Chapter 2 – Alternatives

Environmental United States Department Assessment of Agriculture Bonneville Shoreline Trail – Salt Lake

County U.S. Forest Service

March 2010 Response to Comments

Salt Lake County, Utah Salt Lake Ranger District, Uinta-Wasatch-Cache National Forest

For Information Contact: Steve Scheid 6944 South 3000 East Cottonwood Heights, UT 84121 [email protected] (801) 733-2689

Bonneville Shoreline Trail Environmental Assessment

Environmental Assessment Bonneville Shoreline Trail – Salt Lake County Response to Comments

Table of Contents 1. Purpose and Need ...... 2 2. Alternatives ...... 3 3. General Ecological Resources ...... 8 4. Soils ...... 10 5. Water Resources...... 17 6. Process (Comments Referring to Scoping or NEPA Process) ...... 19 7. Recreation...... 25 8. Economic ...... 31 9. Social ...... 33 10. Transportation ...... 40 11. Vegetation ...... 49 12. Visual Resources ...... 51 13. Wildlife (Not Including Listed or Sensitive Species) and Wildlife Habitat ...... 57 14. Wilderness ...... 62 15. Private Property ...... 65 16. Fire ...... 74

Content Analysis Process Public responses on the Preliminary Environmental Assessment (EA) for the Bonneville Shoreline Trail (BST) project were documented and analyzed using a process called content analysis. This is a systematic process of compiling, categorizing and summarizing all comments submitted on a project. This method is useful in analyzing voluminous comments both individually and collectively. Many of the comments were similar in nature and those were grouped and responded to as such, while other specific comments were responded to individually. All comments were assigned a code number and the comments, whether grouped or individual, retain their code numbers for tracking purposes. Interested parties may review the reading file of original response letters on file at the Salt Lake District Office in Salt Lake City, UT.

Response to Comments 1

Bonneville Shoreline Trail Environmental Assessment

1. Purpose and Need 1. Comment H17: It honestly seems to me that government entities, particularly their leaders, get a notion to do something, obtain funding for the project, then railroad it through because they exist to do this kind of thing. Certainly, there is little democratic representation in all of this. 1. Response: The USFS has involved the public in the decision-making process. The USFS has worked closely with the BST Committee as well as with Salt Lake County and other local government agencies in BST land acquisitions, planning, and trail construction. The proposal was provided to the public and other agencies for comment during scoping March17 to April 17, 2006. A public scoping meeting was conducted on April 5, 2006 to gather comments from the public and interested agencies and organizations on the proposed alignment, construction, and use of the extended BST. Sixty-six people registered at the meeting. Over 350 people have provided comments on the project during the scoping period. 2. Comment H1, H4: Why do we need more biking and hiking trails around here when we have all of Mill Creek Canyon with its many biking and hiking trails, and Wasatch Blvd bike lanes, going north and south, and the new Parley’s Canyon trail just below I-215. I question that there is a need for any trail other than Wasatch Boulevard. Connections to the Neff’s Canyon Trail could be up Oakview Drive then east over to Park Terrace Drive and up Whites Way to the trailhead. 2. Response to Comments H1 and H4: Section 1.2 of the EA provides the purpose and need for the proposed trail. The Forest Plan details a strong commitment by the USFS to complete the BST. In addition, local government has recognized the importance and value of the BST as a community asset. The BST would be recognized and valued as a unique opportunity to provide recreation corridors across multiple ownerships in the face of continuing urban development. The proposed trail is needed to provide unique quality recreation opportunities along the urban-forest interface. In addition to recreational purposes, the trail may serve as a fire buffer and access for fire suppression to protect property in the wildland urban interface. The use of Wasatch Blvd. is reflected and analyzed under the No Action Alternative. Recreational impacts of selecting the No-Action Alternative are outlined in Section 3.3.3. The increased demand for recreation would not be met, user conflicts and conflicts with adjacent property owners would likely continue. Visitor use is expected to increase on built trails, existing user-created trails, as well as proliferation of user-created trails. 3. Comments H37, F4: Building the Bonneville Shoreline Trail above the Eastwood and Olympus Cove residential areas is unnecessary. There are already numerous hiking and biking trails close by in Millcreek Canyon. Street bikers can use Wasatch Blvd. The bridges across Parley’s Canyon are good projects because there is no other way to transverse the canyon above 20th East, but there is no real need for this trail. At this point in time, the expense of putting a trail in where none is necessary seems a foolish use of tax payer money. If someone wants to traverse the mountain side...they may certainly do it now. As well, this area has no lack of trails...many of which are seldom used. If you want to take a hike in this area and not see anyone else on the trail....try the west side of Grandeur Peak from Wasatch. Even the easy accessed Pipe Line trail is lightly used. The expense you are anticipating seems to be incredibly shortsighted.

Response to Comments 2

Bonneville Shoreline Trail Environmental Assessment

3. Response to H37 and F4: The need for the proposed action is described in Section 1.2 of the EA. The Wasatch-Cache National Forest Plan describes why the USFS is considering this project: ―The BST, designated in 1999 as one of sixteen national Millennium Legacy Trails, is envisioned to be an aesthetically pleasing (though urban influenced), non-motorized recreational trail experience, nearby yet apart from the urban Wasatch Front and its many communities. The Bonneville Shoreline is a very important regional trail yet critical portions remain incomplete. The trail serves a variety of users and provides both recreational and economic benefits to local communities. Access to the national forest continues to be threatened as development near the forest continues. In the future the BST will be recognized and valued as a unique opportunity to provide recreation corridors across multiple ownerships in the face of continuing urban development. In addition to recreational purposes, the trail may serve as a fire buffer, a recognizable, defensible physical boundary for the Forest, and access for fire suppression to protect property in the wildland urban interface.‖ As for the funding and maintenance of the trail, any trail would be constructed and maintained with a substantial volunteer contribution and would be funded through a combination of public and private funds. 4. Comment M5, M23, M47, M49: On a more practical note the disruption to the neighborhoods during the construction and the lasting impact to the security and privacy to this residential community seem unreasonable when easier and more convenient alternative routes are available. When decisions concerning bridge safety, health, education, and similar social needs are being deferred, it would seem that spending public funds on an un-needed hiking trail through a residential community would be less than essential. Specific areas mentioned: south end of Mile high Drive, easement from Crestwood Drive, 4. Response to M5, M23, M47, M49: The effects of these concerns are discussed in Section 3.10.3 of the EA. The BST may have a balancing effect on trespassing and vandalism for the following reasons. Some degree of unavoidable incidences of trespassing and vandalism would likely occur with increased visitor use, therefore resulting in minor adverse effects. On the other hand, an increase in visitor use would also produce an increase in visibility to homes, businesses, and other private properties. Increased visibility to an area has a natural tendency to diminish crime rates and therefore produce a balancing effect. Organized neighborhood watch areas and proper signage indicating property boundaries and right-of-ways would help minimize adverse effects. As with trespassing and vandalism, minor adverse effects may be unavoidable as property owners strive to minimize their sense of loss of privacy and security. Two potential ways to mitigate these adverse effects include posting signs at trailheads and along the trail, indicating where the trail enters right-of ways and require dogs to be on a leash (e.g., when going through residential areas).

2. Alternatives 5. Comment H3: Though the desire of a continuous trail over two hundred miles long is appealing on paper, the logistics of this segment begs a few questions. Page 21 of the AP lists this segment at 1.71 miles, which may take an hour or more to hike due to the terrain. How many people would be using this as part of a continuous trail? Unless hikers are dropped off and picked up by non-hikers, those using the trail would have to backtrack over the trail or through roads to return to their parking. Wouldn't a more effective route take hikers higher up the hillside in a non-continuous trail? Hiking to the peak and returning to your car makes more sense from the view of an outdoors person. Those who want this segment as part of a usable continuous trail would more appropriately consider using Wasatch Blvd. Those who want a more scenic and wilderness trail would more

Response to Comments 3

Bonneville Shoreline Trail Environmental Assessment appropriately request a trail to the peak. 5. Response: Routing trails further up the hillside does not meet the theme of the BST, as it would be located too high above the elevation of Lake Bonneville and does not meet criteria for aesthetic values outlined in the MOU (see Section 1.1.3). There is already a large network of FS trails that provide access to most of the peaks in the Wasatch Range in Salt Lake County. A non- continuous trail would not link other segments of the BST nor would it be compatible with the BST concept. It is likely that the majority of users would come from neighborhoods located in close proximity to the trail. A preponderance of local neighborhood use also brings with it high-frequency users. Such a trend is held for the existing University section of the BST. 6. Comment D1, D10, D2: The current BST route, along Wasatch Drive, can easily be widened to allow more room for bikers and less conflict between them and automobile traffic. This would have no negative impact on homeowners, fire risk, or the land itself. Our suggestion is that you leave things as they are now (Alternative 3) or run the trail down Wasatch Blvd. where you already have sidewalks and cycling lanes. 6. Response: The current BST on Wasatch Drive is north of the proposed project. Perhaps you mean Wasatch Blvd, which is considered as the No Action Alternative. Any changes to Wasatch Blvd are not under the jurisdiction of the Forest Service. The route on Wasatch Blvd. is a popular route for road cycling and a large portion of the route has been widened and striped to accommodate a bike lane. The route does not provide a realistic recreation opportunity for hikers or mountain bikers. 7. Comment D3: I view it as tragic that the trail has to run on pavement between Emigration and Parley's Canyons. Please do NOT let that happen on the new sections. 7. Response: The EA for Bonneville Shoreline Trail analyzes alternatives with portions not on the pavement in Alternatives 2 and 3. The EA also provides discussion on access routes (road access). The Agency also recognizes that some sections of trail, especially those on private land and outside the Forest Service jurisdiction, may not be constructed for some time or at all. During that time, it is reasonable to expect that there would be a need and continued use of the BST connects/access routes- requiring the need to travel on pavement. 8. Comment D5: If at all possible the grade into and out of Millcreek, Big Cottonwood and Little Cottonwood 8. Response: Trails will be designed following USFS trail construction standards, including average grades of ten percent or less. 9. Comment D8: In the event there are sections where biking is not permitted, there should be alternative routes on streets which will allow one to ride a mountain bike the entire length of the trail. It is extremely important that one be able to ride a bike the entire length of the trail. 9. Response: In Alternatives 2 and 3, mountain bike use would only be permitted in sections that have formal trailhead or access points and the segments are entirely outside of Designated Wilderness (including Parley‘s to Mill Response to Comments 4

Bonneville Shoreline Trail Environmental Assessment

Creek, Ferguson to Little Cottonwood Canyon TH, and possibly Bells to South Fork trailhead if feasible and consistent with Sandy City trails plan (see figure 11 for restrictions). Since each segment has either a trailhead or access point, it would be possible to continue along the current BST connector (Wasatch Blvd) using the city/state/county road system. However, any changes to Wasatch Blvd or other local roads are not under the jurisdiction of the Forest Service. Bike use is permitted for the entire route in Alternative 1. The reality of the proposed alignment of the BST is that the majority of the trail would be closed to bikes due to the Wilderness regulations prohibiting bikes in Designated Wilderness. Based on topography and existing private property developments, locating more segments of the trail outside of Designated Wilderness were not feasible. 10. Comment D12, 19: I would like to say that having only 3 alternatives (one of which is to NOT build the trail) is extremely limiting. If this segment of the trail were only three or four miles, 3 alternatives might be reasonable. As it is, the segment in question is a significant length and travels through many different areas, some completely developed, and others in the process of development. I therefore propose that smaller segments be looked at with alternatives suggested for each of the smaller segments. 10. Response: The EA analyzes three alternatives in detail. Three additional alternatives were considered but dropped from further analysis. Section 2.3 of the EA explains these alternatives and why they were eliminated from detailed analysis. One alternative that was considered and eliminated aligned the entire route on NFS lands. Each segment of the trails was analyzed for consistency with the purpose and need as well as for feasibility. The majority of the alternative trail did not meet the purpose and need, or realistic trail feasibility and was not carried forward through the alternative process. These sections often were substantially higher in elevation, requiring extensive climbing and switchbacks, and were almost exclusively in Designated Wilderness areas. The section of that alternative route that met those criteria became Alternative 3. The alternatives were developed in response to public comment, coordination with local government units such as the Salt Lake County Parks and Recreation Department and to meet the Purpose and Need for the project. 11. Comment H30: I encourage the Forest Service to look closer at other alternate routes for this trail. It is my belief these alternates were not realistically considered in this EA. There are ways to build this trail that fall within the concept of the BST without exposing existing home owners to increased risk of fire, theft vandalism and geological catastrophes. 11. Response: The EA analyzes three alternatives in detail. Three additional alternatives were considered but dropped from further analysis. Section 2.3 of the EA describes these alternatives and why they were eliminated from detailed analysis. The alternatives were developed in response to public comment, coordination with local government units such as the Salt Lake County Parks and Recreation Department, Forest Plan direction and to meet the Purpose and Need for this project. The decision maker feels that these alternatives provide for disclosure of effects for a reasonable range of alternatives as required under NEPA. See also Response # 10. 12. Comment H47: Since the east side of the Salt Lake Valley already has considerable access for recreational hiking, why not spend the resources earmarked for the BST on the west side of the valley? Access to the Oquirrh and Stansbury ranges is extremely limited. True, Kennecott owns much of the Oquirrhs, but Kennecott has been a good supporter of the community, and may be receptive to providing access to some of their property which is not in active mining areas. It is my understanding that there is also public property in the Oquirrhs. Why not develop some of this? Hiking trails could be established in natural drainages in the Oquirrhs without

Response to Comments 5

Bonneville Shoreline Trail Environmental Assessment creating the visual eyesore that the BST would create. 12. Response: The Salt Lake County Alignment Plan for the BST includes trail alignment for the entire Salt Lake County that also includes a trail system on the west bench of the Salt Lake valley along the Oquirrh Mountains that could eventually tie in with the Tooele valley. There are no NFS lands along this segment and thus beyond the scope of this analysis. This analysis process would not preclude local government agencies with jurisdictions for land use in those areas in conjunction with private land owners to move forward with BST trail development in those areas. The BST Committee, a nonprofit group, has been the main force in establishing priorities and obtaining funding for the analysis and construction of segments of the BST in Northern Utah. Local government agencies have also contributed to the process through their respective trails master planning processes. Please see Section 3.5.3 of the EA for an analysis of effects to visual quality of the area including pictures of already constructed portion of the BST. 13. Comment D9, D13, D14, D22, H2, H9, H16, H19, H23, H28, H29, H42, H43, H48, N58, D7, D15, F44: Support for the No Action Alternative. Dedicating the shoulder of Wasatch Boulevard for the BST will save money and aggravation, preserve the foothills, be safer and in turn still get the views that you are seeking. Opposition to alternative 2, Proposed Action. Legal Action will be pursued under Alternative 2. Reasons cited for opposition to Alt 2: Increased crime, increased vandalism, increased traffic, increased trash and noise, decreased property values and quality of life. Trail construction and use will lead to increased erosion and mass wasting and flooding. The trail will scar the mountainside and spoil to views. I would suggest that either the No-Action route be taken for the whole Bonneville Shoreline Trail (BST) or that a new alternative route replace our segment within the Alternative 2 route described in the Preliminary Environmental Assessment (PEA), July 2007 report. An alternative route could easily include using Wasatch Blvd, to connect the Mill Creek Canyon trailhead with the Neff Canyon trailhead, with a variety of roads (including Oakview Dr.) being used to connect Wasatch Blvd. to the Neff Canyon trailhead. 13. Response: The EA considers the effects utilizing Wasatch Boulevard as the BST under the No Action Alternative. Wasatch Boulevard is public roadway and changes to the roadway are not under the jurisdiction of the Forest Service. Potential impacts to crime, vandalism, traffic, trash and noise, property values and quality of life, erosion, flooding and visual quality are addressed in the their respective section of the EA and responded to in detail in the Response to Comments. The EA has been revised to include detailed a discussion on Access Routes from Wasatch Boulevard to each of the Access Points. The Responsible Official will carefully consider your comments in his decision. He may approve an alternative intact, as presented in the EA, or select an alternative that is a combination of elements of various alternatives, including the No-Action Alternative. The Responsible Official must also determine whether the selected alternative is consistent with the WCNF Forest Plan. See also Response # 6. 14. Comment D17, H50, I1, I2, I3, I5, I6, I8, I9, I12, I11, I13, 114, I16, I17, I19, I20, I21, I22 I24, I15, I27, I28, I31,I32, I33, I35 I36, I37, I39, I40, I41, I42, I45, I48, I49, I50, I52, I53, I54, J12, J21, D18: Support of Alternative 2. It encompasses many more miles of trail preservation. I believe it will be something they’ll be grateful about as city elements encroach farther into natural environments. Private property rights must be respected, and reasonable distances from private homes should be designed in to the trail to the extent practicable. But private property rights do not extend to the right to exclude the general public from enjoying the benefit of access to Forest Service land. To protect trails for the use of pedestrians and bicyclists and for the aesthetic and healthful value they

Response to Comments 6

Bonneville Shoreline Trail Environmental Assessment provide for cities where open space is constantly encroached upon cannot be overstated in worth. Well developed hiking trails add a quality of life and opportunity for a healthier lifestyle. Trails enhance the community. This kind of outlet is very important in our increasing crowded urban space. It would be a great resource for hikers, bikers, and other outdoor enthusiasts. It’s a great way to see the beautiful mountains that are so close to where we live, and there are probably some picturesque views of the Salt Lake valley below. I believe that those who would make use of the trail system would bring positive contributions to the areas nearby including litter clean-up and trail maintenance. It will increase the benefit of pre-existing segments of the Bonneville Shoreline Trail by connecting them and creating one uninterrupted trail system. The closeness to the trail of our current residence was one of the largest motivators of us to relocate to our current home. Property owners that are impacted should see this as a huge amenity to their property and encourage as much trail development as possible. Trail in close proximity to private properties can enhance property values. Park City and Snyderville Basin trail systems are a model. The presence of runners, cyclists, walkers, and other ―recreationalists‖ improves security for the neighborhood by providing extra sets of ―eyes and ears‖ in the area. I also cannot imagine that this cadre of persons would be likely to commit acts of crime or vandalism – to the contrary, these are normally the type of people who are respectful stewards of the land. As roads and parks along the Wasatch Front become more crowded, alternative bicycle and recreation areas are needed. There are less intrusive, more cost-effective, and safer alternatives that will still allow the goals of the BST planning organizations to be accomplished. For example, continuing to use Wasatch Boulevard as a segment of the BST is a viable alternative for portions of the BST. Wasatch Boulevard is at or near where Lake Bonneville’s natural shoreline. Using it would be more consistent with the BST Coalition’s goal of building the trail ―on or near the foothill bench generally considered to be the eastern shoreline of ancient Lake Bonneville.‖ Where alternatives to a proposed government action exist which are less intrusive, more cost- effective, and safer than such action, reason and prudence suggest that such alternatives should be chosen. 14. Response: Potential impacts, both positive and negative, to recreation opportunities, crime, vandalism, traffic, trash and noise, property values and quality of life, erosion, flooding and visual quality are addressed in the their respective section of the EA and responded to in detail in the Response to Comments. The EA has been revised to include detailed a discussion on Access Routes from Wasatch Boulevard to each of the Access Points. The Responsible Official will carefully consider your views in his decision. He may approve an alternative intact, as presented in the EA, or select an alternative that is a combination of elements of various alternatives, including the No-Action Alternative. The Responsible Official must also determine whether the selected alternative is consistent with the WCNF Forest Plan direction regarding the Bonneville Shoreline Trail, the Recreation Opportunity Spectrum and the Multiple Use principals guiding the management of National Forest System Lands. 15. Comment D20: The main area that I am interested is the segment running from Parley’s Canyon to the Mount Olympus Trail. I have a number of concerns regarding the proposed Alternatives 2 and 3 (identical for this area) Bicycles currently have newly paved bicycle lanes extending from Parley’s Canyon to the Mount Olympus trail on Wasatch Blvd. 15. Response: Bicycle use of Wasatch Blvd is discussed under the No-Action Alternative in the EA in Section 3.3. Use of

Response to Comments 7

Bonneville Shoreline Trail Environmental Assessment

Bicycles for the other alternatives is also discussed in Section 3.3.

3. General Ecological Resources 16. Comment E3: I am not a land owner in the Mt. Olympus area. I am not worried about decreased property value or invasion of privacy; I am poor and I welcome multitudes. What I do not welcome is the continued molestation of our mountains and their benefactors (plant, animal, insect, and mineral life). 16. Response: Vegetation, wildlife and soil concerns were identified as issues and are analyzed in Chapter 3 17. Comment H38: My understanding of BLM land is to keep it away from development. You are a ranger. Are you not our representative/advocate to keep this land in its natural state - away from public damage? 17. Response: This proposal addresses NFS land, not BLM lands, though both the BLM and the Forest Service are federal land management agencies. Congress established the Forest Service in 1905 to provide quality water and timber for the Nation's benefit. Over the years, the public has expanded the list of what they want from national forests and grasslands. Congress responded by directing the Forest Service to manage national forests for additional multiple uses and benefits and for the sustained yield of renewable resources such as water, forage, wildlife, wood, and recreation. Multiple use means managing resources under the best combination of uses to benefit the American people while ensuring the productivity of the land and protecting the quality of the environment. For more information about the Forest Service‘s mission please visit http://www.fs.fed.us/aboutus/mission.shtml 18. Comment F1, F2, H34, J26: user created trails The trail itself would leave a large, visible, and erosion-prone scar. Perhaps more importantly, unauthorized side trails would lead to even more erosion and damage (witness the many unsightly side trails around the BST near the University of Utah School of Medicine). I realize that such trails would be discouraged and that most of the users of the proposed trail would be considerate and law-abiding. My concern is with those who are not. Why state that "Existing use and proliferation of user-created trails could increase causing a potential increase in landslide and slope failures" (p. 3-83) without recognizing that additional user-created trails (UCT) could also arise once the trail is created? The EA lacks a description of the assumptions used for the UCT. What methodology was used to understand current use and to forecast future use of UCT? Why is it assumed that a few UCT will cause more damage than the larger footprint of the constructed BST, and further assumed that no additional UCT will be created once the BST is in use? Tables 27 and 9 both omit that UCT would exist in both Alternatives 2 and 3. And they are omitted for many Issues: Socio-Economic Resources; Fire; Archaeological, Cultural, and Historic Resources; Wetlands; Riparian Areas; etc. More documentation is necessary to assess the quality of the UCT comments in the EA. By adding the trail you increase vastly the number of people who will now have access to the mountain side. The increased number of hikers will increase the number of user created trails. If user created trails are the evil as described in alternate 1 it should also be the same evil in alternate 2 and 3. The adverse events documented for each of the three alternatives appear to have been written with a bias toward action. While I feel there should be some building of trails, there should also be complete transparency. In each area described, adverse events under Alternative 1 (No Action) indicate that continued

Response to Comments 8

Bonneville Shoreline Trail Environmental Assessment development and increased human activity will lead to more small trails scattered through the areas. While this is true, it will also happen with Alternative 2 and 3 but this was not mentioned for them. it is also true that some of the areas along the proposed alignment have been completely developed. Given this fact, those areas will not have increased human activity and it should not be listed as an adverse event for those areas. 18. Response: Section 3.5 of the EA discusses the effects of the proposed action and alternatives to Scenery Management and Aesthetics. It has been revised to include analyses of trail profiles, particularly on steeper slopes, and describes necessary trail design features to reduce the size and improve the stability of cut slopes resulting from construction of the trail. Soil erosion is analyzed in depth in Section 3.6.3 of the EA. The potential for erosion was found to be highest during construction of the trail, and during infrequent (30 year return period) high magnitude storm events. The majority of storm events most likely to occur would produce little or no erosion. Best Management Practices, Forest Service Manual and Handbook supplements for trail construction and the protection of soil and water resource, as well as numerous guidelines from the WCNF Plan will be implemented as part of the construction design. These practices will reduce the risk for soil erosion during construction. Appropriate mitigation measures will be employed to reduce to the highest degree possible, the effects of erosion on aesthetics and the soil. Proper implementation of these mitigation measures, coupled with a reduction in UCT, leaves the cumulative effects as minimal. It has not been assumed that no UCT will be created after the proposed trail has been constructed, and it has not been assumed that a few UCT will cause more damage than the larger footprint of the constructed BST. It was only assumed that the construction of the proposed trail in this area will reduce the number of UCT in the area. Section 3.3 (recreation ) has also been revised to address the potential effects of UCTs. 19. Comment F2: The Environmental Assessment (EA) may not be enough analysis. Since geological issues have not been assessed adequately, an Environmental Impact Statement needs to be requested. For example, the EA neglected to discuss the issue of Neff Canyon being in a flood plain. And in our segment of concern (Segment 5 of the AP), part of the EA says the risk is severe, while another part says it is minimal. Figure 25 and Table 26 in PEA list our backyard as BEG (Bradshaw-Agassiz association) with Percent Slope of 40-70 and Severe Hazard of Erosion. Yet the write-up on pages 3-77 through 3-82 summarizes the cumulative impact as minimal. How much of the geology was actually assessed? Did they assess our property where the Alternative 2 route is proposed? To simply assume that "Mitigation measures would reduce the probability of landslide and slope failure" (p. 3-83) is not sufficient analysis. 19. Response: While Section 3.6.1 of the EA acknowledges that the hazard of erosion on these steep slopes is high (severe), the detailed analysis of soil erosion potential presented in Section 3.6.3 of the EA for construction of a trail that meets design criteria designed to control water drainage and runoff from the trail surface revealed the effects to be minimal. Section 3.6.4 of the EA references surveys and reports published by the Utah Geological Survey (UGS) that describe and assess the hazards of existing landslides within the entire Project Area. This section discloses that near the area containing the BEG soil type, just north of Neff‘s Canyon, the BST alignment proposed in Alternative 2 would cross one deep seated, not historically active, landslide. The UGS publication characterizes the hazard of deep seated slides as being chiefly to the area on and immediately surrounding the slide. This section proposes site specific trail design standards to assist in reducing landslide and slope failure hazards that might be created by trail construction within this deposit. In particular, trail design would be modified to assure that runoff is not concentrated on the trail crossing of the slide deposit, but rather dispersed from the trail surface, using trail drainage structures, at multiple locations. To better address your concern, Section 2.2.3 of the EA has been revised to incorporate this design standard for this

Response to Comments 9

Bonneville Shoreline Trail Environmental Assessment area and others with similar landslide hazard.

