UDOT BCC Environmental Study Comment

Public comments are due 12/13 for the UDOT Environmental Study focused on Big Cottonwood Canyon to address wintertime congestion.

Specifically, the study will address:
• Enhanced busses running every 5-10 minutes during peak hours • Mobility hub infrastructure at the mouth of BCC
• Tolling below resort entrances with variable pricing

As always, please keep your comments constructive and respectful while emphasizing the importance of common-sense transportation solutions, limiting our impact on the canyon, and preserving backcountry access.

WBA is pleased to participate in the Stakeholder Working Group for this study. While stakeholders are not decision-makers, we are glad UDOT invited WBA to represent the interests of the backcountry community.

Your participation will help show UDOT that we have a robust local backcountry community whose voice should be considered when discussing changes to BCC.

WBA’s official comment to UDOT

Dear UDOT Big Cottonwood Canyon Environmental Study Team,

The Wasatch Backcountry Alliance (WBA) appreciates the opportunity to provide feedback on the Big Cottonwood Canyon Environmental Study (BCCES) Scoping Phase, during which the study’s preliminary purpose and need, proposed tolling, and transit concept will be finalized.

We recognize UDOT’s commitment, as directed by Senate Bill 2 (2023), to manage winter traffic congestion through tolling and enhanced bus services, and we understand the tight timeline with a decision expected next winter.

The Wasatch Backcountry Alliance is an 11-year-old nonprofit that protects undeveloped terrain and access for human-powered winter recreation and serves as the recognized voice for the backcountry community in the Central Wasatch Mountains. We have a community of 42,522 participants between our paid membership, email subscribers, and social media audience combined. Our Trail Counting Program has documented significant increases in backcountry use in Big Cottonwood Canyon, particularly post-COVID, underscoring the need to consider dispersed recreation in transportation planning.

Big Cottonwood Canyon is home to superb backcountry touring for all skill levels. BCC has over one hundred named backcountry zones and ski runs (Appendix A) and access points (Appendix B). Furthermore, Big Cottonwood Canyon has extensive low-angle terrain, especially in upper BCC, which is critical for staying safe while avalanche hazard is high (Appendix C). A more detailed and comprehensive tool for visualizing terrain risk than simply relying on slope angle is the Avalanche Terrain Exposure Scale (ATES). This scale considers multiple factors beyond steepness, including slope shape, vegetation cover, the presence of terrain traps, and the size

and frequency of avalanche paths. Big Cottonwood Canyon predominantly features terrain classified as “simple” under ATES (Appendix D). This means much of the terrain in the canyon consists of gentle slopes, limited avalanche exposure, and features that generally mitigate risk, such as well-forested areas or terrain without significant overhead hazards. It is crucial to ensure dispersed access to backcountry terrain in Big Cottonwood Canyon, as it offers numerous opportunities for safer backcountry touring, in contrast to Little Cottonwood Canyon, which has far less safe-terrain travel options for dispersed users.

The Wasatch Backcountry Alliance emphasizes the need to address canyon capacity and transportation in Big Cottonwood Canyon through a balanced approach prioritizing both resort visitors and dispersed recreation users. We support enhanced bus services with more buses, consistent and quick schedules, and defined storm-triggered service enhancements, and stops at backcountry trailheads. Trailheads should also have functional restrooms, bigger lots to accommodate bus stops, and improved parking lot maintenance. Tolling has proven to be an effective tool for cutting down on private vehicles and funding associated enhancements, but at a reasonable fee to provide for equitable access. The proposed mobility hub is an essential aspect of the system that we support. We encourage UDOT to continue to support third-party providers like the WBA Backcountry Shuttle and other potential contractors in addition to UTA.

Below are further details.

Canyon Capacity

The Uinta Wasatch Cache National Forest Plan of 2003 – while dated at this point – clearly states several key points:

●  To maintain watershed protection parking capacities of all canyon areas should remain limited to existing levels

●  Unless modification is needed to facilitate mass transit, which should be incorporated, particularly in the winter.

●  The FS will work with other agencies to explore options for reducing private vehicle use.

●  Therefore, establishing a baseline of existing use (vehicle counts, resort patrons, visitation by trailhead, and commercial/residential travel levels) at even a baseline level will provide metrics to determine the immediate and long term growth/decline in vehicle crowding.

●  This should be done in the other three seasons also.

Enhanced Busing:

● The Wasatch Backcountry Alliance is a strong supporter of the enhanced bus service proposed in the project.

●  We strongly support the concept of a conveniently-accessed mobility hub near the base of the canyon.

●  We would like to see it well-connected with valley transit (eg: Olympus Cove, U of U, Holladay, Sugarhouse, Millcreek, downtown SLC), via collaboration between UTA and UDOT.

