Dan Jiron, District Ranger
Salt Lake Ranger District
United States Forest Service
6944 South 3000 East
Salt Lake City, Utah 84121

Re: Solitude Scoping Response

Dear Dan,

Following are Citizens' Committee to Save Our Canyons comments on the Solitude Scoping Notice. It is important to emphasize that Save Our Canyons does not oppose those projects that will provide adequate lift and base facilities for Solitude's ski and snowboard patrons, assuming these projects do not degrade the natural environment, stay within the existing SUP area and do not serve as a rationale for increasing the existing SAOT calculation. Save Our Canyons opposes those projects that will directly or indirectly degrade the Big Cottonwood Canyon environment and serve little or no legitimate purpose in providing skier and snowboard patron services. Save Our Canyon's guiding principle is that the Cottonwood Canyons need to be protected from relentless urbanization pressure, as is so clearly manifested by the Village at Solitude condominium and commercial development.

NEPA requires the Forest Service to examine the cumulative economic and environmental impacts of Solitude's proposed projects. However, rather than an individual EIS limited solely to the Solitude SUP area, a more appropriate analysis would be to conduct a programmatic EIS. A region-wide programmatic EIS will focus on the economic and environmental interconnectedness of ski area expansion. The Forest Service's failure to address the interconnectedness of regional and national skier markets and expansion proposals through a programmatic EIS leads to inappropriate approval of ski area projects and multiple authorizations of ski area expansions without an analysis of and appreciation for their cumulative environmental and economic impacts.

The preferred alternative in the DEIS should embrace the following guideline: The Forest Service does not approve of any new development or facility, or any modifications to an existing development or facility within the Solitude SUP, whose purpose is, or whose effect will be, to promote, enhance or otherwise make more attractive real estate developments on adjacent private land.

Given the small and already congested geographical area in which the Solitude SUP area exists and its proximity to a large growing urban population, SOC feels it to be critically important that the Forest Service make a determination, upon the completion of the NEPA process, as to whether or not the Solitude SUP is essentially "built out" and that the Forest Service will allow no additional facilities, nor any increase in size or capacity of any facilities in the future. If the Forest Service determines that the Solitude SUP area is not "built out" once this MDP process runs it course, then the Forest Service should state clearly the criteria it will use to govern future expansion. This topic (is the Solitude SUP "built out"?) needs to be studied in the DEIS. NEPA provides the legal mandate and process for doing so.

It is important the DEIS analyze the relationship, nexus and cumulative effects and connected actions between Solitude's proposed projects and its real estate development. In what manner will a lighted nordic ski track, lighted ice skating rink, lighted alpine slide, expansion of the Last Chance Mining Camp building, pulse gondola, etc., all located substantially or entirely on Forest Service land, serve to promote, either directly or indirectly, Solitude's real estate development efforts (including the proposed Big Cottonwood Creekside Estates subdivision), which are all located on private land? This review should include a comprehensive analysis of Solitude's ski and snowboard operation finances and its real estate development finances and projections. In the absence of such an analysis, it will not be possible to fully understand and make an informed judgment as to the relationship between the proposed projects and Solitude's real estate development.

Increasing the number of lifts, converting existing lifts to high speed quads, cutting of new runs and grooming of other runs, and increasing base skier facilities will result in an increase in Solitude's capacity to accommodate more patrons. It is important the DEIS analyze SAOT and capacity issues that will arise from these proposed actions on a canyon-wide basis. The 1985 Forest Plan should be the guiding document for this study. The DEIS must not treat these capacity issues in isolation from the larger canyon environment, as any increase in Solitude patronage will create an environmental impact on an area much larger than the Solitude Special Use Permit area alone.

It is important that the DEIS describe and analyze any proposed land exchange proposals (all written and oral) between the Forest Service and Solitude, if any, that have taken place in the past five or six years.

The DEIS process and the Forest Plan revision process are taking place at the same time. The result is that there might not be a Forest Plan document in place to guide the Forest Service through the entire NEPA process for the Solitude MDP. It is important the DEIS address the potential for conflicts and uncertainties arising from both these processes occurring at the same time and how the Forest Service will deal with these uncertainties and potential conflicts. There is some concern that the Forest Plan revision process might in some subtle or unsubtle manner be driven by exigencies arising from the Solitude MDP / NEPA process. Will the Forest Plan revision process be driven by Solitude's desire for a greater SAOT authorization or will the Forest Plan revision process remain independent of these ski resort pressures?

It is important the DEIS analyze, on a canyon-wide basis, cumulative environmental impacts arising from the Solitude MDP.