4. Soils 20. Comment F6: To prevent erosion, I recommend considering sealing the trail. Such a trail is in place in Edmonton, Alberta (a part of the cross-Canada trail) it is very heavily used as it goes through the city, is sealed, and its care includes snow clearance in the winter. Finishing the surface of the trail would expand its use to families and more elderly walkers. 20. Response: The BST will be constructed following existing USFS design standards. The USFS trail design standards specifies that native trail surfaces be used for constructing the Bonneville Shoreline Trail on Forest Service lands. Soil erosion is analyzed in Section 3.6.3 of the EA. The potential for erosion was found to be highest during construction of the trail, and during infrequent (30 year return period) high magnitude storm events. The majority of storm events most likely to occur would produce little or no erosion. Best Management Practices, Forest Service Manual and Handbook supplements for trail construction and the protection of soil and water resource, as well as numerous guidelines from the WCNF Plan will be implemented as part of the construction design. These practices will reduce the risk for soil erosion during construction. 21. Comment F4, F7, F8, F10, F13, F25, F39, M4, M34: The area of the trail above our home has an extreme slope. To construct a trail will require cutting into the side hill and create scaring of the slope. The potential of dislodging boulders during construction is great with the potential of significant property damage. Once construction is completed, individuals using the trail have the potential to dislodge boulders, either accidentally or on purpose, with the same potential result to the property owners. There are numerous boulders on these hills and we have already experienced problems with dislodged boulders with significant property damage. With thousands of people on the trail, this is an accident waiting to happen. The proposed trail traverses steep slopes strewn with medium to large sized boulders, many well over 100 pounds, both on the surface and Sub-surface. Although some rock fall has been the result of the natural dynamics of slope systems, occasional hikers and climbers treading the slopes have caused a greater amount. During construction hundreds (literally) of rocks will be unearthed. Those boulders would have to be removed, at considerable expense, or stabilized on the hill. Even then rocks would risk being dislodged by any use of the trail. There is nothing on the slopes to stop a rolling rock. Such an occurrence would cause serious, even fatal, injury. Deer trails on this slope indicate that most of these rocks are dislodged by deer. We have considered this a small price to pay, but we are concerned that the problem may become severe as the trail construction begins. We have several concerns about the trail crossing private property from Millcreek Canyon south above Parkview Drive to Neff’s Canyon in the designated location: We are concerned about safety issues associated with a trail crossing a steep slope particularly given the unconsolidated nature of the limestones and shales upon which the trail would of necessity be constructed. Some of these slopes range from 50 to 70% and pose a risk of sloughing rock and debris to property owners below. In the Hughes/Canyon Cove area the Bonneville Shoreline rock fall hazard is real; geological analysis of the area revealed the boulder fall to be at a velocity of 35 feet/second with an impact force of 10,000 pounds per square foot. The Hughes/Canyon Cove hillside soil analysis revealed it to be the composed of silt.

Response to Comments 10

Bonneville Shoreline Trail Environmental Assessment

The terrain above Mile High Drive is steep. Equipment, digging, cutting, and people, will cause unnecessary instability to this slope. The instability will be in the form of possible boulder or rock slides, erosion and mud slides. Some years ago, a boulder crashed into a home on Mile High. 21. Response: We agree that, where appropriate, rocks loosened or destabilized by construction or use of the trail would need to be stabilized in some fashion. Section 2.2.3 of the EA has been revised to add trail design considerations that would address your comment. Section 3.5 of the EA discusses the effects of the proposed action and alternatives to Scenery Management and Aesthetics. It has been revised to include analyses of trail profiles, particularly on steeper slopes, and describes necessary trail design features to reduce the size and improve the stability of cut slopes resulting from construction of the trail. Slope gradients encountered by the BST alternative locations, and associated erosion hazard, are discussed in Section 3.6.2 of the EA. A slope analysis report referenced in this section indicated that much of the trail alignments are on steep slopes with high erosion hazards. However, analysis in this same section indicated that predicted soil erosion rates from the trail itself would be very small, due to trail design features that limit average constructed gradients to less than 10%. Trail segments crossing over or in close proximity to known, identified landslide areas will receive site specific trail design and location features to reduce the potential of slumping, sloughing, and other forms of slope failure. Landslides and slope failure effects are discussed in Section 3.6.4 of the EA. 22. Comment M68: There is a danger to the Prospector Hills neighborhood because of potential debris and/or rocks falling into our properties while building the trail. Trail shouldn’t be more than 2’ wide vs. 3’ proposed. 22. Response: We agree that, where appropriate, rocks loosened or destabilized by construction or use of the trail would need to be stabilized in some fashion. Section 2.2.3 of the EA has been revised to add trail design considerations that would address your comment. 23. Comment F34: Segment 3 of Alternative 2 all rocks would need to be removed or securely stabilized. This requires skillful construction expertise and techniques usually not available using volunteer labor. 23. Response: We agree that, where appropriate, rocks loosened or destabilized by construction or use of the trail would need to be stabilized in some fashion. Section 2.2.3 of the EA has been revised to add trail design considerations that would address your comment. The EA references Forest Service Handbook 2309.18. Section 3.23d provides guidance on training and supervision of volunteer trail construction crews to assure quality control. 24. Comment E1, F11, F23: Soils and Erosion – The discussion in section 2.4 contradicts information compiled by sister agencies like the Natural Resource Conservation Service, the Utah Geological Division, and even the County. This trail segment is located on soils rated as ―severe‖ for erosion and in a high probability area for mass wasting, yet, in the face of recent past landslides on similar soils, geology, and slopes along the Wasatch Front, the EA shrugs these issues off. Why? Experts from these or other agencies have a different opinion and data than that discussed in your analysis. None of these agencies who have subject matter experts are on your list of consulted agencies. Why not?

Response to Comments 11

Bonneville Shoreline Trail Environmental Assessment

What happens if your promise of mitigation fails or if your assumption that there would be ―minor adverse effect‖ is wrong? In the face of significant scientific evidence how can you make this statement? This subject needs intensive further inventory and considerable more analysis that is simply not provided by this document. 24. Response: While the EA references information on soils and geology provided by the Natural Resources Conservation Service (NRCS) and Utah Geological Survey (UGS), findings presented in the analysis in no way contradict the source documents. The EA acknowledges the existence and hazards of landslides in the project area by referencing documents published by the UGS. The EA also acknowledges NRCS soil survey interpretations that soil erosion hazard increases with increasing slope steepness, and that trail construction potential is more difficult and costly due to the limitations of steep slopes and rocky soils. Because these references are largely silent on the effects of trail construction on soil erosion and slope stability Sections 3.6.3 and 3.6.4 of the EA present a more detailed analysis of these effects. Like you, the agencies referred to in your comment have been given the opportunity to comment on the EA. None have submitted opinions or data that differ from the conclusions drawn in the analysis presented in Sections 3.6.1 through 3.6.5of the EA. The conclusions of the analysis in these sections are supported by the best science available at this time. Design features and mitigation measures recommended in the analysis that are included in the official Decision Notice for the project, are a required part of project implementation. See also response to #19. 25. Comment F17, F30: The document raises geological issues with cutting into the side of the mountain above our homes. These are brushed off as being minor concerns. There is a very real possibility of erosion and land movement because of the significant cutback required for the construction of the trail. 25. Response: Slope gradients encountered by the BST alternative locations, and associated erosion hazard, are discussed in Section 3.6.2. A slope analysis report referenced in this section indicated that much of the trail alignments are on steep slopes with high erosion hazards. However, analysis in this same section indicated that predicted soil erosion rates from the trail itself would be very small, due to trail design features that limit average constructed gradients to less than 10%. Trail segments crossing over or in close proximity to known, identified landslide areas will receive site specific trail design and location features to reduce the potential of slumping, sloughing, and other forms of slope failure. Landslides and slope failure effects are discussed in Section 3.6.4 of the EA. Section 3.5 of the EA discusses the effects of the proposed action and alternatives to Scenery Management and Aesthetics. It has been revised to include analyses of trail profiles, particularly on steeper slopes, and describes necessary trail design features to reduce the size and improve the stability of cut slopes resulting from construction of the trail. 26. Comment F20: This hillside is steep. We hired an environmental reclamation engineer already to give us an assessment of this mountain, since BSA simply does not care about the impact of cutting into a 50%+ grade slope (that is a large cut- I will send you this report). I am shocked when they look at me and say "We just make the trail, lady--you maintain it." This trail is not environmentally feasible on this mountain. 26. Response: Section 3.5 of the EA discusses the effects of the proposed action and alternatives to Scenery Management and Aesthetics. It has been revised to include analyses of trail profiles, particularly on steeper slopes, and describes necessary trail design features to reduce the size and improve the stability of cut slopes resulting

Response to Comments 12

Bonneville Shoreline Trail Environmental Assessment from construction of the trail. 27. Comment F26: The EA focuses primarily on erosion mitigation efforts during the construction of the trail, public use of the Mill Creek-Neff’s Canyon Segment following construction would result in increased levels of erosion. [Given] the grade of the land in the Mt. Olympus area, soil quality, and other factors, there is a heightened risk of flooding and landslides that would be created by the trail. 27. Response: Trail segments crossing over or in close proximity to known, identified landslide areas will receive site specific trail design and location features to reduce the potential of slumping, sloughing, and other forms of slope failure. Landslides and slope failure effects are discussed in Section 3.6.4. 28. Comment F31: According to the EA this area of the trail is classified by the BEG with percent slope of 40-70 and Severe Hazard of Erosion. The EA in the comparison section states that this is only a minor, adverse affect. Cutting into a slope of this degree to build a trail pad will open soil downhill from the trail to unseen levels of moisture. This will greatly increase the risk of erosion, landslides and slope failures. 28. Response: Soil erosion is analyzed in depth in Section 3.6.3 of the EA. The potential for erosion for the BEG soil type was found to be highest during construction of the trail, and during infrequent (30 year return period) high magnitude storm events. The majority of storm events most likely to occur would produce little or no sediment. Best Management Practices, Forest Service Manual and Handbook supplements for trail construction and the protection of soil and water resource, as well as numerous guidelines from the WCNF Plan will be implemented as part of the construction design. These practices will reduce the risk for sediment transport during construction. Trail segments crossing over or in close proximity to known, identified landslide areas will receive site specific trail design and location features to reduce the potential of slumping, sloughing, and other forms of slope failure. Landslides and slope failure effects are discussed in Section 3.6.4. Slope gradients encountered by the BST alternative locations, and associated erosion hazard, are discussed in Section 3.6.2. A slope analysis report referenced in this section indicated that much of the trail alignments are on steep slopes with high erosion hazards. However, analysis in this same section indicated that predicted soil erosion rates from the trail itself would be very small, due to trail design features that limit average constructed gradients to less than 10%. 29. Comment F35: Construction of the Trail on the route of the ―Z‖ trail will change the pattern of water runoff from the trail and will probably cause serious landslides or movement on certain properties on Thousand Oaks Circle and Jupiter Drive. 29. Response: Trail segments crossing over or in close proximity to known, identified landslide areas will receive site specific trail design and location features to reduce the potential of slumping, sloughing, and other forms of slope failure. Landslides and slope failure effects are discussed in Section 3.6.4. Also, note the section above the ―Z‖ trail is located on private land and the Forest Service has no authority to authorize any section of trail on private land. 30. Comment F18: In the Mt. Olympus Cove area, there is no natural shoreline or existing suggestion of a level path to use. Carving an artificial trail into the side of a steep mountain just for the sake of continuing a trail from point A

Response to Comments 13

Bonneville Shoreline Trail Environmental Assessment to point B is NOT in keeping with the larger vision of the BST as a natural trail integrated with the existing geographic feature of an ancient lake shore. Cutting a deep wedge into a steep mountain is not only artificial and aesthetically unpleasant; it would also make the area vulnerable to land and mudslides. 30. Response: As described in section 1.1.3 of the EA, our intent was to locate the trail on or near the shoreline of ancient Lake Bonneville though not necessarily to locate it precisely along the existing geographic feature. Our reviews of visual effects are they will be minimal and maintain aesthetics of the landscape. Mudflows, as a form of shallow seated landslides, are analyzed in Section 3.6.4 of the EA. None of the proposed BST locations cross over or near any known, identified shallow seated landslides. Trail segments crossing over or in close proximity to known, identified deep seated landslide areas will receive site specific trail design and location features to reduce the potential of slumping, sloughing, and other forms of slope failure. 31. Comment F16, F21: The lower the route on the Wasatch Mountain Range the trail is built, the less there will be problems with erosion and trail maintenance. Steep up- and down-hill sections experience more wear from mountain bikes spinning or skidding their wheels. Alternative 3, which puts the trail higher on the mountainside, requires greater elevation variations and introduce greater potential for erosion. 31. Response: The effects of the proposed BST location and its alternatives on soil erosion are discussed in Section 3.6.3 of the EA. Findings in this section indicate that although the location of the trail under alternative 3 is on slightly steeper slopes, predicted erosion rates for the two alternatives are similar. It should be noted that bikes would be prohibited in most sections of the proposed trail due to the Wilderness designation. 32. Comment F36: Trail design and construction are mentioned in the document but dismissed. Standard trail design has varying trail widths dependant on wilderness issues. The document also states that all cuts will be tapered to a 45 degree slope. Many of the slopes, especially on the segment between Mill Creek and Neff’s Canyon, are greater than 45 degrees. There will be significant environmental and economic impacts caused by trail building on these slopes. These impacts include building trails on soils determined to be ―severe‖ for erosion potential in the preliminary EA and have a high risk for mass wasting (Utah Geological Division). Thin rocky soils are poor candidates for successful restoration and are at very high risk for the invasion of cheat grass. An engineering report showing trail profiles and a long-term restoration plan must be included as an addendums for adequate analysis of all potential impacts. 32. Response: Section 3.5 discusses the effects of the proposed action and alternatives to Scenery Management and Aesthetics. It has been revised to include analyses of trail profiles, particularly on steeper slopes, and describes necessary trail design features to ensure successful revegetation of cut and fill slopes created during construction of the trail. Trail segments crossing over or in close proximity to known, identified landslide areas will receive site specific trail design and location features to reduce the potential of slumping, sloughing, and other forms of slope failure. Landslides and slope failure effects are discussed in Section 3.6.4 of the EA. Slope gradients encountered by the BST alternative locations, and associated erosion hazard, are discussed in Section 3.6.2 of the EA. A slope analysis report referenced in this section indicated that much of the trail alignments are on steep slopes with high erosion hazards. However, analysis in this same section indicated that predicted soil erosion rates from the trail itself would be very small, due to trail design features that limit average constructed gradients to less than 10%.

Response to Comments 14

Bonneville Shoreline Trail Environmental Assessment

33. Comment F37, F40: BST will create soil erosion problems along areas that are covered with historic landslides. It may also increase flood danger. 33. Response: Trail segments crossing over or in close proximity to known, identified landslide areas will receive site specific trail design and location features to reduce the potential of slumping, sloughing, and other forms of slope failure. Landslides and slope failure effects are discussed in Section 3.6.4 of the EA. 34. Comment F41: A three feet wide is too much and the ten feet wide you also suggest in places is absurd. This will only increase the erosion problems. You discuss landslides and slope failures. This is not surprising when you look at how steep the hillside is. 34. Response: The proposed trail width for the BST is 36‖, and 24‖ in designated Wilderness areas. The ten feet is for clearing width, to trail surface. Trail segments crossing over or in close proximity to known, identified landslide areas will receive site specific trail design and location features to reduce the potential of slumping, sloughing, and other forms of slope failure. Landslides and slope failure effects are discussed in Section 3.6.4. Slope gradients encountered by the BST alternative locations, and associated erosion hazard, are discussed in Sections 3.6.2 and 3.6.3 of the EA. A slope analysis report referenced in this section indicated that much of the trail alignments are on steep slopes with high erosion hazards. However, analysis in this same section indicated that predicted soil erosion rates from the trail itself would be very small, due to trail design features that limit average constructed gradients to less than 10%. 35. Comment F43: In the EA, you discuss that most erosive soils are on slopes greater than 30%. My guess is most of the trail will have this challenge. 35. Response: Slope gradients encountered by the BST alternative locations, and associated erosion hazard, are discussed in Section 3.6.2. A slope analysis report referenced in this section indicated that much of the trail alignments are on steep slopes with high erosion hazards. However, analysis in this same section indicated that predicted soil erosion rates from the trail itself would be very small, due to trail design features that limit average constructed gradients to less than 10%. 36. Comment F45: The creation of a trail will enable rain water to more readily seep below the surface and increase the potential for landslides. This problem could become even more severe if the current 7 year drought turns into a 7 year downpour. 36. Response: Trail segments crossing over or in close proximity to known, identified landslide areas will receive site specific trail design and location features to reduce the potential of slumping, sloughing, and other forms of slope failure. Landslides and slope failure effects are discussed in Section 3.6.4. 37. Comment F47: Page 2-24 lists trail design considerations to prevent erosion, including not allowing berms that prevent water from flowing across the trail. Trails designed and maintained as described will not cause additional erosion. No where in your document do you list the maintenance that will be performed to prevent erosion. Many

Response to Comments 15

Bonneville Shoreline Trail Environmental Assessment places in Segment 2 are on steep hillside without trees to hide the trails, and as such erosion caused by unmaintained trails will be clearly visible. 37. Response: The trail design considerations have been revised in Section 2.2.4 that address erosion control and cut slope stabilizations. Section 2.2.2 identifies the need to establish a multi agency agreement to address trail maintenance across the entire trail. The trail segments authorized and constructed on NFS lands, would be subject to the same trail maintenance schedule as all other trails and would be based on priorities across the District. Generally, trail maintenance on NFS system trails consists of trail inventories to help define priorities and erosion control, slope stabilization. User-created trails and switchback cut rehabilitation, and trail and clearing area width maintenance. 38. Comment F22: The design criteria for the slope of the new trail to ―average grades less than 10 percent‖ (Section 1.3) needs to be refined. For a trail that goes up a mountain, this slope grade may be acceptable. However this trail is, by definition, supposed to follow a shoreline and therefore be relatively horizontal. If half of the entire new trail is flat this would mean that the other half could be a slope of 20% and the trail would still be less than 10% on the average. It would be far more meaningful to require that each trail segment from trailhead to trailhead be of an average slope of less than 10%. 38. Response: Section 2.2.2 and Figure 9 describe trail design criteria have been revised and address slope grade and length of grade segments. In calculating the trail to determine a ten percent average, short segments will be measured, not the entire trail. 39. Comment G8: Your trail drainage design could not help to divert great water flows away from this natural drainage without great erosion from the trail itself and the cut above the trail and the spoil fill on the downhill side of the trail. Past rain events are predictive that great flows of mud and muddy water would come down and scar the hillside and flow down the back yards, homes and swimming pools along the eastside of Parkview Drive. 39. Response: Soil erosion is analyzed in depth in Section 3.6.3 of the EA. The risk of sediment transport is highest during construction of the trail, and during infrequent (30 year return period) high magnitude storm events. The majority of storm events most likely to occur would produce little or no sediment.. Best Management Practices, Forest Service Manual and Handbook supplements for trail construction and the protection of soil and water resource, as well as numerous guidelines from the WCNF Plan will be implemented as part of the construction design. These practices will reduce the risk for sediment transport during construction. As you have stated, erosion is occurring even prior to trail construction. Proper trail design and maintenance as wells as rehabilitation of user created trails is expected to result in minor adverse impact to soils. Mudflows, as a form of shallow seated landslides, are analyzed in Section 3.6.4 of the EA. None of the proposed BST locations cross over or near any known, identified shallow seated landslides. Trail segments crossing over or in close proximity to known, identified deep seated landslide areas will receive site specific trail design and location features to reduce the potential of slumping, sloughing, and other forms of slope failure. Proposed trails segments located east of Parkview Lane are located primarily on private land. The Forest Service has no authority to authorize trail segments on private land.

Response to Comments 16

Bonneville Shoreline Trail Environmental Assessment

5. Water Resources 40. Comment F2, G1: A FEMA Flood Plain has been established coming from Neff’s Canyon through the neighborhoods of Mount Olympus. There is been much discussion about the possibility and need to build a diversion dam in the mouth of the canyon. That would destroy any reasonable use of a trail through that location. If a 100 year flood were to occur all trail locations would be wiped out on the face of the hills. 40. Response: In accordance with EO 11988, floodplain maps were reviewed to determine if the proposed action is located in or would affect a 100 year floodplain. Section 3.7.6 of the EA details the findings of that review. No new trail construction is proposed within the 100 year floodplain. Any proposal to construct a detention basin near in Neffs Canyon on NFS lands would need to go through its own environmental review, consistent with NEPA, and address potential impacts to the BST as well as other resource concerns. 41. Comment G2: The EA should mention that Millcreek Canyon may be designated as protected watershed in the future. Restriction and rules applicable to existing protected watersheds would apply to Millcreek Canyon if designated. 41. Response: If Millcreek Canyon is designated as a protected watershed, the applicable restrictions and rules would apply to all activities within the watershed, including use of the trail. 42. Comment G3, G5, G6, G12: I note that the proposed Bonneville Shoreline Train Alignment doesn't seem to address any issues regarding drinking water source protection zones for ground water sources (wells and springs). Portions of the trail in many locations cross protection zones and in some instances are extremely close to springs currently serving as public water sources. The Forest Service is considered a partner in these protection activities (see https://www.denix.osd.mil/denix/Public/News/OSD/Water/water2.html). At the mouth of Mill Creek Canyon; the proposed trail route is a short distance above these springs including Upper Boundary Springs which provides a culinary water source to the Boundary Springs Water Company and to Salt Lake City Public Utilities. Domestic animal waste and other activities introduced by trail usage would have a detrimental effect on water quality at this spring. The EA must address what measure will be implemented to insure that there will be no degradation of water quality at this critical source. 42. Response: The effects of the alternatives on public water supplies are discussed in Section 3.7.3 of the EA. The laws, regulations and guidelines that regulate activities in protected watersheds are also described in this section. Section 3.7.4 (Riparian Areas) discusses the laws, regulations and guidelines for maintaining functioning riparian areas that reduce the potential for degradation of surface water from overland flow of contaminants and sediment. Section 6.1 Appendix A, contains additional direction specific to the maintenance of riparian areas for the protection of water quality and aquatic health. 43. Comment G7: For new sections of trail proposed to enter into Salt Lake City designated watershed we would like to see signage installed to the City’s ―Keep it Pure‖ message, size, format and design. 43. Response: Thank you for your suggestion and for your concern over maintaining the health of the public water supply. All of the alternatives include mitigation measures for directional, interpretive, educational, and regulatory

Response to Comments 17

Bonneville Shoreline Trail Environmental Assessment signage. Your comments will be considered in the final design of a signage plan. 44. Comment G8: Your trail drainage design could not help to divert great water flows away from this natural drainage without great erosion from the trail itself and the cut above the trail and the spoil fill on the downhill side of the trail. Past rain events are predictive that great flows of mud and muddy water would come down and scar the hillside and flow down the back yards, homes and swimming pools along the eastside of Parkview Drive. 44. Response: Water flows and soil erosion are analyzed in depth in Section 3.6 of the EA. The risk of sediment transport is highest during construction of the trail. Design Considerations, BMPs, mitigation measures, Forest Service Manual and Handbook supplements for trail construction and the protection of soil and water resource, as well as numerous guidelines from the WCNF Plan will be implemented as part of the construction design. These practices will reduce the risk for sediment transport during construction. As you have stated, erosion is occurring even prior to trail construction. Proper trail design and maintenance as wells as rehabilitation of user created trails is expected to result in minor adverse impact to soils. See also response to #39. 45. Comment G10: This usage will also damage and compromise the water-shed area. 45. Response: Watershed resources are addressed in the EA in Section 3.7. 46. Comment G11: Figure 26 showing the watershed areas is not accurate. When I was on the Sandy City Water Quality Committee, as I recall, all of the canyons and trails north of Hidden Valley Park (big Willow Canyon) are considered watershed, not as you indicate. With this being watershed, trail use needs to be monitored; not something the Forest Service seems able to do. 46. Response: You are correct that Big Willow Canyon is part of the Sandy City watershed. The engineering manager for the Sandy City Department of Utilities stated that water from the five canyons south of Bells Canyon is collected by the Jordan Valley Water Conservancy District for culinary use. The five canyons are Middle Fork Dry Creek, South Fork Dry Creek, Rock Mouth Canyon, Big Willow Creek, and Little Willow Creek. This information has been added to the EA. Trail and other forest uses in protected watershed areas are patrolled and monitored by Forest Service backcountry rangers. Salt Lake City Public Utilities has for the past ten years provided financial support to the Forest Service to hire three to four rangers each summer to patrol and enforce watershed regulations. The Forest Service has also had discussion with Sandy City for a similar type of agreement for Bells Canyon. The Forest Service and City recently entered into a new five–year agreement to continue the partnership and Sandy City has increased their signing, patrol, and enforcement of their watershed regulations in the Bells Canyon area. 47. Comment L1, M42, M44: security of water supply Several sections of the trail and connectors to the trail are near existing water storage sites and other water supply facilities. These facilities include, but are not limited to, the Ferguson Reservoir addressed at 7743 South Timberline Drive, the Dry Hollow Reservoir near the bottom of Big Cottonwood Canyon addressed at 3931 East Big Cottonwood Canyon Road, the Granite Oaks and Telford Reservoirs near the mouth of Little Cottonwood Canyon addressed at 9311 South North Little Cottonwood Canyon Drive, the Canyon Cove High Reservoir addressed at 6311 South Crestmount Drive, the White Reservoir addressed at 3300 East 4300 South and the Teton Reservoirs addressed at 3308 South Teton Drive. The EA must assess the security issues

Response to Comments 18

Bonneville Shoreline Trail Environmental Assessment introduced by inviting the public near these facilities and present what measure will be implemented to protect these facilities. 47. Response: Security at public water facilities is maintained by the Salt Lake City Department of Public Utilities. The Dept. hired a private security consultant in 1999 to complete a Security Plan and an Emergency Operations Plan for the Department. This plan was completed and implemented in 2000 and is continually being reviewed and updated as needed. The plan includes 24 hour patrolling of water facilities, security hardware, increased surveillance, and increased water quality monitoring. More information on water facility security can be found at: http://www.slcgov.com/utilities/newsevents/news2001/news1242001.htm or by contacting the Dept. of Public Utilities directly. Each of the noted water storage facilities is currently accessible via some form of access route for their ongoing maintenance and servicing. The security effects of providing potential additional access to these sites are similar to those discussed for other private residences in the EA in Section 3.11

6. Process (Comments Referring to Scoping or NEPA Process) 48. Comment J1: vote Please give the public, including the taxpayers on the west side of the valley, an opportunity to vote on the feasibility and necessity of it. 48. Response: The decision to be made by the Forest Service is for only Forest Service lands, not local or state lands, and therefore is not paid through Salt Lake county taxes, but federal funds. Contact your Salt Lake County council for concerns about trail building on county lands. The decision to construct any new trail on NFS lands and trailheads will be made by the Responsible Official. In this case the Responsible Official is the Forest Supervisor of the Uinta-Wasatch-Cache National Forest and the decision is based on the review of the analysis in the EA, not on a vote of public comments, though public comments provide valuable information for the analysis process. 49. Comment J2, J24, J29, J32, S72: public notification The Forest Service has not met the legal requirements within the regulations promulgated for NEPA. Unfortunately the majority of the public is unaware of their rights to comment and participate in the process unless they read classified ads on a daily basis. The Forest Service within their commitment to empower the public must go beyond the legal minimums to inform the community and insure that as many voices as possible can be heard. Community based planning must be transparent and inclusive. The Forest Service completed the legal minimum for this document but failed to seriously inform and engage the public. This gives the appearance of collusion (with special interest groups particularly those who have a financial stake in the proposed action) and reinforces the paradigm that government operates in a vacuum without regard for the needs of the people. There was little effort other than placing a notice in the paper to advise the public that a trail is coming. No letter was provided to me to let me know there would be a trail within a couple of hundred feet of my home. If it was truly the desire to have public input then the public should have been notified in a better way. I recently attended a community council meeting where this action was discussed. Most of the community members and Law Enforcement officials in attendance were surprised and upset that they had not heard about the proposal.

