Save Guanella Pass

2/14/01 Sierra Club Final Formal Comments to FHWA

This is the letter sent to the FHWA opposing Alt. #6

Mount Evans Group of the Sierra Club
P.O. Box 2288
Evergreen, Colorado 80437-2288




January 29, 2001

Mr. Richard Cushing, Environmental Planning Engineer
Federal Highway Administration
CFLHD (HPD-16.5)
555 Zang Street, Suite 259
Lakewood, Colorado 80228

Dear Mr. Cushing,

The Mount Evans Group of the Sierra Club (hereafter referred to as the Mount Evans Group, MEG, or Sierra Club) is submitting the following comments on the Guanella Pass Supplemental Draft Environmental Impact Statement (SDEIS). These comments are in addition to the comments we previously submitted on the Draft Environmental Impact Statement (DEIS), and are intended for inclusion in the Final Environmental Impact Statement.

We thank the FHWA for extending the public comment period on this document. We also appreciate the FHWA's decision to develop a new alternative, and all of the participating agencies' efforts to develop Alternative 6.

For the reasons stated below, the Mount Evans Group cannot support Alternative 6. Instead, we respectfully request that the FHWA develop a minimal improvement alternative that places protection of the area's scenic, environmental, historic and cultural resources first, allowing for limited reconstruction only where necessary to address significant erosion or sedimentation problems; and that this alternative be developed with active, meaningful input from the public.


INTRODUCTION

Public comments on the DEIS made it very clear that the people want the rural, rustic character of the Guanella Pass Byway maintained. According to figures presented in Appendix A of the SDEIS, the FHWA received 638 letters of comment on the DEIS. 58.2% of the respondents supported a minimal-improvement, or Sierra Club, Alternative, while 33% supported Alternative 1, the No Build or No Action Alternative. In addition, citizens' petitions requesting only minimal improvements garnered over 3,600 signatures. In other words, over 90% of the people who care enough about the Byway to submit comments want either minimal improvements or none at all. As a result of this
overwhelming public input, the FHWA announced its intention to develop a new, sixth alternative that would reduce the amount and level of work to be done to the Byway.

While it could represent the first step toward a true minimal-improvement alternative, Alternative 6 does not reflect what the people and the Sierra Club requested. After "final design" decisions are made, we could end up with what an overwhelming majority of people have specifically stated they do not want: a 24-mile long ribbon of smooth, widened, hard-surfaced road that connects Interstate 70 & Highway 285.


ALTERNATIVE SIX

Functional classification
We concur with the FHWA's decision to reduce the functional classification of the Byway from rural collector to rural local, which reflects the road's purpose more closely.

Design speed
We recognize the decrease in design speed (to 20-30 mph) as a further positive indication of the FHWA's effort to respond to the public's request for a road that encourages drivers to enjoy the surrounding beauty. This is also in agreement with the Green Book, which states, "Low design speeds are generally applicable to roads with winding alinement in rolling or mountainous terrain or where environmental conditions dictate" (p. 418).

Because design speed influences other design elements, we support the application of the minimum design speed recommended by AASHTO policy in mountainous terrain (19/20 mph) wherever possible. The lower the design speed, the more closely the road's horizontal alignments, grades and switchbacks can remain to existing conditions, which is what the public wants. When applied in correlation with other design elements, a lower design speed can also contribute to fewer and less severe accidents, thus improving safety.

This minimum design speed could be applied in most segments under a minimal improvement alternative, rather than its more limited application under Alternative 6.

In addition, although the SDEIS shows a projected traffic exceeding 400 vpd by 2025 (III-6), our calculations indicate that the ADT for 2025 will be 387 vpd (still below 400), even with the application of a 3% growth rate, which is higher than the growth rate achieved in the Denver metro area in the 1990s. With a 2.7% growth rate, which more closely reflects the area's actual growth rate, the ADT would increase to 380 vpd by 2020.



Design vehicle
The design vehicle in the DEIS for this project is a Single Unit Truck with a wheelbase of 20 feet; i.e., a full-sized delivery truck. For Alternative 6, the design vehicle has been reduced to a Class C Motorhome, defined as a vehicle with a wheelbase (wb) of 17 feet. We believe even this vehicle is too large for the Byway.

According to the FHWA Automatic Traffic Recorder Count Summary, more than 97% of the vehicles using any part of the Byway are less than 20 feet in total length. Just south of the Pass, 99.1% of the vehicles using the road are less than 20 feet long, while just north of the Pass, 99.5% of vehicles are under 20 feet long.

While The 2000 RV Buyers' Guide is not a technical design manual, it does introduce the reader to the three classes of motorhomes (A, B and C) and offers a more than adequate sampling of the type of vehicle that falls under each class. A frequency distribution of the 41 Class C vehicles described in the guide showed that only 10% of the vehicles are under 20 feet long, while 24% are 20 to 24 feet long, 32% are 25 to 29 feet long, 32% are 30 to 34 feet long, and 2% are 40 to 44 feet long. This means approximately 66% of Class C motorhomes are 25 feet or longer. Of the 20 Class B motorhomes described in the guide, 75% of the vehicles are less than 20 feet long and 25% are 20 to 24 feet long. The Class B motorhome, which has an average wheelbase of 10 to 12 feet, more clearly reflects the type of vehicle using the road now. (Please see "Class B and C Motorhome Data, Appendix A.)

We believe it would be more appropriate to use a Class B Motorhome as a design vehicle for the Byway. This would still accommodate visitors in smaller motorhomes who like to "get away from it all," and those who cannot afford a high-end RV or to camp in an expensive campground. Even if the road were designed for a slightly longer wheelbase than a Class B Motorhome (for example, 13 feet), the reduced size would accommodate the type of vehicle that belongs on this rural local Byway, while discouraging use of the road by larger, inappropriate vehicles (including and especially delivery trucks). It would also relieve the County Commissioners of the burden of having to regulate a large percentage (66%) of the 17-foot wb vehicles wanting to use the road. We do acknowledge that larger vehicles (trucks) that need to get to the hydroelectric dam would still have to be accommodated (by permit), but only as far as the dam.

Use of a Class B Motorhome could allow the FHWA to reduce the radius of some switchbacks beyond what is proposed for Alternative 6, which would reduce some reconstruction and its resulting impacts, and help to preserve the road's character.

Design grade
The FHWA's design grade for all of the build alternatives, including 6, is 9%. For local rural roads with a design speeds between 18 and 30 mph (design speed for Alt. 6), The Green Book recommends a maximum grade of 14% to 16% (Table V-4, p. 421).
The steepest grades on the Byway are one short section of 13% (in South Clear Creek Segment F), one section with a grade of 12.5% (Naylor Creek switchbacks), and two short sections with a grade of 12% (SCC Segment D and Silverdale Segment B). Even the steepest grades on the Byway do not exceed AASHTO standards. As many people have commented before, drivers on a rustic mountain road expect relatively steep grades as part of the mountain driving experience; they would not find it necessary, or desirable, to smooth the road out to a 9% grade.

