The Commission’s Comments on UDOT’s LCC EIS Alternatives and Screening Report

July 10th, 2020

RE: Little Cottonwood Canyon Environmental Impacts Statement

Comments regarding Draft Alternatives and Screening  Reports

 

Dear Josh Van Jura and LCC EIS project team,

The Central Wasatch Commission (CWC) is grateful for the opportunity to provide written comments on the Alternatives and Screening Reports of the Little Cottonwood Canyon Environmental Impact Statement (the Alternatives Report). We would like to first acknowledge the tremendous effort the EIS team has put into the process to date. The team has been accessible to, and coordinated with, the CWC as we work on a parallel effort for a Mountain Transportation System (MTS). The information presented in the Alternatives Report is greatly informative and will be helpful to make decisions moving forward. We appreciate the UDOT work and recognize the challenges of developing objective, good information and analysis and the enormous scrutiny when following a NEPA process and making decisions for the Wasatch Boulevard-Little Cottonwood Canyon corridor.  Your work will serve the CWC and the communities well as key decisions are made for our MTS. 

 

The CWC is an interlocal government of nine local governments in and adjacent to the Central Wasatch Mountains. The Board consists of elected officials from those jurisdictions, including the Mayors of Salt Lake City, Salt Lake County, Millcreek City, Cottonwood Heights, Brighton, Alta, and Park City. The remainder of the Board are Council Members from Salt Lake County, Summit County, and Sandy. The CWC is an outgrowth of the Mountain Accord agreement. The Mountain Accord was a historic planning effort that achieved consensus in 2015 on the recreation, transportation, economic, and conservation solutions for the Central Wasatch Mountains. 

 

Building from the transportation principles of the Mountain Accord, in January 2020 the Central Wasatch Commission began to fulfill its mission to develop a mountain transportation system envisioned in the Mountain Accord.  The CWC believes a mountain transportation system should integrate with the regional transit system, operate year-round, and provide equitable access to recreational opportunities and economic nodes while protecting the communities, watershed, and the quality of water used by hundreds of thousands of residents downstream. To help with this effort, we’ve assembled a technical working group of mode and transportation management experts, vendors, planners, and policy makers to not only help develop the CWC’s MTS but to also aid and provide input on the EIS process. 

 

The Central Wasatch Commission is not advocating for a specific solution at this time. Like UDOT, the CWC is considering a range of alternatives without a bias or pre-conceived notion of outcomes. The process, we hope, will lead to the best possible decision. 

 

The CWC is framing these comments based on the results of scoping for the MTS that were adopted by the Board in April 2020. Attributes and objectives of a successful MTS were developed through scoping of the MTS initiative, stakeholder and public comment, and extensive Commissioner discussion. These are the same attributes and objectives the CWC will use to evaluate mountain transportation system alternatives in the coming months. Additionally, the MTS initiative takes a more regional approach, with the LCC EIS being a part of the larger regional transportation system. The CWC is also reviewing the draft “reasonable range of alternatives” in the context of the scoping, purpose and need, and screening criteria identified previously by UDOT — and our comments on those steps in the EIS process. 

 

It is our hope that the following comments and recommendations will help shape the next phase of the EIS process, as we strive to reach a consensus on a transportation solution that is so greatly needed in these mountains.

 

Comments from the CWC are outlined in the following topics in this document:

• Alignment of UDOT scope, purpose and need, and screening criteria with the CWC’s MTS initiative
• Protection of a critical environment, with particular emphasis on the watershed
• Questions regarding alternatives screening process
• A range of reasonable alternatives 
• Relationship between demand management strategies, modes, and equitable access
• Broader regional transportation needs and system integration

 

The CWC is providing a summary and examples of our comments. As a participating government in the LCC EIS, we are available to provide substantial additional detail and discussion, including the inclusion of experts, so that some of the variations we see between information and analysis can be fleshed out and reconciled.

 

Alignment of scope, purpose and need, and screening criteria

The LCC EIS alternatives have gone through an extensive process to date. Scoping, purpose and need, and screening criteria for this process were developed during the fall and winter of 2019 and public comment was accepted on the developed screening criteria. The CWC provided comments that reflected the consensus of the CWC member jurisdictions. 

There is much alignment between the screening criteria and scope of the LCC EIS and the interests and objectives of the CWC. The CWC supports the goals of improving the safety, mobility, and reliability of travelling along Wasatch Blvd and SR 210 in the Little Cottonwood Canyon corridor.

