We are trying to protect Snow King Mountain, our Town Hill, from harmful development plans by new investors. We want Snow King to succeed as our Town Hill, not an amusement park. The Bridger-Teton office of the US Forest Service has been reviewing the development proposals in an Environmental Impact Statement (EIS) process required by the National Environmental Policy Act (NEPA). We recently officially “objected” to the draft decision by the Forest Service. Objection is a formal step of the process intended to allow a mediated solution and prevent litigation of bad decisions. We were honored to stand alongside many long-time locals, local, statewide, and national conservation and winter recreation groups, and even the Town of Jackson in objecting to both the content and process that led to a very flawed decision. We are now waiting for the Regional Office of the Forest Service to investigate and hopefully recommend changes to solve the serious problems we’ve uncovered.
In this blog series, we’ll share the closing comments from us and two great partners, the Wyoming Wilderness Association and national Winter Wildlands Alliance. We want to bring you “behind the scenes” in the objection meetings, which were also covered well in the Jackson Hole News and Guide. Be in touch with Clare (firstname.lastname@example.org) to learn how to stay involved and stand up for our Town Hill!
Peggie dePasquale: Thank you to the Forest Service and everybody for being here. I appreciate this opportunity to comment. To be totally honest, this project doesn’t impact the landscape that the Wyoming Wilderness Association, who I’m representing today, would generally focus on. However, we could not ignore the procedural shortcomings here.
NEPA is one of the most critical tools that exist in protecting and conserving our wild world, and ignoring these shortcomings would be a disservice to our organization’s missions and the lands we represent.
In contrast to what [Forest Supervisor] Tricia [O’Connor] shared, we maintain that flaws within the Purpose and Need statement, an unreasonable list of alternative actions, and an incomplete analysis of key conservation issues and impacts leave the Forest with no choice but to do a supplemental EIS for this project. NEPA is only effective when it is executed accurately and we ask that you please ensure the integrity of this procedural law that our wild world relies on.
Please rewrite the Purpose and Need section to explain why the proposed actions are actually necessary. This is simple but absolutely foundational in order to comply with the important NEPA requirement. Only once the Purpose and Need is adequate can the alternative actions be developed, and the two sections must support each other, which they do not currently.
Our next concern is that the list of alternative actions within the final EIS are functionally identical, as so many people have pointed out. This was also true back in the draft EIS, and that made it really difficult for the public to distinguish among the alternatives and created undue momentum for all of the unpopular actions to move forward. Furthermore, the final EIS has entirely ignored the public and other agency input on what worthy alternatives could have been, and as we heard today and what was my understanding before, this was true as far back as the scoping period. NEPA requires “consideration of a reasonable range of alternatives that can accomplish the Purpose and Need of the proposed action,” so please rewrite an adequate Purpose and Need and then create a reasonable range of alternatives from it.
The third element of our objection is an incomplete analysis within the final EIS. Considering all the things that might be impacted is not the same as doing a detailed analysis of what those impacts are. And we believe that these impacts are wildlife habitat, plant communities, the compliance with the FS manual, the historic significance of Snow King, the safety of our year-round Snow King patrons, to the cumulative effects of the proposed action, to possible means of mitigating these impacts. This analysis was glaringly incomplete or ignored throughout the process. The final EIS does not meet the standard that we understand has been set within NEPA, and more importantly, the standard that is expected of you and assumed by the public to whom these public lands belong.
So, to close, addressing the issues within the Purpose and Need, a reasonable range of alternatives, and adequate analysis is critical to the integrity of NEPA and its role in filtering projects like these on our public wild lands. Please show us all that you are listening by completing a supplemental EIS and addressing the concerns shared by so many today. As [local snowboarder] Shane [Rothman] said, this is up to you, the Forest, to do the right thing and set things right. Thank you so much for this opportunity and all you’re doing.
Read the other comments here: