The Code of Federal Regulation (CFR) at 40 CFR directs the agency to discuss the direct and indirect impacts of all alternatives.

Transcription

1 Mt. Hood Meadows Parking Improvements Project Final Environmental Impact Statement (FEIS) Objection Statements and Responses Mt. Hood National Forest April 2014 Objectors Friends of Mt. Hood (FOMH) Carl Ohgren (CO) Tamara Shannon (TS) Lee Greenwald (LG) Philippe Mazaud (PM) Peter Cornelison (PC) Objection Numbers (B) (B) (B) (B) (B) (B) Master Development Plan Compliance Overview and Suggested Remedies: The objection statements focus on the language in the 1997 Master Development Plan (MDP) that limits the size of future parking at the Hood River Meadows Base Area to 8 acres, including stormwater management and snow storage. Suggested remedies are to select Alternative 4, which is within the parameters of the MDP, or to adopt a variation of Alternative 6. Objector Statement #1: Objector states that the draft Record of Decision (DROD) designated Alternative 6 as the preferred alternative and that this alternative calls for clearing 9.4 acres for parking, stormwater management and snow storage, which is more than what is authorized in the MDP and that they object to the District authorizing a project not in compliance with the MDP. FOMH at 2; PC at 1. Response: I find that the Responsible Official adequately displayed the effects of the Mt. Hood Meadows Parking Improvements FEIS, and performed site-specific environmental analysis pursuant to NEPA requirements. In addition, the Responsible Official is compliant with the Mt. Hood Meadows Master Development Plan Record of Decision (MDP), with regard to the Mt. Hood Meadows Parking Improvements Final Environmental Impact Statement (FEIS). However, for clarity, I instruct the Responsible Official to clarify that she is modifying and not superseding the MDP, before she signs her Record of Decision (ROD) for this project. The Code of Federal Regulation (CFR) at 40 CFR directs the agency to discuss the direct and indirect impacts of all alternatives. The MDP [p]rovides general direction for future development at MHM [Mt. Hood Meadows] it conceptually approves the number and approximate locations of lifts, additional ski terrain, base expansion, other winter facilities and uses, access and service roads, and summer uses. Implementation will require additional site-specific environmental analysis pursuant to NEPA requirements. MDP at 5. Page 1 of 23

2 The MDP states that [i]f adequate parking areas cannot be sited at the Main Lodge and Westside bases due to environmental and other constraints, future modifications of the Master Plan may be considered to provide additional parking at the Hood River Meadows Base. MDP at 11. The Mt. Hood Meadows FEIS is the site specific analysis required by the MDP and serves as a modification of the MDP, as allowed. MDP at 11. The desired future condition of the Winter Function and Uses portion of the MDP is to [l]imit the amount of parking authorized as a means to promote alternative transportation modes, to minimize the land area committed to development, and to respond to public and agency concerns about increased traffic congestion on US 26. MDP at 9. The FEIS outlined that the selected alternative would increase the Base Area to 47 acres, increase the Estimated Number of Vehicles to 3,509, and increase the Estimated PAOT from parking lots to 8,773. FEIS at The MDP outlined that 42 acres should be the Base Acre size, 4,600 should be the Estimated Number of Vehicles, and 12,500 should be the PAOT levels. MDP at 8; 10 through 11. "Due to the environmental limitations of the sites authorized for parking expansion, the total parking design capacity is limited to a maximum of acres. Using current vehicle occupancy figures, the 8 acres would accommodate approximately 12,500 PAOT [Persons at One Time]. To accommodate the 13,900 PAOT capacities allowed for other facilities, alternative forms of transportation will need to be utilized MDP at 10 through 11. The Responsible Official s draft decision moves the project area toward the desired future condition of the MDP by selecting Alternative 6, that is over 1,000 vehicles less than and almost 4,000 PAOT less than what the MDP authorized. The Responsible Official stated within the DROD at 8 that the selected alternative will further promote alternative modes of transportation by constructing a bus shop. In addition, Mt. Hood Meadows Ski Resort will still utilize alternative modes of transportation in order to achieve the maximum PAOT of 13,900 and continue with initiatives listed on FEIS 2-46 through 2-47, including subsidized bus and lift packages, peak parking day pricing, etc. The FEIS adequately outlined the effects of the Mt. Hood Meadows Parking Improvements Project within Chapter 3. Within Chapter 3, the Responsible Official disclosed the effects to recreation, transportation, soil productivity, water quality, aquatic wildlife, terrestrial wildlife, botany, noxious weeds, cultural resources, visuals, vegetation, air quality, and climate change. FEIS at 3-1 through In addition, the Responsible Official adequately completed the NEPA process for this project as outlined in the Consistency with the National Environmental Policy Act section (FEIS at 19) and the Public Involvement section (FEIS at 15 through 16). Within chapter 2 of the FEIS and within the DROD, the Responsible Official supplied her reasons for exceeding the conceptual parking numbers listed in the MDP and selecting Alternative 6. The Responsible Official stated that the size of vehicles has increased and the number of people traveling in the vehicles has decreased. As a result even the largest parking alternative (Alternative 3), does not meet the number of vehicles or PAOT authorized in the MDP. FEIS at The Responsible Official also stated that she selected Alternative 6 because this addressed the long-term parking need and minimized the need for visitors seeking parking in less desirable and potentially dangerous locations. DROD at 8. Page 2 of 23