If we are interpreting the SDEIS correctly, it appears that under Alternative 6, .62 miles of the road is "proposed to be reduced to a grade at or below 9 percent," while another 1.75 miles will be left at their current grade above 9 percent (III-7). If true, this would be a good example of the FHWA's capability for flexibility in design. If our interpretation is incorrect, and 2.37 miles (10%) of the road will be reduced to a grade at or below 9 percent, we strongly disagree with this action.

Under a minimal improvement alternative, and depending on location, it is possible that more, or all, of the .62 miles proposed for reduction could be maintained at the present grade.

Cross sections (typical and special)
In the SDEIS descriptions, the difference between "Rehabilitation" and "Light Reconstruction" is not clear. For example, in the SDEIS, only Light and Full Reconstruction specify "...adding drainage structures as needed" (p. III-11); adding drainage structures is NOT included under Rehabilitation. However, in Appendix B of the SDEIS, adding drainage structures is included in most of the Rehab segments (pp. B-20 to 33). As another example, only "minor" widening is allowed under Rehabilitation. However, installation of guardrails, which is included under Rehabilitation, requires an additional 7.5 feet of width. We contend that adding 7.5 feet is not "minor" widening." We request that the FHWA more clearly define what is allowed under each level of construction before the reader will be able to understand the extent of each level of construction.

Because all of the areas adjacent to the Byway include sensitive environmental, scenic, historic and/or cultural resources, the first purpose of any road design element should be to minimize impacts on the surrounding environment. While the cross sections under Alternative 6 reflect a slight trend toward this purpose, we contend that more flexibility in design is possible.

Roadway width is an important part of what MEG and a majority of concerned people feel defines the character of the Byway. A good part of the Byway's attraction is that it provides drivers with the (correct) perception that they are traveling on a rough, rustic, somewhat narrow mountain road, a road straight out of Colorado's past. This perception of a narrow road can even slow drivers down, contributing to safety: "With all else being equal, the wider the perceived road, the faster motorists will travel" (p. 17). "Where a difficult condition is obvious, drivers are more apt to accept lower speed operation than where there is no apparent reason for it" (Green Book, p. 63).

Close study of the cross sections described in the SDEIS reveals that while the "roadway" width is 22 feet, the "platform" width varies from 26 to 38 feet wide. Two-foot shoulders, foreslopes, the extra width needed for guardrails and MSE walls and big ditches, all contribute to "platform width," making a road that appears to be, and is, much wider than the real, on-the-ground, 22-foot width that we see today. Also, within the platform width, there is no allowance for trees or tall vegetation, which contributes to the perception of increased width. This is a critical issue that is not being addressed by the FHWA. While some widening is or may be needed to accommodate necessary elements such as ditches, there must be a commitment to maintaining platform width at as minimal a width as is safely possible and to retaining as much natural vegetation, as close to the road, as is possible. Guidance and support for this type of design is provided through the Design Exception Process and Context Sensitive Design, indicating that a commitment to this type of design is allowed under federal guidelines.

In regard to shoulder width, Designing Safer Roads, which provides guidelines for Rehabilitation projects, recommends one-foot shoulders for "highways on mountainous terrain" with a Design Year Volume (ADT) of less than 750 vehicles and less than 10% trucks (Table 5-3, p. 144). Because the majority of the Byway would be rehabilitated under a minimal-improvement alternative, and even 64% of the road would be rehabilitated under Alternative 6, and because road width is such a critical issue, we believe this shoulder width is more appropriate. Reducing shoulder width will reduce impacts on the social and natural environment by requiring less road width and requiring fewer trucks hauling materials (because of a reduced need for materials). Pullouts, which are part of any of the design alternatives for the Byway (including a minimal improvement alternative), can provide a safe area for vehicles to pull completely off the road, which is safer than stopping a vehicle on even a 2-foot wide shoulder.

Regarding Tables III-1a and III-1b (p. III-19), the two tables apparently do not correspond to each other. In Table 1a, Alternative 6, the summation across the table adds to 100%, with special sections being equal to 28%. In Table 1b, it seems the summation across Alt. 6 should add to either the 100% or to the 28% in Table 1a. Instead, the summation adds to 50%, which begs the question, 50% of what? 50% of the route? It is not possible to interpret the information in the two tables, and thus not possible to determine how many actual miles of different special sections will really be in Alt. 6. The same is true of each of the other Alternatives in Table III-1b. The problem may be caused by the overlapping of special sections, but that is unclear. The implication from the table and Figures III-6a through III-6h seems to be that each special section covers a separate area, with no overlap. Further explanation of these tables is needed.

The proposed 5.3 miles of guardrail create a problem for wildlife. Currently, large wildlife (bighorn sheep, mountain goats, elk, deer, bear) cross the road freely, especially on the unpaved sections. Guardrails will create a new hazard. Wildlife entering the roadway from downslope will be forced to jump over the rails instead of walking onto the road, which stresses the wildlife and creates a greater surprise hazard for motorists. The guardrails will also prevent wildlife from exiting the roadway freely. Animals that are "trapped" on the road are more likely to panic and behave irrationally, again creating a greater hazard for both motorists and the animal. Long and/or high cut and retaining walls also can hinder or impede the free movement of many species of wildlife.

Because viewing wildlife is one of the primary reasons visitors come to this area , and because wildlife viewing is an important asset to the economies of Colorado's rural counties, including Park and Clear Creek Counties , the importance of protecting wildlife is paramount. The US Fish and Wildlife Service and Colorado Division of Wildlife must be given sufficient time to review and recommend mitigation or avoidance measures regarding the use, size and extent of any walls, guardrail and other design elements that could hinder wildlife movement; and their recommendations should be adhered to.

Management responsibilities
Alternative 6 appears to be the only alternative for which management responsibilities are assigned. To comply with NEPA regulations, management responsibilities for Alternatives 1 through 5 should also be identified and compared and submitted for public review and comment. As one example, Alternatives 2, 4 and 5, all of which result in a 224% traffic volume increase, would require the two counties to commit to increased patrols and provision of emergency services; it would require the Forest Service to commit to more restrooms and increased maintenance of those restrooms. Additionally, as the DEIS stated that none of the build alternatives in the DEIS were intended to provide a through route connecting I-70 and 285, Clear Creek County, Park County, the Town of Georgetown and the Forest Service would still be responsible for not encouraging an increase in through traffic.