It is important the DEIS analyze the proposed projects in the context and compliance with CEQ /NEPA regulations, one of which is that the EIS must identify all indirect effects that are known and make a good faith effort to explain the effects that are not known but are reasonably foreseeable.

The DEIS must include a disclosure statement from the EIS consulting firm so as to determine any financial or other interest it has in the outcome of the project, including a detailed statement as to the scope and extent of the firm's prior involvement with Solitude and its business partners, including all individuals and businesses who are, or have been, involved in Solitude's real estate development activities as either providers of services or as investors.

Below are comments specific to certain proposed projects:

Resort Operations Center

There are VQO issues given its proposed three-story height and current warehouse appearance. One or more alternatives to the proposed action should be studied in an effort to make this structure more visually acceptable.

Helicopter Emergency Landing Pad

Include and evaluate the following alternative in the DEIS: This landing pad will not be used for any recreational or commercial purposes.

Fire Station

Is Forest Service land an appropriate location for a County fire station? The DEIS needs to study the rationale and necessity for placing the fire station at this site. The DEIS also needs to study other acceptable fire station sites in the canyon.

Eagle Express Day Lodge

The DEIS needs to analyze the height, design and architectural scheme in the context of FCOZ and Forest Service VQOs.

Moonbeam Expansion

One connected action that needs to be analyzed is that the proposed reduced size of the expansion of this building will in turn cause an increased size of the Last Chance Mining Camp expansion. This connected action needs to be analyzed thoroughly.

Satellite & Communication Base Station

No purpose or need is stated. What is its size and obtrusiveness? Will it facilitate the operations and attractiveness of real estate development? What are the VQO issues? Does it serve skier and snowboard patron need?

Bus, High Occupancy and Other Vehicle Parking

SOC applauds the effort to facilitate efficient and environmentally sound transportation alternatives in the canyons. SOC does take issue with the proposed placement of the bus, high occupancy and other vehicle parking in the proposed area immediately south of and adjacent to Big Cottonwood Creek.

This proposed parking area is an inappropriate site choice. Placing a parking lot so close to the highway will create visual quality and possibly water quality issues. The proposed berm in and of itself will be visually obtrusive and will not successfully shield this parking area from most highway viewpoints. The DEIS needs to study not only the negative effects of the current proposed site, but also alternative locations that will be less visually obtrusive.

What constitutes a high occupancy vehicle at ski resort parking areas? The DEIS needs to study average occupancy rates for cars using the Solitude parking lot before one can come to a conclusion as to what constitutes a high occupancy vehicle and is, therefore, accorded some special parking status.

The scoping document states: "Nordic and backcountry skiers regularly park in Solitude's day skier lots and during peak periods, reducing available parking for day skiers and snowboarders". Anecdotal comments such as this are not reliable for decision-making purposes. The DEIS needs to study the impact, if any, of non-patron parking on Solitude parking lot capacity.

Moonbeam Parking Reconfiguration

The DEIS needs to study the net effect on parking capacity that arises from the loss of the upper (east) parking lot due to real estate construction, the availability of underground parking at the Village at Solitude and the loss of private passenger and bus parking that will result from construction of the proposed RV park.

Further, the DEIS needs to study what legal obligation, if any, the Forest Service has to provide replacement parking on public land where the need for such replacement parking arises from the voluntary action of the SUP holder to withdraw private land from ski and snowboard patron parking use due to private business reasons that are unrelated to operations allowed within the special use permit.

Highway Acceleration and Deceleration Lanes, Moonbeam Entrance Road

One of the traffic hazards that arises at the Solitude entrance is that high-speed vehicles often travel, both up and down canyon, commonly in excess of the posted speed limit. SOC supports the goal of providing a safe and smooth flow of merging traffic at the Solitude entrance, but does question the wisdom of any road construction that widens the road substantially and does nothing to slow vehicle speed.

Surely the Forest Service, UDOT and other interested parties can develop a means for providing a safe and smooth entry and exit from Solitude without the need for road construction design that might be appropriate for an urban setting but is totally inappropriate for a canyon setting.

The DEIS should study the feasibility of using a system that meters the Solitude exiting traffic and the down and uphill canyon traffic during the late afternoon "rush hour", including the rate of speed traveled by the canyon traffic, which creates the major risk for accidents.

The DEIS should study the cumulative traffic effects on an already crowded canyon that will arise from the many projects outlined in the scoping document.

Alpine Slide

SOC objects strenuously to a so-called alpine slide in Big Cottonwood Canyon. The Forest Service Interdisciplinary Team has already stated cogent reasons as to why it feels an alpine slide represents an inappropriate use of Forest Service land. These IDT reasons for rejecting the alpine slide should be re-stated and studied in the DEIS.

