|An industrial truck in Nine Mile Canyon with a plume of dust behind it.|
For many years I have enjoyed the archaeological treasures of southern Utah, and especially the rock art of Nine Mile Canyon. After I moved to Price I renewed my acquaintance with Nine Mile Canyon and I was appalled to find Nine Mile (toward Cottonwood Canyon) full of dust and industrial traffic. I soon found out that drilling for natural gas had already started above Cottonwood Canyon without an environmental impact statement under a provision of the the energy plan passed in Washington, D.C.
In late 2005 the Nine Mile Coalition began to hear complaints about the traffic in the canyon especially as regards speed and dust. Myself and another member (Steve Tanner) of the coalition went up in the area of the Great Hunt Panel with a radar gun and a camera to check on the traffic situation. We found that most of the industrial traffic was violating the posted speed limit and I took many pictures of vehicles with dust clouds that you could not see through. In fact, after we spent the day out there the dust was so bad that I had to use my rescue inhaler because I felt my lungs tightening up.
During that time we also washed the dust off some areas that were close to rock art so we could look at the affect of the dust deposition on the rock. We took some glass plates with us and we also set those out.
We didn't get back out in the canyon for about three months (this was over the winter) and since this was the rainy season I thought that the washed places would be easy to see since the rain should keep the dust down.
But we found that if we had not photographed the washed places we would not have been able to find them. The glass plates were covered with dust and the one in the area of the Great Hunt Panel was the worst.
At the time we went back and looked at the panels there were fewer vehicles exceeding the speed limit but the dust plumes were still there. It was clear that the size of the trucks was such that the dust problem was going to be with us regardless of the speed. We followed three liquid carbon dioxide trucks going down to Harmon Canyon and the dust was terrible. Magnesium chloride had been put on the road in places but if the road surface is not firm enough, the mag chloride does no good since the sand is pounded into dust immediately and the mag chloride becomes airborne with the dust..
I wanted to get a traffic count so I went back out to the mouth of Harmon Canyon and climbed up on the hillside opposite the entrance and took pictures while I counted industrial traffic. From 10:30 am to 2:30 pm I counted over 60 trucks and estimate, using some data from Gate Canyon, that there was probably 100 industrial vehicles at that point in a 24 hour period. There were 20 tourist vehicles at that point during that time but they contributed very little to the dust because of their smaller size and slower speed as they looked for rock art.
In my opinion if one of those multiple truck convoys came by it could be very dangerous for the tourists because of the reduced visibility. The industrial users of the road did water it for an hour while I was there, but within an hour the dust was back.
On another trip I went to the mouth of Gate Canyon and counted and photographed the traffic at that point from 8:30 a.m. to noon. I counted over 60 vehicles while I was there, some of them were semi's convoying, especially the carbon dioxide trucks. There was no watering that I saw while I was there and no watering up at the Great Hunt Panel either. When I did my count at Harmon Canyon I counted 25 vehicles after noon and using that information, I would say that 100 vehicles passed there in the 24 hour period. With those being round trips for each vehicle that would add up to 200 trips.
Over the last two years sightseer cars have become less and less as the word spreads about the traffic in the canyon.
We did get the BLM to require a dust study to be done but that ended up in controversy since only the preliminary report was included in Appendix G of the Draft EIS. We obtained a copy of the final lab report and it is clear that the magnesium chloride used on the road is also on the rock surfaces and a water sample shows that it went into the Nine Mile Creek. The dust study did not look at dust concentrations which was for me was frustrating since my specialty has been the transport and impact of pollutants on the public for almost 40 years.
The coalition paid for a portable laser particle detector which enabled us to do a preliminary study of dust concentrations from traffic in the canyon. The particle counter reads out in particles per cubic foot/100 but the readings can be converted to compare to the EPA limits. However for a preliminary study a comparison with area particle counts should be sufficient. In Price the counter shows 10,000 particles/cubic foot. In Nine Mile Canyon with no vehicles passing by the counter it shows 300,000 particles/cubic foot. With 80,000 pound liquid carbon dioxide trucks passing by counter reads 3,000,000 particles per cubic foot. (This is 100 percent opacity, i.e., you can't see anything).
The problem with the dust is not just from an individual truck but from the massive industrial traffic when the full field development happens. Carbon Count did a 24 hour count of traffic in the canyon when two drill rigs were operating and found that there were 340 vehicles mostly within 12 hours. The draft EIS says there will be 575 vehicles at peak development (which is nine drill rigs). We have done other counts and I estimate that the peak traffic will be over 1200 vehicles in 12 hours time. At times there will probably be two trucks a minute in the canyon. The diesel pollution from those trucks will add to the high concentrations of dust.
In addition the 10 compressors at the Dry Canyon Compressor Station will add their pollution to the dust and the truck diesel fumes. The BLM has never accounted for the impact of the Dry Canyon compressor station in any NEPA (National Environmental Policy Act) document and does not model the pollution from the station which sits in a deep canyon that has strong inversions which hold the dust, the diesel and the compressor effluents close to the ground.
The synergistic effect of this type of situation is discussed in an scientific publication by George D. Liekauf entitled "Hazardous Air Pollutants and Asthma" (Environmental Health Perspectives, Vol 110 (Supplement 4), August 2002.
He says that complex mixtures of hazardous air pollution may exacerbate asthma. After one of my talks I received an email from a man with COPD and he told how he had to use oxygen on his last trip in the canyon.
The stack at the Dry Canyon station is washed off when the pollution gets to be too apparent. The chemical effect of the air pollutants on the rock art is not known since the study was so inadequate, but you can already see the rock art being obscured by the dust deposited on the rock surfaces. Any rock art not exposed to the rain will eventually disappear over the 30 years of this project.
My conclusions from all of the above is that the industrial traffic from the BBC project will most likely destroy a unique archaeological treasure. The dust will cover the rock art over the years, the tourists will abandon the canyon because of the health hazards (respiratory and accident hazards) and the lost solitude. Numerous tourists have already complained about the traffic. To no avail, the Hopi have commented numerous times that the traffic and dust threaten their cultural sites in the canyon. Draft EIS Section 5.12, pg 5-36, states that all of the alternatives would result in the loss of important cultural resources. This is a violation of the NEPA and numerous other federal laws protecting antiquities and Indian sacred places.
There has been essentially no monitoring or enforcement by BBC or the BLM so regardless of any promises or requirements in the coming EIS, they will not be honored based on the record of the gas drilling over the last four years.
None of this needs to happen since all that is needed to save the canyon is approximately five miles of bypass road that would take all the traffic out of the main canyon and Cottonwood Canyon. On the West Tavaputs there will be 180 miles of road for this project. In the draft EIS the BLM has eliminated any bypass road alternatives without any proof that they were not feasible. This is a violation of NEPA where no "reasonable alternative" can be eliminated without supporting justification.
(Ivan White is a retired Environmental Consultant and amateur archaeologist living in Price.)