CHAPTER 5 RESPONSE TO COMMENTS
5.1 INTRODUCTION
The Notice of Availability (NOA) for the Montana Snowbowl Expansion DEIS was published in the Federal Register on March 11, 2011. A 45-day public comment period was held from March 11 through April 25, 2011. One open house regarding the proposed project and DEIS was held at the Grant Creek Inn in Missoula on March 30, 2011. Staff from the LNF, MSB and the third- party EIS contractor (Atkins, formerly known as PBS&J) held a presentation, had a brief question and answer period and were available to answer questions from 5:00 to 7:00 pm. Seventy members of the public attended the open house.
Individuals, agencies, non-governmental organizations, and businesses submitted comments at the open house on comment forms and via mail, electronic mail (email) and phone. A total of 61 responses were received (Appendix E). There were no form letters received.
5.2 CONTENT ANALYSIS
Content analysis is the process of compiling, categorizing and analyzing all comments received during the DEIS public comment period. This process incorporates public viewpoints and concerns into the FEIS and facilitates appropriate clarifications, adjustments or the addition of information. It is important to note that this process does not treat comments as votes for or against a proposed project. A majority of comments in favor or against the proposed project does not have bearing on the decision of the LNF.
Each response was given an identification number. Comments within each response were categorized and sorted by resource or topic and paraphrased if necessary for clarity and consistency. The respondents that included that comment are identified by number. Comments that simply stated support for or opposition to the project were not included in the content analysis. The LNF responded to each substantive comment (Sections 5.2.1 through 5.2.17). The original verbatim comments are provided in Appendix E.
5.2.1 Purpose and Need
1. The proposed project will expand the terrain and serve more of the public (beginners and intermediate skiers) than is currently offered at MSB. Respondents: 1, 3, 4, 5, 8, 19, 29, 32, 37, 45, 47, 49, 54, 56, 58, 60, 61.
Response to comment: We agree. That is the Purpose and Need of the project (Section 1.4, p. 1-7 of the FEIS).
2. The proposed project would not provide terrain appropriate for beginner and intermediate skiers. Respondents: 17
Response to comment: The LNF believes that the proposed project would provide terrain appropriate for beginner and intermediate skiers. The available beginner and intermediate terrain at MSB would increase from 105 acres to 144 acres. The number of beginner and intermediate SAOT that could be accommodated at MSB would increase
Final EIS 5-1 Montana Snowbowl Chapter 5 Response to Comments
from 1,050 people to 1,440 people. The LNF feels that this increase does represent an adequate increase in ski terrain for beginner and intermediate ability skiers and therefore meets the Purpose and Need for the project (Section 1.4, pp. 1-7 through 1-10 of the FEIS).
3. There is no justification for expanding MSB. Respondents: 16, 21, 51, 52
Response to comment: Any proposed project that would utilize public lands must undergo an analysis of whether the project meets the stated Purpose and Need for the project, as required under NEPA. The Purpose of and Need (Section 1.4, pp. 1-7 through 1-10 of the FEIS)for this project is based on the goal of the Forest Plan (USDA 1986) to provide recreation opportunities including developed and year-round recreation. These opportunities include:
Providing additional ski terrain Providing additional beginner and intermediate ski terrain Enhancing summer use and balancing summer and winter use.
The proposed project would increase ski terrain at MSB from 255 acres to 441 acres. The available beginner and intermediate terrain at MSB would increase from 105 acres to 144 acres. Summer use would be enhanced by adding more chairlift-serviced hiking and mountain bike trails and access to the new lodge for summer guest services. The LNF feels that the proposed project meets the Purpose and Need; and therefore, that the expansion of MSB is justified.
4. Meeting current and future ski area demand is the main premise behind the "needed" Snowbowl expansion; however, figures expressed within the DEIS do not support this. The DEIS's first chapter states that the three- year average of skier visits to Snowbowl for the 2004-2009 seasons was nearly 10 percent lower than 2002-2004. These figures also express a general decline at MSB after the 2003 closure of Marshall Mountain Ski Area. The numbers don't lie. Data brought forth in the DEIS to support the "need" for expansion actually refutes any "need." Respondent: 21
Response to comment: The number of skiers that visit a ski area is heavily influenced by snow conditions. Low snowpack as a result of drought conditions in the last 10 years resulted in several years where skier numbers were low at MSB, as they likely were at all regional ski areas. The year that was most instrumental in the drop in the 2003-2005 three-year skier average shown on Figure 1-3 (p.1-9 of the FEIS) was the 2003-2004 ski season; due to the lowest snowpack in 20 years MSB only recorded approximately 39,000 skiers that year. In comparison, the 2010-2011 ski season, which had a record high snowpack, brought 74,050 skiers to MSB. The most recent data has been added to Figure 1-3.
Although skier numbers are difficult to predict the LNF believes that there is an increased need for more beginner and intermediate terrain at MSB, especially after the closure of Marshall Mountain.
Final EIS 5-2 Montana Snowbowl Chapter 5 Response to Comments
5. The 2006 document states unequivocally that the Missoula region does not need to increase ski area capacity to keep up with demand. Therefore, this issue should have been moot for some time. Respondent: 21
Response to comment: We believe the commenter is referring to the “Downhill Skiing Needs Assessment for the Bitterroot and Lolo Forest Plan Revisions” (Ryberg 2005). This document concludes, “Based on the analysis of local and regional ski area capacity, the existing or approved capacity of these ski areas is adequate to accommodate projected increases in skier/snowboarder visits within an acceptable utilization range. Considerations should be given to Montana Snowbowl’s proposal to provide a more balanced mix of terrain to meet the desires of the skiing public.”
One of the elements of the Purpose and Need for the proposed project is to provide more ski terrain (Section 1.4.1, p. 1-8 of the FEIS). However, another element is to provide additional beginner and intermediate terrain (Section 1.4.2, p. 1-10 of the FEIS). The Ryberg (2005) document states that consideration must be given to this purpose based on the analysis provided in the report.
6. Wants and needs differ drastically, and for the USFS to acquiesce to the wants of a small, self-interested, and vocal population sends the wrong message to the public at- large. Respondent: 21
Response to comment: As discussed in the Purpose and Need for this project includes providing additional ski terrain as well as additional beginner and intermediate ski terrain, and enhancing summer use and balancing summer and winter use (Section 1.4, p. 1-7 through 1-10 of the FEIS). These needs were identified, and the desires of any group, whether majority, minority or otherwise, have no bearing on the decision whether or not to allow the expansion of MSB.
7. Adding more beginner and intermediate terrain at MSB will fill that which was lost when Marshall Mountain closed. Respondents: 4
Response to comment: We agree. That is the Purpose and Need of the project.
8. The proposed project is not an appropriate use of public lands. Private entities should not gain financially from public lands. Respondents: 21, 50
Response to comment: The LNF adheres to the goals and standards laid out in its current Forest Plan (USDA 1986).
Forest Plan Standard 6 states in part:
The LNF will provide for a wide spectrum of Forest-related dispersed recreation and range of skill levels available to Forest visitors including the elderly and handicapped. The program will provide for use of the Forest on a year-round basis in areas that will minimize conflicts between user groups and other Forest resources.
Final EIS 5-3 Montana Snowbowl Chapter 5 Response to Comments
Forest Plan Standard 7 states in part:
Emphasis will be placed on increasing the use of existing sites by making them usable by a wide segment of society….The private sector and other agencies will be encouraged to provide for increased public needs on National Forest System land and on lands adjacent to the Forest. If and when development proposals are received for expansion of existing or construction of new ski areas, they will be evaluated according to the normal procedures for determining ski area feasibility.
These standards do not preclude financial gain by a proponent.
9. The area has already been developed as a ski area or has a history of past management; therefore it is an appropriate place for the proposed project. Respondents: 26, 29, 58, 60, 61
Response to comment: No response necessary.
10. MSB is not providing adequate services to their customers within their current SUP area and must do so before they are allowed to expand. Respondent: 24
Response to comment: The LNF cannot evaluate MSB’s customers’ satisfaction with their operation as part of the NEPA analysis for this proposed project. The LNF can only evaluate the proposed project against the Purpose and Need for the project and compare that to the environmental effects in order to come to a decision (Section 1.4, pp. 1-7 through 1-10 of the FEIS). Overcoming many of the problems that exist within the current SUP area, such as overcrowding, lack of adequate skier services and lack of lower ability terrain, are the focus of the proposed project within the proposed expansion area.
11. The public must see that MSB is adhering to their current lease. Respondent: 59
Response to comment: MSB operates on the LNF under a special use permit (SUP) and is adhering to the terms the SUP.
12. The proposed project would cause environmental harm to public land that should be protected for future generations. Respondents: 21, 50
Response to comment: The mission of the U.S. Forest Service is to maintain the health, diversity, and productivity of the nation’s forests and grasslands to meet the needs of present and future generations. The Proposed Action would adhere to all Forest Plan standards applicable to the natural resources associated with the proposed expansion area.
13. Missoula needs to maintain the public lands it still has. Respondent: 16
Final EIS 5-4 Montana Snowbowl Chapter 5 Response to Comments
Response to comment: The proposed expansion area would remain public land under SUP by MSB. The Proposed Action would include an amendment of the Forest Plan that would change the management of the proposed expansion area from timber production (MA 16 and 25) to the recreation use of ski areas (MA 8). It is not within this scope of this analysis to decide whether timber production represents “maintenance” of public lands while developed recreation does not.
5.2.2 Proposed Action and Alternatives
1. Lift C should have a midway unloading ramp onto Second Thought, and have the top terminal above Lift D. This would provide beginners with a shorter section of Second Thought, and could possibly provide for moving the t-bar to provide a longer Lift D, and a much easier slope for the t-bar and its riders. This would also reduce traffic for Lift D, by providing the expert skiers who may want to access the steeper east facing terrain of TV Mtn., the means of doing that, riding one lift, instead of two. This would also provide for easier scheduling of lift operators, as the t-bar runs part-time. Respondent: 18
Response to comment: The scope of this analysis includes evaluating whether the Proposed Action as described in Section 1.2 (p. 1-5 of the FEIS) meets the Purpose and Need of the project (Section 1.4, pp. 1-7 through 1-10 of the FEIS) and discloses the environmental effects of the Proposed Action and No Action alternative (Chapter 4 of the FEIS). The scoping period for this analysis allowed the public to offer suggested alternatives or modifications to the Proposed Action as laid out in the MDP (MSB 2004). The LNF would not consider evaluating a new alternative at this time unless it was developed in response to an adverse environmental impact.
2. MSB should fully build out what they are approved to construct within their existing SUP area before they expand. Respondents: 21, 59
Response to comment: It was decided in the 1996 decision that several improvements, including several trails and two lifts, could not be implemented until the access road was improved. Road improvements will be fully completed in the summer of 2013. During road construction it was determined the two lifts would not be necessary and the addition ski trails would not meet the future needs of skiers. Therefore, MSB produced a new master development plan and submitted in 2004 to the Forest Service for approval. The improvements approved by the LNF in 1996 for the existing SUP area (LNF 1996) are analyzed as Connected Actions. If the Proposed Action were approved, 19 acres of beginner/intermediate ski trails that would accommodate 190 SAOT would be constructed in the future within the existing SUP area. However, this acreage alone is not enough to meet the Purpose and Need of providing adequate beginner/intermediate skiing at MSB.
3. With an additional 937 skiers the existing lodge and bar will not be able to accommodate the expanded skier numbers at the end of the day when the TV Mountain Lodge is shut down. An additional building at the base needs to be built to accommodate the increased usage. Respondent: 24
Final EIS 5-5 Montana Snowbowl Chapter 5 Response to Comments
Response to comment: The LNF cannot direct MSB to improve or conduct its operations on private land outside of the SUP area.
4. We recommend the following to educate the public on [wildlife] impacts. Provide science-based educational classes at MSB to educate the public on the fish and wildlife resource values of the area. Respondent: 26
Response to comment: Thank you for your suggestion but it is beyond the scope of this analysis or the authority of the LNF.
5. Add a stipulation to the Special Use Permit for MSB to provide funding or other support to local land trusts to specifically protect wildlife habitat in the North Hills west to Highway 93 in the Missoula Valley. This could be done through monetary contributions, ski or mountain biking fundraisers, and/or selling lanyards for a set price to skiers with the entire donation going to a local land trust (similar to Jackson Hole Ski Resort and the nonprofit American Forests). Respondent: 26
Response to comment: Thank you for your suggestion but it is beyond the scope of this analysis or the authority of the LNF.
6. Currently the Last Run Inn and the main lodge are at capacity during peak days. Trying to get service in any of these facilities is unacceptable. With an increase in skiers there needs to be a corresponding increases in these services. The specific actions for meeting the needs for the proposed actions need to be expanded to include; providing additional skier services. With a detailed study of what services are available now and what will be needed as the skier days increase. Respondent: 38
Response to comment: The balance of skier services currently and under the Proposed Action would be maintained or improved under the Proposed Action and Connected Actions (Table 4-15, Section 4.10.2.1, pp.4-73 and 4-74 of the FEIS). The Proposed Action would include three new skier services buildings, which would relieve crowding in the existing skier services buildings.
7. The proposed Lift A seems to have very little value except to return skiers to the top of the current Grizzly chair. There is not much desirable terrain that is access from this lift and will see minimal use. Another lift that was on the 1996 plan that was never built is the lift from the base of the La Valle chair to the north above the Mid Nut run. This would help access some very nice intermediate terrain and help relieve pressure on La Valle chair as we as give access to the top and a way out in case of chairlift break downs. Respondent: 38
Response to comment: The purpose of proposed Lift A is not to access new terrain but to provide skiers access from the TV Mountain expansion area back into the current ski area without going down to the base area. Although it is already approved (USDA 1996), MSB has stated that it is unlikely to construct a lift from the bottom of the La Valle chairlift to the top of the Mid Nut trail. This area is already accessible via the existing La Valle chairlift.
Final EIS 5-6 Montana Snowbowl Chapter 5 Response to Comments
5.2.3 Geology and Soils
1. With 182 acres being clear-cut, including 39 acres of old growth timber, the expansion area will be directly susceptible to soil erosion. When did the USFS institute policies to clear-cut old growth timber for anthropocentric benefit, while acknowledging that said action will further damage sensitive soils? Respondent: 21
Response to comment: The removal of old growth timber would reduce the acreage of old growth timber in the Grant/O’Keefe EMA from 8.6 percent to 8.4 percent; this is an acceptable reduction and maintains the goal of 8 percent in this EMA. Further discussion of old growth timber removal is below in Section 4.4.2.2 (p. 4-15 of the FEIS).
Soil disturbance is expected during tree clearing and construction activities but is not expected to create long-term effects to soil productivity or erosion except at sites that would have permanent structures and features. Other soil functions (for example, physical, chemical, and biological) are not expected to be an issues with this project because these soil functions are affected only on very small areas such as under buildings, lift towers, and drainfields. Soil effects would generally occur as temporary, limited soil displacement or erosion at sites scattered across TV Mountain. No sediment delivery to streams would occur from these sites because they are not located near streams, and they are separated by areas of undisturbed vegetation (more information is provided in the FEIS, Section 4.2.2, pp. 4-13 through 4-16).
Erosion concerns are greatest where vegetation is completely removed. Short-term erosion may occur but erosion control measures would be implemented until the surfaces are revegetated. The LNF would conduct annual revegetation and erosion control monitoring to ensure revegetation success and erosion control effectiveness (Section 2.7.2, p. 2-22 of the FEIS).
5.2.4 Water Resources – Water Quality
1. Present snowplowing at the parking area already impacts Butler Creek; regardless, MSB has proposed to expand their existing parking facilities. If there has already been identification of degradation via the MSB parking lot, why has MSB not received fines for their indiscretion, and why would the USFS ever consider permitting the expansion of a known pollution source? Respondent: 21
Response to comment: The LNF is aware of the discharge of sediment to Butler Creek from snowplowing. MSB makes every effort to avoid collecting sediment from the parking lot during snowplowing activities. In general, the ground is frozen and covered with a layer of snow/ice during snowplowing, and only fresh snow is plowed prior to vehicles driving on the snow. Regardless, some sediment is discharged over the bank and into the riparian area with plowed snow. This has been identified as a problem at the Butler Creek outfall, but the parking lot fill slope and riparian buffer around Butler Creek below this area appear to reduce this problem below the outfall.
Final EIS 5-7 Montana Snowbowl Chapter 5 Response to Comments
Personnel from the LNF and MSB observed the Butler Creek outfall area in a site visit on August 12, 2011. At that visit the LNF requested that, and MSB agreed to, implement the sediment filtering recommendations identified in Appendix C of the Water Resources Specialist Report, Montana Snowbowl Base Area Stormwater and Snowmelt Runoff Management Assessment and Recommendations (PBS&J 2011b).
