the species composition of native vegetation communities, removing some perennial and annual 

native grass species and damaging physical and biological soil crusts. Exotic annual brome grasses were able to 

establish, creating a fine fuel understory that today fuels 

catastrophic wildfires. Fire-damaged lands are more susceptible to weed invasion. Drought conditions have also 

reduced the health and vigor of native vegetation communities, making individual plants more prone to insect 

infestation or disease; these conditions are predicted to 

become an even more important factor in ecosystem 

health in the Mojave Desert under most climate 

change scenarios.

Climate change within the CIAA could cause increases 

in temperatures and changes in the timing and amounts 

of precipitation. Such changes would affect soil conditions, native vegetative community composition and 

productivity, and natural wildfire regimes in the Mojave 

Desert. Such changes would alter the conditions to which 

vegetation communities have adapted over time, creating conditions that are predicted to favor invasive annual 

grasses, as well as other weed species.

4.32 VEGETATION RESOURCE USES: 

LIVESTOCK GRAZING

This section discusses impacts on livestock grazing from 

proposed management actions of other resources and 

resource uses. Existing conditions concerning livestock 

grazing are described in Section 3.9, Livestock Grazing.

Two livestock grazing allotments with active grazing 

permits overlap the NCA. Approximately 220 acres of 

the Sand Wash allotment and 1,100 acres of the Veyo 

Allotment are within the NCA boundaries and also 

within the Red Mountain Wilderness, Congressionallydesignated in 2009 through OPLMA, and managed by 

BLM to protect its wilderness characteristics. Livestock 

from these two allotments do not graze within the boundaries of the NCA and there are no range improvements 

that would facilitate grazing within the NCA boundaries.

All alternatives propose no changes to currently authorized livestock grazing for the NCA portions of the 

Sand Wash and Veyo Allotments. Any livestock-grazing 

management actions that might be undertaken within 

the NCA and the designated wilderness at a future 

time must be in compliance with the Wilderness Act; 

OPLMA Section 1972 (b) (2); the approved Red Cliffs 

NCA RMP, and the Wilderness Management Plan for 
780 Chapter 4 RCNCA RCNCA Chapter 4 781

VEGETATION RESOURCE USES: LIVESTOCK GRAZING

the Cottonwood Canyon and Red Mountain Wilderness, 

currently being drafted by BLM.

The Diamond Valley allotment is 2,080 acres in total size, 

of which 1,800 acres are BLM-managed public lands; 

approximately 1,200 acres of the total are within the 

NCA boundaries. Livestock have not been grazed on the 

Diamond Valley allotment since 1984, as the allotment 

has been in non-use at the operator’s request.

The remaining allotments within the NCA were made 

unavailable for grazing in 1999, through the SGFO RMP 

and the permits purchased by Washington County from 

the operators. These allotments would continue to be 

unavailable to livestock grazing under all alternatives in 

this RMP over the life of this plan.

4.32.1 Methods of Analysis

This analysis was based on existing data and current and 

projected land uses in the planning area. 

4.32.1.1 Indicators

Indicators of adverse impacts on livestock grazing include the following: 

▶ Management of public lands as unavailable to livestock grazing;

▶ A decrease in permitted AUMs in areas available to 

livestock grazing, due to various resource issues or 

conflicts, or cumulative management actions;

▶ Restricting or prohibiting the ability to construct or 

maintain range improvements and conduct treatments (infrastructure and vegetation).

Indicators of beneficial effects on livestock grazing include the following:

▶ Management of public lands as available to livestock 

grazing;

▶ Public lands that meet Utah Standards for 

Rangeland Health and Guidelines for Grazing 

Management.

4.32.1.2 Assumptions

The analysis includes the following assumptions: 

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA;

▶ All new and existing leases and permits would be 

subject to terms and conditions determined by the 

authorizing officer to achieve the management and 

resource condition objectives for the public lands 

and also managed to meet Utah Standards and 

Guides (Appendix D).

Implementing management actions for the following 

resources would have no impact or negligible impact 

on livestock grazing and are, therefore, not discussed 

in detail: Air Quality, Water Resources, Geologic and 

Paleontological Resources, Cave and Karst Resources, 

Soil Resources, Native Vegetation Communities, Fire and 

Fuels Management, Noxious Weeds and Invasive Species, 

Vegetation Resource Uses: Plant Materials, Special Status 

Species, BLM Sensitive Species, Other Fish and Wildlife 

Species, Heritage Resources, Wilderness, ACECs, Visual 

Resource Management, Natural Soundscapes, Lands with 

Wilderness Characteristics, Recreation Management 

and Visitor Services, Comprehensive Travel and 

Transportation Management, Lands and Realty, Public 

Education and Interpretation, and Scientific Research.

4.32.2 Direct and Indirect Impacts

Under all alternatives, the Alger Hollow, Red Cliffs, 

Yellow Knolls, Washington, Leeds, Sandstone Mountain, 

and Sand Hill Allotments would continue to be unavailable to livestock grazing under all alternatives in this 

RMP over the life of this plan. This management decision was initially made in 1999, through the SGFO RMP, 

and the federal grazing permits acquired by Washington 

County and retired by BLM. Continuation of this management decision would not result in new impacts on any 

livestock grazing operations or livestock operators.

Under all alternatives, the Sand Wash and Veyo 

Allotments would continue to be available for livestock 

grazing and there would be no impacts on current grazing operations in these allotments.

Alternatives B, C, and D propose making public lands in 

the Diamond Valley Allotment unavailable for grazing 

over the life of the RMP. As the allotment has not been 

actively grazed since 1984 at the operator’s request, there 

would be no impacts on current grazing operations.

4.32.2.1 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing

All alternatives would continue to authorize livestock 

grazing in those portions of the Sand Wash and Veyo 

Allotments that overlap the NCA and Red Mountain 

Wilderness. Any livestock-grazing management actions 

that might be undertaken within the NCA and the designated wilderness portions of these allotments at a future 

time must be in compliance with the Wilderness Act; 

OPLMA Section 1972 (b) (2); the approved Red Cliffs 

NCA RMP, and the Wilderness Management Plan for 

the Cottonwood Canyon and Red Mountain Wilderness, 

currently being drafted by BLM. As livestock do not 

VEGETATION RESOURCE USES: LIVESTOCK GRAZING

graze within the NCA and designated wilderness portions of the allotments, and all alternatives continue to 

make public lands available for grazing, there would be 

no impacts on grazing operations.

Alternative A would continue to make the 1,800 acres 

of public land within the Diamond Valley Allotment, 

including the 1,200 acres within the NCA boundary, 

available for grazing over the life of the RMP, subject to 

the terms and conditions of the federal grazing permit.

Alternatives B, C, and D propose to make the 1,800 acres 

of public lands in the Diamond Valley allotment, including the 1,200 acres that are within the NCA boundaries, unavailable for grazing over the life of the RMP. As 

livestock have not been grazed within this allotment for 

more than 25 years, there would be no impacts on grazing operations. The potential socioeconomic impacts of 

these alternatives, compared to Alternative A, are disclosed under Section 4.45. 

4.32.3 Summary of Impacts from Alternatives

Under all alternatives, the Alger Hollow; Red Cliffs; 

Yellow Knolls; Washington; Leeds; Sandstone Mountain; 

and Sand Hill Allotments would continue to be unavailable to livestock grazing under all alternatives in this 

RMP over the life of this plan. As this management decision has been in place since 1999, there would be no new 

impact on livestock grazing operations or operators in 

these allotments.

Under all alternatives, grazing would continue in the 

Sand Wash and Veyo Allotments that overlap the NCA, 

under the current terms and conditions of the grazing 

permits and approved grazing management strategies. 

There would be no impacts to the livestock grazing 

management or livestock operators. Livestock grazing management practices in the Sand Wash and Veyo 

Allotments would continue to be evaluated through 

monitoring and changes made through the grazing 

permitting process, where Utah Standards for Rangeland 

Health are not being met or not making progress toward 

meeting standards.

Alternatives B, C, and D would make the public lands of 

the Diamond Valley Allotment, both inside and outside 

of the boundaries of the NCA, unavailable for livestock 

grazing over the life of the RMP. As this allotment has 

not been actively grazed at the operator’s request, there 

would be no new impact on livestock operators or the 

grazing permit holder.

4.32.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts includes 

BLM-managed grazing allotments in Washington 

County. Past actions or factors that have affected livestock grazing include overgrazing of the rangelands, road 

and highway construction, urbanization, the development of range improvements and vegetation treatments, 

and the construction in major interstate power transmission lines and gas pipelines in designated utility corridors 

in the CIAA. Other factors that have impacted the CIAA 

include prolonged periods of drought, proliferation of 

noxious weeds and exotic invasive species, particularly 

the annual brome species, and more recently, larger and 

more frequent wildfires that have contributed to current 

ecological conditions.

Present actions or factors affecting livestock grazing are 

mainly those that reduce available grazing acreage, restrict management actions or the level of forage production in those areas. Key examples include the effects of 

droughts, exotic invasive species that are fueling an atypical annual fire regime in the Mojave Desert, large wildfires, restrictions on grazing in specific locations (e.g., 

riparian areas) or at certain times to lessen impacts on 

threatened and endangered species and habitats. Future 

actions or factors anticipated to affect livestock grazing in 

the CIAA could include implementation of actions recommended in the 2014 Northeast Mojave Recovery Unit 

Implementation Plan for the Mojave desert tortoise, developed by the Utah/Arizona Recovery Implementation 

Team, an advisory group chartered by the USFWS, under 

the auspices of the Revised Recovery Plan for the Mojave 

Desert Tortoise (2011). Actions are likely to include increased efforts to control invasive annual brome grasses 

and wildfires, through landscape-wide fire breaks and 

fuel treatments in the CIAA. As ongoing research studies 

identify more effective and environmentally sustainable 

treatment methods, it is likely that larger areas would be 

treated and livestock grazing restricted in those areas, 

until resource objectives are met in the project areas. 

Future listings of other native species under the ESA 

could also impose restrictions on livestock grazing.
782 Chapter 4 RCNCA RCNCA Chapter 4 783

VEGETATION RESOURCE USES: PLANT MATERIALS

4.33 VEGETATION RESOURCE USES: PLANT 

MATERIALS

This section discusses impacts on the use of plant materials that might result from proposed management actions 

for other resources and land uses identified in the four 

alternatives in Chapter 2.

4.33.1 Methods of Analysis

This analysis focuses on those management alternatives 

or actions that have the potential to impact the use of 

plant materials. In the absence of quantitative data, best 

professional judgment was used, and impacts are sometimes described using ranges of potential impacts or in 

qualitative terms, if appropriate.

4.33.1.1 Indicators

Indicators of beneficial impacts on the management of 

plant materials include:

▶ Availability of a wide variety of local native plant 

seeds, plants, and cuttings for scientific research and 

restoration purposes. 

Indicators of adverse impacts on the management of 

plant materials include:

▶ Diminished productivity or loss of biodiversity in 

native plant communities;

▶ Unavailability of a wide variety of local native plant 

seeds, plants, and cuttings for scientific research and 

restoration purposes.

4.33.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions are designed to conserve, protect, and enhance the resource values of the NCA;

▶ Plant materials would be available to use in restoration projects and scientific studies.

Implementing management actions for the following resources would have negligible or no impact on 

Vegetation Resource Uses: Plant Materials and are, 

therefore, not discussed in detail: Air Quality, Water 

Resources, Geologic and Paleontological Resources, 

Cave and Karst Resources, Soil Resources, Native 

Vegetation Communities, Fire and Fuels Management, 

Noxious Weeds and Invasive Species, Vegetation 

Resource Uses: Livestock Grazing, Special Status 

Species, BLM Sensitive Species, Other Fish and Wildlife 

Species, Heritage Resources, Wilderness, ACECs, 

Visual Resource Management, Natural Soundscapes, 

Lands with Wilderness Characteristics, Recreation 

Management and Visitor Services, Comprehensive Travel 

and Transportation Management, Lands and Realty, and 

Public Education and Outreach.

4.33.2 Direct and Indirect Impacts

4.33.2.1 Impacts from Management of Vegetation 

Resource Uses: Plant Materials

Under all alternatives, the NCA would continue to be 

closed to commercial and non-commercial (personal 

use) fuelwood, post, and Christmas tree harvesting and 

commercial and non-commercial seed and plant materials collection. These land use restrictions were put in 

place in 1999, through the SGFO RMP, to protect habitat for the Mojave desert tortoise and would be carried 

forward over the life of the RMP. These activities cannot be authorized in the Red Mountain Wilderness and 

the Cottonwood Wilderness (19,989 acres in the NCA), 

pursuant to the mandates of the Wilderness Act. This 

management would continue to have a beneficial effect on many natural and cultural resource values in the 

NCA, including wilderness values, by preventing biomass 

loss, surface disturbances, accidental human-caused fires, 

and other impacts that can be associated with commercial and non-commercial plant materials harvesting or 

collection. 

All alternatives would allow for the collection of plant 

materials for use by Native Americans for religious, 

ceremonial, and traditional purposes. This would have 

a negligible effect on native plant communities, as these 

uses would remove small amounts of material from localized areas.

Alternative C would authorize the collection of seeds and 

plant materials for use for ecological restoration projects 

only in the NCA. Alternatives B and D would expand the 

areas where harvested and collected plant materials could 

be used to similar habitats outside the NCA. The use of 

locally-derived seeds and plant materials would improve 

the success of restoration projects and help to prevent the 

introduction of noxious weeds and invasive species.

4.33.2.2 Impacts from Scientific Research

Alternatives B, C, and D would authorize the collection of seeds and other plant materials under an NCA 

Scientific Research Permit for use in research studies. 

These alternatives would pursue opportunities for studies 

to be conducted that further the development of effective biological or herbicidal controls for exotic invasive 

species and new methods that improve the success of 

re-vegetation techniques in disturbed and fire damaged 

native vegetation communities of the Mojave Desert. 

SPECIAL STATUS SPECIES

4.33.3 Summary of Impacts from Alternatives

Under Alternatives B, C, and D, management actions 

would focus on the conservation, protection, and restoration of native vegetation communities. By not allowing 

commercial and non-commercial harvesting and collection of plant materials, impacts to special status species’ 

habitats that can result from these activities would be 

prevented and native vegetation resources conserved. 

Authorizing the collection and use of the plant materials for research and ecological restoration projects in the 

NCA or adjacent similar habitats, could benefit all wildlife that rely on native plant species to meet their nutritional and other habitat requirements. Native Americans 

would continue to be able to use these resources for religious, ceremonial, and traditional purposes under these 

alternatives, providing a beneficial effect to the continuation of traditional cultural practices.

4.33.4 Cumulative Impacts

The CIAA was defined as the NCA and adjacent federal 

lands managed by BLM and the USFS in Washington 

County. As commercial and non-commercial harvesting and collection of plant materials in the NCA has 

not been authorized since 1999, the management decision to continue this closure would not create a new or 

unusual impact on individuals or commercial ventures. 

Opportunities to harvest and collect plant materials for 

commercial and non-commercial uses continue to be 

available on a majority of the public lands managed by 

the SGFO and on the Dixie National Forest.

4.34 SPECIAL STATUS SPECIES

This section discusses impacts on special status species, 

including federally-listed or proposed species, and BLM 

Sensitive Species from proposed management actions of 

other resources and resource uses.

4.34.1 Methods of Analysis

Data are neither complete nor comprehensive concerning all special status species for the NCA. This analysis 

relied on the best available data from a variety of sources 

and is generally qualitative due to incomplete and unavailable information.

4.34.1.1 Indicators

Indicators of adverse impacts on special status species 

include the following:

▶ Likelihood for impacts on native vegetation causing 

loss of habitat function or value;

▶ Likelihood of injury or mortality to special status or 

BLM Sensitive Species;

▶ Decreased population viability or increased contribution to the need for a federal listing of any 

candidate species or BLM Sensitive Species;

▶ Likelihood of habitat avoidance due to human presence or habitat alteration;

▶ Likelihood of interfering with movement pattern 

that decreases the ability of a species to breed or 

overwinter successfully to a degree that would lead 

to substantial population declines.

4.34.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA;

▶ In general, special status species and BLM Sensitive 

Species would be more susceptible to habitat 

fragmentation, development, or changes in habitat 

conditions, as populations are often already highly 

fragmented, require specific microhabitats, and 

are especially sensitive to disturbance and human 

presence;

▶ Impacts on special status species would be more 

significant than impacts on common species because population viability is already uncertain for 

special status species, and certain species, such as 

special status plants, tend to be poor competitors;

▶ Short-term effects are defined as those that would 

occur over a time frame of two years or less, and 

long-term effects would occur over longer than two 

years;

▶ The health of species is tied to the health of the 

habitats and vegetation on which they depend and 

thus impacts on habitats and vegetation would affect special status species.

Because special status species have specific habitat requirements, disturbance to the species or their habitats 

could result in population declines, which could affect 

survivability of local populations. 

Implementing management actions for the following resources would have no or negligible impacts on 

special status species and are, therefore, not discussed 

in detail: Air Quality, Geologic and Paleontological 

Resources, Cave and Karst Resources, Soil Resources, 

Vegetation Resource Uses: Livestock Grazing, Vegetation 

Resource Uses: Plant Materials, Other Fish and Wildlife 

Species, Heritage Resources, Wilderness, ACECs, Visual 

Resource Management, Natural Soundscapes, Lands 
784 Chapter 4 RCNCA RCNCA Chapter 4 785

SPECIAL STATUS SPECIES

with Wilderness Characteristics, Public Education and 

Interpretation, and Scientific Research.

4.34.2 Direct and Indirect Impacts

4.34.2.1 Impacts from Management of Water 

Resources

All alternatives would strive to protect aquatic habitats 

for BLM Sensitive Species such as the woundfin minnow, Virgin River chub, Virgin spinedace and the desert 

sucker, through restrictions on land uses and authorized 

activities near Quail and Leeds Creeks and the Virgin 

River. Under Alternatives B, C, and D, surface-disturbing 

activities would be prohibited within varying distances 

(250 feet, 1,000 feet, and 500 feet, respectively) from the 

edge of the riparian zones. Alternative C would be the 

most protective, limiting such disturbances to within 

1,000 feet of the edge of the riparian zone, unless the 

project would enhance riparian conditions.

These same management actions would indirectly benefit 

special status species, including the Southwest willow 

flycatcher, western yellow-billed cuckoo and a variety of 

bat species that rely on riparian habitats. These measures 

would reduce the likelihood for decreased population 

viability or increased contribution to the need to list, 

habitat avoidance, interference with species movement, 

and impacts on survival or reproduction associated with 

habitat degradation.

Under Alternatives B, C, and D, re-vegetation of damaged riparian areas would be prioritized to maintain 

or restore proper functioning condition to springs and 

streams. These projects would be conducted using the 

least invasive methods possible, to lessen the amount 

of new surface disturbance and potential soil erosion. 

Riparian restoration would better protect water quality 

and more quickly return proper ecosystem functions. In 

the long-term, restoration of native plant species would 

benefit water resources, as these species are well-suited 

to local environmental conditions and can thrive without 

depleting soil health and water supplies.

4.34.2.2 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Alternative A includes preparation of site specific plans 

to identify desired plant communities, establishing 

specific management objectives, and recommending 

practices to be employed to achieve desired results. This 

could lead to specialized management for those plant 

communities, possibly the quality of habitats for special 

status species.

Alternatives A, B, and D would allow use of non-native 

species for vegetation restoration if specific criteria are 

met and native species are unavailable. Non-native species could more quickly re-establish soil cover, helping to 

stabilize soils and prevent erosion in the short term, and, 

in the long term, improving soil moisture retention for 

native species to establish. However, non-native species 

could also persist and spread, altering native ecosystems, 

reducing the quality of biophysical settings, and not 

facilitating the restoration of native species upon which 

special status species and other wildlife rely for habitat.

Alternatives B, C, and D would provide for implementation-level restoration plans, use of microsite/fertile 

islands, carbon sequestration, use of supplemental water 

sources and inoculation of cryptogamic soil crust with 

mycorrhizae. These additional actions could have a 

beneficial effect on efforts to recover or improve native 

vegetation communities that provide habitat for desert 

tortoise and other listed species. Such actions would 

reduce the competitiveness of invasive annual grasses in 

improving the competitiveness of native bunchgrasses 

and broad-leaved forbs, which is a preferred food source 

for the desert tortoise. 

Alternative B would tailor seed mixes used for ES&R 

projects to include more early successional species, 

include methods of protecting seeds from herbivory, and 

use low impact methods of working seeds into the soil. 

This alternative could increase the chances of successful germination of seeds and improved forage for desert 

tortoise, compared to Alternative A. 

Alternative C would include temporary closures of areas 

to casual dispersed recreation until restoration actions 

meet project goals. This would increase the chance of 

successful recovery of forage species that are important 

to desert tortoise. 

Under Alternative A, fire management actions would 

include full suppression, but with some options for 

minimum impact tactics in special status species’ habitats. These options could be less successful at protecting 

unburned vegetation, given the rapid spread of fires that 

is possible when fueled by invasive brome grasses. The 

use of backburning as part of suppression tactics could 

continue to be authorized, damaging or destroying native 

vegetation in an effort to reduce fire size and spread. 

The rapid employment and appropriate suppression 

responses to minimize fire size and duration in the NCA 

is common to Alternatives B, C, and D. Suppression of 

any wildland fire could have adverse impacts through 

SPECIAL STATUS SPECIES

the removal or loss of vegetation. The use of backburning would be evaluated under Alternatives B and D, and 

minimized to the extent possible. Alternative C would 

not authorize the use of backburning as suppression tool, 

except when deemed essential to protect human life, 

property and the effective control of the fire. 

Alternatives B, C, and D propose fuel breaks and hazard 

fuel reduction projects that would help to limit the accidental ignition and spread of wildfires, protecting native 

vegetation communities and critical habitats. The use 

of existing features (roads, drainages, utility corridors) 

would ensure that the fuel breaks minimize the amount 

of new disturbance and vegetation damage.

Alternatives B and D proposes the widest array of tools 

that could be used to create fuel breaks, including biological, herbicidal, hand removal, targeted grazing, small 

scale weed flaming, and low impact mechanical methods, 

as the means to create the fuel breaks, without causing 

unacceptable levels of damage to native vegetation and 

species habitats. Alternative C would not authorize herbicide use to develop fire breaks and fuel reduction projects, eliminating the potential for impacts related to the 

use of chemical treatments. 

All alternatives provide management direction related to 

the methods that can be employed for ES& R actions to 

restore fire-damaged areas. Alternative A would authorize the use invasive mechanical methods to protect seed, 

through chaining or harrowing. 

Alternative B, C, and D provide a range of potential tools, 

but emphasize use of the least invasive methods to accomplish the goals. Alternative B and D would provide a 

range of management options for seed protection, with 

Alternative D allowing for more invasive methods of seed 

protection, such as chaining or harrowing, to be used. 

The use of mechanical methods could destroy biological 

soil crusts and increase surface disturbance that could 

lead to brome grass infestations and future fires. 

Alternative C would only authorize the use of hand tools 

for re-vegetation projects and could also reduce the 

chance that re-seeding activities could inadvertently lead 

to increased levels of invasive species. 

4.34.2.3 Impacts from Management of Noxious 

Weeds and Invasive Species

Weed control would continue to be implemented under 

all alternatives using an Integrated Weed Management 

approach and relevant standard operating procedures and mitigation measures presented in the Final 

Vegetation Treatments Using Herbicides on BLM Lands 

in 17 Western States PEIS (BLM 2007). With proper 

implementation, weed treatment methods under all alternatives would eliminate or reduce noxious weeds and 

invasive species.

Alternatives B, C, and D identify a slightly variable range 

of tools to control weeds and invasive species, including 

the potential use of biological controls under projectspecific plans in Alternatives B and D. Biological controls 

for invasive annual brome grasses are currently in the experimental stage and may never be applicable on a broad 

scale, even over the life of the RMP. 

Alternatives A, B, and D would also allow chemical 

control of invasive species in unburned areas of the NCA. 

The use of herbicides could damage desired vegetation 

due to over-spray, improper herbicide selection or dosage, or improper timing of application. Alternatively, 

proper chemical control could reduce non-native plants 

while allowing natives to recover, if the chemicals are 

selected and used correctly. These would be beneficial 

impacts, although there would be a slight risk of adverse 

impacts associated with the use of herbicides.

Alternatives B and D authorize the use of targeted grazing to manage invasive plants and to create fuel breaks. 

Targeted grazing is still somewhat experimental in desert 

tortoise habitats based on concerns about trampling of 

dens and burrows, damage to other vegetation, and the 

potential spread of noxious weeds and invasive species 

by grazing animals. The long-term effects of use of this 

management tool are difficult to predict at this time. 

Positive effects could include the removal of large areas 

of non-native annual grasses cost-effectively, creating fire 

breaks that would reduce the chance of accidental ignition and give firefighters a greater ability to contain or 

control fires.

Alternative C would not authorize contracted targeted 

grazing limiting an option to potentially cost-effectively 

control weed infestations in specific types of project areas, such as along roadways or at trailheads. If applied on 

a large scale within desert tortoise habitat, this method 

could result in collapsed dens, injuries and mortalities to 

juvenile tortoises, and the introduction of new noxious 

weeds and invasive species. Desirable native vegetation 

could be removed that would reduce forage for tortoises, 

resulting in minor to moderate negative impacts on this 

species and its critical habitat.
786 Chapter 4 RCNCA RCNCA Chapter 4 787

SPECIAL STATUS SPECIES

4.34.2.4 Impacts from Management of Special Status 

Species, Including BLM Sensitive Species

Alternative A emphasizes habitat protection for special 

status species, through retention, acquisition, and restrictions on land uses and authorized activities.

Under Alternatives B, C, and D, management would 

focus not only on habitat retention and acquisition, but 

also on protection from fire and restoration of damaged 

habitats. The impacts and beneficial effects of native vegetation communities and fire and fuels management are 

described above.

Other management actions would address the need to 

increase populations and assist the recovery and delisting of special status species. These options could include 

the authorization of translocations and predator control. 

In the case of Mojave desert tortoise, translocation could 

help to increase tortoise density and genetic variability, 

and improve reproductive success. 

Project and species level planning would ensure that 

predator control only occurs if scientifically supported, 

and could be discontinued if found to be ineffective or 

counterproductive.

4.34.2.5 Impacts from Management of Recreation 

and Visitor Services

Impacts from recreation could include increased likelihood for injury or mortality, habitat degradation or 

removal, habitat avoidance or displacement and subsequent changes in species movement patterns, and 

impacts on survival or reproduction. Noise caused by humans can have a variety of behavioral and physiological 

effects on wildlife, including increased heart rate, changes 

in metabolism and hormone balance, increased energy 

expenditure, reduced food intake, habitat avoidance and 

abandonment, and reduced reproductive success.

Management of the NCA would conserve, protect, and 

enhance sustainable public recreation opportunities, as 

this was one of the purposes for which the NCA received 

Congressional designation. Recreation would be primarily dispersed in nature and include hiking, mountain biking, rock climbing, hiking, equestrian trail riding, OHV 

riding, hunting, and nature viewing and photography. 

Some commercial, competitive, and organized group 

activities could also be authorized.

Poorly constructed or maintained hiking, mountain bike, 

and equestrian trails have the potential to disturb soils, 

damage soil crusts and damage or destroy vegetation, as 

they contribute to the development of unauthorized “social” trails and trail braiding. These, in turn, create new 

soils and vegetation disturbances that increase erosion. 

Dispersed camping can create similar impacts.

Alternative A would continue to manage the NCA within 

the Red Mountain/Santa Clara SRMA and the SGFO 

ERMA for dispersed recreation uses that generally do 

not include developments or facilities. The management 

of recreational activities and public uses would continue, 

as authorized, through the implementation-level PUP 

for the Reserve. Non-motorized recreational uses in the 

Lowland Zone would continue to be on designated trails; 

off-trail travel would be authorized in the Upland Zone. 

Motorized vehicle travel would be Limited to Designated 

Roads, including the Babylon Road. Dispersed camping 

would continue to be limited to the two designated 

wilderness areas, the Upland Zone, and Sand Cove 

Primitive Camping Area. The current management 

decisions provide considerable protection to soils and 

native vegetation. 

Alternative B, C, and D would not carry forward the 

existing SRMA and ERMA designations, but would 

establish the Red Cliffs SRMA to provide for high-quality 

visitor experiences. Management of the SRMA would 

include rules and guidelines to limit or control activities 

that could impact other NCA resource values through 

management tools such as designated campsites or group 

size limits. A Recreation Area Management Plan would 

be completed to identify authorized recreation and public uses for the SRMA; management decisions from the 

PUP for public lands would not be carried forward under 

these alternatives. 

Alternatives B, C, and D propose the development of a 

professionally-designed non-motorized trail system in 

the NCA to provide high-quality experiences for diverse 

users, with trailheads and waysides that provide maps 

and interpretive information about the NCA purposes 

and values. This trail system would result in impacts 

on soils and native vegetation, as a result of some new 

single-track trail construction. Alternatives B and D 

would mitigate habitat damage from all new trail construction by improving or restoring damaged or degraded habitat within the NCA at a 1:1 ratio; Alternative C 

would restore habitat at a 2:1 ratio. Habitat improvement 

and restoration efforts would help to lessen the negative 

impacts of habitat loss or alteration under these alternatives. Section 7 consultations with the USFWS would 

result in project-specific Biological Opinions that would 

provide Reasonable and Prudent Measures and Terms 

and Conditions to further avoid or minimize impacts on 

SPECIAL STATUS SPECIES

desert tortoise or other special status species that might 

be affected. 

Beneficial effects would be expected from the new trail 

system, as it would minimize the number of new social 

trails that are developed in the short and long term, 

protecting soil and vegetation and lessening the potential for soil compaction and erosion and destruction of 

native vegetation. 

These alternatives also propose changes related to zoning 

of the NCA through the establishment of four Recreation 

Management Zones to guide management of recreational 

uses. Dispersed camping would be prohibited in the Rural 

and Frontcountry Zones under the three alternatives. 

Alternative B would allow dispersed camping in the 

Backcountry Zone, but only at designated sites, which 

would provide metal fire rings. Camping and campfires 

would be prohibited elsewhere in the Backcountry Zone, 

lessening the potential for damage to native vegetation 

and wildfires started from unattended campfires. 

Alternative C would prohibit this activity in the 

Backcountry Zone. These restrictions on dispersed 

camping could help to protect soils and native vegetation, 

lessening the potential for soil compaction or erosion 

and destruction of native vegetation. They could also 

minimize the potential for wildfires that are started by 

unattended campfires. 

Alternative D would authorize dispersed camping and 

campfires in the 14,248 acres of the Backcountry Zone. 

This could have long-term, moderate impacts on soils 

and vegetation, due to soil compaction, damage to native 

vegetation, and increased risk of wildfires. 

Alternatives A, B, and D propose to maintain or upgrade 

existing camping and day use facilities at the Red Cliffs 

Recreation Area within the NCA. Alternative B and D 

could authorize expansion of the existing facilities to accommodate demand. Expansion could remove additional 

native vegetation, resulting in a minor, but permanent, 

negative impact. Project design and consultations with 

USFWS would help to ensure that any new developments 

within the Recreation Area avoid impacts on habitats 

for Gila monsters, desert tortoise, Southwestern willow 

flycatcher, and western yellow-billed cuckoo. 

Alternative C would manage the Recreation Area only for 

day use, decommissioning the campsites and providing 

additional day use amenities and parking. Providing facilities for increased day use could negatively impact soils 

and vegetation, as higher numbers of visitors would use 

the designated trails of the Recreation Area, potentially 

increasing trail tread width and soil compaction. The 

elimination of overnight camping could reduce the potential for wildfires started by unattended campfires. 

Alternative A would continue to manage Sand Cove 

Primitive Camping Area under a no fee permit system; 

no amenities would be provided. Native vegetation and 

soils would continue to be impacted by unmanaged 

camping and parking use of the area by large groups, 

where no fire rings or sanitary facilities are provided. 

Alternatives B and D would develop camping facilities 

at Sand Cove Primitive Camping Area and continue to 

manage it under a permit system. Alternative B would 

include, but is not limited to, a marker delineating 

each campsite and a metal fire ring. In addition to this, 

Alternative D would add to this a vault toilet, a kiosk, 

and vehicle access improvements. Camping would be 

limited to 20 or 40 persons, under Alternatives B and 

D, respectively. These restrictions and amenities could 

help to protect soils and native vegetation, lessening the 

potential for special status species’ habitat degradation or 

loss. They could also minimize the potential for wildfires 

that are started by unattended campfires. 

Alternative C would eliminate camping in this area, providing the highest level of protection to soils, vegetation, 

and wildlife habitats, when compared to the 

other alternatives.

4.34.2.6 Impacts from Management of 

Comprehensive Travel and Transportation

The impacts or benefits on special status species’ habitats 

related to OHV area designations can be estimated by 

comparing the number of acres that are designated as 

Open, Limited to Existing Roads and Trails, Limited to 

Designated Roads and Trails, and Closed to motorized 

vehicle travel and uses through the RMP. Alternatives that 

close more acres to motorized travel would be expected to 

reduce the potential for vehicles to kill or injure wildlife 

and damage or degrade habitats. All alternatives propose 

OHV area designations for the NCA, with specific route 

designations to follow through BLM’s development of a 

TMP for Washington County. OHV area designations 

under all alternatives would designate all acres as either 

Closed or Limited to Designated Roads and Trails.

All alternatives would continue to manage the NCA 

as Closed to OHV use on 19,989 acres and Limited to 

Designated Roads and Trails on 24,870 acres. No acres 

would be managed as Open to Cross-country OHV use 

or Limited to Existing Roads and Trails.
788 Chapter 4 RCNCA RCNCA Chapter 4 789

SPECIAL STATUS SPECIES

All alternatives would result in moderate to major, short 

and long-term beneficial effects on special status species and BLM Sensitive Species, by managing motorized 

vehicles and other travel to avoid or minimize surface 

disturbances related to unauthorized cross-county travel 

and route proliferation and prevent injuries and mortalities to wildlife. Intact soil horizons, soil crusts, and 

vegetation communities would maintain the health of 

habitats for at-risk species. 

4.34.2.7 Impacts from Management of Lands and 

Realty

Under all alternatives, 19,989 acres in two designated wilderness areas would be managed as ROW Exclusion areas, protecting habitats for special status species and BLM 

Sensitive Species from development-related impacts. 

Alternative A would continue to manage 24,686 acres of 

the NCA as a ROW Avoidance area and two designated 

utility corridors (183), one along State Route 18 and one 

along I-15, would be carried forward. Unless specific criteria are met, new ROWs for utilities and transportation 

facilities would not be authorized in the Avoidance area. 

Special status species and BLM Sensitive Species’ habitats 

would be protected from impacts related to new developments within the Avoidance area.

Existing ROWs could be modified to allow for upgrades 

to existing power transmission lines, water lines, and 

associated facilities that could result in damage or loss of 

vegetation, adverse modification of critical habitat for the 

desert tortoise, and the potential for “take” of tortoise, as 

well as other terrestrial special status or BLM Sensitive 

Species. Avian and bat species could be injured or killed 

by new or upgraded power transmission lines. These impacts would be lessened to the maximum extent possible, 

through project design, BMPs, and terms and conditions of the ROW grants. Section 7 consultations with 

the USFWS would result in project-specific Biological 

Opinions that would provide Reasonable and Prudent 

Measures and Terms and Conditions to minimize the 

impacts on desert tortoise or other special status species 

that might be affected.

Alternative B would manage a total of 41,023 acres of the 

NCA as a ROW Exclusion area and would carry forward 

two designated utility corridors, one along State Route 18 

and one along I-15. Approximately 183 acres would continue to be managed as a ROW Avoidance area. Soils and 

native vegetation and species habitats would be protected 

from the impacts related to new ROW developments 

on more acres under this alternative, when compared to 

Alternative A. 

Existing ROWs could be modified to allow for upgrades 

to existing power transmission lines, water lines, and 

associated facilities that could result in damage or loss of 

vegetation, adverse modification of critical habitat for the 

desert tortoise, and the potential for “take” of tortoise, as 

well as other terrestrial special status or BLM Sensitive 

Species. Avian and bat species could be injured or killed 

by new or upgraded power transmission lines. These impacts would be lessened to the maximum extent possible 

through project design, BMPs, and terms and conditions of the ROW grants. Section 7 consultations with 

the USFWS would result in project-specific Biological 

Opinions that would provide Reasonable and Prudent 

Measures and Terms and Conditions to minimize the 

impacts on desert tortoise or other special status species 

that might be affected. 

Alternative C would manage a total of 44,808 acres of the 

NCA as a ROW Exclusion area, protecting soil and native 

vegetation from impacts related to new ROW developments. Under this alternative, the designated utility 

corridor along I-15 would be revoked through the NCA, 

providing additional protection to terrestrial and aquatic 

habitats for special status species and BLM Sensitive 

Species, including riparian habitat along Quail Creek, 

from impacts related to new ROW developments. 

Alternative D would manage 38,324 acres of the NCA as a 

ROW Exclusion area and carry forward the two designated utility corridors along State Route 18 and I-15 that total 

183 acres in size. New utilities could be developed under 

ROWs in either corridor, impacting soils and vegetation 

within these areas through the NCA. Existing ROWs 

could be modified to allow for upgrades to existing power 

transmission lines, water lines, and associated facilities that 

would result in the impacts described above. 

Alternative D would also designate a new utility and 

transportation corridor, totaling 6,350 acres in size, 

where new ROWs could be granted for the development 

of linear ROWs, such as power transmission lines, water 

and gas lines,-fiber-optic lines, and associated facilities, 

including access routes, as well as new site-type ROWs. A 

ROW could also be granted in this corridor for the construction of Washington County’s proposed “northern 

transportation route” multi-lane roadway. 

Development of new utilities and transportation facilities 

in this large corridor could result in damage or loss of 

vegetation, adverse modification of critical habitat for the 

SPECIAL STATUS SPECIES

desert tortoise, and the potential for “take” of tortoise. 

Approximately 4,281 acres of the 6,350 proposed new 

utility and transportation corridor are designated critical 

habitat for the threatened desert tortoise. Data collected 

by UDWR indicate that areas within the corridor that 

are below 1,200 meters in elevation and have less than 

45 degree of slope support average tortoise population 

densities of 16.5 tortoises/km2(UDWR 2011). Estimates 

of tortoise numbers in this area would range from 158 to 

208 tortoises that could be impacted by developments or 

construction within the proposed utility and transportation corridor, although this number could be substantially higher. 

The USFWS has defined designated critical habitat for 

the Mojave desert tortoise as consisting of five habitat-related Primary Constituent Elements (PCEs) that include 

the following attributes:

▶ sufficient quantity and quality of forage species and 

the proper soil conditions to provide for the growth 

of such species; 

▶ suitable substrates for burrowing, nesting, and 

overwintering; 

▶ burrows, caliche caves, and other shelter sites; 

▶ sufficient vegetation for shelter from temperature 

extremes and predators; and

▶ habitat protected from disturbance and humancaused mortality.

The new utility and transportation corridor proposed 

under Alternative D contains all five of the habitat-related PCEs. The sandstone layers in Industrial Wash and 

City Creek provide good opportunities for deep winter 

dens, as do the boulder fields along T-Bone Mesa. These 

areas are already known to contain a number of active 

dens. Where fires have not impacted areas within the 

proposed corridor, native vegetation provides shade and 

shelter for tortoises. 

Within the proposed new designated corridor area, 

below the 1200 meter contour, slightly more than half 

of the habitat has been damaged by recent wildfires. The 

remaining acreage of unburned habitat is now crucial 

to the survival of the tortoise populations, as it provides 

necessary shade, shelter, and intact native vegetation 

communities that better meet tortoise nutritional needs 

than do invasive annual grass species.

The development of new power transmission lines, 

water lines, site-type ROWs, and Washington County’s 

proposed “northern transportation route” multi-lane 

roadway could adversely modify the tortoise critical 

habitat by destroying dens and burrows, and native 

vegetation that provides shelter and nutrition. A new 

multi-lane roadway, constructed along any of the 

alternative alignments proposed by Washington County, 

would fragment habitat. Injuries and mortalities to 

tortoises during new utility developments or roadway 

construction could occur, as this area has some of the 

highest tortoise densities documented in the Upper 

Virgin River Recovery Unit.

Other BLM Sensitive Species have the potential to be 

located within the proposed 6,350 acre designated utility and transportation corridor. Chuckwalla, Mojave 

rattlesnake, Gila monster, sidewinder rattlesnakes, and 

zebra-tailed lizards are among the BLM Sensitive Species 

for which this area of the NCA would provide habitats. 

Utility developments or the construction of Washington 

County’s proposed “northern transportation route” would 

damage or destroy habitats for these reptiles and result in 

injuries and mortalities to these species. As none of these 

native species are currently listed under the protections 

of the ESA, there would be no legal requirements that 

impacts on these species be minimized or mitigated to 

the same degree as federally-listed species. As habitats for 

BLM Sensitive Species are managed to help prevent the 

need for listing under the ESA, the management of 6,534 

acres as designated utility and transportation corridors 

would result in short and long-term direct and indirect 

impacts that could contribute to observed declines in Gila 

monster and other Mojave Desert native reptile species. 

Should populations decline below viability levels, the Gila 

monster in Utah could require listing under the ESA.

Impacts on these resources would be lessened to the 

maximum extent possible for each project, through 

project design, BMPs, re-vegetation, and terms and conditions of the ROW grants. However, potential impacts 

on soils and vegetation from the designation of this new 

utility and transportation corridor, in concert with the 

183 acres included in existing designated corridors along 

State Route 18 and I-15 that would be carried forward, 

would be negative, major, short and long term. 

These impacts would be lessened to the maximum extent 

possible, through project design, BMPs, and terms and 

conditions of the ROW grants. Section 7 consultations with the USFWS would result in project-specific 

Biological Opinions that would provide Reasonable and 

Prudent Measures and Terms and Conditions to minimize the impacts on desert tortoise or other special status 

species that might be affected. 
790 Chapter 4 RCNCA RCNCA Chapter 4 791

SPECIAL STATUS SPECIES

Alternative D would include many of the same beneficial 

management aspects as Alternatives B and C, as they 

relate to the conservation, protection, and restoration of 

soils and native vegetation and more effective fire prevention and hazardous fuel reduction. 

Management decisions under this alternative related 

to Lands and Realty management would not meet the 

conservation, protection, and enhancement purpose of 

the NCA for ecological resources, including soils and 

vegetation. The designation of utility and transportation 

corridors, totaling 6,534 acres in size, would allow for 

development of new utilities and transportation systems, 

including Washington County’s proposed “northern 

transportation route”, under ROWs that could damage 

or destroy native vegetation within some or all of this 

acreage over the life of the RMP. Potential impacts on 

soils and vegetation from the designation of this new 

utility and transportation corridor, in concert with the 

183 acres included in existing designated corridors along 

State Route 18 and I-15 that would be carried forward, 

would be negative, major, short and long term on special 

status species and BLM Sensitive Species. The potential 

impacts on desert tortoise populations as a result of some 

level of adverse modification to as much as 4,281 acres of 

designated critical habitat could threaten the viability of 

tortoises in the Upper Virgin River Recovery Unit. 

4.34.3 Summary of Impacts from Alternatives

Alternative A would continue current management and 

provide moderate protection levels for soils and native 

vegetation and special status and BLM Sensitive Species’ 

habitats, through recreation and travel management 

under the PUP; management of 19,989 acres as a ROW 

Exclusion area and 24,686 acres as an Avoidance area for 

new ROWs.

Use of a systematic approach for resource management 

under Alternatives B and C would generally improve 

management for soils and vegetation. Fire and Fuels 

management under these alternatives would be more 

comprehensive and effective compared to Alternative 

A, potentially reducing the risk of catastrophic wildfire. 

Restoration of disturbed and damaged vegetation communities would strive to restore native species and control noxious weeds and invasive species, using the most 

appropriate and least invasive methods. Impacts from 

recreation uses would be reduced, as the BLM would 

develop professionally designed and sustainable trail 

systems and other facilities to protect resource values and 

provide for high-quality visitor experiences. 

Alternative D would include many of the same beneficial 

management aspects as Alternatives B and C, as they 

relate to the conservation, protection, and restoration of 

soils and native vegetation and more effective fire prevention and hazardous fuel reduction to protect habitats for 

at-risk species. 

Management decisions under this alternative related 

to Lands and Realty management would not meet the 

Congressional mandate that BLM “conserve, protect, 

and enhance” the resource values of the NCA, and in 

particular, all species listed under the protection of the 

ESA that occur in the NCA. The designation of utility and transportation corridors, totaling 6,534 acres in 

size, would allow for development of new utilities and 

transportation systems, including Washington County’s 

proposed “northern transportation route”, under ROWs 

that potentially jeopardize the continued existence of the 

threatened Mojave desert tortoise in the Upper Virgin 

River Recovery unit and reduce populations and habitats 

for other at-risk species. 

4.34.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on 

special status species and BLM Sensitive Species includes federal and non-federal lands in the St. George 

Basin and the Upper Virgin River Recovery Unit for the 

Mojave desert tortoise.

Past human actions within the CIAA, on federal, state, 

municipal, and private lands that have affected these 

resources include the expansion of cities and towns, the 

development of utilities, road and highway construction, 

mineral materials harvesting, mining, grazing by livestock, and vegetation treatments. These have resulted in 

the temporary and permanent loss of native vegetation 

and the erosion of soils. Other factors, such as prolonged 

droughts, wildfires, insects, and disease have also caused 

changes to native vegetation communities. Wildland 

fires remove vegetative cover, potentially accelerating soil 

erosion and the introduction and spread of weeds and 

invasive species. Drought conditions reduce vegetation 

health, which makes vegetation prone to insect infestation or disease. 

Public lands of the NCA today comprise 70% of the land 

base of the multi-jurisdictional Reserve, established as 

the key mitigation component of Washington County’s 

multi-species HCP, approved by the USFWS in 1995. The 

BLM, USFWS, State of Utah, Washington County, and 

the City of Ivins signed an Implementation Agreement 

for the HCP in 1996 that specified the obligations, 

OTHER FISH AND WILDLIFE SPECIES

responsibilities, and tasks of each of the land managing 

entities of the Reserve. The SGFO RMP (1999) supported 

the goals of the HCP through program-specific segregations, withdrawals, closures, and land use restrictions 

to protect critical habitat and populations of the Mojave 

desert tortoise and other at-risk species on the approximately 45,000 acres of BLM-managed public lands within 

the Reserve boundaries. 

The 62,000 acre Reserve includes designated critical 

habitat for the federally-listed threatened Mojave Desert 

tortoise, within the Upper Virgin River Recovery Unit. 

This recovery unit was identified as the smallest and most 

at-risk recovery unit within the Mojave desert tortoise’s 

range by the USFWS's Mojave Desert Tortoise Recovery 

Plan (1994, revised 2011). Management of the Reserve 

land base focuses on the protection of habitat and tortoise populations through restrictions on land uses and 

human activities. 

In 1996, Washington County was issued an Incidental 

Take Permit (ITP) authorizing the “take” of approximately 12,264 acres of non-federal lands in critical habitat 

and 1,169 tortoises, based on the commitments made 

through the HCP and Implementation Agreement. The 

ITP does not authorize the incidental take of tortoises 

or the adverse modification of critical habitat within the 

boundaries of the Reserve. Critical tortoise habitat has 

been adversely modified and tortoises have been “taken” 

on non-federal lands within the St. George Basin under 

the authority of the County’s ITP since its issuance. 

Critical tortoise habitat within the Reserve has been 

adversely modified by large wildfires that have burned 

approximately 30% of the land base and by small scale 

disturbances related to the upgrading of existing utilities; 

project-specific impacts to habitats have been mitigated 

through habitat re-vegetation efforts that have had limited success. Similarly, post-fire re-vegetation projects 

within the Reserve have not been successful at restoring 

native vegetation communities needed to help ensure the 

survival of desert tortoise. 

The designation of three utility and transportation corridors in the NCA, totaling 6,534 acres in size, could 

allow for the development of new utilities and roadways, 

including Washington County’s proposed “northern 

transportation route” highway, in the NCA and Reserve. 

The potential adverse modification of critical habitat and 

“take” of tortoise related to future developments in the 

designated corridors, in concert with the loss of habitat 

to developments and fire in the CIAA, could cumulatively jeopardize the survival of desert tortoises in the 

Upper Virgin River Recovery. As Washington County’s 

ITP does not authorize the incidental take of tortoises 

or the adverse modification of critical habitat within the 

boundaries of the Reserve, future utilities and transportation developments in the designated corridors through 

the NCA could impact the continued authorization of 

the ITP by the USFWS.

Climate change within the CIAA could cause an increase 

or decrease in temperatures and precipitation, which 

would affect soil conditions, vegetation distribution, 

water flows, water quality, and water temperature. Such 

changes would alter the conditions to which vegetation 

communities are adapted, potentially creating conditions 

that could favor certain species or communities, weeds, 

or pests., and further degrade suitable habitat for sensitive species.

4.35 OTHER FISH AND WILDLIFE SPECIES

This section discusses impacts on fish and wildlife from 

proposed management actions of other resources and 

resource uses described in Chapter 2. Existing conditions 

concerning fish and wildlife and descriptions of habitat 

requirements for various species are described in 

Section 3.33.

4.35.1 Methods of Analysis

Impacts to other fish and wildlife could result from management actions that diminish any of the fundamental 

components of fish and wildlife populations and/or habitat listed in the indicators section below. Beneficial effects 

could result from management actions that maintain or 

improve fish and wildlife populations and/or habitat. 

4.35.1.1 Indicators

Indicators of adverse impacts on fish or wildlife include 

changes to the following:

▶ Likelihood of habitat degradation or removal 

through changes to the vegetation communities and 

habitats upon which the fish and wildlife rely;

▶ Likelihood of habitat avoidance due to human presence or habitat alteration;

▶ Likelihood of interfering with a species movement 

patterns that decreases the ability of a species to 

breed or overwinter successfully to a degree that 

would lead to substantial population declines; and

▶ Likelihood of impacts on survival or reproduction to terrestrial species due to indirect effects of 

disruptive activities, such as increased duration or 

frequency of disruptive activities during key time 

periods where species’ fitness is affected. 
792 Chapter 4 RCNCA RCNCA Chapter 4 793

OTHER FISH AND WILDLIFE SPECIES

4.35.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance resource values in 

the NCA;

▶ Wildlife habitat needs vary substantially by species. It is generally true however, that healthy and 

sustainable wildlife populations can be supported 

where there is a diverse mix of plant communities 

with multiple seral stages to supply structure, forage, cover, and other specific habitat requirements. 

Managing for a diverse mix of plant communities 

is thus an important component of managing for a 

diversity of species;

▶ Habitat conditions and quality are directly linked to 

the health, vigor, and cover of vegetation communities, particularly desired native plant communities 

that fish and wildlife species depend on;

▶ Impacts on populations exceeding current carrying 

capacity that would not reduce those populations 

below carrying capacity would not be considered 

significant;

▶ Impacts on terrestrial wildlife from displacement 

depend on the location, extent, timing, or intensity 

of the disruptive activity. Furthermore, impacts 

from displacement would be greater for wildlife 

species that have limited habitat or a low tolerance 

for disturbance/disruption;

▶ Habitat would be managed in coordination with 

UDWR herd management objectives and speciesspecific management plans.

Implementing management actions for the following 

resources would have negligible or no impact on fish 

and wildlife and are therefore not discussed in detail: Air 

Quality, Water Resources, Geologic and Paleontological 

Resources, Cave and Karst Resources, Soil Resources, 

Vegetation Resource Uses: Plant Materials, Special Status 

Species, BLM Sensitive Species, Heritage Resources, 

ACECs, Visual Resource Management, Natural 

Soundscapes, Lands with Wilderness Characteristics, 

Public Education and Interpretation, and 

Scientific Research.

4.35.2 Direct and Indirect Impacts

This section focuses on the indicators listed above as a 

measure of the adverse impacts and beneficial effects that 

could result from the range of management alternatives 

identified in Chapter 2.

4.35.2.1 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Under all alternatives, the goals and objectives for the 

management of native vegetation communities are to 

conserve and protect areas from the negative impacts 

of wildfires and to restore damaged communities with 

desired species. Management actions address the need to 

minimize the loss of unburned and once-burned native 

vegetation, to maintain ecosystem and watershed functions, protect soils, and provide quality habitats for the 

fish and wildlife species of the NCA. 

All alternatives provide for the use of native plant species 

for restoration and rehabilitation. Use of native species 

would maintain the health and vitality of native vegetation communities could provide seed sources for restoration uses. Such actions would reduce the competitiveness 

of non-native annual grasses and potentially re-establish 

native bunchgrasses and broad-leaved forbs that were formerly important components of native vegetation communities in the NCA. These actions would help to restore 

quality habitats for all fish and wildlife species, providing 

adequate forage, cover, and breeding/nesting areas.