Response to Comments 19

Bonneville Shoreline Trail Environmental Assessment

49. Response: We appreciate your comment; the public involvement process has been addressed in the EA under Section 1.5. The Forest Service has encouraged public involvement from the beginning, through a scoping comment period and holding a public meeting. 354 individuals commented during scoping and 66 persons attended the public meeting. The process has also raised substantial media attention, including a number of newspaper articles and television interviews. 50. Comment J3: comments not reflected The findings in the Preliminary EA do not seriously reflect comments – especially those made concerning private property rights, wildlife, trail construction, safety, invasive species, and slope stability made in prior scoping meetings. Many of the findings from analysis in the EA do not reflect current science and professional opinion as expressed in comments made during scoping. Who made the decision to include or exclude comments? Why were comments so difficult to find? How can an interested party (with standing) without intensive computer skills navigate your very complicated web site? 50. Response: All comments from public meetings and scoping were considered—there were no comments excluded from consideration in the scoping process including late responses. Section 1.6 lists the issues that were raised during scoping. It includes impacts on private property values, and private property impacts, wildlife impact, trail design, night lighting, geologic and soil concerns. Only trail design, and night lighting were dismissed from further analysis. Section 1.6.1 gives the rationale for why those issues were not retained. The EA uses current science as available at the time of writing. See references cited in Chapter 5. Comments from scoping can be reviewed at the Salt Lake Ranger District. 51. Comment J5: Section .1.2 of the document says: ―Salt Lake County prepared an alignment plan for the BST and presented it to stakeholders on September 12, 2004 and at a public open house on September 25, 2004. Comments from those meetings were considered and appropriate revisions were made.‖ Who made the decision on what ―appropriate revisions‖ would be? Who were the stakeholders? Why were representative groups from the community, especially potentially impacted landowners, not invited to participate in this process? 51. Response: Section 1.2 refers to Salt Lake County‘s process for accepting the BST plan that was completed prior to the Forest Service proposal to implement the trail plan. The commenter‘s questions on that process are outside of Forest Service jurisdiction and outside the scope of this analysis; though a similar process of public involvement is required under NEPA for this project. This EA has included public comments in identifying issues for analysis. Comments made during scoping were reviewed and considered by an interdisciplinary team of Forest Service employees listed in 4.1.1. All members of the public were invited to attend the open house and submit comments. See also response #49. 52. Comment J6: Description of the location of the Segment 1 of the proposed Alternative 2 is confusing (Page 2- 5, Fig 3). The document cites Crestwood Gulch, which is not a familiar area even for the local residents. It is better to have more magnified figures for the location of the proposed trail segments included in the document. 52. Response: The narrative description of the proposed trail route in the EA borrows from the Alignment Plan prepared by Salt Lake County. The intent of the description is to provide detailed information and utilized the names for a number of drainages and ridges that are not common or shown on USGS topographical maps. The intent was meant to provide additional information, not confuse. We apologize for any confusion; though believe

Response to Comments 20

Bonneville Shoreline Trail Environmental Assessment that between the narrative description and the associated maps, the reader has the information available to provide meaningful understanding and comments on the trail alignment. 53. Comment J7, J34, J37: public meeting I request that the Forest Service hold an additional public meeting to answer questions about the Environmental Assessment that have not yet been adequately answered. 53. Response: Section 1.6 of the EA describes the public involvement opportunities for this process and believes they were appropriate and adequate. Contact individuals were identified on the scoping notices and at the public meetings and it was clearly identified that the public could contact the Forest Service for additional information. 54. Comment J8: legal notice I need to know the date in which the Salt Lake Tribune printed the Legal Notice. 54. Response: The Legal Notice was published in the Salt Lake Tribune on 7/14/07. 55. Comment J10, S57: contact of landowners; Comment J14: error correction Did the Forest Service contact landowners who own property on the trail as identified in the Proposed Action (1.3) to ask either their permission to trespass or for them to participate? Why were adjacent landowners and other interested parties not invited to ―walk‖ the proposed route? Why did the Forest Service and the other ―member’s‖ of the alignment group presume they had the right to trespass on private property and presume to flag a proposed trail without owner consent? Community bases planning must be transparent and inclusive. In order to be successful in both community bases planning and public service the government, at all scales, must go beyond the legal minimum to insure that as many voices as possible can be heard. As one of those parties and one with personal property on the route I was not contacted nor invited until the process was well on its way which could be a procedural error and one that certainly suggests a serious process issue and consequently, a flawed document. Even though the proposed trail directly abuts my property line, I have not received the simple courtesy of a written notice or letter that this public access was adjacent to my home was being considered for final approval. I would not have known about the proposal but for a last minute notification by my neighbors just last week. I should have been directly notified. The fact that this proposal has flown under the radar of affected homeowners like myself causes me great concern about the process for investigation and approval. I request that the comment period be extended and that all affected property owners notified directly and given an opportunity to comment. 55. Response: The initial route design was prepared by Salt Lake County, not the Forest Service. We appreciate your comment; public involvement has been addressed in the EA in Section 1.5 & 1.6. Throughout this process, we have made efforts to reach out to the public and neighboring property owners. Your comment has been added to the public record regarding the Bonneville Shoreline Trail Assessment. See also responses to #‘s 49 & 51. The text describes the trail correctly in Section 2.1.2, just as the map shows. Alternative 2 has the BST climbing up to approximately 5981 feet where it meets Rattlesnake Gulch trail and descends to the trail head. We appreciate your comment and will try to make the description as clear as possible. 56. Comment J39: error correction The EA has an error that will potentially interfere with the public's ability to comment accurately. The EA describes the addition of a trail access point on Teton Drive; the location is actually Crestwood Dr. Teton

Response to Comments 21

Bonneville Shoreline Trail Environmental Assessment would probably be a favorable location for an access point, but Crestwood Dr is not; the road is already narrow as it is, and encouraging parking there will create problems for pedestrians, residents, fire suppression access, and the like. 56. Response: Though this area is not located on NFS land and the Forest Service has no authority to authorize any improvements off the National Forest, the EA has been modified to address access points and routes in Chapter 2. 57. Comment S50: Page 2.20, Segment 2. It lists segment 2 would be entirely on NFS land. As figure 8 and 16 show it clearly crosses the oddly shaped piece of private property that lies in the lower part of Heughs Canyon. 57. Response: The text in the EA is correct and the maps show the land to be National Forest. The confusion stems from that map that shows the land as National Forest, though not as shaded as the surrounding National Forest. This is because the surrounding land is designated Wilderness and the Heughs parcel is not. 58. Comment J15, J16, J19, J20, J42: 60 day comment period We have recently become aware of the release of the Preliminary Environmental Assessment of the Bonneville Shoreline Trail - Salt Lake County, July 2007. Due to the complexity of this document and the inadequacy of the notification procedure, we request that you extend the comment period for an additional 60 days. We further request that the Forest Service hold an additional public meeting to answer questions about the Environmental Assessment that have not yet been adequately answered. 58. Response: Section 1.1 of the EA details the public involvement for this project and a summary of public involvement activities can be found in Section 1.5 of this document. Salt Lake County prepared an alignment plan for the BST and presented it at a stakeholders meeting on September 12, 2004 and at a public open house on September 25, 2004. Comments from these meetings were considered and appropriate revisions were made. In January 2005, Salt Lake County released the BST Alignment Plan for Salt Lake County. Public involvement for this EA was initiated on March 17, 2006. Preparation of this EA was announced in the WCNF Spring 2006 Schedule of Proposed Actions, which was published on April 1, 2006. The proposal was provided to the public and other agencies for comment during scoping March 17 to April 17, 2006. The scoping notice and associated maps were posted on WCNF‘s website. Over 250 people responded to the request for comment. A public scoping meeting was conducted on April 5, 2006 to gather comments from the public and interested agencies and organizations on the proposed alignment, construction, and use of the extended BST. Sixty-six people registered at the meeting. Some comments were received after the scoping period had officially ended. These comments were also considered and added to the project record. The Responsible Official believes this level of public involvement is adequate to capture the issues and concerns generated by interested stakeholders. 59. Comment D7, J18, J23, J25, J35, J41: The Forest Service should perform an Environmental Impact Study (―EIS‖). Indeed, we believe that the issuance of Finding of No Significant Impact (FONSI) is lieu of an EIS for the BST would be arbitrary and capricious and in violation of law. The EIS should be prepared by an unbiased party who is not funded by the proponents of the BST. 59. Response: Under NEPA regulations, an agency undertaking an action is required to determine whether its proposal is one that normally requires or normally does not require an EIS. 40 C.F.R. § 1501.4(a). If the answer to this question is not clear-cut, the agency should prepare an EA. Id. § 1501.4(b).If the agency determines, based

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Bonneville Shoreline Trail Environmental Assessment on the EA, that no EIS is needed because its action would not significantly affect the environment, it may then prepare a FONSI. Id. §§ 1501.4(e), 1508.13. Under NEPA regulations, an agency undertaking an action is required to determine whether its proposal is one that normally requires or normally does not require an EIS. 40 C.F.R. § 1501.4(a). If the answer to this question is not clear-cut, the agency should prepare an EA. Id. § 1501.4(b).If the agency determines, based on the EA, that no EIS is needed because its action would not significantly affect the environment, it may then prepare a FONSI. Id. §§ 1501.4(e), 1508.13. Otherwise, it must prepare an EIS. The Center for Environmental Quality (CEQ), which guides the implementation of NEPA, provides the following guidance on when to prepare an environmental assessment (Sec. 1501.3): (a) Agencies shall prepare an environmental assessment (Sec. 1508.9) when necessary under the procedures adopted by individual agencies to supplement these regulations as described in Sec. 1507.3. An assessment is not necessary if the agency has decided to prepare an environmental impact statement. (b) Agencies may prepare an environmental assessment on any action at any time in order to assist agency planning and decision-making. And in Section 1501.4 (c): Based on the environmental assessment make its determination whether to prepare an environmental impact statement. The construction of a non-motorized recreational trail is not a project that normally requires an EIS and an EA is an appropriate level of NEPA analysis. Based on the outcome of the effects analysis presented in the Bonneville Shoreline Trail EA and supporting documentation, the Responsible Official will determine if an EIS is warranted for this project and decision. The CEQ also recognizes the third party contracting arrangement as a legitimate method of EIS preparation in which the non-Federal party actually executes the contract and pays for the cost of preparing the EIS. 60. Comment J28: I attempted to send the attached letter yesterday but it was returned unsent. The deadline for comments on this matter is today. I will again attempt to send my comments and hope that they will be accepted as arriving on time. I also snail mailed the letter this morning. 60. Response: Your comment has been received and added to the public record regarding the Bonneville Shoreline Trail EA. 61. Comment J30, J37: The issues listed in Section 1.6.1 as ―outside the scope‖ of the EA, are critical issues and need to be addressed by the various BST planning organizations, including the Forest Service and Salt Lake County. Specifically, we believe that detailed analyses and public input are required to evaluate the enforcement of motorized use closure, the need for another trail in the area, the use of private property owners’ land, creek crossings, and other ―dismissed issues.‖ 61. Response: The rationale for dismissing issues from further analysis within this EA is described in 1.6.1 of the EA. Issues may be dismissed from analysis within an EA for a variety of reasons and dismissal does not mean that those issues are not important considerations. The Center for Environmental Quality (CEQ), which guides the implementation of NEPA, provides the following guidance on issue development: (Sec. 1501.7) 1. Identify and eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review (Sec. 1506.3), narrowing the discussion of these issues in the statement to a brief presentation of why they will not have a significant effect on the human environment or providing a reference to their coverage elsewhere.

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Bonneville Shoreline Trail Environmental Assessment

Activities common to all alternatives (such as motorized use closure) do not provide a basis for evaluating differences between alternatives. The need for the trail is addressed in many other documents including The Wasatch-Cache National Forest plan which has been subject to prior environmental Review, the Bonneville Shoreline Trail Alignment Plan and the BST Memorandum of Understanding. The Forest Service has no authority to authorize any trail segments or authorize use on any private land parcel. 62. Comment J33: mitigate below significance Please note that many of the findings in the EA addresses mitigation efforts that would presumably ameliorate some of the impacts of the BST, including without limitation several of the concerns addressed above relating to the Mill Creek-Neff’s Canyon Segment. Please note, however, that under NEPA, mitigation measures may be relied upon to make a finding of ―no significant impact‖ only if they are imposed by statue or regulation, or submitted by an applicant or agency as part of the original proposal. Davis v Mineta, 302 F.3d 1104, 1104, 1125 (10th Cir. 2002). As a general rule, the NEPA regulations contemplate that agencies, including the Forest Service, should use a broad approach in defining significance and should not rely on the possibility of mitigation as an excuse to avoid the EIS requirement. ID. 62. Response: The case of Davis v Mineta, 302 F.3d 1104, 1104, 1125 (10th Cir. 2002) involves a proposal to construct a five-lane highway, bisecting a park, requiring the construction of a new bridge across the Jordan River, and the demolition or removal of several historic structures. The potential impact of that project and the ability to mitigate the effects are of a different scale than those likely to be associated with the construction of a non-motorized recreation trail. Still CEQ does provide guidance on mitigation measures and on using a broad approach to significance. CEQ 40 FAQ s state that: ―In cases where an environmental assessment is the appropriate environmental document, there still may be mitigation measures or alternatives that would be desirable to consider and adopt even though the impacts of the proposal will not be "significant." In such cases, the EA should include a discussion of these measures or alternatives to "assist agency planning and decision making" and to "aid an agency's compliance with [NEPA] when no environmental impact statement is necessary." Section 1501.3(b), 1508.9(a)(2). The appropriate mitigation measures can be imposed as enforceable permit conditions, or adopted as part of the agency final decision in the same manner mitigation measures are adopted in the formal Record of Decision that is required in EIS cases. CEQ also states that ―In some instances, where the proposal itself so integrates mitigation from the beginning that it is impossible to define the proposal without including the mitigation, the agency may then rely on the mitigation measures in determining that the overall effects would not be significant .. [] In those instances, agencies should make the FONSI and EA available for 30 days of public comment before taking action. Section 1501.4(e)(2).‖ The effects of the proposed project consider the effects of all actions including implementation of Best Management Practices, Forest Plan Guidelines, and Forest Service Handbook direction which are incorporated as design criteria into all of the action alternatives. 63. Comment T3: mitigation effectiveness For a number of the issues, it is assumed that the additional "mitigation" will automatically solve that problem that is magnified by the trail. The greater potential of fire will be mitigated by additional fire fighting capabilities; the trail will increase the number of people policing the illegal hunters; the construction of the trail will lead to a "Potential beneficial effect from increased awareness and protection" (p-2-31) for archaeological resources. These mitigators costs money and still leave damage. It seems in each case that Alt 2 increases human traffic, which increases the potential of adverse effects. Mitigation may try to reduce the increase, but there is no guarantee that the mitigation will reduce the risk to make it lower than in the Alt 1 case. We have too many specific questions regarding word choice, logic, and rhetoric to include in this short letter, but we would gladly list them at a further date to assist in improving the quality of the EA.

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Bonneville Shoreline Trail Environmental Assessment

64. Comment J38: The public needs additional insight regarding the trail decision process. For example, more details need to be given regarding how each segment is chosen. Our understanding from oral comments by Forest Service employees is that the trail segments will be chosen on a segment by segment basis. That is, one segment may come from Alt 1 while the next segment may come from Alt 2. Is this correct? And who is authorized to make the trail location decision: will one person or a Forest Service committee make the ultimate decision? And if the trail is designed to be for public use, why and how can other not-fully-public groups trademark or copyright any aspect of the trail, even its name? Will the trail itself still remain public? 63-64. Response: The Responsible Official may select an alternative or may select a combination of alternatives that best meets the purpose and need of the project, that implements the Forest plan and that provides for the greatest benefit at an acceptable level of risk. For this project, the Responsible Official is the Forest Supervisor for the Uinta-Wasatch-Cache National Forest. The Forest Supervisor can only make a decision on those portions of the trail that occur on National Forest lands (see Section 1.3). Segments of the trail proposed for construction off of National forest lands will be decided on by the appropriate governing authority. The trail is a public trail and will remain public. See also response #‘s 49, 51, & 58.

7. Recreation 65. Comment H11: There is no discussion of the effect of connecting the BST with the Pipeline Trail in Millcreek. The volume of bike travel on this section of the trail will be at least 10 times higher than any other similar section, vastly multiplying impacts on animals and birds in the area, accelerating erosion problems, and amplifying parking problems in the neighborhood below this proposed junction. 65. Response: Mountain bike use of the BST would be limited due to Wilderness regulations that prohibit mountain bike use in designated Wilderness Areas. The effects analysis (Section 3.3.3) has been revised to address the potential impacts of mountain bike use in this area. Note, most of the proposed trail alignment from the Pipeline trail to trailheads south of Parleys Canyon lie on private land. The Forest Service has no authority to authorize trail segments on private land. 66. Comment H27: We see no reason to provide another access to public lands primarily for the local neighborhood when numerous access points already exist? For this area, the fact that other existing trails are not continuous adds to this area’s unique character and isn’t a detractor for the residents. 66. Response: The EA identifies and details the rationale for the BST, including local access points. These access points are not primarily for the local neighborhood (as stated in the comment), but are for all potential trail users. While people within the neighborhood would not require access points because of their living proximity to the trails, other users that do not live nearby will certainly need places to park and gain access. Most access points and trailheads are located on private property and the Forest Service has no authority to authorize any improvements on private land. 67. Comment H32: I am writing to express my concerns and opposition to alignment 2 and alignment 3 of the Bonneville Shoreline Trail (BST) for segment 1 (Parley’s Canyon to Millcreek Canyon). Since hikers already have a vast network of accessible trails in segment 1, it appears that the Bonneville

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Bonneville Shoreline Trail Environmental Assessment

Shoreline Trail is really being constructed for the benefit of bikers. Bikers are the only ones who will benefit from the construction of alignment 2 or alignment 3 across segment 1. The combination of the bridge over I- 80 which allows people to ride over from Foothill Drive plus the new bridge across I-215 which will bring many bikers from the Canyon Rim area will make riding from those locations to the Pipeline trail in Millcreek canyon far more popular. I think we will be inundated with bikers on segment 1. Having a large number of bikers heading to Millcreek canyon will dramatically decrease the pleasure local residents currently derive from walking in the area. Bikers have a new path marked along Wasatch Blvd. between 3300 South and Millcreek Canyon; this should be retained as the alignment of choice for segment 1 (―Alignment 1‖). 67. Response: We do not agree with the assertion that the trail would be constructed primarily for the benefit of bikers. The EA is clear that the trail is intended to accommodate several types of nonmotorized use, without any of these uses being prioritized or preferred over the others and that due to Wilderness area regulations, mountain bike opportunities would be precluded in wilderness. The effects of mountain biking, including the Millcreek area, are discussed in the EA in Section 3.3 The concern about ―inundation‖ of the area by bikers is addressed in the response to Comment 48. Your preference for Alignment 1 within Segment 1 is noted. See also responses to # 6 & 65. 68. Comment F21: alt 3 maintenance Alternative 3, which puts the trail higher on the mountainside, requires greater elevation variations and makes the trail less inviting to the average trail user. Alt 3 will require more intensive trail maintenance, which, we have observed, is already inadequate in most segments of the trail we have visited. 68. Response: The recreation effects of constructing a trail higher on the mountain are discussed in the EA in Sections 3.3 and 3.4. All trail design and construction is to be implemented in accordance with USFS design standards and USFS trail construction standards. Concerns such as trail proliferation, trail administration and trail management are considered to be minor with the implementation of BMPs. In addition; funding and personnel from land acquisitions, planning grants, Salt Lake County, Salt Lake City, non-profit organizations and volunteer labor will be used to plan, build and maintain the trail. See also response # 69. 69. Comment H52: general maintenance The WCNF already has insufficient staff and funding to maintain its existing trail system, and the proposed plan will add more. This EA should at least acknowledge this as an on-going unresolved issue that requires attention. Existing BST segments are maintained by an ad-hoc group of volunteers, and problems are developing along certain sections of the trail and its connectors. What the BST (and the rest of the county- wide trail system) needs is adequately funded management and maintenance (not just a plan) dedicated to preventing the trails system from degenerating into an eroded eyesore. This requires coordination with Salt Lake County and other local entities, and the fielding of a paid professional trail management and maintenance staff. 69. Response: Congress directs the Forest Service to manage national forests for multiple uses and benefits and for the sustained yield of renewable resources such as water, forage, wildlife, wood, and recreation. Multiple use means managing resources under the best combination of uses to benefit the American people while ensuring the productivity of the land and protecting the quality of the environment. The Forest Service uses funds allocated by congress to construct and maintain recreational facilities on National Forest lands. The Land and Water Conservation Act (1964) provides continuing access to national forests and funding for recreation. Funding and personnel from land acquisitions, planning grants, Salt Lake County, Salt Lake City, non-profit organizations and volunteer labor will be used to plan, build and maintain the trail. All trail design and construction is to be implemented in accordance with USFS design standards and USFS trail

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Bonneville Shoreline Trail Environmental Assessment construction standards. For these reasons, concerns such as trail proliferation, trail administration and trail management are considered to be minor with the implementation of BMPs. The Forest Service, in coordination with Salt Lake City, Salt Lake County and the BST Coalition prepare, submitted and was awarded a two-year state trail grant to conduct trail maintenance for the BST in Salt Lake City. Similar cooperative agreements and grants are in place in Salt Lake County and Draper City for maintaining existing segments of the BST. These all utilize professional trail maintenance personnel and supervised volunteers. 70. Comment E1, F36: trail difficulty Trail difficulty was also dismissed yet the proposed action proposes to reach Mill Creek through a relatively unstable and very steep slope made up of a combination of fractured limestone and shale ledges, cobble, and unstable soils. This dismissal is flawed in a number of ways and needs to further analyze ecologic, economic, and public safety issues and impacts. 70. Response: The rationale for dismissing issues from further analysis within this EA is described in 1.6.1 of the EA. Issues may be dismissed from analysis within an EA for a variety of reasons and dismissal does not mean that those issues are not important considerations. The Center for Environmental Quality (CEQ), which guides the implementation of NEPA, provides the following guidance on issue development: (Sec. 1501.7) 1. Identify and eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review (Sec. 1506.3), narrowing the discussion of these issues in the statement to a brief presentation of why they will not have a significant effect on the human environment or providing a reference to their coverage elsewhere. Activities common to all alternatives (such as trail difficulty) do not provide a basis for evaluating differences between alternatives. The guidelines for recreation management, specifically the analysis of trail design, construct and difficulty, are addressed by several documents including; The Wasatch-Cache National Forest plan which has been subject to prior environmental Review, the Bonneville Shoreline Trail Alignment Plan and the BST Memorandum of Understanding. The effects of constructing segments of proposed trail are analyzed in detail in Chapter 3 of the EA. 71. Comment H3 Has more than one person hiked the proposed route for Segment 5 to see how challenging it is? 71. Response: Personnel from Salt Lake County, the National Park Service and the Wasatch-Cache National Forest Salt Lake Ranger District have surveyed and reviewed the entire proposed route. 72. Comment I7: I see hikers trekking randomly along the foothills and think that a focused trail would eliminate some of the bushwhacking that really is an invasion of plant and wildlife habitat. 72. Response: Effects of user created trails are described for individual resource areas in Chapter 3 of the EA. 73. Comment K1, M30, M33, M34, K11: user safety Our comments mirror those who have expressed concern about the safety and access to the area above the water tanks (easement from Crestwood Drive) specifically: Steep elevation gain results in severe erosion, dangerous hiking due to loose rocks and ravines, and un-passable biking to all but the most expert riders. Safety to would-be hikers would also be a concern. Heughs Canyon to Dry Hollow is very rugged and dangerous. Additionally rattle snakes abound, which is why Heughs Canyon is also known as rattlesnake

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Bonneville Shoreline Trail Environmental Assessment canyon. Rock fall hazard is real; the shoreline is littered with rocks; hikers are at risk for serious injury or death. The steepness of the area over which the trail is projected is far greater than the 40% indicated. The area by the Millcreek Canyon climb up to the Mount Olympus point on entry is for most people a hand over hand climb. It would not be safe for most hikers and almost impossible to carry a bike up to get to a point of being able to ride it. The main are that I am interested is the segment running from Parley’s Canyon to the Mount Olympus Trail. I have a number of concerns regarding the proposed Alternatives 2 and 3. Due to the terrain in the area, people using bicycles would either not use the trail due to its steepness, or they would potentially ride down the trail at dangerous speeds (this already happens in Millcreek Canyon but is partially ameliorated by bicycles being banned every other day on certain trails) 73. Response: While public health and wellness through trail development is important to the WCNF, its related impacts are not considered to be relevant to the environmental effects assessment of this EA. The rationale for dismissing issues from further analysis within this EA is described in 1.6.1 of the EA. Issues may be dismissed from analysis within an EA for a variety of reasons and dismissal does not mean that those issues are not important considerations. The proposed alternative offers a variety of recreation experiences. They are described in detail in section 3.3 of the EA. For those concerned over user-conflict between bikers and hikers, the proposed trail alignment offers sections that restrict certain user-types. For example, sections where the proposed trail alignment crosses into Designated Wilderness Areas, mechanized vehicles (such as mountain bike) are restricted. Additionally, the trail is designed to an average grade of less than ten percent. While the trail is envisioned as a relatively flat and easy trail suitable for all types of users, it is most likely that there will be areas of the trail that could be more steep and rocky in selected areas, including canyon crossings and wilderness segments. That being stated, all trail design and construct is to be implemented in accordance with USFS design standards and USFS trail construction standards. Therefore, concerns such as trail proliferation, trail administration and trail management are considered to be minor with the implementation of BMPs. For further information, issues of concern on national forest land such as user conflicts, safety, trail use and difficulty, and trail proliferation are addressed and managed according to Forest Plan Standards and Guidelines, forest-wide goals and objectives, desired future conditions, and other applicable laws and guidelines, i.e., Protected Watersheds, Multiplte-Use Sustained Yield Act, ROS; all of which are detailed in The Wasatch-Cache National Forest plan, which has been subject to prior environmental Review. 74. Comment K2: Trail design and construction are mentioned in the document but dismissed. 74. Response: The rationale for dismissing issues from further analysis within this EA is described in 1.6.1 of the EA. Issues may be dismissed from analysis within an EA for a variety of reasons and dismissal does not mean that those issues are not important considerations. The Center for Environmental Quality (CEQ), which guides the implementation of NEPA, provides the following guidance on issue development: (Sec. 1501.7) 1. Identify and eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review (Sec. 1506.3), narrowing the discussion of these issues in the statement to a brief presentation of why they will not have a significant effect on the human environment or providing a reference to their coverage elsewhere. Activities common to all alternatives (such as trail design and construct) do not provide a basis for

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Bonneville Shoreline Trail Environmental Assessment evaluating differences between alternatives. All trail design and construction is to be done in accordance with USFS design standards and USFS trail construction standards. Further, the guidelines for recreation management, specifically the analysis of trail design, construct and difficulty, are addressed by several documents including; The Wasatch-Cache National Forest plan which has been subject to prior environmental Review, the Bonneville Shoreline Trail Alignment Plan and the BST Memorandum of Understanding. 75. Comment O8: Is this strictly a walking path which will not require any mechanical equipment to develop which would destroy vegetation? Can a walking path be made without the use of, or the traveling of trucks, tractors, etc on the path? The steepness of the proposed path location is a great concern with its ultimate soil erosion problems. 75. Response: The proposed trail alignment has been designed to offer a variety of recreational experiences. All trail design and construct is to be implemented in accordance with USFS design standards and USFS trail construction standards. The trail is to be generally constructed by hand, though motorized trail equipment such as a small trail cat or power rake could be used, especially for large-scale user-created trail restoration projects. Effects on vegetation have been addressed in the EA under Section 3.1. Effects on soils and erosion are considered to be minor, with mitigation measures and design criteria further minimizing any impact. Soils and erosion is discussed in detail in Section 3.6 of the EA. 76. Comment K4: biker connections Because some user groups, such as mountain bikers, will not be able to use segments of the new trail that cross into wilderness areas, opportunities to improve the Wasatch Boulevard alignment for bikers should also be pursued. Care should be given to insure that segments of the new trail that do allow bikes are connected to the Wasatch Boulevard alignment. 76. Response: The use of Wasatch Blvd is reflected and analyzed under the No Action Alternative. The EA (Chapter 2) has been revised to address access routes from Wasatch Blvd. to the BST. 77. Comment F27: Alternative 3 has steep, technical sections not tractable by bicycle. 77. Response: Trail difficulty was determined to be outside the scope of analysis. The rationale for dismissing issues from further analysis within this EA is described in 1.6.1 of the EA. See also response #68. 78. Comment K5: Any news on BST extensions in the Ogden area? 78. Response: Some information came be obtained from the Northern Utah BST Master Plan http://www.brag.utah.gov/BST_north.htm or at http://www.bonnevilleshorelinetrail.org/. The public will be notified of other BST extensions through the public interaction process. 79. Comment H53: It would be useful to clarify the difference between ―trailheads‖ and ―access points.‖ 79. Response: Precise definitions for ―trailheads‖ and ―access points‖ are provided in Section 2.0 of the EA.

