ARAPAHOE BASIN 2006 Improvement Plan VOLUME 2

Transcription

1 ARAPAHOE BASIN 2006 Improvement Plan VOLUME 2 ARAPAHOE BASIN Response to Comments on the Draft Environmental Impact Statement DECEMBER 2006 USDA Forest Service White River National Forest Dillon Ranger District

2 RESPONSE TO COMMENTS RECEIVED ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT The Notice of Availability for the 2006 Improvement Plan Draft Environmental Impact Statement (EIS) was published in the Federal Register on July 21, The 45-day comment period for the Draft EIS ended on September 5. In response to the Draft EIS comment period, a total of 42 comment letters (including individual letters, faxes, and s), although not all were received by September 5. All letters were scrutinized, with substantive comments being extracted for responses. 1 Contact information for each commentor was entered into a master database. These substantive comments provide the foundation for which this Response to Comments (RTC) is based. Depending on the resource or context, substantive comments were organized into 12 groupings. Individual comments that were sufficiently unique in nature or context were carried forward verbatim into the RTC and responded to directly under Unique headings. Thematic comments were combined to be representative of common themes that were expressed by numerous individuals. Comments that resulted in an update to a particular component of the analysis between Draft and Final EIS are indicated as such in the RTC. Names and affiliations (if applicable) of people who submitted comments on the Draft EIS are provided below. Note: some commentors provided multiple comment letters and in some cases, multiple names were attached to a single letter. William R. Allen Kevin Allison Martin Balgach David Banas Leah Bathen Bonnie Boex Frederick Certano Tom Clancy Linda Clem Scott Cundy Doug Cuomo Monique DiGiorgio Brundage Mountain Resort Keystone Citizens League Southern Rockies Ecosystem Project 1 Per 36 CFR Part 215, substantive comments are those that are within the scope of the proposed action, are specific to the proposed action, have a direct relationship to the proposed action and include supporting reasons for the Responsible Official to consider. 1

3 Rob Edward Adriane Elliott Eric and Marty Foreman Murlin Goeken Nicole Gordon Ron Haddad Jason Halladay Jeff Tim Hester Hogan Ellen Hollinshead Nora Kelly Julie Kreutzer David Lien Karen Linarez Wendy LoSasso Bob Mayer Roz McClellan Amy McClintock Philip Miller John Patsey Eric Polczynski Dave Rossi Sloan Shoemaker Rocky Smith Jacob Smith Eric Stahl Robert Stewart Mike Sullivan Susie Sutphin Larry Svboda Marla Swanson Bill Vana Ken Wiseman Sinapu CSU - Dept. of Soil & Crop Sciences Backcountry Snowsports Alliance - Summit County Chapter Rocky Mountain Recreation Initiative Wilderness Workshop Colorado Wild, et al. Center for Native Ecosystems US Department of the Interior, Office of Environmental Policy and Compliance Patagonia, Inc. Athletes & Events Environmental Protection Agency 2

4 1. BACKCOUNTRY EXPERIENCE Thematic 1.1 Safe, skiable backcountry terrain in Summit County is gradually being reduced by ski area expansion projects. This is a major concern to the backcountry skiing community since other ski areas, such as Breckenridge and Keystone, are currently in the process or also considering plans to expand lift-served skiing into areas that are accessible only by hiking. The White River National Forest (WRNF) appreciates the important role that backcountry skiing plays in winter recreation on NFS lands, and recognizes that its popularity is increasing across NFS lands. The Forest Service also recognizes the important recreational opportunities that developed ski areas provide in Summit County as well as the goal of implementing quality land management practices under the sustainable multiple-use concept. Accordingly, during the 2002 WRNF Land and Resource Management Plan Final Environmental Impact Statement (2002 Forest Plan FEIS), the WRNF analyzed the tradeoffs of managing NFS lands for developed versus undeveloped recreational opportunities. This resulted in the 8.25 Management Area Prescription (Ski Areas - Existing and Potential). This management area includes existing resorts that have already been permitted and developed, as well as additional suitable terrain into which development is potentially suitable. The Selected Alternative which resulted in the 2002 WRNF Land and Resource Management Plan (2002 Forest Plan) was K, which reduced the acreage allocated for skiing on the WRNF by 44 percent from the 1984 Forest Plan. In Summit County, 30,015 acres of NFS land were allocated for skiing in the 1984 Forest Plan. Alternative K reduced the 1984 Forest Plan allocation for skiing in Summit County by 17 percent to 24,928 acres. Montezuma Bowl area is part of A-Basin s SUP area and falls under the 8.25 Management Area Prescription. The 2002 Forest Plan states that Montezuma Bowl has long been recognized as having excellent potential for skiing and snowboarding. 2 The commentor is referred to Section 3A (Recreation) in the Draft and Final EIS prepared for the 2006 A-Basin Improvement Plan, which includes a cumulative effects analysis that describes the effects on the recreational/ backcountry experience when analyzed against past and present Breckenridge and Keystone environmental assessments. 2 USDA Forest Service, 2002b p