Alternatives A, B, and D would allow use of non-native 

species, but only under very specific conditions and with 

constraints that would prevent the introduction of species that have not been scientifically evaluated for use in 

the Mojave Desert. The use of non-native species could 

help stabilize soils and prevent erosion in the short term, 

and, in the long term, could assist the re-establishment 

of native species. However, there is a risk that the nonnative species could perpetuate and spread, altering 

native ecosystems and reducing the quality of biophysical 

settings for all wildlife. 

Alternative C would not allow the use of non-native species for re-vegetation projects and require the use of local 

native seeds and plant materials. Seed mixes would be 

tailored for ES&R projects to include more early successional species, include methods of protecting seeds from 

herbivory, and use hand or low impact methods of working seeds into the soil. This alternative could increase 

the chances of successful germination of seeds and the 

re-vegetation of native communities, when compared to 

other alternatives, because it would minimize damage 

to biological soil crusts that sustain soil productivity. If 

local native seeds and plant materials were not available, 

re-vegetation projects could not be undertaken, potentially allowing exotic invasive annuals to proliferate and 

prevent native species from re-establishing in the short 

and long term.

OTHER FISH AND WILDLIFE SPECIES

Under Alternatives B, C, and D, land uses that have the 

potential to impede the success of re-vegetation projects 

would be excluded from the project areas until project 

resource goals and objectives have been met. This would 

be a beneficial effect on wildlife habitats, furthering the 

likelihood that native vegetation communities could be 

restored in the long term.

Alternative A still includes a small role for the potential 

use of prescribed fire to achieve management objectives. 

Alternatives B, C, and D allow prescriptive fire as part of 

scientific studies. Prescriptive fires would have a negative 

impact on fish and wildlife habitats, resulting in increased acreage of fire-damaged habitat and possible injuries and mortalities of individuals. Burned areas would 

provide less thermal cover and significantly reduced 

forage for terrestrial species. Soil erosion would be higher 

on fire-damaged areas and could increase sedimentation 

to surface water sources, potentially affecting the quality 

of aquatic and riparian habitats that benefit many species 

of native fish and wildlife.

Under Alternatives B, C, and D, full suppression tactics 

would be employed to minimize fire size and duration, 

benefitting all wildlife, including those that occupy 

aquatic and riparian habitats. Wildfire use to achieve 

management objectives would not be authorized under any of these alternatives. The use of backburning 

would be carefully evaluated as a fire suppression tactic, 

to minimize the loss of unburned habitats and direct 

impacts, such as fire-caused injuries or mortalities, on 

wildlife species.

All alternatives identify a variety of methods that could 

be used to create fuel breaks and reduce hazardous levels 

of invasive annual grasses. These range from methods 

that would create extensive new surface disturbances, 

such as the use of heavy equipment under Alternative A, 

that would also damage or destroy native vegetation that 

benefit wildlife. Alternative C would employ hand tools 

and low impact methods, minimizing impacts to soils 

and native vegetation, maintaining habitats for wildlife 

while reducing some of the fire threat. Alternatives B 

and D would use the broadest array of methods, including herbicides, flaming, and targeted grazing to develop 

fuel breaks, potentially damaging larger areas of wildlife 

habitat in the short term, but potentially creating more 

effective, landscape level fuel breaks that would protect 

habitats in the long term. 

 The three action alternatives would provide higher 

levels of protection for fish and wildlife species and their 

habitats, by minimizing surface disturbances and fire effects, when compared to Alternative A.

4.35.2.2 Impacts from Management of Noxious 

Weeds and Invasive Species 

Noxious weeds and exotic invasive species alter the 

ecological characteristics of native vegetation communities and the quality of wildlife habitats. Under all alternatives, weed control would continue to be implemented, 

using an Integrated Weed Management approach and 

relevant standard operating procedures and mitigation 

measures presented in the Final Vegetation Treatments 

Using Herbicides on BLM Lands in 17 Western States 

Programmatic Environmental Impact Statement (PEIS) 

(BLM 2007). With proper implementation, weed treatment methods under all alternatives would eliminate or 

reduce infestations in the long term. 

Alternatives B, C, and D identify a variable range of tools 

to control noxious weeds and exotic invasive species, 

including the potential use of biological controls, under 

project-specific plans. Biological controls for invasive 

annual brome grasses are currently in the experimental 

stage and may never be applicable on a broad scale, even 

over the life of the RMP. 

Alternatives A, B, and D would also allow chemical 

control of noxious weeds and exotic invasive species in 

unburned vegetation communities. These could damage 

desired vegetation due to over-spray, improper herbicide 

selection or dosage, or improper timing of application. 

Alternatively, proper chemical control could reduce infestations, while preventing impacts on native species, if 

the chemicals are selected and used correctly.

Alternatives B and D would authorize the use of targeted 

grazing to control noxious weed and exotic invasive 

species and create fuel breaks in selected areas. Adverse 

impacts could include trampling and denuding of native 

vegetation, the introduction and spread of noxious weeds 

and exotic invasive species, soil compaction or accelerated erosion from hoof action. Positive effects from the 

use of targeted grazing could include the cost-effective 

reduction of noxious weeds and exotic invasive species, 

as well as creating fire breaks that would help to conserve 

and protect native vegetation communities.

4.35.2.3 Impacts from Management of Other Fish and 

Wildlife Species

Under all alternatives, new wildlife guzzlers or collection catchments could be developed, in collaboration 

with UDWR. These could provide a beneficial effect 

of diverse game and non-game species, by providing 
794 Chapter 4 RCNCA RCNCA Chapter 4 795

OTHER FISH AND WILDLIFE SPECIES

additional water sources. All alternatives would allow 

for the re-introduction, translocation and transplantation of priority native wildlife that could fill key niches to 

balance native ecosystems and would provide a beneficial 

effect on fish and wildlife habitat. New fencing projects 

would be required to meet specific design standards that 

allow safe passage by big game and other wildlife under 

all alternatives.

4.35.2.4 Impacts from Management of Recreation 

and Visitor Services

Alternative A would continue to manage the NCA within 

the Red Mountain/Santa Clara SRMA and the SGFO 

ERMA. The management of recreational activities and 

public uses would continue, as authorized through the 

implementation-level PUP. Non-motorized recreational 

uses in the Lowland Zone would continue to be on designated trails; off-trail travel would be authorized in the 

Upland Zone. Motorized vehicle travel would be Limited 

to Designated Roads, including the Babylon Road. 

Dispersed camping would continue to be limited to the 

two designated wilderness areas, the Upland Zone, and 

Sand Cove Primitive Camping area. The current management provides considerable protection to all wildlife 

species, as recreational activities authorized are primarily 

non-motorized and limited to designated trails, lessening the potential for disruptive effects on wildlife over a 

majority of the NCA.

Alternatives B, C, and D would not carry forward the 

existing SRMA and ERMA designations, but would 

establish the Red Cliffs SRMA to provide for high-quality 

visitor experiences. Management of the SRMA would 

include rules and guidelines to limit or control activities 

that could impact other NCA resource values through 

management tools such as designated campsites or group 

size limits. A Recreation Area Management Plan would 

be completed to identify authorized recreation and public uses for the SRMA; management decisions from the 

PUP for public lands would not be carried forward under 

these alternatives. 

Alternatives B, C, and D propose the development of a 

professionally-designed non-motorized trail system in 

the NCA, to provide high-quality experiences for diverse 

users, with trailheads and waysides that provide maps 

and interpretive information about the NCA purposes 

and values. This system would result in impacts on soils 

and native vegetation as a result of single-track trail construction that could be minor but permanent. Beneficial 

effects would be expected from the new trail system, as it 

would minimize the number of new social trails that are 

developed in the short and long term, protecting soil and 

vegetation that provides quality habitat for all wildlife. 

These alternatives also propose changes related to zoning 

of the NCA, through the establishment of four Recreation 

Management Zones to guide management of recreational 

uses. Dispersed camping would be prohibited in the Rural 

and Frontcountry Zones under the three alternatives. 

Alternatives B would allow dispersed camping only at 

designated sites in the Backcountry Zone and provide 

metal fire rings. Camping and campfires would be prohibited elsewhere in the Backcountry Zone, lessening the 

potential for damage to native vegetation and wildfires 

started from unattended campfires. These use restrictions 

would benefit wildlife by protecting habitat from impacts 

related to dispersed camping.

Alternative C would prohibit this activity in the 

Backcountry Zone. These restrictions on dispersed 

camping could help to protect soils and native vegetation, 

lessening the potential for soil compaction or erosion 

and destruction of native vegetation. They could also 

minimize the potential for wildfires that are started by 

unattended campfires. 

Alternative D would authorize walk-in camping and 

campfires in the 14,248 acres of Backcountry Zone. This 

could have long-term, moderate impacts to wildlife, as 

dispersed camping may cause some species to avoid areas 

of human activity. This activity could also increase the 

potential that habitats could be degraded by camping use 

or that wildfires could start from unattended campfires.

4.35.2.5 Impacts from Management of Lands and 

Realty

Under all alternatives, acquisitions of non-federal inholdings within the NCA from willing owners would 

be beneficial for native fish and wildlife. Acquired lands 

would be managed consistent with the Congressionallydefined purposes for the NCA and the goals, objectives, 

and management decisions from the approved NCA RMP; 

these decisions emphasize the conservation and protection 

of wildlife populations and their habitats.

Under all alternatives, 19,989 acres in two designated wilderness areas would be managed as ROW Exclusion areas, 

protecting habitats for wildlife from all developmentrelated impacts. 

Alternative A would continue to manage 24,686 acres of 

the NCA as a ROW Avoidance area and two designated 

utility corridors (183 acres), one along State Route 18 and 

one along I-15, would be carried forward. Unless specific 

OTHER FISH AND WILDLIFE SPECIES

criteria are met, new ROWs for utilities and transportation 

facilities would not be authorized in the Avoidance area. 

Habitats for diverse fish and wildlife species would be protected from impacts related to new developments within 

the Avoidance area.

Existing ROWs could be modified to allow for upgrades 

to existing power transmission lines, water lines, and 

associated facilities that could result in damage or loss 

of vegetation. Avian and bat species could be injured or 

killed by upgraded power transmission lines. These impacts would be lessened to the maximum extent possible, 

through project design, BMPs, and terms and conditions 

of the ROW grants. 

Alternative B would manage a total of 41,023 acres of the 

NCA as a ROW Exclusion area and would carry forward 

two designated utility corridors, one along State Route 18 

and one along I-15. Approximately 183 acres would continue to be managed as a ROW Avoidance area. Soils and 

native vegetation and species habitats would be protected 

from the impacts related to new ROWs development 

on more acres under this alternative, when compared to 

Alternative A. 

Alternative C would manage a total of 44,808 acres of the 

NCA as a ROW Exclusion area, protecting 24,870 acres 

of soil and native vegetation from impacts related to new 

ROW developments. Under this alternative, the designated 

utility corridor along I-15 would be revoked through the 

NCA, providing additional protection to terrestrial and 

aquatic habitats for other fish and wildlife, including riparian habitat along Quail Creek, from impacts related to new 

ROW developments. 

Alternative D would manage 38,324 acres of the NCA as a 

ROW Exclusion area and carry forward the two designated utility corridors along State Route 18 and I-15 that total 

183 acres in size. New utilities could be developed under 

ROWs in either corridor, impacting soils and vegetation 

within these areas through the NCA. Existing ROWs 

could be modified to allow for upgrades to existing power 

transmission lines, water lines, and associated facilities that 

would result in the impacts described above. 

Alternative D would also designate a new utility and 

transportation corridor, totaling 6,350 acres in size, 

where new ROWs could be granted for the development 

of linear ROWs, such as power transmission lines, water 

and gas lines, fiber-optic lines, and associated facilities, 

including access routes, as well as new site-type ROWs. A 

ROW could also be granted in this corridor for the construction of Washington County’s proposed “northern 

transportation route” multi-lane roadway. The development of new utilities and transportation facilities in this 

large corridor could result in damage or loss of habitat 

for other wildlife species, including crucial mule deer 

habitat. Access roads associated with the development 

of new utilities or a new highway could fragment habitat 

and disrupt the seasonal movements of deer, depending 

upon location of these facilities.

4.35.3 Summary of Impacts from Alternatives

Under Alternative A, native fish and wildlife populations and their habitats would continue to be managed in 

compliance with laws, regulations, and agency policies, 

and in furtherance of relevant UDWR management plans. 

Habitat degradation and loss to wildfires would continue, 

as this alternative does not emphasize full suppression of 

all wildfires and the development of large scale fuel breaks. 

Surface disturbances related to wildfires, livestock grazing at current levels in burned and unburned habitats and 

riparian areas, unmanaged dispersed camping, and other 

recreational activities would continue to degrade, fragment, or destroy habitats for some wildlife species. 

Management of the NCA to “conserve, protect, and enhance” a broad range of resource values under Alternatives 

B, C, and D would benefit fish and wildlife. Changes are 

proposed for those land uses, such as livestock grazing, 

recreation, and the granting of ROWs, to minimize negative impacts on the ecological values that comprise quality 

habitats for native species: native vegetation communities, 

soils, and water resources. The management of wildfires 

and hazardous fuels under the three action alternatives 

would be more comprehensive and effective, when compared to Alternative A, helping to lessen the threat that 

wildfires will continue to damage or destroy habitats and 

impact wildlife populations in the NCA.

Under Alternative C, the BLM would focus on resource 

protection by limiting land uses and authorized activities 

that have the potential to negatively impact native species 

and their habitats. Management would employ the least 

invasive tools and methods and emphasize the use of native vegetation to restore and improve habitats.

Under Alternatives B, C, and D, impacts on fish and 

wildlife populations and habitats would be minimized to 

the extent practical and feasible, through restrictions on 

uses and activities. Habitat conditions would be improved through treatments, weed prevention and control, 

and habitat improvements.
796 Chapter 4 RCNCA RCNCA Chapter 4 797

HERITAGE RESOURCES

4.35.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on native 

fish and wildlife populations includes lands within the 

NCA and adjacent federal lands managed by the USFS in 

the Pine Valley Ranger District.

Past human-caused actions within the CIAA, both on 

federal and non-federal lands, that have affected native fish and wildlife populations and habitats included 

overgrazing of rangelands during the late 19th and early 

20th centuries; the construction of utilities and roads; 

water developments and diversions; range improvements 

and vegetation treatments; and motorized and non-motorized recreational uses. In general, past human activities and land uses have cumulatively resulted in the loss, 

degradation, and fragmentation of habitats and some fish 

and wildlife population declines

Prolonged droughts, the introduction and spread of 

noxious weeds and exotic invasive species, and wildfires 

are natural factors that have also cumulatively impacted 

fish and wildlife populations and habitats. Many of these 

natural factors created conditions that caused or favored 

habitat changes. For example, wildfires removed vegetative cover and damaged soil crusts, leaving soils more 

susceptible to wind and water erosion and weed invasion. 

The “burn-reburn” fire cycle in areas of the CIAA has 

converted late successional shrubland communities into 

invasive brome grasslands that provide poor quality habitat for native wildlife. Drought conditions have reduced 

the health of native vegetation communities, making 

them more prone to insect infestations or disease. 

Future actions are likely to include increased efforts to 

control invasive annual brome grasses and wildfires, 

through landscape-wide fire breaks and fuel treatments 

in the CIAA. As ongoing research studies identify more 

effective and environmentally sustainable broad-scale 

treatment methods, it is likely that larger areas will be 

treated and efforts made to restore native vegetation 

communities, improving wildlife habitats. Land uses that 

have the potential to impact habitat restoration projects, 

would not be authorized in those areas, until resource 

objectives are met. Future listings of other native species 

under the ESA could also impose restrictions on other 

land uses determined to be detrimental to the recovery 

of listed species. These restrictions could benefit all native fish and wildlife species, by protecting habitats and 

minimizing impacts on populations related to land uses 

and human activities. 

Climate change within the CIAA could cause an increase 

or decrease in seasonal temperatures and precipitation, 

which would affect soil conditions, vegetation distribution, and surface water resources. Such changes would 

place some wildlife species at greater risk of population 

declines, particularly those species that cannot adapt to 

changed conditions or migrate to areas where habitat 

conditions are favorable.

4.36 HERITAGE RESOURCES

OPLMA Section 1974 (a) directs BLM to “conserve, 

protect, and enhance for the benefit and enjoyment of 

present and future generations” the cultural, historical, 

educational, and scientific resources of the Red Cliffs 

NCA. To satisfy this Congressional mandate, the goals 

and objectives of heritage resource management focus 

on: conserving and protecting sites and landscapes; promoting stewardship through public outreach and education; encouraging professional and academic research; 

facilitating Native American traditional uses; and engaging interested groups in these efforts.

This section analyses the effects on heritage resources 

that could result from the proposed management actions 

for other resources and land uses presented in the four 

alternatives described in Chapter 2. Current management and information on heritage resources that have 

been identified in the NCA are described in Chapter 3 at 

Section 3.34 Heritage Resources.

4.36.1 Methods of Analysis

Baseline data on heritage resources in the NCA was 

derived from literature reviews, Class II and III level field 

investigations, and consultations with Native Americans 

and other knowledgeable parties. These data are geographically biased toward past project-specific undertakings and may not accurately predict where and how 

many resources may exist in areas of the NCA where 

similar efforts to identify heritage resources have not 

yet been conducted. Given the incompleteness of the 

baseline data, this analysis generally does not attempt to 

precisely quantify affected resources.

The resulting analysis was based on an understanding 

of how land uses and authorized activities may affect 

heritage resources. Federal laws, implementing regulations, and other pertinent guidance (e.g., Secretary of the 

Interior Standards and Guidelines) relating to the determination of effects on heritage resources were considered 

and included in criteria for determining impacts. 

HERITAGE RESOURCES

4.36.1.1 Indicators

Indicators of adverse effects on heritage resources include 

the following:

▶ Extent to which surface-disturbing activities adversely affect integrity of heritage resources, or areas 

of importance to Native American or other traditional communities;

▶ Extent to which an action increases the potential for 

erosion or other natural processes to degrade the 

integrity of heritage resources over time;

▶ Extent to which an action reduces the availability 

of heritage resources for appropriate uses, including access to sacred sites or Traditional Cultural 

Properties by Native Americans.

Indicators of actions that generally benefit the conservation and protection of heritage resources:

▶ Measures that restrict or limit land uses and authorized activities that have the potential to adversely 

affect the NRHP-eligibility characteristics of historic 

properties; and

▶ Measures that preserve or improve the setting of 

a heritage resource, where setting contributes to 

the NRHP-eligibility characteristics of an historic 

property.

4.36.1.2 Assumptions

This analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance resource values in 

the NCA;

▶ Undertakings are defined as federal or federally- assisted actions and those requiring a federal permit, 

license, or approval;

▶ Federal regulations at 36 CFR 800, Section 106 of 

the NHPA, and the Utah Protocol will be applied 

for all undertakings; therefore, adverse effects on 

heritage resources would be avoided or appropriately mitigated. Impacts on heritage resources are 

assessed by applying the criteria of “adverse effect”, 

as defined in 36 CFR Part 800.5a: “An adverse effect 

is found when an action may alter the characteristics of a historic property that qualify it for inclusion in the NRHP in a manner that would diminish 

the integrity of the property’s location, design, setting, workmanship, feeling, or association. Adverse 

effects may include reasonably foreseeable effects 

caused by the action that may occur later in time, be 

farther removed in distance, or be cumulative”;

▶ Native Americans or other traditional communities 

may have concerns about potential impacts on heritage resources, sacred sites, or Traditional Cultural 

Properties. There may be areas of importance to 

contemporary Native Americans that are not readily 

identifiable outside of those communities. These 

concerns would be identified and resolved through 

appropriate levels of consultation required by law, 

regulations, and agency policies.

Implementing management actions for the following 

resources would have no impact or negligible impacts 

on heritage resources and are, therefore, not discussed in 

detail: Air Quality, Soil Resources, Vegetation Resource 

Uses: Livestock Grazing, Vegetation Resource Uses: Plant 

Materials; Special Status Species, BLM Sensitive Species, 

Other Fish and Wildlife Species, Wilderness, ACECs, and 

Natural Soundscapes.

4.36.2 Direct and Indirect Impacts

Compliance with the requirements of Section 106 of the 

NHPA would continue under all alternatives and would 

include efforts to identify heritage resources and evaluate 

these resources for NHRP eligibility. Should the identification of NRHP listed or eligible properties occur as a result of a proposed undertaking, adverse effects to historic 

properties would be assessed and avoided or appropriately mitigated. Natural processes, including wildfires, 

erosion, weed infestations and drought, could continue 

to have impacts on the integrity of heritage resources, 

under all alternatives. 

4.36.2.1 Impacts from Management of Water 

Resources and Soil Resources

Under all alternatives, management goals strive to protect water resources through land use restrictions, BMPs, 

and site-specific mitigation measures that maintain soil 

stability, minimize erosion, and protect water quality. 

Management actions related to achieving these goals 

could provide direct or indirect protections to heritage 

resources, as high densities of sites are typically located 

within close proximity of water sources in arid lands. 

Springs and other water sources are also often identified 

by Native Americans as being sacred places and of traditional cultural importance.

Restrictions on land uses and authorized activities that 

could create erosion in the vicinity of water sources could 

directly or indirectly protect the integrity of site assemblages, surface architectural features, and buried stratified cultural deposits and preclude the loss of scientific 

information. Actions that protect natural water sources 
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could help preserve resources of traditional cultural importance to Native Americans. 

4.36.2.2 Impacts from Management of Geologic and 

Paleontological Resources

Alternative A identifies generalized goals for the management of paleontological resources that include 

providing opportunities for scientific research and 

managing and interpreting specific fossil localities for 

public education. No specific Use Allocations are made 

for paleontological localities or outstanding geological 

features under this alternative. 

Alternatives B, C, and D allocate paleontological resources to three Use Allocations that are consistent with 

the mandates for the NCA from OPLMA. Alternatives B 

and D allocate paleontological resources to Scientific Use, 

Conservation for Future Use, and Public Use. Alternative 

C would limit these allocations to Scientific Use and 

Conservation for Future Use. Measures to protect paleontological localities of scientific interest and outstanding geologic resources include restrictions on the use of 

mechanized equipment for field studies and specimen 

collection and minimizing the potential for inadvertent 

impacts on heritage resources within the general vicinity 

of these activities.

Alternative A allows for the continued collection of petrified (silicified) wood on public lands, as long as collection complies with federal regulations at CFR 3622 and 

is limited to 250 pounds per person per year for personal 

use. However, this alternative does not explicitly define 

the methods that can be used to collect specimens or the 

locations where petrified wood collection is allowed. If 

collection occurs within archaeological sites or extensive 

surface disturbances are created during this activity, the 

impacts on heritage resources could range from negligible to major. 

Alternatives B and C would prohibit the collection of 

common invertebrate fossils and petrified wood for 

commercial and personal use in the NCA, reducing the 

likelihood that archaeological materials could be inadvertently collected or that surface disturbing collection 

activities could impact the integrity and data potential of 

heritage resources.

Alternatives A and D allow for casual collection of rocks 

and minerals and recreational collecting of common 

invertebrate fossils, making the risk for surface disturbances and unauthorized collection at archaeological 

sites greater under these alternatives.

Alternatives B and D authorize the use of hand tools for 

fossil specimen collection by researchers with valid NCA 

scientific research permits and BLM paleontological resource use permits. These alternatives would also evaluate the use of mechanized equipment for this purpose, 

on a case-by-case and site- specific basis. As specimen 

collection activities would be a federally-authorized 

activity, regulations at 36 CFR 800, Section 106 of the 

NHPA, and the Utah Protocol would be applied and 

adverse effects on historic properties within the “area of 

potential effect (APE)” of the activity would be avoided 

or appropriately mitigated. 

Under Alternative C, field investigations and collection 

of fossil specimens would be restricted to the use of hand 

tools. This alternative would generally minimize the potential for adverse effects to heritage resources related to 

these activities, as would compliance with the above-referenced federal laws, regulations, and the Utah Protocol. 

4.36.2.3 Impacts from Management of Cave and Karst 

Resources

Alternative A provides no specific goals, objectives, or 

management actions related to the management of caves 

and karsts in the NCA. Potential impacts on heritage 

resources would continue at current or higher levels 

as a consequence of a lack of baseline data about cave 

resources and no systematic management strategies for 

cave and karst resources. 

Alternatives B, C, and D would initiate systematic inventories of high potential geologic formations to identify 

caves and karsts in the NCA and evaluate them for significance under the FCRPA. As caves may contain cultural 

resources, including rock art, artifacts, biological materials, and buried stratified cultural deposits, this inventory 

could increase the database on heritage resources in the 

NCA and assist with the development of management 

plans to ensure that these heritage resources are appropriately conserved and protected.

4.36.2.4 Impacts from Management of Native 

Vegetation Communities, Fire and Fuels, and Noxious 

Weeds and Invasive Species

All alternatives would strive to conserve, protect, and 

restore native vegetation communities, through direct 

management actions to reduce the threat of wildfires, as 

well as restrictions on land uses and authorized activities. 

These goals would be compatible with heritage resource 

preservation, particularly as they relate to maintaining 

the integrity of setting for site types for which it contributes to NRHP eligibility. All alternatives propose the 

HERITAGE RESOURCES

control and eventual eradication of noxious weeds and 

invasive species. Reductions in invasive annual brome 

grasses that fuel wildfires in the NCA could lessen the 

potential for adverse effects to fire-susceptible heritage 

resources, such as wooden structures. 

Under Alternative A, the development of fire breaks, 

hazardous fuel reduction projects, and vegetation type 

conversions projects could be authorized, on a caseby-case basis. These could be accomplished through 

prescriptive fires and ground-disturbing mechanical 

vegetation treatments, with both methods having the 

potential to damage heritage resources. Compliance with 

the requirements of Section 106 of the NHPA would 

continue under this alternative and would include efforts 

to identify heritage resources within the project areas and 

evaluate these resources for NHRP eligibility. Should the 

identification of historic properties occur as a result of 

undertakings proposed by BLM or others, adverse effects 

would be assessed and avoided or mitigated. 

Alternative B, C, and D also propose the development 

of fire breaks and hazardous fuel reduction projects to 

protect intact native vegetation communities and wildlife habitats. Prescriptive fires, fire use, and vegetation 

conversions would not be authorized under any of the 

three alternatives. Alternatives B, and D would authorize 

a range of tools, including herbicides, targeted grazing, 

and mechanized equipment. Mechanical, biological, 

and chemical treatments could adversely affect heritage 

resources, altering the spatial relationships of surface assemblages and damaging artifacts. Chemical treatments 

could alter the chemistry of soils thereby affecting the 

reliability of radiocarbon or other dating methods and 

artifact residue analysis. 

Alternative C emphasizes the least invasive methods to 

accomplish these projects and would be the most protective of heritage resources, through the minimization 

of surface disturbances. As these projects would all be 

federal undertakings, adverse effects to historic properties would be avoided or appropriate mitigation measures 

developed through consultations under Section 106 of 

the NHPA. Adverse effects to the integrity of the site 

settings would also be avoided or appropriate mitigation measures developed, through consultations under 

Section 106 of the NHPA.

Alternatives B, C, and D identify a range of management 

actions and tools to restore disturbed and fire-damaged 

areas of the NCA, through re-vegetation projects. 

Alternatives B and D, as well as Alternative A, would emphasize the use of native species, but provide for the use 

of non-native species, when certain criteria are met. Only 

Alternative C would not authorize the use of non-native 

plant species and would, therefore, maintain or restore 

the integrity of natural settings where these have been 

lost to surface disturbances, wildfires, and the invasion of 

exotic annual brome grasses.

Wildfires could continue to negatively impact the conservation and protection of heritage resources, by destroying 

native vegetation and increasing soil and water erosion. 

Under all alternatives, all fires would be fully and quickly 

suppressed to limit fire size and minimize damage to 

fire-susceptible resource values. Alternatives B, C, and 

D would require that the fire suppression technique of 

backburning be minimized or avoided entirely, to lessen 

the loss of native vegetation communities to fire suppression actions wherever possible.

 The use of heavy equipment, backburning, and other 

tactics employed during fire suppression could create 

new surface disturbances and loss of native vegetation 

that could negatively affect heritage resources. The potential for damage or loss of sites would be lessened by the 

use of qualified archaeological Resource Advisors during 

fire suppression, but adverse effects could result from the 

need to take immediate actions to minimize the size of 

fires, while still protecting human life and property. The 

potential impacts on heritage resources related to wildfires and fire suppression actions would be mitigated to 

the maximum extent possible, through ES&R actions to 

stabilize soils and restore native vegetation in the short 

and long term. 

4.36.2.5 Impacts from Management of Heritage 

Resources

Congressionally-mandated segregations (OPLMA 

Section 1974) were made when the Red Cliffs NCA was 

designated in 2009 that directly benefit the conservation and protection of heritage resources. These include 

segregating (withdrawing) the public lands of the NCA 

from entry, appropriation, and disposal under the public 

land laws; location, entry, and patenting under the mining laws; and operation of the mineral leasing, mineral 

materials, and geothermal leasing laws, subject to valid 

existing rights. These segregations lessen the potential for 

heritage resource impacts related to sale, transfer or exchange of lands from federal ownership, mining, mineral 

materials sales, as well as oil, gas, and geothermal leasing 

and development. 

Through land use planning, BLM allocates heritage resources into one of six use categories, according to their 
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nature and relative preservation value. Each category 

has corresponding management actions and desired 

outcomes. As examples, sites allocated to Scientific Use 

are managed as available for appropriate research, with 

the desired outcome to be to preserve the resource until 

research or data collection is conducted. Under the 

Conservation for Future Use category, protective measures are implemented to preserve the resource until the 

conditions for use are met. The management action for 

resources allocated to the Traditional Use category would 

be tribal consultation and determination of limitations 

to achieve long term preservation. The management 

action for resources allocated to the Public Use category 

would be to determine permitted uses, and the desired 

outcome would be long-term preservation and on-site 

interpretation. In the Experimental Use category, the corresponding management action would be to determine 

the nature of the experiment and the desired outcome 

would be to protect the resource until it is used. Lastly, 

for resources placed in the Discharge from Management 

category allocation, the management action would be 

to remove protective measures and the desired outcome 

would be no use after recordation, and the resource 

would not be preserved.

Alternative A identifies generalized goals for the management of cultural resources that include protection of 

resource values, providing opportunities for scientific 

research and volunteer site stewardship, for the management and interpretation of sites for public education. No 

specific Use Allocations are made for specific site types in 

this alternative. 

Under Alternatives B, C, and D, heritage resources currently documented or projected to occur in the NCA, are 

designated to four of the six Use Allocations: Scientific 

Use, Conservation for Future Use, Public Use, and 

Traditional Use. These allocations are consistent with the 

conservation, protection, and enhancement purposes for 

which the NCA was Congressionally-designated, through 

OPLMA. Eligible sites or groups of sites would be nominated for inclusion to the NRHP, whenever warranted. The 

integrity of setting and place for cultural landscapes would 

be conserved, protected, and restored, wherever feasible.

Management actions are identified for specific site types 

under each Use Allocation to minimize threats and meet 

long-term conservation goals, through implementationlevel management plans, regulatory signing, physical barriers, site monitoring, restrictions on authorized activities 

and land uses, and public education. 

The Use Allocation to Public Use would enhance opportunities for public education and enjoyment of heritage 

resources, through the identification of appropriate sites 

for interpretation and public visitation. For sites identified as appropriate for Public Use, implementation-level 

plans would identify opportunities for on and off-site 

interpretation, visitor registers, informational and 

directional signing, and other visitor amenities. Class 

III intensive archaeological field inventories would be 

conducted prior to the management of a specific site 

for Public Use, to identify and assess potential effects to 

other heritage properties that may be in close proximity 

related to public visitation.

Under the alternatives, three Heritage Areas are proposed for management to protect heritage resources that 

embody distinctive aspects of regional cultural history. 

Under Alternative C, the approximately 1,196-acre 

Yellow Knolls Heritage Area would be managed to protect the integrity of setting and place of sites containing 

prehistoric rock art and tangible evidence of the subsistence strategies and resource procurement activities of 

Archaic, Formative, and Proto-historic Period groups. 

Proposed management of the Heritage Area would be 

protective of heritage resources and associated settings 

through management under VRM Class II and a ROW 

Exclusion area. Recreation use would be limited to nonmotorized activities on designated trails and limited to 

day use. Off-site interpretation could be developed at 

wayside exhibits located along the non-motorized Yellow 

Knolls Trail system.

Alternatives A, B, and C propose management of the 

approximately 787-acre White Reef Heritage Area to 

maintain and protect the integrity of the historic landscape and sites and features related to the mid-19th 

Mormon settlement at Harrisburg and silver mining 

in the Harrisburg/Silver Reef District. The proposed 

Heritage Area would be located within the Red Cliffs 

Recreation Area, an Expanded Amenity Fee area. 

Management actions would manage the Heritage Area as 

a ROW Exclusion area, under VRM Class II, for day use 

and non-motorized recreation on designated trails. On 

and off-site interpretation could be developed at wayside 

exhibits along the non-motorized White Reef trail system 

to increase public awareness and appreciation of the heritage resources preserved within this historic landscape. 

Under Alternatives A, B, and C, approximately 1,028 

acres of the NCA would be managed as the Babylon 

Heritage Corridor to protect significant vertebrate and 

plant fossil localities, rock art sites, and historic roads, 

HERITAGE RESOURCES

structures, and features related to 19th century silver mining and milling in the Harrisburg/Silver Reef 

District. The Heritage Area would be managed as a ROW 

Exclusion area, under VRM Class II, and all motorized 

OHV use would be Limited to Designated Roads and 

Trails. On and off-site interpretation could be developed, 

including at wayside exhibits along the Babylon Road, to 

increase public awareness and appreciation of the heritage resources preserved within this historic landscape. 

Alternatives B, C, and D would promote opportunities for 

volunteer involvement in Site Stewardship and Docent 

programs that increase public awareness of the need to 

conserve and protect heritage resources. Efforts would 

be made to recruit and train youth and veteran groups, 

citizen stewards, and other volunteers to participate in 

site clean-up and restoration, as well as archaeological 

inventory and data recovery projects that enhance public 

understanding of NCA and regional heritage resources. 

4.36.2.6 Impacts from Management of Visual 

Resources

Visual resource management has the potential to impact the natural scenic qualities of cultural landscapes 

and the integrity of the setting for heritage resources. 

Management under VRM classes that restrict the level 

of change to the characteristic landscape can benefit all 

heritage resources, by limiting the types of facilities that 

can be developed within that landscape and the nature 

and extent of land uses and authorized activities that 

have the potential to impair visual resources. 

Alternative A would manage 19,989 acres within the 

Cottonwood Canyon and Red Mountain Wilderness 

areas as VRM Class I. Approximately 24,870 acres of the 

NCA would continue to be managed as VRM Class III. 

Under this VRM management class, power transmission 

lines, vegetation treatments, and other activities that alter 

the character of the landscape and have the potential to 

adversely impact heritage resources could be authorized. 

The effects on the integrity of the setting heritage resources could be adverse and long term. Adverse effects 

could also result to historic properties within the APE for 

proposed developments and surface disturbing projects. 

These would be avoided or lessened to the maximum extent possible, through project design and other measures 

developed through Section 106 consultations.

Alternative B would manage 19,989 acres as VRM 

Class I; 21,034 acres as VRM Class II, 3,652 acres as 

VRM Class III, and 184 acres as Class IV. Compared 

to Alternative A, management under this classification 

would provide a higher level to cultural landscapes and 

the integrity of setting for heritage resources and minimize the potential for adverse, project-related effects to 

historic properties, by limiting the types of developments 

and actions that could occur within the NCA. 

Alternative C would manage 21,574 acres of the NCA 

as VRM Class I and 23,285 acres as VRM Class II. VRM 

Class I management would be the most protective of the 

scenic qualities of the NCA and afford the highest level 

of protection to cultural landscapes and the integrity of 

heritage resource settings. The types of developments 

and actions that could occur within the NCA would be 

very limited under this alternative, protecting all heritage 

resources from project-specific impacts. 

Alternative D would manage 19,989 acres as VRM Class 

I; 18,336 acres as VRM Class II and 6,534 acres as VRM 

Class IV. Acreages identified for VRM Class IV management would be located within existing and proposed 

utility and transportation corridors where the potential 

development of new power transmission lines, water 

lines, site-type ROWs, and Washington County’s proposed “northern transportation route” multi-lane road 

could impact visual resources and result in long-term 

adverse effects to historic properties within projectspecific APEs. This alternative would provide the lowest 

level of protections to heritage resources from visual 

resource management.

4.36.2.7 Impacts from Management of Lands with 

Wilderness Characteristics

Protections afforded by the management measures for 

lands with wilderness characteristics would provide 

protections for cultural resources. Management measures 

include surface use and ground disturbance restrictions, 

prohibitions on motorized uses, VRM classifications, and 

other restrictions on incompatible activities.

Under Alternatives A, B, and D, heritage resources would 

not realize protective benefits from management of lands 

with wilderness characteristics, because no acres within 

the NCA are proposed for management to specifically 

protect wilderness characteristics. Alternative C proposes to protect 1,586 acres of the NCA for their wilderness characteristics through management under VRM 

Class I, as an Exclusion area for new linear and site-type 

ROWs, and as a closed area to cross-country OHV travel. 

Management under Alternative C would afford the highest 

level of protection for heritage resources, when compared 

to the other alternatives, by restricting land uses and activities that may damage or destroy these resources.
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4.36.2.8 Impacts from Management of Recreation 

and Visitor Services

Greater public awareness of the Congressional designation of the NCA, in concert with local and regional 

population growth, is anticipated to attract more recreational users to the NCA. The impacts of recreation 

activities on heritage resources would vary, depending 

on the intensity and extent of surface disturbances that 

result from the activity. Dispersed camping, off-trail 

horseback riding or mountain biking, and cross-country 

OHV travel would be examples of recreation uses that 

could damage or destroy the integrity and information 

potential of heritage resources. Increased public access to 

certain site types, such as sites with standing architectural 

structures, can inadvertently damage these resources, as 

visitors collapse walls attempting to take photographs 

or disturb surface artifacts. The potential for vandalism 

and unauthorized collection of artifacts from sites can 

be linked to increased recreational activities or improved 

public access

Management of the NCA would conserve, protect, and 

enhance sustainable public recreation opportunities, as 

this was one of the purposes for which the NCA received 

Congressional designation. Recreation would be primarily dispersed in nature and include hiking, mountain 

biking, rock climbing, equestrian trail riding, OHV riding, hunting, and nature viewing and photography. Some 

commercial, competitive, and organized group activities 

could also be authorized.

Poorly constructed or maintained hiking, mountain bike, 

and equestrian trails have the potential to disturb soils, 

damage soil crusts and damage or destroy vegetation, as 

they contribute to the development of unauthorized “social” trails and trail braiding. These, in turn, create new 

soils and vegetation disturbances that increase erosion. 

Dispersed camping can create similar impacts.

Alternative A would continue to manage the NCA within the Red Mountain/Santa Clara SRMA and the SGFO 

ERMA for dispersed recreation uses that generally do 

not include developments or facilities. The management 

of recreational activities and public uses would continue, 

as authorized through the implementation-level PUP for 

the Reserve. 

Non-motorized recreational uses in the Lowland Zone 

would continue to be on designated trails; off-trail travel 

would be authorized in the Upland Zone. Motorized vehicle travel would be Limited to Designated Roads, including the Babylon Road. Dispersed camping would continue 

to be limited to the two designated wilderness areas, the 

Upland Zone, and Sand Cove Primitive Camping Area. 

Alternatives B, C, and D would not carry forward the 

existing SRMA and ERMA designations, but would 

establish the Red Cliffs SRMA to provide for high-quality 

visitor experiences. Management of the SRMA would 

include rules and guidelines to limit or control activities 

that could impact other NCA resource values through 

management tools such as designated campsites or group 

size limits. A Recreation Area Management Plan would 

be completed to identify authorized recreation and public uses for the SRMA; management decisions from the 

PUP for public lands would not be carried forward under 

these alternatives. 

Alternatives B, C, and D propose the development of a 

professionally-designed non-motorized trail system in 

the NCA, to provide high-quality experiences for diverse 

users, with trailheads and waysides that provide maps 

and interpretive information about the NCA purposes 

and values. This trail system would result in impacts 

on soils and native vegetation, as a result of some new 

single-track trail construction 

Beneficial effects would be expected from the new trail 

system, as it would minimize the number of new social 

trails that are developed in the short and long term, protecting heritage resources from the negative effects of soil 

compaction or erosion and disturbances to architectural 

features and surface artifact assemblages. 

These alternatives also propose changes related to zoning 

of the NCA, through the establishment of four Recreation 

Management Zones to guide management of recreational 

uses. Dispersed camping would be prohibited in the Rural 

and Frontcountry Zones under the three alternatives. 

Alternatives B would allow dispersed camping in the 

Backcountry Zone only at designated sites, and provide metal fire rings. Camping and campfires would be 

prohibited elsewhere in the Backcountry Zone, lessening 

the potential for damage to heritage resources from soil 

compaction or erosion and disturbances to architectural 

features and surface artifact assemblages. The risk of site 

damages or loss from unattended campfires would be 

lessened under this alternative. 

Alternative C would prohibit this activity in the 

Backcountry Zone, providing the highest level of protection for heritage resources that could result from dispersed camping. 

Alternative D would authorize walk-in camping and 

campfires in the 14,248 acres of Backcountry Zone. This 

HERITAGE RESOURCES

could have long-term, minor to moderate impacts on 

heritage resources from soil compaction or erosion and 

disturbances to architectural features and surface artifact assemblages. Compliance with the requirements of 

Section 106 of the NHPA would include efforts to heritage resources within the project areas and evaluate these 

resources for NHRP eligibility. Should the identification 

of historic properties occur as a result of undertakings 

proposed by BLM or others, adverse effects would be assessed and avoided or mitigated. 

Alternative A would continue to manage at Sand Cove 

Primitive Camping Area under a no fee permit system; 

no amenities would be provided. As yet undiscovered 

heritage resources could continue to be impacted by 

unmanaged camping and parking by large groups, where 

no fire rings or sanitary facilities are provided. 

Alternatives B and D would develop camping facilities at 

Sand Cove Primitive Camping Area and continue to manage it under a permit system. Vault toilets, fire rings, and 

other amenities would be provided and camping limited 

to 20 or 40 persons, under Alternatives B and D, respectively. These restrictions and amenities could help to protect heritage resources, by developing designed facilities, 

locating them to avoid adverse effects on historic properties, and limiting the size of groups that use the area.

Alternative C would eliminate camping in this area, providing the highest level of protection to heritage resource, 

when compared to the other alternatives.

Compliance with the requirements of Section 106 of the 

NHPA would include efforts to heritage resources within 

the project areas and evaluate these resources for NHRP 

eligibility. Should the identification of historic properties 

occur as a result of undertakings proposed by BLM or 

others, adverse effects would be assessed and avoided 

or mitigated. 

The types and numbers of SRPs would be more intensively managed under these alternatives, when compared 

to Alternative A. The prohibitions and limitations on 

recreation uses and SRPs identified in the three action 

alternatives would lessen the potential for direct, indirect, 

and inadvertent impacts on the integrity and scientific 

information potential of heritage resources.

4.36.2.9 Impacts from Management of 

Comprehensive Travel and Transportation

The impacts or benefits to heritage resources related to 

OHV area designations can be estimated by comparing the number of acres that are designated as Open, 

Limited, and Closed to motorized vehicle travel and uses 

through the RMP. Alternatives that close more acres 

to motorized travel would be expected to reduce the 

potential for negative impacts on the integrity of sites 

and associated settings. All alternatives propose identical 

OHV area designations for the NCA, with specific route 

designations to follow through BLM’s development of a 

TMP for the St. George Field Office. 

All alternatives would manage 19,989 acres as Closed to 

OHV use, 24,870 acres as Limited to Designated Roads 

and Trails, and no acres would be managed as Open to 

Cross County OHV use or Limited to Existing Roads 

and Trails.

All alternatives would result in moderate to major, short 

and long-term beneficial effects on heritage resources 

and cultural settings, by managing motorized vehicles 

and other travel to avoid or minimize surface disturbances related to unauthorized cross-country travel and 

route proliferation.

4.36.2.10 Impacts from Management of Lands and 

Realty

As a result of Congressional designation of the NCA in 

2009, all alternatives now require that public lands in the 

NCA be retained in federal ownership. Federal historic 

preservation laws would be applied to all undertakings 

within the NCA, requiring that adverse effects on NRHPlisted or eligible properties be assessed, avoided, or appropriately mitigated. Federal ownership would provide a 

major and positive benefit to the long-term conservation 

and protection of heritage resources. Under all alternatives, non-federal inholding within the NCA could be 

acquired and managed to conserve, protect, and enhance 

the cultural and historical values of the acquired lands. 

Under all alternatives, 19,989 acres in two designated 

wilderness areas would be managed as ROW Exclusion 

areas, providing the highest level of protection for heritage 

resources based on the limitations of land uses and authorized activities required to protect wilderness character. 

Alternative A would continue to manage 24,686 acres of 

the NCA as a ROW Avoidance area and two designated 

utility corridors, totaling 183 acres, with one along State 

Route 18 and one along I-15, carried forward. Unless 

specific criteria are met, new ROWS for utilities and 

transportation facilities would not be authorized in the 

Avoidance area. Heritage resources would be protected 

from impacts related to new developments within the 

Avoidance area.

Existing ROWs could be modified, both within and 

outside of the designated corridors and in the ROW 
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Avoidance area, to allow for upgrades to existing power 

transmission lines, water lines, and associated facilities 

that could result in adverse effects to historic properties 

and cultural landscapes. These impacts would be lessened to the maximum extent possible, through project 

design, BMPs, and terms and conditions of the ROW 

grants. Compliance with the requirements of Section 106 

of the NHPA would include efforts to heritage resources 

within the project areas and evaluate these resources for 

NHRP eligibility. Should the identification of historic 

properties occur as a result of undertakings proposed 

by BLM or others, adverse effects would be assessed and 

avoided or mitigated. 

Alternative B would manage a total of 41, 023 acres of 

the NCA as a ROW Exclusion area and would carry 

forward two designated utility corridors, one along State 

Route 18 and one along I-15 (183 acres). Approximately 

3,652 acres would continue to be managed as a ROW 

Avoidance area. Heritage resources and settings would 

be protected from the impacts related to new ROW 

developments on more acres under this alternative, when 

compared to Alternative A. 

Existing ROWs could be modified, both within the 

designated corridors and outside in the proposed ROW 

Exclusion area, to allow for upgrades. Compliance with 

the requirements of Section 106 of the NHPA would include efforts to heritage resources within the project areas 

and evaluate these resources for NHRP eligibility. Should 

the identification of historic properties occur as a result 

of undertakings proposed by BLM or others, adverse effects would be assessed and avoided or mitigated. 

Alternative C would manage a total of 44,808 acres of 

the NCA as a ROW Exclusion area, protecting heritage 

resources from impacts related to new ROW developments. Under this alternative, the designated utility 

corridor along State Route 18 would be retained (50 

acres) but the designated corridor along I-15 would be 

revoked through the NCA (133 acres), protecting heritage resources, including the historic Orson B. Adams 

farmstead and the 19th century agrarian landscape of 

Harrisburg, from visual impacts to the integrity of the 

setting of the property and associated landscape related 

to new ROW developments. 

Alternative D would manage 38,324 acres of the NCA as 

a ROW Exclusion area, and carry forward the two designated utility corridors along State Route 18 and I-15 that 

total 183 acres in size. New utilities could be developed 

under ROWs in either corridor, potentially impacting 

historic properties within the corridors. Existing ROWs 

could be modified within and outside of the designated 

corridors to allow for upgrades to existing power transmission lines, water lines, and associated facilities that 

would result in adverse effects to historic properties, as 

described above. Compliance with the requirements of 

Section 106 of the NHPA would include efforts to heritage resources within the project areas and evaluate these 

resources for NHRP eligibility. Should the identification 

of historic properties occur as a result of undertakings 

proposed by BLM or others, adverse effects would be assessed and avoided or mitigated. 

Alternative D would also designate a new utility and 

transportation corridor, approximately 6,350 acres in 

size, where new ROWs could be granted for the development of linear ROWs, such as power transmission lines, 

water and gas lines, fiber-optic lines, and associated 

facilities, including access routes, as well as new site-type 

ROWs. A ROW could also be granted in this corridor 

for the construction of Washington County’s proposed 

“northern transportation route” multi-lane roadway. 

Only a small percentage of the acreage of the proposed 

new utility and transportation corridor has been inventoried to identify and record heritage resources. However, 

prior small-scale investigations have documented 42 

prehistoric or historic period sites, of which 28 have been 

determined to be eligible for listing to the NRHP, as a 

result of consultations under Section 106 of the NHPA. 

The number, location, and types of heritage resources 

recorded to date suggest that site densities within the 

proposed new corridor will be high and that a majority 

will be NRHP-eligible. Project-specific developments 

within the corridor could result in adverse, moderate to 

major, long-term impacts on heritage resources within 

the 6,350-acre proposed new utility and transportation 

corridor under Alternative D. 

Under all alternatives, lands and realty actions that would 

adversely affect heritage resources through ROW developments or other land use authorizations would be subject 

to compliance with Section 106 of the NHPA. Section 106 

provides for the lessening of adverse effects, to the extent 

possible, through mitigation measures that generally 

involve archaeological data recovery excavations to salvage 

important scientific information for a site that will be 

damaged or destroyed though project-related actions. The 

potential loss or damage to heritage resources, even within 

the context of having adverse effects mitigated through 

data recovery treatments, would not be in conformance 

with the Congressionally-defined purpose of the NCA 

HERITAGE RESOURCES

which is the “conservation, protection, and enhancement” 

of the cultural and historic values of the NCA.

4.36.3 Summary of Impacts from Alternatives

Alternative A would continue current management and 

provide moderate protection levels for heritage resources, 

through recreation and travel management under the 

PUP; management of 19,989 acres as a ROW Exclusion 

area and 24,870 acres as an Avoidance area for new ROWs.

Alternatives B, C, and D would generally improve 

management for soils and vegetation. Fire and Fuels 

Management under these alternatives would be more 

comprehensive and effective compared to Alternative 

A, potentially reducing the risk of catastrophic wildfire. 

Restoration of disturbed and damaged vegetation communities would strive to restore native species, and control noxious weeds and invasive species using the most 

appropriate and least invasive methods. Impacts from 

recreation uses would be reduced, as the BLM would 

develop professionally designed and sustainable trail 

systems and other facilities to protect resource values and 

provide for high-quality visitor experiences. 

Management decisions under Alternative D related 

to lands and realty management would not meet the 

Congressional mandate that BLM “conserve, protect, and 

enhance” heritage resource values in the NCA, as adverse 

effects to historic properties could occur on 6,534 acres, 

from the development of new utilities and transportation systems, including Washington County’s proposed 

“northern transportation route” highway.

4.36.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on heritage resources includes all lands in Washington County.

Past human actions within the CIAA, on federal, state, 

municipal, and private lands that have affected these 

resources include the expansion of cities and towns, the 

development of utilities, road and highway construction, 

mineral materials harvesting, mining, grazing by livestock, 

and vegetation treatments. These have resulted in damage and destruction of heritage resources, with mitigation 

salvaging only a small percentage of the data contained in 

these sites. Other factors, such as wildfires, have directly 

and indirectly impacted heritage resources, destroying 

fire-susceptible sites and increasing impacts on surface and 

subsurface cultural materials through erosion and increasing the likelihood of vandalism or site looting. 

Present and reasonably foreseeable future actions would 

include continued regional population growth, the 

expansion of communities adjacent to the NCA, the construction of new utilities in designated corridors, hazard 

fuel reduction treatments, noxious weed control, and 

increasing recreational uses of public lands. Natural factors will include droughts, the introduction and spread of 

noxious weeds and invasive species, wildfires, and changing precipitation regimes related to climate change that 

impact soils, vegetation, and water sources.

Climate change within the CIAA could cause an increase 

or decrease in temperatures and precipitation, which 

would affect soil conditions, vegetation distribution, 

water flows, water quality, and water temperature. Such 

changes would alter the conditions to which vegetation 

communities are adapted, potentially creating conditions 

that could favor certain species or communities, weeds, 

or pests.

Past and present land uses in the NCA include ongoing grazing, increase in recreational demand, invasive 

species, erosion, wildland fire, forest disease and insects, 

drought, and climate change. These would continue to 

affect cultural resources and cultural landscapes through 

loss or disturbance of resources that are not or cannot be 

protected, changes in setting, pressure from incremental 

use, loss of access for Native Americans to resources, and 

theft or vandalism of cultural resources.

Actions related to recreation, grazing, vegetation treatment, and wildland fire, have had past effects and are expected to continue to affect cultural resources. Increased 

frequency of wildland fire due to drought or climate 

change may lead to additional direct loss of cultural 

resources and effects.

