Re: On the Density Determination of Bonanza Mountain Resort

Dear Wasatch County Commissioners,

Thank you for the opportunity to comment on the Bonanza Mountain Resort proposal. As you are aware, the Wasatch Range is an incredible place with towering mountain peaks, clear flowing creeks, and lands that still welcome wild creatures. The enormous growth of the human population in and around the Wasatch puts increasing pressure to adapt the mountains to the needs of people. This creeping force is not easily noticed, as it happens slowly over decades and centuries, but it is a strong force in our Wasatch, and the proposed Bonanza Mountain Resort is a manifestation of this force.

Bonanza Mountain Resort would be built upon private property, so the land is not legally the domain of the public. Still, it should be taken into consideration that over 1 million people cherish the Wasatch Mountains in a way that they would not if significant portions hadn't been protected from development. Save Our Canyons, which includes a number of denizens of Wasatch County in its membership, has been working for 30 years for protection of the watershed, wildlife and recreational resources of the Wasatch Mountains. We urge you to keep Bonanza Flats undeveloped. We have many practical reasons for taking this stance, which we hope you agree will be in the best interest of Wasatch County. They include economics, watershed, wildlife, and complexities resulting from neighboring Brighton Estates. Though we take the stance that the development of Bonanza Mountain Resort is not in the best interest of Wasatch County, or of Utahns, we request that you take our points into consideration before granting approval in its current form.

Economics

One of the amazing features of Utah that draws so many people, whether it be for tourism or to settle, is our wild lands. People come here because they can go out and explore our world-renowned, pristine country. Adventure seekers as well as road-trippers love Utah for its wildness, and tourists are coming in increasing numbers because of this. Wasatch County has an incredible array of stunning scenery, and this is its strong point for tourism. The Olympics will undoubtedly bring even more people to Utah, as the importance of tourism in our state increases. However, we must make sure that we don't love our home to death. Wasatch County has done incredibly well in maintaining the pristine nature of its lands, and can only benefit from maintaining this policy. The County may want to consider the economic benefits of not developing Bonanza Flats.

We understand the (optimistically) projected tax benefit to Wasatch County from the construction of Bonanza. This would likely be pending the success of the project, which of course cannot be guaranteed. We have observed that while the current real estate development in the Wasatch has had a great deal of momentum as of late, this momentum has carried some false promises and disappointed hopes. As an example, The Canyons ski resort president was recently quoted as saying that the "pace of development is slower than we expected" (Salt Lake Tribune, 10 Jan, 2002). The article goes on to say that the "schedule for development needs to be scaled back because real estate sales have been slower than anticipated." This seems to be the current regional trend.

One reason for this may be that the skiing industry has not done as well as many have hoped. While resort development has been robust in Utah with an increase of 44% in overall ski terrain since 1996, skier visits have not kept up with this development. According to the Utah Ski Database report prepared by the Governor's Office of Planning and Budget, the skiing industry in the US has actually been stagnant for the last 20 years. In this same period, Utah's Market Share has grown slightly from 4.5% to about 5.5%. During all this time, developers have been anticipating a large increase in the number of skier visits. Admittedly, the arrival of the Olympics has the potential to bring some added attention to local resorts, but this is a big "if" in an industry that has been stagnant for so long. The time for Bonanza Mountain Resort may yet come, but current market trends suggest that this may not be the most economically favorable time for this development.

2. Watershed

The project area is an invaluable watershed for Utahns from Midway to Provo and on to Salt Lake City. We are concerned for both water quantity and water quality.

Water is as precious as gold in the west, particularly in drought years, and is the source of enormous controversy. We understand that one of the conditions of approval of Bonanza is that UPCMC provide proof that they have enough water on their land to provide for the development. We live in a very dry state, and we do not agree that extremely consumptive uses of water, ie golf courses, are justified, especially in such a crucial watershed area.

Ensuring the continued quality of this water is of indisputable importance. In the event that this project is constructed, some deterioration of the water quality would be inevitable, as with any development. UPCMC has stated its commitment to water quality, including UPCMC's participation in Audubon's certification project, we have noticed that UPCMC has yet to consider a number of various factors that could have a considerable negative impact on water quality.

The golf course is one of our biggest concerns. Golf courses are known to have severe impacts on water quality. Fertilizers, herbicides and sediment impairs groundwater. Removal of these chemicals would require expensive water purification, which would not be economically sound. The negative impacts on water quality of golf courses is well documented. We believe this risk is great enough that even if approval of Bonanza is given, the golf course should be left out of the plans.

Although a storm water system would be put in place along newly constructed roads, salt from the roads in the wintertime would invariably find its way into the groundwater. In addition, oil and other chemicals deposited on roads can find its way into local groundwater.

Current plans show that leashed dogs would be allowed on the property. Dog feces are known to increase levels of coliform bacteria. (The fecal material created by carnivores is typically found in very low concentrations in the wild, as carnivores are rare compared to herbivores like deer and elk. This fecal material has an enormous concentration of coliform bacteria compared to that of herbivores, and hence has a much greater impact on a watershed). Allowing dogs in the development will invariably have a negative impact on water quality.

In the density determination, we saw no mention of whether commercial landscaping fertilizers and herbicides should be allowed. These chemicals are highly toxic to wildlife and also contaminate ground water.

We have been assured of UPCMC's commitment to water quality, but have some suggestions of measures that would be the minimum of what would be required to ensure this quality.