5 Unique 1.2 I would urge the Forest Service to take an in-depth inventory of backcountry recreation in zones such as Montezuma and as well as a thorough study on all the issues facing this growing sport before approving even more developed skiing. An inventory of backcountry skiing opportunities on a Forest-wide basis is beyond the scope of this site-specific proposal and analysis. The reader is also referred to the cumulative effects analysis provided in Section 3A (Recreation) of the Draft and Final EIS prepared for the 2006 A- Basin Improvement Plan for a discussion of recently approved ski area projects that have affected backcountry skiing opportunities on the WRNF. Under the 2002 Forest Plan, ski area boundaries in Summit County were reconsidered based on the need to meet projected use levels. Towards this end, the 2002 Forest Plan (per Alternative K in the FEIS) adjusted ski area SUP boundaries within Summit County effectively, reducing the total area allocated for skiing and snowboarding from 30,015 acres, as designated in the 1984 Plan, to 24,928 acres - a 17 percent reduction. 3 In fact, the number of acres allocated for skiing and snowboarding on the WRNF was reduced by 39,721 acres (44 percent) from the 91,243 acres in the 1984 Forest Plan to 51,522 acres in the 2002 Forest Plan It is becoming more and more difficult for backcountry users to find good hiketo ski/snowboard terrain, especially with recent and proposed future developments at Keystone and Breckenridge. The cumulative effects analysis contained in the Recreation section of the Draft and Final EIS documents discusses recently approved lift and cat skiing projects within undeveloped portions of the Breckenridge, Keystone and Copper Mountain SUP areas. All of these projects are located within the 8.25 Management Area Prescription. To put it in perspective, the 51,522 acres allocated to the 8.25 Management Area Prescription represents approximately 2.2 percent of the approximately 2.3 million acres of NFS lands open to the public and managed by the WRNF. 1.4 If people want to hike there and ski that is one thing but to add a new lift would ruin the backcountry character of the area. Because Montezuma Bowl is not patrolled or maintained by A-Basin, the area exhibits some of the typical characteristics associated with backcountry ski terrain. However, as stated in the DEIS (page 3-10) and FEIS (page 3-11), due to its proximity to A-Basin s parking and guest service facilities, as well as lift-served access via A-Basin s lift network, Montezuma Bowl is considered a quasi backcountry experience. Nonetheless, the potential impacts to the current skiing 3 Ibid. p Ibid. p

6 characteristics of Montezuma Bowl associated with installation of the chairlift are acknowledged in the DEIS (page 3-18) and FEIS (page 3-20): with installation of a lift, and associated grooming, avalanche control, the presence of ski patrol staff, and increased public use, the existing backcountry characteristics of Montezuma Bowl would be essentially eliminated. 1.5 This lift would be taking from the people who are willing to work for their turns and have been doing so for years and years. Impacts to skiers who have accessed Montezuma Bowl from A-Basin s lift network are acknowledged in the Draft and Final EIS documents. Because Montezuma Bowl is within the 8.25 Management Area Prescription (Ski Areas - Existing and Potential) and is within A-Basin s SUP area, the proposal to install a chairlift in Montezuma Bowl is consistent with direction contained in the 2002 Forest Plan. 2. INFRASTRUCTURE Unique 2.1 The impacts of snowmaking have not had sufficient time to be evaluated to be making another giant leap in this alpine environment. Although no snowmaking is proposed in Montezuma Bowl, the environmental impacts of snowmaking on terrain in A-Basin s existing operational boundary were thoroughly analyzed and documented in the 1999 Master Development Plan Final EIS. As documented in the associated Record of Decision, various projects, including snowmaking infrastructure, were approved. As required, the Draft and Final EIS documents analyzing the 2006 Improvement Plan have taken previously-approved projects within the SUP area into consideration and assessed their cumulative effects. 3. VISITATION Unique 3.1 Page 3-17 states that recent growth in visitation at A-Basin validates the White River National Forest Plan s growth expectations. That is, at best, a great stretch of the truth. Projected growth in ski visitation is greatly exaggerated. First of all, there has been little growth in overall visitation to Colorado since , as is clearly shown on Table 3F-1, at page That Table also shows that the Summit County portion of Colorado s ski visitation has increased only slightly during that period, and had a considerably higher percentage of Colorado s snow riders at one time during the period than it has in the most recent seasons. 5

7 The DEIS (page 3-53) and FEIS (page 3-57) state that: In Summit County skier visits have been fluctuating each year since the mid 1990s. However, as demonstrated in Table 3F-1, the percentage of total skiers in the County in relationship to the state has been relatively steady, averaging 33.5 percent over the last seven ski seasons. As stated on page 3-4 of the Final EIS, A-Basin has experienced a 6.7 percent average annual increase in skier visits between the 1994/95 and 2005/06 seasons. Summit County skier visits in the season reached 3,856,253, and the 2002 Forest Plan FEIS anticipated an increase of 320,064 in annual visits above the 2001 level. 5 The projection in the 2002 FEIS (3,853,253 skier visits in 2000/01 to 4,173,317 skier visits in 2009/10) assumes an average annual increase of 0.52 percent. 6 Data provided by Colorado Ski Country indicates that from the 2000/01 and 2005/06 ski season, Summit County ski areas have averaged an annual increase of 1.43 percent during this time period. 7 Should Summit County ski areas continue this growth trend, in the 2009/10 season Summit County ski areas would do approximately 4,415,991 skier visits, 242,674 skier visits above the 2002 Forest Plan FEIS projection. This increase in skier visitation above the 2002 Forest Plan FEIS projection is largely due to growth of the Front Range communities, relatively inexpensive season passes, such as the Buddy Pass and advancements in ski equipment enabling baby-boomer skiers to ski longer and younger people to become skilled at the sport faster than in the past. 8 Due to these factors, in addition to the expected 14.6 percent increase in Summit County s population by the year 2010 to 32,384 (page 3-56 of the Draft EIS), it is reasonable to expect a growth in skier visitation to Summit County ski areas to continue. To accommodate this anticipated growth and preserve a quality skiing experience, terrain currently managed under the 8.25 Management Area Prescription can be considered for development. 3.2 A-Basin is by far the smallest, and thus the least visited, of the four Summit County resorts. Thus a considerable increase in usage in Summit County, if it somehow occurred, might not translate into a big increase for all of A-Basin. While A-Basin offers the smallest number of skiable acres of the four Summit County ski areas; it experiences high utilization rates. Historical data presented on page 3-4 of the Draft EIS demonstrate an upward trend in annual skier visits at A-Basin, most notably after the installation of snowmaking which first operated during the 2002/03 season. Therefore, in conjunction with the expected increase in Front Range and Summit County populations, it is reasonable to expect an increase in skier visitation at A-Basin. Furthermore, the purpose and need of the Proposed 5 USDA Forest Service, 2002b pp Ibid USDA Forest Service, 2002b pp and 3-444; Wyrick, Nationwide Skier Numbers Take A Leap - Vail Daily May 25 Available online at 6