Decisions from this RMP would have effects that, when 

combined with other past, present, and reasonably 

foreseeable actions, could produce cumulative effects on 

cultural resources.

Cumulative effects would result from the destruction and 

loss of known and unrecorded resources and unanticipated discoveries. 

The continued documentation of new cultural resources 

from undertakings and permitted actions that would 

require inventory for compliance would result in additional information to expand and explain the area’s 

cultural history.
806 Chapter 4 RCNCA RCNCA Chapter 4 807

WILDERNESS

4.37 WILDERNESS

This section analyzes potential impacts to the Red 

Mountain and Cottonwood Canyon Wilderness areas from proposed management actions described in 

Chapter 2. Existing wilderness conditions are described 

in Section 3.35.2, Designated Wilderness. Because wilderness designation is a congressional action, the size of 

the wilderness areas remains the same in all alternatives. 

4.37.1 Methods of Analysis

The analysis of potential impacts to the Red Mountain 

and Cottonwood Canyon Wilderness areas is based on 

two data sources: visitor use statistics and GIS. The GIS 

information used in this analysis includes wilderness 

boundaries, management unit boundaries, vegetation 

types, terrain models, wildlife habitat, transportation inventories, dispersed recreation inventories, aerial photography, fire history, and known historical/cultural sites. In 

the absence of data, analyses were based on the expertise 

of recreation/wilderness planners.

Adverse impacts to wilderness character could result 

from management actions that diminish any of the fundamental components of wilderness character listed in 

the indicators section below. Beneficial effects could result from management actions that maintain or enhance 

wilderness character. 

4.37.1.1 Indicators

Indicators of adverse impacts to the Red Mountain and 

Cottonwood Canyon Wilderness areas can be defined by 

potential changes in wilderness character. The fundamental components of wilderness character and their potential for change are listed below. They are further defined 

in Keeping It Wild: an Interagency Strategy to Monitor 

Trends in Wilderness Character Across the National 

Wilderness Preservation System (Landres et al. 2008):

Untrammeled

Untrammeled refers to wilderness as unhindered and 

free from modern human control or manipulation. The 

Wilderness Act defines wilderness as, “an area where 

the earth and its community of life are untrammeled by 

man,” and is “affected primarily by the forces of nature.” 

Potential adverse impacts include:

▶ Number of authorized actions and persistent 

structures designed to manipulate plants, animals, 

pathogens, soil, water, or fire;

▶ Percent of natural fire starts that are manipulated 

within the boundaries of the Wilderness;

▶ Number of unauthorized actions by agencies, citizen groups, or individuals that manipulate plants, 

animals, pathogens, soil, water, or fire.

Natural 

Natural refers to wilderness ecological systems that are 

substantially free from the effects of modern civilization. 

Potential adverse impacts are measured by the status 

of native biological communities as defined by priority 

habitat indicators and standards.

Undeveloped

Undeveloped wilderness has minimal evidence of 

modern human occupation or modification. It is land 

“retaining its primeval character and influence, without 

permanent improvements or human habitation, with 

the imprint of man's work substantially unnoticeable.” 

Potential adverse impacts are defined as physical developments (buildings, fences, water developments), and the 

type and amount of use of motor vehicles.

Outstanding Opportunities for Solitude or Primitive and 

Unconfined Recreation 

Wilderness provides opportunities for people to experience natural sights and sounds, solitude, freedom, risk, 

and the physical and emotional challenges of self-discovery and self-reliance. Potential adverse impacts include:

▶ Amount of visitor use;

▶ Number of official and/or user-created travel routes;

▶ Type and number of agency provided and/or usercreated facilities;

▶ Type and extent of management restrictions;

▶ Impacts on Unique and Supplemental Values.

Wilderness areas “may also contain ecological, geological, or other features of scientific, educational, scenic, or 

historical value.” These values may or may not overlap 

with the other four qualities. Potential adverse impacts 

include:

▶ Adverse impacts on cultural, paleontological, ecological, scientific, scenic, or educational resources;

▶ Declines in numbers or population viability for special status species, including BLM Sensitive Species.

4.37.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resource values 

of the NCA.

▶ The Red Mountain and Cottonwood Canyon 

Wilderness areas would continue to be managed 

WILDERNESS

according to the Wilderness Act of 1964 and 

BLM Manual 6340—Management of Designated 

Wilderness Areas, and subsequent wilderness 

legislation;

▶ Established grazing in the Wilderness is determined 

by the active AUMs permitted at the time of wilderness designation for any allotment that is wholly or 

partly within the Wilderness;

▶ Management of the Wilderness is subject to valid 

existing rights and special provisions identified in 

the Wilderness Act under all alternatives;

▶ Implementation-level activities within the 

Wilderness would be evaluated using the Minimum 

Requirement Decision Guide to determine how the 

activity would impact wilderness character;

▶ Keeping It Wild: an Interagency Strategy to Monitor 

Trends in Wilderness Character Across the National 

Wilderness Preservation System (Landres et al. 2008) 

will be used to track changes in wilderness character over time.

Implementing management actions for the following 

resources would have no adverse impacts on the Red 

Mountain and Cottonwood Canyon Wilderness areas 

and are therefore not analyzed in this section: Air Quality, 

Water Resources, Geologic and Paleontological Resources, 

Cave and Karst Resources, Soil Resources, Other Fish and 

Wildlife Species, Heritage Resources, Lands and Realty, 

Social and Economic Conditions, Public Education and 

Interpretation, and Scientific Research.

4.37.2 Direct and Indirect Impacts

Wilderness character in Red Mountain and Cottonwood 

Canyon is primarily influenced by the volume and 

density of recreational users and the scope of potential 

biological restoration projects. These projects include 

vegetation treatments, the installation, maintenance, and 

use of wildlife improvements, and the management of 

wildland fire and fuels.

Each action alternative identifies a management emphasis for one or more of the components of wilderness 

character.

4.37.2.1 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Landscape-level fuel breaks are proposed in the NCA 

in all alternatives. Such fuel breaks would likely include 

acreage within wilderness since the Cottonwood Canyon 

and Red Mountain Wilderness areas comprise 44% of the 

total NCA acreage. In addition, housing developments 

in Dammeron Valley are pressed up against the Red 

Mountain boundary and the Town of Leeds is in close 

proximity to Cottonwood Canyon. 

A variety of methods for fuel breaks are proposed. 

Alternative D includes any combination of biological 

controls, flaming, herbicides, mechanical methods, and 

hand removal. Alternative B has an identical suite of 

options, minus the flaming. Alternative C is the most 

conservative, with mechanical and hand removal only.

Fuel breaks would require intensive manipulation of vegetation and would have a direct impact on the untrammeled portion of wilderness character. Impacts would 

occur in all alternatives, with varying levels of intensity. 

Impacts in Alternative D could range from moderate to 

major, depending on the scale of the project and the tools 

selected. Alternatives B or C could range from minor to 

moderate for the same reasons. 

There are two factors at play that may require the creation of fuel breaks in and around wilderness. The first 

is the number of housing developments in proximity to 

wilderness. Defensible space around housing developments within the wildland/urban interface is no longer an afterthought; it is now a permanent part of the 

landscape. The second is the volume of invasive species 

(brome) capable of fueling catastrophic wildfires that 

are already present. Manipulating the vegetation by 

constructing fuel breaks would have adverse impacts to 

the untrammeled quality of wilderness character in the 

short term, but could improve it over the long term. It 

could also indirectly benefit opportunities for solitude 

and primitive unconfined recreation by preserving those 

qualities, which would be lost for years in the event of a 

catastrophic wildfire.

Currently, all fires within the NCA are targeted for full 

suppression. This is due to the goals for these FMUs, the 

MOG recommendations for firefighting within desert 

tortoise habitat, the FRCC of 3, and the extensive WUI 

areas that surround the NCA. Fires within the two designated wilderness areas may be fought using MIST, if 

the fires do not threaten critical resources, infrastructure, 

human health and safety, or other pre-designated criteria.

These tactics are due to the number of housing developments on the wilderness boundary, the presence of 

invasive species (brome) capable of fueling catastrophic 

wildfires, a non-fire adapted landscape, and the presence 

of critical tortoise habitat. Fire suppression has shortterm impacts to the untrammeled portion of wilderness 

character but preserves the other qualities in the long 
808 Chapter 4 RCNCA RCNCA Chapter 4 809

WILDERNESS

term. Because of the potential variability in fire starts and 

behavior, it is not possible to quantify potential impacts.

4.37.2.2 Impacts from Management of Noxious 

Weeds and Invasive Species 

Managing noxious weeds could result in direct impacts 

to the untrammeled quality of wilderness character. A 

variety of methods for managing noxious weeds are proposed. Alternative D includes any combination of biological controls, flaming, herbicides, mechanical methods, 

and hand removal. Alternatives A and B have an identical 

suite of options, minus the flaming. Alternative C is the 

most conservative, with hand removal only.

Noxious weed management could require intensive 

manipulation of vegetation. Impacts could occur in all 

alternatives, with varying levels of intensity. Impacts in 

Alternative D could range from moderate to major, depending on the scale of the project and the tools selected. 

Alternative B could range from minor to moderate for 

the same reasons. Over the long term, management of 

noxious weeds in Alternatives A, B, and D could have 

positive effects on the wilderness character component 

of Naturalness. Given the potential variability of noxious 

weed control projects, it is not possible to quantify the 

intensity of the beneficial effects.

Alternative C is restricted to hand removal only. Not allowing spraying would eliminate trammeling, but would 

likely diminish naturalness over time because weed infestations would be difficult to control using hand removal 

methods only. Impacts would be indirect, but could 

range from minor to moderate. 

4.37.2.3 Impacts from Management of Vegetation 

Resource Uses: Livestock Grazing 

There are two active grazing allotments that are partially 

within the Red Mountain Wilderness – Sand Wash and 

Veyo. The Veyo Allotment is comprised of approximately 

18,900 acres, of which only 1,100 acres are within the 

Red Mountain Wilderness. The Sand Wash Allotment 

is approximately 3,900 acres in total size. The grazing 

permit authorizes four head of cattle to be grazed from 

November 16 to May 31 annually. Approximately 220 

acres of the allotment are within the Red Mountain 

Wilderness. The terrain is generally not well suited to 

livestock grazing, being comprised primarily of steepsided cliffs, slick rock, and sand dunes. There are no 

permanent water sources, and forage production is 

very limited in the Wilderness portion of the allotment. 

Although approximately 36 livestock AUMs have been 

allocated within wilderness, livestock do not utilize this 

portion of this allotment, as there are other areas outside 

that are more accessible and better suited to grazing. 

Impacts from grazing operations would typically affect 

Natural and Untrammeled components of wilderness 

character, but in the Red Mountain Wilderness no impacts are anticipated over the life of the plan.

4.37.2.4 Impacts from Management of Vegetation 

Resource Uses: Plant Materials

Harvesting of woodland products, desert vegetation, 

or native seed collection for commercial purposes or 

personal uses would not be authorized under any of the 

alternatives in designated wilderness. Authorization for 

collection of native seeds, plants, and plant materials 

would be made only for scientific research or for storage 

and propagation, to ensure that locally derived native 

plant materials for restoration projects in the NCA or 

adjacent public lands. The collection of plant materials by 

Native Americans for religious, ceremonial, or traditional 

purposes would continue to be an authorized use in 

designated wilderness. Plant materials collection would 

be limited to hand and non-invasive methods, resulting 

in negligible impacts on native vegetation.

4.37.2.5 Impacts from Management of Special Status 

Species 

Designated wilderness provides superior protection for 

special status species and their habitats in all alternatives. 

If translocation were to occur in wilderness, the beneficial effect over the long-term would be the potential for a 

new supplemental wilderness value.

4.37.2.6 Impacts from Management of BLM Sensitive 

Species

Designated wilderness provides superior protection for 

BLM Sensitive Species and their habitats in all alternatives. If translocation were to occur in wilderness, the 

beneficial effect over the long-term would be the potential for a new supplemental wilderness value.

4.37.2.7 Impacts from Management of Wilderness

The Red Mountain and Cottonwood Canyon 

Wilderness areas would be managed in accordance 

with the Wilderness Act of 1964, BLM Manual 6340—

Management of Designated Wilderness, and the implementation-level decisions in the Red Mountain and 

Cottonwood Canyon Wilderness Management Plan. These 

documents require long-term management for the protection of all components of wilderness character and no 

adverse impacts are anticipated.

WILDERNESS

4.37.2.8 Impacts from Management of ACECs

Revoking the Red Mountain ACEC designation would 

have no impact on the Red Mountain Wilderness. 

Management direction from the Wilderness Act of 

1964, BLM Manual 6340—Management of Designated 

Wilderness, and the implementation-level decisions in 

the Red Mountain and Cottonwood Canyon Wilderness 

Management Plan all offer protection superior to that 

of ACEC designation. For a more detailed analysis and 

a comparison of ACEC and Wilderness management 

prescriptions, please see Section 4.38, Areas of Critical 

Environmental Concern.

4.37.2.9 Impacts from Management of Visual 

Resources

Management of the Red Mountain and Cottonwood 

Canyon Wilderness areas according to VRM Class I 

objectives would contribute to the protection of the 

wilderness character components of untrammeled and 

undeveloped by preserving the existing character of the 

landscape. Beneficial effects would be the result for 

all alternatives.

4.37.2.10 Impacts from Management of Natural 

Soundscapes

Certain areas within the Red Mountain and Cottonwood 

Canyon Wilderness areas have ample opportunity to 

experience natural quiet, free of the sights and sounds 

of the nearby urban interface. While these are certainly 

beneficial effects, it is not possible to adequately quantify the value to individual visitors as no auditory data 

is available and everyone’s perception of solitude and 

natural quiet can be different. 

4.37.2.11 Impacts from Management of Lands with 

Wilderness Characteristics

Managing lands with wilderness characteristics specifically to protect those characteristics is proposed only 

in Alternative C. There are four areas within the NCA 

where the inventory shows that wilderness characteristics are present, with 951 acres adjacent to Cottonwood 

Canyon and 635 acres next to Red Mountain. None of 

the four areas contain motorized routes. None of the four 

areas contain non-motorized trails, either existing or 

proposed. All four of the areas are within critical desert 

tortoise habitat. Because of the combination of these 

factors, lands with wilderness characteristics would be 

equally protected in Alternatives A, B, and D and managing specifically for their protection in Alternative C 

would add no protections to designated wilderness that 

are not equally provided by NCA status.

4.37.2.12 Impacts from Management of Recreation 

and Visitor Services

Recreational traffic in the Red Cliffs and Cottonwood 

Canyon Wilderness areas ranges from light to heavy depending on location. Opportunities for primitive, unconfined recreation are easily accessible, but many popular 

destinations can be crowded on spring and fall weekends. 

Proximity to the greater St. George metropolitan area 

provides easy access for a large and growing population. 

There are no existing or proposed recreation management decisions that are inconsistent with the Wilderness 

Act of 1964, BLM Manual 6340, or the Red Mountain / 

Cottonwood Canyon Wilderness Management Plan and 

no significant impacts are anticipated.

4.37.2.13 Impacts from Management of 

Comprehensive Travel and Transportation

Impacts from Travel and Transportation Management 

are non-existent because there are no authorized users 

who require motorized access and the boundaries of the 

Red Mountain and Cottonwood Canyon Wilderness 

areas are well-protected from unauthorized motorized 

use. Cottonwood is surrounded by the RCNCA to the 

west, east, and south, and by Dixie National Forest to 

the north, including the USFS-managed Cottonwood 

Forest Wilderness. Red Mountain is protected by sheer 

sandstone escarpments on three sides that are impossible 

to penetrate by vehicle. The eastern boundary is fenced 

along the entire perimeter.

Both wilderness areas have popular trail systems, which 

are identified only on visitor use maps. The trails are primitive and typically follow washes and topographic features. 

They are not maintained and only two directional signs are 

installed inside the Red Mountain Wilderness. 

4.37.3 Summary of Impacts from Alternatives

Table 4-22 provides a summary of the impacts to wilderness. The first column lists the resource or resource 

use that has an impact/effect on recreation. The second 

column lists whether the action(s) is a beneficial effect 

or an adverse impact. The third column provides a brief 

description of the impact/effect and the final column lists 

the intensity of the impact/effect. A description of intensity levels can be found in the “Methods of Analysis” 

section at the beginning of the Wilderness section.

4.37.4 Cumulative Impacts

The CIAA for wilderness is all of Washington County, the 

northern portion of the Arizona Strip, and the western half of the BLM Kanab Field Office. It includes all 
810 Chapter 4 RCNCA RCNCA Chapter 4 811

WILDERNESS

designated wilderness areas managed by BLM, USFS, and 

NPS, and Wilderness Study Areas managed by the Kanab 

Field Office. 

Following the passage of OPLMA in 2009, Congress 

designated 14 wilderness areas on BLM-managed lands 

in Washington County and three areas within Zion 

National Park. When combined with USFS wilderness 

in the Pine Valley Ranger District, there are 220,439 

acres of designated wilderness in Washington County. 

This is 14% of the entire county. For BLM-managed 

lands the number is significantly higher. Over half of 

the wilderness in the county, 129,000 acres, is on land 

managed by the SGFO. This is 20% of the total BLMmanaged acres in Washington County, or to put it 

another way, one out of every five acres managed by the 

SGFO is designated wilderness.

Wilderness is primarily affected by the number and 

proximity of motorized travel corridors; the volume 

and type of traffic on those corridors; and the quantity 

and type of recreational users. With population in the 

greater St. George metropolitan area increasing 2% annually, visitation to wilderness areas will increase and 

large visitor numbers always have the potential to impact 

wilderness character. However, given the sheer volume 

of wilderness in and around Washington County, there 

is ample opportunity over the life of this plan for visitors 

and residents to have an enjoyable wilderness experience. 

There are no present or future actions, or combination of 

actions, likely to have significant cumulative impacts on 

wilderness character, and the cumulative impacts for all 

alternatives would be identical.

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

4.38 AREAS OF CRITICAL ENVIRONMENTAL 

CONCERN

This section analyzes impacts to ACECs from proposed 

management actions described in Chapter 2. Existing 

ACEC conditions are described in Section 3.35.3, Areas 

of Critical Environmental Concern.

4.38.1 Methods of Analysis

The analysis of potential impacts to the Red Mountain 

ACEC compares the existing ACEC management prescriptions from the SGFO RMP to the mandates from 

OPLMA Section 1972 (a) (M) and Section 1974 relating 

to the management of the Red Mountain Wilderness and 

the Red Cliffs NCA and the legislative requirements from 

the Wilderness Act (Public Law 88-577). The ACEC is 

now partially located within the Red Cliffs NCA and entirely within Red Mountain Wilderness, both designated 

in 2009, through OPLMA.

4.38.1.1 Indicators

Indicators of adverse impacts on ACECs include the 

following:

▶ Degradation of relevant and important values for 

which the area was proposed or designated. 

Indicators of beneficial effects on ACECs include the 

following:

▶ Protection of relevant and important values for 

which the area was proposed or designated.

4.38.1.2 Assumptions

The analysis includes the following assumption:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ NCA and Wilderness designations provide a higher 

level protection for the relevance and importance 

values than does the ACEC designation.

4.38.2 Direct and Indirect Impacts

Revoking the administrative designation of the 4,854-

acre Red Mountain ACEC in Alternatives B, C, and D 

would have no impact on the scenic qualities that were 

identified as the relevance and importance value for 

which this ACEC was designated through the SGFO 

RMP. The ACEC is located entirely within the Red 

Mountain Wilderness, designated through OPLMA, 

and partially within the Red Cliffs NCA. Table 4-23 is a 

comparative analysis that contrasts the existing ACEC 

management prescriptions with the Congressionallymandated segregations, management, and uses related 

to the NCA and Wilderness designations and the requirements for management of designated wilderness 

under the Wilderness Act. There were no valid existing 

rights in the ACEC at the time of NCA and Wilderness 

Resource /Resource Use designation. Impact/Effect Description Intensity

Native Vegetation Impact Fuel breaks require intensive vegetation manipulation Moderate

Impact Fuel breaks could protect naturalness Major

Fire and Fuels Impact Fire and fire suppression could impact naturalness Major

Effect Immediate fire suppression could protect naturalness Major

Noxious Weeds and 

Invasive Species Impact Alternative C restricted to hand removal, least impacting but more time and labor intensive, reducing effectiveness Minor

Impact Alternatives A, B, D have full suite of tools, more impacting but 

more efficient Minor

Livestock Grazing Impact Past and proposed closures and extreme terrain negates livestock 

impacts None

Plant Material Uses Impact Hand gathering only for research or Native American use Negligible

Special Status Species Effect Wilderness designation provides superior protection for habitat Moderate

BLM Sensitive Species Effect Wilderness designation provides superior protection for habitat Moderate

Other Fish and Wildlife Effect Wilderness designation provides superior protection for habitat Moderate

Wilderness Effect Managing as designated wilderness preserves area in perpetuity Major

ACEC Impact Revoking ACEC designation would have no impact None

Visual Resources Effect Managing as designated wilderness preserves area in perpetuity Major

Natural Soundscapes Effect Preserving natural soundscapes would enhance solitude Minor

Wilderness Characteristics Effect Values protected by NCA withdrawals and mandates from 

OPLMA None

Recreation and Visitor 

Services Effect Opportunities for primitive recreation in the urban interface Moderate

Transportation Effect All roads are closed and boundary is protected Moderate

Existing Red Mountain ACEC

Management Prescriptions

Red Cliffs NCA Legislative Withdrawals and Mandates for 

Management

Fluid Mineral Leasing Category 3 – No Surface 

Occupancy

Withdrawn from operation of mineral leasing, mineral materials, and 

geothermal leasing laws- OPLMA and Wilderness Act

Mining Plans of Operation required Withdrawn from entry, location, and patenting under the mining laws, 

subject to valid existing rights- OPLMA and Wilderness Act

Closed to Mineral Material sales Withdrawn from operation of mineral leasing, mineral materials, and 

geothermal leasing laws-OPLMA and Wilderness Act

Retain lands in public ownership Withdrawn from entry, appropriation, and disposal under the public 

land laws-OPLMA and Wilderness Act

Non-federal lands may be obtained through purchase, exchange or donation, to achieve management 

objectives

Acquired lands become part of the NCA and are withdrawn from 

operation of public land laws, mining law, mineral leasing, mineral 

materials, and geothermal leasing laws

Closed to off-road vehicles Closed to off-road vehicles-Wilderness Act

Closed to commercial and non-commercial fuelwood 

harvesting

Closed to commercial and non-commercial fuelwood harvestingWilderness Act

Closed to commercial and non-commercial seed 

harvesting

Closed to commercial and non-commercial seed 

harvesting-Wilderness

Manage as ROW Avoidance area Manage as ROW Exclusion area-Wilderness Act

Manage as VRM Class I Manage as VRM Class I-Wilderness Act

No similar action Closed to mechanized use-Wilderness Act

Table 4-22 Summary of Impacts to Wilderness

Table 4-23 Impacts for Revocation of the Red Mountain ACEC Designation
812 Chapter 4 RCNCA RCNCA Chapter 4 813

VISUAL RESOURCE MANAGEMENT

As shown in Table 4-23 managing these public lands in 

conformance with the OPLMA; the Wilderness Act of 

1964, BLM Manual 6340–Management of Designated 

Wilderness, the RMP, and the Red Mountain/Cottonwood 

Canyon Wilderness Management Plan would provide 

protections that are equal or superior to those provided 

by ACEC designation for all resources in Alternatives 

B, C, and D. The ACEC designation would remain in 

Alternative A, but would provide no additional protection for any resource.

4.38.3 Summary of Impacts from Alternatives

Under Alternative A, the administrative designation of 

the Red Mountain ACEC would be retained, while under 

Alternatives B, C, and D the ACEC designation would 

be revoked. The proposed revocation would not result 

in any impacts on the scenic qualities of the 4,854 acres, 

which comprises the relevance and importance value 

for this ACEC, as these acres are all within the designated Red Mountain Wilderness, which is managed as 

withdrawn from operation of the General Mining Law, 

Mineral Materials Act, Fluid Mineral Leasing Act, the 

Geothermal Leasing Act, and entry or disposal under the 

Public Land laws. Designated wilderness areas are also 

managed VRM Class I, as a ROW Exclusion area, and 

Closed to motorized and mechanized activities, thereby 

providing a higher level of protection for the scenic 

qualities of the area than those of ACEC designation.

4.38.4 Cumulative Impacts

The CIAA is the viewshed to the north of Old Highway 

91, from west of Santa Clara to the Gunlock turnoff. The 

dominant feature in the landscape is Red Mountain, 

which rises a dramatic 1,500 vertical feet above Snow 

Canyon State Park and the local communities of Ivins and 

Santa Clara. The cliff face is the southernmost portion of 

the Red Mountain Wilderness and it extends for a distance of five miles. The scenic cliff face was the identified 

relevance and importance value for this ACEC and the 

special management prescriptions identified in the RMP 

were intended to protect the cliff face from visual disturbances. The ACEC is now entirely within the designated 

Red Mountain Wilderness and partially within the Red 

Cliffs NCA, with both Congressional designations providing higher levels of protection for the scenic qualities 

of Red Mountain than does the ACEC designation. There 

are no cumulative effects related to the revocation of the 

administrative designation of the ACEC, as there are not 

reasonably foreseeable future actions that could impact 

the scenic qualities of the area, as they are now protected 

in perpetuity through NCA and Wilderness designations.

4.39 VISUAL RESOURCE MANAGEMENT

This section analyzes potential impacts to Visual 

Resources from proposed management actions described 

in Chapter 2. Existing conditions are described in Section 

3.36 Visual Resource Management.

4.39.1 Methods of Analysis

Impacts on visual resources are analyzed by how the 

proposed VRM classifications in the Chapter 2 alternatives could alter the visual appeal of the existing landscape, which is described in Chapter 3 through a VRI. 

A VRI is a systematic process designed to determine the 

extent and quality of visual resources in a given area. 

The two main components of a VRI are Scenic Quality 

and Sensitivity. These two components, combined with 

Distance Zones, form a VRI. By overlaying these components in GIS, the combination of attributes determine 

the inventory class, VRI Class I, II, III, or IV. A VRI is 

not a management allocation. Its purpose in the planning 

process is to disclose the potential impacts/effects to the 

public and to the decision maker. 

Because every acre of public land is required to have 

a VRM Class, impacts to visual resources are easily 

quantified. For example, if a change was proposed from 

VRM Class II to VRM Class III, more surface disturbing uses could be allowed and this would have greater 

potential impacts to the VRI classes of Scenic Quality 

and Sensitivity. If the reverse decision were true, the VRI 

Classes would receive greater protection and the potential effects would be beneficial.

Adverse impacts to Visual Resources could result from 

management actions that diminish any of the fundamental components of Scenic Quality or Sensitivity listed 

in the indicators section below. Beneficial effects could 

result from management actions that maintain or protect 

Scenic Quality and Sensitivity. 

4.39.1.1 Indicators

Indicators of adverse impacts on visual resources include 

the following:

▶ A proposed VRM class that could allow a degradation of the existing Scenic Quality rating;

▶ A proposed VRM class that could allow surface 

disturbing activities in a landscape with a high 

Sensitivity rating.

Indicators of beneficial effects on visual resources include 

the following:

VISUAL RESOURCE MANAGEMENT

▶ A proposed VRM Class that offers equal or greater 

protection of existing Scenic Quality and Sensitivity 

ratings.

4.39.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ The Red Mountain and Cottonwood Canyon 

Wilderness areas will be managed as VRM Class I.

▶ More protective VRM Classes are consistent with 

the values described in the enabling legislation for 

the NCA.

▶ Given the proximity to the greater St. George 

metropolitan area, the scenic vistas within the NCA 

would become more valuable over time, increasing 

in sensitivity as measured by the depth of public 

concern over the life of the RMP.

▶ Architectural design standards that create a unique 

and recognizable identity for the NCA would be 

incorporated during the design phase for all new 

surface disturbing projects, regardless of size or 

potential impact to visual resources.

Implementing management for the following resources 

or resource uses would have negligible or no impact 

on visual resources and are therefore not discussed 

in detail: Air Quality, Water Resources, Geologic and 

Paleontological Resources, Cave and Karst Resources, 

Soil Resources, Vegetation Resource Uses: Livestock 

Grazing, Vegetation Resource Uses: Plant Materials, 

Special Status Species, BLM Sensitive Species, Other 

Fish and Wildlife Species, Heritage Resources, Natural 

Soundscapes, Public Education and Interpretation, and 

Scientific Research.

4.39.2 Direct and Indirect Impacts

Visual Resources in the NCA are primarily influenced 

by the volume and density of utility developments along 

the Red Hills Parkway and Cottonwood Road, and by the 

potential for catastrophic fire within the I-15 viewshed. 

Alternatives B, C, and D each identify a different management emphasis for visual resources. Because utility 

and highway development has the most significant impact, the VRM management class alternatives are a mirror image of the rights-of-way alternatives in the Lands 

and Realty section. 

Alternative D is the least restrictive, with a VRM Class 

IV corridor that allows for future highway and utility 

development along Cottonwood Road and across the 

southern end of the NCA. 

Alternative C is the most restrictive, with the NCA being 

comprised only of VRM Class I and II. 

Alternative B strikes a balance with a VRM Class III corridor that would allow limited utility development along 

Cottonwood Road while still protecting visual resources. 

Alternative A shows the existing VRM Classes of VRM 

I for the Red Mountain and Cottonwood Canyon 

Wilderness areas and VRM Class III for the remainder of 

the NCA.

4.39.2.1 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Landscape-level fuel breaks and vegetation treatments 

targeted to remove non-native woody species are proposed in the NCA in all alternatives. Such fuel breaks/

vegetation treatments would include acreage within 

VRM Class I and proposed VRM Class II. A variety of 

methods for fuel breaks are proposed. Alternative D 

includes any combination of biological controls, flaming, herbicides, mechanical methods, and hand removal. 

Alternative B has an identical suite of options, minus 

the flaming. Alternative C is the most conservative, with 

mechanical and hand removal only.

Fuel breaks would require intensive manipulation of vegetation, have a direct impact on the scenic quality, and 

be out of compliance with VRM Class I and most likely 

the proposed VRM Class II. The sensitivity rating of the 

landscape would also be impacted if the viewsheds from 

neighborhoods pressed up against the NCA boundary 

were affected. Fuel break design calls for the use of topographic features, water courses, ephemeral drainages, 

road networks and utility corridors. Utilization of these 

natural and constructed features would lessen the impact 

on native vegetation and help preserve the quality of the 

existing viewshed. 

Despite this, impacts are still likely to occur in all alternatives, with varying levels of intensity. Even when done 

with care, landscape level fuel breaks and vegetation 

treatments would negatively impact the scenic quality 

of the NCA landscape. Impacts in Alternative D could 

range from moderate to major, depending on the scale 

of the project and the tools selected. Alternatives B or C 

could range from minor to moderate because the tool 

section would be more restricted. In all alternatives, it 

would be possible to be out of compliance with VRM objectives in the short term (less than five years). Over the 

long-term, as the landscape adjusts and regains a more 
814 Chapter 4 RCNCA RCNCA Chapter 4 815

VISUAL RESOURCE MANAGEMENT

natural look, it is anticipated that even VRM Class I and 

II objectives could be met.

While large fuel breaks are not a desirable option for a 

scenic landscape, they may be a necessary evil. A welldesigned fuel break would also work to preserve scenic 

quality, which could be lost for decades in the event of a 

catastrophic wildfire.

Under all alternatives, fires within the NCA are targeted 

for full suppression, although Alternative A provides 

some options for minimum impact fire suppression 

methods to be employed. This is due to the goals for 

these FMUs, the MOG recommendations for firefighting 

within desert tortoise habitat, the FRCC of 3, and the extensive WUI areas that surround the NCA. Fires within 

the two designated wilderness areas may be fought using MIST, if the fires do not threaten critical resources, 

infrastructure, human health and safety, or other predesignated criteria.

These tactics are due to the number of housing developments on the wilderness boundary, the presence of 

invasive species (Brome) capable of fueling catastrophic 

wildfires, a non-fire adapted landscape, and the presence 

of critical tortoise habitat. 

Wildland fire can cause great contrast to the natural 

landscape, removing large swaths of vegetation and leaving behind visible scars. Fire and fire suppression can 

have dramatic impacts to visual resources but can also 

preserve larger areas that would have otherwise burned 

over. Because of the potential variability in fire starts, fire 

behavior, and employed suppression techniques, it is not 

possible to quantify potential impacts, but they could 

range from minor to major.

4.39.2.2 Impacts from Management of Noxious 

Weeds and Invasive Species 

A variety of methods for managing noxious weeds and 

invasive species are proposed. Alternative D includes any 

combination of biological controls, flaming, herbicides, 

mechanical methods, and hand removal. Alternatives A 

and B have an identical suite of options, minus the flaming. Alternative C is the most conservative, with hand 

removal only.

Noxious weed management would require intensive manipulation of vegetation and could have a direct impact 

on scenic quality. Impacts could occur in all alternatives, 

with varying levels of intensity. Impacts in Alternative 

D could range from minor to moderate, depending on 

the scale of the project and the tools selected. Alternative 

B could range from negligible to minor for the same 

reasons. Over the long term, management of noxious 

weeds and invasive species in Alternatives A, B, and D 

could have positive effects on scenic quality. Given the potential variability of noxious weed control results, it is not 

possible to quantify the intensity of any beneficial effects.

Alternative C is restricted to hand removal only. Not allowing spraying could diminish scenic quality over time 

because weed infestations would be difficult to control 

using hand removal methods only. Impacts would be 

indirect, but could range from negligible to minor. Over 

the long-term, the reduction of noxious weeds could 

improve ecological integrity as well as scenic quality. 

4.39.2.3 Impacts from Management of Wilderness

Under all alternatives, the Red Mountain and 

Cottonwood Canyon Wilderness areas would be managed as VRM Class I, which is the most restrictive management class for visual resources and is typically applied 

only to areas with special designations. The objective is to 

preserve the existing character of the landscape. The level 

of change to the characteristic landscape should be very 

low and must not attract attention of the casual observer.

Managing these wilderness areas as VRM Class I would 

have beneficial effects to visual resources. Because visible 

surface disturbing activities would not be allowed, and 

the existing landscape is protected in perpetuity through 

wilderness designation, the beneficial effects to visual 

resources would be major and both direct and indirect. 

4.39.2.4 Impacts from Management of ACECs

Revoking the administrative designation of the 4,854 

acre Red Mountain ACEC in Alternatives B, C, and D 

would have no adverse impact on the visual resources, 

the identified relevance and importance values for which 

the ACEC was administratively designated through the 

SGFO RMP. The ACEC is located entirely within the Red 

Mountain Wilderness, designated through OPLMA, and 

partially within the NCA.

The current ACEC management prescriptions are:

▶ Fluid Mineral Leasing Category 3 (No Surface 

Occupancy);

▶ Closed to off-road vehicle use;

▶ Closed to fuelwood harvesting;

▶ Closed to mineral material sales;

▶ Designated ROW Avoidance area;

▶ Mining plans of operation required;

▶ VRM Class I designation;

▶ Retain in public ownership.

VISUAL RESOURCE MANAGEMENT

Managing these public lands as designated wilderness with 

a VRM Class I designation would provide protections that 

are equal to or superior to those provided by ACEC designation for all resources in Alternatives B, C, and D.

The ACEC designation would remain in Alternative A, 

but would provide no additional protection for visual resources. For a more detailed analysis and a comparison of 

ACEC and Wilderness management prescriptions, please 

see Section 4.47, Impacts from Management of Areas of 

Critical Environmental Concern. 

4.39.2.5 Impacts from Management of Visual 

Resources

Impacts to visual resources are analyzed by how the proposed VRM classifications in the Chapter 2 alternatives 

could alter the visual appeal of the existing landscape, 

which is described in Chapter 3 through a VRI. The two 

main components of the Red Cliffs NCA VRI are Scenic 

Quality and Sensitivity. These are described in Chapter 3.

At a landscape level, VRM Class I and II afford more 

protection to areas with high scenic quality and/or highly 

sensitive landscapes. VRM Class III and IV provide progressively fewer protections.

The acreage calculations in the tables below show how 

existing (Alternative A) and proposed (Alternatives B, C, 

and D) VRM Classes could impact the visual landscape 

of the NCA. This is further broken down through acreage 

calculations that show potential impacts to the individual 

components that make up the VRI.

Table 4-24 shows potential impacts to Scenic Quality, 

which is described as the visual appeal of a landscape. 

The rating is based on seven key factors: landform, 

vegetation, water, color, adjacent scenery, scarcity, and 

cultural modifications. Scenery is classified as A, B, or C, 

with A being the highest, and C the lowest.

Table 4-25 shows potential impacts to Sensitivity, which 

is a measure of public concern for the visual landscape. 

Factors for evaluating sensitivity are: types of users, 

amount of use, public interest, adjacent land uses, and 

special areas/unique landscapes. Based on these factors, 

landscapes are assigned a sensitivity level of high, medium, or low.

Table 4-26 shows potential impacts to the VRI classes, 

which are a combination of Scenic Quality, Sensitivity, 

and Distance Zones. The VRI represents the relative 

value of the scenic resources with Class I representing the 

highest values, and Class IV, the lowest values. 

Note: because the NCA is relatively small, within the urban interface, and heavily visited, distance zones are not 

considered relevant as it is always classified 

as Foreground.

To adequately analyze potential impacts to the visual 

landscape of the NCA, it is necessary to understand the 

proposed VRM designations in each of the action alternatives. The major difference between the alternatives lies 

with proposed Lands and Realty actions, including ROW 

Exclusion/Avoidance areas, and utility/highway corridors. The proposed VRM decisions mirror these actions 

with compatible designations.

Alternative C provides the highest protection for visual 

resources. With the exception of the ROW corridor along 

the Red Hills Parkway, the entire NCA would be designated as a ROW Exclusion area. No highways, roads, or 

utility development would be allowed in this alternative. 

The proposed VRM designations of Class I (wilderness) 

and Class II (remainder of NCA) are compatible with 

these protections.

In Alternative C, there would be no adverse impacts to 

visual resources. Designating all acres outside of wilderness as VRM Class II with an overlapping designation 

of ROW Exclusion, would prohibit surface disturbing 

activities and protect all components of the VRI. The 

beneficial effects would be both direct and indirect, as the 

scenic quality of the NCA would be preserved by prohibiting future utility, road, and highway development. This 

alternative would also protect the high sensitivity of the 

landscape, given its proximity to the greater St. George 

metropolitan area. 

Alternative B is less protective of visual resources than 

Alternative C. The two alternatives are similar, but have 

one major difference. Where Alternative C contains only 

VRM Class I and II, Alternative B has 3,652 acres of 

VRM Class III and 184 acres VRM Class IV. These acres 

encompass the existing utility developments that parallel Cottonwood Road and split the NCA from north to 

south. In this alternative the VRM Class III acres would 

be designated as a ROW Avoidance area. The Class III 

designation would allow for future utility development 

within the Avoidance area if no other viable options 

were available. This is consistent with the proposed Class 

III designation.

For Alternative B, there could be minor impacts to visual 

resources. The proposed 3,652 acres of VRM Class III 

could allow for a limited amount of future utility development. The Class III designation would impact 661 
816 Chapter 4 RCNCA RCNCA Chapter 4 817

VISUAL RESOURCE MANAGEMENT VISUAL RESOURCE MANAGEMENT

acres of “A” quality scenery. Those impacts would likely 

be minor because any development that occurred would 

be in close proximity to similar constructed features 

which would minimize the potential impacts.

In Alternative B, all 3,652 acres of the proposed VRM 

Class III are classified as highly sensitive and could 

be impacted. However, those impacts would likely be 

minor because any development that occurred would 

be adjacent to similar constructed features which would 

minimize the potential impacts. The Class III designation comprises 8% of the total acreage in the NCA. The 

remaining 92% would see beneficial effects from the 

remaining Class I and Class II designations as the scenic 

quality and high sensitivity are protected.

Alternative D is the least protective of visual resources, 

with 6,534 acres of VRM Class IV proposed. These acres 

mirror the ROW corridor proposed in this alternative. It 

also encompasses multiple options for the Washington 

County-proposed Northern Corridor. The County has 

proposed five separate options for a highway through the 

NCA and one that is just outside the NCA boundary. As 

a dedicated ROW corridor with proposed highway construction and utility expansion, applying a VRM Class 

IV designation is consistent with the proposed ROW corridor designation.

For Alternative D, there could be moderate to major 

impacts to visual resources, depending on the type and 

scope of proposed development and which alignment of 

the Northern Corridor was chosen. The proposed 6,534 

acres of VRM Class IV would also allow for a significant 

amount of future utility development. There are 1,103 

acres of “A” quality scenery that fall within the Class 

IV designation and all 6,534 acres are classified as high 

sensitivity. While all of these acres could be impacted, it is 

likely that the number of impacted acres would be lower, 

depending on the location and scale of the projects. In the 

interim, it is not possible to accurately quantify impacts 

from future projects that have no tangible development 

plans. It is assumed that any future development within 

the NCA would require site-specific NEPA and attempting to quantify it here is outside the scope of this analysis.

4.39.2.6 Impacts from Management of Lands with 

Wilderness Characteristics

There are four areas within the NCA where the SGFO 

inventory shows that lands with wilderness characteristics are present. All four of the lands with wilderness 

characteristics areas are contiguous to the Red Mountain 

or Cottonwood Canyon Wilderness areas. Managing 

those four areas specifically to protect their wilderness 

characteristics is proposed only in Alternative C. One of 

the proposed management prescriptions is VRM Class I. 

None of the four areas contain motorized routes. None 

of the four areas contain non-motorized trails, neither 

existing nor proposed, in the SGFO Travel Management 

Plan. All four of the areas are within critical desert 

tortoise habitat. All four of the areas are entirely within 

the NCA. Because of the combination of these factors, 

surface disturbing activities would be prohibited, regardless of VRM designation. Managing as VRM Class I in 

Alternative C offers no additional protection for wilderness characteristics that are not achieved by the combination of VRM Class II and management prescriptions for 

other resources in Alternatives B and D. 

4.39.2.7 Impacts from Management of Recreation 

and Visitor Services

Washington County’s year-round climate, combined with 

rapid population growth and the NCA’s backyard accessibility, has resulted in recreational pressures that more 

closely resemble those of a large municipal park system 

than a typical BLM field office. Recreational use in the 

NCA has a long and rich local history, due mainly to the 

fact that the Reserve has been in place for 14 years and 

residents have grown accustomed to the easily accessible 

trails and trailheads. 

The NCA’s major attraction is a network of hiking, biking, and equestrian trails, all set in a stunning backdrop 

of red and white sandstone cliffs interspersed with jetblack basalt flows. Much of the trail system lies within 

the municipal boundaries of St. George, Hurricane, Santa 

Clara, Ivins, and Leeds, many of which have housing 

developments pressed tightly against the NCA boundary. 

Residents of the St. George metropolitan area value the 

NCA for its scenery and high-quality open space.

Recreational use in the NCA has been intensely managed 

since the creation of the original Reserve and is limited 

to non-motorized uses. The lowland zone receives the 

majority of the visitor use, and, in order to protect critical 

desert tortoise habitat, recreational use is further Limited 

to Designated Roads and Trails. Despite the heavy and 

continuous use, particularly at major trailheads and 

popular trails, non-motorized use has little impact on the 

visual landscape. The nature of the authorized activities 

limits the size and scope of impacts to localized areas in 

and around authorized campgrounds and trailheads. 

Management prescriptions proposed for Recreation 

Management Zones in all alternatives would provide 

Existing/Proposed VRM Classes VRI Class - Impacts/Effects in Acres

VRM Class VRM Acres Alternative I II III IV

Class I 19,989 A 19,989 0 0 0

Class III 24,870 A 778 8,971 14,977 144

Class I 19,989 B 19,989 2 0 0

Class II 21,034 B 778 7,901 12,260 95

Class III 3,652 B 942 2,662 48 0

Class IV 184 B 128 54 0 0

Class I 21,574 C 20,624 730 217 3

Class II 23,285 C 142 8,240 14,762 141

Class I 19,989 D 19,989 0 0 0

Class II 18,336 D 777 7,275 10,268 16

Class IV 6,534 D 0 1,696 4,709 129

Existing/Proposed VRM Classes Sensitivity - Impacts/Effects in Acres

VRM Class VRM Acres Alternative High Medium Low

Class I 19,989 A 19,989 2 2

Class III 24,870 A 24,794 48 28

Class I 19,989 B 19,985 2 2

Class II 21,034 B 20,967 45 23

Class III 3,652 B 3,651 0 1

Class IV 184 B 175 4 4

Class I 21,574 C 21,567 3 5

Class II 23,284 C 23,210 48 26

Class I 19,989 D 19,985 2 2

Class II 18,336 D 18,273 42 21

Class IV 6,534 D 6,520 7 7

Existing/Proposed VRM Classes Scenic Quality-Impacts/Effects in Acres

VRM Class VRM Acres Alternative A B C

Class I 19,989 A 19,165 255 570

Class III 24,870 A 6,386 2,934 15,549

Class I 19,989 B 19,165 254 570

Class II 21,034 B 5,598 2,934 12,502

Class III 3,652 B 661 0 2,991

Class IV 184 B 128 0 56

Class I 21,574 C 20,491 277 807

Class II 23,284 C 5,060 2,912 15,312

Class I 19,989 D 19,165 254 570

Class II 18,336 D 5,156 2,934 10,246

Class IV 6,534 D 1,231 0 5,303

Table 4-26 Impacts-Effects to VRI Classes

Table 4-25 Impacts-Effects to Sensitivity Ratings

Table 4-24 Impacts-Effects to Scenic Quality Ratings
818 Chapter 4 RCNCA RCNCA Chapter 4 819

VISUAL RESOURCE MANAGEMENT

equal or greater protection for visual resources than 

existing management found in Alternative A. The development of uniform design standards for recreational 

facilities would be visually attractive and give the NCA a 

unique and recognizable identity.

The management of recreational activities in the NCA 

has both adverse impacts and beneficial effects to visual 

resources. Impacts are direct, localized, and negligible 

to minor as they are comprised of minor surface disturbances on and around existing trails and are not visible 

at a landscape scale. Beneficial effects are the result of 

motorized activities being prohibited in the NCA for the 

past 14 years. These restrictions have preserved the visual 

landscape. They are indirect, and moderate to major. 

4.39.2.8 Impacts from Management of 

Comprehensive Travel and Transportation

Regardless of alternative, there are only two OHV 

area designations in the NCA: 1) Closed to OHV Use 

and, 2) Limited to Designated Roads and Trails. These 

designations do not change by alternative, including 

Alternative A, as motorized use has been restricted to 

designated roads since June 2000. All designated trails 

are limited to non-motorized use only. In all alternatives, 

the Red Mountain and Cottonwood Canyon Wilderness 

areas are closed to motorized and mechanized use. These 

restrictions are expected to continue to preserve the 

visual landscape. 

4.39.2.9 Impacts from Management of Lands and 

Realty

Impacts to visual resources are analyzed in the tables 

below by how the proposed Lands and Realty actions in 

the Chapter 2 alternatives could alter the visual appeal 

of the existing landscape, which is described in Chapter 

3 through a VRI. The two main components of the 

RCNCA VRI are Scenic Quality and Sensitivity. 

At a landscape level, ROW Exclusion affords the most 

protection to areas with high scenic quality or highly sensitive landscapes. ROW Avoidance provides progressively 

fewer protections, and ROW Corridors are designed to 

accommodate a wide variety of major developments.

The acreage calculations in the tables below show how 

existing (Alternative A) and proposed (Alternatives B, C, 

and D) Lands and Realty actions could impact the visual 

landscape of the NCA. This is further broken down 

through acreage calculations that show potential impacts 

to the individual components that make up the VRI. 

The acreage calculations in Table 4-27, Table 4-28, and 

Table 4-29 show potential impacts to the VRI and to 

the individual VRI components of Scenic Quality and 

Sensitivity, and the overall VRI. Because the proposed 

Lands and Realty actions mirror the proposed VRM 

Classes, the analyses are identical to those in Section 

4.39.2.6 Impacts from Visual Resources. For comparison 

purposes:

VISUAL RESOURCE MANAGEMENT

▶ ROW Exclusion = VRM Class II (Class I in 

wilderness);

▶ ROW Avoidance = VRM Class III;

▶ ROW Corridor = VRM Class IV.

Table 4-27 shows potential impacts to Scenic Quality, 

which is described as the visual appeal of an area. The 

rating is based on seven key factors: landform, vegetation, water, color, adjacent scenery, scarcity, and cultural 

modifications. Scenery is classified as A, B, or C, with A 

being the highest.

Table 4-28 shows potential impacts to Sensitivity, which 

is a measure of public concern for the visual landscape. 

Factors for evaluating sensitivity are: types of users, 

amount of use, public interest, adjacent land uses, and 

special areas/unique landscapes. Based on these factors, 

landscapes are assigned a sensitivity level of high, medium, or low.

Table 4-29 shows potential impacts to the VRI classes, 

which are a combination of Scenic Quality, Sensitivity, 

and Distance Zones. The VRI represents the relative 

value of the scenic resources with Class I representing the 

highest values, and Class IV, the lowest values. 

Note: because the NCA is relatively small, within the urban interface, and heavily visited, distance zones are not 

considered relevant.

Because the proposed Lands and Realty actions mirror the 

proposed VRM Classes, the analyses are identical to those 

in Section 4.39.2.10, Impacts from Visual Resources.

Existing/Proposed Lands and Realty Actions Scenic Quality - Impacts/Effects in Acres

ROW Action ROW Acres Alternative A B C

Avoidance 24,686 A 6,259 2,934 15,493

Exclusion 19,989 A 19,165 254 570

Designated Corridor 183 A 128 0 56

Avoidance 3,652 B 0 661 2991

Exclusion 41,023 B 24,763 3,188 13,072

Designated Corridor 183 B 128 0 56

Avoidance 0 C 0 0 0

Exclusion 44,809 C 25,501 3,188 16,119

Designated Corridor 50 C 50 0 0

Avoidance 0 D 0 0 0

Exclusion 38,325 D 24,321 3,188 10,816

Designated Corridor 6,534 D 1,231 0 5,303

Existing/Proposed Lands and Realty Actions Sensitivity - Impacts/Effects in Acres

ROW Action ROW Acres Alternative High Medium Low

Avoidance 24,686 A 24,617 45 24

Exclusion 19,989 A 19,989 0 0

Designated Corridor 183 A 175 4 4

Avoidance 3,652 B 3,652 0 0

Exclusion 41,023 B 40,952 47 25

Designated Corridor 183 B 175 4 4

Avoidance 0 C 0 0 0

Exclusion 44,809 C 44,728 50 30

Designated Corridor 50 C 50 0 0

Avoidance 0 D 0 0 0

Exclusion 38,325 D 38,258 44 23

Designated Corridor 6,534 D 6,520 7 7

Existing/Proposed Lands and Realty Actions VRI Class - Impacts/Effects in Acres

ROW Action ROW Acres Alternative I II III IV

Avoidance 24,686 A 778 8,843 14,922 143

Exclusion 19,989 A 19,989 0 0 0

Designated Corridor 183 A 0 128 54 1

Avoidance 3,652 B 0 942 2,662 48

Exclusion 41,023 B 20,767 7,903 12,260 95

Designated Corridor 183 B 0 128 54 1

Avoidance 0 C 0 0 0 0

Exclusion 44,809 C 20,767 8,923 14,977 144

Designated Corridor 50 C 0 50 0 0

Avoidance 0 D 0 0 0 0

Exclusion 38,325 D 20,767 7,279 10,268 16

Designated Corridor 6,534 D 0 1,696 4,709 129

Table 4-27 Impacts to Scenic Quality Ratings

Table 4-28 Impacts to Sensitivity Ratings

Table 4-29 Impacts-Effect to VRI Classes
820 Chapter 4 RCNCA RCNCA Chapter 4 821

NATURAL SOUNDSCAPES

4.39.3 Summary of Impacts from Alternatives

Table 4-30 provides a summary of the impacts to visual resources. The first column lists the resource or resource use 

that has an impact/effect on visual resources. The second 

column lists whether the action(s) is a beneficial effect 

or an adverse impact. The third column provides a brief 

description of the impact/effect and the final column lists 

the intensity of the impact/effect. 

4.39.4 Cumulative Impacts

The CIAA for visual resources is all lands north of Old 

Highway 91 and I-15, from the Shivwits Reservation to 

Hurricane and extending north to the summit of the Pine 

Valley Mountains. Past and present actions within the 

CIAA that have affected visual resources include wildfires 

and noxious weed invasion, both of which have introduced 

modifications to the landscape. Large swaths of the CIAA 

are protected in perpetuity, including the NCA, Snow 

Canyon State Park, the Red Mountain and Cottonwood 

Canyon Wilderness areas (BLM), and the Pine Valley and 

Cottonwood Forest Wilderness areas (USFS).

