I was recently made aware of a document which was posted on the Prison Relocation Commission (PRC) website on Friday March 27th. The document is titled “Utah State Prison Siting Program Site Screening Assessment Report – Round 2. It identifies, scores and ranks the sites under consideration for the prison as a result of the “second round” of solicitations by the PRC. Unfortunately, this document is somewhat confusing because it has included some sites that were re-scored from round 1 while omitting others. I believe this has led to some confusion, which I am hoping to clear up here. The recently released report can be viewed HERE. Before we dig into this document, we should keep in mind that HB 454 has already identified the full list of potential sites that may be considered as seen in the bill excerpt which I have highlighted in red below.
(2) (a) On or before August 1, 2015, the commission shall:
(i) choose the site for the construction of new prison facilities from among the sites that
the commission recommended as potential sites in the commission’s report to the governor and
the Legislature, adopted on and dated February 27, 2015; and
(ii) report the commission’s choice to the president of the Senate, the speaker of the
House of Representatives, and the governor.
(b) The site chosen by the commission under Subsection (2)(a) shall be the site for the
construction of new prison facilities if the site is approved by the Legislature at:
(i) a special session of the Legislature that the governor convenes for that purpose; or
(ii) an annual general session of the Legislature.
As you can see from the bill text, a report was prepared for the governor and legislature and dated February 27th. That document can be found here. Page 7 of that report identifies the potential sites as follows:
- I-80 / 7200 West (Expanded)
- SR 112/ Depot Boundary
- Lake Mountains West (Eagle Mountain site)
- Cedar Valley South (Fairfield site)
- SR 138 Industrial Park
Though you will find information about many other potential sites on various documents including the one released in March, they are now irrelevant and can not be considered for the relocation of the Draper Prison. From the five sites identified in above, I will only be providing commentary on the I‐80 / 7200 West Site (Expansion) and Cedar Valley South (Fairfield) sites for illustration purposes. I have chosen these two sites because they seem to be in contention for the #1 and #2 spots at the current time. It should also be noted however, that the scoring of the sites which we see in the document, are preliminary and are likely to change for two reasons. One is because the logic of the scoring is flawed and I am going to contest the manner in which the sites have been scored. Two is because a more in-depth analysis will need to be completed to more accurately identify some of the more technical characteristics of each site. I believe the process has been mishandled on many levels. The PRC and the consultant have communicated that the site scoring is preliminary until an in-depth analysis is completed, though the inconsistent scoring has been used to make decisions about future actions. While the scoring may be preliminary, it should be accurate and in this case, it clearly is not.
In the simple comparison below (you can expand the picture by clicking on it and magnifying), we can see the results of the new criteria being used to score the sites. If you are interested in comparing the source of the data I have used and the specifics from the scoring, you can view the linked Original Site Scoring Report from round one. The second round details are linked in the Round 2 Site Scoring Report. I won’t go through every detail of the analysis, but the concept of this new analysis is essentially that the criteria changed. More importantly, the the changing of the criteria resulted in “leftover” points which were “redistributed equally across other criteria to maintain a potential score of 100 points” (Site Screening Assessment Report – Round 2, Pg. 6, paragraph 2). I will spare you the mathematical explanation as to why this method is fundamentally flawed and point out the obvious. The changing of the established criteria in the middle of a process which relies on “quantitative analysis” manipulates of the outcome. Whether manipulation is intentional or not is of no consequence; the result is the same.
By simply reducing the number of potential points from one category and redistributing those potential points to another category, the results may become drastically skewed. A site that may have been rated highly in one category and lower in another can move up or down the overall ranking when potential points are redistributed. We see the effect of this in the comparison of the 1-80/7200 West, and the Cedar Valley South Site’s original scores against their new scores. The Cedar Valley South site has a 25% increase in total score (from 61 points to 76 points), while the 1-80/7200 South site total score decreases by 2% (76 points to 75 points). The redistributed potential points essentially rearrange the weighting of the categories.
Scoring changes for the Cedar Valley South site took the infrastructure category from 6 points in round one, and increased it to 11 points in round two. Increases also came to the water, wastewater, and electric and natural gas categories, though assumptions made by the consultant rely on service from Eagle Mountain. For water and wastewater, I notified the consultant (well prior to the report being posted) that Eagle Mountain City would not be providing either of those utilities to the prison. Doing so would add many miles of infrastructure to our inventory. Cities typically avoid developing far away from their existing infrastructure due to the inefficiency of maintaining the unused portion of the infrastructure where no connections exist to generate revenue. The very long distances to build electric, gas, and communications infrastructure do not warrant an increase in points from the original score. Electric transmission lines would need to be run no less than 10 miles.
In scoring the emergency services for the Cedar Valley South Site in round one, 3.5 points were awarded. Round two has awarded the full 5 points to the Cedar Valley South site, though the services have not changed. It should be noted that Eagle Mountain does not have ownership of a police department or fire department, and would not be willing to pay for serving the prison. The best option would likely be for the Department of Corrections to appropriate funds for such services through the Utah County Sheriff and Unified Fire Authority, just as Eagle Mountain does. We do currently provide mutual aid to the relatively small populations of Cedar Fort and Fairfield. Due to the size of the prison, we would be unwilling to degrade our service voluntarily. In total, the Fairfield site experiences a 25% increase in points scored, while the 7200 West site sees a 2% decrease in scores. There are other concerns I have over the reasoning behind the changes to the scoring, though these are the most visible ones.
At the end of the day, I know that if the prison relocates to the Cedar Valley South site, it will have a significant and detrimental impact on Eagle Mountain’s traffic. We already struggle with meeting the traffic needs of our rapidly growing population. While my role dictates that I care for the needs of the residents of Eagle Mountain, our neighbors in Fairfield are no less important. We will stand shoulder to shoulder with Fairfield and oppose this very frustrating process for their wellbeing, as well as our own. I am disappointed with the way HB 454 was passed during the legislative session. I do not believe it is appropriate to incorporate an increased taxing authority into a prison bill. Taxing authority and the prison move are two separate policy considerations and should be addressed individually. Neither should such heavy decisions be introduced without discussion and then passed in the waning hours of the session. We as elected representatives have been given a very special stewardship and this action is a betrayal of the conservative principles which I know so many of us espouse. To speak for myself, HB 454 was a betrayal at least of my principles. I am disappointed. I hope and pray that my disappointment would not extend to a scoring process which abandons truly objective analysis in order to accomplish a specific result.