8 Action is not only to address the anticipated growth of skier visitation at A-Basin, but also, as stated on page 1-4 of the DEIS and FEIS, to address the ski area s infrastructure deficiencies and to better distribute guests that currently visit A-Basin as the existing terrain is out of balance with A-Basin s unique skier demographic. 3.3 The ski industry is not now and has not been for many years a growth industry. With the current energy costs and economic concerns I believe there will be a decline in skier numbers and the idea of needing more and more terrain is premature and ignores the problems with the existing facility. The Final EIS, Table 3A-1 and accompanying text, has been updated to include A-Basin s annual skier visitation numbers through the 2005/06 season as well as national skier visitation trends. Data provided in the Final EIS indicates an upward trend in terms of skier visits for the ski industry as a whole and in particular Summit County, Colorado. This can be attributed to the County s close proximity to the expanding Front Range communities and Denver International Airport, relatively inexpensive season passes such as the Buddy Pass, and growth from implementation of new market strategies such as NSAA s Model for Growth that promote the availability of high quality skiing recreation experiences, which was anticipated in the Forest Plan. 9 The Purpose and Need for the Proposed Action extends beyond incorporating Montezuma Bowl into A-Basin s operational boundary. The purpose of the Proposed Action also recognizes and seeks to address deficiencies in A-Basin s existing infrastructure such as inadequate parking and alleviating existing base area congestion. These projects, in concert with the added terrain offered in Montezuma Bowl, are designed to enhance the overall recreation experience at A-Basin by creating a more efficient, well-rounded and modern facility. The reader is referred to the Purpose and Need for the Proposed Action on pages 1-4 and 1-5 of the Draft and Final EIS. 3.4 It is possible that visitation increases do not automatically signal the need for more terrain. Annual visitation may be expanding due to early and late season skiing and weekday skiing. We recommend that the Final EIS include information on peak day trends (number of days each season that the resort operated at or above Comfortable Carrying Capacity) and information on weekday visitation trends. The addition of Montezuma Bowl responds to Purpose and Need #1 (Better disperse intermediate and advanced skiers throughout the SUP area.) and #2 (Address terrain capacity issues to accommodate current and anticipated demand.) by providing additional lift-served advancedintermediate and advanced terrain. Furthermore, as indicated in the Recreation Analysis, terrain capacity is based on the number of skiers per acre for a given terrain ability level. Per the MDPA, 9 USDA Forest Service, 2002b pp , 3-444, 3-453, and

9 a comparison of A-Basin s skier/rider market with available terrain capacities demonstrates that A-Basin is out of balance with its specific skier/rider market. In response to this comment, the FEIS Recreation Analysis (Table 3A-2, p. 3-5) has been updated to include days in which A-Basin s CCC (3,210 guests) has been met or exceeded dating back to Over these four seasons, on average, A-Basin has exceeded its CCC six times per season. It is worth noting that Table 3A-2 does not include days in which 80 to 90 percent of A-Basin s CCC was achieved, which are a common occurrence. 3.5 The DEIS includes an analysis of existing lift line wait times (Table 3A-3). Five days were surveyed in 2006 for use in this analysis. The Final EIS should include information on how those five days were selected, whether data were collected on any additional days, and information on the snow conditions for each of those days. This information will assist in understanding whether this limited data is representative of peak days, average days or a range of visitation levels. As indicated in Table 3A-3 of the Draft EIS, the five days that were surveyed in 2006 occurred on weekends in January, February, and March. These were considered representative of typical weekends at A-Basin to provide a fair assessment of what one would typically encounter at the ski area during this time of the year. Table 3A-4 in the Final EIS has been updated to include daily visitation on the five days lift line wait times were recorded. On these surveyed days, daily visitation has varied between 88 and 100 percent off the resort s CCC (3,210). 4. TERRAIN Thematic 4.1 The proposed new lift is not needed because it would add more intermediate terrain; terrain which A-Basin already has plenty of. Therefore the addition of Montezuma Bowl will not achieve the stated, desired terrain balance. The addition of Montezuma Bowl responds to Purpose and Need #1 (Better disperse intermediate and advanced skiers throughout the SUP area.) and #2 (Address terrain capacity issues to accommodate current and anticipated demand.) by providing additional lift-served advancedintermediate and advanced terrain both of which are needed at A-Basin. A traditional slope analysis (i.e., based solely on angles) indicates that terrain in Montezuma Bowl falls into both the intermediate (~195 acres) and advanced (~152 acres) categories. However, there are qualitative components of the terrain in Montezuma Bowl that cannot be captured (e.g., variable snow conditions, moguls and trees) in an analysis that is based purely on slope angles. With the implementation of developed lift-served skiing in Montezuma Bowl, approximately 37 acres of intermediate terrain (across two top-to-bottom trails and two connector 8

