UDOT says either of its two routes would meet the purpose of the Heber Valley Corridor. Both routes build the same new freeway around the west side of Heber City, and both touch the east edge of the North Fields near SR-113. North of downtown, Route A rebuilds US-40 as a freeway. Route B cuts a new freeway across the North Fields from Potter Lane to 900 North. In UDOT’s own numbers, Route B takes 2.4 times the wetlands and other waters (assumed) and 44 more acres of farmland, and costs $48.6 million more in UDOT’s estimate. Route A is the better route.
UDOT says Route A “is more similar to the bypass that Heber City and Wasatch County have been considering, although neither alternative is entirely consistent with the local government preservation corridor.” In March 2026, the County Council and other officials asked for “An alternate alignment based on Route B but located as close to the existing US-40 footprint as possible.” They did not ask for Route A. This site goes further and argues for Route A, which uses US-40 from SR-32 to 900 North.
Draft EIS lines, January 2026, from UDOT’s own GIS data. At full view, the line weight makes each road look wider than it is. Zoom in to see the edges of the pavement. UDOT says its data “must be field verified” before use on a project. The map does not show the homes and businesses that each route would move (27 with Route A, 8 with Route B), or the eligible historic structures that each would demolish (4 with Route A, 1 with Route B). How the maps were made
2.4×the wetlands and other waters with Route B: 53.9 acres against 22.5 (assumed)
46more homes with a noise impact with Route B, in UDOT’s count of residential receptors, with planned buildings: 273 against 227
44 acresmore farmland with Route B, in UDOT’s farmland count: 223 against 179
Route B moves fewer homes and businesses (8 against 27) and demolishes fewer eligible historic structures (1 against 4). Section 2 answers both.
UDOT, October 23, 2026 “Though these potential refinements are being considered for both Alternatives A and B for evaluation purposes, Alternative B remains UDOT’s preferred alternative.” UDOT project page
Section 1
All of the difference is in one stretch
Route A
Route B
Both routes
Farmland, 2025
Wetland and riparian
Developed land
Water
Each field comes from the 2025 state land use survey. Draft EIS lines, January 2026. With Route B, US-40 in this stretch stays a street with signals and gets added turn lanes. The map does not draw those turn lanes. Over the whole route, Route A would move 27 homes and businesses and demolish 4 eligible historic structures. Route B would move 8 and demolish 1. The one structure that both routes take is north of Potter Lane, outside this map.
UDOT writes that “Alternatives A and B are the same except between Potter Lane/College Way and 900 North.” So every difference in what the two routes take is in this stretch. DEIS, p. 2-43
Route A stays on US-40 to 900 North, as a freeway with frontage roads and interchanges.
Route B leaves US-40 on ramps that pass over Potter Lane and College Way. It cuts a new freeway across the North Fields to 900 North, west of 600 West. US-40 stays a street with signals.
Route B’s North Fields Extension across an example field, from above
Right-of-way, 250 feet
Lanes and shoulders
Trail
A football field, for scale
To scale. A quarter-mile square is 1,320 feet on each side and 40 acres. Route B’s 250-foot right-of-way takes about 7.6 acres of it. West of Heber City, both routes build the same 250-foot section. In this stretch, Route A rebuilds US-40 instead. It adds about 34 feet on each side where a frontage road goes, scaled from Figure 2.4-3. UDOT says that farmland in the right-of-way of both routes “would be directly taken out of production”. DEIS, p. 2-27, DEIS, p. 2-25, DEIS, p. 3-32
UDOT writes: “If A-20 zoning is used to define the north fields, both action alternatives would encroach into the east edge of the north fields between 900 North and SR-113 (as would the local government preservation corridor). However, Alternative B would impact the north fields to a greater degree because it would involve constructing a new road through the north fields between Potter Lane/College Way and 900 North.” DEIS Summary, p. S-27
Zoom in on the map to see Route B’s ramps at Potter Lane and its new freeway across the fields.
UDOT prefers Route B. Here is each of UDOT’s reasons, in UDOT’s own words, and this site’s answer, mostly from UDOT’s own Draft EIS.
