CPLC Citizens for the Protection of Logan Canyon
May 10, 1988
Logan District Ranger
U.S. Forest Service
860 North 1200 East
Logan, UT 84321
After reviewing the maps for Logan Canyon's highway, we are submitting the following concerns, comments and questions:
The environmental community has been asked to evaluate a number of proposals within a new alternative which has never before been presented and hence subjected to close review and environmental or engineering analysis. We do not understand why our alternative (August, 1987) has not been given more consideration. We simply do not feel comfortable with this approach; in fact, the approach at this point seems to be "backwards." We ask that the Forest Service carefully consider our comments as follows:
(1) The overall process is becoming difficult to follow at this point. We really do not have a complete understanding of what is actually being proposed and how some of the newer proposals (such as moving Beaver Creek) will affect the Canyon's environment and scenic quality. We would like to see a specific list which could be shared for comment solicitation from the public. Perhaps, a new public scoping document/hearing needs to be prepared if the new highway modifications/alternatives will be seriously considered. It would be much easier to discuss the Canyon's future with a common document from the engineers; this document should be prepared before the "grand field trip" occurs.
(2) The "grand field trip" should be held on a weekend so that it is not limited to elected officials and government staff.
(3) We still want a complete and correct EIS without any gaps or factual errors.
(4) Regarding curves and associated cutting/modifications, we believe that cutting curves will simply -increase speed. We cannot accept vague notions of "improved sight distance" or "driver comfort" with regard to the proposed modifications. Also, the proposed modifications should be clearly identified on the ground and maps; at this point, we only have the original CH2M Hill maps which you have indicated may be different from new alternatives proposed by the three government engineers.
(5) The final disposition of any removed rubble from curve cutting and road realignment must still be identified and explained. Because of the costs associated with the hauling of rubble, it hard to believe that newly generated rubble would be removed to Cache Valley or Bear Lake Valley. We are afraid that UDOT would find some reason to "utilize" the rubble somewhere along the highway or maybe on state land. We have "Rubick's Pile" and UDOT's regular river filling to remind us of their past actions. This information must be included in detail, including
the economic aspects and reality, in the EIS.
(6) We still believe that proper signing, including reinstallation of the missing advisory signs, will be the most cost-effective and environmentally sound method to insure highway safety.
(7) Visual quality must not be soley considered from the driver's perspective. The perspective of all canyon uses must be carefully considered for each proposed modification, i.e. a site specific analysis should be done.
(1) Curbs and gutter: We need more details on the type, size and location of the newly proposed curbs. Our concerns include (a) the possibility of drain gratings becoming bicycle traps, (b) the possibility of new river contamination from runoff, (c) increased maintenance activity and problems, (d) increased probability of this system to fail due to heavy precipitation or lack of maintenance.
For example, the curbs and gutters in Logan have numerous problems despite regular city activities. Another example involves blacktop curbs in Capitol Reef National Park, where they are crumbling and breaking apart. If the proposed curbs and gutters do fail, they might suddenly be replaced by ahoveranxious maintenance staff at UDOT; this could result in something very undesireable. The bottom line, however, is that we simply need much more detailed information on this proposal. We cannot resolve this issue by just talking about it. We need examples,
drawings and maps, along with a discussion of the issues.
(2) Dugway: We are still opposed to a climbing lane in the Dugway. A slow vehicle turnout below Lower Twin Bridge should be considered as noted in our proposal.
(3) Upper Twin Bridge: We believe that raising the roadbed will affect the river because of the added fill.
(4) Logan Cave: How will pedestrians go from the proposed parking lot to the Cave? If the roadbed is raised, it should be done in such a way that it is moved away from the river's edge and the riparian habitat and vegetation is restored.
(5) Temple Fork Parking: We need more information, including drawings.
(6) Elk Point Bridges: We agree with the Forest Service that the proposed dual bridges for Elk Point are not needed, would damage the immediate environment, increase safety problems and affect wildlife, especially big game, who use the area in the winter.
(7) Increased Pavement Width at Tony Grove Basin: We are pleased that the 40 foot pavement width has been abandoned at this location. However, we are concerned about another "hodge podge" approach to the Canyon's highway. The highway's size through this portion of the Canyon should be as similar as possible to the highway in the Middle Canyon and Beaver Creek. We are afraid that varying the road size by as much as is proposed will convey a false impression that this is a high speed route. [From Dave's response it is clear they still want 40' pavement here]
(8) Beaver Creek: We still do not understand what is being proposed for what locations. We really need maps and justifications. At this point, it appears to be an attempt to justify a significantly wider highway which may not be needed.
(9) Multipurpose Turnouts: The current prpposals do not consider multipurpose turnouts. UDOT appears to be afraid of this idea, and we are not really sure why since they do work in other states. We have listed several possibilities in our proposal.
(10) Upper Canyon Climbing Lanes: We need more information on the proposed sizes for the climbing lanes past Beaver Mountain. We could not support a full size standard highway with a climbing lane through these upper sections. We are also concerned about potential road cuts near Amazon Mine.
(11) Limber Pine Fill: We would like to see a fill map for this curve and identify the source of the material.
Please understand that these comments cannot be complete since we do not have any specific document to look at.
Thanks for your considerations,
Sincerely, Rudy Lukez Chair Cache Group Sierra Club Steve Flint, Conservataion Com Bridgerland Audubon Society Tom Lyon, Board Member
Utah Wilderness Association
cc: Dale Bosworth
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