MINERAL BASIN

MB1. The EIS failed to conduct a full and independent review of the MB analysis as the `no-action alternative' in the MDP EIS. An independent review should be performed and include consideration of items MB1-MB11.

From the time Snowbird's MDP was in the scoping stage the USFS received public comments arguing the need to analyze the Mineral Basin expansion as the "Proposed Action." It is impossible to separate Mineral Basin from other elements of the "Proposed Action" which were being considered by the USFS in an EIS. The EIS cannot have action elements associated with the "No-Action" alternative and consequently the required actions were left out of the EIS. The USFS may not have had the right to deny Snowbird their right to build on their private lands, but they did have an obligation to the public that negative impacts to public lands associated with the project be diminished to the greatest extent possible.

Rather than protect the public domain, the USFS ignored federal regulations, misled the public, and quietly traded public lands away. All of this served to benefit Snowbird and harmed the public. Past actions cannot be reversed, but current decisions can be repealed and responsible officials can be reprimanded.

The Mineral Basin Small Tracts Act Interchange was a connected action, intimately tied to other aspects of the Snowbird MDP. The Forest Supervisors evaded the requirements of NEPA by treating this as a separate action appropriate for processing under the Categorical Exclusion mechanism.

The EIS makes clear that existing and proposed skier facilities in Mineral Basin are an integral part of the Snowbird Ski and Summer Resort. The only access to the Mineral Basin lifts is via lifts in the current SUP area. No separate lift ticket is required for the use of the Mineral Basin lift. According to the EIS, the majority of the users of the Hidden Peak facility will be skiers from Mineral Basin, not skiers from within the current SUP area.

The development of lift-supported skiing in Mineral Basin has the potential for significant environmental impacts to both the private land owned by Snowbird at the time that the draft EIS was issued, and the public land surrounding Mineral Basin and the public lands interspersed throughout Mineral Basin which was traded to Snowbird subsequent to the issuance of the draft EIS. NEPA thus requires that the totality of the developments even remotely associated with the Mineral Basin expansion in the proposed MDP be evaluated as a whole.

The connectivity of the Small Tracts Act Interchange with the development of Mineral Basin can be proven in two ways: First, there is a significant economic relationship between the Small Tracts Act Interchange and the development of Mineral Basin. The economic difference between developing Mineral Basin while avoiding the 6-14 public parcels of land which are between 1.98 and 9.3 acres in size versus developing Mineral Basin under full Snowbird ownership is significant. The location of the public parcels shows that the possibility of constructing the Mineral A lift becomes questionable if avoiding the public lands were to have been a necessity. Second, the fact that these formerly public parcels were developed immediately after the Small Tracts Act Interchange was completed makes it probable that the development was done out of necessity, rather than as an oversight. Snowbird and the USFS knew these parcels were to be managed in the same manner as before, yet chose to proceed in violation of the Small Tracts Act. Snowbird made it clear in the Small Tracts Application to the USFS that this conflict existed.

The Forest Service, through its participation in the land exchange described above and through its acquiescence and assistance in the construction of the Mineral A ski lift violated Section 1506.1 of the Council on Environmental Quality Regulations (40 C.F.R. Part 1500).

Section 1506.1 of the Council on Environmental Quality Regulations, concerning "Limitations on actions during NEPA process," states in part:

(a) Until an agency issues a record of decision as provided in Section 1505.2 ..., no action concerning the proposal shall be taken which would:

(1) Have an adverse environmental impact; or

(2) Limit the choice of reasonable alternatives.

(b) If any agency is considering an application from a non-Federal entity, and is aware that the applicant is about to take an action within the agency's jurisdiction that would meet either of the criteria in paragraph (a) of this section, then the agency shall promptly notify the applicant that the agency will take appropriate action to insure that the objectives and procedures of NEPA are achieved.

The Forest Supervisor benefitted the applicant while denying the public a right to comment on actions which affect the management of their lands. Furthermore the public was never notified by the USFS that their objections to the analysis of Mineral Basin as the "No-Action" alternative were denied. The construction of Mineral A lift before the release of the Record of Decision, came as a complete surprise. The WCNF gave no public notice, even though Snowbird claims that the USFS knew of their plans in advance. The items below detail NEPA and other regulatory documents which the WCNF and the Uinta National Forest evaded, resulting in the premature and illegitimate development of Mineral Basin.

MB2. Substantive comments which were made in the draft EIS which were incorrect at the time they were made and known to have been incorrect by both the applicant and the Forest Service.

The Forest Service failed in its obligations under section 1506.5 of the Council on Environmental Quality Regulations (40 C.F.R. Part 1500) to be responsible for the accuracy of information presented in the EIS.

Included within the draft EIS was a description of an expansion of the Snowbird ski area to include Mineral Basin, an area south of the current permit area where no downhill ski development had previously occurred. Only cursory evaluations of the environmental impacts of the Mineral Basin expansion were included in the draft EIS, based on the stated justification that "all of the physical developments and most of the skiing terrain proposed in Mineral Basin are on private land." These statements served to mislead the public and evade requirements of NEPA.

In actuality, as of the time of issuance of the draft EIS, the Forest Service held title to at least six parcels of land totaling at least 1.98 acres in the portion of Mineral Basin proposed for development. Some of the "physical developments" were knowingly planned to cross these parcels. Both the Forest Service and Snowbird were clearly aware of this fact, since they were actively involved in discussion about a land exchange that would give Snowbird ownership of all public parcels. The land exchange was subsequently completed, which should have been reveiwed as a proposed action in the MDP EIS, but instead was side-stepped via the use of a Categorical Exclusion under the Small Tracts Act. Immediately after the exchange, Snowbird constructed a ski lift that was known to cross one or more of these parcels and conducted blasting on one or more parcels (See Attachment 1).

There is no question that had the six parcels remained in public ownership, it would have been necessary to include the Mineral Basin expansion as part of the Proposed Action in the EIS, as required by NEPA. The failure to disclose the public ownership of this land at the time that the draft EIS was issued allowed the land exchange to proceed without public scrutiny -- an outcome clearly beneficial to Snowbird and one that allowed the Forest Service to avoid additional expense and controversy. It may be argued that Categorical Exclusion's also fall under NEPA and public notification is required, however NEPA was also violated in the scoping methods used with the Categorical Exclusion. (see MB7 below)

The EIS failed to list all the permits that were required before Snowbird would be allowed to begin development of Mineral Basin. Under the section in the EIS "1.5 Permits and Authorizations" the Forest Service listed County and other permits necessary for Snowbird to develop Mineral Basin except the ones required by the USFS. The public was also not informed of the possibility that Snowbird would be able to begin construction in Mineral Basin before the completion of the NEPA process.

The fact that significant environmental disruption occurred due to road construction, lift tower construction, and ski run excavation is clear from the photographs included as Attachment 2.