3 In summary, the Responsible Official modified the MDP with site-specific NEPA as allowed by the MDP in order to address the current conditions within the project area, and achieve the desired future condition outlined within the MDP. Objector Statement #2: Objector states that the Alternative 6 approves clearing an additional 2.9 acres at the Hood River Meadows base area for parking and maintenance of buses, and that the total acres cleared in Alternative 6 for vehicle and bus parking is 12.3 acres, which is an increase of more than 50% beyond the limit of 8 acres, as stated in the MDP. FOMH at 2; PC at 1. Response: I find that the Responsible Official s draft decision complied with the MDP and adequately displayed the context and intensity of the Mt. Hood Meadows Parking Improvements Project s effects to the surrounding resources. Please see the response in Objector Statement #1 for the detailed discussion about MDP compliance concerning the Twilight Parking Lot and how the bus shop will aid in achieving the desired future condition of the MDP. In addition, Objector Statement #1 described where the Responsible Official adequately stated the effects of the project. The MDP does not provide specific guidance on constructing alternative modes of transportation facilities (i.e. the bus shop). However, it does clearly promote the use of alternative modes of transportation. MDP at 9. The Responsible Official stated in the DROD at 8 that the selected alternative will further promote mass transit in the project area, aligning the Mt. Hood Meadows Parking Improvements Project with the MDP. The Responsible Official stated that the Mt. Hood Meadows Parking Improvements Project is consistent with required laws and regulations and displayed this discussion within the DROD at 16 through 19 and within the FEIS at Objector Statement #3: Objector believes that the Scoping Notice mistakenly states that the proposed parking was authorized in the MDP. This is in direct conflict with the requirements of the MDP. The Forest Service s statement that the existing MDP authorizes the proposed expansion at the HRM base area is incorrect and disregards the plain language of the Master Plan itself regarding both the location and size of the authorized parking expansions. PC at 1. Response: I find the Responsible Official prepared and distributed an appropriate scoping notice for the Mt. Hood Meadows Parking Improvements Project. This scoping notice adequately displayed the context and intensity of the project. The regulation at 40 CFR outlines NEPA s requirements for scoping. In addition, the regulation at 36 CFR 220.4(c)(5)(e) outlines the agencies responsibility during the scoping process. The Mt. Hood Meadows Parking Improvements Project s scoping documents meet the regulatory requirements for scoping because the scoping documents gave the public adequate information to understand the scope and intensity of the proposed action. Objection Record, Scoping Letter at 1 through 5. Page 3 of 23

4 In addition, the June 29, 2011 Scoping Letter states that [t]he additional parking was authorized in the Master Plan (ROD page 10). Objection Record, Scoping Letter at 1 through 2. According to the letter, this statement was in context of the March 2009 proposal from MHM, which as stated in the letter is a request from MHM to the Forest Service to consider a proposal, to build a new 8 acre parking lot. Objection Record, Scoping Letter at 1 through 2. In this specific context, the parking is aligned with the MDP. MDP at 10. The scoping letter goes on to describe the proposed project, giving the public adequate information about the context and intensity of the project. Objection Record, Scoping Letter at 2 through 4. See response to Objection Statement #1 for the detailed discussion about MDP compliance and the selected alternative. Final Remedies/Resolution: I understand the objectors concerns about consistency between the MDP and the Mt. Hood Parking Improvements Project. I would like to assure the objectors that the Parking Improvements Project is consistent with the desired future condition of the MDP and is aligned with their concerns of increasing alternative modes of transportation, as expressed during the objection resolution meeting. I understand that not all public concerns can be overcome; however, I find that the draft decision balances public concerns and minimizes environmental effects, while aligning with the desired conditions discussed in the MDP. In an effort to reduce confusion and respond to consistency concerns with the MDP, I instruct District Ranger Janeen Tervo to clarify that the Mt. Hood Meadows Parking Lot Improvements Project modifies the MDP in the Final Record of Decision and in the errata for the FEIS. Sunrise Lot Overview and Suggested Remedies: The objection statements focus on what objectors say is an agreement between their organization and Mt. Hood Meadows to build the maintenance facility adjacent to the Sunrise Lot, and that this was rejected by the District. Suggested remedies are to adopt Alternative 2 for the Sunrise Lot. Objector Statement #4: Objector states that they object to the Forest Service refusal to approve design of the Sunrise Lot that was set forth as the applicant s proposed alternative (#2) and that they have worked with Mt. Hood Meadows to establish and maintain a collaborative relationship with regards to upcoming projects. The two organizations discussed the Sunrise Maintenance facility many times. Through that process, Mt. Hood Meadows and FOMH came to agreement that the Sunrise facility could and should be built adjacent to the existing Sunrise parking lot as opposed to on top of the knoll to minimize the need for new roads and further tree clearing, as well as to limit the significant visual impacts of the facility from higher up on Mt Hood. FOMH at 2 and 3. Objector states that the potential for the maintenance facility to add measurable amounts of sediment into Mitchell Creek is speculative and uncertain, and that the effects of tree clearing on the bluff would be more substantial to visual quality objectives. FOMH at 3. Page 4 of 23

