Loop Road Update: Federal Highway Administration Bulldozes Opposition

by Caroline Byrd

In the morning mail on September first, WOC received the Federal Highway Administration’s (FHWA’s) Draft Environmental Impact Statement (DEIS) for the Louis Lake Road, a.k.a. the Loop Road. Glancing over the document’s range of alternatives and summary of comments and correspondence, it’s clear that the FHWA has ignored all public opposition to reconstruction and is hell-bent on "improving" the Loop Road. The FHWA offers us three alternatives: no action (leave the road alone), reconstruct and gravel, and reconstruct and pave. The overwhelming public opposition in Fremont County and elsewhere to a full-blown reconstruction is barely mentioned.

But, I shouldn’t have been surprised. We’ve known all along that the agencies (FHWA, U.S. Forest Service, Wyoming Department of Transportation and Fremont County Commission) weren’t listening to our requests for a smaller project, for spot improvements, for maintaining the backcountry feel of the road and for not spending county dollars on maintenance. Since the first public meeting in October 1996, when the Shoshone National Forest assured us that it wasn’t talking about paving the road, we knew better.

The two action alternatives — Alternative B, reconstruct and gravel, and Alternative C, reconstruct and pave — both entail widening the road to 10-foot-wide travel lanes, two-foot-wide shoulders, 3.3 to 6.6-foot-wide ditches plus another 10 or so feet of "clear zones" in which any trees, rocks or other obstacles are removed so drivers don’t bump into them if they happen to swerve off the 12-foot-wide lane, through the ditch and into the scenery. The end result would transform a scenic dirt road just 16 to 18 feet wide into a broad slash of roadbed, ditches and cleared slopes up to 50 feet wide.

The road won’t just be widened. For both alternatives, the FHWA proposes lowering steep sections and widening curves on switchbacks. The road will be straightened and five to six retaining walls will be built in the first mile of the road. The side slopes will be knocked down along 5.2 miles of switchbacks but, not to worry, the FHWA promises to "minimize visual impacts and preserve the rural, rustic road appearance" of the Loop Road.

If you re-build it, they will come
The FHWA estimates that many more people will drive the Loop Road after it’s been reconstructed. According to the DEIS, 229 vehicles a day travel the stretch of Loop Road that the agencies propose to rebuild. The DEIS predicts a 10% increase in traffic for the reconstruct and gravel alternative and a 30% increase in traffic for the reconstruct and pave alternative. If the road is paved, the agency estimates that 495 vehicles per day will drive up to Worthen Reservoir by the year 2017.

To justify reconstruction in the first place, the DEIS forecasts a 2.5% annual growth rate in traffic if the road is left as is, even though the actual growth rate since 1993 has been only 1.6%. What the FHWA doesn’t tell us is that even at a 2.5% growth rate to 380 vehicles per day by 2017, highway standards for rural roads with fewer than 400 vehicles per day do not call for a double-lane, flat, wide, straight, paved road. The standards are far more flexible than the DEIS reveals.

What happened to spot improvements?
The most common request of the more than 1,000 people who have commented so far on the Loop Road is for spot improvements. The DEIS devotes just one page to the spot improvement idea, which it dismisses.

The document correctly describes what we asked for as "turnouts and pullouts, widening some curves and at selected locations installing guardrails, repairing drainage structures, reducing the washboard surface, and adding road information signs. The rationale for this alternative centers on preserving the road as a rustic, backcountry road, discouraging increased use and promoting low vehicle speeds."

However reasonable this might sound, the FHWA eliminated spot improvements from consideration. First, the agency says, because Fremont County could not assume road maintenance responsibilities for a road that didn’t meet county road standards. (One of the requirements for using FHWA forest highway money is that the county or state agrees to take over maintenance once a road is improved. Years ago, Fremont County agreed to take on maintenance costs and responsibilities if the Loop Road is improved to meet county standards. With spot improvements, the county will not take over the maintenance and FHWA money would not be available for road improvements.)

Second, the DEIS argues, spot improvements would leave the road with inconsistent widths, surfaces and alignments. Third, spot improvements would fail to meet the guidelines for future use in the year 2017, which, at a growth rate of 2.5% a year if the road is left in its current condition, the agencies estimate at 380 vehicles a day for the entire six months that the road is open from Bruce’s Bridge to Worthen Meadows. The agency’s response is a slap in the face to the majority of Fremont County residents who don’t want the county to pay for the maintenance of the road in any case and don’t mind if the road is "inconsistent."