Winter closure
The Mount Evans Group supports winter closure of the Byway as a means to reduce maintenance costs, safety hazards to the public, and impacts on wildlife. We also recognize the counties' reluctance to adopt this practice, meaning that it will probably not be carried out.


Permanent closure
Because of the counties' reluctance to close the Byway in winter, another way to achieve the desired goals of reducing maintenance costs, safety hazards to the public, and impacts on wildlife is to permanently close the top portion of the Byway. The proposal for a Permanent Closure Alternative is outlined in more detail in the January 25, 2001 comments of The Evergreen Naturalists Audubon Society. This alternative meets the project objectives and meets the NEPA requirements of falling within a range of reasonable alternatives, making it a viable alternative. It may also be possible to incorporate permanent closure into another alternative, such as a minimal improvement alternative. At this time, the Mount Evans Group neither supports nor objects to this alternative, but we do support the full consideration of this alternative.

Alternative Surface Types (AST)
The Mount Evans Group supports the use of "chip seal" to provide a more rustic look to already-paved segments.

We do not support paving the Shelf Road in Park County. As discussed below, this creates a new and serious safety problem, and it does not fall within the parameters of "minimal improvement" that the people and the Sierra Club have requested.

The proposal to use "Alternative Surface Types" (AST) on unpaved segments of the Byway brings up numerous issues that are not addressed in the SDEIS.

Because the test strips have not been installed, we do not know what the AST really look like. But descriptions of the AST in the SDEIS (III-26) indicate that at least three of the treatments (macadam, Road Oyl and Permazyme) will create a surface that is as hard as pavement, and two of the treatments (macadam and recycled asphalt) will look like asphalt. When casually interviewed on the project site, construction workers on the Highway 285 project described macadam as "basically the same thing as pavement."

We are especially concerned that, according to documents that we obtained from the Forest Service in response to our Freedom of Information Act request for documents on water quality, the Forest Service is apparently requesting, or prepared to request, that all unpaved segments of the Guanella Byway be surfaced with macadam. The SDEIS would support this request, as footnote 3 in Table III-3 states, "All gravel sections may also be surfaced with one of the five alternatives surface types identified in Section III.E.2" (III-22).

Because some of the AST, particularly macadam, would create a surface that is virtually or relatively similar to a paved surface, using certain AST on all gravel sections would result in the Byway becoming a de facto paved road, which creates new problems and is specifically not what the people and the Sierra Club want.

According to FHWA figures in the Draft EIS, paving a road, or even paving the majority of a road, dramatically increases traffic volumes on the road. Alternative 2, which reconstructs and paves the entire Byway, results in a traffic volume increase of 224% by 2015, more than triple the existing number of vehicles. Further, the DEIS states, "Alternative 4 and Alternative 5 result in 85 percent of the road being paved (including the summit); therefore, traffic volumes under these alternatives increase similarly to Alternative 2" (DEIS, III-7). Table III-1 (III-8) in the DEIS bears out the statement made on p. III-7: Alternatives 2, 4 and 5 all show a 224% increase in traffic volume (over existing conditions) at the pass by 2015. Interestingly, Alternative 3, which reconstructs the entire route to a 24-foot width but leaves approximately ½ of the road unpaved, would only create an 80% increase. Apparently paving the road has the greatest effect on increase in traffic volume. The SDEIS agrees: "Additional traffic growth is anticipated if the route is improved, depending on the extent of improvement (primarily the extent of additional paving)" (B-4).

The higher increase in traffic volume that occurs as a result of surfacing improvement would also require the FHWA to use higher design criteria (such as wider travel lanes) for purposes of safety. Again, this is not acceptable to the public.

In addition, the gravel sections of the road have been identified in public comments as one of the integral parts of the Byway's special character, especially in its role as a Historic Byway (miners did not zip along on paved roads!). "Gravel" means gravel, not a semi-smooth, hardened surface. And, as we discussed in our comments on the DEIS, a gravel surface slows down traffic and discourages the use of the Byway as a connecting route between I-70 and 285. In a few segments, a surfacing treatment that stabilizes the gravel may be necessary, but the sense of "gravel" must remain.

Test strips
In its July 2000 newsletter, the FHWA stated "Beginning this summer, the FHWA is planning to test five alternative surface types that may be used in place of gravel surface....The public will have the opportunity to view and "feel" the differences between the six surface types and provide feedback during the public comment period for the SDEIS" (Newsletter, p. 3).

However, the test strips have not yet been installed. It is stated in the SDEIS that the test strips will be installed this spring. The SDEIS goes on to say, "The test strips will be evaluated to determine if they should be included as options in the FEIS and/or the ROD" (III-26). There is no mention of any opportunity for the public to review and comment on the test strips; if the decision is left until the ROD, there will be no opportunity for public comment.

Because only a tiny minority of people are familiar with all of the different proposed AST, and because the decision of if and/or what type of AST is to be used will have a critical impact on the Byway and adjacent lands, any further decisions on this project must be delayed until the agencies and the public have had an opportunity to review the test strips and provide comments, which must be considered by the FHWA and included as part of the official record.

Additionally, the "pros" and "cons" columns in Table III-6 (P III-28) are not commensurate. The same categories need to be used for each surface type, so they can be compared equally. Using different criteria for each surface type, as the SDEIS does, makes it possible to choose any personally preferred alternative, not necessarily the best for the particular situation. The "pros" and "cons" require their own table, which uses the same criteria for each surface type; for example: cost, appearance, character, dust, smoothness of surface, durability, maintenance, life span, and surface loss.

Example:
Gravel Pros Cons
Cost
Appearance
Character
Dust Characteristics
Surface Characteristics
Durability
Maintenance
Life span
Scattering characteristics
Etc
Gravel and MgCl


Issues for final design

According to the SDEIS and statements made by FHWA representatives at the Public Hearings held on December 4-7, 2000, the following elements will be left to final design:
1) retaining walls (location and/or design)
2) guardrail and guardwall (location and/or design)
3) drainage structures (location and/or type)
4) widening on one side of the road or the other
5) retaining walls vs. rolled back or steepened slopes
6) slope treatments (location, type and/or design)
7) sediment containment structures (location and/or type)
8) Vegetation (removal, type and extent of revegetation, schedule and contracting for revegetation)
9) Alternative Surface Types (location and type)

The arguments in the SDEIS for leaving aesthetic design decisions to final design are weak and illogical. For example, the SDEIS seems to imply that retaining walls and fill walls will only be used in certain alternatives, therefore, to submit the different types of walls for public review would prejudice one alternative over another. But what build alternative excludes the use of retaining walls and/or fill walls? And how would allowing the public to comment on the type of retaining wall or wall treatment they would prefer to see create a prejudice toward one alternative over any others? Worse yet, the SDEIS "teases" the reader with color pictures of the wall options that are being considered, with no promise that the public will ever get to participate in the choice.
Aesthetic issues, such as type of wall, slope treatment and Alternative Surface Types are critical elements of a Scenic and Historic Byway, and cannot be left as last-minute decisions by agencies that either do not or cannot place aesthetic appeal as a primary objective. (The guardrail in the "after" photo on p. IV-27 provides an eloquent argument for the need for public input on design details.) To comply with legal requirements for public participation, we believe the FHWA must provide assurance that the public will be given the opportunity to participate in final design decisions, before the Final EIS is released.