5 Response: I find the Responsible Official appropriately analyzed all alternatives and supplied an adequate rationale for selecting Alternative 6. She selected Alternative 6 over the original proposed action alternative (Alternative 2) for environmental reasons, including potential effects to water quality. The Responsible Official has the responsibility and authority to weigh environmental concerns as well as public comments and collaboration to attain the widest range of beneficial uses to the environment without degradation, or other undesirable and unintended consequences. 42 USC 4331 Sec 101(b)(3). The proposed action may be, but is not necessarily, the agency s preferred alternative. The proposed action may be a proposal in its initial form before undergoing analysis in the EIS process. The agency may decide at the Final EIS stage, on the basis of the Draft EIS and the public and agency comments, that an alternative other than the proposed action is the agency's "preferred alternative." (Council on Environmental Quality, 40 Most Asked Questions Concerning NEPA Regulations). The regulation at 36 CFR defines the Responsible Official as the one who has the authority to make and implement a decision on a proposed action. The FEIS stated that Janeen Tervo, District Ranger for the Hood River Ranger District, is the Responsible Official. The FEIS at 1-16 through 1-17 outlined the decision framework in which the Responsible Official used to make her decision. She explained the rationale behind her selection of Alternative 6 within the DROD. The Responsible Official selected this alternative because it minimized public concerns and reduced environmental consequences further than any other alternative, especially when considering the impacts to water quality and Riparian Reserves. DROD at 7 through 10. Specifically, the rationale for not selecting Alternative 2 was detailed in the DROD at 9. The Alternative 2 maintenance shop location adjacent to the Sunrise Parking Lot was not selected because of the increased risk of sedimentation due to snow removal limitations in the Sunrise Parking Lot footprint. DROD at 9 and 12. The current Sunrise Parking Lot is bounded on 3 sides by a stream and wetlands, which add to the sensitivity of location. FEIS at The existing infrastructure including the stormwater treatment facility was originally designed to accommodate the Sunrise Parking Lot, so the ability of the facilities to handle the additional load from the maintenance shop is unknown. FEIS at 3-67 through The Alternative 2 location had a moderate risk for increased sedimentation, compared to a low risk of the selected alternative. FEIS at Concerns over sediment introduction to surface water from traction gravel application and snow removal activities at the Sunrise Maintenance shop were eliminated in Alternative 6 by moving the new shop s location away from Mitchell Creek (over 500 feet) and the East Fork Hood River (300 feet) so project design criteria and best management practices that include treatment of stormwater would effectively keep this material out of surface water. FEIS at 2-25 through 2-26, 2-28 through 2-29, and 3-77; DROD at 9 through 10 and 12. The water quality analysis and all other resources in Chapter 3, including vegetation management, analyzed the impacts of removing the trees at the Alternative 2 locations. FEIS at 2-36 through 2-41, 3-64 through 3-73, 3-9 through 3-27, 3-52 through 3-58, through 3-127, through 3-169, through Page 5 of 23

6 3-185, through 3-196, through 3-201, through 3-211, through 3-216, through 3-221, and The effects of the Sunrise Maintenance Shop location submitted to the Forest Service by Mt. Hood Meadows Ski Resort was adequately analyzed and considered in regard to water quality and sediment under Alternative 2. The Alternative 6 location of the Sunrise Maintenance Shop was also fully analyzed and considered in regard to water quality. With regard to the objector s statement that potential for construction of the maintenance facility to add measurable amounts of sediment into Mitchell Creek is speculative and uncertain, the FEIS stated "... the potential for increased sedimentation into Mitchell Creek has nothing to do with construction activities and the proposed location of the Sunrise Vehicle Maintenance Shop. The shop would be located across the parking lot from Mitchell Creek and erosion control during and after construction as outlined in the PDC would eliminate the possibility that sediment would enter Mitchell Creek as a result of the maintenance shop construction." The concerns associated with the proposed maintenance shop location in Alternative 2 are related to snow removal and stormwater treatment. FEIS at 3-67 through 3-68 and Appendix B-12. In addition, the FEIS stated that "Once the maintenance shop is built, however, it is anticipated that snow removal strategies currently used would change so that snow is not blown or stored along the northern edge of the parking lot where the new Sunrise Vehicle Maintenance Shop would be located. This would result in more snow, and any associated gravel and/or soil, being blown or pushed and stored along other edges of the parking lot, including the southern edge that borders Mitchell Creek. The maintenance shop would also increase the overall amount of snow that would need to be treated in the Sunrise lot since it would increase the overall footprint by 1.8 acres or approximately 25 percent." FEIS at 3-67, Appendix B -12. Additionally, presence and use of potential pollutants associated with the maintenance shop including lubricants, chemicals, solvents and petroleum products would increase considerably due to the nature of the work that would occur in the shop. Having these pollutants adjacent to three aquatic features increases the potential to introduce these chemicals during snow plowing activities, especially since the remaining snow storage sites are on or adjacent to the aquatic features. The impacts of the Sunrise Maintenance Shop locations to water quality, including the impacts associated with the recent paving, are fully analyzed and disclosed. FEIS at 3-64 through Effects to visual quality with regard to the proposed locations of the maintenance shop were fully analyzed for all alternatives. FEIS at through Project design criteria in relation to visual quality were developed and would be implemented in order to decrease impacts to this resource. FEIS at 2-27 through 2-28; DROD at 33 through 34. The analysis found that the impacts were the same for all action alternatives, (the VQO of Partial Retention would be met for all areas of concern) regardless of location. FEIS at 206 through All alternatives were found to be compliant with direction in the Forest Service Manual 2300, Chapter 2380 Landscape Management, , Mt. Hood National Forest Land and Resource Management Plan (Forest Plan) standards and guidelines, and the MDP. FEIS at The Interdisciplinary Team analyzed the impacts associated with the access roads for each alternative, and differences were disclosed in the FEIS. FEIS at 2-36 through 2-37, 3-64 through Page 6 of 23

