Dear Mr. Topham:
The Citizens for the Protection of Logan Canyon and the Sierra Club's Utah Chapter are very concerned about the current environmental impact statement which is being prepared for the Logan Canyon section of U.S. Highway 89 in, the Wasatch-Cache National Forest. This study, which I understand will be released within the next two or three months, appears to have the following deficiencies based on my client's discussions with various Federal agency personnel:
(1) The public comment period will be too short. The reported 30 day comment period will not provide enough time for citizens and organizations to prepare and present comments concerning the document. Since this study has been underway for nearly three years, and all
previous studies have been very controversial and equally lengthy, I am urging your agency to permit a 120 day comment period.
(2) The range of alternatives is not adequate. It is my understanding that your agency will not provide a complete review of the alternative developed by the Citizens for the Protection of Logan Canyon. This group has a very special interest in the future of the Logan Canyon highway and has presented its alternatives to UDOT and other agencies on a number of occasions. The Citizens for the Protection of Logan Canyon's alternative is reasonable and within the scope of alternatives required to be analyzed pursuant to NEPA and the guidelines developed by the Council on Environmental Quality. See 42 U.S.C. S 4332(C)(iii); 40 C.F.R. 1508.25(b)(2). Could you please explain why the alternative developed by the Citizens for the Protection of Logan County is not fully considered in the EIS and how your agency plans to insure that an adequate range of alternatives, as required by NEPA, is considered in the EIS.
(3) It appears that the EIS's recommendations will be in conflict with the Wasatch-Cache National Forest's current management plan. This plan has very strong provisions for the protection of Logan Canyon's ecosystem which the EIS does not apparently address. Could you please explain how your agency intends to insure that the EIS's recommendations comply with the National Forest Management Act, Pub. L. 94-588, 90 Stat. 2949 (1976) (codified in scattered sections of 16 U.S.C.) and how your agency intends to resolve conflicts between the forest plan and any proposed highway modifications.
I would appreciate a response before your agency releases the draft EIS.
Sincerely, Fern L. Shpard Rocky Mountain Office
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