10 trails) would be groomed on a regular basis to provide for a consistent intermediate descent. Figure 3B in the Final EIS has been updated to include the location of groomed terrain in Montezuma Bowl. The remainder of the terrain (~310 acres) in the Bowl would remain in an ungroomed state and would therefore be defined by climatic conditions (i.e., abundance of snow) and skier utilization patterns (e.g., moguls) as well as by slope gradient and obstacles (e.g., trees). Therefore, in a bowl setting, even terrain that would traditionally be classified as intermediate can assume qualities (e.g., moguls, powder and variable snow conditions) that lend it to use by advanced ability level skiers. (It is noted that the back bowls of Vail offer an overwhelmingly intermediate skiing experience from a slope gradient perspective but are nonetheless world renowned and coveted by advanced skiers.) Therefore, despite the results of the slope angle analysis, upon traversing from the top of the Lenawee chairlift to the ridge overlooking Montezuma Bowl, a skier would be presented with approximately 34 named trails to choose from, with four of them marked as intermediate and the remaining 30 marked as advanced and or expert. The commentor is referred to Table 3A-7 in the Final EIS for updated/clarified terrain distribution by ability levels. 4.2 Summit County already has enough lift-served, high altitude bowl skiing offered at nearby Breckenridge and Keystone ski areas. As demonstrated by recent ski area upgrades (e.g., Aspen, Telluride, Vail, Copper Mountain), there has been a steadily growing demand for lift-served, high-altitude bowl skiing as equipment advances lead to skiers becoming better, faster and desire to get off-piste. The Montezuma Bowl proposal allows A-Basin to respond to this important ski industry phenomenon and to maintain a healthy position in the highly competitive Summit County ski industry, while respecting its reputation as a down-to-earth, day ski area in a region noted for its destination resorts. In the 2005/06 season, Summit County s 4,171,431 skier visits accounted for almost 33 percent of Colorado s total skier visitation. Historically, Summit County has averaged approximately 32 percent of the State s annual skier visits. Furthermore, the Draft and Final EIS (FEIS p. 3-19) state that, according to the 2002 Forest Plan, skier visits in the State of Colorado are expected to increase by an additional 804,723 from approximately 11.6 million by Thus, as more skiers visit Colorado ski areas, more can be assumed to visit Summit County and new opportunities such as Montezuma Bowl become more important. 9

11 Unique 4.3 Finally, a new lift simply does not make sense because A-basin draws skiers for its small-resort atmosphere not for its expansive acreage and because the resort already has an abundance of the type of terrain found in Montezuma Bowl. A-Basin does not offer any lift-served bowl skiing such as that found in Montezuma Bowl. As stated in its 2006 MDPA, maintaining the unique character of A-Basin is paramount to the plan. The Montezuma Bowl chairlift and associated terrain would change the dynamic of A-Basin but should enhance the reputation that A-Basin has gained over the years as a down-to-earth, no frills day ski area that stands in contrast to larger, neighboring destination resorts. 4.4 [The MDPA] categorizes the Montezuma Bowl terrain as advanced intermediate and expert terrain. [2006 MDPA at page 42]. That page notes that the average slope for the advanced intermediate terrain portion of Montezuma Bowl is 19 percent, with the steepest part having 55% slope. Id. However, advanced intermediate terrain is said to be up to 55 percent slope, with intermediate terrain having up to 45 percent slope. Id. At 10. Thus, the 2006 MDP has taken the maximum slope for the intermediate portion of the Montezuma Bowl and assumed that the entire portion is advanced intermediate. But much of the Bowl is clearly not advanced intermediate terrain, as the figures cited above and a quick look at a map show. See DEIS Figure 3B; note that the contours are rather far apart in the middle of the Bowl. Although portions of the terrain found in the middle of the Bowl have a slope gradient between 26 and 45 percent (which is consistent with what would typically be classified as Intermediate ), as indicated previously, terrain ratings are made according to the steepest pitch to be encountered and aside from groomed intermediate trails in the Bowl, all remaining terrain would be signed as Advanced. The reader is referred to Figure 3B in the Final EIS for the location of groomed terrain in Montezuma Bowl. 4.5 [T]he MDP falsifies the amount of expert terrain present in the Bowl, the standard for which is slopes greater than 70 percent. [2006 MDPA at page 10]. However, no terrain in the Bowl has this degree of steepness, as the maximum slope is 65 percent, and the average is only 23 percent. Id. At 58. Table III-1 of the MDPA (page 10) excluded the Advanced terrain level classification that includes slope gradients between 56 and 69 percent. Therefore, the MDPA incorrectly classified all terrain within the advanced and expert classification as Expert. The FEIS has been clarified to indicate that all terrain with slope gradients exceeding 56 percent is considered Advanced (this includes expert, as well). Furthermore, as indicated in the response provided for Comment 4.1, A-Basin will mark groomed terrain in Montezuma Bowl as Intermediate with all remaining ungroomed terrain marked as either Advanced or Expert according to slope gradient or other 10