7 3-73, 3-9 through 3-27, 3-52 through 3-58, through 3-127, through 3-169, through 3-185, through 3-196, through 3-201, through 3-211, through 3-216, through 3-221, and Final Remedies/Resolution: I find that District Ranger Janeen Tervo thoroughly analyzed Alternatives 2 and 6 and displayed a sound rationale for her decision to select Alternative 6. Thus, I find that no remedy or resolution as suggested by objectors is needed. User Experience/Safety Overview and Suggested Remedies: The objection statements focus on the user experience at Mt. Hood Meadows. The objectors believe that it is already too crowded at Mt. Hood Meadows and that the crowds create safety hazards for users. The objectors believe that more parking will result in more overcrowding and safety issues for skiers. While the objectors did not suggest a specific remedy, they appear to support the no action alternative. Objector Statement #5: Objector states that the District needs to reduce parking so that the number of skiers on the hill at any time is reasonably proportional to the available terrain. CO at 2. Objector explains that At Mt. Hood Meadows lift lines will be backed up and the same time there are many skiers on their runs, even though the parking lots are not even full. Because of the way trails intersect and the mixed up and down terrain there are many trail intersections that create hazards for the patrons of Meadows. This problem is already present and will become worse when you bring in more people. CO at 2. Response: I find the Responsible Official s decision to expand the Mt. Hood Meadows Ski Resort parking area was made in accordance with existing Forest Plan desired future condition and will not result in visitation levels that exceed the winter designed capacity established in the MDP for lifts, groomed ski trails, and skier service facilities. Effects to downhill skiing are fully disclosed in the FEIS. The Council on Environmental Quality s implementing regulations for the National Environmental Policy Act requires the agency to determine the underlying purpose and need to which the agency is responding. 40 CFR The Forest Plan identified the desired future condition of this project s A11 land allocation as to provide areas for high quality winter recreation opportunities, including downhill skiing. Expanding the winter recreation parking area would help to achieve the following major characteristics for the land use allocation - high quality winter recreation activities such as downhill skiing, and access by improved Forest Roads suitable for passenger cars. FEIS at The impacts to downhill skiing were fully analyzed and disclosed in the FEIS, Section 3.1. EIS at 3-4 through The analysis considered the skiable areas, uphill lift capacity, and PAOT. FEIS at 1-7 through 1-8; 3-5 through 3-6; 3-9 through 3-11; 3-14; 3-16; 3-19; 3-22 through 3-23; PAOT for winter use was established and authorized within the MDP and is defined as a quantified number of individuals that could be using the facilities at Mt Hood Meadows Ski Resort at the same time. MDP at 9; FEIS at 3-6. The FEIS stated that Alternative 6 would Page 7 of 23

8 produce a PAOT level of 8,773, well below the target amount of 12,500 PAOT from parking lots authorized in the MDP. MDP at 10 through 11; FEIS at 3-22 through 3-24 and The Mt. Hood Meadows Ski Resort capacity was considered in the cumulative effects analysis for downhill ski area operations, disclosing that "[g]eneral on-going ski area activities combined with an increase in parking capacity at MHM could potentially increase overcrowding at the resort and result in increased lift lines and demand on visitor facilities. Peak use days generally correspond with major snow events. Occasionally, large winter snowstorms increase potential avalanche dangers within the resort boundary to the point that MHM cannot open all of the existing lifts. During these times the additional patrons able to access the resort (due to an increase in parking capacity) would be restricted to lifts open for operation. The overlap of these two events could have an effect on downhill ski area operations. The Stadium Lift realignment and the Buttercup Lift improvements would help to alleviate some of the congestion by improving lift services at the resort." FEIS at The FEIS also stated that although it is unknown how much longer lift line times would be with the additional proposed parking capacity, and that times would vary depending on several factors, it is known that the uphill lift capacity at Mt. Hood Meadows Ski Resort is 16,145 people per hour when all lifts are running, which is higher than the MDP authorized maximum 13,900 PAOT (13,100 alpine and 800 Nordic). FEIS at With regard to the objector's comments about trail intersections creating hazards for the patrons, the estimated visitation levels would not exceed the winter designed capacity established and authorized in the MDP for lifts, groomed ski trails, or skier service facilities. FEIS at The expanded parking would service an already existing demand as evidenced by skiers choosing to park on the access roads. FEIS at 1-4 through 1-5; DROD at 4. Enforcement of the No Parking policy on the access roads as outlined in project design criteria R-1 through R-4 would improve the overall safety of those using the ski area. The DROD noted that the project design criteria are a required and integral part of this project. FEIS at 2-25 and 2-27; DROD at 5 and 32 through 33. Objector Statement #6: Objector states that the real safety concern is crowded slopes. Objector states that the PAOT in the MDP was based on just skiers, not snowboarders, and that skiers and snowboarders colliding has been a major cause of injuries and accidents. The objector believes that the PAOT needs to be recalculated downward and that increasing parking would exacerbate the overcrowding issue. LG at 1. Objector states that the District must clearly articulate and disclose to the public any data supporting a need to expand parking well beyond the MDP limitations to serve 13,900 PAOT, and should disclose whether Mt. Hood Meadows Ski Resort could accommodate more than the 13,900 PAOT with the new parking infrastructure (which would appear to be an unauthorized expansion of the PAOT as set by the MDP). PC at 1. Response: I find that the Responsible Official adequately displayed the impacts of the Mt. Hood Meadows Parking Improvements Project and the selected alternative meets the purpose and need of the project. In addition, the Mt. Hood Meadows Parking Improvements Project will not increase PAOT over what is authorized in the MDP. Page 8 of 23

