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A NEWS BULLETIN FROM LOGAN CANYON COALITION
Vol. 1 No.1
March 1, 1995
LCC IS FORMED
If the Utah Depart"Until UDOT has lived up to the
ment of Transportati on
has its way, the na tural
law of the land and provided
beauty of Logan Canyon
truthful analysis and documentaas we know it may soon
be just a picture on a
tion, we (LCC) will be persistent
postcard. Instead of a
in our demands for justice,"
serene mountain byway,
- Kevin Kobe, LCC President
U.S. Highway 89 will be
a high-speed traffic corri dor Hned by scarred hill - spectacular scenery.
and along the Dugway to
We believe that the
sides, reta ining walls,
stem erosion problems.
and c1earzones. UOOT
recent compromise made • Vague wording about
would like to begin work beh¥een Citizens for the
how c1earzones will be
as early as this summer.
Protection of Logan
treated , with c1earzone
Canyon and UOOT is
That's why we have
a reas compri sing up to
unacceptab le. It is merely 22 feet on either side of
formed the Logan
Canyon Coa lition. LCC is a slightly watered down
the road, and the
removal of "su bstantial
version of the Preferred
mad e up of "old timers"
Alternative.
haza rds" within the midwho have been involved
The extent of the con- dle canyon.
with the Logan Canyon/
UDOT issue almost from struction planned will
• Revegetation of mature
the beginning, as well as
still necessitate 15-20
trees and shrubs that
newcomers who advoyears of work, and will
"could require 30 to 50
completely change the
years or might never
ca te a common sense
ambiance of the canyon.
occur aga in."
approach to road
Some of our priority
• A potentially devastatimprovement-one that
ing impact on cutthroat
combines safety, efficien- concerns are:
and brown trout popula . Eight curve cuts
cy and environmental
planned for the middle
tions due to extensive
sensitivity. LCC is dediriprap nea r the bridges,
canyon, along with
cated to keeping Logan
retaining walls in some
River a wild, free flowing UOOT's suggestion that
locations, and permanent
use of cement retaining
river, preserving wildlife
walls would be appropri- problems with sedimenhabitat, and protecting
tation near
ate in the middle canyon
Logan Canyon's
steep curve cuts.
-Two-hundred year-old
Douglas Fir at the summit replaced by a mini mum of 47 feet of pave.
ment, a nd realignment
that will necessitate filling a small side canyon
with debris.
• Extensive widening,
with half of the middle
canyon widened from 26
feet to 34 feet, and the
remaining 24 miles
widened to 40-47 feet to
accomodate higher
design speeds.
• No specifics as far as
mitigation plans, with a
vague promise to use
UOOT's "best management practices."
LCC has pledged its
resources towards pursuring every available
legal op tion. If we pursue litigation, we will
need your support.
Volunteers are needed .
Money will also be needed-litigati on is very
costl y. Please plan on
donating generously!
This is our last opportunity for action.
�LCC Prepares for Forest Appeal
In its effort to per-
suade UDOT to take
another look at the
Conservationist's
Altema tive, the Logan
Canyon Coalition is
working hard in preparation for the Forest
Appeal.
After the recent
approval of the Record
of Decision (ROD) by
both UOOT and the
Federal Highway
Administration, the
last phase of the
process currently rests
with the Forest Service.
This agency's approval
is widely expected, followed by a 45-day
comment period for
public input. Lee
plans to exercise its
legal right by appea ling the Forest Service's
decision.
The Forest Service
is required by the
Wasatch-Cache Forest
Plan to retain the aesthetic and environmental qualities of the
canyon. The Plan will
need to be revised due
to excessive impacts
which would result
from the Preferred
Alternative. A Forest
Plan revision will
require public input as
manda ted by the
NEPA process. Lee
Logan Canyon
Coalition plans to exercise its legal right by
appealing the Forest
Service's decision.
will base its appea l on
the expected Forest
Service decision and
key concerns not adequately addressed by
the FEIS.
as federally threatened or endangered
species. Neither the
Forest Service nor
UDOT have s urveyed
to identify the presence or absence of
these species.
These points include
the following:
1) UOOT has never
clearly demonstrated
the purpose and need
for the project, as
required by NEPA.
4) UOOT's analysis of
the safety data is
admittedly flawed .
5) UOOT has more
flexibility in AASHTO highway design
recommendations
than it acknowledges.
2) The Logan River is
among the top 5% of
all stream fisheries in
the state, yet the FEIS
seriously underestimates the impact to
fisheries.
6) The canyon is the
number one tourist
attraction in the
Bridgerland area, yet
the FEIS fails to
address long-term
negative economic
impacts resulting from
20 years of construction and loss of scenic
values.
3) There are several
species which may
occur in the canyon.
These species are
either listed as sensitive by the Forest
Service or are candi
dates for classification
2
1) The Forest Service
plan mandates retention of the canyon's
visual and aesthetic
qualities. Under the
Preferred Alternative
this mandate would
be violated.
These and other
concerns represent a
legitimate foundation
on which to base our
appeal. If you have
any additional concerns which warrant
consideration, please
contact Lee ASAP.
Thank you.
�=-= = ------- _ _ _ _ '=-"'I'"
-
:--
Economic Benefits or Disaster?
Utah's wide geographical diversity and
expansive open spaces
have filled a void in a
time when many of o ur
wild places are rap idly
falling prey to u rban and
economic sprawl. This is
resulting in a boom in
tourism.
Tourism revenues for
Cache and Rich Cou nties
alone amounted to well
over $64 million in 1993.
This success can be pa rtly attributed to p romotional efforts by the
Cache Chamber of
Commerce, which recognizes Logan Canyon as
the number one attraction in Bridgerland. The
Chamber's 1994 Cache
Valley Utah publica tio n
mentions Logan Canyon
no less than 20 times in
the firs t nine pages.
In addition, the
Bridgerland Travel
Region recently received
a $436,000 federal grant
to promote Logan
Canyon and educate visitors about its characteristics. Clearly the canyon
has a wide base of support and aCknowledgement in terms of value
to the region.
"We look at it as a
real asset to the community," says Marty Spicer,
real estate broker fo r
Coldwell Banker.
But will the canyon
lose its d raw as it undergoes 15 to 20 years of
construction, destructio n, and transformation
of its natural character?
How many moto rists
will p refer the Idaho
route to Yellowstone versus waiting in d usty
traffic for heavy equipment to pass? Will pe0ple still want to d rive to
Garden City to view
Bear Lake and enjoy a
raspberry shake?
Mo re importantly,
will the increase in con-
gestion and traffic
speeds after completion
of construction have a
d etri mental effect on the
canyon's appeal? The
stark reality may be yes!
But still the FEIS provides no assessment of
negative economic
impacts resulting fro m
the highway project. We
need more proof, not
vagueness and ambig ui-
Volunteers Needed
1- Research for Forest
Service Appeal
2- Networking
3- Fundraising
4- Education
5- Mailings
6- Letter writing
7- Events
8- Media relations
9- Passing the word
10- Lega l assistance
11- SLC contacts
12- HELP!
ty.
These are all legitimate concerns which
need to be add ressed
without prej udice and
assumptions. Wha t may
look like a road to economic boom may
become a path to economic disaster.
Equipment Needed
1- Offi ce space
2- Voice mail
3- FAX machine
4- Copier
5- Postage stamps
6- Copy paper
1- Envelopes
8- MONEY'
r------------------------,
YES! I
THE
WANT TO JOIN
LOGAN CANYON COALITION
and receive a subSCription to CANYON WIND
$20.00 Annual Membership
I would like to contribute an additional
$10
$20
$30
$40
$50
Lots more
I would like to volunteer.
I'm broke! Here's five bucks.
Name ______________________________
Street ______________________________
City _ _ _ _ State _ _ _ Zip_ _
Phone
* _____________
_
Plnse make check payable and mail to:
Logan Canyon Coalition
USU Box 1674
L ________
________ .J
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USU Boxll1674
Logan,
Utah 84322-0199
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.---- -- - - - --- -- - -- ---- -- - - --- -- - - --- -- -- - --- - - - - ---- - - ----- - ----- - - - -- -- --- -- - -- - -- -- - --- - - - -- ---A NEWS B ULLET I N FROM LO G AN CANYON COALITION
Vol. 1 No.2
A ugust 1, 1995
USFS Abandons Logan Canyon
LCC Appeal Denied
The Loga n Canyon
Coal itio n (LeC) recent ly
appealed the Forest
Service's decision to
allow the Uta h
Department of
Transporta tion (UDOT)
to construct its "modified" Prefer red
"This unfortunat e decision by
the Forest Seroice has left us
with only one
alternative . .. litigation"
- Tom Lyotl , LCC
A lternative in Logan
Canyon. We were joined
in our appeal by the
Utah Rivers
Co nservation Co uncil.
OUT ex tensive ap pea l
was 187 pages long, and
cove red a ll aspects of
UOOT's proposal. V\e
arg ued that UDOT has
not demonstrated the
purpose and need fo r its
construction p roject, and
that they have not ade-
quately disclosed the
environmenta l impacts of
their project. In June the
Forest Service denied o ur
ap peal.
Comments agai nst
our appeal, and in favor
of UOOT's project, were
submitted to the Forest
Service by UDOT, the
Cache Chamber o f
Co mmerce, a nd Citizens
for the Protection of
Loga n Canyon. The letter
from the chamber
emphasized the value of
Logan Canyon as a major
trucking ro ute.
It is remarkab le that,
given the many poin ts
we raise in ou r appeal,
the Fo rest Service up held
none of them. Their
review of our appea l is
brief and superficia l,
with inad equate respo nses to critical issues.
Without due consid eration, the Forest Service
has ru bber-stamped
implementaton of an
unnecessa ri ly ex pensive
and destruc tive h ighway
p roject.
The Forest Service is
in fact responsi ble fo r
ensuring tha t p urpose
and need fo r construction have been demonstra ted. They are also
responsib le fo r ens uring
that enviro nmenta l
impacts have been adequately assessed, incl uding d amge to scenery,
fis heries, wildli fe, wet1 nds, and the potentia 1
a
Wi ld a nd Scenic status of
the river. This responsibility is cl ea rly stated in
the Wasatch-Cache Forest
Plan and in federal law.
In shirking its responsibility for Logan Canyon,
the Forest Service is v iolating its mand ate and
acting iIIega ll):
LCC is cu rrently ga thering fund s for our lega l
d efense of Logan
Canyon. All co ntributio ns are welco me a nd
w ill be used for legal
costs. All who are interested in helping in ou r
effort to save Loga n
Can yon are invited to
contact us.
A pp eal H igh lig h ts
LCe's appen l is avni/able in the Lognn City
Library nnd USU's Merrill
Library.
(1) UDOT's highway
sa fety analysis utilizes
arti ficially infla ted and
manipulated traffi c volumes, inconsistent with
UOOT's own traffic
(continued nexl " age)
�Appeal ("", Unu"')
counts, in an attempt to
make the previously
widened portion of the
road, the Lower Canyon,
appear safer than the
unwidened sections.
UDOT's proposed construction will in fact
make the highway less
safe.
(2) The difference in
average travel time
between UOOT's
Preferred Alternative and
the Conservationists'
Alternative is, by
UDOT's admi ssio n, less
than 10 minutes! We
question the much
grea ter cost and enviro nmental impact of the
Preferred Alternative
given such a minimal
difference in travel time.
(3) In its highway
design for the Upper
Canyon, UDOT is not
taking advantage of the
fl exibility in road design
allowed by AASHTO
(American Association of
State Highway and
Transportation Officials).
Throughout the canyon,
UDOT has designed the
highway in an arbitrary
and capricious fashi on,
with little environmental
sensitivity.
(4) The Forest Service
has agreed that the segment of the Logan River
from Lower Twin Bridge
to Beaver Creek might
possess mo re "outstandingly remarkable values"
than any other river in
the Wasatch-Ca che
Forest. The Forest
Service has agreed that
this segment should be
reevaluated. for protected
Wild and Scenic River
status. We are concerned
that construction of
UOOr's Preferred
Alternative will degrade
this river segment
enough that its classification will be lowered. It
may no longer qualify
for Wild and Scenic status.
(5) There is no scientific justification whatsoever for UOOT's claims
that trout pop ulations in
Logan River will be
reduced only 4 to 8%,
and that the effects of
increased sedimentation
in the river will be "relatively minor and short
term." UDOT's claims
represen t uneducated
"guesstimates" of fi sheries impacts because of
the lack of adequate data .
(6) The WasatchCache Forest Plan mandates that negative economic impacts of highway construction be
eva luated. This has not
been done.
(7) The Forest
Servi ce's assessments of
impacts to sensi tive
species often rest on
inadequate surveys and
bald assertions that are
either patently false or in
need of substantiation.
(8) Vi sual quality in
Logan Canyon will be
impaired in a manner
inconsistent with guid elines contained in the
Fo rest Service's Logan
Canyo n Scenic Byway
Corrido r Management
Plan. USFS management
policy for Logan Canyon
is inconsistent from document to document.
(9) In its selectio n of
specially-protected 4(f)
properties, pursuant to
the Department of
Transportation Act, the
Forest Service has acted
in an arbitrary and capricious fashion. No rationale is provided for why
some sites were selected
while others of equal
recreational value were
not.
We Request:
Logan
Canyon Coalition
is not trying to stop
all construction in
Logan Canyon.
(1) There must be
honest and straightforward NEPA d ocumentation of the need for, and
the environmental and
economic impacts of, any
proposed highway constructio n. UooT has not
provided this. UDOT
has in fact admitted that
their safety data is
"garbage" and that it
"may be problematic."
(2) The construction
proposal should be
scaled down so as to proteet the sensitive areas of
the canyon and river,
particularly throug h the
upper Midd le Canyon,
Beaver Creek, and the
summit.
(3) UDOT has never
fairly eva luated the
Conservationist's
Alternative.
This Alternative should
be honestly and straightforwardly reconsidered .
2
The Conservationists'
Alternative is far less
expensive and environmentally destructive,
while improving safety
and level of service of the
highway.
(4) The Forest Service
must reevaluate the eligible segment of the Logan
River, from Lower Twin
Bridge to Beaver Creek,
for protected Wild and
Scenic River status,
befo re constructio n is
allowed. Thi s request is
in compliance with 5(d)
planning requirements of
the National Wild and
Scenic Rivers Act .
�August ] , ]995
Lee Fundraiser a Success
By Kevin Kobe
The Logan Can yon
Coali tion would like to
thank all those who were
involved with our
fund rai ser weekend with
Rick Bass and Terry
Tempest William s. \Ilk
would specificall y like to
thank The Grapevine
Restaurant, Slanting Rain
Graphic Design, A Book
Store, the Utah Rivers
Conservation Council
and Director Zacha ry
Frankel, Scott Smith
Photography, mu sicians
Nadene Steinhoff, Chris
Carlson and Joe Farmer,
and of course, nationally
renown authors Rick
Bass and Terry Tempest
Williams. Rick was kind
enough to travel from
northern Montana. O ur
thanks also goes to the
many vo lunteers who
spent countless hours
working to make the
weekend a success, espe-
dally Don Hickman and
Dan Miller.
For those who couldn't make the weekend
events, which were May
11-14, here is a rundown.
Rick Bass spoke in Salt
Lake City at the
University of Utah Fine
Arts Auditorium sponsored by the Utah Rivers
Conservation Council.
Rick spoke about the signifi cance of Logan
Canyon and the absurdity of the current UOOT
highway proposal.
Following Rick, the audience clapped and sang to
the music of Nadene
Steinhoff, Chris Carlson
and Joe Farmer.
Despi te the rain and
unseasonably cool
weather, Rick Bass and
Tom Lyon jo ined some
LCC board members o n a
field trip up Logan
Canyon on Saturday
where film makers were
doing a documentary on
the canyon. This documentary will be shown
on the local cable channel. Rick also managed
to squeeze in time to
speak with local high
school students and to do
a radiO interview.
But the night everyone was wa iting for was
Sa turday night, May 13,
when over 300 people
packed the Eccles
Conference Center.
Longtime canyon advocate Tom Lyon emceed
the event with inspiring
introductions and words
of wisdom. Rick Bass
was humorous but eloquent as he talked about
his years in Logan. Two
Logan Canyon so ngs
from Nadene Steinhoff
and friends hit home,
especially "U.S. 89 Blues"
in which the crowd
erupted with hand clapping, si ngi ng and shouting. Terry Tempest
Williams brought the
evening full circle with
words to motivate people
into action. She recognized Tom Lyon for hi s
efforts, which range from
teaching to advocating.
She recalled conversations with environme nta l
activists that continue to
provide inspiration for
her work. The night
ended with a raffle, great
homemade cooki es and
refreshments, book signings, and a T-shirt and
book sale.
Sunday morning the
Grapevine Restaurant
lived up to its reputation
for excellence at ou r
fund raiser brunch. Chef
Bill Oblock o utdid himself at the sold -out event,
and LCC vol unteers
worked hand in hand
with the gracious staff of
the restaurant to make
the brunch successful. It
was a "stay as long as
you want" kind of morning .
.
130 Nonh 100 East
Logan UT 84321
753-9089
100% for Logan Canyon
�The History of a Highway
Editors note:
This information was
compiled by Nadene Steinhoff
and Steve Flint.
---1959---
Chamber of Commerce.
The State Department of
Fish and Game launched
a formal protest against
the plan. Their protest
was later modified.
ject. The Forest Service
insisted on additional
modifications. UOOT
abandoned the project
for the time being, hoping the Chamber of
Commerce and construction interests would continue the fight for public
support.
1960---
The Utah Department
Bulldozers began
of Transportation
work. The first section
(UDOT) completed
called for widening of
"improvement" plans for the road, passing lanes
the first section of the 39- and stream channelizamile highway from
tion. Construction was
Logan to Bear Lake.
completed up to the
Engineering standards of Malibu Campground.
the time dictated that the
1961
route be as straight and
Plans to reconstruct
direct as possible. It was the section from Malibu
also felt that it was too
Campground to Right
expensive to avoid the
Hand Fork were
Logan River. At that
released. After seeing
time, most highway
the destruction in the
departments didn't feel
first phase, the public
justified spending public was much more responmoney to protect aesthet- sive, writing a barrage of
ic values or environmen- letters to the editor and
tal resources.
to UDOT.
During the first
The Forest Service
phase, Logan residents
and the Utah State
were silent. Public hear- University (USU) College
ings were poorly attendof Natural Resources
ed" except by supporters
issued position stateof the project such as the ments opposing the pro-
calling for extensive
straightening and eightfoot shoulders.
An article in National
Parks magazine condemned previous construction in the canyon
and the new design proposal.
1970 - - -
- - - - 1963 - - - -
Twelve USU professors formed the
zine advocated protecNorthern Utah
tion of the canyon in an
Environmental Advisory
Committee. The group,
article.
---1968--led by fisheries biologist
UOOT decided to
William Helm, was conaccept the Forest Service
cerned about additional
requirements, and came
impacts. At their suggesback to finish the first
tion, UOOT incorporated
phase, but when the bull- an Environmental
dozers moved in it
Steering Committee,
looked like the same "cut gave scenic consideraand fill" job. The intitions higher priority, and
brought a landscape
mate, gently winding
road under arching trees . architect onto the project.
became a fast, wide
UOOT still lacked
asphalt highway.
permission from the
1969--Forest Service, but
A public hearing was
attempted to rush the
held for road reconstruc- project through before
they lost available fundtion from Right Hand
ing.
Fork to Ricks Spring,
National Parks maga-
Adventure 1
Sports
4
�August 1, 1995
Their assertions that
the project was necessary
for hig hway effici ency
and safety were refu ted
by the USU co mmittee,
which claimed that the
safety data was inadequate.
- - - 1971 - - -
The USU co mmittee
succeeded in d elayi ng
the project, ci ting the
need for more information on traffic, tourism
and fisheri es. There was
discussion of the need
fo r an Environme ntal
Impact Statement (EIS)
under the new Na tional
Environmental Pol icy
Act (NEPAl.
UDOT presented a
second proposal. This
was also co nsid ered
u nacceptable by the USU
g roup. The plan called
for extensive cu rve cutti ng through the middle
canyon, elimination o f
picnic and campground
areas, and retaining
walls al ong large sections of the river.
The Forest Service
1987
The Interdisciplinary Team was dis solved by UDOT officials, who were
uncomfortable with public input.
issued an Enviro nmental
Analysis Report on the
project, outlining 20
requirements UDOT
must comply with .
In the face of strong
public o ppositi on a nd
new Forest Service
req uirements, UDOT
scrapped their plans.
They shifted thei r focu s,
and funds to Provo
Canyon.
- - - 1974 - - -
UDOT set up a trai ler
in Logan Canyon and
Ga rden City to distribute
informatio n about their
eventual plans.
1976 - - -
UOOT issued a Route
Analysis Statement, indicating a need for reconstructio n. It included
eight different alternatives. UDOT's recom-
mended action included
shoulders a nd passing
lanes in the middle
canyon, and correctio n of
"substand ard" curves.
Sharp publiC criticism
was directed at UDOT,
wi th Bridgerland
Audubo n Society,
Ci tizens for the
Protection of Logan
Canyon (CPLC), and the
Cache Sierra Club questioning UOOT's stati stical analysis. UDOT
pushed ahead. Analysi s
was begun for an (E IS).
- - - 1979 - --
UOOT presented
their latest proposal for
reconstruction of the
road from Right Hand
Fork to Ricks Spring.
They claimed that the
massive p roject would
require minimal enviro n-
mental ana lysis, saying
that a less d etailed
Environmental Analysis
would be sufficient,
rather than an EIS.
CPLC, a group that
had begun in opposition
to development plans in
Stump Hollow, revived
to fight the road d evelopment. Gunn McKay,
Rep . for Utah's Di strict 1,
went to bat for preservation of the ca nyon.
Tom Lyon and Dianne
Siegfreid visited w ith
regional Federal
Highway Admini stration
(FHWA) offi cials in
Denver to press the
argument that the project
required more ex tensive
analysis. The FHWA
agreed and informed
UDOT that it must prepare an EIS in accordance with new NEPA
requirements.
UDOT was not financially prepa red to take
on a full-b lown environmental analYSiS, and
retrea ted . Between 1980
(continued nat page)
�History
(,on lin,"')
and 1986, UDOT made
periodic visits to Logan
offering modifi cations,
but community activists
still believed the plans
were too excessive.
- - - 1986 - - -
Funding for an EIS
was authorized . CH2M
Hill was hired to do the
analysis.
An Interdiscip lina ry
(10) Team began meeting. Env ironmental
interests were re presented by Steve Fl int, Bill
Helm, Rudy Lukez, Tom
Lyon and Jack Spence.
- - - 1981 - - -
before UDOT dissolved
the group.
Action Force.
- - - 1990 - - -
Steve, Bruce and
Shawn Swaner began
meeting.. again, with
UDOT to forge a compromise and avert lega l
action.
Steve and Bruce felt the
need to move on. A new
steering committee was
appointed fo r CPLC. The
new steeri ng committee
held additional meetings
with UODT.
Audubon magazine
gave coverage to the controversy in a feature article by nationall y re nown
autho r Rick Bass.
- - - 1994 - - -
UOOT issued their
Draft Environmental
Impact Statement (DEIS).
Letters in the OEIS ran 21
in favor of the Modified
Standard, similar to the
Preferred Alternative, as
opposed to 309 in favo r
of the Conservationists'
Alternative.
- - - 1991 - - -
Steve a nd Bruce continued to amass technical
experti se on the project.
They hired enviro nm ental lawyer Jeff Appel.
Jeff's co rrespondence
with UDOT bro ught a
more conciliatory stance.
Negotiations began.
A public relations
effort was begun, with
ten thousand brochures
sent by local activists.
- - - 1995 - - -
UOOT released its
Reco rd of Decision
(ROD) favo ri ng the
"mod ified" Preferred
Alternative. CPLC and
UOOT declared the ROD
a compromise. A new
highway design advisory
team was formed, with
CPLC rep resentation .
Logan Canyon
Scoping meetings
held by UOOT drew 400
citizens, with many
attendees leaving due to
lack of room. Project
planners received 200 let- - - 1992 - ters from an aroused
Nadene Steinhoff and
public.
The 10 Team was dis- other volu nteers organized a Hands Across
solved by UOOT offiThe Canyon rally. The
cials, who were uncomevent, attended by over
fo rtable with public
400 people, was covered
input.
by regional and state
Area citizens submitmedia.
ted the Conservatio nists'
The following week,
Alternative, a proposa l
calling for wider bridges, UOOT approached
Bridgerland Audubon
reconstruction of cu lwith a proposal for
verts, three passi ng lanes
renewed negotiations.
in the Upper Canyon,
1993
paved parking areas,
UDOT released their
road rea lignment at the
Lower Twin Bridge, slow Final Enviro nme ntal
Impact Statement (FEIS).
vehicle turnouts, raised
Hundreds of letters were
road beds in nood areas,
sent protesting the excesimproved intersectio ns
sive plans. Petitions
and increased signage.
were sent by the
- - - 1989
Audubon Society,
Steve Flint and Bruce
Business People for the
Pendery were appointed
Canyon, CPLC, the
to a Citizen's Advi so ry
Cache Sierra Club, and
Team formed by UDOT.
the Loga n Environmental
Two meetings were held
6
Coalition (LCC), spearheaded by Kevin Kobe,
was formed to seek further modifications
through the Forest
Service appeal process.
The Forest Service
released their ROD supporting UOOT.
LCC and the Utah
Rivers Conserva tion
Council submitted a 187page appeal to the Forest
Service. The appea 1 was
researched and authored
by a dozen people, and
edited by Gordo n
Steinhoff. Requested
relief included adequate
NEPA documentation,
and further protection
for the Middle Canyon,
Beaver Creek and the
s ummit.
The Forest Service
denied LCe's appea l,
refUSing to add ress critical issues.
Logan Canyon
Coalition is curren tly
making plans to take
legal action.
�Au g u s t 1 , 199 5
Westwater Canyon
Run the Rapids with LCC
It's true Logan
Canyon CoaJition membershi p can be fun. We
don' t believe in all work
and no play.
Frida y, August 18
th rough Sunday, Aug ust
20, we will r un the
Westwater section of the
Colorado River, locatednorth of Moab.
O Uf
fea rless Lee
leader /p resident, Kevin
Kobe, has said that
Westwater has "some of
the best w hite water in
the state." Kevi n and
his sister Bri dget are
organizing the trip.
Kevin feels that Lee
shou ld be more than a
group that works together, but can be a grou p
that "has a fee li ng of
commun ity and fri ends hi p."
A WORLD
Or: A RT A tJD
Lee plans to fl oat
willing to make the
drive, please let us know
when you register. On
receipt of your registration fee, a confirmation
will be sent which will
incl ud e the date, time
and location of the pretrip meeting.
All participants will
be asked to help in meal
and camp preparation,
and, of course, everyone
needs to know how to
swim!
Westwater early
Saturday morning, set
up camp', and hike and
exp lo re the side canyons
around the campsite.
Sunday the rapids
should be rambunctio us.
The cost is $30 for
LCC members and $50
for non-members (making thi s a perfect time to
join!). The trip will be
limited to 20 individuals,
and oars are being fill ed
rapidly. The cost
includes food o n the
river, the permit and
g roup equipment. It
does not include transportation, food for the
trip to and fro m the
river or personal gear.
Ca r pooling w ill be
arranged during a planning meeting. If you are
Registration:
Please send you r registration money to Logan
Canyo n Coa lition, USU
Box #1674, Loga n, UT
84322-0199.
ComcTlo tJ
IUIAl:
vcents
7SS·S497
11·6
7
Volunteers
Needed
1- Networking
2- Fundraising
3- Education
4- Mailings
5- Letter writing
6- Events
7- Media relations
8- Passing the word
9- SLC contacts
10- HELP!
Equipment
Needed
1- Offi ce space
2- Voice mail
3- FAX machine
4- Copier
5- Postage stamps
6- MONEY!
�r------------------------,
YES! I
THE
WANT TO JOIN
LOGAN CANYON COALITION
and receive a subscription to CANYON WIND
o $20.00 Annual Membership
o I would like to contribute an additional
$10 $20 $30 $40 $50 Lots more
o I would like to voulnteer.
o Here's $12.00 for a great T-Shirt.
o I'm broke! Here's five bucks.
Name,__________________________________
5Ireel_______________________________
City _ _ __
_ _ _Zip _ _ __
Phone#'_ _ _ __
PlUM make check payable and mail to:
Logan Canyon Coalition
U5U Box *1674
L ________________________ J
Logan, UT 84322-0199
LCC T-SHIRTS - 512.00 (three colod
m.. Re;rcled
BULK RATE
u.s. POSTJlGe
Paid
COA.LJl:TJl:ON
Workl", fo r Ih'
of Lo,a" Ca n yo n
USU Box #1674
Logan, Utah
84322-0199
"""'" UT
I'tnrril N'JJJ
�- -- -- -- --- --------.- --- ----- -- - ------ - --- --- ----- - - - - - -- - -- ---- - --- - --.-. - - - - - - - .,. --.aT __ -.-.w--.aT
•
-- ----- ----------
---
-------
___ ..- -.----.aT ____
- - -- - - ----
A NEWS BULLETIN FROM LOGAN CANYON COALITION
August 1, 1996
Vol. 1 No.3
FEI S Violated
UDOT Unveils Plans
The Utah Depa rtment
of Transportation
(UOOT) has u nveiled its
d esign plans for Bu rnt
and Lower Twin Bridges
in Logan Canyon. With
these plans, UOOT is
already in v iolation of its
Final Envirorunental
Impact Statement (PElS)
and its Record of
Decision. UOOT is now
planning extensive
w idening, cuts into the
mountainsides, and
retaining wa lls that were
not disclosed in these
environmenta l documents. The brid ges and
app roaches to the
bridges have not been
d esigned in an environmentally-sensitive fashion. A strong response
has been sent to UOOT
by our attorney, Kate
Zimmerman.
UOOT is now applying for the construction
permits it needs from the
state Division of Water
Rights and the Corps of
Engineers. The Logan
Canyon Coalitio n (LCq
will submit comments to
these agencies and to the
Design changes at this late date,
after opportunities for public
input have closed, is a v iolation of
the letter and the spirit of the
National Environmental
Policy Act (NEPA)
- Lee Altornty, Kau ZinrmernuHI
Environmental Protection Agency. We are asking for a less d amaging
construction proposal,
one that allows for needed highway improvemen ts w hile p rotecting
the canyon's scenic and
environmenta l resou rces.
We continue to raise
funds for the lega l action
we believe is inevitable.
The Record of
Decision sta tes that
"design and posted
speeds wiJI be 35 miles
per hour" in the upper
middle canyon (from
Lower Twin Bridge to
above Ricks Spring). Yet,
at the bridge d esign
workshop in February,
Rod Terry, UDOT project
manager, ind ica ted tha t
the brid ges and
approaches in this area
have been designed for
40 miles per ho ur.
Apparent ly, driv ing time
throug h the canyon has
been a major factor in
the perceived need to
reconstruct the high way,
even thoug h estima ted
savings in travel time are
quite minimal. "Changing design speeds at this
late date, after opportunities fo r p ublic input
have closed, is a v iolation o f both the letter
and spiri t of the National
Environmenta l Policy
Act," Zimmerman said.
Des ig n plans show
Burnt Bridge being
w idened on the downstrea m side. Cuts into
the mo unta inside up to
750 feet long are now
planned both upstream
and downstream from
the bridge. Two retaining walls of 200 fee t long
wiJI be anchored in
riparian areas near the
bridge. Three more
retaining walls, one up
to 400 feet long, are
planned fo r the mountainside below the
bridge. These cuts and
retaining walls are for
the sake of widening the
highway on either side
of the bridge fro m 26 feet
to 34 feet. These d esign
features and their
impacts on the scenery
and adjacent fishery
were not disclosed in the
FEIS. In that document,
UDOT assured us that
the highway in this part
of the canyon would not
be w idened .
Visual impacts w iJI be
significant. Burnt Bridge
is s urrounded by riparian vegetation and
u pland plant communities that have received a
visual sensitivity ranking
(contilwed /lext page)
�Violates ("";.,,,,)
of 6 and 7 by the Forest
Service, indicating that
the roadside in this a rea
cannot absorb alte rations
and still appear as na tur-
allandscape. The affected maple-shrub community on the cut hillsides
will take 10-15 years to
re-establish, while a ffected juniper and Doug las
fir communi ties will take
more than 20 years to reestablish. Some wetlands
and riparian vegeta tion
will be permanently lost.
UOOT has pledged to
color and texture the
extensive retaining walls,
but retaining walls will
still look like retaining
walls, appearing unnatural. Exposed rock faces
will still look like
exposed rock faces, damaging the scenic beauty
of this area.
Lee believes these
impacts are unnecessary.
The bridge could be
tapered into the existing
highway in a shorter distance, eliminating the
need for much of the
wid ening and the accompanying cuts and retaining waUs.
At Lower Twin
Brid ge, mountainsides
will be cut up to 600 fee t
on either side of the
bridge in order to widen
the highway from 26 feet
to 38 feet. A retaining
wall of 200 feet long is
planned above the
bridge. This retaining
wall and cuts above the
bridge were no t disclosed in the FEIS.
UOOT has yet to show a
purpose and need for allY
high way widening in
this middle section of
Logan Canyon. They
have adm itted that their
an accurate d escription
of planned construction
and a better idea of its
impacts. Surely at this
stage of the FEIS, UOOT
cou ld have surveyed the
relevant features of the
can yon, such as the location of wetlands, and
applied appropriate
design standard s in
to provide an accurate
description of construction and assessment of
impacts. Preliminary
plans for Upper Twin
Brid ge show a cut into
the mountainside of
approximately 15 to 24
feet deep and 760 feet
long. This cu t and its
impacts were not disclosed in the FEIS. We
believe that with a fair
assessment of the environmental impacts of the
elltire highway project,
considered as a w hole, a
less damaging construction alternative would be
more a ttractive.
Such an integrated
assessment should be
given in a Supplemental
Environmentallmpact
Statement for the entire
canyon highway project.
There shouJd also be an
honest demonstration of
the purpose and need for
any construction in
Logan Canyon.
" LCC has g rave concerns about both the
need for UOOT's proposal and its impacts on the
special values of the
canyon. These concerns
are only made worse by
UOOT's violations of its
FE IS and its failure to
g ive the public full
opportunity to participate in this decision and
to comment on
potential environmenta l
consequences,"
Zimmennan stated.
traffic and safety d ata is
"garbage" and "problematic."
lmmediately downstream of this bridge is
crucial brown trout
spawning habitat. LCC
is concerned w ith the
impact construction and
the resulting erosion will
have on this fishery. The
Logan River fishery is
currently ranked in the
top 5% of stream fisheries in the sta te. UOOT
has not supplied adequate information on
sedimentation or on trout
mortality. At both
bridges, there will be
increased erosion into the
rive r during and after
construction until ground
cover can be re-established. Increased sediments can smother trout
eggs, clog gills, and kill
the aquatic insects upon
w hich trout feed . UOOT
admits, "Additional loss
of fish habitat could
potentially occur from
riverbank disturbances
and introduction of sediments into the Logan
River as a result of heavy
machinery and activities
associated with bridge
construction."
LCC has suggested
replacing Lower Twin
Brid ge wi th a wider and
sa fer bridge on a new
alignment, while maintaining current highway
wid th . This would eliminate much cutting into
the mo untainsides and
protect this va luab le fish ery. UOOT has refused.
We are concerned
with UOOT's method of
segmenting its Logan
Can yon Highway proposa l into smaller projects in w hich, well after
the FE IS and Record of
Decision, we fin al1y get
2
�1 , 19 96
Allglls t
Logan River, Wild and Scenic
by Drew Parkin
The recent appeal of the
Forest Service decision to
allow highway expansion
in Logan Canyon quesHoned, among other
things, the resuJ ts of a
Forest Service study
regarding wild and scenic
rivers. For many of you,
the idea of a wild and
scenic river evokes images
of the Sa lmon River in
Idaho or the Rogue River
in Oregon . What d oes this
have to do with the Logan
River? A lot.
The Wild and Scenic
Rivers Act requires federal
land management agendes to include w ild and
scenic river evaluations as
part of their normal decision-making processes. In
the case of the Forest
Service, this means that
forest plans must specifically consider wild and
scenic river eligibil ity. It
also means that any
Environmental Impact
Statement that involves
river resource must
address this issue. Further
- and this is the important part - once the
Forest Service identifies a
river as being eligible, it
must, in adherence wi th
its own ad ministrative
directives, manage the
river "in a manner consisten t with the purposes of
the Act, and such that the
outstand ing remarkable
values which make it eHgible for inclusion are not
dim inished to the poin t
where eligibility is negated. In no event should the
free-flowing characteristics of the river be modified."
In response to a threatened lawsuit, the Forest
Service some 10 years ago
set out to identify potentially eligible wild and
scenic rivers. Individual
forests were entrusted
with this and many
responded admirably.
Unfortunately, wild and
scenic evaluations have
never been high on the list
for forest managers in
Utah . That is, not until the
controversy over the
proposal to widen the
roadway through Logan
Canyon. Pressu red by citizens concerned about the
highway proposal, the
Wasa tch-Cache National
Forest undertook a yearlong river study and, in
November 1993, released
its inventory.
The inventory started
by identifying 37 streams
that forest planners
deemed wor thy of being
s tudied. Nex t, the larger
s treams on that list,
including the Logan River,
were subdivided into
"segments." In all, the
Forest Service study considered 59 stream segments. Of these, 18 segments were rejected
out-of-hand as being
insignificant. Beaver
Creek was one of these.
An ad d itional 11 segments
were rejected for not being
free-flowing. These
included s treams tha t had
been s ubjected to water
w ithdrawals, channeHzation or other degradation .
All of the Logan downs tream of Temple Fork
was rejected for this reason. This left 30 segments
that were actually included in the study.
The inventory considered nine separate
resource fea tures. The idea
was to determine the significance of each stream
with regard to each
resource feature. A stream
could be ra ted as ei ther (1)
typical, (2) Significant a t a
statewide level, or
(3) significant at what the
Forest Service termed a
"provincial" level (an area
comprising all of the
Rocky Mountains). A rating of 3 for any given
resource feature would
q ualify a stream segmen t
for wild and scenic river
(conthwed next page)
DID YOU KNOW?
A b ridge o r a city street must
h ave 12 lanes to accommod ate
40,000 automobiles per hour.
1 lane is necessary to
40,000
bicycles
per
hou r.
To elimin ate the need for Midd le
East oil, U.S. commuters w ould
need to b icycle to w ork only 1.25 times each week.
Equating calories to gasoline, the number of miles per
gallon that could be tra veled b y the ave rage cyclist is
3,000.
ook
130 Nort h 100 EaSI
Logan UT 8432 I
753-9089
PL EASE RI DE YOUR B I KE.
SU NR:ISE C VC LE R:V
138 NORTH 100 EAST LOGAN, UTAH 84321
801 -753-3294 M ONOAY - SATURDAY 10:00 A.M. - 6:00
100% fo r L ogan Canyo n
P.M.
3
�Wild
(COlltinlled)
designation. The result?
Of the original 59 s tream
segments, only one - the
Stillwater Fork of the Bear
River - was found eligible based on the rating for
its scenic features. No
other stream received a 3,
and all were therefore
rejected, including the
Logan River.
I was stunned when I
heard the findings. Based
on severa l years of professional experience with
wild,and scenic rivers,
and having detailed
knowledge of the Logan
River, it was my judgment
that the Logan River not
only met but exceeded eligibility requirements.
After pouring over the
report, I concluded that
the study team's basic
assumptions were wrong
and applying these
assumptions greatly
skewed the findin gs. The
decision to use "p rovi ncial" significance as the
cu t-off for eligibility was
the most pervasive error.
The Forest Serv ice Manual
itself d irects that
"statewide" significance is
an appropriate measure
for judging wild and
scenic status. Several
national forests have used
it as the basis of their decisions, and it is accepted
practice for National Park
Service and BLM planners
as well.
Had the WasatchCache used "statewide"
significance as the threshold, the Logan River
would have been included
easily. If anything, I
believe the ratings for the
Logan River are low. I
question the ratin gs for
wildlife, water recreation
and, especially, scenery.
Even if the Forest Service
ratings are correct, it is
obvious the Logan River is
an extremely important
resource with "statewide"
significance. [n five of the
nine categories, the river
received a s tatewide Significance rating. No other
stream had more than
two. The Logan River was
rated as the most significant stream in the
Wasatch-Cache National
Forest for five of the nine
resource categories. Again,
no other stream could
claim more than two. The
conclusion is inescapable.
The Forest Service report
absolutely confirms that,
when compared to other
streams on the forest, the
Logan River is the crown
jewel and is most certainly
eligible for national wild
and scenic river status.
(Drew Parkin is a river policy
conslilfant in Cambridge, Mass.,
alld serves Off the board of dirf"Ctors of till" Pacific RivtrS
COlllleil. HI" prf"Violls/y mallaged
wild and scenic riuer programs
for tire Na tiollal Park Service. He
is a Ilative of Utah and Sptllt severa/ seaSOIIS workillgJor tire
Forest Service ill Logan Canyon.)
USFS data on the Logan River
between Temple Fork and White Pine Creek.
Logan River rating
St.ltewide s ignifiu nce
Highest rating in forut
Typical
reso urces
Wildlife
Rating compared to other
Wasatch..cache streams
Rated in top 5
Rated in top 5
Geology/Hydrology
Statewide significance
Highest rating in forest
Rated in to p 10
Scenery
Water
Typical
Highest rating in forest
Statewide significance
Rated in top 10
Fisheries
Statewide Significance
Tied for highest rating in forest
Ecology
St.ltewide sig nifican ce
Tied for high est rating in forest
This information was taken directly from tile report.
Adventure,
Sports
_.
.
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4
�- -- - - - - - - - - - - -- - ---- -- ---------- - ------- ------ww
Augllst 1, 1996
Canyon News Briefs
by Tim Wagner
Utah citizens lost a serious battle
recently when U.s. District Judge Tena
Campbell ruled in favor of the Utah
Deparhnent of Transportation's
(UDOT) plans for further widening of
U.s. 189 through Provo Canyon.
The Provo River Coalition filed suit
February 29 seeking a temporary
restraining order and a preliminary
injunction to prevent further environmental destruction. Because UDOT
had made significant design changes
since the origina l plans were drafted in
1989, the group argued that NEPA
required a supplemental environmental impact statement. Judge CampbeiJ
saw things differently.
"Plaintiffs have so far failed to
come forward with any evidence for
significant environmental effects arising out of the project as currently
planned," Campbell wrote. The judge
said an agency is not required to supplement an environmental-impact
statement every time new information
is found. At the same time she
acknowledged the design changes
included a new road alignment, additional concrete retaining waiJs, and the
creation of a dirt haul road. Inside
sources say that Campbell's concern
for the environment was a cover-up
for more important matters: the economy and jobs. With a $34 million price
tag for two miles of highway, is it any
wonder?
A bit of irony is that UDOT's plans
for the next phase of the project have
been scrapped due to lack of funding.
Alan Meecham, director of UDOT's
Region Three said, "I've got about five
years left (before retirement) and I'd
like to see some work completed in the
canyon before I'm gone."
In the past there was much talk
about UDOT becoming more trustworthy and willing to compromise. Facts
behind the case give the true p icture of
UDOT. This is not an agency as concerned about public transportation, the
environment, and highway safety as
they are about funding massive,
unnecessary highways.
. LCC now has a great public education and awareness tool for Logan
Canyon. With some tremendous pholos by photographer Scott Smith, LCC
has created a fantastic slide show presentation.
It debuted at a well attended
potluck in February on the USU campus and has since been shown to several groups. The presentation lasts
twenty minutes and is easy to fit into a
variety of public gatherings. If you
know a group that would like to see
the show, contact one of the officers.
• LCC would like to thank the outpouring of support we have re«!ived
from our fundraising letter. The money
($3,155) will help us proceed with our
upcoming UDOT battle. The majority
of our support comes from Cache
Valley, but there are many canyon
lovers across the country. Enthusiasm,
support and love for the canyon is evident by the following:
- "Please accept my donation of $25 to
help save Logan Canyon . I'm not sure
how you traced me down here in
Maine, but I'm sure glad you did.
Thanks."
- "As I will soon be moving and wish
to keep up with these canyon issues,
please add my permanent address to
your mailing list."
- "Thanks again and keep up the good
work. See you in the canyon."
- "Long live Logan Canyon."
- "GOOD LUCK! Just wanted you to
know I was impressed with the professional presentation of the latest
brochure and letter. You articulated
your objections to the project in a
straightforward, no nonsense manner
and 1 appreciated the compromises
tha t you see are necessary. Take Care.
"Coffee with a Cause"
Logan
Blend
• regular· organic · decaffeinated · Night and Day
ra i n@intele.nel 801 .75 J . 05'J
$1.00 is donaled 10 Lee for OV8lYpoond sokJ.
5
�SLOWDOWN
WE MOVE TOO FAST
by Kevin 1. Kobe
On December 3,1995,
members of the Logan
Canyon Coalition drove
from Logan to Garden City.
OUf objective was to assess
the quality and uniformity
of advisory and regulatory
signs. We documen ted our
assessments and addressed
our concerns to Dyke
leFevre, Region One
Director, Utah Deparbnent
of Transportation (UIXJ1).
Our fi rst question to Mr.
leFevre addressed the
inconsistent u se of advisory
speed signs on curves. We
expected to see an advisory
speed sign on any curve
which has a design speed
below the posted speed.
This was the case only from
the summit of Logan
Canyon to Garden City.
There is a 40 mph posted
speed limit. There are also
in both th e uphill and
downhill lanes signs indica ting an approaching
cu rve and an advisory
speed. Most of these curves
have arrows ("chevrons")
around them.
The Middle p art of
Logan Canyon has not one
curve with a posted advisory speed. According to the
1987 Technical
Memorandum, this part of
the canyon has many more
curves than Rich County
that are below the posted
speed.
LCe's question was
quite simple: Why hasn ' t
UOOT posted advisory
speed signs on these
curves?
Mr. leFevre explained
how each curve is "unique
in its capability of sustaining a reasonable speed
through the curve section.
Because of the construction,
maintenance, and natural
ground settlement through
each curve, each one will
drive differently than originally anticipated or
designed. Some curves, as
much as 10 MPH below the
posted speed, are s till able
to reasonably allow travel
through the curves at the
pos ted speed."
"We have been anticipating a project through this
canyon fo r a considerable
length of time and may
have neglected reviewing
each o f the curves below
the posted s peed limit.;;
" I have talked to our
Region Traffic Engineer and
he has indicated that since
we have a completed environmental report and we
know what is going to happen, especially through the
middle canyon, that he will
review the curve signing
and advisory speeds and
make recommendations to
better inform the traveling
public."
To date, UOOT has
fai led to install any advisory speed signs in the
Middle and Upper canyon.
