PRELIMINARY ENVIRONMENTAL REVIEW:

CANYONS-SOLITUDE SKI LINK

Cirrus Ecological Solutions, LC1 September 9, 2010

INTRODUCTION In late June 2010, Mike Goar, managing director of The Canyons Resort (Canyons), engaged Cirrus Ecological Solutions, LC (Cirrus) to complete a preliminary review of environmental constraints associated with a proposed ski link between Canyons and (Solitude), focusing specifically on three resource areas: special-status plant and wildlife species, water quality and watershed resources, and visual resources. This report summarizes our preliminary findings, based on initial document review, a site visit, and our professional experience.

The following discussion of each of the three resource areas begins with an overview of the regulatory context for each resource area. This is followed by key points emerging from our site-specific review. Each of the three sections concludes with a brief summary of the project-permitting implications of our review.

Note that the confidentiality agreement Cirrus signed prior to being engaged in this review limited our access to existing information to readily available, public sources. Accessing other sources, such as agency databases on the locations of raptor nests, rare plants, or other sensitive resources, would have required breaching the agreement.

SPECIAL-STATUS SPECIES Special-status species that may occur in or near the project area that could constrain the project include the following: 1. Federally-listed threatened, endangered, or candidate species. 2. Forest Service sensitive species. 3. Forest Service “Watch List” species (plants). 4. State of listed sensitive species (primarily wildlife). 5. Species protected under the Migratory Bird Treaty Act, including neo-tropical migrant birds. 6. Other raptors.

The Endangered Species Act of 1973 provides for listing and subsequent protection of threatened, endangered, and candidate species. Enforced by the U.S. Fish and Wildlife Service, it is typically the most influential legislation addressing special-status species. The U.S. Fish and Wildlife Service also

1 Cirrus Ecological Solutions, L.C. (Cirrus) is a Logan, Utah, based consulting firm providing a wide range of natural resource and environmental planning and permitting services for the past 12 years. These include comprehensive environmental compliance assistance, environmental impact assessment, biological inventory and analysis, physical resource inventory and analysis, natural resource management and planning, and GIS services. Working with the U.S. Forest Service and other land management and regulatory agencies, Cirrus has completed more than 40 major ski area permitting projects nationwide.

1 enforces the Migratory Bird Treaty Act. Both specify objectives and procedures that other entities, including the Forest Service, must conform with, including consultation if adverse impacts are anticipated. Consultation can be a time consuming process and can result in significant alteration or rejection of a project. Forest Service regulations provide for impact assessment and protection of rare species to avoid federal listing (Forest Service sensitive species), and on the Uinta-Wasatch-Cache National Forest (UWCNF) “watch list” species are also monitored to determine if more formal protection is needed. Utah regulations provide some protection for State-listed sensitive species, though procedures are less formal and less frequently invoked. In general, all these regulations call for regulatory and land management agencies to assess impacts on special-status species, to consider such impacts in their decision making, and to avoid any substantial, adverse impact.

A field review of the Canyons-Solitude Ski link project area to assess special-status species was conducted in July 2010, and consisted of walking the potential lift and egress trail alignments that were under consideration at that time. The field review focused on the habitats that occur in the project area as well as special-status species that are or may be present. Our initial findings include the following:

• The major habitat types that occur in the project area include the following: o Aspen-forb o Spruce-fir o Mountain shrub o Limber pine/montane rocky ridge top/short forb

• General assessment of special-status plant habitat: The habitats inspected appear to represent a low potential for occurrence:

o No potential habitat for federally listed plant species was found.

o Rocky outcrops and ridges represent potential habitat for several species on the Forest Service sensitive and watch list species list. In the project area, rocky outcrops are limited to the ridge top, which occurs at elevations of 9,800 to 10,000 feet. The ridge is dry and vegetated principally with low-statured species. It did not represent likely habitat, and no target species were located during the field review.

o No stream or wetland habitat was noted along the disturbance corridors (except for ), so target species associated with wetland or riparian habitats were not expected. None were found during the field review.

o The spruce-fir habitat was dense, often steep, with little understory. Based on the field review, this habitat type does not represent suitable habitat for sensitive or watch list species associated with some forested habitat types. No such species were found during the field review.

o Sensitive or watch list species are not anticipated in the aspen-forb habitat that occurs in the project area, and none were found during the field review.

o Mountain shrub habitat occurred in opening in the aspen-forb habitat and on the upper slopes in the Willow Heights basin. Sensitive or watch list species are not anticipated in the mountain shrub habitat that occurs in the project area, and none were found during the field review.