Travel
UDOT’s reasonUDOT prefers Route B “primarily because it would perform best with respect to the overall purpose of the project.” DEIS Summary, p. S-23
SR-32 to US-189 on the new road, 2050 evening peak hour DEIS, p. 2-33
Route A7 min 25 s
Route B6 min 15 s
Sum of four Main Street queues, 2050 evening peak hour DEIS, p. 2-32
Route A6,200 feet
Route B3,200 feet
The answer
“Either action alternative would meet the purpose of the project, but there would be differences in their transportation performance.” DEIS, p. 4-40
Route B’s time gain is 70 to 100 seconds on six of the eight regional trips that UDOT times in the 2050 evening peak hour, about 11% to 16%. Route B also has shorter Main Street queues, 3,200 feet against 6,200, and no intersection at level of service F. Route A is faster on the two northbound trips through Main Street. Both routes cut Main Street traffic, by 16% with Route A and 21% with Route B. See each number.
On north US-40, Route A builds interchanges, which UDOT says “offer a safety benefit by eliminating the high-speed conflict points inherent with at-grade intersections.” UDOT adds that local access would then need “some out-of-direction travel.” Appendix 2C, p. 12
On the historic town center, UDOT’s own table says that each route “Would not preclude Heber City from implementing their vision for Main Street.” DEIS, Table 2.4-2, p. 2-32
A minute or two of travel time, and shorter queues on Main Street, do not justify a new freeway across the North Fields.
Homes and businesses
UDOT’s reasonRoute A moves 12 households and 15 businesses. Route B moves 6 households and 2 businesses. “These relocations present substantial social and economic impacts.” DEIS, p. 2-45
“Thirteen of the business relocations for Alternative A would be at the New London development, which is currently under construction.” UDOT wrote this in January 2026. DEIS, p. 2-46
UDOT’s cost totals include right-of-way acquisition. UDOT says that “the actual right-of-way costs cannot be known”. In Appendix 2F, UDOT puts relocation costs at $57 million for Route A and $12 million for Route B, and notes that these “are not based on an appraised value”. The DEIS does not say whether those figures are part of the totals. UDOT says it priced right-of-way “per acre”. If the totals do not include the relocation costs, the cost gap between the routes would be about $4 million, not $48.6 million. The DEIS does not say which is the case. DEIS, p. 2-35, DEIS, p. 4-39, Appendix 2F, p. 13
Each relocation is a real cost to a family or a business. Route B takes 31 more acres of wetlands and other waters, and 44 more acres of farmland, than Route A.
Historic homes and Section 4(f)
UDOT’s reasonUnder Section 4(f), UDOT finds that Route B causes the least overall harm. “Alternative B is of less harm for the first four least overall harm factors based on its lower number of demolished structures,” one against four. UDOT also finds Route B better on the fifth factor, the purpose and need. DEIS, p. 4-40
Eligible historic structures demolished DEIS, p. 4-41
Route A4
Route B1
The answer
UDOT least overall harm factors and findings, Table 4.7-4
Factor (UDOT, DEIS Section 4.7)
What UDOT found
Ability to mitigate adverse impacts to Section 4(f) properties
Route B. Route A demolishes 4 eligible historic structures, and Route B demolishes 1. The mitigation is the same for both.
Relative severity of remaining harm to Section 4(f) properties
Route B, by the same count: 4 structures against 1.
Relative significance of Section 4(f) properties
Route B, by the same count. UDOT says none of the structures “is particularly unique or unusual.”
Views of the official with jurisdiction (for this project, SHPO)
Route B, by the same count. UDOT says SHPO “has not expressed any particular concern” about any of the structures.
Degree to which the project purpose and need is met
Route B. UDOT says both routes meet the purpose and need, and Route B performs better.
Magnitude of adverse impacts to resources not protected by Section 4(f)
Similar. Route A is better for wetlands, farmland, and noise. Route B has substantially fewer relocations.
Substantial differences in cost
Route A, slightly. UDOT calls the $48.6 million gap less than 10% and “fairly negligible.”
