CENTRAL WASATCH COMMISSION MOUNTAIN TRANSPORTATION SYSTEM COMMENT – October 2020
For years now, the Wasatch Backcountry Alliance (WBA) has been stating that we envision a low cost, low emission, energy efficient year-round multi-modal transportation scenario for improving the current traffic issues in the Central Wasatch. The system we envision must be capable of providing efficient and predictable service from numerous locations around the Salt Lake Valley, Park City and the Wasatch Back to both developed locations (ski resorts) and to trailheads and other stopping points for dispersed use and canyon residents in the Central Wasatch.
WBA firmly believes that before any transportation system is selected, there must be a thorough analysis of the purpose and need of the transportation system, and the carrying capacity of the Cottonwood Canyons and Mill Creek. This will help establish the volume of people that need to be moved by the system, which will in turn help determine which transportation system best fits that purpose and need. WBA strongly encourages the CWC to work with other stakeholders, including UDOT, the US Forest Service, and Salt Lake County to undertake a purpose and need assessment as well as a carrying capacity analysis that would be used as a baseline by the various stakeholders for decision making.
While we applaud the fact that the CWC is looking at transportation issues for the entire Wasatch Front and Back, in our opinion the CWC MTS, which has seemingly put every conceivable transportation option and alternative back on the table, is going to create a great deal of confusion with regard to Little Cottonwood Canyon. Given UDOT is leading an EIS process for Little Cottonwood Canyon, which the CWC addresses in the MTS, does UDOT have an obligation to listen to the CWC’s recommendation, let alone follow it? Are people going to be more frustrated that their preferred solution (eg. rail) is not even being considered or discussed by UDOT but is being suggested as a potential solution by the CWC? “Planning” for a theoretical solution that the contructing/controlling agency has not/will not consider seems counterproductive at best and a source of confusion and frustration at worst. Therefore, it seems hard to imagine that Alternative 3 in the CWC MTS is viable, and/or we’d like to understand how the CWC plans to address this discrepancy.
WBA agrees that the MTS should get people to “desired destinations any time of the year” and that the system should “minimize negative environmental impacts on the watershed, ridgelines, air quality, visual quality, both in transit construction and when ultimately in use.” However, as we discuss in more detail below, we take issue with the argument that any transportation system must also allow for egress in the Cottonwood Canyons, as that provides an opportune excuse for connecting LCC – BCC – Park City – Wasatch Back by aerial, tunnel, or both for development purposes. While we of course value safety and do not want to put lives at risk, people choosing to drive and/or live in a mountain environment understand that they inherently accept some level of responsibility and accountability realizing that an avalanche or mudslide could occur and that they could be stuck up the canyon for some period of time. Promising egress as an option is really just interconnect in disguise.
Regarding the gondola and train associated with Alternatives 2 and 3. While we recognize that there may be potential benefits of either operation, there are important components of both a gondola and a cog train that we take issue with:
- Volume – the gondola and/or train as proposed by UDOT will only carry about 1/3 of those people heading up LCC. This means that 2/3 will still be on the LCC road, so how does installing either a gondola or train at an extra (over the expanded bus service) cost of ~$240M or $1B, respectively make any sense if it will not help alleviate the traffic issue currently plaguing LCC and the surrounding Sandy and Cottonwood Heights communities?
- Schedule – Backcountry enthusiasts, employees, and contractors travel the canyon at all hours. It is our understanding that the proposed gondola/train options would focus the schedule around resort opening/closing hours. Scheduling gondola availability for only the peak skiing hours transforms it from a transportation solution to a taxpayer-paid ski lift that primarily benefits two private companies that operate largely on public land.
- It is clear that summertime use of the canyons is as high as wintertime, with the White Pine trailhead currently overwhelmed in the summer resulting in dangerous highway-side parking conditions. Both gondola and/or train must be year-round, particularly since many summertime users are not skiers, yet are taxpayers who will be footing much of the bill for these expensive options.
- Some ability for a stop at the White Pine trailhead for either option would have to be enabled. “Whistle stops” for trailheads is only an identified option for the train, not the gondola, and it seems unrealistic that the train would stop anywhere other than White Pine (eg. is it really going to stop at the Gate Buttress or Lisa Falls on the way up, and will it stop for people standing there on the way down?).
- Both Alts 2 and 3 mention “reduce/limit on-road parking?” There are two ways to address this: add transit stops for trailheads, or dramatically expand parking places. Is there effort/dollars/ability to account for this addition?