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• General Assessment of TES wildlife habitat: The project area represents suitable habitat for a number of wildlife species, including Forest Service sensitive species and other species of interest.

o While potential habitat for the federally listed gray wolf and Canada lynx occurs, the project area is outside what is considered to be occupied by these species. As a result, their low potential for occurrence generally precludes any concern.

o The area may potentially by used by Forest Service sensitive species, such as northern goshawk, three-toed woodpecker, and flammulated owl, for nesting and/or hunting habitat. These species were not observed during the field review. The Solitude FEIS (USDA Forest Service 2001) reported: a pair of northern goshawks nesting in the upper portion of Big Cottonwood Canyon between Brighton and Solitude; positive sightings of three-toed woodpeckers at Solitude; and audio detection of flammulated owls in upper Mill F South Fork. This area is outside the potential disturbance corridors, but additional surveys following approved protocols will be required to assess the current presence of these and other sensitive species in the project area.

o Elk and deer utilize the habitats in the project area. In particular, the aspen forest above Big Cottonwood Canyon appears to be used by elk and deer in the early spring and likely represents elk calving and deer fawning habitat. Such habitat is not limiting for these species in Big Cottonwood Canyon.

o Clearing for a lift corridor or trail would result in some fragmentation of contiguous blocks of forested habitat. For species that require contiguous habitat, these impacts would represent a decrease in habitat value. The potentially affected habitats are not unique in the canyon.

o The habitats in the project area represent habitat for neo-tropical migrant birds and other species protected under the Migratory Bird Treaty Act. Fragmentation of the habitat would likely adversely affect the habitat values for some of these species.

o Red-tail hawks were observed in the project area during the field review, using the area for hunting and possibly nesting. No nests were observed, but more intensive surveys would be required to definitively determine if they occurred in the area.

Based on this review, no significant special-status plant or wildlife issues were noted in the project area. The fact that no federally listed species or critical habitat would be affected is the most important conclusion. However, the field review did not constitute a detailed survey for other special-status species, particularly any that require specific survey protocols. If more comprehensive surveys in the future locate a special-status species, the effect on the project would depend on the nature of the regulations associated with that species. Generally, the type of wildlife or plant issues that might be encountered in this project area could be addressed through disclosure and mitigation (e.g., alteration of lift or egress trail alignments or limits on the timing of construction), and therefore would be unlikely to cause major delays or preclude project permitting.

WATER QUALITY AND WATERSHED RESOURCES Water and watershed resources that could constrain the project if they occurred in or near the project area include the following:

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1. Municipal watersheds and regulations that govern development in these areas. 2. Surface water features including streams, canals, lakes, ponds, and springs. 3. Floodplains or riparian corridors surrounding surface water features. 4. Impaired waterbodies identified on the Utah 303(d) list located in or immediately downstream of proposed developments. 5. Groundwater wells and source water protection plans. 6. Wild and scenic rivers. 7. Wetlands. 8. Areas with seasonally high groundwater. 9. Land areas characterized as highly unstable or erosive. Review of potential disturbance corridors included identification of municipal, state, and federal documentation prescribing management practices of water and soil resources in the project area and a field visit on July 14, 2010, to identify any features susceptible to development impacts.

The major concern is that the project area falls in ’s municipal watershed. Historic legislation gave the City jurisdiction over private lands outside the incorporated area in the watershed. The Salt Lake City Watershed Management Plan (Salt Lake City 1999), includes measures to achieve and maintain high water quality. The City’s Department of Public Utilities is most involved in its enforcement, but the Plan is generally respected, and in some cases formally enforced, by other regulatory and land management agencies with jurisdiction over development within the municipal watershed. The Plan states (p. 3, emphasis added):

The management emphasis prioritizes water quality first and multiple use of the watershed second. The Wasatch Canyons are protected to maintain a healthy ecological balance with stable environmental conditions, healthy streams and riparian areas, and minimal sources of pollution. Existing and potential uses that could lead to the deterioration of water quality are limited, mitigated, or eliminated. To the extent that, in the reasonable judgment of the City, a proposed development or activity, either individually or collectively, poses an actual or potential impact to the watershed or water quality, Salt Lake City will either oppose, or seek to modify, manage, control, regulate or otherwise influence such proposed development or activity so as to eliminate or mitigate potential impacts.

