All: Last week Jay posted a link to the Fox 13 news report on the proposed expansion of the Alton Coal Mine on BLM land just 10 miles south of Bryce Canyon National Park. Only Josephine Grahn appeared to have anything to say about it then, so I’m hoping the following might interest a few to provide input to the BLM regarding the project. The link to the Draft Environmental Statement (DEIS) is: http://www.blm.gov/ut/st/en/prog/energy/coal/alton_coal_project/alton_coal_e.... There are numerous problems with this DEIS and I hope you’ll investigate on your own and not take my or someone else’s word for it. It’s our duty as concerned citizens. However, the part that might be of most interest to this group, of course, is the impact to night skies from BCNP. I’m sharing with y’all some of the issues that I’ve found as I’ve been investigating this (and I’m not even done yet). A serious issue that I see is that the consulting engineers, SWCA, Inc., have blown-off recommendations made by their own consultants with regards to preserving dark skies. I wonder, then, how often is this the case for other issues? Your help in reviewing the DEIS and commenting to the BLM could make a difference. One more thing: All this is being done; all this potential impact to the environment is being justified for just 50 million tons of coal over a project life of 25 years. At two million tons per year, that is less than 0.0002 percent of the US’s annual coal consumption. Your opinion may vary, but I don’t see the benefit for that miniscule amount of dirty coal. Whether you are in favor of this project or opposed to it your voice should be heard. There are public meetings scheduled – see this link for times and locations: http://www.blm.gov/ut/st/en/info/newsroom/2011/november/kanab_blm_to_host.ht.... As you read the DEIS, you’ll find most information about impacts to night skies in Chapter 3, Chapter 4, and Appendix I. Appendix I is especially enlightening. It is the report of Dark Sky Partners, LLC to SWCA, Inc. All of the principals of DSP are professional astronomers, one of whom is a past president of the IDA. If you care to read on, here are issues I’ve already flagged:
From 4.2.1:
“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).” Comments 1. “Skyglow” is not the only physical effect of artificial lighting. For example, the consequences of skyglow may be outweighed by the impacts to safety from direct glare due to poorly aimed and/or excessive lighting (“light trespass”). This safety concern and others (see below) have not been addressed in the DEIS. 2. Paragraph 4.2.1 assumes that lighting impacts to dark nighttime skies are solely aesthetic. While the aesthetic value of clear, dark, pristine nighttime skies is indeed important to BCNP, ecological and environmental impacts to natural resources are of equal or greater concern. These include impacts to land mammals, bats, birds, reptiles, amphibians, invertebrates, fishes and plants, such as are described in Ecological Consequences of Artificial Night Lighting (Catherine Rich and Travis Longcore, Island Press, 2006), none of which appear to have been addressed in the DEIS. 3. In the lighting industry the term, “shielded fixtures” is not a technical term. “Full-cutoff fixtures” are recognized as being responsive to light pollution concerns and are the appropriate fixture type that should have been referenced in the DEIS. 4. Appendix I of the DEIS contains a report to SWCA from its consultant, Dark Sky Partners, LLC (DSP), dated April 2009. As “suggested” to DSP by “Alton Coal Development,” DSP addressed two alternatives, “typical lighting and…brightest expected lighting.” (“FINAL REPORT, Prepared by Dark Sky Partners, LLC for SWCA Environmental Consultants,” Executive Summary, p. 3; italics per original.) In its report, DSP cited a number of assumptions that were made due to insufficient data, either from Alton Coal or from specific product manufacturers. Among the assumptions DSP therefore made, DSP reported that under the brightest expected lighting conditions the impact to night sky darkness would be minor (not negligible) [Note: In environmental law, minor impacts require more investigation, justification and mitigation than negligible impacts.], and subsequently DSP cited a number of mitigations for reducing sky glow. Suggested mitigations include the following: using high-pressure sodium and/or low-pressure sodium lamp types (“…the visible sky glow produced by metal halide lighting is approximately 3 times that produced by high-pressure sodium lighting, and 12 times that produced by low-pressure sodium lighting, on a lumen-for-lumen basis.” FINAL REPORT, p. 23); utilizing portable fixture shielding; aiming portable fixtures to reduce impacts; reducing dust to mitigate the impact of reflected light from potential dust plumes at the site; reduction or elimination of nighttime lighting at the headquarters building. (FINAL REPORT, pp. 23-25) Among its conclusions, DSP says, “Though the sky glow impacts of the potential lighting appear small, particularly when considering the typical lighting expected to be used 90% of the time that the mine is active, the unusually pristine nature of the nighttime landscapes in this region, combined with the high resource value attached to natural nightscapes by BCNP mean that even small impacts may be of concern.” (FINAL REPORT, p. 25; italics added). One would expect that SWCA would include all of DSP’s proposed mitigations in the DEIS, inasmuch as (1) the potential effect of the expected lighting is not considered negligible but minor under certain conditions, and (2) as stated by DSP, even small impacts may be of concern for the resources at BCNP and the greater region. 5. P. 4-15: “For the duration of active mining, the typical mine lighting scenario would result in a 1% increase in night sky brightness at an altitude of 10° above the horizon and a 10% increase 1° above the horizon visible from Yovimpa Point.” While this is a summary of findings described by SWCA’s consultant, Dark Sky Partners, LLC (DSP), the data quoted are for the typical and not the brightest expected lighting conditions as defined by DSP. According to DSP, “Under the brightest lighting condition the sky would brighten by about 3% at zenith angle of 80°, and by 31% at a zenith angle of 89°.” (FINAL REPORT, p. 14.) 6. 4.2.4.2, P. 4-16: “The study conducted by Dark Sky Partners concluded that the predicted skyglow visible from Yovimpa Point in Bryce Canyon National Park would be less than that produced by several small towns in the general area. The study also concluded that the predicted skyglow visible from Brian Head Peak outside of Cedar Breaks National Monument would be much less than skyglow arising from St. George and Cedar City, Utah. Although the impacts of the Proposed Action do not reach a level of significance, there is a high value placed on night sky resources at Bryce Canyon. The mitigations listed in the Nighttime Lighting and the Extent of Skyglow section of this chapter are recommended to further reduce impacts to night sky conditions (Dark Sky Partners 2009).” These are not the conclusions made by Deep Sky Partners in its April, 2009 report to SWCA. On the contrary, DSP concluded that, “…the outdoor lighting for mining operations within the ACT would produce a detectable sky glow when viewed from Yovimpa Point in BCNP for only the brightest lighting scenario analyzed.” (FINAL REPORT, p. 25, italics added.) Summary The DEIS consistently avoids reference to the brightest expected lighting conditions, the impacts of which are detectable and significant, and instead has mislead the reader by quoting or reporting only DSP’s findings that relate solely to the typical expected lighting conditions. The criteria that DSP used to determine impacts were provided by “Alton Coal Development” and were not produced independently. There are no guarantees or restrictions indicated in either DSP’s analysis or the DEIS that any measures would be taken to ensure that lighting levels do not exceed either the “brightest” or even the “typical” expected lighting analyzed by DSP. In fact, the DEIS misstates DSP’s findings and conclusions and does not even endorse all of the mitigations recommended by DSP.