First, water quality in Pine Creek should be monitored no less than two years in advance of phase I construction. This would enable us to have a benchmark of water quality so that the extent of water quality degradation can be measured.

Second, UPCMC must make a binding commitment not to allow water quality to degrade below an agreed upon threshold, and binding mitigation language should be included to repair degradation. Currently, there seems to be no water quality standard for the water in this watershed. According to Wasatch County code, "water quality cannot be degraded beyond its proportional share," the intent of this statement being to prevent water quality degradation. It would be extremely helpful to the county to specifically define "proportional share" as it relates to Bonanza for the purposes of determining a water quality threshold. It would be to the benefit of the County if the water quality threshold and emergency response to water quality degradation were agreed upon by Wasatch County and UPCMC before approval is given.

Third, approval of the Density Determination should be given only if a binding commitment to the Audubon golf course certification program is made. This seems to be the best tool available to ensure that negative impacts on water quality due to the golf course are kept to a minimum next to eliminating the golf course.

3. Brighton Estates

The impact of Bonanza Mountain Resort on neighboring Brighton Estates will be significant. Improved access to Brighton Estates has the potential to lure more people to the Estates, and Save Our Canyons is concerned about the lack of discussion and commitment to the complications that could result.

Currently, Brighton Estates cabins dispose of their human waste into septic systems. Improved access could potentially mean more cabins, and more leach systems. Ultimately, there could be 410 cabins and the accompanying septic contaminants, which is a large load on the land. There is currently no plan to address this potentially enormous risk.

Bonanza Mountain Resort will effect residents of Brighton Estates and ultimately could affect the watershed and regional traffic. These complexities to the development should be addressed by County Commissioners before approval is granted.

4. Wildlife

There is a high abundance of lakes, ponds, wetlands and streams within the project area. An incredible diversity of wildlife depend on the unique habitats bordering these water system, collectively known as "riparian areas." This makes it ideal habitat for many important wildlife species which are increasingly pushed out of the Wasatch Mountains due to human development and visitation. Wetland and riparian areas (are of particular importance to wildlife in Utah, the second driest state in the nation: 80% of Utah species rely heavily on riparian areas. The project area also acts as an important migration corridor for many of these species.

According to UPCMC's documents, threatened, endangered, or sensitive (TES) species have a good potential to live in the project area.

UPCMC has conducted a plant survey in the area, and the same respect should be given to animals in the area. To ensure that no wildlife populations are unduly harmed, an animal survey should be conducted. Binding commitment to conducting an animal survey within the project area should be made before approval is given.

Bonanza development, like any development, is likely to introduce invasive plant species, and the potential for this should be minimized. At Alta, when landscape managers hauled fill dirt from the valley to a formerly pristine land area, a number of invasive plant species were unintentionally introduced. For the next several years, Alta personnel and volunteers worked to pull invasive weeds BY HAND from this land fill area. Ideally, they should have hauled all that fill dirt away or never introduced it in the first place. As things are now, there are still invasive plant species at Alta (Source: Dr. Ty Harrison, Plant Ecologist, Westminster College). For an example of how invasive plant species can create a real mess, let's examine what one of these alien species has done to the budget and land management priorities of the BLM and the USFS: Cheatgrass is the scourge of the inter-mountain west. This plant alone is the cause of countless acres of unproductive biomass, rampant out-of-control grass fires, and loss of valuable food sources for browsers such as elk and deer. The impacts of this proposed development are many, but something as seemingly innocuous as introduced plant species can effectively render a watershed unproductive and fire-prone. It would be prudent to ensure that fill dirt used should not contain invasive species. In addition, prevention of invasive species would also mean careful monitoring of disturbed soil areas, where invasive plant species are most likely to colonize. Disturbed soil areas entails the entire construction project. Only careful monitoring can protect this beautiful area from unnecessary changes.

Save Our Canyons understands that UPCMC has committed to not erect any fences within the project area so that wildlife could roam freely within the project area. But if wildlife are to be allowed within the area, why then should area plantings be restricted to plants that are not native to the area and less attractive to existing wildlife? A clarification of UPCMC's commitment to maintaining the project area as viable wildlife habitat should be assured.

In order to mitigate some wildlife concerns a conservation easement should be required to prohibit ski resort development farther west of the current plans. This area should be specifically excluded from consideration as the interconnect between Park City and Big Cottonwood Canyon because of wildlife and recreational concerns.

5. Density Determination

Our largest concerns about Bonanza Mountain Resort are its effects on scenic value, water quality and wildlife. We believe that many risks could be lessened if the allowable density were lowered. Weber County ordinances currently allow one unit per 40 acres on comparable land. This density, or a density closer to it, is more reasonable considering not only the enormous relative significance of this area as a watershed and wildlife habitat, but also considering its spectacular aesthetic value.

We are especially concerned about the 18-hole golf course and its effects on water quality and wildlife. The sensitive high mountain environment is not the place for a golf course. The golf course fairways should absolutely be included as equivalent residential units due to the heavy impacts incurred on the watershed and wildlife.

In summary, Save Our Canyons is opposed to development of Bonanza Mountain Resort. If approval of the project is granted, though, we would hope that sufficient protection is guaranteed to ensure the health of the watershed and wildlife. If you have any questions, don't hesitate to call or email us. Thank you.

Sincerely,

Gavin Noyes, Director