CPLC Citizens for the Protection of Logan Canyon 17 June, 1987
Mr. Wes Wilson
USEPA, Region
999 18th Street, Suite 1300
Denver, Colorado 80202-2413
Dear Mr. Wilson,
I am writing to express my concerns with the draft EIS currently being prepared for the Logan Canyon highway project (US 89) through the Wasatch-Cache National Forest east of Logan, Utah. This draft is being prepared by CH2MHILL for release this summer. My hope is that the EPA will be able to intervene in the process so that an inadequate, biased document is not released to the public. I realize that this is an extraordinary request, but I feel the situation warrents attention.
Several environmental groups and a number of unaffiliated citizens are working together as Citizens for the Protection of Logan Canyon. We are attempting to make aure the draft EIS is an acceptable document when it is released. As CPLC member Rudy Lukez has already contacted
you with a number of our concerns, I will emphasize problems in the most recent drafts which we have reveived. It 15 only a few days ago that we got our first look at the impacts and mitigation sections of most of these chapters, yet CH2MHILL expects the Interdisciplinary Study Team to have completely reviewed them by Monday, 22 June. Despite the fact that no discussion has taken place on the great majority of the impact assessment part of the document, a summary chapter of the different alternatives has already been written. This chapter is clearly biased in favor of the intensive development alternatives. It scareely acknowledges any environmental impacts, even though some are reviewed in other chapters.
Clearly there will be major impacts. In several alternatives, over 7,000 feet of retaining wall is proposed for a 4.5 mile stretch of road. Most riparian vegetation will be destroyed where these retaining walls are place:d at the edge of the Logan River. While the Terrestrial Resources chapter admits some of the impacts would be obvious for decades, the summary chapter ignores this information. In addition to these retaining walls, a continuous cut into the hillside would be necessary to accomodate the wider road. Despite the fact the Wasatch-Cache Forest Plan calls for the visual "retention" of natural characteristics in the canyon, the summary chapter ignores this conflict.
2.
During the public input period it was clear that there was strong support for a "spot improvement" alternative. It was recommended that each proposed modification be examined on the basis of need, contribution to safety, and environmental impact. Increasing speed (which is all that the more extreme action alternatives would do) is not considered important by most people, although it seems to be about the only thing that the Federal Highway Administration representative is interested in. CH2MHILL has slighted this alternative. Their spot improvement alternative replaces virtually every bridge and culvert, straightens nearly every curve, and places a climbing lane in one of the most difficult sections of the canyon. Impacts are obvious but once again neglected.
This process has been continued despite our repeated mention that the Forest Plan permits only limited change to the canyon highway. The plan is very specific on this, particularly where the Forest Service responds to the public input from the draft version. At the interdisciplinary study team meetings, we have quoted from the plan, yet CH2MHILL has consistently ignored this. There are a number of other unanswered questions: in the present draft. Disposal of rubble from the many proposed cuts has scarcely been addressed; the few available locations (abandoned gravel pits and old roadbeds) will only handle a fraction of the material genetiated by the more extreme action alternatives. Erosion from the resulting cut slopes has not been addressed in the necessary site specific manner. While I could continue with examples, I think this illustrated the problems with the present draft. If they adhere to their present timetable of a summer release of the draft EIS, it is doubtful that the necessary revisions will be done. Some sections require complete rewriting. We would like to see the public receive a fair and
accurate document. This is why we are requesting your assistance. We worry that after $620,000.00 is spent on this study, there will be a feeling that it is necessary to proceed regardless of the quality of the document.
Please contact me if you have any questions.
Sincerely, Stephan D. Flint