12 factors. A-Basin has the discretion to classify terrain (e.g., intermediate, advanced, and/or expert) within Montezuma Bowl as deemed appropriate based on slope gradients, obstacles, etc. 4.6 The purported need for more of certain types of terrain is said to have come from skier surveys. Master Development Plan Amendment of April, 2006 at 20. Surveys are notoriously unreliable, as they can easily be conducted in such a manner as to produce the desired result. It is hard to imagine that A-Basin obtained accurate information from enough people to get a truly accurate picture of what even current visitors want. The skier surveys incorporated into the Draft EIS originate from an annual survey conducted for A-Basin by RRC Associates, a consulting firm that conducts skier surveys nation-wide, providing valuable data that is used by individual ski areas as well as to asses the current state of the ski industry. The purpose of the survey, titled NSAA 2003/04 Demographic skier/snowboarder research -, was to provide A-Basin with a detailed description of the skier demographic that visit the ski area. The survey was conducted over an eight year period starting at the 1996/97 season. Survey methodology included recording guest responses to a series of questions ranging from ability level, approximate age when first started snowriding, to guest state/country of origin. (The reader is referred to the project file for a complete report of the survey results). 4.7 The advanced terrain which is supposedly needed and does exist, is short, rocky and usually holds the worst snow, and quickly becomes another easy intermediate run to the bottom. The Recreation analysis in the Final EIS has been augmented with additional information on snow surveys that have been conducted in Montezuma Bowl to assess the nature of the quality of lift-served skiing that would be provided there. To summarize, terrain and climate factors affecting qualitative aspects of snowboarding and skiing in Montezuma Bowl are not unprecedented, and there are numerous successful ski area operations which not only offer snowboarding and skiing on south facing terrain but also in windier and colder environments than that found at A-Basin. Starting in 2005, A-Basin began assessing the effects of weather, snow cover and terrain on proposed lift-served snowboarding and skiing in Montezuma Bowl. Grooming operations and skier compaction significantly alter the natural snow cover. Snow studies conducted within this area indicate that loose and unconsolidated snow layers or breakable wind slabs would be virtually eliminated due to systematic skier compaction as well as through common avalanche control techniques that are already employed by A-Basin ski patrol. 11

13 4.8 The Porcupine Roadless area and fragile tundra of Montezuma Bowl will not tolerate the additional skier traffic, snowcat traffic, explosives use, or permanent snow fencing needed to hold the snow on the proposed terrain. Proposed increases in skier numbers and ski area management in the Alpine Tundra of Montezuma Bowl should have little adverse effect on the vegetation. The majority of the land above treeline in Montezuma Bowl does not support lush vegetation due to wind scour, natural snowdrifts and shallow rocky soils. The impacts of snow compaction are related more to a persistent snowpack rather than to physical damage to underlying vegetation. Any vegetation in the Alpine Tundra would be protected because grooming activities would only occur after a sufficient snow base was present. The Proposed Action has been reviewed against the 2002 Forest Plan, and is consistent with relevant standards and guidelines regarding the Alpine ecosystem. 4.9 We found an inconsistent accounting of terrain distribution in the DEIS. On p the DEIS indicates that Montezuma Bowl would add 347 acres of advancedintermediate and expert level terrain. This sentence is consistent with what we were told by the USFS on a site visit regarding Montezuma Bowl. Conversely, p. 2-4 indicates that Montezuma Bowl would add 175 acres of intermediate terrain, and 150 acres of advanced and expert terrain. These figures area important as the DEIS argues that A-Basin is lacking advanced intermediate and expert terrain, and has a surplus of intermediate terrain. If figures on p are correct, this lift pod would add more intermediate terrain that is already described as surplus and would add just 150 acres of terrain that meets the stated need for advanced-intermediate and expert terrain. Slightly different boundaries were used to define skiable terrain in Montezuma Bowl in the MDPA and the Draft EIS, leading to a 22-acre difference in the quantification of terrain categorization. This slight discrepancy did not affect the analysis of resources in Montezuma Bowl. The FEIS has been clarified to indicate the results of a slope analysis found in the 2006 MDPA that was conduced in Montezuma Bowl approximately 195 acres of intermediate terrain and approximately 152 acres of advanced terrain, for a total of 347 acres. 10 The 48 acres of hikeback terrain are categorized as advanced due to slope angle and topography MDPA is located in the Project File at the Dillon Ranger District. 12

