Public Comment: UIPA Strategic Business Plan: FY2020-2024
From: Utah Sierra Club
June 19, 2020
Dear Board Members of the Utah Inland Port Authority,
The Sierra Club appreciates this opportunity for public comment on the Utah Inland Port Authority's Strategic Business Plan: FY2020-FY2024. We firmly believe that a project of this magnitude and potential long-term impact must consistently invite and incorporate informed citizen input in order to achieve outcomes based on sustainability and social justice.
Sustainable practices and outcomes meet the needs of the present without compromising the ability of future generations to meet their own needs. We agree with Salt Lake City's Sustainability Department that "sustainability" means prioritizing a healthy society by striving for balance between environmental, societal, economic, and equity needs. The pursuit of equity acknowledges and redresses historic injustice.
The Sierra Club acknowledges that growth is inevitable, but insists that qualitative criteria must supersede the quantitative quest for unregulated development that is neither sustainable nor socially just. The investment of public funds must serve the public's best short- and long-term interests. Planning for infrastructure and productive capacity improvements must be transparent and ensure:
- preservation of natural and social environmental resources
- economic opportunities based on renewable, non-toxic resources
- prudent financial incentives that privilege minority and small businesses
- guaranteed living income for all workers
- increased health care and community services for low-income neighborhoods
- compliance with equity standards set by community stakeholders
- annual progress assessments released for public review
Our review of the Strategic Business Plan: FY2020-2024 raises several concerns, due in large part to the lack of specific project details that might substantiate stated aims and objectives. This is not a business plan likely to lure private sector investors without the legislature having provided a public funding backstop. We are disappointed that, in the third year of its existence and with FY2020 about to end, the Utah Inland Port Authority has failed to articulate precisely how it wants to move forward.
We are concerned that the UIPA plan offers no guarantees that low-income and minority communities disproportionately burdened with impacts of pollution and environmental degradation would be spared further suffering by construction of an Inland Port. Local air quality studies by University of Utah researchers have documented the systemic inequalities of life-threatening conditions borne by west side families bordering the Salt Lake County industrial zones and transportation corridors that would host an Inland Port. With the coronavirus recession hitting black and Hispanic workers far harder than whites, as reflected in the latest national unemployment data, UIPA should have articulated an ironclad commitment to achieving racial economic justice throughout its strategic business plan. Its omission is telling.
The Strategic Business Plan offers no assurance that financial incentives granted by the UIPA board would not skew Utah's economic growth model to favor select corporate and special interests at the expense of smaller enterprises and the general public. We are troubled by the plan's strategic investments statement that equity investments depend on supplemental resources over time. "UIPA may make equity investments" (page 42) is not convincing. We wonder how avoided tax and other incentives given some businesses and denied others would affect those bereft of Inland Port capital largesse but whose taxes fund it. Simply stated, the Sierra Club wants UIPA to identify which economic interest entities would be the likely Inland Port economic winners and losers under the current strategic business plan, how that dynamic would affect Utah's economic stability into the future, and what specific corrections UIPA will make to ensure that outcomes are win-win, not zero sum.
A third focus of our concern is the nature and scope of the proposed Inland Port's potential impacts on the area's working class Utahns who are more likely to be people of color than is the case elsewhere in Salt Lake County and across Utah. As the Sierra Club confronts issues of systemic racism within the history of our organization, we recognize that economic racism remains endemic in U.S. culture and society. The UIPA plan fails to describe how it will address and transcend the prevailing Utah development model that continues to subordinate people of color. As an example, the plan uses the word "minority" only once in its four documents. Even there, in the context of Advisory Services (again page 42), nothing is guaranteed. We have no reason to believe that UIPA truly appreciates Utah social disparities rooted in racism or has any commit to dismantle systematic inequality and expand access for economic opportunity to Utahns of color.
These are among the reasons we believe UIPA's Strategic Business Plan to be deficient and sorely in need of revision. We were also surprised to learn from the Technical Appendix [page A-45] that "[N]o fieldwork was performed" to inform the Environmental Sustainability section. Another disturbing statement holds that "[B]ecause no projects are being proposed under this strategic planning effort, this environmental review is informational only and is not intended to constitute compliance with any regulatory requirements." That is both irritating and troubling. First, because we know that projects are already in motion, such as the Seven County Infrastructure Coalition's satellite logistics facility along with UIPA agreements with Utah Clean Cities and Rocky Mountain Power. And secondly, because environmental regulations seem to have been categorically snubbed by UIPA plan developers.
As regards the Satellite Ports component of the broader Inland Port proposal, UIPA's plan calls for "smart logistics investments" [page 29], but does not clarify how "smart" would be defined and operationalized in actual planning and implementation. The Sierra Club insists that UIPA provide more specific details about what those investments would entail and what commodity transfers they would support.
We are aware that county officials in attendance at the April 2019 satellite port development meeting not only marked Utah maps with proposed satellite port locations, but were charged with drafting 'wish lists' of items to be traded from their respective jurisdictions. We would like to know the outcomes of that charge and why the Utah Association of Counties is now being paid for an assets map that may already have been accomplished through Envision Utah.
Furthermore, and with regard to proposals for Satellite Ports Development in rural areas, we insist that any proposals for UIPA's rural "project areas" and infrastructure meet criteria that include:
- Comprehensive economic assessments of what rural Utah communities need and what human and renewable natural resources are available to effect positive change.
- Clearly stated "just transition" objectives for moving rural Utah beyond extractive industries and other pursuits destructive to the environment and long-term community interests.
- Detailed implementation sequencing with transparency, costs analysis, and accountability at every stage; in other words, a real business plan.
- Rigorous vetting of every proposed satellite port project proposal to ensure that sound, legitimate economic and environmental practices are required and enforced.
- Frequent, third party audits of UIPA and every subordinate entity responsible for securing and administering funds for satellite port projects; and,
- Accountability for strict compliance with the highest state and national environmental standards.
Thanks in advance for paying thoughtful attention to our public comment and to those filed by all members of the public. We look forward to reading a more thorough, actual strategic business plan produced by UIPA in the near future. In the meantime, and particularly in the context of COVID-19 budget cuts and public health concerns, we call upon UIPA to suspend any further construction of Inland Port facilities anywhere in the state at least until the concerns we have raised are addressed and pandemic circumstances permit.