MB3. KW Brown and Associates failed to act as a disinterested party in preparing the EIS.

The fact that one or more false statement of substantive importance were made in the draft EIS calls into question the integrity of KW Brown & Associates, which assisted in the preparation of the draft EIS. Since KW Brown & Associates also assisted in the land exchange, they clearly knew that the statements made about land ownership in Mineral Basin were false at the time that they were made. As a result, the environmental analysis of all of the MDP must start anew with unbiased personnel.

The BA/BE for Mineral Basin prepared by KW Brown and Associates states, "None of the construction activities proposed by Snowbird will occur on lands proposed for the exchange." This is different from Snowbirdís statements on constructing chairlifts and ski runs in the "immediate vicinity" of the federal parcels. It is clear from photographs that the lift alignment of Mineral A crosses over one or more formerly public parcels (see attachment #2). Additional statements from the EIS say, "The alignment and both top and bottom stations are on private land." This was not true at the time the draft EIS was published and the alignment has since been constructed crossing over one or more parcels.

MB4. The Forest Service failed in its obligation to verify that the Small Tracts Act Interchange did not result in significant environmental impacts.

The Forest Service failed in its obligation to verify that the Small Tracts Act Interchange did not result in significant environmental impacts, failed in its obligation to determine that the Small Tracts Act Interchange satisfied the requirements of the Small Tracts Act that there be no significant change in land use as a result of the exchange (see below).

MB5. The Forest Service inappropriately used a Categorical Exclusion for the Small Tracts Act Interchange.

The UNF Forest Supervisor disregarded statements from Snowbird saying that federal parcels were in the `immediate vicinity' of both ski runs and planned chairlift development. The development of these parcels violates both the Small Tracts Act and the use of a Categorical Exclusion.

MB6. The Forest Service failed to analyze the impacts to these public lands from the developments directly resulting from the Small Tracts Act Interchange.

The CE analyzes only the effects of the parcels changing hands from the USFS to the permittee, and not the immediate result of that exchange, which is a violation of NEPA.

It is clear that Snowbird was aware that its planned ski lifts and runs at least potentially crossed what was then public land. Snowbird's request to initiate the land exchange states that: "Snowbird has decided to locate a chairlift in the immediate vicinity of the federal mineral survey fractions. If federal mineral survey fraction A indeed exists (subject to verification upon inspection of pertinent public land records), Snowbird will either seek the necessary easement across this mineral survey fraction or reconfigure its lift and trail network to avoid this parcel." No documents explain how this dilemma was resolved.

MB7. The Forest Service failed to conduct scoping on a Categorical Exclusion.

The Forest Service is unable to provide documentation that adequate public notice of the exchange was made, other than a letter from Snowbird asserting that they described their plans to Save Our Canyons in a private meeting held on July 6, 1998. Members of Save Our Canyons who attended this meeting remember no such conversation. One individual took meeting minutes and the subject was not recorded. The assertion in the letter that Save Our Canyons "did not seem too concerned about such a small issue" is in any event totally implausible, given the confrontational position regularly assumed by Save Our Canyons in matters of such magnitude. Snowbird's role in concealing USFS activities from the public should be investigated.

Through the FOIA process, Save Our Canyons found that only one individual (outside of governmental agencies and Snowbird employees and contractors) was notified of the Small Tracts Act Interchange. This individual was the owner of private land in Mineral Basin.

MB8. In the Mineral Basin Small Tracts Act Interchange the Forest Service used imprecise and antiquated BLM land survey records rather than updated ground surveys already conducted by Snowbird.

The documentation on the land exchange is replete with mention of incomplete and inconsistent records of boundaries. In analyzing and effecting the exchange, the Forest Service chose to utilize BLM information from the time of the original filing of the mining claims, rather than the more complete survey done by Snowbird in September, 1998. This had the effect of reducing by a factor of 5 the described acreage, reducing the number of parcels involved, and reducing the areas covered by those parcels. As a result, the apparent potential conflicts between ski lift and ski run development and public lands was reduced. In addition, it is possible that the federal government received lands of lesser value in the exchange, since it may well have received less acreage than it gave up combined with the fact that the Mineral Basin parcels have a value associated with human use, while the Snowbird parcel is difficult to reach.

MB9. The WCNF failed to issue Snowbird an SUP to cross federal lands to access their private property.

The WCNF Forest Supervisor failed to advise Snowbird to obtain a Special Use Permit to access their private land when hauling lift equipment into Mineral Basin. This action had an adverse environmental impact and served to limit the reasonable choice of alternatives to be considered within the NEPA process. This Special Use Permit also would have required the Forest Service to analyze the effects of both the transport and subsequent development that the lift would have on surrounding public lands. Again the WCNF failed to hold Snowbird to agency procedures which would have required the accessing of Mineral Basin to be studied as part of the `Proposed Action' based on both the effect that the transport of equipment and subsequent devlopments would have on public lands. The failure to issue an SUP benefitted Snowbird by keeping the Mineral Basin expansion out of the eye of the public and saved both the USFS and Snowbird the work and cost of analyzing the impacts of the Mineral Basin developments on public lands.

MB10. The WCNF failed to issue other permits on actions which impacted public lands as a result of Snowbird's developments on private land.

Snowbird utilized public lands as a staging area and temporary dumping site for waste material from private lands without receiving a permit from the USFS. Additional permits may have been required for development related activities (see attachment #1).

MB11. The EIS fails to adequately analyze the effects of MDP projects on Mineral Basin as well as the impacts of Mineral Basin on the MDP and the environment.

The Record of Decision allows an expansion of the Snowbird SUP to include a portion of Mineral Basin. The safety and utility of Mineral Basin without avalanche control is diminished. Additionally, full and effective utilization of the proposed Mineral Basin skiing complex is not possible without a substantial expansion of skier support services on Hidden Peak. For both of these reasons, a full analysis is required of the impacts pf the Mineral Basin development on the proposed actions in the Snowbird MDP. Also the other way around.

Mineral Basin analysis was inadequate `Volume 2- Response to Comments' of the final EIS claims that impacts on Mineral Basin have in fact been analyzed, citing the following specific sections: 3.4.2.5, 4.4.3.2.4, 4.4.4, 3.7.2.3, 3.7.2.4, 4.7.3.2.6, 4.7.3.2.7, and 4.7.4.

The following table shows the topics of each of these sections:

3.4.2.5 Avalanche 4.4.3.2.4 Avalanche, search and rescue. 4.4.4 White Pine Canyon 7.2.3 Backcountry skiing, snowmobiling 3.7.2.4 ORV usage. 4.7.3.2.6 Winter recreation 4.7.3.2.7 Impacts directly associated with the Hidden Peak facility. 4.7.4 White Pine Canyon

As is clear from the table, no impacts of any sort have been analyzed for Mineral Basin, save for a limited discussion of recreational and health and safety issues.

