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UPDATE: Agencies pile on criticism against corridor plan
Sep 25, 2013 | 53491 views | 2 2 comments | 36 36 recommendations | email to a friend | print
download Army Corps of Engineers letter to UDOT about West Davis Corridor
download EPA letter to UDOT about the West Davis Corridor


Davis Clipper Editor

FARMINGTON — Just as the public comment period for the West Davis Corridor draft plan ended, the Army Corps of Engineers sent a letter critical of the proposal to the Utah Department of Transportation.

It came on the heels of a letter from the Environmental Protection Agency to UDOT about the highway that said many of the proposed routes seem to violate the Clean Water Act and that UDOT statements about impacts to air quality are unfounded.

The letters were disseminated on Friday by members of the Shared Solution Coalition, which opposes the freeway and wants UDOT to instead consider a plan that relies on surface streets and mass transportation.

“The ubiquitous and glaring flaws in the (draft plan) should cause UDOT to go back to the drawing board,” said Shared Solution Spokesman Steve Erickson in a press release from the group. “It’s clear this project is nowhere near shovel ready. UDOT should withdraw their draft” and prepare a new plan that fully considers the Shared Solution.

UDOT’s draft plan, officially known as a draft environmental impact statement, identified as the “locally preferred alternative” a route that would start the four-lane divided highway near Glovers Lane, send it northwest along Bluff Road and end it near 4100 West in Syracuse.

Both agencies encourage UDOT to go with a route near Shepard Lane in Kaysville instead. They join a growing chorus of opponents, including Farmington City and the Department of the Interior.

Also speaking out was Hooper City, which says the ending of the road would negatively impact a nearby rural street.

The Utah Reclamation Mitigation and Conservation Commission, which is the federal agency with jurisdiction over the wildlife area, also commented. It has overseen The Nature Conservancy and Great Salt Lake Shorelands Preserve since 1992.

“After millions of dollars of private and public investment, the value of the preserve has increased greatly as more and more shoreland habitat around the Great Salt Lake has undergone conversion to other uses,” reads the comment letter, before saying that complete avoidance of federal lands would be justified and defensible.

The Utah Transit Authority also weighed in. The proposed alignment would prevent the agency from building a second track for Frontrunner, its comments said. It added that the corridor would be useful for bus service between northwestern communities in the county and Frontrunner. 

The Davis Chamber of Commerce, the Davis County Commission and Kaysville City, in contrast, have come out in support of UDOT’s plan.

Army Corps of Engineers letter

The Sept 6. letter from the Corps of Engineers is noteworthy because UDOT needs approval from that agency before it can build. The letter praises the department for acknowledging the wetlands’ existence and acknowledging that, due to development over the last hundred years, few undisturbed habitats remain.

Rather than using that information to justify a focus on avoiding impacts to developed land, however, UDOT should be committed to avoiding or minimizing impacts to the parts of the ecosystem that remain, the letter reads.

The missive was penned by Jason Gipson, chief of the Nevada-Utah branch of the Corps of Engineers.

UDOT could do a better job protecting the Great Salt Lake ecosystem and surrounding wetlands than its draft plan proposes, according to the letter.

Among the proposals UDOT should consider is the “Shared Solution” alternative created by concerned community members, according to the Corps of Engineers. The Shared Solution was not considered prior to UDOT’s announcement of its draft plan.

The Corps of Engineers letter also encourages UDOT to apply the same wetland impact standards it used on its preferred alternative to all the alternatives, and that it should have done a better job of mapping springs before choosing an option rather than studying only those springs that would be affected if the highway were built as planned.

The criticism gains momentum, however, in regard to the noise impacts a freeway would bring on wildlife. UDOT relied heavily on a report created when the Legacy Highway was being built to asses these impacts, but several wildlife resource agencies “have serious concerns regarding the validity of the Legacy Report as well as the manner it is used in the (draft plan) to draw conclusions regarding the (corridor) project,” the letter reads. The Corps is also concerned that UDOT has used information from that report to refute peer-reviewed studies published in scientific journals even though the UDOT study was neither published nor reviewed by outside scientists, Gipson wrote.

Rather than build near Glover Lane, the Corps suggests that UDOT consider the Shepard Lane alternative. Although there are wetlands in both places, the wetlands near Glovers Lane have “substantially higher functions” for water quality and wildlife and they support the Farmington Bay Wildlife Management Area, according to Gipson. The Shepard Lane plan also goes through land that has already been developed rather than shoreline land, the letter asserts.

The letter also discusses the impact on farmland in Layton and impacts on the Weber River of the various alternatives.

UDOT is required by federal law to choose the alternative that has the least negative impact on the aquatic ecosystem, according to the letter.

“There are alternatives presented that would have less impact, both direct and indirect, on waters adjacent to the (Great Salt Lake),” the letter reads. “Based on the available information, we believe the locally preferred alternative does not represent the least environmentally damaging practicable alternative.”

Environmental Protection Agency letter

The Sept. 5 EPA letter didn’t directly ask UDOT to consider the Shared Solution, but said, “Where there are not practicable alternatives to avoid wetlands, we recommend consideration of additional opportunities to minimize adverse impacts through alignment modification and project design features.”

The Glovers Lane route preferred by UDOT would impact high-quality wetlands, the Farmington Bay Wildlife Management Area and the Great Salt Lake Shoreline much more dramatically than an alignment starting further north at Shepard Lane would, the EPA letter reads. It goes on to say that the Federal Highway Administration, which has the final say, should choose a Shepard Lane Route.

The EPA also finds fault with the middle section of the proposed highway. UDOT’s plan would put it directly through a large wetland complex near 4100 West, but that building near 4800 West instead would mean preservation of 4.3 acres of wetlands and 52 acres of wildlife habitat and less impact to 25.4 acres of wetlands 162.9 acres of wildlife habitat.

Many alternatives UDOT studied could violate the Clean Water Act, it reads.

The EPA letter is signed by Martin Hestmark, assistant regional administrator of the office of ecosystems protection and remediation.

UDOT has said that it can’t address any specific comments received about the corridor but will address all comments in its final environmental impact statement, which it intends to work on through the end of this year. A decision from the highway administration is expected in Spring of 2014.

Learn more about UDOT's plan at

Comments-icon Post a Comment
September 21, 2013
I am glad to hear that the EPA, DOI, and Army Corps of Engineers are all stepping in and making UDOT reevaluate the proposed plan for the WDC. Anyone who lives in the area where the proposed freeway is suppose to go knows that it is a special and very important area that needs some protection from UDOT and the politicians and land developers who are trying to bulldoze through it. I really hope UDOT and the public really start to rethink the way we handle growth and congestion. There are other ways and better alternatives that need to be considered and I am grateful for the agencies who are stepping up and letting this be known!
September 21, 2013
Thank you Army Corps of Engineers for recommending that UDOT follow the laws it is supposed to!

If, after this, UDOT continues to side step the law, we can make public comment to report UDOT for fraud, waste, or unethical behavior.

However, because the Army Corps of Engineers will block UDOT from building the road if it is not the least environmentally practicable alternative (LEDPA) I don't think we'll need to report UDOT.

Thank you, Clipper, for keeping this story alive when some of the other papers were trying to bury it early on. Now, they can't ignore the story because it has received so much attention and major government agencies are now stepping up.
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