Over the life of the plan, continued population growth 

in the large and small communities surrounding the 

NCA would erode natural night sky conditions in the 

CIAA. Extended drought conditions combined with 

urban growth construction activities would contribute 

to prolonged periods of fugitive dust and, during certain 

times of the year, could degrade visual resources.

The growing need to decrease the potential for catastrophic fire in the region through vegetation treatments 

aimed at reducing fuel loads would alter the visual 

landscape in the short term. It should be noted that short 

term in this instance could last for five years or more.

Construction of the “northern transportation route” and 

any future utility construction in the NCA would partially compromise the viewshed from the greater St. George 

metropolitan area.

4.40 NATURAL SOUNDSCAPES

This section discusses impacts on natural soundscapes 

from proposed management actions of other resources 

and resource uses. Existing conditions concerning 

soundscapes are described in Section 3.37, Natural 

Soundscapes.

Protection of the acoustical environment has received 

growing attention as a result of the increased understanding of its role in ecosystem health and visitor enjoyment. 

However, noise levels and their impact on NCA visitors 

cannot be effectively analyzed without data. The proposed installation of acoustical monitoring equipment 

that measures sound levels would make this possible.

NATURAL SOUNDSCAPES

4.40.1 Methods of Analysis

The analysis of potential impacts to the natural soundscape in the NCA is based on the local knowledge of 

recreation/wilderness planners. There are no areas within 

the NCA that have not been visited by BLM staff and 

while ambient noise levels have not been measured or 

documented, areas where noise is prevalent or absent 

have been noted.

4.40.1.1 Indicators

Indicators of adverse impacts on natural soundscapes 

include the following:

▶ Excessive ambient noise that is sufficient to degrade the visitor experience. Noises come primarily 

from automobile and other land-based motorized 

use, aircraft overflight, gunshots, and large group 

activities.

4.40.1.2 Assumptions

The analysis includes the following assumptions

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ Ambient noise from the greater St. George metropolitan area and the Interstate 15 corridor cannot be 

mitigated;

▶ NCA visitors should expect noise to be prevalent in the Rural and Frontcountry Recreation 

Management Zones;

▶ NCA visitors can find solitude and quiet in the 

Backcountry and Primitive Zones;

▶ The NCA will pursue opportunities to install acoustical monitoring equipment.

Implementing management for the following resources 

or resource uses would have negligible or no impact on 

natural soundscapes and are, therefore, not discussed 

in detail: Air Quality, Water Resources, Geologic and 

Paleontological Resources, Cave and Karst Resources, 

Soil Resources, Native Vegetation Communities, Fire 

and Fuels, Invasive Species, Vegetation Resource Uses: 

Livestock Grazing, Vegetation Resource Uses: Plant 

Materials, Special Status Species, BLM Sensitive Species, 

Other Fish and Wildlife Species, Heritage Resources, 

Wilderness, ACECs, Visual Resource Management, 

Lands with Wilderness Characteristics, Recreation 

and Visitor Services, Comprehensive Travel and 

Transportation Management, Lands and Realty, Public 

Education and Interpretation, and Scientific Research.

4.40.2 Direct and Indirect Impacts

Identifying and providing opportunities for visitors to 

experience natural soundscapes would be implemented 

primarily through the wilderness management program. 

Solitude is a primary component of wilderness character 

and is closely correlated with natural quiet.

Certain areas within the Red Mountain and Cottonwood 

Canyon Wilderness areas have ample opportunity to 

experience natural quiet, free of the sights and sounds 

of the nearby urban interface. While these are certainly 

beneficial effects, it is not possible to adequately quantify 

the value to individual visitors as everyone’s perception 

of solitude and natural quiet is different. Attempting to 

quantify such an analysis would be extremely difficult.

4.40.3 Summary of Impacts from Alternatives

Solitude is a consistent component of Backcountry and 

Primitive Recreation Management Zones and is closely 

correlated with natural quiet. Visitors have ample opportunity within the NCA to experience natural quiet, free 

of the sights and sounds of the nearby urban interface. It 

is not possible to adequately quantify the value of natural 

soundscapes to visitors until such time as acoustic data 

has been collected and analyzed.

4.40.4 Cumulative Impacts

The CIAA for Natural Soundscapes is similar to the 

extent for Visual Resources. It is defined by the topography that surrounds the NCA; the Pine Valley Mountains 

to the north and east and extending to I-15 and Old 

Highway 91 to the south. Past and present actions within 

the CIAA that have affected natural soundscapes have 

not been identified.

Over the life of the plan, continued population growth in 

the large and small communities surrounding the NCA 

would erode the natural soundscape within the CIAA. 

An increase in population would result in a corresponding increase in vehicle traffic during certain times of 

year. It would also increase the amount of target shooting 

which can disrupt the natural soundscape.

Expansion of utilities in the IPP and Navajo-McCullough 

ROW corridors would have a corresponding increase 

in maintenance vehicle traffic, which would impact the 

natural soundscape in the CIAA.

Resource / Resource Use Impact/Effect Description Intensity

Native Vegetation Impact Fuel breaks require intensive vegetation manipulation Unknown

Impact Fuel breaks may not meet Class II objectives in short term Major

Fire and Fuels Impact Fire and fire suppression can cause great contrast in the 

landscape Major

Effect Immediate fire suppression can protect visual resources Major

Noxious Weeds Impact Large scale projects could require intensive vegetation 

manipulation Unknown

Wilderness Effect VRM Class I provides the highest level of protection Major

ACEC Impact Revoking ACEC designation would have no impact None

Visual Resources Effect Alt C is most protective with VRM Class I or II on every acre Major

Impact Alt B contains VRM Class III for ROW avoidance Moderate

Impact Alt D contains VRM Class IV for ROW corridor Major

Wilderness Characteristics Effect Managing for VRM Class II in lands with wilderness characteristics offers no additional protection None

Recreation Effect Scenic quality is a recreation attraction Moderate

Impact Some recreation activities can impact visual resources Minor

Transportation Effect OHV area designations in all alternatives offer visual protection Moderate

Lands and Realty Effect Alt C contains VRM Class II for ROW exclusion Major

Impact Alt B contains VRM Class III for ROW avoidance Moderate

Impact Alt D contains VRM Class IV for ROW corridor Major

Table 4-30 Summary of Impacts to Visual Resources
822 Chapter 4 RCNCA RCNCA Chapter 4 823

LANDS WITH WILDERNESS CHARACTERISTICS

4.41 LANDS WITH WILDERNESS 

CHARACTERISTICS 

This section discusses impacts on lands with wilderness 

characteristics from the proposed management 

actions of other resources and resource uses. 

Existing conditions concerning lands with wilderness 

characteristics are described in Section 3.38, Lands with 

Wilderness Characteristics.

The BLM is required under FLPMA to maintain inventories of all public lands and their resources, including 

wilderness characteristics, and to consider such information during the land use planning process. During the 

planning process, the SGFO completed a comprehensive 

review of lands within the NCA to determine if they 

possess wilderness characteristics. This review included 

only BLM-administered lands. Within the NCA, four 

areas totaling of 1,586 acres were found to have wilderness characteristics. A detailed description of the inventory process as well as the findings is located in Chapter 

3.38 and in the Lands With Wilderness Characteristics in 

Beaver Dam Wash National Conservation Area and Red 

Cliffs National Conservation Area Inventory at www.blm.

gov/nxld. 

The analysis discusses the potential adverse impacts or 

beneficial effects of planning decisions on lands with 

wilderness characteristics, regardless of whether they are 

managed to protect those characteristics. Alternative C is 

the only alternative where the SGFO would actively manage for the protection of wilderness characteristics.

4.41.1 Methods of Analysis

The analysis of potential impacts to Lands with 

Wilderness Characteristics is based on two data sources: 

visitor use statistics and GIS. The GIS information used 

in this analysis includes wilderness boundaries, management unit boundaries, vegetation types, terrain models, 

wildlife habitat, transportation inventories, dispersed 

recreation inventories, aerial photography, fire history, 

and known historical/cultural sites. In the absence of 

data, analyses were based on the expertise of recreation/

wilderness planners.

4.41.1.1 Indicators

Indicators of adverse impacts on lands with wilderness 

characteristics include degradation of any components 

of the inventoried characteristics. Indicators of beneficial 

effects include the protection or enhancement of any 

components of the inventoried characteristics. 

Potential adverse impacts to wilderness characteristics 

include:

▶ Impacts on area naturalness that are apparent to the 

casual observer;

▶ Increases in visitation that impact opportunities for 

solitude.

Potential beneficial effects to wilderness characteristics 

include:

▶ The protection or enhancement of any of the 

individual components of the inventoried characteristics: naturalness, solitude, and opportunities for 

primitive, unconfined recreation.

4.41.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA;

▶ NCA status provides a high level of protection to 

all resource values, including lands with wilderness 

characteristics.

Implementing management for the following resources 

or resource uses would have negligible or no impact on 

lands with wilderness characteristics and are therefore 

not discussed in detail: Air Quality, Water Resources, 

Geological and Paleontological Resources, Cave and 

Karst Resources, Soil Resources, Native Vegetation 

Communities, Fire and Fuels, Noxious Weeds and 

Invasive Species, Vegetation Uses: Livestock Grazing, 

Vegetation Uses: Plant Materials, Special Status Species, 

BLM Sensitive Species, Other Fish and Wildlife Habitat, 

Heritage Resources, Wilderness, ACECs, Visual 

Resources, Natural Soundscapes, Recreation and Visitor 

Services, Travel and Transportation Management, Lands 

and Realty, Public Education and Interpretation, and 

Scientific Research.

4.41.2 Direct and Indirect Impacts/Effects

Managing lands with wilderness characteristics specifically to protect those characteristics is proposed only 

in Alternative C. There are four areas within the NCA 

totaling 1,586 acres where the SGFO inventory shows 

that wilderness characteristics are present. All four 

of these areas are contiguous to the Red Mountain or 

Cottonwood Canyon Wilderness areas. None of the four 

areas contain motorized routes. None of the four areas 

contain non-motorized trails, either existing or proposed. All four of the areas are within critical desert tortoise habitat. Because of the combination of these factors, 

LANDS WITH WILDERNESS CHARACTERISTICS

lands with wilderness characteristics would be equally 

protected in Alternatives A, B, and D, and managing 

specifically for their protection in Alternative C would 

be redundant as no adverse impacts would occur from 

any management action proposed by another resource or 

resource use (Table 4-31). 

The only difference in management between Alternative 

C and Alternatives B and D is that lands with wilderness characteristics would be managed as VRM Class 

I in Alternative C and as Class II in the others. When 

compared to the other management prescriptions, this 

is an insignificant difference. Managing as Class I offers no additional protection for lands with wilderness 

characteristics. 

4.41.3 Summary of Impacts from Alternatives

Lands with wilderness characteristics are present within 

the NCA. Managing those areas specifically to protect 

their wilderness characteristics is proposed only in 

Alternative C. The proposed management prescriptions 

for lands with wilderness characteristics offer no additional protection for wilderness characteristics as no 

adverse impacts would occur from management actions 

proposed by other resources or resource uses. Wilderness 

characteristics are protected equally in all alternatives.

4.41.4 Cumulative Impacts

The CIAA for wilderness characteristics is all of 

Washington County, the northern portion of the Arizona 

Strip, and the western half of the BLM Kanab Field Office. 

Wilderness characteristics are not wilderness, nor are 

they wilderness study areas. They are a resource that is 

periodically inventoried under FLPMA. However, the 

inventory process is similar to what was used in the 

original 1979-1980 inventory that resulted in the majority of Wilderness study areas (WSA) that exist today. 

The difference between Wilderness/WSA and wilderness characteristics is simple: designating wilderness 

is a congressional action; making a decision to protect 

wilderness characteristics is an administrative action. 

The SGFO conducted an inventory for wilderness 

characteristics across the entire field office as part of this 

planning effort. Using BLM Manual 6310, the presence 

or absence of wilderness characteristics was noted for 

every acre of BLM-managed land. Portions of this inventory are included in this plan; the remainder will be part 

of the Travel Management Plan. 

Wilderness characteristics are primarily affected by the 

number and proximity of motorized travel corridors; the 

volume and type of traffic on those corridors; and the 

quantity and type of recreational users. To a lesser extent, 

range and wildlife management projects can affect areas 

with wilderness characteristics. These impacts normally 

come from vegetation treatments and the installation, 

maintenance, and use of range/wildlife catchments and 

wildlife drinkers. 

The growing need to decrease catastrophic fire potential in 

the region through the reduction of fuel loads by mechanical means would gradually and visibly alter landscapes 

where treatments are conducted, with short-term reductions in the quality of solitude, naturalness, and opportunities for primitive/unconfined recreation. Such projects 

could also preserve wilderness characteristics outside the 

treatment areas by preventing catastrophic wildfires.

Following the passage of OPLMA in 2009, Congress 

designated 14 wilderness areas on BLM-managed lands in 

Washington County and three areas within Zion National 

Park. When combined with USFS wilderness in the Pine 

Valley Ranger District, there are 220,439 acres of designated wilderness in Washington County. This is 14% of the 

entire county. For BLM-managed lands the number is significantly higher. Over half of the wilderness in the county, 

129,000 acres, is on land managed by the SGFO. This 

is 20% of the total BLM-managed acres in Washington 

NCA Management Under All Alternatives, OPLMA Section 1975

Withdrawn from all forms of entry, appropriation, and disposal under public land laws;

Withdrawn from location, entry, and patenting under the mining laws;

Withdrawn from operation of mineral leasing, mineral materials, and geothermal leasing laws; 

Motorized vehicle use Limited to Designated Roads

Proposed Management of Lands with 

Wilderness Characteristics-Alternative C

Proposed Management of NCAAlternative A (No Action)Proposed Management of NCAAlternatives B and D

VRM Class I VRM Class III VRM Class II

ROW Exclusion Area ROW Avoidance Area ROW Exclusion Area

Closed to Commercial and Non-Commercial Fuelwood Harvesting

Table 4-31 Impact Analysis Comparison for Lands with Wilderness Characteristics
824 Chapter 4 RCNCA RCNCA Chapter 4 825

RECREATION AND VISITOR SERVICES

County, or to put it another way, one out of every five acres 

managed by the SGFO is designated wilderness.

4.42 RECREATION AND VISITOR SERVICES

This section analyzes potential impacts to recreation 

resources from the proposed management actions of 

other resources and resource uses. Existing conditions 

concerning recreation are described in Section 3.39 

Recreation and Visitor Services.

As part of the RMP process, the SGFO has three options 

for recreation allocations: 1) designating the entire NCA 

as a SRMA; 2) leaving the existing designations of the 

existing SRMA (Red Mountain/Santa Clara) and ERMA 

(remainder of NCA) in place; or 3) lift the existing 

SRMA and designating the entire NCA as an ERMA.

In an SRMA, management actions are focused on protecting specific, high-quality recreation opportunities 

that are targeted to achieve beneficial outcomes. Benefits 

from recreation opportunities can include personal benefits to participants in the form of improved health and 

well-being; benefits to local communities, both social 

and economic; and benefits to the environment through 

increased protection via targeted infrastructure development, interpretation, and outreach. 

Benefits are dependent on the specific recreational 

activities as well as the physical, social, and operational 

settings where those activities occur (Appendix H). 

Changes in recreation activities or settings can result in 

changes to the experiences visitors have and to the personal, community, and environmental benefits that result 

from those experiences. 

Even though it lacks an official BLM SRMA designation, 

the NCA has been effectively managed as an SRMA since 

the adoption of the PUP for the Reserve in June 2000. 

This document recognized the value of this open space 

for dispersed, non-motorized recreation opportunities. It also recognized that recreational use needs to be 

intensively managed in order to protect the critical desert 

tortoise habitat that was the driving force behind the 

original Reserve. Because of the overlap of critical habitat, urban interface, and existing recreation management, 

SRMA status is proposed in all action alternatives. 

The proposed SRMA is then further divided into RMZ. 

The management zones in Alternatives B, C, and D use 

the standard BLM terminology of Rural, Frontcountry, 

Backcountry, and Primitive, with each having specific 

management prescriptions. Alternative A contains a portion of the existing Red Mountain/Santa Clara SRMA, 

with the remainder having an ERMA designation.

While the NCA does not currently have official SRMA 

status, it does have recreation management zones aimed 

at managing recreational use in critical tortoise habitat. 

These zones, created through the PUP, are Upland and 

Lowland, and in the NCA they correspond roughly with 

the BLM proposed designations of Rural/Frontcountry 

(Lowland) and Backcountry/Primitive (Upland). 

4.42.1 Methods of Analysis

The analysis of potential impacts to recreation activities 

and opportunities were analyzed using two data sources: 

visitor use statistics and GIS. Visitor use is tracked using 

digital traffic counters, which count both motorized and 

non-motorized visitors. Counters are moved periodically 

to track visitation in different locations. The GIS data 

used in this analysis includes, but is not limited to: administrative boundaries, vegetation types, wildlife habitat, T&E species habitat, T&E species occurrence data, 

motorized routes, non-motorized trails, campgrounds, 

dispersed campsites, climbing areas, aerial photography, 

terrain models, fire history, and known historical/cultural sites. In the absence of data, analyses were based on 

the expertise of recreation/wilderness planners and other 

applicable resource specialists.

Adverse impacts to recreation opportunities could result 

from management actions that diminish any of the 

fundamental components listed in the indicators section 

below. These could be restrictions on certain activities or 

changes to the physical, social, and administrative settings that would limit recreation opportunities. 

Beneficial effects could result from management actions 

that maintain or enhance any of the fundamental components listed in the indicators section below. These could 

be improved access for certain activities or changes to the 

physical, social, and administrative settings that would 

enhance recreation opportunities. 

4.42.1.1 Indicators

Indicators of adverse impacts to recreation opportunities 

include the following:

▶ Management actions that result in the elimination 

or reduction of access to recreation opportunities in 

the NCA;

▶ Management actions that result in increased conflict between recreation opportunities and other 

resources or resource uses;

▶ Management actions or allowable use restrictions 

that result in increased conflict between different 

recreational user groups.

RECREATION AND VISITOR SERVICES

Indicators of beneficial effects on recreation include the 

following: 

▶ Management actions that result in the expansion or 

improvement of access to recreation opportunities 

in the NCA;

▶ Management actions that result in decreased conflict between recreation opportunities and other 

resources or resource uses;

▶ Management actions and allowable use restrictions 

that result in decreased conflict between different 

recreation users.

4.42.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ The RCNCA has been managed as a de facto SRMA 

since the adoption of the PUP for the Reserve;

▶ The basic restrictions on the types of allowable recreation activities identified in the PUP will remain 

in place;

▶ Population growth in Washington County will 

result in increased visitation to the NCA;

▶ Demand for Special Recreation Permits would 

increase over the life of the plan, but only if the 

existing trail system was improved.

Implementing management for the following resources 

or resource uses would have negligible or no impact on 

Recreation opportunities and are therefore not discussed 

in detail: Air Quality, Soil Resources, Invasive Species 

Management, Vegetation Resource Uses: Livestock 

Grazing, Other Fish and Wildlife Species, ACECs, and 

Social and Economic Conditions.

4.42.2 Direct and Indirect Impacts

Recreation opportunities in the NCA are primarily influenced by the number and quality of non-motorized trails 

and trailheads; the quality of on and off-site interpretation; and the quality of developed facilities at the Red 

Cliffs Recreation Area. 

Alternatives B, C, and D each identify a different management emphasis for recreation resources. Because protection of critical tortoise habitat has the most significant 

impact on recreation opportunities, the alternatives are a 

mirror image of the special status species alternatives. 

Alternative D is the least restrictive, with proposed expansions of the trail system, campgrounds, and commercial/competitive use. 

Alternative C is the most restrictive, with further restrictions on all types of recreational use. Alternative 

B strikes a balance between the other alternatives. 

Alternative A follows existing recreation management 

through the Reserve PUP. 

4.42.2.1 Impacts from Management of Water 

Resources

The natural sandstone catchments formed by Quail Creek 

along the Red Reef trail are popular destinations for day 

hikers. During the spring, the area is crowded with families, dogs, and students on spring break. Monitoring coliform counts in Quail Creek is proposed during the busy 

months in all alternatives. This could help prevent illness 

and infection among the visiting public. 

If a coliform count proved to be too high and a closure 

were to be required, it could adversely impact a large 

number of visitors, significantly reduce recreation area 

revenue, and increase the need for law enforcement to 

enforce the closure. While it is not possible to analyze 

hypothetical impacts, if the closure was longer than two 

weeks, impacts for the recreation opportunities and recreation revenues could be moderate to major.

4.42.2.2 Impacts from Management of Geologic and 

Paleontological Resources

Conducting paleontological surveys could have beneficial effects if, for example, new dinosaur tracks or other 

paleontological resources were discovered. Such sites are 

popular with the public and are proven recreation attractions. It is possible that recreation opportunities could be 

adversely impacted if a survey, or the results of a survey, 

required a trail closure. 

4.42.2.3 Impacts from Management of Cave and Karst 

Resources

Systematic inventories of cave and karst resources could 

result in increased recreation opportunities if significant 

caves were discovered and made available for public use.

4.42.2.4 Impacts from Management of Native 

Vegetation Communities, and Fire and Fuels

Fuel breaks and hazardous fuels reduction projects may 

offer opportunities for new trail development in areas 

where fuel reduction is already a priority. Locating trails 

within fuel breaks would create new opportunities within 

an already disturbed landscape.

Prohibiting new surface disturbing activities near riparian 

areas varies by alternative: 1,000 feet in Alternative C; 500 

feet in Alternative B; and 250 feet in Alternative D, except 

when the project would improve riparian resources. The 
826 Chapter 4 RCNCA RCNCA Chapter 4 827

RECREATION AND VISITOR SERVICES

construction and maintenance of non-motorized trails 

fall into this category as they are surface disturbing activities. Riparian areas in the NCA are limited to Quail Creek, 

Leeds Creek, and the Virgin River. Smaller areas exist 

elsewhere as the result of small seeps and springs, but only 

the three listed above have consistent running water.

Riparian areas in the desert are rare and tend to attract visitors, drawn by the cooler temperatures, lush 

vegetation, and presence of water. One of the best ways 

to manage visitor use and protect riparian resources is 

to construct sustainable trails in and adjacent to easily 

accessible riparian areas to prevent further degradation from unmanaged visitation. Table 4-32 shows the 

number of trail miles that currently exist inside the three 

buffer zones.

The proposed wildfire management decisions in all 

alternatives are targeted at immediate suppression. 

While this is in place to provide maximum protection for 

desert tortoise habitat and homes in the adjacent wildland urban interface, it also serves to protect recreation 

resources. Once a trail has burned over, it loses much 

of its desirability as a recreation destination as the now 

barren landscape degrades the visitor experience. Full 

suppression tactics preserve the landscape on which the 

recreation experience depends.

4.42.2.5 Impacts from Management of Vegetation 

Resource Uses: Plant Materials

Dispersed camping in Alternative C is allowed only 

in the Primitive Management Zone. Not allowing the 

collection of dead and down materials for campfires 

in Alternative C would remove the option of having a 

campfire in the Red Mountain or Cottonwood Canyon 

Wilderness areas. This would have direct, but negligible 

impacts. It could also have indirect beneficial effects by 

preventing potential wildfires.

4.42.2.6 Impacts from Management of Special Status 

Species 

Using protective measures such as fencing and trail 

designation to protect Shivwits milkvetch habitat is 

proposed in Alternatives B, C, and D and such actions 

have the potential to impact recreation opportunities. 

If the trails were closed and fenced, this could impact 

the White Reef area as the entire trail system in this area 

is within critical habitat. The White Reef, Leeds Reef, 

Adams, Grubstake, Adit, and Tipple trails are all within 

critical habitat. If closures or restrictions were to be 

implemented, recreation opportunities would be severely 

curtailed in one of the most heavily visited areas in the 

NCA. Impacts would be direct and moderate to major.

The decision in the special status species Wildlife section in Alternatives B, C, and D states: Do not authorize 

recreational activities or uses in areas where special 

status species may be degraded by these authorizations. 

This is targeted at the protection of threatened Mojave 

desert tortoise habitat and it has major implications for 

recreational opportunities. While preservation of tortoise 

habitat is required under the endangered species act, it is 

important to analyze how recreational activities threaten 

the tortoise and its habitat. It is also important to recognize the intent of the enabling legislation. OPLMA 

stated that the purpose of the Red Cliffs NCA was: “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.”

The enabling legislation clearly recognized recreational 

use as one of the values of the NCA. While protecting 

and enhancing recreation opportunities cannot be done 

at the expense of other NCA values, careful planning in 

consultation with the USFWS could expand recreational 

opportunities without compromising critical tortoise 

habitat. For a more detailed analysis of recreational 

impacts in the NCA, please see 4.42.2.14 Impacts from 

Management of Recreation and Visitor Services.

4.42.2.7 Impacts from Management of BLM Sensitive 

Species

Authorized activities that degrade aquatic habitat in 

the Virgin River, its tributaries, Quail Creek and Leeds 

Creek, could be restricted in all alternatives. This decision is designed to protect the habitat of the Virgin 

spinedace, desert sucker, and flannelmouth sucker 

populations. Potential impacts to recreation opportunities could require seasonal closures, restrictions on group 

sizes or visitor numbers, or other management actions, 

where fish populations are known to occupy the perennial reaches of Quail and Leeds Creeks.

RECREATION AND VISITOR SERVICES

4.42.2.8 Impacts from Management of Heritage 

Resources

The protection of heritage resources in all alternatives 

would not have adverse impacts to recreation opportunities. It is possible that future surveys could result in road 

closures or trails being rerouted, but any impacts would 

likely be negligible.

If is more likely that the expansion of public use sites proposed in Alternative D, and to a lesser extent Alternative 

B, could result in more interpreted sites that could be 

enjoyed by a variety of visitors. Such sites are popular with 

the public and are proven recreation attractions. Because 

the number and scope of such actions have yet to be defined, it is not possible to quantify the beneficial effects.

4.42.2.9 Impacts from Management of Wilderness

Recreational traffic in the Red Cliffs and Cottonwood 

Canyon Wilderness areas ranges from light to heavy 

depending on location. Opportunities for primitive, 

unconfined recreation are easily accessible, but many 

of the popular destinations can be crowded on spring 

and fall weekends. Proximity to the greater St. George 

metropolitan area provides easy access for a large and 

growing population. 

There are no existing or proposed wilderness management decisions that are inconsistent with proposed recreational activities in the Red Mountain or Cottonwood 

Canyon Wilderness areas.

4.42.2.10 Impacts from Management of Visual 

Resources

Proposed VRM decisions to incorporate visual design 

considerations into project design and to reduce or 

prevent impacts to night skies would enhance the recreational experiences in the NCA. 

4.42.2.11 Impacts from Management of Natural 

Soundscapes

Certain areas within the Red Mountain and Cottonwood 

Canyon Wilderness areas have ample opportunity to 

experience natural quiet, free of the sights and sounds 

of the nearby urban interface. While these are certainly 

beneficial effects, it is not possible to adequately quantify 

the value to individual visitors as everyone’s perception 

of solitude and natural quiet is different.

4.42.2.12 Impacts from Management of Lands with 

Wilderness Characteristics

Managing lands with wilderness characteristics specifically to protect those characteristics is proposed only 

in Alternative C. There are four areas within the NCA 

where the inventory shows that wilderness characteristics 

are present. All four of these areas are contiguous to the 

Red Mountain or Cottonwood Canyon Wilderness areas. 

None of the four areas contain motorized routes. None of 

the four areas contain non-motorized trails, either existing or proposed. All four of the areas are within critical 

desert tortoise habitat. Because of the combination of 

these factors, recreation opportunities would not change 

if the areas were managed specifically to protect wilderness characteristics. Managing for wilderness characteristics offers no measurable beneficial effects to recreation 

opportunities that are not equally provided by NCA and 

Habitat Conservation Plan status.

4.42.2.13 Impacts from Management of Recreation 

and Visitor Services

Revoking the existing ERMA and replacing it with the 

Red Cliffs SRMA, would provide long-term management 

direction consistent with current BLM recreation management practices and national policy. 

Revoking the existing Upland/Lowland Recreation 

Management Zones and replacing them with management zones consistent with existing policy would 

provide BLM staff with a suite of management tools that 

would clarify rules and regulations and improve recreational opportunities. 

The existing management zone boundary that divides 

Upland/Lowland follows topographic features, trails, 

and administrative boundaries and is often confusing to 

the public. Under current management, if a visitor is in 

the lowland zone, they are restricted to designated trails. 

If they’re in the upland zone, cross-country travel is allowed on foot or horseback, but mountain bikes remain 

restricted to designated trails. 

The management zones in Alternatives B, C, and D, simplify the zoning concept by essentially making the management zones, but not the rules, invisible to the public. 

The proposed management zones of Rural, Frontcountry, 

Backcountry, and Primitive are designed to assist BLM 

staff in deciding where management controls will be employed and future funds will be spent. If a visitor crosses 

from the Front country zone into Backcountry zone, interpretative displays would be gone and directional/regulatory signs would be fewer. It is unlikely that the visitor 

would notice the transition, but it is not necessary. The 

goal is to keep visitors on designated trails, and simplifying management controls makes this easier for the public 

to understand.

Miles of Existing Trails Adjacent to Proposed Riparian 

Protections

Alt B – 

Within 500 

Foot Buffer

Alt C – 

Within 1000 

Foot Buffer

Alt D – 

Within 250 

Foot Buffer

Miles of Trail 15.6 12.8 22.1

Table 4-32 Non-Motorized Trails Adjacent to Riparian 

Resources
828 Chapter 4 RCNCA RCNCA Chapter 4 829

RECREATION AND VISITOR SERVICES

Because the primitive zone boundary matches designated 

wilderness, the only rule the visiting public needs to know 

is: If you’re inside the Red Mountain or Cottonwood 

Canyon Wilderness areas, cross-country travel is allowed; 

if you’re outside the wilderness boundary, you must stay 

on designated trails. Since the wilderness boundaries are 

already signed, this removes the confusing upland/lowland zone boundary problem. It also solves the ambiguous 

decision of allowing horses and hikers to venture off-trail 

in the upland zone, but not mountain bikes. This decision 

does not compromise critical tortoise habitat as designated wilderness is almost entirely within the upland zone. 

In Alternatives B, C, and D, the proposed management 

zones are more restrictive than current management. 

This is deliberate and part of a two-pronged approach. 

In conjunction with restricting visitors to designated 

trails outside of wilderness, the trail system would be 

expanded and improved. Please see the section “New Trail 

Construction” below for further analysis.

Developing implementation-level plans in Alternatives 

B, C, and D to manage specific activities would benefit 

recreation opportunities in the long-term by gathering 

site-specific public input and identifying specific needs 

and opportunities.

Developing concessionaire contracts (e.g.: Red Cliffs 

Recreation Area) in Alternatives B, C, and D would allow BLM staff to focus their efforts on other recreation 

priorities while simultaneously providing private 

sector employment.

Developing uniform architectural standards in 

Alternatives B, C, and D for all site improvements, recreational facilities, site fixtures, structures, and associated spaces would provide the NCA with a recognizable 

identity and would improve the visitor experience.

Sand Cove Primitive Camping Area

Alternative A allows primitive camping at Sand Cove. No 

camping facilities in the area currently exist, and impacts 

include vegetation trampling, firewood foraging, and 

human waste. Under Alternative A, impacts are expected 

to remain the same or slowly increase over time as use 

matches local population growth.

In Alternative D, the Sand Cove Primitive Camping Area 

would be upgraded to include a vault toilet, designated 

campsites, delineated parking, vehicle access improvements, and metal campfire rings. These upgrades would 

improve sanitation, public safety, and visitor experiences. This alternative would also limit group size to a 

maximum of 40 individuals. The beneficial effects would 

be direct and minor to moderate. It is likely that this 

decision would increase the Sand Cove campground’s 

popularity and detract from the primitive experience that 

regular visitors have come to expect. An increase in the 

number of amenities and a corresponding increase in use 

may require that the site be considered as a fee area in 

order to pay for the expanded maintenance needs. 

In Alternative C, the Sand Cove Primitive Camping 

Area would be closed to overnight camping and the 

area would be converted to day-use. This would eliminate camping-related impacts like vegetation trampling, 

firewood foraging, and human waste. Day users would 

benefit from this decision, but overnight users would be 

displaced to other locations. This decision would remove 

a recreation opportunity that has been in place for years 

and is relied upon by organized groups.

Alternative B is similar to Alternative A, but would 

include designated campsites and metal campfire rings. It 

would also limit group size to a maximum of 20 individuals. Under this alternative, overnight campers would be 

required to pack out human waste. Alternative B would 

preserve the existing primitive feel of the camping, but 

would reduce impacts from trampling and human waste. 

It is a compromise between the development proposed in 

Alternative D and the closure in Alternative C.

Dispersed Camping

Alternative A allows dispersed camping in the Upland 

Zone only. The Lowland Zone is closed to camping. 

Alternatives B and D are similar; they would allow dispersed camping in the Backcountry and Primitive Zones 

while the Rural and Frontcountry Zones would be closed 

to dispersed camping. Alternative C would close the 

NCA to dispersed camping except in the Primitive Zone.

The SGFO dispersed campsite inventory indicates that 

little to no dispersed camping actually occurs in the 

NCA. This is because the terrain that is accessible from 

authorized roads is relatively open and the roads that 

are open to the public do not offer sufficient seclusion to 

make car camping or walk-in camping a desirable option. 

On Cottonwood Road, visitors looking for a dispersed 

campsite will simply drive a little further to camp in the 

trees on Dixie National Forest. Backpacking and horse 

packing do occur in the Red Mountain and Cottonwood 

Canyon Wilderness areas. Any impacts to dispersed 

camping from decisions in Alternatives B, C, or D are 

likely to be negligible.

RECREATION AND VISITOR SERVICES

New Trail Construction

The designation, construction, and maintenance of individual roads and trails are not land use plan decisions. 

They are implementation decisions, meaning they are 

lower tier, and making future changes to those decisions would not require a land use plan amendment. The 

SGFO is working on a comprehensive travel and transportation plan that analyzes every road and trail within 

the field office boundary, including both NCA’s. This 

planning effort includes everything from paved roads 

to non-motorized singletrack. It also includes proposed 

trails, many of which were submitted by organized user 

groups representing hikers, mountain bikers, and equestrians. The travel planning effort is on a separate, but 

parallel track to this land use planning effort. Its release 

will follow closely behind this plan.

There is a decision in Chapter 2 that states, “Construct 

new trails in the Rural, Frontcountry, or Backcountry 

Zones, as shown in the Travel Management Plan for 

Alternative (B, C, D).” This is an implementation-level decision and it was included for information purposes only, 

because the travel plan is certainly the most anticipated 

part of the current planning efforts. In the NCA, the travel 

plan is considered crucial because it proposes a complete 

overhaul of the existing non-motorized trail network.

In 2000, the PUP designated approximately 178 miles of 

non-motorized trails and associated trailheads as available 

for public recreation use. Of the 178 trail miles, 44 miles 

(26%) were existing two-track roads, the majority of which 

were power line or water line maintenance roads. Nine 

miles (3%) were paved bicycle/pedestrian trails along State 

Route 18 and the Red Hills Parkway. Primitive routes, 

which were unmarked, undeveloped, and unmaintained 

trails, totaled approximately 47 miles (27%). Primitive 

routes, because of their popularity, were included on visitor maps and interpretive publications. Developed and 

maintained singletrack totaled 79 miles (44%).

All other roads, trails, and linear disturbances that were 

not included in the 178 mile authorized trail system were 

officially closed. It was assumed that the authorized trail 

system, cobbled together as it was from a disparate mix 

of maintenance roads, user-created singletrack, and livestock trails, would meet the recreational demands of the 

greater St. George metropolitan area well into the future, 

while adequately protecting critical habitat for desert 

tortoise and other at-risk species. 

Between 2000 and 2007, the population of the greater 

St. George metropolitan area grew an average of 7% 

annually. Many of the newcomers were active retirees, 

drawn by Washington County’s warm weather and abundant recreational opportunities. This population increase 

is also considered the beginning of the boom in local 

non-motorized recreation, driven primarily by increasing numbers of road cyclists, triathletes, hikers, runners, 

rock climbers, and mountain bikers. 

An increase in recreational visits to the Reserve mirrored 

the population increase, and it was at this point that deficiencies in the existing trail system began to surface. New 

residents seeking recreational experiences on heavily 

promoted trails of the Reserve were often disappointed 

when they realized that this meant hiking on power line 

roads and other linear disturbances created by prior land 

uses, such as livestock grazing and utility development. 

Predictably, some users began to pioneer new routes that 

produced the kinds of backcountry experiences they 

were seeking.

More than 100 miles of social trails have since been illegally created within the NCA boundary since the PUP 

was approved in 2000. These were mapped by SGFO 

recreation staff and the documentation of that effort can 

be found in Appendix K. 

The proliferation of unauthorized, user-created trails is 

directly related to the PUP’s designation of the original 

trail system. The main objective for the existing trail 

network was to avoid loss of additional tortoise habitat, 

which would have happened if new trail construction 

was authorized. However, the existing trails were not 

designed for sustainability, or for specific recreation users. The two-track roads that were included in the trail 

network do not provide a high-quality visitor experience, 

as a majority serve as access roads for power transmission lines or other utilities.

The travel plan for the NCA mirrors the aspirational 

goals of the individual alternatives in this plan. But it 

also recognizes the reality that the NCA is the urban 

interface for the greater St. George metropolitan area and 

recreational visits will continue to grow. The travel plan is 

based on the assumption that in order to eliminate illegal 

trail use and protect critical habitat, the trail system must 

provide the experience that visitors are seeking. To do 

this, some new trail construction has to occur. The full 

details and analysis will be released in the travel management plan for the NCA.

Special Recreation Permits

In Alternatives B and C, limiting the number of SRPs 

to 10% of overall visitation would keep the ratio of 
830 Chapter 4 RCNCA RCNCA Chapter 4 831

RECREATION AND VISITOR SERVICES

commercial use to other visitors consistent over time. 

Existing commercial activity is currently about 3% of total visitation, so Alternatives B and C allow for significant 

amount of growth in private sector guiding businesses. 

It is anticipated that it would take 10-15 years before the 

10% threshold is reached. Beneficial effects to private sector businesses would be indirect and minor to moderate.

In Alternative D, the number of SRPs would be limited to 

20% of overall visitation. This would allow for large-scale 

growth in private sector guiding businesses, but it could 

also increase the number of complaints from individual 

visitors about large guided groups. It is possible that the 

20% threshold would never be reached. Beneficial effects 

to the private sector would be indirect and minor to 

moderate. Impacts to the visitor experience could range 

from negligible to moderate.

Group size limits for SRPs would be set on a case-by-case 

basis in Alternatives B and D. Example: guided hikes can 

become cumbersome and unpleasant for participants 

and other trail users when group size exceeds 12, including guides. But the same cannot be said for motor coach 

tours using 21 passenger vans, whose visitors never leave 

the vehicle. This decision would allow BLM Recreation 

staff maximum flexibility when reviewing new SRP applications. Alternative C is more restrictive, limiting all 

groups to a maximum size of 15, including guides.

Competitive events of any kind would not be authorized 

in Alternative C. Competitive non-motorized events 

and organized group events could be authorized in the 

NCA in Alternatives B and D, if they meet the following 

criteria:

▶ Event staging takes place outside the NCA or takes 

place on designated roads and/or at trailheads 

inside the NCA;

▶ The event causes no new surface disturbance;

▶ Event scheduling complies with seasonal restrictions to protect wildlife and habitats, (e.g., restrictions on events during desert tortoise active season, 

generally between March 15 and October 15).

Group size limits for competitive events would be set 

on a case-by-case basis by incorporating the following 

factors: type of event, length of event, number of participants, potential for resource impacts, potential for 

impacts to other visitors, and compatibility with RMZs.

The greater St. George metropolitan area is a hotbed for 

running, triathlon, and cycling events. It also plays host 

to scouting events, church events, school classes, and historical re-enactments. Allowing those events to occur in 

or travel through the NCA could raise the profile of the 

NCA. Adverse impacts are not likely given the restrictive 

event criteria and the group-size factors.

Rock Climbing

Climbing would be authorized on Sandstone Mountain 

in the Babylon area in Alternatives B and D. The area 

has been identified as having potential for a variety of 

climbing opportunities. Sandstone Mountain was not 

included when climbing areas were initially authorized 

in the Reserve’s PUP. Not including it effectively closed 

the area to all climbing and highlighted a major flaw in 

the PUP. Sandstone Mountain is located in the Upland 

Zone, which means that cross-country travel on foot or 

horseback is allowed. So it is legal to walk cross-country 

to the base of the cliff, but it is not legal to actually climb 

on it. If the goal of the decisions in the PUP were to 

protect tortoise habitat, this decision makes no sense 

as tortoise are found on the ground, not on cliff faces. 

Designating this as an official climbing area in the NCA 

clears up this discrepancy.

Climbing would be allowed anywhere in the Primitive 

Zone, which is designated wilderness. Climbing in 

wilderness has a long and rich history, and is one of the 

examples often cited when describing “primitive, unconfined recreation.” Motorized and mechanized equipment 

are not allowed in wilderness so power drills typically 

used to install bolt anchors are prohibited. This generally 

restricts climbing to traditional methods, which dovetails 

perfectly with wilderness designation. 

Other Recreational Activities

Geocaching would be prohibited in the Frontcountry and 

Primitive Zones, which are critical tortoise habitat and 

designated wilderness, respectively. Because visitors are 

required to stay on designated trails in the Frontcountry 

Zone, geocaches would be inappropriate and could 

contribute to vegetation loss and habitat degradation. 

Physical geocaches are also inappropriate in wilderness. 

Virtual geocaches would be allowed because they involve 

no physical installation. 

Geocaches could be allowed in the Rural and 

Backcountry Zones, depending on the proposed location. 

The Backcountry Zone is generally outside of critical 

tortoise habitat and the Rural Zone is comprised of roads 

and trailheads. All geocache placements would require 

permission from NCA staff. Impacts to recreation opportunities would be negligible to minor as these management controls are already in place in Alternative A.

RECREATION AND VISITOR SERVICES

Powered parachutes, remote controlled aircraft, and 

paintball activities are prohibited in all alternatives. 

None of these activities are appropriate in a National 

Conservation Area and all would typically involve noise 

that could disturb other visitors and wildlife, or would require off-trail access. Impacts to recreation opportunities 

would be negligible as there are many other areas outside 

the NCA where these activities would be appropriate.

Discharge of Firearms and Hunting

Target shooting is prohibited in the NCA in all alternatives, including Alternative A, as it frequently requires 

off-trail travel, which poses a risk to desert tortoise 

habitat. Impacts to target shooting would be negligible as 

there are thousands of acres of public land in the county 

where target shooting is an acceptable activity.

Hunting is allowed throughout the NCA, provided it is 

in compliance with state hunting laws. No impacts to 

recreational opportunities would occur. 

Monitoring

Developing a comprehensive program to monitor 

recreational impacts would not affect recreational opportunities, but it would allow for greater protection of 

NCA values, including critical habitat. A comprehensive 

monitoring program would target the protection of critical habitat by focusing primarily on the identification of 

unauthorized trails or any other illegal surface-disturbing activity. 

Public Education and Interpretation

An interpretive master plan would have long-term 

beneficial effects on all resources in the NCA. Informed 

visitors are visitors who both follow the rules and have a 

greater appreciation for the values of the NCA. Beneficial 

effects are indirect and could range from minor to major. 

Scientific Research

One of the biggest gaps in current desert tortoise research is the lack of data about the impact that nonmotorized activities have on tortoise populations. The 

impact of motorized recreation is well documented, but 

there is no valid research on the non-motorized side. 

Could a well-designed hike/bike trail system coexist with 

critical habitat? What is the “zone of influence” of a trail 

system? The NCA provides the perfect laboratory to conduct such studies and the effects of such research could 

have far-reaching implications.

4.42.2.14 Impacts from Management of 

Comprehensive Travel and Transportation

Regardless of alternative, there are only two OHV area 

designations for the NCA: 1) Closed to OHV Use and, 2) 

Limited to Designated Roads and Trails. These designations do not change by alternative, including Alternative 

A, as motorized vehicle travel in the NCA has been managed as Limited to Designated Roads and Trails since 

the SGFO RMP was approved in 1999; the designated 

roads and trails identified through the implementationlevel PUP, approved in 2000. There would be no adverse 

impacts or beneficial effects to recreation opportunities 

from travel and transportation management. All designated trails are limited to non-motorized use only. In all 

alternatives, the Red Mountain and Cottonwood Canyon 

Wilderness areas are closed to motorized use.

4.42.2.15 Impacts from Management of Lands and 

Realty

Alternative A would manage the NCA as an Avoidance 

area for new utility and transportation ROWs, outside 

of the existing designated corridors along State Route 

18 and I-15. Alternative B would manage the NCA as an 

Exclusion area, but would preserve the existing ROW’s 

along State Route 18 and I-15, and provide a ROW 

Avoidance area along the powerlines that currently cross 

the NCA. Alternative C would manage the NCA as an 

Exclusion area for new ROWs and revoke the designated 

corridor along I-15 through the NCA. Alternative D 

would manage the NCA as an Avoidance area for new 

ROWs outside the existing designated corridors along 

State Route 18 and I-15 and designate a new 6,350-acre 

corridor to accommodate new utilities and transportation 

facilities, including the “northern transportation route”.

Washington County has submitted six potential alignments for the “northern transportation route” these 

alignments are shown on Map 4-1. The proposed rightsof-way corridor in Alternative D encompasses all of the 

proposed “northern transportation route” alignments 

and all of the current utility developments on public 

lands. It also provides acreage sufficient to accommodate 

future utility development.

Because of the geographic differences in the alignments, 

each one poses different potential impacts to recreation 

opportunities in the NCA. Those impacts would come 

primarily in the form of disruption to individual trails 

and trailheads. Table 4-33 lists the trails and/or trailheads 

that could be impacted by each proposed alignment. 
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0 1 2 0.5 Miles0 1 2 0.5 Kilometers

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Note: Decisions in this document

only apply to BLM lands

Northern Corridor Alignments

Option 1Option 2Option 3

Option 4Option 5Option 6

BLM Wilderness AreaBureau of Land ManagementStateState Parks and RecreationState Wildlife Reserve/Management Area

Non-motorized Trail

832 Chapter 4 RCNCA RCNCA Chapter 4 833

MAP 4-1 RECREATION AND VISITOR SERVICES

Trails and trailheads listed in Table 4-33 would likely be 

impacted by future development. The magnitude of the 

impacts would depend on final alignment of the “northern transportation route”. Whichever alignment was 

chosen, the trails and trailheads listed either fall within 

the alignment or, in the case of trails, are bisected by the 

alignment. Any of the proposed alignments would also 

preclude other trail development unless non-motorized 

underpasses were included in the development plans. 

Actual impacts would depend on final alignments of 

proposed highways and/or utilities.

4.42.2.16 Impacts from Management of Public 

Education and Interpretation

Developing an interpretive master plan that creates a longterm vision to guide interpretive services could enhance 

the visitor experience at trailheads, campgrounds, and interpretive sites. It would also raise awareness of the fragility of the desert environment and encourage recreational 

users to stay on trails and respect the environment.

4.42.2.17 Impacts from Management of Scientific 

Research

One of the biggest gaps in current desert tortoise research is the lack of data about the impact that nonmotorized activities have on tortoise populations. The 

impact of motorized recreation is well documented, but 

there is no valid research on the non-motorized side. 

Could a well-designed hike/bike trail system coexist with 

critical habitat? What is the “zone of influence” of a trail 

system? The NCA provides the perfect laboratory to conduct such studies and the effects of such research could 

have far-reaching implications.

4.42.3 Summary of Impacts from Alternatives

Table 4-34 provides a summary of the impacts to recreation and visitor service resources. The first column lists 

the resource or resource use that has an impact/effect on 

recreation. The second column lists whether the action(s) 

is a beneficial effect or an adverse impact. The third 

column provides a brief description of the impact/effect 

and the final column lists the intensity of the impact/

effect. A description of intensity levels can be found in 

the Methods of Analysis section at the beginning of the 

Recreation and Visitor Services section.

4.42.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on recreation resources includes all of Washington County, 

including Zion National Park and Dixie National Forest, 

Pine Valley Ranger District. It also includes the Northern 

Arizona Strip where roads and trails share the Arizona/

Utah boundary.

At the broadest level, the physical, social, and operational 

recreation character of BLM public lands is changing 

from natural to more developed, from less crowded to 

more contacts with other users, and from less restrictive to more rules and regulations. These changes would 

impact the activity opportunities that can be offered and 

the recreation experience and benefit opportunities that 

can be produced by land managers and partners.

Northern 

Corridor 

Alignment

Affected Trail Affected Trailhead/

Access Point

Option 1 Black Gulch

High Point

Lange’s Dugway

Winchester

Alger Hollow

Black Gulch

Mesa Rim

Option 2 Black Gulch

Black Knolls

Cottontail

Middleton

Mill Creek

Yellow Knolls

Yellow Knolls

Other Step-Over (3)

Option 3 Cottontail

Middleton

Mill Creek

Twist Hollow

T-Bone

Other Step-Over (1)

Option 4 Pioneer Rim

Twist Hollow

N/A

Option 5 Black Gulch

Black Knolls

Winchester

Yellow Knolls

T-Bone

Yellow Knolls

Other Step-Over (2)

Option 6 Black Gulch

Black Knolls

Cottontail

Middleton

Mill Creek

Winchester

Yellow Knolls

T-Bone

Yellow Knolls

Other Step-Over (3)

Table 4-33 Potential Impacts to Non-Motorized Trails from 

Northern Transportation Route Alignments
834 Chapter 4 RCNCA RCNCA Chapter 4 835

RECREATION AND VISITOR SERVICES COMPREHENSIVE TRAVEL AND TRANSPORTATION MANAGEMENT

Past and present actions that have had, and continue to 

have cumulative impacts, on recreation include adjacent BLM and US Forest Service management plans, 

increased visitation (especially from residents within the 

planning area and those from the surrounding region), 

local community expansion, and advances in outdoor 

recreation equipment.

Forest plans for adjacent National Forest System lands 

and RMPs for adjacent BLM-managed lands have closed 

areas and routes to motorized recreation, causing many 

users to move to BLM-administered lands in the SGFO.

Increasing urban and suburban populations in 

Washington County have greatly increased the level 

of recreational use on BLM-managed lands. There is a 

strong correlation between population growth, visitation, 

and recreation in large part because many new residents 

have moved to the area specifically because of easy access 

to recreation opportunities on BLM- managed lands. 

The expanding suburban development footprint has also 

placed many new neighborhoods directly adjacent to 

BLM property boundaries, resulting in increased trespass 

onto private property and resource impacts from private 

property owners accessing public lands from adjoining 

private land.

The combination of the region’s growing population, the 

NCA planning areas longer season of use in comparison 

to many of Utah’s destinations, and the bounty of desirable recreation settings have combined to greatly increase 

recreational use in the planning area.

Advances in technology are at least partly responsible for 

increased recreation across the planning area. Motorized 

vehicles are more capable of accessing any type of terrain, 

improvements in mountain biking have made that activity increasingly popular, and enhancements in equipment 

and clothing have made day hiking and camping more 

accessible to more people.

Reasonably foreseeable trends that would result in 

cumulative impacts on recreation include continued 

growth patterns in demand for all recreation experiences, 

increased demand for close-to-home recreation opportunities for local residents, continued and increased visitation from a growing regional population, and increased 

popularity of adjacent public lands and private resorts.

4.43 COMPREHENSIVE TRAVEL AND 

TRANSPORTATION MANAGEMENT

TTM is the process of planning for and managing 

transportation systems on public lands. Traditionally, 

BLM’s Travel and Transportation Program focused 

primarily on motor vehicle use. Within the framework 

of TTM, the program has been significantly expanded to 

encompass all forms of transportation, including travel 

by foot, horseback, bicycle, motorcycle, aircraft, and 

four-wheeled vehicles (ATVs, cars, and trucks). This new 

direction is important for the St. George area because 

even though the vast majority of routes in Washington 

County are available for motorized use, the number of 

non-motorized trails is far larger than those of a typical 

BLM field office.

Additionally, TTM expands on the traditional approach 

to transportation planning by implementing an interdisciplinary structure, in that all resources, resource uses, 

and accompanying modes of travel on public lands are 

addressed holistically. The goals, objectives, and desired 

future conditions of all resources and resource uses are 

recognized and addressed with TTM.

At the land use planning level, travel and transportation 

management is limited to Off-Highway Vehicle (OHV)

Area designations. Individual route designations are 

implementation-level decisions.

OHV area designations support resource programs 

and are designed to help achieve their objectives. Those 

designations adhere to the management prescriptions for 

all other resources and resource uses in each alternative. 

