SIERRA CLUB Utah Chapter 93 East 1st South Logan, Utah 84321 November 21, 1979 (801) 753-0987
ARCHES NATL. PARK by Karen Vendell
Gary Lindley, Engineer
District No. 1 Engineer's Office Utah Department of Transportation
128 17th Street Ogden, Utah 84404
RE: Dear Mr. Lindley:
I have recently talked with Craig Rayle, and others concerning the proposed highway
construction activities in Logan Canyon. The Sierra Club is concerned about actions taken
to date by the Utah Department of Transportation in efforts to comply with the National
Environmental Policy Act. The purpose of this letter is to obtain answers to questions
we have about NEPA compliance decisions. A reply to the following items is requested.
1. Determination whether to prepare an Environmental Imact Statement
Section 1501.4 (c) of the Council on Environmental Quality Regulations for implementting
the Procedural Provisions of the National Environmental Policy Act (hereafter called
CEQ NEPA Regulations) reads, Federal agencies shall:
" Based on the environmental assessment make its determination whether
to prepare an environmental impact statement."
As I understand the current situation your office has determined that an Environmental
statement is not necessary for construction of the Logan Canyon Highway. However,
this decision was made prior to preperation of the environmental assessment; the assessment
is to be released in the Spring of 1980. This reversal of decisions appears to
be contrary to the CEQ NEPA regulations. Has your office decided that an environmental
impact statement is not needed for construction of the Logan Canyon Highway from Right
Hand Fork to Ricks Spring? Is the environmental assessment to be finalized in the spring
2. Finding of No Significant Impact
Section 1501.4 (e) of the CEQ NEPA Regulations reads Federal agencies shall:
" Prepare a finding of no significant impact if the, agency determines
on the basis of the environmental assessment pot to prepare a statement.
" (1) The agency shall make the finding of no significant impact available
to the affect public as specified in Section 15.6.6"
The Utah Chapter Sierra Club requests a copy of the "finding of no significant
impact" as noted above.
3. Public involvement in the Finding of No Significant Impact
Section 101.4 (e) (2) of the CEQ NEPA Regulation reads federal agencies shall:
"In certain limited circumstances, whi~h the agency may cover in its
procedures...make the finding of no significant impact ~vailable for
public review for 30 days before the agency makes its final determination
whether to prepare an environmental impact statement and before the action
may begin. The circumstances are:
" (i) the proposed action is, or is closely similar to, one which normally
requires the preparation of an environmental impact statement under the
procedures adopted by the agency... "
Did your office allow for public review of the finding of no significant impact?
When was the finding of no significant impact made? How was the finding of no significant
impact made available to the public?
4. Segmentation of the NEPA Process
Section 1508.27 of the CEQ NEPA Regulations reads in part:
"Significance cannot be avoided by terming an action temporary or by breaking
it down into small component parts ." (Emphasis added.)
The distance from Logan City to Bear Lake is approximately 40 miles. This 40
mile stretch of road includes several miles which have already been widened. The majority
of the canyon road is not widened . Your office now plans to widen a stretch
of highway approximately 6.5 miles long, from Right Hand Fork to Ricks Spring. Did your
finding of no significant impact include an evaluation of constrction planned from from
Right Hand Fork to Bear Lake, or just an evaluation of the mileage from Right Hand Fork
to Ricks Spring?
Additionally, we are concerned about Forest Service Campgrounds which are associated
with the highway proposal; specifically Wood Camp Hollow and Rick Springs campgrounds.
Did the determination that an Environmental Statement was not necessary include the
environmental impacts associated with these two campgrounds?
Any additional information you can provide which will help in understanding compliance
with the National Environmental Policy Act will be appreciated.
Because of the timely nature of this matter, a response is requested within ten
I look forward to hearing from your office. Brian Beard President Utah Chapter Sierra Club
cc: Craig Rayle
Jo Jo Jones
Anthony Ruckel Esq.
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