Kirk Nichols: The disturbing inadequacies of the Little Cottonwood environmental impact study

(Trent Nelson | The Salt Lake Tribune) Little Cottonwood Canyon on Friday, July 21, 2023.

The Utah Department of Transportation and the Utah Legislature’s indefensible gondola is the tip of the iceberg floating in the inadequate environmental impact study.

When done well, the National Environmental Policy Act (NEPA) is a beautiful process requiring consideration of the human environment when planning federal actions. The Little Cottonwood Canyon environmental impact study, however, fails to meet the standards set forth by NEPA.

This should concern Utahns, as UDOT chose to not host a citizen’s appeal process. Following a Record of Decision (ROD), like the one issued July 12, only failures in the NEPA process can be appealed or litigated, not the outcome — the gondola — directly.

So, let’s take a look at the failures. The following five issues illustrate the disturbing inadequacies of the LCC-EIS that, in my opinion, appear to be in violation of NEPA:

1. Failure to include NEPA-mandated connected and cumulative impacts and actions

We all see the traffic congestion in the Wasatch Mountains as a regional issue, from Park City to Little Cottonwood Canyon. NEPA requires a process for discovering the connected and cumulative, foreseeable-future along with past actions and similarly with environmental impacts. Looked at regionally, each project’s solutions must contribute to the reduction of congestion throughout the whole geographic area.

2. Misleading purpose statement

The UDOT LCC-EIS substituted the actual purpose of the road and parking lot expansion to narrowly be only qualities of the road, “to substantially improve roadway safety, reliability and mobility.” In reality, the purpose of the road expansion is to move more people more efficiently onto the public land. The qualities of improved roadway safety, reliability and mobility have no innate purpose but to deliver more people. A revised purpose statement for the LCC-EIS is required. Because of the inaccurate purpose statement, reasonable, rational and required alternatives, as well as the impacts of a million people, were never studied.

3. Inappropriately narrow consideration of affected environment and study area

The affected environment of the LCC-EIS, described as only the roadway and pavement, falsely ignores the sources of congestion. UDOT and the legislature declined to recognize or take responsibility for even one car that backs-up when approaching any intersection with SR-210. Vehicle congestion backs dangerously for two miles onto the 70 mile-an-hour freeway.

NEPA requires the study of the affected environment, not just the small SR-210 highway segment. The congestion must be solved in the valley where it starts. Reasonable alternatives as required by NEPA would have included regional transportation hubs, free reservations for parking or canyon entry and limited and timed entry into the canyons. Instead, UDOT proposed bigger parking lots right in the congested necks of Little and Big Cottonwood canyons, thereby creating more congestion, not reducing it.

4. Failure to consider immediate latent demand of canyon visitors

The only source of growth in visitor increase in the canyon was the estimated population growth of Utah. A much larger, immediate source of demand was ignored. That is, the pent-up latent demand of visitors who would go to the Wasatch more often if there was less congestion. When I asked, UDOT said they considered it too hard to study. It is not too hard to study, and it will be more immediate and of much greater magnitude than population growth.

Informally, I polled my neighbors who visit the Wasatch Front, particularly in winter. I simply asked, “If you were reasonably sure that you would not get caught in traffic delays in the Wasatch canyons, would you go up more often?” All said, yes, even twice as often.

Therefore, if UDOT reduces the congestion by their 30% target, once the word gets out that there is less congestion in the canyon, the latent demand will immediately flood the canyons.

5. Failure to consider the intent of designated roadless areas

UDOT tells us that the gondola is not a roadway, therefore immune to the Forest Service Roadless Rule. The Roadless concept is that man and their machines are not to continue segmenting the world into smaller, less functional units of land. We already have a roadway up Little Cottonwood Canyon, use it intelligently. The gondola will require roads and will segment roadless-designated areas.

Something other than good transportation planning is behind the gondola.

Outside of these failures and inconsistencies, it’s an astronomical cost. Not a few tens of millions of dollars, or even a few hundreds of millions of dollars, but for a thousand-million dollars — that’s $1 billion.

(Kirk Nichols) In a guest commentary for The Salt Lake Tribune, University of Utah professor Kirk Nichols writes that “Utahns can — and must — help the federal government improve public land management.”

Kirk Nichols’ family has been in Utah as legislators, doctors, nurses, ranchers and in the mining industry for more than 175 years. Kirk was formerly a seasonal Forest Service ecologist and is currently a professor of Outdoor Recreation Studies at the University of Utah.