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Bonneville Shoreline Trail Environmental Assessment

80. Comment K6: The use of ―access points,‖ as defined in the EA on page 2-1, without trailhead facilities or signage is a bad idea and will only lead to control problems. 80. Response: There are distinct differences between trailheads and access points. Trailheads would generally provide defined off-street parking facilities that include trial information and may have other amenities. Access points would generally offer only undeveloped roadside parking, with no additional facilities. However, access points would also be well marked and signed to control and direct public use. Definitions for ―trailheads‖ and ―access points‖ are provided in Section 2.0 of the EA. The potential effects of access points are discussed in Section 3.3 and #.5 of the EA. Addition information can also be found in Section 3.10 of the EA. 81. Comment K7, K14: Bikes would quickly erode the trail (Millcreek's Pipeline trail reveals how bikes expand a trail by "banking" a section making it wider, higher, and slick). Multi-use…Including bikers, hikers, horses etc. is crazy. Bikers seem to have no regards for anything other than wild rides, are not courteous and often are dangerous. They are not fun to be around, and they totally destroy the reasons that I go hiking. You discuss the conflicts in the EA, and I feel that bikers should only be allowed on certain days at first. Conflicts with bikers will only increase and need to be dealt with before the trail is built. Keep them on Wasatch Blvd. until they can be civil! 81. Response: Congress directs the Forest Service to manage national forests for multiple uses and benefits and for the sustained yield of renewable resources such as water, forage, wildlife, wood, and recreation. Multiple use means managing resources under the best combination of uses to benefit the American people while ensuring the productivity of the land and protecting the quality of the environment. In order to be compliant with the Multiple Use Sustained Yield Act of 1960 (MUSY) and more specifically the WCNF Forest Plan Standards and Guidelines, the WCNF must be managed for a variety of visitor use/recreation opportunities. A more detailed review of laws, regulations and guidelines concerning recreation and visitor use can be found in Section 3.3.1 of the EA. In addition, all trail design and construction is to be implemented in accordance with USFS design standards and USFS trail construction standards. Therefore, concerns such as trail proliferation, trail administration and trail management are considered to be minor with the implementation of BMPs. The EA notes that Mountain bike use would be minimal due to Wilderness regulation that prohibit mount bike use in designated Wilderness areas. The use of Wasatch Blvd is reflected and analyzed under the No Action Alternative 82. Comment K9: error correction On page 2-11 the map states ―Heughs Canyon Trailhead (Existing)‖. There is no existing trailhead at this location! The map on page 2-23 (and other pages) correctly lists this as proposed. 82. Response: You are correct. The map is in error and has been corrected. Hueghs Canyon is an access point, not a trailhead and is proposed. 83. Comment K10: I strongly support leaving the trail along Wasatch Blvd where it currently is instead of cutting a trail over hillside protected areas. The liability far outweighs the benefit of moving a non- motorized trail through already established housing areas and pristine open space. The liability comes from maintenance of trails will

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Bonneville Shoreline Trail Environmental Assessment required access roads that further erode the hillside. 83. Response: To clarify no access roads will be required to maintain the trail. The use of Wasatch Blvd is reflected and analyzed under the No Action Alternative. See also response #6. 84. Comment K12: I am in favor of the trail system but would not want them marketed widely. 84. Response: Thank you for submitting a comment. Your comment has been added to the public record regarding the Bonneville Shoreline Trail Assessment. 85. Comment H40: One of the major BST benefits is its use in linking the Salt Lake County urban trail system (existing and proposed) to trails (existing and proposed) into the foothills and canyons. It would be useful to display these trail intersections on the maps and discuss the issues and benefits associated with these linkages. 85. Response: The linkages between existing trails and the proposed BST are discussed in Section 3 in the EA. 86. Comment H45: Alternative 2 includes a series of tables summarizing existing and proposed trailheads. The headings on these tables are a bit misleading. For example, Table 2 shows trailheads: Existing (9); Proposed (3). This leads one to believe that Alternative 2 would eliminate six existing trailheads. Changing the ―Proposed‖ trailhead column to ―Additional Proposed‖ would eliminate the confusion. 86. Response: Alternative 2 does not propose to eliminate any trailheads. ―Existing‖ trailheads reference trailheads that already exist and that are to be incorporated into the proposed trail alignment. ―Proposed‖ trailheads reference potential trailheads that currently do not exist, but that are being analyzed for possible implementation. Within Section 2.1.2 Alternative 2:Proposed Action, there is a detailed description of each trailhead (both ―existing‖ and ―proposed‖) that is to be implemented within the proposed trail alignment. Recognize that most access points are located off NFS lands and the Forest Service has no authority to authorize any improvement or facility of NFS lands. 87. Comment K15: error correction On page 3-78, segment 4 you say there will be only 1.25 miles of trail between Hidden Valley Park and Little Cottonwood Canyon. I think the correct distance is probably double that amount. 87. Response: The reference refers to the length of trail on NFS lands. The Soils Section (3.6) has been revised.

8. Economic 88. Comment F4: In the event your cutting and digging causes any of these problems, the price the county/state will pay in legal fees and damages will be greater than putting the trail in itself. 88. Response: Best Management Practices, Forest Service Handbook direction, the low impact nature of the trail design

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Bonneville Shoreline Trail Environmental Assessment and past experience building trails in similar terrain will reduce the likelihood of damage to neighboring properties. In the event of an accident, applicable legal procedures remain available. 89. Comment H18, H7, H8, M3, M52: I am much aghast at the proposed Bonneville Shoreline Trail above the homes in Olympus Cove because such a trail will be very expensive to build and therefore is a waste of taxpayer’s money. Salt Lake County taxpayers) have already incurred an $8,000,000 cost for the bridge across I-215. Has a benefit to cost analysis for the Bonneville Shoreline Trail project been conducted, and if not why? Section 3.4, in Alternative 2 and 3 it lists that ―wilderness character and regulations will be easier to manage because there will be a designated trail system‖. For this to be true it will require money (man power) to make it happen. Since this document fails to mention maintenance/enforcement and how they will be paid for these comments must either be stricken from the document or changed to a con. 89. Response: Congress directs the Forest Service to manage national forests for multiple uses and benefits and for the sustained yield of renewable resources such as water, forage, wildlife, wood, and recreation. Multiple use means managing resources under the best combination of uses to benefit the American people while ensuring the productivity of the land and protecting the quality of the environment. The Forest Service uses funds allocated by congress to construct and maintain recreational facilities on National Forest lands. The Land and Water Conservation Act (1964) provides continuing access to national forests and funding for recreation. In addition; funding for land acquisitions, planning grants and volunteer labor will be used to plan, build and maintain the trail. The Northern Utah Bonneville Shoreline Master Plan, APPENDIX J: BONNEVILLE SHORELINE TRAIL (BST) COMMUNITY TRAIL MYTHS states that regarding the BST trail near Ogden ―Local volunteers have constructed most if not all of the BST along its entire length, keeping development costs extremely low. "Adopt-a-Trail" programs have proven very successful in ongoing maintenance efforts. The Utah Conservation Corps is available to provide trail building services at much reduced cost.‖ The CEQ regulations at 1502.23 state that for the purposes of complying with NEPA the weighing of the merits and drawbacks of various alternatives need not be displayed in a monetary cost-benefit analysis and should not be when there are more qualitative considerations. Providing a non-motorized recreation opportunity is such a qualitative consideration 90. Comment M20: I request a copy of the repayment of any public funds for the construction, operation, and maintenance of the Bonneville Shoreline Trail, if such a schedule of repayment of expenditures of public funds for this trail has been made, and, if not, your latter to me stating why a schedule for the repayment of construction, operation, and maintenance costs was not prepared. Such a schedule should probably include an estimate for the Sheriff’s Search and Rescue additional expenses. 90. Response: The Forest Service uses funds allocated for recreation to plan, construct, operate and maintain recreation facilities on Nation Forest system Lands. These funds are public funds allocated through congress for this purpose and are not intended to be repaid, therefore the Forest Service does not develop a repayment schedule for these or other Forest management activities. Also see responses to numerous comments above regarding funding for construction and maintenance of the BST.

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9. Social 91. Comment M7, M8, M15, M17: law enforcement security For years the end of Mile High Drive has suffered from its use as a ―lover’s lane‖ and site for less desirable activities. It has resulted in late night traffic which in turn resulted in cars being vandalized and property damaged. Frequent requests for additional police patrols and the building of houses closer to the end of the road have helped but not eliminated these problems. All of the traffic on the trail would increase this problem. Law enforcement for these issues more difficult. We are concerned about the increase in street traffic that would result from a parking lot at the end of Mile High Drive. Today, Mile High Drive is a very quiet street with numerous individuals using the street to take their daily walk or jog. There is little ability for law enforcement In speaking recently with Salt Lake County Sheriff’s, they indicated they have no means by which to patrol the mountains. We have several concerns about the trail crossing private property from Millcreek Canyon south above Parkview Drive to Neff’s Canyon in the designated location. We are concerned about security and law enforcement on this trail as there does not appear to be any current provision for providing same by the Salt Lake County Sheriff. Law Enforcement officers in the County, State, and Federal Governments (including the Forest Service) have voiced an opinion contrary to the finding of ―minor adverse effects…‖ from ―trespass, vandalism, conflicts between users and nearby property owners…‖ in PEA. Law enforcement has a concern about search and rescue as well especially on steep, rocky slopes. Signs may deter many people but some could care less and ignore signs. Example: ongoing motor vehicle trespass on the Jordon River Parkway that recently almost caused a fatality with a trail user. Indeed, there is significant anecdotal and documented evidence to the fact that signs are generally ignored. Example: take off your Forest Service uniform and hike one of the leash- only roads or trails and count the violations. Example: review federal and state accident reports and compile a list of serious injury and deaths that have occurred on well-signed trails or sites. Often these incidents have occurred within viewing distance of a warning sign. Note: Please check the records of the County and Utah Department of Wildlife Resources to find out how many issues with hunters, hikers, and other have occurred along this segment. This was brought out in scoping but was ignored. The team must further analyze this issue. 92. Comment J11: The document states that there would be minor socio-economic effects, such as: minor trespassing, minor vandalism, conflicts between visitor users and property owners. There would also be increased traffic, transportation, and parking. What is the definition of ―minor trespassing‖ and ―minor vandalism?‖ We already experience trespassing and vandalism on the property, and we receive virtually no help from law enforcement to control this problem. For this and other reasons, when the document states that these problems would be mitigated by ―effectively communicating trail regulations at each trailhead,‖ to have bikers and hikers and dogs on this trail would make an existing situation worse, and the ―enforcement‖ of putting a mere sign on the trailhead would do little to mitigate the problems. 93. Comment M2: While the bike trail through Olympus Cove may be in the public interest, the proposed parking lot at the end of the circle on Mile High Drive is not in the public interest because it is completely unnecessary, a waste of public funds and an invitation for vandals, litterers and drug dealers for late-night transactions. 94. Comment M41: crime In most cases, we believe the impact should be increased from minor to either moderate or high in the following areas: Increased crime –The crime rate in the neighborhood is extremely low. Although it isn’t anticipated that the crime rate (both violent and non) would increase much, even a single instance of a crime would be unacceptable. The close proximity of the proposed trail and access point(s) to homes in this Response to Comments 33

Bonneville Shoreline Trail Environmental Assessment location gives a criminal very easy access and opportunity. (Remember Elizabeth Smart?) Yearly, we have had to deal with hunters flagrantly crossing private property to access allowable hunting areas. Some have even discharged firearms within sight of our home during bow hunting season. Currently, we experience people partying in Heughs Canyon. We don’t see how a formal trail will stop such activities. Neighborhood crime watch is of limited value in this neighborhood since people are often not home. Who will be the governing agency when an alleged crime is committed? The Sheriff has been contacted for parties in the canyon to insure the partiers are not doing anything unlawful and they promptly explain that is outside their jurisdiction. 95. Comment M46: The trail would increase security issues. The trail could be used as a staging area for home robberies. What provisions are being made for security along the trail? That will cost the taxpayer. 96. Comment M59: The proposed BST trail would encourage neighborhood visits from dangerous individuals. While most outdoor enthusiasts are kind and caring people, we regularly hear reports that Millcreek Canyon is a frequent haven for criminals and sexual predators. The proposed trail would provide these individuals easy access into our otherwise safe neighborhoods. They could hike on the trail and descend at will in to our back yards. We simply do not have confidence that the proposed periodic police patrolling of the BST will be adequate. 97. Comment M69: A potential danger to the Prospector Hills neighborhood from bad subjects being able to see from the Trail our ―expensive‖ homes and breaking in more often. The trail could be placed higher on the slope so that it is hidden from view. 98. Comment M11: public nuisance There is presently an existing trailhead located on Lower Prospector Drive that allows people to access Ferguson Canyon. There is always evidence of campfires, smoking, drinking (i.e. beer cans) along the trail and in Ferguson Canyon. There is little to make one believe that these problems would not become more widespread if the Bonneville Shoreline Trail was extended into a much wider area. In short, the Trail through this area is sure to constitute a major public nuisance. 99. Comment M12: safety The PEA does not adequately address a number of issues that will impact the safety of residents and children. Many rational arguments concerning problems with geology, fire, hunting, trespassing, erosion, etc. have been made to your office. 100. Comment M23, S14, S16, S32, S37, S39, S42, S74, S76: A Trailhead at the south end of Mile High Drive would reduce the privacy and security of our home. The proposed BST trail would enable trail users a direct view into our back yard, violating our precious privacy and peaceful existence. We would sincerely fear for our safety knowing that an individual from the trail could watch us. 101. Comment M37: I am writing to express my concerns and opposition to alignment 2 and alignment 3 of the Bonneville Shoreline Trail (BST) for segment 1 (Parley’s Canyon to Millcreek Canyon). I do not believe that the forest service will have the resources to properly enforce rules and to patrol segment 1. Absent that close monitoring and enforcement, the adverse effects that are called ―minor‖ in the report, but which are major to homeowners along Crestwood Drive – such as trespassing, vandalism, increased traffic, transportation and parking – can be expected.

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102. Comment N36: Our comments mirror those who have expressed concern about the safety and access to the area above the water tanks (easement from Crestwood Drive) specifically: Salt Lake County Sheriff’s Office has responded to an increasing number of calls re: illegal activities in the area above Crestwood Drive, including gun shots, camping, climbing on water tanks. 103. Comment M24: A Trailhead at the south end of Mile High Drive would increase vandalism, pollution, and trespassing. 104. Comment M39: The main are that I am interested is the segment running from Parley’s Canyon to the Mount Olympus Trail. I have a number of concerns regarding the proposed Alternatives 2 and 3 (identical for this area) Based on my reading of the maps given, the trail would cross from the Crestwood Gully to the end of the Pipeline Trail in close proximity to the Skyline High School ―S‖. This would potentially lead to increased vandalism of a school symbol (previously damaged significantly by students from Olympus High School.) 105. Comment M65: There are no provisions in the proposal for patrolling the area [Neff's Canyon access point] for crime which is a greater problem in a residential area than in the university area. There is no way to ensure users are following the basic rules of use. Users would be very far from law enforcement and out of the public eye, but have close access to some nice private homes, a combination which inevitably raises crime rates. Property values would be reduced significantly by such a change. 106. Comment M45: This trail would promote noise pollution and enhance vandalism. 107. Comment M55: I feel the increased traffic that this could bring would also pose serious safety and security risks for our neighborhood. 108. Comment M56: The EA inadequately analyzes this issue, avoiding any substantive discussion of the potential increase of trespass and vandalism as a result of the proposed the Mill Creek-Neff’s Canyon segment of the trail. The trail along this Segment abuts or runs through several parcels of private property. 110. Comment H12, H14, H24, H25, H33 H46, H51, M16, M60: trash and noise The large number of people and machines that may be attracted to this new section of the trail would with the attendant noise, traffic, and confusion is totally out of place in this neighborhood. Beer and pop cans, dog feces in plastic bags and other debris. I believe that there is significant potential for garbage to appear on and around the segment 1 trail. Placing trash cans is not feasible and would be aesthetically disastrous. What additional steps and who will be responsible to keep new trail heads trash free (since current ones are working).We are concerned that the increased traffic in the area and possible increase in noise and crime from those using the trail will diminish our quality of living, and hence our property values. 111. Comment M26, M28: Opening this area to public traffic will inevitably increase litter and other damage. Gang-related graffiti litter, and multiple campfire scars have largely ruined the Mount Olympus trailhead area. I cannot believe the Forest Service wishes the same fate for the foothills between Parley’s Canyon and Mount Olympus. 91-111. Response: Your issues have been addressed in the EA under Section 3.10. As many of you have noted, under the

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Bonneville Shoreline Trail Environmental Assessment existing condition there are law enforcement concerns occurring now, these are recognized under the No Action Alternative. Recreational use of public lands in Salt Lake County is expected to rise regardless of whether additional designated trails are built or not. However, there is little evidence that increased use of designated trails increases law enforcement problems. Often the evidence shows that infractions decrease as use increases. As noted in the Northern Utah Bonneville Shoreline Trail Master Plan Appendix J: Bonneville Shoreline Trail (BST). Community Trail Myths: "The problems we had along the foothills with 4X4 vehicles, gunfire, beer parties, campfires and transients have disappeared. The residents along the system are very pleased and have become users and advocates. On the Ogden River Parkway, the development of the trail system has virtually eliminated crime and unwanted behavior. Only one incident along the three-mile Parkway required a police report in the past twelve months." (Jay Hudson, Assistant to the Mayor, Ogden City February 1996) ―Rail-Trails and Safe Communities. The Experience of 372 Trails‖ ( Rails to Trails Conservancy 1998) http://www.railtrails.org/resources/documents/resource_docs/tgc_safecomm.pdf surveyed law enforcement officials and trail managers from along nearly 7,000 miles of trails with more than 45 million estimated annual users. They found that ―Rail trails are not crime free. No place on earth can make that claim. However when compared to the communities in which they exist, compared to highways and parking lots and compared to many other public and private places, rail-trails have an excellent public safety record.‖ This survey and several other studies show that while fears of increased crime were high prior to construction of the trails, most fears were unrealized after the construction. This same survey includes letters from several letters from local law enforcement agencies stating that the trails have not caused an increase in crime and have often reduced crime rates. Bonneville Shoreline Trail Alignment Plan For Salt Lake County states that the alignment plan was developed in coalition with Salt Lake County Parks and Recreation Division through partnership with the U. S. Forest Service (USFS), the National Park Service Rivers, Trails and Conservation Assistance Program, Mountain land Association of Governments, the Bonneville Shoreline Trail Committee, and the Bonneville Shoreline Trail Coalition. An advisory committee of municipal representatives and landowners has reviewed steps in the planning process. Other participants have included Davis County, North Salt Lake City, and the Utah National Guard located at Camp Williams. In addition the State of Utah Department of Natural Resources, Salt Lake County Commission, Salt Lake City, City of Sandy, City of Draper, City of Holladay, Bonneville Shoreline Trail Committee, Bonneville Shoreline Trail Coalition, Bonneville Resource & Development Council, Inc. and the Wasatch Front Regional Council were consulted during the preparation of this Preliminary EA. These participants represent a wide array of constituents and government agencies who are highly concerned with public safety. 112. Comment M9: I am writing to express my strong objections to a proposed routing of the Bonneville Shoreline Trail on the hillside above the Prospector Hills Subdivision. I cannot believe that cutting a trail into the steep hillside is even being considered. This hillside has obviously had a major fire at some time in the past, and directing public traffic onto this area of the National Forest is not what I would consider to be a prudent decision. In addition, this is a very steep hillside could result in erosion and possibly even a landslide. 112. Response: Your concerns have been addressed in the EA under Sections 3.3, 3.5, and 3.6. See also response #28. 113. Comment J11, M13, M22, M35, M47, Q40: illegal hunting Illegal hunting issues. We do not have enough law enforcement (game wardens) to deter and apprehend the current illegal hunters. There are simply too few to cover the whole Salt Lake Valley. We worry about bow hunters that have reportedly shot downhill toward our homes and children, and we have personally seen hunters scoping downhill for game. They are already hunting illegally on private property and have removed

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Bonneville Shoreline Trail Environmental Assessment no-trespassing signs. We worry that the easy access of a trail will allow an even greater number of hunters to trespass and endanger our children. We do not agree with the argument that a trail will decrease the amount of illegal hunting. Some suggest that people using the trail would deter illegal hunting. Why would their disrespect for the law change just because a formal trail is established? A trail means even more illegal hunters, each now competing more aggressively, without regards to the safety. And even if game wardens were able to try to corner them by coming from either end of the trail, the hunters would most likely hike downhill through our property for a quicker getaway, rather than hike uphill to even more open space where they could be watched by reinforcements. As you are probably aware there are only 2 Fish and Game officers assigned to the Wasatch-Cache local area. Not near enough to stop the trespass and illegal hunting. By providing greater access to this mountain side you will be providing the hunters with an easier way to reach illegal hunting grounds. These people do not care about signs posting no hunting. These are already in place both on the mountain and on our homes. The hunters continue to trespass. No trespassing signs have helped, but not totally solved the hunting problem. It would be absolutely imperative to prohibit hunting of any type in the Olympus Cove area if this trail went through. 114. Comment M61: Just a thought, we often see archery hunters going back into the canyon, would there be an issue with that and the safety of would be hikers? 113-114. Response: Hunting, whether legal or illegal, is under the authority of the State Division of Wildlife Resources. It is recognized that hunting would continue under any alternative. Hunting on NFS land, including Wilderness areas, is legal as long as it is consistent with State hunting ordinances. Providing dedicated access and trails may reduce trespass and reduce user created trails and their associated impacts. It is not expected that an improved access and trail would increase use, as hunters generally hunt in areas that they perceive to have good hunting opportunities rather that ease of access. It is recognized that there are limited enforcement personnel and that some illegal hunting could continue in these areas, regardless of what alternative would be selected. The designation of access and travel routes may aid law enforcement in observing and enforcing their regulations. Private property/trespassing issues are discussed in Section 3.10 of the PEA. 115. Comment H6, M19, M25, M66: unleashed dogs Hikers and bikers would bring their unleashed dogs, bothering residents and intimidating their children and pets. Dog Leash Laws. You dismiss. You or no one or group can control Dog Leash Laws or force or intimidate the doggy public to keep their dogs on a leash. There is no way to patrol the area for off-leash and aggressive dogs, a problem that has been well documented on the BST above the University. 116. Comment P46: Along with great amounts of ―dog poop‖, there will be great volumes of people urine and people poop along the trail. Horrible. 115-116. Response to: Leash laws would pertain to all segments of trail where dogs are permitted (consistent with local ordinances and outside of watershed protection areas). The EA addressed this topic in Section 1.6.1- Enforcement of Dog Leash Laws ―It is recognized that dog leash law enforcement is relevant, and of concern on regional trails, and will be incorporated into trail operation. Because the issue of dog leash law enforcement is a trail issue in many places, not specifically unique on this proposed segment of the BST, the enforcement of dog leash laws is determined to be beyond the scope of this analysis. Enforcement will be referred to regional law enforcement. The EA also discussed the potential effects of dogs in Sections 3.2 & 3.7.

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Bonneville Shoreline Trail Environmental Assessment

117. Comment M29, M54, M57, M66: illegal motorized I realize that this is a non motorized trail, but who protects us from the motorcycles and snow mobiles that don’t care if it is illegal. Motor vehicles on the trail would degrade the area in many ways. A motor vehicle prohibition would, however, be very difficult to enforce because trail access is so easy. Off-road vehicle riders routinely defy road and trail prohibitions. If the police were called there is no way they could get up there. There would be no way to patrol the proposed trail to ensure that users are not using this access to bring motorcycles, ATVs, snowmobiles, and Para gliders into the fragile wilderness area. 117. Response: The District Travel Management Plan identifies all areas of the proposed trail along the Wasatch Front as closed to motorized use. Due to a large degree on the proximity to developed areas, there have not been issues with illegal motorized use. It is expected that the design of the trail and its access points, along with the close proximity to development and easy access and monitoring by law enforcement, that a new trial would not introduce new illegal motorized use. 118. Comment M38: I am writing to express my concerns and opposition to alignment 2 and alignment 3 of the Bonneville Shoreline Trail (BST) for segment 1 (Parley’s Canyon to Millcreek Canyon). The environmental impact plan says that additional development will occur in the area, bringing more people and making the new managed trail a necessity. This is FALSE. New development is not occurring along Segment 1. Some houses are being rebuilt, but that does not increase our population. There is no space for any growth in segment 1, and no managed trail is necessary. 118. Response: The growth referred to the EA does not refer to growth only immediately adjacent to the trail. It refers to growth of the surrounding communities where the expected recreational demand is expected to come from. 119. Comment M42, M44: emergency access Our comments mirror those who have expressed concern about the safety and access to the area above the water tanks (easement from Crestwood Drive) specifically: Emergency access is encumbered 1) by the number of resident cars parked on Crestwood Drive, a situation that would worsen with increased traffic and parking of hiker vehicles using this as a trailhead, 2) to people injured on the steep terrain above the water tanks 119. Response: Socio-economic resources have been addressed in the EA under Section 3.10. Access points, including the Crestwood Drive access point, are located off NFS lands and the Forest Service has no authority to authorize any improvements or stipulate any parking or traffic management policies. However, other communities have worked with their local governments to address similar issues. Sandy City has created a parking and access management plan for the BST near Bells Canyon that restricts parking in some areas and directs users to appropriate access points. Communities could pursue similar management strategies with local government agencies. 120. Comment M51: The current document correctly states the potential adverse effects of user-created trails and un- managed activities (beer parties, etc.) that are likely to occur as a consequence of the no-action alternative. It would be useful to identify areas where this is already happening (Neffs Canyon, for example) and areas where these un-managed activities might proliferate if no action is taken.

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Bonneville Shoreline Trail Environmental Assessment

120. Response: The EA has been revised to include more detailed analysis of user-created trails for pertinent resource areas in Chapter 3. 121. Comment M63: We would be very wary and concerned if either Alternative 2 or 3 were adopted. The primary reason would be safety as we would be very concerned about fire and general access to our property as the BST Alternative #2 would run very close to our back yards. 121. Response: The effects of the alternatives in relation to fire are discussed at length in Section 3.9 of the EA: ―Beneficial effects that may occur include better access to areas for firefighting activities, established fire control line ,increased speed of fire reporting, and increased firefighter safety. In addition to recreational purposes, the trail may serve as a fire buffer, a recognizable, defensible physical boundary for the Forest, and access for fire suppression to protect property in the wildland urban interface. 122. Comment M70: Many of the new trail segments will have different rules and uses and it seems highly unlikely that signage and other educational programs will suffice to control each section and that it will become the role of government to do so. The EA does not sufficiently spell out how enforcement and control will be provided. Page 1-14 of the EA says that the concern ―about the ability to patrol and effectively manage the trail system’s closures and restrictions are to be analyzed in Section 3.3.‖ While Section 3.3 does review appropriate laws and guidelines, it does not in any practical manner, spell out how enforcement and control will be managed or financed. This is a very important issue in order to maintain watershed and wilderness qualities and still allow access. 122. Response: The BST, both existing and proposed, travels through a number of government jurisdictions with varied regulations for use, including watershed and Wilderness regulations. The BST MOU (Section 1.1.3) establishes a consistent means for addressing variations in trail regulations and standardizes signing and education. The Forest Service and other local government trail management programs are well versed in multiple use trail management as it is common across the Forest and on other public lands. Watershed and Wilderness restrictions and their enforcement are a major part of current recreation and trail management programs. Funding for these education and enforcement activities come from appropriated funds as well as partnerships and other non-government funding sources. Management of the BST for existing and new sections would continue to include cooperative management practices between government agencies with jurisdiction over individual segments. See also response #‘s 89, 90, & 111. 123. Comment S13: In the instance of my property and that of my neighbors in Mount Olympus Park, we pay premium prices for our property and subsequent high taxes to live in a place that is quiet, peaceful and comparatively secluded. To infringe on our rights in order to give others an additional place to walk, exercise their animals, and ride bicycles is not equitable. These walkers and riders will do their walking and riding and then go to their homes, wherever they may be. On the other hand, we will not be able to ―go home‖ from the walking and riding. It will be in our homes continually with noises echoing from the pathways to our property below, and we will lose the quiet seclusion we bought and are paying for every day of our lives. 123. Response: The decision to be made with this EA applies to National Forest Service lands only. These lands are managed for multiple uses and are open and available for public use. Providing recreation opportunities for the public is a primary goal of the National Forest. Potential impacts to private property are discussed in

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Bonneville Shoreline Trail Environmental Assessment

Section 3.10.

