This page contains Official Comments on West Davis Corridor freeway (WDC or WDF) made by participating stakeholders such as Federal, State and Local government agencies as well as the citizens’ groups, environmental groups and non-profit organizations that make part of the Shared Solution Coalition. As part of the Environmental Impact Statement Process required under the Federal National Environmental Policy Act (NEPA), the Utah Department of Transportation (UDOT) and the Federal Highway Administration (FHWA), must involve stakeholders and allow for their public comment on the draft freeway plans set forth in the Draft Environmental Impact Statement (DEIS)
Official Comment of the Shared Solution Coalition: Shared Solution DEIS Comments with Exhibits
- “The DEIS inaccurately portrays the need for, and exaggerates the benefits of, the WDF.” […] “The DEIS fails to consider a reasonable range of alternatives as required by NEPA.” Shared Solution Coalition Comment, p. 6.
- “The DEIS does not adequately examine the impacts of the proposed freeway on local and regional air quality.” Shared Solution Coalition Comment, p. 10.
- “The comparison in the DEIS between the build and no-build options is deeply flawed.” Shared Solution Coalition Comment, p. 11.
- “The general message of the DEIS is that construction of the proposed freeway will have little effect on local or Wasatch Front air quality and by implication, health outcomes. As an initial matter, that message is thoroughly contradicted by hundreds of medical studies and the conclusions of virtually all the nation’s public health experts.” Shared Solution Coalition Comment, p. 12.
- “The DEIS fails to adequately consider the impacts of the WDF on ecosystem resources.” Shared Solution Coalition Comment, p. 22.
- “The DEIS fails to adequately consider the impacts of the WDF on water quality.” Shared Solution Coalition Comment, p. 29
- “During past years – even before the WDF DEIS process began – the federal, state, and local city officials having jurisdiction over these three areas have all participated as stakeholders in the DEIS process. Throughout the DEIS process, each of those officials rejected UDOT’s attempts to use their respective Section 4(f) properties [e.g., public parks, recreation areas, wildlife refuges] for a freeway alignment, instead asserting that the properties should be protected under Section 4(f). In spite of this, UDOT ignored these efforts and selected the alignment most damaging to Section 4(f) properties.” Shared Solution Coalition Comment, p. 32.
- “UDOT incorrectly contends that the negative impacts on Section 4(f) properties resulting from the B1 and similar alignments are de minimis [or insignificant].” Shared Solution Coalition Comment, p. 40.
- “Contrary to its stated policy, during the WDF environmental review process FHWA failed to merge the NEPA and Clean Water Act Section 404 permitting processes.” Shared Solution Coalition Comment, p. 42.
- “In summary, truly mitigating for the losses of the proposed freeway is not possible. If the freeway proposal moves forward the residents of Weber and Davis County would be robbed of a major positive aspect of their local environment and Great Salt Lake would lose roughly seven miles of the upper portion of a mostly functioning shoreline to a roadway that would also negatively impact surrounding wetlands, uplands and wildlife/bird habitat.” Shared Solution Coalition Comment, p. 44.
Official Comments of Participating Government Agencies on the WDC freeway DEIS
U.S. Army Corp of Engineers: Army COE Comment on WDC freeway DEIS 09-06-2013
- “Recently, a group of local organizations publicized a conceptual alternative to the WDC Project, called the “Shared Solution.” We encourage the joint-lead agencies to evaluate this alternative to determine if it meets the purpose and need of the project as well as the detailed screening criteria. If the Shared Solution meets these criteria, it should be included in the analysis as another build alternative.” U.S. Army Corp of Engineers Comment, p. 2. “Based on available information, we believe the Locally Preferred Alternative does not represent the least environmentally damaging practicable alternative.” U.S. Army Corp of Engineers Comment, p. 6.
