Last week, the Alliance sent comments to the Town Council regarding the recent requests from Snow King Mountain Resort to update their resort master plan. We have a few concerns, highlighted in the letter below, about the process and include recommendations on how it could be run better to ensure our community has a voice. Read more below.
Jackson Town Council
June 29, 2017
Re: How to best engage our community in Snow King planning
Dear Mayor Muldoon and Town Councilors:
Thank you for the opportunity to comment on your process for involving our community in creating a new plan for Snow King. The Jackson Hole Conservation Alliance respectfully requests that you do a concurrent plan for all of Snow King – including both the ski hill Forest Service “NEPA” process and the entire “base master plan” including the KM6 parcel.
The Alliance believes we have a responsibility to write land use rules that align with our community’s vision as articulated in our comprehensive plan. This is a vision of a community with walkable neighborhoods surrounded by protected open space, working agricultural lands, and connected wildlife habitat. A community where at least two-thirds of our diverse workforce can affordably rent or purchase a safe and healthy home that meets their family’s needs.
A fully concurrent plan that engages the Forest Service, Town, Snow King Resort, and public is the best way to implement the Comprehensive Plan vision at our Town Hill. It’s clear that significant change is coming to Snow King – both the ski resort hill and the commercial resort base area. We must openly discuss not just the new improvements up on the mountain, but also the future commercial and residential development at the base. If we don’t look at the updates as a whole, we can’t analyze and judge the cumulative impacts upon our wildlife, our infrastructure, and our community.
More importantly, unless we look at the whole of Snow King all together, our community can’t help shape a positive vision for the future of our Town Hill – one of the most important parts of what makes Jackson such a great place to live and visit. Disjointed planning would be a serious missed opportunity to involve our whole community in shaping our shared future. Our community – not just the owners of the resort – should drive the vision for the future of our Town Hill. Please create a plan for the whole mountain and base concurrently.
Unfortunately, Snow King Mountain Resort has asked your approval to start a ski resort planning process with the Forest Service, without fully opening up the outdated base master plan at the same time.
Even worse, competing proposals for how to define “phases” have made the whole topic very confusing (see Appendix). But what it boils down to is that Snow King Resort wants to get permits for their uphill improvements first, and only then talk about the base area. Or, if they have to talk about the base area, the Resort wants to leave out the “KM6” parcel, which is the largest undeveloped commercial property in Teton County, with a quarter million square feet of future commercial development potential.
The only way to create a Town Hill that benefits our community in the long run is to have one single fully concurrent process that includes all of the properties at the base, as well as the Forest Service land.
What’s this new “Phase 1” topic?
Although Snow King Resort management has steadfastly resisted opening up the base master plan, they are now asking for a “Phase 1” update. This update would catch up the base master plan to recent changes that may or may not have aligned with the master plan. Also, and significantly, it would re-align property boundaries that the Resort has changed since the plan was adopted (Lots 53, 57, 58). From what we understand, these mis-aligned boundaries are currently holding up sale and construction of commercial properties of up to 150,000 square feet.
At the same time Snow King Resort is refusing to open up their master plan to allow for community input, they are asking you to let them change it in order to sell more commercial property. We do not believe that yet another piecemeal change is in the best interest of our community. Instead of giving the Resort more pieces of what they want without any community benefit in return, we ask that you do one full planning process for the whole mountain.
What about KM6?
The Resort also asked you to leave KM6 out of the planning process until everything else is done – maybe five years out. But KM6 is the largest parcel, and is the cornerstone of the entire base master plan. KM6 is where the “world-class convention center” was supposed to go, along with other commercial development. KM6 is planned for 250,000 square feet of commercial development – a quarter million square feet, the equivalent of nearly 3 new Marriott hotels, and almost half of the total development potential left for Snow King. Trying to run a “concurrent” process without the major cornerstone parcel is like ordering a banana split without the banana – it just doesn’t work.
Can we also talk about housing mitigation?