 

As noted in prior CWC comments, there are still a few important elements that CWC believes need to be considered during the EIS process. In our comments during the scoping and screening process, the CWC requested that a larger regional approach be considered in evaluating an effective result for the LCC EIS; a Wasatch Boulevard-LCC road corridor decision does not occur in isolation. The indirect and cumulative effects from the LCC EIS should address how a broader transportation system, now and foreseeable, is impacted,  A year-round mountain transportation system that serves all users, integrates with the regional transportation system, and considers watershed and water quality protection should be part of primary screening criteria for a reasonable alternative.

 

It was recognized by members of the CWC and its Stakeholders Council, and reflected in previous comments to UDOT, that a significant reduction of automobiles was necessary for the future benefit of LCC. A system needs to be designed and developed to meet current and future recreation demand, and it should be recognized that mobility, reliability, and safety needs exist beyond just one season. 

 

The UDOT LCC EIS makes the goal of reducing peak congestion times during winter a primary objective. However, while reduction of peak periods of that seasonal traffic is important, Little Cottonwood Canyon transportation serves many uses and users on a year-round basis. In addition, decisions that are made with respect to LCC will impact the numbers of users in LCC, as well as in adjacent BCC and other Central Wasatch Mountain areas. For example, we are seeing a spike in users in these mountains during COVID 19, an indication of future use and impacts that should be considered as part of the LCC EIS. All of these concerns should be considered. 

CWC believes the LCC EIS should, as part of its alternatives screening, broaden the criteria for elimination of an alternative to include impacts that could not be mitigated on the watershed or environment. Please see the detailed Salt Lake City Department of Public Utilities and Sandy City comments in this regard. 

 

Protection of a critical environment, with particular emphasis on the watershed

Salt Lake City, a member jurisdiction of the CWC (and with its partners Sandy City and Metropolitan Water District of Salt Lake City and Sandy), is the watershed manager for the Central Wasatch Mountains. Salt Lake City has legal jurisdiction within Little Cottonwood Canyon related to its water rights, watershed management, water infrastructure, and provides specialized expertise within the LCC EIS study area. The CWC shares our member jurisdiction’s concern in that waiting to apply watershed and water quality standards, until the secondary screening, risks selecting an efficient transportation model but a substandard model for water quality. 

The CWC supports SLCDPU comments regarding climate change, impacts to water infrastructure, road widening, parking, cost/benefit, and questions regarding watershed impacts from the gondola system and snow sheds.

 

Questions regarding screening process

There appear to be several instances in the Alternatives Report when the alternatives were not compared equally in the screening process. Please consider whether this was done. For example, we have received information that suggests that the cost analysis is uneven and does not use consistent life-cycle costing with the 2050-time horizon that the EIS has established. 

Another example: the starting point for indicating rail is the existing middle-of-the-Valley rail station, but the starting points for buses and aerial systems are the mouths of BCC and LCC. In addition, it is presumed in the bus and aerial alternatives that the project would occur in the roadway corridor, but for rail, the assumption seems to have been that a separate right of way would be required. It is our understanding from talking to transit experts (bus, aerial, and train) that rail could be accommodated in the road right-of-way, and that aerial might need to occur in places away from the road right-of-way. 

CWC is prepared to provide more detailed information regarding this issue, and we have seen information from the experts consulting with the CWC for our MTS that is substantially different from the analysis in the Alternatives Report. We have asked for more detailed analysis to help us reconcile the differences; to date, we have been told that the Alternatives Report represents all the information of UDOT and its consultants.

 

Range of reasonable alternatives 

There is limited information available for how UDOT applied the screening criteria to arrive at the Reasonable Range of Alternatives. In spite of that, we agree in general with the continued analysis of the three alternatives put forth in the Alternatives Report, i.e., the bus and gondola alternatives. However, we do have concerns as to why some form of a rail alternative was not carried forward for further analysis. 

From what has been communicated, there seems to be three main reasons why cog rail was eliminated. Those reasons are listed below with comments associated with each reason. 

• F(4) impacts
  • Pursuant to information provided by CWC’s consultants and partners (and prior information provided to UDOT), we believe that potential impacts may be able to be adequately addressed through a different alignment that avoids F(4) impacts. 
• Number of homes needed to be purchased 
  • The conclusion made with respect to this issue appears to have assumed that rail would not be placed in existing road rights of way. The rail analysis that CWC has seen includes options to develop rail in existing rights-of-way, thereby potentially avoiding extensive private property purchases. Further, options for buses, aerial, and associated parking all contain the potential of private property acquisition (although possibly to a lesser extent than a train option). In fact, UDOT is considering acquiring property at the mouth of BCC pursuant to a State appropriation for parking and ancillary facilities now.
• Capital costs
  • We question the accuracy of estimated costs and lifecycle costs (time horizon in EIS is 2050) and believe that the total cost for each alternative (life-cycle costs) should be evaluated equally. Experts advising CWC have provided dramatically different estimates of capital costs than are reflected in the Alternatives Report. CWC requests that UDOT re-evaluate the capital cost analyses to address these disparities.
  • As noted above, the Alternatives Report appears to rely upon different assumptions for cost comparisons of the different modes. In addition, it appears as if information provided to CWC in some cases is different from the information and analysis by UDOT’s consultants. Please consider some of the expert analyses provided by other agencies (especially UTA), mode experts (Doppelmeyer and Stadler Rail), businesses (e.g., Alpentech), and private organizations. 
  • The analysis and conclusions in the Alternatives Report differ from what has been provided by the experts advising CWC. While we see detailed numbers as conclusions by UDOT, they do not square with what our experts believe to be commonly accepted capacity and timelines for moving people by different modes. For example, buses, by the UDOT consultants’ own analyses, have a limited capacity to meet the needs in the 2050 timeframe without an unacceptable traffic condition. In addition, our expert advice suggests the availability of significantly greater rail and aerial capacity than reflected in the Alternatives Report.

Based on expert analysis provided to CWC as part of our MTS work, the CWC recommends that some form of rail system should be included in the final list of range of reasonable alternatives. Please note that this recommendation does not reflect a disagreement with the elimination of the specific rail alternatives that were considered in the Alternatives Report. Rather, it is our opinion that the Alternatives Report did not adequately consider other potentially viable types of rail options (e.g., a rail option that has a different start and end point, or an option that utilizes a different path of travel or alternate technology). CWC agrees, however, that the potential negative impacts of a rail system (as noted in the Alternatives Report), such as costs, travel time, congestion, and negative impacts on natural and built environments should be evaluated. 

While considering the alternatives, the screening process, future growth, and the objectives for the CWC and UDOT, the CWC is concerned that the projected number of automobiles in the canyons will increase over existing, unacceptable numbers for the 2050 timeline. The CWC feels the reasonable alternatives and objectives of the EIS should be more aggressive in reducing the number of automobiles in the canyon. 

The CWC is concerned about the ability of the bus alternatives to meet demand created from additional automobile reduction, and, as a result, these options’ ability to meet and maintain the reliability, mobility, and safety objectives outlined in the Alternatives Report. 

This includes accessing an aerial system via bus. It seems the aerial alternative is limited by the bus system’s capacity to deliver passengers to the base station. In the aerial alternative, only 1/5th of the maximum capacity is being met because the bus is limited in being able to deliver 1,000 passengers per hour. Other approaches to this issue, including the report issued by the “Gondola Plus La Caille” group, have a different approach that might better maximize the capacity of an aerial system. (This analysis deserves evaluation.) Furthermore, the Gondola alternative does not include a full analysis of traffic movements and parking at the Gondola station and additional impacts on traffic along Wasatch Blvd. This information would be critical before giving further consideration. 

Avalanche missions also play a critical role in the ability to move up and down the Canyon. The CWC requests that further evaluation be considered in regard to how each of the alternatives could operate during avalanche detention. For example, gondolas could not operate or have any passengers on board while avalanche crews are blasting heavy artillery overhead. Does the gondola option allow for improved access for first responders? Please continue to consider and further refine emergency access and egress for residents, visitors, workers, and first responders. 

We also recommend that UDOT consider a phased approach in its analysis. Bus options serve a purpose within a larger regional transportation structure (along with other modes and demand management strategies) and could serve a role in both short-term and long-term solutions. For example, should there be a phasing consideration (e.g., 5-10 years mitigation with longer term solution)? Early in the LCC EIS process, UDOT was embarking on short- and long-term strategies. Given the long timeframe (5-10 years) to implement any of the alternatives due to capital investment, planning, design, and operational considerations, it would seem wise to consider a phased approach to a transportation solution for the LCC EIS.

The CWC would also like to address the question of whether all alignments were considered or just roadway alignments. It is understandable from a NEPA-simplicity perspective to avoid Forest Service lands and impacts that UDOT’s consultants would try to keep all alternatives within the road right of way. However, it should be noted that the aerial alternative departs significantly from the existing roadway corridor. In addition, avoiding Forest Service lands may not result in the best transportation solution. As noted in other parts of these comments, the impacts on Forest Service lands from increasing the number of users in LCC may necessitate (and CWC would advocate should require) a consideration of impacts beyond the ski areas. CWC would suggest that UDOT and its consultants determine and evaluate the best possible alignment for each alternative that meets the purpose and need and avoids irreversible negative impacts on LCC.

