We are extremely disappointed that the Forest Service is short-circuiting a fair process for reviewing harmful development proposed by the investors at Snow King, and failed to study the reasonable range of alternatives required under the National Environmental Policy Act.
Other than the no-action alternative, which we all know is just there as a formality, every “alternative” in the Draft Environmental Impact Statement (DEIS) is identical in all substantive ways – and they all ignore clear impacts on wildlife and our community.
All so-called “alternatives” include:
- Massive boundary expansions, a new road, and unnecessary ski runs bulldozing wildlife habitat to the east (all the way to Ferrin’s slide in key northern goshawk habitat) and to the west (up to the existing winter wildlife closure on Josie’s)
- The misguided and unsafe idea to send beginners down a road that traverses steep icy slopes like Bearcat and Elk (imagine an out-of-control skier sliding down Bearcat into a group of kids on the road)
- Building a chairlift on the backside and expanding into important wildlife winter range in Leeks Canyon, for the dubious plan of skiing on icy windblown southern slopes
- Bulldozing the historic Panorama House and building a 20,000-25,000 sf building on the ridgeline
- Ziplines from the summit to the base (or to another zipline from Rafferty to the base)
- An ill-defined “wedding venue” on the ridge.
Even worse, the ironically-named “resource protection alternative” would move ski runs from the S-chutes squarely into northern goshawk habitat and add a ski run on Scotty’s Ridge – right next to the wildlife winter closure. A true “resource protection” alternative like we proposed would build things our community wants (like a lift / gondola) within the current operating footprint, and protect lands and wildlife everywhere else.
The DEIS ignores the significant time and effort our community has given to creating a vision for Snow King that supports its future and enhances what we love about our town hill. It blatantly ignores clear requests for alternatives from Jackson Town Council, the Teton County Commission, Wyoming Game and Fish Department, the American Avalanche Institute, and the US Fish and Wildlife Service (see below). And it includes proposals that our community vociferously rejected and that the investors supposedly backed off, like a top-to-bottom zipline into Phil Baux Park.
The DEIS should have included and analyzed a reasonable range of obvious alternatives:
- Switchbacking a new road up inside the current boundaries – an option Snow King’s own engineering firm vetted and presented (see below) – instead of massive boundary expansions into important wildlife habitat
- Protecting – not developing – important wildlife habitat in Leeks Canyon
- No ziplines
- Reasonable development at the top, such as by retrofitting the historic Panorama House to serve as a restaurant/bar.
These alternatives would meet our community’s goals for a successful Snow King without destroying what we love about it. Unfortunately, the Forest Service and their Utah-based consultant didn’t even try to imagine real alternatives to what the developers are proposing.
Refusing to study a reasonable range of alternatives for full analysis at this stage makes a mockery of the environmental review process required under NEPA and makes it impossible for our community to have a fair discussion about the future of our Town Hill.
It’s too bad that the Forest Service tried to rush this review without a fair and full analysis, as the end result may be that they have to start over and do it right, after wasting a year of everyone’s time with this flawed process.
We believe a better outcome is possible for Snow King than what the current investors are pushing, and we believe our community deserves to see a full and fair analysis of reasonable options.
Please tell the Forest Service what you think here, or come to our workshops at 685 S. Cache about how to write effective comments:
- Thursday, February 27 at 12pm
- Tuesday, March 3 at 5:30pm
Diagram from SE Group showing a variety of alternative road alignments, including alternatives fully within current boundaries. The Forest Service should have included these as alternatives in the DEIS:
Town of Jackson scoping comments, October 1, 2018 – excerpt:
Regarding the proposed action, the Town of Jackson asks that the environmental analysis address impacts of each proposed element on wildlife and habitat and provide alternatives, particularly for the boundary expansions and facilities proposed on the summit. … Of further concern are the proposed access road across the north face of the mountain and the proposed gondola and zipline along the Exhibition run from the summit to base. Construction of the access road raises concerns about potential rock slides, landslides and avalanches, as well as visual impacts to the community. The proposed zip line may further erode community character, create parking challenges, impact Phil Baux Park and create noise impacts for neighbors… For these proposed features, the Forest Service should include a range of alternatives, including using the existing access road on the south side of the mountain, a no-action alternative and other possible alignments. Also, the range of alternatives for development should include a net-zero increase of current resort boundary acreage.