As a support function, transportation and travel management is not impacted by other resources and resource 

uses. Instead, transportation and travel management decisions impact other resources and resource uses. These 

impacts are discussed in each of the individual resource 

sections. The existing conditions for travel and transportation management are described in Section 3.19 Travel 

and Transportation Management. The travel plan for 

the NCA mirrors the aspirational goals of the individual 

alternatives in this plan. 

4.43.1 Methods of Analysis

Impacts are quantified where possible. In the absence 

of quantifiable data, professional judgment was used. 

Impacts are sometimes described using ranges of potential impacts or in qualitative terms, if appropriate. 

Adverse impacts to Travel and Transportation 

Management could result from management actions that 

diminish any of the fundamental components listed in 

the indicators section below. 

Beneficial effects could result from management actions 

that maintain or enhance any of the fundamental components listed in the indicators section below. 

Resource / Resource Use Impact/Effect Description Intensity

Water Impact Coliform counts in Quail Creek could result in recreation closures Major

Geological/Paleontological Effect Paleontological surveys could lead to more public use sites Unknown

Cave and Karst Effect Inventories could lead to increased caving opportunities Unknown

Native Vegetation Effect Fuel breaks offer potential new trail development options Unknown

Effect Well-designed trails can help protect riparian areas Minor

Fire and Fuels Effect Fuel breaks could offer new trail alignment opportunities Unknown

Effect Full suppression tactics would protect recreation resources Major

Plant collection Impact Collection of dead and downed wood prohibited in Alt C Minor

Special Status Species Impact Protection measures for Shivwits milkvetch could affect trail 

access

Moderate

Impact Providing recreation opportunities in tortoise habitat is difficult Major

BLM Sensitive Species Impact Protecting sensitive fish species could impact recreation access Major

Heritage Resources Effect Cultural surveys could lead to more public use sites in 

Alternatives B and D Unknown

Wilderness Effect Opportunities for primitive recreation in the urban interface Moderate

Visual Resources Effect Incorporating visual design principles enhances recreation Minor

Natural Soundscapes Effect Preserving natural soundscapes would enhance recreation Negligible

Wilderness Characteristics Effect Lands with wilderness characteristics is already protected by NCA 

management prescriptions None

Recreation Effect SRMA status will simplify recreation management Moderate

Effect Developing concessionaire contracts would boost private sector Minor

Impact Alternative C would close Sand Cove Campground Minor

Effect Alternatives B and D would improve Sand Cove and have stricter 

management

Minor

Impact Alternative C closes NCA to dispersed camping except for 

Primitive Zone Negligible

Effect New trail construction would improve access and opportunities Major

Impact Commercial recreation permits limited to % of overall visitation Negligible

Effect Competitive events could raise the NCA profile Minor

Effect Climbing access would be enhanced by a management plan Minor

Effect Climbing access would be allowed at Sand Mountain Moderate

Effect Climbing would be allowed anywhere in wilderness Moderate

Impact Geocaching is restricted to Rural and Backcountry Zones Minor

Effect Target shooting prohibited in NCA in all alternatives Minor

Effect Tortoise/non-motorized recreation research is needed Unknown

Transportation Effect OHV designations are compatible with all recreation decisions None

Lands and Realty Effect Alternative C is most protective with ROW exclusion Major

Impact Alternative B contains VRM Class III for ROW avoidance Major

Impact Alternative D contains VRM Class IV for ROW corridor Major

Education Effect Interpretive master plan would enhance recreation over time Moderate

Table 4-34 Summary of Impacts to Recreation and Visitor Services
836 Chapter 4 RCNCA RCNCA Chapter 4 837

LANDS AND REALTY

4.43.1.1 Indicators

Motorized vehicle travel in the NCA (outside of the Red 

Mountain WSA\ACEC and Cottonwood Canyon WSA, 

which were closed to motorized travel) has been managed as Limited to Designated Roads and Trails since the 

1999 SGFO RMP was approved; the designated roads 

and trails were identified through the implementationlevel PUP, approved in 2000. 

4.43.1.2 Assumptions

The analysis includes the following assumptions:

▶ Individual route designations are implementationlevel decisions that will be addressed in the TMP 

and tiered to the OHV Area Designations in this 

Amendment;

▶ There would be no impact on use of existing highways or county-maintained roads. The existing 

transportation network is extensive enough to meet 

current and known transportation needs;

▶ Reasonable access will be allowed to the State 

School Trust Lands so that those lands can be developed in a manner that will provide funds for the 

common schools (Cotter Decision, State of Utah v. 

Andrus, 486F. supp. 996, 1979);

▶ Proposed area designations would not affect ROW 

holders, permitted uses, county or state roads, or 

other valid existing rights. Travel closures and limitations apply only to public access.

4.43.2 Direct and Indirect Impacts

Management decisions in the RCNCA RMP for the following resources would have negligible or no impact on 

Transportation and Off-Highway Vehicle Management 

(area designation) and are, therefore, not discussed in 

further detail.

4.43.2.1 Impacts from Transportation and OffHighway Vehicle Management

Impacts on transportation and access would result from 

OHV area designations that open, limit, or close areas to 

motorized use. 

Proposed OHV Designations

Under all alternatives, management that is currently in 

place would continue and public access throughout the 

NCA would remain Limited to Designated Roads and 

Trails. There would be no impacts to OHV area designations as current management would continue.

4.43.3 Summary of Impacts from Alternatives

Under all alternatives, there would be no variation in 

OHV area designations. The designations of Limited to 

Designated Roads and Trails and Closed applies to the 

entire NCA and has been in place since 1996 to protect critical desert tortoise habitat through the PUP. No 

change would be made to that designation in this plan.

4.43.4 Cumulative Impacts

The cumulative impacts analysis boundary for transportation and access includes the planning area and immediately adjacent segments of state and local road networks 

including those Dixie National Forest and State Trust 

Lands, including development actions in and surrounding the planning area that could produce long-term 

cumulative impacts on transportation and access.

The OHV area designations in the area have been in 

place since 1990. There would be no impacts beyond 

what currently occurs.

4.44 LANDS AND REALTY

Lands and realty actions are implemented to support 

various resource management goals, such as land acquisitions to protect habitat. They also authorize public 

uses, such as ROWs or film permits. Because of the 

administrative/support nature of the program, impacts 

are not discussed in relation to the realty program itself, 

but instead to the outcomes of the program, including 

land tenure (ownership) changes and the opportunities 

and constraints on those seeking land use authorizations within the NCA. For example, resource decisions 

to manage areas as Avoidance or Exclusion areas to new 

ROWs to protect special status species’ habitats would 

limit opportunities for the installation of communication 

sites or the construction of utility transmission lines.

4.44.1 Methods of Analysis

Impacts to Lands and Realty are analyzed by how the 

proposed Lands and Realty actions in the Chapter 2 

alternatives could affect land tenure or land use authorizations, which is described in Chapter 3.

4.44.1.1 Indicators

Indicators of beneficial effects on land tenure and land 

use authorizations include the following:

▶ Ability to acquire non-federal inholdings in the 

NCA;

▶ Ability to accommodate the demand for land use 

authorizations.

LANDS AND REALTY

Indicators of adverse impacts on land tenure and land 

use authorizations include the following:

▶ Inability to acquire non-federal inholdings in the 

NCA;

▶ Inability to meet the demand for ROWs and other 

land use authorizations.

4.44.1.2 Assumptions

The analysis includes the following assumptions:

▶ Pursuant to OPLMA Section 1975, BLM will manage all land and interests in land acquired by the 

United States within the National Conservation 

Area as withdrawn from all forms of entry, appropriation, or disposal under the public land laws; 

location, entry, and patent under the mining laws; 

and operation of the mineral leasing, mineral materials, and geothermal leasing laws, subject to valid 

existing rights;

▶ Designated wilderness areas are managed as ROW 

Exclusion areas;

▶ Land acquisitions will depend upon having willing 

sellers and available funding;

▶ Land acquisitions will acquire both surface and 

subsurface rights, whenever possible, to avoid the 

creation of split estates;

▶ All land use authorizations would be managed to 

minimize impacts on the ecological, scenic, wildlife, 

recreational, cultural, historical, natural, educational, and scientific resources of the NCA; 

▶ ROW holders may continue their authorized use as 

long as this use is in compliance with the purposes 

for the ROW and the terms and conditions of the 

grant;

▶ Upon renewal, assignment, or amendment of existing ROWs, additional mitigation or modification 

stipulations may be included, if the requested actions do not adequately protect NCA values.

Implementing management for the following resources or 

resource uses would have negligible or no impact on land 

tenure and land use authorizations and are therefore not 

discussed in detail: Air Quality, Water Resources, Geologic 

and Paleontological Resources, Cave and Karst Resources, 

Soil Resources, Native Vegetation Communities, Fire and 

Fuels Management, Noxious Weeds and Invasive Species, 

Vegetation Resource Uses: Livestock Grazing, Vegetation 

Resources Uses: Plant Materials, Other Fish and Wildlife 

Species, Wilderness, ACECs, Natural Soundscapes, Lands 

with Wilderness Characteristics, Recreation and Visitor 

Services, and Comprehensive Travel and Transportation 

Management, Public Education and Interpretation, and 

Scientific Research.

4.44.2 Direct and Indirect Impacts

Under all alternatives, no public lands would be transferred out of federal ownership, pursuant to OPLMA, 

thereby protecting resource values of the NCA through 

the continued application of federal laws, regulations, 

and policies. 

Over the life of the RMP, land tenure adjustments could 

result in the acquisition of a maximum of 16,366 acres 

of non-federal land within the boundaries of the NCA 

through purchase, exchange, transfer, or donation. Under 

all alternatives, the ability to acquire non-federal inholdings either through purchase or donation would only be 

constrained by the availability of funding. 

Under all alternatives, the designated Red Mountain and 

Cottonwood Canyon Wilderness areas (19,989 acres in 

total) would be managed as ROW Exclusion areas, protecting wilderness values but precluding developments.

Under all alternatives, BLM would work with mining 

claimholders that were active at the time of NCA designation to provide reasonable access to these claims, but 

would ensure that undue and unnecessary degradation 

of NCA resource values does not result from access or 

development activities. Claimants could be impacted to 

varying degrees by reasonable requirements to prevent 

undue and unnecessary degradation of NCA resources. 

Under all alternatives, reasonable access would be allowed to the State School Trust Lands so that those lands 

can be developed in a manner that will provide funds for 

the common schools (Cotter Decision, State of Utah v. 

Andrus, 486F. supp. 996, 1979).

Alternative A would continue to manage 24,686 acres of 

the NCA as a ROW Avoidance Area, with specific criteria, and retain two existing designated corridors along 

SR 18 and I-15. New ROW proponents would be encouraged to locate proposed facilities within the designated 

corridors or other designated corridors that are outside 

the NCA boundaries. This management decision could 

increase expenses for project proponents, as they would 

generally be required to use alternative locations outside 

of the NCA, if the two designated corridors will not meet 

their requirements.

Alternative B would manage 3, 652 acres of the NCA 

as a ROW Avoidance area and 41,023 acres as a ROW 

Exclusion area. Two designated utility corridors, along 

SR 18 and I-15 would be retained. New ROW proponents 
838 Chapter 4 RCNCA RCNCA Chapter 4 839

would be encouraged to locate proposed facilities within 

the designated corridors or other designated corridors 

that are outside the NCA boundaries. This management 

decision could increase expenses for project proponents, 

as they would generally be required to use alternative 

locations outside of the NCA, if the two designated corridors will not meet their requirements

Alternative C would manage 44, 809 acres of the NCA as 

a ROW Exclusion area for linear and site-type ROWs and 

revoke the designated utility corridor along I-15, subject 

to valid existing rights. These management decisions 

would require that proponents find alternative locations 

outside the NCA, potentially increasing project costs. 

Under Alternative D, 38,324 acres of the NCA would be 

managed as a ROW Exclusion area, two existing designated corridors would be retained, and a new utility 

and transportation corridor would be designated. The 

acreage of designated corridors would total 6,534 acres 

and would be available for the siting of new utility lines 

and transportation routes. This alternative would provide 

the greatest flexibility for ROW proponents, potentially 

reducing overall project costs and construction delays.

4.44.2.1 Impacts from Management of Special Status 

Species, Including BLM Sensitive Species

Under all alternatives, the NCA would be managed as 

either a ROW Avoidance or Exclusion area to protect 

habitats for special status species, including the Mojave 

desert tortoise and Shivwits milkvetch. Alternative A 

identifies all of the NCA, outside of designated wilderness areas, for management as a ROW Avoidance area, 

but new ROWs could be authorized if feasible alternative routes or designated corridors are not available. 

Compliance with the terms and conditions of Biological 

Opinions issued by the USFWS related to special status 

species could increase project costs, when compared to 

other areas where these species are not present. 

Alternatives B and D would manage larger acreages of 

the NCA as ROW Exclusion areas (41,023 acres and 38, 

325 acres, respectively) and provide for varying acreages 

of designated corridors for linear ROWs. Proponents 

would be required to locate new facilities within designated corridors whenever possible or seek alternative 

locations for these facilities, potentially increasing project 

costs. Alternative D would offer the greatest flexibility 

for proponents of new ROWs, as it would provide 6,534 

acres of the NCA as designated corridors for linear 

ROWs. Compliance with the terms and conditions of 

Biological Opinions issued by the USFWS related to 

special status species could increase project costs, when 

compared to other areas where these species are not present, under both alternatives. 

Alternative C would manage 44, 808 acres of the NCA as 

a ROW Exclusion area for linear and site-type ROWs and 

revoke the designated utility corridor along I-15, subject 

to valid existing rights. These management decisions 

would require that proponents find alternative locations 

outside the NCA, potentially increasing project costs, 

if utilizing the State Route 18 corridor would not meet 

project purposes. Compliance with the terms and conditions of Biological Opinions issued by the USFWS related 

to special status species for use of the SR 18 corridor 

could minimally increase project costs.

4.44.2.2 Impacts from Management of Heritage 

Resources

Potential impacts from Heritage Resources could occur 

if significant cultural sites were identified along potential 

utility or highway corridors and re-routing or mitigation 

was required. Impacts would not occur in Alternative C as 

the entire NCA would be designated as a ROW Exclusion 

area. Impacts could occur in Alternative B if development 

was authorized in the ROW Avoidance area. Impacts 

are most likely to occur in Alternative D if authorization 

were granted for the Northern Corridor or future utilities. 

Because there is no development currently being proposed, it is not possible to quantify potential impacts.

4.44.2.3 Impacts from Management of Visual 

Resources

Visual resources and Lands and Realty actions are closely 

linked. In this plan, the designation of VRM classes mirrors the designation of ROW designations. For a detailed 

analysis of how VRM and Lands and Realty actions interact, please see the section, “Impacts to Visual Resources 

from Lands and Realty Actions.”

4.44.2.4 Impacts from Management of Lands and 

Realty

Under all alternatives, no lands within the NCA could be 

transferred from federal ownership, as OPLMA segregated the NCA from operation of the public land laws 

to conserve and protect resource values. Acquisitions of 

non-federal lands within the NCA would be dependent 

on available funding and willing sellers.

4.44.3 Summary of Impacts from Alternatives

Table 4-35 provides a summary of the impacts to Lands 

and Realty Management. The first column lists the 

resource or resource use that has an impact/effect on 

LANDS AND REALTY

recreation. The second column lists whether the action(s) 

is a beneficial effect or an adverse impact. The third 

column provides a brief description of the impact/effect 

and the final column lists the intensity of the impact/

effect. A description of intensity levels can be found in 

the Methods of Analysis section at the beginning of the 

Lands and Realty section.

4.44.4 Cumulative Impacts

The CIAA is identified as all of Washington County. 

Cumulative impacts to land tenure and land use authorizations occur through changes in land tenure, through 

special designations, through the development of land 

resources and in changes in access to the land. 

Past human-caused actions within the CIAA included 

the settlement and expansion of communities, land 

tenure adjustments through sale, exchange, transfer, and 

donation, and the construction road, highway, and utility 

construction, water developments and diversions. 

Present and reasonably foreseeable future actions would 

include continued regional population growth, the 

expansion of rural and urban communities, land tenure 

adjustments, and the granting of ROWs across public 

lands for energy transmission, highways, water development projects, and communication sites. Reasonably 

foreseeable future projects involving land use authorizations and land tenure adjustments of federal, state, and 

private lands include:

▶ Lake Powell Pipeline

▶ Warner Valley Reservoir

▶ Sand Hollow Pipeline

▶ Northern Corridor

▶ Western Corridor

▶ Anderson Junction Reservoir

▶ Sand Mountain Land Exchange

The number of land use authorizations granted for use 

of public lands, particularly ROWs and permits, is a 

function of demand for these uses. Future development 

of adjacent state and private lands would likely result in 

additional requests for and approval of land use authorizations for facilities such as roads, utilities, and communication sites. 

Over the life of the RMP, land tenure adjustments could 

result in the acquisition of a maximum of 16,366 acres 

of non-federal land within the boundaries of the NCA 

through purchase, exchange, transfer, or donation. No 

public lands would be disposed of within the NCA, and 

the designated wilderness areas within the NCA, reducing the pool of lands available for transfer from federal 

ownership by approximately 45,000 acres. Management 

of the NCA as an Avoidance and/or Exclusion area for 

linear and site-type ROWs would have a cumulative 

impact of reducing or precluding the granting of new 

ROWs for use of public lands within the NCA. Demand 

for these land use authorizations would be displaced to 

other federal, state, or private lands within the CIAA.

4.45 SOCIAL AND ECONOMIC CONDITIONS

Socioeconomics addresses the social and economic effects of management of BLM-administered land. In this 

context, the word “impact” may indicate positive or negative effects, depending on the context. For instance, an 

alternative may have a particular stated economic impact 

on the socioeconomic study area (Washington County) 

in terms of economic output, labor income, and jobs; this 

impact can be considered a benefit to the economy, but 

SOCIAL AND ECONOMIC CONDITIONS

Resource/Resource Use Impact/Effect Description Intensity

Special Status Species Impact Revoking I-15 ROW in Alt. C to preserve Shivwits milkvetch Unknown

BLM Sensitive Species Impact Revoking I-15 ROW in Alt. C to protect riparian area of Quail 

Creek and BLM Sensitive species habitats Unknown

Heritage Resources Impact Alternative C designates Heritage Areas to be managed as ROW 

Exclusion areas Moderate

Visual Resources Impact Alternative C designates VRM Class II for ROW Exclusion areas Major

Impact Alternative B designates VRM Class III for ROW Avoidance areas Moderate

Effect Alternative D designates VRM Class IV for ROW corridors Moderate

Lands and Realty Impact Alternative A designates the NCA as a ROW Avoidance area Moderate

Impact Alternatives B, C, and D designate the NCA a ROW Exclusion 

area Major

Impact Alternative D designated corridors could increase demand for 

ROWs Major

Table 4-35 Summary of Impacts to Lands and Realty
840 Chapter 4 RCNCA RCNCA Chapter 4 841

SOCIAL AND ECONOMIC CONDITIONS

may also represent a loss of economic activity compared 

to another alternative.

4.45.1 Methods of Analysis

4.45.1.1 Assumptions

The analyses in this section are based on the following 

assumptions: 

▶ Management actions proposed are designed to 

conserve, protect, and enhance the resources of the 

NCA.

▶ Marketplace economic benefits (e.g., labor earnings and employment) to the socioeconomic study 

area (Washington County) will accrue from certain 

activities on BLM-administered land, identified in 

the analyses below;

▶ Nonmarket values will accrue from a range of activities on BLM-administered land, identified in the 

analyses below;

▶ Government revenues (fees, payments in lieu 

of taxes, etc.) derived from activities on BLMadministered lands will continue to be modest and 

not change dramatically over the course of the planning period given the types of activities anticipated 

during the planning period (e.g., no revenues from 

energy minerals);

▶ Demand for use of BLM-administered land for 

recreational activities, including motorized and 

non-motorized use, will remain steady or increase 

through the study period;

▶ Activities and resources available on BLMadministered land will continue to be important to 

the quality of life of current and future study area 

residents;

▶ Employment and labor income, along with migration of retirees who bring non-labor income, will 

continue to be the main drivers of economic and 

population growth in the socioeconomic study area.

4.45.1.2 Economic Impact Analysis–Market Values

This subsection describes methods related to analysis of 

economic impacts that are reflected in market transactions. The next subsection describes methods for analysis 

of impacts to nonmarket values. The analysis of marketbased economic impacts uses two general approaches: 

quantitative analysis and qualitative analysis. 

4.45.1.3 Quantitative Analysis using the IMPLAN 

Model

The quantitative analysis approach is used when possible given adequate available information. In this study, 

adequate data were available for quantitative analysis 

for two resource uses: livestock grazing and recreation. 

The basic strategy used is to first identify and quantify 

the primary impacts of an economic activity affected by 

management decisions. For instance, primary impacts 

include the value of livestock sold to the cattle market 

(specifically, the portion of that value attributable to 

grazing on BLM-administered public lands), and the 

expenditures made locally by recreationists for food, 

lodging, gasoline, guide services, and other goods and 

services attributable to recreation on BLM-administered 

land. Next, where primary impacts can be quantified, 

they can generally also be run through an economic 

model to estimate the economic activity that is generated as the primary impact ripples through the economy, 

“upstream” to providers of goods and services necessary 

for production, and “downstream” as income generated 

from production is spent by the households that receive 

the income. 

The upstream, downstream, and total effects are estimated in this study through use of the IMPLAN model. The 

IMPLAN model was originally developed by the USFS 

and is commonly used by the BLM and many other government and private sector organizations to estimate the 

total economic impacts of various activities, actions, and 

policies. The model tracks inter-industry and consumer 

spending in a local (or regional) economy, allowing estimation of indirect and induced economic impacts in the 

local economy that result from the original economic activity or a change in economic activity. Indirect impacts 

result from local inter-industry purchases caused by the 

direct impact; for example, when a recreation outfitter 

purchases supplies from other local businesses. Induced 

impacts result from re-spending of labor income; that is, 

local purchases of groceries, medical services, and other 

goods and services by households of employees of the 

affected industries. The re-spending within a socioeconomic study area represented by indirect and induced 

impacts is often referred to as the “multiplier effect.” 

Outputs of the IMPLAN model include employment, 

labor income, and gross regional economic output. It is 

important to note that IMPLAN, based on some of its 

data sources, does not distinguish between full-time and 

part-time jobs. Sectors with higher labor earnings per job 

are likely to reflect a high proportion of full-time jobs, 

while sectors with low labor earnings per job often reflect 

a significant number of part-time jobs.

The specific methodology used for the IMPLAN analysis 

for grazing involved three major steps:

SOCIAL AND ECONOMIC CONDITIONS

▶ Identifying the amounts of forage utilized on BLMadministered lands in the NCA under each management alternative;

▶ Estimating the direct economic value per unit of 

forage use;

▶ Estimating the economic impacts based on the total 

value of production.

The amount of forage utilized within the NCA was 

determined by review of BLM grazing permits for the allotments that include land in the NCA. Since 1999, a majority of the public lands within the Red Cliffs NCA have 

been unavailable to livestock grazing, through decisions 

from the SGFO RMP that implemented recommendations from the 1994 recovery plan for the Mojave desert 

tortoise. Small portions of three allotments continue to 

be available for cattle grazing, but receive little to no use. 

BLM range specialists estimated the animal unit months 

(AUMs) of forage available on these portions of the three 

allotments. One AUM is equal to the amount of forage 

consumed by a cow and calf during a 1 month grazing 

period. The AUMs on one allotment would be unavailable under two of the alternatives. The economic impact 

analysis assumes utilization of all available AUMs in each 

alternative, in order to provide an estimate of the maximum economic impact of grazing in the NCA.

The direct value of production per AUM was estimated 

based on state livestock production value data and ratios 

in the livestock economics literature. According to 

Workman (1986), it takes 16 AUMs to produce a marketable cow. Thus, the average value of an AUM can be 

estimated using data on the value of cattle production 

per bred cow and dividing by 16. 

The value per AUM for cattle was based on an 8 year 

average (2005–2012) of the annual value of production of 

cattle and numbers of bred cows statewide from statistics 

of the Utah Department of Agriculture and Food (2013). 

The methodology and data for calculation of the average 

value of cattle production from one AUM of forage are 

shown in Table 4-36.

The average value per AUM was multiplied by the 

number of AUMs available in each alternative. The result 

was the total economic value of livestock production, 

which was entered into Sector 11, Cattle Ranching and 

Farming, of the IMPLAN model. The model calculated 

“leakage” of some of this value out of the socioeconomic 

study area, and the “multiplier effect” re-spending of the 

remaining value within the study area.

The quantitative economic impact analysis for recreation 

involved three major steps:

▶ Quantifying recreation use levels for the NCA 

(number of visits by recreation “segment”);

▶ Estimating the local expenditures per visit by recreation segment;

▶ Estimating the economic impacts based on the total 

expenditures.

Value of 

Production 

(1,000$s)1

Beef Cows That 

Have Calved 

(1,000 Head)2

Value Per Cow Conversion to 

AUMs (AUMs/

Cow)3

Value of 

Production Per 

AUM (Nominal 

$)

Value of 

Production Per 

AUM (2013 $)4

2005 $351,595 347 $1,013.24 16 $63.33 $74.92 

2006 $250,377 325 $770.39 16 $48.15 $55.09 

2007 $222,428 344 $646.59 16 $40.41 $44.91 

2008 $194,134 365 $531.87 16 $33.24 $36.10 

2009 $185,904 350 $531.15 16 $33.20 $35.60 

2010 $221,377 336 $658.86 16 $41.18 $43.71 

2011 $261,808 333 $786.21 16 $49.14 $51.09 

2012 $277,971 330 $842.34 16 $52.65 $53.75 

 Average 2005–2012 (8 years) $45.16 $49.39 

1

 Utah Department of Agriculture and Food 2013, p. 51.

2

 Utah Department of Agriculture and Food 2013, p. 50.

3

 Workman 1986.

4

 Nominal dollars adjusted to 2013 dollars by applying gross domestic product (GDP) deflator factors (GDP chained price 

index) from the 2014 Federal Budget Historical Tables, accessed February 2014 at http://www.whitehouse.gov/omb/budget/

Historical.

Table 4-36 Value of an AUM for Cattle Production
842 Chapter 4 RCNCA RCNCA Chapter 4 843

SOCIAL AND ECONOMIC CONDITIONS

The economic impact results for recreation consist of 

one set of figures for all alternatives. The analysis does 

not address differences between the alternatives. This is 

because the differences in management actions affecting 

recreation cannot be quantified. Differences in impacts 

between the alternatives are discussed qualitatively. It is 

also important to note that the analysis assumes future 

recreation use levels remain constant at recent actual use 

levels. This assumption may mean that the results underestimate the economic effects of recreation. Population 

trends in the U.S., the Rocky Mountains and the socioeconomic study area would tend to indicate that travel 

and recreation will increase in the future; however, it is 

not entirely clear that outdoor recreation is increasing.

The SGFO tracks recreation use levels in the NCA, based 

on data from traffic counters, visitor registers, and interactions between field office staff and recreationists. Data 

for 2013, presented in Table 4-37, were utilized for the 

economic impact analysis.

A variety of data sources were considered for development of estimates of local expenditures per visit by recreation segment, as follows:

▶ National Park visitor expenditure data for two 

nearby national park units (Zion National Park and 

Cedar Breaks National Monument) were rejected 

because these areas see high levels of international 

visitation, which is not consistent with Red Cliffs 

NCA visitation.

▶ Snow Canyon State Park visitor expenditure data 

(Utah State Parks 2009) for local visitors were 

utilized for “Day Trip–Local” visitor expenditures. Based on this park’s location within the 

NCA, expenditures by this recreation segment are 

probably very similar for the park and the BLMadministered land of the NCA. The local park 

visitor profile was overwhelmingly for day use, and 

so was considered to match well to this BLM visitor segment. Expenditure data for non-local park 

visitors could not be broken down by the camping 

and motel use segments used in the BLM NCA 

visitation data, and were not utilized. However, the 

non-local park visitor expenditures and visitor profile were very similar to those for the “Overnight–

Motel” segment in the next source; this was considered an indicator of the validity of the next data 

source for that segment. 

▶ NVUM survey expenditure data for U.S. National 

Forests (White et al. 2013) were utilized for all 

recreation segments except “Day Trip–Local.” The 

NVUM program provides a robust data source 

(most national forests are surveyed on a five-year 

cycle) that is widely used for recreation economic 

impact analysis for areas besides USFS-managed 

lands. This is done by identifying national forest units that are reasonably analogous to another 

recreation management area, and applying the 

recreational expenditure data from NVUM to other 

area-specific recreation use data or estimates. The 

Dixie National Forest, located just north of the Red 

Cliffs NCA, is classified as an average-expenditure 

National Forest, thus the NVUM expenditure data 

for this class of forest were utilized for the NCA 

economic impact analysis. The NVUM expenditure 

data are based on the NVUM survey expenditure 

data across all forests in that class, thus it is statistically a very robust dataset.

Table 4-38 summarizes the expenditure figures used for 

the economic impact analysis, by recreation segment. 

The original data for both Snow Canyon and NVUM are 

expressed as per party spending; figures were adjusted to 

per person spending by applying an average group size of 

2.3. This is the average group size at the Red Cliffs NCA 

as determined by the BLM. 

Total expenditures by recreation segment are the product of multiplying the NCA visits per segment by the 

expenditures per visit per person for the applicable 

segment. The expenditures were parsed into the following IMPLAN model sectors (Table 4-39) according to 

the expenditure distributions for each segment from the 

expenditure source data.

The model calculates “leakage” of some of the expenditures out of the socioeconomic study area; e.g., expenditures at gasoline stations largely flow out of the study 

area, while a higher proportion of expenditures at food 

service establishments stays in the study area due to the 

higher local labor requirements of this industry. The 

total economic impacts are the direct impacts (the initial 

expenditures that stay in the study area) plus the indirect 

and induced impacts (the “multiplier effect”) from the 

re-spending of the expenditures that remain within the 

study area.

The term “economic impact” is often used loosely in EISs. 

In the field of regional economics, “economic impact” 

refers specifically to the effects of “new” income in the 

study area. Thus, it is an appropriate measure to use for 

activities such as oil and gas development and livestock 

grazing, which export almost all of their product out of 

the socioeconomic study area, and thereby bring new 

SOCIAL AND ECONOMIC CONDITIONS

income into the study area. For the recreation industry, 

in this EIS the economic analysis is technically an analysis of “economic contribution,” which includes the effects 

of all spending attributable to BLM-administered land by 

recreationists from outside the study area (new income), 

and of spending by recreationists who live within the 

study area (recycled income). The results of the analysis 

for grazing are taken to represent the economic impact 

of that activity, since local residents buy only a very small 

proportion of the total output of the livestock industry. In 

the case of recreation, however, local residents make considerable recreation-related expenditures (gas, food, and 

so on while on local trips), so it is fair to include those 

expenditures in an analysis of the economic role (“contribution”) of recreation. Put another way, expenditures 

by local and non-local recreationists alike help keep local 

businesses going. However, the term “economic impact” 

is used in both cases for simplicity.

All dollar figures for the results below are in constant 

2013 dollars. The base year used in the IMPLAN model is 

2012, the latest year for which IMPLAN datasets are available. Adjustments were made to model inputs and outputs 

to properly account for differences in the dollar year.

Trip Description Visitor Type Visitor Count Percent

Day Trip - Local Local 76,964 72.5

Day Trip - Non-local Non-local 20,589 19.4

Overnight - Camping Local 405 0.4

Overnight - Camping Non-local 4,446 4.2

Overnight - Motel Non-local 3,800 3.6

Total 106,204 100

Source: BLM recreation data.

Trip Description Visitor Type Total Expenditures Per Visit 

Per Person

Source / Comments

Day Trip - Local Local $43.79 Snow Canyon State Park (Utah State Parks 2009)

Day Trip - Non-local Non-local $29.70 NVUM (White et al. 2013)

Overnight - Camping Local $31.08 NVUM (White et al. 2013)

Overnight - Camping Non-local $29.61 NVUM (White et al. 2013)

Overnight - Motel Non-local $73.11 NVUM (White et al. 2013). Snow Canyon nonlocal park visitor expenditure is similar.

Number Sector Name

324 Retail—Food and Beverages

326 Retail—Gasoline Stations

328 Retail—Sporting Goods, Hobby, Book, Music

330 Retail—Miscellaneous

336 Transit and Ground Passenger Transportation

402 Recreation and Entertainment

406 Museums, Historical Sites, Zoos, and Parks

409 Amusement Parks, Arcades, Etc.

410 Other Amusement and Recreation Industries

411 Hotels and Motels

412 Other Accommodations

413 Food Services and Drinking Places

Table 4-37 Recreational Visitation at the RCNCA 2013

Table 4-38 Expenditures by Per Visit Per Person by Recreation Segment 2013

Table 4-39 IMPLAN Model Sector
844 Chapter 4 RCNCA RCNCA Chapter 4 845

SOCIAL AND ECONOMIC CONDITIONS

4.44.1.4 Qualitative Analysis

Where primary impacts cannot be readily quantified, often the economic impacts can still be described 

qualitatively. In such cases, the focus of the analysis is 

to describe the type of impact in a base scenario (here, 

Alternative A, the no action alternative) and then assess 

the relative changes (qualitative indications of increases 

or decreases in costs or the value of production) that 

would be likely under other alternatives. In this study, the 

market-based economic effects of the alternatives were 

addressed qualitatively for the following resource uses: 

plant materials harvesting, recreation (in addition to the 

quantitative analysis), lands and realty management, and 

special designations. 

4.45.1.5 Economic Impact Analysis—Nonmarket 

Values

The term nonmarket values refers to the benefits individuals attribute to experiences of the environment 

or uses of natural and cultural resources that do not 

involve market transactions and therefore lack prices. 

Nonmarket values capture a wide range of benefits (or 

costs), including those associated with the direct use of a 

resource (for example, the benefits received from hiking 

in a wilderness), as well as those associated with indirect 

uses of a resource (e.g., flood prevention provided by a 

wetland). These are collectively referred to as use values. 

Nonmarket values also include what are referred to as 

passive use values, which include the benefits provided 

by leaving a natural resource in a particular condition 

for future generations (bequest value) or the benefits 

provided by knowing that a resource exists in a particular 

condition (existence value). Because these values are not 

generally expressed in the marketplace, they are difficult 

to estimate but nonetheless BLM guidance calls for efforts to be made to identify and assess impacts to nonmarket values in the planning process (BLM Instruction 

Memorandum No. 2013-131, Guidance on Estimating 

Nonmarket Environmental Values, May 31, 2013). The 

Socioeconomic Baseline Report discusses nonmarket values further. Nonmarket values associated with 

Alternative A are analyzed qualitatively in this EIS, as 

are the impacts of the action alternatives on nonmarket 

values, generally relative to Alternative A.

4.45.1.6 Social Impact Analysis

Social impacts may be driven by economic impacts, such 

as when changes in employment due to management 

decisions lead to impacts on population, housing, and 

community services. Other impacts may be more purely 

social and cultural in nature and can include impacts on 

quality of life, recreation values, amenity values, and traditional land uses and associated cultural values. Social 

impacts may be marginal or substantial, depending on 

the degree to which new and revised management actions alter the course set in previous BLM decisions.

Sometimes social impacts can be quantified; however, in 

this analysis social impacts are described qualitatively. 

Based on the management actions under consideration, 

the alternatives will not produce major differences in 

local employment or other factors that would lead to 

quantifiable impacts on population, housing, and community services.

The qualitative social impacts analysis approach used in 

this EIS is to address impacts based on the varying points 

of view of key types of stakeholders. The Socioeconomic 

Baseline Report (Pinkham 2012) identifies several broad 

categories of stakeholders to this planning process. These 

categories reflect different linkages people have to public 

lands. They also reflect distinct sets of attitudes, beliefs, 

values, opinions, and perceptions about public resources 

and the effects of various management policies and 

actions. Categorization of stakeholders is not meant to 

imply that all individuals and social groups fit neatly into 

a single category; many specific individuals or organizations may have multiple interests and would see themselves reflected in more than one stakeholder category. 

The point of categorization is to allow differentiation of 

social impacts based on broad differences in points of 

view. The social impacts analysis below assesses the alternatives against the different points of view in the broad 

stakeholder categories.

4.45.1.7 Environmental Justice Impact Analysis

The Socioeconomic Baseline Report provides definitions 

and describes methods for analysis of potential EJ issues. 

In short, the baseline report presents a screening analysis 

designed to identify communities within Washington 

County with minority or low-income populations that 

qualify as potential EJ populations based on guidance 

from the Council on Environmental Quality. This analysis identified two potential EJ populations in Washington 

County. The EJ section below provides a qualitative assessment of the likelihood of disproportionately adverse 

human health or environmental (including economic) 

impacts to these populations.

4.45.2 Social and Economic Effects

4.45.2.1 Summary Economic Impact Tables

This section summarizes the quantitative analysis of the 

market value economic impacts of the alternatives. For 

SOCIAL AND ECONOMIC CONDITIONS

this study, adequate data were available for livestock grazing and recreation to allow quantitative economic impact 

analysis using the IMPLAN model. Table 4-40 shows 

the results of the IMPLAN analysis of the market-based 

economic impacts of grazing by alternative. 

The results in Table 4-40 are based on analysis of the 

production value of the AUMs allocated to livestock 

grazing in the NCA under each alternative. These results 

assume all AUMs allocated to grazing would be used, 

and thus indicate the maximum economic value that can 

be derived from grazing in the NCA under each alternative. In the last 25 years, few of these AUMs actually have 

been utilized. 

Table 4-41 shows the results of the IMPLAN analysis 

of the market-based economic impacts related to recreation, including the impacts of motorized recreation 

(management actions under Comprehensive Trails and 

Travel Management).

The economic impact results in Table 4-41 are the best 

estimates that can be made given current estimated 

visitation levels and the nature of the recreation-related 

management actions. It is not possible to reliably estimate differences in recreational visitation levels under 

the different alternatives. None of the management 

actions in the alternatives would result in definitively 

quantifiable changes to recreational use of the NCA. In 

a few cases, minor changes for a particular action—for 

instance, closure of a particular campground—might be 

quantifiable. However, some of that activity would simply 

move to another location; how much of it would move 

is impossible to determine. While the alternatives cannot be differentiated quantitatively for recreation, some 

potential differences in market and nonmarket values associated with recreation are discussed in the alternativefocused sections below.

The tables above show that for the NCA, the economic 

impacts of recreation greatly exceed the economic impacts of grazing. For instance, under Alternative A the 

total economic output generated by recreation in the 

NCA is $3.0 million, while the total economic output 

generated by grazing (assuming all AUMs are actually 

used, which has not been the case for most of the last 25 

years) is $11,600.

4.45.2.2 Alternative A

Economic Impacts—Market Values

The following resource uses may have economic impacts 

that are reflected in market transactions: plant materials harvesting, grazing, recreation, lands and realty 

management (land acquisitions and ROWs, including 

utility and transportation corridors), and special designations. Of these, only grazing and recreation are amenable 

to quantification. The impacts of the other resource uses 

are addressed qualitatively only.

Alt. A Alt. B Alt. C Alt. D

Direct Economic 

Output $6,000 $2,000 $2,000 $6,000

% Difference from 

Alt. A N/A -66 -66 0

Total Economic 

Output $11,600 $3,900 $3,900 $11,600

% Difference from 

Alt. A N/A -66 -66 0

Total Labor 

Earnings $1,200 $400 $400 $1,200

% Difference from 

Alt. A N.A. -66 -66 0

Total Jobs Per Year 0.17 0.06 0.06 0.17

% Difference from 

Alt. A N/A -66 -66 0

All figures are in 2013 dollars.

Estimates are of the impacts on the economy of Washington 

County.

Total Economic 

Impact1 Current 

Visitation Levels

Economic 

Impact1

per 1,000 Visits

Direct Economic 

Output $1,948,300 $18,300

Total Economic 

Output $3,039,500 $28,600

Total Labor 

Earnings $1,063,600 $10,000

Total Jobs Per Year 45.6 0.43

All figures are in 2013 dollars.

Estimates are of the impacts on the economy of Washington 

County.

Estimates include all motorized and non-motorized recreation.

1

Technically, these figures reflect “economic contribution,” as 

they include the effects of NCA recreation-related spending 

by Washington County residents. See the Analysis Methods 

section for discussion of this distinction.

Table 4-40 Annual Local Economic Impacts of Grazing in 

RCNCA

Table 4-41 Annual Local Economic Impacts of Recreation in 

the RCNCA
846 Chapter 4 RCNCA RCNCA Chapter 4 847

SOCIAL AND ECONOMIC CONDITIONS

The economic impact of Alternative A associated with 

plant materials harvesting is negligible. The Washington 

County HCP closed most of the area now in the NCA 

to most plant material harvests; these closures would be 

continued under this alternative.

Grazing in the NCA under Alternative A would support 

up to $11,600 of total economic output, $1,200 of labor 

income, and 0.17 jobs annually in Washington County 

(Table 4-40). These figures are based on the assumption that all AUMs available under Alternative A would 

be utilized; however, actual use in recent years has been 

much less. It is likely that in some years, operators would 

not utilize forage in the NCA, and thus there would be no 

economic impact from grazing attributable to the NCA.

Recreation in the NCA under Alternative A would support $3,039,500 of total economic output, $1,063,600 

of labor income, and 45.6 jobs annually in Washington 

County (Table 4-41). These figures are based on current 

(2013) levels of recreation activity in the NCA (106,204 

visits). It is possible and likely that recreation activity will 

increase over the course of the planning period, particularly given the growth of the St. George area. If recreational use of the NCA increases, the economic benefits 

of recreation to the Washington County economy would 

increase. If recreation activity were to change, the economic impacts would occur at the rates per 1,000 visits 

shown in Table 4-37.

Lands and realty management actions sometimes have 

important economic implications. As noted in the 

Socioeconomic Baseline Report, the NCA currently 

has approximately 26 authorized ROWs. The economic 

impact of these ROWs cannot be readily quantified, 

and Alternative A would not impact existing ROWs. 

Alternative A classifies over half of the NCA as a ROW 

Avoidance area, which means that new ROWs can be 

authorized providing they meet various conditions. 

Thus, Alternative A allows for some level of future 

ROW-dependent development of utilities and facilities 

that could have beneficial effects on the local economy. 

However, Alternative A includes designated ROW corridors along State Route 18 and I-15, but not within 

the area of the NCA where Washington County has 

proposed potential alternative routes for the “northern 

transportation route”; without such a designation, development of a “northern transportation route” through the 

NCA would not be in compliance with the management 

decision from Alternative A. Construction of a “northern 

transportation route” highway would generate a variety 

of market and nonmarket economic benefits. It would 

have negative economic impacts as well. The economic 

benefits and costs of the proposed highway are discussed 

under Alternative D. These benefits and costs probably 

would be forgone under Alternative A.

Under Alternative A, BLM lands and realty actions 

would also include acquisition of state and private lands 

within the NCA. BLM would work with willing property 

owners or administrators to acquire NCA in-holdings 

and edge-holdings that are in the public interest. The 

economic effect of land passing from private to BLM 

ownership is a reduction in local government property 

taxes from the parcel. At the same time, federal payments 

through PILT to local government typically increase.

As discussed in the Socioeconomic Baseline Report, 

special designations of land for conservation purposes 

(parks, monuments, NCAs, wilderness areas, other 

conservation lands) often raise concerns about potential 

negative impacts on traditional, commodity-based uses 

of public lands, but also often attract “amenities-based” 

economic activity such as new recreational visitation 

and migration of persons interested in living near highquality public lands. For this RMP/EIS, this matter is 

essentially moot. The NCA and the Red Mountain and 

Cottonwood Canyon Wilderness areas that overlap the 

NCA were Congressionally-designated; their designation is not subject to change in this planning action. 

Alternative A included an additional special designation: 

the Red Mountain ACEC. This ACEC is entirely located 

within the Red Mountain Wilderness, and any “designation effects” (attraction of visitors) are surpassed by the 

management parameters for a wilderness area and the 

amenity attraction effects of the wilderness and 

NCA designations.

Economic Impacts—Nonmarket Values

The Congressionally-designated purposes of the Red 

Cliffs NCA are: 

(1) 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 NCA; and

(2) Protect each species within the NCA that is listed 

as threatened or endangered under the Endangered 

Species Act of 1973 (OPLMA).

These purposes speak to the nonmarket values provided 

by the resources and uses of the NCA. While some of 

the listed components have market-based aspects—for 

instance, NCA visitors make purchases of gasoline, food, 

SOCIAL AND ECONOMIC CONDITIONS

and equipment in order to recreate in the NCA—each of 

these components is importantly, if not primarily, characterized by the unpriced benefits they provide to present 

and future generations.

Table 4-42 summarizes key resources and resource 

uses in the NCA that provide nonmarket values. The 

table identifies whether the resource or use reflects a 

use value or passive use value. These nonmarket values 

are described in more detail in the paragraphs immediately following the table, along with the implications 

of Alternative A for these values. An important consideration for many of the resources listed in Table 4-42 is 

that they are often dual commodities, meaning they are 

both inputs to biophysical processes as well as endpoints 

that people may place a value on (Boyd and Krupnick 

2009). For example, members of the public may place 

passive use values on the two wilderness areas at the 

Red Cliffs NCA, but these two protected areas also likely 

serve as inputs to maintaining healthy Mojave desert 

tortoise populations and other wildlife species, which are 

themselves resources that people hold nonmarket values 

for. The concept of dual commodities for interconnected 

ecological processes can apply to other resources as well, 

such as geological formations and cultural and archaeological resources. For instance, these resources may be 

used for a variety of purposes, including education and 

research, but may also enhance the nonmarket value of 

an individual’s mountain biking experience on one of the 

Red Cliff NCA’s many recreation trails.

As a result of existing along the transition zone between 

the Colorado Plateau, the Great Basin, and the Mojave 

Desert ecoregions, the Red Cliffs NCA contains several unique plant and wildlife species, some of which 

are found nowhere else in the world. The NCA hosts 

many other common and uncommon species as well. 

A wide range of nonmarket values are derived from 

these resources. For instance, healthy populations of 

these species contribute to use values held for recreation 

Resources and Resource Uses1 Primary Nonmarket Value

Use Value2 Passive Use 

Value3

Threatened, endangered, and rare species – Mojave Desert tortoise, woundfin minnow, Virgin 

River chub, Shiwvits milkvetch, bald eagle •

Plant species – Utah agave, banana yucca, scrub oak, single-leaf ash, pinyon pine, Utah juniper •

Wildlife – Gila monster, mule deer, mountain lion, coyote, jackrabbit, cottontail rabbit, sidewinder rattlesnake, kit fox, Gambel’s quail, golden eagle, red-tailed hawks, western screech 

owls, peregrine falcons, Cooper’s hawks, sharp-shinned hawks, bobcat •

Geological – Navajo Sandstone, Kayenta Formation, ancient volcanic activity with lava flows 

and extinct cinder cones •

Paleontological – dinosaur tracks and fossils  •

Archaeological and historical – a high density of sites from virtually all of the time periods 

typically identified in cultural histories of southwestern Utah: Archaic, Formative, Late 

Prehistoric, Protohistoric, and Historic Period; the Orson B. Adams House, an Anasazi archaeological site, remnants of Harrisburg (a 19th century Mormon agricultural settlement), 

remains of the 19th century silver mining boom in the Harrisburg Mining District

•

Wilderness and areas with wilderness characteristics – Cottonwood Canyon Wilderness, Red 

Mountain Wilderness, and 1,662 acres with wilderness characteristics •

Recreation – extensive trail system, wildlife viewing, hiking, equestrian, OHV, mountain biking, rock climbing, hunting, geocaching, camping, primitive recreation experiences •

Education and research – ecological, wildlife, plants, paleontological, archaeological, 

geological •

Traditional uses – livestock grazing, Native American uses •

1

List of resources and uses is based on Chapter 3, but is not exhaustive.

2

Some resource uses that provide nonmarket use value to participants also provide passive use value to a broader public.

3

Many of the resources people place a passive use value on can also contribute to the magnitude of use values held for recreation, education, research, and traditional use opportunities at the NCA.

Table 4-42 Type of Nonmarket Values Associated with RCNCA
848 Chapter 4 RCNCA RCNCA Chapter 4 849

SOCIAL AND ECONOMIC CONDITIONS

opportunities such as hunting and wildlife observation 

both within and outside the boundary of the NCA. They 

also contribute to use values gained from educational 

experiences and research. Furthermore, nonmarket passive use values can be derived from the protection and 

preservation of important habitat for threatened and 

endangered species. One of the primary objectives of 

the multi-jurisdictional Reserve is to protect and help 

recover populations of the Mojave desert tortoise. 

Such an effort to protect the tortoise and other threatened and endangered species in the Red Cliffs NCA 

contributes to existence values (value in knowing the 

resource will exist in a particular condition) and bequest 

values (for the benefit of future generations) held by 

some people, both inside and outside the socioeconomic 

study area, for preservation of these species. Evidence of 

this is provided by the number of studies that have monetized passive use values associated with various threatened, endangered, and rare species in the United States 

over the years, summarized in Richardson and Loomis 

(2009). While none of these previously conducted studies 

focused on the Mojave desert tortoise specifically, results 

demonstrate that the public places a positive nonmarket 

value on the protection of various threatened and endangered species. Given the potential size of the human 

population outside the study area that values threatened 

and endangered species at the Red Cliffs NCA, the nonmarket passive use values associated with their protection could be quite large. However, these values cannot 

be readily quantified.

Alternative A, which continues current management 

of public lands, provides a variety of protections for the 

species and habitats found in the NCA. BLM has implemented many management recommendations from 

USFWS-approved recovery plans, Biological Opinions 

issued under Section 7 of the ESA, and the Washington 

County Habitat Conservation Plan (1996). Thus, 

Alternative A provides for protection of nonmarket values associated with these species and habitats. However, 

Alternative A may not adequately protect some of these 

values. For instance, in some cases recreation opportunities may compete with wildlife habitat preservation. 

The transition from lowland to upland recreation zones 

combined with the overlapping regulations of wilderness 

designations has led to a confused visiting public regarding where and which activities are permitted, which in 

some cases has compromised habitat protection. Under 

Alternative A, provisions for various management challenges do not exist; for instance, regarding strategies for 

managing wildfires in special status species’ habitat, or 

conditions for authorizing new land uses in these habitats. Further, in requiring that a management plan be developed for the NCA, Congress implicitly recognized that 

current management would be insufficient to achieve 

the purposes of the NCA noted at the beginning of this 

section, which included conserving, protecting, and enhancing ecological and wildlife resources and protecting 

threatened and endangered species.

The Red Cliffs NCA contains unique geological, paleontological, archaeological, and cultural resources, each 

of which may contribute to nonmarket values held by 

some members of the public. The NCA contains Navajo 

Sandstone, originally formed as Jurassic-age Aeolian 

sand dunes, and the Kayenta Formation, which often 

accompanies Navajo Sandstone in iconic images of the 

American West. The area also contains ancient volcanic 

activity that has left evidence of lava flows and extinct 

cinder cones. The NCA has caves and karsts with unique 

geological, biological, cultural, or recreational values. 

Due to the extensive exposure of the Jurassic-age Kayenta 

Formation and Navajo Sandstone, the NCA is home to 

unique paleontological features such as dinosaur tracks 

and fossils from the early Jurassic period. The NCA also 

protects and preserves archaeological sites from human occupation dating back to the Archaic Period. Near 

the Red Cliffs Recreation Area are the remnants of an 

Anasazi archaeological site and the Orson Adams House, 

a mid-19th century Mormon pioneer settlement that recently underwent restoration (BLM 2009). The condition 

of the cultural resource sites within the NCA should be 

considered “good,” per the recommendations of the 2009 

Manager’s Report. These resources contribute to nonmarket use values, such as those held for recreation and 

education opportunities, as well as passive use values, 

such as the benefits received from preservation of unique 

geological, paleontological, archaeological, and historic 

features for future generations (bequest values). A study 

conducted by Loomis et al. (2005) monetized nonmarket 

values associated with recreation opportunities at various sites, including Canyons of the Ancients National 

Monument, which contains a wealth of archaeological 

resources. Results of this study demonstrate that there 

are significant nonmarket benefits associated with such 

cultural sites.

Alternative A has few provisions regarding management 

of archaeological and cultural resources in the NCA, 

and these few provisions are very general. This is also 

true of its provisions for geological and paleontological 

SOCIAL AND ECONOMIC CONDITIONS

resources. Alternative A does not reflect current best 

practices for protection of these various resources, and 

thus provides only limited protections for and support of 

the nonmarket values associated with these resources.