A related LCC ques tion
asked how accident surveys
can be done in the midd le
LCC T-SHIRTS - 512.00 4th"" colorl
canyon if the curves in
question are n ot signed
properly? We did not get a
response. Perhaps UOOT
can't come up with good
accident and traffic da ta.
(So there is no reason for
the project.)
We also documented the
lack of signs warning o f
wildlife crossings. The only
wildlife sign in the entire
project area is located within the Garden City limits.
UOOT documented in the
FEIS that moto rists collide
with animals at least twice
as often in the Midd le and
Upper parts of Logan
Canyon as on the Rich
County side.
Mr. LeFevre's answer:
'' In talking with the
Fores t Service, there does
not appear to be any location that has a prominence
o f animal collisions and
that placing the signs at the
beginning of the canyon is
probably just as effective as
having signs throughout
the canyon . The wildlife
warning signs h ave little
effect on driver behavior
and would be more of a
visual impact in the canyon
than it would provide for
motoris ts behavior." (And
massive construction won't
have a visua l impact?)
To further make our
po int, there was not a concern over vehicle/snowmobile collisions anywhere in
the FEIS, and yet there is a
sign pos ted in the Upper
canyon that reads,
"Snowmobile Crossing:
Next 9 Miles". Why worry
about snowmobiles, and
ignore w ild life?
LCC also asked why
there aren't " Pedestrian
Crossing" signs where
many people are crossing
the road, such as Logan
Cave, Blind Ho llow, Ricks
Spring (which is s till a
planned passing zone) and
Bunchgrass C reek?
Mr. LeFevre indica ted
that " A lot of these socalled pull-outs were created by individuals using
them with disregard for
safety to themselves and
the traveling motorists and
have not been an official
designated turn-out."
With the lack of signs
warning motoris ts of pedestrians, animals, and curves
one begins to worry about
UOOTs mission. Is UOOT
really concerned about our
safety?
�Augllst ] , ]9 96
Lee adds ,fun
to activism
'96 SUMMER FUNDRAISERS
The summer heat and
good 01' fashioned ice
cream combined to pro·
duce a fin ancial bonanza
for the Coali tion at
KRCL's Day In The Park
in Salt Lake City on June
8. Through the efforts of
dedicated LCC member
Dan Miller and a few
other volunteers, over
$600 was raised in a sin·
gle afternoon as festival
geers lined up to pay
$2.00 for a Ben & Jerry's
ice cream bar.
Thanks to Dan and
some good connections,
the hot weather treats
were entirely donated by
the socially·conscious ice
cream manufacturer.
"For awhile we were
the most pop ular booth
there," said Dan. It
shou ld also be noted that
many people stopped by
A WORLD
O.
all members and staff of
bo th band s who d onated
their time and talents,
THANK YOU! THANK
YOU l Please get out and
support these guys .
They' re worth it.
This event was special
for two reasons. One, the
amphitheater was per·
fect. This venue is beauti·
fut yet unused and in
need of some repairs.
Maybe we could do a
fund raiser for the theater
itself. Secondly, Jerry
Joseph, lead singer and
guitarist for the Jack
Mormons, spent a good
deal of time livi ng in
Cache Valley. Thus, it
was like returning home
for him.
They want to come
back as soon as possible,
so what do you say?
just to receive some free
information and sign up
on our roster list. Way to
go Dan!
•••••••••••• ••••••
The Coalition would
like to thank all who
attended our fundraiser
concert with Euphio
Project and the Jack
Mormons on June 6.
Capping the last day of
finals and a beautiful
summer evening,. over
200 people came out to
enjoy live music on
USU's amphitheater on
Old Main Hill. The event
raised nearly $800
towards protecting
Logan Canyon.
We would especially
like to thank the Baugh
Motel for co·sponsoring
the event. Of course, to
EJ)GINGWE$T
2"1'1 SW Sl'lll'!. (; \11111' S I
P OIIIl \'11, OJ{ 'Ii21<l
Logan Canyon Your Destination?
T ComCTIOtJ
CLOnmJG &
- Backpacking - Skiing · Climbing · H iking
. Snowshoeing - Sightseeing
"Ccents
117 North Mai n 5t • Logan, Utah, 84321 • 801 -753-1541
7
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prepare for the legal challenge we believe is inevitable.
Our ability to mount a legal battle depends upon the
moral and financial support of canyon lovers such as
yourself. PLEASE consider a generous donation to save
Logan Canyon and Logan River.
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A NEWS BULLETIN FROM LOGAN CANYON COALITION
Vol. 2 No. 4
Summer 1997
Stop Wo rk Order Lifted
LCC Files Suit
On Ma rch 19 the
Logan Canyon Coalltion
(Lee) filed a complaint
in U.s. District Court
against the Utah
Department of
Transpo rtation (UOOT)
and the Forest Service.
We requested the cou rt to
order a halt to construction at Lower Twin
Bridge in Logan Canyon
until our concerns over
the bridge could be
resolved. The judge s uggested UOOT s top construction. UOOT complied .
We reached an agreement w ith UOOT that
has aUowed us to w ithdraw our request for a
halt to cons truction.
Lee recognizes the need
to replace the bridges,
and work is now proceeding. UDOT has conceded some important
points:
-They ha ve agreed that
in the future they will
not argue for the need to
widen the highway
above Lower Twin
Bridge simply because
they have w idened the
"An improvement to the road
and consequent increase
in operating speed
would expectedly increase the
accident occurrences."
- from a 1974 interna l UOOT memo
highway at the bridge.
Lee was concerned that
widening at the bridge
sets an engineering
precedent to widen the
highway aU the way up
the canyon.
- UDOT has also agreed
to remove the old Lower
Twin Bridge in the most
environmentally sensitive fashion. They ha ve
agreed to present a written plan for removing the
old bridge, with a djscussion of the environmental safeguards they will
employ, and to consider
LCe's comments on their
plan.
Finally, UOOT has
agreed to consider Lee's
comments on their water
quality monitoring plan
and mitigation efforts for
the project. Lee is s uggesting more frequent
moni to ring during construction. We are recommending that for any
future construction better
baseline da ta is ga thered
prior to constructio n.
Unfortunately, for the
present project base line
da ta goes back only to
September, making
impossible adequate
comparison with past
parameter va lues. We
are recommending as
well that for future construction more complete
monitoring be done of
sedimentation due to
construction.
Our lawsuit has
already enabled LCC to
help make highway construction less environmentally destructive.
Lee is grateful to our
attorney, Ray mond Scott
Berry, for his excellent
work on behalf of Logan
Canyon. Scott has put
many hours into lea rning
the details of our case.
His advice has been
invaluable. We are in
good legal hands.
Expertise and ad vice has
been donated from professionals and environmental organizations
across the country. We
are especially g rateful to
Drew Parkin, Jack
Griffith, Steve Flint, Bob
Morris, and Pete Frost
for their expertise and
dedica tion.
Lawsuit Highlights
Our lawsuit still
stands and will be heard
by the court in a few
months. We will explore
the following issues in
court:
-In an internal 1974
memo conceming the
Logan Canyon highway,
(COl/Jill/nod Il!!xl
page)
�Wild and Scenic Rivers
system. The Forest
Service has not followed
UOOT stated, "an
these procedures in the
improvement to the road
case of Logan River.
and consequent increase
in operating speed would ThE:Y should not be
allowing losses to the
expected ly increase the
scenery, the fishery, the
accident occurrences."
water quality and other
Here UOOT is admitting
canyon resources that
what we should know by
will come with UOOT's
common sense.
Widening and straighten- proposal until the evaluation procedure is propering this ca nyon highway,
wi th an increase in traffic ly ca rried out. We have
documented the fai lures
speed, wi ll lead to a less
of the Forest Service to
safe highway. There will
abide by its own regulastill be curves in the road,
limited sight distance and tions.
- The Forest Service is
steep inclines. Especially
mandated by federal law
in the ice and snow of
to generate a list of recrewinter we should not
ation areas in Logan
have traffic hurtling
Canyon that are to
through the canyon at
receive special protection
speeds that are not safe.
from construction
By 1993 UDOT changed
impacts. The Forest
its mind and presented a
Service presented 17 sites,
safety argument for its
most of which are small
proposa l. They promote
parking lots. This meathe myth that thei r proger list was generated
posed construction w ill
with absolutely no ratiolead to a safer highway.
nale for why they chose
Their traffic and accident
data ha ve obviously been these sites and why they
manipulated to make the have ignored other
important recreation
case they wish to make.
a reas. For aU we know,
-In their 1974 memo
the Forest Service threw
UDOT admitted, "The
darts at a map to generonly conclusion w hich
ate its list. LCC has doccan be drawn, therefore,
umented 63 addjtiona l
is that even the most
recreation areas that the
minima l improvemen t to
Forest Service should
the existing highway
have included in its list,
would have severe
areas that are used for
adverse impact on the
picnicking, fishin g, kaycanyon water resources."
acking, rock climbing,
Yet, now UOOT c.I aims
either no impact or mini- etc. The Forest Service's
Management Plan for
mal impact to the fishery
Logan Canyon lists recreand to water quality.
ation as the primary use
They must be thinking
of the canyon. We will
tha t a mirac.le will occur.
explore in court the arbiTheir estimations are
trary and capricious manbased on fantasy, not
ner in which the Forest
good science, which is a
Service has behaved in its
violation of federal law.
evaluation of recreation.
- The Forest Service
- The Forest Service is
has la id out a proced ure
a lso mandated by fed era l
fo r eva luating rivers for
law to account for
inclusion in the national
Lawsui t
impacts of construction
upon its sensitive species,
including Bonneville
Cutthroa t Trout. The
Forest Service's conclusion of no impacts is
based upon no surveys at
all or upon surveys that
are inadequate. The
Forest Serv ice makes bald
assertions that are totally
mysterious, such as "flora l species have been mitigated for." No explanation of this claim is provided. Other assertions
are pa tently false, Stich as
"no fauna l sensitive
species were found withthe proposed project
dIsturbance area,"" a claim
contradicted by information known to the F(1rest
Service about Bonneville
Cutthroa t Trout.
UDOT's highway proposal will result in a
highway that is less sa fe.
It is far more expensive
than is needed, and it is
far too damaging to the
fishery, the scenery, water
quality and other
resources. It threa tens
recreation, the primary
use of the canyon.
UDOT's hi.hwav PI"OPO'Sal is also
porkbarrel project for the
sake of bringing taxpayer
dol lars through the
UOOT burea ucracy. Our
own Conservationists'
Alternative fea tures sensible highway improvements such as bridge
replacement, some passing and turning lanes,
while it protects valuable
canyon resources.
Our lawsuit is essential if we are to save
Logan Canyon from
UOOT's appetite for
asphalt. Our stand has
already made a difference.
(,0,,1i,,""')
""'g'''"
2
�Summer 1997
The Ultimate Impact
Roads Facilitate People
By Tim Wagner
Over the course of the
last eighteen months, I've
had the opportunity to
speak on behalf of LCC to
several groups. After presenting some history and
current facts surrounding
the Logan Canyon issue, I
usually find myself drifting towards what I see as
the biggest threat. That is,
people.
While we are aU rightfully concemed about the
many various fonns of
environmental dcgradation resulting from fifteen
to twenty years of construction, I honestly
believe that a new and
"improved" U.S. Highway
89 through Logan Canyon
will facilitate a tremendous amount of development, and the result, the
"ultimate impact."
Try to project your
thoughts to the fall of
2017. It's a beautiful afternoon and you and your
granddaughter have
decided to go fishing in
Logan Canyon. UOOT
contractors are putting the
finishing touches on
shoulders and drainage
facilities. A new widened
stretch of asphalt lays
before you, extending aU
the way to the summit
and down to Garden City.
Semi-trucks careen by
at 60 miles per hour, making deliveries to a convenience store that has been
located at FrankUn Basin
for the last ten years. Up
the road, adjacent to the
Beaver Mountain tumoff,
lies a brand new restaurant and hotel complex.
The facility occupies over
40 acres with a giant parking lot, sending roadg'rime into Beaver Creek.
Farther up, a new
snowmobile/ ATV dealershjp has located along
with a fast-food franchise.
Because of the increase in
tuming traffic, UOOT has
now started construction
on another widened intersection, forcing massive
cuts into the slope.
Throughout the upper
section of the canyon, residential construction is
booming, along with severa! higher density developments. At times, traffic
is so congested that it continues to back up, with
increasing accidents.
Your fishing trip tums
into a nightmare because
every place you try to
stop is packed with
anglers. Many are out-ofstaters staying at the new
hotel
reading about
the wonderful fishing and
sight-seeing opporhmities
in Logan Canyon, courtesy of Chamber-sponsored national advertising.
Frus trated, you decide
to take a short hike to
view the fall colors. That
too is aborted when you
realize that every trailhead is jammed with vehicles. So much for quality
outdoor recreation.
Sound surreal? It
shouldn't. If you've spent
anytime at aLi in Logan
DID YOU KNOW?
A bridge OC" cily stTftt must
12
10
40.000 aulomobilal pet' hou,. Only 1
U n«eIINl)'
to KIC01I\mOd.;ole 40)100 bicydes pet' hour.
To
the need fo, Middle
oil, US. commuleT\l wou ld nHd lu b iqde 10 work only t.2S times eKh week.
Eql1.Jling
10 guoli ,"" the
n"moo of milal pe' pilon thOIIt rould
boP: lnIveled by the Ivenoge cyclist ;53)100.
PLEASE RI DE YOUR BIKE.
138 NoRTH 100 EAST loG.t.N, UIAH 84321
80 1-753-3294 MoN.- SAl. 10:00 A.M.- 6 :00I!M.
•---.-.--.---
GRAPEVINE
I
tiTa,.aIT
.
3
Canyon in the past years,
you know we are already
seeing the first inklings of
such a scenario. This is a
real situation that can and
will occur, if allowed .
This is why we are seeing some of the major
environmental groups
starting to tackle the issue
of uncontrolled development. Just this past spring
the Sierra Club initiated a
national campaign entitJed "ChaUenge to
SprawL"
According to the club,
" ... nothing threatens our
air, water, and wild places
more than sprawl." Right
up front, the club proclaims the campaign starts
with stopping inappropriate roads and d evelopments. Sound familiar?
One point they take
issue with is the myth that
development results in
increased tax revenues.
The cost of infrastructure
alone needed to meet the
demands of such develop(cont inued /lext page)
�PEOPLE
(con/itwed)
men!, including highways,
sewers, water, electricity,
and communications,
often exceed the long term
revenue.
These are a ll items subsid ized by you, the taxpaye r. And who reaps the
most benefits? The developer and the summer
h ome owner who are
enabled to build in the
canyon beca use they do
not pay the true expense.
Add in the future costs of
decreased air and water
quality, traffic congestion,
and an overall decline in
the quality of life for residents and the price tag
goes through the roof.
Another way to look at
it comes from the n atio na l
organization, The Trust for
Public Land. It recently
cited research showing
how zoning and other
government regulations
actually encourage development into many of our
open spaces. There again,
government investment
(by the taxpayer) into
infrastructu re serves to
boost land va lues, making
them much more attractive
for development.
Is there anyone who
bel ieves that private and
state owned land values in
Logan Canyon will
decrease once the new
" modified preferred alter·
native" is in place?
It all comes back to one
central point. Build it and
they w ill come. This is an
a rgument that can' t be disputed, even by LCe's
staunchest opponents. Yet
it is this, what I refer to as
the "ultimate impacl," that
has not been addressed in
the Environmenta l Impact
Statemen t nor in a ny other
serious d iscussions.
This is the very issue
that helped the Illinois
chapter of the Sierra Club
successfully stop a m ajor
interstate highway expansion. In the ruling the
judge stated, "Highways
create demand for travel
and expansion by their
very existence." Because
the final EIS d id not
include the "necessary
studies," the court felt the
public and other government agencies were not
informed of all the consequences.
Roads precede developmenl. It is a simple idea
and one you will hear
more of n o matter w here
you live. Not that highway
expansion and development is necessarily bad.
-_
_-_.
_
'- .....
. ' -'
.. , • •• "
But there are right ways
and wrong ways and
right places and wrong
places. Logan Canyon is
the wrong place.
And this is why I firmIy believe we need to elevate the discuss ion of this
project beyond the hjghway itself. Whenever we
have the opportunity to
talk with the general public about LCe's position,
we must include the
issues of people and
development. For many,
the topics of bridge
w idths, fishery impacts,
endangered plants, and
wild and scenic rivers are
too abstract.
But ask that person
Log"" Canyon Postcards
GmT'a y"f
Stu d io 404 l'hOlograph y.
Alan Hu u li s
...
i ...g..
3-xS- $,SO f
usu
16701
Utah 1W322"()I9'.I
Adventure,
Sports
o f •••
.
...... ...
......,,, ......
-
4
how they will feel w hen
their favorite fishing hole
or ski or s nowmobile trail
is too crowded, forcing
them to go elsewhere, and
you may find a n ew ally.
Preventing the " ultimate impact" in Logan
Canyon is a lifelong commitment. Achieving reasonable highway sa fety
improvements in lieu of a
massive pork-barrel project is just one incremental
step, but the first step. If
you would like to help or
would like more information about this issue,
please feel free to call me
at 755-0286. Get involved
now.
.:.
EDWARD AUEY
, ...,ItA;, 0' II
I'NII 111.10 ANII 1 ••_
IIII"'N; TO.
LCC POSTCARDS
USU 101C_ I,","
LO;AN. UTAN "111- 01"
�Slimmer 1997
Canyon News Briefs
(Tlte follawillg is reprillled from a letter to
tlte editor of tlte Utall Slate University
All/11m; Magazine.)
the shot-crete is for added stabili ty and is falling off in sheets
as we stand looking ... Shotcrete on this type of canyon
First Provo Canyon, now
material is like putting a band- Provo Callyoll Coalilion
Logan. Soon there will be nothaid on a gushing artery ... The
ing left, only p eople racing
recent slide triggered the
from one spot to another trying County political and business lead- Coalition's worst fears, fears
to find a happiness which can
ers are begitmiug to question the that a four-lane road just won' t
only be found in slowly savorenviront1lel1tal alld finallcial costs work through a narrow area
ing the bea uti es God created.
wi th unstable rock.
of the Provo Cal1yon fiasco, and
are protestil1g tile priority given to
Gilda Sims, class oj 1940,
the cal/yon road at the expense of Looking at this raw, powerful,
currently residing ill Eval1ston,
more Jzeavily traveled roads.)
exposed scar, boulders tumble
Wyomitlg
down as we speak. They
" ... I can hardly stand to be here appear out of nowhere, crash... I am prone to letting out a
ing down, hitting the barrier of
primal scream of anger as I
concrete and wire fencing
(Tlte followillg was sent fr01l1
pass daily the monster dump
UDOT has constructed in an
friends in Provo WilD are watching trucks hauling away the
attempt to protect motorists
tlte last of tlteir cat/yol/ behlg
innards of the can yon.
once the canyon is opened. It
devoured by dynamite, bulldozers
seems as if someone is up there,
and asphalt. Almost-vertical culs We are all looking at the same
hurling down the rocks in
in file cal/yoll walls Itave caused
thing. A massive cut in the
anger. It is driving the engimassive slides, flattellil1g a twocanyon wall--70 feet high and
neers crazy ... Further up the
tOil pickup and closing tlte
300 feet long--that wi ll eventuroad, a waterfall of black mud
highway. Tlte fOllr-laue highway, ally make room for two more
flo ws from an area scraped by a
costing $20 million per mile, is in lanes of de-curved roadway.
bulldozer.
its Jilwl phase. U DOT begal/ tile The first length of the canyon
rec0115tructioll ill the lIIid-1980s
face has been drilled with
We are frustrated, worried and
with a promise to tile enviro1JlIlell- twenty foot spikes and covered sick at heart over what they
tal community tltat tlte road wou ld with shot-crete. The drilling is
have done to our canyon."
be limited to two lmies. Utah
an attempt to stabilize the face;
" Coffee with a Cause"
• regular· organic · decaffelnaled • Night and Day
11.00;'
to LCC Ior..-ery pound sold.
"We are sick at heart over
w hat they h ave done
to our canyon."
�Recreation Threatened
By Kevin f. Kobe
nificance, or enjoyment
of Commerce).
During my recent s ki
trip from Logan Canyon
to Teton Pass, Wyoming,
I saw only two canyons
throughout the entire
300 mile stretch that did
not have s nowmobile
tracks. It made me realize how current highway
plans fo r Logan Canyon
will further threaten
human-powered recreation.
How? Most of the
recreation resources in
Logan Canyon were le ft
out of the highway documents (the FEIS, DElS,
and ROD). This opinion
is s upported by the fac t
that only 17 sites were
lis ted as recrea tion si tes
under Section 4(f) of the
Department of
Transportation Act of
1996.
The Final
Environmental Impact
Statement (FEIS) states
that, " Recreation has
been designated as the
primary use in Logan
Canyon according to the
Wasa tch-Cache National
Forest Land and
Resource Management
Plan. Developed and
undeveloped recreation
lands occur along the
hig hway within the
National Forest. .. "
The entire stretch of
Logan Canyon IS USED
FOR OUTDOOR
RECREATION and is
promoted as s uch (note
the many brochures pro-
duced by the C hamber
o f an UIban park where
Recently, Logan
Canyon Coalition (LCq
inventoried an additiona l 63 sites a long the project area that were not
listed in any of the documents. Most of these
sites provide access for
picnicking, fishing,
climbing, kayaking, bird
watching, sig ht-seeing
and parking for winter
activities.
Many of the sites will
be adversely affected by
the proposed highway
project. These include
direct impacts to the
recrea tion resource, such
as elintina ting access
parking lots, and indirect impacts such as
noise and safety.
According to the FEIS
(p. 6-4), " indirect
impacts include exceeding ambient noise criteria, reduction in access,
visual impacts, vibratio n, and ecological
intrusion. Substantial
impairment occurs only
when the protected
activities, features, or
attributes of the resource
are substantially diminished." The FEIS d efin es
protected activities and
features as, " ... performances at an outdoor
amphitheater, sleeping
in the sleeping area of a
ca mpground, enjoyment
o f a historic site where a
quie t setting is a generalIy recognized fea ture o r
a ttribute of the site's sig-
serenity and quiet are
significant
Based on the above
criteria, all 63 sites, as
well as the entire stretch
of Logan Canyon, will
s uffer "substantially
diminished " recreational
resou rces due to the current hig hway project.
Many o f the activities in
Logan Canyon occur in
areas "where a quiet setting is a generally recognized feature o r attribute
of the site's sig nificance ... " These areas
will be affected by an
in crease in traffic no ise
levels as a result of:
faster speeds, additional
passing lanes (d ue to
vehicle acceleration),
and braking noises.
Another indirect
impact concerns safety
for recreationists; vehid es entering and exiting
recreation sites along a
faster highway w ill be
more dangerous.
Additionally, different trends in recreation
have occur red in Logan
Canyon since the FEIS
was written. Activities
that have grown in popularity and have not
been considered in any
documents include backcountry snowboarding,
boating, fly fishing,
climbing alo ng the rock
cliffs adjacent to the
highway, and recrea tional and professional
cycling.
In conclusion, the list
of 4(f) sites in the FEIS
lacks professional and
scientific integrity. It
falls short of recognizing
the recreation resource
in Logan Canyon a nd
new recrea tio n trends. It
also does not provide
enough information conceming all of the recreational pursuits occurring within any onc of
the 17 4(f) sites in Logan
Canyon.
----.
28 Fed!llIIItft. Lopn. lit 84321
(101) 7Ss-olS7
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I.CC T-SHiIl:TS - 51 2.00 (3 rob)
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Slimmer 199 7
Speak Now, Speak Often
Make Your Voice Heard
G overnment Officials
Letters to the Editor
What to Do
Governor Mike Leavitt
The Herald Journal
State Capitol Building
Salt Lake Ci ty, UT 84114
Ph# 801-538-1000
Fax: 801-538- 1528
75 West 300 North
Logan, UT 8432 1
Phil 801-752-2121
Fax: 801·753-6642
Please write and urge
ou r government officials
and the public to re-evaluate UOOT's plans and to
consider the more fi sca lly
prudent "Conserva tionis ts'
Alternative" that s till
addresses the need s o f
highway safety and Logan
Canyon . It is not a "do
nothing" proposal.
Be s ure to include your
full name, address, s ignature (except e-mail) and
daytime phone number.
Keep your letter short and
to the point. Write about
your personal experiences
in the canyon and use facts
to s upport your a rguments.
e-mail:
govemori?Jemail .state.u Lus
e-mail: hjleUeri?Jhjnews.com
The SaIt Lake Tribune
Rep. Jim Hansen
U.S. House of Representati\'cs
Washington D.C. 205 15
Phil \-202-225-0453
Fax: 1-202-225-5857
Rodney Terry
Project Manager, UOOT
Ave.
PO Box 12580
Ogden, UT 844 12
Phil 801-399-592 1, ext30S
169 North Wan
Fax: 801-399-5926
liz Schuppert
District Ranger
USFS, Logan District
1500 East Highway 89
Logan, UT 84321
Phil 801 -755-3620
Fax: 80 1-755-3639
Public Forum
PO Box 867
Salt La ke City, UT 84110
Fax: 801·237·2022
Deseret News
Readers' Forum
PO Box 1257
Salt Lake City, UT 84110
Fax: 801·237-2121
e-mail: Letters@d esnews.com
The Standard-Examiner
PO Box 951
Ogden, UT 84402-{)951
Phlf 800-234-5505
Phil 801-625-4222
Fax: 801-6254508
e-mail : Letters@standard.ne t
Thank you for
your h e lp !
L()(H, Hilt Oil! 'E\\ \\EII I'\(a. \I:
AW ORLD
(!omCTION
CLOTHING &
Logan Canyon Your Destination?
- Silckpil cking - Skiing -Climbing -Hi king
- Snowshoeing - Sightseeing
Accents
57 SOOT\I lWw • locwI UT 1?4g21
753·3497
htll': I/\"'\\o/l11"rinl'rol'nl11 / ilo o
l
!JON·SAT 11·6
117 North Meln 81
7
�r-----------------------,
YES! I
THE
WANT TO JOIN
LOGAN CANYON COALITION
and receive a subscription to CANYON WI ND
o $20.00 Annual Membership
o I would like to contribute an additional
$10 $20 $30 $40 $50 Lois more
o I would like to volunteer.
o Here's 512.00 for a g reat T-shirt.
o I' m broke! Here's five bucks.
o Please add my name to your mailing list.
pl"JSJ51!ippi"g
Name____________________________
PRINTING (0.
5 Ireel____________________________
Cily _ _ _ _ _ _Slale_ _ _. ip _____
Z
Email_ __ _ ___
P h one#
43
SOUT H
100
LOGAN , UTAH
WEST
84321
TEL . 801.752.031 1
make ch«k payable ilnd m ol;1 to:
Logan Canyon Coalition
USU Box #1674
L _______________________
Logan, UT 84322·0199
FA X 80 1 . 753 . 316 1
Please consider a donation to LCe. All donations will be
used for the protection of Logan Canyon.
LCC wants to thank the hundreds of individuals, businesses
and foundations who have contributed time, money and
expertise towards the legal defense of Logan Canyon. Your
generous support is appreciated.
.. ..
Wi
!!!!
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Paid
lDgall, IJT
Pe.",;t N"SO
Wor k i n s f or t h e P ro t ec t ion o f
USU Box #1674
Logan, Utah
84322-0199
." Please Rellew YOllr
Membersllip Today
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N E W S B U L LE TI N FR OM L OGAN CAN YO N COALI T IO N
Vol. 2 No.5
Spril1g 1998
Bass and Parkin to Headline
Logan River Summit
Have you ever seen
an o fficia l Wil d and
Scenic rive r? Have you
ever wonde red i f the
Logan Rive r possesses
such qua lities? And
ha ve you ever wondered why Utah currently has no rivers that
a re being studied fo r
possible incl usion in the
Wild and Scenic system,
let alone a river with the
officia l designation?
Answers to these
questions and more will
be presented at the
" Logan Ri ve r SummitA Confluence of Ideas/'
Saturday May 16, 1998,
from 8:30 to 4:30 at the
Beaver Mountain Ski
Lodge in Logan
Can yon. Fea tured guest
speakers addreSSing the
w ild and scenic issue
w ilJ be nationalJy
known river policy
ex pe rt Drew Par kin and
Utah Rivers Council
director Zach Frankel.
Have you ever wondered w hy
Utah currently has no rivers
that are being studied for
possible inclusion in the Wild
and Scenic system?
Parkin's expe rtise
includes directing wild
and scen ic rivers programs for the National
Park Service. Currently
he consul ts with many
river orga niza tions,
add ressin g a variety of
rive r issues. Parki n also
serves on the board of
di rectors for the Pacific
Rivers Council A native
o f Utah, he now lives in
Cambrid ge,
Massachusetts.
Zach Frankel sta rted
the Utah Rivers Cou ncil
approxim a te ly five
yea rs ago a nd has
become well known
around the state for his
knowledge of Utah
rivers and the man y
threa ts to their wa tershed s.
A lso speaking on
beha lf of ri ver ecosystems will be na ti ona lly
known author Rick
Bass, who w ill bring his
own style of passion for
our na tura l world. He is
widely loved by
Am erican readers. As a
forme r res ident of
Logan, Utah a nd a USU
alumni , Bass often
spea ks of his intimate
relationship with Logan
Canyon and the Logan
Ri ver.
"Sustainable
Watersheds" w ill be the
theme of an afternoon
panel di sc ussion , CO I11p lete w ith a ques tion
and answer period.
Partic ipants include
John Ca rter with Willow
Creek Ecology who will
address riparian and
wa tershed issues,
Wendy Fisher with U tah
Ope n Land s who will
educa te attendees on
such th ings as conservation easemen ts, Wes
Johnson, president of
Utah's Trout Unlimited
who will talk of the
importance of aquatic
protections, and Mike
Timmons, USU landscape arch itectural professor, who will discuss
visual aesthetic issues.
Acting as panel moderator will be Logan 's
own KUSU program
director Lee Aus tin.
It should be noted
that this conference is
(col1lill!u'd 01/ pagt' 4)
�Bridge Fight Averted
On September 8, 1997
potentia l impacts by ceas- bridge up after it has col·
ing construction during
the Logan Canyon
lapsed into the river?
Coalition sent II letter to
the spa\vning season.
.15 there an envi ronmenTom Twedt of BioWest
UDOT's Sto rm Water
tally less damaging
with questions concernPollution Prevention Plan method of bridge
ing the Utah Department clearly stated,
removal? Since UDOT
of Transportation's
"Cons truction activities
plans to crane the new
wi ll be scheduled to
(UDOT) constructi on
bridge into place, it
avoid period s of aquatic
plans for the fall.
seems that they could
BioWes t is the env ironlife cycles (spawning,
crane pieces of the old
men ta l consultant on the
etc.)." Suddenly UDOr
bridge Qu t w i thout droptwo brid ges project in
annou nced that it was
ping it into the ri verbed.
Logan Canyon.
Surpris ingly, the
Our main conidea of demolishing
After LCC's threa t of alt illj uctioll, the old brid ge durcern was over the
pOSSibility that
UDOY {l l mOItIlCe ri there would be ing spawning seaUDOTwould
son, just upstream of
11 0 bridge demolitioll dur;lIg the
demolis h the o ld
a documented
Brow n Trout fall spawning seaso". brown trout spawnLower Twin
Bridge in the fall. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ing area, was su pd uri ng brown
ported by the Utah
trout spawning season.
considering construction
Division of Wildlife
UDOT's Reevaluation of
and bridge demolition
Resources.
the llucc Bridges Project
during the spaw ing seaOur attorney,
son.
for Logan Canyon conRaymond Scott Berry,
tains a good discuss io n of
We were concerned
faxed a memo to UDOT's
the brown trout spawnthat UDOT wou ld use
attorneys, stating our
ing area immedia tely
explosives to blast ou t
in tention to file for an
the brid ge su pports,
downstrea m of Lower
injunction on all b ridge
Tw in Bridge and the
a llow ing the bridge to
construction and demolipotenti al im pacts of
fall into the riverbed.
tion during the spawn ing
increased sediments
They wou ld then drag
season. At the CAT
u pon the eggs a nd fr y of
the b ridge out o f the
(Cooperating Adv isory
riverbed wi th tractors.
spawning trout.
Team) meeting of
According to U
There would be massive
,e
Sep tember 24, UDOT
a mounts o f sediment
Reeva luation, "The
announced there wou ld
be no bridge demolition
Logan River dmvnstrea m introduced in to the ri ver
during the fa ll. They
of Lower Twin Bridge has as the bridge sank into
agreed that all constructhe riverbanks and was
been used as a spaw ning
tion activity in the fall
site by brown trout. ...
dragged out. The loss to
would be li mited to work
riparian areas wou ld be
sedi ments released into
considerable.
on the deck of the bridge,
the Logan Rive r by conh igh above the ri ver.
s truction activities in la te
Our
There would be no work
su mmer, fa ll , and winter
questions included:
in the river or o n the
could suffocate eggs and
- Precisely how much
riverbanks. We believe
fry, which are expected to sed imen t will be in trothis decision by UDOT
be present in this spaw n- duced into the river?
- Exactly how wi ll the old helped to protec t spawning area from about
ing b rO\'vn trou t in Logan
October through March." bridge be removed?
Rive r.
UDOT had previously
- Wha t w ill be the
agreed to minimize
impacts of cu tting th e
2
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Sprillg 199 8
An Expert Speaks O u t
UDOT's Confused Data
By LCC Stnff
mates or on how accurate their estimates are.
more than o ne accid ent
per ye<lr, " there is only
one site in the entire
canyon with more than 2
The Logan Ca nyon
Coalition asked Dr.
Everett C. Carte r, of the
Transportation Studies
Cen ter of the University
o f Maryland, to exam ine
the Utah Department of
Transportation's (UOOT)
traffic and accident data .
In his report, Dr. Carter
states, "There is d efiniteIy some confusion concerning acciden ts and
traffic volumes in Loga n
Canyon."
Dr. Carter no tes that
the method UDOT used
to estimate traffic fl ows
in Logan Ca nyon " resu.lted in errors." UDOT
used only one counter at
o ne location in the
ca nyon to count vehicles,
and they then used these
counts to estim ate traffic
volumes in nil sections of
the cn nyon. No information is provid ed on how
they calculated their esti-
Here is one exa mple
of error. In the hig her
accidents pe r yea r." He
states. "One o r two acci-
section of the middle
dents/year is not
ca nyon, and in the uppe r
ca nyon, the estimated
traffic vo lumes that
UDOT used to calculate
acciden t rates declined
in the years 1986 - 1990
compared to 1980 - 1985.
Yet the estimated tra ffi c
volumes in the lower
ca nyon, and in the lower
sectio n of the middle
canyon, show a 7%
increase in 1986 - 1990
VS. 1980 -1985. Why
would traffic volumes
increase in the lower secHons of the canyon in
1986 - 1990 and yet
d ec line in the upper sections? There is no expla nation of this discrepan-
unu sually hi gh"! In
o the r words, the Logan
Ca nyon hig hway is not
an especially dangerous
hig hway.
Special Report 214
from the na tional
Trans portation Resea rch
Boa rd (1987) indicates
tha t the benefit of w idening beyond 34 feet is
"q uite lim ited." Dr.
Ca rter states, "Thus a 34
ft. paved section, especiall y in lig ht of the env iro nmen ta l impact,
should be the upper limi t
in Logn n Cn nyon .... "
UooT is planning a 40
foot hi ghway width
above Beaver MOu.ntnLn,
in s pite of the greater
expense and environmental impact o f this
cy.
Dr. Carter observes
that w hil e there are 9
si tes in the canyon \v ith
DID YOU KNOW?
A bridgt' or .. cit y J tTfl't mu st h .. "c 12
Joint'S to ..
4lJ,000 .. utomobil cs pCt hour. Only I I.. nt' iJ nc.:cssuy
to
40,000 bieyclcs pcr hour.
To
thl' nccd for Middl c Eas t
oi l, U.S. commuters would nced to biercit' to work o nl y l.25 tim cs
wl't'k.
u lo riH to
thc
numbcr of milt'S
could
bf tr'''flcd by th f aYf ragc (yelisl i, 3.000.
.
'IY
• :;-
' 1W..1
PLEASE RIDE YOUR BIKE.
138 NOI»H 100 EASl lOGAN. UrN! 84321
801 -753-3294 MQN.- SAl. 10:00 A.M. - 6:00 P.M.
G ,,
-_.- ...
--_--
PEVJNE
...
3
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width, and in spite of
this Specia l Report.
Another report UDOT
apparently ignored,
" Low Cost Methods for
Improving Traffic
Operations on Two-Lane
Roads," wa s published
by the Federal Highwa y
Administra tion in 1987.
This report discusses
low-cost but effecti ve
highway improvements
s uch as slow-vehicle
turnouts and better signing. These improvements have been part of
LCe's propo5<'11 for many
years.
Dr. Carter concludes,
'' In summary, I a m convinced that there is reasonable doubt that a fu ll
scnle/mnjor improvement of the entire
Ca nyon is justified."
.:.
�RIVER
(,,,,lim,"')
be ing underwritte n
th roug h the generos ity
of the ational Ri vers
Coa liti on, w hich is
mad e up of the
America n Ca noe
Assoc., Ameri ca n
Rivers, A meri ca n
Whitewate r Affili a tion,
Na tio nal Wildli fe
Fede ration, Ri ver
Management Society,
Rive r Ne two rk, Sie rra
C lub, and The
Wilde rness Soci ety.
Loca l co-spo nso rs
includ e the Citi zens for
the Protection o f Loga n
Ca nyon and
Brid ge rl and Audubo n.
The ir support is commend able!
Cost for the enti re
day, incl uding a conti ne nta l breakfast and
lu nch, includes $10 for
adu lts and $7.50 for students. Early reg istra tion
is encou raged as seating
is limited to 150 people.
See the enclosed insert
(Uta h mailing o nly) for
m o re info rmatio n. Or
call at 435 / 755-0286.
Why Are Wetlands Important?
Wetlands are important for
ma ny reasons:
Wetlands prevent nooding by hold ing wa ter much
like a sponge. By doing so,
wetlands help keep river
levels norma l and filter and
pu rify the s urface wa ter.
Wetlands accept wa ter
d uring sto rms and w henever water levels arc high.
When wa ter levels are low,
wetland s slowly release
water.
Wetlands also release
vegetative matter into
rivers, which helps feed fis h
in the rivers. Wetlands help
to counter balance the
human effect on rivers by
rej uvenating them and surrounding ecosystems.
Ma ny anima ls that live in
other habitats use wetlands
for migra tion or reprod uction. Fo r example. herons
nest in la rge old trees, bu t
need sha llow areas in order
to wad e for fi sh and aquatic
life. Am ph ibians often for<lgc in upland areas but
return to the water to mate
and reproduce.
Wetlands must not be
thoug ht o f as a unique and
independent habitat. They
arc vital to the survival of
many ecosystems and
......
---...
,.,
,
wild life in genera l.
Unl ike most oth er habita ts, wetlands directly
improve other ceo-systems.
Becausc of its many clea nsing bmefits. wetlands have
been compnred to kid neys.
The analogy is correct, wetlands and kid neys help
con tro l water flow and
cleanse the flow o f liquids
within a system.
Eros ion Contro l
Looking at pictures o f
delt"s, o ne cn n tell that
rivers d eposit" lo t o f mud .
Mud is top soil that has
eroded and w"shed away.
Emergents (plan ts firmly
rooted in the muddy bottom bu t with stalks tha t rise
high above the wa te r su rface) a re able to radica lly
slow the flow o f water. As a
result, they counter the erosive fo rces o f mov ing wa ter
along la kes and ri vers. and
in rolli ng agricultura l landscapes. Erosion control
effo rts in "qua tic areas
often incl ude the planting
of wetlands plants.
Wate r Purifica tion
Wetlands also clean thc
watcr by filtering o ut sedimentation and d ecomposing vegetable ma tter.
Wetlands pla nts help
Adventure,
Sports
-"'-
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, _ "_ _ n
..... ......,.
.......
,
4
convert nitrates and other
life-givi ng chemica ls. Soil
thai is inundated with
water is largely oxygen
free, and the microbes and
bacteria in upla nd soils
depend on oxygen to su rvive. TIle activ ity of such
bacteria is centra l to the
breakdown of n utrients into
fo rms usable by the rest of
the bio tic comm unity.
Some wetland s plants
actua lly pi pe oxygen dow n
into their roots, to provide
to special bacteria. Others,
as in peat moss, build up
huge, "a rtificial" g round
areas on wh ich bacteria can
work. Still others, such as
many noating leaf plan ts,
have d ispensed with the
use o f bacteria altogether
and ex tract needed nutrients from the water itsel f.
The ability o f wetlands
to recycle n utrients ma kes
them critical in the overa ll
fun ctioning of the ea rth . No
other ecosystem is as prod uctive nor as un ique in
this conversion process. In
some p laces, in fa ct.
artificial wetlands were
d eveloped solely fo r the
pu rpose o f water purification.
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S p r ill g 19 98
Canyon News Briefs
LCC LAWSUIT UPDATE
Logan Canyon Coa li tion's
lawsuit against UDOT and
the Forest Service is still in
place. We are now compiling
a list of docu ments we will
req uest from these ngencies
during the d iscove ry phase
of the lawsuit.
We are inte rested in
obtai ning copies of UDOT's
calcula tions of tra ffic flow in
Logan Canyon, for examp le.
Based on traffic counts a t a
si ngle loca tion, UDOT has
esti ma ted traffic flow in a ll
sections of the ca nyon highway. Yet there are serious
d iscrepa ncies in UOOT's estimations.
We wi ll request copies of
the surveys the Forest Service
has condu cted on sensitive
species in Logan Canyon.
The Forest Service has
cl aimed there will be "no
impact" of constructi on upon
et
these species. Y it appea rs
tha t for severa l of these
species the surveys have
been inadequa te, if they exist
at aU .
The documents we obtain
through d iscovery will help
LCC sa ve Logan Canyon from
ulU1ecessarily expensive and
destructi ve highway construction.
Deb Eshelman a CPA and
her daughter Amy Casa massa
come on boa rd as LCe's new
Co-Treasurers. Amy's work
w ill apply towards an adva nce
placemen t science cred it fo m
Jac k Green's Logan High class.
Welcome on boa rd.
Canyon Wind Ed itor Dan
Miller w ill be returning to
Cache Va lley to become more
active in LCC projects. He has
been living in Ogden, Utah
and Oregon as his wife pursued her ca reer. Welcome back
Dan .
• Uuknowu impact 0 11 trollt popllia tiolls.
UDOT's estimate is all IIlIeducated guess based
011 il/adeqllate data. COllstrllctiol/ ill the lower
cal/yoH reduced tlw trOll t populations ill sOllie
areas by 80%.
"Coffee with a Cause"
• regular '
$1 .00 is dona rBd ro LCC
Nigh1and Oay
ro.-"""'Y pound sold.
Logan Canyon Coalition is
up and running on the World
Wide Web. Check out our
homepage at:
http://www.logancanyon.org
�Home Canyon
by To m LyO
l1
Comi ng back from a
long trip east, we'd just
dri ven a few hundred
treeless mi les on a hot
and sunny da y. Most of
the last hours had been
in the mined and p um meled landscape of
south west Wyom ing, a
scene tha t hurts to look
a t. We climbed up fro m
Bea r Llke in third
gear- getting close
now, thirty-odd miles to
Logan- a nd then, over
the summ it, started to
s lip d own into the fold s
o f the hills, steeper a nd
closer on the sides as
we wen t, a nd the trees
aga in, the co mpan ionab le river soon to be
alongsid e. We
g limpsed a good-sized
bull moose moving o ff
through the w illows
along Bea ver Cree k. A
certa in sce nt came in on
the window-wind , a
secret fragrance mad e
up of w illow a nd sage,
toba cco bush, fir a nd
cottonwood, river
water, lime rock in the
sun, Loga n Canyon dirt
". we were ho me now.
When we fi rst s tarted tryin g to p rotec t th e
ca nyon from hi ghway
d rea ms, we had the
id ea that public-works
po li cy was p retty much
a rational process. You
sat d ow n w ith the highway d epartm ent a nd
the Fo rest Service, and
you entered the
canyon 's beauty a nd
re la tive intactness in to
the mi x, and the peop le's love for it, the fishing, the skiing, the hiking, the peace a nd quiet
and s lowness of it, th e
way it stood for a
w hole diffe ren t life.
You always men tioned
w ha t w as sadly true,
that Loga n Ca nyon was
the last of its kind of
pl ace in Uta h.
It was disappointing
that none of this ever
go t across to the highway department. Not
in all these yea rs. It
was as if you were talking a n en tirely d ifferent
language. But w hat
was rea lly stunning was
that the Forest Service
did n' t ca re ei the r. The
Forest Serv ice b lew off
its own Forest Plan, a
documen t supposedly
having the force of law,
in orde r to support the
h ighway d rea m. The
Forest Service should
have been the natural
a ll y of the ca nyon.
Instead, in the end, they
a nswered a d eta iled ,
187-page a ppea l (wh ich
a mo unted to the
Env ironme nta l Impa ct
Statement tha t should
have been d one by
those h ired to d o it)
w ith a page and a half
of bureaucratic dismissa l.
So w ha t we have
lea rned is tha t we are
on o ur ow n, and we
have to be tough a nd
pe rsistent if we wa nt to
be heard- if we wa nt
the canyon to be hea rd .
We can' t just expect
people to be rationa l,
and we can ' t assume
tha t everyone loves the
canyon more than they
love the h ighway
drea m. (Probably a lot
o f people think we can
have the o ld, good
ca nyon and a big hig hway through it.) This
w ho le time has been a
kind of edu ca tion in
realism. That's the
politica l part. In the
hea rt part, it's mad e us
th ink about w hat we
rea ll y va lue, firmed us
down to the home
things.
POSSESSfONS
28 FaSuai A l.ogan.lJI'. 84321
vt.
.......
'7:'.
(IIOU 755-0851
FIne l ob .. « o ,
Logall Ca lly o ll Post cards
Co u'!t'Syof
S tud io 404 rh o tog r.- phy,
Alan Hu es ti s
, ...,,,
J-. 5· s.5O I 4· , 6- S.75
USU nod
log.1n. Ulah 84322.{l L
99
a
M .. t dphy , ,, .. L N e rd ,
' d l 011, a H('f b ,
Pon(A1U>:I 0#
EDWARD Aaa EV
1[ NO t l t .50 IINO $l .oo
lee
USU 8 0l( .
L OCOIIN. U TilI!