9 The regulation at 40 CFR directs the agency to discuss the direct and indirect impacts of all alternatives. In addition, the regulation at 40 CFR directs the agency to briefly specify the underlying purpose and need to which the agency is responding to. The need as stated in the DROD and FEIS was to provide additional parking within the MHM permit area, and that this need for expanded parking is also supported by the need to improve traffic flow and public and customer safety along the access routes as well as within the Main Parking Lot. Safety within the Mt. Hood Meadows Ski Resort was not identified as a part of this project s purpose and need. FEIS at 1-5 through 1-6; DROD at 4. The need for additional parking was identified and authorized in the MDP. MDP at 10 through 11; FEIS at 1-7 through 1-8; DROD at 5. The need for action was based on the existing conditions that current parking facilities are often filled to capacity. FEIS at 1-10 through 1-11; DROD at 3 through 4. PAOT is stated as a quantified number of individuals that could be using the facilities at [Mt. Hood Meadows Ski Resort] at the same time. FEIS at 1-4 and 3-6. The MDP established the design capacity of 13,900 PAOT for lifts, groomed ski trails, and skier service facilities. The MDP further states that PAOT capacity encompasses all users, including Nordic skiers (800 PAOT) and non-skiers. The MDP continues on to state that the authorized winter use capacity, numbers of ski lifts, acres of ski trails, etc. represent design capacities, rather than targets for development. It is possible that environmental and other considerations may necessitate lower levels of development. MDP at 9; FEIS at 3-6. The impacts to downhill skiing were fully analyzed and disclosed in the FEIS, Section 3.1. FEIS at 3-4 through The analysis considered the skiable areas, uphill lift capacity, and PAOT. The FEIS recreation analysis stated that MHM is currently operating within the designed capacity of 13,900 PAOT as authorized within the MDP. FEIS at 3-6. The analysis of Alternative 6 showed that the PAOT would be below the authorized amount in the MDP and disclosed the impacts of that use. FEIS at 3-10 through 3-11 and The response to Objector Statement #5 further discusses overcrowding. Final Remedies/Resolution: I understand objector s concern about overcrowding within the Mt. Hood Meadows Ski Resort and how the Mt. Hood Meadows Parking Improvements Project might influence that. In reviewing the recreation analysis within the FEIS, Section 3.1 and having an understanding that the MDP set a capacity level of PAOT, I find that the District Ranger s Janeen Tervo provided appropriate rationale for her selection of Alternative 6. Thus, I find that no remedy or resolution as suggested by objectors is needed. Purpose and Need/Range of Alternatives Overview and Suggested Remedies: The objection statements focus on the need for the project and the range of alternatives. The objectors question why the project is needed, given what they perceive as a minimal need for parking for just a few hours on peak days. Suggested remedies include not building the parking lot and examining other alternatives to disperse users. The objector also believes that not enough options were considered to avoid building parking. Page 9 of 23