A critical corridor of the LCC EIS is Wasatch Blvd. In July 2019, Cottonwood Heights, a member of the CWC, adopted the Wasatch Boulevard Master Plan which UDOT has included during the EIS process. Important aligning priorities for Cottonwood Heights and the CWC for the Wasatch Blvd. corridor include transit-prioritized roadway capacity instead of unnecessary road widening, improve multi-modal access for the surrounding neighborhoods, traffic calming measures to slow travel speeds, and improve active transportation network along corridor. The CWC shares Cottonwood Heights concerns about the impacts to the residents who live along and adjacent to the corridor and request that further analysis be prepared about mobility improvements for residents. 

 

Relationship between demand management strategies, modes, and equitable access

Tolling and parking strategies have been included in the LCC EIS process and have screened through as part of the package of range of reasonable alternatives. These strategies certainly align well with disincentivizing vehicles, an attribute outlined in the attributes in the MTS.

A top attribute of the CWC’s MTS work is equitable access. Tolling can be considered a regressive tax which takes a larger percentage of income from low-income earners than from high-income earners. The CWC is concerned that tolling SR 210 will limit people’s ability to access a National Forest. 

Additionally, all of the alternatives presented make it difficult for all users to take advantage of the transit services. In order to use any of the alternatives in the proposed Reasonable Range of Alternatives, users must use personal vehicles to access the transit services.  

The CWC is also curious to know how the alternative transit modes would be successful or not with the accompaniment of a tolling strategy. The CWC supports an analysis that considers minimizing the unintended consequences of tolling. 

 

Broader regional transportation needs

The CWC is concerned that the decisions made during this NEPA process will have an indirect and cumulative impact on the surrounding region and are not being considered. How will any of these alternatives impact Big Cottonwood Canyon? The Ikon Pass and Epic Pass allow skiers to access all of the ski resorts any day and even allow for multi-resort visits within one day. Certainly, tolling will have an impact on motorists’ decisions if they pay the toll, take a transit alternative, or drive up Big Cottonwood Canyon or to Summit County. 

Additionally, visitors and residents are increasingly using these canyons and mountains year-around. In fact, visitation to the Cottonwood Canyons during the summer is growing at faster rates than winter. UDOT should consider this reality. 

Consideration should also be given to the potential increased visitation from the south due to expected population growth. The CWC questions why a parking structure/staging area at 9400 South and Highland Drive was eliminated with respect to the aerial/bus alternatives. It is critical to consider population growth in the southern portion of Salt Lake County and Utah County.

Connections for visitors, residents, and workforce between Cottonwood Canyons and Summit County are also a critical consideration. The number of vehicles estimated coming from Summit County to LCC should not be easily dismissed as not having an impact on mobility, reliability, and safety. An opportunity to provide fast and convenient transit services between the economic and recreation nodes is crucial to improving the stated goals of the EIS.

The CWC thanks UDOT for the opportunity to not only provide comments, but to also serve as a cooperating agency. It is the hope of the CWC Board that these comments will be useful during the next phase of the EIS process. The steps taken thus far are helping move towards implementing transportation solutions desperately needed in the Central Wasatch Mountains. It is imperative that stakeholders, policy makers, land managers, and visitors to the Wasatch Mountains receive excellent information and fair evaluation to provide meaningful feedback on potential transportation solutions. The CWC greatly values and is thankful of the work done to date by the EIS team. We look forward to continued collaboration and cooperation during the LCC EIS process.

 

Sincerely,

Chris Robinson

Central Wasatch Commission Chair, and Summit County Councilmember

Cc:

Jenny Wilson, Salt Lake County

Mike Peterson, Cottonwood Heights 

Erin Mendenhall, Salt Lake City

Jeff Silvestrini, Millcreek

Jim Bradley, Salt Lake County

Marci Houseman, Sandy City

Andy Beerman, Park City

Harris Sondak, Town of Alta

Dan Knopp, Town of Brighton

Ralph Becker, Central Wasatch Commission Executive Director

Blake Perez, Central Wasatch Commission Deputy Director

Lindsey Nielsen, Central Wasatch Commission Communications Director

Kaye Mickelson, Central Wasatch Commission Administrator

 

The CWC initiated a parallel effort for a Mountain Transportation System (MTS) in January 2020, and is not advocating for a specific solution at this time. Like UDOT, the CWC is considering a range of alternatives without a bias or pre-conceived notion of outcomes. The graphic below lays out how UDOT’s LCC EIS and the CWC’s MTS processes both intersect and differ.

Read more about the Mountain Transportation System Process here.