Lee T·StliRfli· 512.00 (3 mlor)
'011.-0,,,
6
755-8657
�------== = ==
=
S p ri n g 1 9 9 8
Speak Now, Speak Oftell
Make Your Voice Heard
G overnment Officials
Letters to the Editor
What to Do
Governor Mike Leav itt
State Capitol Building
5.111 La ke City, UT 84114
Th e Herald Journa l
75 West 300 North
Logan, UT84321
Ph# 801-538-1000
Fax: 801-538-1528
e-mail:
governor@email.sta le.u t. us
Ph# 801-752-2121
Fax: 801-753-6642
Please w rite and urge
our government officials
and the public to re-evalua te UOOT's plans and to
consider the more fisca lly
prudent "Conservationists'
Alternative" that s ti ll
add resses the needs of
h ighway safety and Logan
Canyon. It is not a "do
nothi ng" proposa l.
Be su re to include your
fuJI name, address, signature (except e-mail) and
d ay time phone number.
Keep your letter short and
to the point. Write about
you r personal experiences
in the canyon and usc fac ts
to s upport your argumen ts.
Rep. Jim Hansen
U.S. House of Representatives
Washington D.C. 20515
Ph# 1-202-225-0453
Fax: 1-202-225-5857
Rod ney Terry
Project Manager, UOOT
169 North Wall Ave.
PO Box 12580
Ogden, UT 84412
Ph# 801-399-5921, ext3Q5
Fax: 801-399-5926
Brian Ferebee
District Ranger
USFS, Logan District
1500 East H ighway 89
Logan, UT 84321
Ph# 801-755-3620
Fax: 801-755-3639
e-mail: hjletter@hjncws.com
The Salt Lake Tribu ne
Public Forum
PO Box 867
$.1[t L.1ke City, UT 84110
Fax: 801-237-2022
Deseret News
Readers' Forum
PO Box 1257
Salt Lake Ci ty, UT 84110
Fax: 801-237-212 1
e-mail: Letters@desnews.com
The Standard-Exam iner
PO Box 951
Ogden, UT 84402-095 1
Ph# 800-234-5505
Ph# 801-6254222
Fax: 801-625-4508
('-mai[: Letters®Standard.net
LOOK FOR O[' R :>IE\\
AW
ORLD
Or
Tha n k you for
yo u r h e l p!
"Ell PA(a: AT:
Logan Ca nyon You r Destin ation?
&
- Backpa ckin g . S kii ng -Climbing -Hiking
- Snows hoein g . S ig htseei ng
Accent5
57
IANN • loGANUT l?4 g21
117 North Main SI
7
�r-----------------------,
YES! I
WANT TO
JDIN THE
LOGAN CANYON COALITION
and rece ive a s ubscription to CANYON W1ND
o $20.00 Annual Membership
o I would like to contribute an additional
$10 $20 $30 $40 $50 Lots more
o I would like to volunteer.
o Here's $12.00 for a great T-s hirt.
o I' m broke! Here's five bucks.
o Please add m y name to your mailing list.
p/IIs SJ shippillK
Name _______________________________
H
RA
PRINTING
LD
(0.
5Ireel._____________________________
Cily_ _ _ _ _ _ Slale'____ Zip, _____
Email _____________
Phone#
Please
check p" Y.l ble and mail to:
Logan Canyon Coalition
USU Box #1674
L _______________________
Logan, UT 84322-0199
43
SOUTH
LOGAN ,
10 0
UTAH
WEST
84321
TEL .43 5 .752. 0311
FA X 435 .753.3 161
Please consider a donation to LCC. All donations will be used for the protection of
Logan Can yon. LCC wants to tha nk the hW1dred s of individuals, businesses a nd
fOW1dations who have contributed tin1e, money and expertise towa rds the lega l
d efense of Logan Canyon. Your generous support is appreciated.
BU LK RATE
U.S. I'OSTAGE
Paid
COAL:l:T:l:O:N'
Work ing for th .. P rotection of L og.n Canyon
Logtl1r. UT
N"SO
USU Box #1674
Logan, Utah
84322-0199
II' Plea se Renew
YOllr
Melllbership Today
�A NEWS B ULLETIN FR OM L OGAN C ANYON C OALITION
Vol. 3 No.1
Sum mer 1999
Logan River is Eligible for
Wild & Scenic Designation
In January the Wasatch-Cache National al value of this river segment. Concerning recreForest released its draft Rivers Eligibility Study. ation, "highly scenic pristine rivers/ corridors are
This study reports that Beaver Creek and a twen- of higher value" (draft Eligibility Study). The
ty mile-long segment of the Logan River are eligi- Forest Service is mandated to protect the scenery,
ble for Wild and Scenic Rivers designation. The recreation, and other outstandingly remarkable
Logan River segment has been found to have five, values of rivers eligible for Wild and Scenic desmore than any other river in the forest, outstand- ignation.
ingly remarkable values including scenery, fishUDOT is planning cuts into the mountaineries, recreation, ecology, and geology I hydrolo- side at Upper Twin Bridge that will be vertical or
gy. The Logan River is truly the jewel of the "as vertical as possible." This was not evaluated
Wasatch-Cache National - - - - - - - - - - - -- -- - - - - in the FE IS or In
Forest.
UDOT's Record of
We believe that the
Decision. We still do
of
not know how extenUtah
Depa rtment
the Logan as Utah's first
Transportation's (UDOT's)
sive these cuts will be.
Wild and Scenic River
nex t phase of highway
Vertical rock cu ts will
construction w ill harm ___...._______________ not revegetate and will
these values. We are asking that a Supplemental harm the natural appearance and hence the
Environmental Impact Statement be required for scenery and recreational value of this river corrithis highway project.
dar.
Recent design p lans show tha t UooT is
We a re concerned that construction
planning to build approximately 2,275 feet of impacts on Wild and Scenic values are not being
retaining wa lls adjacent to the Logan River seg- evaluated properly. There was no detailed evalument eligible for designation. These wa lls were ation of impacts in either the Final Environmental
not evaluated in the FEIS for this project or in Impact Statement or in the Record of Decision.
UooT's Record of Decision. Seventy-five percent UooT intends to evaluate the impacts of the next
of these walls will be "basket walls," which are phase of construction in a Reevalua tion document.
wire baskets filled with rocks. These walls are not This entirely ignores the impacts of the remaining
attractive in a na tu ral setting. They will not highway project.
appear natura l and will harm the scenery of this
UDOT and the Forest Service are segmentriver segment. They will also harm the recreation- ing this project in their evaluation of impacts
Leave a True Legacy
�Wild & Scenic ("...".."d)
which is a violation of Forest
Service policy and the National
Environm en tal
Policy
Act
(NEPA). From recent design
plans, the next phase of construction covers on ly about
three and a half miles of highway. UOOT is planning an additional approximate ly thirteen
and a half miles of highway
const ruction that will potentially impact Wild and Scenic values, from the Dugway to the
canyon summit.
The danger of segmenting this
project is that once the next
phase of construction is underway, UOOT will be committed
to its larger highway project
with uneva luated and potentially damaging impacts to the
Wild and Scenic va lues of these
rivers. Issues that should be
addressed include: what will be
the ex tent of the required retaining wa lls and vertical cuts as
construction is extended into
th e remaining upper Midd le
Canyon? Will we see a miniDugway a long Uppe r Twin
Bridge and Temp le Fork? In
short, how ugly is this going to
get? According to Forest Service
policy, "Groups of actions,
when added together, may have
collective or cumulative impacts
which are Significant.
Consideration must be given to
the incremental effects of past,
present, and reasonably foreseeable related future actions of the
Forest Service, as well as those
of other agencies and individuals."
We have requested that a supplemental
Environmental
Impact Statement (SE IS) be
required for this highway project in which the entire project
is evaluated with respect to the
Wild and Scenic va lues of these
rivers. Forest Service policy
requires that there be an SEIS
whenever there are "significant
new circumstances or information relevant to environmental
concerns .... " Surely the fact
that the Logan River segment
and Beaver Creek ha ve been
found eligib le for Wild and
Scenic designation is significant
new information. in an SEIS the
purpose and need for a ll
planned construction should be
clearly demonstrated . While we
agree that some highway
r'OSSESS'ONS
28 Federal Ave. Logan, Uf. 84321
Home Accessories,
CoUectibles,
Jewelry,
Gifts
755-0857
2
improvements are needed, such
as replacing the worn bridges,
UOOT has never demonstrated
the purpose and need for their
extensive proposal.
We agree with this statement
by Drew Parkin, an expert on
Wild and Scenic Rivers policy, " .
. . designation as a wild and
scenic river will not preclude
improvement to the highway. It
would, however, require that
UDOT take special precautions,
both in design and construction,
to ensure that the road does not
alter flow regimes, that important
natural
and
scenic
resources are preserved, and
that short-term disruptions to
the river are minimized. Even if
this costs a little more, it would
result in a superior project that
multiple
meets
long-term
needs."
& A«t'ssones
M f'taphyslcdl N t'ed ..
E..
Oil s & HNbs
11
755-8657
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capt.ure a
child's
ima8inaLion!
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".
... A ....,nu.,O lo9 .. n
UT
•
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Toys
*
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75 HlO'5 5
�- -- -- Summer 19 99
Dear Logan City Council:
CANYON LOVERS
My wife and I lived in Logan from 1955, when we came as college stud ents,
until just last yea r. We raised three sons in Logan, and Logan will always be
our heart's country. We absorbed Cache Valley. The silhouette of the mountains, east up the canyon and west across the valley, is still the horizon line
of O UT life.
I wou ldn't mention this background if I didn't think a great many people
share such feelings. Few things go as deep as the sense of home.
Unfortunately, sometimes the deepest values get taken for granted. We're all
very busy. We can even forget to think about the abso lute beauty and purity
of Logan River, coming down the canyon and through the town. Su rely
there can't be many towns anywhere in the world that can say: a wild, clean
river comes down ou t of the mountains to us; there is no one, no town,
upstream.
I think about Logan River a lot these days. Our irrigation and drinking
wa ter here in coastal California is sparse; it comes a long way, and it has
been used several times. There is no way, with all the engineering capability
in the world, we could create the kind of situation Logan has.
So, speaking from deep care for Logan and from the knowledge of how easy
it is to lose natura l resources, and how hard it is to get them back, I respect-
fully urge the Council to endorse Logan River as a Wild and Scenic River.
Logan is lifeblood. Please protect it.
Sincerely,
Thomas J. Lyon
_ , eo-.-. soo .....
PLEASE RIDE
YOUR BIKE
W EB SITE D eSIGN, D eVELOPMENT,
H OSTING, AND P ROMOTION SERVICES
http://zmorlner.com
Info@zmoriner.com
435-755-6595
138 Norm'i 100 EAsT
lOGAN. UtAH 84321
4351753-3294
MoN. - SM.
10:00 .... 1.4 . - 6:00 P.M.
G
PEVINE
II
3
-_
---
,t
l
*" U__l_ '
• ll
... .... ....,
we
Dan Miller
Jaynan Chancellor
Deb Eshelman
Gordon Steinhoff
Derek Staab
Graham Hunter
Kevin Kobe
Tim Wagner
John Carter
Amanda Th immes
Mark Lunt
Bridgett Kobe
Creed Clayton
Carolyn StOnge
Brooke Bigelow
Jim Vandygriff
Coalition
Supporters
-R ick Bass
-Terry Tempest
Williams
oRobert Redford
-C.L. Rawlins
-Sierra Club
-Utah Rive rs Council
-Tom Lyon
-National Rive rs
Coalition
-Maki Foundation
�Canyon News Briefs
Sincere Gratitude
Members of the Logan Canyon
Coalition wou ld like to wholehea rtedly thank Dan Miller for all he has
done for the orgaruza tion . Dan has
lead Lee during his year as president with tremendous energy and
insight. Under his leadership several important adva nces have been
made for Lee including a commitment to getting the Logan River
designated as Utah 's first Wild and
Scenic river.
Dan continues to be active in
Lee, and we are always grateful for
his common sense and unwavering
support. Tha nks Dan, and we wish
you the best w ith your ex tra ti me!
Lee Board of Directors
LOOKING AH E AD
Fall Fundraiser
Lee is proud
to announce its fall
fundraiser: Jerry Joseph and the Jack
Mormons. They will be playing in
the Amphitheatre on Old Main Hill,
USU campus on September 3rd at
7:00 PM . Tickets will be $7 for nonstudents and $5 fo r students.
Giardia Run
Thursday, September 9th at 5:49
PM. Meet at the HPER on the USU
camp us and run to the White Owl.
$15 includes a T-shirt; $10 without.
This year 's theme: Y2K!!
Get Inspired!
Announcing the first annua l " Art
from the River" celebration. Send
your artistic entries inspired by
Logan River (painting, d rawing,
pottery, writing, textiles, or music)
to Brooke Bigelow, 1371 E. 900 N.,
Loga n, Utah 84321. All entries will
be honored at the River Festiva l on
September 18th and special recognition will be given to outstanding
entires in each of three categories:
children 3 to 5 years old; children 6
to 12 years old; and children 13 and
over. Be sure to include your name,
phone number, and age with your
ent ry.
Christmas Auction
With the completion of Dan's
term as preSident, managing and
governing responsibilities for LCC
are being handled through a temporary board of directors. A permanent board will be installed by vote
at the next Lee general meeting in
January. Any LCC member interested in being on the board of directors
should attend bimonthly meetings,
the fi rst and third Tuesday of the
month at 7:30 at Merlin Olsen
Central Park (100 South 200 East).
Logan River Festival
The second annual Logan River
Festival will be at First Dam from
noon to 3 PM on Saturday,
September 18th. Bring your kids,
neighbors. and friends and come
enjoy the Logan River. There w ill be
games, canoe rides, art activities
and displays, and vendors. (For
more informa ti on or to get in volved,
contact Jaynan Chancellor at 7532553.)
Adventure
Sports
4
It's not too early to be thinking
about the LCC Christmas auction.
Watch fo r fur ther details. In the
meanwhile, gather those donations
or services suitable for auction, and
continue the gift by donating your
"classy junque" to be treasured by
someone else for a recycled
Christmas. For more information or
to store donations, contact Jaynan
Chancellor at 753-2553 or Brooke
Bigelow at 753-5682. Thanks for
your generous contribution!
�Summer 1999
Memo To: Brian Dixon, Bridgerland Audubon, Chris Wilson, Cache Anglers, Kathy Gilbert, Citizens For
Protection of Logan Canyon, Dick Carter, High Uintahs Preservation Council, Jon Marvel. Idaho Watersheds
Project, Dan Miller, Logan Canyon Coalition, Ron Younger, Utah Chapter Sierra Club, Barrie Gilbert, Utah
Wildlands Heritage
From: John Carter, Willow Creek Ecology
Re: Logan Canyon/Logan River Protection Zone
I am writing this as a result of the many issues and activities involving Logan Canyon/Logan River, includ ing the
recent land swap, ongoing highway construction, increasing recreational use, second home development, logging
and continued livestock grazing all affecting wildlife, habitat, water quality and aesthetics. Those of us who love
Logan Canyon and all it symbolizes, and the reluctance of the Fores t Service to effec t progressive change as evidenced by the recent rejection of our appeal of the Bear Hodges project show us we ca nnot depend on science or
logic alone. It also shows us that we need community support and unity among ourselves with SOfl)e common
goals and objectives.
To this e nd , I am s uggesting the Logan Canyon/Logan River Protection Zone that recognizes the high quality of
the scenic and wildli fe attributes of the Logan River Watershed, and urges protection. Because of the many sensitive species or habitats recogni zed by the Forest Service as exis ting in the Logan Canyon area and are threatened,
as a group we should demand protection of these watersheds, elimination of livestock grazing and other destructive forest practices and that a p roper value be placed on the natural attributes of the Canyon.
Because of the Bonneville Cutthroa t Trout a nd its potential listing as endangered, Willow Creek Ecology expanded
its monitoring of the Logan River and its tributaries at the end of 1998. We are collecting samples at up to 20 locations, docume nting s ilt loadings, fecal coliform pollution and other general water quality parameters. We are also
assembling a data base of Logan River stud ies of water quality, fisheries, invertebrates, habitat and hydrology.
Our initia l purpose is to comment to the Fish and Wildlife Service in support of listing since a large portion of
Bonneville Cu tthroat Trout populations in Utah exists in the Logan River. Many factors threaten its continued existence including habitat alteration and whirling disease.
I think it is important that we discuss how to combine our efforts and concerns into an effective strategy, gai n public support and pressure the Forest Service and other public entities toward our chosen goals. We saw how iIIinformed the City of Logan was on Wild and Scenic River Status. I think we should use quality of life, economics
and watershed health as driving factors in gaining public support for protection. After all, the watersheds above
Sa lt Lake City are worthy of protection for a variety of reasons, why not here?
�Leave A True Legacy
The Logan as Utah's First Wild and Scenic River
We the undersigned hereby declare oui' support for segments of the Logan River to be designated as Utah 's first Wild
and Scenic River under the federal Wild and Scenic Rivers Act of 1968, as long as that designation doesn't
interlere with traditional uses now enjoyed by the public.
Signature
Print name
Street
City
Siale
Zip
-------------------------+-------------------------+------------------------+---------------------+----t------------ ;
•
z
•
.;
•
•
"
•
,
-------------------------f-------------------------+------------------------+----------------------f----t------------ "
i
-------------------------t-------------------------t------------------------+---------------------1----1------------ 2
•
•
RETURN CO M P l ET E O P ETITIO N S TO THE LOG A N CA N YON COALITION. USU BOX. fl6H . LOGAN. U TAH U 322·01 99
�NOT LATER
WRITE NOW!
Wild and Scenic
Bernie We ingardt
The Wild and Scen ic Rivers Act of
1968 is unique among environmental
Jaws in the world because of its p oten tial
to protect free-nowing rivers and riversections. Yet less than one percent o f the
nation 's total river m iles is included in
the National Wild and Scen ic Rivers
System, and NOT ONE o f Utah 's beautiful rivers has th is outstanding d is tinction.
In 1998 the 30th anniversary of the
Wild an d Scenic Act was celebrated
across the nation. Lee is hoping to
extend thai celebration to Utah before
another 30 yea rs passes with the designation o f the Logan River as Wild and
Scenic. Pub lic support is crucial to m a king th is happen. Show your su pport by
encouraging policy-m a kers to leave a
true legacy in Uta h and recomme nd th e
Logan Ri ver as the firs t Uta h river
inducted into the N a tio na l Wild a nd
Scenic Rivers Syste m .
T h a nk yo u for
your h e l p!
T he Salt l ak e Tri bune
Wasatch-Cache Nationa l Forest
8230 Federal Building
125 South State Street
Salt Lake City. Utah 84138
Public Forum
PO Box 867
Salt Lake City, UT 841 10
Fax:
Bria n Fe re bee
District Ranger
U5FS, Logan District
1500 East Highway 89
Logan, UT 84321
Ph# 435-755-3620
Fax: 435-755-3639
Desere t New s
Readers' Forum
PO Box 1257
Salt Lake City, UT 84110
Fax: 801-237-2121
e-mail: Letters@desnews.com
Logan City Counci l
255 North Main, Logan
UT,84321
The S ta ndard-Examiner
PO Box 951
Ogden, UT 84402-0951
Phil 800-234-5505
Ph# 801--6254222
Alan D. Allred
Karen S. Borg
John L. Harder
e-mail: Lelters@standard.net
Ja nice Pearce
Stephen C. Thompson
Mayor Douglas E. Thompson
Lette rs t o the Edit or
The H e rald Journ al
75 West 300 North
Logan, UT 84321
Ph# 435-752-2121
Fax: 435-753-6642
e-mai l: hjletter@hjnews.com
A WORLD
Logan Canyon Your Destination?
&
-BlCkpildc.in g oS ki ing - C lim b ing oHiking
oSno ws hotin g oSightstt in g
Accents
57 Sourn MAIN • locAII Uni'49 21
753·3497
7
�r--------------------,
J WANT TO JOIN THE
LOGAN CANYON COALITION
LOGAN RIVER
and receive a subscription to CANYON WIND
SCENIC RIVER
YES!
""""
UTAH'S Uri. WILD aad
o $20.00 Annual Membership
o I would like to contribute an additional
$10 $20 $JO $40 $50 Lots more
o I would like to volunteer.
o Here's $12.00 for a great T-shirt.
o I' m broke! Here's five bucks.
o Please add my name to your mailing list.
,llUllu.;,.,;",
LEAVE A
LEGACY
n
•• LOG"_ AI UrAl" 'Ian WItD "_D IC'_IC a",.
Name ________________________________
Streetl ________________________________
City, ______:State
Phone'
Zip, _______
E-mail _____________
Plun ..... ke check
Support the Logan River
and null to,
include shipping
Logan Canyon Coalition
USU Box'1614
L _____
Order these new Wild and Scenic bumper
stickers for the Logan River. A $2.00
donation for each sticker will
_____
Please consider a donation to Lee. All donations will be used for the protection of Logan
Canyon. Lee wants to thank the hundreds of individuals, businesses, and founda tions who have
contributed time, money, and expertise towards the legal defense of Logan Canyon.
Your generous support is appreciated.
.... ...................
Wi
!!
=-=--
. . . . . . . . . _ . . . . . . . . _ • •;:.... _ .
-
- ---
!!'
--= =
-
BULK RATE
US POSTAGE
- -
Paid
CO.4.L:J:T:J:ON
Loga", UT
Pnm,' N° 39
WorkIng f o r Ih e Prolullo n of l oga n Canyon
USU Box #1674
Logan, Utah
84322-0199
.,t
Please Renew Your
Membership Today
�
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LCC newletter, "Canyon Wind"
Description
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Newsletters updating the events of Logan Canyon Coalition including but not limited to the formation of LCC, denial of appeal, violations of FEIS, lifting of the stop work order, and the eligibility of Logan River for wild and scenic designation.
Contributor
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Kobe, Kevin
Lyon, Tom
Wagner, Tim
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Logan Canyon (Utah)
Wilderness areas
Public lands--Utah--Logan Canyon
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Newsletters
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Logan Canyon Coalition
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1995
1996
1997
1998
1999
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Logan (Utah)
Cache County (Utah)
Utah
United States
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1990-1999
20th century
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eng
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Utah State University, Merrill-Cazier Library, Special Collections and Archives, Citizens for the Protection of Logan Canyon/Logan Canyon Coalition Papers, 1963-1999, COLL MSS 314 Box 1 Folder 8
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View the inventory for this collection at: <a href="http://uda-db.orbiscascade.org/findaid/ark:/80444/xv63458">http://uda-db.orbiscascade.org/findaid/ark:/80444/xv63458</a>
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Reproduction for publication, exhibition, web display or commercial use is only permissible with the consent of the USU Special Collections and Archives, phone (435) 797-2663.
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Highway 89 Digital Collections
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MSS314Bx1Fd8
Highway 89;
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c9f2681871dc67d47bca3d7ce872f5be
PDF Text
Text
· /:
,
Pete Morton, Ph.D.
Environmental Consultant
9390 W. 14th Avenue
Lakewood, CO
80215
(303) 202-0442
pmorton@du.edu
February 27, 1996
Peggy Wood
67 1/ 2 S. 500 West
Logan, UT 84321
Dear Peggy:
Thanks for your phone call, I was hoping you would find me, as I
had lost your number and address. Jill and I hope to close on our
new home soon -- at which time our address and phone number will
change -- so e - mail may be the best form of communication until
then.
As I mentioned on the phone I thought the Appeal to the Chief was
excellent and raised some important and valid points.
had
some
time
to
pull
together
environmental audit of t h e FEIS.
the following pages.
my
initial
I
thoughts
finally
for
an
I will briefly outline them on
If the Coalition would like me to expand the analYSis , I will have
some time later this spring, but my summer and fall schedule is
filling up quickly. Let me know.
t1:
re
,
Pete Morton
P.S.
Have you been able to obtain the Environmental Grant book
from Island Press?
�PRELIMINARY ENVIRONMENTAL AUDIT OF THE
FINAL ENVIRONMENTAL IMPACT STATEMENT
LOGAN CANYON HIGHWAY
Prepared by
Pete Morton, Ph.D.
1.
page 9-1 1.
(9.3.2.12) .
The cost-benefi t analysis was deleted
in the FEIS because of the difficulty of assigning costs and
benefits of aesthetic values. Although t he se non-market costs
and benefits are difficult to estimate, there are many
economic studies published in peer-reviewed journal s that
estimate recreation, environmental and aesthetic va lues.
People may also be willing to pay to insure that Logan Canyon
will exist in its present form for future generations to enjoy.
Such non-use, intangible benefits have also been recogn i zed in
the economic literature and are included in es timates of total
economic value . Some discussi on on n on-use benefits and total
economic value of recreation in Logan Canyon seems warranted .
2.
page 9-12
(9.3 .2.13)
The traffic growth rates should be
carefully examine.
Do these rates take into cons ideration
transportation imp'rovements planned elsewhere in the regi on?
Are individual projects double counting? The r-squared may be
too low and there may be other problems with the regression.
How many years o f data were u sed to calibrate the regression
used for the projections?
3.
page 9- 1 2
(9 . 3.2.14) Forest Plan compli ance . Is this based
on compliance with t h e old forest plan?
The forest plans
developed during the fir st round of forest planning t h at I
have reviewed need serious revisions .
A better question to
ask is whet her the planned construction is conSistent with
ecosystem management and the new concepts (e . g. landscape
analysis, etc.) that should be used to develop new forest
pl ans.
4.
The FEIS makes assurances that a revegetation plan will be
prepared and implemented to mitigate the direct and indire ct
impacts to wildlife .
How much will the revegetation plan
cost?
Where will the money come from ?
What budget
constrai nt s exist that will prevent full implementation of the
plan?
In the past , federal agencies have ignored budget
constraints in planning. This failure should be a concern in
these times of s h rin king federal a nd state budgets.
Logan Ca nyon FEIS
Morton
Page 1
�5.
page 9-39. The DEIS stated that mining and logging were major
use s along the project area. Although this was revised in the
FEIS, did this statement impact the Forest Service decision to
approve the project?
6.
page 9 -4 2 . The issue of noise was raised a nd its impact on
recreation experiences. How did they evaluate noise impacts
to determine they were less than 3 dBA? Construction projects
involving heavy equipment will decrease the quality of the
recreational experience .
Even if temporary, the decline in
recreation experiences during construction should be included
as an economic cost in the benefit-cost analysis.
7.
page 9-42.
One of the important facto rs contribut ing to a
quality recreationa l experience (whet her fishing, hiking or
driving for pleasure) is scenic beauty, or visual quality .
Scenic beauty should be an important management consideration
because of the steep slopes in Logan Canyon. Steep slopes are
c l assified by landscape architects as "visually vulnerable",
meaning they have an inherent resistance or susceptibili ty to
degrading visual impacts. The steeper the slope, the greater
its visible surface and the greater the potential for
increased visual disruption.
8.
page 9-43.
Conunent pl23.
The FEIS states that UDOT ' s
deCision not to undertake visual quality improvements for the
Conservationist's alternative was because the improvements did
not justify the costs. This decision cannot be made without
a benefit-cost analysis -- which was dropped from the FEIS.
If a B-C analysis was completed, what benefits were attributed
to improvements in visual quality?
The improved visual
quality in the Conservationist's alternative should be counted
as a benefit in a B-C ana l ysis, while the costs of decreased
visual quality in the preferred a lte r native shou ld be counted
as a cost.
9.
page 9-45.
The short term loss of Class II fisheries is a
cost that should be counted as such in a B- C analysis . Will
budget constraints prevent full
rehabilitation of the
fisheries:
There is also some risk that the mitigation and
rehabilitation efforts will fail .
If rehabilitation efforts
incl ud e the replacement of native fish with stocked fish there
may be some loss of genetic diversity and some long-te rm costs
in terms of a potential decline in the health of native fish
populations.
Page 2
Morton
Logan Canyon FEIS
�10.
page 9-65. As pointed out by the Mayor
will be significant economic impacts
construction. How long is the proposed
Will the Conservation Alternative be a
of Garden City , there
during the proposed
construction project?
shorter project?
I did not see much discussion of the economic impacts on local
communities. These impacts may be very significant for small
businesses
unable
to
survive
the
con s tru c ti o n-indu ced
recession . The discussion of employment impacts should focus
on net j ob change -- job creation l ess potential job losses .
Also, not all jobs are equal.
Small business owners and
employees that live and spend money in a community are more
important to a local economy ( may have a higher multiplier)
than temporary, non-local construction workers that live and
spend their paychecks elsewhere -- and who may move on after
the project is completed .
11.
page 9-75.
Dr . Wilson points out the potential long-term
impacts on fish populations from channelization, etc.
Once
again, these impacts represent economic costs that should be
included in the benefit-cost analysis .
12.
page 9-79 . Although the B-C was not included in the FEIS, Ken
Theis points out that it undervalued the recreation time spent
in the canyon and overesti mates the benefits of speed. This
is probably correct. Researchers have estimated the benefits
of recreation and an economic analysis of those recreation
benefits in Logan Canyon could be completed .
One method u sed is the travel cost method where recreation
benefits are partially based on travel time . Typically travel
time is multipli ed by a percentage of hourly wage to estimate
the recreation benefits from travel .
A decrease in travel
time as a result of the construction may actually represent an
economic cost from a recreation standpoint.
In addition, if the construction increases speed, and if
"speed kills", than there may be a safety cost associated with
the construction.
Accidents at higher speeds can be more
severe and frequent. Are there any studies that contrast the
safety records of wider, faster highways with slower highways
with pullouts through canyons?
Logan Canyon FEIS
Morton
Page 3
�13 .
page 9-87. Comments from Brad Lengas , a doctoral student at
Utah State, indicate that the FEIS ignored the impacts of the
large -scale highway con s truction di s turbances o n populations
of 9 different bat species. This could be significant as bats
provide an ins ect control service to humans -- a service with
potentially significant economic benefits. HBats consume all
type s of insects, including those which are obnoxi ous to
humans (one Little Brown bat can con sume 600 mosquito s per
hour) and tho s e which can cause crop damag e (various beetles
and bugs)."
Sc ientists note that predation plays an important role i n
ending pest e pidemics and in lengt hening the periods between
pes t outbreaks.
If the bat populations decline, insect
infestations may be longe r, more frequent and mor e intense.
In a ddition to increased crop damage, increased insect
populations will decrease the quality o f all forms of n onwinter recreation, with a r esulting l oss of benefits.
The
FEIS should address the impact of constru ction on b at
populations, the potential benefits of sustaining ba t s and
t h e ir habita t , and the costs of not doing so.
14.
page 9-89 . Scott George provides an e x ce lle n t critique of the
DE IS .
He raises an interesting alternative of build i ng a n
add iti onal medical facility rather than extensive highway
improveme nt s . How g reat is the emergency med ica l n eed of Rich
County res idents? Can a small satellite c lini c or h ospital
handle this n eed?
What are the costs of bu ildi ng such a
fac ili ty and how do they compare to the additional hi g hway
constr uction costs of the chosen alterna ti ve?
Potential benefits of the hospital construction al t ernative
include: 1) short term con stru ction jobs ; 2) long-term, hi g h
paying me dic a l jobs and residentiary se r vice jobs; and 3)
improved i nfrastruc ture a nd health serv i ces that will enhance
future economic development potential in Rich County.
15.
page 9 -1 30 . Comme nt s by Ken Theis poi nt o u t t h e appa ren t bias
in the benef it- cost calcu lus.
His observations seems to be
correct . Miti gat ion costs should be incl u ded in the B/C, and
the recreation benefits shou l d be f ully accounted for.
Page 4
Morton
Logan Canyon FEIS
�,I
May 10, 1995
Mr. Jack Ward Thomas, Chief
USDA Forest Service
P.O. Box 96090
Washington, D.C. 20090-6090
Re: Notice of Appeal and Statement of Reasons
USDA Forest Service, Intermountain Region, Record of Decision
U.S. Higbway 89, Logan Canyon
Wasatcb-Cacbe National Forest
Dear Mr. Thomas,
Pursuant to 36 CFR part 215, the Logan Canyon Coalition and the Utah Rivers
Conservation Council hereby appeals the USDA Forest Service, Intermountain
Region, Record of Decision concerning U.S. 89 through Logan Canyon in the
Wasatch-Cache National Forest. This decision was signed on March 31 , 1995 by Dale
N. Bosworth, Regional Forester. This decision amends the Wasatch-Cache National
Forest Land and Resource Management Plan so that it is consistent with the Utah
Department of Transponation's (UDOn modified Preferred Alternative, as described in
UDOT' s Record of Decision. The Forest Service is also granting a transportation
easement across the Wasatch-Cache National Forest to UDOT for the sake of this
project.
Appellants base their appeal of this decision on the reasons included herein.
Thank you for your assistance.
Sincerely,
enclosure
Kevin Kobe, President
Logan Canyon Coalition
(801) 753-5031
�NOTICE OF APPEAL AND STATEMENT OF REASONS
Pursuant to 36 C.F.R., Part 215
Appellants:
Logan Canyon Coalition
U.S.U. Box 1674
Logan, UT 84322-0199
(801) 753-5031
(80 I) 753-0497
Kevin Kobe, President
Jaynan Chancellor, Treasurer
Dr. Gordon Steinhoff
Tim Wagner, Vice-President
Dan Miller, Secretary
Dr. Thomas J. Lyon
Steve Flint
Don R. Hickman
Utah Rivers Conservation Council
1471 South llOO East
Salt Lake City, UT 84105
(80 I) 486-3161
Zachary Frankel, Director
Counsel for Appellants:
Ms. Kate Zimmerman
1320 Claremont Drive, Boulder, CO 80303
(303) 494-1706
Decision Document:
USDA Forest Service, Intermountain Region, Record of Decision,
March 31, 1995
U.S. Highway 89, Logan Canyon
Wasatch-Cache National Forest
Deciding Officer:
Dale N. Bosworth, Regional Forester, Intermountain Region
2
�Decision Appealed:
We appeal the decision to:
(i.) amend the Wasatch-Cache National Forest Land and Resource Management Plan
so that it is consistent with the Utah Department of Transportation's (UDOT) modified
Preferred Alternative, as described in UDOT's Record of Decision, and,
(ii.) grant a transportation easement across the Wasatch-Cache National Forest to
UDOT for the purpose of implementing the modified Preferred Alternative.
We seek the reversal of this decision until UDOT provides a Supplemental
Environmental Impact Statement in which they better document the need for, and the
environmental and economic impacts of, the modified Preferred Alternative. Also, we
seek the reversal of this decision until UOOT scales down its construction proposal so
as to present a genuine compromise between desired Level of Service and
environmental constraints. UDOT should reconsider the Conservationists'
Alternative, as described in Appendix A of this appeal. Finally, we seek the reversal of
this decision until the Forest Service has reevaluated the segment of the Logan River
from Lower Twin Bridge to Beaver Creek for Wild and Scenic River status.
Reasons for Objecting:
Appellants believe that UDOT has not adequately justified the need for its
modified Preferred Alternative through considerations of safety, AASHTO design
standards, traffic flow, or Level of Service. UDOT has not adequately assessed impacts
to wildlife, the fishery, wetlands, or water quality in Logan River. Negative economic
impacts have not been evaluated. UOOT's Record of Decision introduces aspects of
road construction, such as batch plants and haul roads, which were not evaluated in
the FEIS. Visual quality will be impaired in a manner inconsistent with guidelines
contained in the Logan Canyon Scenic Byway Corridor Management Plan.
Furthermore, the Forest Service has agreed that the segment of the Logan River
from Lower Twin Bridge to Beaver Creek might be eligible for Wild and Scenic River
status, and that it should be reevaluated. A segment of the Logan River has been
identified as having, potentially, more outstandingly remarkable values than any other
river in the Wasatch-Cache Forest. Appellants are concerned that construction of
UDOT's modified Preferred Alternative, with its associated impacts to the river and to
the scenery, will degrade this river segment enough that it will no longer qualify for
Wild and Scenic status.
The Conservationists' Alternative improves the highway to an adequate extent,
while minimizing environmental and economic impacts. UDOT's modified Preferred
3
�Alternative is, therefore, neither reasonable nor necessary.
Appellants believe that the Forest Service's Record of Decision violates
guidelines within the Wasatch-Cache National Forest Land and Resources
Management Plan concerning wildlife, fisheries habitat, road construction, water
quality, and economic impacts. The Forest Service is therefore in violation of the
National Forest Management Act. The Forest Service is also in violation of the
Federal Clean Water Act Antidegredation Policy that protects water quality and
designated uses of Logan River. With its dec ision to allow extensive construction
before Logan River is reevaluated for Wild and Scenic River status, the Forest Service
is in violation of the 5(d) planning requirements of the National Wild and Scenic
Rivers Act. The Forest Service is also violating guidelines and objectives within its
Logan Canyon Scenic Byway Corridor Management Plan. Finally, with its inadequate
designation of 4(f) sites within Logan Canyon, the Forest Service is in violation of the
National Transportation Act.
Appellant's objections and reasons are described in more detail below.
On January 11 , 1995, representatives of the Logan Canyon Coalition,
appellants, met with Mr. Reese Pope, Forest Planner for the Wasatch-Cache National
Forest. We handed Mr. Pope a copy of our agenda for the meeting that outlined our
concerns with UDOT's modified Preferred Alternative. We told Mr. Pope that UDOT's
safety discussions in its Final Environmental Impact Statement (FEIS) and Record of
Decision (ROD) appear to be based upon flawed traffic and accident data. Mr. Pope
told us that traffic and accident data is "not our province," referring to the Forest
Service. Appellants believe, however, that ensuring the accuracy of traffic and
accident data;s within the province of the Forest Service when a citizen's group that
can document serious study of this data indicates that this data is problematic. Our
concern is that the Fores t Service is permitting an extensive construction project in the
National Forest that is unnecessary.
We also told Mr. Pope of our concern that UDOT' s assessment of fishery
impacts is inadequate. We told him that we are worried, for example, that UDOT has
underestimated fish mortality by providing a simplistic account of the effects of
increased sedimentation. Mr. Pope replied that the predicted decrease in HCI value
appears to be within acceptable limits. Appellants still believe, however, that UDOT's
fishery discussion, induding its analysis of HCI, is inadequate.
Finally, we told Mr. Pope of our concern that proposed road construction will
hann the scenic and free-flowing characteristics of the Logan River enough that it will
not qualify for Wild and Scenic status when it is reevaluated. Mr. Pope expressed his
opinion th at proposed construction will not hann the eligibility of this river.
4
�Appellants respectfully disagree, and will argue in this appeal that the Wild and
Scenic Rivers Act requires that the Logan River receive interim protection until it is
reevaluated.
Several individual appellants, Dr. Thomas J. Lyon, Steve Flint, and Dr. Gordon
Steinhoff, can document long-standing interest in UDOT's construction plans in
Logan Canyon. We have been involved in early scoping hearings and on a UDOT
interdisciplinary team. We have written many letters to UDOT and other agencies
concerning UDOT' s DEIS, FEIS, and its Record of Decision.
The Utah Rivers Conservation Council, an appellant, is a non-profit
organization dedicated to achieving Wild and Scenic status for those rivers in Utah
that qualify. The long-standing interest of this organization in Logan River is
documented within the book A Citizen's Proposal to Protect the Wild Rivers of Utah,
written and researched by Zachary Frankel, Director of the Utah Rivers Conservation
Council.
STATEMENT OF REASONS
This Statement consists of the following sections:
I. History and Background, 2. Safety Issues, 3. AASHTO Standards and Highway
Design, 4. Wild and Scenic Rivers Issues, 5. Fishery Impacts, 6. Wildlife Impacts and
Sensitive Species, 7. Visual Retention, 8. Economic Impacts, 9. Wetlands, 10. Water
Quality, 11. Construction Impacts Not Evaluated in the FEIS, 12. 4(f) Sites.
There is also an Appendix that contains:
A. a map of Logan Canyon Highway 89, B. a description of the Conservationists'
Alternative, C. photos of the sensitive areas discussed in this appeal.
1. WSTQRY
AND BACKGROUND
The Logan Canyon project was originally envisioned as a bridge replacement
project, and has gradually evolved into a more extensive, 15 to 20 year construction
project. The scale of the project has generated massive opposition by area residents, as
evidenced by 309 letters in support of a lesser alternative, as opposed to 21 in support
of the Modified Standard, an alternative similar to the Preferred Alternative (FEIS,
Table 9-1). Hundreds of additional opposing letters were sent to the Utah Department
of Transportation (UDOT) in response to UDOT's adoption of the Preferred Alternative
as described in its Final Environmental Impact Statement (FEIS) (on file with Nadene
Steinhoff, Bridgerland Audubon Society). Numerous letters to the editor and local
5
�newspaper editorials opposing the Preferred Alternative have been published (Herald
JourfUJl, Cache Citizen, The Statesman, 1988-95). Four hundred protesters rallied in
the canyon in 1992 (Salt Lake Tribune, Deseret News , Herald Journal, Cache Citizen,
KTVX Channel 4 News (ABC), KUTV Channel 2 News (NBC), April 25 and 26, 1992;
High Country News, June 1, 1992). UDOT received 682 signatures supporting a lesser
alternative prior to 1993, and hundreds of petition signatures after the release of the
FEIS, including petitions from Business People for the Canyon, Citizens for the
Protection of Logan Canyon, Logan Environmental Action Force, the Cache Sierra
Club, and Bridgerland Audubon Society (FEIS, Table 9-1).
Early in the process, citizens groups submitted their own highway improvement
alternative. The Conservationists' Alternative is described in Appendix B.
Appellants believe that the Utah Department of Transportation has never
justified the need for a project as extensive as the Preferred Alternative. even as it has
been modified in UDOT's Record of Decision. In the "Purpose and Need" section of
the Draft Environmental Impact Statement (DEIS), UDOT relied heavily on the need
for a reduction in travel time, pointing to the economic benefits of travelers being able
to cut 4 to 8 minutes off their trip. Their costlbenefit analysis was based on
inappropriate assumptions that undervalued the time spent in the canyon and
overvalued the speed with which travelers moved through the canyon (DElS, Table 47). Logan Canyon has been recognized in numerous national magazines, for example,
the recent Audubon magazine (Bass, 1994). It was one of the first designated Forest
Service Scenic Byways. It is not merely a traffic conduit.
After an extensive barrage of public criticism at the idea of trading serious
environmental impacts for a 4 to 8 minute reduction in travel time, UDOT abandoned
its rhetoric about the time savings (FEIS, pages 9-3 to 9-151). Travel time is not
mentioned in the FEIS as a justification for this project. Rather, UDOT relies on
considerations of safety and Level of Service (FEIS, 1-3 to 1-18). The DEIS clearly
stated, however, that "safety is not a primary reason for this project" (DEIS, page 1-22).
Less than two pages were devoted to safety in the DEIS. Appellants believe that this
shift in attempts to justify the project between the DEIS and FEIS is evidence that this
project is not clearly justified. The modified Preferred Alternative is, literally, a
construction project in search of a justification.
UDOT's traffic and accident data is seriously flawed, and yet the Forest Service
has accepted this construction project even after being informed of these flaws
(Bridgerland Audubon Society letter to the Forest Service dated May 2, 1993; Logan
Canyon Coalition meeting with Reese Pope, Jan. 11 , 1995). UDOT's accident severity
data show a correlation between high speeds and high numbers of fatalities and serious
accidents on the already widened and straightened section of highway in the Lower
6
�Canyon. Appellants are concerned that the Forest Service is permitting UDOT to build
a more dangerous highway.
The gain in Level of Service with the modified Preferred Alternative over the
Conservationists' Alternative is marginal. and comes at the cost of greater
environmental destruction (FEIS, Table 2-1). UDOT and the Forest Service are not
taking advantage of flexibility allowed by the American Association of State Highway
and Transportation Officials (AASHTO), and by the Federal Highway Administration,
in order to protect scenic and environmental resources. UDOT and the Forest Service
also ignore recommendations from the Intermodel Surface Transportation Efficiency
Act of 1991 (ISTEA), caUing for greater emphasis on public involvement in highway
design, preservation of scenic beauty, recognition and preservation of Scenic Byways,
and prevention of adverse effects on water quality and wetlands.
UDOT has attempted to portray the Logan Canyon Scenic Byway, classified as
a minor arterial, as a critical link in the nation 's highway system. This attempt to
justify the project is dishonest. The FEIS displays maps portraying U.S. 89 through
Logan Canyon as a critical undeveloped link in a highway system connecting Mexico
with Canada (FEIS, Figure I-I). Logan Canyon is actually a small mountain highway
that will never provide a critical link due to its mountainous, steep terrain and the fact
that it has already been bypassed by alternative routes. 1- 15 is the highway that is of
primary importance in the area, connecting all points south, including Provo, Salt
Lake City and Ogden, with all points north, including Pocatello, Idaho Falls, Butte
and Helena. 1-80 is the major east to west route for commerce, not Logan Canyon (see
Appendix A). As a route from Salt Lake City and Ogden to Yellowstone and the Grand
Tetons, Idaho State Highway 34 will always be faster than the Logan Canyon highway
due to the more rugged terrain of Logan Canyon.
Garden City, at the other end of the Logan Canyon highway, is a small town of
193 people (1990 census), down from a 1980 population of 259. UDOT is proposing
extensive widening and straightening of a highway that has already been bypassed
by faster, alternative routes, and that serves a town of 193 residents, with a population
that has declined by 25% over the past ten years. The entire population of Rich
County (in which Garden City is located) has been declining over the past ten years.
The 1990 population was 1,725, down from the 1980 population of 2,100, a reduction
of almost 18 %, with several key industries moving away from Rich County in recent
years (Bureau of the Census 1994; Utah Governor's Office of Planning and Budget
1993). Appellants believe that this steady population decline is a good indication
that High way 89 does not require the extensive modifications UDOT is proposing.
By accepting UDOT's modified Preferred Alternative, without adequate
justification, the Forest Service is in violation of guidelines in the Wasatch-Cache
7
�National Forest Land and Resource Management Plan concerning unnecessary road
construction (1985, page IV-44).
Much attention has focused on the modifications UDOT has introduced into the
Preferred Alternative as it is described in UDOT's Record of Decision. We believe that
these modifications don't go far enough when viewed in tenns of the countervailing
requirements of the Management Plan and federal laws.
Literature Cited
Bass, R. 1994. Keeping Logan Canyon. Audubon Magazine, Nov.lDec.
Bitton, M. 1992. Partisans of Logan Canyon protest a widened road. High Country
News, June I, 1992.
Lyon, Dr. Thomas J. 1992. The road gang wants to wreck Logan Canyon. High
Country News, June I, 1992.
USDA Forest Service. 1995. Record of Decision (ROD), U.S. Highway 89.
United States Dept. of Commerce, Economics and Statistics. Bureau of the
Census. 1994.
Utah Department of Transportation (UDO"D. 1990. Draft Environmental Impact
Statement (DEIS), U.S. Highway 89, Logan Canyon. Prepared by CH2M
Hill.
Utah Department of Transportation. 1993. Final Environmental Impact
Statement (FEIS), U.S. Highway 89, Logan Canyon. Prepared by CH2M Hill.
Utah Department of Transportation (UOO"D. 1995. Record of Decision (ROD), U.S. 89
Through Logan Canyon.
Utah Governor' s Office of Planning and Budget. 1993. Utah Demographic Report.