Of the four structures, the oldest is a home from about 1906. UDOT says the documentation and outreach that it plans “do not fully offset the fact that the buildings no longer remain physically in the landscape.” DEIS, p. 4-36
UDOT studied a design to avoid each of the three historic homes that only Route A takes. It found none of them “feasible and prudent”. Its reasons: each design adds frontage-road curves below the AASHTO minimum, and UDOT calls the cost “severe”. One design cannot keep driveway access to the house. Another needs about 7 more acres of right-of-way, puts the house between US-40 and the frontage road, and fills about 1 more acre of wetland. The three designs would add about $1.8 million, $4 million, and $1.8 million, for about $7.6 million in all. DEIS, p. 4-29, DEIS, p. 4-32
Four of the five factors that favor Route B count historic structures, and three houses separate the routes. The fifth is how well each route meets the purpose, answered above. One of the four structures is taken by both routes, and UDOT studied designs that avoid the other three, for about $7.6 million. UDOT should weigh those designs again.
Wetlands and the Clean Water Act
UDOT’s reason“Although Alternative B would have greater aquatic resource impacts than would Alternative A, UDOT believes that Alternative B is the LEDPA because Alternative A has ‘other significant adverse environmental consequences.’” UDOT gives three reasons: the Section 4(f) finding, Route A’s relocations, and Route B’s better transportation performance. Appendix 2F names the first two. DEIS, pp. 2-45 to 2-46, Appendix 2F, pp. 12 to 14
The answer
By UDOT’s own count, Route A takes 31.4 fewer acres of wetlands and other waters: 22.5 against 53.9. UDOT calls Route A “substantially better in terms of effects on aquatic resources.” DEIS, p. 4-40
LEDPA means the least environmentally damaging practicable alternative. The U.S. Army Corps of Engineers decides it, in the wetland permit. UDOT counts these waters as “assumed jurisdictional”. As of December 2025, the Corps had not issued its jurisdictional determination. DEIS, p. 2-45
UDOT tested a tie-in near 1200 North and three concepts that moved the 2023 North Fields routes east of 600 West. It found that each would affect more waters of the United States, as UDOT assumed them, than the original alignment. The 1200 North test moved the tie-in to US-40 for both routes. The three concepts east of 600 West compared routes across the North Fields with each other. Route A has no North Fields Extension at all. UDOT says: “Alternative alignments were developed based on minimizing impacts to waters of the United States.” DEIS, pp. 2-19 to 2-20
UDOT surveyed the wetlands near the Route B ramps at Potter Lane in summer 2025. The Draft EIS does not include the results, so “the acreage of aquatic resource impacts might change in the Final EIS.” DEIS, p. 2-20
By UDOT’s own count, Route A takes 31.4 fewer acres of wetlands and other waters. UDOT’s reasons for Route B under the wetland permit are the Section 4(f) finding, the relocations, and the travel performance, all answered above. The Army Corps of Engineers decides the permit.
North Village, access, and growth
UDOT’s reasonRoute B is “more consistent with the master-planned North Village local road network.” With Route A, all traffic on the east side of north US-40 would reach US-40 only at SR-32, College Way, or Coyote Canyon Parkway. UDOT also finds: “Alternative A has greater potential to increase pressure for development along the west side of north US-40 because of its frontage roads and thereby cause indirect impacts to land use.” DEIS, p. 2-46, Appendix 2E, p. 14, DEIS, p. 3-24
The answer
Table 2.4-6 rates both routes “No” for consistency with local plans. Its note: “Alternative B includes a North Fields Extension segment, which is not shown in adopted plans. Neither Alternative A nor Alternative B is consistent with the North Village Master Transportation Plan or with corridor access agreements for north US-40.” DEIS, p. 2-39
The county and the city, not UDOT, decide the zoning. UDOT writes that development on the west side of US-40 in the north fields “would likely be limited by zoning,” and: “Ultimately, the decision to change zoning to allow for development is up to Wasatch County and Heber City.” And: “Representatives with Wasatch County have stated that they do not intend to change the zoning in the north fields from A-20.” UDOT also commits to “no additional interchanges between Potter Lane/College Way and SR-113 being built in the north fields.” DEIS, pp. 3-23 to 3-24
In October 2026, the County Council approved a memorandum of understanding with Heber City on North Fields protections. The Park Record reports: “Both entities agree that North Fields protections should be in place no matter what route is selected.” It adds that “an interlocal agreement is more legally binding”, and that the county expects the Heber City Council to consider the memorandum later. Park Record, October 9, 2026news
UDOT says Route A “follows the local government preservation corridor more closely than Alternative B does.” Route B puts a new freeway through the North Fields.