10. Transportation 124. Comment M31: traffic I would like the committee to highly reconsider any thought of putting a parking lot at the top of Heughs Canyon Circle. Amazingly enough, we get so many late night cruisers going up and down our street on a regular basis that the idea of a parking lot would be scary!! 124. Response: These issues already exist and are unlikely to increase with managed access. Designated access areas can help raise the visibility of the trail and access points, helping to decrease illicit activities. The EA, in Section 3.10, notes the following about the existing conditions and likely future effects of the No Action Alternative: ―The [existing] trail network lacks continuity, is not generally constructed, managed or maintained, and often results in ―dead ends‖. The existing trail segments traverse both private and public land and in many places constitute trespasses or otherwise illegitimate trail segments. Trespassing and illegitimate trail segments will likely increase conflicts between recreation users and nearby private property owners. Vandalism and traffic-, transportation-, and traffic-related issues will likely stay the same, but may increase as recreation use and populations grow. The No-Action Alternative has the potential to have adverse effects on property values; security; privacy; and traffic-, transportation-, and parking-related issues. These effects are based on the premise that the Wasatch Boulevard will not satisfy future recreation needs. Unmanaged recreation activities will therefore increase and may lead to long-term adverse impacts to adjacent communities and private properties.‖ ―The BST may have a balancing effect on trespassing and vandalism for the following reasons. Some degree of unavoidable incidences of trespassing and vandalism would likely occur with increased visitor use, therefore resulting in minor adverse effects. On the other hand, an increase in visitor use would also produce an increase in visibility to homes, businesses, and other private properties. Increased visibility to an area has a natural tendency to diminish crime rates and therefore produce a balancing effect. Organized neighborhood watch areas and proper signage indicating property boundaries and right-of-ways would help mitigate adverse effects.‖ The decision to be made with this EA applies to National Forest Service lands only. The Hueghs Canyon Access would be located on private land and the Forest Service has no authority to authorize any improvements on private land. See Also response #119. 125. Comment N2: A Trailhead at the south end of Mile High Drive would increase the vehicular traffic (people do not drive 25 mph on this road). 125. Response: Traffic issues are addressed in the EA under Section 3.10. Surveys of users of the BST between Emigration Canyon and the University complex, show that most users of the trail come from the immediate neighborhood. The EA explains the expected effects of Alternative 2 on traffic in the areas around access points and trailheads: ―It can be assumed that the BST is likely to receive high levels of visitor use. However, it is not likely that increased visitor use would have a measurable effect on traffic and transportation. This assumption is based on the premise that, as with the University of Utah section of the BST, the majority of users would come from neighborhoods located in close proximity to the trail, resulting in a no-net or minimal increase to local traffic and transportation.

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Bonneville Shoreline Trail Environmental Assessment

Similar to the effects of traffic and transportation, parking may have some adverse effects, but overall they would be minor. The hotspot areas (Mill Creek, Big Cottonwood, and Little Cottonwood canyons and proposed Sandy City connections) would likely absorb most of the parking needs for the anticipated level of visitor use on the BST. Proposed access points in residential areas would primarily serve walk-in use from adjacent neighborhoods.‖ 126. Comment N3: parking lot at mile High Drive We are adamantly opposed to the proposed parking lot at the south end of Mile High Drive. There is a No Parking After 10:00 p.m. and a No Dumping sign outside of our home. When we moved into the home, we had constant problems with people ―parking‖ outside of our home, people having parties by the access road at the end of Mile High Drive, leaving trash, and very busy and fast traffic at all times during the night. We continually called the police. Unfortunately, it takes the police 20-30 minutes to get up here. By that time, the offenders, having been alerted would have left. I have personally caught people doing all kinds of things, from setting firecrackers to doing drugs, up here at night. We have put our personally safety at risk to protect our property and family. 126. Response: Traffic issues are addressed in the EA under Section 3.10. The EA explains the future effects of Alternative 2 on trespass and vandalism: ―The BST may have a balancing effect on trespassing and vandalism for the following reasons. Some degree of unavoidable incidences of trespassing and vandalism would likely occur with increased visitor use, therefore resulting in minor adverse effects. On the other hand, an increase in visitor use would also produce an increase in visibility to homes, businesses, and other private properties. Increased visibility to an area has a natural tendency to diminish crime rates and therefore produce a balancing effect. Organized neighborhood watch areas and proper signage indicating property boundaries and right-of-ways would help mitigate adverse effects.‖ See also response # 119. 127. Comment N6, N11, N15, N37, N38: The proposal lists Mile High Drive (the street on which we live) as an access street to a parking lot. Mile High Drive is a narrow, steep, curving dead-end road which would be negatively impacted by increased traffic and parked vehicles. It would cause dangerous hazards to residential pedestrians and especially to children walking to and from school. 128. Comment N20: Up the street and around the corner on Mile High Drive a new Trail Access facility with parking for 10-11 cars is planned. Any excess could very likely end up on Ledgemont Drive, further adding to the disruption of our lives and possibly the lowering of our property value. 129. Comment N45, N46, S12: The several proposed public access points, for example on Thousand Oaks Circle, Thousand Oaks Drive. and Mile High Drive with the very limited access point parking slots will create overflows and transit blockage. "Parking would be limited to four cars and marked to prevent interference with driveways and the gated community access road" again is no guarantee as to the excess use and abuse of the neighborhood which may occur from further development of this trail and access points. 130. Comment N49: We purchased our home in 1964 because we were drawn to the beauty of living at the base of Mt. Olympus. We were looking for a place that would be peaceful, quiet and with little noise. Quailpoint Road is one block west of Mile High Drive. If such a trail is built that you are proposing, it would cause a lot of traffic on Quailpoint Road, as well as Mile High Drive and other areas in the Mt. Olympus Cove area. It would

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Bonneville Shoreline Trail Environmental Assessment certainly disrupt our peace and quiet. 131. Comment N50, S32: There is no need for the parking lot during the first phase of the implementation. The rational decision is to implement the bike trail without a parking lot on Mile-High Drive initially. A parking lot can be put in if the trail proves to be so successful that the parking in the circle in insufficient. Don't spend public money if there is no need for a parking lot on Mile High Drive and if the lot creates more problems than it solves. Local residents from Mount Olympus Cove who want to use the trail can park in the circle and along Mile High Drive - The Drive is wide enough (or they show up by foot or bike as it is already the case today). Visitors from other locations are welcome to use the existing parking lots at Neff and Mount Olympus trail head. This will keep traffic out of the local residential neighborhoods. Everyone will have great access. 127-131. Response: Private property, trespassing, and vandalism issues are addressed in the EA under Section 3.10. Please see responses # 119 & 124, and in pages prior as they address the concerns regarding traffic and parking in the preceding comments. 132. Comment N4: The proposed Bonneville Shoreline Trail above the homes in Olympus Cove will increase traffic in a residential area where there are children present, and where it is hard to find addresses so that people seeking the trail will wander around greatly on residential streets. 132. Response: Please see response # 131 and responses in pages prior as they address the concerns regarding traffic and parking in the preceding comments. 133. Comment N7, N8: Additional cars parked along the main residential streets, such as Park View Drive, will increase tremendously for home owners on an already narrow and busy road; but would bring more noise and people, greatly disrupting our lives and our peace. It would simply be an invasion into our lives. Check out the addition of parked cars at the base of Mill Creek Canyon for bikers and hikers. 133. Response: Please see response # 131 and responses in pages prior as they address the concerns regarding traffic and parking in the preceding comments. 134. Comment N9: Gilead Way On Gilead Way we have a lot of traffic lost…trying to find Neff’s Canyon…this number would go up greatly if this trail went through. 134. Response: Transportation issues are addressed in the EA under Section 3.10. Please see response # 131 and responses in pages prior as they address the concerns regarding traffic and parking in the preceding comments. 135. Comment N12: Thousand Oaks drive The proposed trail head parking area is to be on an existing Salt Lake County cul-de-sac at the end of Thousand Oaks Drive. Salt Lake County has designed and built cul-de-sacs exclusively for use as a traffic turn around at the end of a dead end street. These cul-de-sacs were not designed as a parking lot. Traffic flow will be impeded and impossible to turn large trucks around without backing back and forth. Trail users will not obey or abide to a 4-car parking restriction. They already park more than 4 on the circle. You’re dreaming if you think 4 car parking will work. The trail head parking will block access to my

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Bonneville Shoreline Trail Environmental Assessment driveway entrance. I currently have major problems with trail users blocking the cul-de-sac and my driveway entrance. 135. Response: Transportation effects are addressed in the EA under Section 3.10. The proposed Alternative 2 designates the end of Thousand Oaks Drive as an access point with parking for four cars. The EA describes how parking effects would be mitigated: ―Access points would generally offer only on-street parking and would be well marked and signed to control and direct public use. Signs located at all access points and trailheads indicating overflow areas and other nearby trailheads could mitigate against vehicles overflowing to undesignated parking areas. See Chapter 2 for a description of parking for all existing and proposed trailheads and access points.‖ Under the No Action alternative, these issues are likely to continue, as population growth and unmanaged use of area trails are expected to continue. 136. Comment N13: Congestion and parking in a residential area is not going to work. The streets barely accommodate a car driving through if there is a parked vehicle on either side of the street. Moreover, the proposed parking is, first of all, inadequate for a trail of the magnitude that BST wants to build. There are parking lots already on Wasatch--at least 2 big ones dedicated to hikers/bikers (not counting Einsteins and Dans). There is one lot for access to the trail up the front of Grandier Peak (admittedly, a strenuous hike) - this is north of Eastwood School. And, the brand new park on Wasatch close to 3900 and 3800 South is lovely. Perfect for bikers. 136. Response: Traffic and transportation issues are discussed in Section 3.10 of the EA. Section 3.10 of the EA describes the effects of parking and traffic around trailheads and access points. See response to comment N12 (above). The EA describes how much of the BST user parking can be accommodated at existing ―hotspot‖ trailheads versus the proposed access points: ―The hotspot areas (Mill Creek, Big Cottonwood, and Little Cottonwood canyons and proposed Sandy City connections) would likely absorb most of the parking needs for the anticipated level of visitor use on the BST. Proposed access points in residential areas would primarily serve walk-in use from adjacent neighborhoods. Parking arrangements differ between access points and trailheads. Trailheads would generally provide defined off-street parking areas and may have other amenities, including drinking fountains, restrooms, and picnic sites. Access points would generally offer only on-street parking and would be well marked and signed to control and direct public use.‖ 137. Comment N16: Canyon Cove drive Canyon Cove drive would have been much busier, which was a real concern for homeowners, especially those with children who play on our quiet streets. 138. Comment N21: A matter of greater concern to me is the proposed relocation of the trailhead for the Heughs Canyon Trail connector. Presently, this trailhead is accessed from parking on Canyon Cove Drive, the street we live on. The trail is approached by climbing up Berghalde Lane, which serves as a driveway for the Borghetti family. They and other neighbors have noted several problems with having the hiker’s park near their front doors and (in the case of Borghettis) drive illegally up their driveway. But what your EA proposes is an even greater problem, and one with which several of us have been blindsided. Why does the BST proposal advocate relocating this access to parking on Canyon Cove Drive – a much busier street – where the parking will be even more intrusive to private homes. At present the parking is on Oak Canyon Drive, where two lots next

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Bonneville Shoreline Trail Environmental Assessment to the approach are unbuildable and about five spaces are available without being in front of anyone’s house on the east side of the street. 137-138. Response: Transportation issues are addressed in the EA under Section 3.10. Please see response # 131 and responses in pages prior as they address the concerns regarding traffic and parking in the preceding comments. 139. Comment H13, N17, N24, N27, N32, N35: Crestwood Access to the water tanks are on Crestwood Drive and not on Teton Drive...Crestwood Drive is a residential street with no sidewalks. There are no parking spaces available at the road to the water tanks. Residents of the whole community use this street for their daily walks. Parked cars, even just two, will make the walking hazardous. The pavement on Crestwood Dr. is only 30 feet wide at the intersection point indicated on the map and serves as the only option for mixed vehicle traffic and pedestrian traffic. Any addition of parked cars on Crestwood Dr. will effectively turn it into a narrow single lane road with added visual barriers (parked vehicles) that will increase the potential for vehicle pedestrian incidents plus make it very difficult if not impossible for two automobiles to pass each other. Crestwood Dr. is currently used extensively by pedestrians as it is located on the high Lake Bonneville level and offers a near level thoroughfare. Furthermore, the street is curved at this segment and thus presents visibility problems for the oncoming vehicles. Public access to the proposed BST segment 1 is adequately served by the Parley's canyon Access point and there are other parking areas open to the public on Wasatch Blvd between 3300 and 3900S 140. Comment N23, N44: EA; page ?? Salt Lake County...Access Point. Water Tank Access (Proposed): A partially paved lane leads from Teton Drive to the water tank at the end of "Mexican Ridge" within the Parley's to Mill Creek section (see below). The road becomes a primitive footpath above the water tank and intersects the BST route on top of the ridge. Parking on the street would be marked near the water tank access road and limited to two vehicles... The Water Tank Access of Teton Drive proposes to use an access currently used and designated for water tank operation and maintenance purposes. The existing easement granted for these activities cannot be expanded beyond this use. As long as security issues are addressed as previously mentioned, Salt Lake City has no issue with sharing this easement however a separate easement must be obtained from the property owner for the proposed trail use. Additionally, parking for this proposed trail access cannot impede our ability to access the water tanks. 139-140. Response: Thank you for pointing out there are existing constraints to using the easement for the water tank access. If this access point is approved the appropriate permissions will be requested. The Forest Service has no authority to authorize or construct any improvements on private land, or cross any private land. Transportation issues are addressed in the EA under Section 3.10. Please see response # 131 and responses in pages prior as they address the concerns regarding traffic and parking in the preceding comments. 141. Comment N18: Parkview At that time it was suggested that the trail follow the existing road of Parkview Drive up to Neff’s Canyon Trail Head. That suggestion had previously been discussed in early years (15 or so years ago) when Mount Olympus neighbors were approached about a location for the trail through the area. Since that time traffic on Parkview Drive has become very busy and at times dangerous. My suggestion would be to take the trail down to Wasatch Blvd. And use roads that would go from along that location to the various trail heads (Parley’s Canyon, Neff’s Canyon). I would not agree to the access points of the Water Tanks (two cars) or the Thousand Oaks Cul-de-sac (four cars). It is too crowded and will cause even more neighbor contention than exists at the Parley’s Canyon location.

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Bonneville Shoreline Trail Environmental Assessment

141. Response: The EA has been revised to address connections between the BST and Wasatch Blvd in Section 2.1. Transportation issues are addressed in the EA under Section 3.10. Please see response # 131 and responses in pages prior as they address the concerns regarding traffic and parking in the preceding comments. 142. Comment N21: A matter of greater concern to me is the proposed relocation of the trailhead for the Heughs Canyon Trail connector. The proposal calls for an easement through Heughs Canyon Circle to the trailhead, apparently crossing the yard of persons who had no idea this was being proposed. I’ve asked a couple of questions already, but I suppose the most important one to ask is, who proposed this relocation and this easement and this foot traffic up Heughs Canyon Circle? It’s not on Forest land, so why is it in a Forest Service proposal? Is it a proposal from the city of Holladay? If so, why have the residents of these two streets been informed of it? If there must be a connector in this area, a better place would seem to me to be in the area of Crestmount Circle, which is higher, probably nearer the elevation of the Bonneville Shoreline, and affords less intrusive parking. (I have not approached homeowners in this part of the subdivision; I simply wonder whether all the possibilities have been evaluated.) Better yet, access to the BST could be provided strictly on Forest land by opening a trail from Wasatch Blvd., where the National Forest land actually dips across Wasatch into the Old Mill Golf Course. 143. Comment N40: The proposed parking access described for the Heughs Canyon Access, under Segment 2 description for alternate 2 will ultimately create an increase in the possibility of automobile accidents for the residents of CCC (Canyon Cove Community) as well as future hikers. Canyon Cove Drive is not only a steep incline in the area at which it intersects Heughs Canyon Circle, there also currently exist a blind curve on Canyon Cove immediately north of Heughs Canyon Circle. In its current condition people must come to a careful and complete stop to assure the absence of cars coming around the blind curve. If cars were allowed to park on Canyon Cove in this area it would be adding a definite hindrance to the poor visibility which already exists thus increasing the potential for car accidents. 144. Comment N33: The impact should be increased from minor to either moderate or high for increased traffic/congestion along Oak Canyon Drive to access Heughs Canyon. Creating an access point parking location with signs would unacceptably increase both auto and foot traffic on a street that is extremely quiet. 142-144. Response: The Forest Service has no authority to make decisions on private land segments of the trail and no trail construction would occur on private land without appropriate authorization from the landowner and local government agency. Consistent with NEPA, this preliminary EA includes a detailed analysis of the potential environmental effects of construction and use of the proposed trail. The interspersed nature of land ownership along the proposed trail alignment requires that our environmental review consider the site-specific effects this trail might have on NFS and adjacent private lands and evaluate the cumulative effects of a feasible trail alignment along the entire segment of the BST in Salt Lake County. Considering and identifying a potential alignment for the BST will not necessarily result in trail construction of any particular segment. The USFS will consider trail development based on site-specific circumstances, including the availability of a trail to be completed from access point to access point. See also Response to #‘s 119, 124, & 131. 145. Comment N26: I am requesting an additional detail of where the two (2) parking stalls will be built.

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Bonneville Shoreline Trail Environmental Assessment

145. Response: It is unclear from the comment where they are questioning parking locations. The water tank access point is limited to two vehicles so this is likely the location to which you are referring. Parking is on Crestwood Drive. The Forest Service has no authority to authorize decisions not on NFS lands. This decision would be the City of Holliday. See also response #‘s 119, 124, & 131. 146. Comment N28: Trailheads should provide adequate parking so that vehicles do not overflow into neighborhoods. Restrooms or port-a-potties and, or garbage cans should be provided where usage requires it. Barriers should be built and maintained at all trailheads to prevent ATVs and SUVs from using the trail. Trails, trailheads and their parking should be closed at 10 PM; street lighting and, or lockable gates should be provided at problem trailheads. Any vandalism or graffiti should be quickly fixed or removed and not allowed to remain. Informational signage about the trail should be posted at each trailhead similar to that shown in the EA at the Bell Canyon trailhead in Figure 19. Signage should also alert hikers when they are crossing into designated wilderness areas. 146. Response: The EA, in Sections 2.2.2 through 2.2.5, describe the trail design criteria and mitigation measures that address these issues. See also response #‘s 119, 124, & 131. 147. Comment N29: The Neff's Canyon access point would bring thousands of drivers a year into a neighborhood beloved for its quietness and peacefulness. The traffic of hikers and those who gets lost on the steep windy roads looking for the trailhead or those who decide to "go for a drive" instead of taking a hike would radically alter this neighborhood where small children play. 147. Response: The effects of transportation issues are addressed in Section 3.10. Neffs Canyon Trailhead is an existing site that receives moderate to high use year round as discussed in the EA in Section 3.3. It is not expected that the development of the BST in this area would substantially change the current levels of use or associated transportation. 148. Comment N31: general traffic The proposed BST trail would increase general neighborhood traffic. This area was designed for residential use. The proposed BST would be a misuse of this otherwise private neighborhood. 148. Response: Socio-economic resources are addressed in the EA under Section 3.10. See also response #‗s 131, 119, &147. 149. Comment N41: Mt O CC Portion of Alternative II: Proposed Action (Salt Lake County Proposed Alignment) from Parleys Canyon to Millcreek Canyon violates requirements established several years ago by the Mount Olympus Community Council in consultation with our community for trail access through our neighborhood. Specifically, our approval was given for public access to the trail at the Parleys Crossing trailhead off of Wasatch Boulevard and in Millcreek Canyon from Rattlesnake Gulch. However, all other access points through our neighborhood were to be unmarked, and no parking was to be provided in areas other than the trailheads identified above The proposals to establish a ―water tank access and/or a Thousand Oaks cul-de-sac access‖ including marked, on-street parking, at these locations will face opposition by the Mount Olympus Community Council. Parking on these streets is already at maximum carrying capacity from residents and informal traffic from persons using these access points. Our community objects to marking parking spaces on

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Bonneville Shoreline Trail Environmental Assessment these streets or to advertising public access at these access points, due to the traffic impact and parking impacts on our neighborhoods, which are not designated to carry additional advertised parking. These streets are already at the limits of their capacity by people who know of and use these access points. Our community has not been opposed to actual access at these points. Rather, it is opposed to advertising this access or to providing any designated parking at these areas. 149. Response: The effects of transportation and parking issues are addressed in the EA in Section 3.10. As noted in response #119, the Forest Service has no authority to authorize any improvement on non-NFS lands, including City of County Streets. Local communities and community councils have every right to work with their local governments to establish policies for parking issues. See also response to #119. 150. Comment N42: Overflow parking from the Neff’s Canyon trailhead lot already extends down to the upper leg of Park Terrace during peak usage times. We get illegal overnight as well as daytime parking by some campers at present. We would like to avoid a further spread of people loading and unloading their bikes and parking on narrow streets outside our homes, letting their dogs loose in our yards, and scattering garbage, as happens in the Neff’s Canyon lot. The huge Mt. Olympus Waters tankers currently make many daily trips to the Neff’s Canyon parking lot, and require a considerable amount of clearance. Additional traffic on the streets here could present a real problem and would be very dangerous in case of a fire because of our narrow, winding streets and very few exits by road from this area. Bedridden and elderly residents would have great difficult evacuating the area. At the very least, the Neff’s Canyon parking lot would have to be enlarged to accommodate more vehicles. Any plan for the trail must include funding for adequate parking and preventing traffic congestion. 150. Response: Parking, transportation and safety issues are addressed in the EA under Section 3.10. See also response #‘s 119, 147, and 149. 151. Comment N48: Section 3.1.1 It states a bridge will be built over perennial drainage Heughs Canyon. This will need to be a metal bridge to prevent it from being stripped and burned at the campfire area further up Heughs Canyon. 151. Response: The EA, in Section 2.2.2 through 2.2.5., describes the trail design criteria, including bridge design that will be required for all trail construction on NFL lands. These design criteria are recommended for sites off NFS lands. 152. Comment N52: Creating a trailhead on Thousand Oaks Circle will obviously cause disruption and inconvenience. I have sincere doubts that putting up signs that the parking space for trailhead access is limited will stop others from parking up and down the street if necessary. 152. Response: The effects of transportation and parking issues are addressed in the EA in Section 3.10. As noted in response #119, the Forest Service has no authority to authorize any improvement on non-NFS lands, including City of County Streets. See also response to #119. 153. Comment N53: I am particularly distressed in reading about the "Mile High Drive Trailhead (USFS, proposed) at the end of Mile High Drive. A "parking lot to accommodate up to 10 vehicles" is of grave concern to me, since the

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Bonneville Shoreline Trail Environmental Assessment stated numerical limit of 10 vehicles is no guarantee that any number might be parking along Mile High Drive for many hours interfering with the residential nature of the area. 153. Response: The effects of transportation and parking issues are addressed in the EA in Section 3.10. See also response #119. 154. Comment N54: Traffic Parking. You say retain. More congestion in Millcreek Canyon and at White’s hill at the Neff’s Canyon Trailhead, with more cigarette butts and dog and people poop and trash. Who? Will pick it up and who? Will pay for that additional cost? 154. Response: The EA summarizes how the maintenance of the project elements would be accomplished in Sections 2.2.2 through 2.2.5. The effects of the proposed trail are discussed in Sections 3.3 and 3.10. ―There were questions raised concerning how the construction and maintenance of this project would be funded. Funding of the project will not be taken into consideration during impact assessment. Any trail would be constructed and maintained with a substantial volunteer contribution and would be funded through a combination of Public and Private funds.‖ 155. Comment N55: I will object with all means at my disposal to prevent a access parking lot. I am most concerned with increased traffic with spillover parking in front of my home which is already bad enough on windy days when paragliders avail themselves of my shade and park their cars of 10+ hours in front of my home. 155. Response: The effects of parking and transportation issues are discussed in the EA in Section 3.10. See also response to #‘s 119. 156. Comment N57: It has been my understanding that the ―official‖ access point to Heughs Canyon is off Oak Canyon Drive. This access point was not mentioned at all in the BST EA. 156. Response: The BST Alignment Plan was created by Salt Lake County and they proposed trail alignments and access points based on their surveys and field studies. Actual use of alternative access points may be different that what has been proposed, as appears to be the case in Hueghs Canyon. Residential development may also play a role in changing access points. The EA identifies the proposed and alternative trail locations and access points based on the Alignment Plan and discloses potential impacts of those by the various resource areas in Chapter 3. 157. Comment N59: Congestion at the trailhead in Hidden Valley Park is already bad on weekend and evenings. Parking problems will be injurious to our neighborhood. In the EA you say that you are assuming ―high levels of visitor use.‖ This is not an appealing outcome. 157. Response: The potential effects of recreation use, transportation and parking, and private property are discussed in the EA in Chapter 3. See also response # 119 and responses above.

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Bonneville Shoreline Trail Environmental Assessment

11. Vegetation 158. Comment O1: Special Status Plant Species Sections 3.1 of the EA regarding the impact on plants are reasonably well stated, however, there are several oversights. All plant surveys should be conducted at the time that the plants are blooming in order to insure a more complete and accurate survey. The EA also fails to analyze the effects on all plant species designated as ―species at risk‖ in the Feb. 2003, FEIS Appendices to the new Wasatch –Cache Forest Plan. Of particular concern are two plant species listed on pages F-1 and F-2 in that appendix that are likely to grow along the new trail segments in wet areas. They are Angelica wheeleri and Epipactis gigantean. The impact of the new trail on all ―species at risk‖ that might be impacted by the new trail should be considered and mitigated. 159. Comment O7, O14: The Forest Service admits that there may be several species found within the proposed trail alignment and that further reconnaissance was not completed prior to the writing of this document. The plan suggests that mitigation will occur if plants are found during construction. Many of these plants have a narrow growth window and fairly specific growth requirements. What happens if the trail is being constructed outside of the growth window of these plants? How do you know where the plants are located without a site specific inventory during the growth window if these plants will be impacted? Why isn’t a specific mitigation plan included in this analysis so that cumulative impacts can truly be analyzed? How can you analyze cumulative impacts of you don’t really know if you have caused impacts and, what happens if you find out you have inadvertently impacted a special species plant without first conducting an inventory within those growth windows? How can something with intense legal and environmental ramifications be so casually dismissed. Analysis can not be done backwards. Mitigation is not intended to replace pre-project analysis in NEPA. Therefore, a species specific inventory must be completed and analyzed prior to a final decision so that cumulative impacts can truly be analyzed? The report does not list the US Fish and Wildlife Services as a consulting agency. Will the public and agencies responsible for special species plants be notified if they are found or if ―mitigation‖ must be done? Federal agencies responsible for management of these species are not included in your list of agencies consulted. More analysis must be completed. 158-159. Response: The Forest Service conducted additional reconnaissance to verify the accuracy of the initial surveys and to determine whether any special status plant species were present. These surveys now cover the entire length of all analyzed segments, and include all species of concern. This updated information is included in the text of the EA, in Section 3.1. Analyses for Angelica Wheeleri and Epipactis gigantean have been updated as well. Any project activities would be conducted in conformance with applicable laws including the Endangered Species Act. This includes any required consultation with USFWS. Consultation with USFWS is not required for sensitive species, only for threatened, endangered, or proposed species. 160. Comment O3: There will be permanent damage to the vegetation of the entire hillside. It would take years to grow back the way it is. 160. Response: Vegetation has been addressed in the EA under Section 3.1. The analysis is clear that the proposed actions would permanently remove certain types and quantities of vegetation, and considers direct, indirect, and cumulative impacts to vegetation.

