Save Our Canyons: Comments on Snowbird MDP DEIS

   

PURPOSE AND NEED

For concession uses involving privately developed facilities, Forest Service policy mandates that the agency shall
"authorize concession developments only where there is a demonstrated public need. Do not permit concession development either solely for the purpose of establishing a profit-making commercial enterprise or where satisfactory public service is or could be provided on nearby private or other public lands" (Forest Service Manual, section 2343.03).
Furthermore, the Forest Service shall
"encourage summertime use of ski area facilities where that use is compatible with or enhances natural resource-based recreation opportunities and does not require additional specialized facilities. Ensure that holders provide for development of facilities and protection of environmental values as an integral part of the development plan for the area" (Forest Service Manual, section 2343.11). [Emphasis added].
    First in the scoping notice and now in the DEIS, the Forest Service has adopted Snowbird's representation of the value of the project without critical evaluation or independent analysis. The purposes and needs, as stated in the DEIS, are cursory, incomplete, unsubstantiated, and mostly anecdotal.
    The DEIS alleges that the proposed project is justified on four major grounds (1-13):
  1. Improved skier circulation
  2. Improved skier services
  3. Quality of four-seasons recreational experience
  4. Need for additional conference facilities
    The DEIS specifically states that an increase in skier capacity is not part of the rationale for either the proposed action or the alternatives (2-16). This statement not withstanding, the DEIS quotes the Utah Governor's Office of Planning and Budget projections for increased skier visitation at Snowbird exceeding 40% over the next ten years (3-27). These projections must be viewed as highly suspect, given the significantly slower growth in the preceding ten years, the flat projections for skiing nationally, and the increase in competition for local and destination skiers due to expansion at Deer Valley, Park City, The Canyons, and Snowbasin. If the projections are in fact incorrect, then much of the rationale for the proposed action and alternatives vanishes.
    The DEIS makes repeated reference to the low skier densities at Snowbird. Mention of current difficulties with skier circulation are limited to five specific areas (3-20):
  1. Exiting from the top of Hidden Peak
  2. The off loading area at the top of the Little Cloud lift
  3. Sections of the Bassackwards trail
  4. The lower portion of the Big Emma trail
  5. The intersection of the Madam Annie's and West 2nd South trails
    Of the proposed projects and alternatives, Hidden A, Alternative A, Gad M, Gad N, Gad P, Gad Q, Mineral D, and Mineral G are all justified directly or indirectly as improving skier circulation, yet none have any effect on the five specific problem areas enumerated in the DEIS.
    It defies logic to use skier circulation arguments to rationalize a large structure on Hidden Peak, construction of the Gad 3 lift, and expansion of the SUP to include Scottie's Bowl.
    The only effect of the proposed Hidden Peak structure on skier circulation that is actually described in the DEIS concerns the need for skiers to travel to Snowbird Center or Mid Gad for skier services (4-45). No evidence is given that meal service at the top of Hidden Peak would, in fact, improve skier circulation for those skiing in the existing permit area, assuming that adequate capacity was available lower on the mountain. To the contrary, few other ski areas have found the need to provide meal services at the top of their lift system.
    The effect of the proposed Hidden Peak structure on skier circulation for those skiing in the proposed Mineral Basin expansion requires an analysis far beyond that provided in the DEIS. The need for meal service is predicated on there being 1,317 skiers in the basin who would use the proposed eating facilities on Hidden Peak rather than traveling down the north side to facilities lower on the mountain. No evidence is given for this usage figure, which represents almost a third of the current 95th percentile utilization. The number is particularly suspect given the south facing aspect of Mineral Basin and the consequent lack of quality snow conditions over much of the season (4-43). The DEIS contradicts the presumption that services for all users of Mineral Basin would need to be accommodated on Hidden Peak by stating that usage of Mineral Basin would be concentrated in the morning only (4-43). The claimed need for a nearly 600 seat restaurant on Hidden Peak is highly questionable.
    The sole justification alleged in the DEIS for the proposed Gad 3 lift (Gad M) and associated trail development (Gad P) is the following statement:
"Some ski terrain within Snowbird's SUP is currently under-utilized due to the difficulty in accessing it. This under-utilization causes crowding in the more easily accessed parts of the resort, creating safety and circulation problems. The elements of the Proposed Action that would substantially relieve access-related safety problems include the Gad 3 Lift construction ... [and] the Little Cloud Lift upgrade."