Trucks and a second road
UDOT’s reasonRoute B “would be more likely to attract regional truck traffic away from Main Street.” It also gives a second road between Potter Lane and 900 North. With Route A, if north US-40 closes there, “all traffic heading north out of the Heber Valley would be required to take River Road.” DEIS, p. 2-46, Appendix 2E, p. 22
The answer
The DEIS has no forecast of truck counts by route. UDOT bases its truck view on travel time and on Route B’s more direct path. Appendix 2E, p. 11
The second road matters if north US-40 closes between Potter Lane and 900 North. With Route A, traffic would then use River Road, as UDOT says. Route A rebuilds that stretch of US-40 as a four-lane freeway with frontage roads.
In the 2050 traffic model, River Road traffic through Midway falls about 33% with Route A and 50% with Route B, compared with no project. Appendix 2C, p. 15
Both routes take traffic off River Road and Main Street. Route A does it without a new road across the North Fields.
Section 3
The trade, in UDOT’s numbers
What each route takes
UDOT’s numbers, Route A first. In each row, “less” marks the route that takes less. The last group shows where Route B takes less.
Farmland in UDOT’s Farmland Protection Policy Act count DEIS, p. 3-38
Route A: 179 acres
Route B: 223 acres
Each square is one acre, the same size in every grid. With Route B, the pale squares equal Route A’s total, and the dark squares are the acres beyond it. The farmland count is UDOT’s FPPA total, which includes some land that UDOT lists as “Not prime farmland”. UDOT counts the waters as “assumed jurisdictional”. As of December 2025, the Army Corps of Engineers had not issued its jurisdictional determination. DEIS, p. 2-45, DEIS, p. 3-189 UDOT calls Route A “substantially better in terms of effects on aquatic resources, and slightly better in terms of farmland”. DEIS, p. 4-40 UDOT says it “will prioritize establishing a mitigation site in the north fields with either alternative”. DEIS Summary, p. S-27
What each route takes, in UDOT numbers. Route A first, then Route B.
Measure
Route A
Route B
Source
Land and water
Aquatic resources taken (assumed)Wetlands are 19.91 and 50.34 acres of this total.
Farmland in UDOT’s Farmland Protection Policy Act countUDOT calls this “FPPA-regulated farmland”. Its totals include 7 and 13 acres that its table lists as “Not prime farmland”. The act directs federal agencies to take farmland loss into account and consider alternatives. It says that it does not authorize the federal government to regulate the use of private land. The three farm and land rows overlap. They measure parts of the same land in different ways.
Agriculture Protection Area landLandowners put this land into Agriculture Protection Areas from March 2023, under a December 2022 county ordinance, while UDOT’s study was under way. The ordinance excluded land near the local corridor, but not land on UDOT’s routes.
Key views with an adverse visual impact, of 9UDOT: “Alternative A would be the most visually impactful to those who reside along north US-40 in the North Village, and Alternative B would be the most visually impactful to those who live in the north fields.”
Hazardous material sites near the route (low and moderate risk)Most of these sites are outside the right-of-way, within 0.5 mile. UDOT calls the waste site impacts of the two routes “very similar”.