Teton County Board of County Commissioners scoping comments, September 24, 2018 – excerpt:
… we would like to highlight the following items and requests… that the EIS process analyzes a range of alternatives for the community and stakeholders to consider related to the Snow King proposal, including but not limited to: multiple options for on-mountain road development, including: designation(s) that would address uses that will be allowed or limited on the new road and associated avalanche mitigation areas proposed in new/expanded acreage[;] options for development that involve a zero net-increase of current resort boundary acreage…
Wyoming Game & Fish Department scoping comments, September 13, 2018 – excerpt:
The importance of Leeks Canyon as a crucial big game winter range cannot be understated nor should it be rendered ineffective because of expanded winter recreation into or adjacent to this important wildlife habitat. Consequently, we do not support any aspect of the proposed expansion of the Snow King Mountain Resort that will entail the development of a new ski lift, snowmaking equipment, increased novice skiing opportunities, increased vehicular acess on roadways from the Snow King summit to the bottom of Leeks Canyon, and new facility construction on the ridges above Leeks Canyon. Evidence of big game use in Leeks Canyon is historical and comprehensive. During annual winter big game aerial surveys over the last 25 years, a substantial number of elk and mule deer that spend the winter from Snow King/Leeks Canyon to Game Creek can be observed on the ridges and south and west exposures in Leeks Canyon. The continued use of this area is essential to the health of the mule deer, elk, and moose that use this winter range.
American Avalanche Institute scoping comments, October 5, 2018 – excerpt:
We have concerns about the new road on the north facing side. This will impact the skier experience and push out into wildlife habitat outside the existing Snow King boundaries.
This proposed road would travel through avalanche start zones and require additional avalanche control. The Leeks Canyon road on the backside has been used in the past and seems to be usable now.
We also have concerns about the proposed expansion into the back bowls of Leeks Canyon. The proposed expansion into this terrain includes multiple lifts/magic carpets, snowmaking, and a yurt camp. Expansion to this extent would have a large impact on field sites that we have used on the ridges west and east/southeast of the summit. But more importantly, the current proposal would create a large increase in human presence and infrastructure in that drainage.
It does not feel appropriate for an expansion of this magnitude into the Leeks Canyon.
The proposed expansion of infrastructure and usage should be balanced with the impact on wildlife habitat. An occasional skier or intermittent use of the Leeks Canyon Road is different than a full resort expansion into that terrain.
US Fish & Wildlife Service scoping comments, September 13, 2018 – excerpt:
Due to the potential impacts to lynx and lynx habitat as a result of implementation of the proposed recreation activities, we recommend the EIS include at least one alternative implementing the following the NRLMD human use guidelines for developed recreation: HU G1 (maintaining inter-trail islands), HU G2 (providing lynx nocturnal foraging opportunities), HU G3 (lynx movement and habitat effectiveness), and HU Gl0 (maintaining security habitat when expanding ski areas and trails). Adopting these guidelines would ensure the proposed activities are designed to minimize the fragmentation of lynx foraging and denning habitat. Reducing the number of new graded/cleared areas, ski runs, bike trails, hiking trails, and buildings within currently contiguous lynx foraging and denning habitats would also reduce the fragmentation of lynx habitat. Alternatively, these Project-related activities could be moved to areas that do not contain lynx habitat. In addition, we recommend the Forest minimize the footprint of new lighted, night ski areas, especially in or adjacent to blocks of contiguous lynx habitat to give lynx the opportunity to forage at night. By implementing these measures the Forest will appreciably reduce the impacts to lynx, lynx denning and foraging habitat, as well as, designated lynx critical habitat within in the Project area.