Given the low skier densities at all but a few isolated locations within the Snowbird permit area, it is hard to understand how increasing accessible terrain satisfies any public purpose. Indeed, referring to the Gad 3 lift the DEIS states:
"while there is little doubt that lift service to new expert terrain would be utilized ... there is limited evidence that this type of terrain would alter current utilization at the resort."
    The experience following construction of the Baby Thunder Lift throws more doubt on the purposes and needs of the Gad 3 Lift. Baby Thunder services some of the least used terrain at Snowbird. This might be due to the fact that it is the shortest lift with the smallest vertical drop (630 ft) at Snowbird (excluding Chickadee). Gad 3 has the same vertical drop and is even shorter than Baby Thunder.
    The DEIS justification for adding Scottie's Bowl to the Snowbird SUP is even more insupportable. While the DEIS makes repeated reference to a mention in the 1985 Forest Plan of adding Scottie's Bowl to the SUP, this is hardly a documentation of either purpose or need as called for under NEPA. The only other references to the purpose and need of the expansion into Scottie's Bowl are claims that this will provide additional powder and tree skiing accessible from the Gad 3 lift. With or without the addition of Scottie's Bowl, the DEIS makes clear that Gad 3 serves no skier circulation need. The claimed increase in powder skiing makes little sense, because as soon as a lift goes in, the powder will be gone. The reason there is powder skiing there now (for people skiing out of bounds) is because this area is currently difficult to access. In this regard, and also in connection with the Gad 3 lift proposal, the DEIS puts forth inconsistent data. On p. 3-25, Table 3-8, the DEIS states that the CCC of Snowbird is 5,161 persons while the terrain has a capacity of 9529 persons. There is thus no justification for acquisition of additional terrain at Snowbird with the current capacity is under-utilized.
    Since the opening of the Snowbird resort in 1971, one of the most enduring public concerns has been a well founded fear that Snowbird has designs on expansion into White Pine Canyon. The DEIS (1-20) first states that this fear is groundless, since
"this proposal does not include SUP expansion into White Pine Canyon"
and then adds some rather chilling language about possible future plans. Given the paucity of other justifications for the Gad 3 Lift and Scottie's Bowl expansion, it is easy to conclude that their primary purpose is profit for Snowbird.
    The only portions of the DEIS aimed at addressing improved skier services are Hidden A, Alternative A, and Base C. SOC does not dispute the purpose or need for Base C. Hidden A is further justified based on a claimed need to improve the quality of the four-seasons recreational experience and the need for additional conference facilities. Alternative A is claimed to satisfy aspects of the four-seasons recreational need, but not the conference facilities.
    Skier services to be provided in the proposed Hidden A structure include a restaurant, a bar (referred to as a "lounge" in the DEIS), a 7,408 square foot food preparation area, 2,640 square feet of retail space, 4,800 square feet for the ski patrol, restrooms of indeterminate size, and over 4,000 square feet of snowcat garages.
    If the argument that a restaurant on Hidden Peak is necessary to improve skier circulation is, as SOC has argued, fallacious, then what public need is served by a restaurant with a capacity of 600 on Hidden Peak that cannot be accomplished by providing meal services elsewhere within the ski area?
    The DEIS fails to give a rationale for the need for a bar on Hidden Peak with a capacity approaching 300 people. Coupled with the restaurant, this would provide simultaneous seating for approximately 900 people, a capacity far exceeding any reasonable estimate of need.
    A 900 seat restaurant and bar on Hidden Peak is neither compatible with nor an enhancement to "natural resource-based recreation." It is thus in direct violation of the Forest Service Manual. Such a restaurant would directly compete with private facilities in Little and Big Cottonwood Canyons and in Millcreek Canyon, another violation of the Forest Service Manual. The fact that the Alta Lodge recently discontinued summer dining suggests that the market for such services is limited and that the large capacity proposed for Hidden Peak might well have significant negative impacts on existing private sector operations.
    Alternative A reduces proposed restaurant seating capacity to 367. As with the larger restaurant that is part of the Proposed Action, the need for this capacity at this location is not supported by any reasonable or independent analysis. As with the Proposed Action, meal services for skiers traveling to the top of Hidden Peak can be provided elsewhere with significantly less environmental impact and minimal or no inconvenience to users or disruption of skier circulation patterns. As with the Proposed Action, the DEIS fails to include evidence that the facility would be used by all those skiing in Mineral Basin.