This problem exists on private land and is not under the jurisdiction of the LNF. Additionally, the only sediment impact to Butler Creek as a result of the Proposed Action is a short-term impact that would result during the installation of the flow meter for the maintenance of 30 gpm to protect over-wintering fish habitat. Therefore, there is no cumulative sediment impact to Butler Creek for which the LNF could require action from MSB under NEPA.
2. Other areas of concern include the long-term impacts of the planned “go-back” (collector) ski and bike trail, new ski runs, and Lift A. Appropriate BMPs and mitigation should be designed and monitored for the affect of each of these features on long-term slope stability and surface runoff. The collector trail is specified as an approximately14- foot wide cut that extends for more than 2 miles from the La Valle Creek drainage back to the lodge. Although this does not appear to cross any perennial streams, it would be expected to expose some ground water seeps, to intercept and direct runoff in spring, etc. Similarly, the construction of a new lift and several runs may have short-term impacts on surface water quality and long-term impacts on the hydrology of La Valle Creek. Ski runs are essentially large-scale, permanent, vertical clear-cuts. This large- scale disturbance has the potential to significantly decrease the filtration and natural interception of water, and initiate new ephemeral channels that feed directly into the stream. On new runs, it is essential to stipulate and monitor the success of revegetation efforts and to monitor the long-term impacts of the disturbance on hydrologic processes. These concerns are compounded by the existing problems at MSB, such as: currently there are many undersized and mis-aligned culverts that are affecting Butler Creek, as well as a perennial tributary reach that passes beneath the lodge. Yet, the DEIS indicates that no new culverts would be installed. Complete revegetation has not been completed on existing runs. Yet we only noticed mention in the DEIS of (active) revegetation in conjunction with grading, road/trail cuts, building-site pads, etc. For the new runs, the implication is that after tree removal (logging activities), the understory vegetation would remain undisturbed and not require revegetation. We encourage the LNF to incorporate the aforementioned items in addressing the cumulative suite of issues affecting Butler and La Valle Creeks though this expansion proposal. Respondent: 26
Response to comment: Section 2.5.2.1 (p.2-17 and 2-18 of the FEIS) provides 14 project-specific mitigation measures to protect water quality. These include the application of LNF BMPs on ski and bike trails and all other construction activities. The collector trail would have its travel-ways outsloped and would be left in a roughened (revegetated) condition to maximize infiltration. Mitigation measures for bike and ski trails would meet or exceed road and skid trail BMP requirements. The existing trails would be inventoried to determine whether they are adequately revegetated and inhibiting erosion and runoff. Identified sites would be corrected through the annual operations and maintenance plan. In addition to the many erosion control and drainage control mitigation measures for this project, an MDEQ stormwater pollution prevention plan would be required that would
Final EIS 5-8 Montana Snowbowl Chapter 5 Response to Comments
provide specific details on the design, location and implementation of all erosion controls.
The LNF would conduct annual revegetation and erosion control monitoring to ensure revegetation success and erosion control effectiveness (Section 2.7.2, p.2-22 of the FEIS).
Section 4.3.3.1 (pp. 4-4 through 4-7 of the FEIS) provides information regarding water yield and the proposed harvest of 182 acres of the proposed expansion area. This would result in the removal of less than 1 percent of the Butler Creek watershed and approximately 2 percent of the La Valle Creek watershed.
Any failure of culverts within the SUP area would require them to be upgraded to meet Q100 flood flow and Aquatic Organism Passage standards. This does not include culverts that are present on the private land at the base area.
3. The EIS acknowledges that sediment delivery to Butler Creek from the parking lot continues to be a long-term problem. Recent upgrades from road construction may have alleviated this situation in part, but we feel strongly that all possible sediment controls should be employed for this situation either before, or as a condition of, the issuance of a new SUP. We recommend that a BMP audit team, including interested members of the public, inspect and comment on the parking lot situation. Ideally, this would occur during the spring, when runoff is active. The Clark Fork Coalition would be glad to cooperate in proposing solutions for this issue. Likewise, given the population of pure, native westslope cutthroat trout in La Valle Creek, we recommend a similar BMP audit inspection during and after construction to ensure that sediment does not reach the stream. Overall, we see this project as a potential improvement to the water quality and quantity of La Valle and Butler Creeks. The septic relocation, effective management of an instream flow rate (with application of the above recommendations) and improved sediment impacts of the parking lot to Butler Creek could create an overall improvement in these streams. Respondent: 30
Response to comment: The parking lot improvements are part of this NEPA analysis as Connected Actions. Therefore, the LNF would inspect the parking lot improvements and identify any deficiencies in the sediment control. Additional information about sediment impacts and improvements due to snowplowing are provided above in Section 5.2.4, Water Resources – Water Quality, Response #1 above.
La Valle Creek is protected by an adequate vegetation buffer of greater than 500 feet from all proposed construction and project features, which would ensure that sediment would not enter La Valle Creek. There is one exception at the lower terminal of Lift A; this structure would be built approximately 150 feet from La Valle Creek. Although this distance is moderately well-vegetated, temporary erosion controls would be installed for added protection during construction. After construction, the site would be revegetated and wood waste from timber harvest would be placed on disturbance locations that are too steep to ensure adequate revegetation. Project-specific mitigation measures outlined in Section 2.5.2.1 (pp. 2-17 and 2-18 of the FEIS) would be applied.
Final EIS 5-9 Montana Snowbowl Chapter 5 Response to Comments
The LNF would conduct annual revegetation and erosion control monitoring to ensure revegetation success and erosion control effectiveness (Section 2.7.2, p. 2-22 of the FEIS).
4. It will be important that adequate sediment and erosion control BMPs are used during all construction and grading activities; disturbed areas are promptly revegetated; and that effectiveness of BMPs and revegetation are monitored and verified. We recommend clear commitment to revegetate eroding areas at the lower lift terminal for the La Valle Creek chairlift adjacent to La Valle Creek. Respondents: 39, 40
Response to comment: Section 2.5.2.1 (pp. 2-17 and 2-18 of the FEIS) provides 14 project-specific mitigation measures to protect water quality. These include the application of LNF BMPs on ski and bike trails and all other construction activities. The LNF would conduct annual revegetation and erosion control monitoring to ensure revegetation success and erosion control effectiveness (Section 2.7.2, p. 2-22 of the FEIS).
Section 2.5.2.1 (pp. 2-17 and 2-18 of the FEIS) also provides mitigation measures for the lower terminal for the existing La Valle lift, including: vegetation cover would be increased by reseeding and mulching or adding organic matter. Water bars would be installed to divert runoff away from stream, if necessary, and discharge to vegetated area away from stream; and sediment fence, berm, or other features would be installed between the site and La Valle Creek. Vegetation buffer effectiveness would be increased by re-seeding fill slope below site and placing mulch or organic material.
5. We recommend that the ski resort operator be required to avoid plowing snow from roads and parking areas into streams, wetlands, and riparian areas. The DEIS does not mention if the MSB currently uses, or intends to use chemicals to stabilize ski runs (e.g., ammonium nitrate or other salts). Chemicals are sometimes used for such purposes at ski areas. The FEIS should state whether MSB uses, or plans to use, chemicals on its ski trails. Any anticipated environmental effect of chemical usage such as impacts to surface or ground water quality, or wetlands should be analyzed and disclosed. Respondent: 40
Response to comment: MSB makes every effort to avoid collecting sediment from the parking lot during snowplowing activities. In general, the ground is frozen and covered with a layer of snow/ice during snowplowing, and only fresh snow is plowed prior to vehicles driving on the snow. Regardless, over the approximately 50 years of operations some sediment is discharged over the bank and into the riparian area with plowed snow. Unfortunately, MSB cannot store that snow in any alternate location. The constraints of the topography and the parking lot configuration does not allow MSB to plow snow away from the Butler Creek bank and riparian area and into an alternate location. As a Connected Action, re-grading of the existing parking lot and base area would be finished in conjunction with the improvements to prevent runoff and sediment from discharging directly into Butler Creek during snowmelt and rainstorms (Sections 4.2.2.1, pp. 4-1 through 4-4 and 4.3.3.1, pp. 4-7 through 4-12 of the FEIS). Additional information about sediment impacts and improvements due to snowplowing are provided above in Section 5.2.4, Water Resources – Water Quality Response #1, above.
Final EIS 5-10 Montana Snowbowl Chapter 5 Response to Comments
MSB does not use any chemicals (toxic or non-toxic) to stabilize ski trails. Occasionally an additive called SnoMax is added to the water used in snowmaking to aid snowmaking in warmer or variable temperatures. The additive contains an active protein made from naturally-occurring bacteria (Pseudomonas syringae) and is non-chemical and non-toxic.
6. The DEIS does not disclose sufficient data on roads, ditches, and culverts to determine if they are point sources of pollution for which permits are necessary. The DEIS proposes to alter the profile of the existing parking lot partially as a solution to the current erosion problem. At pages 3-4, 5 the DEIS states, “A drain installed on the west side of the main parking lot discharges sediment-laden waters into a vegetated riparian area approximately 40 feet from Butler Creek. This work would continue as the road project is completed to further eliminate erosion and sediment delivery to Butler Creek.” Sediment flowing 40 feet from a creek is within the stream buffer and likely would not always be filtered, especially during peak runoff periods. The DEIS merely assumes that the parking lot fix and drain would solve any sediment problem, and therefore does not include proper mitigation for potential failure. This is why permits and TMDLs are necessary before more developments are authorized. The DEIS downplays the fact that openings created by new ski runs would increase the rain-on-snow risk and peak runoff, and therefore damage fish habitat from sediment and flooding. The DEIS merely concludes “no effects.” Respondents: 51, 52
Response to comment: The FEIS includes additional and updated information about the handling of stormwater in the main parking lot. The parking lot improvement project has been completed and the parking lot is now sloped away from Butler Creek towards the mountain. A ditch collects the sediment-laden water and conveys it to a sump that is set below the height of the discharge pipe. Sediment would settle in this sump and the stormwater would then be conveyed through the drain pipe. The discharge point of the drain pipe has been placed higher on the fill slope for the parking lot, which is covered in large talus. This has increased the distance between the discharge point and the stream channel to approximately 75 feet. There is a heavily vegetated riparian area between the discharge point and the stream channel, and site visits in August 2011 did not identify sediment entering the Butler Creek stream channel at this location.
The LNF does not have jurisdiction over permits related to discharges on private land or on TMDL development.
Section 4.3.3.1 (pp. 4-7 through 4-12 of the FEIS) provides information regarding water yield and the proposed harvest of 182 acres of the proposed expansion area. This would result in the removal of less than 1 percent of the Butler Creek watershed and approximately 2 percent of the La Valle Creek watershed.
5.2.5 Water Resources – Water Quantity
1. Using creek flows in winter for snow making will help to delay run off and recharge aquifers which will benefit summer flows and native trout. As climate change leads to earlier spring melt, this manmade snow will help to sustain summer flows for fish. Respondent: 58
Response to comment: Noted. No response necessary.
Final EIS 5-11 Montana Snowbowl Chapter 5 Response to Comments
2. There is little information, however, about how, when and where this instream flow will be measured. Below are our recommendations on these issues: How: As the instream flow rate of 30 gpm is a very small amount of water to quantify accurately and Butler Creek was noted to have an uneven streambed that makes streamflow measurements problematic, we recommend installation of a small weir or flume to allow accurate water measurement. When: In the draft EIS, monitoring is to be performed weekly and reported annually. We would recommend daily monitoring during snowmaking periods, as these are the critical times to assure that the stream is not entirely diverted for snowmaking. In addition, we recommend reporting every 3 months to allow adaptive management if flows are not being adhered to or adjustments need to be made to the monitoring plan. Where: We recommend monitoring at a location just downstream of snowmaking operations. Respondent: 30
Response to comment: The design of the stream monitoring station would be performed by LNF hydrologists and fisheries biologists, and would likely involve a small weir or flume located just below the snowmaking water diversion. The design would ensure that the monitoring station was appropriate and effective for this location and stream type. The design and installation of this station would occur prior to initiation of snowmaking activities in the first season after the Record of Decision is issued for this proposed project, regardless of the status of construction of the new trails and additional snowmaking needs.
The LNF believes that weekly monitoring is adequate to capture changes in stream flow in Butler Creek at the snowmaking diversion. The amount of water used for snowmaking, when active, is consistent and the existing flow in Butler Creek would not fluctuate significantly on a daily basis. It is operationally infeasible to collect these measurements daily without a legitimate reason for doing so. However, the FEIS will state that in the event that weekly monitoring shows that the 30 gpm minimum is not being met, MSB will modify their withdrawal immediately and report this to the LNF within 7 days. The snowmaking period at MSB is generally only mid to late November through the end of January (approximately 2.5 months), so the annual report on monitoring activities would remain the most effective schedule, rather than the suggested 3 month schedule. The FEIS will include that the annual monitoring report shall be submitted to the LNF by April 1 of each year (Section 2.5.2.1, p. 2-18 of the FEIS).
5.2.6 Vegetation – Weeds
1. The historical introduction of "desirable non-native plants" have provided Montana with leafyspurge and knapweed. While I am confident that the USFS would not permit species such as this to be introduced, the USFS track record does not merit my confidence. Respondent: 21
Response to comment: Construction, maintenance and recreational use within the proposed expansion area would increase the risk of establishment of noxious and invasive weeds. Weed control would continue to be implemented as it is under the existing MSB Operating Plan which includes annual monitoring and reporting. FEIS Section 2.5.2.2 (p. 2-18 and 2-19 of the FEIS) and Appendix B provide project-specific
Final EIS 5-12 Montana Snowbowl Chapter 5 Response to Comments
weed mitigation measures. These measures are taken from FSM 2081.2 and USDA (2007c).
2. Weeds are a great threat to biodiversity and can often out-compete native plants and produce a monoculture that has little or no plant species diversity or benefit to wildlife. Noxious weeds tend to gain a foothold where there is soil disturbance, such as construction and grading activities. EPA supports integrated weed management (combined program of mechanical, biological, and chemical weed control), and we encourage use of weed control measures at the earliest stage of invasion to reduce impacts to native plant communities. While the DE IS states that no wetlands were identified in the proposed expansion area (page 3-20), and La Valle Creek is located west of the proposed SUP boundary, there may be construction and/or grading work that disturbs soils, and thus promotes weed spread, near aquatic areas near the parking lot and Snowbowl Road. We are pleased that the weed mitigation measures in Appendix B evidence an understanding of the potential adverse effects of herbicides on water quality and fisheries, and the need to take extra precaution to avoid herbicide transport to 9 streams and wetlands. In addition to the measures that reduce risk of herbicide contamination of aquatic areas in Appendix B, we recommend that use of more toxic herbicides (e.g., tordon) be avoided near aquatic areas, and that potentially toxic herbicides be applied at the lowest rate effective in meeting weed control objectives and according to guidelines for protecting public health and the environment. Respondent: 40
Response to comment: The LNF agrees – as stated in the herbicide mitigation measures (#8, 11, and 12 of Appendix B, p. B-1 of the FEIS) label direction and guidelines for all herbicides will be followed. This would include such measures that reduce risk of herbicide contamination of aquatic areas.
5.2.7 Vegetation – Timber and Old Growth
1. Old growth forest on TV Mountain should be avoided or at least gladed and not clear cut. Respondent: 24
Response to comment: The removal of old growth timber would reduce the acreage of old growth timber in the Grant/O’Keefe EMA from 8.6 percent to 8.4 percent; this is an acceptable reduction and maintains the goal of 8 percent in this EMA. During timber removal for trail construction, MSB would avoid removing larger diameter trees if feasible from an operational and safety standpoint (Section 4.4.2.2, p. 4-15 of the FEIS).
2. [I am] concerned with clear cutting public land in the expansion area. Respondent: 16
Response to comment: Noted. No response necessary. Sections 3.4 (pp. 3-17 through 3-29) and 4.4 (pp. 4-13 through 4-17) of the FEIS provide information and analysis related to timber harvest.
3. The Proposed Action would result in removal of 39 acres of old growth trees. These 39 impacted acres are not depicted on any maps, making it difficult to assess the impacts of this removal. For example, we cannot determine if they all in one tract or in scattered patches throughout the proposed expansion area. Three of the species listed above are especially dependent on old growth large-diameter trees and snags, including brown
Final EIS 5-13 Montana Snowbowl Chapter 5 Response to Comments
creeper, flammulated owl, and pileated woodpecker. In addition to birds, several bat species preferentially use large diameter trees and snags for roosting (Schwab 2006). Studies across the west have shown that silver-haired bats and fringed myotis prefer larger diameter snags for maternity roost sites in unburned forests. Woodpeckers, owls and bats use live trees with hollow interiors for nesting and roosting, in addition to snags. Old growth forests across the West were harvested at an unsustainable rate for many decades. Remaining old growth stands, even if they are marginally classified as old growth, are extremely valuable for maintaining species dependent on large diameter trees. Mitigation for the removal of these large-diameter trees is probably not possible. We recommend that the proposed alternative be modified to reduce or avoid removal of these 39 acres of old growth trees. Respondent: 26
Response to comment: A map showing the forest types including the location of the 39 acres of old growth timber (the areas of old growth with ski runs overlay) has been added to the FEIS (Figure 3-1, p.3-21 of the FEIS). The LNF agrees that old growth and snags are important habitat for MIS wildlife and adequately analyzed the current affected environment (section 3.5, pp. 3-29 through 3-89 of the FEIS) and the impacts of this project (Section 4.5.2.1, pp. 4-18 through 4-53). The FEIS concludes the proposed expansion would not impact old growth forest types used by goshawks (pp. 4-36 through 4-38 of the FEIS) or pileated woodpeckers (p. 4-38 of the FEIS). Additionally, the removal of old growth timber would reduce the acreage of old growth timber in the Grant/O’Keefe EMA from 8.6 percent to 8.4 percent, which is an acceptable reduction and maintains the goal of 8 percent in this EMA (Section 4.4.2.2, p. 4-15 of the FEIS).