- Fees – there was no mention of the potential costs to riders. If fees are prohibitive, the system won’t be utilized. There is no mention of the ski resorts supplementing/offsetting the cost of the gondola as they currently do with the bus, though a Tier 3 objective is “a mix of private/public funds;” is this a reference to the resorts paying for part of this option?
- Highway 210 improvements – In the Draft Alternatives 2 and 3 there was no mention of improvements to Hwy 210 in addition to the gondola or train. For service vehicles, delivery trucks, residents, emergency vehicles, and those who don’t use the gondola or train, the threats that the canyon represents will still exist. For example, if the gondola is chosen, will any improvements be made to Hwy 210, ie. snowsheds/extra lane?
- Convenience of travel – the three-step process for getting up the canyon using the gondola/train (drive your car to one of two intermodal hubs, put on your ski gear (plus potentially help your kids with their gear) to get on a bus, get off the bus to get on the gondola/train, and finally get off the gondola/train 35-40 minutes later to ski (knowing in the back of your mind that you will have to reverse this process in a matter of hours) will create awkwardness at best and a strong disincentive to many at worst. Particularly in the morning, skiers are generally intolerant of time-consuming barriers that threaten their ability to indulge in scarce resources, ie. new snow, which is the defining factor of why new transit options are being considered. There needs to be a better way to get people from where they live to the gondola/train terminal, or we are afraid that people won’t use these options.
- We feel that it’s vital to include a regional transit system from across the SL Valley and potentially additional parking at the gondola/train base itself. Utilizing a seamless transit system from urban stops (eg. downtown, U of U, Olympus Cove, Sandy City, etc.) that is closer to “door-to-door” could be more efficient, which would encourage use and alleviate near-canyon traffic issues.
- Parking/traffic – a bottom terminal at the mouth of LCC (or near La Caille as alternately proposed) will potentially create the same traffic and congestion issues that are supposed to be resolved by implementing the gondola/traffic in the first place. When coupled with buses trying to deliver people to the gondola and vehicles traveling up the canyon, could adding the gondola/train actually have a negative impact on travel?
- Timing – there was no discussion of the potential timing of gondola/train implementation beyond a generic goal of the 2050 plan. The problem is acute now and will only intensify over the next few years. We are disturbed with the apparent lack of planning associated with staged improvements (with all of the options). The relative length of design/development/construction time and disruption associated with the gondola/train vs the other options (particularly with Alternative 3’s rail project) is important and should be part of an open and transparent process. We understand the complexity and long timeframe of implementing bold transit solutions, but there is no mention of any iterative solutions to a problem that is acute now, much less in 10 or 20 years; all well shy of the 30 year timeframe.
Alternative 3 reintroduces the LCC train, which has long not been a part of the Mountain Accord/CWC conversation.
- Alternative 3 conveniently did not include a row showing total costs. It appears that a cog railway would total ~$1.5B, or nearly $500 for every Utah citizen. Considering that this is an order of magnitude more expensive than any other option, we are concerned that it is simply “too much” and/or will have exorbitant fees that could discourage use.
- Considering the infrastructure investment, it does not make sense to curtail train (or gondola) use in the summer. The more dispersed-but-heavy over the course of the day traffic and parking issues at trailheads continues to increase each year and must be part of whatever option is selected.
- Of the many objectives, one of the three Tier 1 objectives is “Protection of watershed, wilderness, and visual quality” of the canyons. It is difficult for us to imagine that a train (or a gondola) is not a huge blight on, much less “protect” the mountain environment in both construction and final impact, particularly as compared to the expanded-bus Alternative 1.
There are several “sub-alternatives” listed that all address LCC to BCC to Park City to Wasatch Back connections. It is unclear to the Wasatch Backcountry Alliance what import “sub-alternatives” have in this case, but we are vehemently against these connections. Salt Lake City has become as world famous for its backcountry skiing as it is for its resort skiing, and canyon-to-canyon connections threaten the already-tenuous nature of the backcountry terrain at the top of the canyons.
With regard to Sub-alternative 1 – Tunnel:
- The first sentence in the sub-alternative 1 description is “This tunnel would help in providing a direct connection between the two canyons and resorts, serving skiers who desire to visit both resorts, as well as making transfers to Snowbird or Solitude.” Again, this is a taxpayer-subsidized ski lift, not a transit option.
