I vividly remember ascending the Sand Hills from Mt. Carmel Junction on Highway 89 approaching Kanab from the north, over 40 years ago. Reaching the crest of the “Sands,” I stopped to marvel at the beauty of Dianas Throne to the north, and White Cliffs stretching to the east. To the west, I could see the jumble of slickrock that is Zion National Park and its West Temple, backed by the Pine Valley Mountains.

In the foreground to the south, is isolated prominence of Red Knoll, and further on, the stretch of the Wygaret Terrace and Moquith Mountain ultimately dropping “over the rim” of the Vermilion Cliffs and on to the Kaibab Plateau on the horizon. All around, the undulating vegetation stabilized dunes with scenic pockets of ponderosa pine and other interesting plants punctuate the land. What a spectacular landscape!

Easy to see why our historic and notable predecessors – John Wesley Powell, Clarence Dutton, Maynard Dixon, Edwin D. Wooley – were inspired by the scene. And, in my 30 years as a resident of the area, I am still awe struck every time I cross the “Sands,” and hike or cross-country ski below the white, yellow and orange cliffs.

Now this landscape is threatened by a mining proposal that will forever alter its breathtaking and expansive beauty, its unique landforms, vegetation and wildlife, recreational opportunities, its quiet, and our limited water resources. The proposal is for strip mining sand for use in oil and gas fracking extraction in the Uintah Basin of Utah and the San Juan Basin in New Mexico.

Southern Red Sands, LLC (SRS) presently holds mineral leases on two State Institutional Trust Lands Administration (SITLA) sections in the Sand Hills area – one on T42S R7W, Section 16, encompassing Red Knoll and surrounding lands, and one on T42S R7W, Section 2, two miles northeast, and adjacent to Red (or Peekaboo) Canyon.

In addition, and not revealed by SRS in local public discussions, is that the company also holds federal mining claims spanning the two surrounding townships – approximately 48 square miles of our presently undisturbed federal/Bureau of Land Management (BLM) public lands.

The current focus of the SRS proposal is the SITLA Section 16 land. However, with the corporate investment of “millions” in mining leases and claims, facilities and equipment involved, it must be presumed that the operation will expand on more of the extensive tract on which mining claims are asserted – essentially the full extent of the Sand Hills bordered by the Yellowjacket Canyon to the west, the White Cliffs to the north, Kanab Creek to the east, and extending south of the Hancock Road.

One of the greatest impacts of the proposed operation will be to Kanab and Kane County’s water resources. All of the mined sands will have to be washed before shipment. SRS has stated that it estimates a need for 18,000 gallons of water per minute for sand washing. They speculate that they can recover/recycle 95 percent of said water, or 17,100 gallons – a highly optimistic, questionable and unproven proposition.

If this could be achieved, they would only require an initial 18,000 gallons, and then, continually thereafter, 900 gallons/minute of replenishment, for a total consumption per year of over 473 million gallons. SRS is negotiating with the City of Kanab and the Kane County Water Conservancy District (KCWCD) to provide all of its water needs, presumably via a new well(s) drilled on or nearby the SITLA parcel. (Even SRS has referred to its water needs as constituting an “obscene amount.”)

Based on City statements, that amount of water would represent an amount equivalent to 82 percent of the City’s current usage of 578.3 million gallons. The projected water use each year by SRS could provide 2,371 four-person households with their yearly water needs (based on USGS information of average use of 167 gallons per person per day in Utah).

• Why is the City of Kanab considering providing water to an industrial undertaking outside the boundaries of the City?

• Can the City and KCWCD afford to allocate so much of its precious and only speculative water reserves for the proposed purposes?

• Will a likely, and strategically planned expansion of SRS mining and processing on additional lands require even more water?

• Despite the SRS statement that Kanab City, or any water provider will face “no infrastructure costs, no wells, no piping” and SRS will simply be “plugging in as a service customer,” how SRS will get water at the SITLA site remains a mystery. Will it be flown or trucked in from the City or KCWCD? Logically, one must assume that a new well will be drilled on site.

• What will a new well, or wells, and associated process and facilities cost the City, KCWCD, and the taxpayers?