All jurisdictional agencies involved in monitoring and permitting development in the watershed are equally aware of and involved in the development proposal process. Enforcement of existing “suitability criteria” such as slopes and setbacks, is a priority for all jurisdictions. Variance applications are reviewed carefully to ensure water quality is not impacted. Jurisdictional agencies will share the same vision for the watershed, which includes understanding and implementing watershed management objectives.

City concerns over the proposed ski link would be primarily focused on water quality impacts, including potential E.coli and sediment contributions to stream channels. The proposed ski link does not appear to have the potential for this type of impact based on water quality records. Ski area development has taken place in Big Cottonwood Canyon since 1936 when Brighton was established, and a notable increase occurred in 1977 when Solitude was rebuilt and reopened. Through this period, monitoring of Big Cottonwood Creek at the Forest boundary indicates that water quality has remained stable, in support of

4 applicable standards, since the mid-1970s and the inception of the Clean Water Act. More detailed discussion of specific water quality parameters follows.

Coliform bacteria contamination, and specifically E. coli, is a primary concern for the City in the municipal watershed. The Utah Division of Water quality, the main source of water quality data on Big Cottonwood Creek, has no data available on E. coli. The City has routinely collected E. coli measurements but does not make them available without specific identification of the purpose for which the data is requested. In order to obtain this data, Canyons would need to disclose their ski link proposal to the City. Therefore, publicly available data on other forms of coliform bacteria were used in this analysis.

Fecal Coliform Big Cottonwood Creek at USFS Boundary

(1976 - 1993) 10000

1000 Numeric Criteria = 400 col./100 ml

100

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Fecal Colliform (col./100 ml) Samples with non-detectable concentrations 0.1 1976 1979 1982 1984 1987 1990 1993 1995 Year

Total Suspended Solids (TSS) Big Cottonwood Creek at USFS Boundary (1976 - 2007) 1000

Pollution Indicator = 90 mg/L 100

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Total Suspended Solids (mg/L) Samples with non-detectable concentrations 5 0.1 1983 1986 1988 1991 1994 1997 1999 2002 2005 2008 2010 Year

Figure 1. Division of Water Quality data collected from Big Cottonwood Creek at the Forest boundary. Source: EPA-STORET database at http://www.epa.gov/storet/ Downloaded August 2010.

Measurements of fecal coliform (a more general form of coliform and a less conclusive marker of human waste than E. coli) are presented in Figure 1 and show that few samples have exceeded the standard of 400 colonies/100 ml over time, and if anything the trend is improving. Note, however, that the period of record is not complete over the past 30 years and includes no measurements after 1993.

Additional measurements of total and fecal coliform collected by Salt Lake City from 1989 through1996 at various locations on Big Cottonwood Creek are shown in Table 1. These values indicate a general decrease in coliform concentrations between upper stream sites and the Forest boundary during most years. In some years (e.g. 1995) little change was observed between upstream and downstream sites. During all years, however, the mean fecal coliform count was well below the 400 colonies/100 ml threshold.

Significant ski resort developments were already in place in Big Cottonwood Canyon during the period of record covered by fecal coliform measurements, so any associated impact is reflected in these records. Although the number of skier visits to Big Cottonwood Canyon has increased since 1995, fecal coliform levels have shown no parallel trend, presumably due to sewage removal by the Big Cottonwood Creek sewer line.

Some concern has been raised in the past over unauthorized and dispersed impacts from human waste generated by resort skiers. Other ski area environmental reviews in the watershed (e.g., master plan EISs for Brighton, Solitude, Alta, and Snowbird) have successfully dismissed impacts of this type as insignificant, generally by documenting adequate sanitation facilities.