10 Specific remedies include considering the ideas that they had already suggested, including providing texting or service to let users know when lots were full, offering early bird lift opening on peak days, putting up a reader board in Sandy and Parkdale to notify users that the lots are full, and creating and encouraging half day passes for peak days to disperse users. Objector Statement #7: The objector states that the need for parking was vastly overstated and that not only are there just a few peak days where parking is an extreme issue, but it is only for an hour and a half! PM at 1; TS at 1. The objector quotes the FEIS, which states that On the peak use days, the parking lots are totally full generally between 9:30 and 11:00. Antidotal evidence shows that approximately 250 cars are turned away on these peak days. The objector believes that much more could be done to address this short infrequent need. TS at 1; LG at 2; PM at 1. The objector believes that growth in alpine skiing will not occur as projected and that the creation of the Twilight lot will impact Nordic skiers, which is where the growth is really occurring. LG at 1. Response: I find the Responsible Official adequately displayed the need for the project and the effects to Nordic skiers. The regulation at 40 CFR directs the agency to discuss the direct and indirect impacts of all alternatives. In addition, the regulation at 40 CFR directs the agency to briefly specify the underlying purpose and need to which the agency is responding to. Both the DROD and FEIS state: "On the peak use days, the parking lots are totally full generally between 9:30 and 11:00." DROD at 3; FEIS at 1-4. A discussion with the interdisciplinary team during my review clarified that once the parking lots are full (between 9:30 and 11:00), they remain full for the remainder of the day. As such, the parking lots are full for the majority of the day and not just for an hour and half. Throughout the day, approximately 250 cars are turned always on these peak days. FEIS at 1-4. The FEIS utilizes data and anecdotal evidence that has been collected over the past years. This included historic and projected skier use data, anecdotal evidence, and informal monitoring. FEIS at 1-4. Section 3.1 of the FEIS displays the project s parking capacity, demand, and PAOT in the recreation section. Section 3.2 of the FEIS displays transportation monitoring reports completed by ODOT and private contractors at Mt. Hood Meadows Ski Resort. This information was used to establish the need and develop six action alternatives that were analyzed in detail. In addition, five additional alternatives were considered but not analyzed in detail. Alternative 1, the No Action Alternative was fully analyzed in the FEIS. This alternative represents the current conditions and the parking lot would not be constructed. Also, a Mass Transit Alternative was considered, but eliminated from detailed study. FEIS at This alternative would use mass transit and alternate forms of transportation to improve public and customer safety and improve traffic flow at Mt. Hood Meadows Ski Resort by reducing the number of vehicles parked there at any time, rather than building another parking lot. This alternative was not analyzed in detail because it is outside the scope of this project and alternative forms of transportation are already required and being utilized by Mt. Hood Meadows Ski Resort. FEIS at Page 10 of 23

11 The MDP authorized 13,900 PAOT with parking to accommodate 12,500 PAOT. The MDP states, "[t]o accommodate the 13,900 PAOT capacities allowed for other facilities, alternative forms of transportation will need to be utilized, i.e., increased carpooling, increased busing, mass transit. MDP at 11. The FEIS stated, "[b]ased on this management direction, MHM is required to continue using and growing alternate forms of transportation in order to reach the PAOT authorized in the Master Plan. FEIS at The FEIS continues on to provide examples that Mt. Hood Meadows Ski Resort was implementing for the ski season. FEIS at The FEIS displayed the visitation statistics for Mt. Hood Meadows Ski Resort; the trend was developed and the assumptions were based on site-specific information. FEIS at 1-4. The FEIS stated, [s]ince opening in 1967/68, the number of skier visits has grown from 55,564 to over 500,000. During the 1970s the average annual rate of growth was twice the Oregon average at 4.6 percent. From 1984 to 1989, the average annual rate of growth has been 2.14 percent, with an annual average of 325,000 skier visits. During the ski season, the number visitations at MHM peaked at over 500,000 visits. The 10-year average for annual visitation from was 409,514 and the three year average from was 441,108 visits. FEIS at 1-4. The FEIS went on to state, Based on this trend, use of the ski area is expected to continue to increase. FEIS at 1-4. The FEIS displayed the impacts to Nordic skiing within the project area. The FEIS stated, [a]pproximately, 0.5 miles (2,746 feet) of Nordic ski trails would be removed to allow for the additional parking. Portions of the Lower Hanel Loop Trail (intermediate) and the Little Loop trail (easiest), and the Beargrass Loop (easiest) would be affected. New Nordic trails would be constructed resulting in a net gain of 0.1 miles (686 feet) of additional Nordic ski trail. FEIS at The FEIS also stated, [w]hile the location of trails would be moved from their current location, the Nordic skier experience of traversing over undulating terrain would remain the same. FEIS at The FEIS acknowledged that impacts will occur due to the proposed changes, but mitigates those impacts with project design criteria. FEIS at Objector Statement #8: Objector states that the need for parking with regard to safety concerns and illegal parking is faulty. The objector believes that the illegal parking is a law enforcement issue that has not been addressed (towing or ticketing) and that if it were addressed, word would get out and the illegal parking situation (and as such, safety concern) would be resolved. LG at 1. Response: I find the Responsible Official adequately displayed the need for the Mt. Hood Meadows Parking Improvements Project. This was bolstered by considering a range of alternatives that was adequate to respond to the purpose and need and the issues identified during scoping. In addition, Oregon State or Forest Service law enforcement actions are beyond the scope of this project. See response to Objector Statement #7 for a detailed discussion about the range of alternatives, the purpose and need of this project, and how the Responsible Official adequately displayed the need and alternatives in her supporting documents. Page 11 of 23