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Bonneville Shoreline Trail Environmental Assessment

161. Comment O4, O5, O10, O12: cheatgrass Invasive Plant Species – ―Both short and long-term adverse effects would be reduced to minor by implementing a weed management plan as a required project mitigation measure.‖ Research at the University of Arizona suggests that the western United States has been in a long-term drying trend for at least thirty years and Utah is still within the grip of a hydrologic drought that started in the late 1990’s. Because of these factors Cheat Grass is slowly encroaching into higher elevations. Hikers have found it several hundred feet up-slope from the proposed trail route. The document admits that there is a significant problem in the area with weeds but fails to mention Cheat Grass, which is probably the most serious invader at least from the standpoint of cumulative impacts. Cheat Grass will certainly invade and without expensive long-term mitigation the promise that native plants will be re-established and that a weed plan will be prepared will not keep the very severe short and long-term impacts from occurring. This issue, especially in the epidemic public lands are facing from weeds, must be thoroughly analyzed. A mitigation plan must be completed and added to the document as an addendum for an appropriate analysis to be completed. Cheat Grass is very flammable and shortens the time between ―normal‖ fire returns. Each subsequent fire, especially on steep slopes like those found in this segment, will grow larger in size, become more intense, increase the probability of more weeds, and further exacerbate other issues such as increased soil movement, habitat fragmentation, impacts to down-hill private property, and could have significant economic impacts both to private land owners and to public lands. How will this be addressed? This is one of the most serious long-term issues and the highly likely scenarios of fire intensity and frequency that will cause further invasion by pernicious annuals must have further analysis. This section must be further analyzed. 162. Comment O10, O11: weeds The EA seems inconsistent in its assessment of risk. Table 9 lists numerous references to Alternative 1 having a greater negative impact than Alternative 2. For example, for Invasive Plant Species, Alt 1 says "would result in ongoing degradation", yet Alt 2 says "adverse affects would be reduced to minor by implementing a weed management plan". Weed management could be implemented in either Alternative, but Alt 2 clearly increases the potential for additional weeds (as described in the last paragraph on page 3-6). And how is it that the potential increase of weeds for Alt 2 is acceptable but that the additional increase for Alt 3 (3rd full paragraph on page 3-8) is unacceptable? Is it acceptable to increase weeds in our backyard (which increases fire hazards) yet unacceptable to increase weeds in Alt 3 areas? Both are building new trails. Granted, the Forest Service may be allowed to do weed management in our backyard and not in the additional Forest Service and Wilderness lands of Alt 3. But this brings up another problem with the current EA and the need for an Environmental Impact Statement: if weed management is included in the EA as a given, why wasn't the impact of weed management assessed and described in detail in the EA? 161-162. Response: Analysis and consideration of the potential for project-related changes in cheatgrass as an invasive species has been added to the EA. However, the forestwide control of cheatgrass is beyond the scope of this document. The analysis of impacts summarized in Table 9 is consistent and accurate. Status quo weed management in the project area under Alternative 1 would be to likely allow invasive species to continue to spread as at present, while a formal project would impose clear, site-specific weed management practices in the project area. This would be anticipated to lead to better management of weeds in the project area. While use of trails can clearly be vectors for the spread of invasive species, this potential is mitigated by the preparation and execution of a weed management plan, which the analysis clearly requires as a BMP. The analysis is clear that implementation of these BMPs would result in ―minor‖ adverse impacts under both action alternatives. Additionally, the impact of weed management was and is clearly assessed in the EA; as a BMP it limits and minimizes potential impacts to the spread of invasive species. The development of a weed

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Bonneville Shoreline Trail Environmental Assessment management plan is a typical part of the Forest Service trail building process. This is done to comply with the overall management plan for the Forest Service. The purpose of the weed management plan is to minimize invasive weed infestation. The WCNF Noxious Weed Treatment EIS 2003 and the associated Integrated Weed Management Strategy provide clear direction. 163. Comment O16: To summarize, this portion [Segment 3, Alternative 2] of the trail would only be acceptable if: Extraordinary efforts were made to assure rapid re-vegetation. 163. Response: The most current procedures would be implemented to revegetate the area immediately adjacent to the trail, in accordance with FS standards, guidelines, and requirements. This would be the case on any segment constructed under any alternative. 164. Comment O17, O18, O19: The main area that I am interested is the segment running from Parley’s Canyon to the Mount Olympus Trail. I have a number of concerns regarding the proposed Alternatives 2 and 3 (identical for this area) This region (Crestwood Gully) is already beginning to have exposure to noxious weeds. Even if the trail building equipment is regularly washed prior to being moved into an area, increased traffic in the area will accelerate the deposition of non-native flora, plus potentially dangerous to native plants insect species. I believe that foreign weeds will be introduced by bicycle tires and riders. 164. Response: The entire Wasatch Front has been exposed to different varieties of noxious weeds, as indicated in the analysis. The analysis identifies that construction and use of trails, including the BST, can create vectors for new weeds and invasive species. The possibility of foreign weed deposition has been analyzed and impacts discussed in Section 3.1.The analysis also discloses the number of user created trails that are already in the area and have infestations already on them. The analysis includes discussion to the effect that a FS designed trail would aid in the efficacy of treatment of weeds by providing a more efficient route to transport crews and herbicides.

12. Visual Resources 165. Comment F14: Please refer to Segment 3, Alternative 2 the portion from Big Cottonwood Canyon to Deaf Smith Canyon described on page 2-12 of the EA. The open steep slopes above the Prospector Hills development are the crucial issue. Unless extreme care is taken with regards to exact location and construction, the trail will have an enormous visual impact on the hillside. The slope is one of the most visually prominent slopes of the lower foothills. It is clearly visible from much of Cottonwood Heights City and from as far away as downtown Salt Lake. It is an integral visual component of the grand entrance to Big Cottonwood Canyon. A trail scar across this slope will be visually offensive to the larger panorama of the Big Cottonwood Canyon view shed. The EA purports that re-vegetation which will help obliterate the scarring effect of the trail. I am not that optimistic. The entire hillside is covered with a carpet of Mule's Ear (wyethia amplexicaulis, which blooms in vibrant yellow in the early summer and turns golden brown in the fall. It is a hardy plant but would be slow to hide a three-foot wide trail buttressed by a four-foot high escarpment. The EA's assessment that in a few years the trail would be hidden by new growth of vegetation is unrealistic. Having attempted restoration projects on those same steep, dry slopes for the last thirty years I know how difficult it is for vegetation to become reestablished. Without vegetative cover, slope erosion will speed up, increasing both the visual and environmental impact created by the trail.

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Bonneville Shoreline Trail Environmental Assessment

165. Response: The potential effects of the BST on visual quality are discussed in the EA (Section 3.5). The portion of the trail that you have expressed your concern about is not located on NFS lands and therefore would not be under Forest Service Management. The mitigation measures and trail design standards are only required for NFS lands, though they are recommended for all non-NFS lands. The intent for the mitigation for non- forest lands would be similar to Forest Service lands where if construction did occur on greater than a forty percent sideslope that retaining structures and matting could be installed to minimize the disturbance and encourage plant growth to minimize trail impacts. Monitoring should occur to assure that vegetation is established. 166. Comment H36: The impact should be increased from minor to either moderate or high in the appearance and maintenance of trail. Property owners in this area have been restricted from ―scarring‖ the land unnecessarily. Similarly, it would be unacceptable for a trail to create an obvious scar across the mountain face visible from most anywhere in the valley. Lots of signs would likely be seen by neighboring land owners. 166. Response: The potential effects of the BST on visual quality are discussed in the EA (Section 3.5). Based on trail track width, BMPs, and other mitigations measures, the analysis shows that where the proposed trail is constructed it may be visible to local residences in foreground for the short-term until vegetation is established. 167. Comment H41: Segment 3 of Alternative 2 would only be acceptable if the trail is placed so it is hidden from view by passing through the scarce clumps of Scrub Oak and /or Big Tooth Maple growing on the hillside. The thickest clumps are located very high on the slopes adjacent to rock cliffs. 168. Comment P17: screen the trail The negative visual impacts of hikers/bikers to the many hundreds of homeowners who would be seeing them, could be somewhat mitigated by careful attention to trail placement. Wherever possible, locating the trail above oak brush and mahogany would not only screen the users from the homeowners but provide welcome shade to hikers from afternoon sun. 167-168. Response: The potential effects of the BST on visual quality are discussed in the EA (Section 3.5). See Sections 2.2.4 and 2.2.5, Design Considerations Common to All Alternatives for common trail design and mitigation measures. 169. Comment P1, P3, P4: If the trail were to take alternate routes behind the private Z trail segments, it would require very deep and disfiguring cuts in very, very steep slopes behind the Z trail that would blemish forever the National Forest and be very expensive to cut in. 170. Comment P2: Significant disruption of the hillside and vegetation would be required to cut into the steep hillsides in order to construct the trail. This is visually a disaster and would violate the National Forest lands we love. 171. Comment F32: The segment running from Parley’s Canyon to the Mount Olympus Trail. (Crestwood Gully to end of Pipeline Trail) would be crossing an area with significant grade. While a trail could easily built across this grade, the trail would necessarily require significant erosion control measures and would be highly visible

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Bonneville Shoreline Trail Environmental Assessment from a distance, marring the natural beauty of the mountain further. 172. Comment P6, P11, P18, P22, P23, P25, P26: It is astonishing to me that the entities which propose this trail, which are supposed to be proponents of natural beauty and conservation, would actually scar the hillsides in the Mount Olympus area, with a biking/walking trail. If it is completed, it will be visible. The base of the trail and thus the vertical mountain side of the trail will require deep cuts, especially where the grade of the slope is steep, leaving a light brown dirt track across the mountain. The scar on the face of Mount Olympus that would be visible from any point in the valley and would never heal. 173. Comment P26: Building the Bonneville Shoreline Trail above the Eastwood and Olympus Cove residential areas is a bad idea. The trail will scar the hillside. There are many areas that it would have to cross that are extremely steep. Trail stability would be difficult to achieve without excessive reinforcement. The original trail across Parley’s Canyon showed signs of degeneration the first year it was built. The Bonneville Trail across Mt. Olympus would be even worse. 174. Comment P8, P9: We are very much opposed to your proposed route. Why scar the mountainside for the benefit of a few; but to the visual detriment of many? 175. Comment P15, P16, P31, P32, P33, P35: Significant disruption of the hillside and vegetation would be required to cut into the steep hillsides in order to construct the trail. This is visually a disaster and would violate the National Forest lands we love. Our views will be a visual eyesore. 176. Comment P20: It is very disturbing to us to learn that a hiking and cycling trail may be built on the side of the hill across the street from us. We are unable to determine the exact location because of the scale of the maps provided, but it is almost certain to result in a serious scarring of the beautiful hillside as it has existed up to now. 177. Comment P27, P30: Substantial scarring on the mountainside will result in the event that the Mill Creek-Neff’s Canyon Segment is constructed as currently proposed. The EA downplays the negative effect that the Mill Creek- Neff’s Canyon Segment will have on the scenery and scarring of the Mt. Olympus mountainside. For example, the EA claims that the construction of the trail would ―cause minor adverse impacts on the scenery of the area, with most viewers and recreational users not noticing a change in the landscape’s overall natural appearance.‖ Our client disagrees with this conclusion, and believes that the scarring on the mountainside as a result of the Mill Creek-Neff’s Canyon Segment would be substantial and detrimental to the overall beauty of Mt. Olympus. It would require cuts and fills to be located on a steep hillside. Any scarring is made even more troubling by the fact other alternatives exist which will not result in new, visible scarring. 178. Comment P37: I am writing to express my concerns and opposition to alignment 2 and alignment 3 of the Bonneville Shoreline Trail (BST) for segment 1 (Parley’s Canyon to Millcreek Canyon). I believe that the large cut that will be needed to construct a three foot wide trail will be visible along Crestwood Drive from the street level and from all streets below Crestwood and that this will be totally unnecessary visual blight. 179. Comment P13: The appearance of the trail to the public would be less than beneficial and would detract from the natural

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Bonneville Shoreline Trail Environmental Assessment feeling of nature. This comment comes from Section 3.5.2, under segment 1, where you imply that the trail ―landscape and character and sense of place is expressed at the highest possible level.‖ That is contrary to the real feeling of the natural look when there is no trail as now. Keep it that way. The trail would be extreme and not beneficial. 180. Comment P41: I urge you to stop the destruction of our beautiful mountains and environment that has been provided to us by nature. It is as wonderful to look at our awesome mountains and be thankful for the beauty they provide to all of us. 169-180. Response: Scenery is addressed in detail in the EA Section 3.5. Scenery management and visual quality is an important consideration of the Forest. It is addressed in the Forest Plan through goals, objectives, standards and guidelines. Scenery is an important natural resource of the WCNF and the surrounding area. It has been shown that high-quality scenery can enhance people‘s lives and benefit society, particularly natural scenery such as is associated with National Forests (USDA 1995). The best predictors of the trail‘s effects on visual resources are examples of trails built to similar standards in similar landscapes. The photos included in the EA of existing BST segments predict what the proposed trail alignments will look like over time. The visual quality of the foothills has been greatly altered by housing developments and road construction. The viewshed from the base to the top of Mount Olympus is not pristine. User-created trails are also evident in some places. Under both action alternatives, existing user created trails would be rehabilitated and the proliferation of user created trails is predicted to decline. Signs would be simple and unobtrusive, but strategically placed to provide trail users with confidence in their location and direction of travel. The EA recognizes that the trail would be visible from some vantage points, but the proposed design standards are for a narrow (24‖ to 36‖), natural surface trail that much of it would be screened by the topography, land forms and vegetation. Trails sides would be revegetated with native plants. Recreational access is an important function of National forest lands. The alternatives for the proposed BST seek to minimize the visual quality impacts of the trail while providing for a quality recreational experience to the public. 181. Comment P7, P40: Your proposal indicates you wish to follow the Bonneville Shoreline. If you follow that shoreline with veracity, in this area, Wasatch Blvd. is the Bonneville Shoreline, not some human created level along the side of the mountain, built there, in order to satisfy the proposal. What’s the point of going up the mountain and scarring it? 181. Response: The BST memorandum of understanding (MOU) identifies nine criteria for the BST trail including that the trail will be built on or near the foothill bench generally considered to be the eastern shoreline of ancient Lake Bonneville. Other criteria include maintaining a distance from automobiles that is both safe and aesthetically pleasing, providing access to public lands and the resources associated with those lands and that the trail will be separate from the developed urban area, but trailheads will provide access that is convenient for residents of urbanized areas (EA Section 1.1.3). The alternatives were designed to best meet the criteria in the BST MOU, the Wasatch-Cache Forest Plan, and the Bonneville Shoreline Trail Alignment Plan. 182. Comment P12: unsightly user-created trails The proposed trail would have significant negative effects on land that is currently untouched (in the past eight years, I have almost never seen anybody in the hills above our house). The trail itself would leave a

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Bonneville Shoreline Trail Environmental Assessment large, visible, and erosion-prone scar. Perhaps more importantly, unauthorized side trails would be unsightly (witness the many unsightly side trails around the BST near the University of Utah School of Medicine). I realize that such trails would be discouraged and that most of the users of the proposed trails would be considerate and law-abiding. My concern is with those who are not. 182. Response: The issue of user created trails is addressed throughout the various resource sections of the EA including, visual quality, wildlife and fish, soils and erosion, recreation and visitor use and others in Chapter 3. The problems with user created trails near the University are also recognized in the EA. 183. Comment P21: Destruction of unmarred, pristine mountainside (with the exception of Skyline's S). I know you can see the difference between the north side of Parleys and this segment of land. Please don't make the same mistake. When people drive down I-80 from the airport, they see how beautiful the mountainside is and it is so impressive. 183. Response: The potential effects of the BST on visual quality, including the segment that includes Mt. Olympus, are discussed in the EA (Section 3.5). Maintaining the visual quality of Mount Olympus, consistent with Forest Plan direction, is important to the National Forest. The proposed trail, while visible at some vantage points, would be designed to reduce the visual impact of the trail on the mountainside. Also note that the foothills, in the vicinity east of Skyline, is perhaps the most affected by user-created trails that are visible from numerous vantage points in the Mill Creek area. 184. Comment P28: This plan will likely disfigure the beautiful mountainside that was a major selling point when we purchased our home in this area. 184. Response: The potential effects of the BST on visual quality are discussed in the EA (Section 3.5). Effects to private land owners with regard to property values and other social issues are discussed in Section 3.10. Proposed trail design would be consistent with the Wasatch–Cache Forest Plan and would meet visual quality standards and be consistent with the Scenic Integrity Objectives in the Forest Plan. 185. Comment P36: The trail will also take away from the visual quality of the mountains. Once the terrain has been cut and damaged it never returns to its original splendor. Point in fact are the natural gas and crude oil pipelines that have been allowed to cut through the state. The Chevron crude oil pipeline running from the Uinta basin to the Wasatch front refineries has been in place for years. The scars to the terrain have never healed. This proposed trail will impact the environment and aesthetic beauty in a similar way and the damage is irreversible! 185. Response: The potential effects of the BST on visual quality are discussed in the EA (Section 3.5). Gas and oil pipelines typically have a much larger footprint than the proposed trail. In addition pipeline corridors must be maintained in an open corridor for maintenance, inspection and safety reasons. Design considerations for utility corridors need to consider access, maintenance, costs and construction issues and are less likely driven by scenic values than are recreational trails on National Forest lands. 186. Comment P39: The visual scarring from the trail is obvious. Although you have taken pictures in the middle of the summer

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Bonneville Shoreline Trail Environmental Assessment when foliage is helping to cover the ―gash‖ above Hidden Valley Park, it would have been better to take the pictures during winter when this ―bath tub ring‖ is unsightly and a disgusting reminder of poor implementation of an idea. 186. Response: The potential effects of the BST on visual quality are discussed in the EA (Section 3.5).The analysis recognizes that the trail will be visible in some places and from some vantage points based on the topography, land form, and vegetation cover of the area. The analysis has been modified to include the seasonal variation. 187. Comment F41, P42, P44: Significant disruption of the hillside and vegetation would be required to cut into the steep hillsides in order to construct the trail and cut area. The 13 foot trail and cut area would be a very visible scar from miles away. The open space will be gone and will be replaced by a horrible scar 10 to 20 feet wide across a beautiful unbroken hillside 187. Response: See response to comment F14 and others above. Trail design specifications are outlined in Section 2.2.2 through 2.2.5 of the EA. Trail clearing widths are anticipated to be approximately 8-10 feet wide. The trail design criterion specifies approximate tread widths of 36 inches for non-Wilderness sections of the trail and 24 inches for Wilderness sections. Specific analysis of the visual impacts that would be anticipated under all alternatives is detailed in the EA (Section 3.5). 188. Comment P47: Proposed Segment 5. Who has hiked the proposed path to see what it actually looks like? The slope may be 45 degrees uphill, which means the scar will be higher than 10 feet, and the Mill Creek side of the ridge is extremely rugged (though the commonly used contour map depicts it as gradually sloped as the west facing part of the ridge). The AP suggests that "Slopes in this section would allow construction by machine" (p.73), though the oral comments at meetings say the trail will be constructed by hand, with no machines. Which is it? 188. Response: Forest Service, Salt Lake County, National Park Service and Contractor personnel have all hiked the entire alignment, including all segments. This impact assessment and analysis is based on information gained during physical reconnaissance of the segments. The EA states that the trail would be constructed by primarily by hand and would use native materials. Motorized trail equipment, including a trail cat (60‖ bulldozer) and trail power rake could be used in areas with access primarily to conduct revegetation efforts on old roadbeds and user created trails. 165-188. General Response: Although comments 165-168 may discuss specific locations they all have a consistent theme of; ―if standard construction practices of digging a trail into a slope is used in a 40% or greater cross slope the effects would be greater than discussed in the Draft EA.‖ We agree, if no mitigation measures were utilized, impacts could be greater than described in the Preliminary EA. We have modified the mitigation measures for the construction of the trail in the EA to those concerns. See Section 2.2.4, Trail specifications. We have also supplemented and modified the analysis to address those concerns more fully. See Sections 3.5 Open Space, Scenic Integrity, and Aesthetics and 3.6 Soils Erosion and Compaction.

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Bonneville Shoreline Trail Environmental Assessment

13. Wildlife (Not Including Listed or Sensitive Species) and Wildlife Habitat 189. Comment Q1, Q7: correction in winter range analysis The document states that construction of this trail will have ―considerable adverse long-term effects. Big game winter habitat would be fragmented and 48 acres/mile of current habitat would not be used as it is now.‖ How does a three foot path and a cut slope have 48 acres per mile in impact? Regardless of the acreage this assessment does not include disruption of vertical migration routes, disruption of fawning and calving areas, impacts from dogs and human harassment nor does it add these cumulative impacts to other habitat cumulative impacts on the Wasatch Front. The impacts from this proposed action must be added to historic actions at least within the big game polygons drawn on your maps. Then a cumulative impacts analysis to big game must be completed across their range. 189. Response: The word ―considerable‖ is incorrect based on the specialist report that concluded the effects would be minor adverse long-term effects. This is based on the short-term impacts, while adverse, would be concentrated in a short period of time and the long-term adaptation of big game species to a single trail verses the continued use of a number of user-created trails across the landscape. Fragmentation of habitat occurs when the habitat is broken into large sections by some sort of disturbance like wildfire, where the habitat type is substantially changed into a different habitat type. Habitat fragmentation does not occur when the occupancy, reproduction or survival of the species is not affected. While some big game species may avoid the trail when occupied by humans, it would not affect their overall population. Based on studies by Taylor and Knight (2003) at Antelope Island State Park, animals within 100 meters of a designated trail, move away from the area when it is occupied by humans hiking or biking on the trail. This figure increases up to 390 meters for human use on user-created trails. The response also varies depending on the density of the surrounding cover. In more open areas the distance will be greater, in heaver more densely vegetated, areas the distance will be less. For purposes of this analysis a figure of 400 feet avoidance distance was applied to both sides of the entire trail (approximately 800 feet – 400 feet on each side of the trail). The acres that may be avoided by deer would be a maximum number for the short term. In spite of these conditions, it is expected that some animals would acclimate to the human presence and others will seek more secluded habitat at higher elevations. People frequently observe deer and elk in their backyards all along the Wasatch Front. It is possible to theorize that instead of big game species being forced into human-impacted habitats created by human encroachment, they are instead adapting to live in and near human developments as selective advantage changes (Thompson and Henderson 1998). The elimination of use of user-created trails will further confine activities to a known area and provide deer and elk with a predictable area of human use. Again, the major problem is that housing developments and uncontrolled human and domestic dog activities on user-created trails in the area have encroached, and continue to encroach, into deer and elk habitat. 190. Comment Q2, Q37, Q26: loss of winter range This is a natural winter range for a fairly good number of deer and elk. They are dependent on the natural flora and vegetation in the late winter/early spring for survival. We have taken enough of the natural winter range. Isn't that what the hillside ordinance was for? Trail access for the hikers has drastically fragmented critical deer range. Construction of the BST will further fragment critical deer winter range.

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Bonneville Shoreline Trail Environmental Assessment

By placing the trail on a steep hillside you will be forcing the game away from much needed areas of lower altitude to provide protection from the elements during key stages of their lives: calving, fawning and winter nesting. 190. Response: Wildlife habitat is addressed in the EA under Section 3.2. Fragmentation of habitat occurs when the habitat is broken into large sections by some sort of disturbance like wildfire, where the habitat type is substantially changed into a different habitat type. Habitat fragmentation does not occur when the occupancy, reproduction or survival of the species is not affected. While some big game species may avoid the trail when occupied by humans, it will not affect their overall population. Deer and elk habitat does not stop at the Forest Service boundary; it formally extends into the foothills that are now being removed from accessible habitat by human developments outside the scope of the USFS. For mule deer and elk winter range, the increased housing developments in lower elevation habitat would continue regardless of the implementation of the proposed action; this development will continue to force the deer and elk to use higher elevation lands. The winter range protection afforded by National Forest would remain largely unchanged. Approximately 11.4 miles of new trail and access points would be in crucial deer habitat; 3.7 miles of which are on Forest Service managed land. Approximately 4.8 miles of existing trail would become part of the formal trail system. The number of miles of user developed trails that would be eliminated is not known. The majority of the proposed trail is on the western edge of the designated crucial deer habitat, habitat that is currently used frequently by recreationists. There would be short-term impacts from construction activities; however, these activities would be mitigated through timing construction to when the deer will have moved into higher elevations. In addition, while some long term effects are inevitable, implementing the proposed action creates a platform for which to better manage increased visitor use, and minimize resource damage. In this light, the long term effect is expected to be minor and is the confinement of deer and elk to suitable habitat on the National Forest and control of the deer populations through Utah Department of Wildlife management efforts. 191. Comment Q15: critical time closure – winter range The south slope is definitely critical winter range for mule deer, but most critical in the early spring (late February, all of March, and till mid April). During this time this slope is frequented by as many as up to 50 deer observed at one time. These deer are in their weakest physical condition at this time. Through many years of first hand observation, the mule deer will tolerate a single human or dog moving them around the side of the mountain and simply rotate on the mountain. However, multiple intrusions, during this time of year, cause the animals to leave the mountainside entirely (not just until dark as implied by the draft EIS text). If this were to happen with consistent frequency of hikers, bikers and dogs, those animals would not be temporarily displaced, but likely discontinue use of the area which means that this winter range habitat area would be lost. I would suggest that a "space -time matrix" of impacts would reveal that if the trail would be closed for use during this critical mule deer time, the impacts would be entirely mitigated. The rest of the year, mule deer leave for higher ground, or can easily hide and escape the impacts. The trail use would then have little or no impact. In that regard the "leave until dark" scenario is accurate, but that is not accurate during the critical spring months. 191. Response: In a Montana study of dogs and wildlife interactions, Sime (1999) stated that dogs with people, dogs on- leash, or loose dogs demonstrated very distinct disturbance reactions from study animals. He also noted that no study came to the conclusion that domestic dogs had a significant influence on overall population dynamics.