Table 1. Average coliform counts in Big Cottonwood Canyon measured from 1989-1996. Sites begin at most downstream location and move upstream above Brighton Ski Resort. Source: Appendix D - Solitude Final EIS (2001). Data provided by Salt Lake City Department of Public Utilities Water Resources Department (6/2/1997). FS Jordan Silver Brighton Site Solitude 1st Bridge 2nd Bridge Boundary Pines Fork Loop Date TC FC TC FC TC FC TC FC TC FC TC FC TC FC 1989 27 5 36 10 56 21 138 27 66 22 n/a n/a n/a n/a 1990 29 11 29 17 69 45 50 19 74 46 85 48 16 6 1991 8 14 34 17 34 17 56 20 97 53 17 12 8 3 1992 34 29 53 40 52 46 62 68 90 75 28 28 27 21 1993 12 4 16 6 16 8 20 8 22 7 19 6 30 27 1994 31 6 23 5 16 2 78 2 34 2 38 9 44 16 1995 79 8 71 8 79 9 74 8 58 9 65 3 75 4 1996 73 6 156 42 129 41 124 55 125 15 45 5 48 7 TC = Total Coliform FC = Fecal Coliform

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Measurements of Total Suspended Solids (TSS) are also shown in Figure 1. The period of record is fairly complete from 1983 through 2007. Several items are noteworthy including (1) few values exceed the 90 mg/L threshold that has been used in the past by DWQ to indicate a harmful level of TSS, (2) measurable TSS concentrations are relatively consistent over time, and (3) the number of samples with non-detectable concentrations of TSS (shown as 0.1 mg/L concentration) are substantial over the period of record. Each of these facts indicate that water quality in Big Cottonwood Canyon has remained high over time in spite of ski area development. This result is likely due to successful application and maintenance of best management practices (BMPs) by ski resorts and others responsible for development in Big Cottonwood Canyon (discussed further below).

Salt Lake County, through the Planning and Development Services Division, has jurisdiction over private lands in the watershed, primarily via the zoning stipulations and restrictions in the Foothills and Canyons Overlay Zone Ordinance (FCOZ). The FCOZ was adopted in 1998 to protect visual and aesthetic qualities as well as reduce risk to development from natural hazards. In regard to watershed resources, FCOZ protects against degradation of water quality, soil productivity, slope stability, aquifer recharge areas, and other environmentally sensitive areas. Developers must apply for and receive from the County either a conditional use permit, demonstrating compliance with the FCOZ, or a variance allowing for noncompliance.

In regard to this project, FCOZ ordinances may generate concerns over sediment delivery to streams following soil surface disturbance or erosion from barren slopes. The roughly 500 feet of egress trail located in the north half of Section 23 (and above 9,000 feet elevation) was a potential concern. The trail approaches to within 150 feet of an intermittent headwater stream channel indicated on USGS topographic maps. However, this area was assessed during our field visit, and no water or indication of water (i.e., channel features) were identified in the area indicated by the map.

Topsoil depths are typically shallow at high elevations in montane settings and would make revegetation difficult but attainable in most areas. BMPs for project design, construction, and site rehabilitation that have been successfully used by Canyons to mitigate these types of impacts would likely need to be provided during the application process for development within FCOZ areas.

Most of the project area is on public land within the UWCNF. As a result, the ski link would require a special use permit, the issuance of which would be subject to review under the National Environmental Policy Act of 1969 (NEPA) and Forest Service regulations regarding its implementation.

Management of watershed resources on the Wasatch Cache National Forest is outlined in the 2003 Revised Forest Plan and Final Environmental Impact Statement (Forest Plan). The project area falls within the Central Wasatch Management Area as defined in the Forest Plan. General concerns defined for this management area include human influences from recreation, homes, historic mining, hydropower, and roads. Specific water and soil resource concerns identified in the Forest Plan that may be potentially related to the proposed ski link include “development on public and private land in riparian areas and vegetation changes associated with ski runs.” Soil productivity and water quality are specific issues from the FEIS that may be concerns with the proposed ski link.

In past Forest Service NEPA processes addressing master development plans or specific projects proposed by ski areas in the municipal watershed, these impacts have been thoroughly analyzed, in recognition of the importance of the watershed. Most of these analyses have resulted in detailed mitigation requirements to protect soil productivity and water quality. Reflecting City and County input, these requirements have typically included preparation of erosion control and stormwater pollution

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protection plans (SWPPPs) for each project, which have in turn involved implementation of a wide array of BMPs to avoid or minimize erosion and adverse impacts on water quality. With these mitigation measures in place, impacts on soil and water resources have rarely resulted in projects not being approved, but many relatively minor revisions to project design and timing have been driven by such impacts.