12 In addition to the response in Objector Statement #7, the purpose and need states, "[b]ecause parking facilities at MHM are often filled to capacity, there is the need to provide for additional parking within the MHM permit area. This need for expanded parking is also supported by the need to improve traffic flow and public and customer safety along the access routes (i.e., FSR 3545 and Highway 26) to the MHM as well as within the Main Parking Lot. DROD at 4. The purpose and need explains that the safety concerns result from both parking along these access roads and people walking along the roads. The FEIS states, "[w]hen parking facilities are filled to capacity at the ski area, customers choose to park along the access roads to both the Main Parking Lot (FSR 3555) and to the Hood River Meadows Parking Lot (FSR 3545), Highway 35, as well as Sno-Parks located near Nordic ski trails along Highway 35. Previously, approximately 440 cars parked along the access roads on peak days. Parking along the access roads and the highway, however, creates an unsafe situation when people are walking along these roads to reach the shuttle pick-up points. Also, as people park along the Hood River Meadows access road (FSR 3545) and highway, the northbound and southbound traffic on Highway 35 is slowed, and at peak ski traffic times, temporarily stopped due to traffic waiting to turn across the southbound lane onto the access road. This congestion created by the traffic can limit ingress and egress by emergency vehicles and shuttle buses, constrain the ability for snow plow equipment to operate safely and effectively, and limit driver line-of-sight along Highway 35. Parking along the access roads within the Permit Area is not allowed under MHM special use permit. FEIS at 1-5. Project design criteria R1 through R4 within the FEIS are focused on managing parking, mitigating parking in unauthorized areas, and mitigating congestion during peak periods to the extent possible. FEIS at Objector Statement #9: Objector states that the District did not consider options that would avoid building parking, including the options they suggested, such as providing texting or service to let users know when lots were full, offering early bird lift opening on peak days to consolidate parking, putting up a reader board in Sandy and Parkdale to notify users that the lots are full, and creating and encouraging half day passes for peak days to disperse users. TS at 1 and 2; PC at 1. Response: I find the Responsible Official considered a range of alternatives that was adequate to respond to the Purpose and Need and the issues identified during scoping. As documented in the DROD, the District Ranger considered 11 alternatives, including six that were analyzed in detail. DROD at 10. These included a No-Action alternative and a Mass Transit alternative that addressed the objectors suggestions. Alternative 1, the No Action Alternative was fully analyzed in the FEIS. This alternative represents the current conditions without constructing the parking lot. Also, a Mass Transit Alternative was considered, but eliminated from detailed study. FEIS at This alternative would use mass transit and alternate forms of transportation to improve public and customer safety and improve traffic flow at Mt. Hood Meadows Ski Resort by reducing the number of vehicles parked there any time, rather than building another parking lot. This alternative was not analyzed in detail because it is outside the scope of this project and alternative modes of Page 12 of 23

13 transportation are already required and being utilized by Mt. Hood Meadows Ski Resort. FEIS at The MDP authorized 13,900 PAOT with parking to accommodate 12,500 PAOT. MDP at 9 through 11. The MDP states, "[t]o accommodate the 13,900 PAOT capacities allowed for other facilities, alternative forms of transportation will need to be utilized, i.e., increase carpooling, increased busing, mass transit. MDP at 11. The FEIS at 2-35 incorporated the traffic monitoring program stated within the MDP into the project. In addition, the Responsible Official stated within the FEIS that Mt. Hood Meadows Ski Resort will continue implementing initiatives that intend to significantly reduce peak-use parking days. FEIS at 2-46 through 47. Objector Statement #10: Objector states that in the event that the District does not consider her ideas or that if they are implemented, but don t disperse users and a parking lot is built, she states that the lot should be a multi-storied lot in the main parking lot to save on plowing, concentrate users, reduce shuttle needs, protect resources, and concentrate traffic. TS at 2. Response: I find the Responsible Official adequately considered a range of alternatives that responded to the Purpose and Need of the project and the issues identified during scoping. As documented in the Draft ROD, the District Ranger considered eleven alternatives, including six that were analyzed in detail. Draft ROD at 10. Looking through the objector s previous comments on this project (within the scoping and comment periods), I was not able to find comments that suggested this alternative before the objection period. This does not allow the Responsible Official adequate time to potentially create a specific alternative that incorporates the objector s suggestion. However, the objector s concerns about plowing, concentrating users, reducing shuttle needs, protecting resources, and concentrating traffic are all addressed in the 11 alternatives that the Responsible Official did consider. See response to Objector Statements #7-#9 for further detail about pertinent regulation and how the Responsible Official adequately analyzed Alternative 1 and the Mass Transit Alternative. Alternatives 3 and 4 addressed the objector s concerns about parking lot size, parking density and location because the proposed Twilight Parking Lot is the largest in Alternative 4 (concentrating parking) and the smallest in Alternative 3 (reducing resource impacts). Alternatives 3 and 4 were described in the FEIS at 2-7 through 2-11 and FEIS at 2-12 through 2-17, respectively. In addition, these alternatives were analyzed throughout Chapter 3 of the FEIS. Objector Statement #11: Objector states that the District needs to take another look at her compromised lot location alternative because she moved the location to be adjacent to the state sheds while still preserving the existing high quality ski trails and consolidating paved areas and that since wetlands are going to be relocated for the turning lane off of the 3545 Road, they could also be relocated for the parking area. TS at 2. Response: I find the Responsible Official adequately considered a range of alternatives that responded to the Purpose and Need and the issues identified during scoping. As documented in Page 13 of 23