The Red Cliffs NCA has two wilderness areas, which 

help better protect tortoise habitat and other natural 

features. The Cottonwood Canyon Wilderness is approximately 11,700 acres in size, and not only provides habitat 

for many of the previously mentioned flora and fauna 

species found in the NCA, but also contains geologic 

features and recreation opportunities for visitors. Due to 

being highly accessible to residents of nearby St. George, 

the Cottonwood Canyon Wilderness is one of the most 

visited wild areas in southwestern Utah (BLM, 2009). The 

second wilderness area found in the NCA is an 8,300 acre 

portion of the 18,700 acre Red Mountain Wilderness located along the western edge of the NCA boundary. This 

wilderness area also contains habitat for wildlife species 

as well as panoramic views of the surrounding region, 

which includes Zion National Park, Virgin River Gorge, 

and the Beaver Dam Mountains. The two wilderness 

areas provide the opportunity for visitors to experience 

primitive recreation, nighttime scenery viewing, integration of the cultural and historical context of the region, 

and improved habitat for wildlife that rely on the natural 

patterns of light and dark. No developed trails exist in 

these two wilderness areas, but well-established primitive 

trails are used for hiking, rock climbing, and horseback 

riding access. All trailheads are located outside the two 

wilderness areas, and have parking, informational kiosks, 

toilets, and equestrian facilities. In addition to these two 

designated wilderness areas, the Red Cliffs NCA also 

contains three units with wilderness characteristics, totaling 1,586 acres. 

The Red Cliffs NCA was evaluated in 2012 using 

guidelines from the document Conducting Wilderness 

Characteristics Inventory on BLM Lands (BLM 2012). 

This inventory found that the identified land units contained naturalness, outstanding opportunities of solitude, 

and outstanding opportunities for primitive, unconfined 

recreation. Thus the two wilderness areas and the areas 

with wilderness characteristics provide opportunities for 

nonmarket use values held for solitude, natural quiet, 

and primitive recreation experiences. Individuals may 

also place a use value on wildlife viewing, education, and 

exploring opportunities within these areas. Passive use 

values may also be held by some members of the public 

for the wilderness areas and areas with wilderness characteristics, namely bequest values and existence values.

Alternative A excludes mountain bikes from designated 

wilderness areas. It designates the two established wilderness areas as ROW Exclusion areas. Broader national 

policies applicable to wilderness areas provide a variety of additional protections. Alternative A does not 

reference the Red Mountain and Cottonwood Canyon 

Wilderness Management Plan, under development by the 

BLM. Alternative A does not include any provisions for 

management of lands with wilderness characteristics. In 

total, Alternative A provides some important protections 

for the nonmarket values associated with wilderness in 

the NCA but does not explicitly protect nonmarket values associated with lands with wilderness characteristics.

At the heart of the NCA is the extensive trail system, 

consisting of 81 designated trails; 68 of which are either 

solely or collaboratively managed by the BLM. To better 

coordinate habitat preservation with recreation and other 

uses, the Red Cliffs NCA is divided into two categorized 

zones according to the Reserve PUP: upland and lowland 

zones. The upland zone generally does not provide quality habitat for desert tortoises, while the lowland zone is 

more sensitive and contains much of the critical habitat. 

Nearly all recreational uses within the lowland zone are 

restricted to designated trails, while visitors in the upland 

zone are permitted to travel off trail. 

Hiking is by far the most popular recreation use of the 

Red Cliffs NCA, but many of the trails within the NCA’s 

network can also be used by other non-motorized activities, including horseback riding, interpretation, and 

mountain biking. However, as noted in Chapter 3, with 

the expansion of nearby mountain-bike specific trails 

outside of the NCA, mountain biking use within the 

NCA boundary appears to be in decline. Rock climbing, 

rappelling, and scrambling is the second most popular 

recreation use in the NCA, and is authorized in three 

locations: Snow Canyon State Park, Paradise Canyon, 

and Pioneer Park. Only one site in the NCA is managed by the BLM: Turtle Wall, found within the Paradise 

Canyon. Geocaching is allowed in the upland zones, but 

disallowed in the lowland zones. Hunting is allowed in 

the upland zone throughout the NCA and in the lowland 

zone on the east side of Cottonwood Road. Hunting is 

the only off-trail use allowed within the lowland zone 

of the NCA. Beyond hunting, recreational shooting is 

disallowed in the NCA. Camping in the sensitive lowland 

zone is restricted to the 11-site campground with vehicle 

space in the Red Cliffs Recreation Area. Dispersed camping is generally allowed in the upland zone of the NCA, 

except for the Sandstone Mountain area where primitive 
850 Chapter 4 RCNCA RCNCA Chapter 4 851

SOCIAL AND ECONOMIC CONDITIONS

camping is by permit only in the Sand Cove camping 

area. Motor vehicle travel is allowed in the NCA, but only 

on the six designated roads identified in the PUP as suitable for such travel on BLM administered land. 

As discussed in the market values section above, there 

are clear economic benefits associated with the expenditures made in the local economy by recreational users 

of the NCA. In addition, some visitors who participate 

in these recreation opportunities receive an economic 

benefit above and beyond any costs actually paid to participate in them. Thus, a nonmarket use value can be held 

by some people for each of the recreation opportunities 

in the NCA. As described in the Socioeconomic Baseline 

Report, economists use the term consumer surplus to 

refer to the difference between the maximum dollar 

amount a consumer would be willing to pay to enjoy 

a good or service, and the actual payments made. This 

additional, unpaid value is a nonmarket use value, and 

many studies have quantified this value for various activities and locations. Loomis (2005) has summarized the 

findings from 1,239 studies covering much of the nation 

from 1967 to 2003. Rosenberger (2012) has prepared an 

online database of 352 documents from economic valuation studies that estimated the nonmarket use value of 

recreation activities in the U.S. and Canada from 1958 to 

2006. Loomis found that (updated here to 2013 dollars), 

consumer surplus for hiking ranged from a low of $16 

per person per day to a high of $93 per person per day. 

Consumer surplus for rock climbing ranged from $44 to 

$75, and consumer surplus for mountain biking ranged 

from $81 to $365. Economists use a methodology known 

as “benefits transfer” to apply values from the economics 

literature to determine total consumer surplus at another 

location. This methodology requires considerable research and great care in order to ensure that the transfer 

is appropriate and the results valid. Conducting this type 

of analysis was beyond the scope and needs for this EIS. 

However, the values cited above do show that nonmarket 

values are substantially greater than zero and should be 

considered–qualitatively in this case–real and important 

to BLM decision making.

Alternative A includes a number of management actions 

for recreation and visitor services and a related resource 

use, comprehensive trails and travel management. In 

addition, some of its management actions for various 

resources (e.g., visual resource management (VRM) 

land classifications) have implications for recreation. In 

general, the recreation-relevant management actions of 

Alternative A are fairly high-level and lack prescriptive 

or permissive specificity. For instance, as noted earlier, 

there is some confusion among recreationists regarding 

the locations and permitted activities of lowland and 

upland recreation zones. In addition to compromising 

habitat protection, this confusion probably reduces the 

value of the recreational experience for some NCA users. 

Alternative A does not reflect current best practices for 

managing recreation in ways that optimize recreational 

experiences for a broad array of users while simultaneously protecting other resource values. 

The NCA provides many educational opportunities. In 

additional to interpretive kiosks and panels, the NCA is 

used by local elementary schools and high schools for 

educational programs, for subjects including wildlife, 

hydrology, local history and archaeology. The NCA is 

also the locus of various research efforts. For instance, 

research on the Mojave desert tortoise has been ongoing since the 1950s in City Creek and Paradise Canyon. 

Education and research activities provide important 

nonmarket use value to the participants, and are passively valued by other members of the public for the 

benefits they bring to society. Alternative A includes 

several education-oriented management actions. These 

actions mainly aim to educate users of the NCA in order 

to reduce resource damage. Education also is mentioned 

as an end in itself, under Paleontological and Geological 

Resources, and Heritage Resources: “provide for stabilization, maintenance, and interpretation of selected sites 

for public enjoyment and education.” Alternative A also 

includes management actions supporting research aimed 

at management issues, and more broadly to “provide for 

legitimate field research by credible scientists and institutions.” In general, Alternative A allows for realization of 

nonmarket values associated with education and research, but does not actively encourage these activities.

The NCA supports nonmarket values associated with 

traditional uses of BLM resources, such as livestock grazing and Native American uses. As with recreation, public 

land managed for livestock grazing provides both market 

values (in this case, forage that generates cash value when 

livestock are sold) and nonmarket values. The nonmarket values associated with livestock grazing include the 

scenic value of open livestock range and ranch operations (Ellingson et al. 2006), including private land that is 

maintained in ranching in part because of the availability 

of public grazing lands. Nonmarket values also include 

the traditions, customs, and culture of ranching in the 

American West (Tanaka et al. 2005), which have experiential use value to ranching participants, surrounding 

SOCIAL AND ECONOMIC CONDITIONS

communities, and to some visitors (Mangan et al. 2005). 

Grazing and ranching also have passive use value (existence value and bequest value) to the non-using public 

who, for instance, appreciate the historic and living 

cultural icon of the American cowboy and independent rancher, and wish to see that heritage continue. In 

2007, the Governor’s Public Land Policy Coordinating 

Office commissioned Utah State University to conduct 

a statewide social survey on how Utah residents use and 

value public land resources, and their views about public 

land management. To achieve adequate sample size, two 

or more counties’ responses were combined, in this case 

Washington and Iron Counties. For these two counties, 

over 37 percent of the respondents indicated that grazing 

on public lands was very important to their area’s quality 

of life. The study did not distinguish among the various 

public land management entities, such as BLM versus the 

Forest Service (Krannich 2008).

Another indicator of the nonmarket value of grazing land 

is that purchases of ranches sometimes occur at prices in 

excess of the production value of the forage on the land 

(Bartlett et al. 2002, Taylor 2006). However, some people 

see nonmarket opportunity costs associated with livestock 

grazing, such as the potential for forage losses for wildlife 

or for conflicts between livestock grazing and other lifestyles that utilize public lands (Todres et al. 2003). 

The NCA’s current role in supporting grazing-related 

nonmarket values is negligible at best. Since the SGFO 

RMP was approved, making all but three allotments 

within the boundaries of today’s NCA unavailable for 

grazing (the associated grazing permits were purchased 

by Washington County), no livestock grazing has occurred in the NCA. The three active allotments have a 

very small amount of forage (121 AUMs) in the NCA. 

Further, the NCA portions of these allotments are difficult to access; as a result this forage receives very little, 

if any, use, and the potential market-based economic 

impact is small (See the Economic Impacts–Market 

Values section above). These AUMs would remain available under Alternative A, but given their small number 

and low level of use, the nonmarket values associated 

with livestock grazing in the NCA under Alternative A 

are also very small. 

BLM-administered land is sometimes important to the 

cultural traditions of Native American tribes. They may 

utilize these lands to gather plants used in medicinal 

and cultural practices, to honor ancestors, for religious 

and cultural ceremonies, and for other purposes. These 

activities provide nonmarket use value to the tribe 

members, and may provide passive use values to tribe 

members and to others who appreciate these traditional 

cultural practices and wish to see them sustained. During 

the scoping period for the EIS, the Paiute Indian Tribe 

of Utah and the Shivwits Band of the Paiutes submitted 

comments indicating their desire to see their ancestral 

landscapes protected from development and managed to 

ensure long-term sustainable use by tribal members and 

the larger public. They also recommended that BLM provide for protection of cultural antiquities, native plants, 

and wildlife; and provide assurances of access to public 

lands for utilization for hunting, fishing, gathering, and 

carrying out ceremonial/spiritual practices. Alternative A 

allows for the collection of vegetative products for Native 

American ceremonial or religious purposes, excluding 

federally-listed species. However, Alternative A has no 

other provisions explicitly supporting or protecting traditional Native American uses of BLM-administered land. 

In summary, Alternative A, which would continue current management practices for the NCA, would provide 

some protections for many of the nonmarket values associated with the NCA. However, the impact of continuing 

current management would probably include some losses 

to nonmarket values as a result of inadequate protections. 

Further, opportunities to enhance these nonmarket values “for the benefit and enjoyment of present and future 

generations” (OPLMA) by clarifying management and 

adding best practices would be foregone.

Social Impacts

In general, social impacts of BLM management actions 

are of two primary types:

▶ Social impacts driven by economic impacts–For 

instance, such impacts may occur when changes in 

employment due to BLM management decisions 

lead to changes in population that drive impacts to 

housing, schools, community services, crime, community cohesion, etc.;

▶ Social impacts that are more purely social and 

cultural in nature–These include impacts on intangible aspects of quality of life, attitudes and beliefs, 

traditional land uses and associated cultural values, 

and so on.

Regarding social impacts driven by economic impacts, 

these types of changes to public infrastructure and services, or to community cohesion, usually only occur in 

situations where major resource development activities 

generate large new employment opportunities, resulting 

in a significant influx of workers. For example, this type 
852 Chapter 4 RCNCA RCNCA Chapter 4 853

SOCIAL AND ECONOMIC CONDITIONS

of impact has occurred in parts of Utah and Wyoming 

where high levels of oil, gas, or coal development are occurring. No similar major economic development based 

on uses of BLM-administered land in the NCA is underway, and Alternative A is not expected to change that. 

Therefore, significant social impacts driven by economic 

impacts likely would not occur under Alternative A.

Regarding impacts that are more purely social and 

cultural in nature, the five high-level stakeholder categories identified and described in the Attitudes and Beliefs 

section of the Socioeconomic Baseline Report are used 

below to assess key social impacts of the alternatives. 

Stakeholders have distinct sets of attitudes, beliefs, values, 

opinions, and perceptions about public lands and the effects of various management policies and actions. These 

views reflect different cultural and economic linkages 

people have to public lands. By looking at the alternatives 

from different points of view, one can identify potential 

social and cultural impacts on each stakeholder group. 

The categorization of stakeholders is not meant to imply 

that all individuals and social groups fit neatly into a 

single category; many specific individuals or organizations may have multiple interests and would see themselves reflected in more than one stakeholder category. 

The point of the categories used here is to allow differentiation of social impacts based on broad differences 

in sociocultural linkages to public lands and associated 

points of view.

Habitat and Resource Conservation Stakeholders would 

find this alternative unsatisfactory. These stakeholders 

believe protecting species and ecosystems is a fundamental social value, and is not sufficiently accomplished 

by the current policies carried forward by Alternative 

A. They believe current management does not place 

enough importance on sensitive species and essential 

habitats, and would view this alternative as leading to the 

long-term demise of these populations and habitats. This 

stakeholder category also includes persons interested in 

the conservation of geological, paleontological, archaeological, and cultural resources, who generally would not 

favor this alternative based on a view that current management does not adequately protect these resources.

Motorized Recreation Stakeholders generally would find 

Alternative A to be favorable. It carries forward policies 

that these stakeholders are very familiar with, based on 

the Habitat Conservation Plan and the PUP. Current closures and current limitations of OHV use to designated 

roads and trails would continue. 

Non-Motorized Recreation Stakeholders would have 

mixed views on Alternative A. Because it carries forward 

familiar policies, some would find it favorable. Others 

would be less favorably inclined, because under current 

management, there is some confusion about recreation 

zones and rules, and sometimes conflicts between different recreational uses. Further, some recreationists 

appreciate the NCA for its ecosystem, flora, and fauna, 

and would feel that Alternative A inadequately protects 

these resources.

Livestock Grazing Stakeholders would favor Alternative 

A because it carries forward current policies that these 

stakeholders have managed to for many years. 

Economic Development Stakeholders would generally 

not favor Alternative A. For these stakeholders, ROWs to 

BLM-administered land for development of utilities and 

other infrastructure for the growing St. George region 

is very important. While this alternative carries forward 

existing policies, and therefore allows for new ROWs in 

accordance with protocols in the Habitat Conservation 

Plan, it does not explicitly designate a new ROW corridor. These stakeholders favor designation of a corridor 

that would allow for development of a “northern transportation route”, which they see as extremely important 

to economic development in the region.

4.45.2.3 Alternative B

Economic Impacts—Market Values

The economic impact of Alternative B associated 

with plant materials harvesting would be the same as 

Alternative A.

Grazing in the NCA under Alternative B could support 

up to $3,900 of total economic output, $400 of labor 

income, and 0.06 jobs annually in Washington County 

(Table 4-40). This is based on utilization of all AUMs 

available under Alternative B; however, actual use in recent years has been much less. In the past, the operators 

have not utilized forage in the NCA and it is likely that 

this pattern would continue in the future. Thus, there 

would be no economic impact attributable to the NCA. 

Under the unlikely assumption that all forage in the NCA 

is utilized, Alternative B would provide 66% less economic benefit to the local economy than Alternative A.

Based on the available data and the difficulties inherent 

in quantifying the impacts of recreation-related management actions, recreation (motorized and non-motorized) 

in the NCA under Alternative B would provide the same 

economic impact to Washington County as Alternative 

A. As with Alternative A, it is likely that recreation 

SOCIAL AND ECONOMIC CONDITIONS

activity under Alternative B will increase over the course 

of the planning period, and the economic benefits to 

Washington County would increase accordingly. If recreation activity were to change due to the management 

actions in this alternative and/or growth, the economic 

impacts would occur at the rates per 1,000 visits shown 

in Table 4-41 above.

The economic impact of Alternative B associated with 

lands and realty actions would be essentially the same as 

Alternative A. However, it is possible that the increased 

ROW Exclusion area in this alternative (to over 90% 

of the NCA) could preclude new ROWs for utilities or 

facilities on BLM-administered land that would benefit 

the local economy.

The economic impact of Alternative B associated with 

special designations would be the same as Alternative A.

Economic Impacts—Nonmarket Values

Relative to Alternative A, Alternative B would provide 

additional support to nonmarket values associated with 

unique species and habitats found within the NCA, by 

protecting those species and habitats through: 

▶ Actions to manage fire fuels proactively, suppress 

wildfires in special status species’ habitats, limit 

prescriptive fires, and better stabilize and recover 

burnt areas;

▶ Greater specificity on use of native seeds and plant 

materials, and methods for their introduction;

▶ Closing the NCA to commercial and noncommercial harvesting of vegetative products;

▶ Additional and more specific actions regarding 

control and eradication of invasive species;

▶ Additional provisions for public education efforts;

▶ Additional provisions for research efforts;

▶ Implementation of land use restrictions and other 

measures to protect particularly sensitive areas (riparian areas, special status species’ habitat);

▶ Inventorying and monitoring of certain species 

populations;

▶ Authorization for the translocation and population 

augmentation of certain sensitive species;

▶ Various limitations on and conditions for authorizing activities in sensitive areas that could have 

negative impacts, such as new ROWs and Special 

Recreation Permits;

▶ Use of species-friendly measures for various structures; e.g., “bat-friendly” gates in caves, wildlife 

escape ramps in watering troughs, etc.;

▶ Clarification of recreation management policies 

and measures through development of a Recreation 

Area Management Plan, establishment of the Red 

Cliffs Special Recreation Management Area and 

four Recreation Management Zones, specification 

of certain site improvements and facility changes, 

conditions for additional changes and development, 

development of a Climbing Management Plan, and 

other recreation-related actions;

▶ Establishing criteria for re-design of the non-motorized trail system, including protection of diverse 

(non-recreation) NCA values;

▶ Requiring, where new trail development would 

result in surface disturbance in designated critical habitats, restoration of an equivalent acreage of 

similar quality habitat;

▶ Increasing considerably the ROW Exclusion area 

in the NCA, not designating any new linear (utility 

and transportation) corridors, and specifying conditions for new ROWs in the ROW Avoidance area;

▶ Excluding new site-type ROWs (e.g., cell towers) 

and prohibiting leases under the authority of the 

Recreation and Public Purposes Act.

In short, through the types of actions noted above, 

Alternative B would positively impact nonmarket values 

associated with species and habitats at the NCA. Relative 

to Alternative A, it would better “conserve, protect, and 

enhance” (OPLMA) ecological and wildlife resources of 

the NCA and thereby increase “the benefit and enjoyment of present and future generations” (OPLMA) of the 

associated nonmarket values.

Relative to Alternative A, Alternative B would better 

protect and enhance nonmarket values associated with 

the NCA’s geological, paleontological, archaeological, and 

cultural resources. It would provide greater specificity 

on allocation of and access to these resources. It would 

prohibit commercial and non-commercial collection of 

fossils and petrified wood, which would help ensure opportunities for their in-situ enjoyment by current visitors 

and future generations. It provides for activity level plans 

(e.g., Cultural Resource Project Plans, Interpretation 

Plans) to direct management of archaeological and 

cultural resource public use sites. It would put in place 

a variety of management actions to stabilize and protect 

these sites.

Alternative B provides no specific management actions 

for lands with wilderness characteristics that differ from 

Alternative A. For designated wilderness, Alternative 
854 Chapter 4 RCNCA RCNCA Chapter 4 855

SOCIAL AND ECONOMIC CONDITIONS

B specifically refers to managing these lands according to the wilderness management plan currently under 

development by the BLM; it is assumed that this plan will 

result in improved management of the wilderness areas 

relative to Alternative A. Therefore, Alternative B would 

be more protective of the nonmarket values associated 

with wilderness than Alternative A, but not necessarily 

more protective of the nonmarket values of lands with 

wilderness characteristics.

With respect to recreation, in order to reduce the impacts of recreation on sensitive species and habitats, 

Alternative B would limit and control recreation activities more than Alternative A. It would do so through a 

number of prescriptive management actions in the RMP, 

and through development of a Recreation Management 

Plan and establishment of the Red Cliffs SRMA and four 

RMZs. Greater control of recreation activities might be 

seen by some recreationists as negatively impacting their 

recreational experience. However, it is at least as likely 

that by clarifying policies and rules for recreation—what, 

where, when, etc.,—confusion could be reduced, conflicts 

could be avoided between different types of recreation 

and with other uses, and thereby, recreational experiences would be enhanced. Further, other actions under 

Alternative B would probably enhance recreational experiences. These actions include moving over 21,000 acres 

from VRM Class III to Class II, and increased educational and interpretive efforts for geological, paleontological, 

archaeological, and cultural resources—resources that 

are often visited by recreationists. On balance, relative to 

Alternative A, Alternative B would enhance nonmarket 

values associated with recreation. 

In the area of education and research, as just noted, 

Alternative B includes multiple provisions for education and interpretation activities connected to the NCA’s 

geological, paleontological, archaeological, and cultural 

resources. These provisions aim to protect resources, 

and to enhance user experiences. Alternative B also 

includes many provisions for education, interpretation, 

and research related to ecological resources and sensitive 

species at the NCA; these provisions are largely aimed at 

protecting these resources but would likely contribute to 

public understanding and enjoyment. The alternative also 

clarifies access to NCA resources for research, and conditions for research activities. Alternative B would enhance 

education and research-related nonmarket values relative 

to Alternative A. 

With respect to nonmarket values associated with traditional uses, Alternative B would make the Diamond 

Valley grazing allotment unavailable for grazing. 

However, this allotment has been in voluntary non-use 

for a majority of the past 25 years, so there is effectively 

no impact from this action. The Sand Wash and Veyo 

allotments would continue to be available for grazing. 

Thus the impacts to nonmarket values associated with 

livestock grazing would be the same as Alternative A. 

Like Alternative A, Alternative B allows for personal use 

collection of native plant materials (excluding all federally-listed native plant species) by Native Americans for 

religious, ceremonial, and traditional purposes (through 

permits). Alternative B also specifically emphasizes 

Native American involvement in research at various heritage sites, and allocates and manages for Conservation 

Use and/or Traditional Use heritage sites identified as 

Sacred Sites by Native Americans. Alternative B would 

enhance the nonmarket values associated with traditional 

Native American uses of the NCA.

In summary, relative to Alternative A, Alternative B would 

provide greater protection and enhancement of most 

nonmarket values associated with the NCA. Levels of a few 

nonmarket values would be the same as Alternative A, and 

it is unlikely that Alternative B would lead to any nonmarket value losses relative to Alternative A.

Social Impacts

Major economic development based on uses of BLMadministered land in the NCA is not expected under 

Alternative B; therefore, social impacts driven by economic development would not occur under this alternative. Impacts that are more purely social and cultural in 

nature could occur as indicated by the likely views of 

different stakeholder groups regarding this alternative.

Habitat and Resource Conservation Stakeholders would 

favor this alternative over Alternative A. Alternative B 

includes many provisions that these stakeholders would 

find more protective of sensitive species and habitats. 

Persons within this stakeholder category who are concerned with the conservation of geological, paleontological, archaeological, and cultural resources would also favor this alternative over Alternative A, as it also includes 

additional protections for these resources.

Motorized Recreation Stakeholders would view 

Alternative B similarly to Alternative A. The OHV area 

designations and limitation of OHV use to the Rural 

Zone encompass all of the roads currently approved 

for OHV use, based on the Habitat Conservation Plan 

and the PUP. Thus, OHV policies are the same under 

SOCIAL AND ECONOMIC CONDITIONS

Alternative B as Alternative A; only the management 

framework (designation of RMZs) changes.

Non-Motorized Recreation Stakeholders would have 

mixed views on Alternative B, which puts in place a different recreation management framework than current 

policies under Alternative A. In general, this framework 

would control recreation activities to a higher degree. 

Some non-motorized recreation stakeholders may find 

the new framework and rules less to their liking. Others 

would appreciate the clarifications that would be made 

regarding what recreation activities can take place 

where and when. They would also appreciate that this 

Alternative would help resolve conflicts between different 

types of recreation.

Livestock Grazing Stakeholders would view this alternative somewhat less favorably than Alternative A because 

it makes the 80 AUMs in the Diamond Valley allotment 

unavailable for the life of the plan. However, because this 

allotment has been in voluntary non-use for most of the 

last 25 years, and because there are so few AUMs available on this allotment within the NCA, this change in 

grazing management under Alternative B would not be a 

major issue for these stakeholders. 

Economic Development Stakeholders would find 

Alternative B less favorable than Alternative A. These 

stakeholders favor designation of a ROW corridor that 

would allow for development of a “northern transportation route”, which they see as extremely important to economic development in the region. Alternative B explicitly 

does not authorize a suitable corridor, while Alternative 

A might allow for such a corridor provided it could be 

designated and developed in accordance with protocols 

in the Habitat Conservation Plan. Alternative B also significantly increases the ROW Exclusion area compared to 

Alternative A, which could preclude ROWs these stakeholders may wish to promote for other economic development purposes.

4.45.2.4 Alternative C

Economic Impacts—Market Values

The economic impact of Alternative C associated 

with plant materials harvesting would be the same as 

Alternative A.

Grazing in the NCA under Alternative C would provide 

the same economic impact to Washington County as 

Alternative B.

Based on the available data and the difficulties inherent in quantifying the impacts of recreation-related 

management actions, recreation (motorized and nonmotorized) in the NCA under Alternative C would provide the same economic impact to Washington County 

as Alternative A. As with Alternative A, it is likely that 

recreation activity under Alternative C will increase over 

the course of the planning period, and the economic 

benefits to Washington County would increase accordingly. If recreation activity were to change due to the 

management actions in this alternative and/or growth, 

the economic impacts would occur at the rates per 1,000 

visits shown in Table 4-41 above.

The economic impact of Alternative C associated with 

lands and realty actions would be essentially the same as 

Alternative A. However, it is possible that the increased 

ROW Exclusion area in this alternative (to 100% of the 

NCA) could preclude new ROWs for utilities or facilities 

on BLM-administered land that would benefit the 

local economy.

The economic impact of Alternative C associated with 

special designations would be the same as Alternative A.

Economic Impacts—Nonmarket Values

Alternative C includes virtually all of the provisions 

noted in the nonmarket values subsection for Alternative 

B that would protect species and habitats in the NCA. 

Thus, relative to Alternative A, Alternative C would better protect and enhance the associated nonmarket values. 

Relative to Alternative B, Alternative C would provide 

somewhat increased protection and enhancement of 

nonmarket values associated with the NCA’s species and 

habitats, through the following actions:

▶ Increasing the riparian area buffer against new surface disturbing activities from 150 to 200 meters;

▶ Limiting collection of seeds and native plant materials to use for scientific study and restoration projects within the NCA;

▶ Various recreation-related closures and prohibitions, including: not authorizing SRPs for competitive non-motorized and organized group events in 

the NCA, closing the Sand Cove Primitive Camping 

Area to overnight camping, and prohibiting dispersed camping in the Backcountry Zone;

▶ Moving over 7,000 acres from Backcountry Zone to 

the Frontcountry Zone, which has somewhat higher 

levels of management control;

▶ Requiring, where new trail development would result 

in surface disturbance in designated critical habitats, 

restoration of similar quality habitat at a 2:1 ratio;

▶ Designating the entire NCA a ROW Exclusion area.
856 Chapter 4 RCNCA RCNCA Chapter 4 857

SOCIAL AND ECONOMIC CONDITIONS

Alternative C is also very similar to Alternative B with 

respect to management of geological, paleontological, 

archaeological, and cultural resources, thus it would improve the protection and enhancement of the associated 

nonmarket values relative to Alternative A. It is more 

restrictive than Alternative B in a few respects. It would 

prohibit casual rock collection. It would also allocate and 

manage for Scientific Use and Conservation Use (not 

Public Use) most paleontological sites and cave/karst 

sites, and most National Register eligible archaeological 

and cultural sites. These actions would reduce the nonmarket use values obtained by the visiting public from 

these resources, possibly increase use values obtained by 

researchers, and probably maintain or enhance passive 

use values (existence and bequest values) received by 

members of the general public who appreciate protection 

of these resources.

Regarding wilderness, Alternative C is similar to 

Alternative B but also includes multiple prescriptions to 

protect 1,586 acres with wilderness characteristics. Thus 

it would better protect and enhance nonmarket values 

associated with wilderness, relative to both Alternative A 

and Alternative B.

Alternative C generally takes the same approach to recreation management as that noted in the nonmarket values 

subsection for Alternative B. Thus, relative to Alternative 

A, Alternative C would better protect and enhance the 

associated nonmarket values. Relative to Alternative B, 

Alternative C has slightly more restrictive VRM classifications, which would enhance nonmarket values for 

some recreationists. It also has several provisions that are 

more restrictive on recreation activity:

▶ Moving over 7,000 acres from Backcountry Zone to 

the Frontcountry Zone, which has somewhat higher 

levels of management control;

▶ SRPs for competitive non-motorized and organized 

group events would not be authorized. 

▶ No new climbing areas would be authorized;

▶ The NCA would be closed to use of dead and down 

materials for campfires;

The net effect of these changes relative to Alternative B is 

difficult to say. It is likely the levels of recreation-related 

nonmarket values under Alternative C would be similar 

to Alternative B.

In the area of education and research, Alternative C 

includes essentially the same provisions as Alternative 

B for education, interpretation, and research activities. Thus, Alternative C would enhance education 

and research-related nonmarket values relative to 

Alternative A, and would provide similar levels of these 

values to Alternative B.

With respect to traditional uses, the management actions 

for livestock grazing are the same in Alternative C as in 

Alternative B. Therefore, the impacts to nonmarket values associated with livestock grazing would be the same 

as Alternative B, and effectively the same as Alternative 

A. Alternative C’s actions related to Native Americans 

are the same as Alternative B. Thus the nonmarket values 

associated with Native American traditional uses would 

be the same as in Alternative B, and better protected and 

enhanced than under Alternative A.

In summary, relative to Alternative A, Alternative C 

would provide greater protection and enhancement of 

many of the nonmarket values associated with the NCA. 

Relative to Alternative B, it would provide similar or 

somewhat greater support for most nonmarket values. 

Social Impacts

Major economic development based on uses of BLMadministered land in the Red Cliffs NCA is not expected 

under Alternative C; therefore, social impacts driven by 

economic development would not occur under this alternative. Impacts that are more purely social and cultural 

in nature could occur as indicated by the likely views of 

different stakeholder groups regarding this alternative.

Habitat and Resource Conservation Stakeholders 

would favor this alternative over all other alternatives. 

Alternative C includes the framework of Alternative B 

that these stakeholders would find more protective of 

sensitive species and habitats, and they would appreciate that Alternative C further strengthens some of the 

measures aimed at protecting these resources. Alternative 

C also includes some measures for geological, paleontological, archaeological, and cultural resources that 

are somewhat more protective of these resources than 

Alternative B. 

Motorized Recreation Stakeholders would view 

Alternative C similarly to Alternatives A and B as OHV 

designations are identical across all alternatives.

Non-Motorized Recreation Stakeholders would view this 

alternative similarly to Alternative B–some would favor 

it over Alternative A and some would not. It is likely that 

(compared to Alternative B) more persons within this 

group would find Alternative C less preferable because 

some additional actions under Alternative C would 

preclude certain activities. These actions include closure 

of the Sand Cove Primitive Camping Area to overnight 

SOCIAL AND ECONOMIC CONDITIONS

camping, prohibition of dispersed camping in the backcountry zone, limitations on group sizes for SRPs, and 

non-authorization of SRPs for competitive non-motorized events and organized groups.

Livestock Grazing Stakeholders would view Alternative 

C in the same way as Alternative B; its grazing-related 

management actions are the same.

Economic Development Stakeholders would find 

Alternative C the least favorable alternative. These stakeholders favor designation of a ROW corridor that would 

allow for development of a “northern transportation 

route”, which they see as extremely important to economic development in the region. Alternative C explicitly 

does not authorize a suitable corridor, while Alternative 

A might allow for such a corridor provided it could be 

designated and developed in accordance with protocols 

in the Habitat Conservation Plan. Alternative C also significantly increases the ROW Exclusion area compared 

to Alternative A, which would preclude ROWs these 

stakeholders may wish to promote for other economic 

development purposes.

4.45.2.5 Alternative D

Economic Impacts—Market Values

The economic impact of Alternative D associated 

with plant materials harvesting would be the same as 

Alternative A.

Grazing in the NCA under Alternative D would provide 

the same economic impact to Washington County as 

Alternative A.

Based on the available data and the difficulties inherent 

in quantifying the impacts of recreation-related management actions, recreation (motorized and non-motorized) 

in the NCA under Alternative D would provide the same 

economic impact to Washington County as Alternative 

A. As with Alternative A, it is likely that recreation activity under Alternative D will increase over the course 

of the planning period, and the economic benefits to 

Washington County would increase accordingly. If recreation activity were to change due to the management 

actions in this alternative and/or growth, the economic 

impacts would occur at the rates per 1,000 visits as 

shown in Table 4-41.

Notably, the designation of a 6,350-acre utility and transportation corridor under Alternative D creates significant uncertainty regarding future recreation levels in the 

NCA. It is possible that access to currently remote lands 

from the corridor could increase recreation levels in the 

NCA, particularly if a “northern transportation route” 

were developed that included recreational access points. 

On the other hand, it is also possible that the site impacts 

and broader visual impacts and noise associated with a 

multi-lane highway or other utility developments, such 

as additional power transmission lines, in the designated 

ROW corridor could discourage recreational users of the 

affected portion of the NCA, and result in reduced recreational use and economic benefits relative to the other 

alternatives. Estimation of the specific and net impacts of 

development of the corridor is beyond the scope of this 

planning-level EIS, and would require specification of 

exact alignments and design features.

The economic impacts of Alternative D associated with 

lands and realty actions likely would be greater than under 

Alternative A or other alternatives. Alternative D designates a 6,350-acre utility and transportation corridor that 

would allow for development of new utility and transportation projects—including a multi-lane highway—that 

might be precluded under Alternative A and would be 

precluded under the other alternatives. Such development 

would likely have beneficial effects (increased economic 

output, labor income, and jobs) on the local economy, especially during the construction stage. As discussed below, 

additional market and nonmarket benefits and costs might 

also result. Designation of the remainder of the NCA as 

an ROW Exclusion area in Alternative D could preclude 

new ROWs in other portions of the NCA land that would 

benefit the local economy. The economic impacts of land 

acquisition under Alternative D would be the same as the 

other alternatives. 

The economic impact of Alternative D associated with 

special designations would be the same as Alternative A.

Economic Impacts—Nonmarket Values

Alternative D includes most of the provisions noted in 

the nonmarket values subsection for Alternative B that 

would protect species and habitats in the NCA. However, 

there are some differences that make Alternative D less 

protective of species and habitats, and their associated 

nonmarket values, than Alternatives B or C. Most of 

these differences are relatively modest:

▶ Reduced conditions on the geographic sourcing and 

native/non-native status of seeds and plant materials used for re-vegetation efforts;

▶ Allowances for use of more invasive methods for 

seeding restoration treatments;

▶ Reduction in the riparian zone buffer, from 150 to 

100 meters;
858 Chapter 4 RCNCA RCNCA Chapter 4 859

SOCIAL AND ECONOMIC CONDITIONS

▶ Classification of 9,397 acres in the Frontcountry 

Zone for recreation management rather than the 

Backcountry Zone (the Frontcountry Zone has 

fewer management controls);

▶ Allowing dispersed camping anywhere in the 

Backcountry Zone.

One major difference exists between Alternative D and 

all other alternatives. Alternative D would designate a 

6,350-acre utility and transportation corridor. This corridor would allow for location of new utilities through the 

NCA, and for the development of Washington County’s 

proposed “northern transportation route” highway. 

The stated need for a “northern transportation route” is 

to reduce projected traffic pressure on existing roads in 

the greater St. George metropolitan area. According to 

the Washington Parkway Cost/Benefit Study, the highway would:

▶ Reduce delays;

▶ Reduce accidents;

▶ Improve air quality; and 

▶ Stimulate economic growth (Horrocks Engineers 

2011).

These benefits all have market and nonmarket value 

components. The Washington Parkway Cost/Benefit 

Study estimated the value of reductions in traffic congestion by multiplying estimated user costs per vehicle hour 

by estimated travel time reductions for various alignments. The cost/benefit ratio was considerably greater 

than 1.0 (unfavorable) for all alignments when considering the annual savings, but would be much less than 1.0 

(favorable) if the net present value of the savings stream 

was taken over the project’s economic life. It is important 

to note that the cost/benefit ratios in the Washington 

Parkway Cost/Benefit Study were based on population 

projections released in 2008 by the Utah Governor’s 

Office of Planning and Budget. These estimates were 

revised downward considerably when that office released 

new projections in 2012. It is not clear if a long-term 

cost/benefit ratio for the highway would be favorable, 

based on the new population projections.

Other market-based benefits of a “northern transportation route” highway project could be calculated. Such a 

project would provide realizable (market-based) economic benefits to the region. The project would also provide 

additional nonmarket values, such as reductions in distress from traffic delays and accidents, or improvements 

in air quality. These benefits might be substantial, but it is 

not within the scope of this RMP/EIS to update previous 

calculations for the highway or estimate other benefits.

At the same time, designation of a 6,350-acre utility 

and transportation corridor through mid-section of the 

45,000-acre NCA would clearly have major negative impacts to many of the resources and associated nonmarket 

values the NCA was designated to protect. The impacts 

of the corridor on NCA resources and resource uses are 

discussed in other sections of Chapter 4 and summarized here with respect to implications for nonmarket 

values. The potential impacts to ecological and wildlife 

resources, and particularly to the habitat and populations 

of the threatened Mojave desert tortoise, are well-known. 

Thus, the nonmarket benefits of protecting and enhancing the ecological and wildlife resources of the NCA 

would be impacted for current and future generations. 

Locating a multi-lane highway in the heart of the NCA 

would compromise the scenic resources of a large area. 

This, and noise from the road, would reduce the nonmarket benefits obtained by recreational users potentially 

affected by the visual and noise impacts of the highway. 

Certain recreational, cultural, and historical sites—depending on the final alignment of the highway—could be 

negatively impacted, directly or through degradation of 

their environs due to the visual and noise impacts of the 

highway. Educational and scientific opportunities could 

be compromised, by the loss of natural and heritage 

resources that would be destroyed by the construction 

of new utilities and transportation facilities within the 

6,350-acre designated corridor. 

Measures to reduce and mitigate the impacts of a “northern transportation route” have been proposed. A study 

prepared for the DMPO and other state and local governments (Jacobs and Logan Simpson Design Inc. 2012) 

identified a range of “context-sensitive solutions” to 

potential impacts on the tortoise. The report maintains 

that creative engineering design and use of a variety of 

best practices could reduce transportation-related threats 

to the tortoise, including direct mortality, habitat loss, 

habitat fragmentation, spread of exotic and invasive 

plants, increased predation, increased public access to 

remote areas, etc. 

However, while the proposed measures could reduce 

impacts relative to a conventionally designed and constructed highway, they would not reduce most impacts 

relative to not developing the highway. And they do not 

address several fundamental issues:

▶ Even if creatively located and designed, the 

highway would result in some—perhaps 

SOCIAL AND ECONOMIC CONDITIONS

considerable—losses and fragmentation of tortoise 

habitat;

▶ The legislation that established the NCA focused 

on conserving, protecting, and enhancing resources 

within the NCA. It does not specifically authorize 

off-NCA mitigation of the resource values the NCA 

was created to protect, such as a “satellite reserve” 

proposed in the DMPO report;

▶ The “context sensitive solutions” do not address the 

potential damage or destruction of other resource 

values, including ecological values, cultural and 

historical resources, scenic, and recreational values 

that were equally identified by Congress as purposes 

for which the NCA was designated. 

Development of a “northern transportation route” under 

Alternative D would negatively impact a majority of the 

unique resources that the NCA was created to protect, 

and their associated nonmarket values. Due to the 

contemplated scale of the project, it is likely that these 

impacts would significantly compromise these resources 

and values, relative to Alternatives A, B, and C, which do 

not designate a ROW corridor that could be utilized for a 

“northern transportation route”. 

With respect to geological, paleontological, archaeological, and cultural resources, Alternative D is essentially 

the same as Alternative B, thus it would generally improve the protection and enhancement of the associated 

nonmarket values relative to Alternative A. However, 

depending on the nature and exact location of development (including a “northern transportation route”) 

within the utility and transportation corridor designated 

in Alternative D, nonmarket values associated with 

geological, paleontological, archaeological, and cultural 

resources may be negatively impacted. Alternative D 

would also allow non-commercial collection of common invertebrate fossils and petrified wood. This would 

increase use value to the collectors, but over time would 

reduce use values to persons who would have reduced 

opportunities to view these resources in situ, and would 

reduce passive use value to persons who value in situ 

preservation of these resources.

Alternative D provides no specific management actions 

for wilderness or wilderness characteristics that differ 

from Alternative B. Therefore, Alternative D would have 

the same impacts on nonmarket values associated with 

wilderness as Alternative B, and would provide increased 

protections of those values relative to Alternative A.

Alternative D generally takes the same approach to recreation management as that noted in the nonmarket values 

subsection for Alternative B. Thus, relative to Alternative 

A, Alternative D would better protect and enhance recreation-related nonmarket values, except if major development of the ROW corridor designated in Alternative 

D occurs, as noted above. Relative to Alternative B, 

Alternative D has slightly less restrictive VRM classifications, which might reduce nonmarket values for some 

recreationists. It also has several additional provisions 

that are somewhat less restrictive on recreation activity. 

These include:

▶ Moving 5,900 acres from Frontcountry Zone to 

the Backcountry Zone, which has somewhat lower 

levels of management control;

▶ Eliminating overnight camping in the Red Cliffs 

Recreation Area;

▶ Providing for a higher level of development of 

facilities and larger group sizes at the Sand Cove 

Primitive Camping Area;

▶ Allowing dispersed camping anywhere in the 

Backcountry Zone;

▶ Providing for a higher limit on visitation under 

SRPs;

▶ Allowing for competitive running and bicycling 

events on roads and trails (under conditions);

▶ Keeping the road leading to the Historic Babylon 

Trailhead open to all vehicles.

The net effect of these changes relative to Alternative 

B (and Alternative C) is difficult to estimate. In the 

absence of major development in the new designated 

utility and transportation corridor, it is likely the levels of 

recreation-related nonmarket values under Alternative D 

would be similar to Alternative B. However, if development (particularly of a “northern transportation route”) 

within the corridor designated in Alternative D occurs, 

the nonmarket values associated with recreation would 

be negatively impacted, probably resulting in lower levels 

of recreation-related nonmarket values under Alternative 

D than under other alternatives.

In the areas of public education and scientific research, 

Alternative D includes essentially the same provisions as 

Alternative B for education, interpretation, and research 

activities. Thus, Alternative D would enhance education and research-related nonmarket values relative to 

Alternative A, and would provide similar levels of these 

values to Alternative B. However, depending on the 

nature and exact location of development (including a 
860 Chapter 4 RCNCA RCNCA Chapter 4 861

SOCIAL AND ECONOMIC CONDITIONS

“northern transportation route”) within the ROW corridor designated in Alternative D, nonmarket values 

associated with education and research may be negatively 

impacted.

Regarding traditional uses, management actions for 

livestock grazing are the same as in Alternative A; therefore, the impacts to nonmarket values associated with 

livestock grazing would be the same as Alternative A. 

Alternative D’s actions related to Native Americans are 

essentially the same as Alternative B. Thus, the nonmarket values associated with Native American traditional 

uses would be the same as in Alternative B, and better protected and enhanced than under Alternative A. 

However, depending on the nature and exact location 

of development (including a “northern transportation route”) within the ROW corridor designated in 

Alternative D, nonmarket values associated with Native 

American traditional uses may be negatively impacted.

In summary, relative to Alternative A, and in the absence 

of major development of the designated ROW corridor, 

Alternative D would generally provide greater protection and enhancement of many of the nonmarket values 

associated with the NCA. However, by designating a new 

6,350-acre utility and transportation corridor within the 

heart of the NCA, and allowing for the development for 

utilities and transportation—particularly a “northern 

transportation route”—Alternative D would very likely 

significantly compromise many of the nonmarket values 

of the NCA, in and near the corridor.

Social Impacts

Major economic development based on uses of BLMadministered land in the Red Cliffs NCA is unlikely 

under Alternative B; therefore, social impacts driven by 

economic development would not occur under this alternative. If a “northern transportation route” were to be 

developed under this alternative, it would create a shortterm increased need for a significant number of construction workers, but it is not likely that major expansions of public infrastructure and services (e.g., schools, 

police, medical facilities and services) would be needed 

to accommodate these short-term workers. Impacts that 

are more purely social and cultural in nature could occur 

as indicated by the likely views of different stakeholder 

groups regarding this alternative.

Habitat and Resource Conservation Stakeholders 

would find this alternative less favorable to their interests than Alternatives B and C because some of its 

measures, while similar to those of Alternatives B and 

C, are less protective of sensitive species and habitats 

than Alternative C, and somewhat less protective than 

Alternative B. These stakeholders would be particularly 

concerned with Alternative D’s provision for a new 

designated utility and transportation corridor suitable 

for Washington County’s proposed “northern transportation route”, which they see as antithetical to the 

conservation purposes of the NCA. These stakeholders 

would have mixed views regarding the favorability of 

Alternative D compared to Alternative A. Some would 

appreciate that the general framework is more protective 

than Alternative A—in most portions of the NCA—of 

the resources they care about. Others would prefer 

Alternative A because it appears to provide less allowance for the authorization and development of a corridor 

for a “northern transportation route”. Persons within this 

stakeholder category who are concerned with geological, 

paleontological, archaeological, and cultural resources 

would have similar views of this alternative.

Motorized Recreation Stakeholders would view 

Alternative D similarly to Alternative B; its OHV area 

designations are the same, and other variations with 

respect to motorized transportation are not significant. 

Non-Motorized Recreation Stakeholders would view 

this alternative similarly to Alternative B–some would 

favor it over Alternative A and some would not. Most of 

Alternative D’s recreation-related provisions are the same 

as, or more permissive than, Alternative B; therefore, it is 

likely that some non-motorized recreationists would prefer Alternative D to Alternatives B and C. However, some 

would find Alternative D much less preferable to any of 

the alternatives because of its designation of a 6,350-acre 

designated utility and transportation corridor, which 

could include development of a “northern transportation 

route” highway. These persons would be concerned that 

a highway through this corridor in the central portion of 

the NCA would have significant impacts—visual impacts, 

noise, reduction of solitude opportunities in formerly 

remote areas, etc.,—on the quality of their recreational 

experiences in the NCA.

Livestock Grazing Stakeholders would view Alternative 

D in the same way as Alternative A; its grazing-related 

management actions are the same.

Economic Development Stakeholders would find 

Alternative D the most favorable alternative. Unlike 

Alternatives A, B, and C, Alternative D explicitly provides for a 6,350-acre designated corridor. This corridor could be suitable for development of a multi-lane 

“northern transportation route” highway, which these 

IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES

stakeholders see as extremely important to economic 

development in the region. However, these stakeholders 

would not favor the decision in Alternative D to designate the remainder of the NCA as a ROW Exclusion 

area, which would preclude ROWs these stakeholders 

may wish to promote for other economic development 

purposes in other portions of the NCA.

4.45.2.6 Environmental Justice Effects

Under the Executive Order on EJ, each federal agency 

must identify and address “disproportionately high and 

adverse human health or environmental effects of its programs, policies, and activities on minority populations 

and low-income populations” (EO 12898, §59 Federal 

Register 7629, 1994). Environmental effects include 

economic effects, such as costs imposed on persons in 

proximity to a federal action. Based on the EJ screening criteria and analysis presented in the Socioeconomic 

Baseline Report, no places in Washington County meet 

the criteria for potential EJ populations based on minority population. One place in Washington County meets 

the criteria for a potential EJ population based on poverty status. This is Hildale City, based on the high percentage of its population living under the poverty level. In 

addition, according to federal guidance for considering 

EJ within the NEPA process (Council on Environmental 

Quality, 1997), Indian Tribes within the affected area 

of the proposed action must be considered in the EJ 

analysis. The analysis determined that a high proportion 

(estimated at 44 %) of Native American individuals in 

Washington County are living in poverty, and, thus, the 

Native American population of the County meets the 

criteria to be considered a potential EJ population. 

Further assessment determined that the potential for 

disproportionately high and adverse human health or environmental effects on these populations from the RMP 

alternatives is low. “Disproportionate” and “adverse” are 

the key concepts in this assessment. An EJ impact only 

exists if the impact on the identified population is harmful, and “appreciably exceeds or is likely to appreciably 

exceed” the impact to the general population or other 

appropriate comparison group. In this case, the appropriate reference population is the general population of 

Washington County. The analysis results are as follows:

▶ Hildale City—This community is located at a considerable distance from the NCA. Thus it is unlikely 

to be adversely impacted by management decisions 

in the NCA RMP. 

▶ Native American population in Washington 

County—This population is unlikely to experience 

both adverse and disproportionately high impacts 

from management decisions in the NCA RMP. No 

Native Americans are known to currently hold any 

grazing permits or Special Recreation Permits in 

the SGFO, so this population would not be affected 

by management actions affecting those permits. 

It is unlikely that any other activities allowed or 

prohibited by the RMP alternatives would have 

adverse health or environmental impacts on Native 

Americans in Washington County at rates that are 

disproportionate to any adverse impacts experienced by other residents, particularly given that the 

Native American population is not concentrated 

in any one area (see the Socioeconomic Baseline 

Report at www.blm.gov/nxld). 

Federal EJ guidance also recognizes impacts to Native 

American cultural sites as potential EJ impacts. With respect to such sites—ethno-historic sites, sacred sites, traditional cultural properties and traditional use areas—all 

RMP alternatives have provisions for consultations with 

American Indian Tribes as required by federal historic 

preservation laws, to inform and direct resource allocation and other management decisions related to these 

heritage resources. The action alternatives (B, C, and 

D) also would develop activity level Cultural Resource 

Project Plans for multiple types of heritage resources in 

consultation with culturally-affiliated American Indian 

Tribes. These consultations should allow for avoidance 

or mitigation of impacts to heritage resources. In summary, it is unlikely that the RMP alternatives would have 

disproportionately high and adverse human health or 

environmental effects on the Native American population of Washington County.

4.46 IRREVERSIBLE AND IRRETRIEVABLE 

COMMITMENT OF RESOURCES

Section 102(2)(C) of NEPA requires a discussion of any 

irreversible or irretrievable commitments of resources that 

are involved in the proposal should it be implemented. An 

irretrievable commitment of a resource is one in which the 

resource or its use is lost for a period of time (e.g., modifications to the landscape from fire or other vegetation treatments). An irreversible commitment of a resource is one 

that cannot be reversed (e.g., the extinction of a species or 

destruction of significant heritage resources).

Implementing some of the management decisions or 

actions identified in the RMP could result in the irreversible or irretrievable commitment of resources. As examples, the development of new trails or trailhead parking 
862 Chapter 4 RCNCA SGFO RMP AMENDMENT Chapter 4 863

RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES AND LONG-TERM 

PRODUCTIVITY

areas would remove vegetation and this resource would 

be lost for a period of time at those locations. However, 

the majority of actions proposed under all alternatives 

would focus on the conservation, protection, and restoration of the NCA, minimizing the potential for the irreversible or irretrievable commitment of resource values.