The development of lift-supported skiing in Mineral Basin will have environmental impacts far beyond those discussed in the EIS. In addition, the development of large-scale visitor support services on Hidden Peak has as a reasonably foreseeable impact real-estate development in Mineral Basin.

Volume 2 of the final EIS states that "Regarding public review and comment on the expansion into Mineral Basin, all Mineral Basin elements were included in the same public involvement process as the rest of the MDP." This statement is untrue. As documented above and in Attachment 1, a land exchange, essential to the development of Mineral Basin as a downhill ski area, was conducted without public review or input and with no environmental analysis of associated actions. It is hard to view the land exchange as anything other than an attempt to evade the requirement for an environmental analysis of the development of Mineral Basin. Whatever the public or private status of the land involved, Mineral Basin development is clearly a cumulative impact of the development proposed for Hidden Peak.

MB12. The EIS fails to justify the need for expanded skiing terrain on public lands in Mineral Basin.

The need for skiing terrain on public lands in Mineral Basin has not been justified. The area which has been given to Snowbird in their SUP extension which adjoins the proposed Mineral B lift site, is seemingly no longer needed for the intended purpose of lift terminal access from a road which was proposed to have crossed this land. The Special Use Permit extension for the use of this land for skiing should be analyzed in conjunction with Snowbird's proposal to construct the ski lift `Mineral B.'

AREA-WIDE IMPACT ANALYSIS

AW1. The EIS fails to include an area-wide impact analysis.

Volume 2 of the final EIS gives three reasons why an area-wide impact analysis was not performed:

• The Environmental Impact Statement's for the four resorts in Big and Little Cottonwood Canyons were prepared at different times.
• Cumulative effects of the proposed actions and alternatives have been included in the EIS.
• The Forest Plan is the appropriate level at which to consider area-wide impacts.

The `Cumulative Impact' sections in the EIS draw areas of impact as narrowly as possible. One consequence of this is the lack of almost any discussion about how the large scale developments now underway or proposed for the four resorts in Big and Little Cottonwood Canyons interact. Any discussion of the interactions between the Snowbird MDP and the massive development now underway in the Park City area is totally missing.

While under ideal circumstances the Forest Planning process might be the most appropriate level at which to consider area-wide impacts, the circumstances with respect to planning for this project are far from ideal. The 1985 Forest Plan failed to account for the extreme growth in recreational use of the Wasatch Mountains. The new Forest Plan will not be completed until major construction projects at the four resorts in Big and Little Cottonwood Canyons are well underway. Deferring an area-wide analysis makes any results obtained from such an analysis near meaningless.

AW2. The Purposes and Needs analysis fails to consider the ski area development underway and planned on private land in Summit County.

According to the Resort Master Development Plan EIS: Alpine Skiing and Recreation Technical Report, annual skier visits in Summit County are projected to increase by approximately 700,000 once planned and ongoing developments are completed. This is half again as large as Snowbird's total annual skier visits. The limited overall growth of skier visits in the state means that either the Summit County resorts will draw skiers from Snowbird, reducing or eliminating the need for the proposed actions, or Snowbird will be drawing skiers away from the Summit County resorts, in violation of Forest Service policy which states that facilities on public land should not compete with similar facilities on nearby private land.

CUMULATIVE IMPACTS

CI1. The cumulative impacts were not adequately addressed.

In addressing the cumulative impacts to `watersheds' in American Fork Canyon the EIS states, `this project would not cause any notable threshold of wetland impact to be crossed.' No reference is given as to which thresholds were measured in American Fork Canyon. No specifics are given about the cumulative effects that Snowbird's devlopments in Mineral Basin will have on public lands. One must assume that they have not been determined.

It is also unclear why, `0.14 acres of wetlands would be impacted by road crossing or ski run construction' under the no-action alternative. If the USFS does not know what action will impact a wetland, how will they know how many acres will be affected. There is also no indication of where this will occur.

No mention was made of cumulative effects of vegetation populations in American Fork Canyon. Snowbird blasted approximately 25 acres of land in Mineral Basin during the summer of 1999. The effects to sensitive species populations is apparently unknown.

WATER QUALITY

WQ1. The EIS and the Record of Decision fail to adequately consider water quality issues related to snow making as proposed in the Record of Decision.

The following comment was made in response to the draft EIS: "[a]dditional withdrawals would lower the water table in the mines, expose more of the heavy metal sulfide minerals to oxidation with additional releases of heavy metals such as cadmium and zinc into the water". This comment relates to increased releases of heavy metals due to fluctuations in the water table in the mine workings caused specifically by the additional Snowbird withdrawals of water for snowmaking. The EIS fails to address the chemical mechanisms by which the heavy metals are solubilized so that they can be transported to the stream with possible harmful effects. (see also attachment 6, sec. 4)

PLANTS AND ANIMALS

PA1. The EIS inadequately lists and evaluates impacts on plants and animals.

The EIS inadequately lists and evaluates impacts on plants and animals, including snow compaction, the impacts of increased avalanche control, increased summer usage of Hidden Peak, the use of polluted water drawn from the Wasatch Drain Tunnel for snowmaking, and the impact of additional automobiles parked on and off the shoulder of State Highway 210 during peak periods. Elaboration on these issues can be found in attachment 6.

PA2. The EIS inadequately analyzes the impact of the proposal on sensitive plant species.

The EIS and the subsequent Forest Service Biological Evaluation/Assessment failed to analyze the impact of the project on many rare and endemic species known to occur or having potential habitat within the project area. Many of the mitigation measures in the final EIS and Record of Decision were not discussed in the draft EIS and have not been subjected to public comment. A number of the proposed mitigation measures have serious defects and need to be modified. Elaboration on these issues can be found in Attachment 6.

TRAFFIC

T1. The EIS fails to consider the cumulative impact of weekend and mid-week traffic congestion on the skiing experience of those visiting the Alta Ski Area and the backcountry.

While the EIS discusses traffic issues in general, it provides no analysis of the impacts on users of the Alta Ski Area and the backcountry. These users suffer the consequences of increased traffic due to development at Snowbird, with none of the benefits. Some of the possible mitigation measures for traffic congestion at Snowbird, such as signalized access at entries 1 and 2, would have a major detrimental effect on the quality of the experience for those continuing on to Alta.

The EIS claims that the impacts on transportation for the no action alternative and the various other alternatives considered in the analysis are effectively the same. If the asserted importance of the Hidden Peak Facility to the skier experience in Mineral Basin is to be believed, this is not true. If expanded skier services are not provided on Hidden Peak, it is reasonable to assume that fewer skiers will visit Mineral Basin. This will likely lower the total visitation at the resort.