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Bonneville Shoreline Trail Environmental Assessment

Other studies (Taylor and Knight 2003, and Lenth et al. 2006) found that deer will not come within 50 to 100 meters (164 to 328 feet) of a trail occupied by humans, mountain bikers or equestrians. The minimum distance increases to 100 to 394 meters (328 to 1,280 feet) when the human is accompanied by a dog, depending on the type of trail. User-created trails or hiking off-trail create the greatest disturbance. Miller et al. (2001) noted that special behavior of off-leash dogs is unpredictable. Dogs wandering off-leash and off-trail are likely to elicit a flush response from deer even if the dog does not chase the animal. Whittaker and Knight (1999) said that predictable spatial activities, such as activity restricted to trails, allow wildlife to habituate to the disturbance. Based on these studies, it is expected that the creation of the BST would result in fewer impacts to deer and elk by consolidating the existing user-created trails into one known area. The deer would become better adapted to where to expect human disturbance and be less prone to flight and undue expenditure of energy reserves. According to Thompson and Henderson (1998), deer and elk do become habituated to humans. This in turn causes management problems for wildlife managers as well as land owners. Other researchers (Miller et al. 2001; Whittaker and Knight 1999; Sime 1999; Taylor and Knight 2003; and Lenth et al. 2006; Mule Deer Working Group 2003) have suggested trails, roads and other areas be closed during critical times of the year to reduce disturbance to deer and elk, just as you suggest. While these suggestions will be evaluated for inclusion in the regulations adopted for the BST system they are not part of required mitigation in the USFS decision. See also response #‘ 189, 190 and 197. 192. Comment Q3, Q11, Q14, Q17, Q18, Q19, Q22, Q23, Q24, Q27, Q28, Q29, Q35, Q41: disruption to wildlife Deer and other native fauna (coyotes, rabbits, foxes and elk, rattlesnakes) now flourish in the foothills because they are protected. This will not be the case once the area is open to hundreds or thousands of bikers, walkers, and their unleashed dogs. As of now there is scarcely a soul there and the big game literally roams free. These creatures have more right to be there than the bikers or hikers. During winters many deer come down for food and shelter. We believe the impact should be increased from minor to either moderate or high for wildlife because this is rattlesnake, gopher, snake, hawk, buzzard, and coyote country and they control rodents such as mice and ground squirrels. When foot traffic increases and animals move to other areas, the natural food chain is altered. Crestwood Gully and from Parleys to Mt Olympus, Above Canyon Cove subdivision Response to Issue 192: Wildlife habitat does not stop at the Forest Service boundary; it formally extends into the foothills that are now being removed from accessible habitat by human developments outside the scope of the USFS. The increased housing developments in lower elevations would continue. These actions would bring changes to the area surrounding the trail as humans and domestic animals venture into existing occupied habitat normally used by the species listed above, regardless of implantation of the proposed alternative. The protection afforded to these species and their habitat on Forest Service land would remain unchanged. In addition, while some long term effects are inevitable, implementing the proposed action creates a platform for which to better manage increased visitor use, and further minimize resource damage. Currently, hikers and bikers are not restricted to a specific trail system in the area. As a result, many user defined trails exist. With implementation of the BST system, it will be easier to focus recreational use to specific areas. This will increase available undisturbed habitat for use by wildlife. The long-term effect is expected to be movement of these species to suitable habitat on the National Forest or other available land away from the Project Area. Control of the human encroachment and additional impacts to the species and their habitat would have to come through local, county and Federal management

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Bonneville Shoreline Trail Environmental Assessment regulations and efforts. It should be noted that more than 15 miles of the trail are/will be monitored or patrolled by local municipalities. Existing county, municipal and federal regulations for domestic dogs require control of dogs with a lease or by other means. Local enforcement of the regulations will hopefully be easier with the development of the BST system and elimination of user-created trails. See also response #‘s 189, 190, 191 and 197. 193. Comments Q5, Q13, Q38, Q32, Q27, Q31: habitat fragmentation A multitude of wildlife utilizes the area. Their habitat would be severely impacted by the trail. The entire length of the proposed trail serves as a wildlife corridor, which would be significantly reduced by the heavily traveled trail. In the previous two years, I have observed herds of deer that number between 20 and 30 animals grazing in the areas proposed for the Heughs Canyon part of the trail’s connection. I would be concerned for these animals and their forced placement if people are allowed to hike through their habitats. I am writing to express my concerns and opposition to alignment 2 and alignment 3 of the Bonneville Shoreline Trail (BST) for segment 1 (Parley’s Canyon to Millcreek Canyon). Alignments 2 and 3 will definitely push wildlife up to higher elevations on Segment 1. Easement from Crestwood Drive: Wildlife habitat (ie., coyote, deer, elk, bobcats) has been dramatically impacted. We remain confident that professionals will hold steadfast to preserving the vegetation, wildlife, recreation, open space, visual quality and aesthetics, traffic, soils, water resources, cultural resources, fires and private property. 193. Response: Wildlife habitat is addressed in the EA under Section 3.2. Wildlife habitat does not stop at the Forest Service boundary; it formally extends into the foothills that are now being removed from accessible habitat by human developments outside the scope of the USFS. The increased housing developments in lower elevations would continue. These actions would bring changes to the area surrounding the trail as humans and domestic animals venture into existing occupied habitat normally used by the species listed above, regardless of implementation of the proposed alternative. The protection afforded to these species and their habitat on Forest Service land would remain unchanged. In addition, while some long term effects are inevitable, implementing the proposed action creates a platform for which to better manage increased visitor use, and further minimize resource damage. The long-term effect is expected to be movement of these species to suitable habitat on the National Forest or other available land away from the Project Area. Control of the human encroachment and additional impacts to the species and their habitat would have to come through local, county and Federal management regulations and efforts. See Response to Issues 189, 190, 191 and 197. 194. Comment Q6, Q7, Q20: lack of mitigation Fragmentation of habitat is a serious long-term impact to wildlife across the state and the world. An honest and extensive further analysis must be conducted prior to making any kind of decision for this and other alternatives. Treatment of the impact on Big Game Populations and winter range (Page 3-13, Section 3.2.2) is incomplete. While the document acknowledges that the wildlife would be impacted, it is not clear what steps would be taken to mitigate the impact. Deer numbers are said be below herd objectives already and it is not clear if the construction of the trail would further reduce this population. From this perspective, the proposed action seems unacceptable. A specific concern was the impact on wildlife from the trail as it crosses private property from Millcreek Canyon south above Parkview Drive to Neff’s Canyon. The preliminary environmental assessment acknowledges this risk but does not appear to address it in any respect.

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194. Response: Fragmentation of habitat occurs when the habitat is broken into large sections by some sort of disturbance like wildfire, where the habitat type is disturbed. Habitat fragmentation does not occur when the occupancy, reproduction or survival of the species is not affected. While some big game species may avoid the trail when occupied by humans, it would not affect populations overall. The USFS, in its 3/17/06 scoping notice, recognized the private land alignment issues and stated ―No trail construction will occur on private land without appropriate authorization from the landowner and local government agency‖, and ―The environmental analysis for this proposal will include analysis for all sections of the BST, including non-NFS land, however the USFS has the authority to make decisions only on NFS land sections of the trail. All decisions regarding BST trail construction on private land will be made by the landowner and local government agency that has jurisdiction over the lands in question. Those local governments have adopted plans for the BST in their jurisdictions‖. The USFS recognizes private landowners‘ rights and has agreed to not build any trail on NFS lands that does not have legal access at both ends and recognizes that some sections of the trail (on NFS and private lands) may not be built if access and easement issues are not resolved. However, the USFS believes that it is important to move forward with the BST concept in Salt Lake County and that the proposed alignment provides the best starting point, despite the potential limitation due to private land issues. Decisions on the trail on private land segments will be determined by landowners and the local government agency with legal jurisdiction of the land parcel in question (WCNF 2007). See Also response #‘ 189, 190 and 197 for additional discussions of mitigation changes to winter habitat for deer and elk. 195. Comment Q9, Q24: The deer which now freely roam the streets and yards in this area would be pushed back farther into the mountains. Wildlife viewing opportunities would cease. 195. Response: The long-term effect is expected to be movement of these species to suitable habitat on the National Forest or other available land away from the Project Area. Established trail systems provide access to areas on Forest Service managed lands for wildlife viewing opportunities. For further information, Wildlife and Wildlife habitat is addressed in detail in the EA under Section 3.2. 196. Comment Q10: snails There are many species of rare snails that live along the Wasatch Front in canyons and along ravines. The Wasatch-Cache FEIS for the Forest Plan in appendix B2, pages 31 to 32, describes many of these snails. The BST EA should analyze the effect of the new trail segments on these snail species as the trail will cut through known habitat for many of these species. Of particular concern is the effect on the Mill Creek mountain snail, which is very rare and limited in distribution. 196. Response: A careful review of the status of the 11 terrestrial snail species and related habitat, as listed in Table B2-11, of the Wasatch-Cache National Forest FEIS, appendix B2, pages 31 and 32, to which you referred is as follows: 1. Four of the 11 species listed do not have habitat or are not found within the foot print of the proposed trail alignment. 2. Two of the 11 have not been found in Salt Lake County since the early 1940‘s. 3. Three others were only found above 7,500 feet in elevation. The trail ranges in elevation from 4948 feet at the beginning to a high point of 6145 feet in segment 1; in segments 2, 3 and 4, the trail elevation is between 5141 feet and 5840 feet. 4. Another species, according to the Utah Natural Heritage database (UDWR 2008) and mollusk literature review publication (Oliver and Bosworth 1999) may or may not be a distinct species; it

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may just be a variant of the more common Rocky mountainsnail. 5. The Mill Creek mountain snail, the final species, is not found in the vicinity of the proposed BST. It is not included in the Utah Sensitive Species List dated December 14, 2007 (UDWR 2007). This publication states, ―The … species on the Utah Sensitive Species List, ―wildlife species of concern,‖ are those species for which there is credible scientific evidence to substantiate a threat to continued population viability‖ (UDWR 2007). There is some question as to the validity of this being a separate species or just a color variant of the Rocky mountainsnail. Additional studies are needed, according to UDWR, to determine if it still exists or is truly a separate species. If, during construction of the trail, a population of snails is encountered, they would be identified and every effort would be made to ensure the population is not adversely affected. 197. Comment Q33: Page 3-16 Segment 2. The statement there is factually incorrect. Segment 2 differs significantly from segment 1, namely what direction the hillside faces. Instead of northwest like segment 1 if faces southeast, and since it’s a hillside it’s tilted up right into the afternoon winter sun. It’s common to see 30-50 mule deer on the hillside above the North end of the Canyon Cove subdivision. Many winter in the draw just north of Heughs Canyon. Consequently within1-2 after a foot of fresh snow falls that hillside will melt bare. The mule deer, chuckers, quail, and other wildlife know this and are commonly seen there in winter afternoons. This same thing (early snow melt) applies to the hillside above the present gun club area. I didn’t see any mention of the coyote families that live and roams between Tolcats and Heughs Canyons 197. Response: Thank you for your observations and comments of the area. The majority of the BST system in segment 2 is on the downslope edge of the crucial deer habitat; only 2.6 miles of trail, proposed for construction in this section, would be in crucial deer habitat. The result would be fewer impacts to these species by consolidating the existing user-created trails into one known area. The deer would become better adapted to where to expect human disturbance and be less prone to flight and undue expenditure of energy reserves. Additional information is available in Response to Issues 189 and 190. Coyotes and other wildlife are known to be in the area. They were not included for evaluation because of their ubiquitous nature and are not considered a Management Indicator Species or special status species. See Section 3.2.4 of the EA and Response to Issues 198 for additional discussion and description of Management Indicator Species. 198. Comment Q36: Concern expressed about the significant impact that the Mill Creek-Neff’s Canyon Segment would have on the wildlife (including without limitation deer, mountain lion, bobcats, western desert cottontail, quail, chukar, etc.) located in the area. The thriving wildlife habitat in the area surrounding his property, and is concerned that the Forest Service has not adequately focused in the EA on the effect this particular Mill Creek- Neff’s Canyon Segment would have on such wildlife. This concern is highlighted by the fact that the EA does not even mention by name several species of wildlife that habitat the area, including several of the above-listed animals. 198. Response: See Response to Issue 197.

14. Wilderness 199. Comment D4, I44, R4: wilderness and bikes As the trail is planned I would hope some thought is given to prevent ruling out bikes. Perhaps an exit/entrance trailhead at the Wilderness boundary on each end would allow bikes to detour. Maybe

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Bonneville Shoreline Trail Environmental Assessment landowners could be persuaded to sell a thin swath of land. I do not know the exact wording of the wilderness bill but if it is within the parameters of the bill to walk or carry a bike through the short stretch, please make that known. If it is impossible to include bikes in this part of the trail so be it. Just please make every effort to build the non wilderness parts with a grade bikes can pass. I think mountain bikers are huge fans of the shoreline and are supportive of the expansion. But I think you saw less support at the meeting from bikers due to the fact that it crosses wilderness. It doesn’t look like many segments from parleys canyon to Big cottonwood would be ride able. Is there any prospect of getting some wilderness exception or corridor of some type for the shoreline trail to allow bikes? I also have a concern about the trail crossing through Wilderness Areas in 2 places, near Mt. Olympus and south of Heughs canyon. Since the bicyclists make up the majority of BST users, threat creates a problem. To make part of the trail off limits to bikes or to set up a scenario in which bikers regularly violate the wilderness restrictions would significantly diminish the value of the trail and would be unacceptable. It is my understanding that to move or modify a Wilderness boundary, an act of US Congress is required and that action appears to me to possibly be justified in this case. I request that you investigate the possibility of changing that Wilderness designation to allow bike traffic and consider that as one of your construction options. I also request that, in doing so, you consider minimizing the amount of Wilderness impacted by keeping the trail alignment as close as possible to the Wilderness/private property boundary. 199. Response: In Alternatives 2 and 3, mountain bike use would only be permitted in sections that are located entirely outside of Designated Wilderness and that have formal trailhead or access points. Since each segment has either a trailhead or access point, it would be possible to continue along the current BST connector (Wasatch Blvd) using the city/state/county road system. Any changes to Wasatch Blvd or other local roads are not under the jurisdiction of the Forest Service. The use of Wasatch Blvd is also reflected and analyzed under the No Action Alternative. The EA has been revised to include access routes to inform users how to access the access points from Wasatch Blvd and assist in improving connections between segments. You are correct that changing a wilderness boundary requires an Act of Congress. As such it is outside the scope of our authority and was eliminated from in depth consideration. 200. Comment R15: difficulty of management Alternatives 2 and 3 include proposed trails through portions of designated wilderness areas, with attendant mechanized travel restrictions. This will be very difficult to manage. The EA should include an analysis of mountain bike impacts on these areas. 200. Response: Mountain bike impacts in these areas are included in the Wilderness and Recreation Sections (3.3 & 3.4) of the EA. While implementing the proposed action may have adverse long-term effects through an increase of visitor use, consequently impacting Wilderness character, beneficial effects may also occur. Through the creation of an established trail system, the WCNF will be able to better manage visitor use, minimize resource damage and in turn provide Wilderness experiences for more people. In addition, funding and personnel from land acquisitions, planning grants, Salt Lake County, Salt Lake City, non-profit organizations and volunteer labor will be used to plan, build and maintain the trail. All trail design and construct is to be implemented in accordance with USFS design standards and USFS trail construction standards. For these reasons, concerns such as trail proliferation, trail administration and trail management are considered to be minor with the implementation of BMPs. 201. Comment R1, R5, R6 R8, R9, R10, R11, R16, R18, P45: Most adamantly many including myself are dismayed and will actively oppose the inclusion in the trail system of specially designated Wilderness Areas. These are special lands that should not be developed, by law, in any manner. Can you imagine the outrage that this violation of a national Wilderness Area in Mt

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Olympus will cause when better understood by the public? Imagine the reaction if it was violated for any other ―project‖. Wilderness. You say retain. But if the trail is used very much then the Wilderness will vanish and be replaced by cigarette butts, plastic water bottles and all kinds of man’s and woman’s and dog’s litter. Most trail users do not know what ―Pack it in, then pack it out‖ means or what ―Leave no trace‖ means. What wilderness that is there now will be gone forever. The importance of wilderness areas is that they are intended to be free from development by public or private interests forever; not subject to change at the whim of current planners. It is important for the preservation of national lands that once established as wilderness that they remain protected. The beauty of Mt. Olympus is that it has been maintained in a natural state and not defiled by the ever encroaching desires of public and private developers. To slash trails through this wilderness and to suffer the impact of the destruction needed to create the trails would forever disfigure this natural heritage. Wilderness lands would be recipient to high levels of damage (human and machine) 201. Response: Based on current and projected use and expanding adjacent populations, user-created trails and trail proliferation have been increasing and are expected to increase into the reasonably foreseeable future. Increased visitor use, user-created trails and trail proliferation may cause minor adverse effects to wilderness character, biological diversity, and overall recreation experience. While expanding the BST and creating an established trail system may contribute to some of these effects, it may also offer opportunity to minimize others. Funding and personnel would be allocated to the maintenance and administration of the BST, providing opportunity for the rehabilitation of user-created trails, and placing USFS technicians in the field to enforce wilderness regulations, thus minimizing trail proliferation. Implementing the proposed action creates a platform for which to better manage increased visitor use in effort to minimize resource damage while preserving Wilderness characteristics. In this light, implementation of the proposed action would be consistent with Wilderness regulations and the WCNF Revised Forest Plan. The WCNF Revised Forest Plan states that no additional trails would be built into the Wilderness except to facilitate short segments of the BST and only where absolutely necessary to minimize resource impacts or to better manage visitor use. The plan further states that the creation of additional user-created trails would not be allowed. Major emphasis would be placed on user education because of high visitor use and adjacency to urban populations. Approximately 2.74 miles of proposed trail would be built on Wilderness under Alternative 2, while Alternative 3 would have approximately 5 miles of proposed trail. Effects are considered to be minor based on the user restrictions set forth in the Wilderness Act and Forest Plan. The segments of proposed trail are considered to be minor when compared to the entire Wilderness area (approximately 36,464 acres). Further information regarding effects on Wilderness can be found in Section 3.4 of the EA. 202. Comments R13, R3: width of trail To summarize, this portion [Segment 3, Alternative 2] of the trail would only be acceptable if: The trail should only be two feet wide, per Wilderness requirements, rather than three feet as permitted on Forest Service land. Cutting through National Forest land which has been designated as wilderness area is wrong. It is our understanding that the trail would be 13 feet wide. This is uncalled for and we are sure that few people, if any, who live in the Mt. Olympus area, would consent to such a proposal knowing all the facts. We believe that such a proposal is unfair, illegal, and ill-planned and would be a terrible eyesore to those who love the beautiful mountain side of Mt. Olympus. 202. Response: All trail design and construct is to be implemented in accordance with USFS design standards and USFS

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Bonneville Shoreline Trail Environmental Assessment trail construction standards, which have be subject to prior environmental review. The trail design criterion specifies approximate tread widths of 36 inches for non-Wilderness sections of the trail and 24 inches for Wilderness sections. All sections of trail in designated Wilderness would be constructed by hand and utilized native trail surfaces, thus minimizing short-term direct effects to Wilderness character. 203. Comment R14: As the population of the Wasatch Front has grown, open space has declined. Can't we save what is left of the remaining open space without further crisscrossing it with more trails? 203. Response: Approximately 2.74 miles of proposed trail would be built on Wilderness under Alternative 2, while Alternative 3 would have approximately 5 miles of proposed trail. Effects are considered to be minor based on the user restrictions set forth in the Wilderness Act and Forest Plan. The segments of proposed trail are considered to be minor when compared to the entire Wilderness area (approximately 36,464 acres). The WCNF Revised Forest Plan states that no additional trails would be built into the Wilderness except to facilitate short segments of the BST and only where absolutely necessary to minimize resource impacts or to better manage visitor use. Given that visitor use, user-created trails and trail proliferation have been increasing and are expected to increase into the reasonably foreseeable future, the proposed action would be consistent with Wilderness regulations and the WCNF Revised Forest Plan.

15. Private Property 204. Comment E1, M17: liability In the unlikely event those private land owners grant an easement to build the trail across private lands, who will maintain legal liability, for lands not in the easement, if and when hiker/biker decides to go off-trail (which is a serious issue on existing trails in your system) and is injured? In the unlikely event that landowners grant easements for this trail in this section who will be liable for events that occur off-trail on adjacent private lands? Clearly the answer would probably be the landowner. The potential for an incident occurring and associated costs must be analyzed. 205. Comment S1, S17, S22, S24, S27, S38, S45, S62, S73: property values The trail and associated trailheads will cause our property values to go down. Ruining the view of owners living in the neighborhood, increased traffic, less solitude, and less wildlife viewing will affect dramatically values of our homes. 204-205. Response: The State of Utah, similar with most states, has statutes that protect private property owners who allow recreation on their property as long as no fee is charged. The effects of user-created trails are discussed in numerous sections in Chapter 3 of the EA. Property values are addressed in the EA under Section 3.10. 206. Comment S2: The Forest Service ―recognizes private landowner’s rights‖ and has agreed not to build any trail on NFS lands that do not have legal access at both ends. It is highly unlikely that landowners between Mill Creek and Neff’s Canyon will grant an easement or right-of-way to build the trail across this section; therefore, this document should include other alternatives, not identified in this document, if the Forest Service ―…believes that it is important to move forward with the BST concept in Salt Lake County…‖ That section also states: ―Please note that trail impacts on private property will be analyzed. Analysis and decisions on the trail on private land segments will be determined by Salt Lake County.‖ This implies that the County will conduct the same level of analysis yet the statement above is contradicted by another

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Bonneville Shoreline Trail Environmental Assessment statement in the same paragraph that says: ―The environmental analysis for this proposal will include analysis for all sections of the BST including non-NFS land…‖ This issue clearly needs clarification and considerable further analysis and should not be dismissed. Note: A list of confusing and contradictory statements in your document, while to numerous to mention in this comment letter, can be made available upon request. 206. Response: The purpose of the environmental analysis is to analyze only those sections of the BST that are located on Forest Service lands. However, the impacts of the trail located on Forest Service lands are studied for effects on both Forest lands and adjacent lands. It is expected that the County would rely on the environmental analysis in this EA as a basis for their decisions on County managed lands. An alternative to locate the trail entirely on NFS lands was considered and most segments were eliminated from further consideration based on steepness and inconsistency with the purpose and need (see Section 2.3). The EA recognizes that some sections of the trail on private land may never be constructed and include a discussion of access routes to disclose potential impacts of users using existing roadways to connect uncompleted sections of the trail (Sections 2.0 & 2.1) . 207. Comment J37: Page 1-11 quotes the Forest Service as saying "'No trail construction will occur on private land without appropriate authorization from the landowner and local government agency'" (italics added for emphasis). We will not give permission to take or use our property because of the safety concerns of the steep slopes, and here the Forest Service has promised not to construct without it. Please change Alternative 2 Segment 1 to include use of Wasatch Blvd. rather than our backyards. 207. Response: As you noted, the Forest Service has no authority to authorize any improvements on private land. The Responsible Official may approve an alternative intact, as presented in the EA, or select an alternative that is a combination of elements of various alternatives, including the No-Action Alternative. See also response # 206. 208. Comment S4, S5, S20, S41: Trail users have no regards or respect for private property. This proposal will be a disaster for all homeowners in the area. A portion of the Z Trail runs directly through my property and I am daily bombarded with trespassers using the Z Trail and ignoring the trail and ―short cutting‖ and trespassing across my front lawn. Some trespassers even walk up and look through my windows as they ignore all my private property rights. Trespassing and ignorance to private property rights will be greatly amplified when and if the proposed Skyline Trail is constructed. Portions of the proposed trail for example the ―Z‖ trail runs directly thru private home lots. Many homes have the ―Z‖ trail in the midst of their fenced yards where they have had restricted access for over 15 years. None of these neighbors would agree to an easement, as all our property values would be adversely impacted. Portions of the proposed trail – particularly the ―Z‖ trail – runs directly along my lot line. Not only would this intrude on the privacy of our home, it would invite trail users to cut through our lot to access Thousand Oaks Circle. Once the public has a right to access the Z trail, they will believe they are entitled to trespass on our land for ingress and egress. We have already experienced hikers coming through our backyard during family BBQ’s and making a point that they have a right to access the National Forest area above our home. These confrontations would likely increase. We would have no choice but to fence off our land and have it posted.

