Save Our Canyons: Comments on Snowbird MDP DEIS

SUMMARY COMMENTS ON DEIS

Much of what is proposed in Snowbird's Master Development Plan, if approved, would represent a qualitative change in the recreational experience available to users of the Wasatch-Cache National Forest. The burden is on the Forest Service to insure that the environmental consequences of this proposal are completely, accurately, and fairly evaluated in an Environmental Impact Statement. We believe that the DEIS is seriously deficient in these regards:
    The analysis of the proposed Hidden Peak structures fails to consider reasonable alternatives and inadequately evaluates the alternatives that are presented.
    The Purposes and Needs used to justify the project are questionable.
    Placing a conference facility and restaurant on top of an 11,000' mountain in the Wasatch makes little practical sense.
    The analysis of visual impacts is technically flawed.
    A thorough review of health and safety concerns is absent.
    The DEIS fails to adequately address the recreational and health and safety impacts on White Pine Canyon of the Gad 3 lift and Scottie's Bowl annexation. Snowbird has long coveted White Pine Canyon for expansion of lift-supported skiing. First the Baby Thunder lift, and now the proposed Gad 3 lift and Scottie's Bowl SUP expansion, are projects viewed by many as aimed directly, if incrementally, at achieving this goal. The Forest Service has an obligation to protect the greater public good by insuring that the last remaining easily accessible area in Little Cottonwood Canyon remains a viable area for dispersed, non-commercial recreation.
    Snowbird's expansion into Mineral Basin would bring intensive development to yet another watershed in the Wasatch. The Forest Service cannot avoid considerations of the environmental impacts of this SUP expansion based on the claim that they would occur on private land, since the support facilities claimed to be necessary to operate in Mineral Basin would be built on public land.
    The snowmaking activities described in the proposed MDP have the potential to seriously degrade an important watershed providing culinary water to the Wasatch Front and to aquatic habitat.
    Some of these deficiencies can be removed in the final EIS without major effort or controversy. Some, however, are fundamental to the decision-making process. Meaningful public participation will be possible only if public comment is solicited on these items before to the Forest Service continues in its determination of how to respond to Snowbird's requests. This can occur only if a supplemental DEIS is published and made available for public review.
    Presuming that a final EIS is issued which appropriately presents the necessary information, the Forest Service then must face the further burden of issuing a Record of Decision that reflects the public interest. The emphasis here must be on the public interest. In particular, Snowbird's interests and the public interests are not one and the same. Snowbird's interest in the proposed projects are relevant to the ultimate decisions made by the Forest Service only insofar as they serve a clearly articulated public need.
    The DEIS attempts to justify the developments proposed in the Snowbird MDP in terms of competitive pressures and specifically points to competition from other Utah resorts. This violates the Forest Service's duty to refrain from committing public resources to aid concessionaires in competing with facilities provided on nearby private land. If the Forest Service violates its duty in this case, there is a reasonable expectation that similar development requests will be forthcoming from one of more of the other ski areas in Big and Little Cottonwood Canyons.
    As a result, we see no way that the Forest Service could grant many of the items requested by Snowbird absent an area-wide EIS.
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Revised July 23, 2004