Many of the elements being left to final design also have the potential of creating negative impacts for wildlife; therefore, these elements must also be addressed under both environmental consequences and mitigation, no later than in the FEIS.

ENVIRONMENTAL IMPACTS

Impacts of increase in traffic volume
Under Alternative 6, traffic volume is estimated to increase by 117% (more than double) over the existing volume, as opposed to an 80% estimated increase if the No Build Alternative is chosen. Even with the application of a less aggressive growth rate of 2.7%, 117% is a significant increase. Presumably, the 117% increase is based on maintaining the same type of road surface as currently exists, with the exception of one extra mile of pavement. As noted above, an increase in improvement of the road's surface (i.e., paving or hardening) has a direct impact on the increase in traffic volume; so the actual increase would be higher if more of the road surface is treated with certain Alternative Surface Types.

According to the SDEIS, increase in traffic volume has a direct effect on use of adjacent Forest Service lands: "...an improved road provides easier access to the recreational sites on Guanella Pass Road, including dispersed recreation areas. Improved access leads to increased use of the forest and social trails. The amount of impact on the recreational resources adjacent to the roadway is proportional to the volume of traffic on the road" (IV-24, emphasis ours). As we mentioned in our comments on the DEIS, the 1995 Pike/San Isabel NF Recreational Capacity Analysis Summary shows that the west side of the Mount Evans Wilderness is already being used well beyond carrying capacity. Statistics in the DEIS show that use of Forest Service campgrounds in the area adjacent to the Byway is nearing capacity; use of dispersing camping areas exceeds capacity. One of the Forest Service's two top concerns for the Guanella Pass area is managing the overuse of lands adjacent to the Byway. Adding even more traffic to the equation just makes the problem worse.

Simply put, even a 117% increase could result in creating more significant environmental problems than any that may currently be caused by the road.



Population and demographics
The private property at Duck Lake is zoned for Commercial development and platted for subdivision. It is very possible that development of this property would lead to a larger, year-round residential population on the Byway, with a resulting increase in traffic and increased demand or need for year-round road maintenance. The SDEIS seems to hint at addressing this issue when it states, "The increased demand for [commercial] services may increase pressure for development of private lands (to be expanded upon in the FEIS)" (IV-9). However, it is not clear what the SDEIS is really alluding to.
This issue must be included as an impact of the project, and mitigation or avoidance measures considered and discussed and submitted for public review and comment.


Water Quality
The fact that Alternative 6 will have less impact on wetland and riparian communities is noted and appreciated by MEG.

At the December 7th, 2000 Public Hearing, FS Clear Creek District Ranger Dan Lovato announced that the Forest Service was out of compliance with the federal Clean Water Act. Apparently, sediment standards (TMDL) were being violated on South Clear Creek, due to sedimentation caused by the road, and specifically the road surface. Further investigation revealed that Mr. Lovato had received mistaken information , but the Forest Service is (correctly) maintaining that it is violating its Forest Plan for water quality.

The Forest Service's announcement that improvement of water quality is one of their top concerns for this project was not brought to the public's attention until the Public Hearings in December 2000. Violation of the Forest Plan for water quality is not mentioned in the DEIS, or in the SDEIS.

Sec.102 (D) (42 USC 4332) of the National Environmental Policy Act states,
Prior to making any detailed statement, the responsible Federal official shall consult with and obtain the comments of any Federal agency which has jurisdiction by law or special expertise with respect to any environmental impact involved. Copies of such statement and the comments and views of the appropriate Federal, State, and local
agencies, which are authorized to develop and enforce environmental standards, shall be made available to the President, the Council on Environmental Quality and to the public as provided by section 552 of title 5, United States Code, and shall accompany the proposal through the existing agency review processes;

This has not been the case with water quality, or with other issues or plans related to the U.S. Forest Service.

The Mount Evans Group acknowledges that water quality is an important issue that cannot be ignored. However, the actual extent of any problem in the Guanella Pass area, and what or how much should be done to address it, is not clear. Although it is obvious that some of the cut and fill slopes are eroding and sediment from the road does get into the streams, USGS studies did not indicate any problems that required immediate address, nor was it clear from the studies what percentage of any sediment was coming from each of three potential sources: the roadbed, the adjacent slopes, or the overall watershed. Additionally, a local newspaper article reports,
According to the Annual Drinking Water Report for Georgetown, the municipal water supply had no violations between Jan. 1 and Dec. 31, 1999. The source of Georgetown's water is South Clear Creek ....Unlike the Idaho Springs water supply, Georgetown's had no violations for turbidity, [or] cloudiness caused by soil runoff, based on samples taken the first day of every month. In fact the town's water had no violations during any of the tests for organic and inorganic contaminants.

There is a need for more study, to determine the exact cause and extent of any water quality problems. The real cause of any problems must be clearly and specifically identified and addressed on a case-by-case basis. It would be senseless to have the FHWA waste millions of taxpayers' money on activities that may provide only negligible improvements. We hereby request further study of this problem, so that the problems can be clearly identified and the proposed solutions carefully weighed against any negative impacts, and that the public be allowed to review and comment on any findings and proposals.

As stated previously, the Mount Evans Group does support protecting water quality. We do not recommend additional paving of the road, as this will lead to greater problems; but we do support fixing erosion, sedimentation and inadequate drainage problems by stabilizing and revegetating eroding slopes, installing curbs or berms to retain gravel along edges of unpaved sections of road and parking lots (as discussed in SDEIS, B-15), building or restoring ditches, installing more culverts and using modification features in drainage systems to reduce sedimentation (inc. baffles, traps and filter systems), and restoring natural hydrology patterns to streams with appropriate methods.

Visual quality: Character of the road
"Character of the road" refers to all of the elements that make this Byway unique and desirable to visit. It is a primary issue that the public is obviously concerned about. It actually goes well beyond visual quality, to include the entire visitor experience. Table IV-8 (IV-23) provides only a partial list of the character elements that were identified at the work group meetings. This table needs to be revised and expanded to include such elements as:
· type and location of vegetation (native? how close to the road?)
· pullouts (spectacular view? hidden in valley but nice place to picnic?)
· slope treatment (falling down on you?)
· ditches/storm drainage (bridges? nonworking culverts?)
· horizontal and vertical alignment (steep? curvy? new views around the corner?)
· traffic and interpretation signs
· sound (peaceful? no traffic sounds?)
· wildlife access ("Did you see the sheep standing in the middle of the road? Cool!")