Under Alternative D, a new 6,350-acre utility and transportation corridor would be designated through the 

NCA. Within this corridor, BLM could authorize ROWs 

for the construction of new utilities and the new “northern transportation route” multi-lane highway requested 

by Washington County. Such developments would result 

in the irreversible or irretrievable commitment of resource values, including native vegetation, soils, heritage 

resources, critical habitat for the Mojave desert tortoise 

and other at-risk species, recreation opportunities, and 

the scenic qualities of the lands. The impacts related to 

the development of utilities and a new highway would be 

mitigated to the extent possible through project design 

and BMPs, but would comprise a significant, irreversible, and irretrievable loss of natural, cultural, visual, and 

social resource values within the designated corridor.

4.47 RELATIONSHIP BETWEEN LOCAL SHORTTERM USES AND LONG-TERM PRODUCTIVITY

Section 102(C) of NEPA requires discussion of the 

relationship between local, short-term uses of human 

environment, and the maintenance and enhancement 

of long-term productivity of resources. As described in 

the introduction to this chapter, “short-term” is defined 

as anticipated to occur within one to five years of implementation of the activity. “Long-term” is defined as following the first five years of implementation but within 

the life of the RMP (projected to be 20 years).

Across all alternatives, certain management actions, 

such as hazardous fuel reduction projects or noxious 

weed control, could result in short-term effects, such as 

increased localized soil erosion, fugitive dust emission, 

vegetation loss or damage, or disturbances to wildlife. 

Alternative C would emphasize land use restrictions 

and the use of the least invasive method to accomplish 

resource objectives and result in the fewest short-term 

resource commitments, when compared to Alternatives 

A, B, and D. In the long term, the three action alternatives would be expected to more effectively restore damaged landscapes, increase biodiversity, and enhance the 

long-term productivity of the public lands of the NCA 

than Alternative A, the No Action Alternative.

Under Alternative D, a new 6,350-acre utility and transportation corridor would be designated through the 

NCA. Within this corridor, BLM could authorize ROWs 

for the construction of new utilities and the new “northern transportation route” multi-lane highway requested 

by Washington County. Such developments would result 

in the long-term loss of resource values and productivity, including native vegetation, soils, heritage resources, 

critical habitat for the Mojave desert tortoise and other 

at-risk species, recreation opportunities, and the scenic 

qualities of the lands. The impacts related to the development of utilities and a new highway would be mitigated 

to the extent possible through project design and BMPs, 

but would comprise a significant, adverse, and irreversible loss of resource values.

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

4.48 AREAS OF CRITICAL ENVIRONMENTAL 

CONCERN

The SGFO RMP Amendment addresses two issues 

that resulted from the passage of OPLMA in 2009. At 

Section 1979, OPLMA mandated BLM to identify areas 

of public land where biological conservation is a priority and undertake activities to conserve and restore 

plant and animal species and natural communities. This 

Congressional mandate would be accomplished through 

the administrative designation of ACECs for native plant 

and animal species and natural communities that meet 

both the relevance and importance criteria and require 

special management to prevent irreparable damage to 

those values.

The BLM Planning Team evaluated all of the ACEC 

nominations and recommended special management 

prescriptions that would address threats related to public 

land management that could cause irreparable damage to 

the relevant and important values. Appendix E provides 

the complete technical report prepared by BLM to document the ACEC evaluation process and the findings.

4.48.1 Methods of Analysis

Impacts are quantified where possible. In the absence 

of quantifiable data, professional judgment was used. 

Impacts are sometimes described using ranges of potential impacts or in qualitative terms, if appropriate. 

Adverse impacts to the relevant and important values of 

designated ACECs could result from management actions that diminish any of the fundamental components 

listed in the indicators section below.

Beneficial effects could result from management actions 

that maintain or enhance any of the fundamental components listed in the indicators section below. 

4.48.1.1 Indicators

Indicators of adverse impacts on the relevant and important values of ACECs, as a result of public land management, include the following:

▶ Declines in species numbers and population viability, resulting in the need to list species under 

the ESA or the inability to delist species, based on 

recovery;

▶ Habitat loss or adverse modification that contributes to the need to list species under the ESA or the 

inability to delist species, based on recovery.

Indicators of beneficial effects on the relevant and important values of ACECs, as a result of public land management, include the following:

▶ Increases in species numbers and population viability, resulting in the delisting of species under the 

protection of the ESA, based on recovery;

▶ Habitats that sustain population viability, allowing 

recovery and delisting of threatened or endangered 

species and precluding the need to list species under 

the ESA.

The relevant and important values and number of 

acres that would be designated for each potential 

ACEC are summarized in Table 2.69, Areas of Critical 

Environmental Concern.

4.48.1.2 Assumptions

The analysis includes the following assumption:

▶ Land uses would not be authorized that would adversely impact the relevant and important values for 

which ACECs are designated.

▶ Management prescriptions proposed for designated 

ACECs, in concert with applicable federal laws, 

regulations, and agency policies, would address 

threats to the relevant and important values of 

potential ACECs, preventing irreparable damage to 

those values.

▶ Management goals, objectives, and decisions from 

the SGFO RMP, unless modified by legislative 

mandates or subsequent RMP Amendments, would 

continue to be valid, existing management for public lands in Washington County (outside of the two 

NCAs and designated Wilderness) until a full RMP 

revision is completed.

4.48.2 Direct and Indirect Impacts

4.48.2.1 South Hills Potential ACEC: (1,950 Acres)

Relevance and Importance Values: Endangered Species: 

Dwarf Bearclaw Poppy and Holmgren Milkvetch 

Management decisions in the SGFO RMP for the following resources would have negligible or no impact 

on the relevance and importance values of the South 

Hills Potential ACEC and are, therefore, not discussed 

in further detail: Air Quality, Soil and Water Resources, 

Riparian Resources, Vegetation Resources, Fish and 

Wildlife Habitat Management, Livestock Grazing 

Management, Recreation, Wilderness Management, 

Cultural and Paleontological Resources, Hazardous 

Chapter 4: Environmental Consequences SGFO RMP Amendment
864 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 865

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

Waste Management, Fire Management, and Wild and 

Scenic Rivers.

Impacts from Management of Lands and Realty

Under Alternatives A and D, the potential ACEC would 

not be designated. Public lands that support federallylisted native plants would generally be retained in 

federal ownership under both alternatives. The full 

legal protections of the ESA would continue to apply 

on federally-managed lands, conferring protections to 

habitats and populations of dwarf bearclaw poppy and 

Holmgren milkvetch.

However, under the current SGFO RMP, in the event that 

exchange or transfer of public lands from federal ownership would result in the acquisition of better quality habitat for a special status species native plant or provide for 

suitable management by another agency or organization, 

some or all of the 1,950 acres of the potential South Hills 

ACEC could leave federal ownership. The legal protections of the ESA would not apply to listed native plant 

populations or critical habitats, if the transferred lands 

were not acquired by another federal agency. Should the 

lands be exchanged or transferred into private or state 

ownership, developments could occur that would damage or destroy habitats and populations of dwarf bearclaw 

poppy and Holmgren milkvetch. Under both alternatives, 

the exchange or transfer from federal ownership could 

result in major adverse impacts on the native plant populations in the South Hills area.

Alternatives B and C would designate the potential 

South Hills ACEC and retain all public lands within the 

ACEC in federal ownership; this would provide a major beneficial effect to populations of dwarf bear poppy 

and Holmgren milkvetch, as the legal protections of the 

ESA would continue to be applied on federally-managed 

lands. Land uses and activities would not be authorized 

by BLM in the ACEC that would damage or destroy 

habitats and plant populations, providing a significantly 

higher level of protection for both native species, when 

compared to Alternatives A and D. 

Alternatives A and D would manage the 1,950-acre 

potential ACEC as an Avoidance area for new ROWs. 

This would provide some level of protection to dwarf 

bearclaw poppy and Holmgren milkvetch, as surface disturbances associated with the construction of new utility 

and transportation facilities under ROWs would generally not be authorized in Avoidance areas. However, the 

SGFO RMP includes a management decision that would 

allow the granting of new ROWs in Avoidance areas if 

they meet specific criteria. Project-specific NEPA analysis 

and Section 7 consultation under the ESA could develop 

measures to lessen, but not completely avoid, impacts on 

dwarf bearclaw poppy and Holmgren milkvetch, should 

new ROWs be authorized.

Under Alternatives B and C, the potential South Hills 

ACEC would be designated and managed as a ROW 

Exclusion area. New ROWs would not be granted, avoiding impacts on these endangered native plants and their 

habitats from the construction of new utility and transportation facilities.

Impacts from Management of Energy and Mineral 

Resources

Under Alternatives A and D, the potential South Hills 

ACEC would not be designated and 1,950 acres of public 

land would continue to be Open to fluid mineral leasing, 

with Special Stipulations. Special Stipulations, projectspecific NEPA analysis, and Section 7 consultation 

under the ESA could develop measures to lessen, but not 

completely avoid, impacts on dwarf bearclaw poppy and 

Holmgren milkvetch.

Alternatives B would manage the potential ACEC as 

Open to fluid mineral leasing with NSO. This stipulation would help to prevent most surface disturbances 

that would impact dwarf bearclaw poppy and Holmgren 

milkvetch populations and habitats, but may not entirely 

protect these listed plants from indirect impacts related 

to this activity.

Alternative C would manage the area as Closed to fluid 

mineral leasing, providing the highest level of protection 

of both plants and their habitats from impacts associated 

with oil and gas leasing and developments.

Under Alternatives A and D, the potential South Hills 

ACEC would not be designated and the public lands 

would remain available for mineral materials sales and 

harvesting. Should such sales be authorized in habitats 

for federally-listed native plants, measures to minimize 

impacts would be developed through a site-specific 

NEPA analysis and Section 7 consultation. It is unlikely 

that all impacts could be avoided if the plants occur 

within the project area, and habitat could be permanently 

lost to this activity.

Alternatives B and C would manage the potential ACEC 

as Closed to mineral material sales and harvesting, 

protecting 1,950 acres of habitat and populations of two 

endangered native plants.

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

Impacts from Transportation and Off-Highway Vehicle 

Management

Alternatives A and D would not designate the potential ACEC, but would manage OHV travel as Limited 

to Designated Roads and Trails, to be identified in the 

TMP currently being prepared by BLM. Under either 

alternative, motorized vehicle travel should not impact 

native plants, as all authorized use would be on designated routes.

Alternative B would provide a higher level of protection 

for plants and habitats than Alternatives A or D, as this 

alternative manages OHV travel in the potential ACEC 

as Limited to Designated Roads and Trails. Alternative C’ 

further limits travel by managing the ACEC under the 

OHV area designation as closed to OHV use with limited 

access for administrative uses only. General public travel 

would not be authorized on the designated roads within 

the potential ACEC, reducing the potential for motorized 

vehicles to impact native plants and their habitats.

Alternative C would manage the potential ACEC as 

Closed to all motorized vehicle uses, providing the highest level of protection of habitats and plant populations of 

dwarf bearclaw poppy and Holmgren milkvetch.

Impacts from Management of Native Vegetation and 

Forest Products

Under all alternatives, the potential ACEC would be 

closed to native seed, plants, and plant material harvesting for commercial purposes and personal use. The area 

would also be closed to forest/woodland product harvesting and collection, for commercial purposes and personal use. These restrictions would help to protect habitats 

and populations of both endangered plant species, by not 

authorizing activities that result in surface disturbances 

and the removal of native vegetation.

Impacts from Management of Recreation 

Under Alternatives A and D, the potential South Hills 

ACEC would not be designated and management direction for the 1,950 acres would continue to be derived 

from the current SGFO RMP. The area would remain 

open to most forms of recreational activities, including dispersed camping and recreational target shooting. 

Dispersed camping in habitats that support federallylisted native plants could cause soil compaction that 

degrades habitats, could damage or destroy plants, and 

could increase the risk of wildfires. Recreational target 

shooting can also destroy native plants and degrade their 

habitats, through soil compaction created by shooters 

and motorized vehicles, as well as the accumulation of 

target trash and other litter.

Under Alternatives B and C, the potential South Hills 

ACEC would be designated and the area closed to dispersed camping.

Alternative B would continue to authorize recreational 

target shooting, but require the use of specific types of 

targets and the removal of all targets, clays, and shells. 

Alternative C would close the area to recreational target 

shooting. Both alternatives would better protect habitats 

and populations for dwarf bearclaw poppy and Holmgren 

milkvetch from the recreational impacts described above. 

Alternatives A, B, and D could continue to authorize the 

issuance of SRPs for commercial, organized group, and 

competitive events in the potential ACEC, if site-specific 

NEPA analysis and Section 7 ESA consultations find 

that the proposed activities would not result in adverse 

modification of critical habitats or the damage or loss of 

the federally-listed native plants.

Alternative C would not authorize the issuance of SRPs 

for competitive events, lessening the potential that authorized recreation activities would negatively impact native 

plant populations and habitats. Alternative C would also 

prohibit commercial and organized groups, providing the 

highest level of protection for dwarf bearclaw poppy and 

Holmgren milkvetch populations and habitats as it relates 

to recreational activities that are authorized under SRPs.

Impacts from Management of Visual Resources

Alternatives A and D would not designate the potential 

South Hills ACEC and the public lands would continue 

to be managed under VRM Class III. This VRM Class 

allows for changes in the landscape to be noticeable; 

projects and developments that create extensive surface 

disturbances could be authorized under this VRM Class. 

Management under this VRM Class would not further 

the protection of native plant populations and habitats.

Alternatives B and C would manage the potential ACEC 

under VRM Class II, providing a higher level of protection for the scenic qualities of the area. Management 

under this VRM Class would restrict the types of projects 

or developments that could be authorized, enhancing 

the protection of dwarf bearclaw poppy and Holmgren 

milkvetch habitats and populations.

Summary of Impacts from Alternatives

Table 4-43 compares the special management prescriptions developed by BLM’s Planning Team to address 

potential threats to the relevant and important values of 
866 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 867

the potential South Hills ACEC with current management under the SGFO RMP. Under Alternatives A and 

D, this potential ACEC would not be designated and 

management of the public lands would continue under 

the management decisions contained in the 1999 SGFO 

RMP. As this comparison shows, Alternatives A and D 

may not sufficiently protect dwarf bearclaw poppy and 

Holmgren milkvetch from impacts related to land uses 

and activities on public lands that could continue to be 

authorized under the SGFO RMP.

Under Alternatives B and C, the potential South Hills 

ACEC would be administratively designated and would 

provide the additional special management attention 

needed to protect these populations of dwarf bearclaw 

poppy and Holmgren milkvetch.

4.48.2.2 State Line Potential ACEC (1,411 Acres)

Relevance and Importance Values: Endangered Species: 

Holmgren Milkvetch and Gierisch Globemallow

Management decisions in the SGFO RMP for the following resources would have negligible or no impact 

on the relevance and importance values of the State 

Line Potential ACEC and are, therefore, not discussed 

in further detail: Air Quality, Soil and Water Resources, 

Riparian Resources, Vegetation Resources, Fish and 

Wildlife Habitat Management, Livestock Grazing 

Management, Wilderness Management, Cultural 

and Paleontological Resources, Hazardous Waste 

Management, Fire Management, and Wild and Scenic 

Rivers.

Impacts from Management of Lands and Realty

Under Alternatives A and D, the potential ACEC would 

not be designated. Public lands that support federallylisted native plants would generally be retained in 

federal ownership under both alternatives. The full legal 

AREAS OF CRITICAL ENVIRONMENTAL CONCERN AREAS OF CRITICAL ENVIRONMENTAL CONCERN

protections of the ESA would continue to be applied 

on federally-managed lands, conferring protections to 

habitats and populations of Holmgren milkvetch and 

Gierisch globemallow.

However, under the current SGFO RMP, in the event that 

exchange or transfer of these public lands from federal 

ownership would result in the acquisition of better habitat or provide for suitable management by another agency 

or organization, some or all of the 1,411 acres could 

leave federal ownership. The legal protections of the ESA 

would not apply to native plant populations or habitats, 

if the transferred lands were not acquired by another federal agency. Should the lands be exchanged or transferred 

into private or state ownership, developments could 

occur that would damage or destroy habitats and populations of both endangered native plants. Under both alternatives, the exchange or transfer from federal ownership 

could result in major adverse impacts on the native plant 

populations in the potential State Line ACEC.

Alternatives A and D would manage the 1,411-acre 

potential ACEC as an Avoidance area for new ROWs. 

This would provide some level of protection to both native plant species, as new ROWs would generally not be 

authorized and surface disturbances associated with the 

construction of new utility and transportation facilities 

would not occur.

However, the SGFO RMP includes a management decision that would allow the granting of new ROWs in 

Avoidance areas when feasible alternative routes or designated corridors are not available. There would be some 

potential that new linear ROWs could be granted that 

would adversely modify critical habitats for Holmgren 

milkvetch and Gierisch globemallow and destroy populations of these native plants. Consultations under Section 

7 of the ESA would be used to identify minimization and 

mitigation measures to avoid or lessen impacts on either 

species, but could not ensure that the granting of new 

ROWs would not measurably and negatively impact the 

potential recovery of these two endemic plants.

Alternatives B and C would provide a major beneficial 

effect by managing all of the public lands in the potential ACEC as a ROW Exclusion area, where linear 

and site-type ROWs would not be authorized. Adverse 

modification of critical habitats for Holmgren milkvetch 

and Gierisch globemallow and impacts to populations of 

these native plants would not occur, as new utility and 

transportation ROWs would not be authorized.

Impacts from Management of Energy and Mineral 

Resources

Under Alternatives A and D, the potential State Line 

ACEC would not be designated and 1,411 acres of public 

land would continue to be Open to fluid mineral leasing, 

with Special Stipulations. Special Stipulations, projectspecific NEPA analysis, and Section 7 consultation under 

the ESA could develop measures to lessen, but perhaps 

not completely avoid, impacts on Holmgren milkvetch 

and Gierisch globemallow.

Alternative B would manage the potential ACEC as Open 

to fluid mineral leasing with NSO. This stipulation would 

help to prevent most surface disturbances that would impact native plant populations and habitats, but may not 

entirely protect these listed plants from indirect impacts 

related to this activity.

Alternative C would manage the area as Closed to fluid 

mineral leasing, providing the highest level of protection 

of both plants and their habitats from impacts associated 

with oil and gas leasing and developments.

Under Alternatives A and D, the potential State Line 

ACEC would not be designated and the public lands 

would remain available for mineral materials sales and 

harvesting. Should such sales be authorized in habitats 

for federally-listed native plants, measures to minimize 

impacts would be developed, through a site-specific 

NEPA analysis and Section 7 consultation. It is unlikely 

that all impacts could be avoided, if the plants occur 

within the project area, and habitat would be permanently lost to this activity.

Alternatives B and C would manage the potential ACEC 

as closed to mineral material sales and harvesting, 

protecting 1,411 acres of habitat and populations of two 

endangered native plants.

Impacts from Transportation and Off-Highway Vehicle 

Management

Alternatives A and D would not designate the potential 

ACEC, but would manage motorized OHV travel as 

Limited to Designated Roads and Trails, to be identified 

in the TMP currently being prepared by BLM. Under 

either alternative, motorized vehicle travel should not 

impact native plants, as all authorized use would be on 

designated routes.

Alternative B would provide a higher level of protection for plants and habitats than Alternatives A or D, as 

this alternative manages motorized vehicle travel in the 

potential ACEC as Limited to Designated Roads and 

Trails and further limit travel on designated roads to 

Resource Relevance

Criteria Met

Importance 

Criteria Met

Special Management to Mitigate Threats

Dwarf Bearclaw-Poppy Yes Yes 1 - Retain in Federal ownership

2 - NSO to Oil and Gas leasing

3 - Close to forest/woodland product and seed 

harvesting

4 - OHV area designation limited to designated routes

5 - ROW exclusion

6 - Manage as VRM II.

7 - Close to mineral material disposal.

8 - Prohibit competitive special recreation permits.

Holmgren milkvetch

Yes Yes

Desert Tortoise Yes No Not Applicable

Gila Monster Yes No

Resource Current Land Use Decision

Dwarf Bear-Poppy

Holmgren milkvetch

1 – VG-08, LD-06, LD-07, Map 2.1: Retain in Federal ownership, a portion (20%) of the 

potential ACEC is identified for disposal in the 1999 SGFO RMP.

2 - RP-11, Table 2-5: Open with Special Stipulations (Category 2)

3 - FR-01, FR-08: T&E Plant Habitats are closed to forest/woodland product and seed 

harvesting

4 - VG-09, OV-01: OHV area designation limited to designated routes, OV-04: Ability to 

close routes in sensitive species habitat

5 - VG-09, LD-19: ROW Avoidance 

6 - VR-01: VRM III.

7 - No applicable decision.

8 - No applicable decision. 

Table 4-43 South Hills Potential ACEC: Comparison of Required Special Management Prescriptions with RMP Decisions
868 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 869

administrative uses only. General public travel would not 

be authorized on the designated roads within the potential ACEC, reducing the potential for motorized vehicles 

to impact native plants and their habitats.

Alternative C would manage the potential ACEC as 

Closed to all motorized vehicle uses, with and exception 

for administrative uses, providing the highest level of 

protection of habitats and plant populations of Holmgren 

milkvetch and Gierisch globemallow.

Impacts from Management of Native Vegetation and 

Forest Product Harvesting

Under all alternatives, the potential ACEC would be 

closed to native seed, plants, and plant material harvesting for commercial purposes and personal use. It 

would authorize the collection of natives seeds, cuttings, 

biological soil crust communities and species for scientific research, conservation, and for use in future restoration projects, as long as this activity is compatible with 

resource management objectives. The area would also be 

closed to forest/woodland product harvesting and collection, for commercial purposes and personal use. These 

restrictions would help to protect habitats and populations of both endangered plant species, by not authorizing activities that result in surface disturbances and the 

removal of native vegetation.

Impacts from Management of Recreation 

Under Alternatives A and D, the potential State Line 

ACEC would not be designated and management direction for the 1,411 acres would continue to be derived 

from the current SGFO RMP. The area would remain 

open to most forms of recreational activities, including 

dispersed camping. Dispersed camping in habitats that 

support federally-listed native plants causes soil compaction that degrades habitats, damages or destroys plants, 

and increases the risk of wildfires.

Under Alternatives B and C, the potential State Line 

ACEC would be designated and the area closed to dispersed camping.

Alternatives A, B, and D could continue to authorize the 

issuance of SRPs for commercial, organized group, and 

competitive events in the potential ACEC, if site-specific 

NEPA analysis and Section 7 ESA consultations find 

that the proposed activities would not result in adverse 

modification of critical habitats or the damage or loss of 

the federally-listed native plants.

Alternative C would not authorize the issuance of SRPs 

for competitive events, lessening the potential that authorized recreation activities would negatively impact native 

plant populations and habitats. Alternative C would also 

prohibit commercial and organized groups, providing 

the highest level of protection for Holmgren milkvetch 

and Gierisch globemallow populations and habitats, as it 

relates to recreational activities that are authorized under 

SRPs.

Impacts from Management of Visual Resources

Alternatives A and D would not designate the potential 

State Line ACEC and the public lands would continue 

to be managed under VRM Class III. This VRM Class 

allows for changes in the landscape to be noticeable; 

projects and developments that create extensive surface 

disturbances could be authorized under this VRM Class. 

Management under this VRM Class would not further 

the protection of native plant populations and habitats.

Alternatives B and C would manage the potential ACEC 

under VRM Class II, providing a higher level of protection for the scenic qualities of the area. Management 

under this VRM Class would restrict the types of projects 

or developments that could be authorized, enhancing the 

protection of Holmgren milkvetch and Gierisch globemallow habitats and populations.

Summary of Impacts from Alternatives

Table 4-44 compares the special management prescriptions developed by BLM’s Planning Team to address 

potential threats to the relevant and important values 

of the potential State Line ACEC with current management under the SGFO RMP. Under Alternatives A and 

D, this potential ACEC would not be designated and 

management of the public lands would continue under 

the management decisions contained in the 1999 SGFO 

RMP. As this comparison shows, Alternatives A and D 

may not adequately protect Holmgren milkvetch and 

Gierisch globemallow from impacts related to land uses 

and activities on public lands that could continue to be 

authorized under the SGFO RMP.

Under Alternatives B and C, the potential State Line 

ACEC would be administratively designated and would 

provide the additional special management attention 

needed to protect populations and habitats for these two 

endangered native plant species.

4.48.2.3 Webb Hill Potential ACEC (520 Acres)

Relevance and Importance Value: Endangered Species: 

Dwarf Bearclaw Poppy

Impacts from Management of Lands and Realty

Under Alternatives A and D, the potential ACEC 

would not be designated. Public lands that support 

AREAS OF CRITICAL ENVIRONMENTAL CONCERN AREAS OF CRITICAL ENVIRONMENTAL CONCERN

federally-listed native plants would generally be retained 

in federal ownership under both alternatives. The full 

legal protections of the ESA would continue to apply on 

federally-managed lands, conferring protections to habitats and populations of dwarf bearclaw poppy.

However, under the current SGFO RMP, in the event that 

exchange or transfer of these public lands from federal ownership would result in the acquisition of better 

habitat or provide for suitable management by another 

agency or organization, some or all of the 520 acres of the 

potential ACEC could leave federal ownership. The legal 

protections of the ESA would not apply to native plant 

populations or habitats if the transferred lands were not 

acquired by another federal agency. Should the lands be 

exchanged or transferred into private or state ownership, 

developments could occur that would damage or destroy 

habitats and populations of dwarf bearclaw poppy. Under 

both alternatives, the exchange or transfer from federal 

ownership could result in major adverse impacts on the 

native plant populations on Webb Hill.

Alternatives B and C would designate the potential Webb 

Hill ACEC and retain all public lands within the ACEC 

in federal ownership for the life of the plan; this would 

provide a major beneficial effect to these populations of 

dwarf bearclaw poppy, as the legal protections of the ESA 

would continue to be applied to listed native plant species on federally-managed lands. Land uses and activities 

that would not be authorized by BLM in the ACEC that 

would damage or destroy habitats and plant populations, 

providing a significantly higher level of protection for 

both native species, when compared to Alternatives 

A and D.

Alternatives A and D would manage the potential ACEC 

as an Avoidance area for new ROWs. This would provide 

some level of protection to both native plant species, as 

surface disturbances associated with the construction of 

new utility and transportation facilities would generally 

not be authorized through ROWs.

However, the SGFO RMP includes a management decision that would allow the granting of new ROWs in 

Avoidance areas when feasible alternative routes or designated corridors are not available. There would be some 

potential that new ROWs could be granted that would 

adversely modify habitat and result in the destruction 

Resource Relevance

Criteria Met

Importance 

Criteria Met

Special Management to Mitigate Threats

Holmgren milkvetch Yes Yes 1 - Retain in Federal ownership

2 - NSO to Oil and Gas leasing

3 - Close to forest/woodland product and commercial 

seed harvesting

4 - OHV area designation Limited to Designated 

Roads and Trails

5 - ROW exclusion

6 - Manage as VRM II.

7 - Close to mineral material disposal.

8 - Prohibit competitive special recreation permits.

Gierisch globemallow

Yes Yes

Resource Current Land Use Decision

Holmgren milkvetch

Gierisch globemallow

1 - VG-08, LD-06, LD-07, Map 2.1: Retain in Federal ownership

2 - RP-11, Table 2-5: Open with Special Stipulations (Category 2)

3 - FR-01, FR-08: T&E Plant Habitats are closed to forest/woodland product and seed 

harvesting

4 - VG-09, OV-01: OHV area designation limited to designated routes, OV-04: Ability to 

close routes in sensitive species habitat

5 - VG-09, LD-19: ROW Avoidance 

6 - VR-01: VRM III.

7 - VG-09, Table 2-6 Mineral Material Sales Designations, does not cover entire potential 

ACEC.

8 - No applicable decision

Table 4-44 State Line Potential ACEC: Comparison of Required Special Management Prescriptions with RMP Decisions
870 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 871

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

of populations of dwarf bearclaw poppy. Consultations 

under Section 7 of the ESA would be used to identify 

minimization and mitigation measures to avoid or lessen 

impacts on either species, but could not ensure that the 

granting of new ROWs would not measurably and negatively impact the potential recovery of dwarf 

bearclaw poppy.

Alternatives B and C would provide a major beneficial 

effect by managing all of the public lands in the potential ACEC as a ROW Exclusion area, where linear, site 

type, and material site ROWs would not be authorized. 

Adverse modification of critical habitats and impacts to 

populations of dwarf bearclaw poppy would not occur, as 

new ROWs would not be authorized.

Impacts from Management of Energy and Mineral 

Resources

Under all alternatives, the potential ACEC would be 

managed as Closed to fluid mineral leasing. Not allowing 

surface disturbance for fluid mineral leasing and development would provide major beneficial effects to this 

endangered plant species’ habitat.

Under Alternatives A and D, public lands of the potential 

ACEC would continue to be available for the sale and 

harvesting of sand and gravel or other mineral materials. 

While the sale of mineral materials would be a discretionary action for BLM and require a site-specific NEPA 

analysis and Section 7 consultations under the ESA, the 

potential would remain that surface disturbances related 

to this activity could occur that would damage habitat 

and impact populations of dwarf bearclaw poppy.

Alternatives B and C would close the area to mineral 

material sales and disposal, protecting 520 acres of dwarf 

bearclaw poppy populations and habitat for the life of 

the plan.

Impacts from Transportation and Off-Highway Vehicle 

Management

Alternatives A, B, and D would manage motorized OHV 

travel as Limited to Designated Roads and Trails, to be 

identified in the TMP currently being prepared by BLM. 

Under either alternative, motorized vehicle travel should 

not impact native plants, as all authorized use would be 

on designated routes.

Alternative C would provide a higher level of protection 

for plants and habitats than the three other alternatives, 

as the potential ACEC would be Closed to motorized vehicles. Motorized vehicle use would be limited to administrative uses only and require prior approval from BLM.

Impacts from Management of Native Vegetation and 

Forest Product Harvesting

Under all alternatives, the potential ACEC would be 

closed to native seed, plants, and plant material harvesting for commercial purposes and personal use. 

Collection of native seeds, cuttings, biological soil crust 

communities and species for scientific research, conservation, and for use in future restoration projects would 

be authorized where compatible with resource management objectives. The area would also be closed to forest/

woodland product harvesting and collection, for commercial purposes and personal use. These restrictions 

would help to protect habitats and populations of both 

endangered plant species, by not authorizing activities 

that result in surface disturbances and the removal of native vegetation.

Impacts from Management of Recreation

Under Alternatives A and D, the potential Webb Hill 

ACEC would not be designated and management direction for the 520 acres would continue to be derived from 

the current SGFO RMP. The area would remain open to 

most forms of recreational activities, including dispersed 

camping. Dispersed camping in habitats that support 

federally-listed native plants can cause soil compaction 

that degrades habitats, can damage or destroy plants, and 

increase the risk of wildfires.

Under Alternatives B and C, the potential Webb Hill 

ACEC would be designated and the area closed to dispersed camping. 

Alternative A could continue to authorize the issuance 

of SRPs for commercial, organized group, and competitive events in the potential ACEC, if site-specific NEPA 

analysis and Section 7 ESA consultations find that the 

proposed activities would not result in adverse modification of critical habitats or the damage or loss of the 

federally-listed native plants.

Alternatives B and C would not authorize the issuance of 

SRPs for commercial, organized group, and competitive 

events, lessening the potential that permitted recreation 

activities could negatively impact dwarf bearclaw poppy 

populations and habitats.

Impacts from Management of Visual Resources

Alternatives A and D would not designate the potential 

Webb Hill ACEC and the public lands would continue 

to be managed under VRM Class III. This VRM Class 

allows for changes in the landscape to be noticeable; 

projects and developments that create extensive surface 

disturbances could be authorized under this VRM Class. 

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

Management under this VRM Class would not further 

the protection of native plant populations and habitats. 

Alternatives B and C would manage the potential ACEC 

under VRM Class II, providing a higher level of protection for the scenic qualities of the area. Management 

under this VRM class would restrict the types of projects or developments that could be authorized, enhancing the protection of dwarf bearclaw poppy populations 

and habitat.

Summary of Impacts from Alternatives

Table 4-45 compares the special management prescriptions developed by BLM’s Planning Team to address 

potential threats to the relevant and important values 

of the potential Webb Hill ACEC with current management under the SGFO RMP. Under Alternatives A and 

D, this potential ACEC would not be designated and 

management of the public lands would continue under 

the management decisions contained in the 1999 SGFO 

RMP. As this comparison shows, Alternatives A and D 

may not adequately protect habitats and populations of 

dwarf bearclaw poppy from impacts related to land uses 

and activities on public lands that could continue to be 

authorized under the SGFO RMP.

Under Alternatives B and C, the potential 520-acre Webb 

Hill ACEC would be administratively designated and 

would provide the additional special management attention needed to protect populations and habitats for this 

endemic endangered native plant.

Resource Relevance

Criteria Met

Importance 

Criteria Met

Special Management to Mitigate Threats

Dwarf Bearclaw Poppy

Yes Yes

1 - Retain in Federal ownership

2 - Closed to Oil and Gas leasing

3 - Closed to forest/woodland product and seed 

harvesting

4 - OHV area designation limited to Designated Roads 

and Trails

5 - ROW exclusion.

6 - Manage as VRM II.

7 - Close to mineral material disposal.

8 - Limit Recreation use to designated non-motorized 

trails.

9 - Prohibit commercial, organized group and competitive special recreation permits.

Resource Current Land Use Decision

Dwarf Bearclaw Poppy 1 - VG-08, LD-06, LD-07, Map 2.1: Retain in Federal ownership, a portion (20%) of the 

potential ACEC is identified for disposal in the 1999 SGFO RMP.

2 - RP-11, Table 2-5: Closed to Oil and Gas Leasing

3 - FR-01, FR-08: T&E Plant Habitats are closed to forest/woodland product and seed 

harvesting

4 - VG-09, OV-01: OHV area designation limited to designated routes, OV-04: Ability to 

close routes in sensitive species habitat

5 - VG-09, LD-19: ROW Avoidance 

6 - VR-01: VRM III inadequate for level of desired protection

7 - VG-09, Table 2-6 Mineral Material Sales Designations, does not cover entire potential 

ACEC

8 - No applicable decision

9 - No applicable decision.

Table 4-45 Web Hill Potential ACEC: Comparison of Required Special Management Prescriptions with RMP Decisions
872 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 873

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

4.48.2.4 Grafton Potential ACEC (47 acres); Moody 

Wash Potential ACEC (24 acres); Mosquito Cove 

Potential ACEC (88 acres); North Creek Potential ACEC 

(54 acres); Santa Clara River Baker Potential ACEC 

(32 acres); Santa Clara River Veyo Potential ACEC (16 

acres); and Virgin River Potential ACEC (245 acres)

Relevance and Importance Values: BLM Sensitive 

Species: Desert Sucker, Flannelmouth Sucker, Virgin 

Spinedace

The seven potential ACECs listed above are evaluated 

together in this impacts analysis as they each support 

aquatic habitats for three native fish of the Virgin River 

system that are BLM Sensitive Species. Similar management actions for public lands are proposed for the seven 

potential ACECs, to address potential threats to these 

three species.

Management decisions in the SGFO RMP for the following resources would have negligible or no impact on the 

relevance and importance values of the seven potential 

ACECs listed above and are, therefore, not discussed in 

further detail: Air Quality, Soil and Water Resources, 

Riparian Resources, Vegetation Resources, Fish and 

Wildlife Habitat Management, Livestock Grazing 

Management, Visual Resource Management, Wilderness 

Management, Cultural and Paleontological Resources, 

Hazardous Waste Management, Fire Management, and 

Wild and Scenic Rivers.

Impacts from Management of Lands and Realty

Under all alternatives, the public lands of the seven 

potential ACECs would be retained in federal ownership. 

This would provide a major beneficial effect to populations of desert sucker, flannelmouth sucker, and Virgin 

spinedace, as BLM management would continue to focus 

on the protection of aquatic habitats, helping to ensure 

these native fish of the Virgin River system do not require 

listing under the ESA. Should public lands in the potential ACECs leave federal management to private or state 

ownership, developments and land uses could impact 

water quality, remove native vegetation, and otherwise 

damage the aquatic habitats that support these species.

Management as a ROW Avoidance area under all alternatives would reduce the likelihood that new linear, sitetype, and materials ROWs would authorize the development of utilities, highways, or other projects that could 

impact aquatic habitats that support native 

fish populations.

However, the SGFO RMP includes a management decision that would allow the granting of new ROWs in 

Avoidance areas when feasible alternative routes or designated corridors are not available. There would be some 

potential that new ROWs could be granted that would 

impact aquatic habitats for native fish. Site-specific NEPA 

analyses and the application of BMPs would be used to 

identify minimization and mitigation measures to avoid 

or lessen impacts on these species.

Impacts from Management of Energy and Mineral 

Resources

Under all alternatives, the public lands of the seven potential ACECs would be managed as Open to fluid mineral leasing, but under stipulations of NSO. No Surface 

Occupancy would help to ensure that oil and gas developments on lands under fluid mineral leases do not increase sedimentation into surface waters, degrade water 

quality, damage riparian vegetation, or alter stream bank 

morphology. Under all alternatives, aquatic habitats 

that support populations of desert sucker, flannelmouth 

sucker, and Virgin spinedace would not be expected to 

be impacted by activities related to fluid mineral leasing.

Under all alternatives, riparian areas would be closed to 

mineral material sales, protecting aquatic habitats and 

native fish populations from the impacts of sand and 

gravel harvesting.

Impacts from Transportation and Off-Highway Vehicle 

Management

Under all alternatives, motorized OHV travel in the 

seven potential ACECs would be managed as Limited 

to Designated Roads and Trails. Moody Wash, the Santa 

Clara River, the Virgin River, and North Creek, and 

their associated riparian areas, would not be impacted 

by cross-country OHV travel that could increase 

sedimentation, degrade water quality, damage riparian 

vegetation, and alter stream bank morphology, protecting aquatic habitats for native fish.

Impacts from Management of Forest Product 

Harvesting

Under all alternatives, the seven potential ACECs would 

be closed to forest/woodland product harvesting and 

collection, for commercial purposes and personal use. 

These restrictions would help to protect aquatic habitats 

and riparian areas by not authorizing activities that could 

increase sedimentation, degrade water quality, damage or 

remove riparian vegetation, and alter stream bank morphology, protecting aquatic habitats for native fish.

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

Impacts from Management of Recreation

Under Alternatives A, B and D, the seven potential 

ACECs would not be designated and management 

direction would continue to be derived from the current 

SGFO RMP. The areas could remain open to most forms 

of recreational activities, including dispersed camping, if 

this activity is not impacting riparian values. Dispersed 

camping in riparian areas can cause soil compaction, increase sedimentation into surface water sources, damage 

or destroy riparian vegetation, and increase the risk of 

wildfires. Each of these impacts could degrade the quality of aquatic habitats that support populations of desert 

sucker, flannelmouth sucker, and Virgin spinedace, potentially decreasing the viability of the fish populations. 

However, in the event that dispersed camping is impacting riparian values, management direction under the 

current SGFO RMP provides for the implementation of 

restrictions and closures of areas to dispersed camping. 

Such restrictions or closures would eliminate the impacts 

on aquatic habitats and riparian values related to this 

recreational activity.

Under Alternative C, the seven potential ACECs 

would be designated and the areas closed to dispersed 

camping. These alternatives would protect aquatic 

habitats and associated riparian areas that support native 

fish populations.

Alternatives A, B, and D could continue to authorize the 

issuance of SRPs for commercial, organized group, and 

competitive events in the potential seven ACECs, if sitespecific NEPA analyses and Section 7 ESA consultations 

find that the proposed activities would not result in impacts on riparian areas, surface water sources, or habitats 

for BLM Sensitive Species.

Under Alternative C, the seven potential ACECs would 

be designated and BLM would not issue SRPs for commercial, organized group, and competitive events, lessening the potential that authorized recreation activities 

would negatively impact aquatic habitats and riparian 

areas, protecting native fish populations.

Summary of Impacts from Alternatives

Table 4-46 compares the special management prescriptions developed by BLM’s ID Team to address potential 

threats to the relevant and important values of the seven 

potential ACECs with current management under the 

SGFO RMP. As this comparison shows, all alternatives, 

including Alternative A (No Action), would provide 

equivalent protections for aquatic habitats and associated 

riparian areas that support desert sucker, flannelmouth 

sucker, and Virgin spinedace. Existing management decisions from the RMP, in concert with applicable federal 

laws, regulations, and agency policies, would address 

Resource Relevance

Criteria Met

Importance 

Criteria Met

Special Management to Mitigate Threats

Desert Sucker Yes Yes 1 - Retain in Federal ownership

2 - NSO to Oil and Gas leasing

3 - Close to forest/woodland product harvest

4 - OHV area designation Limited to Designated 

Roads and Trails

5 - ROW Avoidance 

6 – Prohibit surface-disturbing activities

7 – Prohibit commercial, organized group and competitive special recreation permits

Flannelmouth Sucker Yes Yes

Virgin Spinedace Yes Yes

Riparian

Yes Yes

Bald Eagle Yes No Not applicable

Resource Current Land Use Decision

Desert Sucker

Flannelmouth Sucker

Virgin Spinedace

Riparian

1 - SW-02, FW-13, LD-06, LD-07, Map 2.1: Retain in Federal ownership

2 - RP-11, Table 2-5: No Surface Occupancy (NSO) Stipulations for Oil and Gas leasing

3 - FR-01, RP-11: Riparian habitats are closed to forest/woodland product harvest

4 - FW-26, RP-10, OV-05: OHV area designation limited to designated routes

5 - FW-26, RP-11, LD-19: ROW Avoidance 

6 - FW-26, SW-03: Water quality and floodplain protection

7 - No applicable decision

Table 4-46 Grafton Potential ACEC: Comparison of Required Special Management Prescriptions with RMP Decisions
874 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 875

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

threats to the relevant and important values of potential 

ACECs, preventing irreparable damage to those values.

Administrative designation of the seven potential 

ACECs would not provide a measurably higher level 

of protection to aquatic habitats, riparian areas, and 

populations of BLM Sensitive native fish than what is 

currently provided under management decisions from 

the SGFO RMP.

4.48.2.5 Dalton Wash Potential ACEC (14 acres); 

Harrisburg Bench Potential ACEC (111 acres); Shinob 

Kibe Potential ACEC (70 acres)

Relevance and Importance Values: Endangered Native 

Plants: Dwarf Bearclaw Poppy, Holmgren Milkvetch, 

Shivwits Milkvetch

The three potential ACECs listed above are evaluated 

together in this impacts analysis as they each support 

habitats and populations of the endangered native plant 

species shown above and have similar management identified to address potential threats to these species.

Management decisions in the SGFO RMP for the following resources would have negligible or no impact on 

the relevance and importance value of the three potential ACECs that provide habitats for federally-listed 

endangered native plant species and are, therefore, not 

discussed in further detail: Air Quality, Soil and Water 

Resources, Riparian Resources, Vegetation Resources, 

Fish and Wildlife Habitat Management, Livestock 

Grazing Management, Visual Resource Management, 

Wilderness Management, Cultural and Paleontological 

Resources, Hazardous Waste Management, Fire 

Management, and Wild and Scenic Rivers.

Impacts from Management of Lands and Realty

Under Alternatives A, B, and D, the three potential 

ACECs would not be designated. Under Alternatives A 

and D, public lands that support federally-listed native 

plants would generally be retained in federal ownership. 

The full legal protections of the ESA would continue to 

apply on federally-managed lands, conferring protections 

to habitats and populations of dwarf bearclaw poppy, 

Holmgren milkvetch and Shivwits milkvetch.

However, under the current SGFO RMP, in the event that 

exchange or transfer of public lands from federal ownership would result in the acquisition of better quality 

habitat for a special status species native plant or provide 

for suitable management by another agency or organization, some or all of the public lands in any of the three 

potential ACECs could leave federal ownership. The legal 

protections of the ESA would not apply to listed native 

plant populations or critical habitats if the transferred 

lands were acquired by private or state entities. Should 

the lands be exchanged or transferred into private or state 

ownership, developments could occur that would damage or destroy habitats and populations of dwarf bearclaw 

poppy, Holmgren milkvetch, or Shivwits milkvetch on 

that particular land tract. Under both alternatives, the exchange or transfer from federal ownership could result in 

major adverse impacts on the endangered native plants 

on the exchange tract.

Under Alternative C, the potential ACECs would be designated and public lands within each ACEC would be retained in federal ownership. The full legal protections of 

the ESA would continue to apply on federally-managed 

lands, conferring protections to habitats and populations of dwarf bearclaw poppy, Holmgren milkvetch and 

Shivwits milkvetch.

Under Alternatives A, B, and D, the three potential 

ACECs would not be designated. However, current management under Alternative A and proposed management 

under Alternatives B and D would manage these areas as 

Avoidance areas for all types of ROWs. New ROWs could 

be authorized in ROW Avoidance areas, if site-specific 

NEPA analyses and Section 7 ESA consultations find that 

the proposed activities would not result in impacts on the 

endangered native plants and their habitats. Of the three 

potential ACECs, only the Harrisburg Bench is located 

where new ROWs would likely be sought, given its proximity to Interstate I-15 and a designated utility corridor 

established through the SGFO RMP. 

Alternative C would designate the potential ACEC and 

manage the area as a ROW Exclusion area. Management 

of the areas as an Exclusion area for ROWs would confer a slightly higher level of protection for these three 

endangered plants, as new ROWs would not be granted, 

eliminating any potential that developments would 

impact the endangered plant populations or adversely 

modify their habitats.

Impacts from Management of Energy and Mineral 

Resources

Under Alternatives A, B, and D, the three potential 

ACECs would not be designated. However, current management under Alternative A and proposed management 

under all other alternatives would manage these areas as 

Closed to fluid mineral leasing. Not allowing surface disturbance for fluid mineral leasing and development and 

mineral materials sales and harvesting. These closures 

and restrictions would provide major beneficial effects 

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

for endangered plants and their habitats, protecting them 

from surface disturbances and habitat loss associated 

with these land uses.

Impacts from Transportation and Off-Highway Vehicle 

Management

Under Alternatives A, B, and D, the three potential 

ACECs would not be designated. Current management 

under Alternative A and proposed management under 

all other alternatives limit motorized vehicle travel in the 

three potential ACECs to designated roads and trails. 

This designation would prevent soil disturbances and the 

damage or destruction of plants that would occur under 

an Open OHV designation, where vehicles could travel 

cross-country, by limiting vehicle travel to specific routes 

that would be designated through the TMP.

Impacts from Management of Plant Materials and 

Forest Product Harvesting

Under Alternatives A, B, and D, the three potential 

ACECs would not be designated. Current management 

under Alternative A and proposed management under all 

other alternatives manage these areas as closed to native 

seed, plants, and plant material harvesting for commercial purposes and personal use. The areas would also be 

closed to forest products collection and harvesting for 

commercial purposes and personal use. These restrictions would protect federally-listed endangered plants 

from surface disturbances, soil compaction, and the 

crushing or uprooting of individual plants that can result 

from commercial seed or plant materials collection or 

forest product harvesting.

Impacts from Management of Recreation

Under Alternatives A, B, and D, the three potential 

ACECs would not be designated. Current management 

under Alternative A and proposed management under 

all alternatives except C would allow dispersed camping 

in the Dalton Wash and Shinob Kibe potential ACECs. 

While this recreational activity has some potential to 

negatively impact endangered plants and their habitats, 

it does not currently occur in either of the potential 

ACECs, as there is no road access, neither have trails or 

other recreation facilities, and there is no public demand 

for dispersed camping in these locations.

Alternative A and all other alternatives would continue 

to manage the potential Harrisburg Bench ACEC as 

closed to dispersed camping. This recreational activity 

does not currently occur in the potential ACEC, and 

there is no public demand, as developed campgrounds 

(e.g., Harrisburg KOA, Red Cliffs Recreation Area, and 

Quail Reservoir State Park) are within a one mile radius 

of the potential ACEC.

Under Alternatives A, B, and D, the three potential 

ACECs would not be designated. Current management 

under Alternative A and proposed management under Alternatives B and D would allow the issuance of 

SRPs for commercial, organized groups, and competitive events in these areas, but only if site-specific NEPA 

analyses and Section 7 ESA consultations find that the 

proposed activities would not result in impacts on the 

endangered native plants and their habitats. 

Alternative C would designate the three potential ACECs 

and prohibit the issuance of SRPs for commercial, organized groups, and competitive events, providing negligible benefits to the relevance and importance values 

related to the management of recreational uses in these 

areas, as this is a discretionary action for BLM. It is unlikely that an SRP would be issued where there is potential for adverse impacts on endangered native plants.

Summary of Impacts from Alternatives

Table 4-47 compares the special management prescriptions developed by BLM’s Planning Team to address 

potential threats to the relevant and important values of 

the potential Dalton Wash ACEC, the potential Shinob 

Kibe ACEC, and the potential Harrisburg Bench ACEC 

with current management under the SGFO RMP. Under 

Alternatives A, B, and D, these potential ACECs would 

not be designated and management of the public lands 

would continue under the management decisions contained in the 1999 SGFO RMP. Under Alternative C, the 

three potential ACECs would be designated and additional management prescriptions identified to address 

threats to the three endangered native plant species that 

occur on public lands. 

As this comparison shows, all alternatives, including 

Alternative A (No Action), would provide equivalent 

protections from potential threats to three endangered 

native plants and their habitats from those land uses 

of the public lands that could negatively impact these 

species. Existing management decisions from the SGFO 

RMP, in concert with applicable federal laws, regulations, 

and agency policies, would address threats to the relevant 

and important values of potential ACECs, preventing irreparable damage to those values. Administrative designation of the three potential ACECs would not provide 

a measurably higher level of protection to the relevance 

and importance values than what is currently afforded by 

management under the current SGFO RMP.
876 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 877

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

4.48.2.6 Scarecrow Peak Potential ACEC (9,664 Acres)

Relevance and Importance Values: Threatened Species: 

Mojave Desert Tortoise

This potential ACEC includes 9,664 acres of designated 

critical habitat and populations of the federally-listed 

threatened Mojave desert tortoise, within the Utah 

portion of the Beaver Dam Slope, in the Northeastern 

Mojave Recovery Unit, identified by the USFWS in the 

Recovery Plan for the Mojave Desert Tortoise (1994, revised 2011). These acres were not included in the Beaver 

Dam Slope ACEC, designated by the 1999 SGFO RMP, 

as tortoise population densities and the quality of tortoise habitat were evaluated as being low. Based on these 

factors, management decisions in the SGFO RMP did 

not identify the types of land use restrictions intended to 

protect designated critical habitat or tortoise populations 

that were put into effect in the Beaver Dam Slope ACEC. 

The 1998 Biological Opinion rendered by the USFWS on 

the Proposed SGFO RMP supported BLM’s management 

decisions not to emphasize tortoise protection in this 

area of designated critical habitat, by allowing multiple 

uses of the public lands. Among the multiple uses that 

were allowed to continue in this area was livestock grazing with a season of use that overlapped the tortoise 

spring active season by two months.

Management decisions in the SGFO RMP for the following resources would have negligible or no impact on the relevance and importance value of the 

Scarecrow Peak Potential ACEC and are, therefore, not 

discussed in further detail: Air Quality, Soil and Water 

Resources, Riparian Resources, Vegetation Resources, 

Fish and Wildlife Habitat Management, Cultural 

and Paleontological Resources, Hazardous Waste 

Management, Fire Management, and Wild and 

Scenic Rivers.

Impacts from Management of Lands and Realty

Under Alternatives A, B, and D, the potential ACEC 

would not be designated. Current management under 

Alternative A does not explicitly state that the public 

lands within the potential ACEC would be retained 

in federal ownership, nor does it identify any lands in 

the area for potential disposal through sale, exchange, 

or transfer. The stated objectives for Lands and Realty 

management in the SGFO RMP (LD-02) provide a listing 

of criteria that would allow for changes in land ownership; one of those criteria is that the change results in a 

net gain in important and manageable resources, including listed species habitat. Under Alternatives A, B, and 

D, public lands in the potential Scarecrow Peak ACEC 

could leave federal control, if specific criteria identified in 

the SGFO RMP are met. If changes in ownership would 

place lands within the potential ACEC in private or state 

ownership, developments could occur on those lands. As 

the legal protections of the ESA apply to listed wildlife 

species on non-federal lands, measures to avoid, minimize, and mitigate impacts on designated critical habitat 

and tortoise populations would provide protections, in 

the event of a change of ownership.

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

Under Alternative C, the potential ACEC would be 

designated and public lands would be retained in federal 

ownership, providing protection for designated habitat and populations of desert tortoise through land use 

restrictions and special management attention directed 

toward assisting the recovery and delisting of this threatened species in the Northeastern Recovery Unit.

Under Alternatives A, B, and D, the potential ACEC 

would not be designated. Current management under 

Alternative A and the three other alternatives would 

manage the 9,664-acre area as a ROW Avoidance area 

for all types of ROWs, minimizing the potential that 

new ROWs would result in the development of utilities, 

highways, or other projects. New ROWs could be authorized in ROW Avoidance areas, but only if site-specific 

NEPA analyses and Section 7 ESA consultations find 

that the proposed activities would not result in impacts 

on threatened Mojave desert tortoise and designated 

critical habitat.