4. ...scattered large-diameter trees and snags may occur throughout younger forest types in the proposed expansion area. These should be retained when possible. Removal of 39 acres of old growth forests and removal of large diameter dead trees would incrementally reduce nesting and feeding sites for species dependent on large diameter trees, including pileated woodpecker, brown creeper, and flammulated owl. All of these species are territorial, so removal of nesting habitat reduces the potential population size for these species. These species are listed as Montana Species of Concern due to incremental habitat loss in the special habitats they occupy. Cumulative impacts of timber removal in old growth forests over the long term will continue to reduce this habitat, which has not recovered from unsustainable harvest in the past. Respondent: 26
Response to comment: Old growth timber impacts were analyzed at the EMA level. There are no other projects proposed in the EMA that would cumulatively impact old growth timber.
5. Approximately 39 acres of the proposed 182 acres of tree cutting associated with new ski trail development, lifts and other project components would occur in old growth forest areas. The DEIS appears to discount this loss of old growth trees since it is stated that old growth forest in the Grant/O'Keefe Ecological Management Area comprises 1,452 acres, and loss of 39 acres of old growth would only reduce old growth forest from 8.6% to 8.4% of the area, which is still greater than the goal of maintaining 8% old growth forest in the area. While we are pleased that the amount of old growth forest in the Grant/O'Keefe Ecological Management Area will remain above the LNF goal of 8 percent, we remain concerned about the incremental loss of another 39 acres of old growth forest. Old growth stands are ecologically diverse and provide good breeding and
Final EIS 5-14 Montana Snowbowl Chapter 5 Response to Comments
feeding habitat for many bird and animal species, which have a preference or dependence on old growth (e.g., barred owl, great gray owl, pileated woodpecker). Much old growth habitat has already been lost, and we believe it is important to prevent continued loss of old growth habitat and to promote longterm sustainability of old growth stands, and restore where possible the geographic extent and connectivity of old growth. We also note that often lands outside the forest boundary have not been managed for the late-seral or old growth component, so National Forest lands may need to contribute more to the late-seral component to compensate for the loss of this component on other land ownerships within an ecoregion. There may also be potential indirect, growth inducing effects on old growth forest areas outside the MSB expansion area and off LNF lands that have not been considered. Respondent: 40
Response to comment: Refer to Section 5.2.7, Vegetation – Timber and Old Growth Response #4, above. The LNF agrees that old growth and snags are important habitat for MIS wildlife and adequately analyzed the current affected environment (section 3.5, pp. 3-29 through 3-89 of the FEIS) and the impacts of this project (Section 4.5.2.1, pp. 4- 18 through 4-53). The FEIS concludes the proposed expansion would not impact old growth forest types used by goshawks (pp. 4-36 through 4-38 of the FEIS; as summarized from the Wildlife Report, on file) or pileated woodpeckers (p. 4-38 of the FEIS; as summarized from the Wildlife Report, on file). Section 3.4.4 (p.3-20) demonstrates that old growth estimates across the Lolo NF exceed Forest Plan standards.
It is beyond the scope of this analysis to estimate where and how much old growth timber is present outside of National Forest System lands administered by the LNF. Reasonably foreseeable development in this area would likely occur along Grant Creek Road and lower Snowbowl Road, which is mostly related to agricultural fields in the valley that would not contain old growth timber (Missoula County 2008) (Section 5.2.16).
6. The DEIS fails to disclose the location of the old-growth forest areas, including the old growth that would be lost due to expansion. There is no alternative that considers ways to avoid locating the facilities or ski runs to avoid old growth. Respondent: 51, 52
Response to comment: A map showing the location of the 39 acres of old growth timber removal has been added to the FEIS (Figures 3-1 and 3-2; pp. 3-21 and 3-22). Based on the configuration of ski trails and other facilities and the locations of old growth timber, there would not be an alternative that would substantially reduce the acres of old growth removed that would still meet the purpose and need for the project.
5.2.8 Wildlife – General
1. An elk population, which has significantly increased over the last 30 years, grazes within the proposed expansion area during summer months. The proposed development of summer activities within this area would directly impact elk summer foraging within this area. Within a region that seeks to find all feasible manners in which to promote elk habitats, the purposeful destruction of such seems overtly maligned, naïve, and irresponsible. Respondent: 21
Final EIS 5-15 Montana Snowbowl Chapter 5 Response to Comments
Response to comment: Effects to elk are discussed in Section 4.5.2.1, p. 4-39. The Proposed Action would include converting 182 acres of forested habitat which provides hiding cover to elk, to shrub and herbaceous species, which provide increased forage. Therefore, there is a trade-off in benefits related to the tree removal. The Proposed Action may impact individual elk, but effects to the population would not be expected. The current estimate of elk within the unit is 3,000 where the population objective is 1,900-2,500 elk (see the population distribution, status and trend section in the FEIS, Section 3.5.4.1, p. 3-80). Since 1980, the elk population in the Garnet EMU has increased by an average of 11 percent which is substantial enough to begin causing conflicts with ranchers in the area. Construction activities could temporarily displace elk from summer range; however, summer range is widespread in the Rattlesnake Wilderness, so summer activities would have a negligible effect on elk (FEIS Section 4.5.2.1, p. 4-39). There is no designated winter range within the proposed expansion area.
2. The Affected Environment Section seems fairly complete and thorough, even given the limited amount of actual wildlife data discussed. My overall general concern is that, while the proposed expansion is directly linked with the existing ski area development, it still results in habitat degradation to the existing area. In addition, while most activity associated with the proposed expansion area is seasonal in nature, cumulative impacts, or some portion of those, will occur on a year-round basis, resulting in a general degradation of the existing habitat on the area. The admitted statements of adverse habitat impacts involving several species is a telling implication of habitat quality impacts. Respondent: 25
Response to comment: As disclosed in the effects analysis (FEIS, Ch. 4, pp. 4-17 through 4-54) for wildlife, incremental impacts to wildlife species dependent on existing habitat would occur. These impacts would have the potential to affect individuals but would not affect the viability of the populations. Using the best scientific data available, the LNF demonstrates the habitat for species that occur in the analysis area and forest- wide is relatively abundant and well distributed.
3. Believes the elk should be left alone in the proposed expansion area; this expansion would negatively affect elk. Respondent: 16
Response to comment: See response in Section X.2.8 Wildlife – General, to Comment 1.
4. While the proposed projects footprint on the overall landscape is relatively minor, it still represents habitat degradation and disturbance. I concur with the document's statements regarding big game species; however, I remain concerned about the cumulative impacts of the proposed project upon movement paths from the southern portion of the Flathead Indian Reservation to the North Hills area. Although big game populations are currently healthy in both locations, continued unabated growth and development in the North Hills area, in conjunction with potential development near the expansion area is a concern for the long-term well-being of elk and mule deer population stability. While these populations are currently strong, moose are very limited in the area, and are a concern for the Tribal Wildlife Management Program, as are the cumulative effects of this project.
Final EIS 5-16 Montana Snowbowl Chapter 5 Response to Comments
Respondent: 25
Response to comment: Migration habitat is present to the north and west of the existing and proposed SUP area, connecting the Rattlesnake Wilderness with the Evaro area on the Flathead Indian Reservation as big game species, such as moose and elk, prefer to use mountain meadows, river valleys, wetlands, and clear cuts in the summer and move to higher elevation mature coniferous forest in the winter. While the proposed expansion would not interfere with the migration corridor, construction of homes and subdivisions at lower elevations may reduce the capacity of habitat to support current populations (FEIS Section 4.5.2.1, pp. 4-39 to 4-40). However, the extent to which the construction of homes and subdivisions may occur is not known at this time. The current level of constructions has not caused devastating impacts on existing populations.
5. The TV Mountain area and its adjacent lands in La Valle and Butler Creeks provide summer range for a variety of species, including elk, mule deer, moose, black bear, mountain lion and gray wolf. It also supports year-round populations of furbearers, and possibly wolverine (as per historical trapping records and recent track sightings of wolverine in the Rattlesnake Wilderness Area). Although this area is not within the Grizzly Bear Recovery Zone, grizzly bears have been recently documented in the Rattlesnake Wilderness Area. The landscape also provides important connectivity from spring, summer and fall ranges into crucial winter ranges on foothill grasslands in the lower elevations between US Highway 93 and Grant Creek. To some extent, the current ski boundary already fragments wildlife movement through this area, but the proposed expansion would nearly double the current size of Snowbowl, resulting in an increase in its zone of impact across a much larger landscape. Some of the negative impacts of the expansion include habitat loss, habitat fragmentation, increased edge effect on songbirds, and displacement of wildlife (during and after construction). These negative impacts would be exacerbated by the increase in recreational use at the ski area, especially since the ski resort is currently more of a “Mom and Pop” establishment that receives the majority of use during the winter, but also minimal use throughout the rest of the year. Based on the current proposal, “the Proposed Action would increase outdoor recreation opportunities for both dispersed recreation (e.g., hiking and mountain biking) and developed recreation (e.g., skiing, snowboarding, folf, and lift-supported mountain biking).” The stated Purpose and Need of the project is “enhancing summer use and balancing summer and winter uses” (p. 1-7). Thus, the expansion would result in a more robust 4-season resort, which is significantly different than a modest ski operation because of increased, year-round human activity. Other secondary, negative effects of a 4-season resort include the probability of increased residential and seasonal housing development in the North Hills. With the expansion of the ski area, we would expect to see increased residential and resort development to occur in the North Hills, and consequently, increased property values. The North Hills provides important winter range for elk, and habitat for white-tailed deer, mule deer, moose, black bear, and mountain lion. The City of Missoula Open Space Management Plan describes the North Hills as one of the open space cornerstones in the Valley that is in need of conservation to protect the aesthetic (viewshed) and wildlife resource values. Also, nonprofit land trusts have worked with FWP to identify, protect and conserve key, wildlife-rich parcels in the North Hills area. As development continues to occur in the Missoula Valley, the North Hills becomes even more valuable for wildlife with its direct connection with the Rattlesnake Wilderness, Evaro Hill, and intact Tribal lands to the north. Respondent: 26
Final EIS 5-17 Montana Snowbowl Chapter 5 Response to Comments
Response to comment: See response in Section X.2.8 Wildlife – General, to Comment 4. As disclosed in the impacts section for wildlife (FEIS, Ch. 4, pp. 4-17 through 4-54 and Section 4.0 of the Wildlife Report), the proposed expansion may impact individuals of wildlife species but is not expected to impact the populations of the species. Additionally, the proposed expansion would not appreciably affect development of the North Hills. Implementing the City of Missoula’s Open Space Plan would not be affected by the proposed project. Decisions on zoning or other measures to retain wildlife values in the North Hills are the responsibility of the city and county (of Missoula).
6. It did not appear as though there were any prescriptive mitigative measures described within the DEIS (outside of bear-resistant garbage containers) for the above-mentioned impacts. These are cumulative impacts that should be offset with creative conservation or mitigation strategies, especially since the Proposed Action would allow the private sector to increase year-round recreational opportunities on the LNF, a public resource. Respondent: 26
Response to comment: Additional resource protection measures for wildlife were developed and included in Section 2.5.2.5 (p.2-20) of the FEIS (as adapted from Section 1.2.2, pp.13-14 of the wildlife report (in project file). Cumulative impacts for wildlife are summarized in Section 4.5.2.1.1 (pp. 4-40 through 4-53) of the FEIS for the proposed action. For a more detailed description of the determinations, refer to Section 4.0 of the wildlife report (in the project file).
7. In addition, we would expect to see an increase in wildlife conflicts involving lions, wolves, black bears, grizzly bears, elk and deer. Respondent: 26
Response to comment: Conflicts between private landowners (including livestock and domestic pets) and wildlife is expected to continue long into the future as the population associated with the city of Missoula and surrounding area increases, and development on adjacent private lands increases. Whether or not the project would contribute to increased development in the area is immeasurable and unknown. More than 17% of the NCDE is private land, and the majority of bear-human conflicts and bear deaths occur on these private lands because of conflicts arising from attractants, such as garbage, fruit trees, bird feeders, grills, composting, livestock/poultry feed, etc. Educational efforts (by non-Forest Service entities) would continue to teach private land owners about the negative impacts that attractants have on wildlife species. To reduce the potential for animal/human conflicts, particularly with grizzly bears and black bears, in the proposed and existing SUP all potential animal attractants (including garbage, grills, fuel, etc.) must be stored in a bear resistant manner year-round, consistent with methods outlined in the LNF Food/Wildlife Attractant Storage Order (Section 2.5.2.5, p.2-20 of the FEIS).
8. It has already been established through bird surveys conducted by the Avian Science Center (University of Montana) and others, that pileated woodpecker, Cassin’s finch, brown creeper, Clark’s nutcracker, and numerous neotropical migratory birds are found in the proposed expansion area. Tree removal should avoid the primary nesting periods for these birds (April 1 through August 15), to avoid direct mortality of nestlings and fledglings. Removal of large trees would permanently remove nesting habitat for some
Final EIS 5-18 Montana Snowbowl Chapter 5 Response to Comments
of these species, which will reduce the populations of these species in the expansion area. Respondent: 26
Response to comment: In accordance with the Migratory Bird Treaty Act, and the resulting Memorandum of Understanding between the Forest Service and the U.S. Fish and Wildlife Service, the EIS analyzes the risk to bird species of greatest conservation concern that are typical of a range of habitats that would be affected (e.g. northern goshawk, pileated woodpecker, bald eagle, black-backed woodpecker and flammulated owl). State species of concern that exist in similar habitats would be affected similarly to species addressed in the EIS. The Forest included resource protection measures to reduce the potential for disturbance to breeding birds (Section 2.5.2.5, p. 2-20 of the FEIS and Section 1.2.2, p. 13-14 of the Wildlife Report). While the expansion could impact a few individual animals, through disturbance, displacement, and habitat fragmentation, it would not have impacts at the larger population scale.
9. The section on Bald Eagle (page 4-21 in Direct, Indirect and Cumulative Effects to wildlife, Sec 4.5.2.1), correctly indicates that increased incidence of road-killed wildlife along Grant Creek Road could attract bald eagles and present an increased mortality risk to them from vehicle collisions. A pair of bald eagles nests along Grant Creek, fairly close to Grant Creek Road. Death of one of the nesting adults from this pair would likely reduce the potential productivity of this pair for one or more years until the surviving adult finds a new mate. The DEIS states that rapid carcass removal would reduce this hazard, but does not indicate who will be responsible for removing road-killed animals from Grant Creek Road, or how it would improve over the current situation. Other wildlife species besides big game may experience mortality due to vehicle collisions from increased traffic levels on Grant Creek Road, including furbearers, bears, amphibians, owls, raptors, and songbirds. For example, a road-killed western screech-owl, which is a Montana Species of Concern, was found along Grant Creek Road in December 2010. Mitigation measures to reduce the impacts to wildlife from increased Snowbowl traffic on Grant Creek Road should be implemented, such as providing more frequent shuttles between the lower skier parking lot (adjacent to the Town Pump near Interstate Highway 90) and Snowbowl during the ski season, and expanding these shuttle services to cover summer weekends or non-winter periods when Snowbowl is hosting special events. Respondent: 26
Response to comment: The removal of carcasses along lower Grant Creek Road is the responsibility of Missoula County. MSB will work with Missoula County to ensure removal of carcasses along Grant Creek Road is completed as quickly as possible (Section 2.5.2.5 (p.2-20) of the FEIS (as adapted from Section 1.2.2, pp.13-14 of the wildlife report (in project file). The FEIS also includes providing a continuous shuttle service on busy days from lower Grant Creek Road to MSB, in response to increased traffic concerns (Section 1.3, p. 1-6) to alleviate increased traffic on Grant Creek Road and aid in reducing potential impacts to bald eagles and other animals,.
10. Rarely have I seen much wildlife in this area, and the terrain is nothing special either. The ecosystem takes the brunt of storms 3 seasons of the year, making it unsuitable for spring elk calving. Fawns born in this area don’t have a chance. Cutting trees and seeding the proposed ski runs could result in a new food source from late spring thru the fall, thus improving the habitat for wildlife. Ski resort operations generally last only 4 months, during a season when this area is uninhabitable! The only mammals willing to
Final EIS 5-19 Montana Snowbowl Chapter 5 Response to Comments
go there during winter are skiers and snowboarders, and the occasional confused wolf. When elk begin to migrate to their new food source on the ski runs, nature will regulate the herd size by enticing wolves to play the role they are intended for. It’s win-win for the elk and wolves both, and all other creatures who feed on a kill. Respondent: 27
Response to comment: As discussed in Section 3.5, pp.3-29 through 3-89 of the FEIS, some wildlife species do inhabit MSB during the winter. Species potentially present during winter include Canada lynx, snowshoe hare, pine marten, wolverine, mountain lion and red squirrel. The effects of the proposed expansion on these and other species are discussed in Section 4.5, pp. 4-18 through 4-53 of the FEIS.
11. Many memorable encounters with wildlife and natural beauty happen at the ski hill. These experiences foster desire for conservation and balanced ecology. Expanding MSB may promote increased awareness in humans that far offsets the immediate impacts. Respondent: 32
Response to comment: Noted. No response necessary.
12. Concerned that as Montana Snowbowl expands and becomes a four-season resort, demand for recreational subdivision could increase in Grant and Butler Creeks, areas now providing important habitat for turkeys, deer, elk, and black bears. In coming years, perhaps by the time of Snowbowl’s expansion, grizzly bears may be living in the upper ends of Grant and Butler Creeks. Recreation subdivision will increase the challenge of managing wildlife—particularly mountain lions, bears, and wolves—on the fringes of Missoula. Respondent: 42
Response to comment: The LNF acknowledges that past, existing or proposed projects in the vicinity of the MSB, including the proposed expansion, may detract from potential wildlife linkage habitat. Suburban housing development and associated wildlife-domestic pet conflicts that may ensue as well as human activity in the area may displace wildlife (cumulative impacts to wildlife in Section 4.5.2.1.1, p 4-40 through 4-53 of the FEIS). However, neighboring undeveloped LNF land, including the Rattlesnake Wilderness, provides hiding cover to secure seasonal wildlife movements. Additionally, the LNF does not anticipate the proposed expansion to increase the rate of housing development (Section 4.12.2.1, p. 4-81 through 4-83 of the FEIS). Discussion on future land use, including subdivision, is provided in Section G.2.16, p.G-45 of the FEIS.
13. In recent and impending years industrial ski area expansion stands to occupy more and more high-elevation habitat in the northern Rocky Mountains. Important habitat and connectivity for endangered species and other rare and sensitive wildlife continue to be fragmented and depleted by these expansions. Yet with each expansion, the big picture of how much habitat is threatened or lost is missed as the analyses focus just upon a few acres of each individual expansion. (“This is a relatively small amount of …habitat compared to what is available on adjacent areas…”) Our groups are concerned that the main manager of publicly owned wildlife habitat, the U.S. Forest Service, has not seen fit to perform any analysis of just how far these piecemeal losses of habitat can proceed before the impacts cross the line of ecological and social acceptability. Low elevation habitats, mostly on private or industrial lands, have been largely lost to many wildlife
Final EIS 5-20 Montana Snowbowl Chapter 5 Response to Comments
species due to human developments and encroachments upon key habitats. Connecting corridors for the remaining habitats on higher elevations have been severed by highways and other habitat modifications and developments. And the effects of climate change will likely reduce habitat quality for these species in the coming decades. Now, wildlife stand to permanently lose thousands more acres due to industrial human recreational activities such as alpine skiing, snowmobiling, off-highway vehicles, and other uses. Members of our groups enjoy alpine skiing, including at Montana Snowbowl. But on behalf of the remaining wildlife populations, our groups are forced to ask—how much is enough? The DEIS fails to adequately consider the effects of climate change. There is ongoing and potential loss to species such as Canada lynx, wolverines, and other species depending upon secluded, remote or high-elevation habitats. The DEIS disregards climate change impacts on the viability of maintaining skiing in the expansion area, on Montana Snowbowl (MBS), and on the regional ski industry. Roads create some of the biggest threats to fish and wildlife habitat. Yet the DEIS maps fail to clearly display all the roads and other motorized access routes in the project area and cumulative effects analysis area. The DEIS indicates that there would be more incremental loss of habitat for management indictor and sensitive species such as the Canada lynx, wolverine, northern goshawk, fisher, flammulated owl, pileated woodpecker, black-backed woodpecker, western toad, and elk. Besides winter impacts, summer impacts include permanent habitat alteration and increased displacement from additional mountain bike trails. The DEIS fails to describe the quantity and quality of habitat necessary to sustain the viability of these species and explain the methodology for measuring the habitats. The Lolo National Forest (LNF) viability plans such as its old-growth strategy and the cited Samson document have not passed the test of independent, scientific peer review for assuring viable populations. The DEIS fails to disclose the degree of wildlife habitat impacts due to the likely glading between runs. Respondent: 51, 52
Response to comment: The adjacent lands referenced in the analysis as escape habitat, or refugia, include the Rattlesnake Wilderness (designated by Congress) which was included, along with other private, state, and Forest Service lands, in the cumulative effects analysis area for wildlife (refer to Sections 3.5.3, p.3-36 and 3.5.4 pp.3-36 through 3-44; as well as Section 2.4, p.16 of the Wildlife Report). The analysis area was selected to ensure it was large enough in scale to include the home ranges of most wildlife species in the area as well as to evaluate landscape connectivity for wide- ranging species (including grizzly bear, lynx, wolf, wolverine, fisher, and elk) moving in and among the sub-watersheds. The methodology for measuring habitat quality and quantity, (which is a product of all past activities such as wildfire, vegetation management, climate, road building, development, etc.), is a complex and iterative process that requires using the regulatory framework and best available science and data. Methods are fully detailed in the wildlife report in Section 2 (project file) (including all subsections), and throughout all of Section 3.5, Wildlife Affected Environment pp 3-29 through 3-89 of the FEIS. Table and map displays throughout the sections to aid the reader in visualizing the analysis area. Viability of individual species is addressed (refer to Chapter 3 and 4 of the FEIS, Section 3.5 (pp. 3-25 through 3-89) for Affected Environment and Section 4.5 (pp. 4-17 through 4-53) for Environmental Consequences pertaining to wildlife.
The proposed expansion area will be changed from MA16 (timber production) to MA8 (ski areas) resulting in minimal future habitat manipulation.
Final EIS 5-21 Montana Snowbowl Chapter 5 Response to Comments
Individual species write-ups in from Sections 3 and 4 of the Wildlife Report are summarized in Sections 3.5 (pp. 3-29 through 3-89) and 4.5 (pp. 4-18 through 4-53) of the FEIS. The Resource Protection Measures for wildlife (Section 2.5.2.5, p. 2-20 of the FEIS) requires natural snag and woody debris recruitment to occur (where feasible and where trees are not a hazard to humans) in forested inter-trail islands, thus reducing the possibility of glading between runs. Refer to the response in Section 5.2.8 Wildlife – General of the FEIS, to Comment 4 for information on corridors.
See response to comment #1 in Section 5.2.15 Climate Change of the FEIS. The Wildlife Report adequately addressed the impacts of the expansion along with climate change for species, such as the Canada lynx and wolverine that need areas of deep, persistent snow. For Canada lynx, the Forest found that 94% of the LAU is located in Wilderness (where development is precluded) that would be left intact, with more suitable habitats and persistent snows at higher elevations than those found in the existing or proposed SUP areas. Based on average snow depths, the Rattlesnake Wilderness will continue to provide lynx and wolverine with suitable snow conditions for the duration of the SUP (40 years). Additionally, refer to Section 4.1.3, including Table 4.3 and Sections 4.1.5; 4.3.4 and 4.3.5 of the Wildlife Report (project file).
5.2.9 Wildlife – TES
1. The Canada Lynx is listed as a threatened species; nevertheless, 654 acres of the Canada Lynx Critical Habitat is located within the proposed expansion area (3-42). What is the purpose of designating land as "Canada Lynx Critical Habitat?" If "Critical" is in name only, then please feel free to disregard semantics; however, if the designation is meant to signify an area set aside for preservation and promotion of a species, then actions should be in accordance with this designation. Three separate bird species listed as "sensitive," rely on acreage within the proposed expansion area [Pileated Woodpecker, Northern Goshawk, and Flammulated Owl] (3-50). Yet, their habitats are willing to be sacrificed to increase an unneeded human desire. Ignorance of facts such as these will only provide a precedent for future denigration of our public lands. Respondent: 21
Response to comment: Critical habitat is a term defined in the ESA. It identifies geographic areas that contain features essential for the conservation of a threatened or endangered species and may require special management or protection or considerations. Critical habitat is determined after taking into consideration the economic impact it could cause, as well as any other relevant impacts. The Secretary of the Interior may exclude any area from critical habitat if the benefits of exclusion outweigh the benefits of inclusion, as long as the exclusion would not result in the extinction of the species. When considering which lands should be designated as critical habitat, the FWS uses the best scientific data available as well as information from State, Federal and Tribal agencies and from academic and private organizations. The regulatory framework of management direction for the Canada Lynx, as well as other wildlife species, was used to analyze impacts from the proposed project (Section 3.5.1, pp.3-29 through 3-34 of the FEIS). Programmatic objectives, standards, and guidelines were identified in relation to the proposed expansion (Section 4.5.2.1, pp. 4-21 through 4-27 of the FEIS as summarized from Section 4.1.3 of the Wildlife Report, on file).
The evaluation of impacts to all three birds species are summarized in the FEIS (Section 4.5.2.1. pp. 4-34 through 4-36 for the flammulated owl; p. 4-38 for the MIS pileated
Final EIS 5-22 Montana Snowbowl Chapter 5 Response to Comments
woodpecker; and pp. 4-36 through 4-37 for the Northern Goshawk). Scientific basis for direct, indirect, and cumulative impacts determined each species has an increased risk of displacement due to disturbance from construction and other human activities. Resource Protection Measures (Section 2.5.2.5, p 2-20 in the FEIS) were designed to reduce these impacts.
2. It is difficult to address the Forest Service's response to concerns about potential impacts upon listed species without the benefit of a Biological Assessment on the Preferred Alternative, which will presumably be Alternative B. If the Forest Service follows and requires its guidelines for TES Species management, one might assume the mitigation features that the agency requires will be adequate. However, some level of uncertainty will continue to exist, and the certainty of adherence to accepted management stipulations is not a given. I concur with the documents "may affect, but is not likely to affect" finding on the grizzly bear, but I still have concern about potential conflicts. I have the same concerns about conflicts with black bears, which are very common in the area. Depending upon the nature and extent of other developments on adjoining lands, the potential for bear/human conflicts could increase substantially. Costs of dealing with these conflicts would then fall upon wildlife management agencies that are already limited in funding and personnel to deal with these conflicts. I concur with the document's "may affect, but is not likely to affect" finding on the Canada lynx and gray wolf. Again, the final requirements for mitigation and adherence to those will be important to lessening disturbance and habitat degradation. I concur with the document's findings regarding the bald eagle, black-backed woodpecker, boreal toad, peregrine falcon, flammulated owl, northern goshawk and pileated woodpecker. I continue to have concerns about the proposed expansion's impacts upon the fisher and wolverine. Respondent: 25
Response to comment: A biological assessment for impacts to threatened Canada lynx and grizzly bear was prepared and submitted to the U.S. Fish and Wildlife Service with a request for written concurrence that the proposed expansion “may affect, but is not likely to adversely affect” Canada lynx and Grizzly Bear. Written concurrence was received on June 20, 2013. The project represents a relatively small part of a wolverine’s or fisher’s home ranges which are extensive. The proposed expansion would not affect wolverine denning habitat, which often is in alpine cirques. The expansion area does not appear to be optimal fisher habitat because of large accumulations of snow and the scarcity of riparian habitat.
To reduce the chance of wildlife/human conflict, resource protection measures for wildlife include the implementation of the LNF Food/Wildlife Attractant Storage Order year-round (Section 2.5.2.5, p. 2-20 of the FEIS). The LNF Wildlife Biologist will be contacted immediately if TES or proposed wildlife species are encountered during project implementation. Project implementation will be altered based on the Wildlife Biologist’s assessment of the situation. The LNF is anticipating these and other resource protection measures will reduce the possibility of wildlife/human conflicts; therefore, minimizing the need to involve wildlife management agencies.
The gray wolf was delisted during this assessment and consultation was not required at the time the BA was prepared. The gray wolf discussion was retained in the FEIS but moved to the sensitive species section (refer to Section 3.5.4, p. 3-68 for the Affected Environment discussion and Section 4.5.2, pp. 4-29 through 4-30 for impacts discussion of the FEIS).
Final EIS 5-23 Montana Snowbowl Chapter 5 Response to Comments
Fishers are considered a species of concern for the State of Montana, yet they continue to be classified as a furbearer species managed by the MFWP and are legally trapped under a limited quota system. Fishers have not been documented in the analysis area but large patches of fisher habitat occur adjacent to the riparian areas. It is expected that fishers may be displaced from disturbance during construction but mortality is not expected (refer to Section 3.5.4, p. 3-69 through 3-70 for the Affected Environment discussion and Section 4.5.2, pp. 4-32 through 4-34 for impacts discussion of the FEIS).
Wolverine are currently proposed for federal listing and considered a sensitive species for the Forest Service. Based on the most current scientific information, wolverines may utilize habitat in the proposed and existing SUP areas but as part of a much larger home range. The proposed and connected actions would not affect denning habitat or increase the potential for wolverine mortality from ski area development and subsequent use (refer to Section 3.5.4, p. 3-57 through 3-59 for the Affected Environment discussion and Section 4.5.2, pp. 4-28 through 4-29 for impacts discussion of the FEIS).
3. We do not agree with removing old growth trees. Please leave large-diameter trees for nesting birds, especially flammulated owls in the lower elevation forests of the expansion area. As was mentioned in the DEIS, studies have not been conducted on flammulated owls in the TV Mountain area, but flammulated nesting sites have been documented on nearby habitats. Respondent: 26
Response to comment: Resource protection measures for wildlife (Section 2.5.2.5, p. 2- 20 of the FEIS) have been added to minimize disturbance to wildlife. The protection measure for flammulated owls is to reduce disturbance to mating, nesting, or fledging flammulated owls by no cutting ski runs or hazard trees in occupied flammulated owl habitat from May 1 – July 15 and to work with the LNF Wildlife Biologist to identify these areas prior to construction activities.
4. The DEIS only evaluates potential effects on the Forest Service category of Sensitive Species, but does not evaluate effects on all Montana Species of Concern (SOC). Bird Species of Concern found within the project area include brown creeper, Cassin’s finch, Clark’s nutcracker, flammulated owl, great gray owl, northern goshawk, and pileated woodpecker. The EIS should evaluate impacts on all of these species, not just Forest Service Sensitive Species. Impacts on additional mammal Species of Concern were not evaluated, including hoary bat and fringed myotis. Respondent: 26
Response to comment: The Forest Service is required by the National Forest Management Act (NFMA) and its implementation regulations to provide for a diversity of native plant and animal communities based on the suitability and capability of the land in order to meet multiple use objectives (16 U.S.C. 1604(g)(3)(B); 36 CFR 219.10(b) (2005); and FSM 2670.12).
The wildlife report (on file) for the project, Section 2 – Report Overview and Methodology (pp. 14-20), as well as the Regulator Framework Sections for each species (Sections 3.3.1 (p.27), 3.4.1 (p.34), 3.5.1 (p.37), 3.6.1 (p.41), 3.15.1 (p56), and 3.20.1 (p.64) of the Wildlife Report) explain the laws, regulations, and policies that direct how an analysis of project effects on the full range of habitats provided in the analysis area must be
Final EIS 5-24 Montana Snowbowl Chapter 5 Response to Comments
conducted, including the wildlife species that must be considered. These are also summarized at the beginning of each species description in Section 3.5 (pp. 3-29 through 3-89) of the FEIS.
Additionally, Section 2.5 (p. 17) of the Wildlife Report (on file) states: “Species considered in this analysis include those listed as federally threatened, endangered, or candidate on the Lolo NF (USDI-FWS 2012) and Forest Service sensitive species (USDA-FS 2013). These species are also included on the Montana animal species of concern list (MNHP 2013). In addition, Management indicator species (MIS) were designated in Forest Plans to represent species whose population changes are believed to indicate the effects of management activities on representative wildlife habitats (FSM 2621). Table 2.1 (p. 18) in the Wildlife Report provides a list of those species, special habitat associations, whether the habitat or species are present in the analysis area, and whether the habitat or species would be impacted by proposed activities.