Based on a review of soil surveys prepared by the Natural Resource Conservation Service (NRCS) for Salt Lake County and Summit County, soil characteristics in the ski link project area are typical for the Wasatch Mountains, including areas developed as ski resorts. Table 2 provides a description of specific characteristics of soils located in the project area. These characteristics are summarized by family- complex, which is defined as a group of soil families with similar properties. Most soil textures in these groups are loams with varying amounts of gravel and cobble. The depth to a restrictive layer represents the typical depth of an impermeable layer (i.e., hardpan or bedrock). If no values are shown, no restrictive layer is typically found within the upper 60 inches of the soil profile. All groups shown in Table 2 are comprised of large cobbles (> 12 inches) at 60 inches with the exception of the Starley and Crandall families which have restrictive layers at shallow depths.

Soil tolerance (T) is defined in tons/acre-year and represents a threshold beyond which soil loss exceeds soil production over an extended period. Soil erosion is commonly estimated with the Universal Soil Loss Equation (USLE) or the Revised USLE (RUSLE). Several factors are used as input variables to these equations to calculate an annual average soil loss from sheet and rill erosion in tons/acre-year. Soil properties such as the percent composition of sand, silt, organic matter, soil structure, and soil permeability are used to define these factors. Erosion factor K indicates how susceptible soils are to erosion by water, with higher K factors indicating greater susceptibility to erosion.

The most important information in Table 2 in terms of this review is the Erodability Factor; Kf indicates susceptibility to erosion of the fine-earth fraction, or material less than 2 millimeters. Kf values can potentially range from 0 – 0.69. The Kf values shown in Table 2, for soils in the ski link project area, generally fall in the lower third of this range, indicating a manageable level of erosion hazard. These values are typical for soils located throughout the Central Wasatch Mountains, where ski area development has occurred without notable adverse water quality impact.

Table 2. Representative soil profile characteristics for family-complex groups found in the ski link project area. Depth to Map Unit Family-complex Soil Tolerance - T Erodability restrictive layer ID Name Texture range (tons/year) Factor – Kf (in.) Crandall-Lucky Star- Gravelly loam to 10-20 (Starley Starley family very cobbly loam family) 113 1-5 0.24 – 0.43 complex, 30 to 70 or bedrock 40-60 (Crandall percent slopes family) Dromedary-Rock Gravelly loam to 118 outcrop complex, 30 very cobbly sandy - 5 0.24 to 70 percent slopes clay loam Park City-Dromedary Gravelly loam to 159 gravelly loams, 15 to very cobbly loam - 5 0.20 – 0.37 30 percent slopes Park City-Dromedary Gravelly loam to 160 gravelly loams, 30 to very cobbly sandy - 5 0.20 – 0.37 70 percent slopes clay loam

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Both the Canyons and Solitude have dealt with soil stability and water quality aspects of project planning, permitting, and implementation. A review of the 2001 Solitude master plan EIS, 1999 Brighton master plan EIS, and a 2007 Stormwater Pollution Prevention Plan (SWPPP) prepared for Canyons indicates these aspects have been dealt with successfully in the past. They reflect standard BMPs and procedures for erosion control (e.g., construction timing, use of water bars, topsoil segregation, and prompt revegetation) and stormwater pollution prevention (e.g., runoff barriers, settling basins, approved fueling practices, and spill plans) during and after construction activities that have proven effective in preventing soil erosion and potential impacts on water quality. As a result, these concerns should only be major constraints to the ski link project if there were other environmental issues from the list above involved, which would heighten municipal watershed concerns. As discussed below, there generally no other compounding water quality or watershed issues in the project area.

In regard to the second potential constraint, surface water features including streams, canals, lakes, ponds, and springs, Big Cottonwood Creek is the only notable feature. The skier crossing would have to be designed in such a way as to avoid any impact on the stream channel, to not impede high flows (likely 100-year flows), to not contribute sediment or other contaminants to the stream, and, as discussed below, to not impair floodplain or riparian functions.