“In terms of impacts to non‑Section 4(f) resources, Alternative A is substantially better in terms of effects on aquatic resources, and slightly better in terms of farmland and noise impacts. In contrast, Alternative B would have substantially fewer business and residential displacements. Due to these trade-offs, UDOT determined that Alternatives A and B perform similarly for this least overall harm factor.” DEIS, p. 4-40
UDOT says both routes would likely need wetland mitigation of at least 2 acres for each acre taken. It says the ratio could be as high as 15 to 1, set in consultation with the Corps. At those ratios, UDOT puts the mitigation at about 45 to 338 acres for Route A and about 108 to 809 acres for Route B. UDOT would buy the land from willing sellers, subject to Corps approval, with “a goal of all wetland mitigation being located in the north fields”, and protect it “in perpetuity”. DEIS, p. 2-46, DEIS Summary, pp. S-27 to S-28 A North Field Irrigation Company representative objected that UDOT has “targeted the North Fields to mitigate for wetlands in the east”. KSL, March 8, 2026news
The March letter put groundwater first. UDOT’s model gives about the same salt level in snowmelt runoff for both routes, about 1,380 and 1,410 mg/L. So this page does not count water as a difference between them. Appendix 3K, p. 27
Travel in 2050
UDOT writes: “Neither alternative had the best transportation performance for all measures, the lowest cost, and the fewest impacts to all resources.” DEIS, p. 2-42 The table shows the traffic side, in the 2050 evening peak unless the row says otherwise.
Route B is faster on most trips, by about 11% to 16%, and it takes more traffic off Main Street, north US-40, and River Road. Route A is faster on two trips, both northbound on Main Street. UDOT credits both routes with the same safety gain: each “enhances safety by having fewer conflict points from driveways and intersections.” On north US-40, Route A builds interchanges, which UDOT says “offer a safety benefit by eliminating the high-speed conflict points inherent with at-grade intersections.” UDOT adds: “Alternative A requires local access to reroute to the grade-separated interchanges via frontage roads and the Heber City local street system which requires some out-of-direction travel.” DEIS, p. 2-38, Appendix 2C, p. 12
Section 4
Local plans, UDOT, and the March letter
In the local plans, the bypass ties into US-40 at 900 North. UDOT writes that the local corridor “was identified without any consideration of the abundant wetlands in the northeast segment between 900 North (where the bypass ties into US-40) and SR-113.” North of 900 North, Route A stays on US-40. Route B adds the North Fields Extension. UDOT rates neither route consistent with the local plans (Table 2.4-6, p. 2-39). No county plan puts a road in the North Fields north of 900 North: see the county’s record. DEIS, p. 1-4
UDOT: “Of the two action alternatives, Alternative A is more similar to the bypass that Heber City and Wasatch County have been considering, although neither alternative is entirely consistent with the local government preservation corridor.” And: “Alternative A follows the local government preservation corridor more closely than Alternative B does because Alternative A does not include the North Fields Extension segment.” DEIS, p. 2-46
UDOT also says: “Alternative B is more consistent with Heber City’s North Village Master Plan than Alternative A is.” DEIS, p. 2-46
In 2019, Heber City and Wasatch County asked UDOT “to conduct an EIS to identify a final route for corridor preservation.” DEIS, p. 1-4
The local record is mixed. County Resolution 22-09 (2022) named concerns with three routes: WA1, a west bypass with interchanges, and WB3 and WB4 across the North Fields. Route A later grew out of WA1 and WB1, and Route B grew out of WB3. In 2023 the Heber City Council voted to keep all five routes in the study. County Resolution 24-03 (2024) supports both conservation in the North Fields and the bypass study, and names no route. In February 2026, Heber City made eight requests to UDOT, seven of them design changes. Its letter states no route preference. See the history.
The March 2026 letter
The March 2026 joint letter asked for “An alternate alignment based on Route B but located as close to the existing US-40 footprint as possible,” and said that this “is not one of the presented alternatives.” The letter did not ask for Route A. It also said: “We recognize UDOT’s concerns regarding potential historic resource impacts associated with Route A.”
