From: Lee Greenwald To: FS-objections-pnw-mthood Subject: Twilight Parking lot Date: Monday, March 03, 2014 11:44:20 PM Attachments: 2013 International Report on Snow Mountain Tourism.pdf Cross-country skiing experiencing a Nordic renaissance Olympian.pdf Twilight Parking Lot OBJECTION 3-1-14 EAE v2.doc Dear objections official, I previously raised several objections concerning Mt Hood Meadows application to build the Twilight Parking lot. Though some, not all, of these objections were ostensibly addressed in their responses, they were not addressed fully nor adequately. I raised concerns regarding Meadows assumptions on growth in demand for Alpine skiing. The last ten years MHM stated continued growth trends, but actually the most recent previous two years that has not been the trend. The true growth is in Nordic skiing. The majority of the Nordic community is against the creation of the Twilight lot without a comprehensive analysis of potential future use of this terrain, and nearby Nordic trails and connecting trails. This type of analysis has not been done, and would be precluded by proceeding with the construction of the Twilight lot before all future use options have been considered. Second, I asked that MHM be required by the FS to place the funds, $500,000, for a Nordic center in a designated account for a future Nordic center building, and a restrictive timeline for construction. If the parking lot is to be built, the Nordic community should have some prior input on the Nordic facility to be built prior to the lots final approval. The response that was posted simply stated that "a" facility would be built within three years. That's a long time to wait, and for what? The current HRM hut was originally built as a Nordic building and re-purposed by MHM. We would like to believe MHM that something will be built that will meet the growing Nordic communities needs, but having the design and money put up front before any environmental changes should be required by the FS. Furthermore, I questioned the first bullet point issue on the need for more parking; safety concerns, in particular safety along the access roads and highway 35 due to illegal overflow parking. The logic of this issue is faulty on several levels. First, this is an enforcement issue. Difficulty in enforcing a law is not a logical argument to accommodate the lawbreakers. If this was the case, whenever laws are broken we would be looking for a way to meet lawbreakers needs. If many people are stealing candy, is the proper solution that we should make free candy more available? MHM does a very good job of stopping cars from entering the main lot once full, and directing them to the Sunrise lot. Ditto, when Sunrise is full to the HRM lot. But somehow MHM, and the State police are totally unable to stop people from parking illegally on access roads and 35. They only need to tow and few cars, and write tickets. The word will get out. There is an obvious conflict of interest; MHM has a profit motive to have as many people up in it's facility as possible, regardless of safety, regardless of legality. More importantly is the real safety concern. There have been very few injuries and no deaths on the access roads or 35 attributable to illegally parked cars. However, the real safety concerns on those crowded days is on the slopes. MHM was granted a Person Allowed at One Time (PAOT) in the original master plan. That was quite a while ago, and it was calculated for the number of skiers the skiable terrain could safely accommodate. Two problems, first, as we all know, when there's a storm, and fresh snow, much if not most of the "skiable terrain" is unavailable for skiing. Cascade, Heather, Vista are often closed at the busiest time. This is no small issue. These closed areas make up well more then half of the "skiable terrain". MHM has tried to claim that the problem is self regulating, the lifts are at capacity and limit the number of people on the slopes. This is only partially true. Everyone up there on the most crowded days know there are more people everywhere, the lift-lines, the lodges, the roads and lots and the slopes. Secondly, the calculations for the PAOT were based on skiers, the advent and popularity of snowboarding has changed the dynamics on the slopes. We wouldn't consider allowing snowmobiles on the slopes alongside skiers, the idea would seem absurd, but snowboarders and skiers also see and use the skiable terrain quite differently. There are ski areas that have recognized this and restricted their areas to one sport, Alta is one. MHM has completely disallowed uphill traffic through their permit area during their months of operation because, they claim, of safety concerns. There have been no incidents to support their banning of uphill traffic. Mt Bachelor does allow uphill backcountry skiers in their permit area during their hours of operation. But, MHM has doesn't have any problem with the compatibility of paying lift- using customers. Skiers and snowboarders, are in their minds, perfectly compatible. I would argue, skiers and snowboarders colliding has become a major factor in accidents occurring on the slopes. The safety concerns here are real and far outweigh any overflow parking on access road dangers. Two weeks ago on a busy Sunday MHM ski patrol was so busy with injuries that they couldn't keep up with picking up the injured and breaking up fights between frustrated and enraged sports enthusiasts that were having a miserable day. If MHM is to continue to be a two simultaneous sport area, the safe PAOT needs to be recalculated downward. Accidents continue to plague alpine skiing, and, at least in part, account for the sports diminishing popularity. The biggest danger at MHM when crowded is on the slopes, not on the access road. Broadly viewing the situation, increasing the amount of parking by nearly 1000 cars will exacerbate the dangers, not rectify them. I previously had suggested an alternative which would have used used the ODOT gravel barn as the nidus of a new parking area and Nordic area. With just a small expansion, this area could accommodate nearly 400 cars. This is well more than the access road can illegally handle. The position of the gravel barn, between Teacup Nordic area and MHM Nordic area and in close proximity to the obliterated Clark Creek Snow Park (CCSP) is ideally situated for a new smaller parking lot and nordic center. The (CCSP) was previously cleared and could easily become a groomed corridor to the new Clark Creek Bridge. The chief designer of the Highway 35 improvement project and designer of this bridge told me that this bridge was over designed and could easily accommodate a skiable underpass by just clearing some rocks and pushing in a few feet of snow. I've inspected all this area including the old hiking trail along Clark Creek and from the obliterated CCSP to the Beargrass loop and there are multiple opportunities for low impact connector trails. It would be physically simple to create a united area that would be approximately 50 kms. Less than half what Bend maintains, but second best in Oregon and closest to the largest population center. My suggestion was discounted for various bureaucratic reasons. Several ODOT employees have told me that their 3+ acre permitted area is already inadequate to meet the current needs and that they don't know how they will accommodate the increased demands from an additional parking lot and an addition to the access road. They will need a larger area, or a second nearby location. The posted answer to my concerns and suggestions was simply that the respondent wasn't aware of any ODOT gravel issue concerns. Apparently, they also didn't feel any need to investigate. The respondent did mention the onerous bureaucratic hurdle: there would have to be changes to the ODOT permit, and the MHM permit area. This entire area is under the authority of the FS. The FS issues and revokes and changes permits. The FS should begin to be somewhat proactive when it comes to protecting the mountain and planning best use for the future, not just reactive to financially vested applicants. The fact that my alternative was given essentially no consideration is a tragic victim of bureaucracy. If the Twilight parking area is built according to the "favored alternative 6" what is lost? It will be a done deal for generations. The environmentally less impacting Nordic recreational community will have lost it's best opportunity in the region, MHM will likely be left with a white elephant (white, we should hope, for at least a few months of the future years). For a few hours for a few days, if snow conditions don't deteriorate further, they will have turned a green forest into a hot asphalt parking lot that will be of little use to anyone, including the elk. Most concerning of all is the statement from the DEIS: All alternatives would have no or a negligible effect on climate change, greenhouse gases (GHG), or loss of carbon storage. The project proposes to permanently remove from 9.4 to 22 acres of forest trees to construct a parking lot designed to serve current use and im- prove public safety. The generation of GHG during construction, maintenance, and snow plowing of the parking lot and associated activities would be relatively minor and short term. With the Forest’s tremendous capacity to sequester and store carbon, the loss of forest trees under the action alternatives is unlikely to have a measurable effect on climate change.