2. SAFETY 1SSUF.5
1. The Forest Service has adopted the FEIS, as is mentioned on page 1 of its Record of
Decision. The FEIS, in its purpose and need section, uses a clearly flawed safety
analysis (in violation of the requirement for agencies to insure scientific integrity of
analyses as stated in 40 CFR, Ch. 5, 1502.24). Thus the Forest Service's decision to
8
�•
adopt the FEIS is arbitrary and capricious, as the FEIS does not meet the "standards for
an adequate statement" (40 CFR, Ch. 5, 1506.3a).
2. We have evidence that the proposed construction will result in a more dangerous
road, thus violating the requirements of the Wasatch-Cache National Forest Land and
Resource Management Plan that "public safety needs" be considered regarding the
Logan Canyon highway (1985, page IV-311) .
The Management Plan says about the Logan Canyon highway, "The road will
not be raised to a higher standard than existing" (1985a, page 236; FEIS, page 9-88).
Thus the only true justifications for highway modifications are improvements
necessary for safety and replacement of deteriorated structural elements. However, the
Forest Service has blindly accepted the UDOT safety analysis, despite the fact that the
public had openly disputed UDOT's analysis of safety literally for two decades. The
current UDOT analysis utilizes artificially inflated and manipulated traffic volumes,
inconsistent with UDOT's own traffic counts, in an attempt to make the previously
widened portion of the road (Lower Canyon) appear safer than the unwidened sections.
In addition, UDOT has refused to make any reasonable comparisons of accident
severity, although these data are available in the technical memorandums. Citizens
have long contended that the type of highway modifications proposed here will make
the roadway less safe. Our analysis supports this position.
Accident rates are simply accidents per million vehicle miles. Only elementary
arithmetic is needed for their calculation. What is being questioned here is not the
method of calculation but the numbers used in these calculations.
In 1986, the Interdisciplinary Team was presented with accident rate data in the
fann of computer printouts. These printouts contained accident rates for specific
sections, and also the section length, traffic flow, and accident numbers--all the
infonnation necessary to calculate accident rates. The representatives of the
environmental community on the tearn at that time (Rudy Lukez, Jack Spence, Bill
Helm, and Steve Flint) discovered that the printed accident rates could not be derived
from the accompanying data. The consultants, CH2M Hill, were informed of this, but
presented the flawed data at the September 1986 public meeting in Logan. Rudy
Lukez had to interrupt the presentation to remind the consultants of the problems with
the data. At that time, UDOT and their consultants withdrew the accident rate data
since they found the errors intractable. Subsequently, accident rates were never
mentioned for over six and one half years. During this time the December 1990 DEIS
stated, " .. . safety is not a primary reason for the project ... " (DEIS, page 1-22). Accident
rates were not mentioned in the DEIS, but they suddenly appeared in Table 1-2 of the
March 1993 FEIS.
9
�,
It appears that the accident rates were introduced into the FEIS for two reasons.
One was an attempt to make the Lower Canyon look like the safest part of the road.
This was done by manipulating the traffic volumes in the Lower Canyon upward, thus
reducing the calculated accident rates (the higbway here was widened in the 1960's).
The second use of accident rates was to make it look like the road was quickly
becoming much more dangerous. This was done by drastically reducing traffic flows
in recent years along the rest of the highway. This caused the accident rates to rise,
giving the appearance of a much more dangerous road in recent years. UDOT claimed
a 44% increase in the accident rate as one went from the 1980-'85 period to the
1986-'90 period (page 1- 10 of the FEIS).
It is a straightforward procedure to backcalculate the traffic flows (average
annual daily traffic, abbreviated as ADT or AADlj used in calculating the accident
rates in Table 1-2 of the FEIS. These data are shown in our Table I for each section of
the highway, and the percent change in traffic flow is calculated. Clearly, if one could
believe these data, there are massive reductions in traffic in Logan Canyon in recent
years. In one section of the Middle Canyon, for example, the reduction in recent years
is supposedly almost 80%! Since such massive reductions is clearly not the case
(measured traffic flow is discussed below), the UDOT safety argument based on these
accident rates is meaningless. The response of UDOT to the presentation of tbese ADT
derived from their table was to issue the statement,
"The ADT presented in Revised Table 1-2 are estimates made by UDOT and
are used to calculate the accident rates in segments. However, estimates are
changed periodically as additional information concerning census and other
data is made available. The two periods shown on the table may be
misinterpreted to indicate that there has been a decrease in traffic in the
canyon between the two periods studied. To determine actual usage of the
canyon you should examine the actual traffic count information measured in
the canyon. Year to year counts should also be examined to determine the
trends since variations in traffic usage occurs each year." (October 15, 1993
UDOT press release, distributed at the meeting of the State Transportation
Commission).
Why UDOT believes it should be able to take measured traffic counts for past
years and adjust them according to census and other information is beyond belief.
Clearly, they do not know wbat they are doing.
At the time they issued the above statement, they issued a revision of Table 1-2,
correcting some of the grossest errors for the 1980-'85 period. In examining our Table
I, you will note that there appear to be periodic massive infusions and deletions of
traffic from the highway. These are clearly spurious since only unpaved roads
10
�intersect this highway between Logan and Garden City. Their revised Table 1-2
corrects this, but still shows decreases in more recent years. We show this in our Table
2. Since UDOT provided ADT in the revised table, we did not need to backcalculate it
from the accident rates.
Actual traffic flow can be found in Figure 1-4 of the FEIS . While the FEIS does
not provide a location in the canyon where these traffic volumes are reported to occur,
referring to the 1987 Technical Memorandums makes it absolutely clear that these
numbers represent traffic at Card Canyon (within the mp 378-383.3 section). For all
other Iccations in the canyon, this number is scaled either up or down by a factor.
UDOT has never provided these factors to the public, however they can be
backcalculated from the traffic flow data used in the accident rate calculations. We
have found that these factors vary in a curious manner from table to table. For
example, in the traffic flow projections figure (FEIS, Table 1-5), the decrease in traffic
flow as one goes "up" the canyon (to higher milepost numbers) is much less than is
evident from the accident rate data. Thus UDOT is using vastly different factors at
different times. When they want low traffic in the unwidened portion of the canyon (to
make accident rates high), they use large factors. When they want high traffic in the
unwidened portions of the canyon (to justify highway widening) they use small
factors .
Taking averages for Card Canyon, from Figure 1-4, gives 1812 cars per day for
1980-'85 and 1844 for 1986-'90. This shows a small increase of 1.8 % in the measured
average annual traffic flow between these two periods, rather than the decrease shown
by UDOT's accident rate data (our Tables I and 2) . It also shows that UDOT is using a
traffic flow value in its accident rate calculation for the mp 378-383.3 section that is
1.6 times the measured value in Figure 1-4. There is no logical reason for this
discrepancy. This high traffic flow very effectively decreases the accident rate in this
section. It is blatant fabrication of data that cannot be ignored.
The distortion for the section immediately below, the lower Lower Canyon, mp
374.64-378, is even greater. (UDOT has never produced a method we consider
reasonable for detennining traffic flow in the lower Lower Canyon .) UDOT claims to
have calculated this traffic flow using a method described on page 5 of the Appendix
to their Record of Decision. A traffic flow of 14,000 cars per day is reported for the
section of Highway 89 that lies below Logan Canyon, south of Utah State University
(page 5 of the Appendix to the ROD, mp 373 approximately). Although this section is
well outside Logan Canyon, the traffic flow for this section, representing heavy
University traffic, is artificially "extended" up the canyon to increase the traffic flow
in the lower Lower Canyon, mp 374.64-378 . The rate of 14,000 cars per day is
averaged using a weighting method with a traffic flow of 3,000 cars per day claimed
for the Lower Canyon. This calculation is reported by UDOT to yield a weighted
11
�traffic flow for the lower Lower Canyon, mp 374.64-378, of 7500 cars per day.
However, adhering strictly to the formula for this calculation presented on page 5 of
the Appendix actually produces a value of 4,015 cars per day. UDOT is not only
"extending" University traffic up the canyon to artificially inflate the traffic flow in
the lower Lower Canyon, it has also miscalculated this traffic flow to obtain a value
nearly twice what the formula actually provides.
We would expect to see this number, 4,015 cars per day, in subsequent tables,
yet it never appears. Values of over 6 and 7 thousand cars per day are given in revised
Table 1-2,4510 is used in the accident severity table (page 7 of the Appendix), and
3367 is used in the new accident rate table (page 3 of the Appendix). Part of the
problem is that the milepost section shown on page 5 of the Appendix coincides with
the milepost section in Table 1-2, but does not coincide with section designations in
the other tables.
Rather than attempting to guess how these errors occurred, we will argue that all
of the traffic flows provided by UDOT for the lower Lower Canyon are excessive. The
calculation method presented on page 5 of the Appendix (ROD) has no basis in reality.
What it has done is take a "commuter roadway" outside of Logan Canyon (U.S. 89
south of Utah State University) and use that traffic flow for the first 0.31 miles of
Logan Canyon--an area with DO intersecting roads. The only realistic traffic flow for
the lower Lower Canyon would be something slightly greater than the traffic flow
reported in Figure 1-4 of the FEIS. Despite ten years of time to do this, UDOT has
instead fabricated elaborate methods designed to intimidate the reader (for example,
the material on page 5 of the Appendix to the ROD). Their data showing literally
thousands of cars daily driving into the canyon and turning around in the first few
miles (there are no intersecting roads here) is blatantly absurd to anyone familiar with
the location.
In UDOT's Record of Decision, another attempt is made to analyze accident
rates. This was done because of our repeated questioning of both the original and
revised accident rate data in Table 1-2. (During negotiations with UDOT in 1994,
Dave Berg ofUDOT admitted that UDOT's traffic flow data was literally "garbage,"
hence this additional effort to salvage the safety argument in order to show purpose
and need). This new analysis is conducted for a more recent period, 1989-'93 (ROD,
Appendix, page 3). This new analysis appears to be based on one day's traffic count in
1994, and gives a value of 3367 cars per day for the Lower Canyon where the counter
is located. This is greatly in excess of the 1869 cars per day (1990 data) shown in
Figure 1-4 of the FEIS. Clearly, one day cannot be selected to represent a 5 year
period of traffic flow, because both absolute numbers of cars and the proportional
change in traffic through the canyon differs during different seasons. To further
complicate any reasonable comparison of data, this new analysis subdivides the road
12
�<
into different segments than we find in Table 1-2 (which was retained in the ROD).
How can any comparisons be made with the 1980's data? Clearly, given UDOT's
inability to count cars accurately over this ten year period, we question whether any
UDOT traffic flow data can legitimately be used in this EIS.
Accident severity is a much more important parameter than simple accident rate.
(Refer to the minutes of the interdisciplinary team meeting of August II, 1986, item
#6, review of accident data. From page 3: "Duncan Silver (FHW A) said that a goal
should be statistical reliance and that the number of accidents was not as important as
the severity of the accidents.") In their Record of Decision, UDOT presents accident
severity data for the first time since the 1987 Technical Memorandums (UDOT's ROD,
Appendix, page 7). Their analysis is flawed in two ways. One flaw is that only
fatalities are analyzed. Fatalities are fortunately so infrequent in Logan Canyon (8
fatal accidents for the period UDOT analyzed) that their distribution is statistically
random. The second flaw is that UDOT attempted again to tie them to traffic flow,
calculating a fatal accident rate. Again, the traffic volumes are inflated for the Lower
Canyon (4,510 cars per day for a section with a measured traffic flow of scarcely over
1,800 cars per day).
It is clear that UDOT is unable to provide any consistency in traffic flow data
collection, and thus safety cannot be evaluated by any technique requiring traffic flow
data. This continual manipulation of data has made a mockery of the directive for
agencies to use "scientific integrity" in the process outlined in the National
Environmental Protection Act, 40 CFR, Ch. 5, 1502.24. Thus, this FEIS does not meet
the "standards for an adequate document" which 40 CFR, Ch. 5, 1506.3a requires for
an agency to adopt an EIS. Hence, the Forest Service's adoption of this FEIS is
arbitrary and capricious.
We propose average accident severity as a measure of highway safety. This
comparison is numerically independent of traffic flow. UDOT made these calculations
in the 1987 Safety Technical Memorandum, in Table 3-7. The greatest accident
severity was found in the widened section of the highway. (However, it is not clear
how these calculations were done; attempting to repeat them by averaging the data in
Table 3-8 of the Technical Memorandum does not produce the same average accident
severity values as given by UDOT in Table 3-7.) One could argue that the more
severe the accident, the greater the "weighting" it should be given. Of course these
weightings are arbitrary, but it appears that the method UDOT used was strictly
incremental. We have used a method of increasing the "weight" given a more severe
accident in our Table 3. Again, the widened section of the highway has the most
severe accidents.
Clearly, driving at a speed inappropriate for a section of highway is the
13
�overriding cause of accidents (1987, Table 3-4). Widening and straightening a
highway, without a large concomitant commitment to speed limit enforcement, simply
increases the speed at which it is traveled. It is no surprise the severity of accidents
increases. The issue of speed limit enforcement as a means of improving safety was
raised during the EIS process, but UDOT ignored it. The construction alternative
endorsed by the Forest Service will produce a more dangerous highway, and as a
consequence, the Forest Services' s Record of Decision violates the stipulation of the
Management Plan requiring that safety needs be considered for the Logan Canyon
highway (page IV-3111).
Literature Cited
USDA Forest Service. 1995. (ROD) Record of Decision, U.S. Highway 89.
USDA Forest Service. 1985. Wasatch-Cache National Forest Land and
Resource Management Plan.
USDA Forest Service. 1985a. Wasatch-Cache National Forest Land and
Resource Management Plan; Final Environmental Impact Statement, Ch.6.
Utah Department of Transportation (UOOn. 1995. (ROD) Record of Decision, U.S. 89
Through Logan Canyon.
Utah Department of Transportation. 1993 . (FEIS) Final Environmental Impact
Statement, U.S. Highway 89, Logan Canyon. Prepared by CH2M Hill.
Utah Department of Transportation. 1987. Technical Memoranda. Prepared by
CH2M Hill.
14
�•
Table 1 . Average daily traffic (ADT) bacKcalculated
from Table 1-2 in th e FEIS , and the percent change as
one goes from the early ' 80 ' 5 to the late '80's .
sections
and
mileposts
Lower
3 7 4. 6 4
378 . 00
Middle
383.00
384.40
387.00
388.40
Upper
39 1. 60
392.70
395 . 60
399.40
Rich
404. 75
408.20
410.10
ADT
' 80 - '8 5
from
Tab 1 - 2
ADT
'8 6 -' 90
from
Tab 1 - 2
5710
2820
4693
2969
-17.8
5.3
2004
1815
8323
2990
2372
1815
1742
1781
18 . 4
- 0.0
- 79.1
- 40.4
5239
1840
1979
122 5
1811
1631
1614
1259
- 65.4
-11.4
- 1 8.4
2.8
1383
2247
1277
1164
1292
1228
- 15.8
- 42.5
-3. 8
Percent
Change
canyon
- 378.00
- 383.30
-
Canyon
384 . 40
387.00
388.40
391.60
Canyon
392 ;70
- 395.60
399.40
- 404.75
-
County
408.20
410 . 10
- 411.87
-
-
�•
Table 2. Percent change from the early to late
1980's using UDOT's revised average daily tra ffic
(ADT) as contained in their revised Ta ble 1-2
of t he October '93 press release and (except
for values with *) in their Janu a ry ' 95 ROD. The
percent change for the values changed in the
ROD are given in parentheses.
section
and
'80-'85
mileposts
ADT
' 86 -' 90
Percent
Change
ADT
Lower
374.64
378.00
Canyon
378.00
383.30
6865
2824
7417*
3019
Middle
383.00
384.40
387.00
388.40
Canyon
384.40
387.00
388.40
391. 60
2824
1888
1847
1847
3019
1864
1809
1809
6.9
- 1. 3
- 2.1
-2.1
Upper
391. 60
392.70
395 . 60
399.40
Canyon
392.70
1809
16 80
1613
1257
-2.1
399.40
404.75
1847
1826
1815
1351
- 11.1
- 7.0
Rich
404.75
408.20
410.10
County
408.20
410 . 10
411.87
1299
1298
13 96*
1246
1292
1295
-4.1
- 0.4
-7. 2
395.60
8.0
6.9
(5.3)
- 8.0
(-1. 8)
�Table 3. An index of average accident severity
using data from Table 3-8 of the 1986 Safety
Technical Memorandum (the Technical Memorandums,
all from about 1986, are considered the
"backbone" of the EIS). We have used an increasing
scale for accident severity, weighting "property
damage only" as 1 , "possible injury" as 3,
"nonincapacitating injury " as 7, "incapacitating
injury" as 15, and "fatality" as 31.
Average
Accident
Severity
Widened roadway:
Lower Canyon
(section 0)
6.03
Middle Canyon (section 1)
5.00
Upper canyon (section 2)
4.07
Rich county (section 3)
3.89
Unmodified roadway:
�3,
AASHfO STANDARDS AND IDGHWAY DESIGN
UDOT argues that they must widen and straighten the Logan Canyon Highway,
and add passing lanes, in order to accomplish four major goals. They argue that they
must enhance safety, satisfy AASHIO standards, improve traffic flow, and improve the
capacity of the road to accommodate projected future traffic volumes (FEIS, page 1-3).
We have dealt with safety issues in the previous section of this appeal. In this section
we will discuss the other three goals.
By accepting UDOT's modified Preferred Alternative, the Forest Service is
accepting a road design that allows for unnecessary and unjustified construction in
environmentally sensitive areas of the canyon. The Wasatch-Cache National Forest
Management Plan specifies, as a guideline, that design speeds allowed on roads in this
Forest shall be a "compromise" between desired travel speed and constraints imposed
by the environment (page IV-44). Road design in the Forest must, therefore, also be a
compromise between desired travel speed and environmental constraints. We shall
argue that the road design the Forest Service is accepting in Logan Canyon, with its
decision in favor of the modified Preferred Alternative, does not represent such a
compromise. The Forest Service is therefore in violation of its Management Plan.
Guidelines within this plan are to be "applied in all situations unless some overriding
reason to abandon" them is supported by a Forest Service interdisciplinary analysis
(page IV -24).
AASHTO Standards
UDOT attempts to justify the modified Preferred Alternative by appeal to safety
standards that have been devised by the American Association of State Highway and
Transportation Officials (AASHIO).
AASHTO standards are environmentally friendlier than UDOT admits.
AASHTO recommends flexibility in the design of arterial roads in mountainous areas
where the terrain limits road design. Our first criticism of UDOT's use of AASHIO
standards is that UDOT is not taking advantage of the flexibility in road design that is
allowed by AASHIO.
In the FEIS, UDOT claims that the recommended minimum design speed for a
minor arterial road is 50 miles per hour. Based on this claim, UDOT condemns the
entire Logan Canyon highway, asserting that " the existing highway is therefore substandard" (FEIS, page 1-8). In the special circumstances of mountainous terrain,
however, AASHTO relaxes the minimum design speed for a minor arterial to 40 miles
per hour, down from 50 miles per hour, when, as in Logan Canyon, the daily hourly
volume is over 400 (UDOT 1987, page 7-12; Claire Hendrickson, FHWA, personal
15
�communication),
The current design speed for the section of highway through the Upper Canyon,
40 to 55 miles per hour, actually complies with standards allowed by AASHTO for
mountainous terrain. UDOT has set the design speed from the Beaver Mountain
intersection to over the canyon's summit at 50 miles per hour. By AASHTO standards,
this design speed makes necessary a wider. straighter road. UDOT is insisting on a
design speed, however, which is higher than the minimum allowed by AASHTO for
mountainous terrain.
In this section of highway the conditions are not appropriate for a uniform
design speed of 50 miles per hour. This is particularly true at the summit, where UDOT
plans to widen the road to 40 flo, and put in a passing lane and 22 ft. "clear zones" on
either side of the highway. There is a beautiful grove of mature Douglas Fir at the
summit. The road now winds through this grove, which has appropriately been called
a "cathedral" (Bass 1994). As UDOT plans it now, in its legally-binding FEIS and
ROD, a side canyon will be filled, and roughly one half of these mature trees will be
torn out to make room for the widening and a big curve-cut at the summit. (please see
the photo of the summit we have included in the appendix of this appeaL) The
resulting destruction to the side canyon, the trees and the views at the summit strongly
suggests, we believe, that conditions in the Upper Canyon do not warrant using the 50
miles per hour design speed, plus a passing lane, through this area. UDOT is using
AASHTO standards inflexibly, when AASHTO allows flexibility in design in special
circumstances such as these.
Our second criticism of UDOT's use of AASHTO standards is that they use these
standards in a manner that is arbitrary and capricious. For example, UDOT plans to
widen the highway in the Upper Canyon, from the Beaver Mountain intersection to
over the summit, to 40 flo The design speed is set at 50 miles per hour. Below this
intersection, for about eight miles, UDOT is planning a design speed of 50 miles per
hour, but they intend to widen the road to only 34 flo For this design speed, a road
width of 34 ft. is below AASHTO standards (Roy Nelson, FHW A, personal
communication). Exemptions from AASHTO standards are occasionally granted by
the Federal Highway Administration. Why does UDOT apply AASHTO standards in
this flexible fashion in the lower Upper Canyon, but insist on strictly applying full
AASHTO standards above Beaver Mountain?
UDOT's ROD includes an internal memo from a UDOT safety engineer, who
asserts that a 34 flo road width at this design speed is adequately safe. He cites studies
that report "little change on accident rate when going from 5 to 8 foot shoulder," in
other words, when going from a 34 flo road width to a 40 ft. width. This safety engineer
concludes that while keeping to a 34 ft. width may be substandard, "for this project"
16
�,
this width "would be acceptable" (UDOT 1995, Appendix A, pages 9 and 10). We
have included a copy of this memo at the end of this section of our appeal. In its 1987
Technical Memoranda, UDOT further defends the use of the 34 ft. width. They write,
"A reduction from the standard 8-foot shoulder to the 5-foot shoulder can be
justified in that while the 8-foot width is desirable for parking, a distressed
vehicle can get out of the traffic stream yet remain on the paved surface with a
5-foot shoulder. The narrower shoulder also provides enough room for cyclists
and pedestrians, with minimal interference with motorized vehicles." (1987,
page 7-7)
UDOT is arguing here that a 34 ft. road width is adequately safe and acceptable. In the
FEIS, UDOT praises the safety record of the already "improved" highway in the Lower
Canyon. As UDOT points out, this section of highway has a safety record that exceeds
expectations (FEIS, page 1-9). This section of highway is 34 ft. wide.
As we have described above, the summit of Logan Canyon is particularly
beautiful; the road winds through magnificent old Douglas Fir. Roughly one-half of
these trees will be lost if UDOT widens the road here to 40 ft. and puts in the planned
passing lane and 22 ft. "clear wnes," following the alignment specified in the FEIS
and the ROD. UDOT is relaxing AASHTO standards in order to use the 34 ft. width in
the lower Upper Canyon, below Beaver Mountain. A UDOT safety engineer has
argued that a 34 ft . width is "acceptable" from a safety standpoint, citing studies that
show this. The "improved" highway in the Lower Canyon, which is 34 ft. wide,
exceeds safety expectations. Exemptions from strict AASHTO standards are granted.
It seems the most arbitrary and capricious of decisions to end the 34 ft. width at Beaver
Mountain, and insist upon a 40 ft. width above Beaver Mountain, with the resulting
unacceptable destruction to a side canyon, trees and scenery at the summit.
Another example of UDOT's arbitrary and capricious use of AASHTO standards
is in their plans for the highway in the Middle Canyon. In the lower Middle Canyon,
up to Lower Twin Bridge, UDOT intends to maintain the current design speed of 25
miles per hour, and the current width of 26 ft. They intend to widen the road above
Lower Twin Bridge to 34 ft. , increasing the design speed to a uniform 35 miles per
hour. A design speed of 35 miles per hour is below AASHTO standards for a minor
arterial highway, but, UDOT argues, this design speed is closer to design speeds
recommended by AASHTO.
UDOT attempts to justify ending the 26 ft. road width at Lower Twin Bridge by
saying that "the roadway begins to move further away from the river at this point"
(UDOT 1995a). This statement is patently false. The highway closely follows the
river throughout much of the Middle Canyon above Lower Twin Bridge, particularly
17
�along the Dugway and at Temple Fork intersection, where the highway closely
parallels the river, rising ahove the river on a very steep slope. (Please see the photos
we have provided in the Appendix to this appeal.) Widening the highway in this
section of Logan Canyon will negatively affect the scenery, water quality, and the
fishery. These impacts could be quite serious. UDOT plans to cut 4 to 8 feet into the
mountain at the Dugway for 3/4 of a mile, with extensive widening and curve cuts at
and below the Temple Fork intersection. They plan to place a retaining wall in one
section of the Dugway. There is the risk of extensive retaining walls being placed
throughout the Middle Canyon. UDOT has told us that whenever they cannot
revegetate a slope, they must install retaining walls (Lynn Zollinger, UDOT engineer,
personal communication) .
Located just below Lower Twin Bridge is a documented brown trout spawning
area. Good conditions for trout spawning are relatively rare in Logan River. Fisheries
biologists have informed us that road widening in the Middle Canyon, with associated
curve cuts, will possibly increase the level of sedimentation below Lower Twin Bridge
to the point that there will be significant loss of trout eggs, a sharp decline in food
production for trout, and loss of juvenile brown and cutthroat trout due to clogged
gills. UDOT has refused to do a quantitative analysis of sediment-related impacts,
even when publicly asked to do so by the Forest Service. The possibility of serious
impacts to the scenery and the fishery can be minimized by extending the 26 ft. width
another four miles up to ahove the Temple Fork intersection. This would mean
leaving the upper Middle Canyon at its current design speed of 25 to 35 miles per
hour.
Considering that the highway closely parallels the river in the Middle Canyon
above Lower Twin Bridge, and considering the possibility of serious negative impacts
in this narrow section of the canyon if the road is widened and straightened, it is
arbitrary and capricious to end the 26 ft. section at Lower Twin Bridge.
Let us summarize our concerns so far with UDOT's use of AASIITO standards.
UDOT insists upon using full AASIITO standards in an area where unacceptable
environmental destruction will result, even though AASIITO allows flexibility when
designing a road in mountainous areas where the terrain limits what can be done. It is
not the intent of AASHTO to sanction unnecessary environmental destruction (Amy
Steiner, AASIITO, personal communication). Also, UDOT applies AASHTO standards
in an arbitrary and capricious fashion, without good justification for decisions to
apply these standards in a stricter rather than in a more flexible fashion.
UDOT portrays the curves in the upper Middle Canyon section of highway,
ahove the Lower Twin Bridge, as being unsafe according to AASHTO standards. On
page 2-23 in the FEIS, UDOT criticizes the Conservationists' Alternative for failing to
18
�bring these curves up to AASHTO standards for the posted speed. In Utah, however, a
highway' s posted speed is often a compromise between design speed and the speed
that drivers actually attain. When not federally mandated, posted speed is determined
by calculating the speed that 85 percent of drivers are going. UDOT's proposed
design speed for the upper Middle Canyon is a uniform 35 miles per hour, with
extensive widening and straightening of the road. Drivers would very likely feel
comfortable driving at speeds higher than 35 miles per hour on this widened and
straightened stretch of highway. After all, the current posted speed is 35 miles per
hour. Following standard practice in Utah, the posted speed may again inch up above
design speed, as posted speed is brought more in line with the speed that drivers
actually attain. After UDOT's "improvement" of this highway, these curves would still
fail to satisfy AASHTO standards for the posted speed. Even if UDOT were to keep to
a 35 mile per hour posted speed, as they say they will do in their ROD, the curves in
the upper Middle Canyon would fail to meet AASHTO standards for the speeds that
drivers will very likely be doing through this section of highway. The problem UDOT
points to in its criticism of the Conservationists' Alternative, that the curves are unsafe
according to AASHTO standards, will not really be solved by the modified Preferred
Alternative. The real problem, of course, is that drivers tend to exceed the speed a
road is designed for. This problem will likely only be made worse as UDOT widens
and straightens this section of highway.
Improve Capacity of tbe Higbway to Accommodate Projected Traffic Volumes
UDOT uses a range of projected traffic volumes to argue, for example, that the
present highway, without improvements, will provide a dangerously low level of
service by the year 2010, and that continuous passing lanes are justified throughout
the canyon above Right Hand Fork (1987, page 7-11).
UDOT obtains its projections of traffic volumes by fitting a linear equation to
past measurements of traffic volumes on the Logan Canyon highway, and by fitting a
linear equation to past measurements of the population in northern Utah, in Cache,
Box Elder, and Rich Counties. UDOT obtains a range of projected traffic volumes
through the year 2010 by using these linear equations to project into the future.
UDOT argues that linear equations should be used, rather than exponential,
logarithmic and power equations, because linear equations have been found to best fit
the data (1987, pages 4- 6 through 4-11).
UDOT's projections are of future swnmer traffic volumes. Since 1973, annual
traffic volumes have remained constant (FEIS, Figure 1-4). UDOT is designing the
canyon highway purely for anticipated summer traffic, and more exactly, for
anticipated summer weekend traffic. UDOT reports that summer weekend traffic is
currently double that of weekday traffic (FEIS, page 1-16).
19
�We have fit a quadratic equation to the summer traffic data UDOT provides in
the FEIS, Figure 1-4, and have found that a quadratic equation fits this data slightly
better than does a linear equation. According to the quadratic equation, summer traffic
volumes level off over time to values that are significantly lower in 20 10 than the
values predicted by a linear equation. UDOT chooses a linear equation based upon its
better fit to the data over exponential, logarithmic and power equations. Consistent
with this method, UDOT should choose to use a quadratic equation, with its
significantly lower predictions, based upon the better fit this equation provides to the
data. We have made this point in a letter to UDOT from the Bridgerland Audubon
Society, dated May 2, 1993 (UDOT's ROD 1995, Appendix, Response to Comments
on FEIS, page 18). In response, UDOT says, "A linear model is an accepted and
reasonable model used to project traffic." We are not arguing this claim. Our
statistical results show, however, that in the case of Logan Canyon. a quadratic
equation is the most reasonable equation to use, based on the better fit it provides to
the data.
There are other indications that summer traffic volumes in Logan Canyon are
leveling off over time. We have run regression analyses on the summer traffic data
UDOT provides in the FEIS, Figure 1-4, dividing the data into two categories, 1980 to
1985, and 1986 to 1990. From 1980 to 1985, there is a significant increase in traffic
volume with time (r2=.82, P=.02). From 1986 to 1990, on the other hand, there is not a
significant correlation between traffic volume and time (r2=.46, P=.21). This means
that while in the early 1980's summer traffic increased with time, since 1986 there has
been no significant increase in summer traffic volume with time. This is a good
indication that summer traffic volumes are leveling off.
We have also made this point in a letter to UDOT. They have replied that in
predicting traffic volumes it is invalid to divide the data into small sets of "selected
years" (Response to-Comments on FEIS, page 17). We are not suggesting, however,
that UDOT use five years of data to predict traffic volumes. Our point is, rather, that
we have here another indication that summer traffic volumes are leveling off with time,
and that UOOT's use of a linear equation to predict summer traffic volumes is therefore
invalid, yielding predictions that are too high. The trend shown by the later traffic
data suggests that UDOT is planning to build a highway that is too big for actual
future needs. The fact that a quadratic equation better fits the entire data set also
supports this suggestion.
Finally, from Bureau of the Census reports we have found that the population in
Rich County, on the other side of the canyon, has been declining over the past ten
years. In 1990, the population was 1725 in the entire county, down from the 1980
population of 2100. This is a decline of 17.9%. The population of Garden City, at the
20
�other end of the canyon highway, was 193 in 1990, down from 259 in 1980, a decline
of 25.5% (Bureau of the Census 1994). The population of Rich County is probably a
good indicator of demand on the Logan Canyon highway, as fewer people in Rich
County mean fewer reasons for people to travel back and forth along the highway
between Logan and Rich County. It is unfortunate that UDOT has not provided data
that shows the percentage of vehicles moving through Logan Canyon that end their
journey in Rich County, and the percentage that continue past Rich County into
Idaho or Wyoming. Utah motorists moving to and from more northerly destinations
such as Montpelier and Yellowstone have several alternate routes, including Idaho
highways 34 and 36. Salt Lake and Ogden area motorists moving to and from
destinations in Wyoming such as Evanston and Rock Springs have an alternate and
more direct route on Interstate 80. Most traffic through Logan Canyon is likely local
traffic between Cache and perhaps Box Elder Counties, and Rich County. With the
population of Rich County declining over the past ten years, the demand on the
Logan Canyon highway should at least level off over time, as the 1986 to 1990 data
suggests is happening. This means, again, that UDOT is planning to build a highway
based on predictions of traffic volumes that are too high.
UDOT uses its projections of summer traffic volumes to determine future Level
of Service values for the alternative construction proposals it considers in the FEIS.
UDOT argues that the Preferred Alternative would improve the future Level of Service
"to a much greater extent" than would the Conservationists' Alternative (FEIS, page 99). This argument is flawed, however, given the above indications that UDOT's
predictions of summer traffic volumes are too high. Likely, the highway will not have
to bear the burden of traffic UDOT is predicting.
Even if, for the sake of argument, we accept UDOT's predictions, it isn' t the case
that the Preferred Alternative would provide a "much greater" Level of Service (LOS)
than would the Conservationists' Alternative. In the Upper Canyon, the Preferred
Alternative is expected to provide a LOS of C/O in the year 2010. C/O means
something between C and D. The Conservationists' Alternative is expected to provide
a LOS of D. Please see Table I. The Preferred Alternative provides only an
incremental increase in LOS over the Conservationists' Alternative. For the upper
Middle Canyon, by the year 2010 the Preferred Alternative is expected to provide a
LOS of D, while the Conservationists' Alternative is expected to provide a LOS of DIE.
The gain in Level of Service with the Preferred Alternative is again quite marginal.
According to UDOT's descriptions of Levels of Service, in the Upper Canyon
the Preferred Alternative is expected to bring about "noticeable increases in platoon
formation" and "platoon size," with passing being something between "significantly
reduced" and "extremely difficult" (FEIS, page 1-18). With the Conservationists'
Alternative, passing is expected to be "extremely difficult." How much better off will
. 21
�we be to have passing that is slightly better than "extremely difficult," as opposed to
being simply "extremely difficult"? In the upper Middle Canyon, the Preferred
Alternative is expected to result in "unstable traffic flow," with passing being
"extremely difficult." The Conservationists' Alternative is expected to provide
passing that is something between "extremely difficult" and "virtually impossible."
How much better off will we be with passing that is still "extremely difficult"? It is
expected that by the year 2010, both alternatives will provide Levels of Service that
fall below the va lue that is professionally acceptable. "LOS C is the minimum
desirable LOS for a rural highway" (page 1-19). The marginal gains with the modified
Preferred Alternative, with Levels of Service that are still below the "minimum
desirable,'" are not worth the much greater cost and environmental destruction.
Table 1
Projected LOS by year 2010 (from FElS, Table 2-1)
Preferred Alternative
Conservationists' Alternative
Middle Canyon
(lower) Rt. Hand Fork to Lower
Twin Bridge
(upper) Lower Twin Bridge to
Cattle Guard (MP 391.6)
DIE
DIE
D
DIE
Upper Canyon
C/O
D
We have made this point to UDOT in several letters. Their response is that the
difference between the LOS values C/O and D, for example, represents a significant
improvement (UDOT's ROD, Response to Comments on FEIS, page 80). This claim is
unbelievable, especially given the fact that both alternatives fall below the "minimum
desirable" LOS. UDOT adds that we must evaluate construction alternatives on a
"corridor-wide" basis (page 22). Considering the environmental impacts of the
modified Preferred Alternative in the Middle and Upper sections of the canyon,
however, and considering that the gains in LOS with the modified Preferred
Alternative are quite marginal in these sections of the canyon, there is good reason for
UDOT to scale back its plans in these sections. The corridor-wide LOS would still be
enhanced. We are not protesting UDOT's proposals for the Rich County section of
highway, past the Bear Lake overlook, for example. UDOT should minimize
environmental destruction in the most sensitive areas of the canyon, given the fact that
less destructive, yet practicable, alternatives are available in these areas.
It is likely, however, that neither alternative will bring about the reduced LOS
that UDOT is predicting. since, according to severa l indications, summer traffic
22
�volumes are leveling off over time. For these reasons, flawed traffic projections, and
only marginal gains in predicted Levels of Service, UDOT has not justified its choice
of the modified Preferred Alternative on the basis of its traffic projections.
Improve Traffic Flow
According to UDOT, factors that influence traffic flow include speed and travel
time, passing ability, and "traffic interruptions" (UDOT 1987, page 6-2). These factors
are used to derme the qualitative measure, Level of Service. Level of Service is a
slightly broader concept than traffic flow , also taking into account safety, and driver
"comfort and convenience." We will briefly compare the modified Preferred
Alternative and the Conservationists' Ahemative with respect to the individual factors
that enter into traffic flow. While the modified Preferred Alternative raises design
speeds and increases opportunities for passing, overall traffic flow is enhanced only
marginally when compared to the Conservationists' Alternative, and at the cost of
unnecessary environmental destruction. The Conservationists' Alternative represents
a good compromise between improving traffic flow and protecting environmentally
sensitive areas of the canyon.
In the FEIS, UDOT does not compare the Preferred Alternative and the
Conservationists ' Alternative with respect to travel time through th e canyon (Table 21). This is unfortunate, since the difference in travel time between the two alternatives
is strikingly minimal. In response to letters, UDOT has admitted that the difference is
!O minutes or less (FEIS, page 9-9).
Proposed design speeds for the highway are generally higher in the modified
Preferred Alternative than the Conservationists' Alternative. AASHTO standards
detertOine the width and curvature of a road once a design speed is chosen (Amy
Steiner, AASHTO, personal communication). With a lower design speed,
environmental impacts are lessened. UDOT insists upon a unifortO 50 mile per hour
design speed in the Upper Canyon, even though designing for this speed will result in
destruction at the summit to a side canyon, the mature trees and the scenic views.
UDOT has the alternative, allowed by AASHTO standards, of leaving the design speed
at its present 40 to 55 miles per hour. In the upper Middle Canyon, UDOT insists upon
a unifortO 35 mile per hour design speed, even though designing for this speed will
mean extensive widening and curve cuts , with a retaining wall. The fishery is placed
at risk through the possibility of significantly increased sedimentation and turbidity, a
risk which has not been adequately analyzed. These impacts and possible impacts are
simply not necessary. As they are doing in the lower Middle Canyon, UDOT has the
option of maintaining the current design speed, and so designing a less destructive
road. With an increase in travel time through the canyon of less than 10 minutes, the
environmental impacts to the Middle and Upper Canyons are not necessary.
23
�In their Technical Memoranda, UDOT claims that "the imposition of the lower
speed limits onto the sections which can easily accommodate higher speeds would
increase travel time and driver irritation" (1987, page 7-13). This is, in fact, UDOT's
only defense of the higher design speeds they have chosen, other than their misleading
claim that the AASHTO standard for a minor arterial road is 50 miles per hour (FEIS,
page 1-8). Since the improvement in travel time is minimal, UDOT' s defense comes
down to "driver irritation." UDOT is designing this highway purely for the sake of
drivers being able to "go fast," regardless of the minimal savings in travel time, and
regardless of the environmental destruction.
The modified Preferred Alternative proposes a little over 6.5 miles of new
passing lanes in the Upper Canyon, along half of the highway in the Upper Canyon.
Below the Beaver Mountain intersection, UDOT is proposing over 3 miles of new
passing lanes. UDOT claims that below the Beaver Mountain intersection, in the
Upper Canyon, the highway will be widened to 34 ft. , rather than to the originally
proposed 40 ft. They label the 34 ft. width a "compromise" for the sake of protecting
wetlands (UDOT 1995a). Their claim that the highway in this section will be widened
to 34 ft. is misleading, however, since for over 3 miles of this 8 mile section UDOT is
proposing passing lanes that will extend the width of the road to 44 ft. UDOT plans to
place the 3 miles of passing lanes proposed for below Beaver Mountain in wetlands
along Red Banks and below the Tony Grove intersection. Through these wetlands,
UDOT's "compromise" widens the highway to 44 ft. , rather than 47 ft.
The Conservationists' Alternative proposes 1.6 miles of new passing lanes in
the entire Upper Canyon, avoiding impacts to wetlands. With the minimal
improvement in travel time achieved with the modified Preferred Alternative, the
extensive passing lanes UOOT is proposing are not worth the extra cost and
environmental impact. UDOT argues that construction alternatives cannot be judged
by travel time alone, but must be evaluated in terms of the wider concept, Level of
Service (LOS). As we have argued, however, by UDOT's own estimate the future LOS
we achieve with the modified Preferred Alternative is only an incremental
improvement over the LOS provided by the Conservationists' Alternative.
Considering both travel time and Level of Service, the marginal improvement we
achieve with the modified Preferred Alternative does not warrant either the high
design speeds or the extensive passing lanes proposed in this alternative.
We have asked UDOT to consider using slow vehicle turnouts, along with a
single, more modest passing lane, in the section of highway along Red Banks and
below the Tony Grove intersection, for the sake of protecting wetlands. UDOT refuses
to propose slow vehicle turnouts. In their Technical Memorandum, UDOT admits that
turnouts are "safe when properly used," and that, "A series of turnouts at regular
24
�intervals can provide considerable delay reduction" (1987, page 7-30). UDOT
acknowledges that slow vehicle turnouts are used in other western states along
highways in mountainous terrain. UDOT writes that, "Turnouts are not a substitute for
a passing or climbing lane of adequate length." This may be true, in the proper
circumstances. Along Red Banks and below the Tony Grove intersection , however,
one or two adequately placed slow vehicle turnouts, with a more modest passing lane,
would be a good compromise for the sake of protecting wetlands. Considering the
minimal gain in travel time and Level of Service that would be achieved by placing
passing lanes along half of the highway in the Upper Canyon, there is room here for a
genuine compromise for the sake of environmental protection.
By "traffic interruptions," we assume that UDOT is referring to such control
measures as stop and yield signs, and traffic lights. Neither the modified Preferred
Alternative nor the Conservationists' Alternative propose that such measures be used
along this highway.
UDOT has chosen the modified Preferred Alternative, in part, because, they say,
it better improves driver "comfort and convenience.'" It appears that the modified
Preferred Alternative is motivated simply by the desire to build a big highway on
which drivers can "go fast," without the "irritation" of having to drive at lower speeds
in some areas of the canyon, and without the "inconvenience" of having to adjust
speeds slightly when negotiating some curves, perhaps having to shift gears. We are
arguing that, given the minimal improvements in traffic flow provided by the modified
Preferred Alternative, genuine compromise can and should be made for the sake of
protecting the scenery, wetlands, the fishery, and wildlife. The Forest Service has
designated Logan Canyon a National Scenic Byway. Logan Canyon was once
proposed as a National Park. It has received national attention, for example, in the
recent Audubon magazine article by Rick Bass (1994). Given the tremendous beauty
and recreational value of this canyon, compromise can and should be reached, even if
drivers are constrained from rocketing through the canyon to save fewer than 10
minutes, and even though drivers may be constrained to adjust speeds slightly through
some curves. Logan Canyon is uniquely splendid, and irreplaceable.
The Wasatch-Cache National Forest Management Plan includes several
guidelines that call for a compromise in road design in this Forest. One guideline
states, "Design speed must be a compromise between the travel speed desired and that
which the terrain will permit within the environmental constraints" (page IV-44). This
means that road design must also be a compromise between desired travel speed and
environmental constraints. Design speeds proposed by UDOT, and highway design in
general, throughout the Middle and Upper Canyons, is not a good compromise with
environmental constraints. UDOT has designed the highway in accordance with
projections of future traffic volumes that appear to be arbitrarily high. There are
25
�several indications that summer traffic volumes are leveling off in Logan Canyon. In
defense of its design, UDOT often appeals to AASHTO safety standards. In a sensitive
area of the canyon, however, UDOT is using AASHTO standards in an inappropriately
strict fashion, counter to allowa."ces made by AASHTO for mountainous regions.
UDOT has designed this highway in an arbitrary and capricious fashion, without good
justification for decisions to apply AASHTO standards in a stricter rather than in a
more flexible manner, for example, at the summit and through the upper Middle
Canyon. Design speeds have been chosen by UDOT, it seems, purely for the sake of
drivers being able to attain high speeds through the canyon, without a significant
improvement in travel time or Level of Service. By accepting UDOT's modified
Preferred Alternative, without good justification for the proposed construction, the
Forest Service is violating the above guideline in its Management Plan.
Another guideline states, "The alignment shall lay light on the land ... Except
for necessary stream crossings, riparian areas shall not be disturbed" (page IV-44). The
modified Preferred Alternative cannot be said to lay "light" on the land. A 47 ft. wide
swath through the mature trees and a side canyon at the summit, with 22 ft. wide "clear
zones" on either side, for a total "affected" width of 80 ft. , does not count as laying
"light" on the land. Extensive widening and curve cuts through the upper Middle
Canyon, with hillside excavations and a 4-8 ft. cut into the mountain along the
Dugway for 3/4 of a mile, complete with a retaining wall, will not produce a road that
lays "light" on the land. UDOT plans 1,740 ft. of retaining walls that will be anchored
in riparian areas along Beaver Creek. Such destruction of riparian areas is not
necessary. The Conservationists' Alternative improves traffic flow to an adequate
extent, without such unacceptable impacts upon the canyon and river. By accepting
UDOT's modified Preferred Alternative when an adequate alternative design is
available, the Forest Service is violating the above guideline in its Management Plan
concerning unnecessary impacts of a road on the landscape and riparian areas.
The modified Preferred Alternative is neither reasonable nor necessary. It is not
reasonable, because this highway design has not been adequately justified. It is not
necessary, because there is an adequate and less damaging alternative, the
Conservationists' Alternative. By violating the two guidelines quoted above, the
Forest Service is in violation of the National Forest Management Act. These
guidelines are not to be violated "unless some overriding reason to abandon" them is
supported by a Forest Service interdisciplinary analysis (page IV-24). Such an
interdisciplinary analysis for the purpose of abandoning these guidelines has not been
done.
Finally, in a response to a comment on its Management Plan, the Forest Service
stated, "Improvements to Logan Canyon Highway will be only minor. There is a need
to provide safe bridges and some passing lanes. The road will not be raised to a higher
26
�standard than existing" (Forest Service 1985a, p.236). In violating this commitment to
the public, the Forest Service is acting in bad faith .
We urge the Forest Service to insist that UDOT scale down its proposal to
achieve a genuine compromise between the requirements of traffic flow and Level of
Service, and environmental constraints. A scaled-down proposal should be submitted
before the Forest Service amends the Management Plan and grants the required
easement allowing highway construction in Logan Canyon. We also urge the Forest
Service to insist that UDOT reconsider the Conservationists' Alternative for the Logan
Canyon highway.
Literature Cited
Bass, R. 1994. Keeping Logan Canyon. Audubon Magazine, Nov.lDec.