Parking
Page IV-31, paragraph 3 states "(the peak parking demand reported in the DEIS is shown in parentheses.)" However, this information is not in table IV-9.

The research design for the parking study fails to meet the standards of good research. The determination of existing number of parked vehicles at each site is based on 2 observed Saturdays, on 8/20/94 and 7/20/95. On each date, 11 observations were made, but all observations were thrown out except for the highest scores on each day. Then, from the 2 scores left for each site, again only the highest score was chosen. For each of the 8 sites reported in the SDEIS, 22 observations were made, for a total of 176 observations; but, instead of using all of the information available, only one score (the highest) was chosen to represent each site. This means that at each site 95.5% of the available information was disregarded. This leads to erroneous conclusions, especially regarding the need for an overly large parking lot at the top of the pass.

Table IV-9 must be redesigned to include all of the information available. For example, for Area 1 (the Guanella Pass Parking Area), the appropriate technique for determining what is going on during the days observed is to compute a mean and standard deviation. This provides a good indicator of average use, and also provides an indicator of variability. The mean for this site is 27.23 and a standard deviation (s) of 16.07, indicating high variability. The chosen score of 55, is 1.73 standard deviations above the mean, which means this score is not representative of the information gathered.
Using all the information, and based on the standard formula for % change, it becomes obvious that a parking lot for 118 vehicles is too large. If a more representative existing parking number of 27.23 is used, with a 117% increase, then the potential parking needs at the top of the pass in 2015 equals 59 parking spaces, and not the 118 in Table IV-9 or the 143 mentioned in Appendix B (page B-21).

As noted above, the Forest Service is concerned about overuse of the area, with the summit being a "trouble spot." It would be unwise to place a 143-car parking lot and restrooms at an area where you don't want people to stop.

Wildlife resources
The SDEIS states, "The potential [winter] road closure will not be considered as mitigation for environmental impacts to any threatened and endangered species. The action that the current County Commissioners take cannot bind a future Board of Commissioners and, therefore, cannot guarantee the mitigation provided by a potential road closure" (III-25). This statement should be expanded to include all wildlife potentially affected by winter closure, and should be repeated under Wildlife Resources.



Noise
The Mount Evans Group submitted lengthy comments on noise in its comments on the DEIS.

With Alternative 6, there is an additional noise issue in regard to the possibility of locating borrow sites and staging areas and even an asphalt plant on the Byway, specifically at Geneva Park/Duck Lake and/or Silverdale (IV-44, 46). The additional noise from these sites will have a direct impact on receptors (human visitors and wildlife) in the Wilderness Area and Roadless Areas. The level of impact and mitigation or avoidance measures must be identified and discussed.

Maintenance costs

The design of Table IV-13 (IV-40) forces decision makers to choose a build alternative because an arbitrarily high maintenance cost per year has been established for the no build alternative (Clear Creek $305,000 per year; Park County $160,000). The counties do not spend this amount now, and it is unreasonable to assume they will spend substantially more than they are currently spending. These estimates give County Commissioners a distorted impression of the need for road improvements.

There should be a logical and clearly stated relationship between Tables IV-14, -15 and -16 (pp. IV-41, 42). If we assume that the figures in Table 14 are correct, then most figures in Table 15 should be the scores in Table 14 times 20. However, that does not seem to be the case. Either the scores in Table 15 are wrong, or a better description of how the figures in Table 15 were derived is needed. If the figures in Table 16 are derived by some addition of the figures in Table 15, then we must assume the figures in Table 16 are also wrong.

In Tables 14 and 15, the meaning of each column is unclear, as they are not explained in the text of the SDEIS. Additionally there is no explanation of how many times, and why, a figure in Table 14 will be multiplied to achieve a score in Table 15. The costs of reconstruction for Road Oyl and Permazyme in Table 15 and their derivation are especially unclear. Further Table 14, 15, and 16, need a calculation for the costs of gravel, and not just a footnote.

Finally, the costs in Table 16 don't seem to fit with total maintenance costs derived in Table IV-13.

Construction impacts

Community Disruption
Construction impacts on the residents, businesses and visitors in Georgetown and Grant are not adequately addressed in the SDEIS. It is physically impossible for the amount of construction required under Alternative 6 to be completed on the Georgetown side in three seasons, nor is it possible for the construction on the Park County side to be completed in two seasons. The construction schedule in the DEIS schedules work for 7 days a week. This does not allow for the heavy use the road experiences on weekends, or for bad weather or holidays. Additionally, 8,400 18-wheeled construction trucks passing (one way) through Georgetown and 6,000 construction trucks traveling (one way) on the Park County side will create an intolerable burden for businesses and residents, and a logistic nightmare for travelers on the Byway. A minimal-improvement alternative could significantly reduce these numbers and their resulting impacts.

Vibration
The impacts of vibration on the historic buildings in Georgetown and any mitigation or avoidance measures are not adequately addressed in the SDEIS.

Georgetown is a National Landmark Historic District. The town's careful preservation of its historic buildings is a major draw for tourists, whose dollars provide the majority of the town's economy. According to the FHWA's July 2000 newsletter, the FHWA intended to conduct a vibration study on the town's historic buildings at the time the AST test strips were installed last fall, "to measure potential effects of construction truck hauling on historic properties and other structures" (Newsletter, p. 3). However, the vibration tests have not yet been conducted because the test strips have not been installed. These tests, and discussion of mitigation or avoidance measures must be addressed before the release of the Final EIS, so that the State Historical Preservation Officer, residents of Georgetown and concerned members of the public have the opportunity to review the study and proposed mitigation and/or avoidance measures, and make comments that will be included in the FEIS.

Traffic delays
The SDEIS fails to include the impact of traffic delays that will occur because of oversized hauling vehicles (either 18-wheelers or construction trucks) needing the entire road to negotiate the switchbacks above Georgetown, and possibly other sections of the Byway. These delays will have a severe impact on visitors driving the route and recreationalists using the Byway for access.

Reducing impacts
The SDEIS does not list scaling down the project as a method for reducing impacts. There are numerous opportunities here, such as doing more rehabilitation, reducing the size of parking lots, and limiting reconstruction to specific site problems, such as a specific stretch of unstable, eroding fill slope that is an identified source of stream sedimentation.

Cumulative impacts
In its written comments on the DEIS, the Mount Evans Group requested that "a more comprehensive discussion of cumulative impacts" be included in the Supplemental Draft EIS. This request was not addressed.