Environmental Protection Agency: EPA Comment on WDC Freeway Draft EIS 20130131
- “All action alternatives include substantial and permanent, indirect and cumulative impacts to GSL [Great Salt Lake] wetlands and associated habitats. The GSL ecosystem consists of an irreplaceable mosaic of wetland and terrestrial habitats that together provide nesting, breeding and feeding areas for migratory birds and other wildlife dependent on aquatic habitat areas.” EPA Comment, p. 1. “The presence of a highway in and along the edge of GSL’s ecosystem will permanently degrade their significant ecological functions across hundreds of acres of shoreline habitat thereby reducing the habitat capacity of the GSL ecosystem.” EPA Comment, p. 6.
U.S. Department of the Interior, U.S. Fish & Wildlife Service: USDOI-USFWS Comments 08-13-2013
- “We note that a local coalition has proposed another alternative which has been termed the ‘Shared Solution.’ We encourage UDOT to fully vet this alternative as it did with all 23 preliminary alternatives, and to provide its agency resources to further develop and assess its details. Should this Shared Solution alternative be viable and meet the project purpose and need, it would broaden the range of alternatives and could provide an alternative with fewer impacts to wetland and wildlife resources. We support further development of this alternative.” U.S. Dept. of the Interior Comment, pp. 2-3.
- “The GSL ecosystem is an irreplaceable and immitigable resource due to its location within an arid region, large size, diversity of habitats for migratory birds, and the sheer number of birds, estimated at 7.5 million per year (UDNR 2013).” U.S. Dept. of the Interior Comment, p. 1. “We do not believe that Alternative B1 is the Least Environmentally Damaging Alternative under Section 404 of the Clean Water Act. We therefore recommend UDOT reconsider the selection of the Glovers Lane option and encourage UDOT and the FHWA to select the Shepherd Lane option.” U.S. Dept. of the Interior Comment, pp. 4-5.
- “We conclude that the construction of the WDC, a new 4-lane freeway adjacent to the GSL shore lands would have significant, irreparable impacts to the wildlife populations that rely on those habitats, would substantially degrade the value of that habitat, and would permanently alter the composition of the wildlife community in the area. These impacts would extend large distances from the road, over a kilometer for many species, with substantial effects to the GSL shore land wildlife communities.” U.S. Dept. of the Interior Comment, pp. 6-7.
- “The DEIS does not properly evaluate the combined effects of the indirect effect factors.” […]
- “Ultimately the DEIS discounts any overall negative impact on wildlife communities by addressing each factor only individually, describing its effects, how they would be mitigated, and concluding its impacts are insignificant.” U.S. Dept. of the Interior Comment, p. 7.
- “We continue to encourage UDOT to understand the irreplaceable value of the GSL ecosystem and to ensure that all impacts to this unique resource will be fully mitigated.” U.S. Dept. of the Interior Comment, p. 7
- “While a variety of mitigation measures are included in the 4(f) evaluation, there is no documentation that the “officials with jurisdiction” concur in them or the proposed de minimis findings.” […] “Accordingly, we cannot at this time concur that all measures to minimize harm to wildlife/waterfowl resources have been incorporated into the project. We would be willing to reconsider this position at such time as the officials’ concurrences in both proposed mitigation and de minimis findings have been obtained.” U.S. Dept. of the Interior Comment, pp. 12-13.
Farmington City: Farmington West Davis EIS Eval
- “Based on the information in the DEIS, it is currently unclear whether this Project is needed for the Region at all in 2040 and it is clearly not needed at that time in Farmington City.” Comment of Farmington City, p. 1.
- “There are significant problems with the 4(f) Evaluation (“4(f)”). The fundamental problem is that the Farmington City Conservation Easements qualify as properties that must be protected under Section 4(f) and they are not included in that analysis.” [….] “This is a serious legal flaw and makes no sense.” Comment of Farmington City, p. 2.
- “The problems with this DEIS are significant and far reaching enough that a new or revised DEIS must be undertaken before a final EIS may be undertaken.” […] “Further effort must be invested in the Alternatives Analysis to include the roads located in the entire corrected Study Area, perhaps allowing an alternative that doesn’t require the WDC.” Comment of Farmington City, p. 3.