USDA Forest Service. 1995. (ROD) Record of Decision, U.S. Highway 89.
USDA Forest Service. 1985. Wasatch-Cache National Forest Land and
Resource Management Plan.
USDA Forest Service. 1985a. Wasatch-Cache National Forest Land and
Resource Management Plan; Final Environmental Impact Statement, Ch.6.
United States Dept. of Commerce, Economics and Statistics. Bureau of the
Census. 1994.
Utah Department of Transportation (UDOD. 1995. (ROD) Record of Decision, U.S. 89
Through Logan Canyon.
Utah Department of Transportation. 1995a. U.S. 89 in Logan Canyon (pamphlet
describing the Preferred Alternative).
Utah Department of Transportation . 1993. (FEIS) Final Environmental Impact
Statement, U.S. Highway 89, Logan Canyon. Prepared by CHZM Hill.
Utah Department of Transportation. 1987. Technical Memoranda. Prepared by
CHZM Hill.
27
�Service, and environmental constraints. A scaled-down proposal should be submitted
before the Forest Service amends the Management Plan and grants the required
easement aUowing highway construction in Logan Canyon. We also urge the Forest
Service to insist that UDOT reconsider the Conservationists' Alternative for the Logan
Canyon highway.
Literature Cited
Bass, R. 1994. Keeping Logan Canyon. Audubon Magazine, Nov.lDec.
USDA Forest Service. 1995. (ROD) Record of Decision, U.S. Highway 89.
USDA Forest Service. 1985. Wasatch-Cache National Forest Land and
Resource Management Plan .
USDA Forest Service. 1985a. Wasatch-Cache National Forest Land and
Resource Management Plan; Final Environmental Impact Statement, Ch.6.
United States Dept. of Commerce, Economics and Statistics. Bureau of the
Census. 1994.
Utah Department of Transportation (UD01). 1995.
Through Logan Canyon.
(RO~)
Record of Decision, U.S. 89
Utah Department of Transportation. 1995a. U.S. 89 in Logan Canyon (pamphlet
describing the Preferred Alternative).
Utah Department of Transportation. 1993. (FEIS) Final Environmental Impact
Statement, U.S. Highway 89, Logan Canyon. Prepared by CH2M HiU.
Utah Department of Transportation. 1987. Technical Memoranda.
CH2M Hill.
4. WILD AND SCENIC RIVER PLANNING
Section 5(d) of the Wild and Scenic Rivers Act (Pub. L. No. 90-542, 16 U.S.C.,
127 1 !:UJ;g.) requires all federal agencies to consider potential national wild, scenic,
and recreational river areas in all planning for the use and development of water and
related land resources. The planning responsibility imposed by 5(d) plainly requires
the Forest Service to assess the values of potential Wild and Scenic Rivers on National
Forest lands during the preparation of land and resource management plans pursuant
28
�to the National Forest Management Act (16 U.S.C., 1600 ~.). Section 1924 of the
Forest Management Act recognizes the Forest Service's responsibility in this regard:
"Consideration of potential wild and scenic rivers is an inherent part of the ongoing
land and resource management planning process."
According to Chapter 8 of the Forest Service Land and Resource Management
Planning Handbook, rivers are identified for inclusion in the National Wild and Scenic
Rivers System by several means, including the land management planning process.
The Forest Service has elected to conduct wild and scenic river inventories as a part of
its Forest Management Plan revision process.
The Wasatch-Cache National Forest Land and Resource Management Plan is
currently being revised. Forest Service precedent is to complete the eligibility stage of
the wild and scenic river inventory in a separate document prior to completion of the
Management Plan revision. The suitability stage of the inventory is completed and
included in the Environmental Impact Statement for the Management Plan revision.
In November of 1993, the Wasatch-Cache Forest issued an inventory document
identifying eligible wild and scenic rivers on the Wasatch-Cache National Forest.
This Inventory identified the Stillwater Fork of the Bear River as being eligible for
stream
wild and scenic river status. Appellants are concerned that, initially, only
on the entire Wasatch-Cache National Forest, the Stillwater Fork of the Bear River, was
.found to eligible for interim protection until a suitability study was performed.
Appellants were involved with studying the Logan River and Beaver Creek, using the
eligibility requirements from the Land and Resource Management Planning
Handbook. Even though over 50 pages of information was provided to the Inventory
Team (Citizens for the Protection of Logan Canyon, 1993), no reference was made to
this material in the Inventory except a footnote.
=
Appellants found that certain segments of the Logan River might possess the
free-flowing characteristics and outstandingly remarkable qualities for eligibility if the
evaluation was corrected to use current evaluation techniques. These techniques were
detailed in two letters to the Forest Supervisor (J. Logan, in a 3 page, single-spaced
letter to Ms. Susan Giannettino, Forest Supervisor, 18 January 1994; also D. Parkin, in
a 23 page, single-spaced letter to Ms. Susan Giannettino, 18 February 1994). These
letters concurred in the opinion that the forest planners used an honest and systematic
approach in preparing the Inventory. However, the main thrust of these letters was that
there were "significant flaws in both the methodology and interpretation of policy
guidelines" (Parkin, 1994).
In response, the Wasatch-Cache Forest issued a supplemental report entitled
LMP Revision Planning Record Wild and Scenic Rivers Eligibility Evaluation. This
29
�•
Supplement amended portions of the November 1993 inventory. Departing from
planning criteria set forth in the Wild and Scenic Rivers Act of 1968 (p.L. 90-542, 81
Stat. 906, as amended: 16 U.S.C. 1271 (Note), 1271-1287), the USDA-USDI Guidelines
for implementing the Wild and Scenic Rivers Act (USDA-USDI 1982), Forest Service
Manual 1924, and Forest Service Land and Resource Management Planning
Handbook (Ch. 8), the Wasatch-Cache Forest included an amendment to Appendix D
which identified river segments that were "Likely to be Outstandingly Remarkable."
The Forest identification team denoted with an "M" rivers that might possess
outstandingly remarkable values and that require subsequent study.
In this Supplement, the Logan River was resegmented into two segments, Lower
Twin Bridge to Beaver Creek and Beaver Creek to its source. The segment from Lower
Twin Bridge to Beaver Creek was given five out of nine "might possess outstandingly
remarkable values." This segment lies within the Utah Department of Transportation' s
(UDOT) Highway 89 expansion project. This segment was identified for further study
due to outstanding geologic and hydrologic, scenic, general recreational, fishery and
ecological values. Eighty-two rivers andlor river segments were identified in the
Supplement's reevaluation, and the only river segment that comes close in score to the
Logan River segment from Lower Twin Bridge to Beaver Creek is the East Fork of the
Smith's Fork, which scored only three "might possess outstandingly remarkable
values" (Supplement 1994).
Although no precedent has been set for rivers that "might possess outstandingly
remarkable values," the Forest Service Land and Resource Management Planning
Handbook provides interim protection guidelines for river segments examined in this
Supplement. According to section 8.12 of this Handbook:
"Interim Managment of Study Rivers. Management prescriptions for river
corridors identified in the National River Inventory, or otherwise identified for
study [emphasis added] should provide protection in the following ways:
1. To the extent the Forest Service is authorized under Jaw to control stream
impoundments and diversions, the free-flowing characteristics of the identified
river cannot be modified.
2. Outstandingly remarkable values of the identified river area must be
protected and, to the extent practicable, enhanced.
3. Management and development of the identified river and its corridor cannot
be modified to the degree that eligibility or classification would be affected (i.e.
classification cannot be changed from wild to scenic, or scenic to recreational).
30
�•
Specific management guidelines for each of the river classifications can be
found in the revised USDA-USDI Guidelines for Eligibility, Classification, and
Management of River Areas, and in the additional standards for study river
assessment and management in section 8.2 of this chapter. These management
guidelines should be followed, to the extent of Forest Service authority, for all
identified study rivers.
The protection requirements specified above must be documented in the forest
plan prescriptions and continued until a decision is made as to the future use of
the river and adjacent lands."
The segment of the Logan River from Lower Twin Bridge to Beaver Creek has been
"otherwise identified for study" by the Forest Service in its Supplement. It therefore
qualifies for interim protection under the Management Planning Handbook.
L Tbe Forest Service's Record of Decision violates Interim Protection
Requirements to Maintain tbe Free-Flowing Nature of tbe Eligible Logan River.
According to section 8.21(b) of the Forest Service Management Planning
Handbook, free-flowing is defined as: "existing or flowing in a natural condition
without impoundment, diversion, straightening. rip-rapping. or other minor structures
at the time any river is proposed for inclusion in the Wild and Scenic Rivers System
does not automatically disqualify it for designation, but future construction of such
structures is not allowed" (emphasis added).
The FEIS indicates that cement retaining walls will be used in riparian areas at
Beaver Creek, and that riprap may be required wherever the river is adjacent to
highway expansion. These modifications are in direct conflict with the interim
protection mandated by the Management Planning Handbook.
U. Tbe Record of Decision Violates tbe Forest Service's Interim Protection
Requirements to Maintain tbe Outstandingly Remarkable Values of tbe Logan
River.
A. One of the values identified for the Logan River is its outstandingly
remarkable fishery . According to the Utah Division of Wildlife Resources, the Logan
River fishery is a Class I and II fishery that is ranked as being in the top 5% of all
stream fisheries in the state. This fishery is also considered by the Utah Division of
Water Rights to be one of four major fisheries in the state (Greg Mladenka, Utah
Division of Water Rights, personal communication). According to the FEIS, between
4.4 and 7.6% of brown and cutthroat trout will be lost in the Middle and Upper
Canyons through streambank vegetation removal. Where stream bank vegetation is
31
�•
removed, the FEIS estimates a 40 to 70% loss of brown and cutthroat trout. As
discussed in the fishery impacts section of this appeal, however, fish mortality will
likely be greater than this. UDOT has not adequately addressed sediment-related
impacts on this fishery.
It is obvious that UDOT's construction project will decrease the quality of this
outstanding fishery. The Forest Service Management Planning Handbook clearly
mandates maintenance, if not improvement of, all outstandingly remarkable values.
Unless, subsequent to this appeal, the Wasatch-Cache Forest finds the Logan River
ineligible, unsuitable, or Congress formally elects not to designate the Logan River a
wild and scenic river, the Forest Service has a statutory requirement to ensure that the
outstandingly remarkable fishery value of the Logan River is maintained in its
existing state.
B. Another value identified for the Logan River is its outstandingly remarkable
ecological value. The FEIS states, "The single most important wildlife habitat type
within the project area is woody riparian habitat consisting of forested and scrub/shrub
wetlands and riparian communities that occur along the river and streams." According
to the Environmental Protection Agency, as much as 80% of all wildife species are
dependant upon riparian zones for at least a portion of their life cycles. Riparian zones
thus fulfill an important function in both terrestrial and aquatic ecosystems.
The FEIS estimates that highway construction will require the removal of 3.5
acres, which equals 1.8 miles, of riparian habitat. An additional 11.2 acres of
associated wetlands will be impacted. Riparian zones will be destroyed through
canopy removal, the addition of fill, and rip rap or retaining walls placed throughout
the eligible wild and scenic Logan River segment. This expected 1.8 miles of riparian
habitat removal represents roughly 20% of the eligible wild and scenic section of the
Logan River. The FEIS summarizes these impacts as follows:
"The permanent loss of riparian and wetland habitat has one of the greatest
impacts on wildlife. Most of the habitat loss that occurs as a result of ongoing
highway maintenance activities or that would result from construction of one of
the aIternatives will be permanent. Roadway surfaces along with retaining
walls, parking areas, flattened curves, new alignments, etc., all permanently
eliminate wildlife habitat."
The FEIS further estimates that 149.3 acres of upland habitat will be impacted. This
could lead to "habitat fagmentation [that] can be a significant problem for songbirds,
amphibians, or small mammals."
In summary, with its decision to permit proposed highway construction, the
32
�Forest Service is not managing identified outstandingly remarkable ecological values
of the Logan River in the interim period as required by the Management Planning
Handbook and the Wild and Scenic Rivers Act, pending suitability studies or
Congressional decision.
C. The Logan River was also identified as requiring further study for its
outstandingly remarkable scenic values. The FEIS estimates that construction will
destroy 38 % and 9 % of the most visually sensitive areas within the eligible wild and
scenic river segment, and 58% and 71 % of the moderately visually sensitive areas.
UDOT's modified Preferred Alternative will not comply with the Visual Quality
Objectives established in the Wasatch-Cache Forest Management Plan. If construction
proceeds as planned, the Logan River will no longer possess the outstandingly
remarkable scenic values needed to qualify for Wild and Scenic status.
The "Dugway" will be excavated up to 8 ft. into the mountain, creating a huge
road cut and the need for at least one planned retaining wall. Up canyon from the
Dugway, the curve will be flattened and realignment will start for the replacement of
the Upper Twin Bridge, producing another large road cut. Other road cuts will be
made just below the Temple Fork intersection. The 8 miles of the Upper Canyon (from
mp 391.6 to the Beaver Mountain intersection) will be widened to 34 ft., and areas
with passing lanes, up to 3 miles in length, will be widened to 44 ft. These
construction segments will produce large amounts of cut and fill and a large road base,
further degrading the scenic value.
Although the supplemental study indicated that the eligible Logan River
segment was considered outstandingly scenic because it "Contain[s) a National Scenic
Byway where the river conidor contributes significantly to the road's designation,"
the Forest Service is not managing the segment of the Logan River in the interim
period to maintain its existing outstandingly remarkable scenic value.
DL Tbe Record of Decision Violates tbe Forest Service's Interim Protection
Requirements to Protect the Current Classification Status of the Eligible Logan
River.
In the Supplement to the Inventory released by the Wasatch-Cache Forest, no
classification scheme was recommended for either stretch of the Logan River. It is the
contention of the Utah Rivers Conservation Council, appellants, that the Logan River
should be classified as a SCENIC river under the Wild and Scenic River System.
According to the WiJd and Scenic Rivers Act, classification defmitions are as
follows:
33
�•
"Scenic river areas--Those rivers or sections of rivers that are free of .
impoundments, with shorelines or watersheds still largely primitive and
shorelines largely undeveloped, but accessible in places by roads.
Recreational river areas--Those rivers or sections of rivers that are readily
accessible by road or railroad, that may have some development along their
shorelines, and that may have undergone some impoundment or diversion in
the past."
The USDA-USDI NWSRS Final Revised Guidelines for Eligibility, CFR 39458,
discusses interpretation of development by stating: "Existing low dams , diversion
works, rip-rap. and other minor structures will not bar recreational classification,
provided the watetway remains generally natural and riverine in appearance."
Appellants are concerned that the Logan River segment from Lower Twin
Bridge to Beaver Creek, which "might possess outstandingly remarkable values" as
indicated in the Supplement, will be exposed to inappropriate levels of disturbance by
UDOT's modified Preferred Alternative highway proposal. This Logan River segment
is eligible for Wild and Scenic status, and, therefore, until an adequate evaluation is
complete, the Wild and Scenic Rivers Act mandates no degradation of values.
UDOT's Record of Decision states, "The FEIS recognizes that some screening
vegetation along the river may be disturbed, but again this is estimated in the EIS to
be minor and mostly temporary in nature ... the road reconstruction project will not
affect the potential eligibility or classification of the Logan River" (page 38). "The
FEIS also evaluated the effects of the alternatives on the resources and characteristics
affecting the scenic, historic, recreation, wildlife and fish, cultural and other values
associated with the river and river corridor ... there will be either no or only minor
effects from the Preferred Alternative on these values" (page 37).
Appellants beHeve, however, that there are numerous construction components
in the Preferred Alternative that will result in significant depreciation of wild and
scenic values and will in fact jeopardize the potential classification of the Logan River
and Beaver Creek. Some of these construction components are described above.
Appellants are concerned that UDOT's "minor effects" will be enough to change the
existing classification from scenic to recreational, or from recreational to ineligibility.
This is explicitly contrary to requirements specified in the Forest Service Management
Planning Handbook and in the Wild and Scenic Rivers Act.
IV_ The Forest Service's Record of Decision Violates The National Wild and Scenic
Rivers Act and Forest Service Administrative Direction for Compliance with that
Act.
34
�With its Record of Decision, the Forest Service is in general failing to grant
interim protection to the Logan River segment that has been found eligible for Wild
and Scenic River status. The Forest Service is therefore in violation of the National
Wild and Scenic Rivers Act and its Forest Service Land and Resource Management
Planning Handbook, Chapter 8.
Appellants are also concerned that the planning team did not assess all resource
values that would qualify the Logan River for inclusion as an eligible Wild and Scenic
River. Most notably, there is ample evidence to indicate that the Logan River
possesses outstandingly remarkable water oriented recreation, botanical, and wildlife
values (CPLC, 1993).
Appellants are concerned that the Supplement does not evaluate significant
tributaries of the Logan River, most notably Beaver Creek. Study and protection of
tributary streams is an important component of the wild and scenic planning process
because such streams and creeks are integral components of river systems. The goals
of the Wild and Scenic Rivers Act can best be achieved through preservation and
recognition of river systems as integral wholes, with full recognition of the
contribution of tributary steams. Also, management of such tributaries as Wild and
Scenic Rivers will enhance the Forest Service's ability to maintain and enhance
downstream riverine values.
V. Tbe Forest Service Failed to Adequately Involve tbe Concerned Public in tbe
Inventory Process.
Although Logan Canyon is of high local and national interest, the original
Inventory received a very limited distribution (Bass 1994). Even so, of those
interested parties who responded, the overwhelming majority were critical of the
Inventory. Of those who responded, none were notified of the subsequent reevaluation
or the changes incorporated in the Table of Appendix D in the 1994 Supplement.
The Forest Service has not provided sufficient documentation required for the
concerned public to evaluate the criteria used to draw conclusions in the original
Inventory. The Inventory refers to "detailed field surveys' (1993, pages A-19). In the
Supplement we find the statement, "documentalion used to facilitate judging the
merits of further study have been incorporated in this supplement...· (pages 1-10). Yet
when appellants requested access to this "documentation," all that was forthcoming
were copies of maps with largely unintelligible notations. Apparently, there exists no
clear documentation that can be reviewed by the concerned pUblic. It is irresponsible
for the Forest Service to agree to any depreciation of wild and scenic values without
full involvement of the concerned public.
35
�The Utah Rivers Conservation Council has recommended that the entire Utah
portion of the Logan River conidor be designated as a Scenic river under the NWSRS.
This recommendation was made through A Citizen's Proposal to Protect the Wild
Rivers of Utah, published by the Southern Utah Wilderness Alliance. The WasatchCache Forest has not responded to this recommendation, other than by violating its
(5d) Wild and Scenic River Act planning requirements through issuing its Record of
Decision.
Literature Cited
Bass, R. 1994. Keeping Logan Canyon. Audubon Magazine, Nov.lDec.
Citizens for the Protection of Logan Canyon. 1993. Letter of October 7, 1993, with
numerous attachments containing information about Logan River, Logan
Canyon and Beaver Creek.
Logan, J. 1994. Letter of January 18 to Susan Giannettino, Forest Supervisor,
Wasatch-Cache National Forest.
Parkin, D. 1994. Letter of February 18 to Susan Giannettino, Forest Supervisor,
Wasatch-Cache National Forest.
USDA Forest Service. 1995. (ROD) Record of Decision, U.S. Highway 89.
USDA Forest Service. 1994. Supplement to Inventory of Rivers on the WasatchCache National Forest Eligible for Inclusion in the National Wild and Scenic
Rivers System. Wasatch-Cache National Forest. Salt Lake City, UT.
USDA Forest Service. 1993. Inventory of Rivers on the Wasatch-Cache National
Forest Eligible for Inclusion in the National Wild and Scenic Rivers System.
Wasatch-Cache National Forest. Salt Lake City, UT.
USDA Forest Service. 1985. Final Environmental Impact Statement for the WasatchCache National Forest Land and Resource Management Plan. Wasatch-Cache
National Forest. Salt Lake City, UT.
Utah Department of Transportation (UDOn. 1995. (ROD) Record of Decision, U.S. 89
Through Logan Canyon.
Utah Rivers Conservation Council. A Citizen's Proposal to Protect the Wild Rivers of
Utah, published by the Southern Utah Wilderness Alliance.
36
�S. FlSHERY IMPACTS
The Utah Department of Transportation and the Forest Service are accepting an
analysis of fishery impacts that is inadequate. There is no scientific justification
whatsoever for claims in UDOT's FEIS that trout populations will be reduced 4 to 8%,
and that the effects of increased sedimentation will be "relatively minor and short
term." From the FEIS and supporting documentation, we have no idea what impact
UDOT's Preferred Alternative will have upon fish populations in Logan River.
The Forest Service is also in violation of its Management Plan in not obtaining
adequate analyses of required habitat indices. According to a guideline in the
Wasatch-Cache National Forest Management Plan, the Forest Service must monitor
BCI and HCI indices for Logan River to ensure the continuing quality of fish habitat.
As amended in the Forest Service' s Record of Decision (1995), this guideline states,"ln
all streams maintain the existing HCI and BCI where they exceed the minimum of 42
and 75 respectively. Allow decreases not exceeding 5% of existing condition ... "
(page IV-3(0). (These indices are described in Appendix 0 of the Plan.) No BCI
analysis has been done by the Forest Service or by UDOT, predicting the effect of
UDOT's construction upon this index for Logan River. No macroinvertibrate baseline
data is reported for Logan River. An HCI analysis is briefly reported in the FEIS, but it
is, as we shall show, inadequate. By failing to obtain adequate analyses of BCI and
HCI habitat indices, and by failing to commit to proper monitoring of these indices,
the Forest Service is in violation of its Management Plan. The Forest Service is
therefore in violation of the National Forest Management Act.
The Logan River has been designated a Class I and Class II waterway on the
Utah Division of Wildlife Resources' Unique Streams List. As such, the fishery in
Logan River is among the top 5% of stream fisheries in the state of Utah. This fishery
is considered by the Utah Division of Water Rights to be one of four major fisheries in
the state (Greg Mladenka, Division of Water Rights, personal communication). The
Logan River supports naturally-reproducing populations of brown and cutthroat trout,
and mountain whitefish. Logan River riparian habitat is considered among the "best
preserved in the state" (FEIS, page 9-59). Due to the quality of its fishery, the quality
of the fishing experience in relatively pristine conditions, and accessibility, the Logan
River is a favorite with anglers throughout northern Utah. Anglers who fish the Logan
bring $4 million annually into the local economy (estimate for 1990, UDOT 1987,
Table 7, page 18).
UDOT's analysis of fish loss due to construction begins with an estimate of the
length of stream bank that will be impacted by the removal of vegetation. From
studies by the Division of Wildlife Resources, we have available the number of fish
that are located along each foot of stream bank. This value is multiplied by the
35
.,
~ e- r ~ ~".;it
(
Ci rL. c f ('
..
-r\"r.N~1;., ~ <.r<.-j
�number of feet of stream bank that will be impacted. We now have the number of fish
that are located along the length of impacted stream bank. This number is multiplied
by 40% and by 70% to obtain a range of numbers of fish that will be lost in the
impacted areas. The 40% and 70 % are fish mortality rates that have been borrowed
from a Utah Division of Wildlife Resources study done in 1973 on the effects of the
removal of stream bank vegetation. The numbers of fish lost in the impacted areas are
divided by the total number of fish in the river, to give us a range of percentages of
fish lost through construction. The FEIS concludes that in the Middle Canyon, 4.4 to
7.6% of brown trout will be lost, and the same percentages of cutthroat trout will be
lost. In the Upper Canyon, again 4.4 to 7.6 % of each population will be lost (FEIS,
Table 4.8, pages 4-43 through 4-45).
The Forest Service has asked UDOT for a more extensive analysis. In a letter to
UDOT, Regional Forester J .S. Tilder noted that the analysis UDOT provides in the
DEIS considers only the impact of vegetation removal, ignoring the effects on the
fishery of increased sedimentation due to construction (FEIS, page 9-49). He
recommended that UDOT contact Forest Service fisheries biologists for help with
quantitatively estimating effects of sedimentation. He supplied names and phone
numbers. (Tixier's letter is attached at the end of this section of our appeal.) The
quantitative analysis of fish loss in the FEIS is identical in method to that in the DEIS,
without a quantitative analysis of sedimentation. In its response to Tixier, UDOT
writes that the effects of increased sedimentation are "difficult to predict" (FEIS, pages
9-15,9- 16). In an internal memo, (included at the end of this section), Forest Service
fisheries biologist Jill Dufour (1989) expressed her concern that UDOT is
underestimating the effects of construction upon fish by neglecting turbidity in its
quantitative analysis.
The discussion of fishery iropacts in the FEIS is simplistic because UDOT
refuses to quantitatively predict the increase in sedimentation and turbidity due to
construction. Beyond saying that such an analysis is "difficult," UDOT claims that
such an analysis "would greatly oversimplify and probably overestimate sediment
related effects." They add that a quantitative analysis would not properly account for
UDOT's use of "best management practices" during construction (FEIS, page 4-49).
Several fisheries biologists have informed us that, in fact, the models that are
used to predict sediment-related effects allow biologists to factor into their analysis
the use of practices that limit the sediments entering a river. "Best management
practices" are accounted for in the models used by the Forest Service and others.
Rather than "overestimating" iropacts, as UDOT claims, such models allow biologists
to realistically evaluate the impacts of the disturbance of riparian habitat. By refusing
to do a quantitative analysis of sedimentation and turbidity, UDOT is building a "best
case" scenario geared, it seems, to make the effects of their construction proposal
36
�•
appear palatable--only a 4 to 8% loss of fish . In reality, considering sediment-related
effects, the loss will likely be greater than this.
In its recent Record of Decision, the Forest Service states categorically that "the
environmental effects were adequately disclosed" in UOOT's FEIS (1995, page 2). In
saying this, the Forest Service is ignoring the fact that UDOT has refused to provide a
quantitative analysis of sedimentation, even after being publicly asked to do so by
Regional Forester Tixier. In his request, Tixier cited the "significan ce" of the Logan
River fishery. The Forest Service is also ignoring Jill Dufour' s memo, available in th e
files in the Regional office, expressing her professional opinion that UDOT is
underestimating the effects of increased turbidity by ignoring turbidity in its
quantitative analysis. The Forest Service does not indicate why they have ignored the
reservations expressed by these Forest Service personnel. For this reason, the Forest
Service' s decision to accept UDOT's FEIS appears arbitrary and capricious. It appears
to rest upon political expediency rather than good science.
UDOT provides a qualitative, and very brief, discussion of sedimentation and
turbidity. They write that, "The potential increase in turbidity and possibly siltation
will be expected to have a relatively minor and short-term impact on water quality,
benthic invertebrates, and fish populations" (FEIS, page 4-48). They support this
claim by saying that "only" 10% of Logan River's banks will be impacted through
construction, that not all of the affected stream banks will be impacted at the same
time, and that measures will be used to control sediments entering the river during and
after construction. For example, ground cover will be reestablished along stream
banks, they claim, and construction will be limited to the drier months of the year "to
the extent practicable."
On the other hand, UDOT admits that mature riparian vegetation, with
overhanging cover for fish, "will take considerably longer" to reestablish, up to 10 to
40 years (FEIS, pages 4-31 and 4-48). Growth of new cottonwoods and other
deciduous trees, "could require 30 to 50 years or might never occur again" (page 43 1) . Since mature riparian plant communities take "considerably longer" to
reestablish, the loss of these communities, especially on steep slopes, will likely have
some long term impact on the fishery with respect to erosion control.
In an undated report, "Effects of Road Building on the Logan River," the late
professor of fisheries biology, William Helm, explains that in the drier months runoff
into a river during construction can be especially damaging to a fishery. In riparian
areas that have had vegetation removed, runoff from summer slonns canies a large load
of sediment that, in the lowered flow of the river, is not canied downstream . In the
drier mon ths , sediment tends to be deposited in the areas under construction or just
downstream. If those areas are critical to fish, providing spawning or feeding grounds,
37
�the effects of increased sedimentation and turbidity can be severe. Helm writes that
increased sedimentation can be expected to kill 95-100% of fish eggs. Sediments fill
the spaces between gravel and stones, "greatly decreasing the supply of food for
trout." Juvenile cutthroat trout are found in Logan River throughout the summer
season, and are highly susceptible to sediments clogging their gills. UDOT claims that
it will limit construction to the drier months of the year, but, according to Helm, this is
actually "the worst possible time" to add sediment to rivers. Helm's assessment has
been confirmed by a fisheries biologist with the Utah Division of Wildlife Resources
(personal communication).
UDOT has not established its claim that increased sedimentation and turbidity
due to construction will have a "relatively minor and short-term impact." As Helm
argues, sediment entering a river during the drier months is especially damaging to a
fishery, and UDOT has admitted that mature riparian plant communities take from 10
to 40 years to reestablish. Furthermore, UDOT is planning extensive construction just
beyond the riparian zone. Six curve cuts are planned along the highway through the
Middle Canyon. UDOT is planning to widen the road in the Middle and Upper
Canyons, just beyond, and in some places within, the riparian zone. At the Dugway,
UDOT is planning to carve 4 to 8 feet into the rock and dirt wall on the mountain side
of the highway, for a distance of about 3/4 of a mile. Upstream, Temple Fork
intersection is to be widened, with a turning lane installed. Within the narrow riparian
area between the road and the river, a retaining wall has been proposed to help
stabilize the steep slope. Considering the extent of planned construction along Logan
River, UDOT's claim that increased sedimentation and turbidity will have a "relatively
minor and short-term impact" is unbelievable. With the loss of 10% of the riparian
vegetation, and with extensive road construction in and just beyond the riparian zone,
sediment-related effects will likely be major and long term. In fact, at one point in the
FEIS, UDOT contradicts its conclusion by admitting that effects of increased
sedimentation will be "short- and long-term" (page 4-2). A quantitative discussion of
sediment-related effects would help us detennine how serious these effects will be on
the fishery.
Let us return to UDOT's quantitative analysis of fish mortality. It is simplistic
in that it ignores effects of increased sedimentation and turbidity due to construction.
It is simplistic, as well, in that it assumes that every length of stream bank is
equivalent, with respect to fish spawning and feeding, to every other length of stream
bank. If extensive construction takes place adjacent to sections of the river that are of
critical importance to trout spawning and feeding, the impacts could exceed the
estimated 4 to 8 % mortality.
In a letter to CH2M Hill, preparers of the FEIS, Professor Helm (1987) reported
that the river just downstream of Lower Twin Bridge in the Middle Canyon is an
38
�important spawning area for brown trout. This area features good pools and substrate,
moderate water velocities and good overhanging cover. Helm discovered a relatively
high number of brown trout "redds" or nests in this area, 9 redds in a . 15 mile stretch,
as compared to 2 redds per mile in the river below this point. Two biologists have
looked at this section of the river with us and have confinned that this area may be
important for trout spawning. The extensive construction planned along the Dugway
will be just above and upstream of Lower Twin Bridge. Sediments in runoff from this
construction site will likely enter the river just upstream of the spawning area
discovered by Helm, the sediments possibly killing eggs, damaging food production,
and clogging the gills of juveniles. This would lead to a greater loss to the fishery
than UDOT predicts.
Jill Dufour of the Forest Service worries about the impacts construction at the
Temple Fork intersection will have on juvenile cutthroat trout, and upon any
spawning cutthroat trout, below the intersection. Juvenile cutthroat are found in
Logan River throughout the summer, and Dufour has emphasized to us that these
juveniles are highly susceptible to clogged gills from sediments (personal
communication). Another fisheries biologist, Thomas Pettengill of the Utah Division
of Wildlife Resources, has told us that, in his opinion, the gradient of the river at the
Temple Fork intersection is steep enough that sediments from construction here will
likely be carried further downstream, settling out where the gradient is less steep and
the river slows, at and below Lower Twin Bridge (personal communication).
Sediments from construction at the Temple Fork intersec tion would co mbine with
sediments from construction at the Dugway, all dumping into critical brown trout
spawning and feeding areas in the lower Middle Canyon.
Helm ' s data on brown trout spawning is from 1987. We do not have recent data
on trout spawning in the Logan River. We also do not have recent data on fish habitat.
We need a better indication of the number and distribution of good quality pools in
the river, and the amount and distribution of good substrates for spawning. If good
quality pools and good substrates are rare in the Logan River, as has been reported,
then extensive construction adjacent to these resources could have an impact on the
fishery that is disproportionate to the length of stream bank affected. The single study
that UDOT relies upon for habitat information was done by Adams in 1966 (FEIS,
Table 3-8, page 3-30). This study is almost 30 years old! In her memo within the
Forest Service, Jill Dufour (1989) wrote concerning this study, "I question whether
data from 1966 is applicable to conditions in the Logan River today." In spite of
Dufour's memo, neither UDOT nor the Forest Service have provided us with any
documentation showing that the habitat data Adams gathered in 1966 is relevant
today.
Let us return to UOOT's quantitative analysis of fish mortality. UOOT relies
39
�heavily upon a study done in 1973 by the Utah Division of Wildlife Resources. It is
from this study that UDOT gets the trout mortality rates of 40 to 70%. This study has
not been published. A brief description of methods and results are included within an
internal UDOT memo of 1974. This study is twenty-two years old!
A copy of the table reporting the data from this study has been included at the
end of this section . The blanks or dashes in the table mean, it seems, that no effort was
made to catch fish at that station during that "electrofishing effort." Apparently, the
stations were sampled unevenly. The Right Hand Fork Station was sampled only
once, while the Brachiopod Station was sampled four times. This renders suspect any
range of trout reduction values generated in this study, since sampling effort varies
considerably from station to station.
From the data presented, we cannot conclude, with the authors of this study,
that riparian habitat loss will result in a 40 to 70% reduction in numbers of brown and
cutthroat trout. At the stations sampled, cutthroat and brown trout numbers were
actually reduced by 47 to 80%. At the Brachiopod station, the reported numbers of
cutthroat are lOin the unaltered site and 2 in the altered site, a difference of 8 fish,
which is an 80% reduction in the number of fish in the altered site. No station had a
reduction lower than 47 %. The average percent reduction in brown and cutthroat
trout, considered together, is 65 %. Using a paired-data statistical technique for
estimating the reduction of trout in the population, with a=.05, we have obtained a
range of 58 to 73%. We know of no statistical technique that will provide an estimate
for the population of 40 to 70%, given this data with an average reduction of 65%.
Unfortunately, the authors of this study do not tell us how they obtained their
estimate. Our inquiries to the Utah Division of Wildlife Resources, and to CH2M Hill,
have produced no information on who did this study or how they obtained their
estimate.
Another difficulty with this 1973 study is that it does not accurately indicate
effects of increased sedimentation and turbidity due to construction. UDOT argues
that by providing an estimate of trout reduction in areas that have been altered by the
removal of riparian vegetation during construction, this study automatically accounts
for sediment-related effects on fish . UDOT bases its refusal to do a separate
quantitative analysis of sediment-related effects, in part, on their claim that this study
already indicates such effects. This study cannot, however, indicate effects of
increased sedimentation and turbidity during and just after construction. It was
conducted in the Lower Canyon, where the highway was widened and straightened in
1968. This study was conducted five years later, in 1973. It cannot, then, indicate
effects of increased sedimentation and turbidity during and just after the removal of
riparian vegetation. when these effects are greatest.
40
�•
The most serious problem with this 1973 study, however, is that it is the wrong
kind of srudy for the use UDOT makes of it. This srudy is simply a comparison of fish
numbers at each sampling station. The number of fish is determined along a length of
stream bank with narural vegetation and along an adjacent length of stream bank that
has had the vegetation removed. The results are, not surprisingly, that fish prefer to
spend time in those areas with natural vegetation. This is actually a preference study.
investigating where fish prefer to spend time when there is a choice between adjacent
lengths of stream bank. This srudy does not address the question of how many fish
will actually be lost to the fishery with the loss of riparian vegetation to road
construction. The range of values obtained in this study is not an indication of trout
mortality, but rather an indication of where fish prefer to spend time between adjacent
lengths of stream bank. The kind of srudy we need to estimate actual loss of fish is a
study that measures fish densities along a river prior to and after extensive loss of
riparian vegetation to construction. We require an actual alteration study. There is no
good reason to base an assessment of fish mortality in' Logan River exclusively on a
study that is not designed to answer questions about acrual fish loss.
Basing a quantitative analysis of fish mortality upon this 1973 srudy is not "the
best we can do." Fisheries biologists have informed us that in the fisheries literature it
is common to fmd studies that measure actual fish losses in rivers that have been
altered through road construction. Such alteration studies have been done in Montana
and in Colorado. We have learned that these srudies can easily be located by the
Forest Service through an Internet service. No such srudies are cited by UDOT in its
FEIS or in supporting documentation, yet such srudies are relevant. Also, it would be
helpful to have a quantitative analysis of the sediment-related effects of construction
in the Logan River. It would be helpful to have in hand a recent srudy of fish habitat,
with an indication of the use of the habitat by fish, so that we know where cutthroat
and brown trout are spawning and feeding in relation to planned construction. By
relying exclusively upon this 1973 UDWR srudy in its quantitative analysis, UDOT
has provided a simplistic and inaccurate prediction of fish loss.
Let us sum up our concerns with UDOT's discussion of fish mortality. UDOT's
quantitative analysis incorporates mortality values that are taken from a study that is
22 years old, and is not designed for the use UDOT makes of it. This srudy does not
accurately indicate effects of increased sedimentation and turbidity. Reported values
of trout reduction are apparently incorrect, and so UDOT's analysis based upon these
values appears to be inaccurate. UDOT fails to consider relevant studies of the actual
impacts of road construction upon fisheries. UDOT has refused to predict the effects of
increased sedimentation and turbidity using models that are widely used for this
purpose, even after being publicly asked to do so by the Forest Service, and even after
the Forest Service offered to provide help in generating the predictions. UDOT' s claim
that sediment-related effects will be "minor and short-term" is contradicted by the fact
41
�that UDOT is planning extensive construction in and just beyond the riparian zone,
and by the fact that mature riparian plant communities may take up to 40 years to
reestablish, with a longer time for trees. Professor Helm has found that the drier season,
when UOOT plans to do most of the construction, is actually the "worst possible time"
to add sediment to a river. Those areas of the river that are adjacent to planned major
construction may be of vital importance to the fish . Professor Helm has documented
an important brown trout spawning area just below Lower Twin Bridge. UDOT is
relying upon a study of fish habitat that is almost 30 years old, and, according to one
fisheries biologist, is of doubtful relevance today. We do not have current information
on fish habitat or fish spawning in Logan River.
UDOT will respond that our concerns are no longer as valid as they might have
been, since, in its Record of Decision, UDOT has modified the Preferred Alternative so
that it is less environmentally destructive. Unfortunately, UDOT is still planning
extensive road widening and curve cuts adjacent to, and just upstream of those
sections of the river that are believed to be of vital importance to the fishery,
especially through the Middle Canyon. The general problem with UDOT's assessment
of fishery impacts is that, even with the proposed modifications to the Preferred
Alternative, there are too many unknowns, such as sediment-related effects, that are
not adequately addressed in this FEIS and supporting documentation. There is still
too much potential for unacceptable destruction of this fishery .
As it now stands, there is no scientific justification whatsoever for the
prediction UDOT has provided of a 4 to 8 % loss of trout. In its Record of Decision
(1995), the Forest Service claims that "the environmental effects were adequately
disclosed" in the FEIS. Considering fish mortality, this claim is false. The Forest
Service is accepting an analysis of losses to this fishery that is scientifically
unjustified.
A guideline in the Management Plan calls for monitoring the BCI and HCI
habitat indices for Logan River. As amended by the Forest Service in its Record of
Decision (ROD), this guideline states, "In all streams maintain the existing HCI and
BCI where they exceed the minimum of 42 and 75 respectively. Allow decreases not
exceeding 5% of existing condition where this decrease is temporary and will not
reduce the HCI or BCI below the established minimums" (page IV-3(0). There has
been no analysis of the effect of the Preferred Alternative upon the BCI index. No
macroinvertibrate baseline data is reported for Logan River. We have no idea what the
present BCI value is, so we can have no idea what would constitute a "temporary" 5%
decrease in BCI value. The Forest Service's ROD includes no mention of monitoring
the components of BCI either before or during construction. By ignoring analysis and
monitoring of BCI, the Forest Service is in violation of this guideline in its
Management Plan. Guidelines are to be "applied in all situations unless some
42
�•
overriding reason to abandon" them is supported by a Forest Service interdisciplinary
analysis (page IV -24). Such an analysis for the sake of abandoning guidelines has not
been done.
On the other hand, the FEIS briefly reports an analysis of the effect of the
modified Preferred Alternative upon the HCI index for Logan River (pages 4-2 and 43). This analysis is inadequate. UDOT claims that the predicted decrease in the value
of HCI is due to "removal of vegetation and short- and long-term sedimentation" (page
4-2). In fact, the calculated decrease in HCI reflects only an estimation of the amount
of riparian vegetation that will be removed (Lynn Foster, CH2M Hill, personal
communication). Stream environment is the only component of this index which has
been recently estimated to take into account the impact of road construction. Values
for the other components were borrowed from the Adams 1966 habitat study. Again
there is absolutely no indication of the relevance of this 1966 study to conditions in
the river today. There has been no estimation of the effect of construction upon the
quality of substrate in the river, and no estimation of the effect upon the number and
quality of pools. These components of HCl may be affected by increased
sedimentation during and after construction (Forest Service, personal communication).
There is no estimation of the effect upon stream bank stability. This is not a genuine
analysis of the effect of construction upon the full HCI index. It would have been
much less misleading if UDOT had simply reported their fmdings as the percentage of
stream bank vegetation that will be lost.
In its ROD, the Forest Service states that an analysis of changes in the HCI
index "'is included in the FEIS." This statement is false. The Forest Service is
accepting an HCI analysis that is based on data of questionable relevance, and which
involves an estimation of the effects of construction on only a single component,
ignoring effects upon those components that may indicate increased sedimentation
and serious loss of fish habitat. The Forest Service is allowing a decrease of 5% in the
present HCI value for Logan River. Yet, in its Record of Decision, the Forest Service
does not mention any monitoring it will do of HCI. We do not know what the present
He] value is, and the Forest Service has made no commitment to monitor Her to
ensure compliance. By accepting this inadequate HCI analysis, and by not
committing to effective monitoring, the Forest Service is violating a guideline in its
Management Plan (page lV-3(0).
In the section of the Management Plan, "Desired Future Condition of the
Forest," the Forest Service states, "All MIS habitat will be maintained at levels that
exceed requirements for minimum viable populations" (page IV-57). Cutthroat trout
are listed as an MIS species (page 1I-33). The cutthroat in Logan River may actually
be Bonneville Cutthroat, a species listed as "sensitive" by the Regional Forester (paul
Cowley, Forest Service, personal communication). In their Record of Decision, the
43
�•
•
Forest Service states that UDOT's modified Preferred Alternative "will not adversely
affect the viability of any Forest Service listed sensitive species" (page 8). In the case
of cutthroat in Logan River, the Forest Service has no grounds for saying this.
The 1973 UDWR study that UDOT is relyin.g upon for its fish mortality values
presents a special difficulty in the case of cutthroat trout. This study was done in the
Lower Canyon, well below the upper reaches of Logan River in which most of the
cutthroat populations are found and in which they spawn. The cutthroat in Logan
River are possibly genetically disposed to prefer the colder temperatures of the upper
reaches (Forest Service, personal communication), Cutthroat are found in the Lower
Canyon in relatively small numbers. We must question conclusions reached about
cutthroat in a "habitat" study that has been conducted well below the primary range
and primary habitat of cutthroat, and well below their spawning grounds. We cannot
simply assume that the removal of vegetation in the upper reaches will affect cutthroat
numbers in the same way that it might in the Lower Canyon. Given this problem, and
the other problems with UDOT's analysis of fish mortality, such as the lack of
infonnation concerning sedimentation and turbidity, we cannot conclude that only 4
to 8 % of cutthroat will be lost to construction. By accepting UDOT's flawed
prediction of fish loss and its inadequate HCI analysis, by ignoring the required BCI
analysis, and by failing to commit to proper monitoring of these habitat indices, the
Forest Service is abrogating its responsibility for this MIS, and possibly sensitive,
species. From UDOT's assessment, we have no idea what impact the modified
Preferred Alternative will actually have upon cutthroat habitat or the number of
cutthroat.
With its decision to permit UDOT's modified Preferred Alternative, the Forest
Service is in violation of a guideline in its Management Plan, and in violation of a
directive in its Management Plan concerning an MIS species. The Forest Service is
also in violation of its policies for sensitive species in the National Forests as outlined
in the Forest Service Manual, Title 2600 (1991), section 2672.42, since they have
reached a determination of "no adverse affects" based on inadequate analyses. With
these violations, the Forest Service is in violation of the National Forest Management
Act.
We request that before it agrees to amend its Management Plan and grant the
required easement allowing UDOT to construct the modified Preferred Alternative, the
Forest Service insist that UDOT provide an adequate discussion of impacts to fish
numbers and fish habitat in an SEIS. We further request the Forest Service to insist
that UDOT maintain the current 26 ft. road width from Lower Twin Bridge to above
Ricks Spring. In other words, the 26 ft. width should be maintained throughout the
entire Middle Canyon. Also, there should be no curve cuts around the Temple Fork
intersection. These changes would protect from construction those stretches of the
44
�.,
river that are most essential to the fishery in Logan River. We request that the Forest
Service insist that UDOT consider again the Conservationists' Alternative for Highway
89 in Logan Canyon. This alternative satisfies traffic needs in the canyon, as we
discuss in an earlier section of this appeal, and it better protects the fishery in Logan
River.
Again, the fishery in Logan River is ranked among the top 5% of stream
fisheries in the state. It is considered by the Utah Division of Water Rights to be one
of four major fisheries in the state. We urge the Forest Service to abide by its policies
in giving this fishery careful attention and adequate protection.
Literature Cited
Adams, J.K. 1966. Memorandum to B. Reese concerning aquatic habitat quality in
Logan Canyon. U.S Forest Service, Cache National Forest.
Dufour, J. 1989. Memorandum to D. Baumgartner of January 18. U.S. Forest Service,
Wasatch-Cache National Forest.
Helm, W. 1987. Letter to Stan Nuffer of May 28. Helm reprints collection, Quinney
Library, Utah State University.
Helm, W. undated. "Effects of Road Building on the Logan River." Helm reprints
collection, Quinney Library, Utah State University.
USDA Forest Service. 1995. (ROD) Record of Decision, U.S. Highway 89.
USDA Forest Service. 1991. Forest Service Manual, Title 2600, Wildlife, Fish
and Sensitive Plant Habitat Management. Washington.
USDA Forest Service. 1985. Wasatch-Cache National Forest Land and
Resource Management Plan.
Utah Department of Transportation (UDOl). 1993. (FEIS) Final Environmental
Impact Statement, U.S. Highway 89, Logan Canyon. Prepared by CH2M Hill.
Utah Department of Transportation. 1987. Aquatic Resources Technical
Memorandum. Prepared by CH2M Hill.