14 5. RECREATION Unique 5.1 Montezuma Bowl often has poor snow quality. Snow which faces south, southwest receives sun and wind. This is not good exposure for much of the winter. South facing slopes are often not open due to lack of snow. Visibility is also tough in this area since it s mostly above treeline. Because of its close proximity to the continental divide, wind can be severe. Most visitors cannot tolerate these conditions. South facing slopes are usually only good skiing for a short part of the ski season. The Recreation analysis in the Final EIS (p. 3-18) has been augmented with additional information on snow surveys that have been conducted in Montezuma Bowl to assess the quality of lift-served skiing that would be provided there. Data provided by Hal Hartman & Associates, LLC refutes this comment and snow and visibility studies indicate that snow coverage in Montezuma Bowl would allow this terrain to remain open for the majority of the ski season and limited visibility would occur for 1 out of 20 descents. 5.2 Montezuma Bowl would not serve well intermediate or advanced snow riders. Intermediate users would find a daunting beginning of their run through the Bowl. Advanced users would have a desirable beginning and then a long intermediate run. Longer, more continuous advanced skiing is accessible from the Pallavicini lift. Thus, the Montezuma Bowl lift would not distribute many users away from the Pallavicini, as stated at page A traditional slope analysis (i.e., based on angles) conducted for the 2006 MDPA indicates that the topography of Montezuma Bowl naturally separates skiers of intermediate and advanced abilities. As previously discussed in this RTC, the 347 acres of intermediate (~195 acres) through advanced (~152 acres) level natural open-bowl terrain in Montezuma Bowl is inherently different than anything that is currently lift-served within A-Basin s SUP area. As evidenced at other ski areas, the public has shown considerable interest in open-bowl skiing. 5.3 The new lift would also supposedly "reduce skiers intermingling of different abilities". P How is that possible? Clearly, Montezuma Bowl is a mixture of intermediate and advanced terrain, thus advanced and intermediate users would be mixed in Montezuma Bowl, probably as much more or more than they now are on the front side of the ski area. A slope analysis of Montezuma Bowl indicates that the topography naturally separates intermediate and advanced level terrain. Much of the continuous advanced terrain is located on the west side of the Bowl, with several pockets of advanced spread throughout. The remainder of the terrain is comprised of advanced-intermediate opportunities (see response 4.1). Although open bowl skiing inherently lacks formal (i.e., designated skiers left and rights edges) trails, as 13

15 is the case with all of A-Basin s in-bounds trails, terrain in Montezuma Bowl will be signed to inform skiers of the designated ability level. 5.4 Allowing snowriders to exit A-Basin's special use permit area would violate the Forest Plan. Providing backcountry access points to forest lands from ski area permit boundaries is consistent with the Forest Plan. The Proposed Action includes reconfiguring existing backcountry access points, which have historically allowed skiers to access adjacent forest lands from the A-Basin SUP area. Exiting A-Basin s SUP boundary (administered under the 8.25 Management Prescription) through the backcountry access points (both existing and proposed) necessitates entering adjacent NFS lands administered under the 5.5 Management Prescription ( Forested Landscape Linkages ). Because public access across the 5.5 Management Prescription is not prohibited per the 2002 Forest Plan, current and future use of these areas is therefore consistent with Forest Plan direction and WRNF boundary management policy. 5.5 This expansion in particular is troubling because it will likely lead to overuse of a little-used but highly accessible area, thus degrading the quality of the snow and severely limiting the enjoyment of the area for human-powered recreationalists. As indicated in the DEIS (page 3-18) and FEIS (page 3-20), with installation of a lift, and associated grooming, avalanche control, the presence of ski patrol staff, and increased public use, the existing backcountry characteristics of Montezuma Bowl would essentially be eliminated. 5.6 The addition of the lift won t garner the more difficult ski terrain that A-Basin is hoping to achieve and would take away from the wilderness feel that area offers to both winter and summer enthusiasts. As stated on page 1-12 of the Final EIS, the ROS classification for the entire A-Basin SUP area, including Montezuma Bowl, is designated as Rural. This designation characterizes an area s natural environment as one that is substantially modified by human activities, either through development or human presence. This designation and the 2002 Forest Plan further state that facilities provided in these areas are designed for a large number of people, including motorized use. Although one may experience solitude that is typically associated with a wilderness area, Montezuma Bowl, and the Porcupine Peak IRA are not designated or managed as Congressionally-designated Wilderness areas. As stated on page 3-25 of the Draft EIS, As per the Forest Plan EIS, the high recreational use on Grays and Torreys and multiple private inholdings (patented mining claims) make this area difficult, if not impossible, to manage for Wilderness designation. 14

16 6. ROADLESS AREAS Thematic 6.1 Installation of the Montezuma Bowl lift would permanently alter the roadless characteristics of a large portion of the Porcupine Peak IRA. The Forest Service analyzed the potential impacts to roadless characteristic of the Porcupine Peak IRA with results documented in the Draft and Final EIS documents. As stated in the Draft, due to the large size of the IRA and the relatively small portion that would be affected acres or 3.5 percent of the total IRA area - the Forest Service concluded that the Proposed Action is not large enough to alter roadless characteristics of the entire 8,475-acre Porcupine Peak IRA. This determination is supported by the fact that the area is currently heavily fragmented with patented mining claims and recreational use associated with Grays and Torreys peaks. 6.2 The DEIS incorrectly summarized the opportunities for solitude in the Porcupine Peak IRA. Unique The description of the Porcupine Peak IRA tiers to a roadless area analysis specialist s report that was prepared for the 2002 Forest Plan FEIS in conjunction with the 2002 Forest Plan The FEIS also states that six mining claims are occupied year-round. That is unlikely. The Peru Creek Road, which would have to be used for four-wheeled access, is not plowed in the winter. Only a few snowmobiles infrequently use this road, and the private landowners may occasionally visit their inholdings, but it is not correct to state these lands are occupied in winter. Therefore, the much easier access provided by the proposed Montezuma Bowl lift would introduce a much higher level of human disturbance than now exits in the roadless area. Under the General Mining Law of 1872, the Forest Service must make a distinction between patented and unpatented mining claims. The six mining claims referred to in the Draft EIS are patented mining claims. A patented mining claim is one which the Federal Government has transferred the title to the claimant, making it private land. An unpatented mining claim is a particular parcel of Federal land, valuable for a specific mineral deposit or deposits that are leased from the Federal Government with no transfer of ownership. The use of the term occupied in the Draft EIS as defined by the Forest Service is meant to convey only private ownership, not actual tenancy of the property for any period of time. Although there are currently no permanent structures on these private lands, the owners do posses the legal option to erect permanent structures subject to requisite permits and approvals. 11 USDA Forest Service, 2001a 15

