UDOT’s Little Cottonwood Canyon Proposals Perpetuate Environmental Marginalization in the Wasatch Front
From the SLCA's Justice, Equity, Diversity, and Inclusion (JEDI) Committee
Over the last couple of months, the Salt Lake Climbers Alliance has spotlighted how the Utah Department of Transportation’s (UDOT) Little Cottonwood Canyon transportation proposals threaten climbing. Mere days remain to weigh in. The comment period for the Little Cottonwood Canyon project draft environmental impact statement (EIS) closes this Friday.
Before the comment period closes, we want to highlight concerns affecting sidelined stakeholder groups: lower income individuals—particularly those that hold marginalized racial or ethnic identities—and otherwise disenfranchised residents. UDOT’s draft EIS does not adequately address its proposals’ impacts on these oft-ignored residents, thereby perpetuating environmental marginalization in the Wasatch Front. We invite you to help us advocate for more equitable options.
The problem (in a nutshell) is that UDOT’s proposals impose costs to upper Little Cottonwood Canyon access during the winter in the form of transit fares and vehicle tolling. Such costs disproportionately burden already disadvantaged Wasatch communities, hindering their access to this iconic Wasatch destination. Furthermore, the proposals will negatively impact the types of outdoor recreation most accessible to lower income residents and community members of color. UDOT’s proposals thus offer up an environmental justice “double whammy” and contribute to the existing environmental injustices which marginalized Utahns already suffer.
Environmental Injustice on the Wasatch Front
A robust body of empirical evidence shows how public policy and planning decisions frequently expose marginalized communities to environmental hazards (e.g. pollutants, toxic waste) and simultaneously exclude them from positive environmental amenities (e.g. parks, natural spaces).
The trend is well-documented on the Wasatch Front. For example, research shows that Hispanic, Black, and Pacific Islander households in Salt Lake City are exposed to more toxic air pollution than white households. Likewise, schools with more racial/ethnic minority students have greater exposure to PM2.5 pollution. Salt Lake valley neighborhoods of color and/or lower income have less tree cover than their whiter, wealthier counterparts and feature parks characterized by poorer maintenance and fewer desirable amenities.
Such disparities extend to transportation and public transit. Public transit along the Wasatch Front serves the everyday needs of wealthy residents over those of marginalized communities. And Wasatch area residents of color have fewer transportation options to access outdoor recreation destinations, such as state parks and national forests, when compared to white residents.
The Little Cottonwood Canyon EIS: An Inequitable Project by Design
UDOT’s Little Cottonwood Canyon project is structured such that it will contribute to the Wasatch Front’s legacy of environmental injustices. Following the National Environmental Policy Act (NEPA—the policy under which the UDOT EIS is mandated), agencies are only required to consider the proposals that address a project’s stated “purpose and need.” The Little Cottonwood Canyon project purpose is “to substantially improve roadway safety, reliability, and mobility of S.R. 210” and the needs are further refined to those “related to visits to ski areas, with the greatest traffic volumes on weekends and holidays and during and after snowstorms.” This narrowly-crafted purpose and need effectively ensures that ski area users’ concerns and interests are prioritized ahead of those of other canyon users—precluding good faith efforts towards more equitable outcomes. A more equal (among different types of canyon recreation and users) and equitable (when considering the existing socioeconomic conditions and contexts of Wasatch area communities) project is likely only feasible under a project purpose and need that recognizes and centers the needs of canyon users “diverse” in both recreational and socioeconomic terms.
How UDOT’s Proposals Perpetuate Environmental Injustice
Guided by a narrow purpose and need and clearly crafted without the meaningful participation of marginalized community members, UDOT’s proposals will perpetuate environmental injustice on the Wasatch Front. The agency favors two proposals. Under one, a gondola would drop riders off at one of two destinations (Alta or Snowbird). Under the other, buses would travel to the same destinations on a roadway widened with one or more bus-only lanes. Under either, UDOT intends to deter car travel with private vehicle tolling in the upper canyon. Thus, any of UDOT’s proposals will require visitors to pay to access the upper canyon--no matter how they travel. The cost will likely prohibit upper canyon use among the less-resourced.
To be clear, Salt Lake Climbers Alliance supports enhanced transportation and traffic mitigation strategies—even those that come at an additional cost. We support tolling combined with more buses (without road widening), in particular. But, our support only extends to plans which reflect thorough and nuanced consideration of their environmental justice impacts for those community members who face the greatest difficulties accessing outdoor recreation resources.
To this end, we have three specific environmental justice concerns with UDOT’s proposals:
First, UDOT claims that environmental justice considerations are alleviated in part by the fact that tolling is required only for the upper canyon—assuming that lower-income individuals do not wish to access the upper canyon (and won’t want to in the future). But given that the upper canyon houses the canyon’s most popular backcountry areas, such as the “Emmas” and Grizzly Gulch, this is a flawed assumption. We should collectively facilitate—not impede—disadvantaged residents’ use of the upper canyon’s accessible backcountry terrain for lower-cost winter recreation, such as snowshoeing and sledding, as well as backcountry skiing and snowboarding, and (of course) downhill skiing at the resorts.
Second, although the draft EIS implicitly recognizes the unfair impacts of tolling, it maintains that lower-cost transit options nullify “adverse impact” to marginalized populations. In other words, UDOT’s solution to the barrier of tolling for marginalized residents is “they can take the bus/gondola.” Of course, this ignores the fact that transit fare remains an imposed burden for under-resourced residents and that proposals which limit marginalized residents' de facto transportation options are inherently inequitable. A structurally inequitable transportation solution that narrows the options of disadvantaged residents while increasing the options of the most privileged is a clear-cut case of environmental discrimination.
Third, UDOT’s proposals facilitate transportation to ski areas at the expense of dispersed recreation—and the types of outdoor recreation that are more accessible to marginalized residents, such as bouldering and snowshoeing. In this way, UDOT’s proposals create what environmental justice scholars refer to as a “double whammy” for marginalized residents wishing to recreate in Little Cottonwood Canyon: they impose financial barriers to the upper canyon, while negatively impacting the more accessible recreation options of the lower canyon.
How You Can Support More Equitable Transportation Solutions
We need your help in advocating for more equitable Little Cottonwood Canyon transportation solutions. You can voice your opposition to proposals that further disenfranchise residents by contacting your elected officials. Let them know that while you favor enhanced transportation and traffic mitigation strategies, they should not come at the cost of the recreational opportunities—or choices in how to access them—of marginalized Wasatch Front residents.
Join us in making it clear that any viable transportation solution to Little Cottonwood Canyon’s traffic challenges should offer fair and equitable access to this iconic and valuable environmental resource for all Wasatch Front residents.