    The DEIS gives no justification for the size of the proposed retail space in Hidden A and the DEIS provides no argument as to why the retail space, if truly needed, should not be located elsewhere within the permit area.
    The proposes space for ski patrol operations with no justification other than an unsupported claim that "doubling the existing space for these functions would provide the minimum space necessary for these functions." The Hidden A provides 4,800 square feet for ski patrol and mountain operations. This is reduced to 3,400 square feet in Alternative A. What is the real need? In any event, both numbers are puzzling given the "doubling the existing space" argument, since the total size of the existing structure is only 1,681 square feet and little of that is used for ski patrol functions.
    The DEIS fails to justify either the need for a snowcat garage on Hidden Peak or the size of the proposed garage area.
    The DEIS gives almost no justification for the need for an "interpretive center" on Hidden Peak, other than vague references to improving the quality of four-seasons recreational experiences. No justification of any sort is given for the enormous proposed size of this facility. It would take a truly dramatic change in summer use patterns before facilities even a fraction this size could be fully utilized.
    The restaurant, bar, and interpretive center, taken together, would provide indoor accommodation for well over 1,000 people at a time. In summer, the tram provides the only visitor access other than a long hike to and from Hidden Peak. While the DEIS quotes the capacity of the tram as approximately 1,000 people per hour, this presupposes 125 people per cabin load. While skiers anxious to get to the top as quickly as possible tolerate such crowding, summer visitors will not. Thus, the effective summer capacity of the tram is more like 500 people per hour. Why are the facilities proposed for Hidden Peak far larger than the capacity to transport users to and from the mountain in a timely manner?
    The most complete rationale given for the Hidden A proposal is the need for additional conference facilities. This is based in large part on the statement that approximately 20% of groups interested in booking conference space were unable to do so in 1997 (1-13). The DEIS provides no data to support such conclusions. For an adequate DEIS it would be necessary to conduct an audit of Snowbird's financial records and booking procedures and records. Those records must be made available for public analysis. Do these booking inquiries include all inquiries, or only those groups who clearly would have held meetings at Snowbird were space available? Were groups turned away because of a lack of meeting rooms or because of a lack of lodging?
    The DEIS explicitly states that
"meeting/conference space could probably be developed elsewhere at the resort, but would not capitalize on the peak's scenic location" (2-21).
If the facilities are reasonably available elsewhere, then to place them on Hidden Peak would be a direct and unambiguous violation of Forest Service policy. How can a meeting room possibly "capitalize on the peak's scenic location," given the fact that almost all meetings likely to be held there would involve A/V presentations requiring that the windows be shaded?
    The meeting/conference space being proposed by the DEIS represents a 40% increase over current capacity. Even if all of the 20% of groups allegedly turned away were to have actually utilized Snowbird's facilities had they been available, and even if in all cases the groups were turned away due to a lack of meeting/conference space, a 40% increase in capacity seems excessive. To put this increase in capacity at the top of Hidden Peak is without rational justification, given the environmental and scenic damage that would ensue and the many other locations available for such expansion, both within the permit area and at alternate locations in and around Salt Lake City.
    There is a brief discussion of how sewage will be removed from a proposed building on Hidden Peak, but the DEIS failed to address the issue of water service to Hidden Peak. What is the status of Salt Lake City's concurrence or non-concurrence that they will provide water service beyond their current service area boundary? It is our understanding that the FS policy is to get the written concurrence of the local municipality on all special -use decisions in municipal watersheds. This is an important consideration that the DEIS failed to discuss. What if SLC exercises its veto power in the special-use decision?
    Much has been said by proponents that the Hidden Peak buildings had been "grandfathered" in some manner by the Salt Lake County authorities. While we believe this supposed prior approval to be non-existent, there was nothing in the DEIS that would substantiate the claim that Snowbird has the authorization to construct whatever it wishes.
    In sum, the DEIS has failed to justify that Purpose and Need for the proposed project serves the public good. In its discussion of the Purpose and Need for the proposed project, the Forest Service impermissably relies on the applicant's statement of the Purpose and Need for the project. The Forest Service failed to supply independent justification for the project and an independent determination of the public good. This violates NEPA.
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 Revised July 23, 2004