17 6.4 Also, how realistic is it to construct and maintain the proposed Montezuma Bowl lift without a road? Indeed, a road would probably be needed to bring in the low-impact excavating equipment to be used for grading and for digging the foundation areas for the lift towers and bottom terminal. Sufficient road access exists to the top terminal of the proposed Montezuma Bowl lift (which is outside of the Porcupine Peak IRA) for which to transport most equipment. A helicopter, designed to operate at high elevations and carrying heavy loads, would also be employed for this project to transport equipment and lift componentry in the roadless portion of the Bowl. As indicated in the Draft EIS, transporting excavating equipment and lift infrastructure for the bottom terminal would be accomplished with both over-the-snow techniques via snowcat as well as helicopter transport. Nearby Breckenridge Ski Resort recently constructed the Imperial Express detachable lift on Peak 8 utilizing similar techniques (i.e., road access existed to the bottom terminal, however, the lift corridor and top terminal were successfully completed without construction of a road). A spider excavator, which would be walked down into Montezuma Bowl from A-Basin s frontside, would likely be utilized to construct the Montezuma Bowl lift s bottom terminal and lift tower foundations. Maintenance of the lift would largely be conducted over-the-snow during the winter and spring. Summer and fall maintenance access, if needed, would be accomplished by foot. This method is currently utilized at Breckenridge Ski Resort for maintenance of the Imperial Express Lift, and has proven successful in the absence of a road. 6.5 Especially damaging to roadless character would be the proposed hikeback terrain. A 6-10' wide catchment trail would be constructed about 600 feet below the bottom lift terminal. P That means that impacts of greatly increased use in Montezuma Bowl would extend into the forested area at the bottom of the Bowl and beyond. The proposed hike-back terrain below the bottom terminal of the Montezuma Bowl lift has been analyzed for potential impacts to the Porcupine Peak IRA. The Montezuma Bowl project, and the catchment trail or hike-back terrain in particular, would not affect the eight ecological and social values identified in the 2000 Forest Service Roadless Area Conservation Final EIS (individually or combined) to the point of altering the roadless characteristics of the Porcupine Peak IRA. The reader is referred to the 2006 A-Basin Final EIS, Section 3B, for an analysis of the eight ecological and social values of an IRA. 16

18 6.6 Also, how realistic is it to have workers walk in their tools or to be delivered by helicopter? There may not be good landing spots for copters. Workers accessing the area on foot would have a long walk from the lower lift terminal and towers back up to the road at the top of the existing ski area at the end of the day. Such egress and even presence during much of the day would be made more dangerous by afternoon thunderstorms in a mostly above-timberline area. It is common practice to use helicopters for transporting heavy pieces of equipment and lift componentry. (Note the previous reference to the Breckenridge Peak 8 Imperial Express detachable chairlift in Comment 6.4). During assembly of lift terminals and tower installation, landing spots are not necessary, other than at the staging/refueling area (which would be at A- Basin s base-area). Foot access to the bottom terminal, while admittedly less practical than vehicular access due to additional expenditures of time and energy, is a component of the proposal and analysis, and thus becomes a requirement in the approval to construct the bottom terminal and lift corridor. 7. SAFETY Unique 7.1 The crossing from parking to the ski hill is crazy dangerous. Somebody s gonna get killed by one of the many speeding tankers on US 6 trying to wander across the highway in their ski boots. A pedestrian underpass was analyzed in the 1999 FEIS and approved in the subsequent 1999 Record of Decision (ROD) that would eliminate identified vehicle and pedestrian conflicts caused by guests crossing over Highway 6 to access the ski area from the upper parking lots. The pedestrian underpass is addressed in the Draft and Final EIS in Chapter 3C (Traffic, Parking and Ski Area Access). A-Basin and the Forest Service are currently in the process of planning for the implementation of the pedestrian underpass. 7.2 After heavy snowfalls, the avalanche danger off the west ridge would be too great to allow public use before avalanche control work was performed. Shooting avalanches would make the area safe, but it might deposit large piles of snow at the bottom of the west ridge, reducing the quality of snow riding down the western drainage of the Bowl. Avalanche control work in Montezuma Bowl would be incorporated into A-Basin s Winter Operating Plan which is submitted to the Dillon Ranger District annually. Snow deposition at avalanche run-out zones is a result of both natural and induced avalanches and is a commonly managed condition on steep terrain in this part of Colorado. 17