Naylor Creek Realignment
Although the SDEIS does not discuss which of the proposed realignments may be applied under Alternative 6, the FHWA's July 2000 newsletter states, "The only realignment option still being considered is the Naylor Creek realignment" (p. 3). The Mt. Evans Group does not support this realignment, as it is not clear that any positive gains will outweigh the negative impacts.


ADDITIONAL ISSUES

SAFETY
The FHWA cites potential liability issues regarding safety as one of the primary reasons for their reluctance to further scale down improvements. However, neither the DEIS or the SDEIS offer any evidence that the existing roadway is unsafe in and of itself, or in comparison to other roads, or that any of the proposed improvements will actually address any specific safety problems that may exist. The Mount Evans Group discussed this in its comments on the DEIS, stating:

The DEIS purports that the road must be improved because it is currently unsafe. However, there is no evidence provided in the DEIS to prove that the road is less safe than any other road. The FHWA must provide data on accidents on other roads for comparison. In addition, more background information on the accidents that have occurred on Guanella Pass, including time of year, time of day, weather conditions, health conditions of the driver, etc., must be provided....

The DEIS also provides no discussion of how safety issues could be addressed, other than through paving and widening. There is no discussion or comparison of effectiveness of other techniques that could be used to improve safety, such as better and more adequate signage....There is no comparison of the cost of these techniques vs. the cost of paving and widening the road. (MEG comments, 10/14/99, p.2).

These concerns apply equally to the SDEIS and Alternative 6.

Additionally, Alternative 6 could lead to new safety problems. One example is the proposed paving of the one mile of Shelf Road located in Park County. Because this segment of road is relatively straight and the platform would be so wide (due to the 6-10' ditch and extra width for MSE walls), drivers traveling north will speed up on the paved Park County segment, only to find themselves out of control when they hit the unpaved segment of Shelf Road on the Clear Creek County side. Similarly, drivers headed south on the Park County segment will be traveling much faster than they do at present; when they hit the switchback at the bottom of the traverse, their chances of reacting too late to the sudden change in horizontal alignment will be greater.

PUBLIC PARTICIPATION
It is important to note that Alternative 6 was developed in direct response to the public's comments on the DEIS. The only reason this alternative exists is that the public so overwhelmingly rejected all of the build alternatives in the DEIS. But ever since the FHWA announced its decision to develop a new alternative, it seems the public has been, and is being, left out of the decision-making process, sometimes deliberately.

In the spring of 2000, the FHWA held four "work group" meetings. These work groups were formed for the purpose of providing input on the development and design of Alternative 6. They consisted of official representatives from the program's participating agencies, the FHWA, Forest Service, Clear Creek County, Park County, Georgetown and the Colorado Department of Transportation (CDOT). No members of the public were invited to participate in the work group sessions; in fact, the FHWA specifically excluded members of the public from participating. FHWA representatives cited the Federal Advisory Committees Act (FACA) as the reason they were required to exclude the public. We believe that this is a misinterpretation of FACA, as it is our understanding that FACA is actually intended to ensure that all sides in a federal government decision process are allowed to participate and be heard in a balanced manner. This is especially important when there is evidence of strong public concern regarding an issue, as is the case with Guanella Pass.

Although the FHWA stated in its July 2000 newsletter that the work group sessions "were open to the public for observation," the sessions were not announced in either of the local papers (Fairplay Flume and Clear Creek Courant), apparently because the papers received no notices of the meetings.

Further, at the April 25th meeting in Bailey, Colorado, one member of the general was seated at the work group meeting table and fully participated in the discussion at the table. This created an unbalanced public participation situation, which would violate the Federal Advisory Committees Act.

FOREST SERVICE BYWAY MANAGEMENT PLAN
The SDEIS refers to coordinating plans with the Forest Service:
"...additional restrooms are proposed by the FS." (B-17)
"An enlarged and formalized trailhead parking lot with 143 parking spaces and restroom facility is proposed by the FS at the summit of Guanella Pass..." (B-21)
"The extent to which any of the build alternatives accommodates and controls access to FS facilities will be addressed in greater detail after further coordination with the FS" (IV-49).

The SDEIS also refers specifically to a Forest Service Byway Plan:
Signage, pullouts and restrooms "will be consistent with the FS Scenic Byway Plan for Guanella Pass Road. A draft of the plan has been prepared and is in the process of being finalized for approval by the FS and agencies with jurisdiction of the road" (III-32).

However, as far as we have been able to ascertain, there is no formalized Forest Service Byway Management Plan for this project. If one has been developed, it has not been submitted to the public for review and comment, denying the public's right to be informed of and participate in a federal action that affects our environment.

Without any formal statement from the Forest Service, there are so many unanswered questions that it is hard to understand how the project can continue. For example:
· What are the Forest Service's goals and objectives for the Byway?
· Can Forest Service facilities accommodate the increase in use resulting from a 117% increase in traffic volume, as expected under Alternative 6? If the traffic volume increase is considerably higher because of the application of certain Alternative Surface Types, can the Forest Service accommodate the higher increased use? Can the existing facilities even accommodate the increase in use resulting from an 80% increase in traffic volume expected under the No Action Alternative?
· Does the FS have the funds to manage and maintain more facilities and increased recreational use of the area? How will the impacts of different increases in use, resulting from different increases in traffic volume, need to be managed? At what point of increased use will the FS be unable to tolerate the impacts? When traffic has increased by 80%? 117%? 224%?

The third objective of this project is to "Accommodate and control access to Forest Service facilities along the road" (IV-49). In the absence of any formalized input from the Forest Service, such as a Byway Management Plan, it is impossible to know if Alternative 6, or any of the build alternatives, meet this objective.

Continuation of this project without any formal statement or input from the Forest Service may be in violation of Sec.102 (D) (42 USC 4332) of the National Environmental Policy Act, mentioned earlier in our comments.


NEED FOR A MINIMAL IMPROVEMENT ALTERNATIVE

For the reasons stated above, the Mount Evans Group is unable to support Alternative 6. The critical issues that concern us are:
· The design accommodates vehicles (and their inherent uses) that are not appropriate for use on a rural local recreational Byway that is adjacent to public lands that are being used beyond carrying capacity;
· The design fails to include any features that will prohibit or discourage certain inappropriate uses of the road, such as a connecting route between I-70 and Highway 285;
· The different impacts of the application of the different Alternative Surface Types have not been fully disclosed;
· The public is being denied their legal right to participate in decisions that will have a profound impact on the Byway, their communities, and public lands adjacent to the road;
· Alternative 6 does not meet the priorities expressed in the overwhelming majority of responses to the Draft EIS;
· The SDEIS and Alternative 6 do not address all of the concerns expressed in the overwhelming majority of responses to the Draft EIS.

