Citizens for the Protection of Logan Canyon 17 June, 1987
Mr. Wes Wilaon
USEPA, Region 8
999 18th Street, Suite 1300
Denver, Colorado 80202-2413
Dear Mr. Wilson,
I am writing to express my concerns with the draft ETS 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
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 sure 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 is only a few days ago
that we got our first look at the impacts and mitigation sections
of most o' 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 placed at the edge of the Logan River. While the Terrestrial
Resources chapter admi ts 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.
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 represeniative
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 changes 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
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.
Copies: Bridgerland Audubon
Cache Group Sierra Club
Utah Wilderness Association
Stephan D. Flint
Work: 750-2474 or 752-2242
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