The signers were the seven members of the Wasatch County Council, the Midway mayor and five Midway council members, the Heber City mayor and three Heber City council members, the Charleston mayor, Senator Ronald Winterton, and Representative Mike Kohler. Heber City also sent UDOT its own letter. UDOT comment 689, comment 206
In May 2026, UDOT senior environmental program manager Naomi Kisen said that a route “shifted all the way to close where (U.S.) 40 is” would perform “rather similarly” to Alternative A. She added: “Every change we make does affect our travel time,” and “It’s about trying to find that happy place, where you’re not losing too much of the performance, but you’re also kind of avoiding the impacts that you’re trying to avoid.” UDOT now studies an east shift of Route B. It has not published what the shift would do to relocations, historic sites, or wetlands. Park Record, May 20, 2026news
UDOT describes the shift as “Shifting the Preferred Alternative (Alt B) alignment to the east in the North Fields,” and it has not yet published its current study. Route A needs no new road across the North Fields, and the Draft EIS has already studied it, with its costs and its gains. UDOT project page
The North Fields
In November 2018, county voters approved open space bonds of up to $10 million, 6,916 to 5,050 (57.80%). See the history.
County Resolution 24-03 (2024) supports conservation in the North Fields. It also supports the bypass study, and it names no route.
The county voted to fund a federal conservation easement in the North Fields. It overlapped all five routes then in study, and in early winter 2024 UDOT paused the Draft EIS in part because of it. NRCS later declined to go ahead. DEIS, p. 2-3, p. 5-14
Not everyone agrees. UDOT notes public comments that a bypass through the North Fields would “provide a long-term solution”. DEIS Summary, p. S-27
On February 28, 2026, farmers and residents drove tractors through the North Fields to protest the planned highway. Salt Lake Tribune, March 1, 2026news
Section 5
Laws the Draft EIS discusses
For each law: the test, UDOT’s reading, the March letter’s request, and who decides. This site argues for Route A as policy. It states no view on how UDOT, the Corps, or a court would apply these laws.
Clean Water Act, section 404
The test
One test in the Section 404(b)(1) Guidelines (40 CFR 230.10(a)): no permit for a fill “if there is a practicable alternative” with less harm to the aquatic ecosystem, “so long as the alternative does not have other significant adverse environmental consequences.” An alternative is practicable if it is “available and capable of being done after taking into consideration cost, existing technology, and logistics in light of overall project purposes.”
UDOT’s reading
UDOT believes that Route B is the least environmentally damaging practicable alternative. It says Route A has “other significant adverse environmental consequences”: the Section 4(f) finding, the relocations, and weaker transportation performance. UDOT also says: “An alternative that cannot be identified by both analyses as the least harmful is not practicable.” Appendix 2F names the first two reasons.
The March letter
The March letter asks UDOT to show why the route with less aquatic impact is not the least damaging practicable alternative.
Who decides
The U.S. Army Corps of Engineers, in the permit. As of the Draft EIS (January 2026), it had not made a permit decision.
Section 4(f), U.S. Department of Transportation Act
The test
If no feasible and prudent route avoids the protected sites, the agency may approve only the route that causes the “least overall harm”. The agency weighs seven factors. The route must also include “all possible planning to minimize harm”. The protected sites are publicly owned parks, recreation areas, and wildlife and waterfowl refuges, and historic sites that are on or eligible for the National Register.
UDOT’s reading
In its draft Section 4(f) evaluation, UDOT finds that Route B causes the least overall harm. It says that this “limits UDOT’s ability to select Alternative A.”
The March letter
The March letter asks UDOT to explain the avoidance options and its plan to reduce harm, and to evaluate the North Fields as a farm landscape.
Who decides
UDOT. Under 23 U.S.C. 327, UDOT has taken on the Section 4(f) duties of the Federal Highway Administration. UDOT makes the final finding in the Final EIS or the Record of Decision. The current 23 U.S.C. 327 agreement runs to May 26, 2027. In May 2026, UDOT proposed to renew it for 10 years.
Before it approves federal money for a project, the agency must “take into account the effect of the undertaking on any historic property”. It must also give the Advisory Council on Historic Preservation “a reasonable opportunity to comment”.
UDOT’s reading
UDOT found adverse effects on 4 historic buildings with Route A and 1 with Route B. It applied 11 criteria for rural historic landscapes, and found “no compelling reasons to recommend delineation of a rural historic landscape” in the North Fields.
The March letter
The March letter asks UDOT to evaluate the North Fields as a historic agricultural landscape.