For these reasons, we respectfully request that the FHWA develop a seventh, minimal improvement alternative that places protection of the area's scenic, environmental, historic and cultural resources first, allowing for limited reconstruction only where necessary to address significant erosion or sedimentation problems; and that this alternative be developed with active, meaningful input from the public. Some of the goals of this alternative are to:
· accommodate vehicles that are appropriate for use on a rural local recreational Byway that is adjacent to public lands that are being used beyond carrying capacity;
· design the road to maintain its existing character by using context sensitive design techniques and the design exception process where applicable;
· more clearly define the problems that need to be addressed in the project;
· limit reconstruction to areas that are clearly identified as causes of erosion or sedimentation problems;
· strive for an increase in traffic volume similar to the No Action Alternative (80%);
· encourage more active public participation in the design process;
· place accommodating the needs of wildlife and their habitat as a primary goal.

Appendix B compares a minimal improvement alternative to the project objectives, which are listed on IV-48 & 49. We believe that this alternative meets all of the objectives of the project, and in a manner that is more consistent with what the public has requested, as stated in Appendix A of the SDEIS.

This alternative also meets the NEPA requirement of falling within the range of reasonable alternatives, thus making it a viable alternative for consideration.

We also request that the FHWA develop and consider a Permanent Closure Alternative, which is outlined in the January 25, 2001 comments of The Evergreen Naturalists Audubon Society. This alternative meets the project objectives and meets the NEPA requirement of falling within the range of reasonable alternatives, thus making it a viable alternative for consideration. It may also be possible to incorporate the element of permanent closure into another alternative, such as a minimal improvement alternative. At this time, the Mount Evans Group neither supports nor objects to this alternative, but we do support the full consideration of this alternative.

Respectfully submitted,

Lyn Yarroll
(electronic signature)
Lyn Yarroll, Chair, Guanella Pass Study Group

Tod Bacigalupi
(electronic signature)
Tod Bacigalupi, Vice-Chair, Guanella Pass Study Group

Attached:
Appendix A: Class B and C Motorhome Data
Appendix B: Comparison of a Minimal Improvement Alternative


cc:
Clear Creek County Commissioners Robert Poirot, Fabyan Watrous, Jo Ann Sorensen
Park County Commissioners Jerry Solberg, Leni Walker, Don Staples
Donna Mickley, US Forest Service Special Projects Coordinator


Reference Publications

Marriott, Paul Daniel. Saving historic roads: Design and policy guidelines, John Wiley & Sons in cooperation with The National Trust for Historic Preservation, 1998.

Myerson, Deborah L. Getting it right in the right of way: Citizen participation in context-sensitive highway design, Scenic America, 2000.

Wick, Jim. A state highway project in your town?: Your role and rights, a primer for citizens and public officials, Preservation Trust of Vermont, 1998, 2nd ed.

COMPARISON OF A MINIMAL IMPROVEMENT ALTERNATIVE

COMPARISON OF A MINIMAL IMPROVEMENT ALTERNATIVE
TO THE GUANELLA PASS BYWAY PROJECT OBJECTIVES

Prepared in cooperation with Eric Banta, Esq.

Development of a seventh alternative, consistent with the recommendations we have provided in these and past comments, and with the requests of the respondents to the Draft EIS, is the best way to achieve the project objectives, and to minimize conflict among the stated project objectives, which are not completely compatible.

Public comments on the DEIS, as tabulated in Appendix A of the SDEIS, and comments at public hearings held in December, 2000 indicate that the interested public, including the Mount Evans Group, has overwhelmingly requested that the FHWA give greater priority than has yet been exhibited to the project objectives which minimize overuse of the area, maintain the rustic nature of the roadway, and reduce the environmental impacts of the road, including erosion, sediment control and impacts to water quality and wildlife, while causing minimal disruption to the road corridor.

Presently, the project objectives are prioritized in a manner that is substantially inconsistent with the stated desire of the Mount Evans Group and the majority of the people who have communicated their views to the agency. The project objectives that best embody these stated goals, and which are not given adequate priority by the FHWA, are objectives 3, 7 and 8.

Contrary to what the respondents and the Mount Evans Group have requested, the FHWA has given too much priority to objectives 1 and 2 in developing Alternative 6. The Mount Evans Group does not dismiss these objectives as unimportant, but finds the priority given to these objectives in Alternative 6 creates a material conflict with objectives 3, 7 and 8. The Mount Evans Group submits that a minimal improvement alternative better weighs the goals of each project objective, consistent with what the public has requested and in a manner that does not significantly undermine the goals of any one objective in furtherance of another.

Objective 1 - Provide a roadway width and surface capable of accommodating anticipated 2015 traffic volumes.

This objective is somewhat circular in that it requires that the roadway be improved to meet a certain projected traffic demand. However, the actual increase in traffic will depend on the extent of the road improvements. FHWA traffic studies indicate that the roadway design selected will directly influence the amount of traffic on the road. Thus, in order to satisfy this objective while also trying to meet the conflicting objective of minimizing additional traffic and overuse of the area, the FHWA needs to develop a road design that will result in the lowest number of projected vehicles in 2015, provided such design does not materially conflict with the other objectives. Alternative 6 and the other build alternatives do materially conflict with objectives 3 (overuse), 7 (environmental impacts) and 8 (rural character) of the road, in comparison to the minimal improvements alternative advocated by the Mount Evans Group.

The road design, under the minimal improvement alternative proposed by the Mount Evans Group, would result in the smallest increase in projected traffic volumes over the No Action Alternative, and represents the best compromise to satisfy all objectives and achieve the goals articulated as priorities by the Mount Evans Group and the public at large through the public participation process.

Objective 2 - Improve Safety by Providing a Consistent Roadway Geometry and Providing Reasonable Protection from Unsafe Conditions

FHWA representatives are on record as stating that they cannot adopt a project design with safety standards that are less than what is proposed in Alternative 6. This claim has been disputed.

The objective to improve safety is a necessary one that deserves high priority, but it is arguable that the design elements intended to improve safely (e.g. widening, guardrails, hardening road surface, reducing gradients, widening switchbacks), are likely to create new safety concerns. These elements contribute to increased traffic volume, increased speeds and a false sense of security and less attentive driving; which lead to greater frequency and severity of accidents; increased roadkill, and increased risk to pedestrians. The FHWA's selection of a larger, Class C motorhome and corresponding design elements also contribute to use of the road by larger vehicles, which also increase the likelihood and severity of accidents.

Additionally, there is no material evidence that the existing road is unsafe. There has been no comparison of accidents and injuries with similar roads. Independent research conducted by the Mount Evans Group indicates that the current safety record of the road appears to be above average.