5. We are pleased that project guidelines to address requirements of the Northern Rockies Lynx Management Direction and Inland Native Fish Strategy (INFISH) are identified (page 2-14 to 2-15), and potential effects on the threatened Canada Lynx are evaluated and disclosed (4-15 to 4-20). We are concerned that the proposed project will result in the loss of 45 acres of suitable lynx habitat and 30 acres of mature multi-story habitat in the lynx analysis unit, although this is stated to be a small incremental loss.
Respondent: 40
Response to comment: The proposed and existing SUPs comprise a relatively small percentage (6%) of the southwest corner of the Rattlesnake LAU. The remaining 94% of the LAU is located in designated Wilderness that will remain intact where development is precluded (FEIS Section 4.1.3).The LNF sought informal consultation with the FWS for the threatened Canada lynx (and grizzly bear). The FWS concurs with the LNF determination of “may affect, but is not likely to adversely affect” finding for Canada lynx with the acknowledgement of the loss of acreage.
6. The DEIS proposes to draw a very large quantity of additional water from Butler Creek and expose upper La Valle Creek to an enormous increase in mechanically abetted human activity (via two new lifts [A and B] despite the cutthroat and endangered bull trout known to be present, arguing that these are stranded populations as the creeks no longer flow readily into the Clark Fork, so it doesn’t really matter. The Canada Lynx is listed as a threatened species, yet 654 acres of its Critical Habitat fall within the proposed expansion. In addition other ‘threatened’ or ‘endangered’ or ‘sensitive’ species will be unduly hammered, those either known or suspected to frequent the area and relying on it to (incalculably)various degrees--Grizzlies and Gray Wolves, Fishers and Wolverines, Flammulated Owls and Pileated Woodpeckers and Northern Goshawks. Respondent: 50
Response to comment: The LNF sought informal consultation with the FWS for the threatened Canada lynx and grizzly bear and formal consultation for the endangered bull trout. A concurrence letter on impacts to Canada lynx and grizzly bear was received from the FWS on June 20, 2013. A BO on impacts to threatened bull trout was received on September 20, 2013 from the FWS. The determinations of the impacts of the proposed project are based on the best science available as well as on the ground knowledge of the area. The LNF acknowledges individuals may be impacted (mostly
Final EIS 5-25 Montana Snowbowl Chapter 5 Response to Comments
through displacement during construction and to a lesser degree during subsequent use) but the populations as a whole will remain viable. Please refer to Section 4.5.2.1 (pp. 4- 21 through 4-27) of the FEIS for the determination summary for Canada lynx, Section 4.5.2.1 (pp. 4-19 through 4-21) for grizzly bear, and Section 4.6.2 (pp. 4-57 through 4- 63) for bull trout.
7. The USFS has a fundamental responsibility to “maintain natural habitat” and to “rehabilitate” or even “restore” forests, watersheds, etc. and regarding endangered or threatened species of wildlife, section 7 of the Endangered Species Act “directs federal agencies to ensure that actions authorized, funded or carried out by them are not likely to jeopardize the continued existence of threatened or endangered species or result in destruction or adverse modification of their critical habitat” (3-17). Yet despite these laudable values and goals, so many of the proposed actions--in one way or another, either admittedly or through circumlocution (a wink and a nod)--appear to condone exactly such a broad and ongoing, and perhaps ultimately even irreversible, assault. Respondent: 50
Response to comment: Noted. No response necessary
8. The DEIS fails to adequately recognize the ski area location in relation to important wildlife core habitats. It lacks maps that show the cores along with the important connecting corridors for grizzly bears, wolverines, lynx and other wildlife. For example, the Evaro Hill area has long been considered part of an important wildlife linkage, providing security and connectivity from the Rattlesnake and Mission Mountains to the Bitterroot and Coeur d’Alene Mountains and beyond. In recent years, grizzly bears have been thought to have accessed the Ninemile watershed via the corridor. The DEIS does not indicate how the proposed adverse modification of Canada lynx habitat would be consistent with the Endangered Species Act. In sum, the DEIS fails to adequately analyze cumulative impacts to the ESA-listed, management indictor and sensitive species such as the Canada lynx, wolverine, northern goshawk, fisher, flammulated owl, pileated woodpecker, black-backed woodpecker, western toad, and elk. Respondent: 51, 52
Response to comment: Maps have been added to the FEIS (Figure 3-5, p.3-52; Figure 3-8, p.3-60; Figure 3-9, p. 3-67; Figure 3-10, p. 3-71; Figure 3-12, p.3-79). Wildlife linkage zones and critical habitat were considered in the analysis to determine impact levels to TES wildlife species (Section 3.5.4.6, pp. 3-86 through 3-88 of the FEIS) and the reference to Evaro Hill is specifically addressed on p. 3-88 of the FEIS. The ESA specifies that a federal action must not jeopardize the continued existence of any listed species or result in the alteration of critical habitat that appreciably diminishes the value of critical habitat for the recovery or survival of any listed species. The NRLMD further identifies conservation measures for recreation developments that help achieve management objectives. Based on the analysis of lynx habitat components, the location of the MSB proposed expansion on the margin of lynx critical habitat, and informal consultation with the FWS, it was determined that the project would not appreciably diminish the value of critical habitat for the recovery and survival of lynx (Section 4.5.2.1, pp. 4-21 through 4-27 of the FEIS). Cumulative effects for ESA listed, MIS, and sensitive species are addressed in Section 4.5.2.1, pp. 4-19 through 4-52 of the FEIS and a comprehensive discussion of cumulative impacts is provided in Section 4, pp. 67-108 of the Wildlife Report (on file).
Final EIS 5-26 Montana Snowbowl Chapter 5 Response to Comments
5.2.10 Fish
1. Extinction risks are already extreme for the endangered bull trout and are high for native cutthroat trout within the Butler Creek watershed; further water withdrawal will directly, adversely affect bull trout. Ignorance of this fact is reckless. The USFS should seek to promote the habitats of endangered and native species, not purposefully denigrate their niches. Respondent: 21
Response to comment: The wetted perimeter analysis conducted as part of this EIS (Reiland 2008) concluded that the current water withdrawal for snowmaking at MSB (the existing conditions) was likely negatively affecting over-wintering habitat for bull trout and westslope cutthroat trout in the upper reaches of Butler Creek below the snowmaking water diversion. Therefore, if the LNF chooses the No Action alternative there would be a continued impact to bull trout and westslope cutthroat trout habitat in this reach. However, the Proposed Action would include provisions for maintenance of 30 gpm flow during snowmaking activities to protect this habitat as a Connected Action. Therefore, if the LNF chooses the Proposed Action there would be an improvement in bull trout and westslope cutthroat trout habitat in this reach of Butler Creek.
2. Is concerned about impacts to fish in upper Butler Creek. Is concerned about frog habitat in the Butler Creek watershed. Respondent: 16
Response to comment: Noted. No response necessary. Sections 3.5 (Wildlife, pp. 3-29 through 3-89); 3.6 (Fisheries, pp. 3-90 through 3-105), 4.5 (Wildlife, pp. 4-17 through 4- 4-54) and 4.6 (Fisheries, pp. 4-54 through 4-63) of the FEIS provide information and analysis related to wildlife, fish and other aquatic resources.
3. FWP surveys at 8 sites (2002-2009) on these streams indicate that both support viable, genetically pure westslope cutthroat trout (WCT; a Montana Species of Concern) populations, as well as other sensitive species such as the Rocky Mountain tailed frog. FWP and the US Forest Service are both signatories on the Montana Cutthroat Trout Agreement and MOU, which places extremely high value on and commits to protective measures for remaining genetically pure WCT isolates such as these. The most significant issue associated with this project is the expansion of water withdrawals from Butler Creek for snow-making. Proposed expansion of water usage and extension of the withdrawal period threaten to dewater Butler Creek to the point of impacting resident aquatic populations as they overwinter. Instream flows are an important limiting factor for fish during winter, particularly at these elevations. Our sampling indicated that WCT were abundant right up to the Snowbowl Lodge and likely to the point of diversion. As the Draft EIS mentions, measures to ensure that adequate instream flows are maintained in Butler Creek below the diversion point should be included in the project, guaranteed in writing, and monitored. The Draft EIS indicates that 30 gpm will be left instream throughout the winter, but we are not sure how this flow rate was derived or if <0.1 cfs is adequate to sustain these aquatic populations. This flow rate equates roughly to the discharge of a standard garden hose. Respondent: 26
Response to comment: The discharge in Butler Creek dropped below 0.1 cfs in all study reaches by mid-September, which was before any snowmaking water was withdrawn by
Final EIS 5-27 Montana Snowbowl Chapter 5 Response to Comments
MSB (Reiland 2008). Therefore, MSB water snowmaking withdrawals were not the cause of discharges less than 0.1 cfs.
The 30 gpm maintenance flow rate was developed by LNF and contractor fisheries biologists. This rate was developed by providing an adequate buffer to the Butler Creek base flow rate of 17 gpm which provided 2.4 inches of water at that measurement point (Reiland 2008). The average body depth of a resident adult westslope cutthroat trout is 1.8 inches; therefore, the fisheries biologists concluded that 30 gpm would adequately protect, and improve, over-wintering habitat in the affected reaches.
4. The EPA's most significant environmental concern regarding the proposed MSB expansion DEIS involves increased adverse dewatering effects to Butler Creek fish and aquatic life and crucial over-wintering fisheries habitat that would result from diversion of an additional 20 acre-feet water from Butler Creek during the mid-October to end of March period. It is our understanding that MSB's proposed ski area expansion would increase the total water withdrawals from Butler Creek from 28 acre-feet to 48 acre-feet per year, with the additional water withdrawal needed for both snowmaking (15 acre- feet) and fire protection (5 acre-feet). This will be achieved by withdrawing water at the same rate that is currently used (115 gpm), but extending the period of withdrawal of water from Butler Creek from 55 maximum days per year to 94 days per year (increase of 39 days). The DEIS indicates that the existing MSB water diversion of 28 acre-feet during the mid-October to end of March period for snowmaking and water supply is already negatively affecting over-wintering habitat in section 1 of Butler Creek, and the upper portion of section 2. The DEIS also states that at the local level (Butler Creek, La Valle Creek, and Grant Creek), extinction risks are "extreme" for bull trout (a threatened species) and "high" for westslope cutthroat trout. The reasons given include water withdrawal in Butler Creek and local stream habitat conditions. Population habitat conditions for bull trout are stated to be already functioning at unacceptable risk for all indicators on Butler Creek. Accordingly, we are concerned that diversion of an additional 20 acre-feet over an additional 39 days during the overwintering period is likely to further aggravate dewatering effects to fish and aquatic life and crucial over-wintering habitat. The DEIS states that extending MSB's water withdrawal to mid-October would extend Butler Creek's low flow conditions, and could potentially dewater riffle habitats in Section 1 as early as mid-October, and could impact wests lope cutthroat trout overwintering habitat. The DEIS indicates that MSB would construct a flow monitoring station on Butler Creek to monitor and report flow rates during the winter season, and that the LNF will confirm that flows are protective of aquatic organisms during crucial over-wintering conditions by verifying that minimum flows of 30 gpm will be maintained in Butler Creek for fish habitat. While we are pleased that monitoring of low flows in Butler Creek is proposed, it is not clear to us how flows protective of aquatic life and crucial over- wintering habitat can be consistently provided, since existing water withdrawals are already resulting in adverse effects to Butler Creek aquatic life and over-wintering habitat, and an additional 39 days of water withdrawals at 115 gpm are proposed that will result in loss of an additional 20 acre-feet of streamflow during this winter period. We note that in addition to the 48 acre-feet of water withdrawn from Butler Creek by the MSB, the DEIS states that 17 acre-feet of water are also withdrawn by downstream users from October to March, and it is estimated that the watershed only produces 74 acre-feet of water during this period. This leaves only 9 acre-feet in Butler Creek to support fish and aquatic life during the crucial over-wintering period. Table 3-11 in the DEIS reports Butler Creek flows on various days in 2008, but only includes two days reporting flows during the mid-October to end of March period (i.e., flows of 0.07 cfs or
Final EIS 5-28 Montana Snowbowl Chapter 5 Response to Comments
31 gpm on October 30; and 0.04 cfs or 18 gpm on November 6 in section 1). No flows are reported for section 2 or section 3 of Butler Creek, and no other flows are reported during the mid-October to end of March period (i.e., December, January, February, or March). If a minimum flow of 30 gpm (0.067 cfs) in Butler Creek is needed to maintain fish habitat, it appears that such minimum flows may already be threatened, since the only two reported flows during the October to March period are only 31 gpm and 18 gpm in section 1. We also note that the DEIS states that at the existing MSB diversion Butler Creek flows vary from 80 gpm to 116 gpm during the mid-October to end of March period (which seems inconsistent with the Butler Creek flows reported in Table 3-11). It is not clear to us how 115 gpm will be withdrawn from Butler Creek over an additional 39 days during the winter without additional adverse dewatering effects to crucial over- wintering fisheries habitat. The DEIS states that Butler Creek gains volume as it flows downstream so that dewatering effects diminish downstream, ending before known bull trout locations, but westslope cutthroat trout occupying the upstream dewatered sections of the creek would be affected. The Butler Creek locations on which the existing and proposed MSB diversions take place in relation to important fisheries and fisheries habitat are not clearly presented. We recommend that the FEIS include a map showing Butler Creek sections 1, 2, and 3 and locations of crucial over-wintering pools in relation to MSB water diversion locations. We also recommend that the FEIS include additional discussion regarding how the LNF will be able to confirm that adequate Butler Creek in- stream flows can be consistently maintained that are protective of aquatic life and crucial over-wintering habitat. We believe efforts should be made to mitigate worsening of the already extreme risks of extinction of bull trout and high risk of extinction of westslope cutthroat trout at the local level. We recommend evaluation and discussion regarding the potential for pumping water from other water sources for snowmaking to avoid additional adverse effects to fish and aquatic life and over-wintering and riffle habitats in Butler Creek. Respondent: 39, 40
Response to comment: The wetted perimeter analysis conducted as part of this analysis (Reiland 2008, in project file) concluded that the current water withdrawal for snowmaking at MSB (the existing conditions) was likely negatively affecting over- wintering habitat for bull trout and westslope cutthroat trout in the upper reaches of Butler Creek below the snowmaking water diversion. Therefore, if the LNF chooses the No Action alternative there would be a continued impact to bull trout and westslope cutthroat trout habitat in this reach. However, the Proposed Action would include provisions for maintenance of 30 gpm flow during snowmaking activities to protect this habitat as a Connected Action. If this flow rate were not met, MSB would not be able to withdraw the 115 gpm for snowmaking and maintain reservoir levels. Therefore, if the LNF chooses the Proposed Action there would be an improvement in bull trout and westslope cutthroat trout habitat in this reach of Butler Creek (Table 2-2, p. 2-24 and 2- 25 of the FEIS).
Figure 3-16 has been added to the FEIS (p. 3-94) to show Butler Creek wetted perimeter analysis sections (1, 2, and 3 on the map) in relation to the MSB water diversion. Crucial over-wintering pools were not added because Butler Creek is so small these features could not be effectively displayed.
5. We did not see any mitigation proposed for additional loss of crucial overwintering fisheries habitat in Butler Creek. The DEIS only states that MSB would construct a flow monitoring station on Butler Creek to monitor flow rates during the winter season, and
Final EIS 5-29 Montana Snowbowl Chapter 5 Response to Comments
that the LNF will confirm that minimum of 30 gpm flows will be maintained in Butler Creek for fish habitat. While we are pleased that Butler Creek flow monitoring is proposed, it is not clear to us how flows protective of aquatic life and crucial over- wintering habitat can be consistently provided when it appears that existing water withdrawals are resulting in adverse effects to Butler Creek aquatic life and over- wintering habitat, and additional water withdrawals over an additional 39 days during the winter are proposed that will result in loss of an additional 20 acre-feet of streamflow during the winter period. We recommend that the FEIS include additional discussion regarding how the LNF will be able to confirm that adequate Butler Creek flows can be maintained that are protective of aquatic life and crucial over-wintering habitat. In addition we recommend evaluation and discussion of the potential for pumping water from other water sources for snowmaking to avoid additional adverse effects to fish and aquatic life and over-wintering and riffle habitats in Butler Creek. Respondent: 40
Response to comment: The LNF believes that maintaining 30 gpm in these reaches of Butler Creek would mitigate existing impacts for aquatic life and crucial over-wintering habitat. The 30 gpm maintenance flow rate was developed by LNF and contractor fisheries biologists using a wetted perimeter study (in project file). This rate was developed by providing an adequate buffer to the Butler Creek base flow rate of 17 gpm, which provided 2.4 inches of water at that measurement point (Reiland 2008, project file). The average body depth of a resident adult westslope cutthroat trout is 1.8 inches; therefore, the fisheries biologists concluded that 30 gpm would adequately protect, over- wintering habitat in the affected reaches.
