Mayor Weichers sent the following letter via email to the Utah Department of Transportation (UDOT) project leaders managing the Little Cottonwood Canyon final environmental impact statement (EIS) on Oct. 17, 2022:

Dear Project Team Members and Leadership:

On behalf of the Mayor and City Council, please accept this letter as official public comment from the City of Cottonwood Heights ("the city") regarding the recently published Little Cottonwood Canyon Final EIS ('final EIS'). Attached to this letter are full copies of relevant council actions and previous public comments that remain important and continue to be part of the input from Cottonwood Heights. The following summarizes the comments pertaining to this issue.

RECOMMENDATION 

Cottonwood Heights will experience the most direct and sustained impact of any EIS decision. It is important that the city's input be weighed appropriately given the direct and daily impact of any alternative. Cottonwood Heights continues to strongly oppose the construction of a gondola as a solution for traffic in Little Cottonwood Canyon. This solution creates a disproportionate local impact on Cottonwood Heights with no direct benefit. The city continues to strongly support enhanced and prioritized busing as the primary solution for canyon access through phased, flexible implementation as warranted over time. Additionally, roadway safety and accessibility remain a key local priority. Lowering roadway speeds through collaborative redesign and implementing traffic calming measures, while approaching Wasatch Boulevard as a special gateway corridor, can make this attainable.

'FINAL EIS' COMMENTS 

Throughout the EIS process, the city has consistently outlined its comments, concerns, and local priorities for the EIS outcome. It has provided this feedback to UDOT formally numerous times through public comments, resolutions, and city council discussions. City representatives have also met with UDOT frequently throughout the process to express concerns and reiterate local priorities. The following is an additional list of comments outlining the city's response to the final EIS document:

• Design speed and formal speed limit remain critical factors in ensuring that safety and a high quality of life are improved and maintained for all residents along the Wasatch Boulevard corridor. The City Council unanimously passed a 2022 resolution affirming this as a local priority.
  
  
• The city has been and remains strongly opposed to any gondola alternative, as it is clearly incompatible with the adopted Wasatch Boulevard Master Plan. The city is greatly concerned that rather than having scaled back any gondola solution to address this incompatibility, UDOT instead has proposed a drastic increase to the size of the parking structure at the gondola location, with the proposed 2,500-stall parking structure creating an increased direct negative impact to the city and effectively fracturing the Cottonwood Heights' community around the Wasatch Boulevard corridor.
  
  
• The increased gondola parking capacity will likely result in multiple negative conditions, including:
  • At its highest demand, the expanded structure will result in more vehicular traffic on the Wasatch Boulevard corridor during peak days.
  • During non-peak days and/or outside of ski season, the 2,500-stall parking structure will sit largely unused. The substantial addition to parking capacity serves a small number of days per year, while an investment in flexible, scalable bus solutions represents a much more fiscally prudent approach.
  • In many instances, the gondola travel time to resorts is likely to exceed that of personal vehicular travel time. The city finds this to be concerning for the long-term viability and usability of the hub.

• The city requests UDOT prepare a detailed and long-term plan for the proposed phasing implementation. Portions of this plan should be clearly decoupled from the gondola phase. If well-planned and prioritized busing is found to work effectively, then it should be able to stand as a permanent solution in lieu of any gondola construction. Snow shed construction, Wasatch Blvd. commuter traffic improvements, tolling, etc. should all be laid out. The city recommends the following be included as part of this approach:
  • If and when added roadway capacity is warranted, capacity should be designed and added in a way that is not used by regular vehicular traffic, but reserved instead for buses. Buses could use the extra capacity during peak travel times, and extra capacity could be used as a recreational corridor (i.e. enhanced bike lane} during non-peak hours. This concept is similar to the peak-period shoulder lane from the previous enhanced bus alternative.
  • The city recommends that UDOT, in coordination with the city and other directly affected entities, develop a clear timeline for phased bus implementation. This timeline should establish a minimum number of years (15-20 years} to develop and implement a successful bus alternative. If buses adequately address canyon traffic issues, then the gondola implementation would not be necessary. This approach should also develop and establish 'trigger' metrics after the minimum amount of time has elapsed, wherein escalating to the gondola phase may only take place upon consistently meeting certain negative traffic metrics.
  • UDOT should partner with agencies to provide a phased busing plan that is as detailed as that which has been prepared for gondola services. The city recommends that in preparing this plan, UDOT consider creative approaches, including but not limited to the following:
    • Public-private partnerships with ski resorts to incentivize bus ridership by resort patrons
    • Exploration of subsidized fares to reduce costs for bus riders
    • Immediate and fluctuating tolls based on canyon demand to incentivize bus ridership and improve air quality while reducing peak vehicular traffic on Wasatch Boulevard
    • Utilization of existing parking areas as transit stops throughout the Salt Lake Valley to make ridership more appealing for individuals living in nearby communities. For example, portions of existing strip mall parking lots within the Salt Lake valley could be repurposed through public /private negotiations to create cost effective transit/carpools lots that provide direct service to LCC ski resorts on peak period ski days each season. Eventual scaling of usage of these lots to accommodate year-round canyon and other valley transit demand, makes flexible, long term, and cost-effective transit support for Salt Lake valley residents.
    • Local shuttle services providing transportation between said transit stops and Little Cottonwood Canyon.