The existence of this amusement ride in Big Cottonwood Canyon will violate the intent and spirit of the Canyons Master Plan, FCOZ, Forest Plan and numerous Forest Service rules and guidelines.

Last Chance Mining Camp

The DEIS needs to study this proposed alternative: This building will be designed and sized in a manner that satisfies the needs of Solitude's ski and snowboard patrons. Any proposed use or design that facilitates or promotes the attractiveness of Solitude's real estate operations or Solitude's conference and convention business is prohibited as such uses represent an inappropriate use of Forest Service land.

The DEIS needs to describe and study fully the following scoping document language: "The upgraded Last Chance Mining Camp would be an all-season building and the center for winter evening and summer activities. In the summer, the facility would help manage recreation use, including restroom facilities". Why are "multi-purpose" rooms needed in a building used to support skier and snowboard services? There are no legitimate skier and snowboard patron support services that require a 25,000 square foot structure, especially for one located on Forest Service land and subject to the management prescriptions found in the Forest Plan and other forest management manuals.

The DEIS needs to analyze the business reasons Solitude used to choose this structure, located on public property, as a location for its conference and meeting business instead of constructing similar capacity meeting space at the Village at Solitude. The Solitude website, in its conference section, advertises that the Last Chance Mining Camp structure can accommodate up to 500 conference patrons.

Outdoor Skating Rink

An outdoor skating rink does not serve any purpose in satisfying the needs of Solitude's ski and snowboard patrons. It provides no food, beverage or restroom facilities. It provides no refuge in case of bad weather.

The following assertion needs to be studied in the DEIS: The outdoor ice skating rink is an inappropriate use of Forest Service land for the same reasons the Interdisciplinary Team urged rejection of the alpine slide amusement ride. In addition, such a facility supports and makes more attractive Solitude's real estate development activities, thereby representing connected actions and creating cumulative impacts that are unacceptable.

The DEIS also needs to study Solitude's motive for proposing the construction of a skating rink on public land, as opposed to placing it within Solitude's substantial real estate development perimeter. Why did the Village at Solitude architects purposely omit a skating rink from the Village area?

A lighted skating rink with music will be a major annoyance to nearby cabin owners. It represents a facility and activity that should be provided in a city environment. Like the proposed alpine slide, the ice skating rink is an inappropriate use of Forest Service land.

Nordic Trail Lighting

Low voltage, "state of the art" lighting creates substantial reflected artificial light, thereby creating an unacceptable level of light pollution. The affect of this proposed night lighting on nearby cabin owners and the canyon environment needs to be studied.

Solitude states that its nordic patrons are requesting night lighting. An anecdotal statement that there is a "demand for night lighting" is an insufficient reason for such a project. The DEIS needs to study this assertion to determine its legitimacy.

The DEIS needs to study whether or not night lighting makes economic sense in terms of creating an increase in nordic track revenue that will most likely exceed the cost and expense of installing, maintaining and using the lighting system.

The DEIS needs to analyze the availability and suitability of competing nordic track facilities that exist elsewhere along the Wasatch Front, including Millcreek Canyon, Mountain Dell Golf Course, White Pine Touring, Sundance and the future Soldier Hollow Legacy facility.

The DEIS needs to study the negative visual effects of lighting fixtures strung throughout a Forest Service campground.

Because of the proposed lighted nordic track's proximity to Solitude's real estate development, the DEIS needs to study what connected actions exist and the manner in which such a facility will make the real estate development more attractive to buyers and therefore more financially lucrative to Solitude and its partners. These possibly connected actions need to be studied in the context of the management policies enumerated in the 1985 Forest Plan and other appropriate Forest Service documents.

Pulse Gondola

SOC recognizes that Solitude's patrons who park in the west parking lot face a long walk or an inappropriate ski run in order to access other base areas. The pulse gondola concept might be warranted to satisfy patron circulation problems. The DEIS needs to study the pulse gondola proposal and other options thoroughly, especially the visual quality issues arising from the towers and terminals.

Solbright Lift

The assertion that: "The Solbright lift would provide a more efficient and reliable interconnect between Brighton and Solitude, serving to enhance the overall skiing experience and opportunities in Big Cottonwood Canyon" needs to be supported by verifiable information. Is there any demand for a Brighton / Solitude interconnect? In addition, even if there is patron demand for this lift, should the Forest Service promote such an interconnect scheme?