MSB is already utilizing all of the water from its other water sources/water rights (Section 3.3.4, pp. 3-11 through 3-17 of the FEIS). In addition, to the mitigation measures identified in the FEIS (Section 2.5.2.1, pp. 2-17 through 2-18 of the FEIS) for hydrology and fish, the FS and MSB will follow the conservations measures recommended by the FWS in the BO for bull trout. The conservation measures recommended include the following: 1) the FWS strongly recommends that the Forest define a reporting requirement for determining if flows are adequate to protect aquatic organisms as a condition of the special use permit; 2) the FWS recommends the Forest implement all of the terms and conditions described in the 2003 Biop; 3) the FWS recommends that flow monitoring devices be installed prior to implementation of additional snow-making activities; 4) the FWS recommends the Forest implement all mitigation measures as described on page 31 of the 2012 BA for this project; 5) the FWS recommends the Forest monitor stream temperatures; 6) the FWS recommends the Forest develop a long-term sediment monitoring station to determine the effectiveness measures to reduce parking lot runoff; 7) the FWS recommends the plowed snow not be side cast into Butler Creek.
6. It is stated that approximately 8.1 acre-feet of the additional 15 acre-feet of water withdrawn from Butler Creek for snowmaking will be used in the expansion area in the La Valle Creek drainage (page 4-8), thus, increasing flows to La Valle Creek during spring runoff by 8.1 acre-feet and reducing runoff to Butler Creek by this amount. The DEIS states that both the La Valle and Butler Creek drainages produce annual runoff of about 2,700 acre-feet, and the effect of this slight (8.1 acre-feet trans-basin water diversion is considered to be negligible). We agree that a trans-basin diversion of 8.1 acre-feet in these drainages would likely have a negligible effect on stream channel characteristics (e.g., channel and bank stability), although given the apparent precarious
Final EIS 5-30 Montana Snowbowl Chapter 5 Response to Comments
state of Butler Creek fisheries habitat in light of dewatering concerns it is not clear that the effect of diversion of additional runoff waters from Butler Creek would have a negligible effect upon Butler Creek fisheries habitat and aquatic life. Although we realize spring runoff would likely occur after the crucial over-wintering period, we ask if the loss of this Butler Creek runoff would exacerbate Butler Creek dewatering effects upon aquatic life? Respondent: 40
Response to comment: MSB is not dewatering Butler Creek after March 1, which would be well before spring run-off. Also, run-off stream flow would be more than adequate to provide habitat for aquatic life and fish. Therefore, the trans-basin diversion of 8.1 acre- feet of water from Butler Creek to La Valle Creek is not likely to exacerbate negative effects to Butler Creek aquatic life and fish habitat.
7. The DEIS discloses that existing developments and past actions are already creating sediment problems and adverse habitat impacts to native fish in La Valle Creek and Butler Creek. Populations and habitat conditions are unanimously rated “Functioning at Unacceptable Risk.” Forest Plan/INFISH requirements are not all currently met. BMPs do not always work as planned, and in many cases their fixes are temporary at best. The westslope cutthroat trout and bull trout habitats in La Valle Creek and Butler Creek are disconnected from other habitats, and instead of recognizing these populations’ conservation value the DEIS basically writes them off. This is inconsistent with National Forest Management Act and Forest Plan provisions requiring habitat and populations to be well-distributed so as to avoid extirpation and ultimately, extinction. For bull trout in both creeks, the DEIS says that this may have already happened in recent years. “The withdrawal of the existing water right, however, is likely negatively affecting over- wintering habitat conditions in Section 1 and the upper portion of Section 2.” This is an example of the many current human-caused impacts on native fish in La Valle Creek and Butler Creek. The DEIS does not include a proper, scientific viability assessment for the populations in these streams. Respondents: 51, 52
Response to comment: The populations of westslope cutthroat trout and bull trout in La Valle Creek and Butler Creek have been well documented by LNF and MFWP biologists (EIS Sections 3.6.4.3 and 3.6.4.4). Both species may be present in both streams.
The wetted perimeter analysis conducted as part of this EIS (Reiland 2008) concluded that the current water withdrawal for snowmaking at MSB (the existing conditions) was likely negatively affecting over-wintering habitat for bull trout and westslope cutthroat trout in the upper reaches of Butler Creek below the snowmaking water diversion. Therefore, if the LNF chooses the No Action alternative there would be a continued impact to bull trout and westslope cutthroat trout habitat in this reach. However, the Proposed Action would include provisions for maintenance of 30 gpm flow during snowmaking activities to protect this habitat as a Connected Action. If this flow rate is not met, MSB would not be able to withdraw the 115 gpm for snowmaking. Therefore, if the LNF chooses the Proposed Action there would be an improvement in bull trout and westslope cutthroat trout habitat in this reach of Butler Creek.
The effectiveness of LNF BMPs has been documented during field reviews over the last two decades (Section 2.5.1, p. 2-13 of the FEIS).
Final EIS 5-31 Montana Snowbowl Chapter 5 Response to Comments
5.2.11 Facilities, Transportation and Safety
1. MSB needs to show that it can operate safely before expanding. Respondent: 24
Response to comment: MSB is required by the LNF, the State of Montana and MSB’s insurance company to comply with American National Standards Institute (ANSI) codes that specify what kind of operational safety checks and controls are in place related to the lifts. For example, a licensed tramway engineer must inspect the chairlifts before the commencement of the winter ski season every year. MSB cannot operate their chairlifts without passing this inspection. MSB also must perform an operational safety check each morning before the chairlifts start operating. Additionally, every seven years MSB is required to perform a load test on the chairlifts.
MSB performs ongoing maintenance on the chairlifts as needed, including most recently the replacement of the motor and drivetrain on the Grizzly chairlift from the base area. However, MSB does not have plans to replace any of the lifts within the existing area at this time. It is beyond the jurisdiction of the LNF to direct MSB as to how to conduct its operations as long as the requirements of their SUP are met.
2. An upgrade to the existing Grizzly chairlift and improvement of its base lodge facilities (enlargement, added space) should be considered before expansion takes place. Respondent: 37
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comment #1, above.
3. The Draft EIS assumes that 2.5 skiers are in each car and that each parking space accounts for 2.5 people. At present this number is quite elevated. I suggest taking a survey of the cars traveling to MSB to better estimate this number. I also suggest MSB justifying this number. One of my biggest issues with this expansion is parking. On a busy day, both lots at the ski area fill up and many cars are parked on both sides of the incoming road for ¼ - ½ mile from the base. This can be a safety issue. The Draft EIS states that there will be a continuous shuttle service on busy days. Define what a continuous shuttle service is, including what type of vehicles will be used, how many vehicles will be used and how often people will be picked up. Define what a busy day is. MSB will need to have parking attendants at both the base area and the Grant Creek parking area to maximize the number of spaces in each. If the shuttle isn’t timely skiers will not wait more than 10-15 minutes and will drive to the base area. Respondent: 24
Response to comment: Western ski areas have an average vehicle occupancy (AVO) of 2.7 skiers per car (USDA 2006b). A vehicle occupancy study was not conducted for this analysis so a conservative rate of 2.5 was chosen to analyze parking capacity. However, the LNF acknowledges that parking capacity at MSB is not accurately portrayed by this AVO. Many local skiers drive alone to MSB, and inefficient parking of vehicles and not maximizing parking lot space during snowplowing contribute to the lower actual parking availability at MSB. Additionally, the LNF acknowledges that road- parking for up to one mile from the base does not constitute safe or convenient parking for skiers.
Final EIS 5-32 Montana Snowbowl Chapter 5 Response to Comments
As a response to concerns about parking raised during the DEIS comment period, MSB has proposed several improvements to off-site parking and shuttle service (Section 2.5.2.8, p. 2-21 of the FEIS). These include:
supervision of parking in the main parking lot and two Snowbowl Road parking lots on weekends and on peak weekdays (“powder days”, which are reported as such on MSB’s website and telephone snow report); supervised parking at the parking lot at the base of Grant Creek Road on weekends and peak weekdays; use of signage at the Grant Creek Road parking lot indicating when the main parking lot and two Snowbowl Road parking lots are full; two shuttles operating continuously on weekends and peak weekdays.
The LNF anticipates that this would relieve parking conditions and improve convenience for skiers. However, skiers would still be encouraged to carpool as much as possible.
4. While the existing road has been vastly improved in the last several years there are still some safety issues: Post speed limit signs on a regular basis. On many occasions we have been passed by impatient drivers when we were going a safe speed for the road. Max 25 or 30 MPH. Post “No Passing” signs on Snowbowl Road Install guardrail where needed. Also, the county should be required to pave the Snowbowl road all the way past the existing houses before the hairpin turn. The road gets pot holes and is very rough as winter progresses. More traffic will only make it worse. MSB needs to sand more frequently. Respondent: 24
Response to comment: The speed limit signs were removed during the road construction period. Since construction changed the character of the road, an engineering analysis was completed to determine the appropriate speed limit; a Special Order would need to be signed by the Forest Supervisor to ensure enforcement of the new speed limit. The engineering analysis determined the speed limit to be 15 to 25 mph based on surface conditions. The Special Order will be pursued in the near future. The County portion of the Snowbowl Road is posted at 25 mph. Guardrails were installed in 2012 as part of the road improvement project.
The LNF Missoula District Ranger, Paul Matter, met with a Missoula County Commissioner and the Missoula County Public Works Director on August 11, 2011 to discuss the impacts of traffic on the section of Snowbowl Road under the jurisdiction of Missoula County. Two solutions were discussed: 1) seeking funding to pave the entirety of Snowbowl Road through the Federal Forest Highways program and 2) Missoula County paving the section of Snowbowl Road currently under their jurisdiction, with MSB paying a proportionate share of the cost and Missoula County paying the rest. Resolution of the issue was not found, but the County stated that the issue would be given further discussion by the County Commissioners upon receipt of a written proposal from the LNF. The proposal from the LNF would include an analysis of vehicle traffic volume to determine how much of the traffic is associated with local residences as opposed to how much of the traffic volume is associated with MSB. This analysis would determine the proportion of funding MSB, the County, and residences would contribute to paving the county portion of the road (approximately 500 feet past the hairpin turn).
Final EIS 5-33 Montana Snowbowl Chapter 5 Response to Comments
5. I feel that the number of people/car is not realistic. They can possibly do some type of incentives to encouraging carpooling (i.e. free lunch, reduced ticket prices, coupons, etc.) Respondent: 24
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comment #3, above.
6. NRCS has collected snow survey data at the TV Mountain snow course since 1956. As such, it is considered a legacy data collection site, with over 50 years of continuous data (measured 6 times each year at the first of January through June). This site was included in the Special Use Permit (Authorization ID: MIS218), for the Natural Resources Conservation Service snow monitoring sites on the Lolo National Forest (NF) signed by NRCS and Lolo NF in December 2008. NRCS would like to continue the measurements at TV Mountain snow course and requests that a buffer zone be established surrounding the snow course to keep construction and ski impacts to the site at a minimum. The Memorandum of Understanding (MOU) for Snow Survey and Water Supply Forecasting Program Activities between the Forest Service and the NRCS (FS #08-MU-11132426- 005, NRCS A-3A75-8-3), dated November 20, 2007, contains a statement on Page 3 that should be considered in this instance: Provide a 400-foot or mutually agreed to buffer zone in all directions from the sampling points and sensors at established snow courses and related hydrometeorological data sites. The dimensions of the buffer zone will be depicted and specified on data site maps or exhibits of the MSUP or addendums. Buffer zones will be established to minimize the disturbing influences that road building, timber harvest, or vegetative management may have on natural snow accumulation or measurement. Provide a 400-foot or mutually agreed to buffer zone in all directions from the sampling points and sensors at established snow courses and related hydrometeorological data sites. The dimensions of the buffer zone will be depicted and specified on data site maps or exhibits of the SUP or addendums. Buffer zones will be established to minimize the disturbing influences that road building, timber harvest, or vegetative management may have on natural snow accumulation or measurement. The NRCS has reviewed the Montana Snowbowl DEIS and has found that in searching the document, the TV Mountain snow course was not referenced, even though it is in the proposed area of disturbance for construction and operations. On December 14, 2010, Gene Thompson, on the Missoula Ranger District, contacted Scott Oviatt, NRCS Snow Survey Data Collection Officer, to discuss the potential expansion of the Mountain Snowbowl ski area and to determine if NRCS had been contacted. Their discussion focused on whether NRCS would maintain the snow course at the existing location. Mr. Oviatt followed up with an e-mail to indicate the TV Mountain snow course was included in the Special Use Permit in 2008. Following that e-mail, NRCS has not received any communications regarding the proposed expansion until receipt of the DEIS comment request notification. NRCS requests that the Lolo NF consider our concerns regarding the potential impacts on the future snow measurements at the TV Mountain snow course. Respondent: 2
Response to comment: On August 12, 2011 personnel from the LNF, MSB and NRCS conducted a site visit to discuss the location of proposed facilities in relation to the NRCS snow course site. MSB agreed that they would maintain an adequate buffer
Final EIS 5-34 Montana Snowbowl Chapter 5 Response to Comments
between the proposed trails, drainfield, buildings and lift terminals per NRCS direction provided at that site visit. NRCS will continue to survey the snow course.
7. Snowbowl's use plan should clarify public access to forest land beyond the leased permit land. Currently, public access across leased land does not seem to have a clear policy, and is discouraged by Snowbowl staff. Better would be a clear, visible access policy such as there is at Whitefish Mountain Resort, which details how, where, and when uphill travel may occur. Snowbowl forbids on-trail uphill access during operating hours; this restriction should be eliminated to instead allow access on certain trails at certain times and under certain conditions. Respondent: 7
Response to comment: The following is the public access policy for the existing SUP; upon signature of the ROD the proposed expansion would follow the same policy. The access policy may be expanded in the future to address unforeseen concerns in the expansion area.
“Montana Snowbowl is managed under a SUP on the Lolo National Forest. National Forest lands within the permit area are open to non-motorized public access year round with the following exceptions:
In General: The public may access National Forest land by way of a non-motorized easement across Snowbowl’s private property at the base area parking lot. This easement provides non-motorized public access to National Forest lands south of the parking lot. Private land within the permit area may be closed to public access (excluding the easement). People using this easement must park on the south side of the Snowbowl entrance gate.
In the Summer Season: Roads and trails used by Snowbowl are limited to downhill traffic during business hours. The uphill traffic restriction is in effect one hour prior to the Grizzly Lift opening and one hour after it has closed.
In the Winter Season: All ski runs and trails are closed to uphill traffic when the lifts are operating. The uphill traffic restriction is in effect one hour prior to the lifts opening and until day end sweep has been completed and all skiers coming downhill have arrived at the base area.”
8. How will hikers who want to walk in what is now still fully public land be treated by those charging an access fee for the expanded area? Will it, in fact, become as difficult for them as for skiers now to skin up at MSB? Respondent: 50
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comment #7, above. These policies would apply within the expanded SUP area.
9. Parking lot and road pullouts need to be maintained daily in order to help with current capacity. Respondent: 10
Final EIS 5-35 Montana Snowbowl Chapter 5 Response to Comments
Response to comment: MSB currently plows the parking areas to maximize parking capacity. MSB has also proposed additional improvements to maximize parking capacity; see response to Facilities, Transportation and Safety, Section 5.2.11, response to comment #3, above.
10. I do have concerns about parking top and bottom and the traffic impact on the I-90 interchange and Grant Creek Rd. Respondent: 11
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comment #3, above for a summary of parking capacity improvements.
Sections 3.8.4.1 (pp. 3-108 through 3-110 of the FEIS) and 4.8.2.1.1 (pp. 4-66 through 4-67 of the FEIS) provide information regarding traffic on Grant Creek Road. On peak days the traffic in the morning (MSB opening) and evening (MSB closing) could increase on Grant Creek Road from 38 percent of all traffic to 63 percent of all traffic. This figure represents a peak day, and average traffic would be considerably less.