- “Additionally, a year-round Cottonwood Canyons circulator bus service could be implemented and would be of benefit to all canyon users.” The “benefit” of a circular bus service vs two canyon bus services that go up and down each is unclear to us.
- “This service would supplement the previous year-round local bus route serving each canyon.” There is currently no year-round local bus route; if there was – with stops at trailheads – it would not only be utilized, it could provide a multi-year baseline to determine if additional connections were necessary.
- A cost of an additional $1.5-$2.3B tunnel – $500-700 for every Utahn – is simply outrageous, especially on top of the cost of the other far-more necessary transit improvements.
All three sub-alternatives reference an emergency egress option as their primary benefit. We are concerned that an egress system may not actually function in a crisis. Some of the same conditions that would force road closures (high wind, heavy snow, snow, ice) would create dangerous avalanche conditions or power outages, or a devastating high canyon fire could/would affect both canyons and their respective transit operations. For example, would an aerial lift actually be running from LCC to BCC during a fire or after an earthquake that closes Hwy 210?
Additionally, canyon-to-canyon connections only shift the traffic burden. BCC is already experiencing its own major traffic issues, and in an emergency there is no doubt that it cannot handle the egress of both LCC and BCC visitors and residents. How does CWC propose that UDOT/UTA would move 5000-10,000 people coming from upper LCC to BCC back to the Salt Lake Valley if Hwy 210 is closed?
Improved egress is only a Tier 2 Objective. Again, we do not feel that a tremendously expensive emergency egress option that may or may not be available for a once-in-a-generation potential emergency is a reasonable validation for implementation. Enabling a Tier 2 Objective to take priority over a Tier 1 Objective of “protection of watershed, wilderness, and water quality” is contradictory, which is acknowledged by admitting a negative impact on those qualities, as well as threatening the quality of the backcountry terrain being affected.
It is our understanding that some of the six ski resorts potentially affected by the upper-canyon connections actually do not enthusiastically support the connections, nor does the traffic-affected town of Park City. Thus additional taxpayer-subsidized ski lifts are not warranted.
It is important to note that with canyon-to-canyon connections via aerials in the upper canyons, the traffic and congestion at the canyon entrances will not diminish or be improved. It will lead to more crowding in the both the resorts and the backcountry, and the traffic patterns will remain the same. The amount of time it would take to get from Park City to BCC to LCC via gondolas and their respective connections would likely be greater than that of driving around from Park City, and most Salt Lake County residents have equal access to the two Cottonwood canyons, so only the relatively small population of BCC hotel guests and residents would be in a reasonable position to take advantage of upper canyon connections. Therefore, it’s possible that canyon to canyon connections would not see much use, despite the hard and soft costs of such systems.
Additionally, as effective “ski lifts” that would likely not run in the shoulder seasons or summertime, addressing canyon to-canyon connections as vehicles for emergency egress for only the 4 months of ski season would at best be cumbersome to utilize to address the potential for non-winter emergencies.
Therefore, upper canyon connections serve no useful purpose aside from being an expensive marketing tool for the six ski resorts and communities that don’t necessarily want it.
Most of this document focuses on what we don’t want. What we do want is easy: MTS Alternative 1 focuses on enhanced bus service that is year-round, enables trailhead stops for dispersed users on enhanced roadways, introduces snowsheds and variable tolling for private vehicles, and enables greater safety for bicyclists, and all of these aspects are applied to Little Cottonwood AND Big Cottonwood Canyon across all three options. This is what WBA would like to see, with no upper canyon connections for the reasons stated above.
Additionally, we appreciate that Mill Creek Canyon is addressed with the need to improve pedestrian and bicyclist safety and implement a much-needed year-round canyon shuttle system and are encouraged that receiving a recent FLAP grant is the first step towards achieving these goals.
We also appreciate the effort to improve transit between the Salt Lake Valley and Park City via the Parley’s Canyon corridor (that should also include a paved bicycle path).
Wasatch Backcountry Alliance has formally been a part of the Mountain Accord and Central Wasatch Commission since the beginning of the former’s process, and its board and members have been engaged in the community for decades prior to that. We understand the acute need and challenges associated with this process, and hope that our comments will be taken into due consideration to best help craft and create a solution that fits the current and future needs of the Salt Lake Valley residents and those people visiting the area who wish to explore and enjoy the beauty and majesty of the Central Wasatch.