Utah Department of Transportation. 1974. Memorandum from L.A. Abbey to L.R.
Jester of June 17.
45
�6. wn,DLIFE IMPACTS AND SENSITIVE SPECIES
1.) UDOT's FEIS and ROD violate the Wasatch-Cache National Forest Land and
Resources Management Plan.
a) UDOT's FEIS and ROD violate Goal #16 of the Management Plan (page IV8) and directives within the Plan concerning wildlife (Plan Responses
to Issues, Issue 9, page 1lI-2; Desired Future Condition of the Forest, page
IV-56).
The current productivity level of wildlife habitat will not be maintained or
improved. The current capacity of big game winter range will not be maintained or
increased, but will be diminished or adversely impacted. These results violate
Management Plan provisions cited above.
With the modified Preferred Alternative, 149.3 acres of upland plant
communities will be impacted by construction, compared to 6.9 acres for the
Conservationists' Alternative, over 2100% more impacted areas for the chosen
alternative. According to the FEIS, upland habitat loss and the consequent impacts
during construction activity will affect summer big game range and ruffed and blue
grouse brood rearing areas. The FEIS states that "habitat loss is especially significant
in the case of forested, scrub/shrub, and emergent wetlands and riparian communities
(i.e., upland communities) that are of high value to many species of wildlife" and that
"habitat fragmentation can be a significant problem for songbirds, amphibians, and
small mammals." There is no mention as to which species of songbirds, amphibians, or
small mammals may be affected by upland habitat loss or to what extent they may be
affected, which prevents informed public participation, and leads to arbitrary and
capricious decision making. No mitigation for negative impacts is proposed. ,
According to the Management Plan, the Wasatch-Cache ranks as the most
important wildlife and fisheries Forest in the state (page 1I-3 I). Hunter days use of all
key game species except elk ranks first, while the percentage of statewide habitat ranks
first or second for all species except mule deer. In addition, the highest proportion of
the statewide population of mule deer, moose, and mountain goat inhabits this Forest.
The Wasatch-Cache mule deer population is the largest in the National Forest system.
The FEIS states, "Loss of (winter range) habitat for (mule deer and moose) is
especiaUy critical during severe winters when suitable mule deer winter range covers
only a small area compared to the area occupied during normal winters" (page 4-40).
In a letter to CH2M Hill, preparers of the FEIS, Utah Division of Wildlife Resources
(UDWR) expressed real concern with impacts to winter range, saying, "Loss of these
46
�ranges are particularly critical, and the limiting factor in maintaining viable
populations" (George Wilson, UDWR, 13 February 1987). The National Forest
Management Act specifically mandates that "habitat be managed to maintain viable
populations of existing ... vertebrate species in the planning area" (36 C.F.R., 219.19).
Yet, the loss of mule deer and moose wintering range for the chosen Preferred
Alternative is 134 acres compared to the loss of 2.3 acres with the Conservationists'
Alternative, over 5800% more impacted acres with the chosen alternative.
Additionally, illustration of big game winter range in the FEIS includes only Rich
County, less than 30% of the entire study area.
Another negative impact given only cursory attention in the FEIS involves
increased highway mortality to wildlife, especially big game. Risk associated with
proximity to the highway increases with vehicle speed, effectively diminishing usable
habitat. The FEIS neglects to reveal that increases in highway speeds correlate
positively with increased animal-vehicle collision frequency (Puglisi et al. 1974;
Arnold 1981; Reed et al. 1982; National Safety Council 1984). The FEIS claims that
the mitigation cattle fencing proposed in the modified Preferred Alternative,
extending from the Tony Grove intersection to Franklin Basin, 'will likely reduce ...
vehicle-deer accidents" (page 4- 13). Research demonstrates, however, that deer
readily jump fencing less than 2 meters in height (Feldhammer et al. 1986; Ludwig
and Bremicker 1983; Reed et al. 1982), rendering UDOT's claim about the
effectiveness of cattle fencing unfounded and unrealistic. The estimated impact on
big game species due to increased vehicle collision frequency is not mentioned or
compared for the alternatives, nor is any mitigation proposed.
b) The FEIS violates Goal #17 of the Management Plan (page IV-8) and a
directive in the Desired Future Condition of the Forest section of the
Plan (page IV-56). The FEIS also violates National Forest Management
Act regulations 16 U.S.C., 1604(g) and 36 C.F.R., 219. 19, and National
Environmental Protection Act regulation 40 C.F.R., 1500.I(b).
The status of classified species will not be enhanced. Maintenance of several
sensitive plant species is not insured . The FEIS neglects to mention or evaluate the
potential impact on numerous species of special concern and includes no provision for
the description or maintenance of biological diversity. The information in the FEIS
does not allow informed public participation or decision making.
The FEIS mentions six species that are listed as threatened or endangered by the
U.S. Fish and Wildlife Service, or are listed as 'sensitive" by the Forest Service:
Bald Eagle (e)
47
�...
Peregrine Falcon (e)
Maquire' s Primrose (t)
Cronquist Daisy (s)
Rydberg Musineon (s)
Cache Beardtongue (s)
Numerous Forest Service sensitive species receive no mention in the FEIS:
Boreal Owl
Flammulated Owl
Great Gray Owl
Northern Goshawk
Three-toed Woodpecker
Spotted Bat
Western Big-eared Bat
Wolverine
North American Lynx
Spotted Frog
Maguire Draba
Logan Buckwheat
Aster kineii var. kingii
Many of these sensitive species were mentioned in UDOT's ROD, but at that
point, when virtually the whole process was complete, very few people saw the
infonnation, so in essence the public has never been presented with meaningful
information on th ese species. Waiting until the ROD is published to provide
information excludes the public from participation in the process.
Western or Townsend's big-eared bat is abundant in Logan Cave and has been
captured elsewhere in Logan Canyon; however, throughout its range in the western
United States populations are declining (Brad Lengas, unpublished report to WasatchCache Ranger District 1993); Arizona Game and Fish Department 1993). The
declining status of this bat warrants consideration, particularl y given its high
vulnerability to human disturbance (Schmidly 1991 ; Arizona Game and Fish
Department 1993), including disturbance to riparian habitat. Loss of riparian habitat,
and the noise and pollution from construction, could lead to the disappearance of this
bat from Logan Canyon. If recommended management guidelines do not halt the
decline of this bat, it may qualify for federally threatened status (Brad Lengas,
personal communication).
Evidence supporting the possibility of wolverines in Logan Canyon prompted
the Utah Division of Wildlife Resources to grant funding to the Fisheries and Wildlife
48
�Cooperative Unit at Utah State University to investigate this possibility. Researchers
have installed automatic photographic equipment to identify which mustelid species
is making observed tracks where it is thought wolverine may occur (John Bissonnette,
personal communication). Published Forest Service information indicates there are
wolverines in the Wasatch-Cache National Forest and cites an observation in Logan
Canyon (Forest Service 1994).
~
kingii var. kin2ii. a Forest Service sensitive species, was found in Cache
County during a general botanical survey carried out in conjunction with surveys for
other sensitive plant species (Franklin 1990a). The discovery of this sensitive species
in Cache County never appeared in any UOOT document. Only the Record of
Decision even mentioned the aster, but listed its distribution in four counties, not
including Cache, making any conclusion by the Forest Service that minimum viable
populations will be preserved without a basis in fact, and arbitrary and capricious.
A previously undescribed species of Viola. upon discovery named Viola
franksmithii, was also found in Logan Canyon during the same general botanical
survey (Franklin I990a). This Logan Canyon endemic species was later described in
detail (Holmgren 1992). However, it is not mentioned in any UDOT document. It is
the fifth known plant species endemic to Logan Canyon, including Maquire's
primrose, Cronquist Daisy, Rydberg musineon, and Cache beard tongue. It is
considered possible there are other undiscovered endemics occurring in Logan
Canyon (Frank Smith, personal communication).
The following Fish and Wildlife Service C2 candidate species are not
mentioned in the FEIS. Are these listed as sensitive by the Forest Service?
Western Small-footed Myotis
Long-legged Myotis
Long-eared Myotis
Fringed Myotis
Boreal Toad
Discus shemeki cockerelli
Oreohelix haydeni haydeni
Oreohelix haydeni cQrrugata
Oreohelix peripherica wasatchensis
All four Myotis species have been captured in Logan Canyon (Brad Lengas,
unpublished report submitted to the Logan Ranger District). All depend on the
riparian areas adjacent to the river and thus adjacent to the road. These bats are not
mentioned in the FEIS, making any claim by the Forest Service that minimum viable
populations will be maintained arbitrary and capricious.
49
�...
An undescribed snail species, genus PyrgulQPsis. was discovered along the
highway at Spring Hollow by Dr. Robert Hershler of the Smithsonian Institution
(Hershler 1990). Information on this discovery was provided to UDOT, along with a
recommendation for further investigation prior to road construction activities. The
habitat in which this and several other C2 snail species are found indicates that any of
these species could occur along the highway project site (peter Hovingh, personal
communication),
The FEIS states, "The undescribed snail species has not been nominated as a
candidate species. The species is located down canyon of the project area and will not
be affected by construction activities" (page 9-14). There are 20 species of
PyrgulQPsis in the western United States listed C2 by the U.S. Fish and Wildlife
Service (see Federal Register, Part IV; 50 C.F.R., Part 17, November 15,1994). The
species identity of this PyrgulQPsis is not known. Therefore, it is not known whether
this one is a candidate species. Nevertheless, minimum viable populations must be
preserved, and with no analysis there is no factual basis to claim that viable
populations will be preserved. No surveys along the project site were conducted.
Therefore, it is not known whether this snail species occurs within the project area, or
whether it will be affected by construction activities.
Pyrgulopsis is the sixth species endemic to Logan Canyon. This suggests an
unusually high rate of endemism in this area. The diversity provision of the National
Forest Management Act requires that national forest planning "provide for diversity of
plant and animal communities based on the suitability and capability of the specific
land area" (16 U.S.C.,1604(g)(3)(B». The National Forest Management Act requires
inventory data on wildlife populations and distribution (id, 1604(g)(2)(B»; on
identification of hazards to various resources (id, 1604(g)(2)(C»; and research on the
effects of each management system (id, 1604(g)(3)(C». Likewise, in providing for
diversity, "inventories shall include quantitative data making possible the eva luation
of diversity in terms of its prior and present condition" (36 C.F.R., 219.26 (1984».
None of these Management Indicator Species (MIS) from the Management Plan,
which probably occur in Logan Canyon, received mention in the FEIS or ROD:
Gray Jay
Hairy Woodpecker
Pine Siskin
Yellow-bellied Sapsucker
Warbling Vireo
Mountain Bluebird
Water Pipit
50
�MacGilvary's Warbler
Green-tailed Towhee
Vesper Sparrow
Identification of Management Indicator Species is required by th e National
Forest Management Act (36 C.F.R., 219. 19(a)). This regulation also specifies that
"fish and wildlife habitat shall be managed to maintain viable populations of existing
native and desired non-native vertebrate species in the planning area." A viable
population for planning purposes is defined as "one which has the estimated numbers
and distribution of reproductive individuals to insure its continued exis tence is well
distributed in the planning area. " Regulations further provide that "population trends
of the management indictor species will be monitored and relationships to habitat
changes determined" (id, 219.19(a)(6)). But with no analysis of these MIS indicator
species in the FEIS or ROD, there is no basis for claiming these provisions will be met.
The FEIS makes assertions of no impact when no ground surveys were
conducted to collect baseline data for the majority of all aforementioned species.
Without further information to describe Logan Canyon's biological diversity, the
significance of this diversity, and the potential impacts to the stability of this
di versity, compliance with the National Forest Management Act's diversity mandates
or the National Environmental Protection Act's assessment mandates is not achieved.
2.) The FEIS violates the Endangered Species Act of 1973, as amended.
a) The FEIS violates Section 7(a)(2) and 7(c) of the Endangered Species Act,
and directives in the Management Plan concerning wildlife (plan
Responses to Issues, Issue 9, page III-2; Desired Future Condition of the
Fores t, page IV-56).
The potential impact to the only federally threatened species in the project area
(Primula maguireO was not thoroughly identified using the best scientific and
commercial data available. A Biological Opinion was not written by the U.S. Fish and
Wildlife Service in response to a Biological Assessment provided by the project
proponent, as required by Section 7(c) of the Endangered Species Act.
Information transferred between the U.S. Fish and Wildlife Service and
UDOTIFHW A does not reveal compliance with the Endangered Species Act
requirement for a biological assessment and subsequent issuance of a biological
opinion by the U.S. Fish and Wildlife Service. It is not clear why th e Fish and Wildlife
Service eventually concurred with the "no effect" detennination in the absence of an
adequate biological assess ment. The following discussion chronologically
51
�summarizes correspondence between the Service and UDOTIFHW A.
In March 1987, the Fish and Wildlife Service communicated to FHW A that
Section 7 consultation would be required if the highway project would affect the
primrose (Robert Ruesink, State Supervisor USFWS, to Duncan Silver, FHW A, March
4, 1987). Subsequently, Daniel Dake (UDOT, July 7, 1987) supplied the Fish and
Wildlife Service with a report (Welsh 1987) in order to comply with 50 C.F.R.,
402. 12(j). Ruesink replied to Mr. Dake (July 21 , 1987) that the Service was unable to
prepare a biological opinion at that time, that mOTe information was necessary, and
that any significant reduction of the buffering and road encroachment on the cliff at
Wood Camp may have a deleterious effect on that population of primrose due to
micro-climate changes, to which Maguire's primrose is sensitive.
In August 1989, Ruesink again wrote, this time to Margaret Johnson of CH2M
Hill, preparers of the FEIS, that a project proponent must submit a biological
assessment so that the Fish and Wildlife Service could prepare a biological opinion in
response to the potential impacts to the primrose. UDOT replied with a proposal to
eliminate the slow vehicle turnout near Wood Camp Campground to remove the
Service's concerns about the project's potential impacts on the primrose (Donald
Steinke, UDOT, to Clark Johnson, USFWS, March I, 1990).
In April of 1990, Clark Johnson (Assistant Field Supervisor, USFWS) wrote the
FHW A and recognized UDOT's proposal to eliminate the slow vehicle turnout.
However, the Service again recommended "that the FHW A submit a biological
assessment on the preferred alternative of the U.S. 89 Logan Canyon DEIS when the
alternative is selected and request formal Section 7 consultation at that time."
In February of 1991 , Jonathan Deason (Director, Office of Environmental
Affairs, Department of the Interior) wrote the FHW A to clarify that the Fish and
Wildlife Service had advised the Office of Environmental Affairs of the possibility of
the highway project adversely affecting a federally threatened plant, and that, if so,
Section 7 consultation would be necessary in accordance with the Endangered Species
Act. Deason's letter goes on to say, "Biological opinions are prepared by the FWS in
response to formal consultation requests by the Federal Agency. The botanical reports
relating to Primula Maeuire and other rare plant species prepared for this project do
not constitute a biological opinion as defmed by the act."
Eventually, in April of 1992, without further information indicated, Clark
Johnson (USFWS) wrote to R. James Naegle (UDOn and concurred with UDOT's
determination of no effect to the primrose. This, Johnson wrote, was based on the
information which occurs in the FEIS. The only reference cited in the FEIS is Welsh
1987, which had been the basis for prior unfavorable responses by the Fish and
52
�Wildlife Service.
Clark lohnson ' s 1992 letter is the fIrst and only correspondence from the Fish
and Wildlife Service which concurs with UDOT's no effect determination. In 1987,
Welsh' s report did not suffIce for the Fi. h and Wildlife Service to respond with a
s
biological opinion, and in 1990, the Service recommended the FHW A submit a
biological assessment when an alternative was selected and requested formal Section 7
consultation at that time. Deason's 1991 lener from the Office of Environmental
Affairs to FHW A reiterated that no report submitted up until that time constituted a
biological opinion.
A more current and comprehensive survey report (Franklin 1990b) was not
utilized by UDOT, in spite of references to this report in a letter from the Bridgerland
Audubon Society to UDOT, Feb. 12, 1991. This report systematically surveyed
potential habitat in the Bear River Range and made determinations as to whether the
primrose's distribution extended beyond the known locations in Logan and Right
Fork Canyons. Known locations were derived from Beedlow et al. 1980, Moseley and
Mancuso 1990, Padgett 1986, USFWS 1990, and Welsh 1987. One new occurrence
was located north of the highway approximately . 1 mile beyond the fIrst river crossing
above Wood Camp on a limestone cliff face in the narrow gorge. Franklin' s report
states, "This restricted range, its rarity within that range, and the lack of detailed
demographic and disturbance information on each occurrence of Maguire primrose
indicate that all Logan Canyon occurrences should, at this time, be considered
essential habitat. When more detailed demographic and disturbance information is
available it will be possible to more defInitely ... ' identify essential habitat and those
populations (occurrences) which may best ensure the long term survival of the
species .. .' (FWS 1990)."
Welsh (1987) states, "If the recommendations cited above are followed there
should be minimal or no impact to the Maguire primrose population 4 (and no effect
on the other populations)." Welsh's survey covered 2,000 feet on either side of MP
385, in the vicini ty of Wood Camp. In his report, Welsh referen ced data provided in
an earlier report (Padgett 1986). Padgett surveyed Logan Canyon from the mouth to
0.7 miles south of the USU Forestry Field Station, and concluded, "Because of their
proximity to Highway 89 in Logan Canyon, population numbers 3, 4, 5, 6 and the
lower portion of population I could possibly be impacted by highway expansion."
The FElS provides no basis to conclude that an adequate biological assessment
was ever conducted. Recommendations repeated by the Fish and Wildlife Service and
most surveys suggested further study. Franklin (I990b) and FWS (1990) both
recommend an inventory and census of the Logan Canyon populations of primrose to
"yield precise locations and extent of all P. maguirei populations ... ", yet UDOT
53
�•
ignored this information in selecting its modified Preferred Alternative.
It is recognized that the primrose is vulnerable to micro-climate alterations,
changes in temperature and relative humidity of the atmosphere in the plant's habitat,
and that construction-related production of dust particulates could impede stomate
functioning on the primrose (Franklin 1990b; FWS 1990; Padgett 1986; Welsh 1986;
Beedlow et.al. 1980). In addition, however, recent information suggests that removal
of vegetation within the construction corridor could negatively affect primrose
pollination by eliminating essential host plants visited by the primrose-pollinating
bees (Wolf and Sinclair, unpublished data) . The primrose supplies small quantities of
nectar, making it necessary for pollinating bees to derive supplemental nectar from
other plants. Removal of vegetation in the vicinity of primrose populations may cause
primrose-pollinating bees to move elsewhere, resulting in previously unforeseen
negative impacts on the long-term viability of those primrose populations.
Clearly, information is lacking in the FEIS, in violation of the National
Environmental Protection Act, 1502. 16 and 1502.22. No recognized biological
assessment was submitted to the U.S. Fish and Wildlife Service by the project
proponent in accordance with 50 C.F.R., 402.12(j). The Endangered Species Act
states, "Each Federal agency shall ... insure that any action authorized, funded, or
carried out by such agency ... is not likely to jeopardize the continued existence of any
endangered species or threatened species or result in the destruction or adverse
modification of habitat of such threatened species which is determined to be critical ...
In fulfilling the requirements of this paragraph each agency shall use the best scientific
and commercial data available" (16 U.S.C., 1536 (a)(2)), with "species" including
plants (id, 1532(16».
CEQ regulations provide that impacts in an EIS shall be discussed in proportion
to their significance (40 C.F.R., 1502.2 (b» and that "data and analysis ... shall be
commensurate with their importance" (40 C.F.R. , 1502.15). The National Forest
Management Act states that the plan must "provide for diversity of plant and animal
communities ... " (16 U.S.C., 1604 (g)(3)(B)) and requires planners to "preserve and
enhance the diversity of plant and animal communities" so that it is at least as great as
that which would be expected in a natural forest (36 C.F.R., 219.27 (g».
The National Forest Management Act further specifies: "Habitat determined to
be critical for threatened and endangered species shall be identified, and measures
shall be prescribed to prevent the destruction or adverse modification of such habitat.
Objectives shall be determined for threatened and endangered species that shall
provide for, where possible, their removal from listing as threatened and endangered
through appropriate conservation measures, including the designation of special areas
to meet the protection and management needs of such species"
54
�(36 C.F.R.,219.19(a)(7)).
Literature Cited
Arizona Game and Fish Department. 1993. Bats of Arizona. Arizona Wildlife Views
36(8) :23 .
Arnold, D.A. 1979. Deer on the highway . Traffic Safety 79(5):8- 10.
Beedlow, P.A., J.G. Carter, and FJ. Smith . 1980. Primula ma~\Iirei L. Wms.
(primulaceae), a preliminary report on th e population biology of an endemic
plant. Unpublished report on file at the Utah Natural Heritage Program, Salt
Lake City, Utah .
Feldhammer, G.A., J.E. Gates, D.M. Harman, AJ. Loranger, and K.R. Dixon. 1986.
Effects of interstate fencing on white-tailed deer activity. 1. Wildt. Manage.
50:497-503.
Forest Service. 1994. American marten, fisher, lynx, and wolverine in the western
United States. Rocky Mountain Forest and Range Experiment Station General
Technical Report RM-254. 184 pp.
Franklin, M.A. I 99Oa. Report for 1989 chaUenge cost-share project Wasatch-Cache
National Forest, Target species: Eri~eron cronQu istii (Cronquist daisy),
Musineon lineare (Rydberg musineon) , and Penstemon cyananthus var.
compactus (Cache beardtongue). Utah Natural Heritage Program. Unpublished
report on file at the Utah Natural Heritage Program, Salt Lake City, Utah. 16 pp.
Franklin, M.A. I 990b. Report for 1990 challenge cos t-share project Wasatch-Cache
National Forest, Target species: Primula maguire i L.O. Williams (Maguire
primrose). Utah Natural Heritage Program. Unpublished report on file at the
Utah Natural Heritage Program, Salt Lake C ity, Utah. 10 pp.
Hershler, R. 1990. Field survey and preliminary taxonomy of Great Basin
Springsnails. Final Report for Cooperative Agreement P 852-A I-0035 between
U.S. Department of the Interior, Bureau of Land Management and the
Smithsonian Institution.
Holmgren, N. 1992. Two new species of Viola (Violaceae) from the Intermountain
West, U.S.A. Brittonia 44(3):300-305.
Ludwig, J., and T. Bremicker. 1983. Evaluation of 2.4 m fences and one-way gates
55
�for reducing deer-vehicle collisions in Minnesota. Transportation Research
Record 913:19-22.
Mosely, R.K., and M. Mancuso. 1990. Threatened, endangered, and sensitive plant
inventory of the Bear River Range, Caribou National Forest. Unpublished
report by the Idaho Natural Heritage Program, on file at the Utah Natural
Heritage Program, Salt Lake City, Utah.
National Safety Council. 1984. Warning: AnimaUvehicle crossing. National Safety
News 130(4) :60.
Padgett, W.G. 1986. Maguire primrose summary report. Utah Native Plant Society,
Cache Valley Chapter. Unpublished report on file at the Utah Natural Heritage
Program, Salt Lake City, Utah.
Puglisi, M.J., J.S. Londzey, and E.D. Bellis. 1974. Factors associated with highway
mortality of white-tailed deer. J. Wildl. Manage. 38:799-807.
Reed, D.F., T.D. Beck, and T.N. Woodard. 1982. Methods of reducing deer/vehicle
accidents: Benefit-cost analysis. Wildl. Soc. Bull. 10:349-354.
Schmidly, David J. 1991. The Bats of Texas. Texas A & M University Press, College
Station, TX. pp. 137-141.
U.S. Fish and Wildlife Service (USFWS). 1990. Maguire primrose (Primula maeuirei)
recovery plan. U.S. Fish and Wildlife Service, Denver, Colorado. pp. 1-13.
Welsh, S. 1987. Logan Canyon, U.S. 89 study, Biological Assessment. Unpublished
report on file at the Utah Natural Heritage Program, Salt Lake City, Utah.
7. VISUAL RETENTION
The primary problems associated with the Forest Service's decision to penn it
widening and reconstruction of Highway 89 through Logan Canyon, in relation to
visual quality, stem from the idea that it is alright to destroy that which we are
attempting to preserve. In essence, the Forest Service's decision allows for the
destruction of the scenic quality that it is attempting to manage as a highly protected
resource within Logan Canyon. This decision is not only arbitrary and capricious, but
represents a significant change in the amount of Forest Service land managed for
scenic quality.
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�Scenic Byway Designation
In 1987 the U.S. Congress created a National Scenic Byways Program to
preserve and to enhance scenic byways for the benefit and enjoyment of present and
future generations. According to the Federal Highway Administration, a scenic road is
"a road having roadsides or corridors of high natural beauty and cultural or historical
value. It gives the traveler glimpses of nature, history, geology, landscaping, and
cultural activities along the road. Campgrounds, picnic areas, or other recreational
sites may be built within the scenic corridor, or the road may provide a pleasant access
to such facilities" (FHW A 1988). A scenic route "gives the driver the opportunity to
leave a high-speed Interstate highway or arterial route for a scenic byway that permits
safe, leisurely dri ving" (FHWA 1988). The Utah Travel Council, in cooperation with
federal, state, and local agencies, has developed the Utah Scenic Byways and
Backways publication which provides a description of Utah's scenic road system
offering outstanding scenic beauty to the traveler. This publication offers the
following:
"The beaten path. It gets you there. But for those to whom the reward is in the
journey, there are paths less trodden. Panoramas reserved for the adventurous,
worlds away from the mainstream. Utah's Scenic Byways and Backways ...
These Scenic Byways are all major roads which are regularly traveled. Some
routes feature sharp curves and steep grades. Actual travel speeds are
generally less than the 55 mile-an-hour speed limit. As with all motor vehicle
travel, personal discretion is the key to a safe driving experience."
The Logan Canyon Scenic Byway Corridor Management Plan (CMP) (Forest
Service 1994), sets forth the management of the scenic corridor through Logan
Canyon. Item #1 under the management plan's mission statement provides for
"protect(ion of the) scenic values of the Logan Canyon Scenic Byway through
planning and cooperation between all agencies and government entities that have
jurisdiction within the byway view shed" (CMP, page 3). One of the "overall
objectives" o f the management plan is "to continue developing a consensus between
federal agencies. state agencies, county and city governments and private land owners
charged with the protection of Logan Canyon to identify equitable means for
protecting and improving the scenic and environmental values of Logan Canyon"
(CMP, page 3). One of the "overall actions" provided in the management plan for the
"protection of scenic qualities" is "to include provisions in the Wasatch-Cache Forest
Plan [that] emphasize the protection of scenic value and enhancement of recreation
opportunities" (CMP, page 4).
It has been estimated that the modified Preferred Alternative will destroy 38 %
and 9 % of the most visually sensitive areas , sensitivity levels 6 and 7 , wi thin the
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canyon, respectively (FEIS, page 4-63, Table 4-12). In addition, the modified
Preferred Alternative will destroy 58% and 71 % of the moderately visually sensitive
areas, sensitivity levels 4 and 5, within the canyon, respectively (FEIS, page 4-63,
Table 4-12). The modified Preferred Alternative does not, therefore, protect the scenic
values of the Logan Canyon Scenic Byway. It also does not identify equitable means
for protecting and improving the scenic and environmental values of the canyon, nor
does it reflect provisions in the Wasatch-Cache Forest Management Plan that
emphasize protection of scenic values and enhancement of recreational opportunities.
The selection of the modified Preferred Alternative is therefore in direct conflict with
the Logan Canyon Scenic Byway Corridor Management Plan (Forest Service 1994).
Lack of Forest Plan Consistency
The Wasatch-Cache National Forest Land and Resource Management Plan
(Forest Service 1985) sets forth management of Forest Service lands through
Management Area designations. The Logan Canyon Scenic Byway is contained in the
Logan Canyon Management Area (MA 13) of the Management Plan. The emphasis for
this area is to manage the highway as a Scenic Byway and to protect scenic landscape
qualities (Forest Service 1985, pages IV-29 I and IV-297). According to the
Management Plan, this area is to be managed for the visual quality objective (VQO) of
"retention" (page IV-293) . This objective provides for management activities which
are not visually evident. Under "retention," activities may only repeat fann, line,
color, and texture which are frequently found in the characteristic landscape. Changes
in their qualities of size, amount, intensity, direction, pattern, etc. should not be
evident (Forest Service 1974). The Forest Service's Record of Decision proposes to
amend the Management Plan VQO ' s in MA 13 from "retention" to "modification" for
nearly the entire route. A "modification" VQO would allow for management activities
that visually dominate the characteristic landscape (Forest Service 1974).
The Logan Canyon Management Area encompasses approx imately 12,877
acres of Forest Service land. This corresponds to approximately one percent of Forest
Service land within the Wasatch-Cache National Forest. However, the Logan Canyon
Management Area makes up approximately eight percent of the area managed as
"retention" within the Forest. Compromising eight percent of the area within the
Forest managed for retention is particularly significant when one considers that only
eleven percent of the Forest is managed for retention (Forest Service 1985, page IV60).
Although the Logan Canyon Management Area is a relatively small portion of
the Forest, the second largest concentration of developed recreational sites within the
entire Forest can be found within this area. The only other area within the Forest with
a higher concentration is the Mirror Lake Highway Management Area, which includes
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the only other Scenic Byway within the Forest. Within the Logan Canyon
Management Area, the Forest Service administers 12 developed campgrounds, 4
picnic areas, and 3 organizational camps (CMP, page 13). The Logan Canyon Scenic
Byway provides access to Beaver Mountain Ski Area, which offers downhill skiing
with a lodge, restaurant and shops. It offers access to commercial outfitters offering
horseback rides, snowmobile tours, and lodging. This Scenic Byway also provides
access to over 300 miles of hiking trails, the Mount Naomi Wilderness area, the Great
Western Trail, and miles of scenic back country auto tours (CMP, page 13). The
Logan Canyon Scenic Byway is truly unique, offering some of the most outstanding
recreational opportunities in the state.
Implementation of the modified Preferred Alternative through Logan Canyon
will be in direct conflict with the Wasatch-Cache National Forest Management Plan.
Since the most visually sensitive areas of the canyon, and the most accessible views,
will be impacted an average of 15% (FEIS, Table 4- 16, page 4-77) and cannot be
mitigated, a visual quality objective of retention will not be maintained. The highway
will not conform to management standards for a Scenic Byway. Altering primary
management emphasis of an area, especially an emphasis as critical as scenic retention
on a Scenic Byway, is not a non-significant amendment to the Forest Plan, but a
highly significant change.
Cumulative bnpacts
The cumulative impacts discussion in the FEIS (Chapter 4) does not disclose
the impacts associated with implementation of the ten projects proposed as part of the
Logan Canyon Scenic Byway Corridor Management Plan (Forest Service 1994). In
some cases, these projects will have a substantial impact upon the existing
environment of their respective project areas. Seven of the ten projects proposed
involve clearing and grubbing existing vegetation andlor site grading activities. Five
of the ten projects proposed involve the construction of paved parking areas. Four
"Romtec" restrooms will be installed at four of the ten proposed project sites. Several
of the projects include each of the above impacts combined.
Although NEPA documents will be prepared for each of the proposed projects,
the FEIS does not disclose the cwnulative impacts associated with highway
construction i1l conjunction with the ten projects described in the Logan Canyon
Scenic Byway Corridor Management Plan. This is a serious oversight on the part of
UDOT and the Forest Service, especially considering that the projects proposed under
the Logan Canyon Scenic Byway Corridor Management Plan have been planned since
early 1993, and that a planning committee was formed in late 1991 which included a
representative from UDOT.
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Literature Cited
Federal Highway Administration. 1988. Scenic Byways '88: A National Conference
to Map the Future of America's Scenic Roads and Highways.
USDA Forest Service. 1995. Record of Decision (ROD), U.S. Highway 89.
USDA Forest Service. 1994. Logan Canyon Scenic Byway Corridor Management
Plan: Portraits in Time. Logan Ranger District, Uinta and Wasatch-Cache
National Forests. Logan, UT.
USDA Forest Service. 1974. (VQO Management Discussion ?????)
Utah Department of Transportation. 1993. Final Environmental Impac t Statement
(FEIS), U.S. Highway 89, Logan Canyon. Prepared by CH2M Hill.
8. ECONOMIC IMPACTS
The Fores t Service has violated Goal #53 of the Wasatch-Cache National Forest
Land and Resource Management Plan which states that the Forest Service must
"[i]nform the public about National Forest resource management as related to the ...
local economy" (page IV-2!J .
The local economy is closely tied to recreation and tourism, with Logan
Canyon being recognized as one of the area's most valuable economic assets (Cooper
1989) . The unspoiled landscape of the canyon and its outstanding scenic and
recreational opportunities have been featured in numerous national magazines and
travel guides, including National Parks, National Geographic, Audubon, Glamour
Magazine, Scenic America, and America from the Road. It is not only a draw for
visitors, but a draw for industry and people who are relocating. The Logan Canyon
Scenic Byway Corridor Management Plan (hereafter referred to as the CMP) states,
"Logan Canyon is the focal point for many people who live in the Cache and Bear
Lake Valleys. The scenic and spiritual amenities it provides ... are a big reason people
choose to live here" (page 21).
Efforts are currently underway to enhance the area economy by capitalizing on
the scenic assets of Logan Canyon. Chip Sibbemsen, acting District Ranger with the
Logan office of the Wasatch-Cache National Forest, is spearheading a major recreation
enhancement project with the Bridgerland Travel Region, the Cache Chamber of
Commerce, Cache County, Box Elder County, Utah State University, Bear River
Association of Governments, and individual city governments, businesses and
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organizations. This project, described in the CMP, emphasizes increased marketing of
the Logan Canyon Scenic Byway's recreational and scenic opportunities, devoting
five full pages to "Marketing and Promotion" (CMP, Appendix A)
Howeve~, UDOT's extensive construction plans may interfere with the
promotion of Logan Canyon, and negate the economic benefits of the Scenic Byway
project. The CMP records concerns about proposed construction activities: UDOT's
construction project "has been extremely controversial and there is concern the
improvements may degrade the quality of the environment and the traveling
experience" (page 20). A 1989 study of tourism in the area concluded with a strong
recommendation that Logan Canyon's scenic assets be preserved intact because of the
economic benefits that accrue to the area from its scenic attributes (Cooper, 1989).
Appellants believe that the Forest Service's acceptance of the modified Preferred
Alternative will degrade one of the primary economic resources of Cache and Rich
Counties.
UDOT's FEIS and Record of Decision, and the Forest Service' s Record of
Decision, neglect to acknowledge any long or short tenn negative economic impacts
of proposed construction, including des truction of irreplaceable scenic values,
monetary losses caused by disruption of road service, impacts on big game habitat,
and harm to a fishery that brings in over $4 million annually (estimate for 1990, UDOT
1987, Table 7, page 18). The Forest Service also neglects to address the postconstruction viability of the area as a tourist destination.
National surveys bear out the fact that tourists and recreationists value scenery,
especially scenery that is relatively unspoiled. Tourists and recreationists across the
country rate "driving for pleasure" and "sightseeing" among the top three recreation
activities, out of 37 ranked activities (Report of the President's Commission on
Americans Outdoors, 1987; Outdoor Recreation Resources Review Commission,
1986; and Outdoor Recreation in a Nation of Communities, 1988). These surveys
indicate that protection of natural environments is a critical issue for tourists and
recreationists. Driving for pleasure and sightseeing are hardly as pleasurable when the
view consists of concrete retaining walls, exposed slopes and c1ear zones, rather than
lush forests and wild rivers .
Surveys conducted in northern Utah find that the most popular recreation
activity in Logan Canyon is "viewing the scenery." The third most popular activity,
out of 2 1 ranked activities, is "photography" (Hunt and Cadez 1977; Hunsaker 1969).
Clearly, the scenic assets of the canyon are of primary importance to its users, who
inc1ude local residents and tourists.
There is a c10se connection between scenic values in the canyon and the local
61
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economy, yet UDOT's FEIS and Record of Decision, and the Forest Service's Record
of Decision, fail to make any assessment of how permanent degradation of the
canyon's scenic values will negatively impact the local economy. The Forest Service
has therefore violated Goal /153 of the Wasatch-Cache National Forest Land and
Resource Management Plan, which states that the Forest Service must "[ilnform the
public about National Forest resource management as related to the ... local economy"
(page IV-21). The Forest Service has selected an alternative which may have
extremely detrimental impacts to recreation, on a Scenic Byway where data shows that
recreation is the primary use. The Forest Service has also neglected to address over
300 letters from forest users and business people who voiced concerns about impacts
to scenery and the economy (FEIS, pages 9-3 to 9- 151).
Literature Cited
Cooper, EJ. 1989. Characteristics of Recreational Visitors in the Bridgerland Area.
Hunsaker, L.M . 1969. Tourist recreation interests in Logan, Utah and the surrounding
area. Unpublished manuscript, Utah State University, College of Education.
Hunt, J.D. and Cadez, G. 1977. Bridgerland profile: From non-resident motor vehicle
data 1974-75 (Report /128). Logan, Utah: Institute of Outdoor Recreation and
Tourism, Utah State University.
Logan Ranger District, Wasatch-Cache National Forest. 1994. Logan Canyon Scenic
Byway Corridor Management Plan. Prepared by Chip Sibbernsen.
Outdoor Recreation Resources Review Commission. 1986. Report.
President's Commission. 1987. The report of the President's Commission on
Americans Outdoors. Washington, D.C.
Task Force on Outdoor Recreation Resources and Opportunities. 1988. Outdoor
Recreation in a Nation of Communities. Washington, D.C.
USDA Forest Service. 1995. Record of Decision (ROD), U.S. Highway 89.
Utah Department of Transportation (UOOn. 1991111. Draft Environmental Impact
Statement (DEIS), U.S. Highway 89, Logan Canyon. Prepared by CH2M
Hill .
Utah Department of Transportation. 1993. Final Environmental Impact
Statement (FEIS), U.S. Highway 89, Logan Canyon. Prepared by CH2M Hill.
62
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. ..
Utah Department of Transportation. 1987. Aquatic Resources Technical
Memorandum. Prepared by CH2M Hill.
Utah Department of Transportation (UDOT). 1995. Record of Decision (ROD), U.S. 89
Through Logan Canyon.
USDA Forest Service. 1995. (ROD) Record of Decision, U.S. Highway 89.
USDA Forest Service. 1985. Wasatch-Cache National Forest Land and
Resource Management Plan.
9, WETLANDS ISSUFS
\.) In regards to existing wetlands within Logan Canyon, the Forest Service has
violated the Wasatch-Cache National Forest Land and Resource Management Plan by
issuing a Record of Decision approving UDOT's FEIS and Record of Decision.
a) The FEIS states that there will be 11 .2 acres of jurisdictional wetlands
impacted by the Preferred Alternative (Table S- I). UDOT's Record of Decision states
that this impact may be reduced by as much as 30% (page 34). Proposed wetlands
impacts is in direct conflict with the goal as outlined in the Management Plan, Logan
Canyon Management Area, Watershed MIH code F04(G), which clearly states, "Avoid
soil disturbing activities on steep, erosive, or unstable slopes, and in wetlands,
floodplains , and meadows."
This goal is supported by the Federal Register which states, "A record of
decision for a National Forest System proposed action must display consistency with
the relevant forest plan" (Federal Register, V.57, No. 182, page 43207).
This appears to be binding language in terms of preserving existing wetlands
within the scope of UDOT's construction project. The Forest Service has amended
their own management guidelines concerning visual qualities and fisheries habitat for
Logan Canyon, according to the Forest Services' Record of Decision. But there is no
mention of amending the Management Plan pertaining to the management of
wetlands. For the Forest Service to approve the FEIS and UDOT's Record of Decision,
an amendment to the management goal concerning wetlands is required, with
allowable period for public comment per requirements of the National Environmental
Protection Act.
b) Management goals are further violated by the Forest Service's decision to
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grant a transportation easement for UDOT's highway project.
The Forest Service states that the modified Preferred Alternative considers
"avoiding and minimizing hann to sensitive resources and maintaining the character
of the Logan Canyon" (ROD, page 3). They go on to say, "As a result, minimal
construction will occur in the ecologically sensitive middle canyon .. ." (page 3).
Maps contained within the FEIS indicate 17 separate areas of jurisdictional
wetlands (approximately 1.3 acres) within the Middle Canyon (mp 384 to 391) that
will be permanently lost to road construction under the Preferred Alternative. There
are 47 areas (approximately 7 acres) within the Upper Canyon (mp 391 to 400) that
will be lost. This wou ld suggest that in terms of wetlands impacts, the Upper Canyon
is more ecologically sensitive on an acre per mile basis than the Middle Canyon. If
environmental concerns are indeed the limiting factors for the upper Middle Canyon,
as UDOT claims, then it would seem consistent to keep to that intent throughout the
Upper Canyon. In terms of type and the number of wetland areas in the Upper Canyon,
and the fact that permanent wetland loss results in "one of the greatest impacts on
wildlife," it seems appropriate that the Upper Canyon should receive equal
consideration (FEIS, page 4-33).
Appellants believe it is commendable that UDOT has agreed to reduce the
highway width from 40 ft. to 34 ft. in the Upper Canyon, below the Beaver Mountain
intersection. UDOT's Record of Decision states, "This reduces the impact on wetland
and riparian areas" (page l). It goes on to say, "It is anticipated that the wetland
impacts in this section will be reduced by approximately 30%" (page 34). But as the
same document points out, 3.3 miles (41 %) of those first eight miles in the Upper
Canyon will be 44 ft. wide to accommodate proposed passing lanes. This is only three
feet narrower than the originally planned 47 ft. Without detailed surveys, it is not
possible to accurately determine a 30% reduction in wetland impacts in the Upper
Canyon. Appellants wonder how UDOT arrived at this 30% value. The method of
calculating this has not been disclosed. Does this 30% value take into account the
proposed passing lanes that will be constructed in wetlands?
2.) By approving UDOT's Record of Decision, the Forest Service has violated the
National Forest Management Act.
a) The National Forest Management Act specifically mandates, "Forest
Planning shall provide for adoption of measures, as directed in applicable Executive
orders, to minimize risk of flood loss, to restore and preserve floodplain values, and to
protect wetlands" (36 CFR 2l9.23(1)). Appellants believe that "protect" is strong
language requiring the agency to do just that. Appellants believe that this protection
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clause takes precedence over mitigation. The goal should be avoidance or loss of
exi s tin~ wetlands. The Conservationists' Alternative, with its recommendation of
slow vehicle turnouts and a smaller number of shorter passing lanes, comes closer to
compliance with 36 CFR 219.23(f) .
3.) The Forest Service and UDOT are potentially in violation of section 404
requiremen Is of the Clean Water Act.
a) As the Act states, " ... no discharge of dredged or fill material shall be
permitted if there is a practicable alternative to the proposed discharge which would
have less adverse impact on the aquatic ecosystem ... " (40 CFR 230. lOa). UDOT and
the Forest Service both state that the Conservationists' Alternative does not satisfy the
purpose and need of the project (FEIS, page 4-25, the Forest Service' s ROD, page 12).
They are claiming that there is no practicable alternative to construction in wetlands
as is proposed in the Preferred Alternative (see FEIS, page 4-28). Appellants believe
that slow vehicle turnouts in the Upper Canyon is a practicable alternative.
Appellants believe the Forest Service should reverse its decision to allow
construction of the modified Preferred Alternative, un til UDOT seriously considers the
option of slow vehicle turnouts below th e Beaver Mountain in tersection , combined
with one passing lane in lieu of two. This option has been proposed by many within
the environmental community, citing that slow vehicle turnouts have been used
successfu lly in other states (pendery 1994). The Forest Service should require UDOT
to consider slow vehicle turnouts, along with a smaller number of passing lanes, as a
practical alternative in order to minimize impacts to wetlands.
The Clean Water Act further states, ..... for activities which are not water
dependent, practicable alternatives that do not involve special aquatic sites are
presumed to be available, unless clearly demonstrated otherwise ... " (40 CFR
230. lOa. 1). Neither the FEIS nor UDOT's Record of Decision present evidence that
"clearly demonstrates otherwise."
Literature Cited
Environmental Protection Agency. 1989. Code of Federal RegUlations.
Pendery, Bruce. 1994. Letter of August 12 to Dave Berg, Utah Department of
Transportation.
USDA Forest Service. 1995. (ROD) Record of Decision, U.S. Highway 89, Logan
Canyon.
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USDA Forest Service. 1992. National Environmental Policy Act. Federal Register,
V. 57, No. 182.
USDA Forest Service. 1985. Wasatch-Cache National Forest Land and Resource
Management Plan. Wasatch-Cache National Forest. Salt Lake City, UT
Utah Department of Transportation (UDOT). 1995. (ROD) Record of Decision, U.S. 89
Through Logan Canyon.
Utah Department of Transportation. 1993. (FEIS) Final Environmental Impact
Statement, U.S. Highway 89, Logan Canyon. Prepared by CH2M Hill.
11, CONSTRUCTION IMPACTS NOT EVALUATED IN TIlE FEIS
UDOT's Record of Decision introduces new construction impacts that were
never mentioned in the FEIS. Thus the Forest Service has adopted an FEIS which does
not meet the "standards for an adequate statement" required by 40 CFR 1506.3a for
the adoption of an FEIS.
Rubble and Spoil: UDOT's Record of Decision states, "Excess materials that
are not used in roadway construction or restoration of the borrow area near Bear Lake
Summi~
will be disposed of in locations determined on a case-by-case basis by the
CAT team and approved by the USFS. Excess materials may be ... stock piled (sic) for
future use ... " (page 23).
Neither the DEIS nor the FEIS ever mentioned the stockpiling of rubble for
future use. It was assumed that, for any given section under construction, there would
be more than enough material excavated (see FEIS, Table 4-15) and hence no need to
store material in the canyon. Storage piles will act as sediment sources that will
impact streams, they will directly destroy habitat, and their presence will violate visual
quality requirements.
Permanent disposal of rubble became a major issue upon release of the DEIS,
and was addressed specifically in the FEIS (pages 4-70 and 4-71). The FEIS referred to
only one disposal site in the Canyon, the abandoned borrow area near the summit.
Other than this one site, it specifically stated, "The balance of surplus material will be
deposited outside of the canyon area." Rubble and spoil disposal was a major issue
because highway construction in the Lower Canyon in the 1960 's left a large spoil
pile that has not yet revegetated to a natural appearance. As with the storage piles,
rubble disposal in the canyon will be a sediment source (how can one revegetate this
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subsoil material effectivel y?), will permanently destroy habitat, and will violate visual
quality requirements. None of these impacts were disclosed in the FEIS .
Borrow Pits: UDOT's Record of Decis ion mentions "material sources," in other
words, borrow pits (page 33). These features were never mentioned in the FEIS, yet
they will have undeniable impacts. The wording in the FEIS, such as, "Spoil material
will be generated during excavation. Some of this spoil material will be used for
embankments and other construction related uses" (page 4-70), implies that
excavation for curve cuts, etc. , will be the source of thi s type of construction material.