SUMMARY

For the reasons given in detail in this letter we seek the remedies listed at the outset.

ATTACHMENTS

1. Analysis of the Mineral Basin Small Tracts Act Interchange, with maps of Mineral Basin land ownership prior to the exchange.
2. Photograph of Mineral Basin lift construction and blasting.
3. Copy of Save Our Canyon's Mineral Basin expansion letter to SL District Ranger Dan Jiron and response.
4. Viewshed map of the Hidden Peak structure.
5. Seismic safety of Hidden Peak structure
6. Sensitive plant and animal analysis
7. Save Our Canyon's grandfathering letter regarding the Hidden Peak structure
8. WRNF improper amendment of Forest Plan
9. Utah Skier Visit Analysis critique

The DEIS was grossly deficient in addressing the earthquake hazard presented by a large public structure on the summit of Hidden Peak. The EIS Volume 1 and Volume 2 are improved in addressing the known earthquake activity on the nearby Wasatch Fault and proposes that the structure on Hidden Peak will be designed to the Utah UBC Zone 3 Code. "The peak ground acceleration predicted for firm rock sites in the Snowbird region is 0.25 g with a 10% probability of exceedance within 50 years" EIS, Vol 1, p. 1-20. "The intensity of ground shaking will be more influenced by rock types than topography", EIS, Volume 2, p. 78. These and similar statements in the EIS document fail to consider amplification of earthquake ground motions on ridges and fail to address the comment made by Parry (November 12, 1998 letter to Dan Jiron): "Further, the topography in the vicinity of the structure is rugged and, even though Hidden Peak is located west of the Wasatch Fault, earthquake waves may very likely be focused in the area of the peak and produce unexpectedly high accelerations."

Site specific effects may be serious, cannot be predicted (see below), and should be studied before placing a structure that could expose hundreds of people to a serious earthquake hazard on top of a mountain peak. Two major prehistoric rock slides are present in Little Cottonwood Canyon. The first involves limestones and quartzites similar to those on the summit of Hidden Peak. This major catastrophic rock fall transported large boulders from the vicinity of Devils Castle down into Albion Basin. The second involves the igneous intrusive of the Little Cottonwood stock and transported large boulders into the canyon bottom near Tanners Gulch. The timing of these two rock falls is not known, but may coincide with earthquake events on the Wasatch Fault. It is doubtful that the building code ever considered building structures to accommodate hundreds of people on mountain peaks. Some of the studies in the published literature related to this problem are quoted and cited below:

"Ground motion amplification can also occur as a result of topographical effects; in particular buildings sited on ridges may be vulnerable" Coburn and Spence, 1992 p. 191.

"The recording of high ground motion at the top of a ridge is consistent with observations from earthquakes that at the tops of mountains, rocks are sometimes shattered and damage may be high. In Italy, for example, many old towns are built on hilltops. Careful evaluation of localized damage from the destructive November 23, 1980, ML=6.5 earthquake in southern Italy showed peak intensities (MSK) two units higher on limestone crests than on surrounding lower and softer deposits (Siro, 1982). In this case, because of topography, building on rock was riskier than building on soil. Topographic effects may, however, be more complicated than originally anticipated. Geli, Bard, and Jullien (1988) summarized available studies and noted that amplification at a mountain top is a frequency dependent phenomenon whose largest effect is for seismic waves with wavelengths approximately the same as the width of the mountain. The effect is larger for horizontal than vertical motion." (Reiter, 1990, page 162)

"Along the mountainside, complex deamplification and amplification can occur, possibly leading to large, and dangerous, differential motions especially near the upper parts. While theoretical calculations predict crest amplifications with respect to the base on the order of 1.5, recorded motion indicates that this can reach a factor of 10 and, in one case a factor of 30." (Reiter, 1990, page 162) "Rock outcrop sites on hills affected the amplitude of incident signals by as much as a factor of eight, at frequencies inversely proportional to the dimension of the hill, and more for horizontally that for vertically polarized signals." (Tucker et al., 1984).

"More generally, our observations have shown that local effects at typical rock sites can be large. Inferences of seismic source properties or propagation-path attenuation based on rock-site measurements and estimates of earthquake hazard at rock sites may be largely in error if site effects are not considered". (Tucker, et al., 1984).

"It is often reported after destructive earthquakes in hilly areas that buildings at the top of massive crests suffer more intensive damage than those located at the base; examples of such observations may be found in Angot (1909) (Bambesc, France, 1909 earthquake, Brambati et al. (1980) (Friuli, Italy, 1976 earthquake), Siro (1982) (Irpinia, Italy, 1980 earthquake, and Celebi and Hanks (1986) Chile earthquake of 1985)" (Geli, et al. 1988)

"There exists a significant amplification at hilltops with respect to the base, for frequencies corresponding to wavelengths about equal to the mountain width."

"The hillsides undergo complex amplification-deamplification patterns and also significant differential motions, especially in the upper parts of the hill." (Geli, et al., 1988).

"Experimental studies have measured amplifications of incident seismic signals by rock sites to be as large as a factor of 10" (Bard and Tucker, 1985)

"The site effects of important structures, communication antennae, and power transmission towers located on ridges and mountain tops should be determined to assess their seismic hazard." (Bard and Tucker, 1985)

References

Angot, A., 1909, Le tremblement de terre de Provence (11 Juin 1909), Annales du Bureau Central Meterologique de France, Memoires, 37-93 (in French).

Bard, Pierre-Yves and Tucker, Brian E., 1985, Underground and ridge site effects: A comparison of observation and theory: Bulletin of The Seismological Society of America, Vol. 75, No. 4, pp. 905-922.

Brambati, A.; Faccioli, E.; Carulli, E. B.; Culchi, R. Onofri, R. Stefanini, S.; and Ulcigrai, F., 1980, Studio de microzonizzazione sismica dell'area di Tarcento (Friuli), Edito da Regiona Autonoma Friuli-Venezia Giulia.

Celebi, M. and T. Hanks, 1986, Unique site response conditions of two major earthquakes of 1985: Chile and Mexico, Proceedings of the International Symposium of Engineering Geology Problems ian Seismic Areas, vol. IV, Bari, Italy, April, 1986.

Coburn, Andrew and Spence, Robin, 1992, Earthquake Protection: John Wiley and Sons, New York.

Geli, Louis, Bard, Pierre-Yves, and Jullien, Beatrice, 1988, The effect of topography on earthquake ground motion: A review and new results: Bulletin of the Seismological Society of America, Vol. 78, No. 1, pp. 42-63.

Reiter, Leon, 1990, Earthquake Hazard Analysis: Columbia University Press, New York.

Siro, L., 1982, Southern Italy November 23 1980 Earthquake, Proceeding of the 7th European Conference on Earthquake Engineering, Athens, Greece, September 20-25, 1982.