The Snow King master plan was written 17 years ago, long before the current depth of our workforce housing challenges. As a result, housing mitigation requirements at Snow King are based on the lower requirements of the 1994 Comprehensive Plan, not the current 2012 Comprehensive Plan. It’s not fair that developers at Snow King can build less workforce housing than other employers have to. After you update your housing mitigation rules for the rest of the community through the EngageJH process this year, please bring those new rules into the Snow King master plan. We recognize that the Resort may not wish to change their housing rules and lose their competitive commercial advantage. That’s why the community should maintain as much negotiating power as possible, and run just one process for all updates to Snow King.
What about reasons against a concurrent plan?
We have heard two main arguments against concurrent planning, paraphrased:
1) The Town can’t make the Forest Service engage in a joint planning process or wait for Town approval.
But the motion in the staff report says “The Phase 1 update shall be completed prior to any improvements being made under the USFS permit authorization.” That means the Town will be asking the Forest Service to wait for Town approval anyway, so why not do it concurrently? This was also done successfully in Tahoe, so we know the Forest Service is willing and able to work with local jurisdictions on concurrent plans (see below).
2) Snow King Mountain Resort doesn’t have the resources to update the base master plan.
If a homeowner wants to secure a building permit for an addition to their home, we don’t waive the permit process because they claim they don’t have the “resources” for it. If it’s worth making changes to Snow King, it’s worth doing it right.
In sum, the best way to benefit our whole community is to engage the Resort, the Town, the Forest Service, and the community in one fully concurrent planning process for Snow King – including all “phases,” updates, the base, the hill, and KM6.
Please be in touch with any questions, and as always, we thank you for your commitment to our community.
Civic Engagement Director
Jackson Hole Conservation Alliance
Tahoe example: ski resort, Forest Service, and regional planning agency concurrent process (emphasis added)
The proposed project was required to go through Tahoe Regional Planning Agency’s ten step environmental impact statement process in addition to the Forest Service review process.These reviews were conducted concurrently. …
During the Forest Service and Tahoe Regional Planning Agency process, changes were made to the proposed project. One example included an issue with a proposed coaster location. As a result of realities on the ground, Forest Service staff determined that the proposed location of the coaster was abutting a Stream Environmental Zone, bisected martin habitat and could have a negative impact on the skiing and snowboarding terrain. As a result of these findings, Forest Service staff denied the location of the proposed coaster. However, as a result of a predescribed collaborative process that was developed by the Forest Service, Heavenly and various stakeholders, the location of the coaster was changed to an area with less environmental impact. The establishment of the collaborative process at the onset was instrumental in ensuring that when problems arose they could be investigated, discussed and, if necessary, changed without adding large amounts of time to the review and permitting process. …
Following public comments and deliberation, the Tahoe Regional Planning Agency Governing Board unanimously approved the Heavenly Mountain Resort’s Epic Discovery Project.
Appendix: Comparison chart of “Phase” proposals
We have compiled this table to clarify the different proposals mentioned in the June 15 staff report. The proposals are particularly confusing because they use terms like “Phase 1” and “Phase 2” to mean different things. Hopefully this table will clarify the differences.
The June 15 staff report has two phases:
1) “Phase 1” master plan update
o Catch-up to current conditions: “amendments to the Master Plan that would bring it to date with the development on the ground today and clarify parcel boundaries within the district (e.g. Lots 53, 57 & 58)”
o Whole base area, except KM6
o USFS planning in parallel
(Construction of “improvements” may then proceed)
2) “Phase 2” = KM6
The staff report states that the May 30 Snow King Resort letter has three phases:
1) “Phase 1” = catchup but not the rest of the base
2) “Phase 2” = Phil Baux park and USFS permits & construction
3) “Phase 3” = KM6
A concurrent process would only have one planning phase:
1) Phase 1 = full base master plan + USFS
(Construction may then proceed)
|Staff report proposal||Resort proposal||Concurrent|
· Catch-up (Lots 53, 57, 58)and
· Rest of base plan (except KM6) and
· USFS plan
· Catch-up (Lots 53, 57, 58)
|Only one phase
· Catch-up (Lots 53, 57, 58) and
· Rest of base including KM6and
· USFS plan
· Base other than catch-up and KM6
· Phil Baux
|Build upper mountain “improvements”||Build upper mountain “improvements”||Build upper mountain and base “improvements”|