the primary road to the park. San Juan County and the Federal Highway Administration have retained URS Corporation and Taschek Environmental Consulting to lead a study under the National Environmental Policy Act (NEPA) at a cost of up to $250,000 (secured through federal funding from Congressman Tom Udall).
It appears that an "environmental document" will be prepared by these third-party consultants focusing on a range of alternatives from leaving the road as is (No Action), to chip-sealing the road, to engineering changes to the road. As of September 2009, this environmental document has yet to hit the streets. Deficient transportaion analyses and cultural resources inventories have been prepared for the project. It now apperas that the project proponents want to leave out of the EA the final four miles of CR 7950 from north of Escvada Wash to the park.
San Juan County has already chip sealed the first four miles of CR 7950 which raises issues including NEPA compliance, impacts to archeological resources, and the failure to consult with tribal entities. Despite San Juan County claims that they used no Federal money in the chip-sealing of the first four miles of CR 7950, it is becoming increasingly evident that they failed to comply with NEPA and National Historic Preservation Act (NHPA) and that New Mexico Department of Transportation failed to properly oversee the project.
The National Park Service is currently conducting a “carrying capacity” study at the park to determine funding and infrastructure requirements in association with visitation. SJCA believes that any impact analysis associated with the environmental document for CR 7950 needs to include potential impacts to Chaco Culture NHP as a connected action and should incorporate the conclusions of the “carrying capacity” study being conducted at the park.
While respecting the need for public safety on CR 7950 and the plight of local residents who live adjacent to Chaco Culture NHP, SJCA advocates for improvements to CR 7950 in the form of fencing, good signs, and maintenance; not paving. San Juan County's maintenance records of CR 7950 show a total of 150 maintenance hours for 2004. Perhaps scheduled maintenance of CR 7950 is where San Juan County should be focusing their attention.
SJCA is committed to seeing that Chaco Culture NHP is protected and retains the character that makes it such an important destination in the Four Corners as a World Heritage Site. Decisions concerning CR 7950 must include Chaco Culture NHP and the very real threat of energy development projects adjacent to the park. If San Juan County and the FHWA persist in attempting to pave the Chaco Road, we will expect full compliance with the National Environmental Policy Act and National Historic Preservation Act that evaluates potential impacts to the park.
Because CR7950 is currently unpaved, the number of visitors to Chaco remains moderate. If the road is paved, not only will the remote experience for visitors be diminished, but additional visitors could severely impact the park's archeological treasures. Chaco Culture NHP is currently subject to a decreased budget which limits the number of NPS personnel in the park. In addition, there are significant infrastructure issues in the park which need to be considered.
In your letter, recommend that any road improvements should be in the form of fencing, good signs, and proper maintenance. Remind them that this would be irreversible, and allow more traffic, and safe roads can be dirt/gravel roads. Tell them that the NPS's own 2005 study showed that if the road is paved, then visitation levels could soar more than five times, overwhelming the infrastructure and staff while putting sacred sites at risk. Also request a buffer zone around the park to prevent oil and gas development permanently. Ask that full compliance with the National Environmental Policy Act and National Historic Preservation Act occur that evaluates indirect, direct and cumulative potential impacts to the park.
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