Joe wrote:
For special places like Bryce, preservation should have high priority. I vote to keep the dark skies and all the other advantages of the national park and to protect BLM land where its natural values are high. -- Joe
Joe, A key failure of the BLM's Alton Mine analysis, IMHO, is failure of BLM to perform programmatic environmental analysis for dark sky preservation. In the Alton Mine DEIS, the BLM summarizes its NEPA programmatic analysis and regulatory implementation as ``There are no legal or regulatory requirements with respect to skyglow'' (DEIS at 4-6, 4-7, quoted below). In other words, the DEIS does not consider dark skies a priority because the BLM has never looked at the dark sky aesthetic value on a programmatic level for its substantial Intermountain state's in-holdings. In the absence of programmatic analysis and guidance, the local BLM office suggests some site specific dark sky mitigation efforts (DEIS at 4-7). Those mitigation effects are based on naked-eye aesthetic impacts. The Dark Sky Associates technical report does not analyze, nor does the BLM report address the reduction in telescopic limiting magnitudes. Programmatic analysis NEPA analysis means that a federal agency looks at the regional and national impacts of a policy. Programmatic analysis should guide site specific analysis. An example of programmatic analysis is the development of regional wind power on BLM lands. Any one wind development site may not have adverse environmental impacts, but if the BLM massively expands wind power at many sites, what unanticipated impact might it have on bird migration. What mix of wind, solar and coal development would best advance the nation's needs for a sustainable future? Those are the types of questions that programmatic analysis considers. Recently, the BLM did a Wind PEIS, a West-Energy Corridor PEIS, and, I believe, is revising its 2008 Tar Sands Oil Shale PEIS. Taken collectively, I wonder if any or all of these PEISs consider their individual or cumulative dark sky environmental impact. Looking at any dark sky map of the United States (e.g. http://www.astronomyforum.net/astronomy-locations/usa/ or http://www.darksky.org/ ). It is apparent that the BLM controls the last vestiges of this dwindling aesthetic resource. IMHO, the whole Alton Mine field concept should be put on hold until the BLM does a programmatic EIS for dark skies. Then the agency will be in a position to wisely rule on the Alton Mine proposal. Until then, the BLM is, pun intended, just fumbling around in the dark. However, my view on such matters is similar to the rejected SUWA position rejected in _ Norton v. SUWA_, U.S. Supreme Ct (2004). In that controversy, SUWA sued the local BLM for failing to adequately regulate the use of or plan to regulate the use of ORVs in wilderness study areas. SUWA's claims were rejected by the Supreme Court since the regional BLM plan did discuss ORV use. Clear Skies - Canopus56 =================== Begin Quote =================== The Federal Land Policy and Management Act of 1976 requires that the BLM periodically prepare and update its land-use plans. In that process, the agency establishes objectives for management of visual resources, or landscape protection and change. The public lands in the tract are managed under VRM Class IV objectives. The objective of Class IV is to provide for management activities that require major modifications to the existing character of the landscape. These activities may dominate the view and may be the major focus of the viewer‘s attention. There are no legal or regulatory requirements with respect to skyglow. The KFO RMP does not prescribe any specific surface stipulations for management and protection of aesthetic resources in the tract. However, based on the analysis, the successful bidder would be required to employ skyglow minimization measures for nighttime mining operations. These would consist of: - utilizing 250-watt metal halide lamps producing 25,000 lumens each, contained in fully shielded fixtures for fixed-position light poles (or equipment and measures that would further minimize skyglow as a result of these lights); and - utilizing 1,000-watt metal halide lamps producing 110,000 lumens each and typically aimed at 30 degrees below the horizon, though at times (less than 10% of the time) directed straight sideways toward the horizon (or equipment and measures that would further minimize skyglow as a result of these lights). =================== End Quote =================== Alton Mine DEIS at 4-6 and 4-7. P.S. - For almost four decades, U.S. citizens, through their elected representatives, enacted and preserved NEPA to assure that our valuable common federal resources are managed efficiently and wisely. NEPA, in part, has successfully resisting attempts to gut or repeal it, in part, because of the ``silent majority's'' knowledge that our federal resources need to be professional administered for maximum long-term yield and need to be protected from local pressures to develop our resources for short-visioned and short-term greed. It is not a question of what local Utah citizens' feel is the prevailing political will. It is a question of what is best for the nation's interests from a professional planning and administration viewpoint. It's about the rule of law, and it is not about the will of the local political majority.