Who decides
UDOT, in consultation with the State Historic Preservation Office (SHPO). SHPO agreed with UDOT’s eligibility and effect findings for the buildings and sites in the area of potential effects. The DEIS does not say whether SHPO reviewed the North Fields landscape question. If UDOT and SHPO disagree about whether a property is eligible, or if the Advisory Council or the Secretary of the Interior asks, UDOT must get a determination of eligibility from the Secretary (36 CFR 800.4(c)(2)).
Utah law on Agriculture Protection Areas (Utah Code 17-81-307, formerly 17-41-406)
The test
A state agency that proposes a transportation corridor must consider whether the corridor is on Agriculture Protection Area land or would “interfere with agriculture production activities” on that land. It must consider each “reasonably comparable alternative”, and “make reasonable efforts to minimize or eliminate any detrimental impact on agriculture.” The same section says that a state agency that plans “any development project that might affect land within an agriculture protection area” must submit its plan to the area’s advisory board and to the commissioner of agriculture and food. They review the plan and recommend changes that would protect the area.
UDOT’s reading
UDOT finds “no reasonably comparable alternative” to placing the road on that land. It says a route that avoids all of it would need a shift east at SR-113, which would affect a park, a planned high school, and other sites. UDOT says that the condemnation limits in former Section 17-41-405 (now 17-81-305) apply to a political subdivision. It says it is “a state agency, not a political subdivision”, so these limits “do not apply to UDOT.”
The March letter
The March letter asks that farmland UDOT buys, beyond what the road needs, stay in farm use “to the maximum extent practicable”.
Who decides
The section does not say who decides. Subsections (1) and (2) give the advisory board and the commissioner of agriculture and food a review role for a state agency development plan. The DEIS does not discuss these subsections. This page states no view on whether they apply to UDOT’s corridor. A 2025 law (S.B. 1007) renumbered these sections on November 6, 2025. The DEIS cites the old numbers.
UDOT says that under Section 4(f) it “may approve only the alternative that causes the least overall harm”, and it names Route B. Items 1 and 2 ask UDOT to look at that finding again. Appendix 2F, p. 14
In the Final EIS, weigh again the designs that avoid the three historic homes on Route A.
With those designs, weigh the seven Section 4(f) factors again.
Then, on that new weighing, select Route A in the Record of Decision.
Answer each request in the March letter in the Final EIS. See the requests.
UDOT found the three designs not “feasible and prudent”, in part because their frontage-road curves fall below the AASHTO minimum, and it calls their cost “severe”. One design cannot keep driveway access to its house. Item 1 asks UDOT to weigh that again. If each design keeps its house, each route would demolish one eligible historic structure. UDOT based the four Section 4(f) factors on historic sites on that count, so item 2 asks UDOT to weigh them again. Route B would still be faster, and it would still move fewer homes and businesses. Route A would still take less wetland and farmland. In this site’s view, the wetlands and the farmland of the North Fields should weigh more than the relocations and the travel time. The County Council signed the March letter, which asked for a shifted Route B. DEIS, pp. 4-29 to 4-32, pp. 4-40 to 4-41
The routes are UDOT’s CAD lines for the edges of pavement, the curbs, and the bridge decks, from UDOT’s public GIS service. A check laid them over all 38 design sheets of DEIS Appendix 2D, and they match. UDOT says the data “is for informational purposes and must be field verified prior to being used on a project”.
The colors follow UDOT’s description of each segment. On US-40 between the Route B ramps and 900 North, the map draws the Route A freeway and leaves out the Route B turn lanes. Elsewhere, a segment counts as “Both routes” when it lies within 15 meters of the other route.
Farmland is each field that the 2025 state survey classes as agricultural land use. The survey shows land use, not zoning or ownership.
Sources: UDOT Draft EIS line work (January 2026). Roads, railroad, and city limits: UGRC, Utah SGID. Streams and lakes: USGS National Hydrography Dataset, served by UGRC. Land use: Utah Division of Water Resources, Water-Related Land Use, 2025. Terrain: USGS 3DEP.