Tucker, B. E. King, J. L.; Hatzfeld, D., and Nersesov, I. L., 1984, Observations of hard-rock site effects: Bulletin of the Seismological Society of America, Vol 74, No. 1, pp. 121-136.

Attachment 6 Sensitive Plant and Animal Analysis

The purpose of this section is to review the Snowbird Master Plan FEIS, ROD, and Biological Assessment/Evaluation and related documents as they concern the impact of implementation of the Snowbird plan upon sensitive plant and animal species. Mitigation measures in this regard are also reviewed and suggested changes made.

The proposed construction outlined in the FEIS for Snowbird will have the following impacts on plants and animals within the Snowbird area:

1. Snow compaction: the increased use of snowcats and other snowmachines as well as the increased use of the area by skiers and snowboarders will compact the snow more than occurs naturally. This will affect the melt rate and delay the melt-out, which will affect the growth of plants. (See page 4-120 FEIS 2)
2. The increased use of avalaunchers and other explosives for avalanche control purposes will reduce naturally occurring snow cornices, masses and drifts, and move them downhill, accelerating their melt-out and reducing a source of summer water for plants and animals, especially along the alpine ridges.
3. The increased non-ski season use of the Hidden Peak preferred alternative facility will bring many more users to the area. The number of non-ski season users has not been estimated. But with a seating capacity of 592 people ( ROD) and three turns a day for 200 days, the facility would have a capacity of 355,200 people each non-ski season. Estimates of the need or use of new hiking and biking trails have also not been included in the impact statement. But clearly these new facilities have the ability to at least double or triple the current 68,000 (FEIS 3-39) non-ski season riders of the tram. In turn, these activities would have a great impact on plants and animals in the area. On page 4-131, the FEIS predicts that without implementing restrictions "some level of impact to alpine vegetation from trampling is expected due to the large increase of visitors to the top of Hidden Peak". The question of what level of impact the trampling will have on the environment has not been answered in the FEIS.
4. The proposal to use water directly from the Wasatch Drain Tunnel for snowmaking purposes will negatively impact plants and animals. The amount of zinc, copper and cadmium from the Wasatch Drain Tunnel regularly exceeds 3-A water standards. The use of this water that is heavily laden with metals for snowmaking has not been scientifically studied. The FEIS in one area (p.4-142) states that these heavy metals will run off with the snowmelt into the river. On the same page, the FEIS makes the claim that these metals will be precipitated from the solution during the snowmaking process and accumulate in the soil. Zinc and copper soil toxicity can cause chlorosis, scorching, stunting, and root damage to plants and can be toxic to animals. Cadmium is known to be highly toxic to plants, animals and humans. The "EPA Cadmium Working Group determined that cadmium exceeded EPA risk criteria for mutagenicity, teratogenicity, and fetotoxicity. In addition, they cited a number of possible adverse effects to the lungs, kidneys, liver, carbohydrate metabolism mechanism, gonads, and cardiovascular, skeletal, hematopoietic, and central nervous systems." (William D. Rowe in Evaluation Methods for Environmental Standards, 1983)
5. The expansion of the proposed facilities will increase the number of cars in the parking lot by an estimated 317 vehicles per day (FEIS, p. 2-43), and will increase the likelihood of additional vehicles parking on the roadside along State Hwy. 210 during peak periods. These additional vehicles will then impact plants and animals along the highway.
6. The Utah Indoor Clean Air Act prohibits smoking in public buildings or within 25 feet of any public building doorway. Where will these visitors smoke? On the alpine tundra? What impact will nicotine and cigarette butts have on alpine plants and animals? The FEIS makes does not analyze this impact.
7. The construction of new facilities will have a direct adverse effect on plants and animals and habitat.

By 1997, the U.S. Forest Service had begun a revision of its sensitive species criteria. On July 20, 1999, Region IV of the Forest Service adopted criteria which include species rankings G1-G3, T1-T3 and S-1 or S-2 for its sensitive species list revision, and published a draft list of species which met these requirements. All of the above Natural Heritage sensitive species are listed on the new U.S. Forest Service Region IV draft list of sensitive species. In preparing the Environmental Impact Statement for the Snowbird Master Development Plant (MDP), only the following species were cited for survey and evaluation based on a U.S. Forest Service 1991 list of sensitive species (FEIS, p.3-66): Botrychium crenulatum, Cypripedium fasciculatum, Draba densifolia var. apiculata (Draba globosa), Jamesia americana var. macrocalyx, Lesquerella garrettii. Also listed as species of forest concern are: Ivesia utahensis and Lepidium montanum var. alpinum.

The following nine sensitive plants known from the area from the Natural Heritage Program sensitive species list (which was adopted in the U.S. Forest Service revision of sensitive species list) were not included: Arabis lasiocarpa, Aster kingii var. kingii, Corydalis caseana ssp. brachycarpa, Dodecatheon dentatum var. utahense, Draba brachystylis, Erigeron arenarioides, Erigeron garrettii, Lesquerella utahensis and Penstemon platyphyllus.

The Biological Evaluation/Assessment for Snowbird Ski Resort dated 11-17-99 did not include any analysis of the species listed in the Environmental Impact Statement as "species of forest concern," i.e. Ivesia utahensis and Lepidium montanum var. alpinum.

The Biological Evaluation/Assessment has further inadequacies. Spiranthes diluvialis, the Ute ladies tresses, a federally threatened species, has been found in Diamond Fork and Provo River drainages and was recently located at the north end of Utah Lake and has potential habitat in American Fork Canyon. While it does not grow as high as the Snowbird project, it could still be adversely affected by water quality issues arising from the Snowbird project.

Draba densifolia var. apiculata (Draba globosa), the rockcress draba, occurs in alpine areas in rock, talus and meadows. The claim that this plant will not be disturbed is unfounded, as it will be negatively impacted by snow compaction, explosives used for avalanche control, and trampling caused by the greatly increased use of the area for hiking and biking. The Biological Evaluation/Assessment states "populations in meadows may be subject to more disturbances, although there has been no evidence of a problem." This statement clearly does not evaluate future impacts of the Snowbird proposals. Clearly, there will be no evidence of disturbance until the plan is implemented and there is actual increase of use in the area.

Lesquerella garrettii was named after Albert O. Garrett (1870-1948), East High School, Salt Lake City, biology teacher and author, and grows at 10,000-12,000 feet on talus or rock outcrops in Little Cottonwood Canyon and on Mt. Timpanogos and the mountains east of Provo. The FEIS states that "Surveys of the project area did not locate any individuals of this species, although suitable habitat occurs throughout the project area." (FEIS 3-66) Many collections have been made in the past of Lesquerella garrettii, in Mineral Flat, Mineral Basin, Sugarloaf and Twin Peak areas by such renowned botanists as J. S. Tuhy, W. P. Cottam, F. C. Rowland, D. Atwood and others. It is clear that further survey of this area for this species is warranted.