14 the DROD, the Responsible Official considered 11 alternatives, including six that were analyzed in detail. DROD at 10. These included the Bear Grass Loop Parking Lot alternative, which included the objector s compromised lot location. The regulation at 40 CFR states that an agency preparing an EIS shall assess and consider comments both individually and collectively, developing and evaluating alternatives not previously given serious consideration by the agency. The compromised lot location was considered, but eliminated from detailed study. FEIS at The Bear Grass Loop Parking Lot Alternative was given consideration and the responsible official gave her rationale for not considering this alternative further. FEIS at The FEIS disclosed additional issues with this alternative, beyond the wetland issues. For example, the proximity to Clark Creek would raise geomorphic and hydrologic concerns. FEIS at 2-44 through The proposed compromised lot location alternative was designed to mitigate impacts to the Nordic trail system, which is duplicative to alternative 4 and 5, which were considered in detail. FEIS at In addition, the compromised lot location alternative would cause unnecessary environmental harm. FEIS at Given these two points, the compromised lot location alternative was not considered further. FEIS at Objector Statement #12: Objector states that he previously suggested an alternative that would have used the Oregon Department of Transportation (ODOT) gravel barn as the new parking and Nordic area with just a small expansion and that it would easily accommodate 400 cars to alleviate the illegal parking. LG at 1; PC at 1. Objector also suggested ways to create low impact connector trails for Nordic skiers. Objector states his alternative was discounted for various bureaucratic reasons. LG at 1 and 2. Response: I find that the Responsible Official adequately considered a range of alternatives that responded to the project s purpose and need and the issues identified during scoping. As documented in the DROD, the Responsible Official considered 11 alternatives, including six that were analyzed in detail. DROD at 10. These included the Oregon Department of Transportation (ODOT) Maintenance Yard alternative, which was based on the objector s Oregon Department of Transportation (ODOT) gravel barn alternative. FEIS at The regulation at 40 CFR states that an agency preparing an EIS shall assess and consider comments both individually and collectively, and shall respond by one or more of the means listed in regulations. One of the means listed includes developing and evaluating alternatives not previously given serious consideration by the agency. Within the FEIS, the Responsible Official considered and appropriately eliminated the ODOT gravel barn or the ODOT Maintenance Yard Alternative from detailed analysis. The FEIS stated, [i]n order to implement this alternative, the use at this site as ODOT maintenance yard would need to be terminated. ODOT has made no indications that this site is no longer needed for winter operations. Similarly, the Oregon Nordic Club special use permit would need to be terminated at this site and they have made no indications that this site is no longer needed. Also, Page 14 of 23

15 the MHM permit area boundary would have to be expanded to include the entire ODOT maintenance yard as well as the surrounding area needed for proper storm water management and snow removal associated with parking lots in order to implement this alternative. FEIS at The FEIS went on to state that [t]erminating special use permits does not meet the purpose and need for action for this project. The primary purpose of this project is to serve the design capacity for parking, including area for snow storage, and maintenance facilities that was conceptually approved while minimizing environmental impacts from parking lot construction and maintenance, as was outlined in the Master Plan in 1997 Also, relocating these uses to other areas of the Forest and/or expanding the MHM permit area to accommodate the parking lot is outside the geographic scope of the project. The geographic scope of the project includes the Mt. Hood Meadows Ski Resort permit area and access road to the permit area As such this alternative is outside the scope of this project and was not considered in detail. FEIS at The FEIS stated, there is the need to provide additional parking within the MHM permit area. This need for expanded parking is also supported by the need to improve traffic flow and public and customer safety along the access routes (i.e., FSR 3545 and Highway 26) to MHM as well as within the Main Parking Lot. The need for additional parking was identified in the ROD for the Master Plan (page 10). The need for new maintenance facilities also was identified in the ROD for the Master Plan (page 9). Therefore, the primary purpose of this project is to serve the design capacity for parking, including area for snow storage, and maintenance facilities that was conceptually approved while minimizing environmental impacts from parking lot construction and maintenance, as was outlined in the Master Plan in FEIS at 1-5. Thus, the addition of connector trails was outside the scope of this project. Final Remedies/Resolution: Objectors brought up many innovative ideas to address the need to provide additional parking within the Mt. Hood Meadows Ski Resort. In looking over the Objection Record and in dialogue with the Interdisciplinary Team and District Ranger Janeen Tervo, I recognize that an enormous amount of energy has been put into looking into these innovative ideas. For example, during the objection resolution meeting several individuals urged the Forest Service to look into Joe s proposal, which would remove fingers in the existing parking lot and extend the main parking lot. District Ranger Janeen Tervo and her resource specialists gave the proposal another look and made sure they appropriately considered all aspects of this proposal. As they have documented, Joe s proposal was found to raise substantial issues concerning effects to northern spotted owl nesting areas and to cultural, recreational, and aquatic resources. Objection Record, HRM Expansion Consideration (April 2014). In conclusion, I find that District Ranger Janeen Tervo s thorough analysis of numerous alternatives for this project more than complies with the NEPA. In order to make sure that the need for this project is clearly understood, the Responsible Official will clarify in the Final ROD and in the errata to the FEIS that once parking lots are full (between 9:30 and 11:00 am), they remain full for the remainder of the day. Page 15 of 23