Beyond Big Cottonwood Creek, our GIS review of surface water bodies identified several first-order streams in the vicinity of the potential disturbance corridors. As noted above, one of the potential egress trails is located within 150 feet of an intermittent stream channel defined in GIS stream layers as well as on USGS topographic maps. This area was examined during our field visit, and no evidence of water or a defined channel was found. As a result, no surface water features would be affected by the project as currently proposed.

In terms of floodplains or riparian corridors surrounding surface water features, Big Cottonwood Creek is again the main concern. As noted, the skier crossing would have to address floodplain and riparian concerns as well as issues associated with water quality and the channel itself. Any structures associated with the crossing would need to meet setback requirements (at least 50 feet; more likely 100 feet), and other mitigation to protect riparian resources and floodplain functions could come into play. The Forest Service would undoubtedly incorporate County and City concerns regarding the crossing in developing their requirements for design features and mitigation. It is impossible to foresee exactly what these might be, but this feature will be scrutinized more closely than other aspects of the project. No other floodplain or riparian issues were identified.

The next potential constraint is impaired waterbodies identified on the Utah 303(d) list located in or immediately downstream of proposed developments. The lower portion of Big Cottonwood Creek (below the water treatment plant) is included on the 303(d) list as temperature impaired. In that it would not affect flow, the proposed ski link would not impact this listing. Beyond that, the State, County, and City are all becoming more concerned about rising coliform bacteria levels in streams, and Emigration Creek is currently listed for pathogens (E. coli). As noted above, the proposed ski link should realistically have no impact on E. coli levels in the creek. While this issue may be raised, it should pose no constraint to the project.

In regard to groundwater wells and source water protection plans, none have been identified in the project area. The typical method for identifying source water protection plans starts with submitting an application to the Utah Division of Drinking Water, which would require disclosure of Canyon’s proposed ski link. Therefore, an indirect route to identify culinary groundwater production wells was used for this review. We queried two public databases maintained by Utah Division of Water Rights

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(WELLVIEW Well Information Program and WRPRINT Water Right Info Viewer) and the National Water Information System database (NWIS) maintained by the USGS. Each of these sources is generally considered accurate and reliable for hydrological surveys of surface and groundwater resources. This review indicated diversions of surface water for culinary use from Big Cottonwood Creek in the upper canyon area, but no groundwater production wells were identified in the project area.

If there were any culinary wells in the project area, the associated protection plan to maintain surface water quality would be similar to guidelines stipulated by Salt Lake City for municipal watersheds. With the use of appropriate BMPs, it is unlikely that development of the proposed ski link would violate these guidelines.

Another possible water quality concern is the potential for contaminating surface or groundwater with fuel or hydraulic fluid used by construction equipment or other hazardous substances. This issue is typically raised in environmental reviews of ski area development in Big Cottonwood Canyon and elsewhere. Spill Prevention and Response Plans are typically required to meet federal agency regulations, and they include guidelines that reduce the potential for spills as well as mitigation measures should a spill occur. Many of these requirements are familiar to Canyons and previously used in SWPPP documentation. A review of EISs completed for Brighton and Solitude master plans identified some concerns regarding hydrocarbon spills and water quality impacts from parking lot runoff. These concerns were also addressed with common BMPs defining appropriate methods for transporting, storing, and handling fluids in construction areas.

No Wild and Scenic River designations would be affected by the project. No wetlands outside the Big Cottonwood Creek riparian zone were identified, and those are discussed above. No areas with seasonally high groundwater were identified.

In regard to land areas characterized as highly unstable or erosive, this is a concern in nearly any ski area situation. Steep slopes and shallow soils equate to stability issues associated with difficult site rehabilitation and other problems, and this project area would be no different. While this is a potential issue, it is not outside the norm for ski areas and should only be adequately addressed through the standard types of mitigation discussed above.

The BMPs included in a SWPPP used by Canyons for clearing and grading ski runs within the ski area boundary were reviewed for this analysis. These measures to control stormwater runoff and surface erosion are similar in nature to those required by the Forest Service at Brighton and Solitude ski resorts and viewed as successful over time. Prior to submitting a formal project proposal for the ski link, Canyons could expect to complete site-specific development plans to more clearly define slope lengths, gradients, and other physical characteristics of the project area and meet established county, state, and federal standards for BMP design.

Overall, these water quality and watershed resources issues are within the bounds typically encountered in ski area projects on the Wasatch Front.

