Devin Weder, Project Manager for the BCC EA
Utah Department of Transportation
4501 South 2700 West
PO Box 14141245
Salt Lake City, UT 84114-141245

Subject: Big Cottonwood Canyon Environmental Assessment

Salt Lake County, Utah
UDOT Project Number S-R299(489) / UDOT PIN 21400
Published Environmental Assessment

Dear Big Cottonwood Canyon Environmental Study team,

Please accept the following document as comments from the Central Wasatch Commission (CWC) regarding the published Big Cottonwood Canyon Environmental Assessment. The CWC appreciates the opportunity to provide this comment.

The CWC released the Big Cottonwood Canyon Mobility Action Plan (BCC MAP) in 2023, which was designed to identify and develop strategies to guide multi-modal transportation investments for Big Cottonwood Canyon—expanding sustainable transportation choices that support positive environmental, social, and economic outcomes. The Central Wasatch Commission was invited to submit an agency comment on the scope of UDOT’s environmental study in Big Cottonwood Canyon and did so in December 2024. In that scoping comment, we asked that UDOT include exploration into all of the BCC MAP recommendations for transit and roadway improvements for Big Cottonwood Canyon.

The proposed actions in UDOT’s EA are largely consistent with the recommendations from the CWC’s BCC MAP, however, there are notable impacts to the land and natural resources that the proposed actions would have. Over 34 acres of land would be converted to transportation use — for the gravel-pit mobility hub, the grade-separated interchange on Wasatch Boulevard, the bus transitway at the base of Big Cottonwood Canyon, the resort bus stops, the mid-canyon bus stops, and the bus priority lane around Brighton Loop Road. The proposed actions would require land acquisitions and amendments to the US Forest Service Plan.

The impacts of these needed transit and transportation improvements could be offset by future drafts of the Central Wasatch National Conservation and Recreation Area Act, which would place protections on the land, water, flora, fauna, and wildlife found within these canyons while further stewarding recreational access and providing pathways for development around clustered nodes in the Canyons.

Every function of these canyons relies on the health of the natural resources found within them. In a message to the world made in 2019, David Attenborough is quoted saying, “our economies and political systems are unconsciously predicated on the belief that nature will continue to be a benign and regular provider of the conditions we need to thrive; regular seasons, dependable freshwater, endless fish, pollinators, minerals, soil.” This sentiment is evidenced in the irregularly warm and dry ski season Utah is currently experiencing. Any impact to the natural resources found in Big Cottonwood Canyon and in neighboring mountain landscapes, even if determined to be de minimus should be offset by protective action, to ensure that we do continue to enjoy all that the Central Wasatch offers to us for years to come.

The varied nature of the issues in the Central Wasatch Mountains, and specifically in Big Cottonwood Canyon, should be reflected in a holistic approach to addressing the transportation needs in Big Cottonwood Canyon, if the intent is for these approaches to be effective. If tolling is implemented in Big Cottonwood Canyon, tolling should also be implemented in Little Cottonwood Canyon, to neutralize any toll avoidant behavior and impact on neighboring canyons. Transportation improvements should be coupled with improved land and natural resource protection. Transportation solutions for Big and Little Cottonwood Canyon should be conditioned upon the passage of federal legislation — the Central Wasatch National Conservation and Recreation Area Act. This coupling of federal legislation to transportation is necessary given the delicate balance that was foundational to the Mountain Accord agreement, based on four interdependent systems of the Central Wasatch: transportation, economy, recreation, and environment.

We thank the State for directing resources to address the transportation issues that are reaching a fever pitch in Big Cottonwood Canyon and we urge the State to act similarly to support the land and water protections the Central Wasatch National Conservation and Recreation Area Act would ensure.

Thank you for your consideration of the Central Wasatch Commission’s comments on the BCC Environmental Assessment. Accounting for the populations of the jurisdictions that comprise the Central Wasatch Commission Board, the CWC collectively represents over 1.5 million people. We hope our comments serve to support UDOT. Individual member entities of CWC may provide additional feedback to UDOT on behalf of their organizations. CWC comments may not be inclusive of concerns or comments of individual CWC member entities and reflect the mission of CWC in implementing the intent of Mountain Accord.

Respectfully submitted,

Erin Mendenhall, Salt Lake City Mayor, Central Wasatch Commission Chair

Roger Bourke, Town of Alta Mayor, Central Wasatch Commission Co-Chair

Christopher F. Robinson, Summit County Council Member

Monica Zoltanski, Sandy City Mayor

Bill Ciraco, Park City Council Member

Dan Knopp, Town of Brighton Mayor

Ellen Birrell, Cottonwood Heights Council Member

Emily Gray, Holladay City Council Member