The Solbright lift project is unacceptable because it will set a precedent for other interconnect trams and lifts in the Wasatch, thereby causing unacceptable environmental damage. The DEIS needs to study the cumulative effects, connected actions and precedent setting nature of this and other interconnect schemes that are and have been proposed for the Wasatch Mountains.

Special attention needs to be paid to the possibility of any damage to the spectacular grove of limber pines near the top of the proposed Solbright lift.

Forest Stand Thinning West of Challenger

The DEIS needs to study whether or not this area is being thinned for the benefit of those skiers who want to ski through the trees or for forest health. Are any ski trails proposed for this forest area?

Surface Run-Off Drainage System and Detention Pond and Sewer Line

Water quality issues need to be thoroughly studied by the DEIS, due to the close proximity to Big Cottonwood Creek.

Point source pollution sources arising from the parking areas and mitigation measures need to be studied by the DEIS.

Redman Lift and Associated Trail

Alternative locations for such a beginner ski area need to be studied by the DEIS. Visual quality issues arise from the close proximity of this proposed lift to the highway and the fact that night lighting is proposed.

The SUP area will need to be expanded if the Forest Service allows the construction of this lift. The DEIS should study this issue in the context of the 1985 Forest Plan and other relevant Forest Service management documents.

The Forest Service does not have the duty to ensure that Solitude is able to meet the demand for every niche of the skier market. The DEIS needs to survey all the ski resorts situated in Salt Lake County and Summit County to determine whether or not the demand for a certain skier niche or terrain (in this case beginner skier terrain) is already being met. If beginning skier terrain needs are being met elsewhere, then the construction of the Redman lift should be denied.

The DEIS needs to study the cumulative effects, connected actions and to what extent the proposed Redman lift promotes or enhances Solitude's real estate development activities.

Honeycomb Return Lift

The Honeycomb Bowl is an expert ski area. Its appeal is its powder skiing. Once the area's powder has been tracked out, it is then regarded as a less desirable ski area and receives decreased use. The quality of the skiing experience in the Honeycomb area will be diminished substantially in the event this lift is constructed, as the lift will promote more use of the area and the opportunity for powder skiing will end more quickly.

Although this proposed lift would be located entirely on private land, certain necessary ski trails would be on Forest Service land. The DEIS should study the variety of impacts the construction of ski trails would create and their cumulative effects and connected actions.

RV Hookups

SOC feels that a recreational vehicle park in Big Cottonwood Canyon is totally inappropriate, even if located on private land. To the maximum extent possible, the Forest Service needs to use its considerable leverage to discourage this project. The DEIS needs to study the relevant Salt Lake County zoning and planning regulations that apply.

Although the RV park is proposed for private land, it is a connected action and cumulative impact, as Forest Service land is used for most of Solitude's parking needs. In the absence of adequate parking on public land, Solitude would be disinclined to use private land for a RV park.

The following management policy needs to be studied in the DEIS: To the extent that private land is used for overnight RV parking and hookups, the same amount of Forest Service land that would otherwise be available for parking will be withdrawn from such use.

Lake Solitude Water Storage

The immediate Lake Solitude area is riddled with mine shafts. The water quality in underground workings needs to be studied to determine how this proposed project will effect the opening of waterflow pathways that in turn will effect water flow in the underground workings.

Given the amount of mine shafts in the area, the DEIS should anticipate and study possible unintended environmental consequences of this project.

Lift Upgrades Towers and Terminal Visual Quality Issues

The towers and terminals of all the upgraded lifts, including any new lifts, need to be colored in a manner (dark earth tones) that cause the structures to blend into the summer foliage and skyline background. The favored colors of Solitude are yellow, blue and white. Lift infrastructure colored blue and white might be appropriate for the winter season, but is not appropriate for the balance of the year, given Forest Service VQOs.

Water quality issues

Mine tailings and mine shafts are present in several places throughout the SUP area. The possibility of heavy metal contamination and leaching from tailings should be carefully evaluated in the DEIS.

Mountain Bike Trails

Visual impacts and possible erosion caused by mountain biking trails need to be evaluated by the DEIS.

Potential conflicts and safety issues between hikers and mountain bikers need to be evaluated by the DEIS.

Tree Removal

An accurate count of trees to be removed as a result of the proposed construction projects should be done and mitigation measures need to be studied.

In conclusion, the Citizens' Committee to Save Our Canyons appreciates this opportunity to comment, put forth questions and offer suggested courses of action about Solitude's proposed projects. We look forward to having close involvement with the Forest Service and other interested parties during the entire NEPA process.

Sincerely yours,

Gale Dick
President
Citizens' Committee to Save Our Canyons