Mr. James Naegle
Utah Department of Transportation
4501 So. 2700 West
Salt Lake City, Utah 84119
Thank you for your recent letter concerning my efforts in the Logan Canyon DEIS study.
While I appreciate your comments, I find them inconsistent with your actions. After spending the better part of two years attending meetings, reading documents, checking calculations, etc., I consider it an insult not to be provided with a copy of the preliminary DEIS. It cost us (Sierra Club, Audubon Society, Utah Wilderness Association) $20.00 to duplicate the Forest Service copy, which I understand was made available to us only reluctantly and at the insistence of the Forest Service. So much for the good faith of UDOT.
I also wish to make some comments on the role of the ID team in this study. It was agreed early on that all technical memos would be approved by the team. This has not been done. It was my understanding the DEIS would be approved by the team. This is clearly not to be done. Finally, it was also my understanding the ID team would make recommendations concerning a preferred alternative. Again, this is clearly not to be done. I regard this as a breach of faith by both UDOT and CH2M Hill.
The preliminary DEIS has several major problems:
1. The Spot Improvement Alternative must be considered as encompassing all 35 spot improvements. It is a violation of NEPA requirements to present a shopping list, with UDOT selecting some number of improvements from the list at a later date.
2. In view of this, there is no environmentally acceptable alternative in the preliminary DElS except No Action.
3. NEPA requirements have not been met with respect to a range of alternatives. The Spot Improvement alternative with all 35 projects at the level described is essentially the same as Alternative C.
Unless our alternative (now in the Appendix), or a reasonably similar alternative, is included as a legitimate alternative, we will oppose all alternatives except No Action, or request that the DEIS be rejected as not meeting NEPA requirements. Legal action with respect to this request may also be pursued.
I regret the culmination of two years of effort has resulted in this situation. The environmental representatives on the ID team have repeatedly tried to convince UDOT and CH2M Hill that their concerns need serious attention. It is clear we have failed, and the present situation must be regarded as adversary. Sincerely, Jack T. Spence
Rudy Lukez, Sierra Club
Steve Flint, Audubon Society
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