The DEIS does say the spot improvement alternative would be viable if the road stayed in Forest Service hands but that the Forest Service couldn’t use the pot of money available from the FHWA for "forest highways." The DEIS admits that the FHWA can make exceptions to funding forest highway projects such as spot improvements "where site-specific exceptions to the guidelines are well justified." With so many people asking for spot improvements, why doesn’t the DEIS seriously consider a spot improvement alternative with site-specific exceptions to highway guidelines and include a discussion of available design variances?

What about safety?
The DEIS’s expressed "purpose and need" for this project is primarily to "provide a safe roadway." The document states that the present configuration and history of the Loop Road "suggest that a roadway constructed to modern highway standards would provide a safer traveling environment for the user with the potential to reduce accident rates."

However, this statement is nothing more that an assumption. The DEIS cites no studies to support this assertion, and, in fact, highway safety studies "suggest" just the opposite. Studies carried out worldwide and reported by the World Health Organization reveal that despite numerous technological advances in road and vehicle design, accidents have increased. For example, in the United States, roads with paved shoulders are associated with speeds 10% greater than comparable roads with unpaved shoulders. The shoulders give drivers the false impression that they can safely increase their speed as an adjustment to the "safer" shoulder design.

Most pertinent to the Loop Road, a comparison between two sections of Colorado’s Cottonwood Pass Road, the east side of which was paved in 1992, while the west side was left as a graveled, winding, bumpy road, shows that "improving" the road led to more and more serious accidents. According to data collected by the Colorado Department of Transportation between 1992 and June 1996, there were 16 accidents (with 12 injuries) on East Cottonwood Pass Road (paved) and eight accidents (with no injuries) on West Cottonwood Pass Road (unpaved). Thus, the paved side of Cottonwood Pass Road is twice as dangerous as the graveled side, not safer, as the FHWA would have us believe.

Additionally, the DEIS argues that improving the road would be safer because emergency vehicles could get up the switchbacks faster. Yet the FHWA is not proposing to increase the "design speed" of the road. According to the DEIS, the road will be designed for 19 miles per hour. The road is currently posted at 20 mph.

What happened to no county dollars for maintenance?
Our two newly elected County Commissioners ran on a platform that included promises of no county dollars for Loop Road maintenance. A third Commissioner, Crosby Allen, shares this position. Last December, when Fremont County citizens asked the five-member County Commission to formally withdraw its support for the Loop Road reconstruction project, commissioners voted to postpone any action until the DEIS was released. Now that it’s out, it’s time for the commissioners to fulfill their campaign promises.

Fremont County cannot afford to take on the operation and maintenance of seven miles of an upgraded Loop Road. The County is presently $23 million in arrears in maintaining county roads and is unable to provide adequate road maintenance for many rural residents. The county’s priority should be maintaining roads on which families live, work and travel regularly, rather than asking county residents to pay for maintenance of what is now a Forest Service road that travels exclusively through National Forest lands and is open only five or six months a year.

What happened to all of our comments?
Remember the agencies’ promise that they would listen to the public, that the public would be included in the planning and design of the road and that the project would be abandoned if the public didn’t want it? Reading the DEIS’s summary of comments, you’d be hard pressed to know there was ever any opposition to this project. Due to the selective presentation of information, the DEIS emphasizes support for the project. It does admit that "the single most popular response" from the public was spot improvements. However, the rest of the analysis is confusing and contradictory.

For example, the DEIS says about the June 12, 1997 public meeting that 45 people commented with 67% wanting some form of improvement. The obvious conclusion is that 33% did not want some form of improvement. But, according to the DEIS 15% wanted no improvements — and fails to explain the discrepancy. Later, describing a random telephone survey of one percent of Lander and Riverton residents, the DEIS states that, of the people who knew about the project, "approximately 40% favored it," which should mean that 60% were against it, but the DEIS doesn’t say that.

Since the onset of this FHWA project, if you have testified or written a letter opposing a major upgrade of the Loop Road, the agencies have completely disregarded your views. In a meeting last spring, the FHWA stated that if public comments did not fit within its standards and guidelines, it disregarded them. That must explain why the DEIS fails to include even one of the hundreds of letters from citizens opposing reconstruction. The document does, however, include 19 letters of support for the project.
 

What You Can Do

Contact:
Bert McCauley
Environmental Project Manager
Federal Highway Administration
U.S. Department of Transportation
555 Zang Street, Room 259
Lakewood CO 80228
Telephone (303) 716-2141

To be considered, the FHWA must receive your letter by October 29, 1999.