• The city requests UDOT develop a plan to utilize bus investment throughout the year, beyond seasonal Little Cottonwood Canyon resort demand. This plan should include an analysis of the full impact that an investment in busing could have in the canyons and in the greater region. Such an analysis should be prepared for review by State officials before any allocation of funding for EIS implementation.
• The city finds that the enhanced busing with peak-period shoulder lane alternative provides a solution that is equally (or more) effective, in a way that more closely adheres to the Wasatch Boulevard Master Plan arid better addresses local impacts.
• The city strongly recommends that UDOT immediately implement tolling on single-occupancy vehicles as a primary step in incentivizing transit use.
• The city is concerned with the removal of existing mature pine and spruce trees along the corridor for the purpose of installing sound walls or adding vehicular roadway capacity. The city recommends that UDOT avoid disturbing healthy, mature vegetation to the greatest extent possible. If removal is found to be unavoidable, the city recommends that UDOT utilize a certified arborist to analyze any tree that may require removal. Instead of removal, the city recommends that UDOT relocate any healthy mature trees to a nearby location along the corridor.
• All EIS cost estimates are based on 2019 projections, which are likely outdated given recent inflation and material/labor scarcities. The city recommends that UDOT update cost estimates for all alternatives prior to issuing a record of decision. This updated estimate will provide a more accurate projection for State leadership considering allocation of funding.
• As stated in the September 2021 public comment from the city, a new traffic study should be completed prior to any final record of decision and implementation to ensure findings are accurate and justify the recommendations of the EIS.
  
  

PREVIOUS EIS COMMENTS AND LOCAL PRIORITIES 

The city has been consistently and strongly opposed to any gondola alternative. Instead, the city has always favored a phased-in bus priority approach. Cottonwood Heights bears the most direct impact of the final EIS alternative than any other entity or municipality. The city acknowledges and respects the need to explore options for enhanced canyon access and transit usage. Its priority has always been focused on the local impact of any regional decision. The following have been consistent points of emphasis: 

Enhanced and safe corridor mobility for all users 

• Grade-separated crossings, and enhanced at-grade crossings, coupled with 35mph roadway speeds
• Development of a shared-use path, accessible from adjacent neighborhoods and parking areas, from canyon to canyon

Strong focus on speed reduction and protection of local character and aesthetic through roadway design and speeds

• Lower roadway speeds to 35 miles per hour as occurs throughout Utah on State roads in towns with adjacent commercial and residential components through roadway design and posted speed limit
• Redesign and lower speed mitigate concerns with roadway noise and offset the demand for unsightly sound walls
• Collaborative redesign of Wasatch Boulevard as a special gateway corridor including traffic calming enhancements and other road design components that alert drivers, they are entering a neighborhood area and need to reduce speed.

Appropriate management of traffic congestion and neighborhood access

• Improvement of visibility and safety in and out of neighborhoods adjacent to Wasatch Boulevard, particularly Kings Hill Drive, and Golden Hills Avenue through traffic calming, traffic signals, realigned intersections, improved visibility, and slower roadway speeds

Transit-oriented solutions that alleviate current and future peak-hour congestion from Wasatch Boulevard. Solutions should only be implemented when traffic conditions and data warrant it. 

• Focus on enhanced busing with a major transit hub within a future mixed-use development at the Big Cottonwood Canyon area location alleviates congestion within the corridor
• Tolling and bus-only infrastructure throughout the project area incentivizes transit usage in a way that is flexible and scalable

CONCLUSION 

Based on the input provided in this letter, previous city comments and council actions, recommendations in the city's Wasatch Boulevard Master Plan, and extensive public input from local residents that are most directly affected by the EIS implementation, the city strongly urges UDOT to carefully and thoughtfully consider these comments and provide actionable responses. The city appreciates the opportunity to provide this input and to meet with UDOT project officials regularly. Cottonwood Heights leaders have a strong desire to maintain a productive working partnership to address local impacts in a beneficial way, and to closely collaborate on the local priorities shared above (roadway safety, design, speed reduction, aesthetics, and local access). 

Attached to this letter is a unanimously approved city council resolution regarding roadway design and speed on Wasatch Boulevard (Attachment 1), as well as the city's September 2021 statement from the preferred alternatives phase of the EIS (Attachment 2). The findings and statements in these documents remain demonstrative of the city's ongoing concerns and priorities.  See this PDF for the attachments.

Sincerely,

Michael T. Weichers, Mayor, Cottonwood Heights City