The MEG contends that the FHWA's suggested method to control traffic volumes and speeds and use of the road by inappropriate vehicles, with management by local and federal government agencies, is unrealistic, given the fiscal and manpower constraints on such agencies.

Given this inherent conflict, the FHWA has a duty to devise an alternative that is safer but does not materially frustrate the project's ability to attain the other objectives, especially those objectives which the Mount Evans Group and the majority of the public have very specifically identified as their main priorities for the project.

The road design under the minimal improvement alternative proposed by the Mount Evans Group, still includes safety considerations, but will reduce the prevalence of new safety concerns that are inherent in a faster, wider road as in Alternative 6. A minimal improvement alternative also represents the best compromise to satisfy all objectives and achieve the goals articulated as priorities by the Mount Evans Group and the public at large.

Objective 3 - Accommodate and Control Access to Forest Service Facilities along the Road.

Given the evidence on the record that the Wilderness Area, other Forest Lands and Forest Service facilities adjacent to the Guanella Pass Byway are currently overused and exceeding or close to exceeding capacity, the importance of controlling access to these areas and facilities should logically take precedence over accommodation in the planning process for the road. Alternative 6, however, does very little to control access to FS facilities and public lands. It does accommodate 35-foot-long motorhomes and other large vehicles which are not accommodated by the current road nor by the road that we propose in a minimal improvement alternative. Again, we dispute speculative claims by the FHWA that a permit system by an agency for which there is no current plan, commitment or funding will provide the control needed to further this objective as well as objectives 7 and 8.

A minimal improvement alternative will limit access to vehicles no larger than Class B motorhomes and will not incorporate other design features such as widening the road and belling out switchbacks that will invite increased traffic to the overused area and frustrate attempts to control use within capacity standards. Thus, a minimal improvement alternative again represents the best way to achieve this objective and resolve conflicts presented by Alternative 6 with respect to this and the other objectives.

Objective 4 - Reduce the Anticipated Cost to the Counties and Town in Maintaining the Road

Alternative 6 will save maintenance costs and achieve this objective, but at significant cost to other objectives. A minimal improvement alternative will represent a savings over No Action and achieve this objective, but to a lesser amount.

While a minimum alternative improvement reduces maintenance costs to a lesser extent than Alternative 6, it maximizes Objectives 3, 7 and 8, which are the goals articulated as priorities by the Mount Evans Group and the public at large.

Objective 5 - Repair Roadway Drainage Problems

Both Alternative 6 and the minimal improvement alternative proposed by the Mount Evans Group will significantly improve drainage problems currently present on the road. However, under Alternative 6, reconstructing some areas to address drainage problems will also negatively impact the road's character. A minimal improvement alternative will provide greater care in preserving the road's character by focusing improvements on a smaller, segment-by-segment and case-by-case basis.

Additionally, a minimal improvement alternative represents the best compromise to satisfy all objectives and maximize achievement of the goals articulated as priorities by the Mount Evans Group and the public at large.

Objective 6 - Repair Existing Unvegetated Slopes

Alternative 6 will adequately address needed repairs to existing unvegetated slopes adjacent to the road. However, the minimal improvement alternative proposed by the Mount Evans Group will better achieve this objective while also maximizing Objectives 7 and 8 by addressing specifically identified problem areas with appropriate, site-specific methods.

Again, a minimal improvement alternative represents the best compromise to satisfy all objectives and maximize achievement of the goals articulated as priorities by the Mount Evans Group and the public at large.

Objective 7 - Avoid, Minimize, or Mitigate Adverse Impacts to the Environment by Considering Key Issues Identified Through the Public and Agency Involvement Process

Components of Objective 7 were cited most frequently as major issues in public comments on the DEIS . For the interested public and the Mount Evans Group, Objective 7 is a top priority in terms of designing this project.

Alternative 6 will avoid, minimize or mitigate adverse impacts to the environment. How well Alternative 6 achieves Objective 7 will depend on if and what type of an Alternative Surface Type treatment is chosen, and on other decisions that have been left to final design. However, to a greater or lesser degree, the road improvements under Alternative 6 will increase traffic volume, which will further fragment wildlife habitat, resulting in the loss of undisturbed habitat, and will increase use of areas adjacent to the road, also resulting in the loss of undisturbed habitat.

A minimal improvement alternative will better achieve the goals of Objective 7 than Alternative 6, or any other build alternatives.


Objective 8 - Maintain the Scenic and Rural Character of the Road

Although the FHWA contends that Alternative 6 meet the goals of this objective, the overwhelming majority of comments received by the FHWA on the DEIS and Alternative 6 to date support the conclusion that Alternative 6 will not maintain the road's rustic, scenic and rural character. Rather, Alternative 6 proposes significant changes to the road corridor which will destroy much of its current rustic, backcountry character. The majority of people who commented at the public meetings sponsored by the FHWA in December, 2000 cited Alternative 6's failure to adequately maintain the current character of the road as a significant factor in opposing the Alternative. Furthermore, concern over loss of character of the road with any of the build alternatives was Major Issue #3 raised by the public during the public comment period following release of the DEIS. In our opinion, Alternative 6 does not meet this objective.

A minimal improvements alternative goes much further in maintaining the road's current character since it does not call for such significant changes as contemplated in Alternative 6, including but not limited to, altering the road's existing footprint, the use of guardrails, expanded parking and hard pavement-like alternative surfaces. We believe that a minimal improvement alternative presents a road design which represents a much better compromise between the inherent conflict between objectives 1 and 2 (collectively) and objective 8, as evidenced by Alternative 6's improvements designed to increase safety and accommodate large vehicles with the likely result of loss of the rustic character of the road.

To summarize the discussion of these objectives, Alternative 6 fails to properly resolve conflicts among the project objectives in a manner which effectively responds to the key issues identified by the Mount Evans Group and the interested public. Alternative 6 is still a large construction project which could significantly change the character and usage of the road. Although the road design in Alternative 6 will incorporate significant safety measures, other project objectives that the public has identified as critical to the project are sacrificed as a result thereof. A minimal improvement alternative represents the best compromise to satisfy all objectives and maximize achievement of the goals articulated as priorities by the Mount Evans Group and the public at large through the public participation process.

If the FHWA is unwilling to make wholesale changes to Alternative 6 to better align with the project objectives and the desires of the public who will be using this road for the years to come, the FHWA should develop a seventh minimal improvement alternative consistent with these comments. Such a minimal improvement alternative would address all of the project objectives in a manner which creates less conflict among such objectives in comparison to the current proposed alternatives under consideration. For these reasons, we assert that a minimal improvement alternative is a reasonable alternative as contemplated under NEPA and that the FHWA is required to formally develop and consider such alternative as one of the alternatives for the project to be evaluated in the final EIS.

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