The Biological Evaluation/Assessment states, in reference to Lesquerella garrettii, "Potential impacts to this species are from recreation use (primarily hiking), ski area development, and mountain goat trailing. Garrett bladderpod occurs in open areas in Mineral Basin and at upper elevations in the Snowbird Ski Area." This directly contradicts the conclusion that "Because of the location and habitat for Garrett bladderpod, no projects are likely to impact the species." This species will be negatively impacted by snow compaction, avalanche control and trampling by hikers and bikers, as well as possible construction side effects. It must be remembered that these alpine plant populations are not easily re-established, as stated in the FEIS p. 3-62, "Alpine vegetation that is disturbed can take decades or even centuries to recover naturally (Willard 1996)."

One species that is discussed in the FEIS as a species of "Forest Concern" is Ivesia utahensis (Potentilla utahensis). This plant grows along the ridgeline between Sugarloaf Mountain and Twin Peaks. It is also known from two locations in the western end of the Uinta Mountain range. Ivesia utahensis only grows in alpine tundra and krummholz communities, often in talus, at 10,500-11,800 feet. The FEIS (3-66) cites this plant from the talus slopes below East Twin Peak in Mineral Basin and on Mt. Baldy. However, the habitat of Ivesia utahensis runs along the ridgeline in between. In fact, Lois Arnow, former curator of the Garrett Herbarium at the University of Utah, collected this plant on August 22, 1982, "along the divide about halfway between Mt. Baldy and Twin Peaks, at an elevation of 10,970 feet on an east-facing slope," (Arnow, 6037). One location on Sugarloaf Mountain, between towers 18 and 19, " is being trampled by hikers and mitigation is needed a.s.a.p." (Utah Natural Heritage Program "Element Occurrence Record," 1996) This sensitive endemic plant will be greatly impacted by snow compaction, increased summer recreation, increased avalanche control and construction.

Dodecatheon dentatum var. utahense was recently described by N. Holmgren in 1994. It is known from Big Cottonwood Canyon at the Mossy Ledges picnic area and from the area above Lake Blanche. According to Larry England of the US Fish and Wildlife service there may be fewer than 1000 of these plants and survey work is just beginning. Snowbird contains potential habitat for this plant. The FEIS makes reference to this species in Chapter 1" Purpose and Need" and states on page 1-25 that this species "may also occur in the area." Unfortunately, no further reference is made as to the existence or impact upon this species in the FEIS or the Biological Evaluation/Assessment. This rare and sensitive species could be greatly impacted by the implementation of the Snowbird Master Development Plan.

Jamesia americana var. macrocalyx, designated by the Forest Service as a sensitive plant, occurs in "Mineral Basin on private land in the cliff band encountered between Hidden Peak and the bottom of the basin."(FEIS, p. 3-66) According to the Biological Evaluation/Assessment, "A portion of one population on Snowbird's private land in Mineral Basin will be removed to improve ski conditions." While this species occurs on Snowbird private land, the Forest Service, in allowing Snowbird access, maintenance functions, mountain operations, restaurant facilities and rest rooms at Hidden Peak in support of skiing on this private property, becomes an accessory in the destruction of a rare species. Forest Service Manual 2670.32 clearly indicates "the decision must not result in loss of species viability or create significant trends toward Federal listing." Penstemon platyphyllus grows along the shoulder of State Hwy. 210. This sensitive endemic plant could be affected by an increased number of vehicles parking along and off the side of the road on peak ski days in the spring.

Lesquerella utahensisis is another rare, endemic plant that is listed on both the Natural Heritage and the Forest Service draft list as sensitive. It has been located at Snowbird in short forb communities (FEIS page 3-61). No analysis has been made of the impact of the Snowbird impovements on this plant.

Aster kingii var. kingii is a "rare species of concern for the Forest" (FEIS vol. 2 page 120). It is on the Natural Heritage list of sensitive plants and is also on the new Forest Service draft list of sensitive plants. The author of the response comments suggests that it may not be distinct from Aster kingii var. barnebyana (page 120, FEIS vol. 2) meaning that aster kingii var. kingii and A. barnebyana are one and the same plant. If this is true, it should have definitely been surveyed for and analyised because barnebyana is even on the old list of sensitive plants. Although Aster kingii var.kingii is known from Snowbird and is rare, it was not surveyed for or the negative impacts analyzed as were other plants of forest concern on page 3-66 of the FEIS and it was not even mentioned in the Environmental Evaluation/Assessment.

Erigeron garrettii, another species named for A.O. Garrett, grows at 8,950-12,400 feet on moist cliff faces and crevices, mainly limestone. It is known only from Little Cottonwood Canyon, Mt. Timpanogos, and the mountains east of Provo. This narrow endemic species has not even been considered in the Snowbird FEIS, even though its habitat would be greatly affected by development. The FEIS vol 2 on page 120 states that the reason that it was not considered for surveying was that it "grows on moist limestone cliffs". But the Geologic Map for Snowbird (FEIS 4-19 to 4-20) shows that there are many, many acres of Deseret, Gardison and Maxfield limestone. This species also grows in crevices on limestone and undoubtedly there are some which are moist in the Snowbird project. This sensitive species has been left out of any analysis in the FEIS and the Biological Evaluation/ Assessment, but will surely be impacted.

Another plant, Hymenoxis grandiflora, a Rocky Mountain endemic, also grows along on the ridgeline from Hidden Peak to Mt. Baldy. While it is quite common elsewhere in the Rockies above 10,000 feet, it can only be seen in the Wasatch Range on this ridge and on Mt. Timpanogos. It is described by Welsh ( Utah Flora 1993, p. 233) as a "strikingly beautiful yellow sunflower of alpine tundra." Janet Wingate, in Rocky Mountain Alpines (p. 108), says it is "perhaps the most striking plant that can be seen on the tundra." This plant, affectionately known as "Old Man of the Mountain" or "Graylocks" grew not more than 100 feet south of the Snowbird tram facility and it has already been impacted by Snowbird's reshaping of the ground around the tram center in the summer of 1999. The FEIS vol .2 page 120 states that "Old Man of the Mountain was not encountered in our survey". This only goes to point out the questionable quality of the survey, as it grows along this ridge and is one of the dominant blooming flowers near Mt. Baldy.

The presence of the Boreal Toad (Bufo boreas boreas), according to the FEIS p. 3-80, has been confirmed on three occasions at Snowbird. This toad is currently listed in Colorado, Wyoming and New Mexico as a candidate species for the Endangered Species Act. It is listed on the Division of Wildlife Resources Utah Sensitive Species List as a species of special concern with declining population and is also on the new Forest Service draft Sensitive Species List (1999). This toad would most likely be adversely impacted by poor water quality, heavy metals and by increased summer recreational use. Although this species is known at Snowbird, has declining populations, is listed on many sensitive species lists, the Biological Evaluation/Assessment fails to make any assessment or evaluation of the impact of improvements at Snowbird on the Boreal Toad.