19 7.3 With numerous rocks protruding from the snow or exposed with wind or slightsnow melt, we wonder about the safety of snowriding in the Bowl, especially during poor visibility conditions. Wind and wind chill may make the Bowl undesirable for use on many winter days. Poor visibility will likely be a factor during snowstorms, creating whiteout conditions that would make the Bowl undesirable and unsafe to use. As with many outdoor sports, there are inherent risks associated with snowriding. The Colorado Skier Safety Act notes the inherent risk of skiing including: changing weather conditions; existing and changing snow conditions; bare spots; rocks; stumps; trees; collision with natural objects; man-made objects or other skiers; variations in the terrain; and the failure of the other skiers to ski within their own abilities. Natural hazards and variable weather conditions should be expected at any ski area. Although, as it currently does, natural and man-made obstacles will be marked per Colorado Skier Safety Act requirements. However, it is not possible to eliminate all hazards due to the nature of the sport, natural topography, and the physical extent of the ski area boundary. 7.4 We found no mention of an emergency egress associated with the Montezuma lift. If it has been determined that no emergency, down-mountain, egress is needed, the Final EIS should discuss the means by which injured people will be transported, and how skiers will get back to the base area should the lift malfunction. Chairlifts accessing terrain in relatively remote locations are common, and as with all of A- Basin s chairlifts, the ski area will assemble an emergency evacuation plan for the Montezuma Bowl chairlift as part of their required Winter Operating Plan. This evacuation plan will rely heavily on snowmobiles and snowcats as an emergency transport. 8. SKIER DENSITIES Unique 8.1 Montezuma Bowl would purportedly reduce congestion at the base. Page However, people would still have to get through congestion at the base to get to the Bowl. Congestion at the base area is proposed to be alleviated by upgrading the Exhibition lift, as described on page 2-16 of the DEIS and FEIS. The addition of the Montezuma Bowl lift is expected to alleviate congestion throughout the day, especially during the busy lunchtime hours by keeping people in Montezuma Bowl that might otherwise descend to the base area. In addition, base area congestion will further be reduced by the operation of the Midway Lodge 18

20 (which is under construction as of summer 2006), which will reduce the need for guests to descend to the base area for food and other guest services. The ease of base area congestion is consistent with the purpose and need of the Proposed Action and would improve the overall recreational experience at A-Basin. 8.2 For assessing the existing condition and impacts from the project, the DEIS relies heavily on a two-page report entitled Terrain Distribution Analysis (TDA). As we pointed out in our Scoping Comments, the TDA does not appear to account for the effects on skier flow and density from the proposed upgrade in Exhibition Lift, nor does it appear to anticipate what benefits to skier distribution and flow might be provided by upgrading Pallavacini Lift and building Midway Lodge. The DEIS also does not appear to account for these benefits. These facts argue for the inclusion of an additional action alternative in the EIS to assess whether less terrain-dependent (lower impact) alternative might meet the Purpose and Need. The MDPA includes a terrain distribution analysis, which analyzes both the existing conditions and the proposed upgrades to Exhibition Lift, Montezuma Bowl and parking facilities. The installation of the Midway Lodge was analyzed and approved in the 1999 A-Basin EIS and was carried forward into the 2006 MDPA and addressed as a Previously Approved Project, Not Yet Implemented. Installation of the Midway Lodge is discussed in the Draft and Final EIS Recreation analysis under Alternative 1 in the Lift Line Wait Times heading. with installation of the previously-approved Midway Lodge (anticipated to be operational in 2007), skiers would no longer be required to descend to the base area for guest services, thus allowing more people to remain on-mountain and thereby reducing, but not eliminating, congestion at A-Basin s out-ofbase lifts (particularly during the busy mid-day period when people typically take a break from skiing). It is understood that there may be benefits to upgrading other lifts (e.g., Pallavacini Lift) at A- Basin. Although, in an effort to keep the NEPA process concise and consistent, only those projects which meet the stated Purpose and Need, warrant detailed analysis. While upgrading the Pallavicini chairlift would address some out-of-base capacity issues (thus responding to Purpose and Need #3), it would not address Purpose and Need #1 (Better disperse intermediate and advanced skiers throughout the SUP area) and #2 (Address terrain capacity issues to accommodate current and anticipated demand) by providing additional lift-served advancedintermediate and advanced terrain both of which are needed at A-Basin. 19

21 9. TRAFFIC/PARKING/SKI AREA ACCESS Unique 9.1 How many peak use days are expected to occur? Page 3-32 says there will five per year, while pages 3-36, 3-40 say there will be 6-10 annually. This is important for analysis of impacts from traffic and parking. At A-Basin s current CCC of 3,210, the ski area has averaged between five and ten days annually in which its CCC is exceeded (reference FEIS Table 3A-2). It is worth noting that Table 3A-2 does not include relatively busy days in which 80 to 90 percent of A-Basin s CCC was achieved, which is a common occurrence throughout the ski season on weekends. Under the Proposed Action, in which CCC increases by 22 percent, this trend is expected to continue due to improvements in lifts, terrain, parking and guest services. 9.2 If the Forest Service approves any part of the proposed improvement plan, it should insist that parking lot expansion occur before other project components are installed, as even with no increase in use, parking would remain a problem. The additional visitation expected from opening new terrain would exacerbate this problem. Analysis of all projects and disclosure of associated effects are provided in the Draft and Final EIS documents. Although within the Decision Maker s authority, Forest Supervisor Maribeth Gustafson has not included a requirement for the priority to implement individual approved projects. However, it is the intent of both A-Basin and the Forest Service to complete the parking improvements in a timely manner such that they complement the additional CCC associated with additional terrain and lift capacity. 9.3 There is not and has not been for a long time, enough parking on the hill. Even though A-Basin plans on expanding its parking by 256 spaces, is this enough once a new lift is built? Combined with previously-approved parking projects from the 1999 ROD, the parking improvement specified in A-Basin s 2006 MDPA are designed to address Purpose #4 (Increase parking capacity to meet current and anticipated demand). As noted in the Draft EIS (page 3-37) and Final EIS (page 3-42), in conjunction with previously-approved additions to vehicle capacity of the Upper Overflow lot the Proposed Action would accommodate existing use as well as the anticipated increase in frequency of peak day visitation... Total approved parking under the Selected Alternative is demonstrated in the following table. 20