Borrow pits and their attendant haul roads will destroy hab itat, violate visual quality
requirements, and be sources of sediment-laden runoff that will impact streams. None
of this was disclosed in the EIS process. Further, it appears that UDOT is still trying to
suppress this information in th e Record of Decision, since th e "Construction Impacts"
section makes no mention of either borrow pits or material sources (pages 23-24).
Haul Roads: Haul roads are mentioned for the first time in the EIS process in
UDOT's Record of Decision. They are mentioned on page 23 and also on page 33, in
relation to borrow pits. There was no reason for the public to suspect their presence in
past discussions, since there were no plans for borrow pits or material stockpiles. They
represent a new impact with concerns as stated above.
Staging Areas: UDOT' s Record of Decision reveals that there will be staging
areas needed for construction (page 24). These large areas will destroy habitat, be
sources of sediment and pollutant-laden runoff, and violate visual quality
requirements. Never in the EIS process were staging areas mentioned.
Batch Plants: The potential need for batch plants located in the canyon was
never discussed during the EIS process, but is revealed on page 24 of UDOT's Record
of Decis ion. In addition to the concerns listed for staging areas, batch plants raise air
quality concerns. This should have been dis cussed during the EIS process.
General: These issues should have been discussed by UDOT in the EIS
process, since technical topics such as batch plants, material sources, etc., are not items
which the general public is necessarily informed about. It appears that these technical
details were purposely withheld from the public. The Forest Service has therefore
adopted an FEIS which does not meet the "standards for an adequate statement"
required by 40 CFR 1506.3a for the adoption of an FEIS.
Literature Cited
Utah Department of Transportation (UOOn. 1995. (ROD) Record of Decision, U.S. 89
Through Logan Canyon.
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Utah Department of Transportation. 1993. (FEIS) Final Environmental Impact
Statement, U.S. Highway 89, Logan Canyon. Prepared by CH2M Hill.
Utah Department of Transportation. 1990. (DEIS). Draft Environmental Impact
Statement, U.S . Highway 89, Logan Canyon. Prepared by CH2M Hill.
APPENDIX A
Maps of area
APPENDIX B
Conservationists' Alternative
APPENDIX C
Photos of Affected Areas
68
�United States
Department of
Agriculture
Forest
Service
Washington
Office
File Code:
Date:
Kevin Kobe, President
Logan Canyon Coalition
U.S.U. Box 1674
Logan, Utah 84322-0199
14 th & Independence SW
P . O. Box 96090
Washington. DC 20090-6090
1570-1 (L)
NF S# 9S-13-00-0018-A21S
JUN 2 9 1995
CERTIFIED MAIL -R.R.R.
Dear Mr. Kobe:
W have completed our revie w of your May 15, 1995, appeal of Regional Forester
e
Dale Bosworth 's decision to amend the Wasatch-Cache Forest Plan and to consent
to issuing an easement to the Utah Department of Transportation (UDOT), in
coordination with t he Federal Highway Administration (FHWA), to enable them to
perform needed reconstruction and safety work on Nati onal Forest System land
associated wi th rehabilitation o f u.s. Highway 89 through Logan Canyon.
The Regional Forester's decision is documented in his March 31, 1995, Record
of Deci s i o n (ROD) o n the FHWA's Final Environmental Impac t Statement (EI S) for
the project. My review of your appeal has been conducted pursuant to 36 CFR
215 o f the Secretary's Appeal Regulations. Whereas your appeal challenges the
adequacy of the FHWA 's environmental impact reports, I have limited my review
to the Regional Forester's decision.
In accordance with 36 CFR 215. 19, the
' Appeal Reviewing Officer has reviewed the appeal record and his wri tten
recommendation on the disposition of the appeal is enclosed.
As the Reg i onal Forester stat es i n h is Record of Decision, the Forest Service
is not (emphasis added) making a decision to improve or how to improve U.S.
89. The FHWA and UOOT have already made the decision to improve the r oadway.
See FHWA 's ROD for U.S . Highway 89, project # F -021(7). The bases for the
project, as well as known and anticipated environmental effects, are
ide nt ified and discussed in the associated Nat ional Environmental Policy Act
(NEPAl documents. Mitigation measures have been prescribed for potential and
known adve rse environmental impact, including those concerns identified by the
Forest Service.
In my review of the record, I find that Appellant has actively participated in
the NEPA process and that Appellant's concerns have been considered in the
formulation of the FHWA 's Fi ••al EIS and ROD.
In fact, it appears Appellant's
members were involved in a special citizen group formed to advise the FHWA and
others on how best t o achieve this project in an environmentally sensitive
manner.
See faxed letter dated May 31, 1995, from Lauren M. Keller,
Chairperson, Citizens for the Protection o f Logan Canyon. The FHWA 's ROD
contains many of the reco mmendations proposed by that group (Citi zens f o r the
Protection of Logan Canyon). My finding is re i nforced further by Douglas E.
Thompson, President of the Cache Chamber of Commerce.
In his l ette r as an
inte r ested party dated May 31, 1995, Mr . Thompson gives a detailed description
of the how the project was developed and the Chamber's opposition to
Appellant's current assertions.
Cari n g for the Land and Serving People
Pnn:eo on Aecyc!ecI Paper
FS-6200·28Q (12/93)
."'i
....
�Kevin Kobe, President
2
Reasonable people can be expected to disagree, even when given the similar
facts . We have carefully examined the decisions and mitigation measures taken
by the Regional Forester and find them reasonable and supportable.
It is
fully appropriate that use and occupancy of National Forest System land be
authorized by an easement.
It is also required that changes in Forest Plan
direction be documented through amendment to the Forest Plan.
In this case,
the adjustments are minor, thus, the Regional Forester is correct to provide
for a non-significant amendment to the Forest Plan.
Accordingly, Regional Forester Bosworth's March 31, 1995, decision for the
U.S. Highway 89 rehabilitation project is affirmed.
My decision on your appeal constitutes the final administrative determination
of the Department of Agriculture (36 eFR 215.18).
Sincerely,
c;2~:1I~XW~~
Appeal Deciding Officer
Associate Deputy Chief
National Forest System
Enc l osures
cc:
Regional Forester, R- 4
Zachary Frankel, Director, URce
Caring for th e Land and Serving P eo p le
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"5-6200·280 {12193)
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�united States
Department o f
Agriculture
Pile Code :
Route To:
Subject:
To:
Fores t
Serv ice
1570
14th & Independence SW
P. O. Box 96090
Washington. DC 20090·6090
Washington
Office
Date:
June 15, 1995
Appea l Reviewing Officer Recommendation
Appeal No. 95-13-QQ - Q018-A215
Appeal Deciding Officer
This is my review of the substantive quality of the March 31, 1995, decision
made by Regional Forester Dale Bosworth to amend the Wasatch-Cache National
Forest Land and Resource Management Plan (LRMP ) to be cons i stent with the
Fe deral Highway Administration's (FHWA) and the Utah Department of
Transportation's (UOOT ) deci si o n to construct improvements to U . S. Highway 89
from Logan to Garden City . This decision adopts the UDOT and FHA U,S, Highway
89 Final Environmental Impact Statement (EIS) . The Forest Service was a
cooperating agency for the development of this EIS.
The Regional Forester 's decision changes the visual quality objectives from
retention to parcial re tenti o n for the highway easement near Logan Cave and to
modification for the remainder o f the r o ute.
It also changes t he guidel ine s
for fisheries habitat indices to permit decreases not e xceeding 5 percent of
the existing popUlation when the decreases are temporary and the resulti n g
index exceeds established minimum standards. This decision will grant a
transportation easement over approximately 72 additional ac r es of the
Wasatch· Cache National Fo rest whi ch is required for expansion of the highway
corridor .
As part of my revi e w, I have 'considered the arguments presented in the appeal
by the Logan Canyon Coalition (LCC ) and the Utah Rivers Conservation Council.
Addi t ional ly, I have revie wed the comments submitted by UDOT, Cit izens for the
Protection of Logan Canyon (CPLC l. the Cache Chamber of Commerce.
Appeal Summary
(al Appellant objections
The appellants have raised the following issues : lack of demonstrated purpose
ane need, safety, American Association of State Highway and Transportation
Of f icials (ASSHTO) standards and highway design, wild and scenic river
planning. fishery impacts and Bonneville Cutthroat Trout, wildlife impacts and
sensitive species, sensitive plants. visual retention, economic impacts,
wetlands, water quality, lack of disclosure of construction impacts, and the
application of Section 4(f) of the Department of Transportation Act.
�Appeal Deciding Officer
page 2
(b) Informal meeting results
There was no resolution to the issues discussed at the ~~y 30, 1995, informal
disposition meeting with LCC. Appeal points discussed were safety, highway
design, wild and scenic rivers planning, and impacts to fish including the
80nneville Cutthroat Trout.
(c)
Intere sted Party comments
In their comments, UDOT states the issues raised by the appellants were
addressed in the EIS and its Record Of Decision (ROD).
They also state the
resource requirement s (mitigation ) imposed by the coope rating Federal agencies
have been met.
In the comments received from CPLC, this group explained that the
modifications to the Preferred Alternative for the FHWA ROD was a result of
hours of negotiations with UOOT. They also state the LCC was formed from
members of CPLC "who felt the compromise did n ot go far enough to protect the
canyon. "
The Cache Chamber of Commerce provided specific comments on the issues. They
stated no new issues are raised by the appellants and the Chamber's
fundamental reason for supporting the project is traffic safety. They
emphasi zed every writte n opinion by elected officials representing Cache and
Rich Counties supports the project.
Findinas
(a) Clarity of the decision and rationale
I find the clarity of the decision and its rationale meets agency standards.
The nature of the action under the Regional Forester's decision (FS ROD) is
clearly stated.
He states the limits of his decision and informs the reader
that he is "not making a decision to improve or how to improve u.s. B9" as
t~at decision was already made by FHWA and UDOT with Forest Service
parti cipation (FS ROD page 1)
The FS ROD clearly discloses the logic and rationale for this decision.
Comments from both the public and cooperat ing agencies were considered in
making the decis i on.
Required mitigation measures are disclosed.
(b) Comprehension of benefits and purpose of proposal
The purpose and need for the project is found in Section 1.2 of the £IS. The
need and scope of the Regional Forester's decision is found in the
introduction to the fS ROD. This decision reflects the determination found in
t~e FHWA ROD {p o 15l
that an amendment to the LRMP is necessary to implement
the modified Preferred Alternative.
The No Action Alternati ve was given full
consideration.
�Appeal Deciding Officer
page 3
This proposal was generated by FHWA and UDQT, and the decision to amend the
L~1P will make the proposal consist ent with agency policy and direction.
Gr~~ting the transportation easement is an appropriate use of National Forest
System Lands.
(c ) Consistency of the decision with policy, direction and supporting
information
Contrary to the appellants concerns that environmental and procedural laws
have not been met, I find that the Regional Forester's decision is consistent
with agency policy, direction, the EIS, and its supporting documentation.
Therefore, I do not believe his decision is arbitrary or capricious.
I have
not found any violation of the National Environmental Policy Act (NEPAl, the
National Forest Management Act, the Multiple Use-Sustained Yield ACt, the
Endangered Species Act, the National Hist oric Preservation Act, the Clean
Water Act, the Department of Transportation Act, or any other law.
Of particular interest was the appellants' statement tha t the "Forest Service
management policy for Logan Canyon is inconsistent from document to document"
(Appeal p . 4 ) . In reviewing and comparing the Regional Forester's decision ,
the FHWA ROD, EIS and LRMP, I find no inconsistency.
Plans like the
appellants mentioned Logan Canyon Scenic Byway Corridor Management Plan are
analysis and evaluation tools and are not part of the Forest Service's two
levels of decisionmaking process.
The determinat ion that this is a non-significant amendment to the
W
asatch-Cache National Forest LRMP is appropriate. The decision reflects
site-specific amendment needs related to the implementation of the project and
not s weeping changes to the Forest-wide standards and guidelines.
(d) Effectiveness of public participation activities and use of comments
There has been an extensive public participation process for this project.
Not o nly were the minimum NEPA scoping and notification requirements met,
additional public information meetings were held, a "Citizens Review
Committee" was used to determine whether the Draft EI S addressed the issues in
an understandable and appropriate manner, and any person who commented on the
Draft EIS received a brochure explaining the Preferred Alternative. Comments
were taken on concerns raised by the Preferred Alternative prior to the
release of the Final EIS.
Before making their decision, FHWA and UDOT modified their preferred
alternative through nego tiati ons with CPLC to address and mitigate concerns.
A£ter the FWHA decision and prior to issuing his own decision, the Regional
Forester met with members of the LCC to discuss their concerns over the
project . In his decision, the Regional Forester states "these concerns were
considered in formulation" of his decision (FS ROD p. 10 ) .
The EIS demonstrates other agencies with jurisdiction, the Fish and Wildlife
Se~ice and the Army Corps o f Engineers, were contacted and they provided
�Appeal Deciding Officer
page 4
information for the development of the EIS and its alternatives. State
agencies, elected officials, various organizations, and the media were all
contacted about the project .
(e) Requested changes and objections of the appellants
The appellants are very knowledgeable about the project and its environmental
consequences . However, mOGt of the appeal points raised by the appellants are
outside of the scope of the Regional Forester's decision to amend che LRMP and
to grant an easement.
In their appeal, the appellants have provided specific information which they
believe contradicts the conclusions of the EIS. They have put forth an
extensive, site-specific argument for the implementation of ~a less damaging
alternative" (Appeal p. 4). Specifically, they believe a reduction of the
designated speed for the road would more adequately meet the safety issue
without the environmental loss due to construction .
Their issues were raised early in the NEPA process and alternatives with
appropriate mitigation measures were developed to address their concerns.
However, they claim the FHWA ROD ~introduces new construction impacts that
were never mentioned" in the EIS (Appeal p. 86). These construction impacts
include rubble and spoil disposal, material sources, haul roads, staging
areas, and batch plants. Construction impacts are discussed in section 4.25
of the EIS, and were raised as comments to the Draft £IS.
Reco1lU!lendation
I recommend that the Regional Forester's decision be affirmed.
As a result my review, I find the Forest Service was an active cooperating
agency in the developmen~ of the EIS, the Regional Forester correctly limited
the scope of the decision' to within the jurisdiction of the Forest Service,
there was extensive public participation in trying to resolve the
environmental issues, and the required mitigation measures are appropriate for
the minimizing of environmental impacts while meeting the purpose and need for
the project.
Furthermore, I find that the issues raised by the appellants
were adequately addressed in either the decision or its supporting documents.
Atd!/c/
DAVID L. HESSEL
Director
Timber Management
�.'
"
CPLC
Citizens for the Protection of Logan Canyon
P. O . Box 3608, Logan, Utah 84323 - 3608
USDA-FS
Appeals Reviewing Officer
P.O . Box 96090
Washington, D .C . 20090-6090
Re: Statement of Appeal for Logan Canyon U .S . 89, Logan, Utah.
Dear Sir:
In the Forest Service Appeal, submitted by the Logan Canyon Coalition and othen, there
is no reference to how the Modified Preferred Alternative was created. Members of Qur
orgtlnization. Citizens for the Protection of Logan Canyon, spent countless hours in negotiations
with the Utah Department of Transportation. The Modified Preferred Altcmatlve is the result of
those negotiations. Logan Canyon Coalition was fonned from members of our group who felt the
compromise did not go far enough to protect the canyon.
rfyou have any questions please feel free to contact me at 801 - 752-0706.
__
tcrdY~~
Lauren M . Keller
Chairperson
�655 Canyon Road
Logan, UT 84321
July 14, 1995
Lauren M. Keller, Chairperson
QlLC
P.O. Box 3608
Logan, UT 84323-3608
Dear Lauren,
I think you'd better take me off the CPLC Steering Committee.
I haven't ever done much for the organization, to justify a leadership
position, even nominal, and now I am experiencing a certain
undeniable discomfort. Given recent events. maybe it's better if I
give up the idea of trying to be a bridge between CPLC and LCC.
I wasn't consulted about the idea of writing an interestedparty letter to the Forest Service, but if I had been , I would have
argued strongly against it. First, the official position of CPLC, the one
voted on in October, stated that if the Forest Plan were violated,
there could be an appeal. The Forest Plan, quite clearly, is violated
several different ways by the ROD. So, even though it's a different
group who made the appeal to the Forest Service, CPLC (I would have
argued) should at least remain silent.
Second is the moral dimension . CPLC's letter to the Appeals
Reviewing Officer aligns CPLC with the Modified Preferred
Alternative and says, in effect, that LCC is illegitimate. I am afraid
this indicates that CPLC may be more interested in political turf than
in protecting the Canyon. Why should CPLC have feared a successful
LCC appeal? In the appeal, LCC produced the most comprehensive,
accurate, detailed, and devastating analysis yet done on the proposed
construction . Anyone dedicated to protecting the Canyon should
respect its thoroughness, and be gratefu l for the work of the
compilers. Nothing better -- nothing even close -- has been done on
Logan Canyon . CPLC should not have given the Forest Service any
help in this matter, and certainly should not have undercut a fellow
environmental organization. That is not simply bad manners -- it
denies the whole morality of environmentalism, which is that the
environment comes first.
Sincerely,
Thomas J. Lyon
�r r om : (eche Chfimberl Brid e riend
FaH phone: B01 153
~
,
ue lity : me
CACHE CHAMBER OF COMMERCE /""-160?'\ORTH YiAC-: • LOG.'\.'\ . L"TA H S-B11 • (80 11751-11 6 1· FAX (801 ) 75:--?>. U6
May 3 1. 1995
USDA-Forest Service
Appeals Reviewi ng Officer
P.O. Box 96090
Washington. D.C. 20090-6090
FAX 202-205-1758
[Eight tQ[al pages including this one]
Response to Notice of Appeal and Statement of Reasons From Logan Canyon Coalition
Regarding the Re cord of Decision . U.S . Highway 89 . Logan Canyon
Wasatch-Cache National Forest
I am Douglas E . Thompson. president of the Cache Chamber of Commerce . a 600-member
chamber for all Cache County. and supervisor of the Bridgerland Travel Region Board . which
promotes tourism for Cache and Rich Counties . As a party interested in the Logan Canyon
Highway Project. I am compelled to make comment on the appeal.. Because time constraints and
board meeting schedules precluded getting formal approval of thi s statement from the respective
board s. this statement is my own . It. however.. is based on past discussions and statements
formally approved by both boards .
Appellants' appeal is very well written and documented . On the surface . it appears to be forceful
and mo tivatin g . However. careful analysis by those familiar with the project and the process that
led to the compromise Record of Decision shows many critical flaws in fact and logic in
appellants' document.. No matter how good appellants' rhetoric is . simply saying it does not
make it so .
Errors and misleading sta tements in appellants· document will be deli neated roughly fo11m\/ing
the outline they used in the app~al.
Introduction
Appellants' basic assertions lack foundation in fact.. The record o f public hearings . discu ssio ns.
and public input clearly shows that there has been full and earnest compliance with NEPA
requirements. The construction project has already been sca led down from the Preferred
Alternative recognizing the needs of the Logan Canyon environment. The Conservationists'
Alternative has been honestly and straightforwardly considt!red time and again . The compromise
represen ted by the ROD leans heavily in favo r of the Conserva tionists' Alternative bu t still
provides an acceptable level of service and safety.
This project is the best and most complete attempt at compliance with NEPA requirements of
any project in UDOT's hi story. It is the apparent opi ni on of o.ppeJl:mts that until eve ry square
inch of affected soil.. water and air affected has been analysed and considered . applying only
methodologies accepted by appellant s . the project is not in absolute compliance with NEPA
reqUirements . That level of proof is infeasible and impractical.. Reaso n should rule. The ROD
represents a finely craned compromise that reasonably but not absolu tely protects the
environment. On the other hand . it reasonably protects lives anu safery o f the people whtl use the
highway .
�Cache Chamber ofComme:rce Response To Logan Canyon Coaltion Appeal
Page 2
Extreme views have no place in the process now. Extreme views for protection should have no
more right to be heard at this time than the extreme views for development. The ROD does not
satisfy those who favor greater development but the process does not :lUOW the pro·development
extreme to reiterate their positions. The process gives ear only to those who want les~ than the
ROD.
The group presenting the appeal is a minority within a minority. The large r environmental
community that participated in the discussions and the negotia tions that led to the compromise
could never document that they represented more than a few thousand people. The appellants are
a very small splinter group of a vocal but well orga nized minority. The clear majority of the
citizens of Cache and Rich Counties suppo rted the Preferred Alterna ti ve. EVERY. REPEAT
EVERY. ELECTED OFFICIAL REPRESENTING CACHE AND RICH COUNTIES W HO
HAS WRITTEN AN OPINION SUPPORTS THE PROJECT. The largest local repre se ntative
elected bodies. the Cache Counry Council. the Rich County Commission. and the Cache Mayo rs
Association. have repeatedly stated their support of UDOT project plans. The vote o f approval
of the ROD by the Cache County Council was not unanimous because some council members
felt the ROD did not improve the highway eno ugh .
I. HISTORY AND BACKGROUND
From the very beginning. those most closely associated with tourism in Logan Canyon have had
significant input to the project. The proposals for National Scenic Byway status and the recent
successfullSTEA grant for Byway Enhancement were carefully coordinated among the Forest
Service. UDOT. and the Bridgerland Tra vel Board. Nothing in the ROD will significantly
reduce scenic tourism. in fact. the project will improve the safety of and access for tourists.
That the scale of the project received "massive opposition" is an exaggeration. The opposition
was vocal, media savvy, and very well organized. but it was never very large. Its largest
demonstration claimed only 400 participants: I was there and counted about 250. And its
petitions were critically flawed. One was so misrepresented that one mayor. to hi s profound
embarrassment. signed it t hin~ng it was for the project. On seve ral occasions. the Chamber
polled its members regarding th'e project and the plurality for the projec t never dipped below 70
percent.
Lack of Demonstr ated Purpose and Need
1 am not a safety engineer and do not feel adequate to respond to the technical questions of
safety. However. I drive the canyon often and can speak as a user. When no one else is o n the
road. it is safe enough and the travel time from Logan to Garden Cil)' is acceptable. That is why
the travel speeds have no t been a major issue with proponents. But no o ne driving the Canyon
on a summer weekend would say the canyon highway was safe o r that travel times were
acceptable. To completely alleviate delays during peak traffic would reqUire a project acceptable
to only a very few. But to leave it essentially as it is. with a few rurnouts. as the
Conservationists' Alternative suggests. is neither safe nor reasonable.
Bear Lake and Logan Canyon are the region's two most popular tOUlist attractions. dra\\'ing large
numbers from the populous Wasatch Front (Sal t Lake City. Ogden and ProvO). The traffic
studies do not show the increase in numbers and size o f recreational vehicles and boats traveling
to Bear Lake. Without passing lanes to relieve their length. vehicle convoys on summer
weekends and holidays become accidents waiting to happen. In the opinion of the Chamb;;!f. the
�C ache Chamber of Commerce Response To Logan Canyon Coaltion Appeal
Page3
ROD is inadequate [0 alleviate heavy ho liday traffic pressure but it will hdp. On oth e: r days.
passin g lanes. wider pavement and safer turn s that the ROD sug gests 3re accept3ble.
[h~
When it comes to commerce and demographics. the appeal is wro ng and misleading. 1-80 is n ot
the east access road for commerce out of C ache County: Logan Canyon is. The map in the
Appeal 's Appendix A is extremely mi sleading becau se it eliminates the criti cal connec ting road
between Kemmerer and Little America. where commercial traffic joins 1-80. The following
companies (representing ove r 5.000 employees in Cac he Valley ) have weekly and often daily
shlpments in and o ut of Cac he Valley using Logan Canyon:
Presto Products (plastic bag products. headqu3rters in Wi sconsin )
Cache Valley Cheese (heavy distribution to the east. strong supplie s in the east)
Gossner Foods (dairy foods. strong distribution to the east)
E.A .Mille r (meat packer. strong distribution to th e east. supplies from eaSL).
WeatherShield (window manufactu rer and di stributio n center with \Visconsi n
headquarters) L.W . Miller (custom freight)
Miller Transportation (custom freight)
Pe pperidge Farms (cookies. strong distribution to the east )
LeG rand Johnson (road construction and cement)
Jack Parson (construction and cement)
Logan Coach (horse trailers. strong midwest distribution)
Logan Manufacturing (strong midwest and eas tern distribution)
Simplor Dairy Products (custom cheese wrapping. strong eastern distribution )
Schreiber Foods (processed cheese. supplies grocery stories and fast foods from the
Mississippi west)
These are only the largest. There are many other Cache Valley businesses that depend on a
passable and safe Logan Canyon fo r their livelihood. To ask the se businesses to use 1-80 for
their eastern based commerce would cost millions of dollars every year in increased miles and
delivery time.
Logan Canyon is promoted locally. statewide and nationally as the best and most sce ni c route
from Salt Lake City to Yello,,:,stone. It is promoted locally by Blidge rland Travel Region.
statewide by the Utah Travel Council. and na tio nally by Heart of the Rockie s and the American
Automobile Association (AAA). Even tho ugh it is slightly longer in time than 1- 15 and mile s
than Idaho 34. and higher elevation than either. Logan Canyon is the ro ute recommended by
AAA for Yellowstone to Salt Lake City. not 1- 15 or Idaho 34.
The appeal takes pains to poi nt to the 1980-90 decline in Rich County permanent population. It
does not reveal the reason for the dec line was the boornlbust o f the sou thweste rn Wyoming oil
fields. The 1980 census figures were artificially high because of the boom. The: 1990 figures
show a slow but steady grow th from 1970. The se are permanent po pulation numbers. T he
primary industry of Rich County has shifted to tourism and Garden City is becoming a resort
community with a very high part-time resident population. Now. there are about as many parrtime residents as full-time. Tourism is in creasin g rapidly . Unemployment is running near two
percent and assessed property valuati ons have increased dramatically . While not in a boom. Rich
County's economy is improving steadily. In summary. :.t si mple analysi s o f Rich County ce nsus
figures is misleading when used to predict lower traffi c volumes.
Cit ing the decreasing rale of gro\.vth fo r ca nyon tr:.tffic vol umes is al so misle:::tdi ng because thaI
analysi s does not consider the underlying rea so ns. Su mmer traffic in LC'gan Canyon will always
�',om, :"
Cache Chamber of Commerce Response To Logan Canyon Coaltioo Appeal
Page4
have a hil.!h correlation to (he water level of Bear Lake. The mid-1980's repre se nt near· record
high water levels and consequential higher traffic volumes. The latter years of the study period
represent near-record low lake levels. During those years reliable access to the lake was
available only on the east side of the lake. persuading Wasatc h Front traffic to go through
Wyoming to Laketown. The summer of 1994 was the first year in the last five that large sail
boats CQuid be safelY launched. As the lake level increases. as it has alway s done in its historical
cycles. Logan Canyon traffic volumes will undoubtedly also increase .
Other non-demographic factors will increase Canyon traffic . The improvements and promotion s
financed by the ISTEA Byway Enhancement Grant will draw more tourists. The Forest
Service 's own Great Western Trail promotions will attract more. And the first new commercial
tourism property on Bear Lake in two decades. Harbor Village. will bring even more.
With growth in commerce in Cache Valley. in parr-time Rich County residents, and in touri sm at
Bear Lake and in Logan Canyon. UDOT traffic volume projections will be low.
2. SAFET Y ISSUES
The fundamental reason that the Chamber supports the ROD is safety. As traffic volume
increases. and the Chamber firmly believes it will. safety becomes the only reason to improve the
highway. C urrent travel time for commerce is acceptable. especially when compared to the 1-80
and Idaho 34 alternatives. But already safety is an issue . It is difficult for semi-trailers to
negotiate the tighter turns in the Middle Canyon without having back wheels run off thl! road. It
is possible for two commercial vehicles to pass on Burnt Bridge and the T win Bridges but both
vehicles will likely lose side mirrors.
It is not safe for bicyclists to travel in Logan Canyon past Right Hand Fork because the hard
surface shoulder literally disappears for seve ral miles through the middle canyon. With bicycle
touring growing in popularity. it is unfair to not allow safe bicycle use of the canyon highway.
It is important to note that the majority of the people in Cache Valley re mained publicly silent in
this whole processes. The best way to gauge their feeli ngs is by the people whom th ey elected to
repre sen t th em. Witho ut exception. at every public hearing and in every written respons.e fro m
e lected officials . they unequivocally supP0rled the need for a safe r hi gh way.
Regarding the safery o f the lower. improved section of highway and the greater number of
accidents: it is qUite Si mple . There is su bstantially more traffic in the lower canyon. that 's where
the largest campgrounds are and where the larger fishing facilities are . With more traffic and
more frequent entries and exi ts on the highway. there will be more accidents.
We accept UDOT safety and accident analysi s and numbers. Appellants do not. If one were to
disregard UDOT traffic figures and look only at Forest Service records of usage for lower
campgrounds compared to higher ones in relation to accide nts. accidents per camper wou ld be
higher in the upper canyon.
3. AASHTO STANDARDS AND HIGHWAY DESIGN
Fundame ntal to appellants' arguments is the "arhitrary anll capricious" applicati on of AASHTO
standards. 1 can nN speak to ASSHTO stanllards but I can say thOot nothing in thi s ROn is
"a rbitrary or capricious." Th e environmental community has see n to that. Although tht>
�Cache Chamber of Commerce Response To Logan Canyon Coaltion Appeal
Page5
Chamber and extreme environmentalists often disagreed. particularly in the early stages of the
process. anyone associated with the process will agree that the environmental community has
been te naci ous. Th ey forced UDOT and their consultants to exami ne and reexamine their
analysis and conclusions. Working close ly with UDOT. and other State and Federal age ncie s
associated with the process. I vouch for the earnestness and sincerity of the. bureaucra ts trying to
respond to the questions of the environmentalists.
To say that any of the ROD is "arbitrary and capricious" denies the very material and effective
role that the environmental community has played in the process.
Improve Level of Service of the Highway to Accommodate Projected Traffic Volumes
Once again. in their rush to analyse the appellants did not consider why traffic level gro\vth has
slowed. Undoubtedly . commerce. real esta te. and tourism will cause traffi c levels to increase.
Already. tourism is the greatest contributor to annual cyclica l increases. As promotion increase.
so will tourism volumes.
Impr ove Traffic Flow
On page 27. appellants claim that UDOT has not adequately considered the Conservationists'
Altema(ive and have not compromised "for the sake of environmental protection." From the
view of the Chamber and Travel Region Board. most of the compromises have come from
UDOT. Only in the latest stage s of negoti:ltion did CPLC compromise mu ch. Before that time.
all of the changes in the project had been in the direction of the Conservationists' Alternative. So
much so. that the Chamber was beginning to wonder when and where it would stop. Until the
ROD. Chamber members readily supported UDOT 's proposals. Many Chamber members.
particularly commercial truckers had to be persuaded to approve the ROD . In essence. they said.
"Not one more inch of reductions." They had compromised their positions enough.
To say that UDOT has not genuinely compromised is absurd to anyone who has observed the
process.
4. WILD AND SCENIC R{VERS
Lacking expe rtise in thi s field: we have little to say excep t that it appears to us thaI bringing up
this issue at this late date is only a stalling tactic. If appellants had been sincere in their concern
for the status of the river. they should have brought the issue to the table long ago. They had
ample opportunity .
Furthe r. it is my observation that every precaution is being taken to protect the river. The bridges
will be constructed with no piers in the river and the bridges with pi ers in the river will be
removed . The ROD should actually improve the free flow of the river.
5. FISHERY IMPACTS AND BONNEVILLE CUTTHROAT TROUT
Again. every pre caution is being taken to protect the river. Sedime.nt:ltion will be ke pt to a
minimum in volume and duration.
Concern about sedimentation from work along the dugway borders on the ludicrous. Th e work
along the dugway will be at least dozens of feet away from the liver anu as far away a~ ~ quarter
of a mile .
�CacheCbamber of Commerce Response To Logan Canyon Coa ltion Appeal
Page6
T he disturbing aspect of the appeal is that it clearly places a greater yalue on fish and flowers
m
than it does on hum:: life and safety. Because of compromise to protect fish habitat. Ihe Temple
Fork intersection has been downgraded 10 the point that it will still be da ngerous by design to
make a lef! tum going down canyon. The fish and thl! river are being protecteu at the expense of
huma n safety .
6. WILDLIFE IMPACTS AND SENSITIVE SPECIES and
7. ADDITIONAL CONCERNS WITH SENSITIVE PLANTS
The requests for studies a re for species increasingly obscure and further down the evolutionary
chain. In the May 30. 1995. Forest Service hearing. appe ll an ts req uested studies of
macroinve rtabrates. Will subseq uent studies be asked for bacteria and vi ru s? T he studies have
been reasonably complete. certainly acce ptable fo r NEPA.
8. VISUAL RETENTION
Of all the affected groups. the Bridgerland T ravel Region shou ld be the most concerned with the
scenic visual aspects of the canyon. The Region has repeatedly voiced its support of the canyon
project and has not changed its positio n in the Slightest.
9. ECONOMIC IMPACTS
It is the o pinion of the Cache Chamber of Commerce. the BridgerJa nd Travel Region. the Rich
Coun£)' Commission. the Bear Lake C hamber of Comme rce (Garden City). the Cache Coun£)'
Council and every local governme ntal body that has writte n an opi nion. that the Logan Canyon
highway project will have only positive economic impacts. T he on ly possible negati ve impacts
may be during actual construction because travelers may :lvoid th e canyon. But that can be
minimized by keeping the highway o pe n throughout construction . AAA has indicated they will
continue to recommend travel through the canyon during construction.
10. WETLAND ISSUES
One of the major compromise~ from the Prefe rred Altemalive 10 the ROD is narrowing (he
pavement from (he "cattle guard" to Beaver Mountain to red uce the amo unt of wetlands affecteu
by the project. Along with the concern for wetlands demonstrated in the FEIS. the ROD takes
great care to avoid damage to wetlands. The concerns of appe llants have been heard at every
public hearing on [he proj ect. W etlands conce rns have been more [han adequately addressed.
11. WATER QUALITY AND DESIGNATED USES
Concern for Logan River and the quality of wate r have been one o f the d tiving forces for the
design of the highway project. The re may be mino r. localized. very short tenn damage done
durin g construction but the entire project has been modified to protect the river and irs W:lter
quality. Appellants' description of damage a re from the FEIS for the Preferred Allernative. The
ROD will subs[antially reduce eve n the short tenn impacts.
12. CONSTRUCTION IMPACTS NOT EVALUATED IN THE FEIS
Beca use the very nature of highway cons truction precluues prellicting every possible impact.
several prec':lUtions have been taken to adjust Ihe.: projt::ct to elimi nate or minimize unfor..:seen
impacts. The project e nvironme ntal engineer anll rhe Coope rative Advi sory T:;!am will \\'::atch for
�Cache Chamber of Commerce Response To Logan Canyon Coaltion Appeal
Page 7
immediate problems. Design review of each phase will also reduce pOtential impacts. Even
though LCC was not given a position on the CAT. legitimate concerns brought to the CAT will
surely be acted on.
13 . 4(f) SITES
To include the highway and rights-of-way as
protected recreation is a stretch in any
reasonable person 's imagination. The Forest Service respected the letter and the intent o f secti on
4(f) when it designated the 154(0 sites.
-len
SUMMARY
Appellants have had access to the Environmental Impact Study process from the very beginnin g
of the Logan Canyon Highway project. Their concerns have been heard and have had a profound
affect on the ROD . Appellants had complete and unfettered access to the process. To alter the
project now to suit the appellants is unfair to the cooperators from all sides who worked so hard
within the syste m developing the ROD. Appellants had the opporruni ty (0 speak. they were
heard . and their concerns we re acted upon. What more can citizens ask of the system unle ss it is
their intention to bring process to its knees thro ugh stalling practices.
The EIS process panders to an intellecrual elite while it appears to disre gard the wishes of elec ted
official and long es tablished community organizations. A very small group. armed with a
thorough knowledge of statistics and the willingness to spend the time to analyse each set of
data. could effectively stall a project by challenging the methodologie s used to arrive at the data
in the E IS. That is happening now . Appellants are abusing the system because their personal
agendas for the project have not been mel.
Once a group or an individual agrees with an E IS for a project. they no longe r have a place in the
process. There is no way to defend a position. After accepting an EIS. aU one can do is watch
his position erode away as disagreeing parties are given continued access to the system.
As you review the appeaL please bear in mind th at literally thousands of reasonable people of
good will have acted in good faith to produce the project represented in the ROD. The !a\VS h:lve
been satisfied. The public has been heard. A super-majority represen ted by elected officials. and
establi shed civic organizations support the ROD . Now is the time 10 move forward with :l
project that will save human lives while it more (han adequate ly protects a canyon that we all
love.
Sincerely.
Douglas E. Thompson_ President
Cache Chamber of Commerce
cc:
Senator Orrin Hatch
Congressman James Han sen
Marsha BaiT. US Forest Service Regional Appeals CoonJinator
�United States
Department of
Agriculture
Forest
Service
Intermountain
Region
324 25th Street
Ogden, UT 84401-2310
File Code : 1950
Date : March 31, 1995
Dear Reviewer:
In January, most of you received notification of the Utah Department of
Transpor tation (UDOT) and Federal Highway Administration's decision to
r econstruct portions of U.S. Highway 89 t hrough Logan Canyon . For the next
step of t he process, it was necessary that decisions be made pertaining to
National Forest System lands. My decis ion and amendment for the Wasatch· Cache
National Forest Land and Resource Management Plan are enclosed.
This has been a long and arduous task for all parties involved and many of you
have participated for several years. I first became familiar with this project
as Forest Supervisor of the Wasatch-Cache National Forest . Now several years
and many improvements later, I believe the decision made by UDOT and the
Federal Highway Administration will protec t the valuable re sources in Logan
Canyon yet allow for r oad improvements to be made. Throughout the
environmental analys is, the Forest Service wo rked close ly with these agencies.
If you have any que st ions about this decision, please contact Chip Sibbernsen,
Acting Logan District Ranger, at (801) 755·3620 .
Sincerely,
-
V1 . 6-......
..----DALE N. BOSWORTH
Regional Forester
Enclosure
Caring for the Land and Serving People
Printed on R«:vcIecI Paper
F5-62O).28b (f2/93)
G
�•
RECORD OF DECISION
us
HIGHWAY 89
LOGAN CANYON HIGHWAY - CACHE AND RICH COUNTIES, UTAH
FINAL ENVIRONMENTAL IMPACT STATEMENT (FEIS)
AMENDMENT OF THE WASATCH-CACHE NATIONAL FOREST
LAND AND RESOURCE MANAGEMENT PLAN
AND CONSENT TO GRANT A TRANSPORTATION EASEMENT
ACROSS THE WASATCH-CACHE NATIONAL FOREST
USDA FOREST SERVICE, INTERMOUNTAIN REGION
I.
Introduction
Th i s document contains my decision to amend the Wasatch-Cache National Forest
Land and Resource Management plan (Forest Plan) to be consistent with the
Fe deral Highway Administration's (FHWA) and the Utah Department of
Tra nsportation's (UDOT) decision to construct reasonable and necessary
improvements to U . S. 89 from Logan to Garden City. This document also contains
my decision to consent to grant a transportation easement over approximately
seve nty-two additional acres of the Wasatch-Cache National Forest required for
the project. It is important to clarify that I am not making a decision to
imp rove o r how to improve u.s . 89; FHWA and UDOT, with our participation, haVE'
al ready made the decision to improve the roadway.
II.
My Decis ion and Rationale
Base d on the environmental analysis contained in the FE IS and FHWA's Record of
Dec i si on, I have decided t o amend the Wasatch-Cache National Forest Land and
Re sourc e Management Plan to be consistent with the decision of FHWA and UDOT t.o
cons truct reasonable and necessary improvements on u.s. 89 across National
Fore s t lands in Logan Canyon . This non-significant amendment to the Forest
Plan is attached as appendix to this Record of Decision. This amendment
cha nge s the Visual Quality Objective from retention to partial retention for
t he highway easement near Logan Cave and to modification for the remainder of
t he r oute . It also changes the guidelines for fisheries habitat indiciee to
pe rm i t decreases not exceeding 5 percent of the existing when the decreases al·e
tempo rary and the resulting index exceeds est~lished minimum standards set in
the 19 85 Forest Plan.
Because the project will result in expansion of the highway corridor in some
a re as I have also decided to consent to the FHWA's issuance of a Highway
Eas ement Deed, or series of deeds, to the Utah Department of Transportation fCor
t he phased construction of reasonable and necessary improvements on U.S. 89 .
The de cision for which I am amending the Plan is described in the FElS as the
Pre f e rred Alternative as refined in FHWA's Record of Decision for this FEIS .
To se rve as a basis for this decision, I am adopting the FElS as it relates to
the Wasatch-Cache National Forest. This is pursuant to 40 CFR 1506.3. FHWA
a nd UDOT issued a Record of Decision on January 18, 1995, to implement the
Pr e ferred Alternative as refined in their Record of Decision. The FEIS was
pr e pared by FHWA and UDOT with the full participation of the Forest Service a s
a cooperating agency ,. The effects on and associated with National Forest
�System lands, including consistency with the Forest Plan and meeting
transportation needs, are disclosed in the FEIS and further addressed in FHWA's
Record of Decision. I concur with their decision that the Preferred
Alternative, as refined and described in their Record of Decision, represents
t he best approach.
As a cooperating agency throughout the analysis process, the Wasatch-Cache
National Forest was closely involved in ensuring National Forest needs were
met. Of particular importance to the Forest is to protect sensitive and
endangered species, water quality and fish and wildlife habitat capability; to
maintain the scenic values of Logan Canyon; to maintain the overall character
and values of Logan River and Beaver Creek; and to maintain the potential for
undeveloped recreation along these water courses.
Because of the mitigation measures incorporated into the decision, many of the
impacts to the Logan River and Beaver Creek fisheries will be minimized. Most
potential impacts to water quality will be effective ly mitigated. Furthermore,
impacts to visual quality will be minimized to the extent practical while still
allowing for alterations to the existing roadway. Mitigation measures relating
to Forest Service decisions are highlighted in the next section.
Throughout the drafting of the planning documents for this project both FHWA
and UDOT have been sensitive to the concerns of both the Forest Service and the
public that Logan Canyon's natural resources and character be preserved.
Numerous suggestions for environmental improvement s to the project design and
monitoring to ensure environmental protection were incorporated into the FEIS
and FHWA's Record of Decision. The Preferred Alternative, as refined in FHWA's
Record of Decision, is the only alternative which represents a significant
improvement in highway function and service without seriously impacting visua1
resources and water quality in Logan Canyon.
The Forest Service staff of resource specialists reviewed the FEIS and
determined that the environmental affects were adequately disclosed. In
reviewing the Environmental Consequences in Chapter IV of the FEIS and the
refinements to the preferred alternative and responses to comments in FHWA's
Record of Decision, I have determined that all practicable means to avoid or
minimize environmental impacts within my authority, have been adopted. It is
clear that some impacts will occur, but taking into account the extensive
mitigation and the improvement in design and safety of the road, I concur with
the decision of FHWA and UOOT that the Preferred Alternative, as refined in
their Record of Decision, will best serve the needs of all concerned.
III. Mitigation Measure s
The Forest Service participated as a cooperating agency in development of the
FEIS. In cooperating with FHWA and UDOT, the Forest Service participated in
developing the extensive mitigation described in the FEIS. In addition the
mitigation measures described in the FEIS for the Preferred Alternative, FHWA
incorporated additional mitigation measures in their Record of Decision. I
have reviewed these and concur with these.
The measures highlighted be low relate to issues pertinent to the decisions I am
making as described in Section I of this Record of Decision. These measures
are described in detail in the FEI S as further refined in FHWA 's Record of
2
•
�Decision. Numerous other mitigation measures were a lso incorporated into the
decision of ODOT and FHWA. These are descri bed in their Record of Decision.
In addition to these measures, I am also including some additional measures to
protect the environment. These are identified with an asterik (*).
consenting to arant a transportation easement: Throughout development of
the Preferred Alternative, and subsequent refinements as described in
FHWA's Record of Decision, consideration was given to avoiding and
minimizing harm to sensitive resources and maintaining the character of
Logan Canyon. Protection of the river and surrounding wetland/riparian
edge, avoidance of threatened and sensitive species, avoidance and
minimizing harm to wetland/riparian habitat, visual and recreational
resources of the canyon played an important role in its development and
selection. As a result, minimal construction will occur in the
ecologically sensitive middle canyon, bridges will clear-span the river.
retaining walls will be minimized but employed where needed t o limit
encroachment into sensitive areas, and treatment of clearzones will be
modified from AASHTO recommendations .
All practicable measures to avoid impacts and minimize environmental harm
have been incorporated into the conceptual design described in the FEIS as
refined in FHWA's Record of Decision. The specific measures are described
for the Preferred Alternative in the FEIS and further expanded in FHWA's
Record of Decision. The Forest Service will participate in the detailed
final design phase emphasizing avoidance of impacts and minimization of
environmental harm. Horizontal and vertical alignments will be manipulatE:d
to provide a "best fit".
The Forest Service will participate and coordinate with ODOT in accordanCE:
with the terms of the two Memorandums of Understanding (MOU) between the
Forest Service, UDOT and FHWA that are applicable to this project (see
appendix to this Record of Decision for the general state-wide MOO and the
appendix to FHWA's Record of Decision for the supplemental MOU specific to
us 89 in Logan Canyon). In addition, the Forest Service will work and
coordinate with ODOT and FHWA in the final design, construction and
monitoring of specific projects:
1.
As a member of the Cooperating Advisory Team in the final design phase
for individual projects, the Forest Service will emphasize avoidance
of impacts and minimization of environmental harm.
2.
In development and subsequent approval of revegetation plan s.
construction/post-construction monitoring plans for individual
projects.
3.
In development of other plans (e . g., Wetlands Mitigation Plan) as
described in the FEIS and the "Measures to Minimize Harm" section of
FHWA's Record of Decision.
4.
By approving on-Forest staging, batch plant, and wetland mitigation
areas.
3
�5.
··The mitigation measures prescribed in the F£I5 and this Record of
Decision will be monitored and e nforced as described in the
"Moni toring or Enforcemen t Program " section of FHWA's Record of
Decision. Through its representation on the CAT, the Forest Service
will identify contractual measures prior to construction to ensure the
measures prescribed in the FEIS and FHWA's and this Records of
Decision are implemented. If and where necessary and in accordance
with Forest Service Policy. the Forest Service will specify easement
stipulations prior to construction to ensure the measures prescribed
in the FErs and in this Record of Decision are implemented.**
Amending the Fisheries Habita t Requirements in the Forest Plan ; The
portions of the Logan River within this project area have been rated by the
State as a Class 2 fishery (of great importance to the State) . The river
and its tributaries provide habitat for cutthroat trout (possibly
Bonneville cutthroat, a USFS sens itive species) and numerous other aquatic
species. Issues pertinent to this decision include wetland, water quality
and fisheries impacts. Mitigation measures include all those listed in and
incorporated by reference f r om the "Water Quality ImpactS", ~ Permits ",
"Wet lands and Botanical Resources", and "Water Body Modifications and
wil dlife Impacts" parts of the "Measures to Minimize Harm" section of
FHWA's Record of Decision. The following mitigation measures, which
correspond to other mitigation requirements in FHWA's Record of Decision,
provide additional fisheries mitigation:
6.