11. Currently, Missoula County maintains a short segment of Snowbowl Road. Section 3.8.4.1 of the DEIS does not accurately reflect Missoula County jurisdiction. Our end of maintenance is approximately 0.8 miles from Grant Creek Road. Approximately 0.3 miles is paved and 0.5 miles is gravel. Missoula County does not take traffic counts during the winter months. The information presented in the DEIS is very brief and contains no analysis of impacts to Snowbowl Road or Grant Creek Road. The condition of Snowbowl Road is the single most complained about road in the Grant Creek watershed. We continually receive complaints from residents as well as Snowbowl users. As a result, we have to spend more resources on this road segment than others. The limited information that is provided seems to substantiate our observations. It is commonly accepted that gravel roads are difficult to maintain when traffic volumes approach 400 ADT. AASHTO and EPA recommend serious consideration be given to paving roads that exceed 400 ADT. Yet there is no discussion about this in the DEIS. The proposed expansion of Snowbowl would double the traffic on Snowbowl Road. Two thirds of the projected traffic volumes are attributable to Snowbowl. The proposed action will have an adverse impact to Snowbowl Road and Grant Creek Road and will exacerbate an already existing maintenance problem. No attempt was made to discuss these impacts with Missoula County by anyone affiliated with this project. The DEIS contains no analysis or provide for any recommended mitigation. We contacted the Forest Service Engineer to discuss this proposal. She acknowledged the impacts and has plans to nominate Snowbowl Road as a Forest Highway making it potentially eligible for funding. Even if this were to happen it would likely be a very long time (beyond 10 years) before funding would be available. These impacts need to be addressed now rather later if this proposal is to proceed. Missoula County respectfully requests that the Forest Service conduct the proper analysis to truly examine the impacts to roads created by this proposal. The analysis needs to include both on and off season impacts that the proposed action has. Respondent: 14
Response to comment: The LNF Missoula District Ranger, Paul Matter, met with a Missoula County Commissioner and the Missoula County Public Works Director on August 11, 2011 to discuss the impacts of traffic on the section of Snowbowl Road under
Final EIS 5-36 Montana Snowbowl Chapter 5 Response to Comments
the jurisdiction of Missoula County. Two solutions were discussed: 1) seeking funding to pave the entirety of Snowbowl Road through the Federal Forest Highways program and 2) Missoula County paving the section of Snowbowl Road currently under their jurisdiction, with MSB paying a proportionate share of the cost and Missoula County paying the rest. Resolution of the issue was not found, but the County stated that the issue would be given further discussion by the County Commissioners upon receipt of a written proposal from the LNF. The proposal from the LNF would include an analysis of vehicle traffic volume to determine how much of the traffic is associated with local residences as opposed to how much of the traffic volume is associated with MSB. This analysis would determine the proportion of funding MSB, the County, and residences would contribute to paving the county portion of the road (approximately 500 feet past the hairpin turn).
12. The Grant Creek HOA has spent tens of thousands of dollars (RSID) to maintain a clean and pollution free asphalt road from the Snow Bowl Road confluence at Keegan Trail to Grant Creek Road and beyond. The year round down flow Snow Bowl traffic has directly contributed to roadbed deterioration and drastically impacted air quality. Visit this area anytime of the day and you will witness our asphalt roadway laminated in slick, soggy, instable muds and particulates. Upon drying, these fine particles result in a constant pall of fine dusty air which coats our lungs, our homes and vehicles. Simple Solution/Requirement: Extend the asphalt at the Keegan Trail/Snow Bowl Road confluence. This asphalt/pavement extension should run up and beyond the "attritioned" switchback approximately 1 mile beyond the Keegan Trail/Snow Bowl confluence. Snow Bowl and Mr. Morris need to correct this existing problem prior to addressing their expected expansion. Respondent: 15
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comment #11, above.
13. Providing free or cheap shuttle services on an hourly basis between Snowbowl and the lower parking lot by the Town Pump during ski season would alleviate a lot of traffic issues on Grant Creek Road, and help reduce wildlife mortality from vehicles. In addition, the lower Snowbowl parking lot next to the Town Pump should be monitored more closely to enforce parking restrictions, in order to fully utilize the entire lot for Snowbowl parking. During the winter of 2010-11, large semi-trucks, abandoned vehicles, and other non-Snowbowl users often cluttered that lot, leaving fewer parking spaces for Snowbowl users to park and carpool. Expansion of the lower parking lot to accommodate additional car-pooling would be highly desirable. Unfortunately, Snowbowl took the opposite step several years ago when it sold half of its lower parking lot to Town Pump. Respondent: 26
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comment #3, above.
14. The proposed addition of slopes, lifts, and other facilities addresses only part of the purpose. Keeping all facilities, old or new, in a safe and appealing condition, and providing the hospitality, encouragement and services that most skiers expect will be vital to making this a successful project. Safety first! Any special use permit should include a comprehensive program of safety efforts, the standards for which should be
Final EIS 5-37 Montana Snowbowl Chapter 5 Response to Comments
set by the Lolo National Forest with public input. I propose beginning this program now by requiring MSB, as a condition of any special use permit, to abide by Montana ski area laws, as posted at the Grizzly chairlift. These laws mandate safe practices that protect all ski area users from undue injury. They are current, relevant, and must be acknowledged and observed. I believe LNF should provide oversight of these mandates as a portion of their responsibility towards safety on shared public land. Respondent: 32
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comment #1, above.
15. In the executive Summary and in Chapter 3 of the DEIS the parking capacity shows current capacity of 2,775 skiers. My experience of 100 days skiing in 2011 and 60 to 80 days a year the previous 20 years shows that when they are reaching a ski count of 1,400 to 1,500 skiers, the current parking is close to being maxed out. The main lot will be full to capacity and lot 2 will be to capacity as well as parking for .25 miles down the road. This shows that the current parking accommodates more like 1,500 to 2,000 skiers not the claimed 2,775. The use of 2.5 persons per car seems to be flawed. It appears that a better number would be maybe just over 2 per car. This number could be better calculated by using LNF traffic data collected in 2009. This shows that a maximum number of cars on the Snowbowl road at 1,288 on a day that was probable about 1,400 skiers. The current road condition has been greatly upgraded in the past 7 years allowing busses and other traffic much easier access to the ski area. Now the worst part of this road is constantly the .2 miles that is maintained by Missoula County between the end of the pavement and the switchback going into state land. Because of the heavy traffic and constant freeze/thaw and poor drainage on this portion of the road it is constantly extremely pot holed, muddy and dangerous to navigate. The county needs to pave this portion of the road before it is safe to increase traffic to Snowbowl. Respondent: 38
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comments #3 and #11, above.
16. The storage of petroleum products including but not limited to gasoline, diesel fuel, hydraulic fluid, lubricating oil, and waste oil is regulated under Section 311 of the Clean Water Act, and as amended by the Oil Pollution Act of 1990. A Spill Prevention, Control, and Countermeasures Plan (SPCCP) is required of any facility that at any one time stores over 660 gallons of petroleum product in a single container, or stores over 1,320 gallons in multiple containers. Wheeled containers are included for the purposes of this regulation. The SPCCP regulations are administered by EPA (contact Martha Wolf in Denver at 303-312-6839). SPCCP plans, if required, should include consideration of the specific environmental conditions at the project site, which include steep slopes and rain and snow events, and should consider risks to drinking water sources downstream of the site, see hup:llwww.epa.gov/oilspill/. Although we are not aware of any hazardous materials planned for storage or use at the ski area, should the Forest Service determine that hazardous materials will be used or stored at the site, they should contact the EPA representative at the above telephone number to determine appropriate spill prevention, control, and countermeasure. Respondent: 40
Final EIS 5-38 Montana Snowbowl Chapter 5 Response to Comments
Response to comment: All storage requirements for hazardous materials will be followed as mandated by the EPA.
17. The DEIS does not seriously address the issue of additional traffic on Grant Creek Road, which is the only way in and out of Grant Creek and the only portal for ski traffic. Respondent: 42
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comment #3, above for a summary of parking capacity improvements. Sections 3.8.4.1 (pp. 3-108 through 3-110 of the FEIS) and 4.8.2.1.1 (pp. 4-66 through 4-67 of the FEIS) provide information regarding traffic on Grant Creek Road. The LNF believes this analysis is appropriate to provide adequate information to the public about traffic changes and allow a decision on the proposal.
18. Grant Creek already presents challenges for wildland fire managers because so many homes are tucked in trees on narrow roads with one way in and one way out. Additional development would add to those challenges. Respondent: 42
Response to comment: There is no residential development planned related to the expansion of MSB. See responses to land use comments in Section 5.2.16 that address future land use changes/development.
19. Traffic often backs up north of the Town Pump gas station when motorists are trying to leave Grant Creek on weekday mornings and when skiers are leaving Snowbowl at the end of a busy day. Rebuilding the I-90/Reserve Street interchange will be expensive, but improving Grant Creek Road to accommodate additional traffic safely could be much more expensive. As a Grant Creek resident, I don’t feel it would be proper for me to be assessed for a special improvement district to accommodate traffic created by the Snowbowl expansion. Montana Snowbowl should be required to mitigate the additional traffic or pay its fair share of the cost if Grant Creek Road needs to be improved to handle skier traffic. Measures that might mitigate additional traffic from the ski area expansion include: Incentives to increase the number of skiers per vehicle (estimated at 2.5 skiers per vehicle in the DEIS); more frequent shuttle bus services; improvements to the Snowbowl parking lot north of the Town Pump gas station, allowing it to accommodate more cars. It’s critical to establish the Grant Creek Road traffic baseline now, determining the skier share of traffic now so follow-up studies can document the role that the ski area expansion plays in increasing traffic on Grant Creek Road. Respondent: 42
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comments #3 and #10, above. The Montana Department of Transportation does not have plans to rebuild the I-90/Reserve Street interchange based on additional traffic that would be the result of the MSB expansion (Dickson pers. comm. 2011). There is no design capacity for Grant Creek Road, it is considered adequate to handle the average daily traffic (Dickson pers. comm. 2011).
20. In 2006, the Grant Creek Neighborhood Council conducted a survey of Grant Creek Valley residents on varying topics. Eighty percent of the residents agreed (12% disagreed) the Snowbowl expansion plans should be approved contingent upon maximizing parking north of Sevenar with an increasing use of shuttle service.
Final EIS 5-39 Montana Snowbowl Chapter 5 Response to Comments
Unfortunately, subsequent to this survey, Snowbowl sold approximately half of their parking area to Town Pump for expansion of the service station. This leaves only 130 parking spaces for the Snowbowl shuttle and eliminated the proposed space for the Park-and-Ride facility and bus stop. Therefore, the latest plan does not provide for shuttling additional cars commensurate with the additional increase in skiers, but rather decreases the potential for minimizing the traffic, which was the qualification that residents voiced and expected at the time of the survey. The current plan is to shuttle less than 10% of the skiers with the balance to make their way to the area in private vehicles. The most urgent traffic issue irrespective of the additional Snowbowl expansion load is the single-lane exit from the valley at the I-90 intersection. Traffic frequently backs up well beyond the entrance to the Elk Foundation. Several CIP requests have been made to the city to alleviate this situation and even the stop-gap solution of making two lanes for several car lengths has not been done. With further loading by Snowbowl, a more extensive solution requiring an additional stretch of two-lane road and extension of the underground creek enclosure would be needed. For several years, Grant Creek Neighborhood Council, with its affiliated Grant Creek Trail Association has been planning a trail from the I-90 intersection to the Snowbowl Rd. turnoff. The purpose of this trail is to divorce pedestrian and bicycle traffic from the narrow Grant Creek Rd. The speed limit on the road is 45 mph, which is frequently exceeded by drivers, including those coming and going to the Snowbowl Ski Area. Rights of way for the trail have essentially been secured and the City is planning to construct the two-mile section of the trail within city limits in 2012. However, we have recently been advised by the County Commissioners that the one mile of trail within the county is being postponed to approximately 2015 due to lack of federal funding. Obviously, pedestrian and bicycle safety is already critical under present traffic conditions and would be unacceptably compromised during the construction and expansion of Snowbowl. The following steps are recommended in conjunction with the Snowbowl expansion in the interest of safety and ability of the road to carry the substantial increase in traffic: A. The Snowbowl shuttle parking should be relocated to one or more locations south of I-90. This will allow skiers a shorter distance to drive to catch the shuttle and will alleviate the traffic increases and congestion at the intersection of Grant Creek Rd. and I-90. Given the ever-increasing cost of gasoline and the need to mitigate traffic on the rural road, we would expect the shuttle target should be at least 50% of the skiers. B. The parking area presently used for the Snowbowl shuttle should be obtained by the City for the Park-and- Ride facility. This will further alleviate the traffic congestion at the intersection. It may be possible to exchange other City property with Snowbowl for their enlarged shuttle area. C. For safety reasons, the Grant Creek Trail must be completed in its entirety prior to any construction or logging work connected with the Snowbowl Expansion Project. A contribution to the trail would ensure its completion consistent with the start of work on the Snowbowl Expansion. I note that your traffic analysis ignores the Snowbowl operating and maintenance staff and the logging and construction personnel during the several years of work on the project. Additional traffic data at the I-90 intersection and midway at Creekside is available from the City. I do not believe your analysis addresses the impact on the Grant Creek valley and road as a whole. Respondent: 48
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comments #3 and #10, above.
MSB would require a significant park and ride lot south of Reserve Street in order to provide parking and shuttle service. The additional improvements provided in response
Final EIS 5-40 Montana Snowbowl Chapter 5 Response to Comments
#3, above, should be adequate to alleviate parking congestion without having MSB seek to acquire ownership or lease of a parking lot on Reserve Street, which would be difficult.
It is beyond the scope of this analysis and outside of the jurisdiction of the LNF to require MSB to attempt to sell land to the City of Missoula, and the City of Missoula may or may not have funding to acquire such a parcel should MSB be interested in selling it. It is not reasonable to expect that the proposed MSB expansion project be contingent on the Grant Creek Trail receiving federal funding, and the LNF cannot require MSB to make a monetary donation to the Grant Creek Trail.
The traffic analysis included “vehicles per day” on Snowbowl Road, which was then applied to Grant Creek Road since Snowbowl Road must be accessed by Grant Creek Road. This would include operating and maintenance staff. It is unknown what volume of traffic would be created by construction and logging, but because this work is spread over 11 years it is not likely that a substantial increase in traffic on Grant Creek Road would result. There is MDT traffic data for a point just north of the I-90/Reserve Street interchange (Site ID 32-3A-136). However, this data would not add additional relevant information to this analysis and therefore is not included.
21. Although the Snowbowl road has been improved, the route will continue to be a hazardous drive, as it will still be relatively steep and narrow in places. Also, the road is not consistently maintained for safe traction driving conditions during the ski season. The road itself will continue to limit skiers’ choice of MSB. More frequent deterioration of the condition of the road due to the increase in the number of skiers driving the road is not considered in the DEIS. Likewise, the DEIS fails to consider how the current parking quagmire on busy days would be anything but exacerbated with the projected daily increase in the number of skiers. There is no viable solution proposed for the problem in the DEIS. This situation will also discourage skiers from choosing MSB, as it likely does now. The proposed increase in shuttle service is meager at best. Few more skiers would likely choose the shuttle, given the limited scheduling. Also, taking a bus up a dangerous road is not taken lightly. Respondent: 51, 52
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comments #3 and #11, above for information pertaining to parking improvements and road improvements.
Snowbowl Road is a forest road typical of western Montana forest roads and many roads that access ski areas in the western U.S. MSB regularly applies gravel throughout each day to increase traction, but this type of road would retain risks to drivers based on its configuration and grade. There may be skiers and summer recreationists that would choose not to go to MSB because of the road, but this does not have bearing on this analysis outside of whether MSB makes road improvements required by the LNF.
22. My primary concern is in the area of safety as it pertains to grooming and marking or labeling areas for skier traffic safety. Respondent: 59
Response to comment: Every year MSB must submit an Annual Operating Plan that is approved by the Forest Supervisor. The AOP outlines the objectives and responsibilities
Final EIS 5-41 Montana Snowbowl Chapter 5 Response to Comments
of the season. Both parties acknowledge there are inherent risks in the sport of skiing (skiers also accept this risk upon the purchase of a day or season pass). However, MSB accepts the responsibilities for risk awareness and management as well as resource protection with in the developed limits of the ski area. The LNF accepts the responsibility to monitor activities and operation occurring on public land to ensure MSB is conforming to the requirements of the SUP and fulfilling public safety requirements as well as resource protection requirements. The Missoula Ranger District Snow Range inspects the SUP at least twice a month and has the authority to enforce the permit and operating plan in such cases involving immediate danger to the public or resource protection concerns. It is recognized that hazards, visible and hidden, exist at any ski area. It is further recognized that it would be impossible, and possibly a hazard in and of itself, to mark and fence every such hazard. The ski area has the discretion to determine what hazards, if any, should be marked, signed, or fenced. By marking, signing, or fencing hazards, the ski area shall not be taking on any duties in addition to those set forth under the Montana Skier Responsibility Act. Hazards would be marked as appropriate, when they are identified.
23. I noticed increased frequency and areas groomed during the last two years. I also notice inconsistent and arbitrary grooming of what would be intermediate (or beginner areas) if consistently groomed. For safety purposes the public is best served by routine grooming of given areas. Also, when stating on the ‘snow phone’ that certain runs are groomed, it implies that they were done that day/pm before. We noticed it can be up to three days before, thus ‘grooming’ is altered significantly by weather and intermediate/new skiers can be mislead. Respondent: 59
Response to comment: See response to Facilities, Transportation and Safety, Section 5.2.11, response to comment #22 above. It is the responsibility of MSB to decide when ski trails should be groomed based on snow conditions and the ability level of the trails. As stated in the AOP, grooming should not in any way be constructed to indicate that it will make skiing safer or to limit the inherent risk thereof. Grooming is only an attempt by the area operator to condition the skiing surface, thus providing a more predictable environment to the ski user. Skier risk and responsibility (as well as the ski area responsibility will be judged by the Montana Skier Responsibility Act (MCA 23-2-731).
