Northern Utah Airspace Initiative Environmental Impact Statement Scoping Comments

The Town of Alta, located in Salt Lake County, Utah, is situated at the top of Little Cottonwood Canyon in the Wasatch Mountains. The Town is comprised of approximately 400 residents, a world-class ski resort, and U.S. Forest Service land. It is bounded on the north and south by designated Wilderness Areas, on the east by Brighton Ski Area, and on the west by the Snowbird Ski Resort. During the winter and spring ski season, the Town of Alta has approximately 3,800 visitors per day at the ski area. During the summer, up to 1,000 people visit the Town each day to enjoy the beauty of the wildflowers and the serenity of the area.

The Town of Alta understands that the Federal Aviation Administration (FAA) has proposed an airspace redesign for Salt Lake City International Airport, known as the Northern Utah Airspace Initiative (NUAI). The Town of Alta further understands that the NUAI consists of implementation of a “four-corner post” model for the airspace redesign, and that this model includes routing arriving traffic from the southeast over portions of the Wasatch Mountains that would include the Town of Alta, National Forest, Wilderness Areas, and ski areas. In addition, it is our understanding that the “four-corner post” model also includes an east downwind flight path that would place air traffic over many of the more populated communities along the eastern side of the Salt Lake Valley.

The FAA is conducting an Environmental Impact Statement (EIS) for the NUAI pursuant to the National Environmental Policy Act and other applicable statutes and regulations. The public scoping period to provide comments and guidelines to FAA with respect to issues the public wants examined during the EIS investigation ends May 16, 2003.

Representatives from the Town of Alta learned about the NUAI proposal in July 2002 at an FAA-sponsored “informational meeting”. Since that time, the Town has repeatedly asked questions regarding specific elements of the proposal, including flight frequency, flight elevations, and noise exposure levels over the Town, Alta and Snowbird Ski Areas, and nearby designated Wilderness Areas should the NUAI be implemented. FAA representatives informed the Town of Alta that many details of the NUAI are not available because those parts of the proposal have not yet been determined. Therefore, it appears that the information presented to date by the FAA is lacking in sufficient detail for the Town of Alta, or any concerned government entity, organization, and individual to provide the FAA with scoping comments on specific elements of the plan.

The public scoping meetings that were held in three areas in the Salt Lake Valley on three consecutive days in March did not provide sufficient details of the NUAI, nor did they provide adequate opportunities for the general public to learn about this proposal. Media coverage of the NUAI has, thankfully, brought the proposal to light to many people who were unaware of the general scope of the proposal, but has also appeared to confuse some of the aspects of the proposal, detracting from many important elements of the NAUI, as well as from the Environmental Process itself. The Town of Alta believes that with a change to airspace usage will come significant changes to quality of life for all communities that are in the current and proposed airspace regions.

Because of the lack of specific details of the NUAI, the lack of sufficient public notice for the scoping process, the lack of sufficient and accurate education of the general public regarding the NUAI, and the significant changes a new airspace design will have within the entire region, the Town administration and Town Council members feel that the deadline for public comments for this scoping period is premature and should be extended at least 60 days from May 16. The FAA should, in the first 30 days of that extension, provide more specific detail of the NUAI and its components.

The Town of Alta does not feel properly equipped at this time to provide input to the EIS regarding specific elements of the NUAI since FAA stated that specific components of the NUAI have not yet been designed. However, given the May 16 th public comment deadline, we have, to the best of our ability, compiled general concerns and comments that we respectfully request be thoroughly addressed in the EIS.

1. Given the general information provided by FAA that jets crossing the Wasatch must begin descending at Deer Valley Reservoir at about 23,000 feet above mean sea level (ASL) to an elevation of approximately 12,000 or 13,000 feet ASL over the Salt Lake Valley, it is assumed that jets will be in a descending pattern anywhere from 2,000 to 6,000 feet above ground surface in much of the Wasatch. Jets flying at these relatively low altitudes over the mountains will cause noise and visual impacts in the Town of Alta, ski areas, National Forest, and Wilderness Areas on a regular basis. These areas provide quickly accessible wilderness and recreation opportunities to many who live and work in Utah, as well as to visitors from around the world. This access is important to the health and welfare of the people who use it, as well as to the Utah economy, which is fueled partly by visitors to Utah’s natural areas and ski resorts. Air traffic noise and visual impacts in these areas will have a profound effect on the wilderness and recreational experience in the Wasatch Mountains. In addition, the purposeful implementation of a flight path over designated wilderness areas in the Wasatch will set a precedence that may put designated wilderness areas around the country in jeopardy of being subject to air traffic noise and visual pollution.

2. Under the four-corner post concept’s east downwind route, air traffic will be present above the most densely populated residential area in the State.

3. Commercial jet flyovers may have a significant negative impact to avalanche control and safety at the Town, ski resorts, State Route 210, and within the National Forest. One method of avalanche control includes using military artillery to bring avalanches down. According to a Utah Department of Transportation (DOT) representative, the trajectory of live ammunition used for highway avalanche control could come close to the elevation that the planes are expected to be traveling. The use of artillery is based on rapidly evolving snow/avalanche conditions, and at times, a decision will be made to implement artillery avalanche control within an hour of employing the artillery devices. The presence of commercial aircraft in the vicinity of artillery use for avalanche control would be a conflict, and may have a tremendous effect on public safety. In addition, the possibility exists, that under certain snow pack conditions, low flying commercial aircraft may initiate avalanche release.

4. Search and rescue teams are regularly deployed within the Town and surrounding areas. Helicopters are used as part of the search and rescue operations, as well as for transporting injured people from the mountainous areas to hospitals and emergency vehicles. The Town is concerned that there will be conflict between jet flyovers and the use of these life-saving helicopters.

Based on the above-stated concerns, the Town of Alta administration and Town Council members request that the EIS include:

* Evaluation and reporting of noise exposure levels and exposure frequencies inclusive of all areas under the proposed flight paths;

* Evaluation and reporting of public safety issues in avalanche-prone areas, potential conflict with mountain search and rescue operations, and the potential risk of increasing air traffic over the most densely populated area of the State;

* Evaluation and reporting of socio-economic impacts for the Salt Lake Valley and mountain communities;

* Evaluation and reporting of visual impacts inclusive of all areas under the proposed flight paths;

* Evaluation and reporting of impact to endangered and protected species, and species of concern; and

* Evaluation and reporting of other airspace models in addition to the four-corner post concept.

In addition, the Town of Alta respectfully requests that FAA address any and all comments submitted by citizenry of the Town of Alta, all other individuals, government agencies, and other interested parties during this scoping period.

Please contact my staff and me at the Alta Town office if you have any questions or comments regarding this letter.

Very truly,

Signed by Mayor Levitt

Mayor William H. Levitt
Town of Alta, Utah

cc:
Congressman Jim Matheson
Senator Orrin Hatch
Senator Bob Bennett
Mayor Nancy Workman, Salt Lake County
District Ranger Loren Kroenke, U.S. Forest Service, Wasatch-Cache National Forest
Liam Fitzgerald, Avalanche Program Director, U.D.O.T.
Alta Town Council Members
Alta Planning Commission Members