Best Management Practices and UDOT's Standard Erosion Control plans
will be employed to control sedimentation and siltation, minimize
water quality and habitat degradation, minimize vegetative removal ,
and minimize cut and fill. Detailed Best Management Practices will be
developed during design for each project.
7.
A construction/post· construction monitoring plan will be developed and
implemented by UDOT and approved by the Forest Service during design
of individual projects in order to identify sensitive areas where
monitoring is needed. Monitoring required will be identified in the
project plans and specifications for each project.
B.
The design of clearzones will focus on preservation of aesthetic and
ecological features to the extent possible while considering safety.
The prime directive will be to minimize impacts to wetlands and
riparian habitat without jeopardizing safety.
9.
All work will be conducted on the inland side of the highway where
possible to avoid in· channel activities and minimize riparian habitat
and riverbank disturbance. Road widths described in the FEIS as
further reduced in FHWA's Record of Decision were incorporated to
avoid or minimize impacts. Use of retaining walls or guardrails will
be considered where needed to reduce harm to wetlands and related
resources. This includes work on the Dugway, Temple Fork, in the
lower Upper Canyon, near Rick Springs and other segments described in
the FEIS and FHWA ' o Recor d of Deci sio n.
,
�10.
The design o f passing and turn lanes ' will be evaluated further during
detailed design to assess additional measures to avoid or minimiz e
harm to wetlands.
Use of retaining walls or guardrails will be
c o nsidered where needed to reduce impacts. This includes work in
lower Upper Canyon, culverts near Amazon and Stump Hollows.
intersections at Tony Grove, Beaver Mountain and Franklin Basin; and
othe r segments described in the FEIS and FHWA's Record of Decision .
11 .
A revegetat ion plan will be d e ve l oped by UDOT and approved by the
Fore s t Servi ce during design of individual projects to ensure that
critical habitat and disturbed areas are appropriately revegetated .
12.
Bridge and culvert openings will be sized so that floodplain
e levati ons will not be increased .
13.
Construction staging sites identified during design and approved by
the Forest Service will be kept out of aquatic, wetland and riparian
habitat. The contractor will be limited to the use of the identified
staging sites.
14.
Construct i on work zones will be delineated through the use of fen c ing
in sensitive areas to ensu r e contractor compliance with environmental
limits of operations.
15.
Curbing will be considered at Rick Springs to minimize vehicular
off-pavement impacts to vegetation near and along the riverbanks .
16.
Prior to the wet season all disturbed areas ··which could contribute
sediment into the river·· will be revegetated or reseeded and
··erosion matting installed . ··
17.
Rock and debris generated during the construction will not be
indiscriminately placed along the river banks . ··1£ locations with
excessive erosion are identified where some of the rock may be
beneficial, Forest Service approval will be obtained and the
appropriate permits acquired prior to placing the material .••
18.
··In - river piers will be removed or partially removed where possible
with minimal streambed disturbance.··
19 .
··During design phase and prior to any in-river activities, the Fo rest
and UDWR staff will identify when it is necessary for one or both
agencies to be contacted and on-site to assist UDOT in minimizing
aquatic impacts.··
20 .
··All concrete work on the bridges being replaced will be designed and
completed to minimize any leaks of liquid cement into the river. No
washing of cement trucks will take place in locations where the
material could wash into the river.··
5
�Amending the Visual Quality Objectives in the Forest Plan: US 89 through
Logan Canyon i s both a Natio nal Fo rest Scen i c Byway and a State of Utah
Scenic Byway. I n addition, thi s area li es within the Logan Canyon
Management Area . The Forest Plan presc ription for this management area
e mphasizes pro te c tion of scenic qua l i tie s . Issue s pertinent t o the
de c i sion to amend the VQO ' s include vegetative recovery, road and clearing
de sign featur e s and direct visual impacts. Mitigation meaaures include all
t hose liste d i n and incorporated by reference from the "Visual Impacts,
Batch Plant Locations, and Section 4(£ )" parts of the "Measures to Minimize
Harm" section of FHWA ' s Record of Decision. The f ol lowing mitigation
measures, whi c h correspond to other mit i gation requirements in FHWA's
Re c ord of Deci s ion, provide additional v i~ual mitigation:
21 .
Design o f t he Pre ferred Al ternative as refined in FHWA's Record of
Decisi on pl aced a strong emphasis on minimizing visual impacts. Road
alignments were designed to minimize the amount of visual impact to
the e xtent prac t ical wh i le s t ill p roviding f o r reasonable and
necessary impro ve ments. Aestheti c impacts will be reduced by
manipUlat i ng the horizontal and/or vertical alignment, and by moving
the alignme nt away from the river. This includes the work described
in the nDesign Considerations " part of the nMeasures to Minimize Harm "
section of FHWA's Record of Decision.
22.
The design of clearzones will focus on preservation of aesthetic and
ecol ogical features to the extent possible while considering safety .
No clearzo ne will be provided in the first four miles of the middle
canyon; however, substantial hazards within this area will be
considered for protection.
23.
A revegetation plan will be devel oped by UDOT and approved by the
Forest Service during design of individual projects to ensure that
areas of high visual quality are a voided, where practicable, and that
disturbed areas are appropriately revegetated.
24 .
A constructi on / post-construction monitoring plan will be developed and
implemented by UDOT and approved by the Forest Service during de sign
of individual projects in order to identify sensitive areas where
monitoring is needed. These areas and types of monitoring required
will be ide ntified in the project plans and specifications for each
project.
25 .
Best Management Practices will be used to minimize water quality
degradation, minimize vegetative removal, and minimize cut and fill.
26.
Dust suppression measures will be implemented during construction.
These measures will include water sprinkling, speed limits on haul
road, and use of environmentally safe stabilization chemicals .
27 .
Construction staging sites identified during design and approved by
the Fo rest Service will be ke pt o u t o f sens i tive visual areas . The
contrac tor will be limited to the u se of the identified staging sites .
28.
Construc tio n wor k zone s will be d e lineate d and sensitive areas fenced
to ensure contractor compliance with environmental limits of
operations .
6
�29.
Burnt Bridge will be construc~ed in stages, with widening occurring on
the upstream side, eliminating the detour presented in the FEIS.
30.
In additi on to the reduced width presented in the FEIS f or the Middle
Canyon, the previously proposed nominal roadway width of 40 feet for
the first 8 miles of the Upper Canyon section has been reduced to
34 feet to further minimize impacts to wetlands , visual and other
resources. (NOTE: this is nominal roadway width .. . passing lanes on
3.3 miles increase roadway width to 44 feet where they are present).
31.
The amount and necessity of riprap required f or erosion control at
bridges will be evaluated on a case-by-case basis during final
design. Riprap will be used only where required to stabilize the
streambank and will not exceed 100 feet along both banks up and
downstream from each bridge. Although it is possible this could total
as much as 1,000 feet of the river's length, it is anticipated that
riprap will not be required at each of these locations and the actual
use of riprap will be minimal. Existing rive r and c reek hydraulics
will be maintained by avoiding the encroachment of required riprap
into the channels .
32.
Fill slopes will not be steeper than 2:1 to promote bank stability and
reclamation.
33.
Riparian habitat will be maintained along the river and creek wherever
possible.
34.
Larger mature trees and their root systems will be protected where it.
does not conflict with vehicles and passenger safety.
35 .
Prior to the start of the next wet season, disturbed areas, where
possible will be stabilized, reseeded and revegetated.
36 .
Rock and debris generated during the construction will not be
indiscriminately placed along the river banks. ··1£ locations with
excessive erosion are identified where some of the rock may be
beneficial, Forest Service approval will be obtained and the
appropriate permits acquired prior to placing the material .• •
Th reatened. Endangered and Sensitive Species; In addition to the
mitigation described above, the Forest Service has special concern over
impacts to threatened, endangered and sensitive species of fauna and
flora. During preparation of the FEIS, UDOT and FHWA consulted with the
US Fish and Wildlife Service and Utah Division of Natural Resources
concerni ng potential impacts to these species. Consultation is documented
in the Appendix "Letter From US Fish and Wildlife Service" section of
FHWA's Record of Decision . This correspondence documents the US Fish and
Wildlife Service's determination that the Preferred Alternative as refined
in FHWA's Record of Decisi on and mitigated through measures described in
the "Threatened and Endangered speci es" part of the "Measures to Minimize
Harm" section of FHWA's Record of Decision would not affect Federally
listed threatened and endangered species. This includes the Maguire
primrose (Primula maquirei) . These mitigation measures are incorporated by
reference into this Record of Decision.
7
�In addition to federally threatened and endangered species, the Forest
Service recognizes other sensitive species. The effects of the
alternatives on these species were evaluated. Forest Service policy
requi r es preparation of a biological assessment and biological evaluation
prior to the Forest Service offic ial signing of a decision document.
These
scientific documents describing impacts to threatened, endangered and
sensitive species have been prepared. The original assessment completed in
September of 1993 was recently supplemented to include the most current
information. The original assessment (included in the appendix to FHWA's
Record of Decision) and supplement are included in the project record.
These document that the Preferred Alternative, as refined in FHWA's Record
of Decision, will not adversely affect the viability of any Forest Service
l isted sensitive species.
Wild and Scenic Rivers:
Consideration of potential wild and Scenic RiverE
is an inherent part of the ongoing land and resource management planning
process (Forest Service Manual 1924).
Forests must eva l uate each river to
identify rivers meeting the eligibility crite ria specified in section lib)
and 2(b) of the wild and Scenic Rivers Act and determine the river's
potential classification (wild, scenic, recreational, or a combination
thereof) for those found eligible.
wild and Scenic Rivers were evaluated during preparation of the
Wasatch-Cache Forest Plan approved in 1985 and it did not propose any
rivers for further study as National wild and Scenic Rivers (FE I S for the
1985 Forest Plan, page IV-55). Since t he time period when the Forest Plarl
was approved the philosophy for river eligibi li ty assessment has evolved.
The Forest determined a re-assessment was appropriate and in
December of 1993, the rivers on the Forest were inventoried to identify
those eligible for inclusion in the National wild and Scenic Rivers
System. Both Beaver Creek and the Logan River were inventoried.
Neither
were found to be eligible f or inclusion in the National wild and Scenic
Rive rs System, though the Logan River upstream of Temple Fork was f o und to
possess values significant within the State.
Regardless of the 1985 and 1993 Inventory · findings; the effects of the
project, should Beaver Creek and/or the Logan River ever be determined
eligible, were considered.
Forest Service policy (Forest Service Handbook
1909.12, Section 8.14) requires the Forest Plan to provide for protection
of a river area considered eligible but where the suitabil ity determination
has not been made, until a decis ion is made as to the future use of the
river and adjacent lands.
For eligible rivers, the Forest has to make a
determination whether projected will affect the eligibility or
classification of the reaches of the stream influenced by the project.
This requires determining if:
- the "free-flowing" characteristics of the river are mOdified;
- the potential outstandingly remarkable values for the r iver area al·e
modified; and
- the potential classification of the stream has changed.
The effects of the project on river characteristics which affect its
free-flowing nature, potential outstandingly remarkable values and
potential classification are thoroughly described in the FEIS:
8
�The effects of the alternatives described in Section 4.15 . 1, Water
Body Modification, of the FBIS show some minor rip-rapping near
bridges may occur where necessary to stabilize the streambank. This
would not extend over 100 feet along ' both banks up- and down-stream
from each new bridge, It is anticipated that riprap will not be
required at each of these locations and the actual use of riprap will
be minimal . Existing river and creek hydraulics will be maintained by
avoiding the encroachment of required riprap and/or retaining walls
into the channels. Therefore, the existing river and stream
characteristics pertaining to free-flowing character would not be
altered from the present status .
The FEIS thoroughly evaluated the effects of the alternatives on the
resources and characteristics affecting the scenic, historic,
recreational, wildlife and fish, cultural and other values associated
with the river and river corridor. As clearly summarized in Table S - 2
and as described in more detail in Chapter 4 of the FEIS, there will
either be no or only minor effects from the Preferred Alternative, as
refined in FHWA's Record of Decision, on these values . In addition,
the FEIS notes that many of the minor effects created will be either
temporary in nature or may possibly be mitigated during final design.
Consequently, no potential outstandingly remarkable values will be
eliminat ed.
Highway 89 currently parallels the river for much of its length. As
described in the FEIS, no additional · river crossings will be built nor
will additional stretches of the river be followed. The FEIS
recognizes that some screening vegetation along the river may be
disturbed, but again this is estimated in the BIS to be minor and
mostly temporary in nature. Therefore, the potential wild and Scenic
River classification would not change.
Based on the environmental effects summarized above, the road
recons t ruction project will not affect the eligibility or classification
potentials of the Logan River and therefore, the opportunity for
designating these reaches of Logan River and/or Beaver Creek as a
recreational river(s) in the future is not foreclosed by allowing the
highway improvements described in the Preferred Alternative, as refined in
FHWA's Record of Decision.
IV.
Public Involvement
A no tice of intent initiated by FHWA was published in the Federal Register on
January 23, 1987. To initiate the scoping process and solicit input, a mailing
list containing nearly 100 entries was compiled to include governmental
agencies, associations, the media, and interested individuals . Entries on the
mailing list received a public involvement pl~ which coordinated public and
agency activities.
Public information meetings were held in Logan, Utah on September 23, 1986, and
in Garden City, Utah on November 3, 1986 .
9
�An Interdisciplinary (10) Team composed of transportation planners. civil and
environmental engineers. envi ronmental advocates and recreation and wildlife
s pecialists met frequently in 1986 and 1987 to review technical aspects of the
project and provide insight and perspectives on issues germane to the project .
UDOT used a Citizens Review Committee to review the final Draft Bnvironmental
Impact Statement (OEIS) to determine whether the document addressed the issues
in an understandable and appropriate fashion. The Committee was composed of
representatives of various city and county governments in the project area.
Three formal Beoping meetings were held in March, 1987, to identify major
concerns and re ceive public comments. The meetings were attended by
333 individuals, 64 of whom offered comments. Nearly 200 letters, commenting
o n the proj ect, were received from the public, advocacy groups and government
agencies.
A Draft Environmental Impact Statement (DEIS) for the project was issued in
November, 1990 . UDOT received 457 comments letters expressing various ideas
and sentiments about the Logan Canyon project. Some issues addressed in the
comment letters included: safety, travel time through the canyon, scenic
values, bicycle traffic, fisheries, alternative routes, wetlands, water and
quality and threatened and endangered species. These issues and comments were
addressed i n the DEIS and/or the FSIS.
The Preferred Alternative was presented to the public in a brochure which was
sen t to those who commented on the DEIS . In response to this brochure,
a pproximately 400 letters were received prior to release of the FEIS. These
comments were reviewed and a determination made that they were addressed in tt.e
FEIS or FHWA's Record of Decision.
The FEIS for the project was completed in February of 1993 and made available
to the public for comment. In response, approximately 200 letters were
received . Individual responses to these letters were provided where addresses
were available. Detailed comments were not directly answered, but the
commenter was informed that they would be considered and where appropriate
responded to in FHWA's Record of Decision . In FHWA's Record of Decision, a
summary of comments and responses was provided. The comment letters and
responses are maintained in the UDOT's project record.
All comments received on the FEIS were reviewed and given consideration during
development of FHWA's and this Record(s) of Decision. Between issuance of the
FEIS and issuance of FHWA's Record of Decision, numerous coordination meetings,
field reviews, discussions and correspondence were held. This effort led to
the refinements in the Preferred Alternative described in FHWA's Record of
Decision and referenced in this Record of Decision. A summary of the comments
received on the FEIS and responses is contained on pages 28 through 43 of
FHWA's Record of Decision.
Since FHWA's Record of Decision was iSBued, members of Logan Canyon Coalition
have met and or conversed with Fore st Service representatives regarding
concerns over the project. These concern s were c onsidered in formulation of
this Record of Decision.
10
�•
V.
Alternatives Considered
The following four alternatives were analyzed in detail in the Final
~nvironmental
Impact Statement (FEIS) for U.S. Highway Route 89, Logan Canyon
Highway.
Preferred Alternative:
The Preferred Alternative as described in the FEIS
has been refined in response to comments received. A detailed description
of this alternative is contained in FHWA's Record of Decision and is
incorporated by reference here . In general, this alternative will replace
bridges. make minor alignment adjustments, maintain no clearzone and
maintain the existing 26 foot roadway in the first 4 . 1 miles of the project
area (lower Middle Canyon sectionl. In the 4 miles of upper Middle Canyon
the roadway width will be 34 feet, a clearzone provided, bridges and
culverts replaced, Temple Fork intersection improved, and minor alignment
adjustments made. In lower upper Canyon a 34 feet wide roadway will be
maintained (except as modified by passing and turn lanes), a clear zone
provided, bridges and culverts replaced, intersections improved, and the
range fenced where appropriate. In the remainder of Upper Canyon the
roadway will widen to 40 feet (except as modified by passing and turn
lanes), intersections improved, a clearzone provided, and alignment
adjustments made. From the Bear Lake Summit to Bridgerland subdivision
intersection a 47 feet wide roadway (including a continuous passing lane)
will be established, clear zone provided, numerous alignment adjustments
made, intersections improved, and one landslide area stabilized. From
Bridgerland subdivision to Garden City a 40 feet wide roadway width (47
feet where there are passing lanes) will be established, clearzone
provided, intersection and access points improved, and several alignment
adjustments made. The Preferred Alternative, as refined in FHWA's Record
of Decision, would cause a decline in the Habitat Condition Index for the
Logan River and Beaver Creek. The refined Preferred Alternative would also
result in a Visual Quality Objective of partial retention for the highway
easement near Logan Cave and modification for the remainder of the route.
The refined Preferred Alternative thus does not comply with the Forest
Plan . The Forest Service would consent to grant a transportation easement
for approximately 72 additional acres.
No Action Alternative: The existing roadway width would be maintained
although considerable road maintenance, including improved signing and
replacement of bridges and pavement would be necessary. The No Action
Alternative complies with the Forest Plan. Transportation easements
covering additional lands would not be required.
Standard Arterial Alternative: Improve the highway to current national
highway standards for a minor arterial road with the construction of
passing lanes throughout much of the route and recovery areas resulting in
a roadway width of forty to forty· seven feet and a typical improved area of
sixty·six to ninety·eight feet. The Standard Arterial Alternative would
cause a decline in the Habitat Condition Index for the Logan River and
Beaver Creek and would achieve a Visual ~ality Objective of Modification
rather than Retention. The Standard Arterial Alternative would therefore
not comply with the Forest Plan . The Forest Service would consent to grant
transportation easements for approximately 83 additional acres.
11
�Conservationi sts' Alternative: Spot improvements such as improved signing.
replacement of bridges, slow vehicle turnouts, climbing lanes and paving
and plowing of parking areas . Existing roadway widths would be maintained
in most instance s. with a roadway width of forty · three feet for climbing
lanes. The Conservationists' Alternative would fail to comply with the
Forest Plan Visual Quality Objective in the vicinity of Burnt Bridge. The
Conservationists' Alternative would result in a change of the Visual
Quality Objective of the Burnt Bridge area from Retention to Partial
retention . The Forest Servi ce would consent t o grant transportation
easements covering about 11 additional acres .
The following alternatives were considered in the OEIS but not advanced in the
FEIS.
Corridor Alternatives: The Corridor Alternatives considered other
potential rout es connecting Cache and Rich Counties. The Corridor
Alternatives were dropped because there is no projected need for the
additional r outes for the next twenty years, the environmental consequences
of additiona l highway construction, and the duplicate spending of
operational and maintenance funds for the new route and the existing
highway in Logan Canyon .
Modified Standard Alternative: The Modified Alterna tive proposed a
modified standard along the existing alignment for the road width in the
Middle Canyon section only. It was intended to reduce the impacts of the
Standard Alternative in the Middle Canyon section. The Modified
Alternative was dropped because of unacceptable environmental impacts in
the M
iddl e Canyon, especially the alternative's impacts on wild trout
populations in the Logan River.
Spot Improvements: The Spot Improvements Alternative provided a small ,
incremental modification of the No Action Alternative. The notable
difference between the two alternatives was the inclusion of 7.5 miles of
climbing lanes in the Spot Improvements Alternative. The Spot Improvements
Alternative was not included i n the FEIS because it resulted in no
improvement in traffic-carrying capacity or safety and thus did not meet
the purposes of the project.
Rich County Alte rnative Alignments: Several alternative corridors in the
Rich County section of the project were proposed. These alternative
alignments would have resulted impacts on ·winter habitat for deer and elk,
and disruptions to existing real estate development. Rich County strongly
opposed the alternative alignments . Thus, t he Rich County Alternative
Alignments were not considered in the FEIS.
VI .
Findings Required by other Laws
The Wasatch-Cache has begun preliminary efforts directed towards the Forest
Plan revision scheduled to be completed in 1996 . However, Forest Service
policy and regulations provide for implementation of existing Forest Plan
decisions until amended or revised and do not mandate retention of future
management options. This means the Management Area direction for Management
Area 13, as amended, will continue to be imp lemented until the Forest Plan
revis ion is finalized.
12
�The Wa satch-Cache Forest Plan has been reviewed and a determination made that
while the overall direction and intent of the plan will not be affected, this
decision contains inconsistencies with the Forest Plan which will require
amendment. The actions in this project comply fully with the goa ls of the
Forest Plan, the Management Area Direction, and the Forest-wide standards and
guidelines (See Chapter IV of the Wasatch-Cache Land and Resource Management
Plan) except for the Visual Quality Objective and the fisheries habitat
i ndicies for the Logan River and Beaver Creek. The Visual Quality Objectives
will be changed to Partial Retention in one spot in Middle Canyon and
modi ficati on throughout the remainder of the highway easement. The Habitat
Quality Index for the Logan River and Beaver Creek will be changed to allow
temporary minor decreases provided minimum index l eve ls are still exceeded.
~ FEIS 4 - 2.
Specific changes are documented in the attached plan amendment .
Analysis of these changes is included in the FEIS . I conclude that this is a
non - significant amendment to the Forest Plan as defined in 36 CFR 219.10(e) in
that it does not significantly alter the multiple use goals and objectives for
long term land and resource management for the Forest.
VII. Environmenta l ly Preferable Alternative
The No Act i on Alternative has been identified as the environmental ly preferable
alternative.
VIII.
Implementation Date and Appeal Opportunities
This decision is subject to appeal pursuant to 36 CFR 215 . 7. A written NotiCEof Appeal must be postmarked within 45 days after the date this notice is
published in the Ogden Standard Examiner, Ogden, Utah. The Notice of Appeal
should be sent to: Chief, USDA Forest Service, P.O. Box 96090, washington, D. C.
20090-6090
Appeals must meet content requirements of 36 CFR 215.14 . For further
inf orma tion on this decision, contact Reese Pope at Wasatch-Cache National
Forest, 8236 Federal Building, 125 South State Street, Salt Lake City, UT
84138 or by phone at (801) 524-5188.
If no appeal is received, implementation of this decision may occur on, but not
before, 5 business days from the close of the appeal filing period. If an
appeal is received, implementation may not occur for 15 days following the date
of appea l disposition.
-
trlAH , I 1995
,
Date
DALE N. BOSWORTH
Regional Forester
Intermountain Region
324 25th Street
Ogde n, UT 84403
13
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UT
'iN 3;J.., I
�Dec. 7, 1994
Dear Tenacious member of the Logan Canyon Coalition,
I have enclosed a rough draft of some proposed changes to UDOT's ROD. I've
spoken with some of you about this proposal, and I've incorporated many of your
ideas, including some ideas from the Conservationists' Alternative. I've tentatively
called this new proposal the "Citizens' Alternative." Catchy title, right?
It seems to me that the sooner we decide on the changes we wish to see
through our Forest Service appeal, the more focused and efficient our work will be.
Anyway, we will have to declare, in our appeal, exactly the changes we wish to see.
Please look over this draft, and let me know what you think. I'd like to discuss
this further at our next meeting. In this proposal we should indicate the changes we
want, and also briefly discuss our reasons for requesting each change. Further, indepth, discussions will come in the body of the appeal. This is not a final draft! It is for
the sake of discussion at our next meeting. Please feel free to make suggestions that
will reflect your own point-of-view.
I strongly believe, however, that we should present a proposal to the Forest
Service that is not too "radical," rejecting all improvements to the road except for
bridge replacement. We should allow for further changes that really might improve
safety. We should try, in other words, to appear reasonable, while still defending what
needs to be defended. We should, rt we can, reflect concerns that the Forest Service
and other agencies might themselves have with UDOT's ROD, for example, UDOT's
proposed extensive changes at Temple Fork. With this approach, we might have a
good chance of success with our appeal. In our proposal, we should not try to shut
down everything UDOT wants to do. If we do, we will likely be dismissed too easily by
Forest Service administrators. On the other hand, I do not want us to agree with
UDOT's plans rt we really believe they will unnecessarily harm the canyon.
Please let me know what you think. I would like to reach a good consensus.
Yours in Tenacious Defense of our
Canyon,
Go rQM
S'{-e..I!\\...oqf
753-0497
�Citizens' Alternative
Proposal for Improvement of the Logan Canyon Highway 89
Our alternative is identical to the revised Preferred Alternative proposed by
UDOT in their recent ROD, with the following changes.
1. Keep the 26' road width up to just beyond Ricks Spring. Extend section 1b, described in the FEIS as remaining at 26', up to just beyond Ricks Spring.
This would prevent unnecessary damage to the river, which runs very close to
the road along this stretch. This change helps protect the river and its fishery at the
lower Twin Bridge and the Temple Fork intersection.
2. At the Temple Fork intersection, keep the road to only two travel lanes, without a
right hand or left hand turning lane.
The river along this intersection probably provides very good spawning grounds
for cutthroat trout. Along the entire river, there are very few good spawning grounds for
cutthroat or for brown trout, making this section of the river at Temple Fork extremely
valuable to the fishery in the Logan river. The road at Temple Fork passes very close
to the river. Widening this section of road to accomodate turning lanes would seriously
damage these spawning grounds and so the fishery in the entire river. UDOT presents
no data on the number of vehicles that turn into the Temple Fori< road, and emerge
from the road. This is an unimproved, dirt road that meanders into an unimproved
recreation area. UDOT has not justified the severe damage to this fishery that would
occur here with widening and with turning lanes.
3. Do not flatten curves at and around the Temple Fork area. Curves 39 and 40, at
milepost 388.8, and curves 43 and 45, at mileposts 389.4 and 390.1, should be left on
their present alignments.
The road gradually curves along this section as it follows the river. These
curves are gradual. They are not sharp, so they are not particularly dangerous at a
reasonable speed. UDOT has presented no data showing that these curves are
particularly dangerous. The scenery through here is spectacular. There is no loss in
"driver comfort" as one negotiates these gentle curves and enjoys the views of the river
and canyon walls. The only reason for flattening these curves is to achieve a straighter road so that drivers can "go fast." The resulting slopes may not be revegetated
successfully. The run-off from construction would have to enter the river at some point,
and the increased sedimentation may seriously damage this sensitive cutthroat spawn·
ing area. There would be loss of recreational and scenic values here, with no good
justification of the loss.
,
�4. At Logan Cave, as the road is elevated, use a retaining wall to keep fill out of the
river. There should be no more encroachment into the river. This is consistent with the
ROD, in which UDOT agrees to maintain the '1ree flowing" nature of the Logan River.
(The Conservationists' Alternative called for the road to be "moved away from
the rive~' as it is elevated. This would mean that the mountain on one side of the road
would have to be carved out to create room for the road as it is shifted away from the
river. Is this preferable to use of a retaining wall?)
5. Maintain the 34' road width past the Beaver Mountain intersection and over the
summit to just past the Bear Lake overlook. Do not increase the width in the upper
canyon to 40'.
6. Do not construct a climbing lane over the summit. End the proposed climbing lane
below the summit.
Changes 4 and 5 will possibly allow the road to be kept in its present alignment,
without too much damage to the old-growth forest. If the road is increased to 40', and
a climbing lane over the summit is constructed, the road will need to be moved to a
different alignment in order to avoid severe damage to the forest. But this will involve a
huge amount of fill in a side canyon, with destruction of deer forage and mountain
mahogany. The older road would probably never be completely removed. It would be
much less damaging to keep to the original alignment, with a narrower road.
Furthermore, a wide, straight highway at the summit, complete with a climbing
lane, would encourage drivers to increase speeds to dangerous levels. This is a north·
facing slope at about 8000 feet. The grade of the road may approach 10%. In the
winter, with ice and snow on the road , higher speeds could be especially deadly. At
the summit there is the popular Umber Pine trailhead turnOff, and just past the summit
is the Sunrise Campground turnoff. The road would be safer ~ drivers were not
rocketing over the summit, past these intersections, at excessive speeds, especially in
the ice and snow.
7. Do not construct a passing lane just past the cattle guard. Instead, construct a slowvehicle pullout, and put up a sign informing drivers that a passing lane will begin in a
mile.
This would eliminate unnecessary destruction of wetlands along the road. The
sign would help encourage drivers to be patient until they reach the passing lane.
�8. Maintain a 26' road width along Beaver Creek. Do not increase the width here to
34'.
The road from Ricks Spring to Beaver Creek will be widened to 34', but through
the corridor along Beaver Creek the road will be kept at its current 26', wrth possibly a
slightly lower posted speed. Widening this road to 34' would involve unacceptable
impacts to the creek and aSSOCiated wetlands. The road is simply too close to the
creek and wetlands, on both sides of the road. UDOT claims that it would work in only
a narrow construction zone, but any construction here would seriously damage
riparian habitat and probably wetlands. Beaver Creek contains important spawning
grounds for cutthroat trout, and it contains a population of beaver that have only
recently returned after being driven out by road construction 60 years ago. Any slight
gain in "driver comfort" by widening here is not worth destruction of the cutthroat trout
fishery and important wildlde habitat. UDOT will object to the "bottleneck" in traffic flow
that would be created here d our proposal is implemented. In our proposal, there are
two "bottlenecks," one in the middle canyon and one at Beaver Creek, with a narrower
road and slightly lower posted speeds in each. Possibly, two bottlenecks will better
protect the future health of both of these areas.
9. Insist that no new riprap be used in the canyon. UDOT should be required to
stabilize all damaged riverbanks using natural vegetation, and UDOT should be
required to expend the time and money necessary after construction to ensure that all
revegetation efforts are successful.
The Logan Canyon has great recreational and scenic values. These values
would be harmed with the "easy solution" of riprap. If UDOT goes into the canyon to
widen and straighten some sections of the road, and replace bridges, UDOT should be
required to mitigate in a manner fully consistent with the recreational and scenic
values of this canyon. This means use of natural vegetation that is carefully maintained at UDOTs expense well after construction.
10. UDOT should specdy more explicitly the measures it will take to minimize harm to
the river, to fisheries, and to the scenic value of the canyon. It should also specdy
more explicitly measures rt will take to mrtigate damage from construction.
Too often UDOT simply says that it will use "best management practioes" This
is too vague. UDOT wishes to leave detailed discussion of the exact measures it will
use to minimize harm to "deSign phase." This does not give the public and appropriate
agencies sufficient information to properly evaluate UDOTs proposal before approval
of the project is given by the state transportation commission and the federal highway
administration. Evaluation of the impacts of proposed construction must include
consideration of the exact measures UDOT intends to use to minimize harm and
mitigate damage. Especially when construction will seriously impact particular sites,
such as Temple Fork, Logan Cave and the lower Twin Bridge and Burnt Bridge, UDOT
�should be required to give a site-specdic discussion of exact measures that will be
used. When culverts are replaced, does UDOT intend to use culverts that are graded
and baffled, allowing fish to move through culverts during high water flows? UDOT
mentions that ~ will use' sediment basins to collect sediment from run-off, but does
UDOT intend to change the filters in these basins at appropriate times after construction is completed? In the FEIS, UDOT provides no discussion of how revegetation will
be accomplished after construction, and no estimates of how successful revegetation
efforts will be on the slopes that will be left after curve-cuts. Will UDOT carefully maintain new vegetation after construction is completed? UDOT should be required to
speedy and discuss exact measures ~ will use. These discussions should be in an
EIS, appearing before approval and funding of the project.
�United States
Department of
Agriculture
Forest
Service
Uinta and
Wasatch-Cache
Nationa l Forests
8236 Federal Building
125 South State Street
Sa l t Lake City, UT 841 38
(801) 524-5030
Reply to :
Date:
1950
December 7 , 1994
Dear Interested Forest User ,
The Uinta and Wasatch-Cache National Forests, Ashley National Forest and Bureau
of Land Management have begun t he process of preparing a Suppl ement to the
North Slope Oil and Gas Leas ing Environmental Impact Statement (EIS). The
original analysis examined non-Wilderness Federal lands wi t h Federal mineral
righ ts that should or should not be made available for oil and gas expl oration,
development, and production on the North Slope of the Uinta Mountains. A
decision on the EIS was appealed which l ed to the roadle ss a r ea being removed
from l easing until further analysis could be completed. This Supplement will
focus only on t he issue of roadless areas.
Comments and suggestions concerning this ana l ysis will be accepted through
January 12. 199~ . Comments should be concise and specific to the fo cus of this
Supplement. Please mail comments to Evanston Ranger District. P.O. Box 1880,
Evanston, WY 82930.
The Draft Supplement is expected to be available fo r publ ic r eview in early
February 1995. A 45 day comment period will follow release of the Draft. Upon
analysis and consideration of these comments. the Fi nal Supplement and a new
Decision will be prepared and released.
If you have any questions or concerns. please contact Liz Schuppert at (307)
789-3194 .
Sincerely.
0?~","~ P. k.J;.."
~d' PETER W. KARP
Forest Supervisor
�>
•
Supplement to
North Slope Leasing Environmental Impact Statement
Wasatch-Cache and Ashley National Forests
Summit and Daggett Counties
THE APRIL 94 LEASING DECISIONBeginning in the fall of 1991, the Wasatch· Cache and Ashley National Forests began the
analysis to determine whi ch lands across the North Slope of the Uinta Mountains should be
administratively available for leasing and if they were to be made available for leasing, what
stipulations should be appli ed. A final decision was made in April of 1994 to allow leasing
on 219,000 acres and to not allow leasing on about 23,000 acres.
Four valid appeals were received on thi s decision. As part of the appeals process the Forest
Supervisors met with appellants to discuss resolution of their appeal issues. One of the
primary appeal points was whether or not leasing should be allowed in the "road less area"
portion of the study area. As the Forest Supervisors took a hard look at the decision made
in April and some of the issues raised in the appeals, they determined better information
was needed about the "roadless" portion to make a well informed decision since oil and
gas leasing cou ld influence the area for a long time. This led to a August 18 decision to
withdraw the decision for the "roadless area" portion of the study area (about 80,000 acres).
The remaining 160,000 acres within the study area will be leased as determined in the April
decision.
A BETTER LOOK IN A SUPPLEMENTThe North Slope Leasing EIS analyzed effects for roadless acres across the North Slope and
cumulative effects for all roadless acres contiguous with the High Vintas Wilderness. As
the Forest Supervisors studied their decision and analysis what they found lacking was a
description of the unique roadless characteristics of the major drainages within the study
area. For example, what is the solitude of the Middle Fork Blacks Fork drainage? What is
the natural integrity of the Beaver Creek drainage? Are there other acti vities ongoing or
planned for the future that need to be considered? In other words, they felt there were enough
differences in the road less characteristics in each major drainage to warrant a more detailed
look in a supplement to the Environmental Impact Statement. Once these characteristics
are described , new alternatives will be considered if the 7 alternatives in the EIS do not
provide an adequate mix of leasing scenarios.
Peter W. Karp, Forest Supervisor of the Uinta and Wasatch· Cache National Forest and
Brent McBeth, Acting Forest Supervisor of the Ashley National Forests are the responsible
officials for this action.
THE SIX ROADLESS CHARACTERISTICSThe following roadless characteristics will be considered in each major drainage across the
North Slope:
�1
>
Natura l int eg r ity is the extent to which long-term ecological processes are intact and operating. Impacts to natural integrity are measured by the presence and magnitude of human
induced change to an area. Such impacts include physical developments (e.g roads, utilityrights-of way, fences, lookouts, cabins), recreation developments, domestic livestock grazing,
mineral developments, wildlife/fisheries management activities, vegetative manipulation, and
fire suppression activities.
Appare nt n at u raln ess means that the environment looks natural to most people using the
area. It is a measure of importance of visitors' perceptions of human impacts to the area.
Even though some of the long-term ecological processes of an area may have been interrupted,
the landscape of the area generally appears to be affected by the forces of nature. If the
landscape has been modified by human activity, the evidence is not obvious to the casua l
observer, or it is disappearing due to natural processes.
R em o t e n ess is a perceived condition of being secluded, inaccessible, and out of the way. The
physical factors that can create "remote" settings include topography, vegetative screening,
distance from human impacts such as roads and logging operations (s ight and sound), and
difficulty of travel. A user's sense of remoteness in an area is also influenced by the presence
or absence of roads, thei r condition, and whether they are open to motorized vehicles.
Solit u d e is a personal, subjective value defined as isolation from the sights, sound and
presence of others, and the developments of man. Common indicators of solitude are numbers
of individuals or parties one may expect to encounter in an area during a day, or the number
of parties camped within sight and sound of other visitors. Impacts related to primitive
recreation experiences are normally expressed in changes to t he physical setting, activities
occurring in the area, of to the social experiences of users.
Spec ia l features are those uni que geological, biological, ecological, cultural, or scenic features that may be located in roadless areas. Unique fis h and wildlife species, un ique plants
or plant communities, outstandi ng landscape feat ures such as unique rock formations, and
sign ificant cultu ral resource sites are some examples of the items
Th e M a n ageability/ B ound ari es elem ent relates to the abili ty of the Forest Service to
manage an area to meet size criteria and the five elements discussed above. Changes in
the shape of an area influence how it can be managed. If broken into narrow corridors or
small islands interspersed with areas of non-conforming management practices, many of the
6 elements may be compromised.
WHAT WE NEED FROM YOUTo be most helpful in this analysis, please submit specific comments related to the 6 roadless characteristics within the major drainages (see attached map). Please submit written
comments to Liz Schuppert, Evanston Ranger District, Box 1880, Evanston WY 82930 by
January 12, 1995 .
T he draft supplement is expected in February 1995. If you have any questions or concerns
call Liz Schuppert at (307) 789-3194.
�Wasatch-Cache &Ashley NatWl1flt forests
•
.
-
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USFS Regian Faur
NORTH SLOPE OIL AND GAS Svpple?l!ntal Analysis
•
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, ·SliIIwater/Heydan
2·Eul Fork Bear
3-Wesl Fork Blackl
4-Middle Fork Blecks
5-E. Fork Blacks Fork
S.W. Fork Smith Fork
7-Gilbart Creek
8-e. FOlk Smith Fork
9-Hen'Y' FOlk
10-Belver Creek
Mil e s
o
6
12
18
11·Burnt Fork{Thomp.onIKabeli
12·No. Fork Sheep Creek
13-Mehogany/Oeath VaJley
Ceneral area.
Legend
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Area
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�To: Keller, lauren
18-5-94 4:45p.
FrOll:
OCT~-l994
15:34
FRD1
TO
ENiItEERIi'I:i SERVICES
918e17536139
p. 1 of l
P .01
October 5, 1994
PACSIMD..B TRANSMlTl'AL
COVER SHlllIT
TIllS TRANSMl'ITAL CONTAINS 3 PAGES (INCLUDING COVER PAGE)
SENT BY:
LORRAlNB RICHARDS
UDOT HNVIRONMENTAL DIVISION
4$01 S 2700 W, SLC, UT 84119
PHONE t: (SOl) 965-4159
FAX I: (SOl) 965-4796
SENT TO:
LAUREN KEIJJ<I!
FAX #:
753-6139
,
COMMBNTSfINSTRUcnONS:
Attacbed is • clean copy of the revisions you ...:elved yesterday and the changes we
c:U.scuSKd in yCSlCIday's mec:d.n, fur yuur
~view.
Pk::a:io::il!lC that Shawn and Paul .mccive a
copy. Thanbl
............ PlBASB NQ'IUlY RECIPIENT AS SOON AS POSSmLB ••••••••
�18-5-94 4:45p.
To: Keller , Lauren
OCT-ffi-l994
15:34
FR01
EN3It-EERIt-t3 SERVICES
910017536139
TO
p. Z of 3
P.02
PROPOSIW LilNGUAGB CHANGRS TO 9 - 27 REVISION
U9-89 LOGAN CANYON
Page 2, Last Paragraph. 4th
Sentence~
Since the roadway already serves ae a US Higbway and was
designated as such in accordance with previous legislation,
the determination has been made that this action would not
change the use of the highway.
Page 6, Insert new
p~ragraph
"l"h.:I.. :a.eeds JIIOre work,
after second paragraph.
pu1l some lULgua.ge
~rOJD.
previou.s
:z
paragraphs and add the ~ollowing* A new intersection
providing ace... to the sridgerland Subdivision will be
constructed~
Intersection improvements to other existing
and proposed subdivision accesses will be considered.
Page 21. Second Paragr5ph .
A band at riparian habitat will be maintained along the
river and creek wherever possible to provide
overhanging cover tor fish and to filter surface
runoff.
Page 21, Seventh Paragraph.
Fishery studies will be conducted for individual
projects which have the potential to ~ct tisheries.
Prior to construction, available UDWR fish@ries studies
will be assessed and it necessary updated to provide
baseline data to dete~ine project impacts to
fisheries. Post construction fishery studies wil1 be
conducted. It study results show additional mitigation
measures are warranted as a result of project
activities, mitigation directed at wild fish stocks
will be carried out under the direction ot USFS & UDWR
biologists as explained in the PBIS on pg 5-6.
�To : Ke ller, lauren
18-S-94 4:46p.
OCT-05- 1994
15:35
FRD'1
ENitt-EERlt-I:i SERVICES
TO
910017536139
p. 3 of 1
P. 03
US-89 LOGAN CANYON RDD REVISION. CHANGES AS PBR 10-3 - 94 MTG
Page 12, 2nd Paragraph
Replace 5th sentence.
This team will participate in the development ot all aspects of
design and 1n the resolution of unforeseen problems that ariss
during construction and post construction.
MOr. inoluded ' on page 26 ( ••• below) .
page 24, Batch plant Locations
*
The traffic, safety. recreatioD, and air quality tmpactB
associated with hauling material from the city versus
setting up a batch plant in the canyon will be identified on
a project by project basis in design. The affect o~ these
t.pacta on both the canyon environment and the city
environment will be considered. Th. a •••• ~t will inclu~.
u.p.ats OD the LoWer Canyon lUlc:l compat1bility with future
proj.ct.. The .c.t suitabl. location will be i~entifled in
the project -.peoifioatioaB and the contractor wd11 be
required to conduct hi. batch plant operations in accordance
with the•• ~.QlflQatiOD ••
Page 26, 1st paragraph
MOnitoring and enforcement of the above proposed measur~s to
minimize har.m will be accomplishe~ in accordance with the
Memorandum of understandi.ng (MaU) between ut>OT, PHWA, an(l VSFS.
The MOU is included in the Appendix of this ROD.
It identifies
how the individual projects wll1 be selected, identified and
managed, and how coordination wi1l be accomplished. The MOU
takes each project through design, construction, and postconetruction periods.
It commits to the deve10pment of a
revegetation plan, wetland mitigation plan, and a
construction/post-construction monitoring plan, and commits to
the development of a Cooperating Advisory Team (CAT) which
consists o~ var~ous agencies and indiv1duals. This team w111
provide recommendations of regulatory and permit requirements,
input on enhancement opportunities, mitigative treatments and
overal l content of the design of the project, ~th tinal
decisions being UDOT's responsibility. Th. CAT t.am. will be
invo1ved. throughout the development of: all aspeets o~ de.iSPl,
inc1uding' review o~ .lignment options and other d_lgn featur.s.
During construction aDd po.t construction, the CAT team will be
Coordinated with ~o r.so1v. unEoreseeD eDviroamantal problem. to
ensure that ~t1gative e~~ort8 are succe.s~u1.
�
Text
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Image Height
3323
Image Width
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2602
Local URL
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<a href="http://digital.lib.usu.edu/cdm/ref/collection/highway89/id/294">http://digital.lib.usu.edu/cdm/ref/collection/highway89/id/294</a>
Purchasing Information
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To order photocopies, scans, or prints of this item for fair use purposes, please see Utah State University's Reproduction Order Form at: <a href="https://library.usu.edu/specol/using/copies.php">https://library.usu.edu/specol/using/copies.php</a>
Digital Publisher
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Digitized by: Utah State University, Merrill-Cazier Library
Date Digital
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2013
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Grayscale
Checksum
2543550165
Dublin Core
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Title
A name given to the resource
LCC correspondence
Description
An account of the resource
Multiple correspondences from members of the Logan Canyon Coalition including a notice of appeal and statement of reasons, and discussion of the modifications proposed for Logan Canyon.
Contributor
An entity responsible for making contributions to the resource
Morton, Pete
Kobe, Kevin
Wilcox, Sterling
Hessel, David L.
Lyon, Tom
Thompson, Douglas E.
Bosworth, Dale
Steinhoff, Gordon
Karp, Peter W.
Richards, Lorraine
Subject
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Logan Canyon (Utah)
Environmental policy
Department of Transportation--Utah
Medium
The material or physical carrier of the resource.
Correspondence
Date
A point or period of time associated with an event in the lifecycle of the resource
1994
1995
1996
Spatial Coverage
Spatial characteristics of the resource.
Logan Canyon (Utah)
Cache County (Utah)
Rich County (Utah)
Utah
United States
Temporal Coverage
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1990-1999
20th century
Language
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eng
Source
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Utah State University, Merrill-Cazier Library, Special Collections and Archives, Citizens for the Protection of Logan Canyon/Logan Canyon Coalition Papers, 1963-1999, COLL MSS 314 Box 1 Folder 7
Is Referenced By
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View the inventory for this collection at: <a href="http://uda-db.orbiscascade.org/findaid/ark:/80444/xv63458">http://uda-db.orbiscascade.org/findaid/ark:/80444/xv63458</a>
Rights
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Reproduction for publication, exhibition, web display or commercial use is only permissible with the consent of the USU Special Collections and Archives, phone (435) 797-2663.
Is Part Of
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Highway 89 Digital Collections
Type
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Text
Format
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image/jpeg
Identifier
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MSS314Bx1Fd7
Highway 89;