The pika (Ochotona princeps) is listed by the Division of Wildlife Resources, on its sensitive species list, as a species of special concern due to limited distribution. The Wasatch pika, Ochotona princeps var. uinta is endemic to the Wasatch and Uinta Mountains in Utah and is known from Snowbird (FEIS 3-77). This species plays an important part in seed dispersal of alpine plants during its haying activities. The Biological Evaluation/Assessment makes no reference to this species, even though this species, which does not hibernate, will be negatively affected by increased recreation both winter and summer, avalanche control and construction.

The Biological Evaluation and Assessment for the Snowbird Master Development Plan is listed in FEIS references (page 7-4), as Forest Service 1998c and 1998d, both listed as "under press". In reality they were combined into one fifteen page document which was not signed and released until November 17, 1999. This information, which is so critical for the FEIS, was finished after the draft EIS and the FEIS. This information was not available for public comment and scrutiny during the comment period for the draft EIS. There are significant differences between the information presented in the FEIS and the Biological Evaluation/ Assessment in regards to sensitive species. For example, one is left with the impression on pages 3-66 and 3-67 of the FEIS that Ivesia utahensis and Lepidium montanum var.alpinum, two species of Forest Service Concern, were included in the Biological Evaluation /Assessment, in fact they were not even mentioned. Federal Regulation, 40CFR1502.25, requires that the Environmental Impact Statement be prepared concurrently with and integrated with all other environmental impact analyses and related surveys and studies. The Snowbird Master Plan FEIS did not do this. Both the FEIS and the Biological Evaluation/ Assessment failed to gather and evaluate population data for each sensitive species within the Snowbird project. The Eleventh Circuit Court in Sierra Club v. Martin in 1999 found that this is required under 36 CFR 219.19(a)(1) and (a)(6) and 219.26. Forest Service policy as delineated in Forest Service Manual, Sec. 2672.4 requires a review of all Forest Service planned, funded, executed or permitted programs and activities for possible effects on endangered, threatened, proposed or sensitive species. The biological evaluation is the means of conducting the review. The number one objective of a biological evaluation or assessment as delineated in FSM 2672.41 is "to ensure that Forest Service actions do not contribute to the loss of viability of any native or desired non-native plant or animal species or contribute to trends toward Federal Listing of any species." The Snowbird Final Environmental Impact Statement and the Forest Service Biological Evaluation/Assessment failed to analyze the impact of the project on many rare and endemic species known to occur or having potential habitat within the project area and has not carried out the mandate of FSM 2672.41.

The "Log of Vegetation and Wildlife Surveys Included in Analysis of Snowbird's MDP" (January 6, 2000) shows that a maximum of twelve days were spent in the field surveying wetlands and sensitive plants by Forest Service and contract companies from 1995 to 1998. Half of the days listed were for impact statements for previous smaller Snowbird projects, such as "Ten Turns. " Because the current FEIS is for the Snowbird Master Plan, all areas within the project should have been comprehensively surveyed. Such areas as Mt. Baldy were neglected, even though they will be greatly impacted by improvements in the Master Plan. Not enough time and effort has been expended to ensure that all sensitive species have been located. Federal Regulation 40CFR1502.24 requires scientific accuracy: "Agencies shall insure the professional integrity, including scientific integrity, of the discussions and analyses in environmental impact statements."

The FEIS talks about alpine areas as "rock/scree" habitat, to imply that very little grows in this area. Nothing could be further from the truth. This is a vibrant, beautiful alpine community containing many more plant species that those briefly mentioned in the document. The FEIS is woefully inadequate in this area and understates the importance of the alpine community. Furthermore, the report shows a poor understanding of alpine communities by the statement that "distribution of classic alpine community is limited in the project area. Much of the area that is high enough to support alpine communities is composed of sparsely vegetated rock cliffs and peaks and have been mapped as rock/scree for this analysis." (p. 3-62 ) Alpine communities, by their very nature, are sparsely populated and thrive in rock/scree conditions. The FEIS states that one of the reasons it is called a "rock/scree" community is because of "disturbance that has occurred on the peak and ridgelines." (p. 3-62) Just because this habitat has already been impacted certainly does not justify further development and disturbance in this area. Another reason given for calling it "rock/scree" is that it is steep topography, but many alpine plant species thrive hanging on to cliffs. These alpine communities contain many sensitive plant species and need to be more carefully surveyed and mapped at a finer resolution before any construction takes place. The Wasatch Mountain range has precious little alpine area above the treeline, a rare resource and habitat that should be conserved.

Many of the mitigation measures in the final decision were not discussed in the preliminary EIS and have not been subjected to public comment, the following mitigation measures need to be amended:

VEG 4. This mitigation measure calls for the vegetation management plan to be supplemented to include management of non-forest vegetation, including grass, forb, and shrub communities. This supplement to the vegetation plan should be headed up by a Ph.D. field botanist with a specialty in alpine plants. This plan should cover all areas of Snowbird and should be accomplished before any element of the Snowbird Master Development Plan is implemented, otherwise unidentified sensitive species may be adversely impacted. The last sentence in VEG4 should be changed to read: "All proposed treatments will be reviewed by a silviculturist and a botanist before approval." The word "treatments" is ambiguous and should be defined further. If this includes chemicals or herbicides the impact upon the environment needs to be discussed in the FEIS.

VEG 6. This measure calls for the aggressive treatment of the occurrence of noxious or invasive weeds, but should be restricted to areas where sensitive plants are not present, as such treatment would annihilate innocent surrounding plant material.

VEG 7. The requirement for the use of 90% native seed should be increased 100% and native should be defined as Northern Utah native seed. Hymenoxis grandiflora should be included in the short forb mix.

VEG 10. The mere requirement of distributing interpretive pamphlets will not suffice to protect plant material in sensitive areas. Areas containing sensitive species should be seriously restricted or fenced off. A naturalist patrol, similar to the current ski patrol or the bike patrol called for in the MDP, should be implemented during the non-ski season. The purpose of this naturalist patrol would be to educate the public about sensitive plants and animals and to prohibit recreation in sensitive areas.

VEG 11. Should be changed to read "Qualified Ph.D. level botanist will survey new alignments and facility footprints prior to construction. If any sensitive or protected species are found, coordinate appropriate action with the Forest Service prior to construction."

VEG 12. This should call for multiple representative soil and wetland samples, not a single sample from each. Samples from indicator plants should also be taken and checked for heavy metals.