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208. Response: Trespassing and private property issues are addressed in the EA under Section 3.10. Mitigating these effects revolve around effectively communicating trail regulations at each trailhead and access point, law enforcement and patrol. Private land owners retain the right to manage their property in a manner they deem appropriate and in accordance with local ordinances. 209. Comment S6, S9, S10, S19, S33: I will not sell nor grant an easement to any entity for the construction of the proposed trail across my land. Arlin Geophysical Company and Fujilyte currently owns the property on which the proposed Water Tank Access (Figure 3, Alternative 2, Segment 1) is in the process of being engineered as well as the property on Teton Circle which is presently used to access trails illegally constructed by trail users. The specific parcel numbers are 16-25-327-025, 16-25-327-023 and 16-25-376- 008. We have attempted to develop this property with a promise from Salt Lake City Officials that we would be granted approval for construction of five, five-acre home sites and agreed to grant trail access as part of our application for development. That approval has not been granted. We therefore do not grant any rights for the any trail access. We are angered by the lack of concern that the Ranger District has shown to us as private landowners as well as the continued trespass on our properties. It has come to our attention from the Preliminary Environmental Assessment Bonneville Shoreline Trail that the proposed Bonneville Shoreline Trail is planned to cross our property without our permission. For over ten years we have fought to secure our rights regarding our land and our rights to develop it while and warding against unauthorized access. We have installed ―no-trespassing‖ signs, erected chains and gates all of which the public has pulled down. Someone has even gone as far as to build a trail on our property without so much as a letter informing us of their efforts. A trail along the Bonneville Shoreline – which is a visible geologic, hydrologic and historic part of our state’s history – and one that would serve the greatest population, would be an asset to the community. However, the trail alignment in the Proposed Action should not propose to impact private property rights (by invading private property within the proposed route without the consent of those landowners) without the permission and participation [of] the landowners. The Proposed Action should not further exacerbate the cumulative impacts to the landscape from all of our activities along the Wasatch Front. Cumulative impacts (poorly compiled and analyzed in specific sections as shown below) from this proposed action must be added to the cumulative impacts of all other activities on public lands along the Wasatch Front. We live at 3985 Parkview Drive and control the family trust that owns the 18.79 acres of ground behind our home and the 2 homes to the south of us. This land is referred to in the Environmental Assessment document on page 66 as parcel number 1636477001. The proposed trail, as described in Alternative 2, goes directly through this parcel of ground. We have expressed multiple times in previous meetings that we will not grant any easement for a trail over this property, nor will we ever sell any portion of the property for the use of a trail. This property was purchased over 60 years ago to protect these homes from this very type of encroachment. 209. Response: The Forest Service, in its 3/17/06 scoping notice, recognized the private land alignment issues and stated ―No trail construction will occur on private land without appropriate authorization from the landowner and local government agency‖, and ―The environmental analysis for this proposal will include analysis for all sections of the BST, including non-NFS land, however the USFS has the authority to make decisions only on NFS land sections of the trail. All decisions regarding BST trail construction on private land will be made by landowners and the local government agency that has jurisdiction over the lands in question. Those local governments have adopted plans for the BST in their jurisdictions‖. The USFS recognizes private landowners‘ rights and has agreed to not build any trail on NFS lands that does not have legal access at

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Bonneville Shoreline Trail Environmental Assessment both ends and recognizes that some sections of trail (on NFS and private lands) may not be built if access and easement issues are not resolved. See also response #‘s 206 & 208. 210. Comment S8: Private Property: The private property I am aware of that goes to the top of the ridge cannot be crossed by the trail due to State Law. Your own statements that you would not build a trail to a property that you could not cross over seem to contradict your own design of the trail. Why waste money and time on this issue of the trail over private property when it is not going to happen. Go back down where the trail can function on Wasatch Blvd. 210. Response: This option is reflected in Alternative 1. The USFS believes that it is important to move forward with the BST concept in Salt Lake County and that the proposed alignment provides the best starting point, despite the potential limitation due to landowners and issues. Decisions on the trail on private land segments will be determined by landowners and Salt Lake County or the local government agency that has jurisdiction over the lands in question. See also response #‘s 206, 208, & 209. 211. Comment S18, S29, S30: At the north end of the proposed trail, a section of the trail appears to cross into property owned by Salt Lake City Corporation. This must be verified and if the trail crosses into SLC property then this proposed use must be approved through the City’s public process. There is private land owned by the residents at the end of Crestmount Circle, where the water tank is and where the trail would cross Heughs Canyon stream and going south. Would there be an issue with that? Portions of the proposed trail – for example the ―Z‖ trail run directly through private home lots. 211. Response: The Forest Service has no authority to make decisions on private or local government land segments of the trail and no trail construction will occur on private land without appropriate authorization from the landowner and local government agency. See also response #‘s 206, 208, & 209. 212. Comment S23: Decrease value of our homes, because of an ugly scar on what is now a beautiful environment and should not be relinquished to a convenience, which can be accomplished in many other already existing locations. 212. Response: The potential effects to private property are discussed in the EA in Section 3.10. Two other alternatives for trail locations (Alt. 1 & 3) are analyzed in the EA and are discussed in Chapter 2. 213. Comment S36: People who live in this area have paid a premium for property close to untouched and undeveloped National Forest land. It is my understanding that much of the natural area has been designated as a Wilderness Area not subject to further development. 213. Response: See response to #‘s 123 & 201. 214. Comment S42, S43, S46, S47, S49, S51, S52, S55. S66: I am strongly opposed to the Bonneville Shoreline Trail through Hughes/Canyon Cove area because the trail is too close to private homes. I am writing to express my concerns and opposition to alignment 2 and alignment 3 of the Bonneville Shoreline Trail (BST) for segment 1 (Parley’s Canyon to Millcreek Canyon). As a local property owner of Response to Comments 68

Bonneville Shoreline Trail Environmental Assessment long standing, I do not want increased ―walk-in access;‖ hunters and others are already coming down and attempting to access the street by going through our property. Publicizing and encouraging use of the BST will increase the likelihood of people disturbing property owners. It has recently come to my attention that there are tentative plans to make the Bonneville Trail accessible from the Canyon Cove Subdivision. I believe this location of a trailhead and parking will be the source of a significant loss of privacy to the neighborhood. In most cases, we believe the impact should be increased from minor to either moderate or high in the following areas: Impact on privacy of homeowners –For this segment, the proposed trail comes extremely close to (if not bordering) not only private property lines, but to the homes built on those properties. It would not be difficult to hear the conversations of those on the trail or for them to hear our conversations in the privacy of our back patio. We’ve tested this ourselves and could communicate quite easily from proposed trail site to our back patio. With the elevation and proximity to our home, hikers would be able to see in windows that were designed for our viewing pleasure. There are cases every year where hikers have simply passed through our back yard to get to the street because they are tired. After careful review of your proposed Skyline Trail access plan, we would like to verbalize our opposition to the proposal. There are many reasons for our opposition, which can be summarized as followed: There would be extensive violation to private property Efforts should be made to protect the property of those living near the trail, but they should have known where they were buying/moving when they selected their locations. Provide basic protection to adjoining property owners, but focus on the long term community benefits and objectives. My home can be seen from the ―Z‖ trail. The construction of the Skyline Trail incorporating the ―Z‖ trail will reduce the value to my property. I am also concerned about the loss of privacy and security that would result from the use of the trail. As it is snow whenever anyone uses the ―Z‖ trail I can hear his or her conversation on my patio and deck. The mountain acts as a megaphone for all sounds I like the proposed alternative, but what I don’t want to see is sections of the trail not completed because of private land issues. I recognize that this is a preliminary type of layout, and that adjustments will have to be made during design. I would assume that, if needed, portions of alternative 3 could be applied in the event that private property owners are not willing to allow the trail to be constructed through their land. Would a separate EA have to be completed to incorporate portions of alternative 3 into the design? It would be better if some sort of agreements could be documented with the private land owners prior to finalizing the proposed alignment for this study. Efforts should be made to protect the property of those living near the trail, but they should have known where they were buying/moving when they selected their locations. Provide basic protection to adjoining property owners, but focus on the long term community benefits and objectives. My home can be seen from the ―Z‖ trail. The construction of the Skyline Trail incorporating the ―Z‖ trail will reduce the value to my property. I am also concerned about the loss of privacy and security that would result from the use of the trail. As it is snow whenever anyone uses the ―Z‖ trail I can hear his or her conversation on my patio and deck. The mountain acts as a megaphone for all sounds I feel this is a significant violation of private property rights and could undoubtedly affect the value of our home. We are concerned that the PEA does not adequately address a number of issues that will impact the safety of our families and children. Trespassing issues. With the proposed trail being on a steep slope in our backyard, we are worried about increased traffic through our yard when trail-users decide not to continue on the trail (which becomes more

Response to Comments 69

Bonneville Shoreline Trail Environmental Assessment rugged once it crosses the ridge and heads toward Mill Creek Canyon) and, instead, seek the fastest route to a paved road, which would go through our backyards. The only trespassers we currently have to deal with are the illegal hunters who come through during a short hunting season. But with a trail, we have to worry about the harm caused by trespassers through spring, summer, and fall. The trail opens up our protected backyards and makes them vulnerable, and especially vulnerable to those currently hunting illegally with bows and arrows. 214. Response: The EA analyzes the effects of the proposed alternatives on NFS lands and the effects of a potential alignment on private land in Section 3.10. Since the Forest Service has no decision to make regarding alignment of the trail on private lands, there would no further NEPA documentation required by or for the Forest. However, the public agency with decision authority regarding trail construction on private lands may have requirements for further environmental or legal review or public involvement. There have been many studies that examine the effects of public trails on their adjacent neighbors. This website http://www.americantrails.org/resources/adjacent/sumadjacent.html summarizes many of them. In general studies find that: ―Homeowners nationwide express the same concerns and fears about proposed trails in their neighborhoods. But studies in various parts of the United States seem to show that concerns about trails lowering property values and increasing crime are unfounded. In fact, trails have consistently been shown to increase (or have no effect on) property values, to have no measurable effect on public safety, and to have an overwhelming positive influence on the quality of life for trail neighbors as well as the larger community.‖ (Webel, Suzanne. 2000. Trail Effects on Neighborhoods: Home Value, Safety, Quality of Life Are trails safe? How do they affect property values of adjacent residents? A summary of four studies) In another study: “The Impact of the Brush Creek Trail on Property Values and Crime” (Santa Rosa, CA, Michelle Miller Murphy, Sonoma State University, 1992) 64% of respondents felt the trail increased the quality of life in the neighborhood, with another 13% saying "no effect" 33% said the trail would make their home easier to sell, with 49% saying "no effect" 23% said the trail would make their home sell for more, with 69% saying "no effect" It goes on to state that; "The study shows neither increased crime nor decreased property values due to trails. On the contrary, the most overwhelming opinion by residents along the Brush Creek Trail is that the trail/creek has a positive effect on the quality of life in the neighborhood." From "Kent County Adjacent Businesses and Residential Landowners' Attitudes Towards and Use of the Fred Meijer White Pine Trail State Park in Michigan." Prepared by: Kristen Steger, Christine Vogt, Ph.D. and Charles Nelson, Ph.D. Department of Community, Agriculture, Recreation and Resource Studies, Michigan State University, 2000 Only 2% of businesses and 1% of residents believe the trail has a negative influence on the community. Eight in ten adjacent businesses and residents believe the WPT has a positive influence on the community and Kent County as a whole, while only 2% of businesses and 1% of residents believe the trail has a negative influence on the community and Kent County. Forty-seven percent of businesses believe the trail is a positive influence on their employees and two- thirds of residents feel it is a positive influence on their household. Conversely, 2% of businesses believe the trail is a negative influence on their employees and 7% of residents believe the trail is a negative influence on their household. Additionally most studies report that adjacent homeowners become heavy users of the trail with between 74% and greater 90% saying that they use the trail regularly or have used it in the past year. 215. Comment S54: On the whole, Alternative 2 will also raise property values because affluent out-of-state homebuyers who value outdoor recreation will be greatly impressed with quality-of-life attributes of the Olympus Cove.

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Bonneville Shoreline Trail Environmental Assessment

216. Comment S56: I feel this is a significant violation of private property rights and could undoubtedly affect the value of our home. 217. Comment S59: I like the current situation of Mile High Drive. I do not believe this proposal will improve my property value, my quality of living; my family's quality of living; my neighborhood's quality of living. 218. Comment S68: I am not in favor of the Proposed Heughs Canyon Access Point in both Alternative 2 and Alternative 3 proposals. I am not aware that I have an easement ordinance to allow a foot trail right-of-way to access Heughs Canyon from my property, nor would I be amendable to the idea. I often have hikers trespassing on my land to access the canyon when signs are clearly marked ―No Trespassing‖. Allowing foot traffic would devalue my property values, impact the vegetation and negatively impact the aesthetics and sense of open space my property provides. 215-218. Response: The EA analyzes the effects of the proposed alternatives on NFS lands and the effects of a potential alignment on private land in Section 3.10. The effects of a presumed trail alignment that crosses private are analyzed as connected or foreseeable actions; however the National Forest has no authority to make decisions regarding the use of private property. There have been many studies that examine the effects of public trails on their adjacent neighbors. This website http://www.americantrails.org/resources/adjacent/sumadjacent.html summarizes many of them. In general studies find that: ―Homeowners nationwide express the same concerns and fears about proposed trails in their neighborhoods. But studies in various parts of the United States seem to show that concerns about trails lowering property values and increasing crime are unfounded. In fact, trails have consistently been shown to increase (or have no effect on) property values, to have no measurable effect on public safety, and to have an overwhelming positive influence on the quality of life for trail neighbors as well as the larger community.‖ (Webel, Suzanne. 2000. Trail Effects on Neighborhoods: Home Value, Safety, Quality of Life Are trails safe? How do they affect property values of adjacent residents? (A summary of four studies). Studies also consistently show that realtors believe that trails adjacent to private property do not hinder the ability to sell a home, either increase or do not affect the value of a home and overwhelmingly use the location of nearby trails as a selling point for homes. Forest lands are public lands and are managed under the Multiple Use Sustained Yield Act that among other things states that: ―the national forests are established and shall be administered for outdoor recreation, range, timber, watershed, and wildlife and fish purposes‖ and that the ―Secretary of Agriculture is authorized to cooperate with interested State and local governmental agencies and others in the development and management of the national forests‖. Construction of a trail that provides recreation opportunities for the public is not considered a violation of the National Forest. There is little evidence that existence of a non-motorized recreational trail reduces property values and in fact, in some places has been shown increase the value of residential properties. The demand for recreational use of the Forest is expected to increase. All of the alternatives recognize some impact on private property. The EA states that: ―Actions that may occur in the reasonably foreseeable future include increased demand for recreation opportunities, urban encroachment on NFS lands, and a potential Neff‘s Canyon detention basin. The WCNF would continue to play an important role in meeting the demand for recreation opportunities. As recreation use continues to grow, conflict between users may escalate. Management of these user conflicts would be guided by Forest Plan Standards and Guidelines, forest-wide goals and objectives, desired future conditions, and other applicable laws and guidelines, e.g., Protected Watersheds and ROS.‖

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Bonneville Shoreline Trail Environmental Assessment

As numerous respondents have noted, trespass occurs with the existing alignment (the No Action Alternative). The EA acknowledges this stating that; ―The existing trail segments traverse both private and public land and in many places constitute trespasses or otherwise illegitimate trail segments. Trespassing and illegitimate trail segments will likely increase conflicts between recreation users and nearby private property owners. Vandalism and traffic-, transportation-, and traffic-related issues will likely stay the same, but may increase as recreation use and populations grow. The No-Action Alternative has the potential to have adverse effects on property values; security; privacy; and traffic-, transportation-, and parking-related issues. These effects are based on the premise that the Wasatch Boulevard will not satisfy future recreation needs. Unmanaged recreation activities will therefore increase and may lead to long-term adverse impacts to adjacent communities and private properties.‖ The Forest has also been active in acquiring several parcels of land that will benefit the Bonneville Shoreline Trail and will reduce conflicts among trail users and private land owners (WCNF Forest Plan Monitoring Report 2004). Monitoring of trail impacts will continue under the Forest Plan Monitoring efforts. 219. Comment S60, S69: Homeowners in the area purchased their lots and built their homes based in part on the understanding that the hillside above our homes could not be developed. We also expected that the nature of the National Forest would not be violated. That key fact was and is part of our residential values. To the extent that our residential values would be diminished, it would constitute a taking by inverse condemnation that would require compensation. Any attempt to engage in a government sponsored trail would involve direct ―takings‖ of property These will be fought legally in extensive litigation if you elect to proceed, and even if you prevail it will be extraordinarily expensive to pay compensation for such ―takings‖. 220. Comment H20, H22, S25, S28: As a resident on the east side of Mile High Drive, I am naturally upset about the loss of peace and privacy that this trail would impose on my family. I am also concerned about the increase in street traffic that would result from a parking lot at the end of Mile High Drive. Like all residents of this area, we moved here in part because of the pristine and undisturbed nature of the public land above our homes. In fact, before purchasing our home, I consulted the Forest Service and was assured that no roads or trails would ever be built on public land above Olympus Cove. If a public road or trail had been in place then, we would not have purchased the property. 219-220. Response: It is not clear how the understanding of homeowners regarding use of NFS lands above their homes was reached or with whom it was reached with. The Wasatch Cache National Forest has had a Forest Plan in place since 1985. The Forest Plan was revised in 2003 after extensive analysis and public participation. Under the current Forest Plan the project area falls within the roaded natural, Semi-primitive non-motorized and wilderness/semi–primitive non-motorized Recreation Opportunity Spectrum (ROS) classes. All of these ROS classes allow for non-motorized trail use and the trail design is modified to meet the guidelines for each of the ROS classes as it passes through them. There are also Forest Plan goals and objectives specific to the construction of the Bonneville Shoreline Trail. Forest lands are public lands and are managed under the Multiple use Sustained Yield Act that among other things states that: ―the national forests are established and shall be administered for outdoor recreation, range, timber, watershed, and wildlife and fish purposes‖ and that the ―Secretary of Agriculture is authorized to cooperate with interested State and local governmental agencies and others in the development and management of the national forests‖. Construction of a trail that provides recreation opportunities for the public is not considered a violation of the National Forest. There is little evidence that existence of a non-motorized recreational trail reduces property values and in fact, in some places has been shown increase the value of residential properties. See also responses above and #‘s 123 & 201.

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Bonneville Shoreline Trail Environmental Assessment

221. Comment S61: Would the trail define a limit to home development above? 221. Response: Construction of the trail does not change the ownership or zoning regulations of lands above or below the trail. 222. Comment S65: Alternative 3 in the PEA. While this alternative is billed as "an alignment not on private land" (p. 2-18), it still goes through private lands, since the description of Segment 1 (Mill Creek Canyon to Neff Canyon) has not changed from page 2-5 to 2-18. An additional alternative was mentioned on page 2-27 in Section 2.3, but it was eliminated from detailed analysis because of 6 bullet points. Those 6 bullet points (with slight modification of words that would keep the principle of the ideas) are equally valid for eliminating from consideration the route through our private property on the segment of concern. Replace "Wilderness Areas" with "private property owners", and you have points that should be likewise applied to our segment of concern. If the Forest Service can eliminate the prospects of another alternative for those reasons, the Forest Service should also allow us to eliminate the prospects of a trail through our steep backyards for similar reasons. 222. Response: The Forest Service has no authority authorize trails or other improvements off of NFS lands. Private landowners have the ability to eliminate the possibility of a trail crossing their private land. The purpose of the EA is to disclose the potential effects of the proposed action and a reasonable range of alternatives to provide the public with an opportunity to comment on the proposal and to ensure the decision maker has understand the potential effects in order to make an informed decision. As noted, the decisions to be made will only be for NFS lands. Despite any depiction of alternative routes on private land, the land owner retains the decision authority for their property. 223. Comment S70: Portions of the proposed trail—for example the ―Z‖ trail-- run directly thru private home lots…my home has the Z trail in the midst of our fenced yard where we have restricted access for over 15 years, and many neighbors have the same issue. We would not agree to an easement, as our property values would be adversely impacted. 224. Comment S34, S77: Many landowners have expressed the view that they will neither sell their property nor grant an easement to facilitate the construction of the BST. Worth noting, the legality of exercising eminent domain to take private property for use of trails, paths or other ways for walking, hiking, bicycling and other uses is expressly prohibited under Utah law. See Utah Code Ann. Sec 78- 34-1-(3). 225. Comment S64: Private Land Feasibility – You dismiss. None of the private landowners, to my knowledge, will allow the BST to cross their land. This was stated during and after the meeting in April of 2006 and has been stated again since. Why can’t you and the others involved in proposing this high- up route get it through your skulls that this proposal will never be accepted? I believe that your salary is paid from public funds. I pay part of your salary and I object to you wasting my money on further planning on the BST on the high-up route. 223-225. Response: The effects of a proposed trail alignment that crosses private land are analyzed as connected or foreseeable actions in Section 3.10 in the EA, however the Forest Service has no authority to make decisions on private land segments of the trail and no trail construction would occur on private land without appropriate

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Bonneville Shoreline Trail Environmental Assessment authorization from the landowner and local government agency. See also response #‘s 119, 123, 201 & 223.

16. Fire 226. Comment F4: Fire, caused by machinery is also a distinct possibility with the current dry nature of the landscape Comment T1, T4, T5, T7, T8, T11, T12, T15, T19, T20,T22, T23, T25, T27, T37, T38: Encouraging greater use of the trails in the area only compounds the risk of fires in the area which is already highly vulnerable to this hazard. The density of trees and oak brush in our area is far beyond the norm. The potential danger from wild fires. With the number of people on the trail, there is an increased risk of fire. Most of the hikers will be responsible, but it only takes one who is not to create a fire. The oak and underbrush on trail could allow a fire to spread quickly the potential of great property damage to nearby residences and destruction of a beautiful hillside. A fire would destroy the habitat but could make the area prone to mud slides until the vegetation is re-established. 227. Comment T9, T31: A trail will provide better access in the event of a fire and it would provide a fire break for the first small fire. However, in the long-term, impacts to habitats and increased populations of flammable weeds and grasses due to trail construction and maintenance, coupled with very steep west-aspect slopes and increased human activity, the likelihood of a catastrophic fire is significantly higher due to implementation of this project. It is proven by researchers, including Forest Service scientist, that the historic exclusion of fire has had some serious downstream (timeline) cumulative impacts. Because of this and the spike in populations of cheat grass and other weeds fire is one of those change agents whose occurrence has a high probability of causing significant cumulative impacts across the landscape to water quality, wildlife, and human values. The government’s intensive and expensive program of mitigating Wildland/Urban interface fires is an example of how seriously your agency and other view this problem. This trail is certainly in the wildland/urban interface. Therefore, how can you dismiss fire so casually? This section and subject matter and the soils section have such a high probability of causing serious ecologic and economic impacts that the analysis is flawed and must be re-done. More analysis and modeling must be done before a decision can be made. 228. Comment T13: In your own Environmental Assessment, segment 3.9.2 Affected Environment: Fire, it states that Fire occurrence records from 1970-2001 were analyzed for the following statistics. And I quote, ―Of the almost 2000 fires in the WCNF’s Fire Occurrence data base from 1970-2001, 63% of the fires were human caused. The rest (37%) by lightening.‖ If a trailhead is put in at the end of Mile High Drive, you are inviting more people into a very high-risk area for fires. 229. Comment M50: Adding the trails as described in each of these alternatives will create a possible hazard for the residents of CCC (Canyon Cove Community). If drought conditions such as those we have experienced this summer persist in future years, it would take only once careless hiker to set off a brush fire that would jeopardize a large number of homes. The trails as outlines are much too near the existing homes of CCC 230. Comment M46, T16, T21: Opening the area to traffic will also increase the risk of fire. Although the Environmental Assessment maintains that the trail would provide a firebreak and increased vigilance, it will also attract smokers and would-be campers who will – without a doubt – discard burning cigarettes and build illegal campfires in the

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Bonneville Shoreline Trail Environmental Assessment foothills (as they do routinely near the Mount Olympus trailhead, where there appears to be no serious law enforcement). A wildfire in this area will do incalculable damage, not only to homes but also to the beautiful landscape. 231. Comment T17: Fire –A trail will provide better access in the event of a fire and it would provide a fire break for the first small fire. However, in the long-term, impacts to habitats and increased populations of flammable weeds and grasses due to trail construction and maintenance, coupled with very steep west-aspect slopes and increased human activity, the likelihood of a catastrophic fire occurring is significantly higher due to implementation of this project. More analysis and modeling must be done before a decision can be made. 232. Comment T26: The impact should be increased from minor to either moderate or high for increased fire danger. As noted in the report, the mountainside is covered with grasses and dry brush most of the year. The area of concern is that between homes and the trail, not above the trail as suggested in the EA document. Given the restriction that property owners could only disturb land within 30 ft of their homes in addition to the fact that in places the brush is overgrown close to homes, the buffer between the homes and dry tinder is minimal. Any spark or carelessly thrown cigarette could be disastrous. There have been fires that scorched the mountain side on both North and South of Canyon Cove in the past 10 years. 233. Comment T30: Fire: Alternate 2 which is being proposed claims there would be Minor Adverse Effect to Beneficial Effect. Increased human traffic on this mountain side so close to our homes will undoubtedly increase the chance of fire. More people on the trail mean more people smoking, shooting off illegal fireworks etc. There is no amount of statistical data that can refute this. This alone means an increase in fire danger. While the trail may be used as a fire break the first time. Once the mountain has burned the indigenous plant life will most likely be replaced by cheat grass. Once this occurs the trail will not prove to be a viable fire break. It is also stated in the EA that the trail would assist fire fighters in accessing fires. This portion of the trail is extremely difficult to reach from either the Neff’s Canyon or Rattlesnake Gulch Trailheads. This means the firefighters will still continue to access mountain fires via our back yards not the trail. 234. Comment M64, T33: Increased human traffic can increase the probability and severity of fires on our hillside. While a trail may also serve as a firebreak, a trail so close to our homes will not improve the ability of fire fighters to fight the fires, since they would more readily hike up our backyards rather than travel an additional mile on road just to hike an additional mile on the trail. By then it may be too late for our property and our families. If a fire does occur, then the geological concerns mentioned above are magnified, since the fragile root systems will be gone; hence illustrating the importance of not allowing any increase in the probability of fire. We can live with the natural risk of lightening, but we can't live with the added risk of careless humans on a steep hillside. 235. Comment T34: The trail would be constructed on a steep slope covered with oak and cheat grass, which already presents an extreme fire hazard from spring to winter each year as it is. Drawing 16,000 more people into this area, as was estimated by the proponents of the trail between Old Mill Corporate Center and Big Cottonwood Canyon, would dramatically increase the already high fire risk in our area. 236. Comment T35: The BST will encourage additional human traffic in an area already at high risk for fire. When a passing smoker starts a fire on the trail, it will threaten wildlife and homes within minutes. Who will pay for the damages? Why increase traffic in an already endangered area?

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Bonneville Shoreline Trail Environmental Assessment

237. Comment T29: Sec 3.0 No studies were listed to support the conclusion that trails ―may‖ act as a fire line. Please cite them. 226-237. Response: The Action Alternatives, which include the most trail construction and use, may have the greatest potential to increase fire risk through an increase in human activity. However, these Action Alternatives may also have the greatest potential to decrease fire risk. Populations and development adjacent to the Project Area are increasing. Increased visitor use on existing trails and user-created trails will occur whether or not the proposed alternative is implemented. Thus, indirect, long-term, adverse effects include increased risk of fire because use of the Project Area will increase whether or not the proposed alternative is implemented. Through the creation of an established trail system, the WCNF will be able to better manage visitor use and minimize resource damage. Increased trail use may increase the incidental public ―monitoring‖ of fire and may increase the speed with which fire is reported. Use along a designated trail, compared with a network of user-created trails, may serve to discourage activities (campfires and party fires) that may increase the potential for human caused wildfires. The new trail may provide improved fire fighter access and result in more rapid and effective fire suppression. The trail would also improve firefighter safety in that it offers cleared, less obstructive access, but more importantly, egress as an escape route to a predetermined safety zone. The new trail may also provide a fire control line to prevent fire from extending toward the urban interface. The new trail may also provide an opportunity for fire suppression, in that an established anchor point (the trail) that has already been constructed and cleared to mineral soil can be used as a point of ―back fire‖ to prevent a fire from extending toward the urban interface. Some concern exists that increased visitor use will increase introduction of invasive species, such as cheat grass, thus further increasing fire danger. However, adverse effects would be reduced to minor by implementing a weed management plan as a required project mitigation measure. As noted in Section 3.9, a number of wildfires in or near the project area have been human-caused and have created impacts, including subsequent mud slides. None of the fires on the SLRD in those cases have been caused by hikers. Fires have been caused by illegal off highway vehicles and abandoned campfires. The BST section in Salt Lake City has been in use since the early 1990‘s and receives high use. There have been no reports of human-caused fires during that time period. The Corner Canyon Fire in Draper occurred in 2008 and was started on the road below the trail. The trail did not stop the fire in all areas, but did stop its progress to the north and provided access for firefighters. There have not been any studies specific to trails‘ role in serving as an effective fireline, however the National Wildfire Coordinating Group, the federal wildland firefighting training group, in its ―Wildland Fire Suppression Tactics Reference Guide (04/96) states under Fireline Location ― Always anchor the fireline to a barrier or other control line to prevent being outflanked by fire. Barriers can be natural or human made, i.e., roads, trails rivers, lakes, old burns, rock (p. 20).‖ The Guide also states ―clear all firelines to mineral soil for all or part of the width. Clearing a fireline to mineral soil prevents the fire from spreading through fuel across the fireline (p. 30).‖ The tail clearing line, approx. ten feet in width, also may stop or slow the fire and is advised under the Guide (p. 33-35). Generally, a trail and its clearing with, serve in a very similar manner as a fireline and fire break. Invasive species, notably noxious weeds, are a concern, especially after wildfires. The Forest Service has a policy of preparing and implementing a Burned Area Rehabilitation Plan (BAER) after any substantial wildfire where resource concerns due to the fire are present. The BAER plan identifies resource issues and concerns and provides a plan to mitigate those, often including erosion, mudslide, recreation facilities, wildlife habitat, and noxious species. Mitigation often includes seeding and mulching to reintroduce native species. This was the case for the Corner Canyon Fire in Draper. A series of mitigation measures were

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Bonneville Shoreline Trail Environmental Assessment conducted including areal seeding and mulching, as well as constructing check dams and mini detention basins to protect against mud slides. After one year, the reseeding effort appears to be very successful with a high germination rate and vigorous crop of desired vegetation. Fire issues are addressed in detail under Section 3.9 of the EA. Management of invasive plant species is addressed in Section 3.1 of the EA. 238. Comment T39: I strongly support leaving the trail along Wasatch Blvd where it currently is instead of cutting a trail over hillside protected areas. The liability far outweighs the benefit of moving a non-motorized trail through already established housing areas and pristine open space. The liability comes from fire danger to housing from walking and riding traffic non patrolled area to prevent small motorized vehicles. 238. Response: The use of Wasatch Blvd is reflected and analyzed under the No Action Alternative. All views were carefully considered during development and evaluation of the existing Alternatives. Fire issues are addressed in the EA under Section 3.9. 239. Comment T40: I am in favor of Alternative 3 in which the proposed route of the BST is on National Forest Land and above the residential homes in Heughs Canyon. I have concerns about the increased risk of fire with use of the BST but, I think Alternative 3 route is preferable because the vegetation is more open, easier to be monitored and less appealing to unauthorized activities than the Alternative 2 proposal. 239. Response: Fire issues, for all alternatives, are addressed in the EA under Section 3.9.

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