In the evening of October 1, two days before the deadline for public comment on the Draft Alternatives Working Paper for the Southern Nevada Supplemental Airport Environmental Impact Statement, I left the little house I am renting in the Ivanpah Valley and walked outside. The moon, a day past new, had set behind the Ivanpah Range before the sky had even grown dark, and that was some hours before I walked out. A pale glow blanketed the horizon to the north — the glare of Las Vegas and its outliers — but aside from that and a few scattered pinpoints of light, and a far-distant string of glimmers tracing the course of the interstate, the night was dark, and the Milky Way blazed plain in the sky.

I walked along the road I live on, following the northern limits of the Mojave National Preserve.

After a time, even in darkness like this, your pupils will dilate. Your eyes adjust. You begin to see in the dark. Light from the stars alone becomes sufficient for you to move around. The white line at the side of the road comes into view. The Datura’s white flowers, open at night to attract pollinating hawkmoths, become plainly visible. There is a green glint in mid-pavement: a bit of old glass refracts the headlights of an oncoming car still six or seven miles down the road.

You can also see the nearby state line, but that’s not as difficult. The little casino outpost of Primm punctuates the black with blazing red light. More than eleven miles away and it still hurts to look at it with dark-adapted eyes.

Building a new airport just north of Primm, the preferred alternative toward which this document is aimed, would brighten that spot on the horizon by several orders of magnitude. Scattered light from that direction, from Primm and Jean and Las Vegas’ burgeoning metastasopolis, already attenuates the darkness. With thousands of lights on the runway edges and taxiways, sodium-vapor lights in the parking lots, headlights on planes and passenger cars, lights shining out from the terminal loading areas and through the windows of the gift shops, and with the additional light from new commercial building in Primm and Jean the airport would almost certainly provoke, the night here would be very much brighter.

This would be an annoyance for those of us who crave darkness. For those residents of the Ivanpah Valley that rely on darkness to hunt or to avoid the hunters, for those who use pale night light to find nectar-laden flowers and are confused by artificial light, the challenge posed by the new brightness would exceed annoyance.

The valley is not wilderness, at least not that part of it outside the Preserve. There are intrusions on the night. Freight trains roar past sounding loud horn, engines both ends straining to build up momentum for the long climb to Cima. There is traffic on my road, long-haul truckers heading for Searchlight, vacationers in RVs and motorcycles heading for the Colorado River. I can hear them from several miles away. They approach. They grow louder. They pass. The noise recedes.

And then the noise ebbs, and the cricket song swells, and the coyotes’ song, the breeze, the sound of blood in your veins.

I have lived in the Ivanpah Valley only a few months. I have been spending nights in the country around it for more than a decade. In the Preserve, or in the little Wee Thump Joshua Tree Wilderness just across the low range of hills between the New York Mountains and the McCullough Range, the nights are even quieter. From Sunrise Rock on Cima Road, where I have been camping for more than a decade, you can make out the sound of the freight trains cresting the saddle at Cima if the wind is right, and if you are not having a conversation at the time. Sometimes the clattering sound of a truck’s jake brakes makes it all the way to you from Mountain Pass, just before fading completely. Away from the road in Wee Thump it is quieter still. You can hear the wing beats of ravens from a mile off.

You can also hear air traffic. At 30,000 feet, or 40,000, the engines of jets heading for or from Southern California airports are more noticeably audible than they would be in places with more background noise. Their roar is somewhat muted, but it is obvious, and it is an intrusion.

The prospect of subjecting the valley and its surround to noise from jets at tenth that altitude is a daunting one. Noise that loud would pose a severe annoyance to the human residents and visitors of the valley. The bats who still thrive here, who rely on the fine-tuned sonar to snatch insects out of the air, would likely find the noise more than an annoyance. Studies have shown that the noise of a dirt-bike engine can significantly damage the hearing of desert rodents if the biker rides once past the rodents’ burrows. Hearing-impaired small animals are more vulnerable to predators. And we would fill their valley with the noise of hundreds of jets a day, landing and taking off.

I do presume that the agencies responsible for operating and overseeing the airport would work with the National Park Service to establish flight paths which would minimize noise in the Preserve, to the extent physically possible, though likely at the cost of increasing noise in other areas with equivalent natural values such as Wee Thump and the McCullough Range’s bighorn sheep habitat.