VEG13, proposed. A conservation agreement needs to be signed between the Forest Service and Snowbird, as the steward of the land, to develop and implement management practices to ensure that sensitive species at Snowbird do not become threatened or endangered because of Snowbird's actions.

Wil 11. This mitigation should be removed or restated. Locating hiking trails only in ecotones would seriously impact alpine and subalpine plant communities. Restate as: "hiking trails should be located to minimize impact on plants, trees and animals, especially sensitive species."

HEA2, proposed . Because little is known about what happens to heavy metals in the snowmaking process, the following safety precautions should be implemented:

1. snowmaking should be restricted to hours when the public is not on the ski hill,
2. employees involved in snowmaking should be required to wear approved air respirators while blowing snow and have their health monitored with blood and urine tested yearly to check for elevated heavy metal toxicity levels,
3. signs should be posted in the snowmaking areas warning visitors not to eat the snow,
4. any Wasatch Drain Tunnel water stored in the Hellgate Mine Tunnel and used for snowmaking purposes should be tested for heavy mineral toxicity,
5. snowmaking will not be allowed if the pressure at the Wasatch Drain Tunnel falls below 200 feet of head, as the water quality tends to degrade abruptly when it goes below this level.

REC 2. Add another sentence to the end, stating "Close any of the current three miles of hiking trails that do not meet Forest Service standards and cannot be brought up to Forest Service standards without destroying sensitive plants or their habitat in the process."

Conclusion: There will be many negative impacts to sensitive plant and animal species and their habitat as a result of implementation of the Snowbird Master Plan. These impacts need to be comprehensively studied, analyzed and prevented in order to ensure that sensitive species do not become threatened or endangered. There are many inadequacies in the Snowbird Master Plan FEIS, the Biological Evaluation/ Assessment and mitigation measures. The principles of ecosystem management require that these inadequacies be corrected before the Master Plan is implemented, otherwise sensitive species will be greatly impaired and the quality of life diminished. Attachments: PA Attachment A., Log of Vegetation and Wildlife Surveys Included in Analysis of Snowbird's MDP.

PA Attachment B., Snowbird Biological Evaluation/Assessment

Attachment 9 Utah Skier Visit Analysis Critique

The FEIS, page 3-34 to 3-36, uses data from "Utah Skier Visit Analysis", May 1998 and "Utah Ski Database" January 1998, both from the Governor's Office of Planning and Budget, State of Utah, to justify the expansion of Snowbird. However, there are serious problems with the analysis in these reports in regard to the predicted growth rate for Snowbird for both destination and resident skiers.

Last ski year, 1998-1999, the total number of skier days in the US, according to the National Ski Area Association, was 52 million days, representing a drop from the previous two years and was even smaller than the 53.9 skier days reported ten years previous in The Utah Ski Data Base. In 1990, there were 11.3 million alpine skiers (Salt Lake Tribune, 11/23/97) this amount has declined rapidly to 7.7 million in 1998-1999 (National Ski Areas Association). Skiing has clearly lost its popularity. Snowboarders are counted in the number of skier days, if you take them out you would find that the number of skier days would be in sharp decline in the US. Snowboarders now make up 23.2% of the skier days (National Ski Areas Association). While snowboarders have helped to keep the number of skier days from falling, these "sportsters" clearly have different taste and preferences. The Utah Skier Visit analysis does not discuss or build snowboarders into their models but assumes they are the same as skiers.

The Utah Skier Visit Analysis, in trying to predict destination skier days, ran many multiple regressions using numerous independent variables. The only two variables that they found, that were significant, were the amount of snow and US Skier age population. However, the Utah Ski Data Base, page 9, shows that the US population, age 15 to 54, would only grow at a rate of .61% per year for the next 11 years to 2007 compared to a rate of growth of .97% for the previous 11 years. This significant variable was "felt" to have too low a growth rate (Utah Skier Visit Analysis page 9). The Utah Skier Visit Analysis fails to give the scientific assumptions for their feelings. Instead they decided to use the long term growth of destination skier days in Utah of 52,981 per year, or a growth rate of 2.9% per year for 1997. This is 4.75 times as fast as the predicted rate of growth for skier age population in the US. Given the fact that the number of skiers is declining, this means that Utah resorts will have to get an increasing share of a shrinking market. No analysis is given to substantiate Utah's ability to do this, other than historical data. It seems likely that Utah Ski Industry will encounter increasingly stiff competition, especially from Colorado resorts. The Utah Skier Visit Analysis states in their conclusion on page 17 that "The major reason skier visit growth to 2007 is expected to grow more rapidly than since 1985 is that Utah's skiing age population will grow much more rapidly to 2007." The FEIS, in volume two, page 95 and 96, uses this line of reasoning to justify the Snowbird project. However, the data presented in the Utah Ski Data Base, page 8, does not bear this out. The average growth rate for skiers ages 15-44, the age grouping they use in their modeling, will actually decline from 2.14% per year for the period from 1986 to 1996 to 1.60% per year for 1997 to 2007. Furthermore, Snowbird's prime local market in Salt Lake County, which accounts for 60% of Snowbird's resident skier days (Utah Skier Visit Analysis, table 3) for the same age group is projected to only grow at a rate of .43% for the period of 1997 to 2007 (State of Utah Long Term Economic and Demographic Projections). In addition, Salt Lake County could feel the biggest brunt from the layoff of some 50,000 jobs after the Olympics. (Salt Lake Tribune 9/22/99).

The popularity of skiing in Utah, climbed from .5 visits per skiing age person in 1960 to 1.8 visits per skiing age person in 1980 (Utah Skier Visit Analysis, page 4) but has declined to 1.4 since. This shows that the popularity of skiing among Utahns is declining. Skiing is losing its attractiveness among the local population to other activities which are growing rapidly such as snowshoeing, crosscountry skiing, snowmobiling, backpacking, mountain climbing, rollerblading, four wheeling, boating and even computers. The Utah Skier Visit Analysis projects local ski visits to increase based on past history but fails to take into account Utah's decreasing preference for skiing and its increased demand for other for other activities.

The Utah Skier Visit Analysis attempts to predict the effect that expansion at Snowbird, Solitude and Snowbasin would have on the distribution of local skiers. It assumes that other resorts will not expand or make improvements. This simply is not so, particularly among the Park City resorts. The possibility of a new resort between Park City and Deer Valley has not been analyzed.

Because the rate of growth in skier age population in the US, Utah and Salt Lake County is declining, as well as the declining popularity of skiing, and increased competition from other resorts, Snowbird will be lucky to have a growth rate of 1% in both destination and local skier days from now until 2007. Given a growth rate of 1%, the Snowbird's 1998-99 skier day total of 383,000 will rise to 427,300 in 2007 and not the projected 501,200 in the FEIS on page 3-36. This does not justify the size of the expansion called for under the preferred alternative in the FEIS.

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