24. Please also look at road user data – lots of parent/non-skier traffic too. Respondent: 59
Response to comment: Traffic data used in the analysis does not differentiate between the type of user accessing MSB via Grant Creek Road and Snowbowl Road.
5.2.12 Recreation
1. Missoula is growing. The university population is growing. Marshall Mountain appears to be done for the foreseeable future. Skiing and snowboarding are healthy, outdoor, lifetime sports. If we are to get more people involved in these wonderful sports we need more terrain, especially better learning and family-type terrain. This expansion is the way to achieve this. Missoula is an outdoor, recreation-oriented community and we need to improve and increase these opportunities as the area grows. Respondent: 9
Final EIS 5-42 Montana Snowbowl Chapter 5 Response to Comments
Response to comment: Noted. No response necessary.
2. MSB needs to expand their summer recreation offerings. Respondent: 31
Response: The Proposed Action (Section 1.2, p. 1-5 of the FEIS) would expand summer recreation with more hiking, mountain biking, and folf opportunities. Additionally, Lift C would operate during summer hours to provide scenic chairlift rides.
3. Will skiers still be allowed to ski off the power line trail off of TV Mountain? Respondent: 43
Response to comment: The “power line” from the top of TV Mountain to the base area would not be a maintained trail but would be open to skiers.
4. Recreation is a prime reason that the Forest Service exists. Respondent: 9
Response to comment: Noted. No response necessary.
5. I feel the Forest Service is best served by opening up more public land to the public for the express purpose of enhancing the western Montana lifestyle. This project combines fun with fitness, and improves an otherwise useless section of public land. All business’s need to grow to meet an expanding market demand! My point is supported by the fact that Montana Snowbowl’s 2011 season broke their all time record for skiers visit in a season. Missoula’s ski industry is poised to continue growing and Montana Snowbowl is maxed out and needs to grow with it. It’s basically a clean industry, good for the economy and environment! Respondent: 27
Response to comment: Noted. No response necessary.
6. As a recreation area, the entire site will be more closely monitored than it has been as a logging area, including a water flow monitor to ensure appropriate run off in to local streams. I reassert that expansion would not disrespect the forest, but in fact cut down fewer trees than logging, and provide additional access for more people to enjoy the forest. Respondent: 33
Response to comment: Noted. No response necessary.
7. My family and I spend much of our free time recreating on Montana's public lands. Each season brings a different activity and all of them involve our public lands. Through these activities we engage our peers and therefore our community. Respondent: 44
Response to comment: Noted. No response necessary.
Final EIS 5-43 Montana Snowbowl Chapter 5 Response to Comments
8. I believe that despite the environmental impacts that the expansion entails, getting more people to love skiing outweighs the impacts because it gets people intimately involved with the landscape around them. Respondent: 53
Response to comment: Noted. No response necessary.
5.2.13 Visual Resources
1. Anyone pausing a moment while hiking or biking in the hills around Missoula will see yet- another huge chunk of our Northern hills gobbled up by this proposed expansion. Look North: much of what is to the East of the existing MSB rims the Rattlesnake Wilderness. To the West is TV Mountain, easy access to which hitherto has been discouraged due to the expensive electronic equipment situated there—yet now The Montana Snowbowl Ski and Summer Resort would spread even further up and across that great chunk of our Northern view-shed and down the other side into La Valle Creek—in effect reshaping and controlling most of our northern mountain boundary with numerous new trails for skiing and biking, miles of pipes and even a lodge atop TV MTN, etc.. Respondent: 50
Response to comment: The west side of TV Mountain and the viewshed referred to in the comment has a long management history that includes a former ski lift and several timber harvests. The Proposed Action would certainly add to the visual impact of management activities on this viewshed. Section 4.11.2.1.1, Photograph 4-1 (p. 4-79 of the FEIS) provides a simulation of how the viewshed would change under the Proposed Action. Section 2.5.2.3 (p. 2-19 of the FEIS) provides a list of 11 mitigation measures that would reduce the visual impact.
2. The DEIS indicates that the ski area expansion would not be consistent with the Forest Plan’s visual quality requirements and standards, and fails to consider an alternative that could meet those standards. The ski area expansion on the west side of TV Mountain would add more degradation to the scenery, recently impacted by the public insult created by the partial development of the proposed Bitterroot Resort near Lolo by Tom Maclay. Respondents: 51, 52
Response to comment: The Proposed Action would fall under the Modification VQO. The Proposed Action would meet Forest Plan visual standards and guidelines because the proposed expansion area would be re-classified as MA 8 (recreation), which has a Modification classification.
The Bitterroot Resort was not considered in the cumulative effects analysis because the current trails cut in this location would not share a viewshed with the proposed expansion area.
3. Granted trees will be needed to be removed-this process can benefit the local economy without creating a huge area of "clear cutting" or "eye sore". Respondent: 12
Response to comment: See response to Visual Resources, Section 5.2.13, response to comment #1.
Final EIS 5-44 Montana Snowbowl Chapter 5 Response to Comments
5.2.14 Economics
1. Let’s keep the skier $s in Missoula. Respondent: 19
Response to comment: Noted. No response necessary.
2. I hope there is some mechanism to protect all the seniors who live in the affected drainages from property value and taxes which will surely increase dramatically as they have in Grant Creek/Butler Creek over the last decade. Respondent: 20
Response to comment: The Proposed Action would not affect property values or individual property taxes (Section 4.12.2.1, p. 4-86 of the FEIS) based on conversations with a commercial appraiser from the State of Montana Treasurer Appraisal/Assessment Office who stated there is no correlation between ski area development and changes in property taxes or appraisal value.
3. The espoused economic incentives that would arrive, if expansion were permitted, are false. The DEIS states unequivocally that the expansion of Montana Snowbowl would not result in a creation of income from outside sources. Expansion would only result in the "transfer of income" between local residents (4-60). New economic incentives would not arrive to Missoula. Utilizing economic growth as the impetus for permitting this expansion is mendacious. Respondent: 21
Response to comment: Promoting economic growth is not part of the Purpose and Need for this project. Economic effects are evaluated in this analysis but “incentives” are not evaluated as such and are not part of the decision-making process. The EIS provides any changes to economics from baseline conditions that would occur as is required under NEPA.
4. Property in the North Hills of the Missoula Valley already is expensive to protect, but if property values were to increase as a result of the ski resort expansion, it would be extremely challenging to raise funds to protect the wildlife resource values of the North Hills and its adjacent lands. Respondent: 26
Response to comment: No increase to property values is anticipated as a result of the Proposed Action (Section 4.12.2.1, pp.4-81 through 4-87 of the FEIS).
5. The expansion will cause MSB to drastically increase ticket prices and make it too expensive. Respondents: 28, 50, 51, 52
Response to comment: It is beyond the scope of this analysis to estimate future ticket prices charged by MSB. However, it is likely that ticket prices would remain competitive with other regional ski areas.
Final EIS 5-45 Montana Snowbowl Chapter 5 Response to Comments
6. The price of gas and travel expenses impacts skiers that have to drive long distances from Missoula to get beginner and intermediate terrain. Respondents: 42, 50
Response to comment: Noted. No response necessary.
7. MSB now has a 40-year extension on its lease on its existing SUP--for a pittance of some $24,000/year, a fixed percentage of its gross income and whose exact profits are proprietary information only--and I have it from several informed outdoor folks that although access to the non-paying public is a legal right, MSB in effect makes it nearly impossible for skiers who want to skin up the mountain to actually do so. Respondent: 50
Response to comment: See response to comment #7 in Section 5.2.11, Facilities, Transportation, and Safety (above).
8. “A chief attraction of area skiing facilities, such as MSB and most of its competitors in the region, is affordability.” (DEIS at 3-113.) There is no analysis in the DEIS that supports an assumption that the expanded and more developed ski area would remain similarly affordable. There seems to be a direct correlation between the acreage covered by a ski area and/or its developed amenities, and the cost of a lift ticket. Respondents: 51, 52
Response to comment: Refer to Section 5.2.14, Economics, response to comment #5 above.
9. Regarding skier numbers: How were statistics gathered? Which days? Please look closely at which days per week/year and how skiers are counted. Respondent: 59
Response to comment: Skier counts presented in Chapter 1 (Figure 1-3, p. 1-9) and Section 3.12.5 (Figure 3-25, p. 3-141) were total skiers for a season. Individual day counts were not provided and this level of detail is beyond the scope of this analysis. Skier data was provided by MSB and represents the number of tickets sold each day plus the number of season pass holders attending each day over the ski season. Season pass holders are counted by marking off their attendance on data sheets when they get on the Grizzly chairlift.
5.2.15 Climate Change
1. In our inevitable future there will be less snow--thus more water needed for making snow and, doubtless, future MSB requests for such; there will be more and worse fires—thus harsher threats to fauna and flora and even more water withdrawn to fight fires and replenish MSB reservoirs. Respondent: 50
Response to comment: Section 4.3.3 (pp.4-7 through 4-12 of the FEIS) states “prudent planning should be based on a conservative approach to climate change” (p. 4-12 of the FEIS). The proposed expansion of MSB should proceed only with the acknowledgment that there will almost certainly be years over the next three decades when snowpack
Final EIS 5-46 Montana Snowbowl Chapter 5 Response to Comments
may be inadequate, especially early season”. However, the conditions of the proposed expansion SUP would still require MSB to maintain 30 gpm flows in Butler Creek.
2. The DEIS also does not discuss the potential effect of climate change on the proposed ski area expansion project. Most climate change models predict warmer winters and more of the region's precipitation coming in the form of rain than as snow, overall less snowpack, and more rapid melting of snowpack in the Rocky Mountain West. This has potential to affect existing and expanded snowmaking infrastructure at ski areas, including MSB, and possibly exacerbate stream dewatering concerns. We recommend that the FEIS discuss climate change and its potential effects on ski area operations, and analyze and disclose potential climate change adaptation or contingency measures, particularly in regard to snowmaking and effects on surface water diversions and maintaining adequate in-stream flows to support fisheries. Respondent: 39
Response to comment: See response to comment #1 above (in Section 5.2.15, Climate Change).
5.2.16 Land Use
1. We also have concerns about potential indirect, growth inducing effects of the proposed MSB expansion upon environmentally sensitive areas. Ski area expansions can promote and hasten additional growth and development to serve the increased numbers of skiers and service workers. Additional visiting skiers require transportation, improved road access, increased wastewater treatment, water supply, restaurants, hotels, service workers, and places for those service workers to live. Often the indirect, growth inducing impacts of ski area expansions, and the infrastructure, growth and development sprouting nearby to serve the ski area causes greater environmental impacts or concerns than the direct impacts of the ski area expansion itself. The DEIS includes minimal discussion or disclosure of potential indirect, growth inducing and land use changing effects of the proposed MSB expansion. We recommend that the FEIS identify and discuss potential indirect effects or induced growth or development changes that may be associated with the ski area expansion (and potential doubling of skier capacity), of.ar least make a good faith effort to explain the effects that are "reasonably foreseeable" (40 CFR 1508.8(b)). How much developable private land lies within easy commuting distance of the MSB? Are there environmentally sensitive areas such as riparian areas, wetlands or other important wildlife habitat (e.g., old growth) within reasonable proximity to MSB that may be developed as an indirect response to MSB expansion and increased skier use? Will induced growth and land use change have an effect on air, water, and other natural systems and/or environmentally sensitive areas near the ski area? We recognize that future land uses and potential growth near the ski area may not be precisely known, but it may be possible to consider likely land uses and development trends in the area and estimate and disclose the likelihood that undeveloped land near the ski area will be developed as an indirect result of the ski area expansion. Respondent: 39
Response to comment: Section 4.12 (pp. 4-81 through 4-87 of the FEIS) includes a discussion of effects to land use as a result of the Proposed Action. Generally, it is not anticipated that the expansion of MSB would directly or indirectly result in additional development and associated environmental effects. A reasonably foreseeable action is
Final EIS 5-47 Montana Snowbowl Chapter 5 Response to Comments
future residential development on Grant Creek Road and lower Snowbowl Road. This area is within the Missoula County Urban Fringe Development Area and developable land is present, mostly related to the agricultural fields in the valley (Missoula County 2008). Although residential development is a reasonably foreseeable action the potential increase in residential housing along Grant Creek Road and lower Snowbowl Road would not likely be related to the expansion of MSB but would reflect a general trend in building houses in the urban interface outside of Missoula. MSB has been operating in its current location since 1961, and an expansion of terrain is not likely to be the impetus for “resort” housing development. MSB is primarily a local ski area and its guests live in close proximity to Missoula. The expansion is also unlikely to trigger residential development near MSB because the travel time to MSB from Missoula is short.
2. The DEIS stated that future residential housing development is a reasonably foreseeable action along Grant Creek road and lower Snowbowl Road, which would have a cumulative impact on traffic on Grant Creek Road (page 4-45). It was stated that this may contribute to the need for additional transportation infrastructure such as park-and- ride lots and mass transit. It is also stated that it is beyond the scope of this analysis to predict potential residential housing and related needs. We believe the indirect, growth inducing and land use changing effects that may be associated with the ski area expansion (and potential doubling of skier capacity) and their resultant environmental impacts, should be within the scope of the environmental impact analysis for the proposed MSB expansion in accordance with CEQ NEPA regulation 40 CFR 1508.8(b). Ski area expansions can promote and hasten additional growth and development to serve the increased numbers of skiers and service workers. Additional visiting skiers require transportation, improved road access, increased wastewater treatment, water supply, restaurants, hotels, service workers, and places for those service workers to live. Often the 7 indirect, growth inducing impacts of ski areas, and the infrastructure, growth and development sprouting nearby to serve the ski area causes greater environmental impacts/concerns than the direct impacts of the ski area expansion itself. We recommend that the FEIS identify and discuss indirect effects or induced growth or development changes or at least make a good faith effort to explain the effects that are "reasonably foreseeable." How much developable private land lies within easy commuting distance of MSB? Are there environmentally sensitive areas such as riparian areas and wetlands or other important wildlife habitat within reasonable proximity to MSB that may be developed as an indirect response to MSB expansion and increased skier use? Will induced growth and land use change have an effect on air, water, and other natural systems and/or environmentally sensitive areas near the ski area? We recognize that future land uses near the ski area may not be precisely known, but it may be possible to consider likely land uses and development trends in the area and estimate and disclose the likelihood that undeveloped land near the ski area will be developed as an indirect result of the ski area expansion. Also, the consistency of the proposed MSB expansion with Missoula County Land Use Plans should be disclosed. Respondent: 39
Response to comment: See response to comment #2 above in Section 5.2.16, Land Use.
Final EIS 5-48 Montana Snowbowl Chapter 5 Response to Comments
5.2.17 NEPA Compliance and Adequacy
1. It must therefore be assumed that private- and self-interests have aggrandized to supersede scientific findings. This would not be the first instance of USFS personnel acting against science; yet, it would result in another misallocation of our public lands. While the USFS may be the entity responsible for protection and conservation of much of our public lands, it is often forgotten that the USFS is not the owner of these lands. Forest service lands are the lands of the people, and when science supports non-action within our forests, personal and private interests should never devalue or nullify this fact. Respondent: 21
Response to comment: The LNF analyzes all environmental effects using the best available science. Such is the case in this analysis. The effects of two alternatives: No Action and the Proposed Action in this analysis. If the Decision-maker, in this case Lolo NF Supervisor Debbie Austin, determines that the effects of implementing the Proposed Action are not acceptable, she may chose the No Action Alternative in which case the MSB Ski area expansion would not occur.
2. Based on the procedures EPA uses to evaluate the adequacy of the information and the potential environmental impacts of the proposed action and alternatives in an EIS, the DEIS has been rated as Category EC-2 (Environmental Concerns - Insufficient Information) [further detail provided below] due to concerns regarding potential effects to fisheries and aquatic life from increased dewatering of Butler Creek, and insufficient evaluation and disclosure of potential indirect, growth inducing effects of ski area expansion on nearby environmentally sensitive areas. We recommend additional analysis and information to fully assess and mitigate all potential impacts of the management actions.
U.S. Environmental Protection Agency Rating System for Draft Environmental Impact Statements Definitions and Follow-Up Action* Environmental Impact of the Action LO - - Lack of Objections: The Environmental Protection Agency (EPA) review has not identified any potential environmental impacts requiring substantive changes to the proposal. The review may have disclosed opportunities for application of mitigation measures that could be accomplished with no more than minor changes to the proposal. EC - - Environmental Concerns: The EPA review has identified environmental impacts that should be avoided in order to fully protect the environment. Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce these impacts...Category 2 - - Insufficient Information: The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternatives that are within the spectrum of alternatives analyzed in the draft EIS, which could reduce the environmental impacts of the action. The identified additional information, data, analyses or discussion should be included in the final EIS. Respondent: 39
Response to comment: Noted. Insufficiencies as identified by the EPA and other comments were rectified and the changes between the DEIS and FEIS are provided as Appendix F in the FEIS.
Final EIS 5-49 Montana Snowbowl