I have, in fact, no choice but to presume one way or the other. The Draft Alternatives document provides me with no data on the matter. It does not mention the Mojave National Preserve even once. The Preserve occupies perhaps a third of the Ivanpah Valley and the Draft Alternatives document mentions it not once. The Preserve would be a factor in routine operation of the proposed airport rivaled in importance only by weather and the Law of Gravity, and the Draft Alternatives document mentions it not once.

There is no mention of the effect of noise or light pollution on the Preserve’s irreplaceable dark and silent night. There is no mention of the cumulative effect on the Preserve of burning hundreds of thousands of liters of jet fuel in the Ivanpah Valley each day. For that matter, there is no mention of the airport offering potential convenience for future Preserve visitors.

The document does not specifically mention the Mojave National Preserve even once.

This is not to say the authors of the document display no sensitivity either to the environment or the importance people place on it. For instance, in correctly ruling out an alternative airport site in the Eldorado Valley, the authors state, on pages 3-66 and 3-67:

“The potential for extraordinary community disruption exists with this alternative due to inconsistencies with the City’s natural resource conservation and growth management policies. Although no residential relocations would occur as a result of this alternative, the expectations of citizens – based on long-standing city policy – are that the Eldorado Valley Transfer Area would serve primarily as a conservation area and buffer area (from development) and development of this nature would not occur.  It is reasonable to assume that development of the airport in the Eldorado Valley would lead to induced development pressures that would also be inconsistent with … [Boulder City’s] natural resources conservation and growth management policies, leading to further community disruption.” [Italics in original.]

For this and similar reasons, the authors rule out an Eldorado Valley site as neither “feasible” nor “prudent.”

Nor do the authors dismiss the importance of more intangible human annoyance. As part of the rationale for deeming a second Boulder City site unfeasible and imprudent, the authors state (on page 3-56):

“No residential relocations would be required as a result of this alternative. However, the development of this alternative would be inconsistent with the Boulder City growth management policies described previously. This inconsistency could result in “indirect” community disruption. In other words, the surrounding community may not be directly displaced, however the development of a commercial service airport within Boulder City could disrupt the way of life citizens had grown accustomed to and expected based on historical practices and city policy.”

In the equivalent section of the document discussing the Ivanpah Valley alternative, this is the sole mention of community disruption:

“…the area surrounding the proposed airport site is vacant and no residential relocations would be required as a result of expansion.  Therefore, there is no anticipated potential for extraordinary community disruption as a result of [the Ivanpah Valley] alternative.”

And the authors’ take on the Ivanpah site’s “Unique Problems and Truly Unusual Factors,” in toto:

“A new Ivanpah Valley Airport would not result in unreasonable drive times from the hotel centroid of the Las Vegas Metropolitan Area.  Based on the existing roads serving the area, the total drive time is estimated to be 44 minutes from the hotel centroid. Part of the Proposed Action includes a “superarterial” highway with direct access from the Sloan area to the airport, easing passenger access to the site.”

There is a national park ten miles from the proposed airport, with many square miles of that park in direct line of sight of the nighttime glare and with no buffers from the intense noise, a siting whose sole precedent in the United States, a proposed airport eight miles from Everglades National Park, was scrapped because the incompatibility between airport and Park could not be overcome, and the sole Truly Unusual Factor affecting the Ivanpah Valley site is the commute to the “hotel centroid” on the Strip?

Gentlemen and ladies, this document is deeply flawed.

A week ago, just before sunset after a day of scattered small rainstorms, a friend and I got out of her car near the abandoned railroad siding known as “Ivanpah,” well within the Preserve, about 75 miles from the Las Vegas hotel centroid. We had a clear and unobstructed view of the whole valley there, at the end of the paved section of Ivanpah Road. A desert tortoise stood at roadside. We’d stopped to make sure no passing cars hit her as she tried to cross but there were no passing cars, and she had no apparent intent to cross. Unperturbed by our presence, she fell asleep as we watched. A band of coyotes began singing somewhere off toward Morning Star Mine Road. It was hard not to feel very small. The valley held an immensity of space and of time as well, humbling both in the sense of personal insignificance it conveyed and in the realization of our frightening capacity to do unintended harm.

It was one of those moments I have found surprisingly common here in the Ivanpah Valley, a place that though altered by human hands is still precious, still wild in essence, well worth being defended from further unnecessary change.