Impacts from Management of Energy and Mineral 

Resources

Under Alternatives A, B, and D, the potential ACEC would 

not be designated. Current management under Alternative 

A and proposed management under Alternatives B and 

D would manage the public lands as Open to fluid mineral leasing, with Special Stipulations (Category 2). These 

stipulations would seasonally restrict development activities on fluid mineral leases to the period between Oct. 1 

and Mar. 15, subject to on-site biological evaluations and 

consultations under Section 7 of the ESA with the USFWS. 

During this time period, desert tortoise are generally 

inactive, in burrows and dens for the winter hibernation 

period, minimizing the potential that developments would 

result in the “take” of individual tortoises. On-site biological evaluations could identify occupied burrows and dens 

and develop measures to avoid crushing or collapsing 

these shelters during project developments. These stipulations and Biological Opinions issued through Section 7 

consultations would help to avoid, minimize, and mitigate 

the adverse modification of designated critical habitat and 

tortoise injuries and mortalities. However, under these 

alternatives, developments on fluid mineral leases would 

result in the permanent loss or degradation of designated 

critical habitat.

Under Alternative C, the potential ACEC would be 

designated and managed as Open to fluid mineral leasing 

with NSO stipulations. Management under NSO would 

strive to minimize the surface disturbances and impacts 

to designated critical habitat and tortoise populations that 

would result from oil and gas developments on leased 

areas, through mitigation, compensation, and restoration 

of habitat to predisturbance conditions when operations 

cease. Management under NSO would provide a higher 

level of protection for desert tortoise, but would not eliminate all impacts.

 Under all alternatives, designated critical habitat for 

special status species would be closed to mineral materials 

sales and harvesting, providing a moderate beneficial effect 

by prohibiting the removal of sand and gravel from public 

lands and the associated surface disturbances that would 

result in the permanent loss of critical habitat for desert 

tortoise and the potential “take” of individual tortoises as a 

result of this activity.

Impacts from Transportation and Off-Highway Vehicle 

Management

Under Alternatives A, B, and D, the potential ACEC 

would not be designated. Current management under Alternative A and proposed management under 

Alternatives B, C, and D would continue motorized vehicle travel under the OHV area designation of Limited 

to Designated Roads and Trails, with route designations 

to follow through the TMP being prepared by BLM. This 

designation would prevent habitat impacts by limiting 

vehicle travel to specific routes that would be designated 

through the TMP.

Impacts from Management of Forest Product 

Harvesting

Under Alternatives A, B, and D, the three potential 

ACECs would not be designated. Under Alternative C, 

the areas would be closed to forest products collection 

and harvesting, for commercial purposes and personal 

use. These restrictions would protect federally-listed endangered plants from surface disturbances, soil compaction, and the crushing or uprooting of individual plants 

that can result from commercial seed or plant materials 

collection or forest product harvesting.

Impacts from Management of Recreation 

Under Alternatives A, B, and D, the potential ACEC 

would not be designated. Current management under Alternative A and proposed management under 

Alternatives B and D would continue management that 

could authorize the issuance of SRPs for commercial, organized groups, and competitive events, if a site-specific 

NEPA analysis and Section 7 consultations under the 

ESA find that proposed activities or events would not 

result in the adverse modification of critical habitat or 

the “take” of Mojave desert tortoise.

Resource Relevance 

Criteria Met

Importance 

Criteria Met

Special Management to Mitigate Threats

Shivwits milkvetch

Yes Yes

1 – Retain in Federal ownership

2 - NSO to Oil and Gas leasing

3 - Close to forest/woodland product and commercial 

seed harvesting

4 - OHV area designation is closed

5 - ROW Avoidance 

6 - Manage as VRM II

Resource Current Land Use Designation

Shivwits milkvetch 1 - VG-08, LD-06, Map 2.1: Retain in Federal ownership

2 - RP-11, Table 2-5, Appendix 2: Subject to No Surface Occupancy (NSO) Stipulations for 

Oil and Gas leasing

3 - FR-01, FR-08: T&E Plant Habitats are closed to forest/woodland product and seed 

harvesting

4 - VG-09, OV-01: OHV area designation is Limited to Designated Roads and Trails

5 - VG-09, LD-19: ROW Avoidance 

6 - VRM Class II and within the Zion Scenic Corridor

Table 4-47 Dalton Wash Potential ACEC: Comparison of Required Special Management Prescriptions with RMP Decisions
878 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 879

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

Under Alternative C the potential ACEC would be designated and management of recreation would prohibit the 

issuance of SRPs for competitive, organized groups, and 

commercial events. This management decision would 

provide negligible benefits to the relevance and importance values related to the management of recreational 

uses in these areas, as the issuance of SRPs is a discretionary action for BLM and no permits would be granted that 

have the potential to adversely modify critical habitat or 

cause the “take” of desert tortoise.

Summary of Impacts from Alternatives

Table 4-48 compares the special management 

prescriptions developed by BLM’s Planning Team to 

address potential threats to the relevant and important 

value of the potential Scarecrow Peak ACEC with current 

management under the SGFO RMP. Under Alternatives 

A, B and D, this potential ACEC would not be designated 

and management of the public lands would continue 

under the management decisions contained in the 1999 

SGFO RMP.

As this comparison shows, all alternatives, including 

Alternative A (No Action), would provide equivalent 

protections from potential threats to Mojave desert 

tortoise and 9,664 acres of designated critical habitat 

from those land uses of the public lands that could 

negatively impact this threatened species. Existing 

management decisions from the SGFO RMP, in concert 

with applicable federal laws, particularly the ESA, 

regulations, and agency policies, would address threats 

to the desert tortoise, preventing irreparable damage to 

this species. Administrative designation of the potential 

ACECs would not provide a measurably higher level of 

protection to the relevance and importance values than 

what is currently afforded by management under the 

current SGFO RMP.

Under Alternative C, the potential 9,664-acre Scarecrow 

Peak ACEC would be administratively designated and 

would provide additional management prescriptions to 

protect populations and habitats for the Mojave desert 

tortoise.

4.48.3 Summary of Impacts from Alternatives

The BLM Planning Team evaluated all of the ACEC 

nominations for priority biological species, determined 

which areas of nominated public lands supported species 

that met both the relevance and importance criteria for 

ACEC designation, and identified threats related to public land management that could cause irreparable damage to the relevant and important values. The Team then 

compared the current management decisions from the 

SGFO RMP (which remains valid existing management 

AREAS OF CRITICAL ENVIRONMENTAL CONCERN

for the public lands in Washington County until a full 

plan revision is completed) to the special management 

prescriptions that would be needed to address the identified threats related to public land management. This 

process resulted in the range of alternatives developed for 

the RMP Amendment.

Alternatives A and D would not designate any new 

ACECs and would continue to manage eight ACECs designated in the SGFO RMP (100,084 acres). Alternative B 

would designate three new ACECs totaling 3,881 acres. 

Alternative C would designate 14 new ACECs totaling 

13,931 acres.

Under Alternatives A and D, no new potential ACECs 

would be designated, as the management decisions in the 

1999 SGFO RMP would provide adequate protection and 

prevent irreparable damage or loss of the relevant and important values for which these ACECs were nominated.

Under Alternative B, three potential ACECs would be 

administratively designated, as the evaluation of current 

management under the SGFO RMP indicated that additional special management is needed to protect populations and habitats for these endangered native plant 

species in the potential South Hills, State Line, and Webb 

Hill ACECs.

Alternative C would designate 14 new ACECs and retain 

all existing ACECs, providing a range of alternatives for 

comparison in the Draft EIS. Special management prescriptions were identified under this alternative to ensure 

that irreparable damage to priority biological species 

related to public land management would not occur.

4.48.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts on the 

relevance and importance values for the potential ACECs 

evaluated in the RMP Amendment is the 1,573,880 acre 

land base of Washington County, including all federal, 

tribal, state, and private lands. These values include: 

endemic native plant species, native fish of the Virgin 

River system, Mojave Desert wildlife species, and riparian resources.

Past human-caused actions within the CIAA have affected native plant and animal species and habitats and 

resulted in the need to include many of these species 

under the protections of the ESA. These included: overgrazing of rangelands during the late 19th and early 20th 

centuries; land modifications in support of agricultural 

enterprises; the settlement and expansion of local cities 

and towns; the construction of highways, roads, and 

utilities; surface water impoundments and diversions 

for agricultural and municipal purposes; range improvements and vegetation treatments; and motorized OHV 

and non-motorized recreational uses. In general, past human activities and land uses have cumulatively resulted 

in the loss, degradation, and fragmentation of habitats 

for native species and declining numbers of endemic 

native plants, native fish of the Virgin River system, and 

many Mojave Desert wildlife species. Habitats for native 

plants that required listing under the ESA have been 

damaged or destroyed on non-federal lands, as the ESA 

only requires protection of these species on federallymanaged lands.

Prolonged droughts, the introduction and spread of 

noxious weeds and exotic invasive species, wildfires, 

and post-fire flooding are natural factors that have also 

cumulatively impacted the quality of habitats for native 

plant and wildlife species. Many of these natural factors created conditions that caused or favored habitat 

changes. Drought conditions have impacted the health 

of native vegetation communities, making them more 

prone to insect infestations, disease, and “die-offs”. Since 

2003, more than 250,000 acres in a variety of vegetation 

types have burned in Washington County, with some 

acres being burned more than once. The “burn-reburn” 

fire cycle in areas of the CIAA has converted shrubland 

communities into invasive brome grasslands that provide 

poor quality habitat for native plant and wildlife species. 

Wildfires have removed vegetative cover and damaged 

soil crusts, leaving soils more susceptible to wind and 

water erosion and weed invasion. Riparian communities 

along Moody Wash, Mogatsu Creek, Beaver Dam Wash, 

the Santa Clara River and the Virgin River in Washington 

County have been drastically altered by post-fire flooding over the past decade, impacting aquatic habitats for 

at-risk native fish of the Virgin River system. 

Future actions are likely to include increased efforts to 

control invasive annual brome grasses and wildfires, 

through landscape-wide fire breaks and fuel treatments 

in the CIAA. As ongoing research studies identify more 

effective and environmentally sustainable broad-scale 

treatment methods, it is likely that larger areas will 

be treated and efforts will be made to restore native 

vegetation communities, improving native plant and 

wildlife species habitats. Land uses that have the potential 

to impact habitat restoration projects, would not be 

authorized in those areas, until resource objectives are 

met. These restrictions could benefit all native plant, 

fish, and wildlife species, by protecting habitats and 

Resource Relevance

Criteria Met

Importance 

Criteria Met

Special Management to Mitigate Threats

Desert Tortoise Yes Yes 1 - Retain in Federal ownership

2 - NSO to Oil and Gas leasing

3 - Close to forest/woodland product and seed 

harvesting

4 - OHV area designation Limited to Designated 

Roads and Trails

5 - ROW avoidance

6 - Close to mineral material disposal.

7 - Prohibit commercial, organized group and competitive special recreation permits.

Birds of Conservation Concern Yes No

Desert Sucker Yes No

Virgin Spinedace Yes No

Riparian

Yes No

Resource Current Land Use Decision

Desert Tortoise 1 - LD-06, LD-07, Map 2.1: Retain in Federal ownership

2 - RP-11, Table 2-5: Open with Special Stipulations (Category 2)

3 - FW-22: Desert Tortoise Habitats are closed to forest/woodland product and seed 

harvesting

4 - OV-01: OHV area designation Limited to Designated Roads and Trails.

5 - FW-22, LD-19: ROW Avoidance 

6 - FW-22: closed to mineral material disposal

7 - No applicable decision

Table 4-48 Scarecrow Peak Potential ACEC: Comparison of Required Special Management Prescriptions with RMP Decisions
880 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 881

minimizing impacts on populations related to land uses 

and human activities.

Climate change within the CIAA could cause an increase 

or decrease in seasonal temperatures and precipitation, 

which would affect soil conditions, vegetation distribution, and surface water resources. Such changes would 

place some plant and wildlife species at greater risk 

of population declines, particularly those species that 

cannot adapt to changed conditions or migrate to areas 

where habitat conditions are favorable.

Cumulative impacts on federally-listed native plants 

would be expected to continue in the long term, on 

private, municipal, and some State-owned lands, as the 

ESA does not provide legal protections for native plants 

on non-federal lands. These impacts would include permanent loss or degradation of habitats and populations 

of Shivwits and Holmgren milkvetch, dwarf bearclaw 

poppy, and Gierisch globemallow to developments, OHV 

activities, and other recreational uses.

The designation and management of ACECs on public 

lands to achieve biological conservation of endemic native plants that are listed or could be listed under the ESA 

is expected to cumulatively and significantly benefit these 

species, as populations and habitats would receive the full 

legal protections of the ESA. Protective management on 

public lands may be the only way to ensure the survival 

of these endemic native plants, as populations and habitats on non-federal lands are lost to developments and 

other land uses.

Cumulative impacts on federally-listed native fish and 

wildlife species and designated critical habitats on 

federal, state, municipal, and private lands would likely 

continue to be avoided, minimized, and mitigated, as 

the legal protections of the ESA apply on both Federal 

and non-federal lands. Washington County’s 20-year 

Incidental Take Permit, issued under section 10 of the 

ESA in 1996, would continue to authorize the incidental take of desert tortoise of up to 1,169 desert tortoises 

within 12,264 acres of critical habitat and 31,282 acres 

of potential habitat on non-federal lands in Washington 

County. This Incidental Take Permit is expected to be 

re-issued by the USFWS at the end of the 20 year period, if minimization and monitoring measures committed through Washington County’s approved Habitat 

Conservation Plan continue to comprise appropriate 

mitigation measures. These included the efforts to 

protect approximately 62,000 mixed jurisdictional acres 

and tortoise populations within the Upper Virgin River 

Recovery Unit, through fencing, law enforcement, and 

public education.

4.49 PRIORITY BIOLOGICAL CONSERVATION 

AREAS

At Section 1979, OPLMA mandated BLM to identify 

areas of public land where biological conservation is a 

priority and undertake activities to conserve and restore 

plant and animal species and natural communities. This 

legislative direction would be accomplished through the 

proposed designation of new ACECs to direct special management attention to the protection of special 

status species’ habitats and populations. It would also be 

accomplished through proposed changes in the management of public lands in northwestern Washington 

County to protect crucial habitat and migration corridors 

for mule deer, other big game and wildlife species, and 

diverse predators, species that may not meet both the 

relevance and importance criteria for ACEC designation. BLM has labeled this area the Bull Valley Mountains 

Multi-Species Management Area (Management Area) in 

this Amendment.

4.49.1 Methods of Analysis

Impacts are quantified where possible. In the absence 

of quantifiable data, professional judgment was used. 

Impacts are sometimes described using ranges of potential impacts or in qualitative terms, if appropriate. 

Adverse impacts to wildlife habitats and migration corridors in the Management Area could result from management actions that diminish any of the fundamental 

components listed in the indicators section below. 

Beneficial effects could result from management actions 

that maintain or enhance any of the fundamental components listed in the indicators section below. 

4.49.1.1 Indicators

Indicators of adverse impacts on biological conservation 

in the Management Area include the following:

▶ Habitat degradation or removal through changes to 

the vegetation communities, water resources, and 

other habitat components;

▶ Habitat avoidance due to human presence or habitat 

alteration;

▶ Interferences with a species movement patterns that 

decreases the ability of a species to breed or overwinter successfully to a degree that would lead to 

substantial population declines;

▶ Impacts on species survival or reproduction caused 

by disruptive activities;

PRIORITY BIOLOGICAL CONSERVATION AREAS

▶ Injuries or mortalities in wildlife populations directly related to public land management.

Indicators of beneficial effects on biological conservation 

in the Management Area include the following:

▶ Habitat improvements through protection of vegetation communities, water resources, and other 

habitat components;

▶ Increases in wildlife population numbers and species diversity, including natural predators;

▶ Reductions in injuries or mortalities in wildlife populations directly related to public land management.

4.49.1.2 Assumptions

The analysis includes the following assumptions:

▶ Management actions proposed would further biological conservation goals;

▶ Impacts on terrestrial wildlife from displacement 

depend on the location, extent, timing, or intensity 

of the disruptive activity. Impacts would be greater 

for wildlife species that have limited habitat or a low 

tolerance for disturbance/disruption;

▶ Habitat would be managed in coordination with 

UDWR, to further herd management objectives and 

species-specific management plans.

4.49.2 Direct and Indirect Impacts

Management decisions in the SGFO RMP for the following resources would have negligible or no impact on 

biological conservation in the Management Area and are, 

therefore, not discussed in further detail: Air Quality, Soil 

and Water Resources, Riparian Resources, Vegetation 

Resources, Fish and Wildlife Habitat Management, 

Livestock Grazing Management, Forestry, Recreation, 

Visual Resource Management, Wilderness Management, 

Cultural and Paleontological Resources, Hazardous 

Waste Management, Fire Management, Wild and Scenic 

Rivers, and Native American Coordination.

Under Alternative A, the public lands of the proposed 

Management Area would remain open to multiple uses, 

including fluid minerals leasing and development, mineral material sales, and the granting and development of 

new linear and site-type ROWs, outside of existing designated corridors. Public lands could also be exchanged 

and subsequently developed. This alternative would 

provide negligible to minor protections for yearlong and 

crucial winter range for mule deer, other big game and 

wildlife species, and their natural predators, based on 

current management decisions. 

Under Alternatives B, C, and D, the goals and objectives would be to manage approximately 87, 031 acres of 

public land as the Bull Valley Mountains Multi-species 

Management Area to conserve priority biological habitats and protect migration routes for mule deer, other big 

game and wildlife, and predators. Management under 

these alternatives would provide varying levels of protection for a large block of public land that provides yearlong and crucial winter range for mule deer, other wildlife, and predators. These same management decisions 

would help to ensure that new roads, developments, 

or facilities do not fragment this important habitat or 

impede the safe migration of mule deer herds, other big 

game, and their predators seasonally from summer to 

winter range.

4.49.2.1 Impacts from Management of Lands and 

Realty

Under Alternative A, public lands within the 

Management Area could be transferred from federal 

ownership, if specified criteria identified in the SGFO 

RMP (LD-06, page 2.2) are met. Should public lands 

be transferred from federal management into private 

or state ownership, new developments could occur that 

would fragment or destroy habitats and contribute to 

population declines in mule deer and other wildlife. The 

movement of mule deer herds between winter and summer ranges could be impeded by development on lands 

transferred from federal ownership. 

Implementation of Alternatives B, C, and D would result 

in a major beneficial effect on wildlife, by retaining a 

large block of undeveloped public land in federal ownership, allowing for the protective management of crucial 

habitat and movement corridors for mule deer, predators, and other wildlife species over the life of the RMP. 

These alternatives would provide for the acquisition of 

non-federal lands within the Management Area through 

purchase from willing sellers, exchange, transfer or donation. Acquired lands would be managed consistent with 

the management prescriptions of the adjacent public 

lands, helping to protect additional acreage of habitats for 

wildlife and migration corridors.

Alternatives A and D would manage approximately 955 

acres of the Management Area as an Avoidance area 

for new linear or site-type ROWs. This would provide 

negligible to minor level of protection for crucial mule 

deer winter range and habitats for other wildlife species, 

as soils and native vegetation would not be impacted 

by ROW developments. Habitat fragment through the 

PRIORITY BIOLOGICAL CONSERVATION AREAS
882 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 883

construction of new ROW access roads would also not 

occur within this acreage. 

Alternative B would result in a moderate beneficial 

effect for multiple wildlife species, managing 72,423 

acres, outside of the two designated utility corridors, 

as an Avoidance area for linear and site-type ROWs. 

Management under this alternative would lessen, but 

not eliminate, the potential for new power transmission 

lines or natural gas pipelines to be authorized, outside of 

the two existing designated corridors. The construction 

of new utilities would impact soils and native vegetation, 

resulting in the loss or degradation of wildlife habitats. 

During construction and maintenance activities, wildlife 

populations would likely be disturbed and displaced to 

other areas, potentially during important seasonal breeding periods. 

Alternative C proposes to manage 72,423 acres, outside 

of the two designated utility corridors, as an Exclusion 

area for linear and site-type ROWS. Management under 

this alternative would eliminate the potential for new 

linear or site-type ROWs to be authorized outside of 

the two existing designated corridors, protecting native 

vegetation in mule deer crucial winter range from loss to 

developments and eliminating the potential for fragmentation of habitats for diverse wildlife species. This alternative would preclude the granting of new ROWs for solar 

and wind energy developments that could negatively 

impact wildlife habitats, resulting in the potential permanent loss of many acres of native vegetation to developments, the fragmentation of habitats by new access roads, 

and an increased potential for vehicle-related wildlife injuries and mortalities. Fencing and structures associated 

with these types of large scale energy developments could 

impede the safe movement of mule deer herds between 

winter and summer ranges, impacting the improvement 

of herd numbers that is desired by UDWR. 

4.49.2.2 Impacts from Management of Mineral 

Resources

Fluid Minerals Leasing

Under Alternatives A and D, 58,935 acres of the 

Management Area would be managed as Open to fluid 

mineral leasing, with Standard Stipulations; 24,375 acres 

as Open with Special Stipulations, 1,695 acres Open with 

NSO, and 2,026 acres managed as Closed to fluid mineral 

leasing. Oil and gas developments could be authorized 

on public lands, resulting in the permanent loss of many 

acres of native vegetation and the fragmentation of 

habitats by new access roads. These developments would 

increase the potential for vehicle-related mortalities for 

all wildlife. Fencing and structures associated with these 

types of large scale energy developments could impede 

the safe movement of mule deer herds between winter 

and summer ranges, impacting herd numbers.

Under Alternative B, 0 acres of the Management Area 

would be open to fluid mineral leasing with Standard 

Stipulations; 83,310 acres would be managed as Open 

with Special Stipulations, 1,695 acres Open with NSO, 

and 2,026 acres managed as Closed to fluid mineral leasing. As under Alternative A, oil and gas developments 

could be authorized on up to 83,310 acres of public 

land, resulting in the permanent loss of many acres of 

native vegetation and the fragmentation of habitats by 

new access roads. These developments would increase 

the potential for vehicle-related mortalities for all wildlife. Fencing and structures associated with these types 

of large scale energy developments could impede the 

safe movement of mule deer herds between winter and 

summer ranges. Special Stipulations would provide only 

limited protections to mule deer and other wildlife by 

seasonally restricting development activities in crucial mule deer winter range during the period between 

November 1 and April 15. The long-term impacts on 

wildlife habitats and populations would be similar to 

those described under Alternative A.

Alternative C would manage 87,031 acres of public land 

in the Management Area as Closed to fluid mineral leasing. This alternative would provide the highest level of 

protection for wildlife habitats and migration corridors, 

as the developments, access roads, and human intrusions 

associated with fluid minerals leasing would not occur.

Mineral Material Sales

Alternatives A and D would manage 58,647 acres of 

public land as Open for mineral material sales, 19,457 

acres as Open with site-specific restrictions in crucial 

mule deer winter range, and 8,981 acres as Closed to 

mineral material sales. A total of 78,104 acres of wildlife 

habitat could be impacted by the sale and harvesting of 

sand and gravel under these alternatives, resulting in the 

permanent loss of many acres of native vegetation and 

the fragmentation of habitats by new access roads. These 

developments would increase the potential for vehicle-related mortalities for all wildlife. Site-specific restrictions 

in crucial mule deer winter range would provide limited 

protections to mule deer and other wildlife by seasonally restricting development activities during the period 

between November 1 and April 15.

PRIORITY BIOLOGICAL CONSERVATION AREAS

Alternative B would manage 78,104 acres of public land 

as Open for mineral material sales with site-specific 

restrictions, and 8,981 acres as Closed to mineral material sales. This alternative would provide a slightly higher 

level of protection for wildlife habitat when compared 

to Alternative A, as more acreage would be subject to 

site-specific restrictions. But the loss of vegetation and 

the fragmentation of habitat by new access roads could 

substantially impact mule deer, other wildlife and predators, as mineral material sales could still be authorized on 

78,104 acres of public land.

Alternative C would manage 87,031 acres of public land 

as Closed to mineral materials sales. This alternative 

would protect wildlife habitat from the loss of vegetation 

and fragmentation by new access roads by not authorizing the sale and harvesting of mineral materials.

4.49.2.3 Impacts from Travel Management

Under Alternative A, public lands in the Management 

Area would continue to be managed under the following 

OHV area designations for motorized vehicles: 45,849 

acres as Open to cross-country travel, 40,871 acres as 

Limited, and 307 acres as closed. Management of 45,849 

acres as Open to cross-country travel would have the potential to damage or destroy many acres of native vegetation and fragment wildlife habitats through the creation 

of new vehicle routes. Cross-country travel could result 

in vehicle-related injuries and mortalities for all wildlife. The management of 40,875 acres as Limited would 

help to prevent damage or loss of native vegetation, the 

creation of new vehicle routes that fragment habitats, and 

lessen the potential for vehicle related injuries and fatalities. Managing 307 acres of public land as Closed to motorized vehicles would confer a minor benefit to wildlife 

and habitats, by eliminating the impacts described above.

Under Alternatives B and D, the Management Area would 

be managed as Limited to Designated Roads and Trails, 

with specific route designations to follow in the TMP 

being prepared by BLM for Washington County. This designation would help to prevent damage or loss of native 

vegetation, the creation of new vehicle routes that fragment habitats, and lessen the potential for vehicle related 

injuries and fatalities for mule deer and other wildlife. 

Under Alternative C, 86,724 acres of the Management 

Area would be managed as Limited to Designated Roads 

and Trails, with specific route designations to follow 

in the TMP being prepared by BLM for Washington 

County. Approximately 307 acres would be managed as 

Closed to motorized vehicles. Both designations would 

help to prevent damage or loss of native vegetation, the 

creation of new vehicle routes that fragment habitats, 

and lessen the potential for vehicle related injuries and 

fatalities for mule deer and other wildlife. This alternative would provide a higher level of protection for 

priority biological species and natural communities from 

impacts related to motorized vehicle travel than the 

other three alternatives.

4.49.3 Summary of Impacts from Alternatives

Alternative A would not identify 87,031 acres of public 

land in the proposed Management Area as a priority 

biological conservation area for mule deer, other wildlife, 

and predators that rely on these species. It would not 

develop management actions to protect crucial habitats 

and migration corridors for these species. The public 

lands within the Management Area could be exchanged 

or transferred from federal ownership, if specific criteria 

are met. The leasing of public land tracts for renewable 

energy and fluid minerals could continue on a majority 

of the public lands in this area, as could mineral material sales and the granting of new ROWs, outside of two 

designated corridors. Developments on renewable energy 

and fluid mineral leases could fragment wildlife habitats, 

impede the movement of herds in migration corridors, 

and increase the risks of injuries and fatalities to mule 

deer and other wildlife.

Alternatives B, C, and D would manage the 87,031 acres 

of public land in the identified Management Area as a 

priority biological conservation area, pursuant to the 

mandate of OPLMA at sec. 1979. Management decisions 

would emphasize the protection of habitats and migration corridors for mule deer, other wildlife, and associated predators, through limitations on land use authorizations, such as leases for renewable energy and fluid 

minerals and the development of new ROWs, outside of 

two designated corridors.

Under all alternatives, new power transmission lines, 

pipelines, and associated access roads, are expected to be 

constructed in the two one-mile wide designated corridors that cross the Management Area, resulting in short 

and long-term losses of native vegetation, and short-term 

disruption of wildlife during construction. The impacts 

on wildlife habitats and populations that result from new 

ROW developments would be minor and localized to the 

designated corridors.

In the long and short term, the management decisions 

proposed under Alternatives B, C, and D would benefit wildlife and natural communities, by lessening the 

PRIORITY BIOLOGICAL CONSERVATION AREAS
884 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 885

potential for land uses that would result in habitat loss 

and fragmentation or impede the safe movement of wildlife in seasonal migration corridors.

4.49.4 Cumulative Impacts

The CIAA used to analyze cumulative impacts is the 

Washington County portion of the UDWR-defined Pine 

Valley Deer Herd Unit #30, which includes federal lands 

managed by BLM and the USFS Pine Valley Ranger 

District, state, and private lands. In Washington County, 

this unit is generally located west of I-15 and extends 

to the Utah-Nevada state line and south to the UtahArizona state line. Data are collected by UDWR on deer 

population numbers and habitat conditions (e.g., vegetation transects, other range trend studies) in this Deer 

Herd Unit at regular intervals.

Public lands managed by BLM in Washington County in 

this Deer Herd Unit provide approximately 47, 018 acres 

of year-long mule deer range, 36,143 acres of summer 

range, and 210, 905 acres of winter range (UDWR 2012). 

Appropriate management of mule deer habitats on public 

lands will continue to be important to the maintenance 

and improvement of mule deer numbers, as regional human population growth and the demand for all types of 

developments on private and state lands will continue to 

reduce mule deer and other wildlife habitats over time. 

Large, generally roadless tracts of public lands must 

also continue to serve as migration corridors for mule 

deer herds, other wildlife, and their predators, as species 

move between crucial winter and summer ranges. These 

same corridors may become even more important to the 

survival of many wildlife species, in the face of changing 

climatic conditions.

Past land uses in the CIAA that affected mule deer 

populations and habitats included overgrazing of public 

rangelands during the late 19th and early 20th centuries; 

community growth; the construction of highways, roads, 

utilities, and fence lines that impede wildlife movements; the development of rural residential subdivisions; 

vegetation conversion treatments; hunting; trapping; 

and motorized recreational uses. In general, past land 

uses and human activities have cumulatively resulted in 

the loss, degradation, and fragmentation of habitats and 

population declines in overall deer numbers in this unit 

(UDWR 2012). Habitat loss and fragmentation, human 

encroachment, hunting, and trapping have all contributed to declines in black bear and mountain lion numbers 

in the CIAA.

Prolonged droughts, catastrophic wildfires fueled by 

exotic invasive species, and post-fire flooding are natural 

factors that have also cumulatively impacted the quality of mule deer habitats and contributed to population 

declines. These natural factors created conditions that 

caused or favored habitat changes. Drought conditions 

have reduced the health of native vegetation communities, making them more prone to insect infestations, 

disease, and “die-offs”. Since 2003, wildfires have burned 

more than 250,000 acres in a variety of vegetation types 

in Washington County, with some acres being burned 

more than once. The “burn-reburn” fire cycle in areas of 

the CIAA has converted shrubland communities into invasive brome grasslands that provide poor quality habitat 

for all native wildlife. Wildfires have removed vegetative 

cover and damaged soil crusts, leaving soils more susceptible to wind and water erosion and weed invasion. 

Riparian communities along Moody Wash, Mogatsu 

Creek, and the Santa Clara River have been altered by 

post-fire flooding, such as the events that occurred in 

January of 2005.

Future actions in the CIAA that will benefit wildlife 

habitats are likely to include increased efforts to control 

invasive annual brome grasses and wildfires, through 

landscape-wide fire breaks and fuel treatments. As ongoing research studies identify more effective and environmentally sustainable broad-scale treatment methods, it 

is likely that larger areas will be treated and efforts made 

to restore native vegetation communities, improving 

wildlife habitats. Land uses that have the potential to impact habitat restoration projects would not be authorized 

in those areas, until resource objectives are met. These 

restrictions could benefit all native fish and wildlife species, by protecting habitats and minimizing impacts on 

populations related to land uses and human activities.

Developments on non-federal lands would be expected 

to increase and further fragment wildlife habitats in the 

CIAA. The construction of new rural residential subdivisions and roads could impede the safe movement of mule 

deer and other wildlife between traditional use areas or 

crucial winter, summer, or fawning areas.

Climate change within the CIAA is predicted to result in 

higher seasonal temperatures and highly variable precipitation, potentially affecting soil conditions, vegetation 

community distributions, and surface water resources. 

Such changes would place some wildlife species at greater 

risk of population declines, particularly those species that 

cannot adapt to changed conditions or migrate to areas 

where habitat conditions are favorable.

PRIORITY BIOLOGICAL CONSERVATION AREAS

The establishment and protective management of 

the 87,031-acre Bull Valley Mountains Multi-species 

Management Area on public lands in northwestern Washington County over the life of the RMP 

Amendment would benefit mule deer, other wildlife species, and their natural predators, by minimizing habitat 

loss and fragmentation related to land uses of the public 

lands. This decision would protect a large and remote 

tract of public land for use as a migration corridor where 

herds could move unimpeded seasonally between crucial 

habitats. It would also ensure that the Management Area, 

which comprises approximately 5% of the Pine Valley 

Deer Herd Unit #30, would continue to provide suitable 

habitat for mule deer, other wildlife, and predators in the 

long term.

4.50 COMPREHENSIVE TRAVEL AND 

TRANSPORTATION MANAGEMENT

Section 1977 (b) (1) of OPLMA, directed the Secretary, 

through BLM, to “develop a comprehensive travel [and 

transportation] management plan” (TMP) for public 

lands in Washington County. Prior to the development 

of this plan, the SGFO RMP must be amended to modify 

certain existing off-highway vehicle (OHV) area designations (Open, Limited or Closed), to be in compliance 

with 43 CFR 8340.0-5, (f), (g), and (h), 43 CFR 8342.1 

(a-d), and related agency policies. Area designations 

provide the framework within which individual route 

designations are made, as BLM prepares the legislativelymandated travel management plan. 

Travel management planning provides a support function for all other BLM programs. Specifically, it provides 

for ingress, egress, and access to public and other lands in 

the planning area. The goals for travel and transportation 

management are to work with stakeholders to establish 

an appropriate transportation system that contributes 

to the protection of sensitive resources (such as wildlife 

habitat, riparian areas, and cultural resources) while 

accommodating a variety of uses, and a range of motorized and non-motorized recreation opportunities with 

minimal conflicts between users. 

The potential impacts on diverse public land uses and resource values, including cultural resources, special status 

species, etc., that might result from the OHV area designations proposed in the 1998 St. George Field Office (formerly called the Dixie Resource Area) Proposed Resource 

Management Plan were disclosed and analyzed in the 

Final Environmental Impact Statement that was published 

with the Proposed RMP. The OHV designations that 

were approved by the 1999 SGFO Record of Decision 

and RMP are shown on Map 3-70. The analysis of the 

environmental consequences of making changes to 

the current OHV area designations through the RMP 

Amendment is tiered to and incorporates by reference 

the analyses contained in the 1998 Proposed RMP/FEIS

for all public land resource values. 

The changes proposed in the current RMP Amendment 

would establish OHV area designations that are equal 

to or more restrictive of motorized vehicle travel and 

uses than those contained in the 1999 SGFO RMP. The 

amount of acreage that would be Open to cross-country travel under Alternatives B, C, and D in the RMP 

Amendment would be significantly lower than what is 

currently available under Alternative A. This change 

would measurably decrease the potential for motorized 

vehicle impacts on cultural resources, wildlife habitats, 

riparian areas, and lands with wilderness characteristics, as cross-country travel by motorized vehicles 

would no longer be authorized on 59,226 acres of public 

land. Alternatives B, C, and D would modify the current Limited to Existing Roads and Trails to Limited to 

Designated Roads and Trails on 386,562 acres. This modification would also provide benefits to diverse natural 

and cultural resource values and improve enforcement 

of travel restrictions, as public land users could more 

easily determine which routes are authorized for use and 

might be less likely to illegally pioneer new routes that 

cause new surface disturbances and potential impacts on 

archeological sites, wildlife habitats, or riparian areas.

A TMP is being developed by the SGFO in conjunction with, but on a separate schedule from, this RMP 

Amendment. This implementation-level plan will identify which routes will be open or closed to motorized 

vehicle use, or limited to certain types or seasons of use 

and will be supported by an Environmental Assessment 

that will disclose the potential impacts or benefits of 

the specific route designations on all land uses and 

resource values of the public lands managed by BLM in 

Washington County.

For the purposes of this analysis, adverse impacts to 

travel and transportation are those that restrict travel 

(e.g., managing areas as closed or limited to motorized 

travel) or those that limit the BLM’s ability to provide for 

maintenance or expansion of the transportation network 

to meet the needs of other resources or resource uses, 

or to ensure protection of human health and safety. In 

general, there are more adverse impacts to transportation 

and access when areas are closed to motorized travel. 

COMPREHENSIVE TRAVEL AND TRANSPORTATION MANAGEMENT
886 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 887

Actions that increase access or expand the transportation 

network would have beneficial effects.

4.50.1 Methods of Analysis

Impacts are quantified where possible. In the absence 

of quantifiable data, professional judgment was used. 

Impacts are sometimes described using ranges of potential impacts or in qualitative terms, if appropriate. 

Adverse impacts to Travel and Transportation 

Management could result from management actions that 

diminish any of the fundamental components listed in 

the indicators section below.

Beneficial effects could result from management actions 

that maintain or enhance any of the fundamental components listed in the indicators section below. 

4.50.1.1 Indicators

The management approach and assumptions for each 

alternative would guide the route designations in the 

TMP and set the stage for future route designations on 

public lands managed by the SGFO. The indicator is the 

number of acres designated as Open, Closed, or Limited 

on public lands managed by the SGFO.

4.50.1.2 Assumptions

The analysis includes the following assumptions:

▶ There would be no impact on use of existing highways or county-maintained roads;

▶ Reasonable access will be allowed to the State 

School Trust Lands so that those lands can be developed in a manner that will provide funds for the 

common schools (Cotter Decision, State of Utah v. 

Andrus, 486F. supp. 996, 1979);

▶ The Sand Mountain Special Recreation 

Management Area would continue to be managed 

under the Open area designation under all alternatives, consistent with the agreement for joint 

management with the State of Utah’s Sand Hollow 

State Park;

▶ Individual route designations are implementationlevel decisions that will be addressed in the TMP 

and tiered to the OHV Area Designations in this 

Amendment.

4.50.2 Direct and Indirect Impacts

A change in OHV area designations from Open to either 

Limited or Closed would generally be beneficial to 

natural and cultural resource values by minimizing the 

direct and indirect impacts that can result from motorized vehicles traveling off roadways. For threatened 

and endangered species and other wildlife, the potential 

for population impacts and habitat loss or degradation 

would be avoided or lessened through these changes. 

Direct and indirect impacts to cultural resources, such as 

artifact displacement, loss of site integrity, and looting, 

would be minimized through a change in area designation from Open to either Limited or Closed. Impacts 

that could occur to cultural resources within close 

proximity to linear travel features may be further reduced 

through the route designation process associate with the 

development of the TMP. 

In all but Alternative A (No Action), potential direct and 

indirect impacts to natural and cultural resource values 

have been minimized in accordance with 43 CFR 8342 

(a) through a reduction in the acreage of areas designated 

as Open. The extent and magnitude varies by alternative, with Alternative C being the most beneficial by 

reducing the Open area acreage to the greatest extent. 

There would be no impact on use of existing highways or 

county-maintained roads. 

Reasonable access will be allowed to the State School 

Trust Lands so that those lands can be developed in a 

manner that will provide funds for the common schools 

(Cotter Decision, State of Utah v. Andrus, 486F. supp. 

996, 1979);

The Sand Mountain Special Recreation Management 

Area would continue to be managed under the Open 

area designation under all alternatives, consistent with 

the agreement for joint management with the State of 

Utah’s Sand Hollow State Park;

Individual route designations are implementation-level 

decisions that will be addressed in the TMP and tiered to 

the OHV Area Designations in this Amendment.

4.50.2.1 Impacts from Transportation and OffHighway Vehicle Management

Proposed OHV Designations

The range of management alternatives proposed in 

the Amendment for OHV area designations is shown 

in Table 4-49, Table 4-50, and displayed on Map 2-52 

through Map 2-55.

Open Designations

The primary difference in OHV Area Designation acreage between Alternative A (No Action) and the three 

action alternatives is the result of the elimination of 

the approximately 60,000-acre Open OHV area in the 

northwest corner of Washington County, just south of 

the Dixie National Forest boundary (Map 3-70). Under 

COMPREHENSIVE TRAVEL AND TRANSPORTATION MANAGEMENT

Alternatives B, C, and D, this Open designation would 

change to Limited. Prior to completion of the TMP, this 

would mean all motorized traffic is restricted to existing 

roads and trails. Once the TMP is complete and all routes 

have been evaluated and have received a designation, all 

motorized traffic would be restricted to designated roads 

and trails.

This 60,000-acre area in the northwest corner of 

Washington County was designated as Open in the 1999 

SGFO RMP. The terrain is mountainous and densely 

forested with pinyon pine, Utah juniper, serviceberry, 

and other woody shrubs, virtually eliminating the option for safe, motorized cross-country travel. These 

environmental factors, combined with the lack of demand for an Open OHV Area in this remote corner of 

the SGFO administrative area, disqualifies the area for 

consideration as an Open area under BLM Handbook 

8342 (Travel and Transportation Management). The 

Handbook states, “Open areas will be limited to a 

size that can be effectively managed and geographically identified to offer a quality OHV opportunity for 

participants.” The Open designation in the Bull Valley 

Mountains is large (nearly 60,000 acres in size) and does 

not offer a safe, quality cross-country OHV experience. 

It should be noted that the existing roads and trails in 

the area do offer abundant and popular opportunities 

for OHV recreation experiences, but on roads and trails, 

rather than cross-country riding. 

The proposed change from Open to Limited for this 

area would have negligible to minor impacts on motorized recreational users, for the reasons described in the 

previous paragraph. While the area would no longer be 

available for cross-country travel, such travel was not a 

safe or viable option. Motorized use of the existing roads, 

primitive roads, and trails in the area would continue to 

be authorized under the Limited designation.

The approximately 21,442 acre Sand Mountain OHV 

Area would remain open to cross-country travel in all alternatives. This area meets all of the BLM 8342 Handbook

criteria for Open areas. There are spacious dunes for 

ATVs and motorcycles to play on; slickrock challenges 

for technical four-wheel drive enthusiasts; the area is geographically defined by Sand Mountain; and has intense 

public demand, due to the proximity of Sand Mountain 

to the major population centers of Washington County.

In Alternative B, the Open OHV Area remains the same 

as under Alternative A. In Alternative C, the area’s size is 

reduced by 1,639 acres to protect significant paleontological resources in Warner Valley. In Alternative D, the area 

is increased by 2,652 acres, resulting in minor benefits 

to users as the southwestern boundary of the OHV area 

is extended to the edge of the cliffs above the Warner 

Ridge-Fort Pearce ACEC.

Closed Designations

Across all alternatives, there are approximately 132,000 

acres of designated wilderness managed by the SGFO 

that will continue to be closed to motorized use. In 

Alternative A, there are an additional 540 acres that are 

managed as closed to motorized vehicles. These acres 

include the Warner Valley Dinosaur Track Site (40 acres), 

the Fort Pearce Historic Site (40 acres), and the canyon 

COMPREHENSIVE TRAVEL AND TRANSPORTATION MANAGEMENT

OHV Area 

Designation

Alt. A Alt. B Alt. C Alt. D

Open to Crosscountry OHV 

Use

80,668 

acres 

(16%)

21,442 

acres 

(4%)

19,803 

acres 

(4%)

24,094 

acres 

(5%)

Limited to 

Existing Roads 

and Trails

297,042 

acres 

(57%)

0 acres 

(0%)

0 acres 

(0%)

0 acres 

(0%)

Limited to 

Designated 

Roads and 

Trails

26,937 

acres 

(5%)

386,563 

acres 

(74%)

385,033 

acres 

(74%)

384,209 

acres 

(74%)

Closed to OHV 

Use

115,786 

acres 

(22%)

112,427 

acres 

(22%)

115,591 

acres 

(22%)

112,129 

acres 

(21%)

Total 520,711 (100%)

OHV Area 

Designation

Alt. A Alt. B Alt. C Alt. D

Open to Crosscountry OHV 

use

80,668 

acres 

(16%)

21,371 

acres 

(4%)

19,803 

acres 

(4%)

24,089 

acres 

(5%)

Limited to 

Existing Roads 

and Trails

297,042 

acres 

(57%)

358,882 

acres 

(69%)

359,657 

acres 

(69%)

356,155 

acres 

(69%)

Limited to 

Designated 

Roads and 

Trails

26,937 

acres 

(5%)

27,029 

acres 

(5%)

25,376 

acres 

(5%)

27,067 

acres 

(5%)

Closed to OHV 

use

115,786 

acres 

(22%)

113,151 

acres 

(22%)

115,596 

acres 

(22%)

113,121 

acres 

(21%)

Total 520,711 (100%)1

1

Acreage total reflects public lands outside of the two NCAs.

Table 4-50 OHV Area Designations by Alternative Following 

TMP Completion

Table 4-49 Proposed OHV Area Designations by Alternative
888 Chapter 4 SGFO RMP AMENDMENT SGFO RMP AMENDMENT Chapter 4 889

of Lone Pine Arch (460 acres). In Alternatives B and D, 

these designations would change from Closed to Limited, 

creating additional public access on designated roads 

and trails. In Alternative C, the current closures would 

remain in place. Impacts from Alternatives A and C 

would be negligible to minor. Improved accessibility in 

Alternatives B and D would likely result in minor beneficial effects as access to these popular Public Use and 

visitor destination sites is improved.

Limited Designations

Alternative A retains the Limited to Existing Roads 

and Trails designation and Alternatives B, C, and D 

would shift to Limited to Designated Roads and Trails, 

upon completion of the TMP. Continuing the Limited 

to Existing designation in Alternative A could hamper 

the BLM’s ability to reduce unauthorized travel due to 

continued public uncertainty about what constitutes an 

existing route. In areas with higher route density, the 

establishment of new, unauthorized routes can happen 

quickly and confusion often follows because users now 

see those routes as legal because they are “existing.” In the 

long term, this could result in moderate impacts to travel 

opportunities for motorized users due to the possibility 

of area closures for resource protection.

Under Alternatives B, C, and D, the Limited to Designated 

Roads and Trails category provides a more stable, longterm, sustainable transportation system. Impacts to travel 

opportunities from this designation would be negligible. 

However, it should be noted that impacts could be more 

substantial following the TMP because that document 

will provide alternative designations of open, closed, 

or limited for each individual route. Depending on the 

alternative chosen, there could be either beneficial effects 

or negative impacts to travel opportunities.

4.50.3 Summary of Impacts from Alternatives

Under Alternatives B, C, and D, there would be up to 

a 75% reduction in the acreage designated as Open to 

cross-country motorized travel. There is a slight variation in the number of acres in the Open category across 

the alternatives. This is due to variations in the size of 

the Sand Mountain OHV area under Alternatives C and 

D. Following completion of the TMP, the majority of the 

planning area (74%) would be Limited to Designated 

Roads and Trails. The number and types of routes in 

these areas to be designated will be identified in the draft 

TMP and the environmental impacts or benefits evaluated and disclosed in an Environmental Assessment.

4.50.4 Cumulative Impacts

The CIAA for transportation and access includes federally-managed lands in Washington County, including the 

Pine Valley Ranger District of the Dixie National Forest 

and Zion National Park. It also includes federally-managed lands in the following BLM Field Offices: Kanab, 

Cedar City, Caliente Field Station, and Arizona Strip.

Alternatives B, C, and D would change the Open area 

designation for nearly 60,000 acres in the Bull Valley 

Mountains to Limited to Designated Roads and Trails, as 

the area is not suitable for safe cross-country travel. This 

change reflects current policies in travel planning on 

federally-managed lands. Prior to the mid to late 1980s, 

federal policy was generally that areas were managed as 

Open to cross-country travel, unless specifically closed. 

That policy has changed so that areas are closed to crosscountry OHV use, unless specifically managed as Open. 

Of the approximately 22,600,000 federally-managed 

acres in southwestern Utah, southeastern Nevada, and 

northern Arizona, about 8 percent are currently managed as Open to cross-county vehicle use. A majority 

of this acreage is managed by BLM’s Cedar City Field 

Office which is currently preparing a new RMP and also 

developing a TMP that would be expected to change 

the OHV designations from its older land use plans to 

bring them in line with current federal policies. It is 

expected that large areas will be managed as Limited 

to Designated Roads and Trails, continuing to provide 

opportunities for motorized recreational activities on 

designated roads and trails.

A reduction in the size of the Sand Mountain OHV Area 

is anticipated to occur over time, based on past actions 

and reasonably foreseeable future actions; listed below 

are actions that have affected the OHV area or are projected to in the foreseeable future.

4.50.4.1 Past Actions

▶ Sand Hollow Golf Course R&PP Lease to the City 

of Hurricane – reduced the OHV area by 303 acres 

and eliminated public access at this location.

▶ Southern Parkway Project-Federal Highways 

Administration appropriation of public lands modified or eliminated public access across the entire 

northern end of the Open area.

4.50.4.2 Proposed Actions

▶ Warner Valley Reservoir Project – could reduce 

Open area by 400 acres and eliminate public access 

at this location

COMPREHENSIVE TRAVEL AND TRANSPORTATION MANAGEMENT

▶ Lake Powell Pipeline Project– could reduce Open 

area by 500 acres and eliminate public access at this 

location.

▶ Land Exchange – could reduce Open area by 1,200 

acres and modify public access at this location.

The Sand Mountain Open OHV Area provides highquality motorized recreation experiences for local 

residents and visitors to southwestern Utah. The nearly 

20,000 acres of sand dunes and slickrock appeal to 4x4, 

ATV, UTV, and motorcycle users. The proximity of the 

Open area to the Sand Hollow Reservoir State Park 

increases revenues to the State Park and allows motorized recreationists to enjoy water based and cross-county 

recreational experiences. The cumulative reduction in 

acreage in the Sand Hollow OHV area and the impacts 

on access as a result of reasonably foreseeable future actions and projects could have moderate to major impacts 

on motorized recreational uses in Washington County.

4.51 IRREVERSIBLE AND IRRETRIEVABLE 

COMMITMENT OF RESOURCES

Section 102(2) (C) of NEPA requires a discussion of any 

irreversible or irretrievable commitments of resources 

that are involved in the proposal should it be implemented. An irretrievable commitment of a resource is 

one in which the resource or its use is lost for a period 

of time (e.g., modifications to the landscape from fire or 

other vegetation treatments). An irreversible commitment of a resource is one that cannot be reversed (e.g., 

the extinction of a species or disturbance to protected 

cultural resources).

Implementing the management decisions or actions 

identified in the RMP Amendment would not result in 

the irreversible or irretrievable commitment of resources, 

because of the narrow scope and emphasis of the amendment. Under the alternatives, new ACECs would be 

administratively designated or other special management areas identified to protect at-risk native plants, fish, 

and wildlife, through land use restrictions. Similarly, 

OHV area designations would be modified as a land use 

planning level decision, with no implementation-level 

actions identified until the TMP is completed. Neither of 

the issues addressed by the RMP Amendment have the 

potential for the irreversible or irretrievable commitment 

of resource values.

4.52 RELATIONSHIP BETWEEN LOCAL SHORTTERM USES AND LONG-TERM PRODUCTIVITY

Section 102(C) of NEPA requires discussion of the relationship between local, short-term uses of the human 

environment, and the maintenance and enhancement of 

the long-term productivity of resources. As described in 

the introduction to this chapter, “short-term” is defined 

as anticipated to occur within one to five years of implementation of the activity. “Long-term” is defined as following the first five years of implementation but within 

the life of the RMP (projected to be 20 years).

Implementing the decisions or actions identified in the 

RMP Amendment would result in the long-term conservation and protection of habitats for at-risk native plants, 

fish, and wildlife, through the administrative designation 

of new ACECs. Management prescriptions for designated 

ACECs would restrict some uses of the human environment, such as energy development or mineral materials 

harvesting, on public lands within the ACECs, to prevent 

the loss of federally-listed endemic native plants populations or wildlife species and damage or destruction of 

critical habitats for these at-risk species. The duration 

of these restrictions would be expected to last over the 

life of the RMP or longer, until such time as species 

listed under the protection of the ESA are recovered and 

delisted. Recovery and delisting would enhance the longterm productivity of natural ecosystems in Washington 

County, maintaining native plants and wildlife that are 

clearly adapted to the unique environmental conditions 

of the area. 

Special management in the Bull Valley Mountains MultiSpecies Management Area would conserve habitats and 

migration corridors for wildlife species that may not 

meet the relevance and importance criteria for ACEC 

designation. Management decisions could have a negative impact on some short and long-term uses of the public lands, with some uses, such as energy development, 

mineral materials harvesting, and new developments 

under ROWs, precluded or restricted to protect those 

habitats and species. These special management actions 

would further the long-term productivity of natural 

ecosystems, maintaining and enhancing the numbers of 

mule deer, other wildlife, and their natural predators.

Similarly, OHV area designations would be modified as 

a land use planning level decision, with no implementation-level actions identified until the TMP is completed. 

The proposed modifications would be more restrictive 

of motorized vehicle uses than under the current RMP, 

enhancing the long-term productivity of diverse resource 

values on public lands in the planning area.

RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES AND LONG-TERM 

PRODUCTIVITY