Summary of damage that the Logan River Watershed Project will do to our community if we do not stop it NOW
Oppose spending your federal, state and local tax dollars on misguided MEGA-irrigation PROJECT
called the Logan River Watershed Project
Small changes are not going to improve this project . IT needs a top to bottom overhaul.
Two Rivers Coalition
Briefing about the damage and flaws of the Logan River Watershed Project
Logan River Watershed Draft Plan–environmental impact statement (DEIS) and Logan River System Stewardship
https://www.nrcs.usda.gov/state-offices/utah/logan-river-watershed-project
Prepared by the Two Rivers Coalition for lawmakers, decision makers and the public.
Three sections:
1) concerns about the DEIS process and content;
2) specific stewardship requests for the Logan River system; and
3) win-win proposal.
DEIS PROCESS CONCERNS
The DEIS presents an inadequate range of alternatives under NEPA
Why it matters: National Environmental Policy Act (NEPA) requires federal agencies to rigorously evaluate all reasonable alternatives. This is a legal standard, not a suggestion.
Evidence: Only two nearly identical action alternatives ($280M and $308M) and a no-action alternative. There is no alternative flood control, no partial project (e.g., flood control only), no phased approach, no conservation-first scenario.
Design-phase corrections are not a substitute for a complete DEIS
Why it matters: The DEIS comment period is the only formal opportunity for public input. Once a Record of Decision is issued, there is no legal obligation for further public engagement.
Evidence: Project sponsors and the Cache Water District board have publicly stated that concerns can be addressed in the design phase, which is incorrect as a matter of NEPA law.
The firm that drafted the DEIS is also reviewing and compiling public comments, creating a potential conflict of interest
Why it matters: JUB Engineers, the contracted author of the DEIS, stands to receive substantial engineering work if the $308 million project proceeds, creating a financial incentive that calls into question its objectivity in fairly characterizing public opposition.
Evidence: Public comments are overwhelmingly critical of the project; dismissive statements by project sponsors about those comments suggest the public record may not be compiled with the impartiality that a federal NEPA process requires.
DEIS FINANCIAL CONCERNS
The $308M cost is nearly 90% federal funds and three times the annual national PL 83-566 budget
Why it matters: This single project would consume more than three years of the entire national Watershed Protection and Flood Prevention Act budget, crowding out worthy projects nationwide. Congressional appropriators and every other state competing for PL 83-566 funds have a direct interest in how this classification is applied.
Evidence: The DEIS's preferred alternative includes 120 miles of buried pressurized irrigation pipeline whose primary purpose is to deliver irrigation water to shareholders. This is the same water that has flowed through open canals for a century and a half. The DEIS classifies much of this pipeline cost as "Flood Prevention" rather than "Agricultural Water Management," on the theory that removing irrigation water from the canals reduces the volume of water available to overflow during storm events. However, the DEIS's own economic analysis allocates 92% of the flood damage reduction benefit to the "Agricultural Distribution and Stormwater increment" and only 8% to the "Floodplain increment," confirming that flood control is largely an incidental co-benefit of the irrigation system, not its primary purpose. Classifying $137.6M of irrigation pipeline costs as Flood Prevention (100% federal cost share) rather than Agricultural Water Management (75% federal cost share) shifts approximately $34M in costs from the project sponsors to federal taxpayers. See Draft Plan–EIS, Table 6-3, p. 6-5.