VISUAL RESOURCES The potential “red flag” issue here is the visual impact of the proposed ski link, particularly the lift and egress trail corridors, the lifts themselves, and the skier crossing of SR 190 and Big Cottonwood Creek.

Visual resource concerns on National Forest System lands are managed in accordance with the Forest Service’s Scenery Management System (SMS) and associated management direction in the Forest Plan. The Forest Plan also designates SR 190 as a Scenic Byway. Private land visual concerns generally fall

10 under the regulatory auspices of Salt Lake County’s FCOZ. Both would come to bear on the proposed ski link.

The SMS and Forest Plan direction are most important for the proposed ski link. The Forest establishes a Landscape Character Theme (LCT) for the project area of “Natural Appearing” and a Scenic Integrity Objective (SIO) of “High.” This combination is described as follows:

Landscapes where the valued landscape character “appears” intact. Deviations may be present but must repeat the form, line, color, texture, and pattern common to the landscape character so completely, and at such a scale, that they are not evident.

If the same LCT and SIO were maintained for the project area under an accepted ski link proposal, clearings for lift and egress trail corridors would have to be completed to mimic natural features, the lifts may have to be screened by vegetation or topography, and the skier crossing would have to “complement the surrounding landscape.” This could probably be done but would require additional effort to design and build the project. It’s possible that the skier crossing would be considered part of Solitude’s base area, where the LCT of “Resort Natural Setting” would allow more leeway in its design and construction. Then only the upper-mountain infrastructure would be held to the stricter visual standards.

In regard to the FCOZ, which would apply directly to private land in the project area and be considered by the Forest Service in analysis and decisions regarding public land, there are potentially applicable provisions regarding construction on steep slopes and ridgelines. The following direction is most relevant (Section 19.72.030, B, 3, a):

With the exception of permitted, minor, ski area improvements, which may cross but not follow designated ridgelines, and with the further exception of instances where a waiver has been granted pursuant to this chapter, no development shall intrude into any ridge line protection area that has been identified and designated as part of an adopted county or township plan…or has been identified and designated by the county during the development review and approval process set forth in Section 19.72.050 of this chapter.

The paragraph that follows goes on to define designated ridgelines in a manner that makes it likely that the northern ridgeline of Big Cottonwood Canyon that would be crossed by the ski link lift system would qualify. The obvious saving grace here is the exception provided for “permitted, minor, ski area improvements” which should apply if the Forest Service approved the project.

Another consideration in terms of visual impact involves the proposed wilderness. While the current lift and trail alignments are outside the proposed wilderness boundary, visual and other types of disturbance adjacent to wilderness boundaries have been raised as an issue numerous times in the past. The conclusion has generally been that wilderness designation, and particularly proposed designation, does not dictate management of adjacent lands. Having said that, the Forest Service might still question whether approval of the proposed facilities might alter the area’s “wilderness character” assessment and thus its prospects for designation.

Overall, visual impact is an issue that could impact permitting of the proposed ski link. This is not so much because of the importance (or lack thereof) of the visual impact itself but because of associated factors: it takes more effort and resources to mitigate than many other types of impact, it is potentially inconsistent with current Forest Plan management direction (LCT and SIO, discussed above), and it has a remote chance of affecting the wilderness discussion. The actual impact would be minor, and there are probably ways to work through the associated issues. But for people looking for reasons not to accept the

11 proposal, visual impact provides one – not sufficient on its own, but another challenge to deal with positively.

CONCLUSIONS This review has not identified any “show stopper” types of environmental issues in the areas of special status species, water quality and watershed resources, or visual resources. Based on the cited regulatory considerations, the resources present in the project area, and the nature of the proposal, it appears that any potential impacts would be minor and that most would be mitigable – nothing unusual for ski area infrastructure proposals that are routinely approved.

For this project, the initial hurdle will be getting the Forest Service to accept the proposal, a decision which may be affected by a number of factors, including the wilderness proposal currently being considered by Congress and its long-term implications for interconnections among Wasatch Front ski areas. In light of these factors, the potential impacts outlined above, particularly the municipal watershed and visual impact issues, may cast a larger shadow than they normally would. Based on this initial review, special status species do not pose a constraint, and once the application was accepted, the potential watershed and visual impacts would be relatively straightforward to deal with.

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