• Will the drawdown of a new well in the Sand Hills area adversely affect the groundwater aquifer and other water rights and water users in the area?

• All indications are that aquifer drawdown in the noted area will affect groundwater seepage into the Three Lakes Canyon tributary of Kanab Creek and Kanab Creek itself.

• Aquifer depletion will affect surface water flow currently used by our farmers and ranchers throughout the Kanab area.

• Riparian resources of the canyon systems could also be forever degraded or destroyed.

• If the City and KCWCD have sufficient water reserves to connect to, and fulfill SRS industrial needs, why are these entities participating in the proposed Lake Powell Pipeline at ultimate significant expense to taxpayers?

And, many more impacts are foreseen and possible:

• The degradation or destruction of the aesthetically scenic northern highway approach and exit from Kanab, and inter-park Mt. Carmel Scenic Byway.

• The loss of natural sounds and quiet away from the immediate vicinity of the highway.

• Destruction of natural vegetation on a large scale, including potential destruction of relict or unusual vegetation species such as isolated stands of ponderosa in interdunal hollows. (The BLM has recognized the relict vegetation parcels in the larger area, for protection, monitoring and study, and similar parcels arguably exist.)

• Impacts on grazing resources and permittees.

• SRS has stated that the mining process is as simple as “push[ing] back the sagebrush.” In actuality, everything – vegetation (trees, shrubs, forbs, grasses, etc.), and sand, to a reported average depth of 40 feet – will be stripped. Reclamation efforts are asserted by SRS, but this will be no easy task given the resultant exposed surface of underlying rock, or limited remnant sand depleted of organic matter and nutrients in this ecologically marginal area of shifting sands.

• Loss of “crucial” winter deer habitat (as identified by Utah DWR and the BLM) for the Paunsaugunt and Cedar Mountain deer herds; and other detrimental impacts on the deer, such as facility and trucking noise aversion, trucking “take”/kills, etc.

• Loss of important winter habitat for bald eagles (we’ve all seen many in this area); and other detrimental impacts on all eagles and other raptors.

• With likely strip-mining expansion over much of the Sand Hills, impairment of identified wilderness quality BLM lands.

• Impact and literal reduction of recreational opportunities including camping, picnicking, hiking, horseback riding, mountain-biking, hunting and OHV exploration on authorized routes.

• Increased highway maintenance and safety impacts with 192 semi-trucks per day coming and going from and to the north on Hwy. 89. (SRS has stated “four trucks an hour leaving the plant 24/7” (and of course the same number arriving), presumably as related only to northward Uintah Basin deliveries.

If, and when, deliveries are expanded to the San Juan Basin in N.M., we can presumably expect a similar number of semis rolling south and east through Kanab.)

So, what can we citizens, residents, taxpayers and public land users do?

Unfortunately, SITLA is not required to follow any public process, or environmental analysis in making land use decisions within its jurisdictional authority. Nevertheless, public communications to SITLA on its proposals or actions may have some effect.

Of course, public attention and participation in Kanab City, Kane County and KCWCD actions is warranted. Changes in water right points of diversion by these entities, through the Utah Division of Water Rights public notice and comment procedures should be closely watched, and citizen input submitted.

In addition, public attention and comment regarding BLM actions related to the frac sand mining proposals is important. Right now, BLM is inviting public comment on a request from Kane County to widen and improve the dirt/gravel road from Hwy 89 to the Section 16 SITLA parcel.

The associated, required National Environmental Policy Act analysis must include all foreseeable, connected effects – such as sand mining on SITLA and immense tracts of surrounding BLM lands – resulting even from this right-of-way request.

We should demand careful analysis by our stewards – Kanab City, Kane County, KCWCD, the BLM, and the Utah Division of Water Rights in their consideration and actions regarding this undertaking.


John Hiscock is a retired National Park Service manager, having held numerous park land management positions and assignments over his career. He frequently dealt with water rights, hydrologic research, and water system operations, public land law, and resource management.

Hiscock holds a Juris Doctor degree in law from the University of Utah, and a B.A. in History from the University of California. He has been published in various periodicals throughout his career.