●  We appreciate the goal of 5-10 minute buses

●  We encourage the time periods to expand to accommodate the many residents, dispersed users, and canyon workers who are not on the resort-opening hours.

●  6am-6pm would be acceptable.

●  Earlier and later would be better; fewer cars early in the morning would enable more effective plowing.

●  We propose some buses be Solitude and/or Brighton Express buses and some buses or shuttles be “backcountry” buses – that would also visit Solitude and Brighton – to address both backcountry and resort skiers’ needs.

●  We support – and appreciate – the resorts’ continued subsidizing of the bus system via customers’ and workers’ passes.

●  We support snow/ski-worthy buses (tires, racks, space).

Bus stop infrastructure:

●  New bus waiting areas at Solitude and Brighton resorts should be confined to existing developed areas, such as resort parking lots, to avoid impacting undeveloped land or removal of current non-resort roadside parking.

●  A 5,000 to 7,000-square-foot building would displace 17 to 23 parking spaces in a typical parking lot, depending on its exact footprint and the layout of the lot. This is a negligible decrease in total available parking at Solitude and Brighton Resorts and we support this.

●  Amenities such as affordable day lockers, heated public restrooms, heated waiting areas, and educational kiosks could be beneficial for encouraging use by resort patrons.

●  If there are revenue-generating services at the resort bus stops, we recommend that funds be used to improve the visitor experience and environmental footprint throughout the canyon, not just at the ski resorts.

●  Improvements at bus stops in Cardiff, Spruces, and Silver Fork should not reduce existing dispersed user parking, including roadside and striped spaces.

●  If there are plans to remove existing parking, we need to know how many parking spots would be lost, both roadside parking capacity and striped parking spots.

●  The loss of just a few trailhead parking spots is much more significant than a few spots at a resort.

●  In addition to the bathrooms at the Spruces and Reynolds Flat trailheads, working bathrooms should be considered at Butler, Mill B, and Mineral Fork.

●  These three lots should be considered for bus appropriate infrastructure.

Tolling:

●  We cautiously support the concept of canyon tolling

●  We support toll fees going towards the bus use to keep bus fees low/affordable

●  We support toll fees going towards plowing of backcountry trailheads and the construction/maintenance of their bathrooms.

●  We support moderate toll fees to make public access to public lands affordable.

●  We recommend considering a FastPass tolling system, as these systems are designed to streamline the process of paying a toll while allowing vehicles to drive through toll stations at normal or reduced speeds, eliminating the need for stops and reducing congestion.

●  We support the concept of tolling high in the canyon to address the 90% of cars going to/near the top of the canyon, but also support tolling for all canyon travel.

Nepa:

●  We urge UDOT to conduct at least an Environmental Assessment (EA) and perhaps even an Environmental Impact Statement (EIS) for this project to allow for thorough public input and environmental review.

●  This project will not satisfy a Categorical Exclusion nor a Finding Of No Significant Impact (FONSI). To Satisfy a FONSI, the agency must show that the project does not satisfy one or more elements of NEPA 102-© for the following reasons:

○  major impact: yes, Big Cottonwood Canyon sees approximately 1.45 million recreational visits annually, primarily during the winter months.

○  federal jurisdiction: yes, some of the proposed changes would take place on Forest Service-managed lands.

○  resulting action: yes, the outcome of this project will result in construction and policy changes.

○  human environment: this project will changes people’s lives and their environment.

●  It is critical that the public have the public to see the ongoing plans and have the opportunity to comment as per the rules associated with an EA or EIS.

Traction Law:

●  Traction Law improvement should be included in the study.

●  The traction law should be implemented when storms are forecasted (ie afternoon fronts) as well as when storms are happening (ie morning storms).

●  The accuracy and timing of forecasts have improved dramatically over the last decade and UDOT should at least use their own weather people/alert systems or even work with the SLC office of the NWS.

●  Snow-related road incidents are more common on slippery descents, where tire quality is paramount for braking.

●  Ignoring forecasts of imminent afternoon storm fronts will result in the same – or bigger – traffic issues.

●  Some sort of digital/FastPass system (“reading” the windshield stickers) would be preferable to manual inspections that create the same traffic issues that are trying to be avoided.

Seasonality:

●  We understand that this project focuses on winter use and WBA is a winter-centric organization

●  The same trajectory associated with increased growth in the valley creating untenable traffic issues will intensify year-round.

●  Therefore, adaptability of the systems to the other four seasons is strongly encouraged. We believe these measures will support a balanced approach that benefits both resort and dispersed recreation while addressing congestion. Thank you for considering our input, and we encourage UDOT to seek continued engagement as this process unfolds.

Cover photo from https://udotinput.utah.gov/bccstudy